&EPA
United States
Environmental Protection
Agency
February 2002
EPA 260-B-02-001
Toxic Chemical Release Inventory
Reporting Forms and Instructions
Revised 2001 Version
Section 313
of the Emergency Planning and
Community Right-to-Know Act
(Title III of the Superfund Amendments
and Reauthorization Act of 1986)
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WHERE TO SEND REPORTS
REGULAR, CERTIFIED MAIL, OVERNIGHT
OR HAND DELIVERED
(SECTION A.7 (PAGES 5-7))
FOR TRI-ME OR ATRS SOFTWARE SUPPORT CALL:
TRI Software Support Hotline
(877) 470-4830; fax: (703) 292-6389
OR
Email: tri software support@sdc.com
Hours of Operation:
8:00 AM to 7:00 PM E.T.
For questions regarding Form R or Form A call:
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW CALL CENTER
(800) 424-9346 OR (703) 412-9810
TDD (800) 553-7672 OR TDD (703) 412-3323
http://www.epa.gov/epao swer/hotline/
HOURS OF OPERATION:
9:00 AM TO 5:00 PM E.T.
Closed Federal Holidays
HOW TO OBTAIN FORMS
AND OTHER
INFORMATION
(SECTION A.8 (PAGE 7))
Please send either: (1) one copy of each
Form R or Form A, or (2) an ATRS 2001 or
TRI-ME diskette to EPA at the
appropriate address listed in Section A.7
(PAGE 5-7) and a diskette or hard copy of
each to your state. Be aware that not all
states accept versions of the Forms on
diskette. Do not send a copy to your EPA
Regional Office
STATE DESIGNATED
SECTION 313 CONTACTS
(APPENDIX F)
SECTION 313 EPA REGIONAL
CONTACTS
(APPENDIX G)
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Important Information for Reporting Year 2001
The following information updates or corrects the Reporting Forms and Instructions for Reporting Year 2001 as well as highlights
new resources developed by EPA.
All references to reporting year 2000 and all other date related references have been changed to reflect the current reporting
year(i.e., reporting year 2000 has been changed to reporting year 2001; prioryear 1999 was changed to prioryear2000, etc.).
This change was made for the Form R, Form A, and the instructions.
Starting with reporting year 2001, lead and lead compounds are classified as persistent, bioaccumulative and toxic (PBT)
chemicals. The reporting thresholds for lead and lead compounds, except lead contained in stainless steel, brass or bronze
alloys, have been lowered to 100 pounds. For specific guidance on the reporting of lead, see page 16.
The EPCRA section 313 Chemical List (Table II) has been updated to reflect that the de minimis exemption is not applicable
for lead and lead compounds, except for supplier notification purposes and except for lead when it is contained in stainless
steel, brass or bronze alloys (see Appendix D).
The de minimis level for the following chemicals have been changed from 0.1% to 1.0%: dimethylformamide and saccharin.
The de minimis level for the following chemicals have been changed from 1.0% to 0.1%: 1,2-butylene oxide, catechol,
chloroprene, chlorothalonil, C.I. Solvent Yellow 3, dichlorobromomethane, ethyl benzene, alpha-hexachlorocyclohexane, and
hexachloroethane.
The qualifier for isopropyl alcohol has been changed to match exactly the qualifier that is listed in the Code of Federal
Regulations, the new qualifier is "Only persons who manufacture by the strong acid process are subject, no supplier
notification." EPA believes that use of this qualifier will make it clearer that only facilities that manufacture isopropyl alcohol
by the strong acid process are subject to reporting (i.e., processors and users of isopropyl alcohol are not subject to reporting).
Table II, which lists all EPCRA section 313 chemicals and chemical categories with their respective de minimis limits, has
been updated.
For a list of all EPCRA section 313 delisted chemicals, visit the TRI Home page (www.epa.gov/tri).
Starting with reporting year 2000, new chemical activity threshold levels are set for persistent, bioaccumulative and toxic
(PBT) chemicals and chemical categories (Section B.4.e).
For PBT chemicals (except lead when it is contained in stainless steel, brass or bronze alloy) and chemical categories, the de
minimis exemption, Form A, and range reporting are not allowed (Section B.4.e).
The reverse side of the pages of the Form R and Form A include a box stating, "This page intentionally left blank." Please
do not copy double-sided.
Appendix A contains reporting instructions specific to Federal facilities that are required to report under Executive Order
13148. Further guidance for Federal facilities may be obtained from the EPCRA Call Center at (800) 424-9346, or (703) 412-
9810.
Appendix C, "Common Errors in Completing Form R Reports and Making Data Available" has been updated.
The State and Regional contact lists have been updated (Appendices F and G).
The Alternate Threshold provides eligible facilities with the option of submitting a simplified Form A instead of the full Form
R report for non-PBT chemicals and chemical categories.
A list of EPCRA section 313 industry-specific and chemical-specific guidance documents and information on ordering these
documents free of charge is provided on page ix.
Toxics Release Inventory Reporting Forms and Instructions for RY2001
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Important Information for Reporting Year 2001
This year's Reporting Forms and Instructions guidance document does not include a pre-printed Form R page 1. The Agency
has discontinued preparing these pre-printed forms since less than 6% of the facilities reporting last year used the forms.
Further, the Agency strongly encourages facilities to submit over the Internet or on floppy diskettes using TRI-ME or ATRS
reporting software. Facilities can still load (import) into TRI-ME and ATRS some of their data from the prior years.
The following information identifies changes to the TRI Reporting Software.
Included in this reporting package is a compact disk (CD) that contains several industry-specific and chemical-specific
regulatory guidance documents, including documents specific to the newly added industry groups, the EPCRA Section 313
Questions and Answers-book, ATRS2001 and TRI-ME (Windows 95,98 and NT; Windows 2000 compatible) and ATRS and
TRI-ME supporting documentation. These documents also are available via the Internet at http://www.epa.gov/tri.
Remarks specific to ATRS and TRI-ME have been added to the instructions manual. These are denoted by a 'followed by
text.
EPA has developed the TRI Assistance Library (TRIAL) which is a Windows based help utility containing key TRI policy
and guidance documents.
EPA encourages you to submit reports electronically using (via the Internet) the new TRI-ME reporting software. If you do
not choose to submit via the Internet, EPA encourages you to submit your report on diskette using either TRI-ME or ATRS.
Toxics Release Inventory Reporting Forms and Instructions for RY2001
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Toxics Release Inventory Reporting Forms and Instructions
Table of Contents
I. TRI Reporting Software v
II. Chemical and Industry Guidance ix
III. General Guidance ix
IV. Chemical-Specific Guidance x
V. Industry-Specific Guidance xi
A. General Information 1
A.I WhoMustReport 1
A.2 How to Assemble a Complete Report 1
A.2.a. The Toxic Chemical Release Reporting Form, EPA Form R 1
A.2.b. The Alternate Threshold Form A Certification Statement 1
A.3 Trade Secret Claims 2
A.4 Recordkeeping 2
A.5 How to Revise or Withdraw TRI Data 3
A.6 When the Report Must Be Submitted 5
A.7 Where to Send the Forms 5
A.7.a. How to Send Your Disks Containing Form R(s) and/or Form A(s) 5
A.7.a. 1 Labeling Your Submission Diskette 6
A.7.a.2 Submitting by Diskette to States 6
A.7.b. How to Submit Form R(s) and/or Form A(s) to EPA via the Internet (EPA's Central Data Exchange (CDX)). ... 6
A.8 How to Obtain Forms and Other Information 7
B. How to Determine if Your Facility Must Submit EPA Form R or Form A
Certification Statement 10
B.I Full-Time Employee Determination 10
B.2 Primary SIC Code Determination 10
B.2.a. Multi-Establishment Facilities 12
B.2.b. Auxiliary Facilities 13
B.2.c. Property Owners 13
B.3 Activity Determination 13
B.3.a. Definitions of "Manufacture," "Process," and "Otherwise Use" 13
B.3.b. Persistent Bioaccumulative Toxic (PBT) Chemicals and Chemical Categories Overview 15
B.3.c. Activity Exemptions 16
B.4 Threshold Determinations 22
B.4.a. How to Determine if Your Facility Has Exceeded Thresholds 23
B.4.b. Threshold Determinations for On-Site Reuse Operations 24
B.4.c. Threshold Determinations for Ammonia 24
B.4.d. Threshold Determinations for Chemical Categories 24
B.4.e Threshold Determination for Persistent Bioaccumulative Toxic (PBT) Chemicals 25
B.4.f. Mixtures and Other Trade Name Products 25
B.5 Release and Other Waste Management Determinations for Metals, Metal Category Compounds,
and Nitrate Compounds 26
C. Instructions for Completing EPA Form R 32
Part I. Facility Identification Information 32
Section 1. Reporting Year 32
Section 2. Trade Secret Information 32
2.1 Are you claiming the EPCRA section 313 chemical identified on page 2 a trade secret? 32
2.2 If "yes" in 2.1, is this copy sanitized or unsanitized? 32
Section 3. Certification 32
Section 4. Facility Identification 32
4.1 Facility Name, Location, and TRI Facility Identification Number 32
4.2 Full or Partial Facility Indication 33
Toxics Release Inventory Reporting Forms and Instructions \
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Toxics Release Inventory Reporting Forms and Instructions
Table of Contents
4.3 Technical Contact 33
4.4 Public Contact 33
4.5 Standard Industrial Classification (SIC) Code 33
4.6 Latitude and Longitude 34
4.7 Dun & Bradstreet Number 34
4.8 EPA Identification Number 34
4.9 NPDES Permit Number(s) 34
4.10 Underground Injection Well Code (UIC) Identification Number 34
Section 5. Parent Company Information 34
5.1 Name of Parent Company 35
5.2 Parent Company's Dun & Bradstreet Number 35
Part II. Chemical Specific Information 36
Section 1. EPCRA Section 313 Chemical Identity 36
1.1 CAS Number 36
1.2 EPCRA Section 313 Chemical or Chemical Category Name 36
1.3 Generic Chemical Name 37
1.4 Distribution of Each Member of the Dioxin and Dioxin-like Compounds Category 37
Section 2. Mixture Component Identity 37
2.1 Generic Chemical Name Provided by Supplier 37
Section 3. Activities and Uses of the EPCRA Section 313 Chemical at the Facility 38
3.1 Manufacture the EPCRA Section 313 Chemical 38
3.2 Process the EPCRA Section 313 Chemical (incorporative activities) 38
3.3 Otherwise Use the EPCRA Section 313 Chemical (non-incorporative activities) 39
Section 4. Maximum Amount of the EPCRA Section 313 Chemical On-site at Any Time During the Calendar Year .... 39
Section 5. Quantity of the EPCRA Section 313 Chemical Entering Each Environmental Medium On-site 40
5.1 Fugitive or Non-Point Air Emissions 41
5.2 Stack or Point Air Emissions 42
5.3 Discharges to Receiving Streams or Water Bodies 42
5.4.1 Underground Injection On-Site to Class I Wells 42
5.4.2 Underground Injection On-site to Class II-V Wells 42
5.5 Disposal to Land On-site 42
5.5.1A RCRA Subtitle C landfills 42
5.5.1B Other landfills 42
5.5.2 Land treatment/application farming 43
5.5.3 Surface impoundment 43
5.5.4 Other Disposal 43
Section 5 Column A: Total Release 43
Section 5 ColumnB: Basis of Estimate 44
Section 5 Column C: Percent From Stormwater 45
Section 6. Transfers of the EPCRA Section 313 Chemical in Wastes to Off-Site Locations 46
6.1 Discharges to Publicly Owned Treatment Works 46
6.I.A.I Total Transfers 47
6.1. A.2 Basis of Estimate 47
6.2 Transfers to Other Off-Site Locations 48
6.2a Column A: Total Transfers 50
6.2b Column B: Basis of Estimate 50
6.2c Column C: Type of Waste Management: Disposal/Treatment/Energy Recovery/Recycling ... 51
Section 7. On-Site Waste Treatment, Energy Recovery, and Recycling Methods 53
Section 7A On-Site Waste Treatment Methods and Efficiency 53
7A Column a: General Waste Stream 53
7A Column b: Waste Treatment Method(s) Sequence 53
7A Column c: Range of Influent Concentration 57
7A Column d: Waste Treatment Efficiency Estimate 57
7A Column e: Based on Operating Data? 58
Section 7B On-Site Energy Recovery Processes 58
ii Toxics Release Inventory Reporting Forms and Instructions
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Toxics Release Inventory Reporting Forms and Instructions
Table of Contents
Section 7C On-Site Recycling Processes 59
Section 8. Source Reduction and Recycling Activities 59
D. Facility Eligibility Determination for Alternate Threshold and for
Reporting on EPA Form A Certification Statement 69
D. 1 Alternate Threshold 69
D.2 What is the Form A Certification Statement? 69
D.3 What is the Total Annual Reportable Amount? 69
D.4 Recordkeeping 69
D.5 Multi-establishment Facilities 69
D.6 Trade Secrets 70
D.7 Metals and Metal Category Compounds 70
E. Instructions for Completing EPA Form A Certification Statement 71
Part I. Facility Identification Information 71
1. Reporting Year 71
2. Trade Secret Information 71
2.1 Are you claiming the EPCRA Section 313 chemical identified on page 2 trade secret? 71
2.2 If "yes" in 2.1, is this copy sanitized or unsanitized? 71
3. Certification 71
4. Facility Identification 71
4.1 Facility Name, Location, and TRI Facility Identification Number 71
4.2 Federal Facility Designation 72
4.3 Technical Contact 72
4.4 Intentionally Left Blank 72
4.5 Standard Industrial Classification (SIC) Code 72
4.6 Latitude and Longitude 73
4.7 Dun & Bradstreet Number(s) 73
4.8 EPA Identification Number(s) 73
4.9 Facility NPDES Permit Number(s) 73
4.10 Underground Injection Well Code (UIC) Identification Number(s) 73
5. Parent Company Information 73
5.1 Name of Parent Company 73
5.2 Parent Company's Dun & Bradstreet Number 73
Part II. Chemical Identification 74
1. Toxic Chemical Identity 74
1.1 CAS Number 74
1.2 EPCRA Section 313 Chemical or Chemical Category Name 74
1.3 Generic Chemical Name 75
2. Mixture Component Identity 75
2.1 Generic Chemical Name Provided by Supplier 75
Table I SIC codes 10-73 1-1
Table II EPCRA Section 313 Chemical List (including chemical categories) for Reporting Year 2000 II-l
Table III State Abbreviations III-l
Table IV Federal Information Processing Standards (FIPS) Codes IV-1
Appendix A Federal Facility Reporting Information A-l
Appendix B Reporting Codes for EPA Form R B-l
Appendix C Common Errors in Completing Form R Reports and Making Data Available C-l
Appendix D Supplier Notification Requirements D-l
Appendix E How to Determine Latitude and Longitude From Topographic Maps E-l
Toxics Release Inventory Reporting Forms and Instructions iii
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Toxics Release Inventory Reporting Forms and Instructions
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Appendix F State Designated Section 313 Contacts F-l
Appendix G Section 313 EPA Regional Contacts G-l
Appendix H Other Relevant Section 313 Materials H-l
Appendix I Sample Revision and Withdrawal Letters 1-1
Index
iv Toxics Release Inventory Reporting Forms and Instructions
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TRI Reporting Software
Toxics Releases Inventory - Made Easy (TRI-ME) Software 2001
The TRI-ME 2001 software is a new tool to help facilities in determining and completing their Emergency Planning and Community
Right-to-Know (EPCRA) section 313 (TRI) obligations. TRI-ME is an interactive, intelligent, user-friendly software tool that guides
facilities through the TRI reporting experience. By leading prospective reporters through a series of logically ordered questions,
TRI-ME streamlines the analysis needed to determine if a user must complete a Form R report or Form A certification for a particular
chemical. For those facilities required to report, the software provides the user with guidance for each data element on the reporting
forms. Additionally, this software has a one-stop guidance feature, the TRI Assistance Library (TRIAL) that allows users to do
keyword searches on the statute, regulations, and many EPCRA section 313 guidance documents. Forthe more experienced reporter,
TRI-ME allows direct data entry onto electronic versions of the Form R and A. TRI-ME will check the data for common errors and
then prepare the forms. All of the information contained in this RY2001 Reporting Forms and Instructions book is contained within
TRI-ME.
TRI-ME allows the user to submit the forms on paper, floppy disk, or electronically via an Internet connection. Facilities that used
ATRS forRY 1999 or RY 2000, can load some of this data into TRI-ME. For reporting year 2001, reporting facilities may use either
TRI-ME or ATRS. TRI-ME was distributed to approximately 6,000 facilities last year as a pilot form and many facilities that tried
TRI-ME were very pleased with it.
Automated TRI Reporting Software (ATRS) 2001
ATRS software is the electronic version of the Form R and Form A that TRI submitters can use to report their toxic chemicals
released into the land, air, water or otherwise managed as a waste. The software does check for some errors and has some built in
intelligence. For reporting year 2001, reporting facilities may use either TRI-MEor ATRS. Listed below are some features of this
year's ATRS.
Vanadium Patch
ATRS2000 required the installation of a patch for the reporting of vanadium compounds to insure that the software recognized this
category as a metal, thus allowing a submitter to use the appropriate M codes for reporting as applicable. This functionality has been
incorporated into ATRS2001 thus making the use of the patch unnecessary. If you need to revise or make a first time submission
for reporting years prior to RY 2000 for vanadium with the qualifier "fume or dust", we recommend you use ATRS99, available
at http://www.epa.gov/tri/report/atrs/atrs99.
Legacy Data Migration Problems
Some ATRS 2000 users could not migrate data from ATRS 99 due to operating system file handling nuances (primarily Windows
2000 and Windows NT). Users also had trouble reloading some data for facilities that had apostrophes in their name or street
address. These problems have been repaired to the extent possible for ATRS 2001.
Backup Function
The backup function did not operate properly for users running non-Windows 95 operating systems. This has been repaired.
PBT Chemical Rules
The PBT chemical validation logic was not disabled for users submitting pre-1999 reporting year submissions. This has been
repaired for ATRS 2001.
Toxics Release Inventory Reporting Forms and Instructions v
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TRI Reporting Software
Toxics Release Inventory Assistance Library (TRIAL)
TRIAL is a searchable, indexed file that contains the statutes, the regulations, and most of the_key guidance documents a facility
is likely to need for TRI reporting. TRIAL is a separate program, but also comes with TRI-ME and ATRS.
What are the differences between the Automated TRI Reporting Software (ATRS) and Toxics Release
Inventory - Made Easy (TRI-ME)?
EPA plans to completely transition from ATRS to TRI-ME. For reporting year (RY) 2001 (reports due July 2002), facilities may
use either TRI-ME or ATRS.
The TRI-ME software is a new tool to help facilities in determining and completing their Emergency Planning and Community
Right-to-Know (EPCRA) section 313 (TRI) Form R and As. TRI-ME is an interactive, intelligent, user-friendly software tool that
guides facilities through the TRI reporting experience. In contrast, while ATRS allows facilities to complete the Form R and As
on their personal computers, it provides much less guidance and assistance.
A full comparison of the two TRI software reporting tools is provided in the table below.
TRI Reporting Software for the Form R and A.
Comparison of TRI-ME versus ATRS for RY2001 (forms due July 2002)
Feature
Guides the user through the process of determining whether they must report based
on their SIC code and number of employees. Helps determine primary SIC code.
Guides facilities through the process of determining whether they exceed the
chemical activity thresholds for manufacture, process and otherwise use for any
TRI chemicals.
Allows users to access and search the TRI Assistance Library (TRIAL) of TRI
guidance documents
Intelligently linked to TRIAL. A user is shown particular paragraphs of guidance
that might be directly relevant to the section of the Form R they are working on.
Allows users to load or import their facility information and chemical names from
RY1999orRY2000.
Allows users to load or import their facility information and chemical names from
years prior to RY1999.
Allows users to load or import their prior year quantitative information on releases
and waste transfers.
Guides facilities in completing the Form R and A by explaining each element of the
form through a questionnaire format.
Allows expert TRI users to bypass most of the hand-holding guidance and directly
enter the data into the forms.
Allows users to directly enter data into the forms on a computer screen.
Streamlines the completion of Form R, Part II, Section 7a information on waste
treatment methods.
Prevents facilities from making common errors while completing the Form R and
A.
TRI-ME
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
ATRS
No
No
Yes
No
Yes
Yes
Yes
No
Not applicable
Yes
No
Some
vi Toxics Release Inventory Reporting Forms and Instructions
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TRI Reporting Software
TRI Reporting Software for the Form R and A.
Comparison of TRI-ME versus ATRS for RY2001 (forms due July 2002)
Feature
Checks (validates) the forms to identify critical and potential errors that should be
corrected before submitting the forms to EPA.
Allows users to print their forms on paper or on floppy discs (using the same file
format from RY2000).
Allows users to submit their forms electronically over the Internet.
TRI-ME
Yes
Yes
Yes
ATRS
Some
Yes
No
Toxics Release Inventory Reporting Forms and Instructions vii
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Chemical and Industry Guidance Documents
To receive a copy of any of the EPCRA section 313 documents
listed below, check the box(es) next to the desired document(s).
There is no charge for any of these documents. Be sure to type
or clearly print your full mailing address in the space provided
on the third page of this form (page xi). Send this request form
to the address below or call (202) 564-9554. Many of these
documents are available via the Internet. For current versions,
visit the TRI Home Page (http://www.epa.gov/tri).
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave., N.W.
Attn: TRI Documents
MC: 2844
Washington, DC 20460
(202) 564-9554
Email: TRIDOCS@epa.gov
I. General Guidance
40 CFR 372, Toxic Chemical Release Reporting;
Community Right-to-Know; Final Rule
A reprint of the final EPCRA section 313 rule as it
appeared in the Federal Register (FR) February 16,
1988 (53 FR 4500) (OTSFR 021688).
Common Synonyms for Chemicals Listed Under
Section 313 of the Emergency Planning and
Community Right-to-Know Act
(EPA 745-R-95-008)
This glossary contains chemical names and their
synonyms for substances covered by the reporting
requirements of EPCRA section 313. The glossary
was developed to aid in determining whether a facility
manufactures, processes, or otherwise uses a chemical
subject to EPCRA section 313 reporting.
EPCRA Section 313; Toxic Chemical Release
Inventory; Data Quality Checks to Prevent
Common Reporting Errors on Form R/Form A
August 1998 (EPA 745-R-98-012)
EPCRA Section 313 Questions and Answers
Revised 1998 Version
December 1998 (EPA 745-B-98-004)
The revised 1998 EPCRA Section 313 Questions and
Answers document assists regulated facilities in
complying with the reporting requirements of EPCRA
section 313. This updated document presents
interpretive guidance in the form of answers to many
commonly asked questions on compliance with
EPCRA section 313. In addition, this document
includes comprehensive written directives to assist
covered facilities in understanding some of the more
complicated regulatory issues. This updated guidance
document is intended to supplement the instructions for
completing the Form R and the Alternate Threshold
Certification Statement (Form A).
EPCRA Section 313 Questions
Addendum for Federal Facilities
May 2000 (EPA 745-R-00-003)
and Answers
This document is an addendum to the EPCRA section
313 Questions and AnswersRevised 1998 Version. It
provides additional assistance to federal facilities in
complying with EPCRA section 313. Federal facilities,
which are subject to compliance under EPCRA through
Executive Order 13148, frequently have operations that
are different from the private sector facilities subject to
EPCRA. The document contains questions and answers
that address some of those differences.
EPCRA Section 313 Release and Other Waste
Management Reporting Requirements
February 2001 (EPA 260/K-01-001)
The brochure alerts businesses to their reporting
obligations under EPCRA section 313 and assists in
determining whether their facility is required to report.
The brochure contains the EPA regional contacts, the list
of EPCRA section 313 toxic chemicals and a description
of the Standard Industrial Classification (SIC) codes
subject to EPCRA section 313.
Persistent Bioaccumulative Toxic (PBT) Chemicals;
Final Rule (64 FR 58666)
A reprint of the final rule that appeared in the Federal
Register of October 29,1999. This rule adds certainPBT
chemicals and chemical categories for reporting year
2000 and beyond under EPCRA section 313, lowers
their activity thresholds and modifies certain reporting
exemptions and requirements for PBT chemicals and
chemical categories. In a separate action, as part of the
October 29, 1999 rulemaking, EPA added vanadium
(except when contained in alloy) and vanadium
compounds. These are not listed as PBT chemicals.
Supplier Notification Requirements
(EPA 560-4-91-006)
This pamphlet assists chemical suppliers who may be
subject to the supplier notification requirements, gives
examples of situations which require notification,
describes the trade secret provision, and contains a sample
notification.
Toxics Release Inventory Reporting Forms and Instructions ix
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Chemical and Industry Guidance Documents
* Toxic Chemical Release Inventory Reporting Forms
and Instructions Revised 2001 Version
February 2002 (EPA 260-B-02-001)
Toxics Release Inventory: Reporting Modifications
Beginning with 1995 Reporting Year
February 1995 (EPA 745-R-95-009)
Trade Secrets Rule and Form (53 FR 28772)
A reprint of the final rule that appeared in the Federal
Register of July 29,1988. This rule implements the trade
secrets provision of the Emergency Planning and
Community Right-to-Know Act (section 322) and includes
a copy of the trade secret substantiation form.
II. Chemical-Specific Guidance
EPA has developed a group of guidance documents specific to
individual chemicals and chemical categories.
Emergency Planning and Community Right-to-
Know Section 313: List of Toxic Chemicals within
the Chlorophenols Category
June 1999 (EPA745-B-99-013)
Toxics Release Inventory List of Toxic Chemicals
within the Glycol Ethers Category and Guidance for
Reporting
December 2000 (EPA745-R-00-004)
Emergency Planning and Community Right-to-
Know Act Section 313: Guidance for Reporting
Hydrochloric Acid (acid aerosols including mists,
vapors, gas, fog and other airborne forms of any
particle size)
December 1999 (EPA 745-B-99-014)
Emergency Planning and Community Right-to-
Know Act - Section 313: Guidance for Reporting
Releases and Other Waste Mangement Activities of
Toxic Chemicals: Lead and Lead Compounds
November 2001 (EPA-260-B-01-027)
Emergency Planning and Community Right-to-
Know Act - Section 313: Guidance for Reporting
Toxic Chemicals: Mercury and Mercury
Compounds Category
August 2001 (EPA 260-B-01-004)
Toxics Release Inventory List of Toxic Chemicals
within the Nicotine and Salt Category and Guidance
for Reporting
June 1999 (EPA 745-R-99-010)
Toxics Release Inventory List of Toxic Chemicals
within the Water Dissociable Nitrate Compounds
Category and Guidance for Reporting
December 2000 (EPA 745-R-00-006)
Emergency Planning and Community Right-to-
Know Act - Section 313: Guidance for Reporting
Toxic Chemicals: Pesticides and Other Persistent
Bioaccumulative Toxic (PBT) Chemicals
August 2001 (EPA 260-B-01-005)
Toxics Release Inventory List of Toxic Chemicals
within the Polychlorinated Alkanes Category and
Guidance for Reporting
June 1999 (EPA 745-B-99-023)
Emergency Planning and Community Right-to-
Know Act - Section 313: Guidance for Reporting
Toxic Chemicals: Polycyclic Aromatic Compounds
Category
August 2001 (EPA 260-B-01-003)
Toxics Release Inventory List of Toxic Chemicals
within the Strychnine and Salts Category and
Guidance for Reporting
June 1999 (EPA745-R-99-011)
Emergency Planning and Community Right-to-
Know Act Section 313: Guidance for Reporting
Sulfuric Acid (acid aerosols including mists, vapors,
gas, fog and other airborne forms of any particle
size)
March 1998 (EPA745-R-97-007)
Toxics Release Inventory List of Toxic Chemicals
within Warfarin Category
June 1999 (EPA745-B-99-011)
Toxics Release Inventory List of Toxic Chemicals
within Ethylenebisdithiocarbamic Acid, Salts and
Esters Category and List of Mixtures that Contain
the Individually listed Chemicals Maneb, Metiram,
Nabam, and Zineb
September 2001 (EPA 260-B-o 1-026)
Emergency Planning and Community Right-to-
Know Act - Section 313: Guidance for Reporting
Aqueous Ammonia
December 2000 (EPA 745-R-00-005)
Emergency Planning and Community Right-to-
Know Act - Section 313: Guidance for Reporting
Toxic Chemicals within the Dioxin and Dioxin-like
Compounds Category
December 2000 (EPA 745-B-00-021)
x Toxics Release Inventory Reporting Forms and Instructions
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Chemical and Industry Guidance Documents
III. Industry-Specific Guidance
EPA has developed a group of individual guidance documents
for certain industries.
EPCRA Section 313: Guidance for
Chemical Distribution Facilities
January 1999 (EPA 745-B-99-005)
EPCRA Section 313: Guidance for
Coal Mining Facilities
February 2000 (EPA 745-B-00-003)
EPCRA Section 313: Guidance for
Electricity Generating Facilities
February 2000 (EPA 745-B-00-004)
EPCRA Section 313 Reporting Guidance for
Food Processors
September 1998 (EPA 745-R-98-011)
EPCRA Section 313 Reporting Guidance for
the Leather Tanning and Finishing Industry
April 2000 (EPA 745-B-00-012)
EPCRA Section 313: Guidance for
Metal Mining Facilities
Januaryl999 (EPA745-B-99-001)
EPCRA Section 313: Guidance for
Petroleum Terminals and Bulk Storage Facilities
February 2000 (EPA 745-B-00-002)
Emergency Planning and Community Right-to-
Know Act Section 313 Reporting Guidance for the
Presswood and Laminated Products Industry
August 2001 (EPA 260-B-01-013)
EPCRA Section 313 Reporting Guidance for the
Printing, Publishing, and Packaging Industry
May 2000 (EPA 745-B-00-005)
EPCRA Section 313: Guidance for RCRA
Subtitle C TSD Facilities and Solvent Recovery
Facilities
January 1999 (EPA 745-B-99-004)
EPCRA Section 313 Reporting Guidance for
Rubber and Plastics Manufacturing
May 2000 (EPA 745-B-00-017)
EPCRA Section 313 Reporting Guidance for
Semiconductor Manufacturing
July 1999 (EPA 745-R-99-007)
EPCRA Section 313 Reporting Guidance for
Spray Application and Electrodeposition of Organic
Coatings
December 1998 (EPA 745-R-98-014)
EPCRA Section 313 Reporting Guidance for
the Textile Processing Industry
May 2000 (EPA 745-B-00-008)
PLEASE TYPE MAILING ADDRESS HERE (DO NOT ATTACH BUSINESS CARDS)
Name/Title
Company Name
Mail Stop
Street Address
P.O. Box
City/State/ZIP Code
Toxics Release Inventory Reporting Forms and Instructions xi
-------
Paperwork Reduction Act Notice: The annual public burden related to the Form R, which
is approved under OMB Control No. 2070-0093, is estimated to average 52.1 hours per
response. The annual public burden related to the Form A, which is approved under OMB
Control No. 2070-0143, is based on a combination of the estimated burdens for 1) determining
whether a listed toxic chemical is eligible for certification under the alternate threshold, and
2) completing the Form A. The burden of determining eligibility for certification is estimated
to average 33.2 hours for each chemical that is certified. The burden of completing the Form
A is estimated to average 1.4 hours, regardless of the number of chemicals being certified.
The total burden per response is the combination of these two, and will vary depending on
the number of listed toxic chemicals being certified.
According to the Paperwork Reduction Act, "burden" means the total time, effort,
or financial resources expended by persons to generate, maintain, retain, or disclose or
provide information to or for a Federal agency. For this collection it includes the time needed
to review instructions; train personnel to be able to respond to the collection of information;
search data sources; complete and review the collection of information; and transmit or
otherwise disclose the information. An agency may not conduct or sponsor, and a person is
not required to respond to, a collection of information unless it displays a currently valid
OMB control number. The OMB control numbers for this information collection appear
above and on the forms. In addition, the OMB control numbers for EPA's regulations, after
initial display in the final rule, are listed in 40 CFR part 9.
Send comments on the accuracy of the provided burden estimates, and any
suggested methods for minimizing respondent burden, including through the use of
automated collection techniques to the Director, OEI Collection Strategies Division, U.S.
Environmental Protection Agency (Mail Code 2822), 1200 Pennsylvania Avenue, N.W.,
Washington, D.C. 20460. Include the OMB control number in any correspondence, but do
not submit the requested information to this address. The completed forms should be
submitted in accordance with the instructions accompanying the form, or as specified in the
corresponding regulation.
xii Toxics Release Inventory Reporting Forms and Instructions
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 01/31/2003
Page 1 of 5
EPA
United States
Environmental Protection
Agency
FORM R
TOXIC CHEMICAL RELEASE
INVENTORY REPORTING FORM
Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986,
also known as Title III of the Superfund Amendments and Reauthorization Act
WHERE TO SEND COMPLETED FORMS: 1. EPCRA Reporting Center
P.O Box 3348
Merrifield, VA 22116-3348
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix F)
Enter "X" here if this
is a revision
For EPA use only
Important: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART I. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
2.1
Are you claiming the toxic chemical identified on page 2 trade secret?
No (Do not answer 2.2;
Yes (Answer question 2.2;
Attach substantiation forms)
Go to Section 3)
2.2
Is this copy
Sanitized
Unsanitized
(Answer only if "YES" in 2.1)
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted
information is true and complete and that the amounts and values in this report are accurate based on reasonable estimates
using data available to the preparers of this report.
Name and official title of owner/operator or senior management official:
Signature:
Date Signed:
SECTION 4. FACILITY IDENTIFICATION
4.1
TRI Facility ID Number
Facility or Establishment Name
Facility or Establishment Name or Mailing Address(if different from street address)
Street
Mailing Address
City/County/State/Zip Code
City/State/Zip Code
Country (Non-US)
4.2
This report contains information for:
: check a or b; check c or d if applicable)
a.
An entire
facility
Part of a
facility
A Federal
facility
d.
GOCO
4.3
Technical Contact Name
Telephone Number (include area code)
4.4
Public Contact Name
Telephone Number (include area code)
4.5
SIC Code (s) (4 digits)
Primary
a.
b.
c.
d.
e.
4.6
Latitude
Degrees
Minutes
Seconds
Longitude
Degrees
Minutes
Seconds
4.7
Dun & Bradstreet
Number(s) (9 digits)
4.8
EPA Identification Number
(RCRA I.D. No.) (12 characters)
4.9
Facility NPDES Permit
Number(s) (9 characters)
4.10
Underground Injection Well Code
(UIC) I.D. Number(s) (12 digits)
a.
a.
b.
b.
SECTION 5. PARENT COMPANY INFORMATION
5.1
Name of Parent Company
NA
5.2
Parent Company's Dun & Bradstreet Number
NA
EPA Form 9350-1 (Rev. 01/2001) - Previous editions are obsolete.
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Page 2 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important: DO NOT complete this section if you completed Section 2 below.)
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
1.4 Distribution of Each Member of the Dioxin and Dioxin-like Compounds Category.
(If there are any numbers in boxes 1 -17, then every field must be filled in with either 0 or some number between 0.01 and 100. Distribution should
be reported in percentages and the total should equal 100%. If you do not have speciation data available, indicate NA.)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
NAQ[
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check all that apply.)
3.1 Manufacture the toxic chemical:
3.2 Process the toxic chemical:
3.3 Otherwise use the toxic chemical:
a.
Produce
b.
Import
If produce or import:
For on-site use/processing
For sale/distribution
As a byproduct
As an impurity
a.
b.
c.
d.
e.
As a reactant
As a formulation component
As an article component
Repackaging
As an impurity
As a chemical processing aid
As a manufacturing aid
Ancillary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ONSITE AT ANY TIME DURING THE CALENDAR YEAR
4.1
(Enter two-digit code from instruction package.)
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
A. Total Release (pounds/year*)
(Enter range code or estimate**)
B. Basis of Estimate
(enter code)
C. % From Stormwater
5.1
5.2
5.3
Fugitive or non-point
air emissions
Stack or point
air emissions
NA
NA
Discharges to receiving streams or
water bodies (enter one name per box)
Stream or Water Body Name
5.3.1
5.3.2
5.3.3
If additional pages of Part II, Section 5.3 are attached, indicate the total number of pages in this box
and indicate the Part II, Section 5.3 page number in this box. (example: 1,2,3, etc.)
EPA Form 9350-1 (Rev. 01/2001) - Previous editions are obsolete.
* For Dioxin or Dioxin-like compounds, report in grams/year
** Range Codes: A= 1 -10 pounds; B= 11- 499 pounds; C= 500 - 999 pounds.
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Page 3 of 5
EPA FORM
TR
R
PART II. CHEMICAL - SPECIFIC INFORMATION (CONTINUED) TOX
Facility ID Number
ic Chemical, Category or Generic Name
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE (Continued)
Underground Injection onsite
5-4-1 to Class 1 Wells
Underground Injection onsite
5-4-2 to Class II-V Wells
5.5 Disposal to land onsite
5.5.1 A RCRA Subtitle C landfills
5.5. 1B Other landfills
_ _ _ Land treatment/application
O.O.&
farming
5.5.3 Surface Impoundment
5.5.4 Other disposal
NA
A. Total Release (pounds/year*) (enter range B. Basi
code** or estimate) (ente
5 of Estimate
r code)
SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1. A Total Quantity Transferred to POTWs and
6.1.A.1. Total Transfers (pounds/year*)
(enter range code** or estimate)
Basis of Estimate
6.1.A.2 Basis of Estimate
(enter code)
POTW Name
61 R
POTW Address
City
POTW Name
6 1 B
State County
POTW Address
City
State County
If additional pages of Part II, Section 6.1 are attached, indicate the total number of pages
in this box | | and indicate the Part II, Section 6.1 page number in this box | | (example:
Zip
Zip
1,2,3, etc.)
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
6.2. Off-Site EPA Identification Number (RCRA ID No.)
Off-Site Location Name
Off-Site Address
City
State
Is location under control of reporting facility or parent compa
County
ny?
Country
'P (Non-US)
Yes No
EPA Form 9350-1 (Rev. 01/2001) - Previous editions are obsolete.
* For Dioxin or Dioxin-like compounds, report in grams/year
' Range Codes: A = 1 -10 pounds; B = 11 - 499 pounds; C = 500 - 999 pounds.
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Page 4 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (Continued)
A. Total Transfers (pounds/year*)
(enter range code** or estimate)
B. Basis of Estimate
(enter code)
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1.
1.
1. M
2.
2.
2. M
3.
3.
3. M
4.
4.
4. M
6.2. Off-Site EPA Identification Number (RCRA ID No.
Off-Site location Name
Off-Site Address
City
State
County
Zip
Country
(Non-US)
Is location under control of reporting facility or parent company?
Yes
No
A. Total Transfers (pounds/year*)
(enter range code** or estimate)
B. Basis of Estimate
(enter code)
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. M
2.
2.
2. M
3.
3.
3. M
4.
4.
4. M
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
Not Applicable (NA) -
Check here if no on-site waste treatment is applied to any
waste stream containing the toxic chemical or chemical category.
a. General
Waste Stream
(enter code)
b. Waste Treatment Method(s) Sequence
[enter 3-character code(s)]
c. Range of Influent
Concentration
d. Waste Treatment
Efficiency
Estimate
Based on
Operating Data ?
7A.1a
7A. 1c
7A. 1d
7A. 1e
Yes No
7A.2c
7A.2d
7A.2e
Yes No
7A.3c
7A.3d
7A.3e
Yes No
7A.4c
7A.4d
7A.4e
Yes No
7A.5c
7A.5d
7A.5e
Yes No
If additional pages of Part II, Section 6.2/7A are attached, indicate the total
and indicate the Part II, Section 6.2/7A page number in this box :
number of pages in this box
~1 (example: 1,2,3, etc)
EPA Form 9350-1 (Rev. 01/2001) - Previous editions are obsolete.
* For Dioxin or Dioxin-like compounds, report in grams/year
** Range Codes: A = 1 -10 pounds; B = 11 - 499 pounds; C = 500 - 999 pounds.
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Page 5 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
Not Applicable (NA) -
Check here if no on-site energy recovery is applied to any waste
stream containing the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character code(s)]
2
SECTION 7C. ON-SITE RECYCLING PROCESSES
Not Applicable (NA) - Check here if no on-site recycling is applied to any waste
stream containing the toxic chemical or chemical category
Recycling Methods [enter 3-character code(s)]
6.
SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES
Column A
Prior Year
(pounds/year*)
Column B
Current Reporting Year
(pounds/year*)
Column C
Following Year
(pounds/year*)
Column D
Second Following Year
(pounds/year*)
8.1
Quantity released'
8.2
Quantity used for energy recovery
onsite
8.3
Quantity used for energy recovery
offsite
8.4
Quantity recycled onsite
8.5
Quantity recycled offsite
8.6
Quantity treated onsite
8.7
Quantity treated offsite
8.8
Quantity released to the environment as a result of remedial actions,
catastrophic events, or one-time events not associated with production
processes (pounds/year)
8.9
Production ratio or activity index
8.10
Did your facility engage in any source reduction activities for this chemical during the reporting year? If not,
enter "NA" in Section 8.10.1 and answer Section 8.11.
Source Reduction Activities
[enter code(s)]
Methods to Identify Activity (enter codes)
8.10.1
a.
b.
8.10.2
a.
b.
8.10.3
a.
b.
8.10.4
a.
b.
8.11
Is additional information on source reduction, recycling, or pollution control activities
included with this report ? (Check one box)
YES
NO
EPA Form 9350-1 (Rev. 01/2001) - Previous editions are obsolete.
* For Dioxin or Dioxin-like compounds, report in grams/year
*** Report releases pursuant to EPCRA Section 329(8) including "any spilling, leaking,
pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping,
or disposing into the environment." Do not include any quantity treated onsite.
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0143
Approval Expires: 01/31/2003 Page _1_of.
United States
Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY
FORMA
WHERE TO SEND COMPLETED FORMS: 1. EPCRA Reporting Center
P.O Box 3348
Merrifield, VA 22116-3348
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix F)
Enter "X" here if this
is a revision
For EPA use only
Important: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART I. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
2.1
Are you claiming the toxic chemical identified on page 2 trade secret?
No (Do not answer 2.2;
Yes (Answer question 2.2;
Attach substantiation forms)
Go to Section 3)
2.2
Is this copy
Sanitized
Unsanitized
(Answer only if "YES" in 2.1)
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that to the best of my knowledge and belief, for each toxic chemical listed in the statement, the annual reportable
amount as defined in 40 CFR 372.27 (a), did not exceed 500 pounds for this reporting year and that the chemical was
manufactured, processed, or otherwise used in an amount not exceeding 1 million pounds during this reporting year.
Name and official title of owner/operator or senior management official:
Signature:
Date Signed:
SECTION 4. FACILITY IDENTIFICATION
4.1
TRI Facility ID Number
Facility or Establishment Name
Facility or Establishment Name or Mailing Address(if different from street address)
Street
Mailing Address
City/County/State/Zip Code
City/State/Zip Code
Country (Non-US)
4.2
This report contains information for:
: check c or d if applicable)
A Federal
facility
GOCO
4.3
Technical Contact Name
Telephone Number (include area codej
4.4
Intentionally left blank
4.5
SIC Code (s) (4 digits)
Primary
b.
d.
4.6
Latitude
Degrees
Minutes
Seconds
Longitude
Degrees
Minutes
Seconds
4.7
Dun & Bradstreet
Number(s) (9 digits)
4.8
EPA Identification Number
(RCRA I.D. No.) (12 characters)
4.9
Facility NPDES Permit
Number(s) (9 characters)
4.10
Underground Injection Well Code
(UIC) I.D. Number(s) (12 digits)
b.
b.
SECTION 5. PARENT COMPANY INFORMATION
5.1
Name of Parent Company
NA
5.2
Parent Company's Dun & Bradstreet Number
NA
EPA Form 9350-2 (Rev. 01/2001) - Previous editions are obsolete.
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IMPORTANT: Type or print; read instructions before completing form
Page of
EPA FORM A
PART II. CHEMICAL IDENTIFICATION TRIFID:
Do not use this form for reporting PBT chemicals including Dioxin and Dioxin-like Compounds*
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
* See the TRI Reporting Forms and Instructions Manual for the list of PBT Chemicals (including Dioxin and Dioxin-like Compounds)
EPA Form 9350-2 (Rev. 01/2001) - Previous editions are obsolete. (Make additional copies of this page, if needed)
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A. General Information
Reporting to the Toxic Chemical Release Inventory (i.e., Toxics
Release Inventory (TRI)) is required by section 313 of the
Emergency Planning and Community Right-to-Know Act
(EPCRA, or Title III of the Superfund Amendments and
Reauthorization Act of 1986), Public Law 99-499. The
information contained in the Form R constitutes a "report," and
the submission of a report to the appropriate authorities
constitutes "reporting."
The Pollution Prevention Act, passed into law in October, 1990
(Pub. L. 101-508), added reporting requirements to Form R.
These requirements affect all facilities required to submit Form
R under section 313 of EPCRA. The data were required
beginning with reports for calendar year 1991.
Reporting is required to provide the public with information on
the releases and other waste management of EPCRA section 313
chemicals in their communities and to provide EPA with release
and other waste management information to assist the Agency
in determining the need for future regulations. Facilities must
report the quantities of routine and accidental releases, and
releases resulting from catastrophic or other one time events of
EPCRA section 313 chemicals, as well as the maximum amount
of the EPCRA section 313 chemical on-site during the calendar
year and the amount contained in wastes managed on-site or
transferred off-site.
A completed Form R or Form A must be submitted for each
EPCRA section 313 chemical manufactured, processed, or
otherwise used at each covered facility as described in the
reporting rules in 40 CFR Part 372 (originally published
February 16, 1988, in the Federal Register and November 30,
1994, in the Federal Register (for Form A)).
A.I Who Must Report
Section 313 of EPCRA requires that reports be filed by owners
and operators of facilities that meet all of the following criteria.
n The facility has 10 or more full-time employee equivalents
(i.e., a total of 20,000 hours or greater; see 40 CFR 372.3);
and
n The facility is included in Standard Industrial
Classification (SIC) Codes 10 (except 1011, 1081, and
1094), 12 (except 1241), 20-39,4911 (limited to facilities
that combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4931 (limited to
facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4939
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4953 (limited to facilities regulated under
RCRA Subtitle C, 42 U.S.C. section 6921 et seq.), 5169,
5171, and 7389 (limited to facilities primarily engaged in
solvents recovery services on a contract or fee basis); and
n The facility manufactures (defined to include importing),
processes, or otherwise uses any EPCRA section 313
chemical in quantities greater than the established
threshold in the course of a calendar year.
Executive Order 13148 extends these reporting requirements to
federal facilities, regardless of their SIC code.
A.2 How to Assemble a Complete Report
A.2.a. The Toxic Chemical Release
Reporting Form, EPA Form R
The five-page EPA Form R consists of two parts:
D Part I, Facility Identification Information (page 1); and
n Part II, Chemical-Specific Information (pages 2-5).
Most of the information required in Part I of Form R can be
completed, photocopied, and attached to each chemical-specific
report. However, Part I of each Form R submitted must
have an original signature on the certification statement and
the trade secret designation must be entered as appropriate. Part
II must be completed separately for each EPCRA section 313
chemical or chemical category. Because a complete Form R
consists of at least five unique pages, any submission containing
less than five unique pages is not a valid submission.
A complete report for any EPCRA section 313 chemical that is
not claimed as a trade secret consists of the following completed
parts:
n Part I with an original signature on the certification
statement (Section 3); and
n Part II.
Staple all five pages of each report together. If you check "yes"
on Part II, Section 8.11, you may attach additional information
on pollution prevention activities at your facility.
A.2.b. The Alternate Threshold Form A
Certification Statement
EPA Form A Certification Statement (hereafter referred to as
Form A) was established in 1994. This form is based on an
alternate threshold for facilities with small amounts of an
EPCRA section 313 chemical in waste. The Form A serves to
certify that a facility is not subject to Form R reporting for a
Toxics Release Inventory Reporting Forms and Instructions 1
-------
General Information
specific toxic chemical. Like the Form R described above, the
Form A consists of two parts, but only consists of a total of two
pages.
n Part I, Facility Identification Information, which also
includes the "certification" regarding the eligibility to use
the Form A (page 1); and
n Part II, Chemical Identification (page 2).
Since 1998, the Form A may be used to report multiple
chemicals. Four chemicals may be reported on page 2 of the
form. If more than four chemicals are to be reported, additional
copies of page 2 can be used to report qualifying chemicals.
The Form A must have an original certification statement on
page 1 and contain an appropriate trade secret designation for
the form. A complete report for Form A consists of at least two
pages for each submission.
A.3 Trade Secret Claims
For any EPCRA section 313 chemical whose identity is claimed
as trade secret, you must submit to EPA two versions of the
substantiation form as prescribed in 40 CFR Part 350, published
July 29,1988, in the Federal Register (53 FR 28772) as well as
two versions of the EPCRA section 313 report. One set of
reports, the "unsanitized" version, should provide the actual
identity of the EPCRA section 313 chemical. The other set of
reports, i.e., the "sanitized" version, should provide only a
generic identity of the EPCRA section 313 chemical. If EPA
deems the trade secret substantiation form valid, only the
sanitized set of forms will be made available to the public.
Use the order form in this document to obtain copies of the rule
and substantiation form. Further explanation of the trade secret
provisions is provided in Part I, Sections 2.1 and 2.2, and Part
II, Section 1.3, of the instructions.
In summary, a complete report to EPA for an EPCRA section
313 chemical claimed as a trade secret must include all of the
following:
A completed "unsanitized" version of Form R or Form A
report including the EPCRA section 313 chemical identity
(staple the pages together);
A "sanitized" version of a completed Form R or Form A
report in which the EPCRA section 313 chemical identity
items (Part II, Sections 1.1 and 1.2) have been left blank
but in which a generic chemical name has been supplied
(Part II, Section 1.3) (staple the pages together);
A completed "unsanitized" version of a trade secret
substantiation form (staple the pages together); and
A "sanitized" version of a completed trade secret
substantiation form (staple the pages together).
Securely fasten all four reports together.
Some states also require submission of both sanitized and
unsanitized reports for EPCRA section 313 chemicals whose
identity is claimed as a trade secret. Others require only a
sanitized version. Facilities may jeopardize the trade secret
status of an EPCRA section 313 chemical by submitting an
unsanitized version of the EPCRA section 313 report to a state
agency or Indian tribe that does not require unsanitized forms.
You may identify an individual State's submission requirements
by contacting the appropriate state-designated EPCRA section
313 contact (see Appendix F).
A.4 Recordkeeping
Sound recordkeeping practices are essential for accurate and
efficient TRI reporting. It is in the facility's interest, as well as
EPA's, to maintain records properly.
Facilities must keep a copy of each report filed for at least three
years from the date of submission. These reports will be of use
when completing future reports.
Facilities must also maintain those documents, calculations,
worksheets, and other forms upon which they relied to gather
information for prior reports. In the event of a problem with
data elements on a facility's Form R or Form A report, EPA
may request documentation from the facility that supports the
information reported.
EPA may conduct data quality reviews of Form R or Form A
submissions. An essential component of this process involves
reviewing a facility's records for accuracy and completeness.
EPA recommends that facilities keep a record for those EPCRA
section 313 chemicals for which they did not file EPCRA
section 313 reports.
A partial list of records, organized by year, that a facility should
maintain include:
Previous years' EPCRA section 313 reports;
EPCRA section 313 Reporting Threshold Worksheets;
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;
Invoices from waste management companies;
2 Toxics Release Inventory Reporting Forms and Instructions
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General Information
Manufacturer's estimates of treatment efficiencies;
RCRA Manifests;
Process diagrams that indicate emissions and other
releases; and
Records for those EPCRA section 313 chemicals for
which they did not file EPCRA section 313 reports.
A.5 How to Revise or Withdraw TRI Data
U.S. EPA has received several questions relating to withdrawing
and revising TRI data submitted by facilities, such as:
What should be submitted?
To whom should this request be sent?
What are the reasons for revisions/withdrawals?
If you determine that you need to request a revision/withdrawal
of a submission(s), EPA recommends that you use the sample
letters provided below and in Appendix I of the TRI Reporting
Forms and Instructions (2001 version).
Submitting a request to EPA to revise TRI data
Facilities that filed a Form R and/or Form A Certification under
EPCRA Section 313 may send their requests to revise the Form
R and/or Form A Certification submissions) in EPA's database
(i.e., the Toxics Release Inventory System (TRIS)) and in the
public version of the database.
In order to have a submission in the TRI database revised, EPA
recommends that facilities send their request to EPA and the
appropriate State agency, if required by completing a 'Request
for Revision' template (provided below and in Appendix I of the
TRI Reporting Forms and Instructions (2001 version)) and a
copy of the Form R or Form A Certification you would like to
be revised in the EPA database to the EPCRA Reporting Center.
EPA will review each request and notify the requestor by letter
whether or not the revision has been accepted. Note, late
submissions for chemicals not reported in a previous reporting
year are not considered revisions for that year. In order to
effectively process the request, EPA needs the following
information:
Facility name and TRI facility identification number
(TROTD)
Facility mailing address
Reporting year
Chemical name
Technical contact name and phone number
Name and phone number of the requester
Reason(s) for revision
Signature.
Facilities may request a revision for one or several reasons, such
as:
Revision of facility identification information.
Revision of chemical identification information.
Revisionof release and other waste management activities
information.
Result of an EPA /State inspection.
Result of notice of technical error, notice of significant
error, or notice of noncompliance from EPA.
Result of voluntary disclosure or audit policy.
Hardcopy revisions may be submitted using the most recent
form available or the most recent version of the ATRS (for
reporting years after 1990)or TRI-ME software. Certify and date
the form on Page 1 or provide a cover letter with the software
created data revision. Alternatively, you may submit a
photocopy of your original submission (from your file) with the
corrections made in blue ink. Re-sign and re-date the
certification statement on Page 1. For revisions to 1990 and
earlier reporting year submissions, use the paper form and write
"VOLUNTARY REVISION" on page 1 of the form. For
revisions to 1991 and later reporting year submissions, enter
"X" in the space marked "Enter "x" here if this is a revision," on
page 1 of the form.
The EPA ATRS 2001 software allows you to revise your form
data and submit your revisions for any reporting year after 1987.
TRI-ME software allows you to revise your form data only for
the reporting year for which the TRI-ME software was
developed. The documentation provided with the ATRS 2001
and TRI-ME software contains specific instructions, oryoumay
call the ATRS and TRI-ME technical support hotline at (877)
470-4830. The Technical Support Hotline number is to be used
for ATRS and TRI-ME and does not provide regulatory support.
If you submitted your data using software developed by a
vendor, you must contact the software developer to determine if
their software is capable of creating revisions. If not, you can
use either the ATRS or TRI-ME software or the current
hardcopy paper form. Please be careful when submitting
magnetic media revisions to resubmit only the revised
submissions. Do not resubmit a diskette containing all of your
original submissions if you are only revising one or several of
them. Whenever you submit a diskette to EPA, do not also
submit a printout of what is on the diskette because they will
both be processed potentially resulting in duplicate records for
your facility.
Where to Send Your Revision Request
When submitting a revision request to EPA regarding the
submission(s) of your TRI Form R and/or Form A Certification,
please send your request to the EPCRA Reporting Center.
To send requests by regular mail:
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
Attention: TRI Revision Request
Toxics Release Inventory Reporting Forms and Instructions 3
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General Information
To send requests by certified mail or overnight mail (i.e. FedEx,
UPS, etc.):
EPCRA Reporting Center
c/o Titan Systems Corp.
Suite 300
4600 North Fairfax Drive
Arlington, VA 22203
Attention: TRI Revision Request
(703) 816-4445
Submitting a Request to EPA to Withdraw TRI
Data
Facilities that filed a Form R and/or Form A Certification under
EPCRA Section 313 may send their requests to EPA to
withdraw the Form R and/or Form A Certification submissions)
fromEPA's database (i.e., the Toxics Release Inventory System
(TRIS)) and from the public version of the database.
In order to have a submission removed from the TRI database,
EPA recommends that facilities send their request to EPA and
the appropriate State agency, if required, by completing a
'Request for Withdrawal' template (provided below and in
Appendix I of the TRI Reporting Forms and Instructions (2001
version)) and a copy of the Form R or Form A Certification they
would like to be withdrawn from the EPA database to the
EPCRA Reporting Center. EPA will review each request and
notify the requestor by letter whether or not the withdrawal
request has been accepted. In order to effectively process the
request, EPA needs the following information:
Facility name and TRI facility identification number
(TROTD)
Facility mailing address
Reporting year
Chemical name
Technical contact name and phone number
Name and phone number of the requester
Reason(s) for withdrawal
Signature.
Facilities may request a withdrawal for one or several reasons,
such as:
They manufacture, process or otherwise use less than
threshold quantities. (The reporting thresholds are 25,000
pounds for manufacturing or processing and 10,000
pounds for otherwise use except for persistent
bioaccumulative toxic (PBT) chemicals and chemical
categories. PBT chemicals and chemical categories have
reporting thresholds of 10 or 100 pounds except for the
dioxin and dioxin-like compounds category that has a
reporting threshold of 0.1 gram.)
Change in EPA reporting requirements for this chemical.
It is no longer manufactured, processed or otherwise used
above reporting thresholds or it has been deleted from the
EPCRA Section 313 toxic chemical list.
Qualify for one of the following EPCRA Section 313
exemptions:
de minimis (Please note that de minimis exemption
is not allowed for PBT chemicals and chemical
categories.)
Article
Laboratory activities
Use as structural component
Coal extraction activities
Routine janitorial or facility grounds maintenance
Use for motor vehicle maintenance/operation
Personal use by employees or other persons
Chemical contained in certain intake water or intake
air
Metal mining overburden
The chemical reported is not an EPCRA Section 313
reportable chemical.
The chemical reported is not in a form listed on the
EPCRA Section 313 toxic chemical list (i.e., aerosol,
fume or dust, fibrous form, etc.).
Activities involving the reported chemical do not meet the
definition of manufacturing, processing, or otherwise use.
Qualify for a Form A Certification submission.
Where to send your withdrawal request
When submitting a withdrawal request to EPA regarding the
submission(s) of your TRI Form R and/or Form A Certification,
please send your request to the EPCRA Reporting Center.
To send requests by regular mail:
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
Attention: TRI Withdrawal Request
To send requests by certified mail or overnight mail (i.e. Fed Ex,
UPS, etc.):
EPCRA Reporting Center
c/o Titan Systems Corp.
Suite 300
4600 North Fairfax Drive
Arlington, VA 22203
Attention: TRI Withdrawal Request
(703) 816-4445
4 Toxics Release Inventory Reporting Forms and Instructions
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General Information
A.6 When the Report Must Be
Submitted
As specified in EPCRA section 313, the report for any calendar
year must be submitted on or before July 1 of the following year
whether using Form R or Form A. If the reporting deadline falls
on a Saturday or Sunday, EPA will accept the forms which are
postmarked on the following Monday (i.e., the next business
day). For example, RY2001 reports should be postmarked on or
before Monday, July 1,2002. Any voluntary revision to a report
can be submitted anytime during the calendar year for the
current or any previous reporting year. However, voluntary
revisions for the current reporting year should be submitted by
July 31 in order to be included in that year's public data release.
A.7 Where to Send the Forms
Submissions must be sent to both EPA and the State (or the
designated official of an Indian tribe). If a report is not received
by both EPA and the State (or the designated official of an
Indian tribe), the submitter is considered out of compliance and
subject to enforcement action. Send reports to EPA by regular
mail to:
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
Attn: Toxic Chemical Release Inventory
Certified mail, overnight mail, and hand-delivered submissions
only should be addressed to:
EPCRA Reporting Center
c/o Titan Systems Corp.
Suite 300
4600 North Fairfax Drive
Arlington, VA 22203
(703) 816-4445
Also send a copy of the report to the State in which the facility
is located. ("State" also includes: the District of Columbia, the
Commonwealth of Puerto Rico, Guam, American Samoa,
Marshall Islands, the U.S. Virgin Islands, the Northern Mariana
Islands, and any other territory or possession over which the
U.S. has jurisdiction.) Refer to Appendix F for the appropriate
State submission addresses.
Facilities located on Indian land should send a copy to the Chief
Executive Officer of the applicable Indian tribe. Some tribes
have entered into a cooperative agreement with States; in this
case, report submissions should be sent to the entity designated
in the cooperative agreement.
EPA has developed apackage called "TRI Reporting Software."
The easy-to-use CD-ROM includes ATRS and TRI-ME software
and comes with complete instructions for its use. It also
provides prompts and messages to help you report according to
EPA instructions. For copies of the CD-ROM you may call the
EPA at (202) 564-9554. ATRS and TRI-ME also are available
for downloading from EPA's website at http://www.epa.gov/tri.
Private vendors offer software to assist facilities in producing
magnetic media submissions or computer-generated facsimiles
for EPCRA section 313 reports. Every year and upon request,
EPA makes available to vendors a copy of \h& Magnetic Media
File Formats document for that specific reporting year. This
document provides software vendors with details describing the
appropriate output file format for processing in EPA's TRI
database.
It should be noted, however, that some States may accept only
paper copies of the EPCRA section 313 report. If this is the
case, a magnetic media or computer-generated facsimile may be
unacceptable.
A.7.a. How to Send Your Disks Containing
Form R(s) and/or Form A(s)
Included in this reporting package (on the enclosed CD-ROM)
is the Automated TRI Reporting Software (ATRS) and TRI-ME.
If you use ATRS or TRI-ME, please follow the instructions
below for submitting your TRI forms on magnetic
media/diskette.
A.7.a.l Labeling Your Submission Diskette
A label must be attached to each diskette. The label may be
typed or legibly handwritten. A sample label follows with the
necessary information.
TRIS Report
Company Name
Date: 6/30/2002
Report Year: 2001
Density: HD
Number: 1 of 1
Contact: Technical Contact Name
(505) 555-5369
Toxics Release Inventory Reporting Forms and Instructions 5
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General Information
The types of packaging and shipping used for magnetic media
submissions are left to the discretion of the submitting facility.
Please send completed diskettes, along with a cover letter and an
original certification signature from each submitting facility to:
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
Certified mail, overnight mail, and hand-delivered submissions
only should be addressed to:
Attn: TRI Magnetic Media Submission
EPCRA Reporting Center
c/o Titan Systems Corp.
Suite 300
4600 North Fairfax Drive
Arlington, VA 22203
(703) 816-4445
If you are submitting reports on magnetic media/diskette to
EPA, you must enclose a cover letter signed by the official listed
in Section 3 of Part I of the Form R or Form A (name and
official title of owner/operator or senior management official)
for each separate facility. Cover letters for both EPA and States
can be printed from ATRS and TRI-ME. The letter on page 9 is
a sample. Since you are filing by diskette, do not include paper
copies of the reports that are on the diskette.
A.7.a.2 Submitting by Diskette to States
Submitters must submit a copy of each Form R or Form A to the
appropriate state agency. As of the publication of this book and
the TRI Reporting Software, the following states confirmed that
they accept diskette submissions:
AK
AL
AZ1
CA
CO
DE
FL
GA
HI
IA
ID
IL
IN
KS
LA
MD
MI
MN
MO
MT
ND
NH
NJ
NM
NV
NY
OH
OK
OR
PA
SC2
SD
TX
UT
VA
VT
WA
WI
WV
WY
Arizona Emergency Response Commission accepts diskette
submissions while the Arizona Dept. of Environmental Quality accepts
only paper submissions. Submissions must be sent to both agencies.
2South Carolina accepts only diskette submissions.
If your state is not listed here, please contact your state office to
confirm that paper submissions are required. A list of state
contacts can be found in Appendix F.
A.7.b How to Submit Form R(s) and/or Form
A(s) to EPA via the Internet (EPA's Central Data
Exchange (CDX))
TRI-ME has the ability to directly submit your TRI
submissions) via the Internet (also known as EPA's Central
DataExchange(CDX)). If you choose to submit your TRI Form
R(s) and or Form A(s) via the Internet, you must send a
certification letter signed by the official listed in Section 3 of
Part I of the Form R and/or Form A for each facility reported.
After successfully submitting your RY 2001 submission(s) via
the Internet, TRI-ME will then prompt you to print your
certification letter. It is important to use the certification letter
printed from the software, as it contains your CDX identification
number which is a unique identifier in matching your
certification letter with the data files submitted via the Internet.
The letter on page 8 is a sample. Your certification letter must
include the CDX ID number so a signature can be matched with
your TRI submission. If you chose to submit via the Internet, do
not send paper or diskette copies of the reports. Please be aware
that submitting via the Internet to the U. S. EPA does not satisfy
your state reporting requirements for your facility. You must
report to your state separately and in the required format
specified by your state (i.e., diskette, paper, etc.). Please send
the signed certification letter from each submitting facility to:
EPCRA Reporting Center
ATTN: Internet CDX Submission
P.O. Box 3348
Merrifield, VA 22116-3348
Certified mail, overnight mail, and hand-delivered submissions
only should be addressed to:
EPCRA Reporting Center
ATTN: Internet CDX Submission
c/o Titan Systems Corp.
4600 North Fairfax Drive
Suite 300
Arlington, VA 22203
(703) 816-4445
This service allows you to securely submit your TRI data to
EPA over the Internet and receive an immediate
acknowledgment that your data has been accepted. Please note
the acceptance of your data by CDX means that your data was
successfully transmitted over the Internet. You must print, sign
and mail the TRI certification statement to the EPCRA
Reporting Center to complete the submission process. Your
certification letter MUST contain your CDX ID number, your
TRI Facility ID number, the toxic chemicals for which you
submitted Form Rs or Form A certification statements via CDX,
AND your original signature.
6 Toxics Release Inventory Reporting Forms and Instructions
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General Information
If you have any questions about the electronic submission See "Chemical and Industry Specific Documents" section (p. ix)
process, call 1-888-890-1995 between the hours of 8:00 A.M. - for the document request form and more information on
6:00 P.M. Eastern Time. Alternatively, you may contact the available documents.
CDX Help desk via E-mail at: EPACDX@LMI.ORG. For
additional information about CDX, please see: Questions about completing Form R or Form A may be directed
http ://www. epa. gov/cdx/. to the EPCRA Call Center at the following address or telephone
numbers.
A.8 How to Obtain Forms and Other
. Emergency Planning and Community
IniOrmatlOn Right-to-Know Information Call Center
U.S. Environmental Protection Agency
A copy of both forms is included in this booklet. Remove the 1200 Pennsylvania Ave., S.W. (5101)
appropriate form and produce as many photocopies as needed. Washington, D.C. 20460
Related guidance documents may be obtained from EPA's TRI
Website (http://www.epa.gov/tri) and EPA: (800) 424-9346 or (703) 412-9810;
TDD (800) 553-7672 or TDD (703) 412-3323
U.S. Environmental Protection Agency from 9:00 a.m.- 5:00 p.m. Eastern Time
Ariel Rios Building (Mon.-Fri., except Federal Holidays)
1200 Pennsylvania Ave., N.W.
Attn: TRI Documents EPA Regional Staff also may be of assistance. Refer to
MC: 2844 Appendix G for a list of EPA Regional Offices.
Washington, DC 20460
(202) 564-9554
Email: TRIDOCS@epa.gov
Toxics Release Inventory Reporting Forms and Instructions 7
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General Information
Sample LetterElectronic reporting via the Internet
Facility Name
Facility Address
Facility City/State/Zip Code
TRI Facility ID
CDX ID: RY0100001
Date
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
Attn: Toxic Chemical Release Inventory CDX Submission
To Whom It May Concern:
On Friday, April 13, 2002, the Toxic Release Inventory chemical release reporting information was submitted to the Central
Data Exchange via electronic data transfer. This information was submitted as required under section 313 of the Emergency
Planning and Community Right-to-Know Act of 1986 and the Pollution Prevention Act of 1990, for:
YOUR FACILITY NAME
We are submitting a total of 2 Chemical Report(s) for our facility. These 2 Chemical Report(s) are described below:
Chemical Name Report Year CAS Number Report Type
METHANOL 2001 67-56-1 5-page Form R
DICHLORO-PENTAFLUORO 2001 13474-88-9 2-page Form A
Our technical point of contact is:
[TECHNICAL CONTACT NAME] Phone Number: 252-522-6443
and is available if any questions or problems arise in your processing of the chemical release reporting information.
I hereby certify that I have reviewed the submitted chemical release reporting information and that to the best of my
knowledge and belief, the submitted information is true and complete and that the amounts and values in this report are
accurate based on reasonable estimates using data available to the preparers of this report.
Sincerely,
Signature
8 Toxics Release Inventory Reporting Forms and Instructions
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General Information
Sample Letter Reporting by diskette. Send one copy to EPCRA Reporting Center and one to appropriate state agency
(see Appendix F).
Facility Name
Facility Address
Facility City/State/Zip Code
TRI Facility ID
Date
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
Attn: Toxic Chemical Release Inventory
Magnetic Media Submission
To Whom It May Concern:
Enclosed please find one (1) microcomputer diskette containing toxic chemical release reporting information for:
YOUR FACILITY NAME
This information is submitted as required under section 313 of the Emergency Planning and Community Right-to-Know Act
of 1986 and the Pollution Prevention Act of 1990.
We are submitting a total of 1 Chemical Report(s) for our facility.
These 1 chemical report(s) are described below:
Chemical Name Reporting Year CAS Number Report Type
Zinc (fume or dust) 2001 7440-66-6 5-page Form R
Our technical point of contact is:
[TECHNICAL CONTACT NAME] Phone Number: (505) 555-1212
and is available should any questions or problems arise in your processing of these diskettes.
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted
information is true and complete and that the amounts and values in this report are accurate, based on reasonable estimates
using data available to the preparers of this report.
Sincerely,
Signature
Toxics Release Inventory Reporting Forms and Instructions 9
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B. Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
This section will help you determine whether you must submit
an EPCRA section 313 report. This section discusses EPCRA
section 313 reporting requirements such as the number of full-
time employees, primary SIC code, and chemical activity
threshold quantities. The EPCRA section 313 chemicals and
chemical categories subject to reporting are listed in Table II
(also see 40 CFR 372.65). (See Figure 1 for more information.)
number of hours is equal to the time worked by the workers at
the facility (12,000 hours), plus the time worked by the sales
staff for the facility (6,000 hours), plus the time worked by the
contract employees at the facility (2,000 hours), or 20,000
hours. Dividing the 20,000 hours by 2,000 yields 10 full-time
employees. This facility has met the full time employee criteria
and may be subject to reporting if the other criteria are met.
B.I Full-Time Employee Determination B.2 Primary SIC Code Determination
The number of full-time "employees" is dependent only upon
the total number of hours worked by all employees and other
individuals (e.g., contractors) for the facility during the calendar
year and not the number of persons working. Therefore, a
"full-time employee," for purposes of EPCRA section 313
reporting, is defined as 2,000 work hours per year. This
includes hours worked, paid leave, and holidays. To determine
the number of full-time employees workingforyourfacility, add
up the hours worked by all employees during the calendar year,
including contract employees and sales and support staff
working for the facility, and divide the total by 2,000 hours.
The result is the number of "full time employees." In other
words, if the total number of hours worked by all employees is
20,000 hours or more, your facility meets the ten employee
threshold.
Examples include:
n A facility consists of 11 employees who each worked
1,500 hours for the facility in a calendar year.
Consequently, the total number of hours worked by all
employees for the facility during the calendar year is
16,500 hours. The number of full-time employees for this
facility is equal to 16,500 hours divided by 2,000 hours per
full-time employee, or 8.3 full-time employees. Therefore,
even though 11 persons worked for this facility during the
calendar year, the number of hours worked is equivalent to
8.3 full-time employees. This facility does not meet the
employee criteria and is not subject to EPCRA section 313
reporting.
n Another facility consists of six workers and three sales
staff. The six workers each worked 2,000 hours for the
facility in the calendar year. The sales staff also each
worked 2,000 hours in the calendar year although they
may have been on the road half of the year. In addition,
five contract employees were hired for a period during
which each worked 400 hours for the facility. The total
Standard Industrial Classification (SIC) codes 10 (except 1011,
1081, and 1094), 12 (except 1241), 20-39, 4911 (limited to
facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4939
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4953
(limited to facilities regulated under the RCRA Subtitle C, 42
U.S.C. section 6921 et seq.), 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvent recovery services on a
contract or fee basis) are covered by the rule and are listed in
Table I. The first two digits of a 4-digit SIC code define a
major business sector, while the last two digits denote a
facility's specialty within the major sector. For a detailed
description of 4-digit SIC codes, refer to the "Standard
Industrial Classification Manual 1987." The facility should
determine its own SIC code (s), based on its activities on-site,
using the SIC Manual. State agencies and other organizations
may assign SIC codes on a different basis than the one used by
the SICManual. However,forpurposesofEPCRAsection313
reporting, these state assigned codes should not be used if they
differ from ones assigned using the SIC Manual.
The EPCRA Call Center can assist facilities with determining
which SIC codes are assigned for specific business activities as
referenced in the SIC Manual. Clothbound editions of the SIC
Manual are available in most major libraries or may be ordered
through the National Technical Information Service, 5285 Port
Royal Road, Springfield, VA 22161, (703) 605-6000. The
access numberforthe clothbound manual is PB87-100012, and
the price is $36.00 + shipping and handling.
The North American Industry Classification System (NAICS) is
a new economic classification system that will replace the 1987
SIC code system. EPA will address the SIC code change, as it
relates to EPCRA in an upcoming Federal Register notice. This
upcoming change does NOT affect 2001 EPCRA section 313
reporting.
10 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Does your facility have 10 or more full-time
employees or the equivalent?
(see definition under B.I)
YES
Is your facility's primary SIC Code included on the
EPCRA Section 313 list?
or is your facility a Federal facility?
(see B.2 and Table I)
YES
Does Your Facility Manufacture, Process, or
Otherwise Use Any EPCRA Section 313 Chemicals
and Chemical Categories?
(See Table II. B.3-B.5, andD.l-D.7)
YES
Does Your Facility Exceed Any of the Thresholds for
a Chemical or Chemical Category (after excluding
quantities that are exempt from threshold calculations)
YES
AN EPCRA SECTION 313 REPORT IS
REQUIRED FOR THIS CHEMICAL OR
CHEMICAL CATEGORY
YES
Is the chemical or chemical category identified as
Persistent, Bioaccumulative and Toxic (PBT)?
YES
NO
NO
NO
NO
NO
STOP
NO EPCRA
SECTION 313
REPORTS
REQUIRED FOR
ANY CHEMICALS
Is the amount manufactured, OR processed, OR otherwise used, less than or equal to 1,000,000 pounds
AND is the reportable amount less than or equal to 500 Ibs/yr
NO
YES
FORM R IS REQUIRED FOR THIS CHEMICAL
OR CHEMICAL CATEGORY
(FORM A CANNOT BE SUBMITTED)
FORMA
OR
FORM R IS REQUIRED FOR THIS CHEMICAL
CATEGORY
Figure 1. EPCRA Section 313 Reporting Decision Diagram
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
B.2.a. Multi-Establishment Facilities
Examples include:
Your facility may include multiple establishments that have
different SIC codes. A multi-establishment facility is a facility
that consists of two or more distinct and separate economic
units. If your facility is a multi-establishment facility, calculate
the value of the products produced, shipped, or services
provided from each establishment within the facility and then
use the following rule to determine if your facility meets the SIC
code criterion:
If the total value of the products produced, shipped, or
services provided at establishments with covered SIC
codes, i.e., 10 (except 1011, 1081, and 1094), 12 (except
1241), 20-39,4911 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4931 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4939 (limited to
facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4953
(limited to facilities regulated under the RCRA Subtitle C,
42 U.S.C. section 6921 et seq.), 5169, 5171, or 7389
(limited to facilities primarily engaged in solvents recovery
services on a contract or fee basis) is greater than 50% of
the value of the entire facility's products and services, the
entire facility meets the SIC code criterion.
If any one establishment with a covered SIC code, i.e., 10
(except 1011, 1081, and 1094), 12 (except 1241), 20-39,
4911 (limited to facilities that combust coal and/or oil for
the purpose of generating electricity for distribution in
commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4939 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4953 (limited to
facilities regulated under the RCRA Subtitle C, 42 U.S.C.
section 6921 et seq.), 5169, 5171, or 7389 (limited to
facilities primarily engaged in solvents recovery services
on a contract or fee basis) produces or ships products or
provides services whose value exceeds the value of
products and services produced or shipped by every other
establishment within the facility considered individually,
the facility also meets the SIC code criterion.
The value of production or service attributable to a particular
establishment may be isolated by subtracting the product value
obtained from other establishments within the same facility from
the total product or service value of the facility. This procedure
eliminates the potential for "double counting" production and
services in situations where establishments are engaged in
sequential production or service activities at a single facility.
A facility in coating, engraving and allied services has two
establishments. The first establishment, a general
automotive repair service, is in SIC code 7537, which is
not a covered SIC code. However, the second
establishment, a metal paint shop is in SIC code 3479,
which is a covered SIC code. The metal paint shop paints
the parts received from general automotive repair service.
The facility determines the product is worth $500/unit as
received from the general automotive repair service (in
non covered SIC code 7537) and the value of the product
is $1500/unit after processing by the metal paint shop (in
covered SIC code 3479). The value added by the metal
paint shop is obtained by subtracting the value of the
products from the general automotive repair service from
that of the value of the products of the metal paint shop.
(In this example, the value added = $l,500/unit -
$500/unit = $l,000/unit.) The value added ($l,000/unit)
by the establishment in SIC code 3479 is more than 50%
of the product value. Therefore, the facility's primary SIC
code is 3479, which is a covered SIC code.
A food processing establishment in a facility processes
crops grown at the facility in a separate establishment.
The facility could base the value of the products of each
establishment on the total production value of each
establishment. Alternatively, the facility could first
determine the value of the crops grown at the agricultural
establishment, and then calculate the contribution of the
food processing establishment by subtracting the crop
value from the total value of the product shipped from the
processing establishment (value of product shipped from
processing - crop value = value of processing
establishment).
A covered multi-establishment facility must make EPCRA
section 313 chemical threshold determinations and, if required,
must report all relevant information about releases and other
waste management activities, and source reduction activities
associated with an EPCRA section 313 chemical for the entire
facility, even from establishments that are not in covered SIC
codes (i.e., the covered SIC codes are 10 (except 1011, 1081,
and 1094), 12 (except 1241), 20-39, 4911 (limited to facilities
that combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4931 (limited to
facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4939
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4953
(limited to facilities regulated under the RCRA Subtitle C, 42
U.S.C. section 6921 et seq), 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvents recovery services on a
contract or fee basis)). EPA realizes, however, that certain
establishments in a multi-establishment facility can be, for all
12 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
practical purposes, separate business units. Therefore, while
threshold determinations must be made for the entire facility,
individual establishments may report releases and other waste
management activities separately, provided that the total
releases and other waste management quantities for the whole
facility are represented by the sum of the releases and other
quantities managed as waste reported by each of the separate
establishments and the compliance determination is based on the
entire facility.
B.2.b. Auxiliary Facilities
An auxiliary facility is one that supports another covered
establishment's activities (e.g., research and development
laboratories, warehouses, and storage facilities). An auxiliary
facility can assume the SIC code of another covered
establishment if its primary function is to service that other
covered establishment's operations. For the purposes of
EPCRA section 313, auxiliary facility is defined as one
primarily engaged in performing support services for another
covered establishment or multiple establishments of a covered
facility and is in a different physical location than the primary
facility. In addition, an auxiliary facility performs an integral
role in the primary facility's activities. In general, an auxiliary
facility's basic administrative services (paperwork, payroll,
employment) are performed by the primary facility. Thus, a
separate warehouse facility (i.e., one not located within the
physical boundaries of a covered facility) may become a
covered facility because it services a covered establishment in
SIC codes 10 (except 1011,1081, and 1094), 12 (except 1241),
20-39,4911 (limited to facilities that combust coal and/or oil for
the purpose of generating electricity for distribution in
commerce), 4931 (limited to facilities that combust coal and/or
oil for the purpose of generating electricity for distribution in
commerce), 4939 (limited to facilities that combust coal and/or
oil for the purpose of generating electricity for distribution in
commerce), 4953 (limited to facilities regulated under the
RCRA Subtitle C, 42U.S.C. section 6921 etseq.), 5169, 5171,
and 7389 (limited to facilities primarily engaged in solvents
recovery services on a contract or fee basis). Auxiliary facilities
that are in these aforementioned codes are required to report if
they meet the employee criterion and reporting thresholds for
manufacture, process, or otherwise use.
B.2.c. Property Owners
You are not required to report if you merely own real estate on
which a facility covered by this rule is located; that is, you have
no other business interest in the operation of that facility (e.g.,
your company owns an industrial park). The operator of that
facility, however, is subject to reporting requirements.
B.3 Activity Determination
B.S.a. Definitions of "Manufacture,'
and "Otherwise Use"
'Process,'
Manufacture: The term "manufacture" means to produce,
prepare, compound, or import an EPCRA section 313 chemical.
(See Part II, Section 3.1 of these instructions for further
clarification.)
Import is defined as causing the EPCRA section 313 chemical
to be imported into the customs territory of the United States.
If you order an EPCRA section 313 chemical (or a mixture
containing the chemical) from a foreign supplier, then you have
imported the chemical when that shipment arrives at your
facility directly from a source outside of the United States. By
ordering the chemical, you have "caused it to be imported,"
even though you may have used an import brokerage firm as an
agent to obtain the EPCRA section 313 chemical.
Do Not Overlook Coincidental Manufacture
The term manufacture also includes coincidental production of
an EPCRA section 313 chemical (e.g., as a byproduct or
impurity) as a result of the manufacture, processing, otherwise
use, treatment, disposal or other waste management of other
chemical substances. In the case of coincidental production of
an impurity (i.e., an EPCRA section 313 chemical that remains
in the product that is distributed in commerce), the de minimis
exemption, discussed in Section B.3.c of these instructions,
applies. The de minimis exemption does not apply to
byproducts (e.g., an EPCRA section 313 chemical that is
separated from a process stream and further processed or
disposed). Certain EPCRA section 313 chemicals may be
manufactured as a result of wastewater treatment or other
treatment processes. For example, neutralization of wastewater
containing nitric acid can result in the coincidental manufacture
of a nitrate compound (solution), reportable as a member of the
nitrate compounds category.
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Example 1: Coincidental Manufacture
Your company, a nitric acid manufacturer, uses aqueous ammonia in a waste treatment system to neutralize an acidic
wastewater stream containing nitric acid. The reaction of ammonia and nitric acid produces a solution of ammonium nitrate.
Ammonium nitrate (solution) is reportable under the nitrate compounds category and is manufactured as a byproduct. If
the ammonium nitrate is produced in a quantity that exceeds the 25,000-pound manufacturing threshold, the facility must
report under the nitrate compounds category.
The aqueous ammonia is considered to be otherwise used and 10% of the total aqueous ammonia would be counted towards
the 10,000-pound otherwise use threshold. Reports for releases of ammonia must also include 10% of the total aqueous
ammonia from the solution of ammonium nitrate (see the qualifier for the ammonia listing).
As another example, combustion of coal or other fuel in boilers/furnaces can result in the coincidental manufacture of metal
category compounds and sulfuric acid (acid aerosols), hydrochloric acid (acid aerosols), and hydrogen fluoride.
Process: The term "process" means the preparation of a EPCRA section 313 chemicals in the same physical state or
listed EPCRA section 313 chemical, after its manufacture, for chemical form as that received by your facility, or preparation
distribution in commerce. Processing is usually the that produces a change in physical state or chemical form.
incorporation of an EPCRA section 313 chemical into a The term also applies to the processing of a mixture or other
product (see Part II, Section 3.2 of these instructions for trade name product (see Section B.4.b of these instructions)
further clarification). Processing includes preparation of the that contains a listed EPCRA section 313 chemical as one
component.
Example 2: Typical Process and Manufacture Activities
Your company receives toluene, an EPCRA section 313 chemical, from another facility, and reacts the toluene with air
to formbenzoic acid, which the company distributes in commerce. Your company processes toluene and manufactures
and processes benzoic acid. Benzoic acid, however, is not an EPCRA section 313 chemical and thus does not trigger
reporting requirements.
Your facility combines toluene purchased from a supplier with various materials to form paint which it then sells. Your
facility processes toluene.
Your company receives a nickel compound (nickel compounds is a listed EPCRA section 313 chemical category) as
a bulk solid and performs various size-reduction operations (e.g., grinding) before packaging the compound in 50-
pound bags, which the company sells. Your company processes the nickel compound.
Your company receives a prepared mixture of resin and chopped fiber to be used in the injection molding of plastic
products. The resin contains a listed EPCRA section 313 chemical that becomes incorporated into the plastic, which
the company distributes in commerce. Your facility processes the EPCRA section 313 chemical.
In the combustion of coal or oil, metal category compounds may be produced from either the parent metal or a metal
compound contained in the coal or oil. If a metal undergoes a change of valence, a metal compound is considered to
be manufactured. For example, during the combustion process copper in valence state zero changes to copper in
valence state +2 in a compound such as copper (II) oxide (CuO). Furthermore, a metallic compound could be
transformed to another metallic compound without a change in valency (e.g., copper (II) chloride (CuCl) is transformed
to copper (II) oxide). The transformation to a new compound by combustion without a change in valence state is also
considered to be "manufactured" for purposes of EPCRA section 313.
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Otherwise Use: The term "otherwise use" means any use of
an EPCRA section 313 chemical, including an EPCRA
section 313 chemical contained in a mixture or other trade
name product or waste, that is not covered by the terms
"manufacture" or "process." Otherwise use of an EPCRA
section 313 chemical does not include disposal, stabilization
(without subsequent distribution in commerce), or treatment
for destruction unless:
(1) The EPCRA section 313 chemical that was disposed,
stabilized, or treated for destruction was received from off-
site for the purposes of further waste management;
or
(2) The EPCRA section 313 chemical that was disposed,
stabilized, or treated for destruction was manufactured as a
result of waste management activities on materials received
from off-site for the purposes of waste management activities.
Relabeling or redistributing of the EPCRA section 313
chemical where no repackaging of the EPCRA section 313
chemical occurs does not constitute an otherwise use or
processing of the EPCRA section 313 chemical." (See 62 FR
23846 and Part II, Section 3.3 of these instructions for further
clarification).
Example 3: Typical Otherwise Use Activities
When your facility cleans equipment with toluene, you are otherwise using toluene. Your facility also separates two
components of a mixture by dissolving one component in toluene, and subsequently recovers the toluene from the
process for reuse or disposal. Your facility otherwise uses toluene.
A covered facility receives a waste containing 12,000 pounds of Chemical A, a non-PBT EPCRA section 313 chemical,
from off-site. The facility treats the waste, destroying Chemical A and in the treatment process manufactures 10,500
pounds of Chemical B, another non-PBT EPCRA section 313 chemical. Chemical B is disposed on-site. Since the
waste containing Chemical A was received from off-site for the purpose of waste management, the amount of Chemical
A must be included in the otherwise use threshold determination for Chemical A. The otherwise use threshold for a non-
PBT chemical is 10,000 pounds and since the amount of Chemical A exceeds this threshold, all releases and other waste
management activities for Chemical A must be reported. Chemical B was manufactured in the treatment of a waste
received from off-site. The facility disposed of Chemical B on-site. Since Chemical B was generated from waste
received from off-site for treatment for destruction, disposal, or stabilization, the disposal of Chemical B is considered
to be an otherwise use. Thus, the amount of Chemical B must be considered in the otherwise use threshold
determination. Thus, the reporting threshold for Chemical B has also been exceeded and all releases and other waste
management activities for Chemical B must be reported.
B.S.b. Persistent Bioaccumulative
Toxic (PBT) Chemicals and
Chemical Categories Overview
On October 29, 1999 EPA published a final rule (64 FR
58666) adding certain chemicals and chemical categories to
the EPCRA section 313 list of toxic chemicals and lowering
the reporting threshold for persistent bioaccumulative toxic
(PBT) chemicals. In addition, on January 17, 2001 EPA
published a final rule (66 FR 4500) that classified lead and
lead compounds as PBT chemicals and lowered their
reporting thresholds. The lower reporting thresholds for lead
applies to all lead except when lead is contained in a stainless
steal, brass or bronze alloy.
Dioxinand dioxin-like compounds, lead compounds, mercury
compounds and poly cyclic aromatic compounds (PACs) are
the four PBT chemical categories with lower reporting
thresholds. The 17 members of the dioxin and dioxin-like
compounds category and the 21 members of the PACs
category are listed in Table He. of these instructions. The
dioxin and dioxin-like compounds category has the qualifier,
"Manufacturing; and processing or otherwise use of dioxin
and dioxin-like compounds if the dioxin and dioxin-like
compounds are present as contaminants in a chemical and if
they were created during the manufacture of that chemical."
EPA has added six individual chemicals to the EPCRA
section 313 list of toxic chemicals that also had their
thresholds lowered: benzo(g,h,i)perylene, benzo(j,k)fluorene
(fluoranthene), 3-methylcholanthrene, octachlorostyrene,
pentachlorobenzene, and tetrabromobisphenol A (TBBPA).
Benzo(j,k)fluorene and 3-methylcholanthrene were added as
members of the polycyclic aromatic compounds (PACs)
chemical category.
EPA lowered the reporting thresholds for PBT chemicals to
either 100 pounds, 10 pounds, orinthe case of the dioxin and
dioxin-like compounds chemical category, to 0.1 gram. The
table at the beginning of Section B.4 of these instructions lists
Toxics Release Inventory Reporting Forms and Instructions 15
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
the applicable manufacture, process, and otherwise use
thresholds for the listed PBT chemical.
EPA eliminated the de minimis exemption for all PBT
chemicals (except lead when contained in stainless steel,
brass or bronze alloy). However, this action does not affect
the applicability of the de minimis exemption to the supplier
notification requirements (40 CFR 372.45(d)(l).
All PBT chemicals and chemical categories (hereafter
referred to as simply PBT chemicals) are excluded from
eligibility for the alternate threshold of one million pounds
and thus the Form A cannot be used for PBT chemicals. In
addition, PBT chemicals are ineligible for range reporting for
on-site releases and transfers off site for further waste
management. This will not affect the applicability of range
reporting of the maximum amount on site as required by
EPCRA section 313(g).
All releases and other waste management quantities greater
than 0.1 pounds of a PBT chemical (except the dioxin and
dioxin-like compounds chemical category) should be
reported at a level of precision supported by the accuracy of
the underlying data and estimation techniques on which the
estimate is based. For quantities of 10 pounds or greater,
only whole numbers are required to be reported. If a
facility's release or other waste management estimates
support reporting an amount that is more precise than whole
numbers, then the more precise amount should be reported.
For the dioxin and dioxin-like compounds chemical category,
which has a reporting threshold of 0.1 gram, facilities need
only report all release and other waste management quantities
greater than 100 micrograms (i.e., 0.0001 grams).
Notwithstanding the numeric precision used when
determining reporting eligibility thresholds, facilities should
report on Form R to the level of accuracy that their data
supports, up to seven digits to the right of the decimal. EPA's
reporting software and data management systems support
data precision to seven digits to the right of the decimal. If a
facility has information on the distribution of dioxin and
dioxin-like compounds, the facility must report either the
distribution that best represents the distribution of the total
quantity of dioxin and dioxin-like compounds released to all
media, or the facility's one best media specific distribution in
Part II, Section 1.4, of the Form R (40 CFR Section
372.85(b)(15)(ii).
Lead and Lead Compounds
Beginning January 1, 2001, lead and lead compounds are
classified as PBT chemicals and are subject to the lower
manufacturing, processing and otherwise use threshold of 100
pounds. However, when lead is contained in stainless steel,
brass, or bronze alloys it is subject to the higher 25,000
pound manufacturing and processing thresholds and the
10,000 pound otherwise use threshold. Listed below are
some important guidelines to use when calculating threshold
and release and other waste management quantities:
1) quantities of lead not contained in stainless
steel, brass or bronze alloy are applied to both the 100
pound threshold and the 25,000/10,000 pound thresholds;
2) quantities of lead that are contained in stainless
steel, brass or bronze alloys are only applied toward the
25,000/10,000 pound thresholds;
3) a facility may take the de minimis exemption for
those quantities of lead in stainless steel, brass, or bronze
alloys that meet the de minimis standard (e.g., manufactured
as an impurity). Accordingly, the de minimis exemption may
be considered for quantities of lead in stainless steel, brass, or
bronze alloys but it may not be considered for lead not in
stainless steel, brass, or bronze alloys;
4) Form A, range reporting in Sections 5 and 6 of
the Form R and the use of whole numbers and 2 significant
digits may not be applied to lead reporting once the lower,
100 pound threshold has been exceeded. Therefore, if a
facility exceeds the 25,000/10,000 pound threshold but does
not exceed the 100 pound threshold, the facility may consider
Form A, range reporting in Sections 5 and 6 of the Form R,
and the use of whole numbers and 2 significant digits. Once
the 100 pound threshold is exceeded, however, the facility
may not consider Form A, range reporting in Sections 5 and
6 of the Form R and the use of whole numbers and 2
significant digits even if the 25,000/10,000 pound threshold
is also exceeded; and
5) consolidated reporting between lead and lead
compounds is allowed only on Form R because Form A is
never allowed when reporting lead compounds.
B.S.c. Activity Exemptions
Otherwise Use Exemptions. Certain otherwise uses of listed
EPCRA section 313 chemicals are specifically exempted:
Otherwise use as a structural component of the
facility;
Otherwise use in routine janitorial or facility
grounds maintenance;
Personal uses by employees or other persons;
16 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Otherwise use of products containing EPCRA
section 313 chemicals for the purpose of
maintaining motor vehicles operated by the facility;
or
Otherwise use of EPCRA section 313 chemicals
contained in intake water (used for processing or
non-contact cooling) or in intake air (used either as
compressed air or for combustion).
The exemption of an EPCRA section 313 chemical otherwise
used 1) as a structural component of the facility; or 2) in
routine janitorial or facility grounds maintenance; or 3) for
personal use by an employee cannot be taken for activities
involving process-related equipment.
Articles Exemption. EPCRA section 313 chemicals
contained in articles that are processed or otherwise used at
a covered facility are exempt from threshold determinations
and release and other waste management calculations. The
exemption applies when the facility receives the article from
another facility or when the facility produces the article itself.
The exemption applies only to the quantity of EPCRA section
313 chemical present in the article. If the EPCRA section
313 chemical is manufactured (including imported),
processed, or otherwise used at the covered facility other than
as part of the article, in excess of an applicable threshold
quantity, the facility is required to report (40 CFR Section
372.38(b)). For an EPCRA section 313 chemical in an item
to be exempt as part of the article, the item must meet all the
following criteria in the EPCRA section 313 article
definition; that is, it must be a manufactured item (1) which
is formed to a specific shape or design during manufacture,
(2) which has end use functions dependent in whole or in part
upon its shape or design during end use, and (3) which does
not release a toxic chemical under normal conditions of
processing or otherwise use of the item at the facility.
If the processing or otherwise use of all like items results in
a total release of 0.5 pound or less of an EPCRA section 313
chemical in a reporting year to any environmental medium,
EPA will allow this release to be rounded to zero, and the
manufactured items retain their article status. The 0.5 pound
threshold does not apply to each individual article, but applies
to the sum of all releases from processing or otherwise use of
all like articles. If all the releases of like articles over a
reporting year are completely captured and recycled/reused
on-site or off-site, those items retain their article status. Any
amount that is released and is not recycled/reused will count
toward the 0.5 pound per year cut-off value.
The articles exemption applies to the normal processing or
otherwise use of articles. This exemption does not apply to
the manufacture of the article. EPCRA section 313 chemicals
incorporated into articles produced at a facility must be
factored into threshold determinations and release and other
waste management calculations.
If, in the course of processing or otherwise use, an item
retains its initial thickness or diameter, in whole or in part, it
meets the first part (i.e., it must be a manufactured item
which is formed to a specific shape or design during
manufacture) of the article definition. If the item's basic
dimensional characteristics are totally altered during
processing or otherwise use, the item does not meet the first
part of the definition. An example of items that do not meet
the definition would be items which are cold extruded, such
as lead ingots, which are formed into wire or rods. On the
other hand, cutting a manufactured item into pieces which are
recognizable as the article would not change the original
dimensions as long as the diameter or the thickness of the
item remained the same; the articles exemption would
continue to apply. Metal wire may be bent and sheet metal
may be cut, punched, stamped, or pressed without losing their
article status as long as the diameter of the wire or tubing or
the thickness of the sheet is not totally changed.
An important aspect of the articles exemption is what
constitutes a release of an EPCRA section 313 chemical.
Any processing or otherwise use of like articles that results in
a release to the environment (of more than 0.5 pounds)
negates the article status and precludes eligibility for the
exemption. Cutting, grinding, melting, or other processing of
manufactured items could result in a release of an EPCRA
section 313 chemical during normal conditions of processing
or otherwise use and therefore negate the exemption as
articles.
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Example 4: Articles Exemption
Nickel that is incorporated into a brass doorknob is processed to manufacture the brass doorknob, and therefore must
be counted toward threshold determinations and release and other waste management calculations. However, the use
of the brass doorknobs elsewhere in the facility does not have to be counted. Disposal of the brass doorknob after its
use does not constitute a "release;" thus, the brass doorknob remains an article.
If an item used in the facility is fragmented, the item is still an article if those fragments being discarded remain
identifiable as the article (e.g., recognizable pieces of a cylinder, pieces of wire). For instance, an eight-foot piece of
wire is cut into two four-foot pieces of wire, without releasing any EPCRA section 313 chemicals. Eachfour-foot piece
is identifiable as a piece of wire; therefore, the article status for these pieces of wire remains intact.
EPCRA section 313 chemicals received in the form of pellets are not articles because the pellet form is simply a
convenient form for further processing of the material.
De Minimis Exemption. The de minimis exemption allows
facilities to disregard certain minimal concentrations of non-
PBT chemicals in mixtures or other trade name products they
process or otherwise use when making threshold determinations
and release and other waste management calculations. The de
minimis exemption does not apply to the manufacture of an
EPCRA section 313 chemical except if that EPCRA section 313
chemical is manufactured as an impurity and remains in the
product distributed in commerce, or if the EPCRA section 313
chemical is imported below the appropriate de minimis level.
The de minimis exemption does not apply to a byproduct
manufactured coincidentally as a result of manufacturing,
processing, otherwise use, or any waste management activities.
The de minimis exemption does not apply to any PBT chemical
(except lead when it is contained in stainless steel, brass or
bronze alloy) or PBT chemical category. A list of PBT
chemicals may be found in Section B.4 of these instructions.
When determining whether the de minimis exemption applies to
an EPCRA section 313 chemical, the owner/operator should
consider only the concentration of the non-PBT EPCRA section
313 chemical in mixtures and other trade name products in
process streams in which the EPCRA section 313 chemical is
undergoing a reportable activity. If the non-PBT EPCRA section
313 chemical in a process stream is manufactured as an
impurity, imported, processed, or otherwise used and is below
the appropriate de minimis concentration level, then the quantity
of the non-PBT EPCRA section 313 chemical in that process
stream does not have to be applied to threshold determinations
nor included in release or other waste management
determinations. If a non-PBT EPCRA section 313 chemical in
a process stream is below the appropriate de minimis level, all
releases and other waste management activities associated with
the EPCRA section 313 chemical in that stream are exempt from
EPCRA section 313 reporting. It is possible to meet an activity
(e.g., processing) threshold for an EPCRA sections 13 chemical
on a facility-wide basis, but not be required to calculate releases
or other waste management quantities associated with a
particular process because that process involves only mixtures
or other trade name products containing the non-PBT EPCRA
section 313 chemical below the de minimis level.
Once a non-PBT EPCRA section 313 chemical concentration is
at or above the appropriate de minimis level in the process
stream, threshold determinations and release and other waste
management calculations must be made, even if that chemical
later falls below the de minimis level in the same process stream.
Thus, all releases and other quantities managed as waste that
occur after the de minimis level has been met or exceeded are
subject to reporting. If an EPCRA section 313 chemical in a
mixture or other trade name product at or above de minimis is
brought on-site, the de minimis exemption never applies.
De minimis levels for non-PBT EPCRA section 313 chemicals
and chemical categories are set at concentration levels of either
1% or 0.1%; PBT chemicals and chemical categories do not
have de minimis levels with regard to this exemption. The 0.1%
de minimis levels are dictated by determinations made by the
National Toxicology Program (NTP), Annual Report on
Carcinogens, the International Agency for Research and Cancer
(IARC) Monographs, or 29 CFR part 1910, subpart Z.
Therefore, once a non-PBT chemical's status under NTP, IARC,
or 29 CFR part 1910, subpart Z indicates that the chemical is a
carcinogen or potential carcinogen, the reporting facility may
disregard levels of the chemical below the 0.1% de minimis
concentration provided that the other criteria for the de minimis
exemption are met. De minimis levels for chemical categories
apply to the total concentration of all chemicals in the
category within a mixture, not the concentration of each
individual category member within the mixture.
De Minimis Application to the Processing or
Otherwise Use of a Mixture
The de minimis exemption applies to the processing or otherwise
use of a non-PBT EPCRA section 313 chemical in a mixture.
Threshold determinations and release and other waste
management calculations begin at the point where the chemical
meets or exceeds the de minimis level. If a non-PBT EPCRA
18 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
section 313 chemical is present in a mixture at a concentration Concentration Ranges Straddling the De Minimis Value
below the de minimis level, this quantity of the substance does
not have to be included for threshold determinations, release and There may be instances in which the concentration of a non-
other waste management reporting, or supplier notification PBT chemical is given as a range straddling the de minimis
requirements. The exemption will apply as long as the mixture limit. Example 6 illustrates how the de minimis exemption
containing de minimis amounts of a non-PBT EPCRA section should be applied in such a scenario.
313 chemical never equals or goes above the de minimis limit.
Example 5: De Minimis Applications to Process and Otherwise Use Scenarios for Non-PBT Chemicals
There are many cases in which the de minimis "limit" is crossed or recrossed by non-PBT chemicals within a process or otherwise
use scenario. The following examples are meant to illustrate these complex reporting scenarios.
Increasing Concentration To or Above De Minimis Levels During Processing for Non-PBT Chemicals
A manufacturing facility receives toluene that contains chlorobenzene at a concentration below its de minimis limit. Through
distillation, the chlorobenzene content in process streams is increased over the de minimis concentration of 1%. From the point
at which the chlorobenzene concentration equals 1% in process streams, the amount present must be factored into threshold
determinations and release and other waste management estimates. The facility does not need to consider the amount of
chlorobenzene in the raw material, i.e., when below de minimis levels, when making threshold determinations. The facility does
not have to report emissions of chlorobenzene from storage tanks or any other equipment associated with that specific process
where the chlorobenzene content is less than 1%.
Fluctuating Concentration During Processing for Non-PBT Chemicals
A manufacturer produces an ink product that contains toluene, an EPCRA section 313 chemical, below the de minimis level. The
process used causes the percentage of toluene in the mixture to fluctuate: it rises above the de minimis level for a time but drops
below the level as the process winds down. The facility must consider the chemical toward threshold determinations from the
point at which it first equals the de minimis limit. Once the de minimis limit has been met the exemption cannot be taken.
Toxics Release Inventory Reporting Forms and Instructions 19
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Example 6: Concentration Ranges Straddling the De Minimis Value
A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1.25% manganese. Manganese is eligible for
the de minimis exemption at concentrations up to 1%. The amount of mixture subject to reporting is the quantity containing
manganese at or above the de minimis concentration:
[(8,000,000) x (1.25% - 0.99%)] + (1.25% - 0.25%)
The average concentration of manganese that is not exempt (above the de minimis) is:
(1.25%+1.00%)-(2)
(8,000,000) x (1.25%-0.99%)
(1.25%-0.25%)
(1.25%+1.00%)
(2)
= 23,400 pounds
Therefore, the amount of manganese that is subject to threshold determination and release and other waste management
estimates is:
= 23,400 pounds manganese (which is below the processing threshold for manganese)
In this scenario, because the facility's information pertaining to manganese was available to two decimal places, 0.99 was used
to determine the amount below the de minimis concentrations. If the information was available to one decimal place, 0.9 should
be used, as in the scenario below.
As in the previous example, manganese is present in a mixture, of which 8,000,000 pounds is processed. TheMSDS
states the mixture contains 0.2% to 1.2% manganese. The amount of mixture subject to reporting (at or above de minimis limit)
is:
[(8,000,000) x (1.2% - 0.9%)] + (1.2% - 0.2%)
The average concentration of manganese that is not exempt (at or above de minimis limit) is:
(1.2%+1.0%)+ (2)
Therefore, the amount of manganese that is subject to threshold determinations and release and other waste management
estimates is:
(8,000,000) x (1.2%-0.9%)
(1.2%+1.0%)
(2)
= 26,400 pounds
= 26,400 pounds manganese (which is above the processing threshold for manganese)
20 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Example 7: De Minimis Application in the Coincidental Manufacture in a Mixture
Coincidental Manufacture as a Product Impurity
Toluene-2,4-diisocyanate reacts with trace amounts of waterto form trace quantities of 2,4-diaminotoluene. The resulting product
contains 99% toluene-2,4-diisocyanate and 0.05% 2,4-diaminotoluene. The 2,4-diaminotoluene would not be subject to EPCRA
section 313 reporting nor would supplier notification be required because the concentration of 2,4-diaminotoluene is below its
de minimis limit of 0.1% in the product. Coincidental manufacture/production refers only to production of a chemical via a
chemical reaction. It would not include separation of a byproduct from a purchased mixture during a processing operation.
Coincidental Manufacture as a Commercial Byproduct and Impurity
Chloroform is a reaction byproduct in the production of carbon tetrachloride. It is removed by distillation to a concentration of
less than 150 ppm (0.0150%) remaining in the carbon tetrachloride. The separated chloroform at 90% concentration is sold as
a byproduct. Chloroform is subject to a 0.1% (1000 ppm) de minimis limit. Any amount of chloroform manufactured and
separated as byproduct must be included in threshold determinations because the de minimis exemption does not apply to
manufacture of a chemical as a byproduct. Releases of chloroform prior to and during purification of the carbon tetrachloride
should be reported. The de minimis exemption can, however, be applied to the chloroform remaining in the carbon tetrachloride
as an impurity. Because the concentration of chloroform remaining in the carbon tetrachloride is below the de minimis limit, this
quantity of chloroform is exempt from threshold determinations, release and other waste management reporting, and supplier
notification.
Coincidental Manufacture as a Waste Byproduct
A small amount of formaldehyde is manufactured as a reaction byproduct during the production of phthalic anhydride. The
formaldehyde is separated from the phthalic anhydride as a waste gas and burned, leaving no formaldehyde in the phthalic
anhydride. The amount of formaldehyde produced and removed must be included in threshold determinations and release and
other waste management estimates even if the formaldehyde were present below the de minimis level in the process stream where
it was manufactured or in the wastestream to which it was separated.
De Minimis Application in the Manufacture The de minimis exemption also does not apply to situations
of the Listed Chemical in a Mixture where the manufactured chemical is released or transferred to
wastestreams and thereby diluted to below the de minimis level.
The de minimis exemption generally does not apply to the
manufacturing of anEPCRA section 313 chemical. However, the Laboratory Activities Exemption. EPCRA section 313
de minimis exemption may apply to mixtures and other trade chemicals that are manufactured, processed, or otherwise used
name products containing non-PBT EPCRA section 313 in a laboratory at a covered facility under the direct supervision
chemicals that are imported into the United States. (See example of a technically qualified individual do not have to be
5 on page 19.) considered for threshold determinations and release and other
waste management calculations. However, pilot plant scale and
Another exception applies to non-PBT EPCRA section 313 specialty chemical production does not qualify for this
chemicals that are coincidentally manufactured as impurities that laboratory activities exemption, nor does the use of EPCRA
remain in the product distributed in commerce below the de section 313 chemicals for laboratory support activities, such as
minimis levels. The amount remaining in the product is exempt the use of chemicals for equipment maintenance.
from threshold determinations. If the chemical is separated from
the final product, it cannot qualify for the exemption. Any Coal Extraction Activities Exemption. If an EPCRA section
amount that is separated, or is separate, from the product, is 313 chemical is manufactured, processed, or otherwise used in
considered abyproduct and is subject to threshold determinations extraction by facilities in SIC code 12, a person is not required
and release and other waste management calculations. Any to consider the quantity of the EPCRA section 313 chemical so
amount of an EPCRA section 313 chemical that is manufactured manufactured, processed, or otherwise used when considering
in a wastestream must be considered toward threshold threshold determinations and release and other waste
determinations and release and other waste management management calculations (See example 8). Reclamation
calculations and accounted for on Form R. activities occurring simultaneously with coal extraction
activities (e.g., cast blasting) are included in the exemption.
However, otherwise use of ash, waste rock, or fertilizer for
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
reclamation purposes are not considered part of extraction; non-
exempt amounts of EPCRA section 313 chemicals contained in
these materials must be considered toward threshold
determinations and release and other waste management
calculations.
Metal Mining Overburden Exemption. If an EPCRA section
313 chemical that is a constituent of overburden is processed or
otherwise used by facilities in SIC code 10, a person is not
required to consider the quantity of the EPCRA section 313
chemical so processed or otherwise used when considering
threshold determinations and release and other waste
management calculations.
For purposes of EPCRA section 313 reporting, overburden is the
unconsolidated material that overlies a deposit of useful material
or ore. It does not include any portion of the ore or waste rock.
Example 8: Coal mining extraction activities
Included among these are explosives for blasting operations,
solvents, lubricants, and fuels for extraction related equipment
maintenance and use, as well as overburden and mineral
deposits. The EPCRA section 313 chemicals contained in
these materials are exempt from threshold determinations and
release and other waste management calculations, when
processed or otherwise used during extraction activities at
coal mines.
B.4 Threshold Determinations
EPCRA section 313 reporting is required if threshold quantities
are exceeded. Separate thresholds apply to the amount of the
EPCRA section 313 chemical that is manufactured, processed or
otherwise used.
You must submit a report for any EPCRA section 313 chemical,
which is not listed as a PBT chemical, that is manufactured or
processed at your facility in excess of the following threshold:
25,000 pounds per toxic chemical or category over the
calendar year.
You must submit a report for any EPCRA section 313 chemical,
which is not listed as a PBT chemical, that is otherwise used at
your facility in excess of the following threshold:
10,000 pounds per toxic chemical or category over the
calendar year.
You must submit a report for any EPCRA section 313 chemical,
which is listed as a PBT chemical, that is manufactured,
processed or otherwise used at your facility above the
designated threshold for that chemical.
The chemical names, CAS numbers and their reporting
thresholds are listed in the table below. See Table He
of these instructions for lists of individual members of
the dioxin and dioxin-like compounds chemical
category and the polycyclic aromatic compounds
chemical category.
Chemical or chemical
category name
Aldrin
Benzo [g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds category
(manufacturing; and the
processing or otherwise use
of dioxin and dioxin-like
compounds category if the
dioxin and dioxin-like
compounds are present as
contaminants in a chemical
and if they were created
during the manufacturing of
that chemical
Heptachlor
Hexachlorobenzene
Isodrin
Lead (this lower threshold
does not apply to lead when
contained in stainless steal,
brass or bronze alloy)
Lead compounds
Mercury
Mercury compounds
Methoxychlor
(table continued on next page)
CAS
number or
chemical
category
code
309-00-2
191-24-2
57-74-9
N150
76-44-8
118-74-1
465-73-6
7439-92-1
N420
7439-97-6
N458
72-43-5
Threshold
(pounds,
unless
noted
otherwise)
100
10
10
0.1 gram
10
10
10
100
100
10
10
100
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Chemical or chemical
category name
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Polychlorinated biphenyls
(PCBs)
Polycyclic aromatic
compounds category
(PACs)
Tetrabromobisphenol A
Toxaphene
Trifluralin
CAS
number or
chemical
category
code
29082-74-4
40487-42-1
608-93-5
1336-36-3
N590
79-94-7
8001-35-2
1582-09-8
Threshold
(pounds,
unless
noted
otherwise)
10
100
10
10
100
100
10
100
B.4.a. How to Determine if Your
Facility Has Exceeded Thresholds
To determine whether your facility has exceeded an EPCRA
section 313 reporting threshold, compare quantities of EPCRA
section 313 chemicals that you manufacture, process, or
otherwise use to the respective thresholds for those activities. A
worksheet is provided in Figure 2A to assist facilities in
determining whether they exceed any of the reporting thresholds
for non-PBT chemicals; Figures 2B-D provide worksheets for
PBT chemicals. This worksheet also provides a format for
maintaining reporting facility records. Use of this worksheet is
not required and the completed worksheet(s) should not
accompany Form R reports submitted to EPA and the State.
Complete the appropriate worksheet for each EPCRA section
313 chemical or chemical category. (The worksheets can be
found at the end of section B.4.) Base your threshold
determination for EPCRA section 313 chemicals with qualifiers
only on the quantity of the EPCRA section 313 chemical
satisfying the qualifier.
Use of the worksheets is divided into three steps:
Step 1 allows you to record the gross amount of the EPCRA
section 313 chemical or chemical category involved in activities
throughout the facility. Pure forms as well as the amounts of the
EPCRA section 313 chemical or chemical category present in
mixtures or other trade name products must be considered. The
types of activity (i.e., manufacturing, processing, or otherwise
using) for which the EPCRA section 313 chemical is used must
be identified because separate thresholds apply to each of these
activities. A record of the information source(s) used should be
kept. Possible information sources include purchase records,
inventory data, and calculations by a process engineer. The
data collected in Step 1 will be totaled for each activity to
identify the overall amount of the EPCRA section 313 chemical
or chemical category manufactured (including imported),
processed, or otherwise used.
Step 2 allows you to identify uses of the EPCRA section 313
chemical or chemical category that were included in Step 1 but
are exempt under EPCRA section 313. Do not include in Step
2 exempt quantities of the EPCRA section 313 chemical not
included in the calculations in Step 1. For example, if Freon
contained in the building's air conditioners was not reported in
Step 1, you would not include the amount as exempt in Step 2.
Step 2 is intended for use when a quantity or use of the EPCRA
section 313 chemical is exempt while other quantities require
reporting. Note the type of exemption for future reference.
Also identify, if applicable, the fraction or percentage of the
EPCRA section 313 chemical present that is exempt. Add the
amounts in each activity to obtain a subtotal for exempted
amounts of the EPCRA section 313 chemical or chemical
categories at the facility.
Step 3 involves subtracting the result of Step 2 from the results
of Step 1 for each activity. Compare this net sum to the
applicable activity threshold. If the threshold is met or
exceeded for any of the three activities, a facility must submit
a Form R for that EPCRA section 313 chemical or chemical
category. Do not sum quantities of the EPCRA section 313
chemical that are manufactured, processed, and otherwise used
at your facility, because each of these activities requires a
separate threshold determination. For example, if in a calendar
year you processed 20,000 pounds of a non-PBT EPCRA
section 313 chemical and you otherwise used 6,000 pounds of
that same chemical, your facility has not met or exceeded any
applicable threshold and thus is not required to report for that
chemical.
Worksheets should be retained to document your determination
for reporting or not reporting, but should not be submitted with
the report.
You must submit a report if you exceed any threshold for any
EPCRA section 313 chemical or chemical category. For
example, if your facility processes 22,000 pounds of a non-PBT
EPCRA section 313 chemical and also otherwise uses 16,000
pounds of that same chemical, it has exceeded the otherwise use
threshold (10,000 pounds for a non-PBT chemical) and your
facility must report even though it did not exceed the process
threshold (25,000 pounds for a non-PBT chemical). In
preparing your reports, you must consider all non-exempted
activities and all releases and other waste management
quantities of the EPCRA section 313 chemical from your
Toxics Release Inventory Reporting Forms and Instructions 23
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
facility, not just releases and other waste management quantities
from the otherwise use activity.
Also note that threshold determinations are based upon the actual
amounts of an EPCRA section 313 chemical manufactured,
processed, or otherwise used over the course of the calendar
year. The threshold determination may not relate to the amount
of an EPCRA section 313 chemical brought on-site during the
calendar year. For example, if a stockpile of 100,000 pounds of
a non-PBT EPCRA section 313 chemical is present on-site but
only 20,000 pounds of that chemical is applied to a process, only
the 20,000 pounds processed is counted toward a threshold
determination, not the entire 100,000 pounds of the stockpile.
B.4.b. Threshold Determinations
for On-Site Reuse Operations
Threshold determinations of EPCRA section 313 chemicals that
are reused at the facility are based only on the amount of the
EPCRA section 313 chemical that is added during the year, not
the total volume in the system. For example, a facility operates
a refrigeration unit that contains 15,000 pounds of anhydrous
ammonia at the beginning of the year. The system is charged
with 2,000 pounds of anhydrous ammonia during the year. The
facility has therefore "otherwise used" only 2,000 pounds of
anhydrous ammonia, a non-PBT EPCRA section 313 chemical,
which is below the otherwise use threshold for anhydrous
ammonia and is not required to report (unless there are other
"otherwise use" activities of ammonia, that when taken together,
exceed the reporting threshold). If, however, the whole
refrigeration unit was recharged with 15,000 pounds of
anhydrous ammonia during the year, then the facility would have
exceeded the otherwise use threshold, and would be required to
report.
This does not apply to EPCRA section 313 chemicals "recycled"
or "reused" off-site and returned to a facility. Such EPCRA
section 313 chemicals returned to a facility are treated as the
equivalent of newly purchased material for purposes of EPCRA
section 313 threshold determinations.
B.4.c. Threshold Determinations for Ammonia
The listing for ammonia includes the modifier "includes
anhydrous ammonia and aqueous ammonia from water
dissociable ammonium salts and other sources; 10% of total
aqueous ammonia is reportable under this listing". The qualifier
for ammonia means that anhydrous forms of ammonia are 100%
reportable and aqueous forms are limited to 10% of total aqueous
ammonia. Therefore, when determining threshold quantities,
100% of anhydrous ammonia is included but only 10% of total
aqueous ammonia is included. If any ammonia evaporates from
aqueous ammonia solutions, 100% of the evaporated ammonia
is included in threshold determinations.
For example, if a facility processes aqueous ammonia it has
processed 100%ofthe aqueous ammoniain that solution. If the
ammonia remains in solution, then 10% of the total aqueous
ammonia is counted towards threshold. If there are any
evaporative losses of anhydrous ammonia, then 100% of those
losses must be counted towards the processing threshold. If the
manufacturing, processing, or otherwise use threshold for the
ammonia listing are exceeded, the facility must report 100% of
these evaporative losses in Sections 5 and 8 of the FormR.
B.4.d. Threshold Determinations
for Chemical Categories
A number of chemical compound categories are subject to
reporting. See Table He for a listing of these EPCRA section
313 chemical categories. When preparing threshold
determinations for one of these EPCRA section 313 chemical
categories, all individual members of a category that are
manufactured, processed, or otherwise used must be counted.
Where generic names are used at a facility, threshold
determinations shouldbe based on CAS numbers. Forexample,
Poly-Solv EB does not appear among the reportable chemicals
in Table Ha or lib but its CAS number indicates Poly-Solv EB
is a synonym for ethylene glycol mono-n-butyl ether, a member
of the certain glycol ethers chemical category (code N230). For
chemical compound categories that are not listed as PBT
chemicals, threshold determinations must be made separately
for each of the three activities. Do not include in these
threshold determinations for a category any chemicals that are
also individually listed EPCRA section 313 chemicals (see
Table Ha or lib) or chemicals that have been deleted from a
category (e.g., a class of copper phthalocyanine compounds has
been deleted from the copper compounds category).
Individually listed EPCRA sections 13 chemicals are subject to
their own, individual threshold determination.
Organic Compounds
For the organic compound categories, you are required to
account for the entire weight of all compounds within a
specific compound category (e.g., glycol ethers) at the facility
for BOTH the threshold determination and release and other
waste management estimates.
Metal-Containing Compounds
Threshold determinations for metal-containing compounds
present a special case. If, for example, your facility processes
several different nickel compounds, base your threshold
determination on the total weight of all nickel compounds
processed. However, if your facility processes both the
"parent" metal (nickel) as well as one or more nickel
compounds, you must make threshold determinations for both
nickel (CAS number 7440-02-0) and nickel compounds
(chemical category code N495) because they are separately
listed EPCRA section 313 chemicals. If your facility exceeds
24 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
thresholds for both the parent metal and compounds of that same
metal, EPA allows you to file one combined report (e.g., one
report for nickel compounds, including nickel) because the
release information you will report in connection with metal
category compounds will be the total pounds of the metal
released. If you file one combined report, you should put the
name of the metal compound category on the Form R. In the
example above, the facility that exceeded reporting thresholds for
both nickel and nickel compounds chemical category, that
facility could submit a single Form R for the nickel compounds
chemical category, which would contain release and other waste
management information for both nickel and nickel compounds.
Do not put both names on the Form R.
The case of metal compounds involving more than one metal
should be noted. Some metal compounds may contain more than
one listed metal. For example, lead chromate is both a lead
compound and a chromium compound. In such cases, if
applicable thresholds are exceeded, you are required to file two
separate reports, one for lead compounds and one for chromium
compounds. Apply the total weight of the lead chromate to the
threshold determinations forboth lead compounds and chromium
compounds. (Note: Only the amount of each parent metal
released or otherwise managed as waste (not the amount of the
compound), would be reported on the appropriate sections of
both Form Rs. SeeB.5.)
Nitrate Compounds (water dissociable; reportable only when
in aqueous solution)
For the category nitrate compounds (water dissociable;
reportable only when in aqueous solution), the entire weight of
the nitrate compound is counted in making threshold
determinations. A nitrate compound is covered by this listing
only when in water and only if dissociated. If no information is
available on the identity of the type of nitrate that is
manufactured, processed or otherwise used, assume that the
nitrate compound exists as sodium nitrate.
B.4.e Threshold Determination for Persistent
Bioaccumulative Toxic (PBT) Chemicals
There are two separate thresholds for EPCRA section 313 PBT
chemicals; these thresholds are set based on the chemical's
potential to persist and bioaccumulate in the environment. The
manufacturing, processing and otherwise use thresholds for PBT
chemicals is 100 pounds, while for the subset of PBTs chemicals
that are highly persistent and highly toxic, it is 10 pounds. One
exception is the dioxin and dioxin-like compounds chemical
categorythe threshold for this category is 0.1 gram. The PBT
chemicals, their CAS numbers (or chemical category code), and
their reporting thresholds are listed in a table in the introductory
section of B.4. See Table He of these instructions for lists of
individual members of the dioxin and dioxin-like compounds
chemical category and the polycyclic aromatic compounds
(PACs) chemical category.
B.4.f. Mixtures and Other
Trade Name Products
EPCRA section 313 chemicals contained in mixtures and other
trade name products must be factored into threshold
determinations and release and other waste management
calculations.
If your facility processed or otherwise used mixtures or other
trade name products during the calendar year, you are required
to use the best information available to determine whether the
components of a mixture are above the de minimis
concentration and, therefore, must be included in threshold
determinations and release and other waste management
calculations. If you know that a mixture or other trade name
product contains a specific EPCRA section 313 chemical,
combine the amount of the EPCRA section 313 chemical in the
mixture or other trade name product with other amounts of the
same EPCRA section 313 chemical processed or otherwise used
at your facility for threshold determinations and release and
other waste management calculations. If you know that a
mixture contains an EPCRA section 313 chemical but no
concentration information is provided by the supplier, you do
not have to consider the amount of the EPCRA section 313
chemical present in that mixture for purposes of threshold
determinations and release and other waste management
calculations.
Observe the following guidelines in estimating concentrations
of EPCRA section 313 chemicals in mixtures when only limited
information is available:
If you only know the upper bound concentration, you must
use it for threshold determinations (40 CFR section
372.30(b)(ii)).
If you know the lower and upper bound concentrations of
an EPCRA section 313 chemical in a mixture, use the
midpoint of these two concentrations for threshold
determinations.
If you know only the lower bound concentration, you
should subtract out the percentages of any other known
components to determine a reasonable upper bound
concentration, and then determine a midpoint.
If you have no information other than the lower bound
concentration, calculate a midpoint assuming an upper
bound concentration of 100%.
Toxics Release Inventory Reporting Forms and Instructions 25
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
In cases where you only have a concentration range
available, you should use the midpoint of the range
extremes.
B.5 Release and Other Waste Management
Determinations for Metals, Metal Category
Compounds, and Nitrate Compounds
Metal Category Compounds
Although the complete weight of the metal category compounds
must be used in threshold determinations for the metal
compounds category, for release and other waste management
determinations, only the weight of the metal portion of the metal
category compound must be considered. Remember that for
metal category compounds that consist of more than one metal,
release and other waste management reporting must be based on
the weight of each metal, provided that the appropriate
thresholds have been exceeded.
Metals and Metal Category Compounds
As stated above, for compounds within the metal compound
categories only the metal portion of the metal category
compound should be considered in determining release and other
waste management quantities forthe metal category compounds.
Therefore, if thresholds are separately exceeded for both the
"parent" metal and its compounds, EPA allows you to file a
combined Form R for the "parent" metal and its category
compounds. This Form R would contain all of the release and .
other waste management information for both the "parent"
metal and metal portion of the related metal category
compounds. For example, you exceed thresholds for chromium.
You also exceed thresholds for chromium compounds. Instead
of filing two Form Rs you can file one combined Form R. This
Form R would contain information on quantities of chromium
released or otherwise managed as waste and the quantities of
the chromium portion of the chromium compounds released or
otherwise managed as waste. When filing one combined Form
R for an EPCRA section 313 metal and metal compound
category, facilities should identify the chemical reported as the
metal compound category name and code in Section 1 of the
Form R. Note that this does not apply to the Form A. See the
section in these instructions on the Form A.
Nitrate Compounds (water dissociable; reportable only in
aqueous solution)
Although the complete weight of the nitrate compound must be
used for threshold determinations for the nitrate compounds
category, for release and other waste management calculations
only the nitrate portion of the compound should be reported
26 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Example 9: Mixtures and Other Trade Name Products
Scenario #1: Your facility otherwise uses 12,000 pounds of an industrial solvent (Solvent X) for equipment cleaning. The
Material Safety Data Sheet (MSDS) for the solvent indicates that it contains at least 50% methyl ethyl ketone (MEK), an EPCRA
section 313 chemical; however, it also states that the solvent contains 20% non-hazardous surfactants. This is the only MEK-
containing mixture used at the facility.
Follow these steps to determine if the quantity of the EPCRA section 313 chemical in solvent X exceeds the threshold for
otherwise use.
1) Determine a reasonable maximum concentration for the EPCRA section 313 chemical by subtracting out the non-
hazardous surfactants (i.e., 100% - 20% = 80%).
2) Determine the midpoint between the known minimum (50%) and the reasonable maximum calculated above (i.e., (80%
+ 50%)/2 = 65%).
3) Multiply total weight of Solvent X otherwise used by 65% (0.65).
12,000 pounds x 0.65 = 7,800 pounds
4) Because the total amount of MEK otherwise used at the facility was less than the 10,000-pound otherwise use
threshold, the facility is not required to file a Form R for MEK.
Scenario #2: Your facility otherwise used 15,000 pounds of Solvent Y to clean printed circuit boards. The MSDS for the
solvent lists only that Solvent Y contains at least 80% of an EPCRA section 313 chemical that is only identified as chlorinated
hydrocarbons.
Follow these steps to determine if the quantity of the EPCRA section 313 chemical in the solvent exceeds the threshold for
otherwise use.
1) Because the specific chemical is unknown, the Form R will be filed for "chlorinated hydrocarbons." This name will
be entered into Part II, Section 2.1, "Mixture Component Identity." (Note: Because your supplier is claiming the
EPCRA section 313 chemical identity a trade secret, you do not have to file substantiation forms.)
2) The upper bound limit is assumed to be 100% and the lower bound limit is known to be 80%. Using this information,
the specific concentration is estimated to be 90% (i.e., the mid-point between upper and lower limits).
(100% + 80%)/2 = 90%
3) The total weight of Solvent Y is multiplied by 90% (0.90) when calculating for thresholds.
15,000x0.90 = 13,500
4) Because the total amount of chlorinated hydrocarbons exceeds the 10,000-pound otherwise use threshold, you must
file a Form R for this chemical.
Toxics Release Inventory Reporting Forms and Instructions 27
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Figure 2A. EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet1
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Date Worksheet Prepared:
Prepared By:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
1.
2.
3.
4.
Subtotal:
Information Source
Total Weight (Ib)
Percent EPCRA
Section 313 Chemical
by Weight
EPCRA Section 313
Chemical Weight
Ob)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (Ib.):
Manufactured
(A) Ib
Processed
(B) Ib
Otherwise Used
(0 Ib
Exempt quantity of the EPCRA Section 313 chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (de ndninds,
articles, facility, activity)
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical Exempt
from Above (Ib):
Manufactured
(A) Ib
Processed
(B,) Ib
Otherwise Used
(C,) Ib
Amount subject to threshold:
Compare to threshold for EPCRA section 313 reporting.
(A-Aj)
Ib
Ib
Ib
25.000 Ib 25.000 Ib
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R or Form A; retain it for your records.
10.000 Ib
1 Note: Chemicals listed as PBT have separate thresholds (dioxin and dioxin-like compounds chemical category = 0.1 g; highly persistent, highly bioaccumulative toxic chemicals = 10 Ib; all
other PBT chemicals = 100 Ib). Make certain you are using the appropriate worksheet for the toxic chemical of concern.
28 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Figure 2B. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100 Pound Thresholds
Date Worksheet Prepared:
Prepared By:
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
1.
2.
3.
4.
Subtotal:
Information Source
Total Weight (Ib)
Percent EPCRA
Section 313 Chemical
by Weight
EPCRA Section 313
Chemical Weight
(Ib)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (Ib.):
Manufactured
(A) Ib
Processed
(B) Ib
Otherwise Used
(0 Ib
Exempt quantity of the EPCRA Section 313 chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (articles,
facility, activity)1
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical Exempt
from Above (Ib):
Manufactured
(A) Ib
Processed
(B,) Ib
Otherwise Used
(C,) Ib
Amount subject to threshold:
Compare to threshold for EPCRA section 313 reporting.
Ib
Ib
Ib
100 Ib
100 Ib
100 Ib
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R; retain it for your records.
1 Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
Toxics Release Inventory Reporting Forms and Instructions 29
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Figure 2C. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10 Pound Thresholds
Date Worksheet Prepared:
Prepared By:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
1.
2.
3.
4.
Subtotal:
Information Source
Total Weight (Ib)
Percent EPCRA
Section 313 Chemical
by Weight
EPCRA Section 313
Chemical Weight
Ob)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (Ib.):
Manufactured
(A) Ib
Processed
(B) Ib
Otherwise Used
(0 Ib
Exempt quantity of the EPCRA Section 313 chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (articles,
facility, activity)1
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical Exempt
from Above (Ib):
Manufactured
(A,) Ib
Processed
(B,) Ib
Otherwise Used
(C,) Ib
Amount subject to threshold:
Compare to threshold for EPCRA section 313 reporting.
Ib
.Ib
Ib
10 Ib
10 Ib
10 Ib
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R; retain it for your records.
1 Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
30 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Figure 2D. EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like Compounds Chemical Category
Date Worksheet Prepared: _
Prepared By:
Facility Name:
EPCRA Section 313 Chemical or Chemical Category: Dioxin and Dioxin-Like Compounds
Chemical Category Code: N150
Reporting Year:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
1.
2.
3.
4.
Subtotal:
Information Source
Total Weight (g)
Percent EPCRA
Section 313 Chemical
by Weight
EPCRA Section 313
Chemical Weight
(g)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (g.):
Manufactured
(A) 2
Processed
(B) g
Otherwise Used
(0 2
Exempt quantity of the EPCRA Section 313 chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (articles,
facility, activity)1
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical
Exempt from Above (g):
Manufactured
(A) 2
Processed
(B,) 2
Otherwise Used
(C,) 2
.8
Amount subject to threshold: (A-Aj)_
Compare to threshold for EPCRA section 313 reporting. 0.1 gram 0.1 gram
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R; retain it for your records.
.g
0.1 gram
1 Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
Toxics Release Inventory Reporting Forms and Instructions 31
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C. Instructions for Completing EPA Form R
Part I. Facility Identification
Information
Section 1. Reporting Year
This is the calendar year to which the reported information
applies, not the year in which you are submitting the report.
Information for the 2001 reporting year must be submitted on
or before July 1,2002.
Section 2. Trade Secret Information
2.1 Are you claiming the EPCRA section 313 chemical
identified on page 2 a trade secret?
Answer this question only after you have completed the rest of
the report. The specific identity of the EPCRA section 313
chemical being reported in Part II, Section 1, may be designated
as a trade secret. If you are making a trade secret claim, mark
"yes" and proceed to Section 2.2. Only check "yes" if you
manufacture, process, or otherwise use the EPCRA section 313
chemical whose identity is a trade secret. (See page 2 of these
instructions for specific information on trade secrecy claims.)
If you checked "no," proceed to Section 3; do not answer
Section 2.2.
Do not submit trade secret reports electronically or on
diskette.
2.2 If "yes" in 2.1, is this copy sanitized or unsanitized?
Answer this question only after you have completed the rest of
the report. Check "sanitized" if this copy of the report is the
public version that does not contain the EPCRA section 313
chemical identity but does contain a generic name in its place,
and you have claimed the EPCRA section 313 chemical identity
trade secret in Part I, Section 2.1. Otherwise, check
"unsanitized."
Section 3. Certification
The certification statement must be signed by the owner or
operator or a senior official with management responsibility for
the person (or persons) completing the form. The owner,
operator, or official must certify the accuracy and completeness
of the information reported on the form by signing and dating
the certification statement. Each report must contain an original
signature. Print or type in the space provided the name and title
of the person who signs the statement. This certification
statement applies to all the information supplied on the form
and should be signed only after the form has been completed.
Section 4. Facility Identification
4.1 Facility Name, Location, and
TRI Facility Identification Number
Enter the full name that the facility presents to the public and its
customers in doing business (e.g., the name that appears on
invoices, signs, and other official business documents). Do not
use a nickname for the facility (e.g., Main Street Plant) unless
that is the legal name of the facility under which it does business.
Also enter the street address, mailing address, city, county, state,
and zip code in the space provided. Do not use a post office box
number as the street address. The street address provided should
be the location where the EPCRA section 313 chemicals are
manufactured, processed, or otherwise used. If your mailing
address and street address are the same, enter NA in the space for
the mailing address.
If your facility is not in a county, put the name of your city,
district (for example, District of Columbia), or parish (if you are
in Louisiana) in the county block of the Form R and Form A as
well as in the county field of ATRS or TRI-ME. "NA" or
"None" are not acceptable entries.
For Section 4.1 in both ATRS and TRI-ME: If your mailing
address is outside the U.S., click the "Non-US" box. You
will still provide the mailing facility name, address, and
city. There is nothing to enter in the state field. Youthen
enter the postal code, county or province, and country in
the respective fields.
Remember, both ATRS and TRI-ME can accept
international postal codes and nine-digit zip codes for U.S.
addresses.
If you have submitted a Form R or Form A for previous reporting
years, a TRI Facility Identification Number has been assigned to
your facility. If you know your TRI Facility Identification
Number, complete Section 4. If you do not know your TRI
Facility Identification Number, contact the EPCRA Call Center
(see page 7). If your facility has moved, do not enter your TRI
facility identification number, enter "New Facility." If you are
filing a separate Form R for each establishment at your facility,
use the same TRI facility identification number for each
establishment.
Enter "New Facility" in the space for the TRI Facility
Identification number if this isyour first sub mission of a Form R.
For ATRS, when entering a TRI Facility Identification
Number, enter all 15 characters. If you have a TRI Facility
Identification Number which has fewer than 15 characters
(either alpha or numeric), use the space bar on your
computer keyboard (example: 12345-JV -RT1 ). If you
have reported for prioryears, then your facility information
32 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for completing Part I of EPA Form R
can be found by searching a list of facilities. Simply click
on the icon to the right of the TRI Facility ID field in
ATRS to view the list of the TRI Facilities (NOTE: This
feature is only available with the CD-ROM version due to
space limitations on diskette). If you are a new facility,
simply type "New Facility."
For TRI-ME, simply enter your TRI Facility Identification
Number without hyphens. If you have a TRI Facility
Identification Number which has fewer than 15 characters
(either alpha or numeric), use the space bar on your
computer keyboard (example: 12345JV RT1 ). If you
are a new facility, click the "New Facility" box.
4.2 Full or Partial Facility Indication
EPCRA section 313 requires reports by "facilities," which are
defined as "all buildings, equipment, structures, and other
stationary items which are located on a single site or on
contiguous or adjacent sites and which are owned or operated
by the same person."
The SIC code system defines business "establishments" as
"distinct and separate economic activities [that] are performed
at a single physical location." Under section 372.30(c) of the
reporting rule, you may submit a separate Form R for each
establishment, or for groups of establishments in your facility,
provided all releases and other waste management activities and
source reduction activities involving the EPCRA section 313
chemical from the entire facility are reported. This allows you
the option of reporting separately on the activities involving an
EPCRA section 313 chemical at each establishment, or group
of establishments (e.g., part of a covered facility), rather than
submitting a single Form R for that EPCRA section 313
chemical for the entire facility. However, if an establishment or
group of establishments does not manufacture, process, or
otherwise use or release or otherwise manage as waste an
EPCRA section 313 chemical, you do not have to submit a
report for that establishment or group of establishments for that
particular chemical. (See also Section B.2.a of these
instructions.)
A covered facility must report all releases and other waste
management activities and source reduction activities of an
EPCRA section 313 chemical if the facility meets a reporting
threshold for that EPCRA section 313 chemical. However, if
the facility is composed of several distinct establishments, EPA
allows these establishments to submit separate reports for the
EPCRA section 313 chemical as long as all releases and other
waste management activities of the EPCRA section 313
chemical from the entire facility are accounted for. Whether
submitting a report for the entire facility or separate reports for
the establishments, the threshold determination must be made
based on the entire facility. Indicate in Section 4.2 whether
your report is for the entire covered facility as a whole or for
part of a covered facility (i.e., one or more establishments).
Federal facilities and contractors at federal facilities
(GOCOsGovernment-owned, contractor-operated facilities)
check either 4.2c or 4.2d, but not both. Federal facilities check
4.2c, even if their TRI reports contain release and other waste
management information from contractors located at the facility.
Contractors at federal facilities, which are required by EPCRA
section 313 to file TRI reports independently of the federal
facility, check 4.2d. This information is important to prevent
duplication of federal facility data. (See Appendix A for further
guidance on these instructions.)
4.3 Technical Contact
Enter the name and telephone number (including area code) of a
technical representative whom EPA or State officials may
contact for clarification of the information reported on Form R.
This contact person does not have to be the same person who
prepares the report or signs the certification statement and does
not necessarily need to be someone at the location of the
reporting facility. However, this person must be familiar with
the details of the report so that he or she can answer questions
about the information provided.
Remember, both ATRS and TRI-ME can accept
international telephone numbers (be sure to include Oil as
the prefix to your international telephone number).
4.4 Public Contact
Enter the name and telephone number (including area code) of a
person who can respond to questions from the public about the
report. If you choose to designate the same person as both the
technical and the public contact, you may enter "Same as Section
4.3" in this space. This contact person does not have to be the
same person who prepares the report or signs the certification
statement and does not necessarily need to be someone at the
location of the reporting facility. If your facility does not have
a public contact, provide the technical contact name and
telephone number in the public contact name and telephone
number fields.
Remember, both ATRS and TRI-ME can accept
international telephone numbers (be sure to include Oil as
the prefix to your international telephone number).
4.5 Standard Industrial Classification (SIC) Code
Enterthe appropriate four-digit Standard Industrial Classification
(SIC) Code that is the primary SIC Code for your facility in
Section 4.5(a). Enter any other applicable SIC Codes for your
facility in 4.5 (b)-(f). Table I lists the SIC codes within 10
(except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4939
(limited to facilities that combust coal and/or oil for the purpose
Toxics Release Inventory Reporting Forms and Instructions 33
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Instructions for Completing Part I of EPA Form R
of generating electricity for distribution in commerce), 4953
(limited to facilities regulated under the RCRA Subtitle C, 42
U.S.C. section 6921 etseq.), 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvent recovery services on a
contract or fee basis). If the report covers more than one
establishment, enter the primary 4-digit SIC code for each
establishment starting with the primary SIC code for the entire
facility. You are required to enter SIC codes only for those
establishments within the facility that fall within SIC codes 10
(except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4939
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4953
(limited to facilities regulated under the RCRA Subtitle C, 42
U.S.C. section 6921 etseq.), 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvents recovery services on a
contract or fee basis). If you do not know your SIC code,
consult the 1987 SIC Manual (see Section B.2 of these
instructions for ordering information).
The North American Industry Classification System (NAICS)
is a new economic classification system that will replace the
1987 SIC code system. EPA will address the SIC code change,
as it relates to EPCRA, in an upcoming Federal Register notice.
This upcoming change does NOT affect the 2001 EPCRA
section 313 reporting.
4.6 Latitude and Longitude
Enter the latitude and longitude coordinates of your facility.
Sources of these data include EPA permits (e.g., NPDES
permits), county property records, facility blueprints, and site
plans. Instructions on how to determine these coordinates can
be found in Appendix E. Enter only numerical data. Do not
preface numbers with letters such as N or W to denote the
hemisphere.
Latitude and longitude coordinates of your facility are very
important for pinpointing the location of reporting facilities and
are required elements on the Form R. EPA encourages facilities
to make the best possible measurements when determining
latitude and longitude. Please check to make sure the latitude
and longitude coordinates of your facility are correct. For the
continental United States readings should be within 24ฐ23'58"
and 49ฐ22'16" latitude, and 66ฐ53'06" and 124ฐ50'55"
longitude. For Alaska readings should be within51ฐ10'30" and
71ฐ26'04" latitude, and 129ฐ59'29" and 187ฐ39'08" longitude.
For Hawaii readings should be within 18ฐ51'56" and 28ฐ30'59"
latitude, and 154ฐ45'21" and 178ฐ26'25" longitude. As with any
other data field, missing, suspect, or incorrect data may generate
an error notice in the Facility Data Profile to be issued to the
facility. (See Appendix C: Common Errors in Completing
Form R Reports and Making Data Available.)
4.7 Dun & Bradstreet Number(s)
Enter the nine-digit number assigned by Dun & Bradstreet (D &
B) for your facility or each establishment within your facility.
These numbers code the facility for financial purposes. This
number may be available from your facility's treasurer or
financial officer. You can also obtain the numbers from your
local Dun & Bradstreet office (check the telephone book White
Pages). If a facility does not subscribe to the D & B service, a
"support number" canbe obtained from the D &B center located
in Allentown, Pennsylvania, at (610) 882-7748 (8:30 AM to 8:00
PM, Eastern Time), toll free at (800) 333-0505 or on the web at
www.dnb.com. If none of your establishments has been assigned
a D & B number, enter NA in box (a). If only some of your
establishments have been assigned D & B numbers, enter those
numbers in Part I, section 4.7.
4.8 EPA Identification Number(s)
The EPA Identification Number is a 12-character number
assigned to facilities covered by hazardous waste regulations
under the Resource Conservation and Recovery Act (RCRA).
Facilities not covered by RCRA Subtitle C are not likely to have
an assigned identification number. If your facility is not required
to have an identification number, enter NA in box (a). If your
facility has been assigned EPA IdentificationNumbers, you must
enter those numbers in the spaces provided in Section 4.8.
4.9 NPDES Permit Number(s)
Enter the numbers of any permits your facility holds under the
National Pollutant Discharge Elimination System (NPDES) even
if the permit(s) do not pertain to the EPCRA section 313
chemical being reported. This nine-character permit number is
assigned to your facility by EPA or the State under the authority
of the Clean Water Act. If your facility does not have a permit,
enter NA in Section 4.9a.
4.10 Underground Injection
Well Code (UIC) Identification Number(s)
If your facility has a permit to inject a waste that contains or
contained the EPCRA section 313 chemical into Class 1 deep
wells, enterthe 12-digit Underground Injection Well Code (UIC)
identification number assigned by EPA or by the State under the
authority of the Safe Drinking Water Act. If your facility does
not hold such a permit(s), enter NA in Section 4.10a. You are
required to provide the UIC number for wells that receive the
EPCRA section 313 chemical being reported in the current
reporting year.
Section 5. Parent Company Information
You must provide information on your parent company. For
purposes of Form R, a parent company is defined as the highest
level company, located in the United States, that directly owns
34 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part I of EPA Form R
at least 50% of the voting stock of your company. If your 5.2 Parent Company's Dun & Bradstreet Number
facility is owned by a foreign entity, enter NA in this space.
Corporate names should be treated as parent company names Enter the D & B number for your ultimate U.S. parent company,
for companies with multiple facility sites. For example, the if applicable. The number may be obtained from the treasurer or
Bestchem Corporation is not owned or controlled by any other financial officer of the company. If your parent company does
corporation but has sites throughout the country whose names not have a D & B number, check the NA box.
begin with Bestchem. In this case, Bestchem Corporation
would be listed as the parent company. Note that a facility that
is a 50:50 joint venture is its own parent company.
5.1 Name of Parent Company
Enter the name of the corporation or other business entity that
is your ultimate U.S. parent company. If your facility has no
parent company, check the NA box.
Toxics Release Inventory Reporting Forms and Instructions 35
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Instructions for Completing Part II of EPA Form R
Part II. Chemical Specific Information
In Part II, you are to report on:
n The EPCRA section 313 chemical being reported;
n The general uses and activities involving the EPCRA
section 313 chemical at your facility;
n On-site releases of the EPCRA section 313 chemical from
the facility to air, water, and land;
n Quantities of the EPCRA section 313 chemical transferred
to off-site locations;
n Information for on-site and off-site disposal, treatment,
energy recovery, and recycling of the EPCRA section 313
chemical; and
n Source reduction activities.
Section 1. EPCRA Section 313
Chemical Identity
1.1 CAS Number
Enter the Chemical Abstracts Service (CAS) registry number in
Section 1.1 exactly as it appears in Table II of these instructions
for the chemical being reported. CAS numbers are cross-
referenced with an alphabetical list of chemical names in Table
II. If you are reporting one of the EPCRA section 313 chemical
categories (e.g., chromium compounds), enter the applicable
category code in the CAS number space. EPCRA section 313
chemical category codes are listed below and can also be found
in Table He and Appendix B.
EPCRA section 313 Chemical Category Codes
NO 10 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N150 Dioxin and dioxin-like compounds
N171 Ethylenebisdithiocarbamic acid, salts and
esters (EBDCs)
N230 Certain glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N503 Nicotine and salts
N511 Nitrate compounds (water dissociable,
reportable only in aqueous solution)
N575 Polybrominated biphenyls (PBBs)
N583 Fob/chlorinated alkanes (CIO to C13)
N590 Poly cyclic aromatic compounds (PACs)
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N770 Vanadium compounds
N874 Warfarin and salts
N982 Zinc compounds
If you are making a trade secret claim, you must report the CAS
number or category code on your unsanitized Form R and
unsanitized substantiationform. Do not include the CAS number
or category code on your sanitized Form R or sanitized
substantiation form.
1.2 EPCRA Section 313 Chemical or
Chemical Category Name
Enter the name of the EPCRA section 313 chemical or chemical
category exactly as it appears in Table II. If the EPCRA section
313 chemical name is followed by a synonym in parentheses,
report the chemical by the name that directly follows the CAS
number (i.e., not the synonym). If the EPCRA section 313
chemical identity is actually a product trade name (e.g., Dicofol),
the 9th Collective Index name is listed below it in brackets. You
may report either name in this case.
Do not list the name of a chemical that does not appear in Table
II, such as individual members of a reportable EPCRA section
313 chemical category. For example, if you use silver chloride,
do not report silver chloride with its CAS number. Report this
chemical as "silver compounds" with its category code, N740.
If you are making a trade secret claim, you must report the
specific EPCRA section 313 chemical identity on your
unsanitized Form R and unsanitized substantiation form. Do not
report the name of the EPCRA section 313 chemical on your
sanitized Form R or sanitized substantiation form. Include a
generic name in Part II, Section 1.3 of your sanitized Form R
report.
EPA requests that the EPCRA section 313 chemical, chemical
category, or generic name also be placed in the box marked
"Toxic Chemical, Category, or Generic Name" in the upper
right-hand corner on all pages of Form R. While this space is not
a required data element, providing this information will help you
in preparing a complete Form R report.
36 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
1.3 Generic Chemical Name
Complete Section 1.3 only if you are claiming the specific
EPCRA section 313 chemical identity of the EPCRA section
313 chemical as a trade secret and have marked the trade secret
block in Part I, Section 2.1 on page 1 of Form R. Enter a
generic chemical name that is descriptive of the chemical
structure. You must limit the generic name to seventy
characters (e.g., numbers, letters, spaces, punctuation) or less.
Do not enter mixture names in Section 1.3; see Section 2 below.
In-house plant codes and other substitute names that are not
structurally descriptive of the EPCRA section 313 chemical
identity being withheld as a trade secret are not acceptable as a
generic name. The generic name must appear on both sanitized
and unsanitized Form Rs, and the name must be the same as that
used on your substantiation forms.
1.4 Distribution of Each Member of the Dioxin and
Dioxin-like Compounds Category
Report a distribution of the chemicals included in the dioxin and
dioxin-like compounds category. Such distribution shall either
represent the distribution of the total quantity of dioxin and
dioxin-like compounds released to all mediafromyourfacility;
or your facility's one best media-specific distribution. When
reporting dioxin and dioxin-like compounds, if there are any
numbers in boxes 1-17, then every field must be filled in with
either 0 or some number between 0.01 and 100. Distribution
should be reported in percentages and the total should equal
100%. If you do not have speciation data available, indicate
NA (see Figure 3). If you are not reporting for dioxin and
dioxin-like compounds, leave the entire section blank.
You should not report the quantity of dioxin and dioxin-like
compounds released or otherwise managed as waste in Section
1.4. Quantities released or otherwise managed as waste should
be reported in Sections 5, 6 and 8.
There are 17 individual chemicals listed in the dioxin and
dioxin-like compounds category. Each of these chemicals are
assigned a number from 1 to 17. These numbers correspond to
the boxes in Section 1.4. The individual chemicals in the dioxin
and dioxin-like compounds category and their number are in the
matrix below:
1
2
3
4
5
6
67562-39^
55673-89-7
70648-26-9
57H7^4_9
72918-21-9
60851-34-5
1,2,3,4 ,6,7,8-Heptachlorodibenzofuran
1, 2,3,4 ,7,8,9-Heptachlorodibenzofuran
1,2,3,4,7,8-Hexachlorodibenzofuran
1,2,3,6,7,8-Hexachlorodibenzofuran
1,2,3,7,8,9-Hexachlorodibenzofuran
2,3,4 ,6,7,8-Hexachlorodibenzofuran
7
8
9
10
11
12
13
14
15
16
17
39227-28-6
57653-85-7
19408-74-3
35822^16-9
39001-02-0
03268-87-9
57117-^1-6
57117-31^1
40321-76^1
51207-31-9
01746-01-6
1 ,2,3,4,7,8-Hexachlorodibenzo- p-dioxin
1 ,2,3,6,7,8-Hexachlorodibenzo- p-dioxin
1 ,2,3,7,8,9-Hexachlorodibenzo- p-dioxin
1 ,2,3,4,6,7,8-Heptachlorodibenzo- p-
dioxin
1,2,3,4,6,7,8,9-Octachlorodibenzofuran
1 ,2,3,4,6,7,8,9-Octachlorodibenzo- p-
dioxin
1 ,2,3,7,8-Pentachlorodibenzofuran
2,3,4,7,8-Pentachlorodibenzofuran
1 ,2,3,7,8-Pentachlorodibenzo- p-dioxin
2,3,7,8-Tetrachlorodibenzofuran
2,3,7,8-Tetrachlorodibenzo- p-dioxin
Section 2. Mixture Component Identity
Do not complete this section if you have completed Section 1 of
Part II. Report the generic name provided to you by your
supplier in this section if your supplier is claiming the chemical
identity proprietary or trade secret. Do not answer "yes" in Part
I, Section 2.1 on page 1 of the form if you complete this section.
You do not need to supply trade secret substantiation forms for
this EPCRA section 313 chemical because it is your supplier
who is claiming the chemical identity a trade secret.
Example 10: Mixture Containing Unidentified
EPCRA Section 313 Chemical
Your facility uses 20,000 pounds of a solvent that your
supplier has told you contains 80% "chlorinated aromatic,"
their generic name for a non-PBT EPCRA section 313
chemical subject to reporting under EPCRA section 313.
You, therefore, know that you have used 16,000 pounds of
some EPCRA section 313 chemical and that exceeds the
"otherwise use" threshold for a non-PBT chemical. You
would file a Form R and enter the name "chlorinated
aromatic" in the space provided in Part II, Section 2.
2.1 Generic Chemical Name Provided by Supplier
Enter the generic chemical name in this section only if the
following three conditions apply:
1. You determine that the mixture contains an EPCRA section
313 chemical but the only identity you have for that
chemical is a generic name;
Toxics Release Inventory Reporting Forms and Instructions 37
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Instructions for Completing Part II of EPA Form R
1. You know either the specific concentration of that
EPCRA section 313 chemical component or a maximum
or average concentration level; and
3. You multiply the concentration level by the total annual
amount of the whole mixture processed or otherwise used
and determine that you meet the process or otherwise use
threshold for that single, genetically identified mixture
component.
Section 3. Activities and Uses of the EPCRA
Section 313 Chemical at the Facility
Indicate whether the EPCRA section 313 chemical is
manufactured (including imported), processed, or otherwise
used at the facility and the general nature of such activities and
uses at the facility during the calendar year (see figure 3). You
are not required to report on Form R the quantity manufactured,
processed or otherwise used. Report activities that take place
only at your facility, not activities that take place at other
facilities involving your products. You must check all the
boxes in this section that apply. Refer to the definitions of
"manufacture," "process," and "otherwise use" in the general
information section of these instructions or Part 40, Section
372.3 of the Code of Federal Regulations for additional
explanations.
3.1 Manufacture the EPCRA Section 313 Chemical
Persons who manufacture (including import) the EPCRA
section 313 chemical must check at least one of the following:
a. Produce The EPCRA section 313 chemical is
produced at the facility.
b. Import The EPCRA section 313 chemical is imported
by the facility into the Customs Territory of the United
States. (See SectionB.S.a of these instructions forfurther
clarification of import.)
And check at least one of the following:
c. For on-site use/processing The EPCRA section 313
chemical is produced or imported and then further
processed or otherwise used at the same facility. If you
check this block, generally you should also check at least
one item in Part II, Section 3.2 or 3.3.
d. For sale/distribution The EPCRA section 313
chemical is produced or imported specifically for sale or
distribution outside the manufacturing facility.
e. As a byproduct The EPCRA section 313 chemical is
produced coincidentally during the manufacture,
processing, or otherwise use of another chemical
substance or mixture and, following its production, is
separated from that other chemical substance or mixture.
EPCRA section 313 chemicals produced as a result of
waste management are also considered byproducts.
f. As an impurity The EPCRA section 313 chemical is
produced coincidentally as a result of the manufacture,
processing, or otherwise use of another chemical but is not
separated and remains in the mixture or other trade name
product with that other chemical.
In summary, if you are a manufacturer of the EPCRA section 313
chemical, you must check (a) and/or (b), and at least one of (c),
(d), (e), and (f) in Section 3.1.
3.2 Process the EPCRA Section 313 Chemical
(incorporative activities)
Persons who process the EPCRA section 313 chemical must
check at least one of the following:
a. As a reactantA natural or synthetic EPCRA section 313
chemical is used in chemical reactions for the manufacture
of another chemical substance or of a product. Includes but
is not limited to, feedstocks, raw materials, intermediates,
and initiators.
b. As a formulation component An EPCRA section 313
chemical is added to a product (or product mixture) prior to
further distribution of the product that acts as a
performance enhancer during use of the product. Examples
of EPCRA section 313 chemicals used in this capacity
include, but are not limited to, additives, dyes, reaction
diluents, initiators, solvents, inhibitors, emulsifiers,
surfactants, lubricants, flame retardants, and rheological
modifiers.
c. As an article component An EPCRA section 313
chemical becomes an integral component of an article
distributed for industrial, trade, or consumer use. One
example is the pigment components of paint applied to a
chair that is sold.
d. RepackagingThis consists of processing or preparation
of an EPCRA section 313 chemical (or product mixture) for
distribution in commerce in a different form, state, or
quantity. This includes, but is not limited to, the transfer of
material from a bulk container, such as a tank truck to
smaller containers such as cans or bottles.
e. As an impurity The EPCRA section 313 chemical is
processed but is not separated and remains primarily in the
mixture or other trade name product with that/those other
chemical(s).
38 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Example 11: Manufacturing and Processing Activities
of EPCRA Section 313 Chemicals
In the two examples below, it is assumed that the threshold
quantities for manufacture, process, or otherwise use (25,000
pounds, 25,000 pounds, and 10,000 pounds, respectively for
non-PBT chemicals; 100 pounds for certain PBT chemicals;
10 pounds for highly persistent, highly bioaccumulative toxic
chemicals; and 0.1 grams for the PBT chemical category
comprised of dioxin and dioxin-like compounds) have been
exceeded and the reporting of EPCRA section 313 chemicals
is therefore required.
1. Your facility manufactures diazomethane. Fifty percent
is sold as a product, thus it is processed. The remaining 50%
is reacted with alpha-naphthylamine, forming N-methyl-
alpha-naphthylamine and also producing nitrogen gas.
n Your company manufactures diazomethane, anEPCRA
section 313 chemical, both for sale/ distribution as a
commercial product and for on-site use/processing as
a feedstock in the N-methyl-alpha-naphthylamine
production process. Because the diazomethane is a
reactant, it is also processed. See Figure 3 for how this
information would be reported in Part II, Section 3 of
FormR.
n Your facility also processes alpha-naphthylamine, as a
reactant to produce N-methyl-alpha-naphthylamine, a
chemical not on the EPCRA section 313 list.
2. Your facility is a commercial distributor of Missouri
bituminous coal, which contains mercury at 1.5 ppm (w:w).
You should check the box on the Form R at Part II, Section
3.2.e for processing mercury as an impurity.
3.3 Otherwise Use the EPCRA Section 313 Chemical (non-
incorporative activities)
Persons who otherwise use the EPCRA section 313 chemical
must check at least one of the following:
a. As a chemical processing aid An EPCRA section 313
chemical that is added to a reaction mixture to aid in the
manufacture or synthesis of another chemical substance but
is not intended to remain in or become part of the product
or product mixture is otherwise used as chemical
processing aid. Examples of such EPCRA section 313
chemicals include, but are not limited to, process solvents,
catalysts, inhibitors, initiators, reaction terminators, and
solution buffers.
b. As a manufacturing aid An EPCRA section 313
chemical that aids the manufacturing process but does not
become part of the resulting product and is not added to the
reaction mixture during the manufacture or synthesis of
another chemical substance is otherwise used as a
manufacturing aid. Examples include, but are not limited
to, process lubricants, metalworking fluids, coolants,
refrigerants, and hydraulic fluids.
c. Ancillary or other use An EPCRA section 313
chemical is used at a facility for purposes other than aiding
chemical processing or manufacturing as described above
is otherwise used as ancillary or other use. Examples
include, but are not limited to, cleaners, degreasers,
lubricants, fuels, EPCRA section 313 chemicals used for
treating wastes, and EPCRA section 313 chemicals used to
treat water at the facility.
Section 4. Maximum Amount of the EPCRA
Section 313 Chemical On-site at Any Time During
the Calendar Year
For data element 4.1 of Part II, insert the code (see codes below)
that indicates the maximum quantity of the EPCRA section 313
chemical (e.g., in storage tanks, process vessels, on-site shipping
containers, or in waste) at your facility at any time during the
calendar year. If the EPCRA section 313 chemical was present
at several locations within your facility, use the maximum total
amount present at the entire facility at any one time. While range
reporting is not allowed for PBT chemicals elsewhere on the
Form R, range reporting for PBT chemicals is allowed for
Maximum Amount On Site.
Toxics Release Inventory Reporting Forms and Instructions 39
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Instructions for Completing Part II of EPA Form R
Figure 3. Hypothetical Sections 1, 2 and 3 of Part II of the Form R.
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important: DO NOT complete this section if you completed Section 2 below.)
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category)
334-88-3
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list)
Diazomethane
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes" Generic Name must be structurally descriptive-)
1.4 Distribution of Each Member of the Dioxin and Dioxin-like Compounds Category.
(If there are any numbers in boxes 1-17, then every field must be filled in with either 0 or some number between 0.01 and 100. Dislribution should
be reported in percentages and the total should equal 0 or 100%. If you do not have speciation data available, check NA.)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
NA
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check all that apply.)
3.1 Manufacture the toxic chemical:
3.2 Process the toxic chemical:
3.3 Otherwise use the toxic chemical:
Produce
Import
If produce or import:
For on-site use/processing
For sale/distribulion
As a byproduct
As an impurity
X
As a reactant
As a formulation component
As an article component
Repackaging
As an impurity
As a chemical processing aid
As a manufacturing aid
Ancillary or other use
Weight Range in Pounds
Range Code
01
02
03
04
05
06
07
08
09
10
11
From...
0
100
1,000
10,000
100,000
1,000,000
10,000,000
50,000,000
100,000,000
500,000,000
1 billion
To...
99
999
9,999
99,999
999,999
9,999,999
49,999,999
99,999,999
499,999,999
999,999,999
more than 1 billion
If the EPCRA section 313 chemical present at your facility
was part of a mixture or other trade name product, determine
the maximum quantity of the EPCRA section 313 chemical
present at the facility by calculating the weight percent of the
EPCRA section 313 chemical only.
Do not include the weight of the entire mixture or other trade
name product. These data may be found in the Tier II form
your facility may have prepared under Section 312 of
EPCRA. See Part 40, Section 372.30(b) of the Code of
Federal Regulations for further information on how to
calculate the weight of the EPCRA section 313 chemical in
the mixture or other trade name product. For EPCRA section
313 chemical categories (e.g., nickel compounds), include all
chemical compounds in the category when calculating the
maximum amount, using the entire weight of each compound.
Section 5. Quantity of the EPCRA Section 313
Chemical Entering Each Environmental
Medium On-site
In Section 5, you must account for the total aggregate on-site
releases of the EPCRA section 313 chemical to the
environment from your facility for the calendar year.
40 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
On-site releases to the environment include emissions to the
air, discharges to surface waters, and releases to land and
underground injection wells.
For all toxic chemicals (except the dioxin and dioxin-like
compound category), do not enter the values in Section 5 in
gallons, tons, liters, or any measure other than pounds. You
must also enter the values as whole numbers. Numbers
following a decimal point are not acceptable for toxic
chemicals other than those designated as PBT chemicals. For
PBT chemicals, facilities should report release and other
waste management quantities greater than 0.1 pound (except
the dioxin and dioxin-like compounds category) provided the
accuracy and the underlying data on which the estimate is
based supports this level of precision. For the dioxin and
dioxin-like compounds category, facilities should report at a
level of precision supported by the accuracy of the underlying
data and the estimation techniques on which the estimate is
based. For the dioxin and dioxin-like compounds chemical
category, which has a reporting threshold of 0.1 gram,
facilities need only report all release and other waste
management quantities greater than 100 micrograms (i.e.,
0.0001 grams). (See example 12). Notwithstanding the
numeric precision used when determining reporting eligibility
thresholds, facilities should report on Form R to the level of
accuracy that their data supports, up to seven digits to the
right of the decimal. EPA's reporting software and data
management systems support data precision up to seven
digits to the right of the decimal.
Example 12: Reporting Dioxins and
Dioxin-Like Compounds
If the total quantity for Section 5.2 of the Form R (i.e.,
stack or point air emissions) is 0.00005 grams or less,
then zero can be entered. If the total quantity is
between 0.00005 and 0.0001 grams then 0.0001 grams
can be entered or the actual number can be entered
(e.g., 0.000075).
NA vs. a Numeric Value (e.g., Zero). Generally, NA is
applicable if the waste stream that contains or contained the
EPCRA section 313 chemical is not directed to the relevant
environmental medium, or if leaks, spills and fugitive
emissions cannot occur. If the waste stream that contains or
contained the EPCRA section 313 chemical is directed to the
environmental medium, or if leaks, spills or fugitive
emissions can occur, NA is not appropriate, even if treatment
or emission controls result in a release of zero. If the annual
aggregate release of that chemical was equal to or less than
0.5 pound, the value reported is zero (unless the chemical is
a listed PBT chemical).
For Section 5.1, NA generally is not applicable for volatile
organic compounds (VOCs). For Section 5.5.4, NA generally
would not be applicable, recognizing the possibility of
accidental spills or leaks of the EPCRA section 313 chemical.
An example that illustrates the use of NA vs. a numeric value
(e.g., zero) would be nitric acid involved in a facility's
processing activities. If the facility neutralizes the wastes
containing nitric acid to a pH of 6 or above, then the facility
reports a release of zero for the EPCRA section 313
chemical, not NA. Another example is when the facility has
no underground injection well, in which case NA should be
entered in Part I, Section 4.10 and checked in Part II, Section
5.4.1 and 5.4.2 of Form R. Also, if the facility does not
landfill the acidic waste, NA would be checked in Part II,
Section 5.5. l.B of Form R.
You are not required to count as a release, quantities of an
EPCRA section 313 chemical that are lost due to natural
weathering or corrosion, normal/natural degradation of a
product, or normal migration of an EPCRA section 313
chemical from a product. For example, amounts of an
EPCRA section 313 chemical that migrate from plastic
products in storage do not have to be counted in estimates of
releases of that EPCRA section 313 chemical from the
facility.
All releases of the EPCRA section 313 chemical to the air
must be classified as either stack or fugitive emissions, and
included in the total quantity reported for these releases in
Sections 5.1 and 5.2. Instructions for columns A, B, and C
follow the discussions of Sections 5.1 through 5.5.
5.1 Fugitive or Non-Point Air Emissions
Report the total of all releases of the EPCRA section 313
chemical to the air that are not released through stacks, vents,
ducts, pipes, or any other confined air stream. You must
include (1) fugitive equipment leaks from valves, pump seals,
flanges, compressors, sampling connections, open-ended
lines, etc.; (2) evaporative losses from surface impoundments
and spills; (3) releases from building ventilation systems; and
(4) any other fugitive or non-point air emissions.
Engineering estimates and mass balance calculations (using
purchase records, inventories, engineering knowledge or
process specifications of the quantity of the EPCRA section
313 chemical entering product, hazardous waste manifests, or
monitoring records) may be useful in estimating fugitive
emissions. Check the NA box in Section 5.1 if you do not
engage in activities that result in fugitive or non-point air
emissions of this listed toxic chemical. For VOCs, NA
generally would not be applicable.
Toxics Release Inventory Reporting Forms and Instructions 41
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Instructions for Completing Part II of EPA Form R
5.2 Stack or Point Air Emissions
Report the total of all releases of the EPCRA section 313
chemical to the air that occur through stacks, confined vents,
ducts, pipes, or other confined air streams. You must include
storage tank emissions. Air releases from air pollution
control equipment would generally fall in this category.
Monitoring data, engineering estimates, and mass balance
calculations may help you to complete this section. Check
the NA box in Section 5.2 if there are no stack air activities
involving the waste stream that contains or contained the
EPCRA section 313 chemical.
5.3 Discharges to Receiving Streams or Water Bodies
In Section 5.3 you are to enter all the names of the streams or
water bodies to which your facility directly discharges the
EPCRA section 313 chemical on which you are reporting. A
total of three spaces is provided on page 2 of Form R. Enter
the name of each receiving stream or surface water body to
which the EPCRA section 313 chemical being reported is
directly discharged. Report the name of the receiving stream
or water body as it appears on the permit for the facility. If
the stream is not included in the NPDES permit or its name
is not identified in the NPDES permit, enter the name of the
off-site stream or water body by which it is publicly known
or enter the first publicly named water body to which the
receiving waters are a tributary, if the receiving waters are
unnamed. Do not list a series of streams through which the
EPCRA section 313 chemical flows. Be sure to include all
the receiving streams or water bodies that receive stormwater
runoff from your facility. Do not enter names of streams to
which off-site treatment plants discharge. Enter NA in
Section 5.3.1 if there are no discharges to receiving streams
orwater bodies of the waste stream that contains or contained
the EPCRA section 313 chemical (See discussion of NA vs.
a Numeric Value (e.g., Zero) in the introduction of Section
5).
Enter the total annual amount of the EPCRA section 313
chemical released from all discharge points at the facility to
each receiving stream or waterbody. Include process outfalls
such as pipes and open trenches, releases from on-site
wastewater treatment systems, and the contribution from
stormwater runoff, if applicable (see instructions for column
C below). Do not include discharges to a POTW or other off-
site wastewater treatment facilities in this section. These off-
site transfers must be reported in Part II, Section 6 of Form R.
Wastewater analyses and flowmeter data may provide the
quantities you will need to complete this section.
Discharges of listed acids (e.g., hydrogen fluoride, nitric acid)
may be reported as zero if the discharges have been
neutralized to pH 6 or above. If wastewater containing a
listed acid is discharged below pH 6, then releases of the acid
must be reported. In this case, pH measurements may be
used to estimate the amount of mineral acid released.
5.4.1 Underground Injection On-Site to Class I Wells
Enter the total amount of the EPCRA section 313 chemical
that was injected into Class I wells at the facility. Chemical
analyses, injection rate meters, and RCRA Hazardous Waste
Generator Reports are good sources for obtaining data that
will be useful in completing this section. Check the NA box
in Section 5.4.1 if you do not inject the waste stream that
contains or contained the EPCRA section 313 chemical into
Class I underground wells (See discussion of NA vs. a
Numeric Value (e.g., Zero) in the introduction of Section 5).
5.4.2 Underground Injection On-site to
Class II-V Wells
Enter the total amount of the EPCRA section 313 chemical
that was injected into wells at the facility other than Class I
wells. Chemical analyses and injection rate meters are good
sources for obtaining data that will be useful in completing
this section. Check the NA box in Section 5.4.2 if you do not
inject the waste stream that contains or contained the EPCRA
section 313 chemical into Class II-V underground wells (See
discussion of NA vs. a Numeric Value (e.g., Zero) in the
introduction of Section 5).
5.5 Disposal to Land On-site
Five predefined subcategories for reporting quantities
released to land within the boundaries of the facility are
provided. Do not report land disposal at off-site locations in
this section. Accident histories and spill records may be
useful (e.g., release notification reports required under
Section 304 of EPCRA, Section 103 of CERCLA, and
accident histories required under Section 112(r)(7)(B)(ii) of
the Clean Air Act). Where relevant, check the NA box in
sections 5.5.1 A through 5.5.3 if there are no disposal
activities for the waste stream that contains or contained the
EPCRA section 313 chemical (See discussion of NA vs. a
Numeric Value (e.g., Zero) in the introduction of Section 5).
For 5.5.4, facilities generally should report zero, recognizing
the potential for spills or leaks.
5.5.1 A RCRA Subtitle C landfills Enter the total amount
of the EPCRA section 313 chemical that was placed in
RCRA Subtitle C landfills. Leaks from landfills need not be
reported as a release because the amount of the EPCRA
section 313 chemical has already been reported as a release.
5.5.1B Other landfills Enter the total amount of the
EPCRA section 313 chemical that was placed in landfills
other than RCRA Subtitle C landfills. Leaks from landfills
need not be reported as a release because the amount of the
EPCRA section 313 chemical has already been reported as a
release.
5.5.2 Land treatment/application farming Land
treatment is a disposal method in which a waste containing an
42 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
EPCRA section 313 chemical is applied onto or incorporated
into soil. While this disposal method is considered a release
to land, any volatilization of EPCRA section 313 chemicals
into the air occurring during the disposal operation must not
be included in this section but must be included in the total
fugitive air releases reported in Part II, Section 5.1 of
FormR.
5.5.3 Surface impoundment A surface impoundment is
a natural topographic depression, man-made excavation, or
diked area formed primarily of earthen materials (although
some may be lined with man-made materials), that is
designed to hold an accumulation of liquid wastes or wastes
containing free liquids. Examples of surface impoundments
are holding, settling, storage, and elevation pits; ponds, and
lagoons. If the pit, pond, or lagoon is intended for storage or
holding without discharge, it would be considered to be a
surface impoundment used as a final disposal method. A
facility should determine, to the best of its ability, the
percentage of a volatile chemical, e.g., benzene, that is in
waste sent to a surface impoundment that evaporates in the
reporting year. The facility should report this as a fugitive air
emission in section 5.1. The balance should be reported in
section 5.5.3.
Quantities of the EPCRA section 313 chemical released to
surface impoundments that are used merely as part of a
wastewater treatment process generally should not be
reported in this section. However, if the impoundment
accumulates sludges containing the EPCRA section 313
chemical, you must include an estimate in this section unless
the sludges are removed and otherwise disposed (in which
case they should be reported under the appropriate section of
the form). For the purposes of this reporting, storage tanks
are not considered to be a type of disposal and are not to be
reported in this section of Form R.
5.5.4 Other Disposal Includes any amount of an EPCRA
section 313 chemical released to land that does not fit the
categories of landfills, land treatment, or surface
impoundment. This other disposal would include any spills
or leaks of EPCRA section 313 chemicals to land. For
example, 2,000 pounds of benzene leaks from an
underground pipeline into the land at a facility. Because the
pipe was only a few feet from the surface at the erupt point,
30% of the benzene evaporates into the air. The 600 pounds
released to the air would be reported as a fugitive air release
(Part II, Section 5.1) and the remaining 1,400 pounds would
be reported as a release to land, other disposal (Part II,
Section 5.5.4).
Column A: Total Release
Only on-site releases of the EPCRA section 313 chemical to
the environment for the calendar year are to be reported in
this section of Form R. The total on-site releases from your
facility do not include transfers or shipments of the EPCRA
section 313 chemical from your facility for sale or
distribution in commerce, or of wastes to other facilities for
disposal, treatment, energy recovery, or recycling (see Part II,
Section 6 of these Instructions). Both routine releases, such
as fugitive air emissions, and accidental or non-routine
releases, such as chemical spills, must be included in your
estimate of the quantity released.
Releases of Less Than 1,000 Pounds. For total annual
releases or off-site transfers of an EPCRA section 313
chemical from the facility of less than 1,000 pounds, the
amount may be reported either as an estimate or by using the
range codes that have been developed (range reporting in
section 5 does not apply to PBT chemicals). The reporting
range codes to be used are:
Code
A
B
C
Range (pounds)
1-10
11^99
500-999
Do not enter a range code and an estimate in the same box in
column A. Total annual on-site releases of an EPCRA
section 313 chemical from the facility of less than 1 pound
may be reported in one of several ways. You should round
the value to the nearest pound. If the estimate is greater than
0.5 pound, you should either enter the range code "A" for
"1-10" or enter"!" in column A. If the release is equal to or
less than 0.5 pound, you may round to zero and enter "0" in
column A.
Note that total annual releases of 0.5 pound or less from the
processing or otherwise use of an article maintain the article
status of that item. Thus, if the only releases you have are
from processing an article, and such releases are equal to or
less than 0.5 pound per year, you are not required to submit
a report for that EPCRA section 313 chemical. The 0.5-
pound release determination does not apply to just a single
article. It applies to the cumulative releases from the
processing or otherwise use of the same type of article (e.g.,
sheet metal or plastic film) that occurs over the course of the
reporting year.
Releases of 1,000 Pounds or More. For releases to any
medium that amount to 1,000 pounds or more for the year,
you must provide an estimate in pounds per year in column
A. Any estimate provided in column A need not be reported
to more than two significant figures. This estimate should be
in whole numbers. Do not use decimal points.
Toxics Release Inventory Reporting Forms and Instructions 43
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Instructions for Completing Part II of EPA Form R
Calculating On-Site Releases. To provide the release
information required in column A in this section, you must
use the best readily available data (including relevant
monitoring data and emissions measurements) collected at
your facility to meet other regulatory requirements or as part
of routine plant operations, to the extent you have such data
for the EPCRA section 313 chemical.
When relevant monitoring data or emission measurements are
not readily available, reasonable estimates of the amounts
released must be made using published emission factors,
material balance calculations, or engineering calculations.
You may not use emission factors or calculations to estimate
releases if more accurate data are available.
No additional monitoring or measurement of the quantities or
concentrations of any EPCRA section 313 chemical released
into the environment, or of the frequency of such releases,
beyond that required under other provisions of law or
regulation or as part of routine plant operations, is required
for the purpose of completing Form R.
You must estimate, as accurately as possible, the quantity (in
pounds) of the EPCRA section 313 chemical or chemical
category that is released annually to each environmental
medium on-site. Include only the quantity of the EPCRA
section 313 chemical in this estimate. If the EPCRA section
313 chemical present at your facility was part of a mixture or
other trade name product, calculate only the releases of the
EPCRA section 313 chemical, not the other components of
the mixture or other trade name product. If you are only able
to estimate the releases of the mixture or other trade name
product as a whole, you must assume that the release of the
EPCRA section 313 chemical is proportional to its
concentration in the mixture or other trade name product. See
Part 40, Section 372.30(b) of the Code of Federal
Regulations for further information on how to calculate the
concentration and weight of the EPCRA section 313 chemical
in the mixture or other trade name product.
If you are reporting an EPCRA section 313 chemical category
listed in Table II of these instructions rather than a specific
EPCRA section 313 chemical, you must combine the release
data for all chemicals in the EPCRA section 313 chemical
category (e.g., all listed members of certain glycol ethers or
all listed members of chlorophenols) and report the aggregate
amount for that EPCRA section 313 chemical in that category
separately. For example, if your facility releases 3,000
pounds per year of 2-chlorophenol, 4,000 pounds per year of
3 -chlorophenol, and 4,000 pounds peryear of 4-chlorophenol
to air as fugitive emissions, you should report that your
facility releases 11,000 pounds per year of chlorophenols to
air as fugitive emissions in Part II, Section 5.1.
For aqueous ammonia solutions, releases should be reported
based on 10% of total aqueous ammonia. Ammonia
evaporating from aqueous ammonia solutions is considered
to be anhydrous ammonia; therefore, 100% of the anhydrous
ammonia should be reported if it is released to the
environment. For dissociable nitrate compounds, release
estimates should be based on the weight of the nitrate only.
For metal category compounds (e.g., chromium compounds),
report releases of only the parent metal. For example, a user
of various inorganic chromium salts would report the total
chromium released regardless of the chemical compound and
exclude any contribution to mass made by the other portion
of the compound.
Column B: Basis of Estimate
For each release estimate, you are required to indicate the
principal method used to determine the amount of release
reported. You will enter a letter code that identifies the
method that applies to the largest portion of the total
estimated release quantity.
The codes are as follows:
M Estimate is based on monitoring data or measurements
for the EPCRA section 313 chemical.
C Estimate is based on mass balance calculations, such as
calculation of the amount of the EPCRA section 313
chemical in wastes entering and leaving process
equipment.
E Estimate is based on published emission factors, such
as those relating release quantity to through-put or
equipment type (e.g., air emission factors).
O Estimate is based on other approaches such as
engineering calculations (e.g., estimating volatilization
using published mathematical formulas) or best
engineering judgment. This would include applying an
estimated removal efficiency to a treatment, even if the
composition of the waste before treatment was fully
identified through monitoring data.
For example, if 40% of stack emissions of the reported
EPCRA section 313 chemical were derived using monitoring
data, 30% by mass balance, and 30% by emission factors,
you would enter the code letter "M" for monitoring.
If the monitoring data, mass balance, or emission factor used
to estimate the release is not specific to the EPCRA section
313 chemical being reported, the form should identify the
estimate as based on engineering calculations or best
engineering judgment (O).
If a mass balance calculation yields the flow rate of a waste,
but the quantity of reported EPCRA section 313 chemical in
the waste is based on solubility data, report "O" because
"engineering calculations" were used as the basis of estimate
44 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
of the quantity of the EPCRA section 313 chemical in the
waste.
If the concentration of the EPCRA section 313 chemical in
the waste was measured by monitoring equipment and the
flow rate of the waste was determined by mass balance, then
the primary basis of the estimate is "monitoring" (M). Even
though a mass balance calculation also contributed to the
estimate, "monitoring" should be indicated because
monitoring data were used to estimate the concentration of
the waste.
Mass balance (C) should only be indicated if it is directly
used to calculate the mass (weight) of EPCRA section 313
chemical released. Monitoring data should be indicated as
the basis of estimate only if the EPCRA section 313 chemical
concentration is measured in the waste being released into the
environment. Monitoring data should not be indicated, for
example, if the monitoring data relate to a concentration of
the EPCRA section 313 chemical in other process streams
within the facility.
It is important to realize that the accuracy and proficiency of
release estimation will improve over time. However,
submitters are not required to use new emission factors or
estimation techniques to revise previous FormR submissions.
Column C: Percent From Stormwater
This column relates only to Section 5.3discharges to
receiving streams or water bodies. If your facility has
monitoring data on the amount of the EPCRA section 313
chemical in stormwater runoff (including unchanneled
runoff), you must include that quantity of the EPCRA section
313 chemical in your water release in column A and indicate
the percentage of the total quantity (by weight) of the EPCRA
section 313 chemical contributed by stormwater in column C
(Section 5.3C).
If your facility has monitoring data on the EPCRA section
313 chemical and an estimate of flow rate, you must use these
data to determine the percent stormwater.
If you have monitored stormwater but did not detect the
EPCRA section 313 chemical, enter zero in column C. If
your facility has no stormwater monitoring data for the
chemical, enter NA in this space on the form.
If your facility does not have periodic measurements of
stormwater releases of the EPCRA section 313 chemical, but
has submitted chemical-specific monitoring data in permit
applications, then these data must be used to calculate the
percent contribution from stormwater. One way to calculate
the flow rates from stormwater runoff is the Rational Method.
In this method, flow rates, Q, can be estimated by multiplying
the land area of the facility, A, by the runoff coefficient, C,
and then multiplying that figure by the annual rainfall
intensity, I (i.e., Q = A*C*I). The rainfall intensity, I, is
specific to the geographical area of the country where the
facility is located, and may be obtained from most standard
engineering manuals for hydrology. The flow rate, Q, will
have volumetric dimensions per unit time, and will have to be
converted to units of pounds per year. The runoff coefficient
represents the fraction of rainfall that does not seep into the
ground but runs off as stormwater. The runoff coefficient is
directly related to how the land in the drainage area is used.
(See table below)
Description of Land Area
Business
Downtown areas
Neighborhood areas
Industrial
Light areas
Heavy areas
Industrial
Railroad yard areas
Unimproved areas
Streets
Asphaltic
Concrete
Brick
Drives and walks
Roofs
Lawns: Sandy Soil
Flat, 2%
Average, 2-7%
Steep, 7%
Lawns: Heavy Soil
Flat, 2%
Average, 2-7%
Steep, 7%
Runoff Coefficient
0.70-0.95
0.50-0.70
0.50-0.80
0.60-0.90
0.20-0.40
0.10-0.30
0.70-0.95
0.80-0.95
0.70-0.85
0.70-0.85
0.75-0.95
0.05-0.10
0.10-0.15
0.15-0.20
0.13-0.17
0.18-0.22
0.25-0.35
Choose the most appropriate runoff coefficient for your site
or calculate a weighted-average coefficient, which takes into
account different types of land use at your facility:
Weighted-average runoff coefficient =
(Area 1 % of total)(Cl) + (Area 2 % of total)(C2) +
(Area 3 % of total)(C3) + ... + (Area i % of total)(Ci)
where
Ci = runoff coefficient for a specific land use of
Area i.
Toxics Release Inventory Reporting Forms and Instructions 45
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Instructions for Completing Part II of EPA Form R
Example 13: Stormwater Runoff
Your facility is located in a semi-arid region of the United States that has an annual precipitation (including snowfall) of 12
inches of rain. (Snowfall should be converted to the equivalent inches of rain; assume one foot of snow is equivalent to one inch
of rain.) The total area covered by your facility is 42 acres (about 170,000 square meters or 1,829,520 square feet). The area
of your facility is 50% unimproved area, 10% asphaltic streets, and 40% concrete pavement.
The total Stormwater runoff from your facility is therefore calculated as follows:
Land Use
Unimproved area
Asphaltic streets
Concrete pavement
% Total Area
50
10
40
Runoff
Coefficient
0.20
0.85
0.90
Weighted-average runoff coefficient = [(50%) x (0.20)] + [(10%) x (0.85)] + [(40%) x (0.90)] = 0.545
(Rainfall) x (land area) x (conversion factor) x (runoff coefficient) = Stormwater runoff
(1 ft/year) x (1,829,520 ft2) x (7.48 gal/ft3) x (0.545) = 7,458,222 gallons/year
Total Stormwater runoff = 7,458,222 gallons/year
Your Stormwater monitoring data shows that the average concentration of zinc in the Stormwater runoff from your facility from
a biocide containing a zinc compound is 1.4 milligrams per liter. The total amount of zinc discharged to surface water through
the plant wastewater discharge (non-stormwater) is 250 pounds per year. The total amount of zinc discharged with Stormwater
is:
(7,458,222 gallons stormwater)x(3.785 liters/gallon) = 28,229,370 liters Stormwater
(28,229,370 liters stormwater)x(1.4 mg zinc/liter) x 10~3 g/mg x (1/454) Ib/g = 87 Ib zinc.
The total amount of zinc discharged from all sources of your facility is:
250 pounds zinc from wastewater discharged
+87 pounds zinc from Stormwater runoff
337 pounds zinc total water discharged
The percentage of zinc discharge through Stormwater reported in section 5.3 column C on Form R is:
(87/337)xlOO% = 26%
Section 6. Transfers of the EPCRA Section
313 Chemical in Wastes to Off-Site Locations
You must report in this section the total annual quantity of
the EPCRA section 313 chemical in wastes sent to any off-
site facility for the purposes of disposal, treatment, energy
recovery, or recycling. Report the total amount of the
EPCRA section 313 chemical transferred off-site after any
on-site waste treatment, recycling, or removal is completed.
For all toxic chemicals (except the dioxin and dioxin-like
compounds category), do not enter the values in Section 6 in
gallons, tons, liters, or any measure other than pounds. You
must also enter the values as whole numbers. Numbers
following a decimal point are not acceptable for toxic
chemicals other than those designated as PBT chemicals. For
PBT chemicals, facilities should report release and other
waste management quantities greater than 0.1 pound (except
the dioxin and dioxin-like compounds category) provided the
accuracy and the underlying data on which the estimate is
based supports this level of precision. For the dioxin and
dioxin-like compounds category, facilities should report at a
level of precision supported by the accuracy of the underlying
data and the estimation techniques on which the estimate is
based. However, the smallest quantity that need be reported
on the Form R for the dioxin and dioxin-like compounds
category is 0.0001 grams (See example 12 on page 41).
Notwithstanding the numeric precision used when
46 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
determining reporting eligibility thresholds, facilities should
report on Form R to the level of accuracy that their data
supports, up to seven digits to the right of the decimal. EPA's
reporting software and data management systems support
data precision to seven digits to the right of the decimal.
NA vs. a Numeric Value (e.g., Zero). You should enter a
numeric value if you transfer an EPCRA section 313
chemical to a publicly owned treatment works (POTW) or
transfer wastes containing that toxic chemical to other off-site
locations. If the aggregate amount transferred was less than
0.5 pound, then you should enter zero (unless the chemical is
listed as a PBT chemical). Also report zero for transfers of
listed mineral acids (i.e., hydrogen fluoride and nitric acid) if
they have been neutralized to a pH of 6 or above prior to
discharge to a POTW; do not check NA.
However, if you do not discharge wastewater containing the
reported EPCRA section 313 chemical to a POTW, enter NA
in the box for the POTW's name in Section 6. l.B._ If you
do not ship or transfer wastes containing the reported EPCRA
section 313 chemical to other off-site locations, enter NA in
the box for the off-site location's EPA Identification Number
in Section 6.2._.
Important: You must number the boxes for reporting the
information for each POTW or other off-site location in
Sections 6.1 and 6.2. In the upper left hand corner of each
box, the section number is either 6. l.B._. or 6.2._.
If you report a transfer of the listed EPCRA section 313
chemical to one or more POTWs, number the boxes in
Section 6.1.B as 6.I.B.J., 6.1.B.2, etc. If you transfer the
EPCRA section 313 chemical to more than two POTWs,
photocopy page 3 of Form R as many times as necessary and
then number the boxes consecutively for each POTW. At the
bottom of Part II Section 6.1 of the Form R you will find
instructions for indicating the total number of page 3s that
you are submitting as part of Form R, as well as indicating
the sequence of those pages. For example, your facility
transfers the reported EPCRA section 313 chemical in
wastewaters to three POTWs. You would photocopy page 3
once, indicate at the bottom of each page 3 that there are a
total of two page 3s and then indicate the first and second
page 3. The boxes for the two POTWs on the first page 3
would be numbered 6.1.B.j_ and 6.1.B.2, while the box for
third POTW on the second page 3 would be numbered
6.I.B.3.
If you report a transfer of the EPCRA section 313 chemical
to one or more other off-site locations, number the boxes in
section 6.2 as 6.2.1, 6.2.2, etc. If you transfer the EPCRA
section 313 chemical to more than two other off-site
locations, photocopy page 4 of Form R as many times as
necessary and then number the boxes consecutively for each
off-site location. At the bottom of page 4 you will find
instructions for indicating the total number of page 4s that
you are submitting as part of Form R as well as indicating the
sequence of those pages. For example, your facility transfers
the reported EPCRA section 313 chemical to three other off-
site locations. You would photocopy page 4 once, indicate at
the bottom of Section 6.2 on each page 4 that there are a total
of two page 4s and then indicate the first and second page 4.
The boxes for the two off-site locations on the first page 4
would be numbered 6.2.1 and 6.2.2, while the box for the
third off-site location on the second page 4 would be
numbered 6.2.3.
6.1 Discharges to Publicly Owned Treatment Works
In Section 6. LA, estimate the quantity of the reported
EPCRA section 313 chemical transferred to all publicly
owned treatment works (POTWs) and the basis upon which
the estimate was made. In Section 6. I.E., enter the name and
address for each POTW to which your facility discharges or
otherwise transfers wastewater containing the reported
EPCRA section 313 chemical. The most common transfers of
this type will be conveyances of the toxic chemical in facility
wastewater through underground sewage pipes; however,
materials may also be trucked or transferred via some other
direct methods to a POTW.
If you do not discharge wastewater containing the reported
EPCRA section 313 chemical to a POTW, enter NA in the
box for the POTW's name in Section 6. l.B._ (See discussion
of NA vs. a Numeric Value (e.g., Zero) in the introduction of
Section 6).
6.1.A.1 Total Transfers
Enter the total amount, in pounds, of the reported EPCRA
section 313 chemical that is contained in the wastewaters
transferred to all POTWs. Do not enter the total poundage of
the wastewaters. If the total amount transferred is less than
1,000 pounds, you may report a range by entering the
appropriate range code (range reporting in section 6.I.A.I
does not apply to PBT chemicals). The following reporting
range codes are to be used:
Code
A
B
C
Reporting Range (in pounds)
1-10
11^99
500-999
6.1.A.2 Basis of Estimate
You must identify the basis for your estimate of the total
quantity of the reported EPCRA section 313 chemical in the
wastewater transferred to all POTWs. Enter one of the
following letter codes that applies to the method by which the
largest percentage of the estimate was derived.
Toxics Release Inventory Reporting Forms and Instructions 47
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Instructions for Completing Part II of EPA Form R
M Estimate is based on monitoring data or measurements
for the EPCRA section 313 chemical as transferred to
an off-site facility.
C Estimate is based on mass balance calculations, such as
calculation of the amount of the EPCRA section 313
chemical in streams entering and leaving process
equipment.
E Estimate is based on published emission factors, such as
those relating release quantity to through-put or
equipment type (e.g., air emission factors).
O Estimate is based on other approaches such as
engineering calculations (e.g., estimating volatilization
using published mathematical formulas) or best
engineering judgment. This would include applying an
estimated removal efficiency to a waste stream, even if
the composition of the stream before treatment was
fully identified through monitoring data.
If you transfer an EPCRA section 313 chemical to more than
one POTW, you should report the basis of estimate that was
used to determine the largest percentage of the EPCRA
section 313 chemical that was transferred.
6.2 Transfers to Other Off-Site Locations
In Section 6.2 enter the EPA Identification Number, name,
and address for each off-site location to which your facility
ships or transfers wastes containing the reported EPCRA
section 313 chemical for the purposes of disposal, treatment,
energy recovery, or recycling. Also estimate the quantity of
the reported EPCRA section 313 chemical transferred and the
basis upon which the estimate was made. This would include
any residual chemicals in "empty" containers transferred off-
site. EPA expects that all containers (bags, totes, drums, tank
trucks, etc.) will have a small amount of residual solids
and/or liquids. Please see Example 14 on page 49 for residue
quantities left in drums and tanks when emptied.
If appropriate, you must report multiple activities for each
off-site location. For example, if your facility sends a
reported EPCRA section 313 chemical in waste to an off-site
location where some of the EPCRA section 313 chemical is
to be recycled while the remainder of the quantity transferred
is to be treated, you must report both the waste treatment and
recycle activities, along with the quantity associated with
each activity.
If your facility transfers an EPCRA section 313 chemical to
an off-site location and that off-site location performs more
than four activities on that chemical, provide the necessary
information in Box 6.2.1 for the off-site facility and the first
four activities. Provide the information on the remainder of
the activities in Box 6.2.2 and provide again the off-site
facility identification and location information.
If you do not ship or transfer wastes containing the EPCRA
section 313 chemical to other off-site locations, enter NA
(See discussion of NA vs. aNumeric Value (e.g., Zero) in the
introduction of Section 6) in the box for the off-site location's
EPA Identification Number (defined in 40 CFR 260.10 and
therefore commonly referred to as the RCRA ID Number).
This number may be found on the Uniform Hazardous Waste
Manifest, which is required by RCRA regulations. If you
ship or transfer wastes containing an EPCRA section 313
chemical and the off-site location does not have an EPA
Identification Number (e.g., it does not accept RCRA
hazardous wastes or you do not know the RCRA
Identification Number), enter NA in the box for the off-site
location EPA Identification Number. If you ship or transfer
the reported EPCRA section 313 chemical in wastes to
another country, you do not need to report a RCRA ID for
that waste. Indicate NA in the RCRA ID field. Enter the
complete address of the non-U.S. facility in the off-site
address fields, the city in the city field, the non-U.S. state or
province in the county field, the postal code in the zip code
field, and the foreign country code in the country field. The
most commonly used FIPs codes are listed in Table IV. To
obtain a FIPS code for a country not listed, contact the
EPCRA Call Center. There is nothing to enter in the state
field.
For Section 6.2 in both ATRS and TRI-ME: If your off-
site location is outside the U.S., click the "Non-U.S."
box. For off-site locations outside the U.S., you do not
need to report a RCRA ID. Indicate "NA" in the RCRA
ID field. You will still provide the name, street address,
and city. There is nothing to enter in the State field.
You then enter the postal code, county or province, and
country in the respective fields.
Remember, both ATRS and TRI-ME can accept
international postal codes and nine-digit zip codes for
U.S. addresses.
48 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Summary of Residue Quantities From Pilot-Scale Experimental Studya>b
(weight percent of drum capacity)
Unloading
Method
Pumping
Pumping
Pouring
Pouring
Gravity
Drain
Gravity
Drain
Gravity
Drain
Vessel Type
Steel drum
Plastic drum
Bung-top steel
drum
Open-top steel
drum
Slope-bottom
steel tank
Dish-bottom
steel tank
Dish-bottom
glass-lined tank
Value
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Material
Kerosene0
1.93-3.08
2.48
1.69-4.08
2.61
0.244 - 0.472
0.404
0.032-0.080
0.054
0.020-0.039
0.033
0.031-0.042
0.038
0.024-0.049
0.040
Water"
1.84-2.61
2.29
2.54-4.67
3.28
0.266 - 0.458
0.403
0.026-0.039
0.034
0.016-0.024
0.019
0.033-0.034
0.034
0.020 - 0.040
0.033
Motor Oile
1.97-2.23
2.06
1.70-3.48
2.30
0.677-0.787
0.737
0.328-0.368
0.350
0.100-0.121
0.111
0.133-0.191
0.161
0.112-0.134
0.127
Surfactant
Solution*
3.06
3.06
Not
Available
0.485
0.485
0.089
0.089
0.048
0.048
0.058
0.058
0.040
0.040
Trom "Releases During Cleaning of Equipment." Prepared by PEI Associates, Inc., for the U.S. Environmental Protection Agency, Office of
Pesticides and Toxic Substances, Washington DC, Contract No. 68-02-4248. June 30, 1986.
bThe values listed in this table should only be applied to similar vessel types, unloading methods, and bulk fluid materials. At viscosities greater
than 200 centipoise, the residue quantities can rise dramatically and the information on this table is not applicable.
Tor kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
dFor water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
Tor motor oil, viscosity = 94 centipoise, surface tension = 34.5 dynes/cm2
tor surfactant solution, viscosity = 3 centipoise, surface tension =31.4 dynes/cm2
Example 14: Container Residue
You have determined that a Form R for an EPCRA section 313 chemical must be submitted. The facility purchases and uses one
thousand 55-gallon steel drums that contain a 10% solution of the chemical. Further, it is assumed that the physical properties
of the solution are similar to water. The solution is pumped from the drums directly into a mixing vessel and the "empty" drums
are triple-rinsed with water. The rinse water is indirectly discharged to a POTW and the cleaned drums are sent to a drum
reclaimer.
In this example, it can be assumed that all of the residual solution in the drums was transferred to the rinse water. Therefore, the
quantity transferred to the drum reclaimer should be reported as "zero." The annual quantity of residual solution that is
transferred to the rinse water can be estimated by multiplying the mean weight percent of residual solution remaining in water
from pumping a steel drum (2.29% from the preceding table, "Summary of Residue Quantities From Pilot-Scale Experimental
Study") by the total annual weight of solution in the drum (density of solution multiplied by drum volume). If the density is not
known, it may be appropriate to use the density of water (8.34 pounds per gallon):
(2.29%) x (8.34 pounds/gallon) x (55 gallons/drum) x (1,000 drums) = 10,504 pounds solution
The concentration of the EPCRA section 313 chemical in the solution is only 10%.
(10,504 pounds solution) x (10%) = 1,050 pounds
Therefore, 1,050 pounds of the chemical are transferred to the POTW.
Toxics Release Inventory Reporting Forms and Instructions 49
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Instructions for Completing Part II of EPA Form R
6.2a Column A: Total Transfers
For each off-site location, enter the total amount, in pounds (in
grams for dioxin and dioxin-like compounds), of the EPCRA
section 313 chemical that is contained in the waste transferred
to that location. Do not enter the total poundage of the waste.
If you do not ship or transfer wastes containing the EPCRA
section 313 chemical to other off-site locations, enter NA (See
discussion of NA vs. a Numeric Value (e.g., Zero) in the
introduction of Section 6) in the box for the off-site location's
EPA Identification Number (defined in 40 CFR 260.10 and
therefore commonly referred to as the RCRA ID Number). If
the total amount transferred is less than 1,000 pounds, you may
report a range by entering the appropriate range code (range
reporting in section 6.2 does not apply to PBT chemicals). The
following reporting range codes are to be used:
chemical being recovered and only a fraction subsequently
treated, report the appropriate recycling activity along with the
quantity.
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999
If you transfer the EPCRA section 313 chemical in wastes to an
off-site facility for distinct and multiple purposes, you must
report those activities for each off-site location, along with the
quantity of the reported EPCRA section 313 chemical associated
with each activity. For example, your facility transfers a total
of 15,000 pounds of toluene to an off-site location that will use
5,000 pounds for the purposes of energy recovery, enter 7,500
pounds into a recovery process, and dispose of the remaining
2,500 pounds. These quantities and the associated activity
codes must be reported separately in Section 6.2. (See Figure 4
for a hypothetical Section 6.2 completed for two off-site
locations, one of which receives the transfer of 15,000 pounds
of toluene as detailed.) If you have fewer than four total
transfers in Section 6.2 Column A (see examples in Figure 4),
an NA should be placed in Column A of the first unused row to
indicate the termination of the sequence. If all four rows are
used, there is no need to terminate the sequence. If there are
more than four total transfers, re-enter the name of the off-site
location, address, etc. in the next row (6.2.2) and then enter NA
when the sequence has terminated if there are fewer than 8 (i.e.
anytime there are fewer than 4 transfers listed in a Section 6.2
block, an NA should be used to terminate the sequence).
Do not double or multiple count amounts transferred off-site.
For example, when a reported EPCRA section 313 chemical is
sent to an off-site facility for sequential activities and the
specific quantities associated with each activity are unknown,
report only a single quantity (the total quantity transferred to
that off-site location) along with a single activity code. In such
a case, report the activity applied to the majority of the reported
EPCRA section 313 chemical sent off-site, not the ultimate
disposition of the EPCRA section 313 chemical. For example,
when an EPCRA section 313 chemical is first recovered and
then treated with the majority of the EPCRA section 313
Example 15: Reporting Metals and Metal Category
Compounds that are Sent Off-site
A facility manufactures a product containing elemental
copper, exceeding the processing threshold for copper.
Various metal fabrication operations for the process produce
a wastewater stream that contains some residual copper and
off-specification copper material. The wastewater is
collected and sent directly to a POTW. Periodic monitoring
data show that 500 pounds of copper were transferred to the
POTW in the reporting year. The off-specification products
(containing copper) are collected and sent off-site to a
landfill. Sampling analyses of the product combined with
hazardous waste manifests were used to determine that
1,200 pounds of copper in the off-spec product were sent to
the off-site landfill.
Therefore, the facility should report 500 pounds in Section
6.1, 1200 pounds in Section 6.2 using waste code M72
(Landfill/Disposal Surface Impoundment) and 1,700 pounds
in Section 8.1 Quantity Released Off-site.
Note that for EPCRA section 313 chemicals that are not
metals or metal category compounds, the quantity sent to
POTWs and to other off-site treatment locations should be
reported in Section 8.7 Quantity Treated Off-site.
6.2b Column B: Basis of Estimate
You must identify the basis for your estimates of the quantities
of the reported EPCRA section 313 chemical in waste
transferred to each off-site location. Enter one of the following
letter codes that applies to the method by which the largest
percentage of the estimate was derived.
M Estimate is based on monitoring data or measurements
for the EPCRA section 313 chemical as transferred to
an off-site facility.
C Estimate is based on mass balance calculations, such as
calculation of the amount of the EPCRA section 313
chemical in streams entering and leaving process
equipment.
E Estimate is based on published emission factors, such
as those relating release quantity to throughput or
equipment type (e.g., air emission factors).
O Estimate is based on other approaches such as
engineering calculations (e.g., estimatingvolatilization
using published mathematical formulas) or best
50 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form R
engineering judgment. This would include applying an
estimated removal efficiency to a waste stream, even
if the composition of the stream before treatment was
fully identified through monitoring data.
6.2c Column C: Type of Waste Management: Disposal/
Treatment/Energy Recovery/Recycling
Enter one of the following M codes to identify the type of
disposal, treatment, energy recovery, or recycling methods used
by the off-site location for the reported EPCRA section 313
chemical. You must use more than one line and code for a
single location when distinct quantities of the reported EPCRA
section 313 chemical are subj ect to different waste management
activities, including disposal, treatment, energy recovery, or
recycling. You should use the code that, to the best of your
knowledge, represents the ultimate disposition of the chemical.
If the EPCRA section 313 chemical is sent off-site for further
direct reuse (e.g., an EPCRA section 313 chemical in used
solvent that will be used as lubricant at another facility) and
does not undergo a waste management activity (i.e., release
[including disposal], treatment, energy recovery, or recycling
[recovery]) prior to that reuse, it need not be reported in section
6.2 or section 8.
Incineration vs. Energy Recovery
You must distinguish between incineration, which is waste
treatment, and legitimate energy recovery. For you to claim that
a reported EPCRA section 313 chemical sent off-site is used for
the purposes of energy recovery and not for waste treatment, the
EPCRA section 313 chemical must have a significant heating
value and must be combusted in an energy recovery unit such as
an industrial boiler, furnace, or kiln. In a situation where the
reported EPCRA section 313 chemical is in a waste that is
combusted in an energy recovery unit, but the EPCRA section
313 chemical does not have a significant heating value, e.g.,
CFCs, use code M54, Incineration/ Insignificant Fuel Value, to
indicate that the EPCRA section 313 chemical was incinerated
in an energy recovery unit but did not contribute to the heating
value of the waste.
Metals and Metal Category Compounds
Metals and metal category compounds will be managed in waste
either by being released (including disposed) or by being
recycled. Remember that the release and other waste
management information that you report for metal category
compounds will be the total amount of the parent metal released
or recycled and NOT the whole metal category compound. The
metal has no heat value and thus cannot be combusted for
energy recovery and cannot be treated because it cannot be
destroyed. Thus, transfers of metals and metal category
compounds for further waste management should be reported as
either a transfer for recycling or a transfer for disposal. The
applicable waste management codes for transfers of metals and
metal category compounds for recycling are M24, metals
recovery, M93, waste broker recycling, or M26, other
reuse/recovery. Applicable codes for transfers for disposal
include M10, M41, M62, M71, M72, M73, M79, M90, M94,
and M99. These codes are for off-site transfers for further
waste management in which the wastestream may be treated but
the metal contained in the wastestream is not treated and is
ultimately released. For example, M41 would be used for a
metal or metal category compound that is stabilized in
preparation for disposal.
Applicable codes for Part II, Section 6.2, column C are:
Disposal
M10 Storage Only
M41 Solidification/StabilizationMetals and Metal
Category Compounds only
M62 Wastewater Treatment (Excluding POTW) Metals
and Metal Category Compounds only
M71 Underground Inj ection
M72 Landfill/Disposal Surface Impoundment
M73 Land Treatment
M79 Other Land Disposal
M90 Other Off-Site Management
M94 Transfer to Waste Broker Disposal
M99 Unknown
Treatment
M40 Solidification/Stabilization
M50 Incineration/Thermal Treatment
M54 Incineration/Insignificant Fuel Value
M61 Wastewater Treatment (Excluding POTW)
M69 Other Waste Treatment
M95 Transfer to Waste Broker Waste Treatment
Energy Recovery
M56 Energy Recovery
M92 Transfer to Waste Broker Energy Recovery
Recycling
M20 Solvents/Organics Recovery
M24 Metals Recovery
M26 Other Reuse or Recovery
M28 Acid Regeneration
M93 Transfer to Waste Broker Recycling
Toxics Release Inventory Reporting Forms and Instructions 51
-------
Instructions for Completing Part II of EPA Form R
Figure 4
Hypothetical Secton 6.2 Completed for Two Off-Site Locations
This off-site location receives a transfer of 15,000 pounds of toluene and will combust 5,000 pounds for the purposes of energy
recovery, enter 7,500 pounds into a recovery process, and dispose of the remaining 2,500 pounds.
This off-site location receives a transfer of 12,500 pounds of tetrachloroethylene (perchloroethylene) that is part of a waste that is
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATION
6.2.1
Off-Site EPA Identification Number (RCRA No.)
Off-Site Location Name
Street Address
City
State
Acme \^
UULttbblb
/aste Services
2461
Market Street
Releaseville
CO
Zip Code
A. Total Transfers (pounds)/year)
(enter range code or estimate)
1.
2.
3.
4.
5,000
7,500
2,500
NA
O(\A(. i Is location under cc
oU'fO 1 facility or parent co
B. Basis of Estimate
(enter code)
i.O
2.C
3.0
4.
County
TTill
11111
ntrol of reporting Q y E No
mpany " '
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. M56
2. M20
3. M72
4. M
combusted for the purposes of energy recovery in an industrial furnace. Note that the tetrachloroethylene is reported using code
M54 to indicate that it is combusted in an energy recovery unit but it does not contribute to the heating value of the waste.
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATION
6.2.2
Off-Site EPA Identification Number (RCRA No.)
Off-Site Location Name
Street Address
City
State
UJJJlb//2
Conibus
tion, Inc.
5432
25 Facility Road
Dumfry
CO
Zip Code
A. Total Transfers (pounds)/year)
(enter range code or estimate)
1.
2.
12,500
NA
3.
4.
Sfi^fifi 's 'ocation under cc
oU J(J(J facility or parent co
B. Basis of Estimate
(enter code)
i. 0
2.
3.
4.
County
DU111S
>ntrol of reporting i i Yes El No
mpany
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. M54
2. M
3. M
4. M
52 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Section 7. On-Site Waste Treatment, Energy
Recovery, and Recycling Methods
You must report in this section the methods of waste treatment,
energy recovery, and recycling applied to the reported EPCRA
section 313 chemical in wastes on-site. There are three separate
sections for reporting such activities.
Section 7A
Efficiency
On-Site Waste Treatment Methods and
Most of the chemical-specific information required by EPCRA
section 313 that is reported on Form R is specific to the EPCRA
section 313 chemical rather than the waste stream containing the
EPCRA section 313 chemical. However, EPCRA section 313
does require that waste treatment methods applied on-site to
waste streams that contain the EPCRA section 313 chemical be
reported. This information is reportable regardless of whether
the facility actively applies treatment or the treatment of the
waste stream occurs passively. This information is collected in
Section 7 A of Form R.
In Section 7A, you must provide the following information if
you treat waste streams containing the reported EPCRA section
313 chemical on-site:
(a) The general waste stream types containing the EPCRA
section 313 chemical being reported;
(b) The waste treatment method(s) or sequence used on all
waste streams containing the EPCRA section 313
chemical;
(c) The range of concentration of the EPCRA section 313
chemicals in the influent to the waste treatment method;
(d) The efficiency of each waste treatment method or waste
treatment sequence in destroying or removing the EPCRA
section 313 chemical; and
(e) Whether the waste treatment efficiency figure was based
on actual operating data.
Use a separate line in Section 7A for each general waste stream
type. Report only information about treatment of waste streams
at your facility, not information about off-site waste treatment.
If you do not perform on-site treatment of waste streams
containing the reported EPCRA section 313 chemical, check the
NA box at the top of Section 7A.
7A Column a: General Waste Stream
For each waste treatment method, indicate the type of waste
stream containing the EPCRA section 313 chemical that is
treated. Enter the letter code that corresponds to the general
waste stream type:
A Gaseous (gases, vapors, airborne particulates)
W Wastewater (aqueous waste)
L Liquid waste streams (non-aqueous waste)
S Solid waste streams (including sludges and slurries)
If a waste is a combination of water and organic liquid and the
organic content is less than 50%, report it as a wastewater (W).
Slurries and sludges containing water must be reported as solid
waste if they contain appreciable amounts of dissolved solids,
or solids that may settle, such that the viscosity or density of the
waste is considerably different from that of process wastewater.
7A Column b: Waste Treatment Method(s) Sequence
Enter the appropriate waste treatment code from the list below
for each on-site waste treatment method used on a waste stream
containing the EPCRA section 313 chemical, regardless of
whether the waste treatment method actually removes the
specific EPCRA section 313 chemical being reported. Waste
treatment methods must be reported for each type of waste
streambeing treated (i.e., gaseous waste streams, aqueous waste
streams, liquid non-aqueous waste streams, and solids). Except
for the air emission treatment codes, the waste treatment codes
are not restricted to any medium.
Waste streams containing the EPCRA section 313 chemical may
have a single source or may be aggregates of many sources. For
example, process water from several pieces of equipment atyour
facility may be combined prior to waste treatment. Report waste
treatment methods that apply to the aggregate waste stream, as
well as waste treatment methods that apply to individual waste
streams. If your facility treats various wastewater streams
containing the EPCRA section 313 chemical in different ways,
the different waste treatment methods must be listed separately.
If your facility has several pieces of equipment performing a
similar service in a waste treatment sequence, you may combine
the reporting for such equipment. It is not necessary to enter
four codes to cover four scrubber units, for example, if all four
are treating waste streams of similar character (e.g., sulfuric acid
mist emissions), have similar influent concentrations, and have
similar removal efficiencies. If, however, any of these
parameters differs from one unit to the next, each scrubber must
be listed separately.
If you are using the hardcopy paper form, and if your facility
performs more than eight sequential waste treatment methods on
a single general waste stream, continue listing the methods in
the next row and renumber appropriately those waste treatment
method code boxes you used to continue the sequence. For
example, if the general waste stream in box 7A. la had nine
treatment methods applied to it, the ninth method would be
indicated in the first method box for row 7A.2a. The numeral
"1" would be crossed out, and a "9" would be inserted.
Toxics Release Inventory Reporting Forms and Instructions 53
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Instructions for Completing Part II of EPA Form R
Example 16: Calculating Releases and Other Waste Management Quantities
Your facility disposes of 14,000 pounds of lead chromate (PbCrO4.PbO) in an on-site landfill and transfers 16,000 pounds of
lead selenite (PbSeC^) to an off-site land disposal facility. You would therefore be submitting three separate reports on the
following: lead compounds, selenium compounds, and chromium compounds. However, the quantities you would be reporting
would be the pounds of "parent" metal being released on-site or transferred off-site for further waste management. All quantities
are based on mass balance calculations (See Section 5, Column B for information on Basis of Estimate and Section 6.2, Column
C for waste management codes and information on transfers of EPCRA section 313 chemicals in wastes). You would calculate
releases of lead, chromium, and selenium by first determining the percentage by weight of these metals in the materials you use
as follows:
Lead Chromate (PbCrO4.PbO) Molecular weight = 546.37
Lead (2 Pb atoms) Atomic weight = 207.2x2 = 414.4
Chromium (1 Cr atom) Atomic weight = 51.996
Lead chromate is therefore (% by weight)
(414.4/546.37) = 75.85% lead and
(51.996/546.37) = 9.52% chromium
Lead Selenite (PbSeO4) Molecular weight = 350.17
Lead (1 Pb atom) Atomic weight = 207.2
Selenium (1 Se atom) Atomic weight = 78.96
Lead selenite is therefore (% by weight)
(207.2/350.17) = 59.17% lead and
(78.96/350.17) = 22.55% selenium.
The total pounds of lead, chromium, and selenium disposed on or off-site from your facility are as follows:
Lead
Disposal on-site: 0.7585 x 14,000 = 10,619 pounds from lead chromate
Transfer off-site for disposal: 0.5917 x 16,000 = 9,467 pounds from lead selenite
Chromium
Disposal on-site: 0.0952 x 14,000 = 1,333 pounds from lead chromate
Selenium
Transfer off-site for disposal: 0.2255 x 16,000 = 3,608 pounds from lead selenite
54 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Treatment applied to any other general waste stream types
would then be listed in the next empty row. In the scenario
above, for instance, the second general waste stream would
be reported in row 7 A. 3 a. See Figure 5 for an example of a
hypothetical Section 7A completed for a nine-step waste
treatment process and a single waste treatment method.
The completion of each waste treatment method sequence
should clearly be marked by using an NA following the last
waste treatment code, except in the situation in which exactly
eight waste treatment methods are listed. For example, if the
waste stream in box 7A. Ib has three waste treatment codes
listed, a NA should be placed in the fourth method box to
indicate the termination of the sequence. If the waste stream
has exactly eight waste treatment codes, there is no need to
enter an NA to terminate the sequence. If the waste stream
has more than eight waste treatment codes: (1) Enter NA in
Column C in the initial row and any subsequent rows in
which the sequence is not terminated to indicate that the
given waste stream continues on the next row (e.g., if waste
treatment codes are continued in 7A.2b from 7A. Ib, a NA
should be indicated in 7A.lc.); (2) enter NA in the box
following the last waste stream code to indicate the
termination of the sequence, unless the sequence ends in the
method box 8 (i.e., there are 8, 16, 24, 32, etc. waste stream
codes); and (3) complete the information for Columns C, D,
and E in the last row for a given sequence. For example, if
the sequence terminates in 7A.3b, then fill in all relevant
information for C, D, and E in this row. You do not need to
reenter your General Waste Stream code in column A. See
Figure 5 for an example.
If you need additional space to report under Section 7A,
photocopy page 4 of Form R as many times as necessary. At
the bottom of page 4 you will find instructions for indicating
the total number of page 4s that you are submitting as part of
Form R, as well as instructions for indicating the sequence of
those pages.
Waste Treatment Codes
Air Emissions Treatment (applicable to gaseous waste
streams only)
A01 Flare
A02 Condenser
A03 Scrubber
A04 Absorber
A05 Electrostatic Precipitator
A06 Mechanical Separation
A07 Other Air Emission Treatment
Biological Treatment
B11 Aerobic
B21 Anaerobic
B31 Facultative
B99 Other Biological Treatment
Chemical Treatment
- Lime or Sodium
CO 1 Chemical Precipitation -
Hydroxide
C02 Chemical Precipitation Sulfide
C09 Chemical Precipitation Other
C11 Neutralization
C21 Chromium Reduction
C31 Complexed Metals Treatment (other than pH
adjustment)
C41 Cyanide Oxidation Alkaline Chlorination
C42 Cyanide Oxidation Electrochemical
C43 Cyanide Oxidation Other
C44 General Oxidation (including Disinfection)
Chlorination
C45 General Oxidation (including Disinfection)
Ozonation
C46 General Oxidation (including Disinfection)
Other
C99 Other Chemical Treatment
Toxics Release Inventory Reporting Forms and Instructions 55
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Instructions for Completing Part II of EPA Form R
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
Q Not Applicable (NA) - Check here if no on-site waste treatment is applied to any
waste stream containing the toxic chemical or chemical category.
a. General
Waste Stream
(enter code)
7A.1a
W
7A.2a
7A.3a
A
7A.1b
3
6
b. Waste Treatment Method(s) Sequence
[enter 3-character code(s)]
P17
P21
7A.2b
3
6
1
4
7
9/
7A.3b
3
6
4
7
1
4
7
P12
P61
B21
C44
A01
2
5
8
2
5
8
2
5
8
P18
P42
P11
NA
NA
c. Range of Influent
Concentration
7A.1c
NA
7A.2c
1
7A.3c
1
d . Waste
Treatment
Efficiency
Estimate
7A.1d
%
7A.2d
99 %
7A.3d
91 %
e. Based on
Operating Data?
7A.1e
Yes
No
7A.2e
Yes
X
No
7A.3e
Yes
X
No
Figure 5. Hypothetical Section 7A
56 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Incineration/Thermal Treatment
F01 Liquid Injection
F11 Rotary Kiln with Liquid Inj action Unit
F19 Other Rotary Kiln
F31 Two Stage
F41 Fixed Hearth
F42 Multiple Hearth
F51 FluidizedBed
F61 Infra-Red
F71 Fume/Vapor
F81 Pyrolytic Destructor
F82 Wet Air Oxidation
F83 Thermal Drying/Dewatering
F99 Other Incineration/Thermal Treatment
Physical Treatment
P01 Equalization
P09 Other Blending
P11 Settling/Clarification
P12 Filtration
P13 Sludge Dewatering (non-thermal)
P14 Air Flotation
P15 Oil Skimming
P16 Emulsion Breaking Thermal
P17 Emulsion Breaking Chemical
P18 Emulsion Breaking Other
P19 Other Liquid Phase Separation
P21 Adsorption Carbon
P22 Adsorption Ion Exchange (other than for
recovery/reuse)
P23 Adsorption Resin
P29 Adsorption Other
P31 Reverse Osmosis (other than for recovery/reuse)
P41 Stripping Air
P42 Stripping Steam
P49 Stripping Other
P51 Acid Leaching (other than for recovery/reuse)
P61 Solvent Extraction (other than recovery/reuse)
P99 Other Physical Treatment
Solidification/Stabilization
G01 Cement Processes (including silicates)
G09 Other Pozzolonic Processes (including silicates)
Gil Asphaltic Processes
G21 Thermoplastic Techniques
G99 Other Solidification Processes
7A Column c: Range of Influent Concentration
The form requires an indication of the range of concentration
of the EPCRA section 313 chemical in the waste stream (i.e.,
the influent) as it typically enters the waste treatment step or
sequence. The concentration is based on the amount or mass
of the EPCRA section 313 chemical in the waste stream as
compared to the total amount or mass of the waste stream.
Enter in the space provided one of the following code
numbers corresponding to the concentration of the EPCRA
section 313 chemical in the influent:
1 = Greater than 10,000 parts per million (1%)
2 = 100 parts per million (0.01%) to 10,000 parts per
million (1%)
3 = 1 part per million (0.0001%) to 100 parts per million
(0.01%)
4 = 1 part per billion to 1 part per million
5 = Less than 1 part per billion
Note: Parts per million (ppm) is:
milligrams/kilogram (mass/mass) for solids and
liquids;
cubic centimeters/cubic meter (volume/volume) for
gases;
milligrams/liter for solutions or dispersions of the
chemical in water; and
milligrams of chemical/kilogram of air for
particulates in air.
If you have paniculate concentrations (at standard
temperature and pressure) as grains/cubic foot of air, multiply
by 1766.6 to convert to parts per million; if in
milligrams/cubic meter, multiply by 0.773 to obtain parts per
million. These conversion factors are for standard conditions
of 0ฐ C (32ฐF) and 760 mm Hg atmospheric pressure.
7A Column d: Waste Treatment Efficiency Estimate
In the space provided, enter the number indicating the
percentage of the EPCRA section 313 chemical removed
from the waste stream through destruction, biological
degradation, chemical conversion, or physical removal. The
waste treatment efficiency (expressed as percent removal)
represents the percentage of the EPCRA section 313 chemical
destroyed or removed (based on amount or mass), not merely
changes in volume or concentration of the EPCRA section
313 chemical in the waste stream. The efficiency, which can
reflect the overall removal from sequential treatment methods
applied to the general waste stream, refers only to the percent
destruction, degradation, conversion, or removal of the
EPCRA section 313 chemical from the waste stream, it does
not refer to the percent conversion or removal of other
constituents in the waste stream. The efficiency also does not
refer to the general efficiency of the treatment method for any
waste stream. For some waste treatment methods, the percent
removal will represent removal by several mechanisms, as in
an aeration basin, where an EPCRA section 313 chemical
Toxics Release Inventory Reporting Forms and Instructions 57
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Instructions for Completing Part II of EPA Form R
may evaporate, biodegrade, or be physically removed from
the sludge.
Percent removal can be calculated as follows:
(I-E) x 100%
I
where:
I = amount of the EPCRA section 313 chemical in
the influent waste stream (entering the waste
treatment step or sequence) and
E = amount of the EPCRA section 313 chemical in
the effluent waste stream (exiting the waste
treatment step or sequence).
Calculate the amount of the EPCRA section 313 chemical in
the influent waste stream by multiplying the concentration
(by weight) of the EPCRA section 313 chemical in the waste
stream by the total amount or weight of the waste stream. In
most cases, the percent removal compares the treated effluent
to the influent for the particular type of waste stream. For
solidification of wastewater, the waste treatment efficiency
can be reported as 100% if no volatile EPCRA section 313
chemicals were removed with the water or evaporated into
the air. Percent removal does not apply to incineration
because the waste stream, such as wastewater or liquids, may
not exist in a comparable form after waste treatment and the
purpose of incineration as a waste treatment is to destroy the
EPCRA section 313 chemical by converting it to carbon
dioxide and water or other byproducts. In cases where the
EPCRA section 313 chemical is incinerated, the percent
efficiency must be based on the amount of the EPCRA
section 313 chemical destroyed or combusted, except for
metals or metal category compounds. In the cases in which
a metal or metal category compound is incinerated, the
efficiency is always zero.
Similarly, an efficiency of zero must be reported for any
waste treatment method(s) that does not destroy, chemically
convert or physically remove the EPCRA section 313
chemical from the waste stream.
For metal category compounds, the calculation of the
reportable concentration and waste treatment efficiency must
be based on the weight of the parent metal, not on the weight
of the metal compound. Metals are not destroyed, only
physically removed or chemically converted from one form
into another. The waste treatment efficiency reported must
represent only physical removal of the parent metal from the
waste stream (except for incineration), not the percent
chemical conversion of the metal compound. If a listed waste
treatment method converts but does not remove a metal (e.g.,
chromium reduction), the method must be reported with a
waste treatment efficiency of zero.
EPCRA section 313 chemicals that are strong mineral acids
neutralized to a pH of 6 or above are considered treated at a
100% efficiency.
All data readily available at your facility must be used to
calculate waste treatment efficiency and influent EPCRA
section 313 chemical concentration. If data are lacking,
estimates must be made using best engineering judgment or
other methods.
7A Column e: Based on Operating Data?
This column requires you to indicate "Yes" or "No" to
whether the waste treatment efficiency estimate is based on
actual operating data. For example, you would check "Yes"
if the estimate is based on monitoring of influent and effluent
wastes under typical operating conditions.
If the efficiency estimate is based on published data for
similar processes or on equipment supplier's literature, or if
you otherwise estimated either the influent or effluent waste
comparison or the flow rate, check "No."
Section 7B On-Site Energy Recovery Processes
In Section 7B, you must indicate the on-site energy recovery
methods used on the reported EPCRA section 313 chemical.
Only EPCRA section 313 chemicals that have a significant
heating value and are combusted in an energy recovery unit
such as an industrial furnace, kiln, or boiler, can be reported
as combusted for energy recovery in this section. If a
reported EPCRA section 313 chemical is incinerated on-site
but does not contribute energy to the process (e.g.,
chlorofluorocarbons), it must be considered waste treated on-
site and reported in Section 7A. Metals and metal category
compounds cannot be combusted for energy recovery and
should NOT be reported in this section. Do not include the
combustion of fuel oils, such as fuel oil #6, in this section.
Energy recovery may take place only in an industrial kiln,
furnace, or boiler.
NA vs. a Numerical Value (e.g., Zero). If you do not
perform on-site energy recovery for a waste stream that
contains or contained the EPCRA section 313 chemical,
check the NA box at the top of Section 7B and enter NA in
Section 8.2. If you perform on-site energy recovery for the
waste stream that contains or contained the EPCRA section
313 chemical, enter the appropriate code in Section 7B and
enter the appropriate value in Section 8.2. If this quantity
is less than or equal to 0.5 pound, round to zero (unless the
chemical is a listed PBT chemical) and enter zero in 8.2.
(Note: for metals and metal compounds, you should only
report NA in Sections 7B and Section 8.2.)
58 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Energy Recovery Codes
U01 Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
U09 Other Energy Recovery Methods
If your facility uses more than one on-site energy recovery
method for the reported EPCRA section 313 chemical, list
the methods used in descending order (greatest to least)
based on the amount of the EPCRA section 313 chemical
entering such methods.
Section 7C On-Site Recycling Processes
In Section 7C, you must report the recycling methods used on
the EPCRA section 313 chemical.
In this section, use the codes below to report only the
recycling methods in place at your facility that are applied to
the EPCRA section 313 chemical. Do not list any off-site
recycling activities. (Information about off-site recycling
must be reported in Part II, Section 6, "Transfers of the Toxic
Chemical in Wastes to Off-Site Locations.")
NA vs. a Numerical Value (e.g., Zero). If you do not
perform on-site recycling for the reported EPCRA section
313 chemical, check the NA box at the top of Section 7C and
enter NA in Section 8.4. If you perform on-site recycling for
the reported EPCRA section 313 chemical, enter the
appropriate code in Section 7C and enter the appropriate
value in Section 8.4. If this quantity is less than or equal to
0.5 pound, round to zero (unless the chemical is a listed PBT
chemical) and enter 0 in Section 8.4.
On-Site Recycling Codes
Rll Solvents/Organics
Distillation
R12 Solvents/Organics
Evaporation
R13 Solvents/Organics
R14 Solvents/Organics
Extraction
R19 Solvents/Organics
R21 Metals Recovery-
R22 Metals Recovery -
R23 Metals Recovery -
R24 Metals Recovery -
R26 Metals Recovery -
R27 Metals Recovery -
R28 Metals Recovery -
R29 Metals Recovery -
R30 Metals Recovery -
Recovery Batch Still
Recovery Thin-Film
Recovery Fractionation
Recovery Solvent
Recovery Other
- Electrolytic
- Ion Exchange
- Acid Leaching
- Reverse Osmosis
- Solvent Extraction
- High Temperature
- Retorting
- Secondary Smelting
-Other
R40 Acid Regeneration
R99 Other Reuse or Recovery
If your facility uses more than one on-site recycling method
for an EPCRA section 313 chemical, enter the codes in the
space provided in descending order (greatest to least) based
on the volume of the reported EPCRA section 313 chemical
recovered by each process. If your facility uses more than ten
separate methods for recycling the reported EPCRA section
313 chemical on-site, then list the ten activities that recover
the greatest amount of the EPCRA section 313 chemical
(again, in descending order).
Section 8. Source Reduction
and Recycling Activities
This section includes the data elements mandated by section
6607 of the Pollution Prevention Act of 1990 (PPA).
In Section 8, you must provide information about source
reduction activities and quantities of the EPCRA section 313
chemicals managed as waste. For all appropriate questions,
report only the quantity, in pounds, of the reported EPCRA
section 313 chemical itself (except the dioxin and dioxin-like
compound category). Do not include the weight of water,
soil, or other waste constituents. When reporting on the
metal category compounds, report only the amount of the
metal portion of the compound as you do when estimating
release amounts.
Sections 8.1 through 8.9 must be completed for each EPCRA
section 313 chemical. Section 8.10 must be completed only
if a source reduction activity was newly implemented
specifically (in whole or in part) for the reported EPCRA
section 313 chemical during the reporting year. Section 8.11
allows you to indicate if you have attached additional
optional information on source reduction, recycling, or
pollution control activities implemented at any time at your
facility.
Sections 8.1 through 8.7 require reporting of quantities for
the current reporting year, the prior year, and quantities
anticipated in both the first year immediately following the
reporting year and the second year following the reporting
year (future estimates).
Toxics Release Inventory Reporting Forms and Instructions 59
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Instructions for Completing Part II of EPA Form R
Example 17: On-Site Waste Treatment
A process at the facility generates a wastewater stream containing an EPCRA section 313 chemical (chemical A). A second
process generates a wastewater stream containing two EPCRA section 313 chemicals, a metal (chemical B) and a mineral acid
(chemical C). Thresholds for all three chemicals have been exceeded and you are in the process of completing separate Form
Rs for each chemical.
These two wastewater streams are combined and sent to an on-site wastewater treatment system before being discharged to a
POTW. This system consists of an oil/water separator that removes 99% of chemical A; a neutralization tank in which the pH
is adjusted to 7.5, thereby destroying 100% of the mineral acid (chemical C); and a settling tank where 95% of the metal
(chemical B) is removed from the water (and eventually landfilled off-site).
Section 7 A should be completed slightly differently whenyou file the FormR for each of the chemicals. The table accompanying
this example shows how Section 7 A should be completed for each chemical. First, on each Form R you should identify the type
of waste stream in Section 7A. la as wastewater (aqueous waste, code W). Next, on each Form R you should list the code for
each of the treatment steps that is applied to the entire waste stream, regardless of whether the operation affects the chemical
for which you are completing the Form R (for instance, the first four blocks of Section 7 A. Ib of all three Form Rs should show:
P19 (liquid phase separation), Cll (neutralization), Pll (settling/clarification), and N/A (to signify the end of the treatment
system). Note that Section 7A. Ib is not chemical specific. It applies to the entire waste stream being treated. Section 7A. Ic
of each Form R should show the concentration of the specific chemical in the influent to the first step of the process (oil/water
separation). For this example, assume chemicals A, B, and C are all present at concentrations greater than 1%. Therefore, code
" 1" should be entered. Section 7A. Id applies to the efficiency of the entire system in destroying and/or removing the chemical
for which you are preparing the Form R. You should enter 99% when filing for chemical A, 95% for chemical B, and 100%
for chemical C. Finally, you should report whether the influent concentration and efficiency estimates are based on operating
data for each chemical, as appropriate.
Chemical A
7A.la
W
7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
1
7A.ld
99 %
7A.le
Yes No
X
Chemical B
7A.la
W
7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
1
7A.ld
95 %
7A.le
Yes No
X
Chemical C
7A.la
W
7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
1
7A.ld
100 %
7A.le
Yes No
X
Note that the quantity removed and/or destroyed is not reported in Section 7 and that the efficiency reported in Section 7A. Id
refers to the amount of EPCRA section 313 chemical destroyed and/or removed from the applicable waste stream. The amount
actually destroyed should be reported in Section 8.6 (quantity treated on-site). For example, when completing the Form R for
Chemical B you should report "0" pounds in Section 8.6 because the metal has been removed from the wastewater stream, but
not actually destroyed. The quantity of Chemical B that is ultimately landfilled off-site should be reported in Sections 6.2 and
8.1. However, when completing the Form R for Chemical C you should report the entire quantity in Section 8.6 because raising
the pH to 7.5 will completely destroy the mineral acid.
60 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Example 18: Reporting On-Site Energy Recovery
One waste stream generated by your facility contains,
among other chemicals, toluene and Freon 113. Threshold
quantities are exceeded for both of these EPCRA section
313 chemicals, and you would, therefore, submit two
separate Form R reports. This waste stream is sent to an on-
site industrial furnace that uses the heat generated in a
thermal hydrocarbon cracking process at your facility.
Because toluene has a significant heat value (17,440
BTU/pound) and the energy is recovered in an industrial
furnace, the code "U02" would be reported in Section 7B
for the Form R submitted for toluene.
However, as Freon 113 does not contribute any value for
energy recovery purposes, the combustion of Freon 113 in
the industrial furnace is considered waste treatment, not
energy recovery. You would report Freon 113 as entering
a waste treatment step (i.e., incineration), in Section 7A,
column b. In Section 7B the facility should report zero.
Do not enter the values in Section 8 in gallons, tons, liters, or
any measure other than pounds. You must also enter the values
as whole numbers. Numbers following a decimal point are not
acceptable for toxic chemicals other than those designated as
PBT chemicals. For PBT chemicals facilities should report
release and other waste management quantities greater than 0.1
pound (except the dioxin and dioxin-like compounds category)
provided the accuracy and the underlying data on which the
estimate is based supports this level of precision. Forthe dioxin
and dioxin-like compounds category facilities should report at
a level of precision supported by the accuracy of the underlying
data and the estimation techniques on which the estimate is
based. However, the smallest quantity that need be reported on
the Form R for the dioxin and dioxin-like compounds category
is 0.0001 grams (See example 12 on page 41). Notwithstanding
the numeric precision used when determining reporting
eligibility thresholds, facilities should report on Form R to the
level of accuracy that their data supports, up to seven digits to
the right of the decimal. EPA's reporting software and data
management systems support data precision to seven digits to
the right of the decimal.
NA vs. a Numeric Value (e.g., Zero). You should enter a
numeric value in the relevant sections of Section 8 if your
facility has released, treated, combusted for energy recovery or
recycled any quantity of an EPCRA section 313 chemical during
the reporting year. If the aggregate quantity of that toxic
chemical was equal to or less than 0.5 pound for a particular
waste management method, you should enter the value zero
(unless the chemical is a PBT chemical) in the relevant section.
However, if there has been no on-site or off-site treatment,
combustion for energy recovery or recycling on the waste
stream containing the EPCRA section 313 chemical, then you
should enter NA in the relevant section. (Note: for metals and
metal category compounds, enter NA in Sections 8.2, 8.3, 8.6
and 8.7, as treatment and combustion for energy recovery
generally are not applicable waste management methods for
metals and metal compounds). For Section 8.1, NA generally
is not applicable recognizing the potential for spills, leaks, or
fugitive emissions of the EPCRA section 313 chemical. You
should enter NA in section 8.8 if there were no remedial actions,
catastrophic events such as earthquakes, fires, or floods or
one-time events not associated with normal or routine
production processes for that toxic chemical. If there was a
catastrophic event at your facility, but you were able to prevent
any releases from occurring, then enter zero in Section 8.8.
Column A: Prior Year
Quantities for Sections 8.1 through 8.7 must be reported for the
year immediately preceding the reporting year in column A. For
reports due July 1, 2002 (reporting year 2001), the prior year is
2000. Information available at the facility that may be used to
estimate the prioryear's quantities include the prioryear's Form
R submission, supporting documentation, and recycling, energy
recovery, treatment, or disposal operating logs or invoices.
Column B: Current Reporting Year
Quantities for Sections 8.1 through 8.7 must be reported for the
current reporting year in column B.
Columns C and D: Following Year and
Second Following Year
Quantities for Sections 8.1 through 8.7 must be estimated for
2002 and 2003. EPA expects reasonable future quantity
estimates using a logical basis. Information available at the
facility to estimate quantities of the chemical expected during
these years include planned source reduction activities, market
projections, expected contracts, anticipated new product lines,
company growth projections, and production capacity figures.
Respondents should take into account protections available for
trade secrets as provided in EPCRA section 322 (42 USC
11042) for the chemical identity.
Toxics Release Inventory Reporting Forms and Instructions 61
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Instructions for Completing Part II of EPA Form R
Relationship to Other Laws
The reporting categories for quantities recycled, used for energy
recovery, treated, and disposed apply to completing Section 8 of
Form R as well as to the rest of Form R. These categories are to
be used only for TRI reporting. They are not intended for use
in determining, under the Resource Conservation and Recovery
Act (RCRA) Subtitle C regulations, whether a secondary
material is a waste when recycled. These definitions also do not
apply to the information that may be submitted in the Biennial
Report required under RCRA. In addition, these definitions do
not imply any future redefinition of RCRA terms and do not
affect EPAปS RCRA authority or authority under any other
statute administered by EPA.
Differences in terminology and reporting requirements for
EPCRA section 313 chemicals reported on Form R and for
hazardous wastes regulated under RCRA occurbecause EPCRA
and the PPA focus on specific chemicals, while the RCRA
regulations and the Biennial Report focus on waste streams that
may include more than one chemical. For example, a RCRA
hazardous waste containing an EPCRA section 313 chemical is
recycled to recover certain constituents of that waste, but not the
toxic chemical reported under EPCRA section 313. The
EPCRA section 313 chemical simply passes through the
recycling process and remains in the residual from the recycling
process, which is disposed. While the waste may be considered
recycled under RCRA, the EPCRA section 313 chemical
constituent would be considered to be disposed for TRI
purposes.
Quantities Reportable in Sections 8.1-8.7
Section 8 of Form R uses data collected to complete Part II,
Sections 5 through 7. For this reason, Section 8 should be
completed last. Sections 8.1, 8.3, 8.5, 8.7, and 8.8 use data
collected to complete sections 5 and 6 of Form R. The
relationship between sections 5, 6, and 8.8 to sections 8.1, 8.3,
8.5, and 8.7 are provided below in equation form.
Section 8.1. Report releases pursuant to EPCRA section 329(8)
including "any spilling, leaking, pumping, pouring, emitting,
emptying, discharging, injecting, escaping, leaching, dumping,
or disposing [on-site or off-site] into the environment (including
the abandonment of barrels, containers, and other closed
receptacles)." This includes on-site releases in section 5 and
off-site releases in section 6 (releases plus transfers to disposal
and transfers to POTWs of metals and metal compounds), but
excludes quantities reported in sections 5 and 6 due to remedial
actions, catastrophic events, or non-production related events
(see the discussion on section 8.8.)
Example 19: Reporting Future Estimates
A pharmaceutical manufacturing facility uses an EPCRA
section 313 chemical in the manufacture of a prescription
drug. During the reporting year (2001), the company
received approval from the Food and Drug Administration
to begin marketing their product as an over-the-counter drug
beginning in 2002. This approval is publicly known and
does not constitute confidential business information. As a
result of this expanded market, the company estimates that
sales and subsequent production of this drug will increase
their use of the reported EPCRA section 313 chemical by
3 0% per year for the two years following the reporting year.
The facility treats the EPCRA section 313 chemical on-site
and the quantity treated is directly proportional to
production activity. The facility thus estimates the total
quantity of the reported EPCRA section 313 chemical
treated for the following year (2002) by adding 30% to the
amount in column B (the amount for the current reporting
year). The second following year (2003) figure can be
calculated by adding an additional 30% to the amount
reported in column C (the amount for the following year
(2002) projection).
Metals and metal category compounds reported, 1) in section 6.2
as sent off-site for stabilization/solidification (M41metals) or
wastewater treatment (excluding POTWs) (M62metals)
and/or, 2) in section 6.1 discharges to POTWs should be
reported in section 8.1. These quantities should NOT be
reported in section 8.7 because the metals are ultimately
disposed.
ง 8.1 = ง 5 + ง 6.2 (disposal) + ง 6.1 (metals and metal
category compounds only) - ง8.8 (on-site release or off-site
disposal due to catastrophic events)1
Sections 8.2 and 8.3. These relate to an EPCRA section 313
chemical or a mixture containing an EPCRA section 313
chemical that is used for energy recovery on-site or is sent off-
site for energy recovery, unless it is a commercially available
fuel (e.g., fuel oil no. 6). Forthe purposes of reporting onForm
R, reportable on-site and off-site energy recovery is the
combustion of a waste stream containing an EPCRA section 313
chemical when:
(a) The combustion unit is integrated into an energy recovery
system (i.e., industrial furnaces, industrial kilns, and
boilers); and
(b) The EPCRA section 313 chemical is combustible and has
a significant heating value (e.g., 5000 BTU)
62 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Note: Metals and metal category compounds cannot be
combusted for energy recovery. For metals and metal category
compounds, enter NA in Sections 8.2 and 8.3.
ง 8.2 is reported in section 8 only
ง 8.3 = ง 6.2 (energy recovery) - ง8.8 (off-site energy
recovery due to catastrophic events)1
Sections 8.4 and 8.5. These relate to an EPCRA section 313
chemical in a waste that is recycled on-site or is sent off-site for
recycling.
ง 8.4 is reported in section 8 only
ง 8.5 = ง 6.2 (recycling) - ง 8.8 (off-site recycling due to
catastrophic events)1
Section 8.6 and 8.7. These relate to an EPCRA section 313
chemical (except for metals and metal category compounds) or
a waste containing an EPCRA section 313 chemical that is
treated on-site or is sent to a POTW or other off-site location for
waste treatment.
ง 8.6 is reported in section 8 only
ง 8.7 = ง 6.1 (excluding metal/metal category compounds) +
ง 6.2 (treatment) - ง 8.8 (off-site treatment due to
catastrophic events)1
An EPCRA section 313 chemical or an EPCRA section 313
chemical in a mixture that is a waste under RCRA must be
reported in Sections 8.1 through 8.7.
8.8 Quantity Released to the Environment as a Result of
Remedial Actions, Catastrophic Events, or One-Time Events
Not Associated with Production Processes
In Section 8.8, enter the total quantity of the EPCRA section
313 chemical released directly into the environment or sent off-
site for recycling, energy recovery, treatment, or disposal during
the reporting year due to any of the following events:
(1) remedial actions;
(2) catastrophic events suchas earthquakes, fires, orfloods; or
(3) one-time events not associated with normal or routine
production processes.
These quantities should not be included in Sections 8.1 through
8.7
1 ง8.8 includes quantities of toxic chemical released on-site or managed as
waste off-site due to remedial actions, catastrophic events, or one-time
events not associated with the production processes.
The purpose of this section is to separate quantities recycled,
used for energy recovery, treated, or disposed that are associated
with normal or routine production operations from those that are
not. While all quantities released, recycled, combusted for
energy recovery, or treated may ultimately be preventable, this
section separates the quantities that are more likely to be
reduced or eliminated by process-oriented source reduction
activities from those releases that are largely unpredictable and
are less amenable to such source reduction activities. For
example, spills that occur as a routine part of production
operations and could be reduced or eliminated by improved
handling, loading, or unloading procedures are included in the
quantities reported in Sections 8.1 through 8.7 as appropriate.
A total loss of containment resulting from a tank rupture caused
by a tornado would be included in the quantity reported in
Section 8.8.
Similarly, the amount of an EPCRA section 313 chemical
cleaned up from spills resulting from normal operations during
the reporting year would be included in the quantities reported
in Sections 8.1 through 8.7. However, the quantity of the
reported EPCRA section 313 chemical generated from a
remedial action (e.g., RCRA corrective action) to clean up the
environmental contamination resulting from past practices
should be reported in Section 8.8 because they cannot currently
be addressed by source reduction methods. A remedial action
forpurposes of Section 8.8 is a waste cleanup (including RCRA
and CERCLA operations) within the facility boundary. Most
remedial activities involve collecting and treating contaminated
material.
Also, releases caused by catastrophic events are to be
incorporated into the quantity reported in Section 8.8. Such
releases may be caused by natural disasters (e.g., hurricanes and
earthquakes) or by large-scale accidents (e.g., fires and
explosions). In addition, releases due to one-time events not
associated with production (e.g., terrorist bombing) are to be
included in Section 8.8. These amounts are not included in the
quantities reported in Sections 8.1 through 8.7 because such
releases are generally unanticipated and cannot be addressed by
routine process-oriented accident prevention techniques. By
checking your documentation for calculating estimates made for
Part II, Section 5, "Quantity of the Toxic Chemical Entering
Each Environmental Medium On-site," you may be able to
identify release amounts from the above sources. Emergency
notifications under CERCLA and EPCRA as well as accident
histories required under the Clean Air Act may provide useful
information. You should also check facility incident reports and
maintenance records to identify one-time or catastrophic events.
Note: While the information reported in Section 8.8 represents
only remedial, catastrophic, or one-time events not associated
withproductionprocesses, Section 5 of FormR (on-site releases
to the environment) and Section 6 (off-site transfers for further
waste management) must include all on-site releases and
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Instructions for Completing Part II of EPA Form R
transfers as appropriate, regardless of whether they arise from
catastrophic, remedial, or routine process operations.
Avoid Double-Counting in Sections 8.1 Through 8.8
Do not double- or multiple-count quantities in Sections 8.1
through 8.7. The quantities reported in each of those sections
should be mutually exclusive. Do not multiple-count quantities
entering sequential reportable activities.
Do not include in Sections 8.1 through 8.7 any quantities of the
EPCRA section 313 chemical released into the environment due
to remedial actions; catastrophic events such as earthquakes,
fires, or floods; or unanticipated one-time events not associated
with the production process such as a drunk driver crashing
his/her car into a drum storage area. These quantities should be
reported in Section 8.8 only. For example, 10,000 pounds of
diaminoanisole sulfate is released due to a catastrophic event
and is subsequently treated off-site. The 10,000 pounds is
reported in Section 8.8, but the amount subsequently treated off-
site is not reported in Section 8.7.
8.9 Production Ratio or Activity Index
For Section 8.9, you must provide a ratio of reporting year
production to prior year production, or provide an "activity
index" based on a variable other than production that is the
primary influence on the quantity of the reported EPCRA
section 313 chemical recycled, used for energy recovery,
treated, or released. The ratio or index must be reported to the
nearest tenths or hundredths place (i.e., one ortwo digits to the
right of the decimal point). For EPCRA section 313 PBT
chemicals, including the dioxin and dioxin-like compounds
category, you will report the same as for chemicals that are not
listed as PBT (i.e., up to one or two digits to the right of the
decimal point). If the manufacture, processing, or use of the
reported EPCRA section 313 chemical began during the current
reporting year, enter NA as the production ratio or activity
index. Note, this is not to be reported as a percent (i.e., report
1.10 for a 10% increase, not 110%).
It is important to realize that if your facility reports more than
one reported EPCRA section 313 chemical, the production ratio
or activity index may vary for different chemicals. For facilities
that manufacture reported EPCRA section 313 chemicals, the
quantities of the EPCRA section 313 chemical(s) produced in
the current and prior years provide a good basis for the ratio
because that is the primary business activity associated with the
reported EPCRA section 313 chemical(s). In most cases, the
Example 20: Quantity Released to the Environment as a Result of Remedial Actions,
Catastrophic Events, or One-Time Events Not Associated with Production Processes.
A chemical manufacturer produces an EPCRA section 313 chemical in a reactor that operates at low pressure. The reactants and
the EPCRA section 313 chemical product are piped in and out of the reactor at monitored and controlled temperatures. During
normal operations, small amounts of fugitive emissions occur from the valves and flanges in the pipelines.
Due to a malfunction in the control panel (which is state-of-the-art and undergoes routine inspection and maintenance), the
temperature and pressure in the reactor increase, the reactor ruptures, and the EPCRA section 313 chemical is released. Because
the malfunction could not be anticipated and, therefore, could not be reasonably addressed by specific source reduction activities,
the amount released is included in Section 8.8. In this case, much of the EPCRA section 313 chemical is released as a liquid
and pools on the ground. It is estimated that 1,000 pounds of the EPCRA section 313 chemical pooled on the ground and was
subsequently collected and sent off-site for treatment. In addition, it is estimated that another 200 pounds of the EPCRA section
313 chemical vaporized directly to the air from the rupture. The total amount reported in Section 8.8 is the 1,000 pounds that
pooled on the ground (and subsequently sent off-site), plus the 200 pounds that vaporized into the air, a total of 1,200 pounds.
The quantity sent off-site must also be reported in Section 6 (but not in Section 8.7) and the quantity that vaporized must be
reported as a fugitive emission in Section 5 (but not in Section 8.1).
64 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Example 21: Avoiding Double-Counting Quantities in
Sections 8.1 through 8.7
5,000 pounds of an EPCRA section 313 chemical enters a
treatment operation. Three thousand pounds of the EPCRA
section 313 chemical exits the treatment operation and then
enters a recycling operation. Five hundred pounds of the
EPCRA section 313 chemical are in residues from the
recycling operation that is subsequently sent off-site for
disposal. These quantities would be reported as follows in
Sections:
Section 8.1: 500 pounds disposed
Section 8.4: 2,500 pounds recycled
Section 8.6: 2,000 pounds treated (5,000 that initially
entered 3,000 that subsequently entered
recycling)
To report that 5,000pounds were treated, 3,000pounds were
recycled, and that 5 00 pounds were sent off-site for disposal
would result in over-counting the quantities of EPCRA
section 313 chemical recycled, treated, and disposed by
3,500 pounds.
production ratio or activity index must be based on some
variable of production or activity rather than on EPCRA section
313 chemical or material usage. Indices based on EPCRA
section 313 chemical or material usage may reflect the effect of
source reduction activities rather than changes in business
activity. EPCRA section 313 chemical or material usage is
therefore not a basis to be used for the production ratio or
activity index where the EPCRA section 313 chemical is
"otherwise-used" (i.e., non-incorporative activities such as
extraction solvents, metal degreasers, etc.).
While several methods are available to the facility for
determining this data element, the production ratio or activity
index must be based on the variable that most directly affects the
quantities of the EPCRA section 313 chemical recycled, used
for energy recovery, treated, or released. Examples of methods
available include:
(1) Amount of EPCRA section 313 chemical manufactured in
2001 divided by the amount of EPCRA section 313
chemical manufactured in 2000; or
(2) Amount of product produced in 2001 divided by the
amount of product produced in 2000.
8.10 Did Your Facility Engage in Any Source Reduction
Activities for This Chemical During the Reporting Year?
Section 8.10 must be completed only if a source reduction
activity was newly implemented specifically (in whole or in
part) for the reported EPCRA section 313 chemical during the
reporting year. If your facility engaged in any source reduction
activity for the reported EPCRA section 313 chemical during the
reporting year, report the activity that was implemented and the
method used to identify the opportunity for the activity
implemented. If your facility did not engage in any source
reduction activity for the reported EPCRA section 313 chemical,
enter NA in Section 8.10.1 and answer Section 8.11.
Source reduction means any practice that:
n Reduces the amount of any hazardous substance, pollutant,
or contaminant entering any waste stream or otherwise
released into the environment (including fugitive
emissions) prior to recycling, energy recovery, treatment,
or disposal; and
n Reduces the hazards to public health and the environment
associated with the release of such substances, pollutants,
or contaminants.
The term includes equipment or technology modifications,
process or procedure modifications, reformulation or redesign
of products, substitution of raw materials, and improvements in
housekeeping, maintenance, training, or inventory control.
The term source reduction does not include any practice that
alters the physical, chemical, or biological characteristics or the
volume of a hazardous substance, pollutant, or contaminant
through a process or activity that itself is not integral to and
necessary for the production of a product or the providing of a
service.
Source reduction activities do not include recycling, using for
energy recovery, treating, or disposing of an EPCRA section
313 chemical. Report in this section only the source reduction
activities implemented to reduce or eliminate the quantities
reported in Sections 8.1 through 8.7. The focus of the section is
only those activities that are applied to reduce routine or
reasonably anticipated releases and quantities of the reported
EPCRA section 313 chemical recycled, treated, used for energy
recovery, or disposed. Do not report in this section any
activities taken to reduce or eliminate the quantities reported in
Section 8.8. If you have fewer than four source reduction codes
in Section 8.10, an NA should be placed in the first column of
the first unused row to indicate the termination of the sequence.
If all four rows are used, there is no need to terminate the
sequence. If there are more than four source reduction codes,
photocopy page 5 of Form R as many times as necessary and
then number the boxes consecutively for each source reduction
activity. Enter NA when the sequence has terminated, unless
the sequence ends at 4, 8, 12, 16, etc. source reduction codes.
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Instructions for Completing Part II of EPA Form R
Source Reduction Activities includes many, but not all, of the codes provided in the RCRA
biennial report. Remember that source reduction activities
You must enter in the first column of Section 8.10, "Source include only those actions or techniques that reduce or eliminate
Reduction Activities," the appropriate code(s) indicating the the amounts of the EPCRA section 313 chemical reported in
type of actions taken to reduce the amount of the reported Sections 8.1 through 8.7. Actions taken to recycle, combust for
EPCRA section 313 chemical released (as reported in Section energy recovery, treat, or dispose of the EPCRA section 313
8.1), used for energy recovery (as reported in Sections 8.2-8.3), chemical are not considered source reduction activities.
recycled (as reported in Sections 8.4-8.5), ortreated (as reported
in Sections 8.6-8.7). The list of codes below
Example 22: Determining a Production Ratio
Your facility's only use of toluene is as a paint carrier for a painting operation. You painted 12,000 refrigerators in the current
reporting year and 10,000 refrigerators during the preceding year. The production ratio for toluene in this case is 1.2
(12,000/10,000) because the number of refrigerators produced is the primary factor determining the quantity of toluene to be
reported in Sections 8.1 through 8.7.
A facility manufactures inorganic pigments, including titanium dioxide. Hydrochloric acid (acid aerosols) is produced as a waste
byproduct during the production process. An appropriate production ratio for hydrochloric acid (acid aerosols) is the annual
titanium dioxide production, not the amount of byproduct generated. If the facility produced 20,000 pounds of titanium dioxide
during the reporting year and 26,000 pounds in the preceding year, the production ratio would be 0.77 (20,000/26,000).
Example 23: Determining an Activity Index
Your facility manufactures organic dyes in a batch process. Different colors of dyes are manufactured, and between color
changes, all equipment must be thoroughly cleaned with solvent containing glycol ethers to reduce color carryover. During the
preceding year, the facility produced 2,000 pounds of yellow dye in January, 9,000 pounds of green dye for February through
September, 2,000 pounds of red dye in November, and another 2,000 pounds of yellow dye in December. This adds up to a total
of 15,000 pounds and four color changeovers. During the reporting year, the facility produced 10,000 pounds of green dye
during the first half of the year and 10,000 pounds of red dye in the second half. If your facility uses glycol ethers in this cleaning
process only, an activity index of 0.5 (based on two color changeovers for the reporting year divided by four changeovers for
the preceding year) is more appropriate than a production ratio of 1.3 3 (based on 20,000 pounds of dye produced in the current
year divided by 15,000 pounds in the preceding year). In this case, an activity index, rather than a production ratio, better reflects
the factors that influence the amount of solvent recycled, used for energy recovery, treated, or released.
A facility that manufactures thermoplastic composite parts for aircraft uses toluene as a wipe solvent to clean molds. The solvent
is stored in 55-gallon drums and is transferred to 1-gallon dispensers. The molds are cleaned on an as-needed basis that is not
necessarily a function of the parts production rate. Operators cleaned 5,200 molds during the reporting year, but only cleaned
2,000 molds in the previous year. An activity index of 2.6 (5,200/2,000) represents the activities involving toluene usage in the
facility. If the molds were cleaned after 1,000 parts were manufactured, a production ratio would equal the activity index and
either could be used as the basis for the index.
A facility manufactures surgical instruments and cleans the metal parts with 1,1,1 -trichloromethane in a vapor degreaser. The
degreasing unit is operated in a batch mode and the metal parts are cleaned according to an irregular schedule. The activity index
can be based upon the total time the metal parts are in the degreasing operation. If the degreasing unit operated 3,900 hours
during the reporting year and 3,000 hours the prior year, the activity index is 1.3 (3,900/3,000).
66 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Example 24: "NA" is Entered as the Production Ratio or Activity Index
Your facility began production of semiconductor chips during this reporting year. Perchloroethy lene is used as a cleaning solvent
for this operation and this is the only use of the EPCRA section 313 chemical in your facility. You would enter NA in Section
8.9 because you have no basis of comparison in the prior year for the purposes of developing the activity index.
Example 25: Determining the Production Ratio Based on a Weighted Average
At many facilities, a reported EPCRA section 313 chemical is used in more than one production process. In these cases, a
production ratio or activity index can be estimated by weighting the production ratio for each process based on the respective
contribution of each process to the quantity of the reported EPCRA section 313 chemical recycled, used for energy recovery,
treated, or disposed.
Your facility paints bicycles with paint containing toluene. Sixteen thousand bicycles were produced in the reporting year and
14,500 were produced in the prior year. There were no significant design modifications that changed the total surface area to be
painted for each bike. The bicycle production ratio is 1.1 (16,000/14,500). You estimate 12,500 pounds of toluene recycled,
used for energy recovery, treated, or released as a result of bicycle production. Your facility also uses toluene as a solvent in
a glue that is used to make components and add-on equipment for the bicycles. Thirteen thousand components were
manufactured in the reporting year as compared to 15,000 during the prior year. The production ratio for the components using
toluene is 0.87 (13,000/15,000). You estimate 1,000 pounds of toluene treated, recycled, used for energy recovery, or released
as a result of components production. A production ratio can be calculated by weighting each of the production ratios based on
the relative contribution each has to the quantities of toluene treated, recycled, used for energy recovery, or released during the
reporting year (13,500 pounds). The production ratio is calculated as follows:
Production ratio = 1.1 x (12,500/13,500) + 0.87 x (1,000/13,500) = 1.08
Example 26: Source Reduction
A facility assembles and paints furniture. Both the glue
used to assemble the furniture and the paints contain
EPCRA section 313 chemicals. By examining the gluing
process, the facility discovered that a new drum of glue is
opened at the beginning of each shift, whether the old drum
is empty or not. By adding a mechanism that prevents the
drum from being changed before it is empty, the need for
disposal of the glue is eliminated at the source. As a result,
this activity is considered source reduction. The painting
process at this facility generates a solvent waste, that
contains an EPCRA section 313 chemical that is collected
and recovered. The recovered solvent is used to clean the
painting equipment. The recycling activity does not reduce
the amount of EPCRA section 313 chemical recycled, and
therefore is not considered a source reduction activity.
Source Reduction Activity Codes:
Good Operating Practices
W13 Improved maintenance scheduling, record keeping,
or procedures
W14 Changed production schedule to minimize equipment
and feedstock changeovers
W19 Other changes made in operating practices
Inventory Control
W21 Instituted procedures to ensure that materials do not
stay in inventory beyond shelf-life
W22 Began to test outdated material continue to use if
still effective
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labeling procedures
W25 Instituted clearinghouse to exchange materials that
would otherwise be discarded
W29 Other changes made in inventory control
Spill and Leak Prevention
W31 Improved storage or stacking procedures
W32 Improved procedures for loading, unloading, and
transfer operations
W33 Installed overflow alarms or automatic shut-off
valves
W35 Installed vapor recovery systems
W36 Implemented inspection or monitoring program of
potential spill or leak sources
W39 Other changes made in spill and leak prevention
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Instructions for Completing Part II of EPA Form R
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
W49 Other raw material modifications made
Process Modifications
W51 Instituted re-circulation within a process
W52 Modified equipment, layout, or piping
W53 Used a different process catalyst
W54 Instituted better controls on operating bulk
containers to minimize discarding of empty
containers
W55 Changed from small volume containers to bulk
containers to minimize discarding of
empty containers
W58 Other process modifications made
Cleaning and Decreasing
W59 Modified stripping/cleaning equipment
W60 Changed to mechanical stripping/cleaning devices
(from solvents or other materials)
W61 Changed to aqueous cleaners (from solvents or other
materials)
W63 Modified containment procedures for cleaning units
W64 Improved draining procedures
W65 Redesigned parts racks to reduce drag out
W66 Modified or installed rinse systems
W67 Improved rinse equipment design
W68 Improved rinse equipment operation
W71 Other cleaning and decreasing modifications made
Surface Preparation and Finishing
W72 Modified spray systems or equipment
W73 Substituted coating materials used
W74 Improved application techniques
W75 Changed from spray to other system
W78 Other surface preparation and finishing
modifications made
source reduction activity implementation at your facility. If
more than three methods were used to identify the source
reduction activity, enter only the three codes that contributed
most to the decision to implement the activity.
TO 1 Internal pollution prevention opportunity audit(s)
T02 External pollution prevention opportunity audit(s)
T03 Materials balance audits
T04 Participative team management
T05 Employee recommendation (independent of a formal
company program)
T06 Employee recommendation (under a formal company
program)
T07 State government technical assistance program
T08 Federal government technical assistance program
T09 Trade association/industry technical assistance
program
T10 Vendor assistance
Til Other
8.11 Is Additional Optional Information on Source
Reduction, Recycling, or Pollution Control Activities
Included with this Report?
Check "Yes" for this data element if you have attached to this
report any additional optional information on source reduction,
recycling, or pollution control activities you have implemented
in the reporting year or in prior years for the reported EPCRA
section 313 chemical. If you are not including additional
information, check "No." If you submit additional optional
information, try to limit this information to one page that
summarizes the source reduction, recycling, or pollution control
activities. If there is a contact person at the facility, other than
the technical or public contact provided in Part I, Section 4, the
summary page should include that person's name and telephone
number for individuals who wish to obtain further information
about those activities. Also submit a copy of this additional
information to the appropriate state agency as part of the Form
R submittal to that agency.
Product Modifications
W81 Changed product specifications
W82 Modified design or composition of product
W83 Modified packaging
W89 Other product modifications made
Methods to Identify Activity
In columns a through c of Section 8.10, the "Methods to Identify
Activity," you must enter one or more of the following code(s)
that correspond to those internal and external method(s) or
information sources you used to identify the possibility for a
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D. Facility Eligibility Determination for Alternate Threshold and for
Reporting on EPA Form A Certification Statement
This section will help to determine whether you can submit the
simplified Form A Certification Statement (hereafter referred to
as Form A). The criteria are based on the total annual reportable
amount of the listed chemical or chemical category and the
amount manufactured, processed, or otherwise used.
D.I Alternate Threshold
On November 30, 1994, EPA published a final rule (59 FR
61488) that provides qualifying facilities an alternate threshold
of 1 million pounds. Eligible facilities wishing to take
advantage of this option may certify on a simplified two-page
form referred to as Form A Certification Statement and do not
have to use Form R. The "TRI Alternate Threshold for
Facilities with Low Annual Reportable Amounts," provides
facilities otherwise meeting EPCRA section 313 reporting
thresholds the option of certifying on Form A provided that they
do not exceed 500 pounds for the total annual reportable amount
(defined below) for that chemical, and that their amounts
manufactured or processed or otherwise used do not exceed
one-million pounds. As with determining section 313 reporting
thresholds, amounts manufactured, processed, or otherwise used
are to be considered independently. This modification does not
apply to forms being submitted on or before July 1, 1995
(covering the 1994 reporting year). If you fill out a Form A for
an EPCRA section 313 chemical, do not fill out a Form R for
that same chemical.
However, there is an exception to the alternate threshold rule
described in the preceding paragraph. All PBT chemicals
(except certain instances of reporting lead in stainless steel,
brass or bronze alloys) are excluded from eligibility for the
alternate threshold.
D.2 What is the Form A
Certification Statement?
The Form A, which is described as the "certification statement"
in 59 FR 61488, is intended as a means to reduce the compliance
burden associated with EPCRA section 313. The Form A must
be submitted on an annual basis for each eligible chemical.
Facilities wishing to take advantage of this burden reducing
option should submit a Form A for such chemicals meeting the
conditions described below, and should not submit a Form R to
the EPCRA Reporting Center for that chemical. The
information submitted on the Form A includes facility
identification information and the chemical or chemical category
identity. The information submitted on the Form A will appear
in the TRI data base in the same manner that information
submitted on Form R appears. An approved Form A and a
magnetic version of reporting have been included in this
Reporting Forms and Instructions package.
D.3 What is the Total Annual
Reportable Amount?
For the purpose of this optional reporting modification, the
annual reportable amount is equal to the combined total
quantities released at the facility (including disposed within the
facility), treated at the facility (as represented by amounts
destroyed or converted by treatment processes), recovered at the
facility as a result of recycle operations, combusted for the
purpose of energy recovery at the facility, and amounts
transferred from the facility to off-site locations for the purpose
of recycle, energy recovery, treatment, and/or disposal. These
volumes correspond to the sum of amounts reportable for data
elements on EPA Form R (EPA Form 9350-1; Rev. 04/97) as
Part II column B of section 8, data elements 8.1 (quantity
released), 8.2 (quantity used for energy recovery on-site), 8.3
(quantity used for energy recovery off-site), 8.4 (quantity
recycled on-site), 8.5 (quantity recycled off-site), 8.6 (quantity
treated on-site), and 8.7 (quantity treated off-site).
D.4 Recordkeeping
Each owner or operator who determines that they are eligible,
and wishes to apply the alternate threshold to a particular
chemical, must retain records substantiating this determination
for a period of three years from the date of the submission of
the Form A. These records must include sufficient
documentation to support calculations as well as the calculations
made by the facility that confirm their eligibility for each
chemical for which the alternate threshold was applied.
A facility that fits within the category description, and
manufactures, processes or otherwise uses no more than
one-million pounds of an EPCRA section 313 chemical
annually, and whose owner/operator elects to take advantage of
the alternate threshold, is not considered an EPCRA section 313
covered facility for that chemical for the purpose of submitting
a Form R. This determination may provide further regulatory
relief from other federal or state regulations that apply to
facilities on the basis of their EPCRA section 313 reporting
status. A facility will need to reference other applicable
regulations to determine if their actual requirements may be
affected by this reporting modification.
D.5 Multi-establishment Facilities
For the purposes of using Form A, the facility must also make
its determination based upon the entire facility's operations
including all of its establishments (see 59 FR 61488 for greater
detail). If the facility as a whole is able to take advantage of the
alternate threshold, a single Form A is required. The eligibility
to submit a Form A must be made on a whole facility
determination. Thus, all of the information necessary to make
the determination must be assembled to the facility level.
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Facility Eligibility Determination for Alternate Threshold and for Reporting on EPA Form A
D.6 Trade Secrets
EPA is requiring that a facility submit a unique Form A for each
EPCRA section 313 chemical meeting the conditions of the
alternate threshold. Facilities may assert a trade secrecy claim
for a chemical identity on the Form A as on the Form R.
Reports submitted on a per chemical basis protect against the
disclosure of trade secrets. Form As with trade secrecy claims,
like Form Rs with similar claims, will be separately handled
upon receipt to protect against disclosure. Commingling trade
secret chemical identities with non-trade secret chemical
identities on the same submission increases the risk of
disclosure.
Do not submit trade secret reports electronically or
on diskette.
D.7 Metals and Metal
Category Compounds
For metal category compounds, the category level of 500
pounds applies to the amount of parent metal waste that is
reported on Form R, but the thresholds apply to the amount of
metal category compounds manufactured, processed, or
otherwise used. For Form A certification involving both listed
parent metals and associated metal compounds, the one million
pound alternate threshold mustbe applied separately to the listed
parent metal and the associated metal compound(s). Threshold
determinations must be made independently for each because
they are separately listed EPCRA section 313 chemicals.
n If the threshold is exceeded for the listed parent metal
but not the associated metal category compounds, then
the releases of metal reported on Form R for the parent
metal need not include the releases from the metal
category compounds.
n If both the parent metal and the associated metal
compounds exceed the alternate threshold, then the
facility has the option of filing one Form R for both,
using the metal category compound name and
reporting total releases based on parent metal content.
n If neither the parent metal nor the associated metal
compounds exceed the alternate threshold, then the
facility should file a Form A for each, since the
reporting thresholds must be applied to each listed
parent metal and all compounds in the associated
compound category. EPA believes it is appropriate to
make this distinction between filing the Form R and
Form A because the Form R accounts for amounts of
metal released or otherwise managed and Form A
verifies that the alternate threshold for each listed
chemical or chemical category has not been exceeded.
Similarly, separate listings on Form A should be submitted for
all other listed chemicals even if EPA allows one listing on
Form R to be filed for two or more listed chemicals, (e.g.,
o-xylene, p-xylene and xylene (mixed isomers)). For example,
if a facility processes in three separate process streams, xylene
(mixed isomers), o-xylene, and p-xylene, and exceeds the
conditions of the alternate threshold for each of these listed
substances, the facility may combine the appropriate information
on the o-xylene, p-xylene, and xylene (mixed isomers) into one
FormR, but cannot combine the reports into one listing on Form
A.
Facilities that process o-xylene, p-xylene, and xylene (mixed
isomers) in separate process streams and do not exceed the
conditions of the alternate threshold for one or more of the
compounds may submit a separate Form A for each of the forms
of xylene meeting the alternate threshold and report on Form R
for those forms that do not. Similar to reporting on the parent
metals and their associated category compounds described
above, facilities that separately process all types (i.e., isomers)
of xylene with individual activity levels within the conditions of
the alternate threshold should file a separate Form A for each
type of xylene.
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E. Instructions for Completing EPA Form A Certification Statement
Beginning with the 1998 reporting year, facilities may enter as
many chemicals as are eligible on a single Form A.
For all parts of Form A:
n Type or print information on the form in the format
requested. Use black ink. (Using blue ink for the
certification signature is suggested as a means of
indicating its originality.)
n All information on the Form A is required.
n Do not leave items in Parts I and II on the Form A
blank unless specifically directed to do so; if an item
does not apply to you, enter NA in the space provided.
If your information does not fill all the spaces provided
for a type of information, enter NA, in the next blank
space in the sequence.
n Do not submit an incomplete form. The certification
statement (Part I, Section 3) specifies that the report is
complete as submitted. See page 1 of these
instructions for the definition of a complete
submission.
Part I. Facility Identification
Information
Section 1. Reporting Year
This is the calendar year to which the reported information
applies, not the year in which you are submitting the report.
Information for the reporting year 2001 must be submitted on or
before July 1, 2002.
Section 2. Trade Secret Information
2.1 Are you claiming the EPCRA Section 313 chemical
identified on page 2 a trade secret?
If facilities wish to report more than one eligible chemical on the
same Form A, then they are not able to make trade secrecy
claims. Any trade secrecy claims must be made on a separate
form, and then the process is the same as using the Form R and
as described in the following instructions.
The specific identity of the EPCRA section 313 chemical being
reported in Part II, Section 1, may be designated as a trade
secret. If you are making a trade secret claim, mark "yes" and
proceed to Section 2.2. Only check "yes" if you manufacture,
process, or otherwise use the EPCRA section 313 chemical
whose identity is a trade secret. (See page 2 of these
instructions for specific information on trade secrecy claims.)
If you checked "no," proceed to Section 3; do not answer
Section 2.2.
Do not submit trade secret reports electronically or on
diskette.
2.2 If "yes" in 2.1, is this copy sanitized or unsanitized?
Check "sanitized" if this copy of the report is the public version
that does not contain the EPCRA section 313 chemical identity
but does contain a generic name in its place, and you have
claimed the EPCRA section 313 chemical identity trade secret
in Part I, Section 2.1. Otherwise, check "unsanitized."
Section 3. Certification
The Form A must be signed by the owner or operator or a senior
official with management responsibility for the person (or
persons) completing the form. The owner, operator, or official
must certify the accuracy and completeness of the information
reported on the form by signing and dating the Form A. Each
report must contain an original signature. Unlike the
certification statement contained on Form R, the certification
statement provided on the Alternate Threshold Form A pertains
to the facility's eligibility of having met the conditions as
described in Section D or in the Federal Register 59 FR 61488
(November 30, 1994). Print or type in the space provided the
name and title of the person who signs the statement. This
certification statement applies to all the information supplied on
the form and should be signed only after the form has been
completed.
Section 4. Facility Identification
4.1 Facility Name, Location, and TRI Facility
Identification Number
Enter the full name that the facility presents to the public and its
customers in doing business (e.g., the name that appears on
invoices, signs, and other official business documents). Do not
use a nickname for the facility (e.g., Main Street Plant) unless
that is the legal name of the facility under which it does
business. Also enter the street address, mailing address, city,
county, state, and zip code in the space provided. Do not use a
post office box number as the street address. The street address
provided should be the location where the EPCRA section 313
chemicals are manufactured, processed, or otherwise used. If
your mailing address and street address are the same, enter NA
in the space for the mailing address.
If your facility is not in a county, put the name of your city,
district (for example District of Columbia), or parish (if you are
in Louisiana) in the county block of the Form R and Form A as
well as in the County field of ATRS or TRI-ME. "NA" or
"None" are not acceptable entries.
For Section 4.1 in both ATRS and TRI-ME: If your
mailing address is outside the U.S., click the "Non-U.S."
box. You will still provide the mailing facility name,
address, and city. There is nothing to enter in the State
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Instructions for Completing Part I of EPA Form A
field. You then enter the postal code, county or province,
and country in the respective fields.
Remember, both ATRS and TRI-ME can accept
international postal codes and nine-digit zip codes for U. S.
addresses.
If you have submitted a Form A or Form R for previous
reporting years, a TRI Facility Identification Number has been
assigned to your facility. If you know your TRI Facility
Identification Number, complete Section 4. If you do not know
your TRI Facility Identification Number, contact the EPCRA
Call Center (see page 7). If your facility has moved, do not
enter your TRI facility identification number, enter "New
Facility."
Enter "New Facility" in the space for the TRI Facility
Identification number if this is your first submission.
For ATRS, when entering a TRI Facility Identification
Number, enter all 15 characters. If you have a TRI
Facility Identification Number which is less than 15
characters (either alpha or numeric), use the space bar
on your computer keyboard (example: 12345-JV -
RT1 ). If you have reported for prior years, then your
facility information can be found by searching a list of
facilities. Simply click on the icon to the right of the
TRI Facility ID field in ATRS to view the list of the
TRI Facilities (NOTE: This feature is only available
with the CD-ROM version due to space limitations on
diskette). If you are a new facility, simply type "New
Facility."
For TRI-ME, simply enter your TRI Facility
Identification Number without hyphens. If you have a
TRI Facility Identification Number which is less than
15 characters (either alpha or numeric), use the space
bar on your computer keyboard (example: 12345JV
RT1 ). If you are a new facility, click the "New
Facility" box.
4.2 Federal Facility Designation
Executive Order 13148 directs federal facilities to comply with
Right-To-Know Laws and Pollution Prevention Requirements.
Please indicate in 4.2.C. if the reporting facility is a federal
facility or in 4.2.D if the submitter is a contractor at a federal
facility (GOCO). If the reporting facility is not a federal facility,
leave this space blank. Form R allows a facility to report
multiple submissions for the same chemical if the facility is
composed of several distinct establishments. This data element
provides the option of reporting full or partial facility
information on Form R, however, this is not applicable for those
facilities taking advantage of the Alternate Threshold and Form
A. An explanation of this is provided in Section D.
4.3 Technical Contact
Enter the name and telephone number (including area code) of
a technical representative whom EPA or State officials may
contact for clarification of the information reported on Form A.
This contact person does not have to be the same person who
prepares the report or signs the Form A and does not necessarily
need to be someone at the location of the reporting facility.
However, this person must be familiar with the details of the
report so that he or she can answer questions about the
information provided.
Remember, both ATRS and TRI-ME can accept
international telephone numbers (be sure to include Oil
as the prefix to your international telephone number).
4.4 Intentionally Left Blank
4.5 Standard Industrial Classification (SIC) Code
Enter the appropriate four-digit Standard Industrial
Classification (SIC) Code that is the primary SIC Code for your
facility in Section 4.5(a). Enter any other applicable SIC Codes
for your facility in 4.5 (b)-(f). Table I lists the SIC codes within
10 (except 1011, 1081, and 1094), 12 (except 1241), 20-39,
4911 (limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in commerce),
4931 (limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in commerce),
4939 (limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in commerce),
4953 (limited to facilities regulated under the RCRA Subtitle C,
42U.S.C. section 6921 et seq.), 5169, 5171, and 7389 (limited
to facilities primarily engaged in solvents recovery services on
a contract or fee basis). If the report covers more than one
establishment, enter the primary four-digit SIC code for each
establishment starting with the primary SIC code for the entire
facility. You are required to enter SIC codes only for those
establishments within the facilities that fall within SIC codes 10
(except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4939
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4953
(limited to facilities regulated under the RCRA Subtitle C, 42
U.S.C. section 6921 et seq.), 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvents recovery services on a
contract or fee basis). If you do not know your SIC code, consult
the 1987 SIC Manual (see section B.2 of these instruction for
ordering information).
The North American Industry Classification System (NAICS),
is a new economic classification system that will replace the
1987 SIC code system. EPA will address the SIC code change,
as it relates to EPCRA, in an upcoming Federal Register notice.
72 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part I of EPA Form A
This upcoming change does NOT affect the 2001 EPCRA
section 313 reporting.
4.6 Latitude and Longitude
Enter the latitude and longitude coordinates of your facility.
Sources of these data include EPA permits (e.g., NPDES
permits), county property records, facility blueprints, and site
plans. Instructions on how to determine these coordinates can
be found in Appendix E. Enter only numerical data. Do not
preface numbers with letters such as N or W to denote the
hemisphere.
Latitude and longitude coordinates of your facility are very
important for pinpointing the location of reporting facilities and
are required elements on the Form A. EPA encourages facilities
to make the best possible measurements when determining
latitude and longitude. As with any other data field, missing,
suspect, or incorrect data may generate an error notice in the
Facility Data Profile to be issued to the facility. (See Appendix
C: Common Errors in Completing Form R Reports and Making
Data Available.)
4.7 Dun & Bradstreet Number(s)
Enter the nine-digit number assigned by Dun & Bradstreet
(D & B) for your facility or each establishment within your
facility. These numbers code the facility for financial purposes.
This number may be available from your facility's treasurer or
financial officer. You can also obtain the numbers from your
local D & B office (check the telephone book White Pages). If
a facility does not subscribe to the D & B service, a "support
number" can be obtained from the center located in Allentown,
Pennsylvania, at (610) 882-7748 (8:30 am to 8:00 pm, Eastern
Time), toll free at 800 333 0505 or on the web atwww.dnb.com.
If none of your establishments has been assigned a D & B
number, enter NA in box (a). If only some of your
establishments have been assigned Dun & Bradstreet numbers,
enter those numbers in Part I, section 4.7.
4.8 EPA Identification Number(s)
The EPA Identification Number is a 12-character number
assigned to facilities covered by hazardous waste regulations
under Resource and Conservation and Recovery Act. Facilities
not covered by RCRA are not likely to have an assigned
Identification Number. If your facility is not required to have an
Identification Number, enter NA in box (a). If your facility has
been assigned multiple EPA Identification Numbers, you must
enter those numbers in the spaces provided in Section 4.8.
4.9 Facility NPDES Permit Number(s)
Enter the numbers of any permits your facility holds under the
National Pollutant Discharge Elimination System (NPDES) even
if the permit(s) do not pertain to the EPCRA section 313
chemical being reported. This nine-character permit number is
assigned to your facility by EPA or the State under the authority
of the Clean Water Act. If your facility does not have a permit,
enter NA in Section 4.9a.
4.10 Underground Injection Well Code (UIC)
Identification Number(s)
If your facility has a permit to inject a waste containing the
EPCRA section 313 chemical into Class 1 deep wells, enter the
12-digit Underground Injection Well Code (UIC) identification
number assigned by EPA or by the State under the authority of
the Safe Drinking Water Act. If your facility does not hold such
a permit(s), enter NA in Section 4.10a. You are required to
provide the UIC number for wells that receive the EPCRA
section 313 chemical being reported in the current reporting
year.
Section 5. Parent Company Information
You must provide information on your parent company. For
purposes of the Form A, a parent company is defined as the
highest level company, located in the United States, that directly
owns at least 50% of the voting stock of your company. If your
facility is owned by a foreign entity, enter NA in this space.
Corporate names shouldbe treated as parent company names for
companies with multiple facility sites. For example, the
Bestchem Corporation is not owned or controlled by any other
corporation but has sites throughout the country whose names
begin withBestchem. In this case, Bestchem Corporation would
be listed as the parent company. Note that a facility that is a
50:50 joint venture is its own parent company.
5.1 Name of Parent Company
Enter the name of the corporation or other business entity that
is your ultimate US parent company. If your facility has no
parent company, check the NA box.
5.2 Parent Company's Dun & Bradstreet Number
Enter the Dun & Bradstreet (D & B) Number for your ultimate
US parent company, if applicable. The number may be obtained
from the treasurer or financial officer of the company. If your
parent company does not have a D & B number, check the NA
box.
Toxics Release Inventory Reporting Forms and Instructions 73
-------
Instructions for Completing Part II of EPA Form A
Part II. Chemical Identification
Reporting on the Alternate Threshold Form A Certification
Statement for metals, metal category compounds, and mixed
isomers differs somewhat from Form R reporting. Please refer
to Section D for these guidelines.
Section 1. Toxic Chemical Identity
(Important: DO NOT complete this section if you completed
Section 2 of Part II below.)
1.1 CAS Number
Enter the Chemical Abstracts Service (CAS) registry number in
Section 1.1 exactly as it appears in Table II of these instructions
for the chemical being reported. CAS numbers are
cross-referenced with an alphabetical list of chemical names in
Table II. If you are reporting one of the EPCRA section 313
chemical categories (e.g., chromium compounds), enter the
applicable category code in the CAS number space. EPCRA
section 313 chemical category codes are listed below and can
also be found in Table He and Appendix B-l.
EPCRA section 313 Chemical Category Codes
NO 10 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N150 Dioxin and dioxin-like compounds*
N171 Ethylenebisdithiocarbamic acid, salts and esters
(EBDCs)
N230 Certain glycol ethers
N420 Lead compounds*
N450 Manganese compounds
N458 Mercury compounds*
N495 Nickel compounds
N503 Nicotine and salts
N511 Nitrate compounds (water dissociable; reportable
only when in aqueous solution)
N575 Polybrominated biphenyls (PBBs)
N583 Polychlorinated alkanes (CIO to C13)
N590 Poly cyclic aromatic compounds (PACs)*
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N770 Vanadium compounds
N874 Warfarin and salts
N982 Zinc compounds
*Facilities cannot take the alternate threshold for chemicals
and chemical categories listed as PBT chemicals.
If you are making a trade secret claim, you must report the CAS
number or category code on your unsanitized Form A and
unsanitized substantiation form. Do not include the CAS
number or category code on your sanitized Form A or sanitized
substantiation form.
1.2 EPCRA Section 313 Chemical or
Chemical Category Name
Enter the name of the EPCRA section 313 chemical or chemical
category exactly as it appears in Table II. If the EPCRA section
313 chemical name is followed by a synonym in (parentheses),
report the chemical by the name that directly follows the CAS
number (i.e., not the synonym). If the EPCRA section 313
chemical identity is actually a product trade name (e.g., dicofol),
the 9th Collective Index name is listed below it in brackets.
You may report either name in this case.
Do not list the name of a chemical that does not appear in Table
II, such as individual members of a reportable EPCRA section
313 chemical category. For example, if you use silver chloride,
do not report silver chloride with its CAS number. Report this
chemical as "silver compounds" with its category code N740.
If you are making a trade secret claim, you must report the
specific EPCRA section 313 chemical identity on your
unsanitized Form A and unsanitized substantiation form. Do not
report the name of the EPCRA section 313 chemical on your
sanitized Form A or sanitized substantiation form. Include a
generic name in Part II, Section 1.3 of your sanitized Form A.
1.3 Generic Chemical Name
Complete Section 1.3 only if you are claiming the specific
EPCRA section 313 chemical identity of the EPCRA section
313 chemical as a trade secret and have marked the trade secret
block in Part I, Section 2.1 on page 1 of Form A. Enter a
generic chemical name that is descriptive of the chemical
structure. You must limit the generic name to seventy
characters (e.g., numbers, letters, spaces, punctuation) or less.
Do not enter mixture names in Section 1.3; see Section 2 below.
In-house plant codes and other substitute names that are not
structurally descriptive of the EPCRA section 313 chemical
identity being withheld as a trade secret are not acceptable as a
generic name. The generic name must appear on both sanitized
74 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form A
and unsanitized Form A, and the name must be the same as that
used on your substantiation forms.
Section 2. Mixture Component Identity
Report the generic name provided to you by your supplier in this
section if your supplier is claiming the chemical identity
proprietary or trade secret. Do not answer "yes" in Part I,
Section 2.1 on page 1 of the form if you complete this sec+tion.
You do not need to supply trade secret substantiation forms for
this EPCRA section 313 chemical because it is your supplier
who is claiming the chemical identity a trade secret.
2.1 Generic Chemical Name Provided by Supplier
Enter the generic chemical name in this section only if the
following three conditions apply:
1. You determine that the mixture contains an EPCRA
section 313 chemical but the only identity you have for
that chemical is a generic name;
2. You know either the specific concentration of that EPCRA
section 313 chemical component or a maximum or average
concentration level; and
3. You multiply the concentration level by the total annual
amount of the whole mixture processed or otherwise used
and determine that you meet the process or otherwise use
threshold for that single, genetically identified mixture
component.
Toxics Release Inventory Reporting Forms and Instructions 75
-------
This Page Intentionally Left Blank
-------
Table I. SIC codes
10 Metal Mining (except 1011,1081
and 1094)
1021 Copper Ores
1031 Lead and Zinc Ores
1041 Gold Ores
1044 Silver Ores
1061 Ferroalloy Ores, Except Vanadium
1099 Miscellaneous Metal Ores, Not Elsewhere
Classified
12 Coal Mining (except 1241)
1221 Bituminous Coal and Lignite Surface Mining
1222 Bituminous Coal Underground Mining
1231 Anthracite Mining
20 Food and Kindred Products
2011 Meat packing plants
2013 Sausages and other prepared meat products
2015 Poultry slaughtering and processing
2021 Creamery butter
2022 Natural, processed, and imitation cheese
2023 Dry, condensed, and evaporated dairy
products
2024 Ice cream and frozen desserts
2026 Fluid milk
2032 Canned specialties
2033 Canned fruits, vegetables, preserves, jams, and
jellies
2034 Dried and dehydrated fruits, vegetables, and soup
mixes
2035 Pickled fruits and vegetables, vegetable sauces
and seasonings, and salad dressings
2037 Frozen fruits, fruit juices, and vegetables
2038 Frozen specialties, n.e.c.*
2041 Flour and other grain mill products
2043 Cereal breakfast foods
2044 Rice milling
2045 Prepared flour mixes and doughs
2046 Wet corn milling
2047 Dog and cat food
2048 Prepared feeds and feed ingredients for animals
and fowls, except dogs and cats
2051 Bread and other bakery products, except cookies and
crackers
2052 Cookies and crackers
2053 Frozen bakery products, except bread
2061 Cane sugar, except refining
2062 Cane sugar refining
2063 Beet sugar
2064 Candy and other confectionery products
2066 Chocolate and cocoa products
2067 Chewing gum
2068 Salted and roasted nuts and seeds
2074 Cottonseed oil mills
2075 Soybean oil mills
2076 Vegetable oil mills, n.e.c.*
2077 Animal and marine fats and oils
2079 Shortening, table oils, margarine, and other edible fats
and oils, n.e.c.*
2082 Malt beverages
2083 Malt
2084 Wines, brandy, and brandy spirits
2085 Distilled and blended liquors
2086 Bottled and canned soft drinks and carbonated waters
2087 Flavoring extracts and flavoring syrups, n.e.c.*
2091 Canned and cured fish and seafoods
2092 Prepared fresh or frozen fish and seafoods
2095 Roasted coffee
2096 Potato chips, corn chips, and similar snacks
2097 Manufactured ice
2098 Macaroni, spaghetti, vermicelli, and noodles
2099 Food preparations, n.e.c.*
21 Tobacco Products
2111 Cigarettes
2121 Cigars
2131 Chewing and smoking tobacco and snuff
2141 Tobacco stemming and redrying
22 Textile Mill Products
2211 Broadwoven fabric mills, cotton
2221 Broadwoven fabric mills, manmade fiber, and silk
2231 Broadwoven fabric mills, wool (including dyeing and
finishing)
2241 Narrow fabric and other small wares mills: cotton,
wool, silk, and manmade fiber
*"Not elsewhere classified" indicated by "n.e.c."
Toxics Release Inventory Reporting Forms and Instructions 1-1
-------
Table I
2251 Women's full length and knee length hosiery,
except socks
2252 Hosiery, n.e.c.*
2253 Knit outerwear mills
2254 Knit underwear and nightwear mills
2257 Weft knit fabric mills
2258 Lace and warp knit fabric mills
2259 Knitting mills, n.e.c.*
2261 Finishers of Broadwoven fabrics of cotton
2262 Finishers of Broadwoven fabrics of manmade
fiber and silk
2269 Finishers of textiles, n.e.c.*
2273 Carpets and rugs
2281 Yarn spinning mills
2282 Yarn texturizing, throwing, twisting, and winding
mills
2284 Thread mills
2295 Coated fabrics, not rubberized
2296 Tire cord and fabrics
2297 Nonwoven fabrics
2298 Cordage and twine
2299 Textile goods, n.e.c.*
23 Apparel and Other Finished
Products made from Fabrics and
Other Similar Materials
2311 Men's and boys' suits, coats, and overcoats
2321 Men's and boys' shirts, except work shirts
2322 Men's and boys' underwear and nightwear
2323 Men's and boys' neckwear
2325 Men's and boys' separate trousers and slacks
2326 Men's and boys' work clothing
2329 Men's and boys' clothing, n.e.c.*
2331 Women's, misses', and juniors' blouses and shirts
2335 Women's, misses', and juniors' dresses
2337 Women's, misses', and juniors' suits, skirts, and
coats
2339 Women's, misses', and juniors', outerwear, n.e.c.*
2341 Women's, misses', children's, and infants'
underwear and nightwear
2342 Brassieres, girdles, and allied garments
2353 Hats, caps, and millinery
2361 Girls', children's and infants' dresses, blouses,
and shirts
2369 Girls', children's and infants' outerwear, n.e.c.*
2371 Fur goods
2381 Dress and work gloves, except knit and all leather
2384 Robes and dressing gowns
2385 Waterproof outerwear
2386 Leather and sheep lined clothing
2387 Apparel belts
2389 Apparel and accessories, n.e.c.*
2391 Curtains and draperies
2392 House furnishings, except curtains and draperies
2393 Textile bags
2394 Canvas and related products
2395 Pleating, decorative and novelty stitching, and tucking
for the trade
2396 Automotive trimmings, apparel findings, and related
products
2397 Schiffli machine embroideries
2399 Fabricated textile products, n.e.c.*
24 Lumber and Wood Products, Except
Furniture
2411 Logging
2421 Sawmills and planing mills, general
2426 Hardwood dimension and flooring mills
2429 Special product sawmills, n.e.c.*
2431 Millwork
2434 Wood kitchen cabinets
2435 Hardwood veneer and plywood
2436 Softwood veneer and plywood
2439 Structural wood members, n.e.c.*
2441 Nailed and lock corner wood boxes and shook
2448 Wood pallets and skids
2449 Wood containers, n.e.c.*
2451 Mobile homes
2452 Prefabricated wood buildings and components
2491 Wood preserving
2493 Reconstituted wood products
2499 Wood products, n.e.c.*
25 Furniture and Fixtures
2511 Wood household furniture, except upholstered
2512 Wood household furniture, upholstered
2514 Metal household furniture
2515 Mattresses, foundations, and convertible beds
2517 Wood television, radio, phonograph, and sewing
machine cabinets
2519 Household furniture, n.e.c.*
2521 Wood office furniture
2522 Office furniture, except wood
2531 Public building and related furniture
2541 Wood office and store fixtures, partitions, shelving,
and lockers
2542 Office and store fixtures, partitions, shelving, and
lockers, except wood
2591 Drapery hardware and window blinds and shades
1-2 Toxics Release Inventory Reporting Forms and Instructions
*"Not elsewhere classified" indicated by "n.e.c."
-------
Table I
2599 Furniture and fixtures, n.e.c.*
26 Paper and Allied Products
2611 Pulp mills
2621 Paper mills
2631 Paperboard mills
2652 Setup paperboard boxes
2653 Corrugated and solid fiber boxes
2655 Fiber cans, tubes, drums, and similar products
2656 Sanitary food containers, except folding
2657 Folding paperboard boxes, including sanitary
2671 Packaging paper and plastics film, coated and
laminated
2672 Coated and laminated paper, n.e.c.*
2673 Plastics, foil, and coated paper bags
2674 Uncoated paper and multiwall bags
2675 Die-cut paper and paperboard and cardboard
2676 Sanitary paper products
2677 Envelopes
2678 Stationery tablets, and related products
2679 Converted paper and paperboard products, n.e.c.
27 Printing, Publishing, and Allied
Industries
2711 Newspapers: publishing, or publishing and
printing
2721 Periodicals: publishing, or publishing and
printing
2731 Books: publishing, or publishing and printing
2732 Book printing
2741 Miscellaneous publishing
2752 Commercial printing, lithographic
2754 Commercial printing, gravure
2759 Commercial printing, n.e.c.*
2761 Manifold business forms
2771 Greeting cards
2782 Blank books, looseleaf binders and devices
2789 Bookbinding and related work
2791 Typesetting
2796 Plate making and related services
28 Chemicals and Allied Products
2812 Alkalie s and chlorine
2813 Industrial gases
2816 Inorganic pigments
2819 Industrial inorganic chemicals, n.e.c.*
2821 Plastics materials, synthetic resins, and
non-vulcanizable elastomers
2822 Synthetic rubber (vulcanizable elastomers)
2823 Cellulosic manmade fibers
2824 Manmade organic fibers, except cellulosic
2833 Medicinal chemicals and botanical products
2834 Pharmaceutical preparations
2835 In vitro and in vivo diagnostic substances
2836 Biological products, except diagnostic substances
2841 Soap and other detergents, except specialty cleaners
2842 Specialty cleaning, polishing, and sanitation
preparations
2843 Surface active agents, finishing agents, sulfonated oils,
and assistants
2844 Perfumes, cosmetics, and other toilet preparations
2851 Paints, varnishes, lacquers, enamels, and allied
products
2861 Gum and wood chemicals
2865 Cyclic organic crudes and intermediates, and organic
dyes and pigments
2869 Industrial organic chemicals, n.e.c.*
2873 Nitrogenous fertilizers
2874 Phosphatic fertilizers
2875 Fertilizers, mixing only
2879 Pesticides and agricultural chemicals, n.e.c.*
2891 Adhesives and sealants
2892 Explosives
2893 Printing ink
2895 Carbon black
2899 Chemicals and chemical preparations, n.e.c.*
29 Petroleum Refining and Related
Industries
2911 Petroleum refining
2951 Asphalt paving mixtures and blocks
2952 Asphalt felts and coatings
2992 Lubricating oils and greases
2999 Products of petroleum and coal, n.e.c. *
30 Rubber and Miscellaneous Plastics
Products
3011 Tires and inner tubes
3021 Rubber and plastics footwear
3052 Rubber and plastics hose and belting
3053 Gaskets, packing, and sealing devices
3061 Molded, extruded, and lathe cut mechanical rubber
products
3069 Fabricated rubber products, n.e.c.*
3081 Unsupported plastics film and sheet
3082 Unsupported plastics profile shapes
3083 Laminated plastics plate, sheet, and profile shapes
3084 Plastics pipe
*"Not elsewhere classified" indicated by "n.e.c."
Toxics Release Inventory Reporting Forms and Instructions 1-3
-------
Table I
3085 Plastics bottles
3086 Plastics foam products
3087 Custom compounding of purchased plastics resins
3088 Plastics plumbing fixtures
3089 Plastics products, n.e.c.*
31 Leather and Leather Products
3111 Leather tanning and finishing
3131 Boot and shoe cut stock and findings
3142 House slippers
3143 Men's footwear, except athletic
3144 Women's footwear, except athletic
3149 Footwear, except rubber, n.e.c.*
3151 Leather gloves and mittens
3161 Luggage
3171 Women's handbags and purses
3172 Personal leather goods, except women'shandbags
and purses
3199 Leather goods, n.e.c.*
32 Stone, Clay, Glass and Concrete
Products
3211 Flat glass
3221 Glass containers
3229 Pressed and blown glass and glassware, n.e.c.*
3231 Glass products, made of purchased glass
3241 Cement, hydraulic
3251 Brick and structural clay tile
3253 Ceramic wall and floor tile
3255 Clay refractories
3259 Structural clay products, n.e.c.*
3261 Vitreous china plumbing fixtures and china and
earthenware fittings and bathroom accessories
3262 Vitreous china table and kitchen articles
3263 Fine earthenware (whiteware) table and kitchen
articles
3264 Porcelain electrical supplies
3269 Pottery products, n.e.c.*
3271 Concrete block and brick
3272 Concrete products, except block and brick
3273 Ready mixed concrete
3274 Lime
3275 Gypsum products
3281 Cut stone and stone products
3291 Abrasive products
3292 Asbestos products
3295 Minerals and earths, ground or otherwise treated
3296 Mineral wool
3297 Nonclay refractories
3299 Nonmetallic mineral products, n.e.c.*
33 Primary Metal Industries
3312 Steel works, blast furnaces (including coke ovens), and
rolling mills
3313 Electrometallurgical products, except steel
3315 Steel wiredrawing and steel nails and spikes
3316 Cold-rolled steel sheet, strip, and bars
3317 Steel pipe and tubes
3321 Gray and ductile iron foundries
3322 Malleable iron foundries
3324 Steel investment foundries
3325 Steel foundries, n.e.c.*
3331 Primary smelting and refining of copper
3334 Primary production of aluminum
3339 Primary smelting and refining of nonferrous metals,
except copper and aluminum
3341 Secondary smelting and refining of nonferrous metals
3351 Rolling, drawing, and extruding of copper
3353 Aluminum sheet, plate, and foil
3354 Aluminum extruded products
3355 Aluminum rolling and drawing, n.e.c.*
3356 Rolling, drawing, and extruding of nonferrous metals,
except copper and aluminum
3357 Drawing and insulating of nonferrous wire
3363 Aluminum die-castings
3364 Nonferrous die-castings, except aluminum
3365 Aluminum foundries
3366 Copper foundries
3369 Nonferrous foundries, except aluminum and copper
3398 Metal heat treating
3399 Primary metal products, n.e.c.*
34 Fabricated Metal Products, except
Machinery and Transportation
Equipment
3411 Metal cans
3412 Metal shipping barrels, drums, kegs, and pails
3421 Cutlery
3423 Hand and edge tools, except machine tools and
handsaws
3425 Handsaws and saw blades
3429 Hardware, n.e.c.*
3431 Enameled iron and metal sanitary ware
3432 Plumbing fixture fittings and trim
3433 Heating equipment, except electric and warm air
furnaces
3441 Fabricated structural metal
3442 Metal doors, sash, frames, molding, and trim
1-4 Toxics Release Inventory Reporting Forms and Instructions
*"Not elsewhere classified" indicated by "n.e.c."
-------
Table I
3443 Fabricated plate work (boiler shops)
3444 Sheet metal work
3446 Architectural and ornamental metal work
3448 Prefabricated metal buildings and components
3449 Miscellaneous structural metal work
3451 Screw machine products
3452 Bolts, nuts, screws, rivets, and washers
3462 Iron and steel forgings
3463 Nonferrous forgings
3465 Automotive stampings
3468 Crowns and closures
3469 Metal stampings, n.e.c.*
3471 Electroplating, plating, polishing, anodizing, and
coloring
3479 Coating, engraving and allied services, n.e.c.*
3482 Small arms ammunition
3483 Ammunition, except for small arms
3484 Small arms
3489 Ordnance and accessories, n.e.c.*
3491 Industrial valves
3492 Fluid power valves and hose fittings
3493 Steel springs, except wire
3494 Valves and pipe fittings, n.e.c.*
3495 Wire springs
3496 Miscellaneous fabricated wire products
3497 Metal foil and leaf
3498 Fabricated pipe and pipe fittings
3499 Fabricated metal products, n.e.c.*
35 Industrial and Commercial
Machinery and Computer
Equipment
3511 Steam, gas and hydraulic turbines, and turbine
generator set units
3519 Internal combustion engines, n.e.c.*
3523 Farm machinery and equipment
3524 Lawn and garden tractors and home lawn and
garden equipment
3531 Construction machinery and equipment
3532 Mining machinery and equipment, except oil and
gas field machinery and equipment
3533 Oil and gas field machinery and equipment
3534 Elevators and moving stairways
3535 Conveyors and conveying equipment
3536 Overhead traveling cranes, hoists, and monorail
systems
3537 Industrial trucks, tractors, trailers, and stackers
3541 Machine tools, metal cutting types
3542 Machine tools, metal forming types
3543 Industrial patterns
3544
3545
3546
3547
3548
3549
3552
3553
3554
3555
3556
3559
3561
3562
3563
3564
3565
3566
3567
3568
3569
3571
3572
3575
3577
3578
3579
3581
3582
3585
3586
3589
3592
3593
3594
3596
3599
36
3612
3613
Special dies and tools, die sets, jigs and fixtures, and
industrial molds
Cutting tools, machine tool accessories, and
machinists' measuring devices
Power driven handtools
Rolling mill machinery and equipment
Electric and gas welding and soldering equipment
Metalworking machinery, n.e.c.*
Textile machinery
Woodworking machinery
Paper industries machinery
Printing trades machinery and equipment
Food products machinery
Special industry machinery, n.e.c.*
Pumps and pumping equipment
Ball and roller bearings
Air and gas compressors
Industrial and commercial fans and blowers and air
purification equipment
Packaging equipment
Speed changers, industrial high speed drives, and gears
Industrial process furnaces and ovens
Mechanical power transmission equipment, n.e.c.*
General industrial machinery and equipment, n.e.c.*
Electronic computers
Computer storage devices
Computer terminals
Computer peripheral equipment, n.e.c.*
Calculating and accounting machines, except
electronic computers
Office machines, n.e.c.*
Automatic vending machines
Commercial laundry, dry-cleaning, and pressing
machines
Air conditioning and warm air heating equipment and
commercial and industrial refrigeration equipment
Measuring and dispensing pumps
Service industry machinery, n.e.c.*
Carburetors, pistons, piston rings, and valves
Fluid power cylinders and actuators
Fluid power pumps and motors
Scales and balances, except laboratory
Industrial and commercial machinery and equipment,
n.e.c*
Electronic and Other Electrical
Equipment and Components, Except
Computer Equipment
Power, distribution, and specialty transformers
Switchgear and switchboard apparatus
*"Not elsewhere classified" indicated by "n.e.c."
Toxics Release Inventory Reporting Forms and Instructions 1-5
-------
Table I
3621 Motors and generators
3624 Carbon and graphite products
3625 Relays and industrial controls
3629 Electrical industrial appliances, n.e.c.*
3631 Household cooking equipment
3632 Household refrigerators and home and farm
freezers
3633 Household laundry equipment
3634 Electrical housewares and fans
3635 Household vacuum cleaners
3639 Household appliances, n.e.c.*
3641 Electric lampbulbs and tubes
3643 Current carrying wiring devices
3644 Noncurrent carrying wiring devices
3645 Residential electric lighting fixtures
3646 Commercial, industrial, and institutional electric
lighting fixtures
3647 Vehicular lighting equipment
3648 Lighting equipment, n.e.c.*
3651 Household audio and video equipment
3652 Phonograph records and pre-recorded audio tapes
and disks
3661 Telephone and telegraph apparatus
3663 Radio and television broadcasting and
communications equipment
3669 Communications equipment, n.e.c.*
3671 Electron tubes
3672 Printed circuit boards
3674 Semiconductors and related devices
3675 Electronic capacitors
3676 Electronic resistors
3677 Electronic coils, transformers, and other inductors
3678 Electronic connectors
3679 Electronic components, n.e.c.*
3691 Storage batteries
3692 Primary batteries, dry and wet
3694 Electric equipment for internal combustion
engines
3695 Magnetic and optical recording media
3699 Electrical machinery, equipment, and supplies,
n.e.c.*
37 Transportation Equipment
3711 Motor vehicles and passenger car bodies
3713 Truck and bus bodies
3714 Motor vehicle parts and accessories
3715 Truck trailers
3716 Motor homes
3721 Aircraft
3724 Aircraft engines and engine parts
3728 Aircraft parts and auxiliary equipment, n.e.c.*
3731 Ship building and repairing
3732 Boat building and repairing
3743 Railroad equipment
3751 Motorcycles, bicycles and parts
3761 Guided missiles and space vehicles
3764 Guided missile and space vehicle propulsionunits and
propulsion unit parts
3769 Guided missile and space vehicle parts and auxiliary
equipment, n.e.c.*
3792 Travel trailers and campers
3795 Tanks and tank components
3799 Transportation equipment, n.e.c.*
38 Measuring, Analyzing, and
Controlling Instruments;
Photographic, Medical and
Optical Goods; Watches and Clocks
3812 Search, detection, navigation, guidance, aeronautical,
and nautical systems and instruments
3821 Laboratory apparatus and furniture
3822 Automatic controls for regulating residential and
commercial environments and appliances
3823 Industrial instruments for measurement, display, and
control of process variables; and related products
3824 Totalizing fluid meters and counting devices
3 825 Instruments for measuring and testing of electricity and
electrical signals
3826 Laboratory analytical instruments
3827 Optical instruments and lenses
3829 Measuring and controlling devices, n.e.c.*
3841 Surgical and medical instruments and apparatus
3842 Orthopedic, prosthetic, and surgical appliances and
supplies
3843 Dental equipment and supplies
3844 X-ray apparatus and tubes and related irradiation
apparatus
3845 Electromedical and electrotherapeutic apparatus
3851 Ophthalmic goods
3861 Photographic equipment and supplies
3873 Watches, clocks, clockwork operated devices, and
parts
39 Miscellaneous Manufacturing
Industries
3911 Jewelry, precious metal
3914 Silverware, plated ware, and stainless steel ware
1-6 Toxics Release Inventory Reporting Forms and Instructions
*"Not elsewhere classified" indicated by "n.e.c."
-------
3915 Jewelers' findings and materials, and lapidary
work
3931 Musical instruments
3 942 Dolls and stuffed toys
3944 Games, toys and children's vehicles; except dolls
and bicycles
3949 Sporting and athletic goods, n.e.c.*
3951 Pens, mechanical pencils, and parts
3952 Lead pencils, crayons, and artists' materials
3953 Marking devices
3955 Carbon paper and inked ribbons
3961 Costume jewelry and costume novelties, except
precious metal
3965 Fasteners, buttons, needles, and pins
3991 Brooms and brushes
3993 Signs and advertising specialties
3995 Burial caskets
3996 Linoleum, asphalted-felt-base, and other hard
surface floor coverings, n.e.c.*
3999 Manufacturing industries, n.e.c.*
49 Electric, Gas, and Sanitary
Services (limited to 4911,4931,4939 and
4953)
4911 Electric Services (limited to facilities that combust
coal and/or oil for the purpose of generating
electricity for distribution in commerce)
4931 Electric and Other Services Combined (limited to
facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce)
4939 Combination utilities, Not Elsewhere Classified
(limited to facilities that combust coal and/or oil
for the purpose of generating electricity for
distribution in commerce)
4953 Refuse Systems (limited to facilities regulated
under the RCRA Subtitle C, 42 U.S.C. section
692letseq.)
51 Wholesale Trade-Nondurable
Goods (limited to 5169 and 5171)
5169 Chemical and Allied Products, Not Elsewhere
Classified
5171 Petroleum Terminals and Bulk Stations
73 Business Services (limited to 7389)
7389 Business Services, Not Elsewhere Classified
(limited to facilities primarily engaged in solvents
recovery services on a contract or fee basis)
*"Not elsewhere classified" indicated by "n.e.c." Toxics Release Inventory Reporting Forms and Instructions 1-7
-------
This Page Intentionally Left Blank
-------
Table II. EPCRA Section 313 Chemical List For Reporting Year 2001
(including Toxic Chemical Categories)
Individually listed EPCRA Section 313 chemicals with CAS numbers are arranged alphabetically starting on page II-3. Following
the alphabetical list, the EPCRA Section 313 chemicals are arranged in CAS number order. Covered chemical categories follow.
Certain EPCRA Section 313 chemicals listed in Table II have parenthetic "qualifiers." These qualifiers indicate that these EPCRA
Section 313 chemicals are subject to the section 313 reporting requirements if manufactured, processed, or otherwise used in a specific
form or when a certain activity is performed. The following chemicals are reportable only if they are manufactured, processed, or
otherwise used in the specific form(s) listed below:
Chemical
Aluminum (fume or dust)
Aluminum oxide (fibrous forms)
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)
Asbestos (friable)
CAS
Number
7429-90-5
1344-28-1
7664-41-7
1332-21-4
Hydrochloric acid (acid aerosols including mists, vapors, gas, fog, 7647-01-0
and other airborne forms of any particle size)
Phosphorus (yellow or white) 7723-14-0
Sulfuric acid (acid aerosols including mists, vapors, gas, fog, and 7664-93-9
other airborne forms of any particle size)
Vanadium (except when contained in an alloy) 7440-62-2
Zinc (fume or dust) 7440-66-6
Qualifier
Only if it is a fume or dust form.
Only if it is a fibrous form.
Only 10% of aqueous forms. 100%
of anhydrous forms.
Only if it is a friable form.
Only if it is an aerosol form as
defined.
Only if it is a yellow or white form.
Only if it is an aerosol form as
defined.
Except if it is contained in an alloy.
Only if it is in a fume or dust form.
The qualifier for the following three chemicals is based on the chemical activity rather than the form of the chemical. These chemicals
are subject to EPCRA section 313 reporting requirements only when the indicated activity is performed.
Chemical/ Chemical Category CAS Number
Dioxin and dioxin-like compounds NA
(manufacturing; and the processing or otherwise use
of dioxin and dioxin-like compounds if the dioxin
and dioxin-like compounds are present as
contaminants in a chemical and if they were created
during the manufacture of that chemical.)
Isopropyl alcohol only (only persons who 67-63-0
manufacture by the strong acid process are subject,
no supplier notification)
Saccharin (manufacturing, no supplier notification) 81-07-2
Qualifier
Only if they are manufactured at the
facility; or are processed or otherwise
used when present as contaminants in a
chemical but only if they were created
during the manufacture of that chemical.
Only if it is being manufactured by the
strong acid process. Facilities that process
or otherwise use isopropyl alcohol are not
covered.
Only if it is being manufactured.
There are no supplier notification requirements for isopropyl alcohol and saccharin since the processors and users of these chemicals
are not required to report. Manufacturers of these chemicals do not need to notify their customers that these are reportable EPCRA
Toxics Release Inventory Reporting Form and Instructions II-1
-------
Table II
section 313 chemicals.
Note: Chemicals may be added to or deleted from the list. The Emergency Planning and Community Right-to-Know Call
Center, (800) 424-9346, or (703) 412-9810, will provide up-to-date information on the status of these changes. See section B.4.b
of the instructions for more information on the de minimis values listed below. There are no de minimis levels for PBT chemicals
since the de minimis exemption is not available for these chemicals (an asterisk appears where a de minimis limit would
otherwise appear in Table II). However, for purposes of the supplier notification requirement only, such limits are provided in
Appendix D.
Chemical Qualifiers
This table contains the list of individual EPCRA Section 313
chemicals and categories of chemicals subject to 2000 calendar
year reporting. Some of the EPCRA Section 313 chemicals listed
have parenthetic qualifiers listed next to them. An EPCRA
Section 313 chemical that is listed without a qualifier is subject
to reporting in all forms in which it is manufactured, processed,
and otherwise used.
Fume or dust. Two of the metals on the list (aluminum and
zinc) contain the qualifier "fume or dust." Fume or dust refers to
dry forms of these metals but does not refer to "wet" forms such
as solutions or slurries. As explained in Section B.3.a of these
instructions, the term manufacture includes the generation of an
EPCRA Section 313 chemical as a byproduct or impurity. In
such cases, a facility should determine if, for example, it
generated more than 25,000 pounds of aluminum fume or dust in
the reporting year as a result of its activities. If so, the facility
must report that it manufactures "aluminum (fume or dust)."
Similarly, there may be certain technologies in which one of
these metals is processed in the form of a fume or dust to make
other EPCRA Section 313 chemicals or other products for
distribution in commerce. In reporting releases, the facility
would only report releases of the fume or dust.
EPA considers dusts to consist of solid particles generated by any
mechanical processing of materials including crushing, grinding,
rapid impact, handling, detonation, and decrepitation of organic
and inorganic materials such as rock, ore, and metal. Dusts do
not tend to flocculate, except under electrostatic forces.
A fume is an airborne dispersion consisting of small solid
particles created by condensation from a gaseous state, in
distinction to a gas or vapor. Fumes arise from the heating of
solids such as lead. The condensation is often accompanied by
a chemical reaction, such as oxidation. Fumes flocculate and
sometimes coalesce.
Manufacturing qualifiers. Two of the entries to the section 313
EPCRA Section 313 chemical list contain a qualifier relating to
manufacture. Forisopropyl alcohol, the qualifier is "only persons
who manufacture by the strong acid process are subject."_For
saccharin, the qualifier simply is "manufacturing." For isopropyl
alcohol, the qualifier means that only facilities manufacturing
isopropyl alcohol by the strong acid process are required to
report. In the case of saccharin, only manufacturers of the
EPCRA Section 313 chemical are subject to the reporting
requirements. A facility that processes or otherwise uses either
EPCRA Section 313 chemical would not be required to report for
those EPCRA Section 313 chemicals. In both cases, supplier
notification does not apply because only manufacturers, not users,
of the EPCRA Section 313 chemical must report.
Ammonia (includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium salts and other
sources; 10 percent of total aqueous ammonia is reportable
under this listing). The qualifier for ammonia means that
anhydrous forms of ammonia are 100% reportable and aqueous
forms are limited to 10% of total aqueous ammonia. Therefore
when determining threshold and releases and other waste
management quantities all anhydrous ammonia is included but
only 10% of total aqueous ammonia is included. Any
evaporation of ammonia from aqueous ammonia solutions is
considered anhydrous ammonia and should be included in
threshold determinations and release and other waste
management calculations.
Sulfuric acid and Hydrochloric acid (acid aerosols including
mists, vapors, gas, fog, and other airborne forms of any
particle size). The qualifier for sulfuric acid and hydrochloric
acid means that the only forms of this chemical that are reportable
are airborne forms. Aqueous solutions are not covered by this
listing but any aerosols generated from aqueous solutions are
covered.
Nitrate compounds (water dissociable; reportable only when
in aqueous solution). The qualifier for the nitrate compounds
category limits the reporting to nitrate compounds that dissociate
in water, generating nitrate ion. For the purposes of threshold
determinations the entire weight of the nitrate compound must be
II-2 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
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.
Phosphorus (yellow or white). The listing for phosphorus is
qualified by the term "yellow or white." This means that only
manufacturing, processing, or otherwise use of phosphorus in the
yellow or white chemical form triggers reporting. Conversely,
manufacturing, processing, or otherwise use of "black" or "red"
phosphorus does not trigger reporting. Supplier notification also
applies only to distribution of yellow or white phosphorus.
Asbestos (friable). The listing for asbestos is qualified by the
term "friable," referring to the physical characteristic of being
able to be crumbled, pulverized, or reducible to a powder with
hand pressure. Only manufacturing, processing, or otherwise use
of asbestos in the friable form triggers reporting. Supplier
notification applies only to distribution of mixtures or other trade
name products containing friable asbestos.
Aluminum Oxide (fibrous forms). The listing for aluminum
oxide is qualified by the term "fibrous forms." Fibrous refers to
a man-made form of aluminum oxide that is processed to produce
strands or filaments which can be cut to various lengths
depending on the application. Only manufacturing, processing,
or otherwise use of aluminum oxide in the fibrous form triggers
reporting. Supplier notification applies only to distribution of
mixtures or other trade name products containing fibrous forms
of aluminum oxide.
a. Individually-Listed Toxic Chemicals
Arranged Alphabetically
Notes for Sections A and B of following list of TRI
chemicals:
"Color Index" indicated by "C.I."
* There are no de minimis levels for PBT chemicals,
except for supplier notification purposes (see
Appendix D)
CAS Number Chemical Name
De Minimis
Limit
71751-41-2 Abamectin[AvermectinBl] 1.0
30560-19-1 Acephate 1.0
(Acetylphosphoramidothioic acid O,S-
dimethyl ester)
75-07-0 Acetaldehyde 0.1
60-35-5 Acetamide 0.1
75-05-8 Acetonitrile 1.0
98-86-2 Acetophenone 1.0
53-96-3 2-Acetylaminofluorene 0.1
62476-59-9 Acifluorfen, sodium salt 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-2-
nitrobenzoic acid, sodium salt]
107-02-8 Acrolein 1.0
79-06-1 Acrylamide 0.1
79-10-7 Acrylic acid 1.0
107-13-1 Acrylonitrile 0.1
15972-60-8 Alachlor 1.0
116-06-3 Aldicarb 1.0
309-00-2 Aldrin *
[l,4:5,8-Dimethanonaphthalene,
l,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a-
hexahydro-(l.alpha.,4.alpha.,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
28057-48-9 d-trans-Allethrin 1.0
[d-trans-Chrysanthemic acid of d-allethrone]
107-18-6 Allyl alcohol 1.0
107-11-9 Allylamine 1.0
107-05-1 Allyl chloride 1.0
7429-90-5 Aluminum (fume or dust) 1.0
20859-73-8 Aluminum phosphide 1.0
1344-28-1 Aluminum oxide (fibrous forms) 1.0
834-12-8 Ametryn 1.0
(N-Ethyl-N'-(l-methylethyl)-6-(methylthio)-
l,3,5,-triazine-2,4-diamine)
117-79-3 2-Aminoanthraquinone 0.1
60-09-3 4-Aminoazobenzene 0.1
92-67-1 4-Aminobiphenyl 0.1
82-28-0 l-Amino-2-methylanthraquinone 0.1
Toxics Release Inventory Reporting Form and Instructions II-3
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
33089-61-1 Amitraz 1.0
61-82-5 Amitrole 0.1
7664-41-7 Ammonia 1.0
(includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium
salts and other sources; 10 percent of total
aqueous ammonia is reportable under this
listing)
101-05-3 Anilazine 1.0
[4,6-Dichloro-N-(2-chlorophenyl)-l,3,5-
triazin-2 -amine]
62-53-3 Aniline 1.0
90-04-0 o-Anisidine 0.1
104-94-9 p-Anisidine 1.0
134-29-2 o-Anisidine hydrochloride 0.1
120-12-7 Anthracene 1.0
7440-36-0 Antimony 1.0
7440-38-2 Arsenic 0.1
1332-21-4 Asbestos (friable) 0.1
1912-24-9 Atrazine 1.0
(6-Chloro-N-ethyl-N' -(1 -methylethyl)-1,3,5-
triazine-2,4-diamine)
7440-39-3 Barium 1.0
22781-23-3 Bendiocarb 1.0
[2,2-Dimethyl-l,3-benzodioxol-4-ol
methylcarbamate]
1861-40-1 Benfluralin 1.0
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)-benzenamine)
17804-35-2 Benomyl 1.0
98-87-3 Benzal chloride 1.0
55-21-0 Benzamide 1.0
71-43-2 Benzene 0.1
92-87-5 Benzidine 0.1
98-07-7 Benzoic trichloride 0.1
(Benzotrichloride)
191-24-2 Benzo(g,h,i)perylene *
98-88-4 Benzoyl chloride 1.0
94-36-0 Benzoyl peroxide 1.0
100-44-7 Benzyl chloride 1.0
7440-41-7 Beryllium 0.1
82657-04-3 Bifenthrin 1.0
92-52-4 Biphenyl 1.0
111-91-1 Bis(2-chloroethoxy) methane 1.0
111-44-4 Bis(2-chloroethyl) ether 1.0
542-88-1 Bis(chloromethyl) ether 0.1
108-60-1 Bis(2-chloro-l-methylethyl)ether 1.0
56-35-9 Bis(tributyltin) oxide 1.0
10294-34-5 Boron trichloride 1.0
7637-07-2 Boron trifluoride 1.0
CAS Number Chemical Name
De Minimis
Limit
314-40-9
53404-19-6
7726-95-6
35691-65-7
353-59-3
75-25-2
74-83-9
75-63-8
1689-84-5
1689-99-2
357-57-3
106-99-0
141-32-2
71-36-3
78-92-2
75-65-0
106-88-7
123-72-8
7440-43-9
156-62-7
133-06-2
63-25-2
1563-66-2
75-15-0
56-23-5
463-58-1
5234-68-4
120-80-9
2439-01-2
133-90-4
57-74-9
Bromacil 1.0
(5-Bromo-6-methyl-3-(l-methylpropyl)-
2,4( lH,3H)-pyrimidinedione)
Bromacil, lithium salt 1.0
[2,4(lH,3H)-Pyrimidinedione,5-bromo-6-
methyl-3-(l-methylpropyl), lithium salt]
Bromine 1.0
l-Bromo-l-(bromomethyl)- 1.0
1,3 -propanedicarbonitrile
Bromochlorodifluoromethane 1.0
(Halonl211)
Bromoform (Tribromomethane) 1.0
Bromomethane 1.0
(Methyl bromide)
Bromotrifluoromethane 1.0
(Halon 1301)
Bromoxynil 1.0
(3,5-Dibromo-4-hydroxybenzonitrile)
Bromoxynil octanoate 1.0
(Octanoic acid, 2,6-dibromo-4-
cyanophenylester)
Brucine 1.0
1,3-Butadiene 0.1
Butyl aery late 1.0
n-Butyl alcohol 1.0
sec-Butyl alcohol 1.0
tert-Butyl alcohol 1.0
1,2-Butylene oxide 0.1
Butyraldehyde 1.0
Cadmium 0.1
Calcium cy anamide 1.0
Captan 1.0
[lH-Isoindole-l,3(2H)-dione, 3a,4,7,7a-
tetrahydro-2-[(trichloromethyl)thio]-]
Carbaryl [1-Naphthalenol, 1.0
methylcarbamate]
Carbofuran 1.0
Carbon disulfide 1.0
Carbon tetrachloride 0.1
Carbonyl sulfide 1.0
Carboxin 1.0
(5,6-Dihydro-2-methyl-N-
phenyl-1,4-oxathiin-3 -carboxamide)
Catechol 0.1
Chinomethionat 1.0
[6-Methyl-l,3-dithiolo[4,5-b]quinoxalin-2-
one]
Chloramben
[Benzoic acid, 3-amino-2,5-dichloro-]
Chlordane
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-hexahydro-]
1.0
II-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
CAS Number Chemical Name
De Minimis
Limit
115-28-6 Chlorendic acid
90982-32-4 Chlorimuron ethyl
[Ethyl-2-[[[[(4-chloro-6-methoxyprimidin-2-
y l)amino] carbony 1] amino] sulfony 1]
benzoate]
7782-50-5 Chlorine
10049-04-4 Chlorine dioxide
79-11-8 Chloroacetic acid
532-27-4 2-Chloroacetophenone
4080-31-3 l-(3-Chloroallyl)-3,5,7-triaza-
1-azoniaadamantane chloride
106-47-8 p-Chloroaniline
108-90-7 Chlorobenzene
510-15-6 Chlorobenzilate
[Benzeneacetic acid, 4-chloro-.alpha.- (4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
75-68-3 l-Chloro-l,l-difluoroethane
(HCFC-142b)
75-45-6 Chlorodifluoromethane
(HCFC-22)
75-00-3 Chloroethane (Ethyl chloride)
67-66-3 Chloroform
74-87-3 Chloromethane (Methyl chloride)
107-30-2 Chloromethyl methyl ether
563 -47-3 3 -Chloro-2-methyl-1 -propene
104-12-1 p-Chlorophenyl isocyanate
76-06-2 Chloropicrin
126-99-8 Chloroprene
542-76-7 3-Chloropropionitrile
63938-10-3 Chlorotetrafluoroethane
354-25-6 1-Chloro-l, 1,2,2-
tetrafluoroethane (HCFC-124a)
2837-89-0 2-Chloro-l, 1,1,2-
tetrafluoroethane (HCFC-124)
1897-45-6 Chlorothalonil
[1,3-Benzenedicarbonitrile, 2,4,5,6-
tetrachloro-]
95-69-2 p-Chloro-o-toluidine
75-88-7 2-Chloro-1,1,1-
trifluoroethane (HCFC-133a)
75-72-9 Chlorotrifluoromethane (CFC-13)
460-35-5 3-Chloro-l,l,l-
trifluoropropane (HCFC-253fb)
5598-13-0 Chlorpyrifos methyl
[O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate]
64902-72-3 Chlorsulfuron
[2-Chloro-N-[[(4-methoxy-6-methyl-l,3,5-
triazin-2-yl)amino]carbonyl]
benzenesulfonamide]
1.0
1.0
Chromium 1.0
C.I. Acid Green 3 1.0
C.I. Acid Red 114 0.1
C.I. Basic Green 4 1.0
C.I. Basic Red 1 1.0
C.I. Direct Black 38 0.1
C.I. Direct Blue 6 0.1
C.I. Direct Blue 218 1.0
C.I. Direct Brown 95 0.1
C.I. Disperse Yellow 3 1.0
C.I. Food Red 5 0.1
C.I. Food Red 15 1.0
C.I. Solvent Orange 7 1.0
C.I. Solvent Yellow 3 0.1
C.I. Solvent Yellow 14 1.0
C.I. Solvent Yellow 34 0.1
(Auramine)
C.I. Vat Yellow 4 1.0
Cobalt 0.1
Copper 1.0
Creosote 0.1
p-Cresidine 0.1
m-Cresol .0
o-Cresol .0
p-Cresol .0
Cresol (mixed isomers) .0
Crotonaldehyde .0
Cumene .0
Cumene hydroperoxide .0
Cupferron 0.1
[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 1.0
[3-(2-Chloro-3,3,3-trifluoro-l-propenyl)-2,2-
dimethylcyclopropane-carboxylic acid
cyano(3 -phenoxyphenyl)methyl ester]
2,4-D 0.1
[Acetic acid, (2,4-dichlorophenoxy)-]
Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione)
0.1
1.0
1-2-
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
*]
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
7440-47-3
4680-78-8
6459-94-5
569-64-2
989-38-8
1937-37-7
2602-46-2
28407-37-6
16071-86-6
2832-40-8
3761-53-3
81-88-9
3118-97-6
97-56-3
842-07-9
492-80-8
128-66-5
7440-48-4
7440-50-8
8001-58-9
120-71-8
108-39-4
95-48-7
106-44-5
1319-77-3
4170-30-3
98-82-8
80-15-9
135-20-6
21725-46-2
1134-23-2
110-82-7
108-93-0
68359-37-5
68085-85-8
94-75-7
533-74-4
Toxics Release Inventory Reporting Form and Instructions II-5
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
CAS Number Chemical Name
De Minimis
Limit
53404-60-7 Dazomet, sodium salt 1.0 1717-00-6
[Tetrahydro-3,5-dimethyl-2H-1,3,5-
thiadiazine-2-thione, ion(l-), sodium]
94-82-6 2,4-DB
1929-73-3 2,4-D butoxyethyl ester
94-80-4 2,4-D butyl ester
2971-38-2 2,4-D chlorocrotyl ester
1163-19-5 Decabromodiphenyl oxide
13684-56-5 Desmedipham
1928-43-4 2,4-D 2-ethylhexyl ester
53404-37-8 2,4-D 2-ethyl-4-
methyrpentyl ester
2303-16-4 Diallate
[Carbamothioic acid, bis(l-methylethyl)-S-
(2,3-dichloro-2-propenyl) ester]
615-05-4 2,4-Diaminoanisole
39156-41-7 2,4-Diaminoanisole sulfate
101-80-4 4,4'-Diaminodiphenyl ether
95-80-7 2,4-Diaminotoluene
25376-45-8 Diaminotoluene (mixed isomers)
333-41-5 Diazinon
334-88-3 Diazomethane
132-64-9 Dibenzofuran
96-12-8 l,2-Dibromo-3-
chloropropane (DBCP)
106-93-4 1,2-Dibromoethane
(Ethylene dibromide)
124-73-2 Dibromotetrafluoroethane
(Halon 2402)
84-74-2 Dibutyl phthalate
1918-00-9 Dicamba
(3,6-Dichloro-2-methoxybenzoic acid)
99-30-9 Dichloran
[2,6-Dichloro-4-nitroaniline]
95-50-1 1,2-Dichlorobenzene
541-73-1 1,3-Dichlorobenzene
106-46-7 1,4-Dichlorobenzene
25321-22-6 Dichlorobenzene (mixed isomers)
91-94-1 3,3'-Dichlorobenzidine
612-83-9 3,3'-Dichlorobenzidine
dihydrochloride
64969-34-2 3,3'-Dichlorobenzidine sulfate
75-27-4 Dichlorobromomethane
764-41-0 l,4-Dichloro-2-butene
110-57-6 trans-l,4-Dichloro-2-butene
1649-08-7 l,2-Dichloro-l,l-
difluoroethane (HCFC-132b)
75-71-8 Dichlorodifluoromethane (CFC-12) 1.0
107-06-2 1,2-Dichloroethane (Ethylene 0.1
dichloride)
540-59-0 1,2-Dichloroethylene 1.0
77-73-6
1.0
0.1
0.1
0.1
1.0
1.0
0.1
0.1
1.0
0.
0.
0.
0.
0.
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.
0.
0.
0.
0.
0.
1.0
1.0
1.0
75-43-4
75-09-2
127564-92-5
13474-88-9
111512-56-2
422-44-6
431-86-7
507-55-1
136013-79-1
128903-21-9
422-48-0
422-56-0
97-23-4
120-83-2
78-87-5
10061-02-6
78-88-6
542-75-6
76-14-2
34077-87-7
90454-18-5
812-04-4
354-23-4
306-83-2
62-73-7
51338-27-3
115-32-2
1,1-Dichloro-l-fluoroethane 1.0
(HCFC-141b)
Dichlorofluoromethane (HCFC-21) 1.0
Dichloromethane (Methylene 0.1
chloride)
Dichloropentafluoropropane 1.0
l,l-Dichloro-l,2,2,3,3- 1.0
pentafluoropropane (HCFC-225cc)
l,l-Dichloro-l,2,3,3,3- 1.0
pentafluoropropane (HCFC-225eb)
1,2-Dichloro-l,1,2,3,3- 1.0
pentafluoropropane (HCFC-225bb)
1,2-Dichloro-l,1,3,3,3- 1.0
pentafluoropropane (HCFC-225da)
1,3-Dichloro-l,1,2,2,3- 1.0
pentafluoropropane (HCFC-225cb)
1,3-Dichloro-l,1,2,3,3- 1.0
pentafluoropropane (HCFC-225ea)
2,2-Dichloro-l,1,1,3,3- 1.0
pentafluoropropane (HCFC-225aa)
2,3-Dichloro-l,1,1,2,3- 1.0
pentafluoropropane (HCFC-225ba)
3,3-Dichloro-l,1,1,2,2- 1.0
pentafluoropropane (HCFC-225ca)
Dichlorophene 1.0
[2,2'-Methylenebis(4-chlorophenol)]
2,4-Dichlorophenol 1.0
1,2-Dichloropropane 1.0
trans-l,3-Dichloropropene 0.1
2,3-Dichloropropene 1.0
1,3 -Dichloropropy lene 0.1
Dichlorotetrafluoroethane 1.0
(CFC-114)
Dichlorotrifluoroethane 1.0
Dichloro-l,l,2-trifluoroethane 1.0
l,l-Dichloro-l,2,2- 1.0
trifluoroethane (HCFC-123b)
1,2-Dichloro-l,1,2- 1.0
trifluoroethane (HCFC-123a)
2,2-Dichloro-l, 1,1- 1.0
trifluoroethane (HCFC-123)
Dichlorvos 0.1
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
Diclofop methyl 1.0
[2-[4-(2,4-Dichlorophenoxy)phenoxy]
propanoic acid, methyl ester]
Dicofol 1.0
[Benzenemethanol, 4-chloro-
. alpha.-4-(chlorophenyl)-. alpha.-
(trichloromethyl)-]
Dicyclopentadiene 1.0
II-6 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
1464-53-5
111-42-2
38727-55-8
117-81-7
64-67-5
35367-38-5
101-90-6
94-58-6
55290-64-7
60-51-5
119-90-4
20325-40-0
111984-09-9
124-40-3
2300-66-5
60-11-7
121-69-7
119-93-7
612-82-8
41766-75-0
79-44-7
2524-03-0
68-12-2
57-14-7
105-67-9
131-11-3
77-78-1
99-65-0
528-29-0
100-25-4
88-85-7
534-52-1
51-28-5
121-14-2
606-20-2
25321-14-6
39300-45-3
123-91-1
957-51-7
122-39-4
Diepoxybutane 0.1
Diethanolamine 1.0
Diethatyl ethyl 1.0
Di(2-ethylhexyl) phthalate (DEHP) 0.1
Diethyl sulfate 0.1
Diflubenzuron 1.0
Diglycidyl resorcinol ether 0.1
Dihydrosafrole 0.1
Dimethipin 1.0
[2,3 -Dihydro-5,6-dimethyl-1,4-dithiin-
1,1,4,4-tetraoxide]
Dimethoate 1.0
3,3'-Dimethoxybenzidine 0.1
3,3'-Dimethoxybenzidine 0.1
dihydrochloride (o-Dianisidine
dihydrochloride)
3,3'-Dimethoxybenzidine 0.1
hydrochloride (o-Dianisidine hydrochloride)
Dimethylamine 1.0
Dimethylamine dicamba 1.0
4-Dimethylaminoazobenzene 0.1
N,N-Dimethylaniline 1.0
3,3'-Dimethylbenzidine (o-Tolidine) 0.1
3,3'-Dimethylbenzidine 0.1
dihydrochloride (o-Tolidine dihydrochloride)
3,3 '-Dimethylbenzidine 0.1
dihydrofluoride (o-Tolidine dihydrofluoride)
Dimethylcarbamyl chloride
Dimethyl
chlorothiophosphate
N,N-Dimethylformamide
1,1-Dimethyl hydrazine
2,4-Dimethylphenol
Dimethyl phthalate
Dimethyl sulfate
m-Dinitrobenzene
o-Dinitrobenzene
p-Dinitrobenzene
Dinitrobutyl phenol (Dinoseb)
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Dinitrotoluene (mixed isomers)
Dinocap
1,4-Dioxane
Diphenamid
Diphenylamine
0.1
1.0
1.0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
CAS Number Chemical Name
De Minimis
Limit
122-66-7
2164-07-0
136-45-8
138-93-2
94-11-1
541-53-7
330-54-1
2439-10-3
120-36-5
1320-18-9
2702-72-9
106-89-8
13194-48-4
110-80-5
140-88-5
100-41-4
541-41-3
759-94-4
74-85-1
107-21-1
151-56-4
75-21-8
96-45-7
75-34-3
52-85-7
60168-88-9
13356-08-6
66441-23-4
72490-01-8
39515-41-8
1,2-Diphenylhydrazine
(Hydrazobenzene)
Dipotassium endothall
[7-Oxabicyclo(2.2. l)heptane-2,3-
dicarboxylic acid, dipotassium salt]
Dipropyl isocinchomeronate
Disodium
cyanodithioimidocarbonate
2,4-D isopropyl ester
2,4-Dithiobiuret
Diuron
Dodine [Dodecylguanidine
monoacetate]
2,4-DP
2,4-D propylene glycol
butyl ether ester
2,4-D sodium salt
Epichlorohydrin
Ethoprop
0.1
1.0
1.0
1.0
0.1
1.0
1.0
1.0
0.1
0.1
0.1
0.1
1.0
[Phosphorodithioic acid O-ethyl S,S-dipropyl
ester]
2-Ethoxyethanol 1.0
Ethyl aery late 0.1
Ethylbenzene 0.1
Ethyl chloroformate 1.0
Ethyl dipropylthiocarbamate 1.0
(EPTC)
Ethylene 1.0
Ethylene glycol 1.0
Ethyleneimine (Aziridine) 0.1
Ethylene oxide 0.1
Ethylene thiourea 0.1
Ethylidene dichloride 1.0
Famphur 1.0
Fenarimol 1.0
[.alpha.-(2-Chlorophenyl)-.alpha.-(4-
chlorophenyl)-5-pyrimidinemethanol]
Fenbutatin oxide 1.0
(Hexakis(2-methyl-2-phenylpropyl)
distannoxane)
Fenoxaprop ethyl 1.0
[2-(4-((6-Chloro-2-
benzoxazolylen)oxy)phenoxy)propanoic
acid, ethyl ester]
Fenoxycarb 1.0
[[2-(4-Phenoxy phenoxy)ethyl]carbamic acid
ethyl ester]
Fenpropathrin 1.0
[2,2,3,3-Tetramethylcyclopropane carboxylic
acid cyano(3-phenoxyphenyl)methyl ester]
Toxics Release Inventory Reporting Form and Instructions II-7
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
55-38-9 Fenthion 1.0
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester, phosphorothioic
acid]
51630-58-1 Fenvalerate 1.0
[4-Chloro-alpha-( 1 -methylethyl)
benzeneacetic acid cyano (3-phenoxyphenyl)
methyl ester]
14484-64-1 Ferbam 1.0
[Tris(dimethylcarbamodithioato- S,S')iron]
69806-50-4 Fluazifop butyl 1.0
[2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]phenoxy]propanoic acid, butyl
ester]
2164-17-2 Fluometuron 1.0
[Urea, N,N-dimethyl-N'-[3-
(trifluoromethy l)pheny 1] -]
7782-41-4 Fluorine 1.0
51-21-8 Fluorouracil (5-Fluorouracil) 1.0
69409-94-5 Fluvalinate 1.0
[N-[2-Chloro-4-(trifluoromethyl)phenyl]-
DL-valine(+)-cyano(3 -
phenoxyphenyl)methyl ester]
133-07-3 Folpet 1.0
72178-02-0 Fomesafen 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-N-
methylsulfonyl-2-nitrobenzamide]
50-00-0 Formaldehyde 0.1
64-18-6 Formic acid 1.0
76-13-1 FreonllS 1.0
[Ethane, 1,1,2-trichloro- 1,2,2,-trifluoro-]
76-44-8 Heptachlor *
[l,4,5,6,7,8,8-Heptachloro-3a, 4,7,7a-
tetrahydro-4,7-methano-lH-indene]
118-74-1 Hexachlorobenzene *
87-68-3 Hexachloro-l,3-butadiene 1.0
319-84-6 alpha-Hexachlorocyclohexane 0.1
77-47-4 Hexachlorocyclopentadiene 1.0
67-72-1 Hexachloroethane 0.1
1335-87-1 Hexachloronaphthalene 1.0
70-30-4 Hexachlorophene 1.0
680-31-9 Hexamethyrphosphoramide 0.1
110-54-3 n-Hexane 1.0
51235-04-2 Hexazinone 1.0
67485-29-4 Hydramethylnon 1.0
[Tetrahydro-5,5-dimethyl-2(lH)-
pyrimidinone[3-[4-(trifluoromethyl)phenyl]-
l-[2-[4-(trifluoromethyl)phenyl]ethenyl]-2-
propenylidene]hydrazone]
302-01-2 Hydrazine 0.1
10034-93-2 Hydrazine surfate 0.1
CAS Number Chemical Name
De Minimis
Limit
7647-01-0
74-90-8
7664-39-3
123-31-9
35554.44-0
55406-53-6
13463-40-6
78-84-2
465-73-6
25311-71-1
67-63-0
80-05-7
120-58-1
77501-63-4
7439-92-1
58-89-9
330-55-2
554-13-2
121-75-5
108-31-6
109-77-3
12427-38-2
7439-96-5
93-65-2
149-30-4
7439.97-6
150-50-5
126-98-7
Hydrochloric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
Hydrogen cyanide 1.0
Hydrogen fluoride 1.0
Hydroquinone 1.0
Imazalil 1.0
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy )ethyl] - IH-imidazole]
3-Iodo-2-propynyl 1.0
butylcarbamate
Iron pentacarbonyl 1.0
Isobutyraldehyde 1.0
Isodrin *
Isofenphos[2-[[Ethoxyl[(l- 1.0
methylethyl)amino]phosphinothioyl]oxy]
benzoic acid 1-methylethyl ester]
Isopropyl alcohol 1.0
(only persons who manufacture by the strong
acid process are subject, no supplier
notification)
4,4'-Isopropylidenediphenol 1.0
Isosafrole 1.0
Lactofen 1.0
[Benzoic acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy]-2-nitro-, 2-
ethoxy-l-methyl-2-oxoethyl ester]
Lead *
(when lead is contained in stainless steel,
brass or bronze alloys the de minimis level is
0.1)
Lindane 0.1
[Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(l.alpha.,2.alpha.,3.beta., 4.alpha., S.alpha.,
6.beta.)-]
Linuron
Lithium carbonate
Malathion
Maleic anhydride
Malononitrile
Maneb
[Carbamodithioic acid, 1,2-ethanediylbis-,
manganese complex]
Manganese 1.0
Mecoprop 0.1
2-Mercaptobenzothiazole (MET) 1.0
Mercury *
Merphos 1.0
Methacrylonitrile 1.0
II-8 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
Metham sodium (Sodium 1.0
methyldithiocarbamate)
Methanol 1.0
Methazole 1.0
[2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
oxadiazolidine-3,5-dione]
Methiocarb 1.0
Methoxone 0.1
((4-Chloro-2-methylphenoxy) acetic acid)
(MCPA)
Methoxone sodium salt 0.1
((4-Chloro-2-methylphenoxy) acetate
sodium salt)
Methoxychlor *
[Benzene, 1,1 '-(2,2,2-
trichloroethylidene)bis[4-methoxy-]]
2-Methoxyethanol 1.0
Methyl aery late 1.0
Methyl tert-buty 1 ether 1.0
Methyl chlorocarbonate 1.0
4,4'-Methylenebis(2-chloroaniline) 0.1
(MBOCA)
4,4'-Methylenebis(N,N-dimethyl) 0.1
benzenamine
Methylene bromide 1.0
4,4'-Methylenedianiline 0.1
Methyl ethyl ketone 1.0
Methyl hydrazine 1.0
Methyl iodide 1.0
Methyl isobuty 1 ketone 1.0
Methyl isocyanate 1.0
Methyl isothiocyanate 1.0
[Isothiocyanatomethane]
2-Methyllactonitrile 1.0
Methyl methacry late 1.0
N-Methylolacry lamide 1.0
Methyl parathion 1.0
2-Methylpyridine 1.0
N-Methyl-2-pyrrolidone 1.0
Metiram 1.0
Metribuzin 1.0
Mevinphos 1.0
Michler' s ketone 0.1
Molinate 1.0
(IH-Azepine-l-carbothioic acid, hexahydro-
, S-ethyl ester)
Molybdenum trioxide 1.0
Monochloropentafluoroethane 1.0
(CFC-115)
Monuron 1.0
67-56-1
20354-26-1
2032-65-7
94-74-6
3653-48-3
72-43-5
109-86-4
96-33-3
1634-04-4
79-22-1
101-14-4
101-61-1
74-95-3
101-77-9
78-93-3
60-34-4
74-88-4
108-10-1
624-83-9
556-61-6
75-86-5
80-62-6
924-42-5
298-00-0
109-06-8
872-50-4
9006-42-2
21087-64-9
7786-34-7
90-94-8
2212-67-1
1313-27-5
76-15-3
150-68-5
CAS Number Chemical Name
De Minimis
Limit
505-60-2
88671-89-0
142-59-6
300-76-5
91-20-3
134-32-7
91-59-8
7440-02-0
1929-82-4
7697-37-2
139-13-9
100-01-6
99-59-2
98-95-3
92-93-3
1836-75-5
51-75-2
55-63-0
88-75-5
100-02-7
79-46-9
924-16-3
55-18-5
62-75-9
86-30-6
156-10-5
621-64-7
759-73-9
684-93-5
4549-40-0
59-89-2
16543-55-8
100-75-4
99-55-8
27314-13-2
2234-13-1
29082-74-4
19044-88-3
20816-12-0
Mustard gas 0.1
[Ethane, l,l'-thiobis[2-chloro-]]
Myclobutanil 1.0
[.alpha. -Butyl-.alpha. -(4-chlorophenyl)- 1H-
1,2,4-triazole-l -propanenitrile]
Nabam 1.0
Naled 1.0
Naphthalene 1.0
alpha-Naphthylamine 0.1
beta-Naphthylamine 0.1
Nickel 0.1
Nitrapyrin 1.0
(2-Chloro-6-(trichloromethyl)pyridine)
Nitric acid 1.0
Nitrilotriacetic acid 0.1
p-Nitroaniline 1.0
5-Nitro-o-anisidine 1.0
Nitrobenzene 0.1
4-Nitrobiphenyl 0.1
Nitrofen 0.1
[Benzene, 2,4-dichloro-1 -(4-nitrophenoxy)-]
Nitrogen mustard 0.1
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
Nitroglycerin
2-Nitrophenol
4-Nitrophenol
2-Nitropropane
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
p-Nitrosodiphenylamine
N-Nitrosodi-n-propylamine
N-Nitroso-N-ethylurea
N-Nitro so -N-methy lurea
N-Nitrosomethylvinylamine
N-Nitrosomorpholine
N-Nitrosonornicotine
N-Nitrosopiperidine
5-Nitro-o-toluidine
Norflurazon
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)pheny 1] -3 (2H)-py ridazinone]
Octachloronaphthalene
Octachlorostyrene
Oryzalin
[4-(Dipropylamino)-3,5-dinitrobenzene
sulfonamide]
Osmium tetroxide
1.0
1.0
1.0
0.1
0.1
0.1
0.1
1.0
1.0
0.1
0.1
0.1
0.1
0.1
0.1
0.1
1.0
1.0
1.0
*
1.0
1.0
Toxics Release Inventory Reporting Form and Instructions II-9
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
301-12-2 Oxydemeton methyl 1.0
[S-(2-(Ethylsuffinyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
19666-30-9 Oxydiazon 1.0
[3-[2,4-Dichloro-5-(l-
methylethoxy)phenyl]- 5-(l,l-
dimethylethyl)-l,3,4-oxadiazol-2(3H)-one]
42874-03-3 Oxyfluorfen 1.0
10028-15-6 Ozone 1.0
123-63-7 Paraldehyde 1.0
1910-42-5 Paraquat dichloride 1.0
56-38-2 Parathion 1.0
[Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl)ester]
1114-71-2 Pebulate 1.0
[Butylethylcarbamothioic acid S-propyl
ester]
40487-42-1 Pendimethalin *
[N-(l-Ethyrpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine]
608-93-5 Pentachlorobenzene *
76-01-7 Pentachloroethane 1.0
87-86-5 Pentachlorophenol (PCP) 0.1
57-33-0 Pentobarbital sodium 1.0
79-21-0 Peracetic acid 1.0
594-42-3 Perchloromethyl mercaptan 1.0
52645-53-1 Permethrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid, (3-
phenoxyphenyl) methyl ester]
85-01-8 Phenanthrene 1.0
108-95-2 Phenol 1.0
26002-80-2 Phenothrin 1.0
[2,2-Dimethyl-3-(2-methyl-1 -
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester]
95-54-5 1,2-Phenylenediamine 1.0
108-45-2 1,3-Phenylenediamine 1.0
106-50-3 p-Phenylenediamine 1.0
615-28-1 1,2-Phenylenediamine dihydro- 1.0
chloride
624-18-0 1,4-Phenylenediamine dihydro- 1.0
chloride
90-43-7 2-Phenylphenol 1.0
57-41-0 Phenytoin 0.1
75-44-5 Phosgene 1.0
7803-51-2 Phosphine 1.0
7723-14-0 Phosphorus (yellow or white) 1.0
85-44-9 Phthalic anhydride 1.0
1918-02-1 Picloram 1.0
88-89-1 Picric acid 1.0
11-10 Toxics Release Inventory Reporting Forms and Instructions
CAS Number Chemical Name
De Minimis
Limit
51-03-6
29232-93-7
1336-36-3
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
57-57-8
123-38-6
114-26-1
115-07-1
75-55-8
75-56-9
110-86-1
91-22-5
106-51-4
82-68-8
76578-14-8
Piperonyl butoxide 1.0
Pirimiphos methyl 1.0
[O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-dimethylphosphorothioate]
Fob/chlorinated biphenyls *
(PCBs)
Potassium bromate 0.1
Potassium dimethyldithio- 1.0
carbamate
Potassium N-methyldithio- 1.0
carbamate
Profenofos 1.0
[O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
propyl phosphorothioate]
Prometryn 1.0
[N,N'-Bis(l-methylethyl)-6-methylthio-l,3,5-
triazine-2,4-diamine]
Pronamide 1.0
Propachlor 1.0
[2-Chloro-N-( 1 -methylethyl)-N-
phenylacetamide]
Propane sultone 0.1
Propanil 1.0
[N-(3,4-Dichlorophenyl)propanamide]
Propargite 1.0
Propargyl alcohol 1.0
Propetamphos 1.0
[3 - [(Ethy lamino)methoxyphosphinothioyl]
oxy]-2-butenoic acid, 1-methylethyl ester]
Propiconazole 1.0
[l-[2-(2,4-Dichlorophenyl)-4-propyl-l,3-
dioxolan-2-yl]-methyl-lH-1,2,4,-triazole]
beta-Propiolactone 0.1
Propionaldehyde 1.0
Propoxur 1.0
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
Propylene (Propene) 1.0
Propyleneimine 0.1
Propylene oxide 0.1
Pyridine 1.0
Quinoline 1.0
Quinone 1.0
Quintozene 1.0
(Pentachloronitrobenzene)
Quizalofop-ethyl 1.0
[2-[4-[(6-Chloro-2-
quinoxalinyl)oxy]phenoxy] propanoic acid
ethyl ester]
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
10453-86-8 Resmethrin 1.0
[[5-(Phenylmethyl)-3-furanyl]methyl-2,2-
dimethyl-3 -(2-methyl-1 -propenyl)
cyclopropanecarboxylate]
81-07-2 Saccharin (manufacturing, no 1.0
supplier notification)
94-59-7 Safrole 0.1
7782-49-2 Selenium 1.0
74051-80-2 Sethoxydim 1.0
[2-[ 1-(Ethoxyimino)butyl]-5-[2-
(ethylthio)propyl] -3 -hydroxyl-2-cyclohexen-
1-one]
7440-22-4 Silver 1.0
122-34-9 Simazine 1.0
26628-22-8 Sodium azide 1.0
1982-69-0 Sodium dicamba 1.0
[3,6-Dichloro-2-methoxybenzoic acid,
sodium salt]
128-04-1 Sodium dimethyldithiocarbamate 1.0
62-74-8 Sodium fluoroacetate 1.0
7632-00-0 Sodium nitrite 1.0
131-52-2 Sodium pentachlorophenate 1.0
132-27-4 Sodium o-phenylphenoxide 0.1
100-42-5 Styrene 0.1
96-09-3 Styrene oxide 0.1
[7664-93-9 Sulfuric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
2699-79-8 Sulfuryl fluoride (Vikane) 1.0
35400-43-2 Sulprofos 1.0
[O-Ethyl O-[4-(methylthio)phenyl]
phosphorodithioic acid S-propylester]
34014-18-1 Tebuthiuron 1.0
[N-[5-(l,l-Dimethylethyl)-l,3,4-thiadiazol-
2-yl] -N,N' -dimethylurea]
3383-96-8 Temephos 1.0
5902-51-2 Terbacil 1.0
[5-Chloro-3 -(1,1 -dimethylethyl)-6-methyl-
2,4(lH,3H)-pyrimidinedione]
79-94-7 Tetrabromobisphenol A *
630-20-6 1,1,1,2-Tetrachloroethane 1.0
79-34-5 1,1,2,2-Tetrachloroethane 1.0
127-18-4 Tetrachloroethylene 0.1
(Perchloroethylene)
354-11-0 1,1,1,2-Tetrachloro-2-fluoro ethane 1.0
(HCFC-121a)
354-14-3 1,1,2,2-Tetrachloro-l-fluoro ethane 1.0
(HCFC-121)
CAS Number Chemical Name
De Minimis
Limit
961-11-5
64-75-5
7696-12-0
1.0
7440-28-0
148-79-8
62-55-5
28249-77-6
139-65-1
59669-26-0
23564-06-9
23564-05-8
79-19-6
62-56-6
137-26-8
1314-20-1
7550-45-0
108-88-3
584-84-9
91-08-7
26471-62-5
95-53-4
636-21-5
8001-35-2
43121-43-3
2303-17-5
68-76-8
101200-48-0
1983-10-4
2155-70-6
78-48-8
1.0
1.0
Tetrachlorvinphos
[Phosphoric acid, 2-chloro-l-(2,4,5-
trichlorophenyl) ethenyl dimethyl ester]
Tetracycline hydrochloride
Tetramethrin
[2,2-Dimethyl-3 -(2-methyl-1 -propenyl)
cyclopropanecarboxylic acid (1,3,4,5,6,7-
hexahydro-1,3 -dioxo-2H-isoindol-2-
yl)methyl ester]
Thallium
Thiabendazole
[2-(4-Thiazolyl)- IH-benzimidazole]
Thioacetamide
Thiobencarb
[Carbamic acid, diethylthio-, S-(p-
chlorobenzyl)ester]
4,4'-Thiodianiline
Thiodicarb
Thiophanate ethyl
[[l,2-Phenylenebis(iminocarbonothioyl)]
biscarbamic acid diethylester]
Thiophanate methyl
Thiosemicarbazide
Thiourea
Thiram
Thorium dioxide
Titanium tetrachloride
Toluene
Toluene-2,4-diisocyanate
Toluene-2,6-diisocyanate
Toluene diisocyanate (mixed
isomers)
o-Toluidine
o-Toluidine hydrochloride
Toxaphene
Triadimefon
[l-(4-Chlorophenoxy)-3,3-di-methyl-l-(lH-
1,2,4- triazol-l-yl)-2-butanone]
Triallate 1.0
Triaziquone 1.0
[2,5-Cyclohexadiene-l,4-dione, 2,3,5-tris(l-
aziridinyl)-]
Tribenuron methyl 1.0
[2-[[[[(4-Methoxy-6-methyl-l,3,5- triazin-2-
y l)-methylamino] -carbonyl] amino] sulfony 1]
benzoic acid, methyl ester)
Tributy Itin fluoride 1.0
Tributy Itin methacry late 1.0
S,S,S-Tributyltrithio- 1.0
phosphate (DBF)
1.0
1.0
0.1
1.0
0.1
1.0
1.0
.0
.0
0.1
.0
.0
.0
.0
0.1
0.1
0.1
0.1
0.1
*
1.0
Toxics Release Inventory Reporting Form and Instructions II-1 1
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
52-68-6 Trichlorfon 1.0
[Phosphoric acid,(2,2,2-trichloro-l-hydroxy-
ethyl)-,dirnethyl ester]
76-02-8 Trichloroacetyl chloride 1.0
120-82-1 1,2,4-Trichlorobenzene 1.0
71-55-6 1,1,1-Trichloroethane (Methyl 1.0
chloroform)
79-00-5 1,1,2-Trichloroethane 1.0
79-01-6 Trichloroethylene 0.1
75-69-4 Trichlorofluoromethane(CFC-ll) 1.0
95-95-4 2,4,5-Trichlorophenol 1.0
88-06-2 2,4,6-Trichlorophenol 0.1
96-18-4 1,2,3-Trichloropropane 0.1
57213-69-1 Triclopyr triethylammonium salt 1.0
121-44-8 Triethylamine 1.0
1582-09-8 Trifluralin *
[Benezeneamine, 2,6-dinitro-N,N-dipropyl-
4-(trifluoromethyl)-]
26644-46-2 Triforine 1.0
[N,N'-[l,4-Piperazinediylbis-(2,2,2-
trichloroethylidene)]bisformamide]
95-63-6 1,2,4-Trimethylbenzene 1.0
2655-15-4 2,3,5-Trimethylphenyl 1.0
methylcarbamate
639-58-7 Triphenyltin chloride 1.0
76-87-9 Triphenyltin hydroxide 1.0
126-72-7 Tris(2,3-dibromopropyl) 0.1
phosphate
72-57-1 Trypanblue 0.1
51-79-6 Urethane (Ethyl carbamate) 0.1
7440-62-2 Vanadium (except when contained 1.0
in an alloy)
50471-44-8 Vinclozolin 1.0
[3-(3,5-Dichlorophenyl)-5-ethenyl-5-methyl-
2,4-oxazolidinedione]
108-05-4 Vinyl acetate 0.1
593-60-2 Vinyl bromide 0.1
75-01-4 Vinyl chloride 0.1
75-35-4 Vinylidene chloride 1.0
108-38-3 m-Xylene 1.0
95.47-6 o-Xylene 1.0
106-42-3 p-Xylene 1.0
1330-20-7 Xylene (mixed isomers) 1.0
87-62-7 2,6-Xylidine 0.1
7440-66-6 Zinc (fume or dust) 1.0
1222-67-7 Zineb 1.0
[Carbamodithioic acid, 1,2-ethanediyibis-,
zinc complex]
b. Individually Listed Toxic Chemicals
Arranged by CAS Number
CAS Number Chemical Name
De Minimis
Limit
50-00-0
51-03-6
51-21-8
51-28-5
51-75-2
51-79-6
52-68-6
52-85-7
53-96-3
55-18-5
55-21-0
55-38-9
55-63-0
56-23-5
56-35-9
56-38-2
57-14-7
57-33-0
57-41-0
57-57-8
57-74-9
58-89-9
59-89-2
60-09-3
60-11-7
60-34-4
60-35-5
60-51-5
61-82-5
62-53-3
62-55-5
Formaldehyde 0.1
Piperonyl butoxide 1.0
Fluorouracil (5-Fluorouracil) 1.0
2,4-Dinitrophenol 1.0
Nitrogen mustard 0.1
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
Urethane (Ethyl carbamate) 0.1
Trichlorfon 1.0
[Phosphonic acid, (2,2,2-trichloro-l-
hydroxyethyl) dimethyl ester]
Famphur 1.0
2-Acetylaminofluorene 0.1
N-Nitrosodiethylamine 0.1
Benzamide 1.0
Fenthion 1.0
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester, phosphorothioic
acid]
Nitroglycerin 1.0
Carbon tetrachloride 0.1
Bis(tributyltin) oxide 1.0
Parathion 1.0
[Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl) ester]
1,1 -Dimethy Ihy drazine 0.1
Pentobarbital sodium 1.0
Phenytoin 0.1
beta-Propiolactone 0.1
Chlordane *
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-hexahydro-]
Lindane 0.1
[Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(l.alpha.,2.alpha.,3.beta.,4.alpha,
5.alpha.,6.beta.)-]
N-Nitrosomorpholine 0.1
4-Aminoazobenzene 0.1
4-Dimethylaminoazobenzene 0.1
Methyl hydrazine 1.0
Acetamide 0.1
Dimethoate 1.0
Amitrole 0.1
Aniline 1.0
Thioacetamide 0.1
11-12 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
62-56-6 Thiourea 0.1
62-73-7 Dichlorvos 0.1
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
62-74-8 Sodium fluoroacetate 1.0
62-75-9 N-Nitrosodimethylamine 0.1
63-25-2 Carbaryl 1.0
[1-Naphthalenol, methylcarbamate]
64-18-6 Formic acid 1.0
64-67-5 Diethyl sulfate 0.1
64-75-5 Tetracycline hydrochloride 1.0
67-56-1 Methanol 1.0
67-63-0 Isopropyl alcohol 1.0
(only persons who manufacture by the
strong acid process are subject, no supplier
notification)
67-66-3 Chloroform 0.1
67-72-1 Hexachloroethane 0.1
68-12-2 N,N-Dimethylformamide 1.0
68-76-8 Triaziquone 1.0
[2,5-Cyclohexadiene-l,4-dione, 2,3,5-tris(l-
aziridinyl)-]
70-30-4 Hexachlorophene 1.0
71-36-3 n-Butyl alcohol 1.0
71-43-2 Benzene 0.1
71-55-6 1,1,1-Trichloroethane (Methyl 1.0
chloroform)
72-43-5 Methoxychlor *
[Benzene, 1,1'-(2,2,2-
trichloroethylidene)bis[4-methoxy-]]
72-57-1 Trypanblue 0.1
74-83-9 Bromomethane (Methyl bromide) 1.0
74-85-1 Ethylene 1.0
74-87-3 Chloromethane (Methyl chloride) 1.0
74-88-4 Methyl iodide 1.0
74-90-8 Hydrogen cyanide 1.0
74-95-3 Methylene bromide 1.0
75-00-3 Chloroethane (Ethyl chloride) 1.0
75-01-4 Vinyl chloride 0.1
75-05-8 Acetonitrile 1.0
75-07-0 Acetaldehyde 0.1
75-09-2 Dichloromethane (Methylene 0.1
chloride)
75-15-0 Carbon disulfide 1.0
75-21-8 Ethylene oxide 0.1
75-25-2 Bromoform (Tribromomethane) 1.0
75-27-4 Dichlorobromomethane 0.1
75-34-3 Ethylidene dichloride 1.0
75-35-4 Vinylidene chloride 1.0
75-43-4 Dichlorofluoromethane 1.0
(HCFC-21)
CAS Number Chemical Name
De Minimis
Limit
75-44-5 Phosgene
75-45-6 Chlorodifluoromethane
(HCFC-22)
75-55-8 Propyleneimine
75-56-9 Propylene oxide
75-63-8 Bromotrifluoromethane
(Halon 1301)
75-65-0 tert-Butyl alcohol
75-68-3 l-Chloro-l,l-difluoroethane
(HCFC-142b)
75-69-4 Trichlorofluoromethane (CFC-11)
75-71-8 Dichlorodifluoromethane
(CFC-12)
75-72-9 Chlorotrifluoromethane (CFC-13)
75-86-5 2-Methyllactonitrile
75-88-7 2-Chloro-l,l,l-trifluoroethane
(HCFC-133a)
76-01-7 Pentachloroethane
76-02-8 Trichloroacetyl chloride
76-06-2 Chloropicrin
76-13-1 FreonllS
[Ethane, 1,1,2-trichloro-1,2,2,-trifluoro-]
76-14-2 Dichlorotetrafluoroethane 1.0
(CFC-114)
76-15-3 Monochloropentafluoroethane 1.0
(CFC-115)
76-44-8 Heptachlor *
[l,4,5,6,7,8,8-Heptachloro-3a,4,7,7a-
tetrahydro-4,7-methano- IH-indene]
76-87-9 Triphenyltin hydroxide 1.0
77-47-4 Hexachlorocyclopentadiene 1.0
77-73-6 Dicyclopentadiene 1.0
77-78-1 Dimethyl sulfate 0.1
78-48-8 S,S,S-Tributyltrithiophosphate 1.0
(DBF)
78-84-2 Isobutyraldehyde 1.0
78-87-5 1,2-Dichloropropane 1.0
78-88-6 2,3-Dichloropropene 1.0
78-92-2 sec-Butyl alcohol 1.0
78-93-3 Methyl ethyl ketone 1.0
79-00-5 1,1,2-Trichloroethane 1.0
79-01-6 Trichloroethylene 0.1
79-06-1 Acrylamide 0.1
79-10-7 Aery lie acid 1.0
79-11-8 Chloroacetic acid 1.0
79-19-6 Thiosemicarbazide 1.0
79-21-0 Peracetic acid 1.0
79-22-1 Methyl chlorocarbonate 1.0
79-34-5 1,1,2,2-Tetrachloroethane 1.0
79-44-7 Dimethylcarbamyl chloride 0.1
79-46-9 2-Nitropropane 0.1
Toxics Release Inventory Reporting Form and Instructions 11-13
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
CAS Number Chemical Name
De Minimis
Limit
79-94-7 Tetrabromobisphenol A
80-05-7 4,4'-Isopropylidenediphenol
80-15-9 Cumene hydroperoxide
80-62-6 Methyl methacrylate
81-07-2 Saccharin (manufacturing, no
supplier notification)
81-88-9 C.I. Food Red 15
82-28-0 1 -Amino-2-methylanthraquinone
82-68-8 Quintozene
[Pentachloronitrobenzene]
84-74-2 Dibutyl phthalate
85-01-8 Phenanthrene
85-44-9 Phthalic anhydride
86-30-6 N-Nitrosodiphenylamine
87-62-7 2,6-Xylidine
87-68-3 Hexachloro-l,3-butadiene
87-86-5 Pentachlorophenol (PCP)
88-06-2 2,4,6-Trichlorophenol
88-75-5 2-Nitrophenol
88-85-7 Dinitrobutyl phenol (Dinoseb)
88-89-1 Picric acid
90-04-0 o-Anisidine
90-43-7 2-Phenylphenol
90-94-8 Michler'sketone
91-08-7 Toluene-2,6-diisocyanate
91-20-3 Naphthalene
91-22-5 Quinoline
91-59-8 beta-Naphthylamine
91-94-1 3,3'-Dichlorobenzidine
92-52-4 Biphenyl
92-67-1 4-Aminobiphenyl
92-87-5 Benzidine
92-93-3 4-Nitrobiphenyl
93-65-2 Mecoprop
94-11-1 2,4-D isopropyl ester
94-36-0 Benzoyl peroxide
94-58-6 Dihydrosafrole
94-59.7 Safrole
94-74-6 Methoxone
((4-Chloro-2-methylphenoxy) acetic acid)
(MCPA)
94-75-7 2,4-D [Acetic acid, (2,4- 0.1
dichlorophenoxy)-]
94-80-4 2,4-D butyl ester 0.1
94-82-6 2,4-DB 1.0
95.47-6 o-Xylene 1.0
95-48-7 o-Cresol 1.0
95-50-1 1,2-Dichlorobenzene 1.0
95-53-4 o-Toluidine 0.1
95-54-5 1,2-Phenylenediamine 1.0
95-63-6 1,2,4-Trimethylbenzene 1.0
*
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
1.0
0.
0.
1.0
0.
0.
0.
0.
0.1
1.0
0.1
0.1
0.1
95-69-2
95-80-7
95-95-4
96-09-3
96-12-8
96-18-4
96-33-3
96-45-7
97-23-4
97-56-3
98-07-7
98-82-8
98-86-2
98-87-3
98-88-4
98-95-3
99-30-9
99-55-8
99-59-2
99-65-0
100-01-6
100-02-7
100-25-4
100-41-4
100-42-5
100-44-7
100-75-4
101-05-3
101-14-4
101-61-1
101-77-9
101-80-4
101-90-6
104-12-1
104-94-9
105-67-9
106-42-3
106-44-5
106-46-7
106-47-8
106-50-3
106-51-4
p-Chloro-o-toluidine
2,4-Diaminotoluene
2,4,5-Trichlorophenol
Styrene oxide
1,2-Dibromo-3 -chloropropane
(DBCP)
1,2,3 -Trichloropropane
Methyl acrylate
Ethylene thiourea
Dichlorophene
[2,2'-Methylenebis(4-chlorophenol)]
C.I. Solvent Yellow 3
Benzoic trichloride
(Benzotrichloride)
Cumene
Acetophenone
Benzal chloride
Benzoyl chloride
Nitrobenzene
Dichloran [2,6-Dichloro-4-
nitroaniline]
5-Nitro-o-toluidine
5 -Nitro -o -anisidine
m-Dinitrobenzene
p-Nitroaniline
4-Nitrophenol
p-Dinitrobenzene
Ethylbenzene
Styrene
Benzyl chloride
N-Nitrosopiperidine
Anilazine
[4,6-Dichloro-N-(2-chlorophenyl)-l,3;
triazin-2-amine]
4,4'-Methylenebis(2-chloroaniline)
(MBOCA)
4,4'-Methylenebis(N,N-
dimethyl)benzenamine
4,4'-Methylenedianiline
4,4'-Diaminodiphenyl ether
Diglycidyl resorcinol ether
p-Chlorophenyl isocyanate
p-Anisidine
2,4-Dimethylphenol
p-Xylene
p-Cresol
1,4-Dichlorobenzene
p-Chloroaniline
p-Phenylenediamine
Quinone
5-
0.1
0.1
1.0
0.1
0.1
0.1
1.0
0.1
1.0
0.1
0.1
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
0.1
1.0
0.1
1.0
0.1
0.1
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
11-14 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
CAS Number Chemical Name
De Minimis
Limit
106-88-7 1,2-Butylene oxide
106-89-8 Epichlorohydrin
106-93-4 1,2-Dibromoethane
(Ethylene dibromide)
106-99-0 1,3-Butadiene
107-02-8 Acrolein
107-05-1 Allyl chloride
107-06-2 1,2-Dichloroethane (Ethylene
dichloride)
107-11-9 Allylamine
107-13-1 Acrylonitrile
107-18-6 Allyl alcohol
107-19-7 Propargyl alcohol
107-21-1 Ethylene glycol
107-30-2 Chloromethyl methyl ether
108-05-4 Vinyl acetate
108-10-1 Methyl isobutyl ketone
108-31-6 Maleic anhydride
108-38-3 m-Xylene
108-39-4 m-Cresol
108-45-2 1,3-Phenylenediamine
108-60-1 Bis(2-chloro-l-methylethyl) ether
108-88-3 Toluene
108-90-7 Chlorobenzene
108-93-0 Cyclohexanol
108-95-2 Phenol
109-06-8 2-Methylpyridine
109-77-3 Malononitrile
109-86-4 2-Methoxyethanol
110-54-3 n-Hexane
110-57-6 trans-l,4-Dichloro-2-butene
110-80-5 2-Ethoxyethanol
110-82-7 Cyclohexane
110-86-1 Pyridine
111-42-2 Diethanolamine
111-44-4 Bis(2-chloroethyl) ether
111-91-1 Bis(2-chloroethoxy) methane
114-26-1 Propoxur
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
115-07-1 Propylene (Propene)
115-28-6 Chlorendic acid
115-32-2 Dicofol
[Benzenemethanol, 4-chloro-.alpha. -4-
(chlorophenyl)-.alpha.-(trichloromethyl)-]
116-06-3 Aldicarb
117-79-3 2-Aminoanthraquinone
117-81-7 Di(2-ethylhexyl) phthalate
118-74-1 Hexachlorobenzene
119-90-4 3,3 '-Dimethoxybenzidine
1.0
0.1
0.1
*
0.1
134-29-2
134-32-7
135-20-6
136-45-8
3,3'-Dimethylbenzidine 0.1
(o-Tolidine)
Anthracene 1.0
2,4-DP 0.1
Isosafrole 1.0
p-Cresidine 0.1
Catechol 0.1
1,2,4-Trichlorobenzene .0
2,4-Dichlorophenol .0
2,4-Dinitrotoluene 0.1
Triethylamine .0
N,N-Dimethylaniline .0
Malathion .0
Simazine .0
Diphenylamine .0
1,2-Diphenylhydrazine 0.1
(Hydrazobenzene)
Hydroquinone 1.0
Propionaldehyde 1.0
Paraldehyde 1.0
Butyraldehyde 1.0
1,4-Dioxane 0.1
Dimethylamine 1.0
Dibromotetrafluoroethane 1.0
(Halon 2402)
Tris(2,3-dibromopropyl) 0.1
phosphate
Methacrylonitrile 1.0
Chloroprene 0.1
Tetrachloroethylene 0.1
(Perchloroethylene)
Potassium 1.0
dimethyldithiocarbamate
Sodium dimethyldithiocarbamate .0
C.I. Vat Yellow 4 .0
Dimethyl phthalate .0
Sodium pentachlorophenate .0
Sodium o-phenylphenoxide 0.1
Dibenzofuran
Captan
[ IH-Isoindole-1,3 (2H)-dione, 3a,4,7,7a-
tetrahydro-2-[(trichloromethyl)thio]-]
Folpet 1.0
Chloramben 1.0
[Benzoic acid, 3-amino-2,5-dichloro-]
o-Anisidine hydrochloride 0.1
alpha-Naphthylamine 0.1
Cupferron 0.1
[Benzeneamine, N-hydroxy-N-nitroso,
ammonium salt]
Dipropyl isocinchomeronate 1.0
0.1
0.1
0.1
0.1
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
119-93-7
120-12-7
120-36-5
120-58-1
120-71-8
120-80-9
120-82-1
120-83-2
121-14-2
121-44-8
121-69-7
121-75-5
122-34-9
122-39-4
122-66-7
123-31-9
123-38-6
123-63-7
123-72-8
123-91-1
124-40-3
124-73-2
126-72-7
126-98-7
126-99-8
127-18-4
128-03-0
128-04-1
128-66-5
131-11-3
131-52-2
132-27-4
132-64-9
133-06-2
133-07-3
133-90-4
Toxics Release Inventory Reporting Form and Instructions 11-15
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
137-26-8 Thiram 1.0
137-41-7 Potassium N-methyldithio- 1.0
carbamate
137-42-8 Metham sodium (Sodium 1.0
methyldithiocarbamate)
138-93-2 Disodium cyanodithioimido- 1.0
carbonate
139-13-9 Nitrilotriacetic acid 0.1
139-65-1 4,4'-Thiodianiline 0.1
140-88-5 Ethyl acrylate 0.1
141-32-2 Butyl acrylate 1.0
142-59-6 Nabam 1.0
148-79-8 Thiabendazole 1.0
[2-(4-Thiazolyl)-lH-benzimidazole]
149-30-4 2-Mercaptobenzothiazole 1.0
(MET)
150-50-5 Merphos 1.0
150-68-5 Monuron 1.0
151-56-4 Ethyleneimine (Aziridine) 0.1
156-10-5 p-Nitrosodiphenylamine 1.0
156-62-7 Calcium cyanamide 1.0
191-24-2 Benzo(g,h,i)perylene *
298-00-0 Methyl parathion 1.0
300-76-5 Naled 1.0
301-12-2 Oxydemeton methyl 1.0
[S-(2-(Ethylsuffinyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
302-01-2 Hydrazine 0.1
306-83-2 2,2-Dichloro-l,l,l-trifluoroethane 1.0
(HCFC-123)
309-00-2 Aldrin *
[1,4:5,8-Dimethanonaphthalene,
1,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a-
hexahydro-(l.alpha.,4.alpha.,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
314-40-9 Bromacil 1.0
(5-Bromo-6-methyl-3-(l-methylpropyl)-
2,4(lH,3H)-pyrimidinedione)
319-84-6 alpha-Hexachlorocyclohexane 0.1
330-54-1 Diuron 1.0
330-55-2 Linuron 1.0
333-41-5 Diazinon 1.0
334-88-3 Diazomethane 1.0
353-59-3 Bromochlorodifluoromethane 1.0
(Halonl211)
354-11-0 1,1,1,2-Tetrachloro-2-fluoroethane 1.0
(HCFC-121a)
354-14-3 1,1,2,2-Tetrachloro-l-fluoroethane 1.0
(HCFC-121)
354-23-4 l,2-Dichloro-l,l,2- 1.0
trifluoroethane (HCFC-123a)
CAS Number Chemical Name
De Minimis
Limit
354-25-6
357-57-3
422-44-6
422-48-0
422-56-0
431-86-7
460-35-5
463-58-1
465-73-6
492-80-8
505-60-2
507-55-1
510-15-6
528-29-0
532-27-4
533-74-4
534-52-1
540-59-0
541-41-3
541-53-7
541-73-1
542-75-6
542-76-7
542-88-1
554-13-2
556-61-6
563-47-3
569-64-2
584-84-9
593-60-2
594-42-3
606-20-2
608-93-5
612-82-8
612-83-9
l-Chloro-1,1,2,2- 1.0
tetrafluoroethane (HCFC-124a)
Brucine 1.0
1,2-Dichloro-l,1,2,3,3- 1.0
pentafluoropropane (HCFC-225bb)
2,3-Dichloro-l,1,1,2,3- 1.0
pentafluoropropane (HCFC-225ba)
3,3-Dichloro-l,1,1,2,2- 1.0
pentafluoropropane (HCFC-225ca)
1,2-Dichloro-l,1,3,3,3- 1.0
pentafluoropropane (HCFC-225da)
3-Chloro-l,l,l-trifluoropropane 1.0
(HCFC-253fb)
Carbonyl sulfide 1.0
Isodrin *
C.I. Solvent Yellow 34 0.1
(Auramine)
Mustard gas 0.1
[Ethane, l,l'-thiobis[2-chloro-]]
1,3-Dichloro-l, 1,2,2,3- 1.0
pentafluoropropane (HCFC-225cb)
Chlorobenzilate 1.0
[Benzeneacetic acid, 4-chloro-.alpha.-(4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
o-Dinitrobenzene 1.0
2-Chloroacetophenone 1.0
Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione)
4,6-Dinitro-o-cresol 1.0
1,2-Dichloroethylene 1.0
Ethyl chloroformate 1.0
2,4-Dithiobiuret 1.0
1,3-Dichlorobenzene 1.0
1,3 -Dichloropropy lene 0.1
3-Chloropropionitrile 1.0
Bis(chloromethyl) ether 0.1
Lithium carbonate 1.0
Methyl isothiocyanate 1.0
[Isothiocyanatomethane]
3-Chloro-2-methyl-l-propene 0.1
C.I. Basic Green 4 1.0
Toluene-2,4-diisocyanate 0.1
Vinyl bromide 0.1
Perchloro methyl mercaptan 1.0
2,6-Dinitrotoluene 0.1
Pentachlorobenzene *
3,3'-Dimethylbenzidine 0.1
dihydrochloride (o-Tolidine dihydrochloride)
3,3'-Dichlorobenzidine 0.1
dihydrochloride
11-16 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
De Minimis
CAS Number Chemical Name Limit
615-05-4
615-28-1
621-64-7
624-18-0
624-83-9
630-20-6
636-21-5
639-58-7
680-31-9
684-93-5
709-98-8
759-73-9
759-94-4
764-41-0
812-04-4
834-12-8
2,4-Diaminoanisole
1 ,2-Phenylenediamine
dihydrochloride
N-Nitrosodi-n-propylamine
1 ,4-Phenylenediamine
dihydrochloride
Methyl isocyanate
1,1, 1 ,2-Tetrachloroethane
o-Toluidine hydrochloride
Triphenyltin chloride
Hexamethylphosphoramide
N-Nitroso-N-methylurea
Propanil (N-(3,4-Dichlorophenyl)
propanamide)
N-Nitroso-N-ethylurea
Ethyl dipropylthiocarbamate
(EPTC)
1 ,4-Dichloro-2-butene
1 , 1 -Dichloro- 1 ,2,2-trifluoroethane
(HCFC-123b)
Ametryn
0.1
1.0
0.1
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
0.1
1.0
1.0
1.0
1.0
(N-Ethyl-N'-(l-methylethyl)-6-(methylthio)-
842-07-9
872-50-4
924-16-3
924-42-5
957-51-7
961-11-5
989-38-8
1114-71-2
1120-71-4
1134-23-2
1163-19-5
1313-27-5
1314-20-1
1319-77-3
1320-18-9
1330-20-7
1332-21-4
1335-87-1
1336-36-3
1344-28-1
1464-53-5
1563-66-2
1,3,5, -triazine-2,4-diamine)
C.I. Solvent Yellow 14
N-Methyl-2-pyrrolidone
N-Nitrosodi-n-butylamine
N-Methylolacrylamide
Diphenamid
Tetrachlorvinphos
[Phosphoric acid, 2-chloro-l-(2,4,5-
trichlorophenyl)ethenyldimethyl ester]
C.I. Basic Red 1
Pebulate
[Butylethylcarbamothioic acid S-propyl
ester]
Propane sultone
Cycloate
Decabromodiphenyl oxide
Molybdenum trioxide
Thorium dioxide
Cresol (mixed isomers)
2,4-D propylene glycol butyl
ether ester
Xylene (mixed isomers)
Asbestos (friable)
Hexachloronaphthalene
Polychlorinated biphenyls (PCBs)
Aluminum oxide (fibrous forms)
Diepoxybutane
Carbofuran
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
*
1.0
0.1
1.0
CAS Number Chemical Name
De Minimis
Limit
1582-09-8 Trifluralin *
[Benezeneamine, 2,6-dinitro-N,N-dipropyl-4-
(trifluoromethyl)-]
1634-04-4 Methyl tert-butyl ether 1.0
1649-08-7 l,2-Dichloro-l,l-difluoroethane 1.0
(HCFC-132b)
1689-84-5 Bromoxynil 1.0
(3,5-Dibromo-4-hydroxybenzonitrile)
1689-99-2 Bromoxynil octanoate 1.0
(Octanoic acid, 2,6-dibromo-4-cyanophenyl
ester)
1717-00-6 1,1-Dichloro-l-fluoroethane 1.0
(HCFC-141b)
1836-75-5 Nitrofen 0.1
[Benzene, 2,4-dichloro-1 -(4-nitrophenoxy)-]
1861-40-1 Benfluralin 1.0
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)benzenamine)
1897-45-6 Chlorothalonil 0.1
[1,3-Benzenedicarbonitrile, 2,4,5,6-
tetrachloro-]
1910-42-5 Paraquat dichloride 1.0
1912-24-9 Atrazine 1.0
(6-Chloro-N-ethyl-N' -(1 -methylethyl)-1,3,5-
triazine-2,4-diamine)
1918-00-9 Dicamba 1.0
(3,6-Dichloro-2-methoxybenzoic acid)
1918-02-1 Picloram 1.0
1918-16-7 Propachlor 1.0
[2-Chloro-N-( 1 -methylethyl)-N-
phenylacetamide]
1928-43-4 2,4-D 2-ethylhexyl ester 0.1
1929-73-3 2,4-D butoxyethyl ester 0.1
1929-82-4 Nitrapyrin 1.0
(2-Chloro-6-(trichloromethyl)pyridine)
1937-37-7 C.I. Direct Black 38 0.1
1982-69-0 Sodium dicamba 1.0
[3,6-Dichloro-2-methoxybenzoic acid,
sodium salt]
1983-10-4 Tributyltin fluoride 1.0
2032-65-7 Methiocarb 1.0
2155-70-6 Tributyltin methacrylate 1.0
2164-07-0 Dipotassium endothall 1.0
[7-Oxabicyclo(2.2.1)heptane-2,3-dicarboxylic
acid, dipotassium salt]
2164-17-2 Fluometuron 1.0
[Urea, N,N-dimethyl-N'-[3-
(trifluoromethyl)pheny 1] -]
2212-67-1 Molinate 1.0
(lH-Azepine-1-carbothioic acid, hexahydro-
S-ethyl ester)
Toxics Release Inventory Reporting Form and Instructions 11-17
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
2234-13-1 Octachloronaphthalene 1.0
2300-66-5 Dimethylamine dicamba 1.0
2303-16-4 Diallate 1.0
[Carbamothioic acid, bis(l-methylethyl)-S-
(2,3-dichloro-2-propenyl) ester]
2303-17-5 Triallate 1.0
2312-35-8 Propargite 1.0
2439-01-2 Chinomethionat 1.0
[6-Methyl-1,3 -dithiolo [4,5-b]quinoxalin-2-
one]
2439-10-3 Dodine 1.0
[Dodecylguanidine monoacetate]
2524-03-0 Dimethyl chlorothiophosphate 1.0
2602-46-2 C.I. Direct Blue 6 0.1
2655-15-4 2,3,5-Trimethyrphenyl methyl 1.0
carbamate
2699-79-8 Sulfuryl fluoride (Vikane) 1.0
2702-72-9 2,4-D sodium salt 0.1
2832-40-8 C.I. Disperse Yellow 3 1.0
2837-89-0 2-Chloro-l,U,2- 1.0
tetrafluoroethane (HCFC-124)
2971-38-2 2,4-D Chlorocrotyl ester 0.1
3118-97-6 C.I. Solvent Orange 7 1.0
3383-96-8 Temephos 1.0
3653-48-3 Methoxone sodium salt 0.1
((4-Chloro-2-methylphenoxy) acetate
sodium salt)
3761-53-3 C.I. Food Red 5 0.1
4080-31-3 l-(3-Chloroallyl)-3,5,7-triaza-l- 1.0
azoniaadamantane chloride
4170-30-3 Crotonaldehyde 1.0
4549-40-0 N-Nitrosomethylvinylamine 0.1
4680-78-8 C.I. Acid Green 3 1.0
5234-68-4 Carboxin 1.0
(5,6-Dihydro-2-methyl-N-phenyl-l,4-
oxathiin-3 -carboxamide)
5598-13-0 Chlorpyrifos methyl 1.0
[O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate]
5902-51-2 Terbacil 1.0
[5-Chloro-3 -(1,1 -dimethylethyl)-6-methyl-
2,4(lH,3H)-pyrimidinedione]
6459-94-5 C.I. Acid Red 114 0.1
7287-19-6 Prometryn 1.0
[N,N' -Bis( 1 -methylethyl)-6-methylthio-
1,3,5-triazine-2,4-diamine]
7429-90-5 Aluminum (fume or dust) 1.0
7439-92-1 Lead *
(when lead is contained in stainless steel,
brass or bronze alloys the de minimis level is
0.1)
7439-96-5 Manganese 1.0
7439-97-6 Mercury *
CAS Number Chemical Name
De Minimis
Limit
7440-02-0
7440-22-4
7440-28-0
7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-47-3
7440-48-4
7440-50-8
7440-62-2
7440-66-6
7550-45-0
7632-00-0
7637-07-2
7647-01-0
7664-39-3
7664-41-7
7664-93-9
7696-12-0
7697-37-2
7723-14-0
7726-95-6
7758-01-2
7782-41-4
7782-49-2
7782-50-5
7786-34-7
7803-51-2
8001-35-2
8001-58-9
9006-42-2
10028-15-6
10034-93-2
10049-04-4
Nickel 0.1
Silver 1.0
Thallium 1.0
Antimony 1.0
Arsenic 0.1
Barium 1.0
Beryllium 0.1
Cadmium 0.1
Chromium 1.0
Cobalt 0.1
Copper .0
Vanadium (except when contained .0
in an alloy)
Zinc (fume or dust) .0
Titanium tetrachloride .0
Sodium nitrite .0
Boron trifluoride .0
Hydrochloric acid .0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
Hydrogen fluoride 1.0
Ammonia 1.0
(includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium
salts and other sources; 10 percent of total
aqueous ammonia is reportable under this
listing)
Sulfuric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
Tetramethrin 1.0
[2,2-Dimethyl-3 -(2-methyl-1 -
propenyl)cyclopropanecarboxylic acid
(l,3,4,5,6,7-hexahydro-l,3-dioxo-2H-
isoindol-2-yl)methyl ester]
Nitric acid .0
Phosphorus (yellow or white) .0
Bromine .0
Potassium bromate 0.1
Fluorine
Selenium
Chlorine
Mevinphos
Phosphine
Toxaphene *
Creosote 0.1
Metiram 1.0
Ozone 1.0
Hydrazine sulfate 0.1
Chlorine dioxide 1.0
11-18 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
10061-02-6 trans-l,3-Dichloropropene 0.1
10294-34-5 Boron trichloride 1.0
10453-86-8 Resmethrin 1.0
[[5-(Phenylmethyl)-3-furanyl]methyl-
2,2-dimethyl-3 -(2-methyl-1 -propenyl)
cy clopropanecarboxylate] ]
12122-67-7 Zineb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
zinc complex]
12427-38-2 Maneb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
manganese complex]
13194-48-4 Ethoprop 1.0
[Phosphorodithioic acid O-ethyl S,S-
dipropyl ester]
13356-08-6 Fenbutatin oxide 1.0
(Hexakis(2-methyl-2-phenylpropyl)
distannoxane)
13463-40-6 Iron pentacarbonyl 1.0
13474-88-9 l,l-Dichloro-l,2,2,3,3- 1.0
pentafluoropropane (HCFC-225cc)
13684-56-5 Desmedipham 1.0
14484-64-1 Ferbam 1.0
[Tris(dimethylcarbamodithioato-S, S ')iron]
15972-60-8 Alachlor 1.0
16071-86-6 C.I. Direct Brown 95 0.1
16543-55-8 N-Nitrosonornicotine 0.1
17804-35-2 Benomyl 1.0
19044-88-3 Oryzalin 1.0
[4-(Dipropylamino)-3,5-
dinitrobenzenesulfonamide]
19666-30-9 Oxydiazon 1.0
[3-[2,4-Dichloro-5-(l-methylethoxy)
phenyl] -5-( 1,1 -dimethylethyl)-1,3,4-
oxadiazol-2(3H)-one]
20325-40-0 3,3'-Dimethoxybenzidine 0.1
dihydrochloride (o-Dianisidine
dihydrochloride)
20354-26-1 Methazole 1.0
[2-(3,4-Dichlorophenyl)-4-methyl- 1,2,4-
oxadiazolidine-3,5-dione]
20816-12-0 Osmium tetroxide 1.0
20859-73-8 Aluminum phosphide 1.0
21087-64-9 Metribuzin 1.0
21725-46-2 Cyanazine 1.0
22781-23-3 Bendiocarb 1.0
[2,2-Dimethyl-l,3-benzodioxol-4-
olmethylcarbamate]
23564-05-8 Thiophanate methyl 1.0
CAS Number Chemical Name
De Minimis
Limit
23564-06-9
23950-58-5
25311-71-1
25321-14-6
25321-22-6
25376-45-8
26002-80-2
26471-62-5
26628-22-8
26644-46-2
27314-13-2
28057-48-9
28249-77-6
28407-37-6
29082-74-4
29232-93-7
30560-19-1
31218-83-4
33089-61-1
34014-18-1
34077-87-7
35367-38-5
Thiophanate ethyl 1.0
[[l,2-Phenylenebis(iminocarbonothioyl)]
biscarbamic acid diethyl ester]
Pronamide 1.0
Isofenphos 1.0
[2-[[Ethoxyl[(l-methylethyl)-
amino]phosphinothioyl]oxy]benzoic acid 1-
methylethyl ester]
Dinitrotoluene (mixed isomers) 1.0
Dichlorobenzene (mixed isomers) 0.1
Diaminotoluene (mixed isomers) 0.1
Phenothrin 1.0
[2,2-Dimethyl-3 -(2-methyl-1 -
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester]
Toluene diisocyanate 0.1
(mixed isomers)
Sodium azide 1.0
Triforine 1.0
[N,N'-[ 1,4-Piperazinediylbis (2,2,2-
trichloroethylidene)]bisformamide]
Norflurazon 1.0
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)pheny 1] -3 (2H)-py ridazinone]
d-trans - Allethrin 1.0
[d-trans-Chrysanthemic acid of d-allethrone]
Thiobencarb 1.0
[Carbamic acid, diethylthio-, S-(p-
chlorobenzyl)ester]
C.I. Direct Blue 218
Octachlorostyrene
Pirimiphos methyl
[O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-dimethylphosphorothioate]
Acephate 1.0
(Acetylphosphoramidothioic acid O,S-
dimethyl ester)
Propetamphos 1.0
[3-[(Ethylamino)
methoxyphosphinothioyl]oxy]-2-butenoic
acid, 1-methylethyl ester]
Amitraz 1.0
Tebuthiuron 1.0
[N-[5-(l,l-Dimethylethyl)-l,3,4-thiadiazol-2-
y 1] -N,N' -dimethy lurea]
Dichlorotrifluoroethane 1.0
Diflubenzuron 1.0
1.0
*
1.0
Toxics Release Inventory Reporting Form and Instructions 11-19
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
35400-43-2
35554-44-0
35691-65-7
38727-55-8
39156-41-7
39300-45-3
39515-41-8
40487-42-1
41198-08-7
41766-75-0
42874-03-3
43121-43-3
50471-44-8
51235-04-2
51338-27-3
51630-58-1
52645-53-1
53404-19-6
53404-37-8
53404-60-7
55290-64-7
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
Sulprofos
[O-Ethyl O-[4-(methylthio)phenyl]-
phosphorodithioic acid S-propyl ester]
Imazalil
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl]-lH-imidazole]
1 -Bromo-1 -(bromomethy 1)-1,3 -
propanedicarbonitrile
Diethatyl ethyl
2,4-Diaminoanisole sulfate
Dinocap
Fenpropathrin
[2,2,3,3 -Tetramethylcyclopropane
carboxylic acid cyano(3-
phenoxyphenyl)methyl ester]
Pendimethalin
[N-(l-Ethyrpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine]
Profenofos
[O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
propyl-phosphorothioate]
3,3'-Dimethylbenzidine 0.1
dihydrofluoride (o-Tolidinedihydrofluoride)
Oxyfluorfen 1.0
Triadimefon 1.0
[ 1 -(4-Chlorophenoxy)-3,3-dimethyl-1 -(1H-
1,2,4-triazol- l-yl)-2-butanone]
Vinclozolin 1.0
[3-(3,5-Dichlorophenyl)-5-ethenyl-5-methyl-
2,4-oxazolidinedione]
Hexazinone
Diclofop methyl
[2-[4-(2,4-Dichlorophenoxy)-
phenoxy]propanoic acid, methyl ester]
Fenvalerate
[4-Chloro-alpha-( 1 -methylethyl)-
benzeneacetic acid cyano(3-
phenoxyphenyl)methyl ester]
Permethrin
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropane carboxylic acid,
(3-phenoxyphenyl)methyl ester]
Bromacil, lithium salt
[2,4(lH,3H)-Pyrimidinedione, 5-bromo-6-
methyl-3-(l-methylpropyl), lithium salt]
2,4-D 2-ethyl-4-methylpentyl 0.1
ester
Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-1,3,5-
thiadiazine-2-thione, ion(l-), sodium]
Dimethipin 1.0
[2,3 -Dihydro-5,6-dimethyl-1,4-dithiin
1,1,4,4-tetraoxide]
1.0
1.0
1.0
1.0
1.0
CAS Number Chemical Name
De Minimis
Limit
55406-53-6
57213-69-1
59669-26-0
60168-88-9
60207-90-1
62476-59-9
63938-10-3
64902-72-3
64969-34-2
66441-23-4
67485-29-4
68085-85-8
68359-37-5
69409-94-5
69806-50-4
71751-41-2
72178-02-0
72490-01-8
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
3-Iodo-2-propynyl butyl
carbamate
Triclopyr triethylammonium salt
Thiodicarb
Fenarimol
[.alpha.-(2-Chlorophenyl)-.alpha.-4-
chlorophenyl)-5-pyrimidinemethanol]
Propiconazole
[l-[2-(2,4-Dichlorophenyl)-4-propyl-
1,3 -dioxolan-2-yl] -methyl- 1H- 1,2,4,-triazole]
Acifluorfen, sodium salt 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-2-
nitrobenzoic acid, sodium salt]
Chlorotetrafluoroethane
Chlorsulfuron
[2-Chloro-N-[[(4-methoxy-6-methyl-
l,3,5-triazin-2-yl)amino] carbonyl]
benzenesulfonamide]
3,3'-Dichlorobenzidine sulfate
Fenoxaprop ethyl
[2-(4-((6-Chloro-2-
benzoxazolylen)oxy)phenoxy)propanoic acid,
ethyl ester]
Hydramethylnon 1.0
[Tetrahydro-5,5-dimethyl-2(lH)-
py rimidinone [3 - [4-(trifluoromethy 1) phenyl] -
l-[2-[4-(trifluoromethyl)phenyl]ethenyl]-2-
propenylidene] hydrazone]
Cyhalothrin 1.0
[3 -(2-Chloro-3,3,3 -trifluoro-1 -propenyl)-2,2-
dimethylcyclo-propanecarboxylic acid
cyano(3-phenoxyphenyl) methyl ester]
Cyfluthrin
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid,
cyano(4-fluoro-3 -phenoxyphenyl) methyl
ester]
Fluvalinate
[N-[2-Chloro-4-(trifluoromethyl)-
phenyl]DL-valine(+)-cyano(3 -
phenoxyphenyl)methyl ester]
Fluazifop butyl
[2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]phenoxy]propanoic acid, butyl
ester]
Abamectin [Avermectin B1 ] 1.0
Fomesafen 1.0
[5-(2-Chloro-4-(trifluoromethyl)-phenoxy)-
N-methylsulfonyl)-2-riitroberizamide]
Fenoxycarb 1.0
[[2-(4-Phenoxy phenoxy)ethyl-] carbamic
acid ethyl ester]
1.0
1.0
1.0
11-20 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
74051-80-2 Sethoxydim 1.0
[2-[ 1 -(Ethoxyimino)butyl] -5-[2-
(ethylthio)propyl] -3 -hydroxyl-2-cyclohexen-
1-one]
76578-14-8 Quizalofop-ethyl 1.0
[2-[4-[(6-Chloro-2-quinoxalinyl)
oxy]phenoxy]propanoic acid ethyl ester]
77501-63-4 Lactofen 1.0
[Benzole acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy]-2-nitro-, 2-
ethoxy-l-methyl-2-oxoethyl ester]
82657-04-3 Bifenthrin 1.0
88671-89-0 Myclobutanil 1.0
[.alpha. -Butyl-.arpha.-(4-chlorophenyl)-lH-
1,2,4-triazole-1 -propanenitrile]
90454-18-5 Dichloro-l,l,2-trifluoroethane 1.0
90982-32-4 Chlorimuron ethyl 1.0
[Ethyl-2-[[[[(4-chloro-6-methoxyprimidin-2-
y l)amino] carbony 1] -
amino] sulfony l]benzoate]
101200-48-0 Tribenuron methyl 1.0
[2-[[[[(4-Methoxy-6-methyl-l,3,5-triazin-2-
y l)methylamino] carbony 1]
amino] sulfonyl]benzoic acid, methyl ester]
111512-56-2 l,l-Dichloro-l,2,3,3,3- 1.0
pentafluoropropane (HCFC-225eb)
111984-09-9 3,3'-Dimethoxybenzidine 0.1
hydrochloride (o-Dianisidine hydrochloride)
127564-92-5 Dichloropentafluoropropane 1.0
128903-21-9 2,2-Dichloro-l, 1,1,3,3- 1.0
pentafluoropropane (HCFC-225aa)
136013-79-1 1,3-Dichloro-l, 1,2,3,3- 1.0
pentafluoropropane (HCFC-225ea)
c. Chemical Categories
Section 313 requires reporting on the EPCRA Section 313
chemical categories listed below, in addition to the specific
EPCRA Section 313 chemicals listed above.
The metal compound categories listed below, unless otherwise
specified, are defined as including any unique chemical
substance that contains the named metal (e.g., antimony, nickel,
etc.) as part of that chemical's structure.
EPCRA Section 313 chemical categories are subject to the 1%
de minimis concentration unless the substance involved meets the
definition of an OSHA carcinogen in which case the 0.1% de
minimis concentration applies. The de minimis concentration for
each category is provided in parentheses. The de minimis
exemption is not available for PBT chemicals, therefore an
asterisk appears where a de minimis limit would otherwise appear.
However, for purposes of the supplier notification requirement
only, such limits are provided in Appendix D.
N010 Antimony Compounds (1.0)
Includes any unique chemical substance that contains
antimony as part of that chemical's infrastructure.
N020 Arsenic Compounds (inorganic compounds: 0.1;
organic compounds: 1.0)
Includes any unique chemical substance that
contains arsenic as part of that chemical's
infrastructure.
N040 Barium Compounds (1.0)
Includes any unique chemical substance that
contains barium as part of that chemical's
infrastructure. This category does not include:
Barium sulfate CAS Number 7727-43-7
N050 Beryllium Compounds (0.1)
Includes any unique chemical substance that
contains beryllium as part of that chemical's
infrastructure.
N078 Cadmium Compounds (0.1)
Includes any unique chemical substance that
contains cadmium as part of that chemical's
infrastructure.
N084 Chlorophenols (0.1)
OH
H(5-x)
Where x = 1 to 5
N090 Chromium Compounds
(except for chromite ore mined in the Transvaal
Region of South Africa and the unreacted ore
component of the chromite ore processing residue
(COPR). COPR is the solid waste remaining after
aqueous extraction of oxidized chromite ore that
has been combined with soda ash and kiln roasted
at approximately 2,000 deg.F.)
(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.
Toxics Release Inventory Reporting Form and Instructions 11-21
-------
Table II
N096 Cobalt Compounds (0.1)
Includes any unique chemical substance that contains
cobalt as part of that chemical's infrastructure.
N100 Copper Compounds (1.0)
Includes any unique chemical substance that contains
copper as part of that chemical's infrastructure. This
category does not include copper phthalocyanine
compounds that are substituted with only hydrogen,
and/or chlorine, and/or bromine.
N106 Cyanide Compounds (1.0)
X+CN~ where X = H+ or any other group where a
formal dissociation may occur. For example KCN or
Ca(CN)2.
N120 Diisocyanates (1.0)
This category includes only those chemicals listed
below.
3 8661 -72-2 1,3 -Bis(methylisocyanate) -
cyclohexane
10347-54-3 l,4-Bis(methylisocyanate)-
cyclohexane
2556-36-7 1,4-Cyclohexane
diisocyanate
134190-37-7 Diethyldiisocyanatobenzene
4128-73-8 4,4'-Diisocyanatodiphenyl
ether
75790-87-3 2,4'-Diisocyanatodiphenyl
sulfide
91-93-0 3,3'-Dimethoxybenzidine-
4,4'-diisocyanate
91-97-4 3,3'-Dimethyl-4,4'-
diphenylene diisocyanate
139-25-3 3,3'-Dimethyldiphenyl
methane-4,4'-diisocyanate
822-06-0 Hexamethylene-1,6-
diisocyanate
4098-71-9 Isophorone diisocyanate
75790-84-0 4-Methyldiphenylmethane-3,4-
diisocyanate
5124-30-1 l,l-Methylenebis(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
N150 Dioxin and Dioxin-Like Compounds
(Manufacturing; and the processing or otherwise
use of dioxin or dioxin-like compounds if the dioxin
and dioxin-like compounds are present as
contaminants in a chemical and if they were
created during the manufacture of that chemical.)
(*) This category includes only those chemicals listed
below. [Note: When completing the Form R, Part II,
Section 1.4, enter the distribution percent estimates for
each of the dioxin and dioxin-like compounds
chemical category members in the order they are listed
here (i.e., 1-17).]
1,2,3,4,6,7,8-
Heptachlorodibenzofuran
1,2,3,4,7,8,9-
Heptachlorodibenzofuran
1,2,3,4,7,8-
Hexachlorod-benzofuran
1,2,3,6,7,8-
Hexachlorodibenzofuran
1,2,3,7,8,9-
Hexachlorodibenzofuran
2,3,4,6,7,8-
Hexachlorodibenzofuran
1,2,3,4,7,8-
Hexachlorodibenzo-p-dioxin
1,2,3,6,7,8-
Hexachlorodibenzo-p-dioxin
1,2,3,7,8,9-
Hexachlorodibenzo-p-dioxin
1,2,3,4,6,7,8-Heptachlorodibenzo-
/>-dioxin
1,2,3,4,6,7,8,9-
Octachlorodibenzofuran
1,2,3,4,6,7,8,9-
Octachlorodibenzo-p-dioxin
1,2,3,7,8-
Pentachlorodibenzofuran
2,3,4,7,8-
Pentachlorodibenzofuran
1,2,3,7,8-
Pentachlorodibenzo-p-dioxin
2,3,7,8-
Tetrachlorodibenzofuran
2,3,7,8-
Tetrachlorodibenzo-p-dioxin
N171 Ethylenebisdithiocarbamic acid, salts and esters
(EBDCs) (1.0)
Includes any unique chemical substance that contains
an EBDC or an EBDC salt as part of that chemical's
infrastructure.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
67562-39-4
55673-89-7
70648-26-9
57117-44-9
72918-21-9
60851-34-5
39227-28-6
57653-85-7
19408-74-3
35822-46-9
39001-02-0
3268-87-9
57117-41-6
57117-31-4
40321-76-4
51207-31-9
1746-01-6
11-22 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
N230 Certain Glycol Ethers (1.0)
R-(OCH2CH2)n-OR'
where n= 1, 2, or 3
R = alkyl C7 or less; or
R = phenyl or alkyl substituted phenyl;
R' = H, or alkyl C7 or less; or
OR' consisting of carboxylic acid ester, sulfate, phosphate,
nitrate, or sulfonate.
N420 Lead Compounds (*)
Includes any unique chemical substance that contains
lead as part of that chemical's infrastructure.
N450 Manganese Compounds (1.0)
Includes any unique chemical substance that contains
manganese as part of that chemical's infrastructure.
N458 Mercury Compounds (*)
Includes any unique chemical substance that contains
mercury as part of that chemical's infrastructure.
N495 Nickel Compounds (0.1)
Includes any unique chemical substance that contains
nickel as part of that chemical's infrastructure.
N503 Nicotine and salts (1.0)
Includes any unique chemical substance that contains
nicotine or a nicotine salt as part of that chemical's
infrastructure.
N511 Nitrate compounds (water dissociable; reportable
only when in aqueous solution) (1.0)
N575 Polybrominated Biphenyls (PBBs) (0.1)
with the limiting molecular formulas C1(1H19C13 and
N583
H(10-x)
Where x = 1 to 10
Polychlorinated alkanes (C10 to C13) (1.0, except for
those members of the category that have an average
chain length of 12 carbons and contain an average
chlorine content of 60% by weight which are subject
to the 0.1% de minimis)
CH2x+,yCly
where x= 10 to 13;
y = 3 to 12; and
the average chlorine content ranges from 40 70%
C13H16C112
N590 Polycyclic aromatic compounds (PACs) (*)
This category includes the chemicals listed below.
56-55-3 Benzo(a)anthracene
205-99-2 Benzo(b)fluoranthene
205-82-3 Benzo(j)fluoranthene
207-08-9 Benzo(k)fluoranthene
206-44-0 Benzo(j,k)fluorene
189-55-9 Benzo(r,s,t)pentaphene
218-01-9 Benzo(a)phenanthrene
50-32-8 Benzo(a)pyrene
226-36-8 Dibenz(a,h)acridine
224-42-0 Dibenz(a,j)acridine
53-70-3 Dibenzo(a,h)anthracene
194-59-2 7H-Dibenzo(c,g)carbazole
5385-75-1 Dibenzo(a,e)fluoranthene
192-65-4 Dibenzo(a,e)pyrene
189-64-0 Dibenzo(a,h)pyrene
191-30-0 Dibenzo(a,l)pyrene
57-97-6 7,12-Dimethylbenz(a)-
anthracene
193-39-5 Indeno(l,2,3-cd)pyrene
56-49-5 3-Methylcholanthrene
3697-24-3 5-Methylchrysene
5522-43-0 1-Nitropyrene
N725 Selenium Compouds (1.0)
Includes any unique chemical substance that contains
selenium as part of that chemical's infrastructure.
N740 Silver Compounds (1.0)
Includes any unique chemical substance that contains
silver as part of that chemical's infrastructure.
N746 Strychnine and salts (1.0)
Includes any unique chemical substance that contains
strychnine or a strychnine salt as part of that chemical's
infrastructure.
N760 Thallium Compounds (1.0)
Includes any unique chemical substance that contains
thallium as part of that chemical's infrastructure.
N770 Vanadium Compounds (1.0)
Includes any unique chemical substance that
contains vanadium as part of that chemical's
infrastructure
N874 Warfarin and salts (1.0)
Includes any unique chemical substance that
contains warfarin or a warfarin salt as part of that
chemical's infrastructure.
Toxics Release Inventory Reporting Form and Instructions 11-23
-------
Table II
N982 Zinc Compounds (1.0)
Includes any unique chemical substance that contains
zinc as part of that chemical's infrastructure.
11-24 Toxics Release Inventory Reporting Forms and Instructions
-------
Table III. State Abbreviations
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Marshall Islands
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
AL
AK
AS
AZ
AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL
IN
IA
KS
KY
LA
ME
MH
MD
MA
MI
MN
MS
MO
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Northern Marianas Islands
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
MT
NE
NV
NH
NJ
NM
NY
NC
ND
MP
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
WI
WY
Toxics Release Inventory Reporting Forms and Instructions III-l
-------
This Page Intentionally Left Blank
-------
Table IV. Federal Information Processing Standards (FIPS) Codes
AA
AC
AF
AG
AJ
AL
AM
AN
AO
AR
AS
AT
AU
AV
AY
BA
BB
BC
BD
BE
BF
BG
BH
BK
BL
BM
BN
BO
BP
BR
BS
BT
BU
BV
BX
BY
CA
CB
CD
CE
CF
Aruba
Antigua and
Barbuda
Afghanistan
Algeria
Azerbaijan
Albania
Armenia
Andorra
Angola
Argentina
Australia
Ashmore and
Cartier Islands
Austria
Anguilla
Antarctica
Bahrain
Barbados
Botswana
Bermuda
Belgium
The Bahamas
Bangladesh
Belize
Bosnia and
Herzegovina
Bolivia
Burma
Benin
Belarus
Solomon Islands
Brazil
Bassas da India
Bhutan
Bulgaria
Bouvet Island
Brunei
Burundi
Canada
Cambodia
Chad
Sri Lanka
Congo
CG
CH
CI
CJ
CK
CM
CN
CO
CR
CS
CT
CU
CV
CW
CY
DA
DJ
DO
DR
EC
EG
El
EK
EN
ER
ES
ET
EU
EZ
FG
FI
FJ
FK
FO
FP
FR
FS
GA
GB
Zaire GG
China GH
Chile GI
Cayman Islands GJ
Cocos (Keeling) GK
Islands GL
Cameroon GM
Comoros GO
Colombia GP
Coral Sea Islands GR
Costa Rica GT
Central African GV
Republic GY
Cuba GZ
Cape Verde HA
Cook Islands HK
Cyprus HM
Denmark
Djibouti HO
Dominica HR
Dominican HU
Republic 1C
Ecuador ID
Egypt IM
Ireland IN
Equatorial Guinea IO
Estonia
Eritrea IP
El Salvador IR
Ethiopia IS
Europa Island IT
Czech Republic IV
French Guiana IZ
Finland JA
Fiji JE
Falkland Islands JM
(Islas Malvinas) JN
Faroe Islands JO
French Polynesia JU
France
French Southern KE
and Antarctic Lands KG
The Gambia
Gabon
Georgia
Ghana
Gibraltar
Grenada
Guernsey
Greenland
Germany
Glorioso Islands
Guadeloupe
Greece
Guatemala
Guinea
Guyana
Gaza Strip
Haiti
Hong Kong
Heard Island and
Mcdonald Islands
Honduras
Croatia
Hungary
Iceland
Indonesia
Isle of Man
India
British Indian
Ocean Territory
Clipperton Island
Iran
Israel
Italy
Cote DTvoire
Iraq
Japan
Jersey
Jamaica
Jan Mayen
Jordan
Juan de Nova
Island
Kenya
Kyrgyzstan
Toxics Release inventory Reporting Form and Instructions IV-1
-------
Table IV
KN
KQ
KR
KS
KT
KU
KZ
LA
LE
LG
LH
LI
LO
LS
LT
LU
LY
MA
MB
MC
MD
MF
MG
MH
MI
MK
ML
MN
MO
MP
MR
MT
MU
MV
MW
MX
MY
MZ
NC
NE
NF
NG
NH
NI
NL
Democratic
People's Republic
of Korea
Kingman Reef
Kiribati
Republic of Korea
Christmas Island
Kuwait
Kazakhstan
Laos
Lebanon
Latvia
Lithuania
Liberia
Slovakia
Liechtenstein
Lesotho
Luxembourg
Libya
Madagascar
Martinique
Macau
Moldova
Mayotte
Mongolia
Montserrat
Malawi
Macedonia
Mali
Monaco
Morocco
Mauritius
Mauritania
Malta
Oman
Maldives
Montenegro
Mexico
Malaysia
Mozambique
New Caledonia
Niue
Norfolk Island
Niger
Vanuatu
Nigeria
Netherlands
NO
NP
NR
NS
NT
NU
NZ
PA
PC
PE
PF
PG
PK
PL
PM
PO
PP
PU
QA
RE
RO
RP
RS
RW
SA
SB
SC
SE
SF
SG
SH
SI
SL
SM
SN
SO
SP
SR
ST
SU
sv
sw
sx
Norway
Nepal
Nauru
Suriname
Netherlands
Antilles
Nicaragua
New Zealand
Paraguay
Pitcairn Islands
Peru
Paracel Islands
Spratly Islands
Pakistan
Poland
Panama
Portugal
Papua New Guinea
Guinea-Bissau
Qatar
Reunion
Romania
Philippines
Russia
Rwanda
Saudi Arabia
St. Pierre and
Miquelon
St. Kitts and Nevis
Seychelles
South Africa
Senegal
St. Helena
Slovenia
Sierra Leone
San Marino
Singapore
Somalia
Spain
Serbia
St. Lucia
Sudan
Svalbard
Sweden
South Georgia and
South Sandwich
Islands
SY
SZ
TC
TD
TE
TH
TI
TK
TL
TN
TO
TP
TS
TU
TV
TW
TX
TZ
UG
UK
UP
UV
UY
UZ
VC
VE
VI
VM
VT
WA
WE
WF
WI
WS
WZ
YM
ZA
ZI
Syria
Switzerland
United Arab
Emirates
Trinidad and
Tobago
Tromelin Island
Thailand
Tajikistan
Turks and Caicos
Islands
Tokelau
Tonga
Togo
Sao Tome and
Principe
Tunisia
Turkey
Tuvalu
Taiwan
Turkmenistan
Tanzania
Uganda
United Kingdom
Ukraine
Burkina
Uruguay
Uzbekistan
St. Vincent and the
Grenadines
Venezuela
British Virgin
Islands
Vietnam
Vatican City
Namibia
West Bank
Wallis and Futuna
Western Sahara
Western Samoa
Swaziland
Yemen
Zambia
Zimbabwe
Toxics Release inventory Reporting Form and Instructions IV-2
-------
Appendix A. Federal Facility Reporting Information
Special Instructions for TRI Federal
Facility Reporting
Why Do Federal Facilities
Need to Report?
Executive Order 13148, Greening the Government Through
Leadership in Environmental Management, requires federal
agencies to comply with the Emergency Planning and
Community Right-To-Know Act of 1986 (EPCRA) and the
Pollution Prevention Act of 1990 (PPA). Federal facilities
have been subject to EPCRA section 313 and PPA since
reporting year 1994. TRI submissions are due to EPA on
July 1 of the year following each reporting (calendar) year.
Reporting by the federal facility does not alter the reporting
obligation of on-site contractors. "Nothing in this order
alters the obligations under EPCRA, PPA, and CAA
independent of this order for Government-owned,
contractor-operated facilities and Government corporations
owning or operating facilities or subjects such facilities to
EPCRA, PPA, or CAA if they are otherwise excluded.
However, each agency shall include the releases and other
waste management of chemicals for all such facilities to
meet the agency's reporting responsibilities under section
501 of this order." Section 902(c).
Identifying Federal Facility Reports
Federal facility reports are identified as federal by several
indicators on the form. The facility name and parent
company name are critical indicators and must be reported
as described below. Another critical indicator is the federal
facility report box, Part I, 4.2c. Federal facilities only
should check this box to indicate that the report is from a
federal agency for a federal facility; federal facilities should
not check the GOCO box, (Part I, Section 4.2d of the Form
R). Contractors located at federal facilities (GOCOs) should
check the GOCO box (Part I, Section 4.2d of the Form R);
they should not check the box 4.2c. Facilities should also
complete the partial or complete facility blocks (Form R
page 2, block 4.2a and 4.2b) as appropriate. If you are a
federal facility reporting for the first time, write "new" in the
TRI Facility ID (TRIFID) box, even if a contractor has
reported for your facility in the past. The contractor will
retain the original TRIFID. You will be assigned a new
TRIFID the first time you report.
The "Double Counting" Problem
As structured, the law and the executive order require both
regulated industries and the federal government to report TRI
data, sometimes for the same site. In order to prevent duplicate
data in the TRI database, which could result in "double counting"
data for some chemicals and locations, EPA must be able to
identify and distinguish the "Government Owned Contractor
Operated" (GOCO) reports submitted by the federal contractor
from the federal facility reports which contain data for the same
site. To accomplish this, federal facility reports must be
accompanied by either 1) exact copies (paper or electronic) of all
contractor TRI reports, including when the totals reported by the
federal facility are greater than that reported by the contractor(s),
or 2) a cover letter which includes a list of the facility contractors
which submit TRI reports to EPA, identifying each contractor by
name, TRI technical contact, and TRI facility name and address.
Additionally, federal facilities must check Form R, Part I,
Section 4.2c, while contractors at federal facilities must check
Form R, Part I, Section 4.2d.
Magnetic Media Reporting
EPA encourages all federal facilities and GOCO facilities to
report using either EPA's Magnetic Media reporting software, or
one of the commercially available packages. If the GOCO
submits its reports on magnetic media to EPA and to the federal
facility, the federal facility may submit magnetic media copies of
their GOCO TRI reports to EPA provided that those reports
account for all subject activities at the facility. Magnetic media
reports must be accompanied by a cover letter which includes:
Required Form R certification statement;
List of the chemicals reported on the federal facility's
disk; and
List that identifies the contractors) [if any] by name
and and by TRIFID number if they have an assigned
TRIFID number, and the chemicals they reported
(which are on the contractors' attachment disk(s))
How to Report Your Facility Name
Facility name is a critical data element. It is used by EPA to
create the TRI facility ID number, which is a unique number
designed to identify a facility site. The facility name and
TRIFID number are used by all TRI data users to link data from
a single site across multiple reporting years. A federal facility is
assigned a new TRIFID number when the federal report is
Toxics Release Inventory Reporting Forms and Instructions A-l
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Appendix A
entered into the Toxics Release Inventory system for the
first time. This TRIFID number, generated when the first
report is entered into the Toxics Release Inventory System,
will be included in future reporting packages sent to the
federal facility, and should be used by the federal facility in
all future reports.
Federal facilities should report their facility name on page 1
of the Form Rs (Section 4.1), as shown in the following
example:
U.S. DOE Savannah River Site
It is very important that the agency name appear first,
followed by the specific plant or site name.
Federal contractors at GOCO facilities should report their
names as shown in the following example:
U.S. DOE Savannah River Site Westinghouse
Operations.
How to Report Your Standard
Industrial Classification (SIC) Code
Federal facilities should report the SIC code which most
closely represents the activities taking place at the site.
Additional guidance on determining your SIC code is
provided in the Forms and Instructions booklet. The table
on the next page contains Public Administration SIC codes
91-97 covering executive, legislative, judicial,
administrative and regulatory activities of the Federal
government. Government-owned and operated business
establishments are classified in major SIC groups 01-89
according to the activity in which they are engaged. For
example, a Veterans Hospital would be classified in Group
806 Hospitals.
How to Report Your "Parent
Company" Name
Federal facilities should report their parent company name
on page 2 of the Form Rs (Section 5.1) by reporting their
complete Department or Agency name, as shown in the
following example:
U.S. Department of Energy
Block 5.2, Parent Company's Dun & Bradstreet Number,
should be marked NA.
Federal contractors at GOCO facilities should not report a federal
department or agency name as their parent company. A federal
name in the parent company name field will classify the report
as federal, and the GOCO may be identified as a non-reporter.
How to Revise Your Data After It Has Been
Submitted
Any TRI Form R submitter may voluntarily revise their
submission if they find errors after their reports have been sent
to EPA. If the revision is to a hardcopy report, the facility should
photocopy the original form, use a blue or black pen to mark out
the incorrect value and write in the corrected value. The revised
report should be submitted to EPA, with an "X" in the revision
block on page 1 of the Form R. If the revision is to a diskette, a
new diskette should be submitted, containing the data only for
the revised submission, not all the chemicals originally reported.
If a federal facility receives a copy of a revision from a
contractor located at the federal facility, the facility should revise
the federal report, and submit the revised report to EPA and the
appropriate state along with an exact copy of the contractor's
revision. The cover letter from the federal facility must indicate
that its submission is a revision.
National Security Data
DO NOT SUBMIT NATIONAL SECURITY DATA TO THE
EPCRA REPORTING CENTER. National security data are
handled through a separate process. Facilities should consult the
Guidance for Implementing Executive Order 12856 documents
(this guidance for Executive Order 12856, which was superceded
by Executive Order 13148, still applies for national security
issues) or call the EPCRA Call Center if their Form R
submission involves a national security data claim.
Who Should Sign Federal Form R
Reports?
Federal Form R reports must be signed by the senior federal
employee on-site. If no federal employee is on-site, federal Form
R reports must be signed by the senior federal employee with
management responsibility for the site. Federal Form R reports
must be signed by a federal employee. Contractor employee
signatures are not considered valid on federal reports.
A-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix A
More Help is Available!
Federal facilities may call EPA's EPCRA Call Center at
(800) 424-9346, (703) 412-9810, TDD (800) 553-7672 to
ask specific questions concerning how to submit their Form
R reports.
Standard Industrial Classification
Codes 91-97
Division J Public Administration
91 Executive, Legislative, and
General Government, Except
Finance
9111 Executive Offices
9121 Legislative Bodies
9131 Executive and Legislative Offices Combined
9199 General Government, Not Elsewhere Classified
92 Justice, Public Order, and
Safety
9211 Courts
9221 Police Protection
9222 Legal Counsel and Prosecution
9223 Correctional Institutions
9224 Fire Protection
9229 Public Order and Safety, Not Elsewhere Classified
93 Public Finance, Taxation, and
Monetary Policy
9311 Public Finance, Taxation, and Monetary Policy
94 Administration of Human
Resource Programs
9411 Administration of Educational Programs
9431 Administration of Public Health Programs
9441 Administration of Social, Human
Resource and Income Maintenance
Programs
9451 Administration of Veterans' Affairs,
Except Health and Insurance
95 Administration of Environmental Quality
and Housing Programs
9511 Air and Water Resource and Solid Waste Management
9512 Land, Mineral, Wildlife, and Forest Conservation
9531 Administration of Housing Programs
9532 Administration of Urban Planning and Community and
Rural Development
96 Administration of Economic
Programs
9611 Administration of General Economic
Programs
9621 Regulation and Administration of
Transportation Programs
9631 Regulation and Administration of
Communications, Electric, Gas, and Other
Utilities
9641 Regulation of Agricultural Marketing and
Commodities
9651 Regulation, Licensing, and Inspection of
Miscellaneous Commercial Sectors
9661 Space Research and Technology
97 National Security and International
Affairs
9711 National Security
9721 International Affairs
Toxics Release Inventory Reporting Forms and Instructions A-3
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Appendix B. Reporting Codes For EPA Form R
Form R Part II
Section 1.1. CAS Number
EPCRA Section 313 Chemical Category Codes
NO 10 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N150 Dioxin and dioxin-like compounds
N171 Ethylenebisdithiocarbamic
acid, salts and esters (EBDCs)
N230 Certain glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N503 Nicotine and salts
N511 Nitrate compounds
N575 Polybrominated biphenyls (PBBs)
N583 Polychlorinated alkanes
N590 Poly cyclic aromatic compounds
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N770 Vanadium compounds
N874 Warfarin and salts
N982 Zinc compounds
Section 4. Maximum Amount of the Toxic
Chemical On-Site at Any Time During the
Calendar Year
Weight Range in Pounds
Range Code
01
02
03
04
05
06
07
08
09
10
11
From...
0
100
1,000
10,000
100,000
1,000,000
10,000,000
50,000,000
100,000,000
500,000,000
1 billion
To....
99
999
9,999
99,999
999,999
9,999,999
49,999,999
99,999,999
499,999,999
999,999,999
more than 1 billion
Section 5. Quantity of the Non-PBT Chemical
Entering Each Environmental Medium On-site
and Section 6. Transfers of the Toxic Chemical
in Wastes to Off-Site Locations
Total Release or Transfer
Code
A
B
C
Basis of Estimate
Range Obs)
1-10
11-499
500-999
M: Estimate is based on monitoring data or measurements
for the EPCRA section 313 chemical as transferred to
an off-site facility.
C: Estimate is based on mass balance calculations, such as
calculation of the amount of the EPCPxA section 313
chemical in waste streams entering and leaving process
equipment.
E: Estimate is based on published emission factors, such
as those relating release quantity to through-put or
equipment type (e.g., air emission factors).
O: Estimate is based on other approaches such as
engineering calculations (e.g., estimating volatilization
using published mathematical formulas) or best
Toxics Release Inventory Reporting Forms and Instructions B-l
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Appendix B
engineering judgment. This would include applying
an estimated removal efficiency to a treatment, even if
the composition of the waste before treatment was
fully identified through monitoring data.
Section 6. Transfers of the Non-PBT Chemical
in Wastes to Off-Site Locations
Type of Waste Disposal/Treatment/Energy
Recovery/Recycling
M10
M20
M24
M26
M28
M40
M41
M50
M54
M56
M61
M62
M69
M71
M72
M73
M79
M90
M92
M93
M94
M95
M99
Storage Only
Solvents/Organics Recovery
Metals Recovery
Other Reuse or Recovery
Acid Regeneration
Solidification/Stabilization
Solidification/Stabilization-Metals and Metal
Category Compounds only
Incineration/Thermal Treatment
Incineration/Insignificant Fuel Value
Energy Recovery
Wastewater Treatment (Excluding POTW)
Wastewater Treatment (Excluding POTW) Metals
and Metal Category Compounds only
Other Waste Treatment
Underground Injection
Landfill/Disposal Surface Impoundment
Land Treatment
Other Land Disposal
Other Off-Site Management
Transfer to Waste Broker -
Transfer to Waste Broker -
Transfer to Waste Broker -
Transfer to Waste Broker -
Unknown
- Energy Recovery
- Recycling
Disposal
- Waste Treatment
Section 7A. On-Site Waste Treatment Methods
and Efficiency
General Waste Stream
A Gaseous (gases, vapors, airborne particulates)
W Wastewater (aqueous waste)
L Liquid waste streams (non-aqueous waste)
S Solid waste streams (including sludges and slurries)
Waste Treatment Methods
Air Emissions Treatment
A01 Flare
A02 Condenser
A03 Scrubber
A04 Absorber
A05 Electrostatic Precipitator
A06 Mechanical Separation
A07 Other Air Emission Treatment
Biological Treatment
B11 Biological Treatment Aerobic
B21 Biological Treatment Anaerobic
B31 Biological Treatment Facultative
B99 Biological Treatment Other
Chemical Treatment
CO 1 Chemical Precipitation Lime or Sodium
Hydroxide
C02 Chemical Precipitation Sulfide
C09 Chemical Precipitation Other
C11 Neutralization
C21 Chromium Reduction
C31 Complexed Metals Treatment (other than
pH Adjustment)
C41 Cyanide Oxidation Alkaline Chlorination
C42 Cyanide Oxidation Electrochemical
C43 Cyanide Oxidation Other
C44 General Oxidation (Including Disinfection)
Chlorination
C45 General Oxidation (Including Disinfection)
Ozonation
C46 General Oxidation (Including Disinfection) Other
C99 Other Chemical Treatment
Incineration/Thermal Treatment
F01 Liquid Injection
F11 Rotary Kiln with Liquid Injection Unit
F19 Other Rotary Kiln
F31 Two Stage
F41 Fixed Hearth
F42 Multiple Hearth
F51 FluidizedBed
F61 Infra-Red
F71 Fume/Vapor
F81 Pyrolytic Destructor
F82 Wet Air Oxidation
B-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix B
F83 Thermal Drying/Dewatering
F99 Other Incineration/Thermal Treatment
Physical Treatment
P01 Equalization
P09 Other Blending
P11 Settling/Clarification
P12 Filtration
P13 Sludge Dewatering (Non-thermal)
P14 Air Flotation
P15 Oil Skimming
P16 Emulsion Breaking Thermal
P17 Emulsion Breaking Chemical
P18 Emulsion Breaking Other
P19 Other Liquid Phase Separation
P21 Adsorption Carbon
P22 Adsorption Ion Exchange (Other than for
recovery/reuse)
P23 Adsorption Resin
P29 Adsorption Other
P31 Reverse Osmosis (Other than for recovery/reuse)
P41 Stripping Air
P42 Stripping Steam
P49 Stripping Other
P51 Acid Leaching (Other than for recovery/reuse)
P61 Solvent Extraction (Other than for recovery/reuse)
P99 Other Physical Treatment
Solidification/Stabilization
G01 Cement Processes (Including Silicates)
G09 Other Pozzolonic Processes (Including Silicates)
Gil Asphaltic Processes
G21 Thermoplastic Techniques
G99 Other Solidification Processes
Range of Influent Concentration
1 = Greater than 10,000 parts per million (1 percent)
2 = 100 parts per million (0.01 percent) to 10,000 parts
per million (1 percent)
3 = 1 part per million (0.0001 percent) to 100 parts per
million (0.01 percent)
4 = 1 part per billion to 1 part per million
5 = Less than 1 part per billion
[Note: Parts per million (ppm) is milligrams/kilogram
(mass/mass) for solids and liquids; cubic centimeters/cubic
meter (volume/volume) for gases; milligrams/liter for solutions
or dispersions of the chemical in water; and milligrams of
chemical/kilogram of air for particulates in air. If you have
paniculate concentrations (at standard temperature and pressure)
as grains/cubic foot of air, multiply by 1766.6 to convert to parts
per million; if in milligrams/cubic meters, multiply by 0.773 to
obtain parts per million. Factors are for standard conditions of
0ป (32ปF) and 760 mmHg atmospheric pressure.]
Section 7B. On-Site Energy Recovery Processes
U01 Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
U09 Other Energy Recovery Methods
Section 7C. On-Site Recycling Processes
Rl 1 Solvents/Organics Recovery Batch Still
Distillation
R12 Solvents/Organics Recovery Thin-Film
Evaporation
R13 Solvents/Organics Recovery Fractionation
R14 Solvents/Organics Recovery Solvent Extraction
R19 Solvents/Organics Recovery Other
R21 Metals Recovery Electrolytic
R22 Metals Recovery Ion Exchange
R23 Metals Recovery Acid Leaching
R24 Metals Recovery Reverse Osmosis
R26 Metals Recovery Solvent Extraction
R27 Metals Recovery High Temperature
R28 Metals Recovery Retorting
R29 Metals Recovery Secondary Smelting
R30 Metals Recovery Other
R40 Acid Regeneration
R99 Other Reuse or Recovery
Section 8.10. Source Reduction Activity Codes
Good Operating Practices
W13 Improved maintenance scheduling, record keeping,
or procedures
W14 Changed production schedule to minimize equipment
and feedstock changeovers
W19 Other changes in operating practices
Inventory Control
W21 Instituted procedures to ensure that materials do not
stay in inventory beyond shelf-life
W22 Began to test outdated material continue to use if
still effective
Toxics Release Inventory Reporting Forms and Instructions B-3
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Appendix B
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labeling procedures
W25 Instituted clearinghouse to exchange materials that
would otherwise be discarded
W29 Other changes in inventory control
Spill and Leak Prevention
W31 Improved storage or stacking procedures
W32 Improved procedures for loading, unloading, and
transfer operations
W33 Installed overflow alarms or automatic shut-off
valves
W35 Installed vapor recovery systems
W36 Implemented inspection or monitoring program of
potential spill or leak sources
W39 Other changes made in spill and leak prevention
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
W49 Other raw material modifications made
Process Modifications
W51 Instituted recirculation within a process
W52 Modified equipment, layout, or piping
W53 Use of a different process catalyst
W54 Instituted better controls on operating bulk
containers to minimize discarding of empty
containers
W55 Changed from small volume containers to bulk
containers to minimize discarding of empty
containers
W58 Other process modifications
Cleaning and Degreasing
W59 Modified stripping/cleaning equipment
W60 Changed to mechanical stripping/cleaning devices
(from solvents or other materials)
W61 Changed to aqueous cleaners (from solvents or
other materials)
W63 Modified containment procedures for cleaning units
W64 Improved draining procedures
W65 Redesigned parts racks to reduce drag out
W66 Modified or installed rinse systems
W67 Improved rinse equipment design
W68 Improved rinse equipment operation
W71 Other cleaning and degreasing modifications
Surface Preparation and Finishing
W72 Modified spray systems or equipment
W73 Substituted coating materials used
W74 Improved application techniques
W75 Changed from spray to other system
W78 Other surface preparation and finishing
modifications
Product Modifications
W81 Changed product specifications
W82 Modified design or composition of products
W83 Modified packaging
W89 Other product modifications
Section 8.10. Methods Used to Identify Source
Reduction Activities
For each source reduction activity, enter up to three of the
following codes that correspond to the method(s) which
contributed most to the decision to implement that activity.
TO 1 Internal Pollution Prevention Opportunity Audit(s)
T02 External Pollution Prevention Opportunity Audit(s)
T03 Materials Balance Audits
T04 Participative Team Management
T05 Employee Recommendation (independent of a
formal company program)
T06 Employee Recommendation (under a formal
company program)
T07 State Government Technical Assistance
Program
T08 Federal Government Technical Assistance Program
T09 Trade Association/Industry Technical
Assistance Program
T10 Vendor Assistance
Til Other
B-4 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C. Facility Data Profiles, and Common Errors in Completing
Form R Reportsjmd Form A Certifications
EPA wishes to ensure that facilities submit all required TRI chemical submissions in a timely manner so that the information may be
included in its national database, annual public data release, and other information products. Moreover, EPA seeks to ensure that all
submitted data is complete and accurate. This appendix provides an overview of Facility Data Profiles (FDPs), an important
communication tool that EPA uses to ensure consistent, complete, and accurate submissions from reporting facilities. This appendix
also provides specific guidance to avoid common errors in completing Form Rs and Form As, including errors in threshold
determination, misapplication of exemptions, and overlooking activities involving a reportable chemical, any of which may result in
mistaken non-reporting of a chemical.
A. Facility Data Profile (FDP)
Facility Data Profiles (FDPs) are sent by the EPCRA Reporting
Center to a reporting facility in response to any submission the
EPCRA Reporting Center receives. A submission can include
an original or revised Form R or Form A, or corrections
included in a response to a previous FDP. The FDP serves two
primary purposes. First, EPA wants to give the reporting
facility the opportunity to confirm that the EPCRA Reporting
Center has entered its data correctly into EPA's national
computer system - i.e., the EPCRA Reporting Center "echoes
back" the information that it has received. Second, if the
EPCRA Reporting Center identifies potential errors in the forms
a facility has submitted, the FDP indicates what these errors are
and requests that the facility provide EPA with corrections. If
the data presented on a facility' s FDP do not match those on the
form(s) it submitted, or if the EPCRA Reporting Center has
identified errors in a facility's submissions, or if a facility
discovers errors in its submitted data, the facility may use the
FDP to make the needed corrections. The FDP does not serve
as a means to withdraw a Form R and/or Form A. Withdrawal
requests should be mailed to the EPCRA Reporting Center. For
additional information regarding withdrawal procedures, go to
www.epa.gov/tri.
An FDP is comprised of the following sections:
Instruction and Signature page. This first page
provides instructions for how to review and respond to
the FDP. The bottom half of the page provides a
certification statement to be signed by a facility
owner/operator or senior management official.
Summary of Notices of Significant Errors (NOSEs).
This page lists all significant errors (NOSE level
errors) for your facility's submissions organized by
chemical submission and the FDP serves as a Formal
Notice of Significant Error. If you have no significant
errors, this page will indicate so.
Facility Information (Primary Facility). This
section displays all facility specific data, inclusive of
TRI Facility Identification, facility name, facility
address, facility mailing address, relevant permits
(e.g., RCRA, NPDES, and UIC), Standard Industrial
Classification code (SIC), and other facility data.
Errors related to facility information will be provided
in this section.
Facility Information (Establishment). If an
establishment reports separately from other
establishments at the facility, this section provides
subordinate facility data. Errors related to facility
information will be provided in this section.
Chemical Report Summary. This section lists all
chemicals reported by the facility for each reporting
year affected by the FDP. For example, if the FDP is
responding to five original chemical submissions for
Reporting Year 1999 and revisions to one chemical
for Reporting Year 1998, a list of all chemicals for
both years will appear.
Chemical Reports. All recently processed Form R
or Form A submission data (i.e., chemical specific
data) are displayed here under the appropriate facility
or subordinate facility names. The FDP displays
facsimiles for chemical reports for recent
submissions, revisions or responses to FDPs only.
For example, if a facility originally reported five
chemicals forReporting Year 1998, and subsequently
revises only one chemical submission, the facility
will receive a FDP for Reporting Year 1998 with
only the revised chemical included in the Chemical
Reports section. Hence there may be fewer chemical
reports than chemicals listed in the Chemical
Summary section. If only facility level changes have
occurred (i.e., Part I of the Form R or A), this section
is not provided.
Toxics Release Inventory Reporting Forms and Instructions C-l
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Appendix C
B. Levels of Errors Identified in FDPs:
Notice of Non-Technical Data Change
(NDC), Notice of Technical Errors
(NOTE), Notice of Significant Errors
(NOSE). Notice of Noncompliance (NON).
FDP Error Reporting. In addition to "echoing back" the
information a facility has submitted, FDPs are used to identify
potential errors, as well as indicate where the EPCRA Reporting
Center has made minor clerical corrections to submissions. As
submission information is entered into EPA's national database,
a series of automated data quality checks are performed. The
data quality checks are useful to correct such things as TRI
Facility Identification, facility name, county spelling, as well as
to perform validation checks to ensure consistency among data
elements within a given Form R or Form A. These data quality
checks, however, cannot detect whether release, transfer, or
waste management quantities were calculated or entered
accurately. Within a FDP notice, there may be up to three
different types of errors identified.
First, a Non-Technical Data Change (NDC) notifies you of
simple, clerical errors that EPA has corrected for you. It is not
necessary to respond to a NDC. The EPCRA Reporting Center
will correct simple, clerical errors that are not technical or
scientific a "non-technical data change." For example, if
a facility transposes CAS numbers (e.g., the submitter lists
7623-00-0 for sodium nitrite instead of 7632-00-0), the EPCRA
Reporting Center will correct this clerical error and display the
correct information on the FDP sent to the facility. If a facility
lists a specific glycol ethers subcategory, the EPCRA Reporting
Center will replace this subcategory with the reportable name
"certain glycol ethers." The messages used on FDPs to report
non-technical data changes are shown below at the end of this
appendix under the heading "E. Messages used to report
Notices of Technical Errors (NOTEs) and Non-technical Data
Changes (NDCs)."
Second, a Notice of Technical Error (NOTE) highlights
inconsistencies or miscalculations that may distort your
facility's information in EPA's public data products or skew
analyses. Incomplete addresses, no technical or public contact
provided, missing or invalid SIC codes, or the use of range
codes to report PBT chemical releases are all examples of
technical errors. You should respond to NOTE level errors as
soon as possible. These types of errors require that the
reporting facility make corrections on their FDP (or provide the
EPCRA Reporting Center with a brief explanation why they do
not believe that it is an error) or submit a revised Form R or
Form A. Depending upon when your changes are received,
there may or may not be sufficient time to incorporate them into
our database in time for public data release. Technical errors do
not prevent submissions from being entered into the data
management system, but indicate inconsistencies or
miscalculations in the submitted form. These errors can distort
public information products and skew any analyses if not
corrected. The messages used on FDPs to report NOTE level
errors are shown below at the end of this appendix under the
heading "E. Messages used to report Notices of Technical
Errors (NOTEs) and Non-technical Data Changes (NDCs).
Third, more serious errors are classified as Notices of
Significant Errors (NOSE). The FDP serves as the formal
Notice of Significant Error. Significant errors prevent
submissions from being entered into the EPCRA Reporting
Center data management system or do not allow the EPCRA
Reporting Center to verify the authenticity of the submission.
Invalid forms, missing pages, no certification signature, no
chemical name or CAS number are examples of significant
errors. These types of errors require that the reporting facility
make corrections on their FDP (or provide the EPCRA
Reporting Center with a brief explanation why they do not
believe that it is an error) or submit a revised Form R or Form
A. A facility must respond to a Notice of Significant Error
within 21 days of receipt. Failure to respond within the initial
21 day requirement could result in the issuance of a Notice of
Noncompliance (NON). A Notice of Noncompliance is not
included in a FDP and is mailed seperately.
The Agency will issue a conditional Notice of
Noncompliance (NON) to a facility for failure to respond to
a Notice of Significant Error (NOSE) within the required
period. A NON will require a facility to take the corrective
action noted in the NOSE via the FDP within 21 days and
respond to the Agency that corrective action has been taken.
If a facility fails to respond to the NON within the required
time period, the Agency may take further action.
Facilities must keep copies, for three years, of submitted Form
R reports and Form A certifications and all documentation
used to complete their submissions. This documentation
should include calculations for threshold determinations, the
basis of exemptions applied, and the estimation techniques and
data used for all quantities reported on the Form R and Form
A.
C-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
C. Common Errors in Completing Form
R Reports and Form A Certification
Statements, including Reporting
Determination Errors
General Considerations
Incomplete Forms. A complete Form R report for a
single EPCRA section 313 chemical or single EPCRA
section 313 chemical category consists of five pages
stapled together. EPA cannot enter into the database
data from a package that contains only one page 1, but
several page 2s, 3s, 4s, and/or 5s. Such forms are
considered incomplete submissions.
Threshold Determinations
Calculating threshold determinations. Annual
quantities manufactured, processed, or otherwise used
for section 313 chemicals must be calculated, not
surmised. The assumption that thresholds are exceeded
commonly leads to error.
Misclassification of EPCRA section 313 chemical
activity. Failure to correctly classify an EPCRA
section 313 chemical activity may result in an incorrect
threshold determination. As a result, a facility may fail
to submit the required Form R.
EPCRA section 313 chemical activity overlooked.
Many facilities believe that because the section 313
reporting requirement pertains to manufacturers, only
the use of EPCRA section 313 chemicals in
manufacturing processes must be examined. Any
activity involving the manufacture, process, or
otherwise use of an EPCRA section 313 chemical or
chemical category must be included in threshold
determinations. Commonly overlooked activities
include importation of chemicals, generation of waste
byproducts, processing of naturally occurring metals
and metal category compounds in ore, manufacturing
and processing of reaction intermediates, the use of
chemicals for cleaning of equipment, and the generation
of byproducts during combustion of coal and/or oil.
Facilities should take a systematic approach to identify
all chemicals and mixtures used in production and
non-production capacities, including catalysts, well
treatment chemicals, and wastewater treatment
chemicals.
Reporting EPCRA section 313 chemicals in mixtures
and other trade name products. EPCRA section 313
chemicals contained in mixtures (including ores and
stainless steel alloys) and other trade name products
must be factored into threshold determinations and
release and other waste management determinations,
provided that the de minimis exemption cannot be
taken. When the EPCRA section 313 chemical being
reported is a component in a mixture or other trade
name product, report only the weight of the EPCRA
section 313 chemical in the mixture. Refer to Section
B.4b of this document to calculate the weight of an
EPCRA section 313 chemical in a mixture or other
trade name product.
Reporting coincidental manufacturing. Coincidental
manufacturing must not be overlooked. If coal and/or
fuel oil and other raw materials that contain EPCRA
section 313 chemicals are used in boilers/burners, there
is a potential for the coincidental manufacture of
EPCRA section 313 chemicals such as sulfuric acid
(acid aerosols), hydrochloric acid (acid aerosols),
hydrogen fluoride, and metal category compounds.
Additionally, manufacturing of EPCRA section 313
chemicals during waste treatment is commonly
overlooked. For example, the treatment of nitric acid
may result in the coincidental manufacturing of a
reportable chemical (nitrate compounds).
Container Residue
Overlooking container residue. Container residue
must not be disregarded in release and other waste
management calculations. Even a "RCRA empty"
drum is expected to contain a residue and it must be
considered for TRI reporting. Additionally, on-site
drum rinsing and disposal of the rinsate will result in a
release and other waste management activity. Refer to
"Estimating Releases and Waste Treatment Efficiencies
for Toxic Chemical Reporting Forms."
Part I. Facility Identification Information
Section 1. Reporting Year
Invalid Forms. The correct version of the form for the
reporting year in question must be used. Forms
provided for reporting years 1987-1990 must not be
used to report data for reporting years 1991-1995. Form
Rs provided for reporting years 1987-1995 must not be
used to report data for years 1996 and later.
Toxics Release Inventory Reporting Forms and Instructions C-3
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Appendix C
Section 2. Trade Secret Information
Incorrect completion of trade secret information.
The responses to trade secret questions in Part I
Section 2 and Part II Section 1.3 of Form R/Form A
must be consistent. If trade secrecy is indicated, a
sanitized Form R/Form A and two trade secret
substantiations (one sanitized) must be submitted in the
same package as the trade secret Form R/Form A. Part
II Section 1.3 should be blank if no trade secret claim
is being made. Also, if you indicate in Part I, Section
2.1 that you are not claiming trade secret information,
leave Part I, 2.2 blank.
Section 3. Certification
Missing certification signature. If you are submitting
your Form R and/or Form A by hardcopy, an original
certification signature must appear on page 1 of every
Form R and/or Form A submitted to EPA. If you are
submitting your Form R and/or Form A via diskette or
electronically through EPA's Central Data Exchange
(CDX), a certification letter containing the certification
language as noted in 40 CFR ง 372.85(b)(2), with the
signature of a senior management official, must
accompany the submission. The certification letter
must contain the certification language. An example of
the certification letter is included in Section A of these
instructions.
Section 4. Facility Identification
Incorrect latitude and longitude coordinates.
Latitude and longitude coordinates must be determined
using the correct map and correct measurement
techniques and reported in degrees, minutes, and
seconds. For additional guidance, see Appendix E of
this document.
"Questionable" entries. Incorrect entries may require
corrections to be made by the facility. Questionable
entries may include:
Missing or incorrect street address;
Missing or incorrect ZIP codes;
Missing County names;
Invalid SIC codes;
Missing or invalid Dun & Bradstreet
numbers;
Missing or invalid RCRA, NPDES, or UIC
numbers; and
Incomplete off-site and POTW
information (e.g., missing city name)
If amounts are reported in units other than pounds (e.g., metric
units) or with exponential numbers, EPA may require a
revision of the Form R/Form A submitted. The exception is
for the reporting of dioxin and dioxin-like compounds where
the amounts are reported in grams.
Part II. Chemical-Specific Information
Section 1. Toxic Chemical Identity
Reporting chemical abstract service (CAS) numbers
in Section 1.1. Beginning with the 1991 reporting year,
EPA has assigned alphanumeric category codes to the
twenty chemical categories for the purposes of
reporting the CAS number field in Section 1.1. When
completing a Form R for a chemical category, the
appropriate code for that category must be provided in
Section 1.1. The CAS numbers are listed in Table II:
"Section 313 Toxic Chemical List," and if needed, the
category codes are listed in Appendix B: "Reporting
CodesforEPAFormR." Category guidance documents
are listed in the Chemical and Industry Guidance
Documents section in this document.
Failure to check for synonyms. Some reportable
chemicals (especially glycol ethers and toluene
diisocyanates) have many synonyms that do not readily
imply they are in the category. For example,
"benzene,!,3-diisocyanatomethyl" may not be readily
recognized as "toluene diisocyanate (mixed isomers)."
Invalid chemical identification in Section 1.2. The
CAS number and the chemical name reported here must
exactly match the listed official EPCRA section 313
CAS number and EPCRA section 313 chemical name.
Failure to consider an EPCRA section 313 chemical
qualifier. Only EPCRA section 313 chemicals in the
form specified in the qualifier require reporting under
section 313 and should be reported on Form R with the
appropriate qualifier in parentheses. For example,
isopropyl alcohol is listed on the EPCRA section 313
chemical list with the qualifier "manufacturing- strong
acid process, no supplier notification." Thus, the
ONLY failities that should report this EPCRA section
313 chemical are those that manufacture isopropyl
alcohol by the strong acid process.
Generic chemical name in Section 1.3. A generic
chemical name should only be provided if the section
313 chemical identity is claimed as a trade secret.
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Appendix C
Section 2. Mixture Component Identity
Identifying chemicals used in mixtures. Facilities
must carefully review the most recent MSDS or
supplier notification for every mixture brought on-site
to identify all section 313 chemicals used during a
reporting year. Although some mixtures may not have
MSDSs, the best readily available information should
be used to determine the presence of EPCRA section
313 chemicals in ores and alloys.
Mixture names in Section 2.1. Mixture names are to
be entered here only if the supplier is claiming the
identity of the EPCRA section 313 chemical a trade
secret and that is the sole identification. Mixture names
that include the name or CAS number of one or more
EPCRA section 313 chemicals are not valid uses of the
mixture name field.
Section 3. Activities and Uses of the Toxic Chemical at the
Facility
Reporting EPCRA section 313 chemical activity.
EPCRA section 313 chemical activity is commonly
overlooked or misclassified. Any activity involving the
manufacture, process, or otherwise use of an EPCRA
section 313 chemical must be examined. For example,
waste treatment operations otherwise use EPCRA
section 313 chemicals to treat waste streams and may
coincidentally manufacture an additional EPCRA
section 313 chemical as a result of the treatment
reaction. Such activity must be considered. Further,
EPCRA section 313 chemical activity must be correctly
classified as either "manufactured," "processed," or
"otherwise used."
Section 3.1 "Manufacture"means to produce, prepare,
compound, or import an EPCRA section
313 chemical.
Section 3.2 "Process" means the preparation of an
EPCRA section 313 chemical after its
manufacture, which incorporates the
EPCRA section 313 chemical into the final
product, for distribution in commerce.
Section 3.3 "Otherwise use" encompasses any use of an
EPCRA section 313 chemical that does not
fall under the terms "manufacture" or
"process," and includes treatment for
destruction, stabilization (without
subsequent distribution in commerce),
disposal, and other use of an EPCRA
section 313 chemical, including an EPCRA
section 313 chemical contained in a mixture
or other trade name product. Otherwise use
of an EPCRA section 313 chemical does not
include disposal, stabilization (without
subsequent distribution in commerce), or
treatment for destruction unless:
1. The EPCRA section 313 chemical that was
disposed, stabilized, or treated for
destruction was received from off-site for
the purposes of further waste management;
or
2. The EPCRA section 313 chemical that was
disposed, stabilized, or treated for
destruction was manufactured as a result of
waste management activities on materials
received from off-site for the purposes of
further waste management activities.
For example, solvents in paint applied to a manufactured
product are often misclassified as processed, instead of
otherwise used. Because the solvents are not incorporated into
the final product, the solvent is being otherwise used, not
processed. Such situations must be interpreted accurately.
Section 4. Maximum Amount of the Toxic Chemical On-
site at Any Time During the Calendar Year
Maximum amount on-site left blank. Failure to
provide the appropriate code for maximum amount on
site.
Section 5. Quantity of the Toxic Chemical Entering
Each Environmental Medium On-site
Incorrectly reporting stack emissions. Fugitive
emissions from general indoor air must not be reported
as stack missions when released from a single building
vent. Additionally, stack emissions from storage tanks,
including loading, working, and breathing losses from
tanks, must not be overlooked or reported as fugitive
emissions.
Overlooking releases to land. Section 313 chemicals
placed in stockpiles or in surface impoundments should
be reported as a "release to land" even if no section 313
chemicals leak from these sources. Quantities of
section 313 chemicals land-treated should be reported
as a "release to land."
Toxics Release Inventory Reporting Forms and Instructions C-5
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Appendix C
Section 6. Transfers of the Toxic Chemical in Wastes to
Off-site Locations
Reporting discharges to POTWs in Section 6.1.
When quantities of a listed mineral acid are neutralized
to a pH of 6 or greater, the quantity reported as
discharged to a POTW should be reported as zero. It is
incorrect to enter "NA" (Not Applicable), in such a
situation.
Reporting other off-site transfers in Section 6.2.
Any quantities reported in Sections 8.1, 8.3, 8.5, and
8.7 as sent off-site for disposal, treatment, energy
recovery, or recycling, respectively, must also be
reported in Section 6.2 along with the receiving
location and appropriate off-site activity code.
Section 7A. On-Site Waste Treatment Methods and
Efficiency
Failure to report waste treatment methods in
Section 7A. Waste treatment methods used to treat
waste streams containing EPCRA section 313
chemicals, and the efficiencies of these methods, must
be reported on Form R. Information must be entered for
all waste streams, even if the waste treatment method
does not affect the EPCRA section 313 chemical. If no
waste treatment is performed on waste streams
containing the EPCRA section 313 chemical, the box
marked "Not Applicable" in Section 7A must be
checked on Form R.
Section 7B. On-Site Energy Recovery Processes
Incorrect reporting of waste treatment methods in
Section 7A. The type of waste stream, influent
concentration, and waste treatment method for each
waste stream are required to be reported on Form R
using specific codes, along with the waste treatment
efficiency expressed as percent removal. The waste
treatment codes are listed in Appendix B: "Reporting
Codes for EPA Form R," of the Toxic Chemical
Release Inventory Reporting Forms and Instructions.
Reporting on-site energy recovery methods in
Section 7B. When a quantity is reported in Section 8.2
as combusted for energy recovery on-site, the type of
energy recovery system used must be reported in
Section 7B, and vice versa.
Section 7C. On-Site Recycling Processes
Reporting on-site recycling methods in Section 7C.
When a quantity is reported in Section 8.4 as recycled
on-site, the type of recovery method must be reported
in Section 7C, and vice versa.
Section 8. Source Reduction and Recycling Activities
The entries in this section must be completed, even if
your facility does not engage in source reduction or
recycling activities.
Columns C and D, the future year projections for
questions 8.1 through 8.7, must be completed. EPA
expects a reasonable estimate for the future year
projections. Zero can be used in columns C and D to
indicate that the manufacture, process, or otherwise use
of the chemical will be discontinued. In such cases,
columns C and D for Section 8.1 through 8.7 must all
contain zeroes.
It is incorrect to use range codes to report quantities in
Section 8. Range codes can be used only in Sections 5
and 6 of Form R.
It is incorrect to use the same codes from Section 4 for
reporting the maximum amount of the reported EPCRA
section 313 chemical on-site to report quantities in
Section 8.
Quantities reported in Section 8.1 through 8.7 are
mutually exclusive and additive. This means that
quantities of the reported EPCRA section 313 chemical
must not be double-counted in Section 8.1 through 8.7.
Some double-counting errors have been due to
confusion over the differences in how on-site treatment
of an EPCRA section 313 chemical is reported in
Section 7A as compared to Section 8. In Section 7A,
information on the treatment of waste streams
containing the EPCRA section 313 chemical is
reported, along with the percent efficiency in terms of
destruction or removal of the EPCRA section 313
chemical from each waste stream. In Section 8, only the
quantity of the EPCRA section 313 chemical actually
destroyed through the treatment processes reported in
Section 7A is reported in Section 8.6 to avoid
double-counting within Sections 8.1 through 8.7.
Quantities reported in Sections 8.1 through 8.7 must not
be reported in Section 8.8 and vice versa.
C-6 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
Any time a reported EPCRA section 313 chemical is
contained in a waste, and the waste is associated with
routine production-related activities and is recycled,
combusted for energy recovery, treated, disposed, or
otherwise released either on- or off-site, that quantity of
the EPCRA section 313 chemical must be included in
the quantities reported in Sections 8.1 through 8.7.
Reporting quantities in Section 8.1 "Quantity
released." Quantities of EPCRA section 313 chemicals
that are released (including disposed) on-site and
reported in Section 5 of Form R must be reported in
Section 8.1. Quantities of EPCRA section 313
chemicals transferred off-site for the purposes of
disposal reported in Section 6.2 must appear in Section
8.1 using the following codes:
M10 Storage Only;
M41 Solidification/Stabilization Metals and
Metal Category Compounds Only;
M62 Wastewater Treatment (excluding POTW)
Metals and Metal Category Compounds
Only;
M71 Underground Injection;
M72 Landfill/Disposal Surface Impoundment;
M73 Land Treatment;
M79 Other Land Disposal;
M90 Other Off-Site Management; and
M94 Transfer to Waste BrokerDisposal
M99 Unknown.
Metals and metal category compounds transferred off-
site to POTWs in Section 6.1 must appear in Section
8.1. To report correctly in Section 8.1, a facility must
include quantities that are released to the environment,
either on-site or off-site, excluding releases due to
catastrophic events or non-production related activities.
ง8.1 = ง5 + ง6.1 (metals and metal category
compounds only) + ง 6.2 (disposal only) - ง 8.8
(on-site or off-site release due to catastrophic events)1
Reporting quantities in Section 8.2 "Quantity used for
energy recovery on-site." A quantity must be reported
in Section 8.2 for the current (reporting) year when a
method of on-site energy recovery is reported in Section
7B, and vice versa. An error facilities make when
completing Form R is to report the methods of energy
recovery used on-site in Section 7B but not report the
total quantity associated with those methods. Another
error is to report a quantity in this section if the
combustion of the EPCRA section 313 chemical took
place in a system that did not recover energy (e.g., an
incinerator). A quantity of the EPCRA section 313
chemical combusted for energy recovery must not be
reported if the EPCRA section 313 chemical does not
have a significant heating value. Examples of EPCRA
section 313 chemicals that do not have significant
heating values include metals, metal category
compounds, and halons. Metals and metal portions of
metal compounds will never be treated or combusted
for energy recovery. Section 8.2 must not include any
quantities of the EPCRA section 313 chemical
associated with non-production related activities, such
as catastrophic releases and remedial actions, as well as
other one-time events not associated with routine
production practices, that were combusted for energy
recovery on-site.
Reporting quantities in Section 8.3 "Quantity used
for energy recovery off-site." As in Section 8.2, a
quantity must not be reported in this section if the
off-site combustion of the EPCRA section 313 chemical
tookplace in a system that did not recover energy (e.g.,
incinerator). A quantity of an EPCRA section 313
chemical must not be reported as sent off-site for the
purposes of energy recovery if the EPCRA section 313
chemical does not have a significant heating value.
Examples of EPCRA section 313 chemicals that do not
have significant heating values include metals, metal
category compounds, and halons. Metals and metal
portions of metal category compounds will never be
treated or combusted for energy recovery. Quantities
must be reported in Section 8.3 that are reported in
Section 6.2 as transferred off-site for the purposes of
combustion for energy recovery using the following
codes:
M56 Energy Recovery
M92 Transfer to Waste Broker -
- Energy Recovery
1 ง8.8 includes quantities of toxic chemical released on-site or
managed as waste off-site due to remedial actions, catastrophic events, or
one-time events not associated with the production processes.
ง 8.3 = ง 6.2 (energy recovery) - ง 8.8 (off-site
energy recovery due to catastrophic events)2
Reporting quantities in Section 8.4 "Quantity
recycled on-site." A quantity must be reported in
Section 8.4 for the current reporting year when a
method of on-site recycling is reported in Section 7C,
and vice versa. An error facilities make when
completing Form R is to report the methods of
recycling used on-site in Section 7C but not report the
total quantity recovered using those methods.
In addition, only the amount of the chemical that
Toxics Release Inventory Reporting Forms and Instructions C-7
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Appendix C
was actually recovered is to be reported in Section
8.4. Any quantities of the EPCRA section 313 chemical
associated with non-production related activities such as
catastrophic releases and remedial actions, as well as
other one-time events not associated with routine
production practices that were recycled on-site must not
be included in Section 8.8.
Reporting quantities in Section 8.5. "Quantity recycled
off-site." Quantities reported in Section 6.2 as transferred
off-site for the purposes of recycling must be included in
Section 8.5 using the following codes:
M20 Solvents/Organic Recovery;
M24 Metals Recovery;
M26 Other Reuse or Recovery;
M28 Acid Regeneration;
M93 Transfer to Waste Broker Recycling.
Quantities that are actually recycled at an off-site facility
must not be reported in Section 8.5 facilities should
report the quantity that was sent off-site for the purposes
of recycling.
ง8.5 = ง6.2 (recycling) - ง8.8 (off-site recycling due
to catastrophic events)2
Reporting quantities in Section 8.6 "Quantity treated
on-site." Quantities may not always have to be reported
in Section 8.6 when Section 7A is completed. This is
because the information reported in Section 7A and
Section 8 is different. Information on how waste streams
containing the reported EPCRA section 313 chemical are
treated is reported in Section 7A, while the quantity of the
EPCRA section 313 chemical actually destroyed as a
result of on-site treatment is reported in Section 8.6. If a
quantity is reported in Section 8.6, Section 7A must be
completed but the reverse may not be true. This may
result in apparent discrepancies between Section 7A and
Section 8. For example, a facility may treat wastewater
containing an EPCRA section 313 chemical by removing
the EPCRA section 313 chemical and then disposing of it
on-site. The treatment of the wastewater would be
reported in Section 7A, with an efficiency estimate based
on the amount of the EPCRA section 313 chemical
removed from the wastewater. Although the waste stream
has been treated because the EPCRA section 313
chemical has been removed, the EPCRA section 313
chemical has not been treated because it has not been
destroyed. The facility would report only the amount of
the EPCRA section 313 chemical actually destroyed
during treatment in Section 8.6 and the amount ultimately
disposed in Section 8.1 to avoid double-counting the same
quantity in Section 8. In cases where the EPCRA section
313 chemical is not destroyed during a treatment process
and subsequently enters another activity, such as
disposal (e.g., metals removed from wastewater and
subsequently disposed on-site), the quantity of the
EPCRA section 313 chemical would be reported as
disposed in Section 8.1, not as treated in Section 8.6.
Quantities of the EPCRA section 313 chemical
associated with non-production related activities such
as catastrophic releases and remedial actions, as well as
one-time events not associated with routine production
practices, that were treated on-site, must not be
included in Section 8.6. Metals will never be treated or
combusted for energy recovery.
Reporting quantities in Section 8.7 "Quantity
treated off-site." Quantities reported in Section 6.2 as
transferred off-site for the purposes of treatment must
be included in Section 8.7 using the following codes:
M50 Incineration/Thermal Treatment;
M54 Incineration/Insignificant Fuel Value;
M61 Wastewater Treatment (excluding POTW);
M69 Other Waste Treatment; and
M95 Transfer to Waste Broker Waste
treatment.
Quantities of an EPCRA section 313 chemical, except
metals and metal category compounds, sent off-site to
a POTW should also be reported in Section 8.7.
To report correctly EPCRA section 313 chemicals in
Section 8.7, use the following equation.
ง8.7 =ง6.1 (excluding metal/metal category
compounds) + ง6.2 (treatment) - ง8.8 (off-site
treatment due to catastrophic events)2
Reporting quantities in Section 8.8 "Quantity
released to the environment as a result of remedial
actions, catastrophic events or one-time events not
associated with production processes." The quantities
that are reported in Section 8.8 are associated with
non-production related activities such as catastrophic
releases and remedial actions, as well as one-time
events not associated with routine production practices,
that were released directly to the environment or
transferred off-site forthe purposes of recycling, energy
recovery, treatment or disposal. Quantities reported in
Section 8.8 must not be reported in Sections 8.1
through 8.7.
2ง8.8 includes quantities of toxic chemical released on-site or
managed as waste off-site due to remedial actions, catastrophic events, or
one-time events not associated with the production processes.
C-8 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
' ' Reporting the production ratio in Section 8.9. A
production ratio or activity index must be provided in
Section 8.9. A zero is not acceptable and "NA" (Not
Applicable) can be used only when the reported EPCRA
section 313 chemical was not manufactured, processed, or
otherwise used in the year prior to the reporting year.
Calculating production ratio in Section 8.9. In
calculating a production ratio for "otherwise used"
chemicals, an activity index must be used rather than
quantities purchased or released from year to year.
Reporting source reduction activities in Section 8.10.
It is an error to report a source reduction activity in
Section 8.10 and not report at least one method used to
identify that activity and vice versa.
D. FDP Messages Used to Report Notices
of Significant Errors
1. You have used an invalid Form R or Form A by using
either a form not applicable for the reporting year, or a
facsimile form that has not been approved by EPA.
Resubmit your data on a current EPA approved Form R or
A.
2. Pages were missing from the form received. Correct this
by resubmitting a complete certified form for this
chemical substance.
3. Multiple chemicals reported in your Form R. You must
submit a separate and complete Form R for each chemical
cited.
4. You have provided a valid CAS number and a valid
chemical name, but they do not match. Respond by
providing a valid CAS Number and matching Chemical
Name.
5. You have left part or all of the chemical identification
sections blank. Respond by providing a valid CAS
Number and matching Chemical Name or Mixture
Component Identity.
6. You reported a CAS number and/or chemical name that
are invalid. Respond by providing a valid CAS Number
and/or matching Chemical Name.
7. Your form indicated Trade Secret status with an
indication that this form is a Sanitized version, but the
report contains no Generic Chemical Name. You must
provide a Generic Chemical Name for this sanitized form.
8. You did not sign the Form or certification letter. Per
EPCRA Section 313(g)(l)(B), each submission must
contain an original signature certifying the accuracy and
completeness of the information reported by signing the
certification statement on the Form or certified letter.
Please be sure to sign the certification statement in this
FDP to certify your submission data.
9. You have reported a Persistent Bioaccumulative Toxic
(PBT) chemical on a Form A. PBT chemicals (e.g.,
DioxinandDioxin-like Compounds, Lead Compounds,
Mercury Compounds and Polycyclic Aromatic
Compounds (PACs)) are not eligible for the alternate
threshold. Thus, they must be reported on a Form R.
Please resubmit your data on a Form R.
10. You did not indicate in part II, section 3 which
activity(ies) and use(s) of the EPCRA section 313
chemical occur at your facility. Please indicate at least
one of the activity (ies) anduse(s) of the EPCRA section
313 chemical occur at your facility.
11. You did not complete Part II, Sections 5 and 6 Please
provide the required information; otherwise indicate
NA.
12. You did not complete Part II, Section 7. Please provide
the required information; otherwise indicate NA.
13. You did not complete Part II, Section 8. Please provide
the required information; otherwise indicate NA.
E. Messages Used to Report Notices of
Technical Errors (NOTEs) and Non-
technical Data Changes (NDCs)
Invalid codes throughout Form R
14. You submitted an invalid code. To correct this, consult
the instructions for the proper table value and provide
a valid code value. [Specific location on the form of the
invalid code is given.] (NOTE)
15 PBT chemicals (e.g., Dioxin and Dioxin-like
Compounds, Lead Compounds, Mercury Compounds
and Polycyclic Aromatic Compounds (PACs)) are
ineligible for range reporting for on-site releases and
transfers off-site for further waste management. Please
provide specific release, transfer, and other waste
management values.(NOTE)
16. For aluminum (fume or dust) or zinc (fume or dust), the
Waste Management codes M56 and M92 are
unacceptable. Please provide the proper Waste
Management codes for these chemicals. (NOTE)
17. For asbestos (friable), the Waste Management codes
M56 and M92 are unacceptable. Please provide the
proper Waste Management codes for these chemicals.
(NOTE)
Toxics Release Inventory Reporting Forms and Instructions C-9
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Appendix C
General Errors for both the Form R and/or Form A
18. You reported a negative value for a release, transfer or
other waste management quantity. Please provide a non-
negative value for the specified part and section. (NOTE)
19. You have reported a value for a PBT chemical beyond
seven digits to the right of the decimal. EPA's data
management systems support data precision up to seven
digits to the right of the decimal. EPA has truncated
your numeric submission so the number of digits to the
right of the decimal do not exceed seven. If this was
incorrect, specify the correct value, not exceeding seven
digits to the right of the decimal. (NDC)
Errors in Part I, Facility Identification Information
20. No Public Contact name and/or telephone number was
listed. Please provide the name and telephone number of
your Public Contact. (NOTE)
21. No Technical Contact name and/or telephone number
was listed. Please provide the name and telephone
number of your Technical Contact. (NOTE)
22. The Federal Facility box was not checked on your form
but we believe you are a Federal Facility. Unless you
respond that you are not a Federal Facility, we will
continue to treat you as a Federal Facility. (NOTE)
23. A valid SIC code was not provided. Please provide at
least one valid primary four-digit SIC code. (NOTE)
24. You reported an invalid state code. If the address is in
the US, please use a valid US Postal Service state code
(see Table III of the Reporting Forms and Instructions).
If the address is not in the US, please enter a valid code
in the Country Field (see Table IV of the Reporting
Forms and Instructions) (NOTE)
25. Either Box A (An Entire Facility) or Box B (Part of a
Facility) should be checked in Part I, Section 4.2. One
of the 2 boxes must be checked, but not both. (NOTE)
26. If applicable, check either Box C (Federal Facility) or
Box D (GOCO) in Part I, Section 4.2, but do not check
both boxes. (NOTE)
27. You did not enter Longitude or Latitude values for the
facility. Please enter a Longitude and Latitude value.
(NOTE)
28. You entered an invalid Longitude/Latitude value(s).
Longitude degrees must be between 0 and 180, latitude
degrees must be between 0 and 90; minutes and seconds
for either latitude or longitude must be between 0 and 60.
(NOTE)
29. Dun and Bradstreet Numbers (Part I Section 4.7) are
typically 9 characters in length. Please check the
number(s) submitted. If they are incorrect, please make
the appropriate changes. If you believe that they are
correct, no further action is necessary. (NOTE)
30. EPA Identification Numbers (RCRA I.D. No. Part I
Section 4.8) are typically 12 characters in length. Please
check the number(s) submitted. If they are incorrect,
please make the appropriate changes. If you believe that
they are correct, no further action is necessary. (NOTE)
31. NPDES Permit Numbers (Part I, Section 4.9) are
typically 9 characters in length. Please check the
number(s) submitted. If they are incorrect, please make
the appropriate changes. If you believe that they are
correct, no further action is necessary. (NOTE)
32. Underground Injection Well Code (UIC) I.D. Numbers
(Part I, Section4.10) are typically 12 digits. Please check
the number(s) you have supplied. If they are incorrect,
please make appropriate changes. If youbelieve that they
are correct, no further action is necessary. (NOTE)
33. If this is a North American phone number, please enter
all 10 digits (i.e., include area code). If this is for
another country, please begin the phone number with
"Oil" as the prefix to your international telephone
number. (NOTE)
Errors in Part II, Section 1. Toxic Chemical Identity
34. You have correctly identified the chemical but have used
a synonym for the chemical name. EPA has changed the
Chemical Name to use the preferred TRI nomenclature.
Please specify the correct CAS Number and matching
Chemical Name. (NDC)
35. You reported a valid TRI CAS Number, a valid
Chemical Name, and a generic Chemical Name.
Therefore, the Generic Chemical Name was deleted. If
this was incorrect, specify the Generic Chemical Name
to be used. (NDC)
36. You reported a valid TRI CAS Number, a valid
Chemical Name, and a Mixture Component Identity.
Therefore, the Mixture Component Identity was deleted.
If this was incorrect, specify the Mixture Component
Identity to be used. (NDC)
37. EPA has changed the TRI chemical category code you
reported in Part II, Section 1.1 fromN151 toN150 (the
code was incorrectly listed in some pages of the
Reporting Forms and Instructions), the correct TRI
chemical category code for Dioxin and Dioxin-like
Compounds. If this is incorrect and you are not reporting
Dioxin and Dioxin-like Compounds, please specify the
correct CAS number or chemical category code and
C-10 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
matching chemical name.(NDC)
37a. You have reported for isopropyl alcohol (Only persons
who manufacture by the strong acid process are subject)
(CAS number 67-63-0). If you did not manufacture
isopropyl alcohol by the strong acid process, you have
submitted this form in error and should request that the
form be withdrawn. (NOTE)
Errors in Form R, Part II, Section 1.4. Dioxin and Dioxin-
like Compounds
38. EPA has deleted the entry of zeros in Part II, Section 1.4
because you indicated a CAS number or chemical
category in Part II, Section 1.1 other than Dioxin and
Dioxin-like Compounds. When reporting for a chemical
other than Dioxin and Dioxin-like Compounds, you
should leave Section 1.4 blank. (NDC)
39 You did not complete Section 1.4. If you report Dioxin
and Dioxin-like Compounds in Part II, Sections 1.1 or
1.2, you must complete ection 1.4. Please report the
distribution of chemicals included for Dioxin and
Dioxin-like Compounds. If you do not have speciation
data available, indicate NA. (NOTE)
40. Part II, Section 1.4 of your Form R contains data for
Dioxin and Dioxin-like Compounds. However, you have
indicated a CAS number or chemical category code in
Part II, Section 1.1 other than Dioxin and Dioxin-like
Compounds (N150). If you are reporting for Dioxin and
Dioxin-like Compounds, please provide the proper
chemical category code (N150). Otherwise please
indicate on the FDP that Section 1.4 should be left blank.
(NOTE)
41. You did not provide values in all 17 boxes in Part II,
Section 1.4 and/or the values do not total to 100%.
When reporting the distribution of each member of the
Dioxin and Dioxin-like Compounds category, you must
fill in each of the 17 boxes in Part II, Section 1.4 with
either 0 or a number between 0.01 and 100. The
summation of the 17 fields in Section 1.4 must equal
100. Please review Part II, Section 1.4 and enter values
where needed and/or adjust the percentages where
needed so that their summation equals 100%. (NOTE)
42. You reported numeric values in Part II, Section 1.4 for a
chemical that is not a Dioxin and Dioxin-like
Compounds. It appears that the information reported in
Part II, Section 1.4 is not valid. If you are reporting for
Dioxin and Dioxin-like Compounds, please indicate on
this FDP that the chemical category name in Part II,
Section 1.2 should be Dioxin and Dioxin-like
Compounds, or submit a new Form R. Otherwise,
please indicate on this FDP that the values in Part II,
Section 1.4 should be blank. (NOTE)
43. Part II, Section 1.4 of your Form R contains data for
Dioxin and Dioxin-like Compounds. However, you have
indicated both NA and zero. When reporting the
distribution of each member of the Dioxin and Dioxin-
like Compounds category, you must fill in each of the 17
boxes in Part II, Section 1.4 with either 0 or a number
between 0.01 and 100. The summation of the 17 fields
in Section 1.4 must equal 100. If you do not have
speciation data available, indicate NA rather than zero.
(NOTE)
Errors in Part II, Section 3. Activities and Uses of Toxic
Chemical At The Facility
44. You did not indicate in Part II, Section 3 which
activity(ies) or use(s) of the EPCRA section 313
chemical occur at your facility. In most cases, you do
need to indicate an activity or use in Sections 3.2 or 3.3
if you have indicated in Section 3.1 the chemical is for
"on-site use/processing". (NOTE)
Errors in Part II, Section 4. Maximum Amount of the
Toxic Chemical Onsite At Any Time During the Calendar
Year
45 You did not complete Part II, Section 4.1. Please provide
a valid two digit code for the "maximum amount of
chemical on-site at any time during the calendar year."
(NOTE)
Errors in Part II, Section 5. Quantity of the Toxic
Chemical Entering Each Environmental Medium Onsite
46. You did not complete Part II, Section 5.3. If you have
discharged to water, please provide the Stream/Water
Body name, the Release estimate or range code, Basis of
Estimate and % from Stormwater; otherwise indicate
"NA" (Not Applicable). (NOTE)
47. There are missing or incomplete data for Part II, Section
5.3. If you have discharged to water, please provide the
Stream/Water Body name, the Release estimate or range
code, Basis of Estimate and % from Stormwater;
otherwise indicate "NA" (Not Applicable). (NOTE)
48. You did not complete Part II, Section 5. Please provide
the Release estimate or range code and Basis of
Estimate; otherwise indicate "NA" (Not Applicable).
(NOTE)
49. There are missing or incomplete data for Part II, Section
5. Please provide the Release estimate or range code and
Basis of Estimate; otherwise indicate "NA" (Not
Applicable). (NOTE)
Errors in Part II, Section 6. Transfers of the Toxic
Chemical In Wastes To Off-Site Locations
50. You did not complete Part II, Section 6.1, "discharges to
POTW." If you did not discharge wastewater containing
the section 313 chemical to a POTW(s), enter "NA" (Not
Applicable), otherwise please provide the Transfer
Toxics Release Inventory Reporting Forms and Instructions C-l 1
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Appendix C
amount or range code, Basis of Estimate, POTW Name
and Location. (NOTE)
51. You reported a POTW(s) name and location but did not
provide a Transfer amount. Please provide a Total
Transfer amount or range code and Basis of Estimate;
otherwise, if there was no transfer to a POTW of
wastewater that contains or contained the section 313
chemical, delete the POTW location and indicate "NA"
(Not Applicable) for the POTW transfer amount.
(NOTE)
52. You reported a Total Transfer amount or range code and
Basis of Estimate in Part II Section 6.1 but did not
indicate a POTW name and location in Section 6.I.B.
Please provide the POTW Name and Location.
(NOTE)
53. You provided an incomplete POTW name and address.
Please provide the name and complete address for the
POTW. (NOTE)
54. There are missing or incomplete data for Part II, Section
6.1. Please provide the transfer amount or range code
and Basis of Estimate for Discharges to POTWs.
(NOTE)
55. You did not complete Part II, Section 6.2, "Transfers to
Other Off- site Locations." If you did not transfer the
waste containing the section 313 chemical to other off-
site locations, enter "NA" (Not Applicable), otherwise
please provide Offsite EPA ID, Name, Location,
Transfer amount or range code, Basis of Estimate, and
type of Waste Management code. (NOTE)
56. You reported an Off-site Transfer amount or range code
and Basis of Estimate in Part II Section 6.2 but did not
indicate an Off-site name and location in Section 6.2.
Please provide the Off-site Name and Location.
(NOTE)
57. You reported an Off-site name and location but did not
provide a Transfer amount. Please provide a Total
Transfer amount or range code, Basis of Estimate and
type of Waste Management code; otherwise, if there was
no transfer to this Off-site location, delete the Off-site
name and location and indicate "NA" (Not Applicable)
in the Off-site EPA Identification Number (RCRA ID
No.) field. (NOTE)
5 8. You reported an Off-site name and location, but there are
missing or incomplete data for the off-site transfer
amount, basis of estimate and type of waste management
code. Please provide the Off-site Transfer amount or
range code, Basis of Estimate, and type of Waste
Management code. (NOTE)
5 9. You provided incomplete off-site name and address data.
For a transfer to a domestic off-site location, you must
provide a street address, city, state, county and zip code.
For a transfer to a foreign off-site location, you must
provide a street address, city and a two character country
code. (NOTE)
60 You reported an invalid Type of Waste Management
code. For metals/metal compounds use only disposal and
certain recycling activities codes. Consult the Reporting
Instructions for metal and metal compounds and correct
with a valid Waste Management (i.e., "M") code.
(NOTE)
61 You reported an invalid Type of Waste Management
code. For Barium Compounds use only disposal and
certain recycling activities codes, M61Wastewater
Treatment (Excluding POTW) or M69Other Waste
Treatment. Consult the Reporting Instructions for metal
and metal compounds and correct with a valid Waste
Management (i.e., "M") code. (NOTE)
62. For non-metals codes M41 and M62 are unacceptable.
Provide the appropriate Disposal or Other Waste
Management code for this non-metal substance.
(NOTE)
Errors in Part II, Section 7. On-Site Waste Treatment
Methods and Efficiency
63. There are no data contained in all of Part II, Section 7 A.
If you do not treat wastes containing the EPCRA section
313 chemical at your facility, indicate "NA;" otherwise
please provide the general waste stream code, waste
treatment methods, range of influent concentration,
waste treatment efficiency estimate and whether this is
based on operating data for all on-site waste treatments
for this chemical. (NOTE)
64.
There are missing data in Part II, Section 7A. Please
provide the general waste stream code, waste treatment
methods, range of influent concentration, waste
treatment efficiency estimate and whether this is based
on operating data. (NOTE)
65.
There are no data in Part II, Section 7B. If no on-site
energy recovery processes are used for this section 313
chemical at your facility, indicate "NA;" otherwise
please provide at least one three-character on-site energy
recovery process code. (NOTE)
66. There are no data in Part II, Section 7C. If no on-site
recycling processes are used for this section 313
chemical at your facility, indicate "NA;" otherwise
please provide at least one three-character on-site
recycling process code. (NOTE)
Errors in Part II, Section 8. Source Reduction and
Recycling Activities
67. There are missing data for Part II, Section 8.1-8.7.
Please provide an estimate or "NA" (Not Applicable) in
each box for section 8.1-8.7, columns A, B, C, and D.
You may only use "NA" (Not Applicable) when there is
C-12 Toxics Release Inventory Reporting Forms and Instructions
-------
no possibility a release or transfer occurred. You may
enter zero if the release or transfer was equal to or less
than half a pound. (NOTE)
68. There are missing data in Part II, Section 8.8. Please
provide an estimate or "NA" (Not Applicable). You may
only use "NA" (Not Applicable) when there is no
possibility a release or transfer occurred. You may enter
zero if the release or transfer was equal to or less than
half a pound. (NOTE)
69. There are no data in Part II, Section 8.9. Please provide
a production ratio, an activity index, or "NA" (Not
Applicable) if the chemical manufacture or use began
during the current reporting year. (NOTE)
70. There are no data inPart II, Section 8.10. If your facility
did not engage in any source reduction activity for the
reported chemical, enter "NA" (Not Applicable) and
answer 8.11. Otherwise please provide Source
Reduction Activities and Methods code(s). (NOTE)
71. There are missing data in Part II, Section 8.10. Please
provide Source Reduction Activities and Methods
code(s). (NOTE)
72. Neither box was checked in section 8.11. Please check
one of the boxes in section 8.11 indicating if additional
information on source reduction, recycling, or pollution
control activities is included with your Form R report.
(NOTE)
Errors relating to the reconciliation of data in Part II,
Section 8 and Part II, Sections 5,6, and 7
73. You did not complete Sections 8.1-8.7 column B or 8.8.
If you report releases in Part II, Section 5 and/or an off-
site transfer in Section 6.2 and/or quantities transferred
off-site to POTWs in Section 6.1, you must report an
estimate in Part II, Sections 8.1 through 8.7 column B
and/or Section 8.8. (NOTE)
74. You did not complete Sections 5,6, or 7. If you enter an
estimate in Part II, Sections 8.1 through 8.7, column B
and/or Section 8.8, you must also report releases in Part
II, Section 5 and/or off-site transfers in Section 6.2
and/or quantities transferred off-site to POTWs in
Section 6.1 and/or waste treatment, energy recovery, or
recycling codes in Section 7. Please provide data for
Sections 5, 6, and/or 7. (NOTE)
75. You reported an estimate in Part II, Section 8.2, column
B, "Quantity Used for Energy Recovery On-site," but
did not provide an on-site energy recovery code in Part
II, Section 7B. Please provide an on-site energy recovery
code for Part II, Section 7B. (NOTE)
76. You reported an "On-site Energy Recovery Process"
code in Part II, Section 7B, but you did not provide an
estimate of the quantity used for energy recovery in Part
II, Section 8.2, column B. Please provide an estimate of
Appendix C
the quantity used for energy recovery for Part II, Section
8.2, column B. (NOTE)
77. You reported an estimate in Part II, Section 8.4, column
B "Quantity Recycled On-site" but did not provide an
on-site recycling code in Part II, Section 1C. Please
provide an on-site recycling code for Part II, Section 1C.
(NOTE)
78. You reported one or more on-site recycling process
codes in Part II, Section 1C but did not provide an
estimate in Part II, Section 8.4, column B, "Quantity
Recycled On-site." Please provide an estimate of the
quantity recycled for Section 8.4 column B. (NOTE)
Toxics Release Inventory Reporting Forms and Instructions C-13
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This Page Intentionally Left Blank
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Appendix D. Supplier Notification Requirements
Because manufacturers reporting under section 313 must know
the EPCRA section 313 chemical composition of the products
they use to be able to accurately calculate releases, EPA
requires some suppliers of mixtures or other trade name
products containing one or more of the EPCRA section 313
chemicals to notify their customers. This requirement has been
in effect since January 1, 1989.
This appendix explains which suppliers must notify their
customers, who must be notified, what form the notice must
take, and when it must be sent.
Who Must Supply Notification
You are covered by the section 313 supplier notification
requirements if you own or operate a facility which meets all
of the following criteria:
(1) Your facility is in Standard Industrial Classification
[SIC] codes 20-39;
(2) You manufacture (including import) or process an
EPCRA section 313 chemical; and
(3) You sell or otherwise distribute a mixture or other trade
name product containing the EPCRA section 313
chemical to either:
A facility in a covered SIC code (see Table I).
A facility that then may sell the same mixture or
other trade name product to a firm in a covered
SIC code (see Table I).
Note that you may be covered by the supplier notification
rules even if you are not covered by the section 313 release
reporting requirements. For example, even if you have
fewer than 10 full-time employees or do not manufacture or
process any of the EPCRA section 313 chemicals in sufficient
quantities to trigger the release and other waste management
reporting requirements, you may still be required to notify
certain customers.
Who Must Be Notified
Also, note that beginning with the 1998 reporting year, seven
new industries are now covered by most of the EPCRA section
313 reporting requirements. These new industries are not
required to comply with most of the supplier notification
requirements. Industries whose primary SIC code is not within
20 through 39 are not required to initiate the distribution of
notifications for EPCRA section 313 chemicals in mixtures or
other trade name products that they send to their customers.
However, if these facilities receive notifications from their
suppliers about EPCRA section 313 chemicals in mixtures or
other trade name products, they should forward the
notifications with the EPCRA section 313 chemicals they send
to other covered users.
An example would be if you sold a lacquer containing toluene
to distributors who then may sell the product to other
manufacturers. The distributors are not in a covered SIC code,
but because they sell the product to companies in covered SIC
codes, they must be notified so that they may pass the notice
along to their customers, as required.
The language of the supplier notification requirements covers
mixtures or other trade name products that are sold or
otherwise distributed. The "otherwise distributes" language
applies to intra-company transfers. However, if the company
has developed an internal communications procedure that
alerts their other facilities to the presence and content of
covered EPCRA section 313 chemicals in their products, then
EPA would accept this.
Note that beginning with the first shipments in 1998, facilities
in SIC codes 20-39 will be required to also notify facilities in
the newly added industry groups.
Supplier Notification Must Include the
Following Information:
(1) A statement that the mixture or other trade name product
contains an EPCRA section 313 chemical or chemicals
subject to the reporting requirements of EPCRA section
313(40CFR372);
(2) The name of each EPCRA section 313 chemical and the
associated Chemical Abstracts Service (CAS) registry
number of each chemical if applicable. (CAS numbers
are not used for chemical categories, since they can
represent several individual EPCRA section 313
Toxics Release Inventory Reporting Forms and Instructions D-l
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Appendix D
chemicals.); and
(3) The percentage, by weight, of each EPCRA section 313
chemical (or all EPCRA section 313 chemicals within a
listed category) contained in the mixture or other trade
name product.
For example, if a mixture contains a chemical (i.e., 12 percent
zinc oxide) that is a member of a reportable EPCRA section
313 chemical category (i.e., zinc compounds), the notification
must indicate that the mixture contains a zinc compound at 12
percent by weight. Supplying only the weight percent of the
parent metal (zinc) does not fulfill the requirement. The
customer must be told the weight percent of the entire
compound within an EPCRA section 313 chemical category
present in the mixture.
How the Notification Must Be Made
The required notification must be provided at least annually in
writing. Acceptable forms of notice include letters, product
labeling, and product literature distributed to customers. If
you are required to prepare and distribute a Material Safety
Data Sheet (MSDS) for the mixture under the Occupational
Safety and Health Act (OSHA) Hazard Communication
Standard, your section 313 notification must be attached to the
MSDS or the MSDS must be modified to include the required
information. (A sample letter and recommended text for
inclusion in an MSDS appear at the end of this appendix.)
You must make it clear to your customers that any copies or
redistribution of the MSD S or other form of notification must
include the section 313 notice. In other words, your customers
should understand their requirement to include the section 313
notification if they give your MSDS to their customers.
When Notification Must Be Provided
In general, you must notify each customer receiving a mixture
or other trade name product containing an EPCRA section 313
chemical with the first shipment of each calendar year. You
may send the notice with subsequent shipments as well, but it
is required that you send it with the first shipment each year.
Once customers have been provided with an MSD S containing
the section 313 information, you may refer to the MSDS by a
written letter in subsequent years (as long as the MSDS is
current).
If EPA adds EPCRA section 313 chemicals to the section 313
list, and your products contain the newly added EPCRA
section 313 chemicals, notify your customers with the first
shipment made during the next calendar year following EP Aปs
final decision to add the chemical to the list. For example, if
EPA adds chemical ABC to the list in September 1998,
supplier notification for chemical AB C would have begun with
the first shipment in 1999.
You must send a new or revised notice to your customers if
you:
(1) Change a mixture or other trade name product by
adding, removing, or changing the percentage by
weight of an EPCRA section 313 chemical; or
(2) Discover that your previous notification did not
properly identify the EPCRA section 313 chemicals in
the mixture or correctly indicate the percentage by
weight.
In these cases, you must:
(1) Supply a new or revised notification within 30 days of
a change in the product or the discovery of
misidentified EPCRA section 313 chemical(s) in the
mixture or incorrect percentages by weight; and
(2) Identify in the notification the prior shipments of the
mixture or product in that calendar year to which the
new notification applies (e.g., if the revised notification
is made on August 12, indicate which shipments were
affected during the period January 1-August 12).
When Notifications Are Not Required
Supplier notification is not required for a "pure" EPCRA
section 313 chemical unless a trade name is used. The identity
of the EPCRA section 313 chemical will be known based on
label information.
You are not required to make a "negative declaration." That
is, you are not required to indicate that a product contains no
EPCRA section 313 chemicals.
If your mixture or other trade name product contains one of the
EPCRA section 313 chemicals, you are not required to notify
your customers if:
(1) Your mixture or other trade name product contains the
EPCRA section 313 chemical in percentages by weight
of less than the following levels (These are known as de
minimis levels)
0.1 percent if the EPCRA section 313 chemical is
defined as an "OSHA carcinogen;"
D-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix D
' ' 1 percent for other EPCRA section 313 chemicals.
De minimis levels for each EPCRA section 313 chemical
and chemical category are listed in Table II. PBT
chemicals (except lead when contained in stainless steel,
brass or bronze alloys) are not eligible for the de minimis
exemption. Therefore, de minimis levels are not provided
for these chemicals in Table II. However, for purposes of
supplier notification requirements only, such notification
is not required when the following PBT chemicals are
contained in mixtures below their respective de minimis
levels:
Chemical or chemical
category name
Aldrin
Benzo [g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds
(manufacturing; and the
processing or otherwise
use of dioxin and dioxin-
like compounds if the
dioxin and dioxin-like
compounds are present as
contaminants in a
chemical and if they were
created during the
manufacturing of that
chemical
Heptachlor
Hexachlorobenzene
Isodrin
Lead
Lead compounds
Mercury
Mercury compounds
Methoxychlor
Octachlorostyrene
Pendimethalin
CAS
number or
chemical
category
code
309-00-2
191-24-2
57-74-9
N150
76-44-8
118-74-1
465-73-6
7439-92-1
N420
7439-97-6
N458
72-43-5
29082-74-4
40087-42-1
Supplier
notification
limit (%)
1.0
1.0
0.1
1.0*
0.1
0.1
1.0
0.1
0.1**
1.0
1.0
1.0
1.0
1.0
Pentachlorobenzene
Fob/chlorinated
biphenyls (PCBs)
Polycyclic aromatic
compounds category
Tetrabromobisphenol A
Toxaphene
Trifluralin
608-93-5
1336-36-3
N590
79-94-7
8001-35-2
1582-09-8
1.0
0.1
0 i***
1.0
0.1
1.0
*The de minimis is 1.0 for all members except for
2,3,7,8-Tetrachlorodibenzo-/>-dioxin which has a 0. 1%
de minimis.
**The de minimis is 0.1 for inorganic lead compounds
and 1.0 for organic lead compounds
***The de minimis is 0.1 except for
benzo(a)phenanthrene, dibenzo(a,e)fluoranthene,
benzo(j,k)fluorene, and 3-methylcholanthrene which are
subject to the 1.0% de minimis.
(2) Your mixture or other trade name product is one of the
following:
An article that does not release an EPCRA section 313
chemical under normal conditions of processing or
otherwise use.
Foods, drugs, cosmetics, alcoholic beverages, tobacco,
or tobacco products packaged for distribution to the
general public.
Any consumer product, as the term is defined in the
Consumer Product Safety Act, packaged for
distribution to the general public. For example, if you
mix or package one-gallon cans of paint designed for
use by the general public, notification is not required.
(3) You are initiating distribution of a mixture or other
trade name product containing one or more EPCRA
section 313 chemicals and your facility is in any of the
newly covered SIC codes including facilities whose
SIC code is within SIC major group codes 10 (except
1011, 1081, and 1094), 12 (except 1241); industry
codes 4911 (limited to facilities that combust coal
and/or oil for the purpose of generating power for
distribution in commerce), 4931 (limited to facilities
that combust coal and/or oil for the purpose of
generating power for distribution in commerce), or
4939 (limited to facilities that combust coal and/or oil
for the purpose of generating power for distribution in
commerce); or 4953 (limited to facilities regulated
Toxics Release Inventory Reporting Forms and Instructions D-3
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Appendix D
under the Resource Conservation and Recovery Act,
subtitle C, 42 U.S.C. Section 6921 et seq.) or 5169,
or 5171, or 7389 (limited to facilities primarily
engaged in solvents recovery services on a contract
or fee basis).
Trade Secrets
(4) If claiming a specific concentration a trade secret, you
should record explanations of why a specific
concentration is considered a trade secret and the basis
for the upper bound concentration limit.
This information must be readily available for inspection by
EPA.
Chemical suppliers may consider the chemical name or the
specific concentration of an EPCRA section 313 chemical in
a mixture or other trade name product to be a trade secret. If
you consider the:
(1) Specific identity of an EPCRA section 313 chemical to be
a trade secret, the notice must contain a generic chemical
name that is descriptive of the structure of that EPCRA
section 313 chemical. For example, decabromodiphenyl
oxide could be described as a halogenated aromatic.
(2) Specific percentage by weight of an EPCRA section 313
chemical in the mixture or other trade name product to be
a trade secret, your notice must contain a statement that
the EPCRA section 313 chemical is present at a
concentration that does not exceed a specified upper
bound. For example, if a mixture contains 12 percent
toluene and you consider the percentage a trade secret, the
notification may state that the mixture contains toluene at
no more than 15 percent by weight. The upper bound
value chosen must be no larger than necessary to
adequately protect the trade secret.
If you claim this information to be trade secret, you must have
documentation that provides the basis for your claim.
Recordkeeping Requirements
You are required to keep records for three years of the
following:
(1) Notifications sent to recipients of your mixture or other
trade name product;
(2) All supporting materials used to develop the notice;
(3) If claiming a specific EPCRA section 313 chemical
identity a trade secret, you should record why the EPCRA
section 313 chemical identity is considered a trade secret
and the appropriateness of the generic chemical name
provided in the notification; and
D-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix D
Sample Notification Letter
January 2, 2002
Mr. Edward Burke
Furniture Company of North Carolina
1000 Main Street
Anytown, North Carolina 99999
Dear Mr. Burke:
This letter is to inform you that a product that we sell to you, Furniture Lacquer KXZ-1390, contains one or more chemicals
subject to section 313 of Emergency Planning and Community Right-to-Know Act (EPCRA). We are required to notify you of
the presence of these chemicals in the product under EPCRA section 313. This law requires certain industrial facilities to report
on annual emissions and other waste management of specified EPCRA section 313 chemicals and chemical categories. Our
product contains:
Toluene, Chemical Abstract Service (CAS) number 108-88-3, 20 percent, and
Zinc compounds, 15 percent.
If you are unsure whether you are subject to the reporting requirements of EPCRA section 313, or need more information, call
EPA's EPCRA Call Center at (800) 424-9346 or (703) 412-9810. Your other suppliers should also be notifying you about
EPCRA section 313 chemicals in the mixtures and other trade name products they sell to you.
Finally, please note that if you repackage or otherwise redistribute this product to industrial customers, a notice similar to this one
must be sent to those customers.
Sincerely,
Emma Sinclair
Sales Manager
Furniture Products
Toxics Release Inventory Reporting Forms and Instructions D-5
-------
Appendix D
Sample Notification on an MSDS Furniture Products
Section 313 Supplier Notification
This product contains the following EPCRA section 313 chemicals subject to the reporting requirements of section 313
of the Emergency Planning and Community Right-To-Know Act of 1986 (40 CFR 372):
CAS Number Chemical Name Percent by Weight
108-88-3 Toluene 20%
NA Zinc Compounds 15%
This information should be included in all MSDSs that are copied and distributed for this material.
Material Safety Data Sheet
D-6 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix E. How To Determine Latitude and Longitude From
Topographic Maps
Latitude and longitude coordinates of reporting facilities
are very important for pinpointing facility location and are
a required data element on Form R. As such, EPA is
encouraging facilities to make the best possible
measurements when determining latitude and longitude.
As with any other data element, missing, suspect, or
incorrect data may result in EPA issuing a Notice of
Technical Error to the facility.
Latitude is the distance north or south of the equator.
Longitude is the distance east or west of the prime
meridian (Greenwich, England). Latitude and longitude
are measured in degrees, minutes, and seconds.
60" (seconds) = 1' (minute)
60' (minutes) = 1 "(degree)
The most important tool available for determining latitude
and longitude for your facility is the U.S. Geological
Survey (USGS) topographic quadrangle map. These maps
are published in varying degrees of detail. The most
detailed version of the topographic quadrangle map is in
7.5 x 7.5 minute increments with a scale of 1:24000 (i.e.,
one inch on the map represents 2,000 feet). Detailed
topographic quadrangle maps are also available in7.5 x 15
minute increments with a scale of 1:250,000 (i.e., one inch
on the map represents approximately four miles). It is
very important that latitude and longitude measurements
be made from one of the detailed maps described above.
Otherwise, measurements will not accurately reflect the
location of your facility and could be identified as an error
on your Form R submission.
In order to identify the detailed topographic quadrangle
map in which your facility is located, the USGS has
published an index and a catalog of topographic maps
available for each state. Both the index and the catalog
are available in many libraries or free of charge from the
Distribution Branch of the USGS (address on following
page). The Index to Topographic and Other Map
Coverage helps you to identify the most detailed map in
which your facility is located. To identify the most
detailed map, follow these simple steps on how to use the
index:
(1) The beginning of each index contains a map of the
state, broken into numbered quadrangular sections.
The numbered quadrangular sections are called
general areas of interest. Identify the numbered
section in which your facility is located.
(2) The subsequent pages of the index contain detailed
maps of each general area of interest, in numerical
order. Identify the detailed map corresponding to the
numbered general area of interest identified in Step
1.
(3) Within this detailed map, identify the smaller
quadrangular area in which your facility is located.
This smaller quadrangular section is the specific area
of interest. Record first the letter then the number
coordinate for your specific area of interest (e.g.,
E4).
(4) Using the chart found on the same page as the
detailed map of the general area of interest, record
the name of the specific area of interest in which
your facility is located, identified by the letter and
number coordinates (e.g., Richmond).
The name of the specific area of interest and its
corresponding letter and number coordinates identify the
most detailed topographic quadrangle map in which your
facility is located. To identify the map reference code and
file number necessary to order this map, follow these
simple steps for using the Catalog of Topographic and
Other Published Maps for the state in which your facility
is located:
(5) The beginning of the catalog explains the meaning of
the reference code. On the pages following this
explanation, there are charts listed alphabetically by
the name of the specific area of interest with
corresponding file numbers and map reference
codes. Using the name of the specific area of
interest recorded in Step 4, identify the file number
and map reference code from the chart for the map in
which your facility is located (e.g., file number
00692, map reference code 37977-E4-TF-024-00).
(6) Use the file number and map reference code to
obtain the specific topographic quadrangle map in
which your facility is located.
These detailed topographic quadrangle maps are available
in many libraries or for purchase from the Distribution
Branch of the USGS and from private map dealers. The
Catalog of Topographic and Other Published Maps
contains a list of map depository libraries and topographic
map dealers for each state covered in the catalog.
To purchase a topographic quadrangle map from the
USGS, you must send a written request to the Distribution
Branch of the USGS, containing the file number, map
reference code, the name of the city, state and zip code in
which your facility is located, payment of $4.00 per map
sheet and a handling charge of $3.50 for each order
mailed.
Toxics Release Inventory Reporting Forms and Instructions E-l
-------
Appendix E
The Distribution Branch of the USGS can be reached at:
Distribution Branch of the USGS
P.O. Box 25286
Denver Federal Center
Denver, CO 80225
(303) 202-4700
ALLOW 5 WEEKS FOR DELIVERY
In addition, you may purchase a topographic quadrangle
map from the USGS through a USGS Public Inquiry
Office. The Public Inquiry Offices are listed for each state
on the inside back cover of the Catalog of Topographic
and Other Published Maps.
If you need help in determining your latitude and
longitude, once you have the necessary map, the Earth
Science Information Center can provide assistance:
1-888-ASK-USGS
ask@usgs.gov
Please call in advance of the section 313 reporting
deadline to avoid unnecessary delays.
Determining Your Facility's
Latitude and Longitude
(See diagram next page.)
Once you have obtained the correct map for your facility:
(1) Mark the location of your facility on the map with a
point. If your facility is large, choose a point central
to the production activities of the facility. If certain
structures inyourfacility are represented on the map,
mark one of the structures with a point.
(2) Construct a small rectangle around the point with
fine pencil lines connecting the nearest 2.5' or 5'
graticules. Graticules are intersections of latitude
and longitude lines that are marked on the map edge,
and appear as black crosses at four points in the
interior of the map.
(3) Read and record the latitude and longitude (in
degrees, minutes, and seconds) for the southeast
corner of the small quadrangle drawn in step two.
The latitude and longitude are printed at the edges of
the map.
(4) To determine the increment of latitude above the
latitude line recorded in step 3,
position the map so that you face west;
place the ruler in approximately a north-south
alignment, with the "0" on the latitude line
recorded in step 3 with the ruler edge intersecting
the point.
Without moving the ruler, read and record:
the measurement from the latitude line to the
desired point (the point distance);
the measurement from the latitude line to the
north line of the small quadrangle (the total
distance).
Determine the number of seconds to be added to the
latitude recorded in step 3 by using the ratio:
Point distance x 150" = increment of latitude
Total distance
between lines
[Note: 150" is the number of seconds of arc for the side of
the small quadrangle on a 7.5' map. If you are using a 15'
map, the multiplication factor is 300" instead of 150" since
each graticule is 5' of latitude or longitude.]
For example:
Point distance
Total distance
99.5
192.0
99.5 x 150"
192.0
77.7"
01'17.7"
(60" = 1'; 77.7" = 60" + 17.7" = 01' 17.7")
Latitude in step 3
Increment
Latitude of point
32ป17'30"
+ Ori7.7"
32ป18'47.7"
to the nearest second = 32ป18'48"
(5) To determine the increment of longitude west of the
longitude line recorded in step 3,
position the map so that you face south;
place the ruler in approximately an east-west
alignment with the "0" on the longitude line
recorded in step 3 with the ruler edge intersecting
the point.
Without moving the ruler, read and record:
E-2 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix E
the measurement from the longitude line to the
desired point (the point distance);
the measurement from the longitude
line to the west line of the small quadrangle
(the total distance).
Determine the number of seconds to be added to the
longitude recorded in step 3 by using the ratio:
Point distance x 150" = increment of longitude
total distance
between lines
For example:
Point distance
Total distance
65.0
149.9
65.0 xl50" = 65" = 01'05"
149.9
(60" = 1'; 65" = 60" + 05" = Ol'OS")
Longitude in step 3 78ป85'00"
Increment + 01'05"
Longitude of point 78ป86'05"
to the nearest second = 78ป66'05"
You should use positive coordinates when determining
longitude.
Note: Use the appropriate address for submission of
Form R reports to your State. In addition, many
States have additional state reporting requirements.
Check with your State contact on any State
requirements.
Toxics Release Inventory Reporting Forms and Instructions E-3
-------
Appendix E
Latitude/Longitude Diagram
Point Latitude 32ฐ18'48" North, Longtitude 78ฐ06'05" West
Note: This diagram is based on a USGS 7.5 Minute Series Topographic Map.
It is not drawn to scale.
1_
WEST
POINT
QUADRANGLE
NORTH
+
GRATICULE
SOUTH
32ฐ22'30"
32ฐ20'00"
EAST
32ฐ17'30"
78ฐ05'00"
78ฐ02'30"
32ฐ15'00"
78ฐ00'00"
E-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix F. State Designated Section 313 Contacts
Submitting by Diskette to States: As of the
publication of this book the following states
confirmed that they accept diskette submissions.
Do not send submissions via email.
AK
AL
AZ2
CA
CO
DE
FL
GA
HI
IA
ID
IL
IN
KS
LA
MD
MI
MN
MO
MT
ND
NH
NJ
NM
NV
NY
OH
OK
OR
PA
sc1
SD
TX
UT
VA
VT
WA
WI
WV
WY
If your state is not listed here, please contact
your state office to confirm that paper
submissions are required.
Alabama
Mr. Kirk Chandler
Alabama Emergency Response Commission
Alabama Department of Environmental
Management
P.O. Box 301463
Montgomery, AL 36130-1463
(334) 260-2717; fax (334) 272-8131
kfc(@,adem.state.al.us
Alaska
Ms. Camille Stephens
Department of Environmental Conservation
Government Preparedness and Response Program
410 Willoughby Ave., Suite 105
Juneau, AK 99801-1795
(907) 465-5220; fax (907) 465-5244
cstephen(@,envircon.state.ak.us
American Samoa
Mr. Togipa Tausaga
American Samoa EPA
American Samoa Government
Office of the Governor
Pago Pago, AS 96799
International Number (684) 633-2304;
fax (684) 633-5801
asepa(@,samoatelco. com
Arizona2
Mr. Daniel Roe, Executive Director
Arizona Emergency Response Commission
5636 East McDowell Road
Phoenix, AZ 85008
(602) 231-6345; fax (602)392-7519
roed@,dem. state.az.us
Mr. Bill Quinn
Arizona Department of Environmental Quality
Pollution Prevention Program, Mail Stop M0636B
3033 N. Central
Phoenix, AZ 85012
(602) 207-4203; fax (602) 207-4538
quinn.bill(@,ev.state.az.us
Arkansas
Mr. Robert Johns
Arkansas Dept. of Emergency Management
P.O. Box 758
Conway, AR 72203-0758
(501) 730-9790; fax (501) 730-9754
robert.iohns(g),adem.state.ar.us
Certified Mail ONLY
Mr. Robert Johns
Arkansas Dept. of Emergency Management
1835 South Donaghey
Conway, AR 72032
South Carolina accepts only diskette submissions.
Arizona Emergency Response Commission accepts
electronic submissions while the Arizona Dept. of Environmental
Quality accepts only paper submissions. Submissions must be sent to
both agencies.
Toxics Release Inventory Reporting Forms and Instructions F-l
-------
Appendix F
California
Coordinator
California Environmental Protection Agency
Office of Environmental Information Management
P.O. Box 806
Sacramento, CA 95812-0806
Attn: Toxics Release Inventory
(916) 324-3421; fax (916) 324-1788
Certified or Express Mail Only
California Environmental Protection Agency
Office of Environmental Information Management
400 P Street
Sacramento, CA 95812
Attn: Toxics Release Inventory
Colorado
Mr. Kirk Mills
Pollution Prevention Program
Colorado Department of Public Health and
Environment
4300 Cherry Creek Drive South
Denver, CO 80246-1530
(303) 692-2977; fax (303) 782-4969
kirk.mills(@,state.co.us
http://www.cdphe.state.co.us/environ.asp
Commonwealth of Northern Mariana Islands
Mr. Ignacio V. Cabrera, Director
Division of Environmental Quality
Commonwealth of the Northern Mariana Islands
P.O. Box 1304
Saipan, MP 96950
International Number (670) 664-8500; fax (670)
664-8540
deq.director(@,saipan.com
Connecticut
Mr. Joseph Pulaski
SERC Administrator
Department of Environmental Protection
79 Elm Street, 4th Floor
Hartford, CT 06106-5127
(860) 424-3373; fax (860) 424-4059
i oseph.pulaski(@,po. state .ct. us
Delaware
Mr. David Fees
Delaware Natural Resource and Environment Control
EPCRA Reporting Program
Air Quality Management Section
156 S. State Street
Dover, DE 19901
(302) 739-4791; fax (302) 739-3106
dfees(@,dnrec.state.de.us
District of Columbia
Ms. Michele Penick
Environmental Planning Specialist
Emergency Response Commission for Title III
2000 14th Street, NW, 8th Floor
Washington, DC 20009
(202) 673-2101, ext. 1159; fax (202) 673-2290
mpenick-oep(g),dcgov.org
Florida
Mr. Sam Brackett
State Emergency Response Commission
Florida Department of Community Affairs
2555 Shumard Oak Blvd.
Tallahassee, FL 32399-2100
(850) 413-9970; fax (850) 488-1739
sam.brackett(@,dca. state .fl.us
Georgia
Dr. Bert K. Langley
Georgia Environmental Protection Division
7 Martin Luther King, Jr. Drive, Room 643
Atlanta, GA 30334
(404) 656-6905; fax (404) 657-7893
bert langlev(fl),mail.dnr.state.ga.us
Guam
Ms. Conchita S.N Taitano, Division Administrator
Guam Environmental Protection Agency
Air and Land Division
P.O. Box 20439
Barrigada, GU 96921
International Number (671) 646-8863;
fax (671)477-9402
taitano(@,kuentos. guam.net
F-2 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix F
Hawaii
Mr. Denis Shimamoto
Hawaii State Emergency Response Commission
Hawaii Department of Health
919 Ala Moana Blvd., Room 206
Honolulu, HI 96814
(808) 586-4694; fax (808) 586-7537
heer(g),eha.health.state.hi.us
Idaho
Mr. Bill Bishop
Bureau of Hazardous Materials
4040 Guard Street, Bldg. 600
Gowen Field
P.O. Box 83720
Boise, ID 83705-5004
(208) 422-5725; fax (208) 442-4485
bbishop(@,bds. state, id.us
Illinois
Mr. Stan Ostrem
Office of Environmental Policy & Science #26
Illinois Environmental Protection Agency
1021 N. Grand Avenue, East
P.O. Box 19276
Springfield, IL 62794-9276
(217) 785-3557; fax (217) 782-1312
epa8579(@,epa.state.il.us
Certified or Express Mail ONLY
Mr. Stan Ostrem
Office of Environmental Policy & Science #26
Illinois Environmental Protection Agency
1021 N. Grand Avenue, East
Springfield, IL 62702
Indiana
Harry Davis, Environmental Engineer
OPPTA/Pollution Prevention Branch
Indiana Dept. of Environmental Management
100 North Senate Ave.
P.O.Box 6015
Indianapolis, IN 46206-6015
(317) 232-8188; fax (317) 232-5627
hdavis(o),dem.state.in.us
www.state.in.us/idem/oppta
Iowa
Stuart Schmitz, Supervisor
Contaminated-Sites Section
Iowa Department of Natural Resources
900 E. Grand Avenue
DesMoines, IA50319
(515) 242-5241; fax (515) 281-8895
stuart. schmitz(@,dnr. state.ia.us
Kansas
Mr. Scott Bangert
Kansas Dept. of Health and Environment
Right-to-Know Program
J Street and 2 North
Forbes Field Building 283
Topeka, KS 66620
(785) 296-1689; fax (785) 296-1545
sbangert@kdhe.state.ks.us
Kentucky
Mr. Alex Barber
Kentucky Department for Environmental Protection
14 Reilly Road
Frankfort, KY 40601-1132
(502) 564-2150; fax (502) 564-4245
barber(g)nrpath.state.kv.us
Louisiana
Ms. Linda Brown
Department of Environmental Quality
Office of Environmental Assessment Evaluation
Division
P.O. Box 82178
Baton Rouge, LA 70884-2178
(225) 765-0305; fax (225) 765-0617
lindab(@,deq. state.la.us
Certified Mail/FedEx
Linda Brown
Department of Environmental Quality
Office of Environmental Assessment
7290 Bluebonnet Boulevard
Baton Rouge, LA 70810
Toxics Release Inventory Reporting Forms and Instructions F-3
-------
Appendix F
Maine
TRI Coordinator
Senior Hazardous Materials Planner
State Emergency Management Agency
72 State House Station
Augusta, ME 04333-0072
(207) 626-4503; fax (207) 626-4499
robert.s.gardner(@,state.me.us
Maryland
Ms. Patricia Williams
MDE/TARSA
Community Right-to-Know
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3800; fax (410) 631-3873
pwilliams(@,mde.state.md.us
Massachusetts
Mr. Walter Hope
Massachusetts Department of Environmental
Protection
Bureau of Waste Prevention
1 Winter Street
Boston, MA 02108
(617) 292-5982; fax (617) 292-5858
walter.hope(@,state.ma.us
Michigan
Mr. Robert Jackson
State Emergency Planning and Community
Right-to-Know
Michigan Dept. of Environmental Quality
Environmental Assistance Division
P.O. Box 30457
Lansing, MI 48909
(517) 373-2731; fax (517) 241-7966
JACKSORC(fl),state.mi.us
Certified Mail ONLY
Mr. Robert Jackson
State Emergency Planning and Community
Right-to-Know
Michigan Dept. of Environmental Quality
Environmental Assistance Division
333 S. Capitol
Town CTR, 2nd Floor
Lansing, MI 48933
Minnesota
Mr. Steve Tomlyanovich
Department of Public Safety
Emergency Response Commission
444 Cedar Street, Suite 223
StPaul,MN55101
(651) 282-5396; fax (651) 296-0459
steve.tomlyanovich(@,state.mn.us
Mississippi
Mr. John David Burns, TRI Coordinator
Mississippi Department of Environmental Quality
P.O. Box 20305
Jackson, MS 39289-1305
(601) 961-5005; fax (601) 961-5660
Community Right-to-Know Hotline 1 (800) 535-0202
John burns(@,deq.state.ms.us
Certified Mail ONLY
John David Burns
Mississippi Dept. of Environmental Quality
1410 Riverside Drive
Jackson, MS 39202
Missouri
Mr. Gene Nickel
Technical Assistance Program
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
(573) 526-6627; fax (573) 526-5808
nrnicke(@,dnr.state.mo.us
Certified Mail ONLY
Gene Nickel
Technical Assistance Program
Missouri Department of Natural Resources
1659 East Elm Street
Jefferson City, MO 65101
Montana
Mr. Tom Ellerhoff
Montana Emergency Response Commission DEQ
Metcalf Building
1520 East 6th Avenue
Helena, MT 59620-0901
(406) 444-5263; fax (406) 444-4386
tellerhoff(@,state.mt.us
F-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix F
Navajo Nation
Ms. Derrith Watchmen, Executive Director
Navajo Environmental Protection Agency
P.O. Box 339
Window Rock, AZ 86515
(520) 871-7692
Fax: (520) 871-7261
Nebraska
Mr. Donnie Zach
SARA Title III Coordinator
Nebraska Environmental Quality
P.O. Box 98922
Lincoln, NE 68509-8922
(402) 471-4251; fax: (402) 471-2909
donnie.zach(@,mail.deq.state.ne.us
Certified Mail ONLY
Donnie Zach
SARA Title III and NEPCRA Coordinator
Nebraska Dept of Environmental Quality
1200 N Street, Suite 400
Lincoln, NE 68509
Nevada
Ms. Alene Coulson
Nevada Division Environmental Protection
333 West Nye Lane, Room 138
Carson City, NV 89706-0851
(775) 687-4670, ext. 3006; fax: (775) 687-6396
acoulson(@,govmail.state.nv.us
Form R Package ONLY
Alene Coulson
c/o State Emergency Response Commission
555 Wright Way
Carson City, NV 89711-0925
New Hampshire
Mr. Leland Kimball
New Hampshire Office of Emergency
Management Agency, Title III Program
State Office Park South
107 Pleasant Street
Concord, NH 03301
(603) 271-2231; fax (603) 225-7341
leek(@,nhoem.state.nh.us
New Jersey
Mr. Andrew Opperman
Department of Environmental Protection
EPCRA Section 313
Bureau of Chemical Release Information & Prevention
P.O. Box 405
Trenton, NJ 08625-0405
(609) 292-6714; fax (609) 633-7031
aopperma(@,dep.state.ni .us
New Mexico
Mr. Max Johnson, Coordinator
New Mexico Emergency Response Commission
Hazardous Materials Bureau
P.O. Box 1628
Santa Fe, NM 87504-1628
(505) 476-9620; fax (505) 476-9695
MjohnsontglDPS.state.nm.us
Certified Mail ONLY
Mr. Max Johnson, Coordinator
New Mexico Emergency Response Commission
Hazardous Materials Bureau
Emergency Management Bureau
4491 Cerrillos Road
Santa Fe,NM 87505
New York
Mr. Sitansu Ghosh
New York State Department of Enviromental
Conservation
Pollution Prevention Unit
625 Broadway, 12th Floor
Albany, NY 12233-8010
(518) 402-9492; fax: (518) 401-9021
sbghoshfg.gw.dec.state.nv.us
North Carolina
Anthony B. Bonapart
NC Division of Emergency Management
4714 Mail Service Center
Raleigh, NC 27699-4714
(919) 733-3899; fax (919) 733-2860
Hotline: (919) 733-1361
1-800-541-1403 (NConly)
Abonapart@,ncem.org
Toxics Release Inventory Reporting Forms and Instructions F-5
-------
Appendix F
North Dakota
Mr. Ray De Boer
North Dakota State Division of Emergency
Management
P.O. Box 5511
Bismarck, ND 58506-5511
(701) 328-8100; fax (701) 328-8181
rdeboer(@,state.nd.us
Certified Mail ONLY
Ray DeBoer
ND State Division of Emergency Management
Fraine Barracks Road, Building 35
Bismarck, ND 58506-5511
Ohio
Ms. Cindy DeWulf
Ohio Environmental Protection Agency
Lazarus Government Center
P. O. Box 1049
Columbus, OH 43216-1049
(614) 644-3606; fax (614) 644-3681
cindv.dewulf(@,epa.state.oh.us
Certified Mail ONLY
Ms. Cindy DeWulf
Ohio Environmental Protection Agency
Lazarus Government Center
122 South Front Street
Columbus, OH 43215
Oklahoma
Ms. Monty Elder
Department of Environmental Quality
Risk Communication
P.O. Box 1677
Oklahoma City, OK 73101-1677
(405) 702-1017or (800) 869-1400;
fax (405) 702-1001
montv.elder(@,deq.state.ok.us
Oregon
Mr. Bob Albers
Oregon Emergency Response Commission
Office of State Fire Marshall
4760 Portland Road, Northeast
Salem, OR 97305-1760
(503) 378-3473 (ext. 262); fax (503) 373-1825
bob.ALBERS(@,state.or.us
Pennsylvania
Mr. Thomas J. Ward, Jr.
Department of Labor and Industry
Bureau of PENNSAFE
Labor and Industry Building
P.O. Box 68571
Harrisburg, PA 17106-8571
(717) 783-2071; fax (717) 783-5099
pennsafe(@,dri.state.pa.us
http://www.dli.state.pa.us/pennsafe
Certified Mail ONLY
Thomas J. Ward, Jr.
Bureau of PENNSAFE
Department of Labor and Industry
7th & Forster Street, Room 1623
Harrisburg, PA 17120
Puerto Rico
Mr. Genaro Torres
Director of Superfund and Emergencies
Title III-SARA Section 313
Environmental Quality Board
Ferrnadez Junco Station
P.O. Box 11488
Santurce, PR 00910
(787) 766-2823; fax (787) 766-0150
icaemer(@,prtc.net
Certified Mail ONLY
Mr. Genaro Toress
Director of Superfund and Emergencies
Environmental Quality Board
Emergency Response and Remedial Office
National Plaza #431
Ponce de Leon Avenue
HatoRey, PR 00917
Rhode Island
Ms. Karen Slattery
RI Department of Environmental Management
Division of Air Resources
235 Promenade Street, Suite 230
Providence, RI 02908
Attn: Toxic Release Inventory
(401) 222-2808 (ext. 7030); fax (401) 222-2017
kslatter(@,dem.state.ri.us
F-6 Toxics Release Inventory Reporting Forms and Instructions
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Appendix F
South Carolina3
Mr. Michael Juras
Community Right-to-Know
SC Dept of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
(803) 898-4385; fax (803) 898-4487
iurasms(@,columb31 .dhec.state.sc.us
South Dakota
Ms. Lee Ann Smith, TRI Coordinator
South Dakota Department of Environment and
Natural Resources
523 East Capitol
Pierre, SD 57501-3181
(605) 773-3296; fax (605) 773-6035
leeann.smith(fl),state.sd.us
Tennessee
Ms. Betty Eaves, Administrator
TERC/Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville, TN 37204
(615) 741-2986; fax (615) 242-9635
beaves(fl),tnema.org
Texas
U.S. Postal Service Delivery
including Certified Mail
Mr. Blake Kidd
Toxics Release Inventory Program, MC 164
Texas Natural Resource Conservation Commission
P.O. Box 13087
Austin, TX 78711-3087
(512) 239-4874; fax (512) 239-1515
toxic(g),tnrcc. state.tx.us
Overnight Express Mail ONLY
Mr. Blake Kidd
Toxics Release Inventory Program, MC 164
Texas Natural Resources Conservation Commission
12100 Park 35 Circle, Building E (3rd Floor)
Austin, TX 78753
Utah
Mr. Neil Taylor
UT Div. of Environmental Response and Remediation
168 North 1950 West
Salt Lake City, UT 84116
(801) 536-4102; fax (801) 536-4242
ntaylor(@,deq. state .ut.us
Vermont
Mr. Paul Van Hollebeke
VT Dept. of Environmental Conservation
Environmental Assistance Division
103 S. Main St.
Waterbury, VT 05671-0411
(802) 241-3629; fax (802) 241-3273
paulv(@,dec.anr.state.vt.us
Virginia
Ms. Dona Huang
Virginia Emergency Response Commission
Virginia Dept. of Environmental Quality
SARA Title III Program
P.O. Box 10009
Richmond, VA 23240-0009
(804) 698-4489; fax (804) 698-4264
drhuang(g),deq.state.va.us
Certified Mail ONLY
Ms. Dona Huang
SARA Title III Program
Virginia Department of Environmental Quality
629 East Main Street
Richmond, VA 23219
Virgin Islands
Mr. Hollis L. Griffin
Department of Planning and Natural Resources
Division of Environmental Protection
1118 Watergut Homes
Christianshead, St. Croix 00820-5965
St. Croix: (340) 773-0565; fax (340) 773-9310
St. Thomas: (340) 777-4577; fax (340) 774-5416
hlgrifl2(@yiaccess.net
3 South Carolina accepts only diskette submissions.
Toxics Release Inventory Reporting Forms and Instructions F-7
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Appendix F
Washington
U. S. Postal Service Delivery
including Certified Mail
Ms. Idell Hansen
Department of Ecology
Hazardous Waste/Toxics Reduction Program
P.O. Box 47659
Olympia, WA 98504-7659
(360) 407-6727 or (800) 633-7585;
fax (360) 407-6715
ihan461 (@,ecv. wa. gov
Federal Express or UPS Mail ONLY
Ms. Idell Hansen
Department of Ecology
Hazardous Waste/Toxics Reduction Program
300 Desmond Drive
Lacey, WA 98503
West Virginia
Mr. Stephen Kappa
West Virginia Emergency Response Commission
West Virginia Office of Emergency Services
1900 Kanawna Blvd. (Building 1, Room EB-80)
Charleston, WV 25305-0360
(304) 558-5380; fax (304) 344-4538
skappal(@,wvoes.state.wv.us
Wisconsin
Ms. Tara L. Edblom
Environmental Toxicologist/TRI Coordinator
Department Natural Resources
Bureau of Integrated Science Services
101 South Webster Street
P.O. Box 7921
Madison, WI 53707-7921
(608) 264-6043; fax: (608) 267-2531
edblot(@,dnr.state.wi.us
Wyoming
Ms. Bobbi Tenborg
SERC/LEPC Program Manager
WY Emergency Management Agency
5500 Bishop Boulevard.
Cheyenne, WY 82009-3302
(307) 777-4910; fax: (307) 635-6017
btenbo(o),state. wv .us
Notes:
(1) If an Indian tribe has chosen to act independently
of a state for the purpose of section 313 reporting,
facilities located within the Indian community should
report to the tribal SERC, or until the SERC is
established, the Chief Executive Officer of the Indian
tribe, as well as to EPA; (2) Facilities located within
the Territories of the Pacific should send a report to
the Chief Administrator of the appropriate territory, as
well as toEPA.
F-8 Toxics Release Inventory Reporting Forms and Instructions
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Appendix G. Section 313 EPA Regional Contacts
Region 1 (CT, ME, MA, NH, RI, and VT)
Dwight Peavey
Assistance and Pollution Prevention Office
USEPA Region 1 (SPT)
1 Congress Street, Suite 11000
Boston, MA 02114-2023
(617) 918-1829; fax (617) 918-1810
peavev.dwight(@,epa.gov
Region 2 (NJ, NY, PR, and VI)
Nora Lopez
Pesticides and Toxic Substances Branch
USEPA Region 2 (MS-105)
2890 Woodbridge Avenue, Building 10
Edison, NJ 08837-3679
(732) 906-6890; fax (732) 321-6788
lopez.nora(fl),epa. gov
Region 3 (DE, DC, MD, PA, VA, and WV)
William Reilly
Toxics Programs and Enforcement Branch
USEPA Region 3 (3WC33)
1650 Arch Street
Philadelphia, PA 19103-2029
(215) 814-2072; fax (215) 814-3114
reilly. williani(@,epa. gov
Region 4 (AL, FL, GA, KY, MS, NC, SC, TN)
Ezequiel Velez
EPCRA Enforcement Section
USEPA Region 4 Atlanta Federal Center
6IForsyth Street, S.W.
Atlanta, GA 30303-8960
(404) 562-9191; fax (404) 562-9163
velez.ezequiel(@,epa.gov
Region 5 (IL, IN, MI, MN, OH, and WI)
Thelma Codina
Pesticides and Toxics Branch
USEPA Region 5 (DT-8J)
77 West Jackson Boulevard
Chicago, IL 60604
(312) 886-6219; fax (312) 353-4788
codina.thelma(fl),epa. gov
Region 6 (AR, LA, NM, OK, and TX)
Warren Layne
Pesticides and Toxics Substances Branch
USEPA Region 6 (6PDT)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
(214) 665-8013; fax (214) 665-6762
lavne.warren(@,epa. gov
Region 7 (IA, KS, MO, and NE)
Stephen Wurtz
Air, RCRA and Toxics Division
USEPA Region 7 (ARTD/CRIB)
901 North 5th Street
Kansas City, KS 66101
(913) 551-7315; fax (913) 551-7065
wurtz. stephent@,epa. gov
Region 8 (CO, MT, ND, SD, UT, and WY)
Joyel Dhieux
Office of Pollution Prevention, Pesticides and Toxics
USEPA Region 8 (8P-P3T)
999 18th Street, Suite 300
Denver, CO 80202-2466
(303) 312-6447; fax (303) 312-6044
dhieux.jovel(@.epa. gov
Region 9 (AS, AZ, CA, GU, HI, MH, MP, and NV)
Adam Browning
Toxics Section
USEPA Region 9 (CMD-4-2)
75 Hawthorne Street
San Francisco, CA 94105-3901
(415) 947-4178; fax (415) 744-1073
browning. adani(@,epa. gov
Region 10 (AK, ID, OR, and WA)
Christina Colt
Office of Waste & Chemicals Management
USEPA Region 10 (WCM-128)
1200 Sixth Avenue
Seattle, WA 98101-1128
(206) 553-4016; fax (206) 553-8509
colt. christina(@,epa. gov
Toxics Release Inventory Reporting Forms and Instructions G-l
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Appendix H. Other Relevant Section 313 Materials
Public Data Release
1999 Toxics Release Inventory Public Data Release State
Fact Sheets (EPA 260-F-01-001)
The fact sheets can be found on the Internet at
http://www.epa.gov/tri/tri99. The 1999 Toxics Release
Inventory (TRI) State Fact Sheets report includes TRI data for
each state. In addition, the report provides a general overview
of TRI and the 1999 TRI data, a description of the information
included in the state fact sheet, and data summary tables. This
report provides a detailed analysis of each state's data for the
manufacturing industries (those industries reporting since
1988) and the seven major industrial sectors reporting for the
first time in 1998. EPA provides this type of analysis as a
snapshot of each state's releases and other waste management.
1999 Toxics Release Inventory Public Data Release
Report (EPA 260-R-01-001)
This publication can be found on the Internet at
http://www.epa.gov/tri/tri99. The 1999 Toxics Release
Inventory (TRI) Public Data Release Report, published in
April 2001, provides an overview of the 1999 TRI reporting
year data. This report provides: detailed analyses and
supporting tables for TRI releases and other waste
management; an overview of the seven new industry sectors
reporting to TRI for the first time in 1998; an analysis of the
geographic distribution of TRI releases and other waste
management; an analysis of interstate and instrastate transport
of TRI chemicals in the US; and other information relating to
TRI data.
Access to TRI Information On-line
The TRI Home Page (http://www.epa.gov/tri) offers
information useful to both novice and experienced users of the
Toxics Release Inventory. It provides, in lay terms, a
description of what TRI is, how it can be used, TRI data, and
TRI rules and guidance. You can find out about TRI products,
view or download the 1999 TRI data release reports, and
identify who to contact for more information in EPA regions
and state programs across the country. From the TRI home
page, you can "link" to other EPA and non-EPA sites that
allow you to search the TRI database online.
TRI Explorer (http://www.epa.gov/triexplorer/) is an on-line
tool that EPA has created to allow for searches of the TRI data.
It allows the user to search using five criteria: facility,
chemical, year or industry type (SIC code), and geographic
area (at the county, state or national level). The tool will
generate three types of reports: (1) Release Reports (including
on- and off-site releases (i.e., off-site releases include transfers
off-site to disposal and metals and metal compounds
transferred to POTWs)); (2) Waste Transfer Reports (including
amounts transferred off-site for further waste management but
not including transfers off-site to disposal); and (3) Waste
Quantity Reports (including amounts recycled, burned for
energy recovery, quantities treated, and quantities released).
TOXNETฎ (http://toxnet.nlm.nih.gov/). the National Library
of Medicine's (NLM) Toxicology Data Network, provides free
access to TRI data. Users can search by chemical or other
name, chemical name fragment, or Chemical Abstracts Service
Registry Number. Also searchable are facility or parent
company name, state, city, county, or zip code. Search results
can be limited to releases greater than a specified number of
pounds, and individual releases can be summed together to
display a total amount.
RTK-Net (http://www.rtk.net) is an online network concerned
with environmental issues, in particular, matters arising from
the passage of right-to-know provisions embodied inEPCRA
legislation. RTK-net was established by two non-profit
organizations (Unison Institute and OMB Watch) to provide
access to TRI, link TRI with other environmental data, and
exchange information among public interest groups. RTK-Net
is a full-service center providing free dial-in access privileges
to complete database services, training and technical support,
e-mail and electronic conferences pertaining to issues such as
health, activism, and environmental justice. For more
information contact:
RTK-Net
1742 Connecticut Ave., N.W.
Washington, D.C. 20009-1171
(202) 797-7200
Other TRI Information
EPA's Integrated Risk Information System (IRIS)
http://www.epa.gov/iris is an electronic database containing
information on human health effects that may result from
exposure to various chemicals in the environment. IRIS was
initially developed for EPA staff in response to a growing
demand for consistent information of chemical substances for
use in risk assessments, decision-making and regulatory
activities. The information in IRIS is intended for those
without extensive training in toxicology, but with some
knowledge of health sciences.
Consolidated List of Chemicals Subject to Reporting
Under the Act (Title III List of Lists), (November 1998)
http://www.epa.gov/ceppo/pubs/titie3.pdf
Toxics Releases Inventory Forms and Instructions H-l
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Appendix H
Available as an IBM compatible disk from: The National
Technical Information Service, 5285 Port Royal Road,
Springfield, VA 22161, (703) 605-6000, Document Number:
PB98-500473, $69.00.
Chemicals in Your Community, A Citizen's Guide to the
Emergency Planning and Community Right-to-Know Act,
December 1999 (EPA 550-99-001)
This booklet is intended to provide a general overview of the
EPCRA requirements and benefits for all audiences. Part I of
the booklet describes the provisions of EPCRA and Part II
describes more fully the authorities and responsibilities of
groups of people affected by the law. Available through
written request at no charge from:
Emergency Planning and Community Right-To-
Know Information Hotline
1200 Pennsylvania Ave., NW (5101)
Washington, DC 20460
(800) 424-9346
Chemicals in the Environment
Issue number 6 of Chemicals in the Environment (CIE),
published in the Fall of 1997, is devoted entirely to TRI. This
22 page publication contains 19 articles ranging from the
history of TRI to the future of new TRI products. Articles
include perspectives from the community, State, Federal, and
International level. The publication also provides valuable
information on training and contacts within the EPA. CIE is
available free over the Internet
(http://www.epa.gov/opptintr/cie) or from EPA by asking for
publication EPA749-R-97- 00 Ib. To request copies, contact:
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave., N.W.
Attn: TRI Documents
MC: 2844
Washington, DC 20460
(202) 564-9554
Email: TRIDOCS@epa.gov
to compile information, including a database, on management,
technical, and operational approaches to source reduction.
PPIC provides information to the public and industries
involved in conservation of natural resources and in reduction
or elimination of pollutants in facilities, workplaces, and
communities.
To request EPA information on pollution prevention or obtain
factsheets on pollution prevention from various state programs
call the PPIC reference and referral service at (202) 260-1023,
or fax a request to (202) 260-0178, or write to:
PPIC
1200 Pennsylvania Ave., N.W. (3404)
Washington, D.C. 20460
The Pollution Prevention Information Clearinghouse
(PPIC)
PPIC was established as part of EPA's response to the
Pollution Prevention Act of 1990, which directed the Agency
H-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix I. Sample Revision and Withdrawal Letters
REQUEST FOR WITHDRAWAL
Facility Name
Facility Mailing Address
Date:
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
Attention: TRI Withdrawal Request
To whom it may concern:
(Fill in your facility name and TRIFID here) is requesting a withdrawal for the
following submission filed under EPCRA Section 313 from EPA's database (i.e. the Toxics Release
Inventory System (TRIS)):
Chemical Name Reported:
CAS Number/Category Code:
Report Type (please check one): Form R Form A Certification
Reporting Year:
Reason(s) for Withdrawal:
Please include a copy of Form R or Form A certification you want to withdraw.
The technical contact is: Insert name here and may be reached at:
Insert telephone number here .
Requester's Name:
Requester's Signature:
Address:
(* if different from facility
address or facility mailing
address)
Please submit a copy of the request to appropriate state agency, if required.
Toxics Release Inventory Reporting Forms and Instructions 1-1
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Appendix I
REQUEST FOR REVISION
Facility Name
Facility Mailing Address
Date:
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
Attention: TRI Revision Request
To whom it may concern:
(Fill in your facility name and TRIFID here) is requesting a revision for the following
submission filed under EPCRA Section 313 from EPA's database (i.e. the Toxics Release Inventory
System (TRIS)):
Chemical Name Reported:
CAS Number/Category Code:
Report Type (please check one): Form R Form A Certification
Reporting Year:
Reason(s) for Revision:
Please include a copy of Form R or Form A certification (revision box checked) you want to revise.
The technical contact is: Insert name here and may be reached at:
Insert telephone number here .
Requester's Name:
Requester's Signature:
Address:
(* if different from facility.
address or facility mailing
address)
Please submit a copy of the request to appropriate state agency, if required.
Toxics Release Inventory Reporting Forms and Instructions 1-2
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Index
Activity Exemptions 16
Activity Index 64
Alternate Threshold 69
Ammonia 24
Ancillary Use 39
Article Component 38
Articles Exemption 17
ATRS 3, 5, 32, 33, 48, 71, 72
B
Byproduct 38
Generic Chemical Name 36, 37
GOCO Facility 33
Guidance Documents 7
I
Import 38
Impurity 38
Joint Venture 35
Certification of Form R 32
Chemical Categories 24, 36
Chemical Processing Aid 39
Chemical Synonym 36
Coal Extraction Activities Exemption 21
Coincidental Manufacture 13, 14, 21
Contractor 10
D
De Minimis Exemption 18, 21
Definitions
Establishment 33
Facility 33
Manufacture 13
Otherwise Use 15
Process 14
Dioxin and Dioxin-like Compounds 61
Data Precision 16
Distribution 37
Double-Counting 64, 65
Dun & Bradstreet Number 34, 35
E
Employee Determination 10
EPA Identification Number 34
EPCRA Call Center 7
EPCRA Reporting Center 5, 6
Executive Order 13148 1
Facility Identification 32
Form A 71
Form R 32
Formulation Component 38
Laboratory Activities Exemption 21
Latitude and Longitude 34
Lead and Lead Compounds 15,16
M
Manufacture 38
Manufacturing Aid 39
Maximum Amount On-site 39
Metal Compounds 24, 26
Metal Mining Overburden Exemption 22
Mixture Component Identity 37
Motor Vehicle Maintenance Exemption 17
Multi-Establishment Facilities 12
N
NA vs. a Numeric Value 41, 47, 58, 59, 61
Nitrate Compounds 25, 26
NPDES Permit Number 34
o
On-Site Reuse Operations 24
Organic Compounds 24
Otherwise Use 39
Otherwise Use Exemptions 16
Overburden 22
Parent Company 34
Partial Facility Indication 33
PBT Chemicals 15, 22, 25, 61
Data Precision 16
List 22, 23
Process 38
Produce 38
Production Ratio 64, 66
Public Contact 33
Toxics Release Inventory Reporting Forms and Instructions Index1
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Index
R
RCRA Waste 63
Reactant 38
Recordkeeping 2, 23
Repackaging 38
Reporting deadline 5
Reporting Decision Diagram 12
Reporting Year 32
Reuse 15, 17,24,51
Revise Data 3-4
S
Sale/Distribution 3 8
SIC Code Determination 10
SIC Manual 10
Software Vendors 5
Source Reduction 59, 66
Structural Component Exemption 16
Submitting eletronically 5, 6
Submitting Forms 5
Submitting Separate Reports 33
T
Technical Contact 33
Threshold Determinations 23-25
Threshold Worksheets 28-31
Trade Secret 2, 32, 36
TRI Facility Identification Number 32
TRI-ME3, 5, 33,48, 71,72
u
Underground Injection 34
W
Waste Rock 22
Withdraw Data 3-4
Toxics Release Inventory Reporting Forms and Instructions Index2
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