EPA260-B-06-001
January 2006
Toxic Chemical Release
?
Inventory Reporting Forms
and Instructions
Revised 2005 Version
Section 313
of the Emergency Planning and
Community Right-to-Know Act
(Title III of the Superfund Amendments
and Reauthorization Act of 1986)
e
OFFICE OF
ENVIRONMENTAL
INFORMATION
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PLEASE NOTE:
Beginning with Reporting Year 2006, EPA
will only be distributing the TRI-Made Easy
Software (TRI-ME) CD. You will no longer
receive a hard copy Reporting Forms and
Instructions manual. The TRI-ME Software
contains the Reporting Forms and
Instructions manual for your convenience.
The Reporting Forms and Instructions will
also be available for download at
www.epa.gov/tri. If you require further
assistance, please call 1-202-564-9554 or
email the TRI Program at tri.us@epa.gov.
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More Information or Assistance
TRI Regulatory Questions:
If you have a question about a TRI reporting requirement, please refer to
our website for hotline information at:
Internet:
TRI Software Support:
If you have questions about how to install or use the TRI-Made Easy (TRI-
ME) software or the TRI Assistance Library., please contact TRI Software
Support at:
TRI Software Support Hotline: 1-877-470-4830
E-mail: trime@saic.com
TRI Reporting Materials:
You can use TRI-ME and the TRI Assistance Library to electronically
search and read TRI guidance documents, including this document. The
TRI Web page contains links guidance on filling out and submitting TRI
reporting forms:
TRI Regional Contacts:
EPA Regional Coordinators often work closely with reporting facilities in
their area, providing training and outreach, and assistance in completing
forms. For a list of TRI Regional coordinators see Appendix F.
TRI State Contacts:
EPCRA section 313 requires facilities to submit reports to both EPA and
their State. For a list of State designated section 313 contacts see
Appendix E.
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Important Information for Reporting Year 2005
TRI-ME Tutorial. The TRI Program has developed a series of" TRI-ME Tutorial" videos to assist facilities
with using the TRI-ME software. The "TRI-ME Tutorial" videos walk facilities through the TRI-ME and
CDX reporting experience and highlight specific tools, for example, the Section 8 Calculator. The tutorials
are available via streaming video on the TRI website at http://www.epa.gov/tri/report/trime/tutorials. The
tutorials are also offered in a downloadable format from the website.
Methyl Ethyl Ketone (MEK) Delisting. Facilities are no longer required to report MEK because of a court
order removing MEK from the TRI. The final rule states that facilities are not required to report releases of
and other waste management information for MEK that occurred during the 2004 reporting year or for
activities in the future.
Reporting and Updating Latitude/Longitude and Program ID Data in RY 2005. As part of the TRI
Forms Modification Rule, latitude and longitude data (Part I, Section 4.6 of Forms R and A) and Program
identification (ID) numbers including RCRA, NPDES and UIC ID numbers (Part 1, Section 4.8, 4.9, and
4.10 of Forms R and A) will no longer be collected by the TRI program. However these data elements will
still be part of the TRI data disseminations. TRI data users will obtain these data elements from the Facility
Registry System (FRS), EPA's centralized database system for facility information. That system will gather
these data elements from existing data, other EPA programs, state and local governments and commercial
sources.
If they choose, TRI facilities will still have the ability to review, update and insert latitude and longitude
values and Program ID numbers that are being used to represent them. Facilities that use TRI-ME and file
their reports over the Internet will be able to do this by signing into the Central Data Exchange (CDX).
Links to CDX and this process will also be available to facilities through the electronic Facility Data Profile,
the electronic Facility Data Release and on the TRI-ME web page. Facilities may also review and update
their latitude and longitude values on the Internet via the Envirofacts FRS Query at
.
Facilities that do not have Internet access will be able to update their latitude and longitude coordinates and
Program ID values by contacting the EPA Facility Error Notification/Correction Center at 703-243-8307.
Or by mail at:
Lockheed Martin - NEISEC
Error Notification/Correction Center
1010 North Glebe Road
Arlington, VA 22201
Early Public Availability of 2005 TRI Reports. U.S. EPA will be conducting anElectronic Facility Data
Release (eFDR) for Reporting Year 2005 forms, making individual forms, as submitted by each facility,
publicly available before the traditional annual Public Data Release. This is in response to requests to make
the TRI data publicly available earlier. This earlier availability will occur before EPA has completed all the
data quality checks, compilations, and trend analysis that are traditionally done as part of the annual Public
Data Release. For information on the annual Public Data Release, and the early release of the individual
2005 TRI forms, see the Agency's website .
EPA's Audit Policy. If you discover your facility is or may have been in violation of Section 313 of
EPCRA (TRI Reporting), please refer to EPA's Policy entitled, "Incentives for Serf-Policing: Discovery,
Disclosure, Correction, and Prevention of Violations" (Audit Policy), 65 FR 19618, April 11, 2000. You
may qualify for having all gravity based penalties waived if your facility meets all nine (9) conditions of the
Audit Policy. For more information on EPA's Audit Policy, see the Agency's website
.
EPA's Small Business Compliance Policy. If you have 100 or fewer employees and discover that your
facility is or may have been in violation of Section 313 of EPCRA (TRI Reporting), please refer to EPA's
Small Business Compliance Policy. EPA will eliminate or significantly reduce penalties for small
businesses that meet the conditions of the Policy, including voluntarily discovering violations and promptly
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Important Information for Reporting Year 2005
disclosing and correcting them. This Policy implements Section 223 of the Small Business Regulatory
Enforcement Fairness Act (SBREFA) of 1996. For more information, see the Agency's website
.
The following information updates the Reporting Forms and Instructions for Reporting Year 2005 as well as
highlights new resources developed by EPA.
n Per the TRI Reporting Forms Modification Rule (39931 Federal Register/Vol. 70, No. 132, Tuesday, July
12, 2005):
n Sections 4.6,4.8,4.9, and 4.10 in Part 1 have been deleted on Forms R and A;
n The number of codes used in Form R, Part II, Section 7A, column B (Waste Treatment Method(s)
Sequence), have been reduced from 64 to 25;
H Section 7A, column C (Range of Influent Concentration) of Form R, Part II has been deleted;
H Facilities are now allowed to report their treatment efficiency as a range instead of an exact
percentage in section 7A, column D (Waste Treatment Efficiency Estimate) of Form R, Part II;
H Section 7 A, Column E (Based on Operating Data) of Form R, Part II has been deleted;
H The number of recycling codes for section 7C (On-Site Recycling Processes) of Form R, Part II
have been reduced from 16 to 3;
H Section 8.11 of Form R, Part II has been modified. TRI-ME users can now use an optional text
box to submit information on source reduction, recycling, or pollution control activities; and
H All references to reporting year 2004 and all other date related references have been changed to reflect the
current reporting year (i.e., reporting year 2004 has been changed to reporting year 2005; prior year 2003
was changed to prior year 2004., etc.). This change was made for the Form R, Form A Certification
Statement, and the instructions.
H See the TRI Home Page at under "Featured Topics" for information regarding the
decision in Barrick Goldstrike Mines Inc. v. Whitman.
H Appendix C, "Facility Data Profiles, and Common Errors in Completing Form Reports and Form A
Certifications," has been updated.
n The State and Regional contact lists have been updated (Appendices F and G).
n Beginning with Reporting Year 2004, the de minimis level for naphthalene has been changed from 1.0% to
0.1% since naphthalene is now classified as an OSHA carcinogen.
H Beginning with Reporting Year 2004, methyl ethyl ketone (CAS number 78-93-3) has been removed from
the EPCRA section 313 list of reportable toxic chemicals.
The following information identifies changes to the TRI Reporting Software.
H For Reporting Year 2005, the TRI-ME software will no longer support the ability to print federal paper
submissions. This means that facilities will no longer be able to use the TRI-ME software and then print
paper submissions for federal reporting purposes. However, TRI-ME will continue to support the ability to
print paper file copies and state paper submissions.
Why is EPA removing the federal paper submission option from TRI-ME?
The preferred method to report to TRI is by submitting over the internet via CDX using the TRI-ME
software. CDX reporting allows facilities to file a paperless report, significantly reduce data errors, and
receive instant receipt confirmation of submission. Another benefit of submitting via CDX is that it
expedites the receipt of a Facility Data Profile (FDP) thereby giving facilities the ability to quickly review
and correct the information captured by EPA. If a facility does not have internet access, it is strongly
encouraged to use the diskette submission method which also significantly reduces data errors.
Will facilities be able to print file copies?
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Important Information for Reporting Year 2005
Yes.
Will facilities be able to print state submissions with TRI-ME?
Yes. TRI-ME will still support the ability to generate paper submissions for their respective state officials.
n EPA encourages you to use TRI-ME to submit reports through the Internet via CDX. Previous reporters can
submit via CDX using TRI-ME without sending any paper to EPA. Although EPA recommends submitting
via CDX, EPA does accept diskettes created by the TRI-ME software or other approved software.
H Included in this reporting package is a compact disc (CD) that contains the TRI-ME reporting software
(Windows 98, 2000, XP and NT compatible), the EPCRA section 313 Questions and Answers document
and addendum, as well as several industry-specific and chemical-specific guidance documents. The TRI-ME
software and previously mentioned documents are also available via the Internet at .
The following information consists of updates to the Reporting Forms and Instructions from previous reporting
years.
H Effective for RY 2003, Part II, Section 5.5.3-Surface Impoundments has been divided into 5.5.3A-RCRA
Subtitle C Surface Impoundments and 5.5.SB-Other Surface Impoundments.
n Effective for RY 2003, Part II, Section 8.1 has been divided into 8. la-Total on-site disposal to Class I
Underground Injection Wells, RCRA Subtitle C landfills, and other landfills, 8.1b-Total other on-site
disposal or other releases, 8.1c-Total off-site disposal to Class I Underground Injection Wells, RCRA
Subtitle C landfills, and other landfills, and 8. Id-Total other off-site disposal or other releases.
H Effective for RY 2003, the M codes used in Column C of Section 6.2 of the Form R have been updated.
M63 (Surface Impoundment) was deleted and replaced by M codes M66 (RCRA Subtitle C Surface
Impoundment) and M67 (Other Surface Impoundments). M71 (Underground Injection) was deleted and
replaced by M codes M81 (Underground Injection to Class I Wells) and M82 (Underground Injection to
Class II-V Wells).
n Effective for RY 2003, the U codes used in Section 7B of the Form R have been updated. Code U09~Other
Energy Recovery Methods, has been deleted. This code is not applicable since the only energy recovery
methods are combustion in a kiln, boiler or industrial furnace. Combustion units other than kilns, boilers
and industrial furnaces are used for treatment of the toxic chemical (except for metals and metal
compounds).
H Starting with Reporting Year 2002, facilities could provide an email address for the Technical Contact. EPA
encourages all facilities to take advantage of this new opportunity. By providing an email address, facilities
will receive the following benefits:
n Real-time notifications when a Facility Data Profile (FDP) has been updated and posted to the FDP
website
n Receive TRI Program updates and other important notifications.
O Use of the ATRS was discontinued after Reporting Year 2001. ATRS 2001, however, may still be used to
revise data for reporting years 1987 to 2001.
D Starting with Reporting Year 2002, facilities can determine their latitude and longitude by using the TRI
Facility Siting Tool found on the TRI Home page. For more information about the siting tool see Appendix
E.
D 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 when lead is
contained in stainless steel, brass or bronze alloys, have been lowered to 100 pounds. For specific guidance
on the reporting of lead, see page 15.
D Starting with reporting year 2001 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
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Important Information for Reporting Year 2005
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).
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 vii.
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).
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Toxics Release Inventory Reporting Forms and Instructions
Table of Contents
I. TRI Reporting Software v
II. Chemical and Industry Guidance vii
III. General Guidance vii
IV. Chemical-Specific Guidance viii
V. Industry-Specific Guidance ix
A. General Information 1
A.I Who Must Report 1
A.2 How to Submit Forms 1
A.2.a How to Submit Form R(s) and/or Form A(s) to EPA via the Internet (EPA's Central Data Exchange
(CDX)) 1
A.2.bHowto Send Your Disks Containing Form R(s) and/or Form A(s) 2
A.2.b.l Labeling Your Submission Diskette 2
A.2.b.2 Submitting by Diskette to States 2
A.2.c How to Submit Paper Form R(s) and/or Form A(s) 2
A.3 Trade Secret Claims 3
A.4 Recordkeeping 3
A.5 How to Revise or Withdraw TRI Data 4
A.6 When the Report Must Be Submitted 6
A.7 How to Obtain Forms and Other Information 6
B. How to Determine if Your Facility Must Submit a Form R or is Eligible to Use the
Form A 8
B.I Full-Time Employee Determination 8
B.2 Primary SIC Code Determination 8
B.2.a. Multi-Establishment Facilities 10
B.2.b. Auxiliary Facilities 10
B.2.c. Property Owners 11
B.3 Activity Determination 11
B.3.a. Definitions of "Manufacture," "Process," and "Otherwise Use" 11
B. 3 .b. Persistent Bioaccumulative Toxic (PBT) Chemicals and Chemical Categories Overview 14
B.3.c. Activity Exemptions 15
B.4 Threshold Determinations 20
B.4.a. How to Determine if Your Facility Has Exceeded Thresholds 20
B.4.b. Threshold Determinations for On-Site Reuse Operations 21
B.4.c. Threshold Determinations for Ammonia 21
B.4.d. Threshold Determinations for Chemical Categories 22
B.4.e Threshold Determination for Persistent Bioaccumulative Toxic (PBT) Chemicals 22
B.4.f. Mixtures and Other Trade Name Products 22
B.5 Release and Other Waste Management Determinations for Metals, Metal Category Compounds,
and Nitrate Compounds 23
C. Instructions for Completing EPA Form R 29
Part I. Facility Identification Information 29
Section 1. Reporting Year 29
Section 2. Trade Secret Information 29
2.1 Are you claiming the EPCRA section 313 chemical identified on page 2 a trade secret? 29
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Table of Contents
2.2 If "yes" in2.1, is this copy sanitized or unsanitized? 29
Sections. Certification 29
Section 4. Facility Identification 29
4.1 Facility Name, Location, and TRI Facility Identification Number 29
4.2 Full or Partial Facility Indication 29
4.3 Technical Contact 30
4.4 Public Contact 30
4.5 Standard Industrial Classification (SIC) Code 30
4.6 Latitude and Longitude 30
4.7 Dun & Bradstreet Number 30
4.8 EPA Identification Number 30
4.9 NPDES Permit Number(s) 30
4.10 Underground Injection Well Code (UIC) Identification Number 31
Sections. Parent Company Information 31
5.1 Name of Parent Company 31
5.2 Parent Company's Dun & Bradstreet Number 31
Part II. Chemical Specific Information 31
Section 1. EPCRA Section 313 Chemical Identity 31
1.1 CAS Number 31
1.2 EPCRA Section 313 Chemical or Chemical Category Name 31
1.3 Generic Chemical Name 32
1.4 Distribution of Each Member of the Dioxin and Dioxin-like Compounds Category 32
Section 2. Mixture Component Identity 32
2.1 Generic Chemical Name Provided by Supplier 33
Sections. Activities and Uses of the EPCRA Section 313 Chemical at the Facility 33
3.1 Manufacture the EPCRA Section 313 Chemical 33
3.2 Process the EPCRA Section 313 Chemical (incorporative activities) 33
3.3 Otherwise Use the EPCRA Section 313 Chemical (non-incorporative activities) 34
Section 4. Maximum Amount of the EPCRA Section 313 Chemical On-site at Any Time during the Calendar Year
34
Section 5. Quantity of the EPCRA Section 313 Chemical Entering Each Environmental Medium On-site 35
5.1 Fugitive or Non-Point Air Emissions 36
5.2 Stack or Point Air Emissions 36
5.3 Discharges to Receiving Streams or Water Bodies 36
5.4.1 Underground Injection On-Site to Class I Wells 37
5.4.2 Underground Injection On-site to Class II-V Wells 37
5.5 Disposal to Land On-site 37
5.5.1A RCRA Subtitle C landfills 37
5.5. IB Other landfills 37
5.5.2 Land treatment/application farming 37
5.5.3A RCRA Subtitle C Surface Impoundments 37
5.5.3B Other Surface Impoundments 37
5.5.4 Other Disposal 37
Sections Column A: Total Release 38
Section 5 Column B: Basis of Estimate 38
Section 5 Column C: PercentFrom Stormwater 39
Section 6. Transfers of the EPCRA Section 313 Chemical in Wastes to Off-Site Locations 41
6.1 Discharges to Publicly Owned Treatment Works 41
6.I.A.I Total Transfers 41
6.1.A.2 Basis of Estimate 42
6.2 Transfers to Other Off-Site Locations 42
6.2a Column A: Total Transfers 42
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6.2b Column B: Basis of Estimate 44
6.2c Column C: Type of Waste Management: Disposal/ Treatment/Energy Recovery/Recycling 44
Section?. On-Site Waste Treatment, Energy Recovery, and Recycling Methods 47
Section 7A On-Site Waste Treatment Methods and Efficiency 47
7A Column a: General Waste Stream 47
7A Columnb: Waste Treatment Method(s) Sequence 47
7A Column c: Range of Influent Concentration 49
7A Column d: Waste Treatment Efficiency Estimate 49
7A Column e: Based on Operating Data? 50
Section 7B On-Site Energy Recovery Processes 50
Section 7C On-Site Recycling Processes 50
Sections. Source Reduction and Recycling Activities 52
D. Facility Eligibility Determination for Alternate Threshold and for
Reporting on EPA Form A 61
D.I Alternate Threshold 61
D.2 What is the Form A Certification Statement? 61
D.3 What is the Total Annual Reportable Amount? 61
D.4 Recordkeeping 61
D.5 Multi-establishment Facilities 61
D.6 Trade Secrets 61
D.7 Metals and Metal Category Compounds 62
E. Instructions for Completing EPA Form A 62
Part I. Facility Identification Information 62
Section 1. Reporting Year 62
Section 2. Trade Secret Information 62
2.1 Are you claiming the EPCRA Section 313 chemical identified on page 2 a trade secret? .. 62
2.2 If "yes" in 2.1, is this copy sanitized or unsanitized? 63
Sections. Certification 63
Section 4. Facility Identification 63
4.1 Facility Name, Location, and TRI Facility Identification Number 63
4.2 Federal Facility Designation 63
4.3 Technical Contact 63
4.4 Intentionally Left Blank 63
4.5 Standard Industrial Classification (SIC) Code 63
4.6 Latitude and Longitude 64
4.7 Dun & Bradstreet Number(s) 64
4.8 EPA Identification Number(s) 64
4.9 Facility NPDES Permit Number(s) 64
4.10 Underground Injection Well Code (UIC) Identification Number(s) 64
Sections. Parent Company Information 64
5.1 Name of Parent Company 64
5.2 Parent Company's Dun & Bradstreet Number 64
Part II. Chemical Identification 64
Section 1. Toxic Chemical Identity 64
1.1 CAS Number 64
1.2 EPCRA Section 313 Chemical or Chemical Category Name
1.3 Generic Chemical Name 65
Section 2. Mixture Component Identity 65
2.1 Generic Chemical Name Provided by Supplier 65
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Table of Contents
Table I
Table II
Table III
Table IV
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
Index
SIC codes 10-73 1-1
EPCRA Section 313 Chemical List (including chemical categories) for Reporting Year 2003... II-1
State Abbreviations III-l
Federal Information Processing Standards (FIPS) Codes IV-1
Federal Facility Reporting Information A-l
Reporting Codes for EPA Form R and Instructions for Reporting Metals B-l
Facility Data Profiles and Common Errors in Completing Form R Reports and Form
A Certifications C-l
Supplier Notification Requirements D-l
State Designated Section 313 Contacts E-l
Section 313 EPA Regional Contacts F-l
Other Relevant Section 313 Materials G-l
Sample Withdrawal Letter H-l
iv Toxics Release Inventory Reporting Forms and Instructions
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Toxics Release Inventory — Made Easy (TRI-ME) Software 2005
The TRI-ME 2005 software helps facilities in determining and completing their Emergency Planning and Community
Right-to-Know (EPCRA) section 313 and Pollution Prevention Act (PPA) section 6607 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 Statement 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, that allows users to
search the statute, regulations, and many EPCRA section 313 guidance documents by key word. For the more
experienced reporter, TRI-ME allows direct data entry onto electronic versions of the Form R and Form A Certification
Statement. TRI-ME will check the data for common errors and then prepare the forms. All of the information contained
in this RY2005 Reporting Forms and Instructions book is contained within TRI-ME.
TRI-ME allows the user to submit the forms on via the Internet through CDX or on diskette. TRI-ME supports submitting
electronically over the Internet using EPA's CDX without mailing any paper to EPA.
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 integrated into TRI-ME.
What Happened to the Automated TRI Reporting Software (ATRS)?
EPA is no longer producing new versions of ATRS. After Reporting Year 2001, EPA replaced ATRS with the TRI-ME
software. For Reporting Year 2005, facilities are encouraged to use the TRI-ME software. TRI-ME was distributed as a
pilot for Reporting Year 2000. In Reporting Year 2001, EPA distributed both TRI-ME and ATRS to all TRI reporting
facilities.
Can I Use or Load Past Year's data into TRI-ME?
You may load prior year data from Reporting Year 2004 submission diskettes or from TRI-ME Reporting Year 2004
facility files. With few exceptions, all of your prior year data will be loaded directly into the Reporting Year 2005
forms. To load Reporting Year 2003 data into TRI-ME 2005, you must first load your data into TRI-ME 2004. If
you have questions about loading data prior to Reporting Year 2003, please call the CDX Helpdesk at 1-888-890-
1995.
Can I Use TRI-ME if I Have My Own TRI Software?
Yes. Some facilities have their own software or use private software to assist in preparing their TRI reports. This "third
party software" is often designed to produce output files that match EPA's Magnetic Media File Formats (sometimes
called the TRI 18 flat files). These file formats can be found on the TRI Home page at . You may
load these flat files directly into TRI-ME and then use TRI-ME to check your forms for common errors. You can then
also use TRI-ME to submit the forms to U.S. EPA and your state.
What Are the Key Features of TRI-ME?
n TRI-ME allows prior TRI reporters to submit a paperless submission through the Internet, via CDX. The TRI-
ME software will also allow first-time reporters to submit their reports via CDX.
H An expert desk top software tool that guides facilities through the process of determining whether they must
report based on the SIC codes, number of employees and chemical threshold criteria.
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Toxics Release Inventory — Made Easy (TRI-ME) Software 2005
Walks users through the process of preparing and submitting their forms. Many routine tasks associated with
the preparation and submission of the forms have been eliminated or streamlined.
Assists facilities in understanding each element of the Form R and Form A Certification Statement.
Allows expert users to bypass most of the detailed assistance and directly enter data into the forms.
Enables users to access and search the TRI Assistance Library to find additional guidance from EPA on how to
report. With TRI-ME there is often no need to obtain a paper version of an EPA TRI guidance document.
Contains extensive intelligence to prevent facilities from making common errors.
Alerts users to possible errors so they can double check their forms before submitting them.
Assists users in completing Section 8 of the Form R. The Section 8 Calculator assists users in calculating their
Section 8 source reduction and recycling activity quantities.
Allows users to load their data from the prior year.
Also enables facilities to submit their forms on a diskette or on traditional paper forms to their state.
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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 x). 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 .
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave., N.W.
Attn: TRI Documents
MC: 2844T
Washington, DC 20460
202 564-9554
Email: TRIDOCS@epa.gov
I. General Guidance
a 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).
Q Common Synonyms for Chemicals Listed
Under Section 313 of the Emergency Planning
and Community Right-to-Know Act
March 1995 (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 01°
reporting.
313
Q 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).
Q EPCRA Section 313 Questions and Answers -
Addendum to the Revised 1998 Version
December 2004 (EPA-260-B-04-002)
As a result of Executive Order 13148, regulatory
actions, and legal decisions over the past five years,
some of the Qs & As contained in the 1998 Q &A
Document were updated. The 1998 Q & A
Document remains valid guidance in all other
respects.
Q EPCRA Section 313 Questions and Answers
Addendum for Federal Facilities
May 2000 (EPA 745-R-00-003)
This document is an addendum to the EPCRA
section 313 Questions and Answers—Revised 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.
a 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.
O 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 certain PBT 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.
Toxics Release Inventory Reporting Forms and Instructions vii
-------
Guidance Documents
n 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.
H Toxic Chemical Release Inventory Reporting
Forms and Instructions Revised 2003
Version
February 2004 (EPA 260-B-04-001)
H Toxics Release Inventory: Reporting
Modifications Beginning with 1995 Reporting
Year
February 1995 (EPA 745-R-95-009)
O Trade Secrets Rule and Substantiation 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). The current trade secret
substantiation form can be accessed at
.
II. Chemical-Specific Guidance
EPA has developed a group of guidance documents
specific to individual chemicals and chemical
categories.
Q Emergency Planning and Community
Right-to-Know Section 313: List of Toxic
Chemicals within the Chlorophenols
Category
June 1999 (EPA745-B-99-013)
Q Toxics Release Inventory List of Toxic
Chemicals within the Glycol Ethers
Category and Guidance for Reporting
December 2000 (EPA745-R-00-004)
Q 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)
Q Emergency Planning and Community
Right-to-Know Act - Section 313:
Guidance for Reporting Releases and Other
Waste Management 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 (EPA 745-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)
viii Toxics Release Inventory Reporting Forms and Instructions
-------
Guidance Documents
Q 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-01-026)
Q Emergency Planning and Community Right-
to-Know Act - Section 313: Guidance for
Reporting Aqueous Ammonia
December 2000 (EPA 745-R-00-005)
Q 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)
III. Industry-Specific Guidance
EPA has developed a group of individual guidance
documents for certain industries.
Q EPCRA Section 313: Guidance for
Chemical Distribution Facilities
January 1999 (EPA 745-B-99-005)
Q EPCRA Section 313: Guidance for
Petroleum Terminals and Bulk Storage
Facilities
February 2000 (EPA 745-B-00-002)
Q EPCRA Section 313: Guidance for
Coal Mining Facilities
February 2000 (EPA 745-B-00-003)
Q EPCRA Section 313: Guidance for
Electricity Generating Facilities
February 2000 (EPA 745-B-00-004)
Q EPCRA Section 313 Reporting Guidance for
Food Processors
September 1998 (EPA 745-R-98-011)
Q EPCRA Section 313 Reporting Guidance for
the Leather Tanning and Finishing Industry
April 2000 (EPA 745-B-00-012)
Q EPCRA Section 313: Guidance for
Metal Mining Facilities
January 1999 (EPA 745-B-99-001)
Q Emergency Planning and Community Right-
to-Know Act Section 313 Reporting Guidance
for the Presswood and Laminated Products
Industry
August 2001 (EPA260-B-01-013)
Q EPCRA Section 313 Reporting Guidance for
the Printing, Publishing, and Packaging
Industry
May 2000 (EPA 745-B-00-005)
Q EPCRA Section 313: Guidance for RCRA
Subtitle C TSD Facilities and Solvent
Recovery Facilities
January 1999 (EPA 745-B-99-004)
Q EPCRA Section 313 Reporting Guidance for
Rubber and Plastics Manufacturing
May 2000 (EPA 745-B-00-017)
Q EPCRA Section 313 Reporting Guidance for
Semiconductor Manufacturing
July 1999 (EPA 745-R-99-007)
Q EPCRA Section 313 Reporting Guidance
forthe Textile Processing Industry
May 2000 (EPA 745-B-00-008)
Q EPCRA Section 313 Reporting Guidance for
Spray Application and Electrodeposition of
Organic Coatings
December 1998 (EPA 745-R-98-014)
Toxics Release Inventory Reporting Forms and Instructions ix
-------
Guidance Documents
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
x Toxics Release Inventory Reporting Forms and Instructions
-------
Paperwork Reduction Act Notice: The annual public burden related to the FormR, which is
approved under OMB Control No. 2070-0093, is estimated to average 29.6 hours per response for non-
PBT chemicals and 51.3 hours per response for PBT chemicals. The annual public burden related to
the Form A, which is approved under OMB Control No. 2070-0143, is estimated to average 20.5 hours
for a facility that certifies one chemical per Form A Certification Statement. Responding to this
information collection requires 1) determining whether a listed toxic chemical is eligible for
certification under the alternate threshold, and 2) completing the Form A Certification Statement. The
burden of determining eligibility for certification and associated recordkeeping is estimated to average
19.2 hours for each chemical that is certified. The burden of completing the Form A Certification
Statement 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.
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. This includes the time
needed to review instructions; develop, acquire, install, and utilize technology and systems for the
aurposes of collecting, validating, and verifying information, processing and maintaining information,
ffld disclosing and providing information; adjust the existing ways to comply with any previously
applicable instructions and requirements; train personnel to be able to respond to a collection of
nformation; 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 EPA's regulations are listed in 40 CFR Part 9 and 48 CFR
hapter 15.
Send comments on the Agency's need for this information, the accuracy of the provided
surden estimates, and any suggested methods for minimizing respondent burden, including through the
use of automated collection techniques, to the Director, Collection Strategies Division, U.S.
Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460; and
;o the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th
street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Include the EPA ICR number
ind OMB control number in any correspondence.
The completed forms should be submitted in accordance with the instructions accompanying
;he form, or as specified in the corresponding regulation.
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 01/31/2008 Page 1 of 5
United States
Environmental Protection Agency
FORMR
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
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center
P.O. Box 1513
Lanham, MD 20703-1513
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 1. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
Are you claiming the toxic chemical identified on page 2 trade secret?
2.1
Yes (Answer question 2.2;
J Attach substantiation forms)
No (Do not answer 2.2;
Go to Section 3)
2.2
Is this copy Sanitized f
(Answer only if "YES" in 2.1)
Unsanitized
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
4TT
TRI Facility ID Number
Facility or Establishment Name |
Facility or Establishment Name or Mailing Address (If different from street address) I
Street
Mailing Address |
City/County/State/Zip Code |
City/State/Zip Code |
Country (Non-US)
This report contains information for: I 1 An entire
Important: Check a orb; check cord if applicable) a. | | facility
Part of a
facility
A Federal
facility
GOCO
Technical Contact Name
Telephone Number (include area code) |
Email Address
4.4
Public Contact Name \
Telephone Number (include area code) |
4.5
SIC Code (s) (4 digits)
Primary
b.
d.
4.7
Dun & Bradstreet
Number (s) (9 digits)
SECTION 5. PARENT COMPANY INFORMATION
5.1
Name of Parent Company
NA
5.2
Parent Company's Dun & Bradstreet Number
NA
EPAForm9350 -1 (Rev. 01/2006) - Previous editions are obsolete.
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 01/31/2008 Page 2 of 5
FORMR
PART II. TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM
FRI 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.)
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.)
i A 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.)
123456 7 8 9 10 11 12 13 14 15 16 17
J _ I _ I _ I
I _ I _ I _ I _ L
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
mport
If produce or import
C. LJ For on-site use/processing
d.LJ For sale/distribution
e I I As a byproduct
f I I As an impurity
As a reactant
As a formulation component
As an article component
Repackaging
As an impurity
a. | | As a chemical processing aid
b. | | As a manufacturing aid
C. I I 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 a range code** or estimate)
B. Basis of Estimate
(enter code)
C. % From Stormwater
5.1
Fugitive or non-point
air emissions
NA
5.2
Stack or point
air emissions
NA
5.3
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. I (example: 1,2,3, etc.)
EPAForm 9350-1 (Rev. 01/2006) - 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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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 01/31/2008
Page 3 of 5
FORMR
PART II. CHEMICAL - SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE (continued)
NA
A. Total Release (pounds/year*) (enter range
code ** or estimate )
B. Basis of Estimate
(enter code)
5.4.1
Underground Injection onsite
to Class I Wells
5.4.2
Underground Injection onsite
to Class II-V Wells
5.5
Disposal to land onsite
5.5.1A
RCRA Subtitle C landfills
5.5.1B
Other landfills
5.5.2
Land treatment/application
farming
5.5.3A
RCRA Subtitle C
surface impoundments
5.5.3B
Other surface impoundments
5.5.4 Other disposal
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 Basis of Estimate
Total Transfers (pounds/year*)
(enter range code ** or estimate)
6.1.A.2 Basis of Estimate
(enter code)
6.1.B
POTW Name
POTW Address
City
State
County
Zip
6.I.B.
| POTW Name
POTW Address
City
State
County
Zip
If additional pages of Part II, Section 6.1 are attached, indicate the total number of pages
in this box I I and indicate the Part II, Section 6.1 page number in this box |
(example: 1,2,3, etc.)
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
62. 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
EPAForm 9350-1 (Rev. 01/2006) - Previous editions are obsolete.
* For Dioxin or Dioxin-like compounds, report in grams/year
** Range Codes: A=l-10 pounds: B=ll-499 pounds; C=500 - 999 pounds.
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double-sided!
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 01/31/2008
Page 4 of 5
FORMR
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.
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 (N A) -
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- or 4- character code(s)]
d. Waste Treatment Efficiency
[enter 2 character code]
7 A. la
7A.lb I
7A.ld
7A.2a
7A.2b I
7A3a
7A.3b I
7A.2d
7A.3d
7A4a
7A.4b
7A.4d
7A5a
7A.5b I
7A.5d
If additional pages of Part II, Section 6.2/7A are attached, indicate the total number of pages in this box
and indicate the Part II, Section 6.2/7 page number in this box: I (example: 1,2,3,etc.)
EPAForm 9350-1 (Rev. 01/2006) - Previous editions are obsolete.
*For Dioxin or Dioxin-like compounds, report in grams/year
**Range Codes: A=l -10 pounds; B=ll - 499 pounds C= 500-999 pounds.
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 01/31/2008
Page 5 of 5
FORMR
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
n Check here if no on-site energy recovery is applied to any waste
Not Applicable (N A) -
stream containing the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character code(s)]
1
2 3
1
SECTION 1C. ON-SITE RECYCLING PROCESSES
n,. ,, Check here if no on-site recycling is applied to any waste
Not Applicable (N A) -
stream containing the toxic chemical or chemical category.
Recycling Methods [enter 3-character code(s)]
1
2 3
SECTION 8. SOURCE REDUCTION AND RECYLING ACTIVITIES
8.1
8.1a
8.1b
&lc
8.1d
8.2
8.3
8.4
8.5
8.6
8.7
8.8
8.9
8.10
8.10.1
8.10.2
8.10.3
8.10.4
8.11
Total on-site disposal to Class I
Underground InjectionWells, RCRA
Subtitle C landfills, and other landfills
Total other on-site disposal or other
releases
Total off-site disposal to Class I
Underground Injection Wells, RCRA
Subtitle C landfills, and other landfills
Total other off-site disposal or other
releases
Quantity used for energy recovery
onsite
Quantity used for energy recovery
offsite
Quantity recycled
onsite
Quantity recycled offsite
Quantity treated onsite
Quantity treated offsite
Column A
Prior Year
(pounds/year*)
Column B
Current Reporting Year
(pounds/year*)
Quantity released to the environment as a result of remedial actions, catastrophic events,
or one-time events not associated with production processes (pounds/year)*
Production ratio or activity
index
Column C
Following Year
(pounds/year*)
Column D
Second Following Year
(pounds/year*)
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)
a. b. c.
a. b. c.
a. b. c.
a. b. c.
If you wish to submit additional optional information on source reduction, recycling, or pollution Yes
control activities, check "Yes." 1 1
EPAForm 9350-1 (Rev. 01/2006) - Previous editions are obsolete.
*For Dioxin or Dioxin-like compounds, report in grams/year
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0143
Approval Expires: 01/31/2008 Page 1 of
EPA
United States
Environmental Protection Agency
TOXICS CHEMICAL RELEASE INVENTORY
FORMA
WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center
P.O. Box 1513
Lanham, MD 20703-1513
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE
(See instruction 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 1. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
Are you claiming the toxic chemical identified on page 2 trade secret?
2.1
Yes (Answer question 2.2;
J Attach substantiation forms)
No (Do not answer 2.2;
Go to Section 3)
2.2
Is this copy Sanitized f
(Answer only if "YES" in 2.1)
Unsanitized
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 offical 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: (Important: Check c or d if applicable)
A Federal
facility
GOCO
4.3
Technical Contact Name
Telephone Number (include area code) |
Email Address
4.4
Intentionally left blank
4.5
SIC Code (s) (4 digits)
Primary
b.
4.7
Dun & Bradstreet
Number (s) (9 digits)
SECTION 5. PARENT COMPANY INFORMATION
5.1
Name of Parent Company
NA
5.2
Parent Company's Dun & Bradstreet Number
NA
EPAForm 9350 -2 (Rev. 01/2006) - Previous editions are obsolete.
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double-sided!
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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 _
i 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)
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
i Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
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)
. Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY Report of
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
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.)
f i Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY Report of
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.1
, Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
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.)
-
. L
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
*See the TRI Reporting Fomrs and Instructions Manual forthe list of PBT Chemicals (including Dioxin and Dioxin-like Compounds)
EPAForm9350 -1 (Rev. 01/2006) - Previous editions are obsolete.
(Make additional copies of this page, if needed)
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This side intentionally
left blank.
Please do not copy
double-sided!
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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.1 Who Must Report
Section 313 of EPCRA requires that reports be filed by
owners and operators of facilities that meet all of the
following criteria.
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
H 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 etseq.), 5169,5171, and 7389 (limited to facilities
primarily engaged in solvents recovery services on a
contract or fee basis); and
D 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 Submit Forms
A.2.a. How to Submit Form R(s) and/or Form A(s)
to EPA via the Internet (EPA's Central Data
Exchange (CDX))
The preferred method to report to TRI is by the use of
the TRI-Made Easy (TRI-ME) software and submittal
through the Internet via CDX. CDX allows facilities to
file a paperless report, significantly reduce data errors,
and receive instant receipt confirmation of their
submission. Facilities that use TRI-ME, submit through
the Internet via CDX, and reside in a state participating
in the TRI State Data Exchange, will have their forms
sent simultaneously to EPA and their respective State
officials via the Environmental Information Exchange
Network. Once a TRI submission is certified it will be
electronically forwarded to state officials. Once the
TRI submission has been certified your obligation to
report to EPA and your state will be satisfied.
EPA encourages you to use TRI-ME to submit your TRI
submission(s) via CDX. TRI-ME allows you to submit
a completely paperless report to EPA (Internet and
diskette submissions are not available for trade secret
claims). If you choose to submit via the Internet, do
not send duplicate paper or diskette copies of the
reports. Please be aware that if your facility does not
reside in a state participating in the TRI State Data
Exchange submitting via the Internet 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.).
If you have any questions about the CDX submission
process, call toll free: 1- 888-890-1995 between the
hours of 8:00 A.M. - 6:00 P.M. Eastern Time. For
additional information about CDX, please see:
.
Toxics Release Inventory Reporting Forms and Instructions 1
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General Information
confirmed that they accept diskette submissions:
A.2.b. How to Send Your Disks Containing Form R(s)
and/or Form A(s)
If you do not have Internet access, EPA still encourages you
to use the TRI-ME software and submit your reports using a
diskette. If you choose to submit your TRI Form R(s)
and/or Form A(s) on magnetic media/diskette using TRI-
ME, please follow the instructions below. If you choose to
submit on diskette, do not submit duplicate CDX or paper
copies of the reports that are on the diskette.
A.2.b.l Labeling Your Submission Diskette
Company Name
Date: 6/30/2006
Reporting Year: 2005
Density: HD
Number: 1 of
1
Contact: Technical Contact Name
505 555-5369
A label should be attached to each diskette. The label may
be typed or legibly handwritten. A sample label above
shows the necessary 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:
TRI Data Processing Center
P.O. Box 1513
Lanham, MD 20703-1513
Certified mail, overnight mail, and
submissions only should be addressed to:
hand-delivered
Attn: TRI Magnetic Media Submission
TRI Data Processing Center
c/o Computer Sciences Corporation
Suite 150
8400 Corporate Drive
Landover, MD 20785-2294
301 429-5005
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 senior management official) for each
separate facility. The TRI-ME software assists the user in
preparing cover letters for both EPA and states. The letter
on page 8 is a sample. Since you are filing by diskette, do
not include duplicate paper copies of the reports that are on
the diskette.
A.2.b.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
AK
GA
MD3
MM6
SD
WY
AL
ffl
MI4
NV
TX
AR1
IA
MN
OH
UT
AZ2
ID
MO5
OK
VA
CA
IL
MT
OR
VT
CO
IN
ND
PA
WA8
DE
KS
NH
PR
WI
FL
LA
NJ
SC7
wv
1 Arkansas facilities must report using TRI-ME on
diskettes.
2Arizona Emergency Response Commission
accepts electronic submissions, however the Arizona Dept. of
Environmental Quality accepts only paper submissions.
Submissions must be sent to both agencies.
Maryland accepts diskette submissions, but
requires that paper copies be sent as well.
4Michigan accepts Internet submissions; reports
submitted electronically via Internet to EPA's Central Data
Exchange does not require any separate mailing of reports
(disk or paper). Also accepts diskettes.
'Missouri only accepts diskettes created using TRI-
ME software.
6 New Mexico requires paper copies in addition to
diskette.
7South Carolina only accepts reports submitted
electronically via Internet to EPA's Central Data Exchange.
Facilities submitting by Internet are exempt from any
separate mailing to SC DHEC. If Internet access is not
available, it will be necessary to mail a diskette copy to SC
DHEC.
8Washington strongly encourages
submittals by diskette or via CDX if available.
electronic
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.2.C How to Submit Paper Form R(s) and/or Form A(s)
It is EPA's ultimate goal to move away from processing
diskette and paper submissions and receive all TRI
submissions via CDX. Although EPA strongly discourages
paper submissions due to increased possibility of errors,
paper submissions are currently still accepted. Paper
submissions must be sent to both EPA and the state (or the
designated official of an Indian tribe). If a report is not
2 Toxics Release Inventory Reporting Forms and Instructions
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General Information
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. To send requests by regular mail:
TRI Data Processing Center
P.O. Box 1513
Lanham,MD 20703-1513
To send requests by certified mail or overnight mail (i.e. Fed Ex,
UPS, etc.):
TRI Data Processing Center
c/o Computer Sciences Corporation
Suite 150
8400 Corporate Drive
Landover, MD 20785-2294
(301)429-5005
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 Commonwealth of the
Northern Mariana Islands, and any other jurisdiction and Indian
Country.). 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.
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. The current
substantiation form is available on the TRI Website at
. One set of reports,
the "unsanitized" version, must provide the actual identity of the
EPCRA section 313 chemical. The other set of reports, i.e., the
"sanitized" version, must provide a generic class or category for
the chemical that is structurally descriptive 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:
D A completed "unsanitized" version of Form R or Form A
report including the EPCRA section 313 chemical
identity (staple the pages together); and
D 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 that is structurally descriptive has been
supplied (Part II, Section 1.3) (staple the pages
together); and
n A completed "unsanitized" version of a trade secret
substantiation form (staple the pages together); and
n 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).
Where to send your trade secret submission
Please send only trade secret submissions to the P.O. Box
below.
To send trade secret submissions by regular mail:
EPCRA Substantiation Packages
P.O. Box 1515
Lanham,MD 20703-1515
To send trade secret submissions by certified mail or
overnight mail (i.e. Fed Ex, UPS, etc.):
TRI Data Processing Center
c/o Computer Sciences Corporation
Suite 150
8400 Corporate Drive
Landover, MD 20785-2294
Attention: EPCRA Substantiation Packages
301 429-5005
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
Toxics Release Inventory Reporting Forms and Instructions 3
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General Information
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:
O Previous years' EPCRA section 313 reports;
a EPCRA section 313 Reporting Threshold Worksheets;
a Engineering calculations and other notes;
O Purchase records from suppliers;
O Inventory data;
O EPA (NPDES) permits and monitoring reports;
a EPCRA section 312 Tier II Reports;
a Monitoring records;
a Flowmeter data;
O RCRA Hazardous Waste Generator's Report;
O Pretreatment reports filed by the facility with the local
government;
O Invoices from waste management companies;
n Manufacturer's estimates of treatment efficiencies;
n RCRA manifests;
n Process diagrams that indicate emissions and other
releases; and
n 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
EPA has received several questions relating to withdrawing and
revising TRI data submitted by facilities, such as:
• What are the reasons for revising?
• How do I revise my submission?
• To whom should this request be sent?
What are the reasons for revising?
Facilities that filed a Form R and/or Form A Certification
Statement under EPCRA Section 313 may submit a request to
revise their submission(s) to the Toxics Release Inventory System
(TRIS) database and in the public version of the database,
Envirofacts and TRI Explorer. Facilities may request a revision
for one of several reasons, such as:
• To revise facility identification information
• To revise chemical identification information
• To revise release and other waste management activities
information
• To revise as a result of an EPA/State inspection
• To revise as a result of Data Quality Alerts, a Notice of
Technical Error (NOTE), Notice of Significant Error
(NOSE), or a Notice of Noncompliance (NON)
• To revise as a result of a voluntary disclosure through
EPA's audit policy.
Note: Late submissions for chemicals not reported in a previous
reporting year are not considered revisions for that year.
How do I revise my submission(s)?
If you have determined that your facility wishes to
revise a TRI submission, you must send your request to
EPA and the appropriate State agency. For submitting
a revision to EPA, please use one of the following
methods:
1. TRI-ME via Internet (CDX) - The preferred method for
submitting revised TRI forms is by the use of the TRI Made-
Easy (TRI-ME) software and submission through the Internet
via the CDX. You can download the TRI-ME software at
. There are several advantages to using
CDX. They are as follows: paperless filing, electronic
signature process, significant reduction of data errors, and
instant confirmation of your submission. If you have
questions about submitting forms via CDX, please contact the
CDX Hotline at epacdx@csc.com or call toll free: 1-888-890-
1995. Submission of revisions through CDX is only
available for revision of reports from RY 2002 and later. For
revisions to submissions form RY 2001 and prior, EPA
recommends using an alternative, such as using ATRS or
TRI-ME via diskette.
2. TRI-ME via diskette - If you do not have Internet
access, EPA still encourages you to use the TRI-ME software
and to submit responses by diskette to one of the addresses
given below. All diskette submissions must be accompanied
by a signed Certification Statement. If you do not have the
TRI-ME software for the Reporting Year that you are
correcting, please contact EPA at 202-564-9554.To send
request by regular mail:
TRI Data Processing Center
P.O. Box 1513
Lanham,MD 20703-1513
Attention: TRI Revision Request
To send request by certified mail or overnight mail:
TRI Data Processing Center
c/o Computer Sciences Corporation
Suite 150
8400 Corporate Drive
Landover, MD 20785-2294
Attention: TRI Revision Request
301-429-5005
3. Hard Copy Form - Although EPA strongly discourages
paper submissions due to the increased possibility of data
entry errors, you may make corrections by one of three hard
copy methods:
• Facility Data Profile (FDP)
• Photocopy of Original
• Blank Form
a Facility Data Profile - The FDP presents the
information a facility submitted to EPA, and includes
identified errors with the submissions. If you use the
FDP to make corrections, you must submit the full
Form R or Form A Certification Statement equivalent
for each chemical. You make your revisions by
marking-up the FDP in blue ink. Also, you must sign
and submit the certification statement on page 3 of
4 Toxics Release Inventory Reporting Forms and Instructions
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General Information
the FDP. If you do not have a copy of the facility FDP,
you can retrieve it from the Internet at .
If you or the technical contact has questions about how to
respond by using your FDP, please refer to the instruction
page of the FDP or call 301-429-5005.
O Photocopy of Original Submission - You may submit a
photocopy of your original submission (from your file)
with the corrections made in blue ink. Resign and re-date
the certification statement on Page 1. Please enter an "X"
in the space marked "Enter 'X' here if this is a revision,"
on page 1 of the form.
n Blank Form - Hard copy submissions may be submitted
using the form applicable for that particular reporting year
or the most recent form available. You can request prior
year reporting forms at tridocs@epa.gov. Please
remember to certify and date the form on page 1. Also,
please enter an "X" in the space marked "Enter 'X' here if
this is a revision," on page 1 of the form.
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 TRI Data Processing Center.
To send requests by regular mail:
TRI Data Processing Center
P.O. Box 1513
Lanham,MD 20703-1513
Attention: TRI Revision Request
To send requests by certified mail or overnight mail (i.e. Fed Ex,
UPS, etc.):
TRI Data Processing Center
c/o Computer Sciences Corporation
Suite 150
8400 Corporate Drive
Landover, MD 20785-2294
Attention: TRI Revision Request
301 429-5005
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 submission(s) from EPA'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,
facilities must send their request to EPA and the appropriate state
agency, if required, by completing a 'Request for Withdrawal'
template (provided in Appendix I of this document). 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, you should submit the following
information:
O Facility name and TRI Facility Identification Number
(TRIFID).
O Facility mailing address.
n Reporting year.
n Chemical name.
n Technical contact name and phone number.
n Name and phone number of the requester.
n Reason(s) for withdrawal.
n 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 grams).
• 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 TRI Data
Processing Center.
To send requests by regular mail:
Toxics Release Inventory Reporting Forms and Instructions 5
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General Information
TRI Data Processing Center
P.O. Box 1513
Lanham,MD 20703-1513
Attention: TRI Withdrawal Request
To send requests by certified mail or overnight mail (i.e. Fed Ex,
UPS, etc.):
TRI Data Processing Center
c/o Computer Sciences Corporation
Suite 150
8400 Corporate Drive
Landover, MD 20785-2294
Attention: TRI Withdrawal Request
301 429-5005
See "Chemical and Industry Specific Documents" section (p.
ix) for the document request form and more information on
available documents.
Questions about completing Form R or Form A may be
directed to the TRI Information Center (formerly the EPCRA
Call Center) toll free. For contact information see the TRI
Home Page at .
EPA Regional Staff also may be of assistance. Refer to
Appendix G for a list of EPA Regional Offices.
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). RY2005 reports
should be postmarked on orbefore Monday, July 3,2006. If
you submit using TRI-ME via the Central Data Exchange
(CDX), you will receive your Facility Data (FDP) in an
expedited fashion. 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.
Always remember to review your FDP. The FDP presents
the information you have submitted to EPA. If the
Technical Contact provided an email address in the Form
R/Form A, they will receive an email notifying them when
their FDP has been updated and posted to the FDP website.
You can retrieve your FDPs at . If you
have questions regarding your FDP, please send an email to
tri.efdp@csc.com or call, 1-301-429-5005.
A.7 How to Obtain Forms and Other
Information
A copy of both forms is included in this booklet. Remove the
appropriate form and produce as many photocopies as needed.
Related guidance documents may be obtained from EPA's TRI
Web site and EPA:
U.S. Environmental Protections Agency
Ariel Rios Building
1200 Pennsylvania Ave., N.W.
Attn: TRI Documents
MC: 2844T
Washington, DC 20460
202 564-9554
Email: TRIDOCS@epa.gov
6 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). TEI-ME automatically creates this letter for you if you elect to create a diskette submission.
Facility Name
Facility Address
Facility City/State/Zip Code
TRI Facility ID
Date
TRI Data Processing Center
P.O. Box 1513
Lanham, MD 20703-1513
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 section 6607 of 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) 2005 7440-66-6 5-page Form R
Our technical point of contact is:
[TECHNICAL CONTACT NAME] Phone Number: 505555-1212
and is available should any questions or problems arise in your processing of these diskettes.
If the enclosed diskette contains one or more Form R chemicals, then I hereby certify that I have reviewed the enclosed 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(s) are accurate based on reasonable estimates using data available to the preparers of this report(s).
If the enclosed diskette contains one or more Form A chemicals, then I hereby certify that to the best of my knowledge and belief,
for each toxic chemical listed in the Form A 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 the reporting year.
Sincerely,
Signature
Toxics Release Inventory Reporting Forms and Instructions 1
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
This section will help you determine whether you must submit
an EPCRA section 313 report (EPA Form R or Form A
Certification Statement). This section discusses EPCRA
section 313 reporting requirements such as the number of full-
time employees, primary SIC code, and chemical activity
threshold quantities. The EPCRA section 313 chemicals and
chemical categories subject to reporting are listed in Table II
(also see 40 CFR 372.65). (See Figure 1 for more
information.)
B.I Full-Time
Determination
Employee
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.
When making the full-time employee determination the
facility must consider all paid vacation and sick leave used as
hours worked by each employee. In addition, EPA interprets
the hours worked by an employee to include paid holidays.
To determine the number of full-time employees working for
your facility, add up the hours worked by all employees
during the calendar year, including contract employees and
sales and support staff working for the facility, and divide the
total by 2,000 hours. The result is the number of "full time
employees." In other words, if the total number of hours
worked by all employees for your facility 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 during the calendar year. The sales staff also
each worked 2,000 hours during the calendar year
although they may have been on the road half of the
year. In addition, five contract employees were hired
for a period during which each worked 400 hours for
the facility. The total number of hours is equal to the
time worked by the workers (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
(2,000 hours), or 20,000 hours. Dividing the 20,000
hours by 2,000 yields 10 full-time employees. This
facility has met the full time employee criteria and may
be subject to reporting if the other criteria are met.
B.2 Primary SIC Code Determination
Standard Industrial Classification (SIC) codes 10 (except
1011, 1081, and 1094), 12 (except 1241), 20-39, 4911
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4939 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4953 (limited to
facilities regulated under the RCRA Subtitle C, 42 U.S.C.
section 6921 et seq.\ 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvent recovery services on a
contract or fee basis) are covered by EPCRA section 313 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 SIC Manual. However, for purposes of
EPCRA section 313 reporting, these state assigned codes
should not be used if they differ from ones assigned using the
SIC Manual.
The TRI Information 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 22161,703605-6000. The access number
for the clothbound manual is PB87-100012, and the price is
$36.00 + shipping and handling.
Facilities should be aware that in several years from now, the
TRI Program will be using North American Industry
Classification System (NAICS) codes instead of SIC codes.
Please refer to the TRI Program's proposed rule titled
"Community Right-to-Know; Toxic Chemical Release
Reporting Using North American Industry Classification
System (NAICS)" published in the Federal Register on March
21,2003. (66 FR 13872) This upcoming change does NOT
affect 2005 EPCRA Section 313 reporting.
8 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
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 1)
YES
Does your facility manufacture, process,
or otherwise use and EPCRA section 313
chemicals and chemical categories?
(see Table II, B.3-B.5, and D.1-D.7)
YES
Does your facility exceed any of the
thresholds for a chemical or chemical
category (after excluding quantities that
are exempt form threshold calculations)
YES
AN EPCRA SECTION 313 REPORT IS
REQURED FOR THE 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 CANNONT BE
SUMBITTED)
FORM A OR FORM R IS REQUIRED
FOR THIS CHEMICAL CATEGORY
Figure 1. EPCRA Section 313 Reporting Decision Diagram
Toxics Release Inventory Reporting Forms and Instructions 9
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
B.2.a. Multi-Establishment Facilities
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 added of the products produced,
shipped, or services provided from each establishment within
the facility and then use the following rule to determine if
your facility meets the SIC code criterion:
Q If the total value added 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 etseq.), 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
added of the entire facility's products and services, the
entire facility meets the SIC code criterion.
Q 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,or7389 (limited to facilities primarily
engaged in solvents recovery services on a contract or
fee basis) has a value added of services or products
shipped or produced that is greater than any other
establishment within the facility (40 CFR Section
372.22(b)(3)) the facility also meets the SIC code
criterion.
The value added of production or service attributable to a
particular establishment may be isolated by subtracting the
product value obtained from other establishments within the
same facility from the total product or service value of the
facility. This procedure eliminates the potential for "double
counting" production and services in situations where
establishments are engaged in sequential production or service
activities at a single facility.
Examples include:
Q A facility in coating, engraving and allied services has
two establishments. The first establishment, a general
automotive repair service, is in SIC code 7537, which is
not a covered SIC code. However, the second
establishment, a metal paint shop is in SIC code 3479,
which is a covered SIC code. The metal paint shop
paints the parts received from general automotive repair
service. The facility determines the product is worth
$500/unit as received from the general automotive
repair service (in non covered SIC code 7537) and the
value of the product is $1500/unit after processing by
the metal paint shop (in covered SIC code 3479). The
value added by the metal paint shop is obtained by
subtracting the value of the products from the general
automotive repair service from that of the value of the
products of the metal paint shop. (In this example, the
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.
Q A food processing establishment in a facility processes
crops grown at the facility in a separate establishment.
To determine the value added of the products of each
establishment 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
practical purposes, separate and distinct business units.
Therefore, while threshold determinations must be made for
the entire facility, individual establishments which compose
the entire facility may report their individual releases and
other waste management activities separately. However, the
total releases and other waste management quantities for the
entire facility must be represented by the sum of the releases
and other quantities managed as waste reported by each of the
separate establishments.
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
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
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, an auxiliary facility is defined as one
primarily engaged in performing support services for another
covered establishment or multiple establishments of a covered
facility and is in a different physical location than the primary
facility. In addition, an auxiliary facility performs an integral
role in the primary facility's activities. In general, an
auxiliary facility's basic administrative services (paperwork,
payroll, employment) are performed by the primary facility.
Thus, a separate warehouse facility (i.e., one not located
within the physical boundaries of a covered facility) may
become a covered facility because it services a covered
establishment in SIC codes 10 (except 1011,1081, and 1094),
12 (except 1241), 20-39, 4911 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4931 (limited to
facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4939
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4953 (limited to facilities regulated under the
RCRA Subtitle C, 42 U.S.C. section 6921 et seq.\ 5169,
5171, and 7389 (limited to facilities primarily engaged in
solvents recovery services on a contract or fee basis).
Auxiliary facilities that are in these aforementioned codes are
required to report if they meet the employee criterion and
reporting thresholds for manufacture, process, or otherwise
use.
B.2.c. 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,"
"Process," and "Otherwise Use"
Manufacture: The term "manufacture" means to produce,
prepare, compound, or import an EPCRA section 313
chemical. (See Part II, Section 3.1 of these instructions for
further clarification.)
Import is defined as causing the EPCRA section 313 chemical
to be imported into the customs territory of the United States.
If you order an EPCRA section 313 chemical (or a mixture
containing the chemical) from a foreign supplier, then you
have imported the chemical when that shipment arrives at
your facility directly from a source outside of the United
States. By ordering the chemical, you have "caused it to be
imported," even though you may have used an import
brokerage firm as an agent to obtain the EPCRA section 313
chemical.
Do Not Overlook Coincidental Manufacture
The term manufacture also includes coincidental production
of an EPCRA section 313 chemical (e.g., as a byproduct or
impurity) as a result of the manufacture, processing, otherwise
use or disposal of another chemical or mixture of chemicals.
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.
Process: The term process" means the preparation of a listed
EPCRA section 313 chemical, after its manufacture, for
distribution in commerce. Processing is usually the
incorporation of an EPCRA section 313 chemical into a
product (see Part II, Section 3.2 of these instructions for
further clarification), however, a facility may process an
impurity that already exists in a raw material by distributing
that impurity in commerce. Processing includes preparation
of the EPCRA section 313 chemicals in the same physical
state or chemical form as that received by your facility, or
preparation that produces a change in physical state or
chemical form. The term also applies to the processing of a
mixture or other trade name product (see Section B.4.b of
these instructions) that contains a listed EPCRA section 313
chemical as one component.
Otherwise Use: The term 'otherwise use" means any use of
an EPCRA section 313 chemical, including an EPCRA section
313 chemical contained in a mixture or other trade name
product or waste, that is not covered by the terms
"manufacture" or "process." Otherwise use of an EPCRA
section 313 chemical does not include disposal, 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;
(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).
Toxics Release Inventory Reporting Forms and Instructions 11
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Example 1: Coincidental Manufacture
Q 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).
Q 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.
Example 2: Typical Process and Manufacture Activities
Q Your company receives toluene, an EPCRA section 313 chemical, from another facility, and reacts the toluene with air to
form benzoic acid, which the company distributes in commerce. Your company processes toluene and manufactures and
processes benzoic acid. Benzoic acid, however, is not an EPCRA section 313 chemical and thus does not trigger
reporting requirements.
Q Your facility combines toluene purchased from a supplier with various materials to form paint which it then sells. Your
facility processes toluene.
Q 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.
Q 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.
Q 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(CuO)). 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.
12 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Example 3: Typical Otherwise Use Activities
Q When your facility cleans equipment with toluene, you are otherwise using toluene. Your facility also separates two
components of a mixture by dissolving one component in toluene, and subsequently recovers the toluene from the process
for reuse or disposal. Your facility otherwise uses toluene.
Q A covered facility receives a waste containing 12,000 pounds of Chemical A, 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.
Toxics Release Inventory Reporting Forms and Instructions 13
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
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.
Dioxin and dioxin-like compounds, lead compounds, mercury
compounds and polycyclic 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 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."
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, or in the case of the dioxin and
dioxin-like compounds chemical category, to 0.1 grams. The
table at the beginning of Section B .4 of these instructions lists
the applicable manufacture, process, and otherwise use
thresholds for the listed PBT chemicals.
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 Section 372.45(d)(l)).
All PBT chemicals and chemical categories (hereafter referred
to as PBT chemicals) are excluded from eligibility for the
alternate threshold of one million pounds. Thus the Form A
cannot be used for PBT chemicals (except lead when it is in
stainless steel, brass or bronze alloys when the 100 Ibs
threshold for lead has not been exceeded). 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
14 Toxics Release Inventory Reporting Forms
estimate is based. 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 grams, 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 that exceeds the 25,000/10,000 pound threshold 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
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
compounds is allowed only on Form R because Form A is
never allowed when reporting lead compounds.
B.3.C. Activity Exemptions
Otherwise Use Exemptions. Certain otherwise uses of listed
EPCRA section 313 chemicals are specifically exempted:
Q Otherwise use as a structural component of the
facility;
Q Otherwise use in routine janitorial or facility
grounds maintenance;
Q Personal uses by employees or other persons;
Q Otherwise use of products containing EPCRA
section 313 chemicals for the purpose of
maintaining motor vehicles operated by the facility;
and
Q Otherwise use of EPCRA section 313 chemicals
contained in intake water (used for processing or
non-contact cooling) or in intake air (used either as
compressed air or for combustion).
The exemption of an EPCRA section 313 chemical otherwise
used 1) as a structural component of the facility; or 2) in
routine janitorial or facility grounds maintenance; or 3) for
personal use by an employee cannot be taken for activities
involving process-related equipment.
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.
What constitutes a release of an EPCRA section 313 chemical
is important since processing or otherwise use of articles that
result in a release to the environment (or more than 0.5
pounds) negate 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.
Toxics Release Inventory Reporting Forms and Instructions 15
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Example 4: Articles Exemption
Q 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.
Q If an item used in the facility is fragmented, the item is still an article if those fragments being discarded remain
identifiable as the article (e.g., recognizable pieces of a cylinder, pieces of wire). For instance, an eight-foot piece of wire
is cut into two four-foot pieces of wire, without releasing any EPCRA section 313 chemicals. Each four-foot piece is
identifiable as a piece of wire; therefore, the article status for these pieces of wire remains intact.
Q EPCRA section 313 chemicals received in the form of pellets are not articles because the pellet form is simply a
convenient form for further processing of the material.
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 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 must
consider the concentration of the non-PBT EPCRA section
313 chemical in mixtures and other trade name products. If
the non-PBT EPCRA section 313 chemical in a mixture or
other trade name product 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 mixture
or other trade name product 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 mixture or other trade name product
is below the appropriate de minimis level, all releases and
other waste management activities associated with the EPCRA
section 313 chemical in that mixture or other trade name
product are exempt from EPCRA section 313 reporting. It is
possible to meet an activity (e.g., processing) threshold for an
EPCRA section 313 chemical on a facility-wide basis, but not
be required to calculate releases or other waste management
quantities associated with a particular process because that
process involves only mixtures or other trade name products
containing the non-PBT EPCRA section 313 chemical below
the de minimis level.
EPA interprets the de minimis exemption such that once a
non-PBT EPCRA section 313 chemical concentration is at or
above the appropriate de minimis level in the mixture or other
trade name product 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 mixture or other trade name product. Thus, EPA
16 Toxics Release Inventory Reporting Forms and Instructions
considers reportable all releases and other quantities managed
as waste that occur after the de minimis level has been met or
exceeded. 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) in its Annual
Report on Carcinogens, the International Agency for Research
and Cancer (IARC) in its 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 section 313 chemical is present in a mixture at a
concentration below the de minimis level, this quantity of the
substance does not have to be included for threshold
determinations, release and other waste management
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
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 when below de minimis levels, i.e., prior to distillation to 1%, 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.
reporting, or supplier notification requirements. The
exemption will apply as long as the mixture containing de
minimis amounts of a non-PBT EPCRA section 313 chemical
never equals or goes above the de minimis limit.
Concentration Ranges Straddling the De Minimis Value
There may be instances in which the concentration of a non-
PBT chemical is given as a range straddling the de minimis
limit. Example 6 illustrates how the de minimis exemption
should be applied in such a scenario.
De Minimis Application in the Manufacture
of the Listed Chemical in a Mixture
The de minimis exemption generally does not apply to the
manufacturing of an EPCRA section 313 chemical. However,
the de minimis exemption may apply to mixtures and other
trade name products containing non-PBT EPCRA section 313
chemicals that are imported into the United States. (See
example 5 on page 18.)
The exemption also applies to non-PBT EPCRA section 313
chemicals that are manufactured as impurities that remain in
the product distributed in commerce below the de minimis
levels. The amount remaining in the product is exempt from
threshold determinations. If the chemical is separated from
the final product, it cannot qualify for the exemption. Any
amount that is separated, or is separate, from the product, is
considered a byproduct and is subject to threshold
determinations and release and other waste management
calculations. Any amount of an EPCRA section 313 chemical
that is manufactured in a waste stream must be considered
toward threshold determinations and release and other waste
management calculations and accounted for on Form R even if
that chemical is manufactured below the de minimis level.
Toxics Release Inventory Reporting Forms and Instructions 17
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Example 6: Concentration Ranges Straddling the De Minimis Value
Q A facility processes 8,000,000 pounds of amixture 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%) -
(8,000,OOOXl.25% - 0.99%)'
(1.25% -0.25%)
x
'(l.25%+ 1.00%)'
= 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.
Q As in the previous example, manganese is present in a mixture, of which 8,000,000 pounds is processed. The MSDS
states the mixture contains 0.2% to 1.2% manganese. The amount of mixture subject to reporting (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
'(8,000,000X1 -2% ~ 0.9%)
(l.2%-0.2%)
(l.2%+ 1.0%)'
. (2) .
= 26,4QQpounds
= 26,400 pounds manganese (which is above the processing threshold for manganese)
18 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Example 7: De Minimis Application in the Manufacture of a Toxic Chemical in a Mixture
Manufacture as a Product Impurity
Toluene-2,4-diisocy anate reacts with trace amounts of water to 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.
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 subj ect toa0.1%(1000 ppm) de minimis limit. Any amount of chloroform manufactured and separated
as byproduct must be included in threshold determinations because EPA does not interpret the de minimis exemption to apply to the
manufacture of a chemical as a byproduct. Releases of chloroform prior to and during purification of the carbon tetrachloride must
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.
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 waste stream to which it was separated because EPA does not interpret mixtures and trade name products to
includes wastes.
The de minimis exemption also does not apply to situations
where a toxic chemical in waste is diluted to below the de
minimis level.
Laboratory Activities Exemption. EPCRA section 313
chemicals that are manufactured, processed, or otherwise used
in a laboratory at a covered facility under the direct
supervision of a technically qualified individual do not have to
be considered for threshold determinations and release and
other waste management calculations. However, pilot plant
scale and specialty chemical production does not qualify for
this laboratory activities exemption, nor does the use of
EPCRA section 313 chemicals for laboratory support
activities, such as the use of chemicals for equipment
maintenance.
Coal Extraction Activities Exemption. If an EPCRA section
313 chemical is manufactured, processed, or otherwise used in
extraction by facilities in SIC code 12, a person is not required
to consider the quantity of the EPCRA section 313 chemical
so manufactured, processed, or otherwise used when
considering threshold determinations and release and other
waste management calculations (See example 8).
Reclamation 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 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 manufactured,
processed or otherwise used during extraction activities
at coal mines.
Toxics Release Inventory Reporting Forms and Instructions 19
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
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:
Q 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:
Q 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 poly cyclic
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
CAS
number or
chemical
category
code
309-00-2
191-24-2
57-74-9
N150
76-44-8
118-74-1
Threshold
(pounds,
unless
noted
otherwise)
100
10
10
0.1 gram
10
10
Chemical or chemical
category name
Lead (this lower
threshold does not apply
to lead when it is
contained in stainless
steal, brass or bronze
alloy)
Lead compounds
Mercury
Mercury compounds
Methoxychlor
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Poly chlorinated
biphenyls (PCBs)
Polycyclic aromatic
compounds category
(PACs)
Tetrabromobisphenol A
Toxaphene
Trifluralin
CAS
number or
chemical
category
code
7439-92-1
N420
7439.97-6
N458
72-43-5
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)
100
100
10
10
100
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.
20 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
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 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 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 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% of the aqueous ammonia in that solution. If
the ammonia remains in solution, then 10% of the total
aqueous ammonia is counted towards the threshold. If there
are any evaporative losses of anhydrous ammonia, then 100%
of those losses must be counted towards the processing
Toxics Release Inventory Reporting Forms and Instructions 21
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
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 Form R.
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.m 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 should be based on CAS numbers. For
example, 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 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).
Individually listed EPCRA section 313 chemicals are subject
to their own, individual threshold determination.
Organic Compounds
For the organic compound categories, you are required to
account for the entire weight of all compounds within a
specific compound category (e.g., glycol ethers) at the facility
for BOTH the threshold determination and release and other
waste management estimates.
Metal Category Compounds
Threshold determinations for metal category 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
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 the nickel and nickel compounds chemical
category 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 category compounds involving more than
one metal should be noted. Some metal category compounds
may contain more than one listed metal. For example, lead
chromate is both a lead compound and a chromium
compound. In such cases, if applicable thresholds are
exceeded, you are required to file two separate reports, one for
lead compounds and one for chromium compounds. Apply
the total weight of the lead chromate to the threshold
determinations for both lead compounds and chromium
compounds. (Note: Only the amount of each parent metal
released or otherwise managed as waste, not the amount of the
compound, would be reported on the appropriate sections of
both Form Rs. 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
chemicals' 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
bioaccumulative, it is 10 pounds. One exception is the dioxin
and dioxin-like compounds chemical category—the 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 readily available data (or reasonable
estimates if such data are not readily available) to determine
whether the toxic chemicals in a mixture meet or exceed the
de minimis concentration and, therefore, whether they 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
22 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
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 it is present
below the de minimis level, 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. PBT chemicals are
not eligible for the de minimis exemption except lead when it
is contained in stainless steel, brass or bronze alloy.
Observe the following guidelines in estimating concentrations
of EPCRA section 313 chemicals in mixtures when only
limited information is available:
Q If you only know the upper bound concentration, you
must use it for threshold determinations (40 CFR section
372.30(b)(ii)).
Q If you know the lower and upper bound concentrations
of an EPCRA section 313 chemical in a mixture, EPA
recommends you use the midpoint of these two
concentrations for threshold determinations.
Q If you know only the lower bound concentration, EPA
recommends you subtract out the percentages of any
other known components to determine a reasonable
upper bound concentration, and then determine a
midpoint.
Q If you have no information other than the lower bound
concentration, EPA recommends you calculate a
midpoint assuming an upper bound concentration of
100%.
Q In cases where you only have a concentration range
available, EPA recommends you 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, only the weight of the metal
portion of the metal category compound must be considered
for release and other waste management determinations.
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
For compounds within the metal compound categories, only
the metal portion of the metal category compound must be
considered in determining release and other waste
management quantities for the 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 FormR. Note that
this does not apply to the Form A. See the section in these
instructions on the Form A. See Appendix B for more
information about reporting the release and other waste
management of metals and metal compounds.
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 only the nitrate portion of the compound
should be used for release and other waste management
calculations.
Toxics Release Inventory Reporting Forms and Instructions 23
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
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% n-hexane, an EPCRA section 313
chemical; however, it also states that the solvent contains 20% non-hazardous surfactants. This is the only n-hexane-containing
mixture used at the facility.
EPA recommends you 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 n-hexane 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 n-hexane.
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.
EPA recommends you 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.
24 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Figure 2A. EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet1
Facility Name: Date Worksheet Prepared:
EPCRA Section 313 Chemical or Chemical Category: Prepared By:
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 (de minimis,
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
Ib
Amount subject to threshold: (A-Aj) Ib (B-Bj) Ib (C-Cj)
Compare to threshold for EPCRA section 313 reporting. 25,000 Ibs 25,000 Ibs 10,000 Ibs
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.
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 Ibs;
all other PBT chemicals = 100 Ibs). Make certain you are using the appropriate worksheet for the toxic chemical of concern.
Toxics Release Inventory Reporting Forms and Instructions 25
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Figure 2B. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100 Pound Thresholds
Facility Name: Date Worksheet Prepared:
EPCRA Section 313 Chemical or Chemical Category: Prepared By:
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
Amount of the EPCRA Section 313 Chemical Exempt
from Above (Ib):
Manufactured
(A,) Ib
Processed
(B,) Ib
Otherwise Used
(C,) Ib
(A-AO_
Ib (B-BO_
Amount subject to threshold:
Compare to threshold for EPCRA section 313 reporting. 100 Ibs 100 Ibs
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R; retain it for your records.
Ib
Ib
100 Ibs
Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
26 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Figure 2C. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10 Pound Thresholds
Facility Name: Date Worksheet Prepared:
EPCRA Section 313 Chemical or Chemical Category: Prepared By:
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.
(A-AO_
Ib (B-BO_
.Ib
Ib
10 Ibs
10 Ibs
10 Ibs
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R; retain it for your records.
Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
Toxics Release Inventory Reporting Forms and Instructions 27
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
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
Amount subject to threshold: (A-Aj) g (B-Bj) g (C-Cj) g
Compare to threshold for EPCRA section 313 reporting. 0.1 gram 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.
Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
28 Toxics Release Inventory Reporting Forms and Instructions
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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 2005 reporting year must be submitted on or
before July 1,2006.
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 3 of these
instructions for specific information on trade secrecy claims.) If
you checked "no," proceed to Section 3; do not answer
Section 2.2.
D 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 that is
structurally descriptive in its place, and if 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 a senior official
with management responsibility for the person (or persons)
completing the form. A senior management 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. You should print or
type the name and title of the person who signs the statement in
the space provided. 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
must 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, you
should 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 TRI-ME. "NA" or
"None" are not acceptable entries.
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, you should complete Section
4. If you do not know your TRI Facility Identification
Number, you should contact the CDX Help Desk toll free at
1-888-890-1995 or your Regional TRI Program
representative, or utilize Envirofacts on the Web to look up
the address or facility name . 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, you should use the same TRI Facility Identification
Number for each establishment.
The TRI Facility Identification Number is established by the
first Form R submitted by a facility at a particular location.
Only a change in address warrants filing as a new facility;
otherwise, the TRI Facility Identification Number is retained
by the facility even if the facility changes name, ownership,
production processes, SIC codes, etc. This identification
number will stay with this location. If a new facility moves
to this location it should use this TRI Facility Identification
Number. Establishments of a facility that report separately
should use the TRI Facility Identification Number of the
facility.
You should enter "New Facility" in the space for the TRI
Facility Identification number if this is your first
submission.
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 (or by any person which
controls, is controlled by, or under common control with
such person). A facility may contain more than one
establishment."
EPCRA section 313 defines establishment as "an economic
unit, generally at a single physical location, where business
is conducted or where services or industrial operations are
performed." 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
Toxics Release Inventory Reporting Forms and Instructions 29
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Instructions for Completing Part II of EPA Form R
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. 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
(GOCOs—Government-owned, contractor-operated facilities)
should check either 4.2c or 4.2d, but not both. Federal facilities
should 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, should 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. You
should also enter an email address for this person. EPA
encourages facilities to provide an email address for its Technical
Contact on their TRI submissions because they will be able to
receive important program updates and email alerts notifying
them when their FDP has been updated and is available on the
FDP website. If the technical contact does not have an email
address you should enter NA. 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 should be familiar with the details of the report so that he
or she can answer questions about the information provided.
4.4 Public Contact
Enter the name and telephone number (including area code) of a
person who can respond to questions from the public about the
report. If you 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.
4.5 Standard Industrial Classification (SIC) Code
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, 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). If the report covers more than one
establishment, enter the primary 4-digit SIC code for each
establishment starting with the primary SIC code for the
entire facility. You are required to enter SIC codes only for
those establishments within the facility that fall within SIC
codes 10 (except 1011, 1081, and 1094), 12 (except 1241),
20-39, 4911 (limited to facilities that combust coal and/or
oil for the purpose of generating electricity for distribution
in commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4939 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4953 (limited to
facilities regulated under the RCRA Subtitle C, 42 U.S.C.
section 6921 et seq.\ 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvents recovery services on
a contract or fee basis). If you do not know your SIC code,
consult the 1987 SIC Manual (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 2005 EPCRA section 313 reporting.
4.6 Latitude and Longitude
(Deleted)
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 number can be obtained,
toll free at 800 234-3867 (8:00 AM to 6:00 PM, Local
Time) or on the Web at . If none of your
establishments has been assigned a D & B number, you
should 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)
(Deleted)
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
3 0 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing EPA Form R
4.9 NPDES Permit Number(s)
(Deleted)
4.10 Underground Injection
Well Code (UIC) Identification Number(s)
(Deleted)
Section 5. Parent Company Information
You must provide information on your parent company. For
purposes of the Form R, 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 should be treated as parent company names for
companies with multiple facility sites. For example, the
Bestchem Corporation is not owned or controlled by any other
corporation but has sites throughout the country whose names
begin with Bestchem. In this case, Bestchem Corporation should
be listed as the parent company. Note that a facility that is a
50:50 joint venture is its own parent company. When a facility is
owned by more than one company and none of the facility
owners directly owns at least 50 percent of its voting stock, the
facility should provide the name of the parent company of either
the facility operator or the owner with the largest ownership
interest in the facility. If neither the operator nor this owner has a
parent company, then the NA box should be checked.
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, you should check the NA box.
5.2 Parent Company's Dun & Bradstreet Number
Enter the D & B number for your ultimate U. S. parent company,
if applicable. The number may be obtained from the treasurer or
financial officer of the company. If your parent company does
not have a D & B number, you should check the NA box.
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), you should 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
NO 90 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 Poly chlorinated alkanes (CIO to C13)
N590 Polycyclic 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 substantiation form. 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
Toxics Release Inventory Reporting Forms and Instructions 31
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Instructions for Completing Part II of EPA Form R
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 an 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 that is structurally descriptive in Part
II, Section 1.3 of your sanitized Form R report.
EPA requests that the EPCRA section 313 chemical, chemical
category, or generic name also be placed in the box marked
"Toxic Chemical, Category, or Generic Name" in the upper
right-hand corner on all pages of Form R. While this space is
not a required data element, providing this information will
help you in preparing a complete Form R report.
1.3 Generic Chemical Name
Complete Section 1.3 only if you are claiming the specific
EPCRA section 313 chemical identity of the EPCRA section
313 chemical as a trade secret and have marked the trade
secret block in Part I, Section 2.1 on page 1 of Form R. Enter
a generic chemical name that is descriptive of the chemical
structure. You should 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 media from your
facility 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, you should indicate NA. 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 must
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
7
8
9
10
11
P
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
03268-87-9
57117-41-6
57117-31-4
40321-76-4
51207-31-9
01746-01-6
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
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.
3 2 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
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, 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
folio-wing 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, generically identified mixture
component.
Section 3. Activities and Uses of the
EPCRA Section 313 Chemical at the
Facility
Indicate whether the EPCRA section 313 chemical is
manufactured (including imported), processed, or otherwise
used at the facility and the general nature of such activities
and uses at the facility during the calendar year (see figure
3). You are not required to report on Form R the quantity
manufactured, processed or otherwise used. Report
activities that take place only at your facility, not activities
that take place at other facilities involving your products.
You must check all the boxes in this section that apply.
Refer to the definitions of "manufacture," "process," and
"otherwise use" in the general information section of these
instructions or Part 40, Section 372.3 of the Code of
Federal Regulations for additional explanations.
3.1 Manufacture the EPCRA Section 313 Chemical
Persons who manufacture (including import) the EPCRA
section 313 chemical must check at least one of the following:
a. Produce — The EPCRA section 313 chemical is
produced at the facility.
b. Import — The EPCRA section 313 chemical is
imported by the facility into the Customs Territory of the
United States. (See Section B.3.a of these instructions
for further 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
Persons who process the EPCRA section 313 chemical must
check at least one of the following:
a. As a reactant — A natural or synthetic EPCRA
section 313 chemical is used in chemical reactions
for the manufacture of another chemical substance
or of a product. Includes but is not limited to,
feedstocks, raw materials, intermediates, and
initiators.
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.
Toxics Release Inventory Reporting Forms and Instructions 3 3
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Instructions for Completing Part II of EPA Form R
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. Repackaging — This consists of processing or
preparation of an EPCRA section 313 chemical (or
product mixture) for distribution in commerce in a
different form, state, or quantity. This includes, but
is not limited to, the transfer of material from a bulk
container, such as a tank truck to smaller containers
such as cans or bottles.
e. As an impurity — The EPCRA section 313
chemical is processed but is not separated and
remains in the mixture or other trade name product
with that/those other chemical(s).
3.3 Otherwise Use the EPCRA Section 313 Chemical (non-
incorporative activities)
Example 11: Manufacturing and Processing
EPCRA Section 313 Chemicals
Activities of
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 fifty percent is
reacted with alpha-naphthylamine, forming N-methyl-alpha-
naphthylamine and also producing nitrogen gas.
Your company manufactures diazomethane, an EPCRA
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 Form R.
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.
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 that is used at a facility for purposes other
than aiding chemical processing or manufacturing as
described above is otherwise used as an 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 wastes generated) 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 the Maximum
Amount On Site.
3 4 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA 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 Uie 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. Distribution 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
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. X Produce b.
Import
IF produce or import:
For on-site use/processing
For sale/distribution
As a byproduct
As an impurity
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
(e.g., nickel compounds), include all chemical compounds in
the category when calculating the maximum amount, using
the entire weight of each compound. When reporting for
dioxin and dioxin-like compounds you should convert the
maximum amount from grams to pounds before choosing the
appropriate range code in Section 4 of Part II.
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.
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 (do not use
scientific notation). 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
name product. For EPCRA section 313 chemical categories
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Instructions for Completing Part II of EPA Form R
category), provided the accuracy and the underlying data on
which the estimate is based supports this level of precision.
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).
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.
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 should not be used, 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 should be checked in Part II,
Section 5.5.1 .B of Form R.
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. You should 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.
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. You should 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. You should enter
NA in Section 5.3.1 if there are no discharges to receiving
streams or water 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 water body. Include process outfalls
such as pipes and open trenches, releases from on-site
wastewater treatment systems, and the contribution from
stormwater runoff, if applicable (see instructions for column C
3 6 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
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. You should 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 n-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. You should 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. aNumeric 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, you should check the NA box in sections
5.5.1A 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.
5.5.1A RCRA Subtitle C landfills —Enter the total amount of
the EPCRA section 313 chemical that was placed in RCRA
Subtitle C landfills. EPA has not required facilities to
estimate leaks from landfills because the amount of the
EPCRA section 313 chemical has already been reported as a
release.
facilities to estimate leaks from landfills because the amount
of the EPCRA section 313 chemical has already been reported
as a release.
5.5.2 Land treatment/application farming — Land treatment
is a disposal method in which a waste containing an EPCRA
section 313 chemical is applied onto or incorporated into soil.
While this disposal method is considered a release to land,
any volatilization of EPCRA section 313 chemicals into the
air occurring during the disposal operation must not be
included in this section but must be included in the total
fugitive air releases reported in Part II, Section 5.1 of Form R.
Surface Impoundments — 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 must
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 during the reporting year. The
facility must report this as a fugitive air emission in section
5.1. The balance should be reported in either section 5.5.3 A
or5.5.3B.
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 an 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 must 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.
5.5.3A RCRA Subtitle C Surface Impoundments — Enter
the total amount of the EPCRA section 313 chemical that was
placed in RCRA Subtitle C surface impoundments.
5.5.3B Other Surface Impoundments — Enter the total
amount of the EPCRA section 313 chemical that was placed
in surface impoundments other than RCRA Subtitle C surface
impoundments.
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).
5.5. IB Other landfills — Enter the total amount of the
EPCRA section 313 chemical that was placed in landfills
other than RCRA Subtitle C landfills. EPA has not required
Toxics Release Inventory Reporting Forms and Instructions 3 7
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Instructions for Completing Part II of EPA Form R
Section 5 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
11-499
500-999
Do not enter a range code and an estimate in the same box in
column A. Total annual on-site releases of an EPCRA section
313 chemical from the facility of less than 1 pound may be
reported in one of several ways. You should round the value
to the nearest pound. If the estimate is greater than 0.5 pound,
you should either enter the range code "A" for" 1 -10" or enter
"1" 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.
Calculating On-Site Releases. To provide the release
information in column A, EPCRA section 313(g)(2) requires a
facility to use readily available data (including monitoring
data) collected pursuant to other provisions of law, or, where
such data are not readily available, "reasonable estimates" of
the amounts involved. If available data (including monitoring
data) are known to be nonrepresentative, facilities must make
reasonable estimates using the best readily available
information.
Reasonable estimates of the amounts released should 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 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 should 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 per year of 4-chlorophenol
to air as fugitive emissions, you must 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 must 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.
Section 5 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 should enter a letter code that identifies the
3 8 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
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
should 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, you should report "O"
because "engineering calculations" were used as the basis of
estimate of the quantity of the EPCRA section 313 chemical
in the waste.
If the concentration of the EPCRA section 313 chemical in the
waste was measured by monitoring equipment and the flow
rate of the waste was determined by mass balance, then the
primary basis of the estimate should be "monitoring" (M).
Even though a mass balance calculation also contributed to
the estimate, "monitoring" should be indicated because
monitoring data were used to estimate the concentration of the
waste.
Mass balance (C) should only be indicated if it is directly
used to calculate the mass (weight) of EPCRA section 313
chemical released. Monitoring data should be indicated as the
basis of estimate only if the EPCRA section 313 chemical
concentration is measured in the waste being released into the
environment. Monitoring data should not be indicated, for
example, if the monitoring data relate to a concentration of the
EPCRA section 313 chemical in other process streams within
the facility.
It is important to realize that the accuracy and proficiency of
release estimation will improve over time. However,
submitters are not required to use new emission factors or
estimation techniques to revise previous Form R submissions.
Section 5 Column C: Percent from Stormwater
This column relates only to Section 5.3—discharges to
receiving streams or water bodies. If your facility has
monitoring data on the amount of the EPCRA section 313
chemical in stormwater runoff (including unchanneled runoff),
you must include that quantity of the EPCRA section 313
chemical in your water release in column A and indicate the
percentage of the total quantity (by 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 incolumnC. If your
facility has no stormwater monitoring data for the chemical,
you should 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
Runoff Coefficient
0.70-0.95
0.50-0.70
0.50-0.80
0.60-0.90
Toxics Release Inventory Reporting Forms and Instructions 3 9
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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%
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%
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
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.
You should 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:
40 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
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 40).
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 must 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, you
should enter NA in the box for the POTW's name in Section
6.1 .B._ If you do not ship or transfer wastes containing the
reported EPCRA section 313 chemical to other off-site
locations, you should 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 comer of each
box, the section number is either 6.1 .B._. or 6.2._.
If you report a transfer of the listed EPCRA section 313
chemical to one or more POTWs, you should number the
boxes in Section 6.1 .B as 6.1 .B. 1,6.1 .B.2, etc. If you transfer
the EPCRA section 313 chemical to more than two POTWs,
you should 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
should be numbered 6.I.B.I and 6.1.B.2, while the box for
third POTW on the second page 3 should 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, you should 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, you should 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 the 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 should 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 should be
numbered 6.2.3.
6.1 Discharges to Publicly Owned Treatment Works
In Section 6.1 A, 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., you should 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 6.1 .B._ (See discussion
ofNA 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:
Toxics Release Inventory Reporting Forms and Instructions 41
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Instructions for Completing Part II of EPA Form R
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
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. You should enter one
of the following letter codes that applies to the method by
which the largest percentage of the estimate was derived.
M— Estimate is based on monitoring data or measurements
for the EPCRA section 313 chemical as transferred to
an off-site facility.
C— Estimate is based on mass balance calculations, such as
calculation of the amount of the EPCRA section 313
chemical in streams entering and leaving process
equipment.
E— Estimate is based on published emission factors, such as
those relating release quantity to through-put or
equipment type (e.g., air emission factors).
O— Estimate is based on other approaches such as
engineering calculations (e.g., estimating volatilization
using published mathematical formulas) or best
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 48 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 a single waste stream 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, you should
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). 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) enter NA in the box for the
off-site location EPA Identification Number. If you ship or
transfer hazardous wastes containing an EPCRA section 313
chemical to a facility that treats, stores, or disposes RCRA
hazardous wastes, make sure to include that facility's RCRA
Identification Number in the box for the off-site location EPA
Identification Number. This RCRA ID is shown on the
RCRA manifest that must accompany the hazardous waste to
the off-site facility.
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. You should 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 TRI Information Center. There is nothing
to enter in the state field.
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, you
should 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:
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999
42 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/cm
dFor water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
Tor motor oil, viscosity = 94 centipoise, surface tension = 34.5 dynes/cm
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 43
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Instructions for Completing Part II of EPA Form R
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, will enter 7,500 pounds into a recovery process, and
will 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 you should 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, you should
report the final disposition of the toxic chemical.
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 POTW eventually releases these
chemicals to a stream. The off-specification products
(containing copper) are collected and sent off-site to a RCRA
Subtitle C 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 must report 500 pounds in Sections 6.1
and 8.Id, and 1200 pounds in Sections 6.2 (waste code M65
(RCRA Subtitle C Landfill) should be used) and 8.Id.
Note that for EPCRA section 313 chemicals that are not
metals or metal category compounds, the quantity sent for
treatment at POTWs and to other off-site treatment locations
must be reported in Section 8.7 — Quantity Treated Off-site.
However, if you know that some or all of the chemical is not
treated for destruction at the off-site location you must report
that quantity in Section 8.1.
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., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying an estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment was
fully identified through monitoring data.
6.2c Column C: Type of Waste Management: Disposal/
Treatment/Energy Recovery/Recycling
You should enter one of the following M codes to identify the
type of disposal, treatment, energy recovery, or recycling
methods used by the off-site location for the reported EPCRA
section 313 chemical. You must use more than one line and
code for a single location when distinct quantities of the
reported EPCRA section 313 chemical are subject to different
waste management activities, including disposal, treatment,
energy recovery, or recycling. You must use the code that
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 treatment
for destruction, 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
44 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form R
heating value, e.g., CFCs, you should 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, M64, M65,
M66, M67, M73, M79, M81, M82, 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 should 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/Stabilization—Metals and Metal
Category Compounds only
M62 Wastewater Treatment (Excluding POTW) -
Metals and Metal Category Compounds only
M64 Other Landfills
M65 RCRA Subtitle C Landfills
M66 Subtitle C Surface Impoundment
M67 Other Surface Impoundments
M73 Land Treatment
M79 Other Land Disposal
M81 Underground Injection to Class I Wells
M82 Underground Inj ection to Class II-V Wells
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 4 5
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Instructions for Completing Part II of EPA Form R
Figure 4
Hypothetical Section 6.2 Completed for Two Off-Site Locations
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
UULttbblb
Market Street
Anywhere
CO
Zip Code |S location under a
5U4O1 facility or parent ca
A. Total Transfers (pounds)/year)
(enter range code or estimate) (enter code)
1.
2.
3.
4.
5,000
7,500
2,500
NA
i.O
2.C
3.0
4.
2461
County
TTill
11111
introl of reporting r- 1 „ ryi No
mpany
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. M56
2 M20
_ M03
4. M
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, will enter 7,500 pounds into a recovery process, and will 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
combusted for the purposes of energy recovery in an industrial furnace. Note that the tetrachloroethylene should be 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
1
City
State
Combus
UUL)lb7/2
tion, Inc.
5432
5 Facility Road
Dumfiy
pn
Zip Code
A. Total Transfers (pounds)/year)
(enter range code or estimate)
1.
2.
12,500
NA
3.
4.
Cn^Ofi Is location under ct
olOUU facility or parent co
i. 0
2.
3.
4.
County
>ntrol of reporting Q Yes [3 No
mpany
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
j M54
2. M
3. M
4. M
46 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 On-Site Waste Treatment Methods and
Efficiency
Most of the chemical-specific information required by
EPCRA section 313 that is reported on Form R is specific to
the EPCRA section 313 chemical rather than the waste stream
containing the EPCRA section 313 chemical. However,
EPCRA section 313 does require that waste treatment
methods applied on-site to waste streams that contain the
EPCRA section 313 chemical be reported. This information
is reportable regardless of whether the facility actively applies
treatment or the treatment of the waste stream occurs
passively. This information is collected in Section 7A of
FormR.
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; and
(c) The efficiency of each waste treatment method or waste
treatment sequence in destroying or removing the
EPCRA section 313 chemical.
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)
that of process wastewater.
7A Column b: Waste Treatment Method(s) Sequence
Due to the publication of the TRI Reporting Forms
Modification Rule on July 12, 2005, the on-site waste
treatment method(s) sequence reporting requirement codes
have changed. Prior to the publication of this rule, there were
64 waste treatment codes in this section of Form R Part II.
Now there are 25 such codes. A table is provided in
Appendix B displaying the original codes along with the new
codes, to ease the determination of which of the new codes are
appropriate for your use.
Enter the appropriate waste treatment code from the list below
for each on-site waste treatment method used on a waste
stream containing the EPCRA section 313 chemical,
regardless of whether the waste treatment method actually
removes the specific EPCRA section 313 chemical being
reported. Waste treatment methods must be reported for each
type of waste stream being treated (i.e., gaseous waste
streams, aqueous waste streams, liquid non-aqueous waste
streams, and solids). Except for the air emission treatment
codes, the waste treatment codes are not restricted to any
medium.
Waste streams containing the EPCRA section 313 chemical
may have a single source or may be aggregates of many
sources. For example, process water from several pieces of
equipment at your facility may be combined prior to waste
treatment. Report waste treatment methods that apply to the
aggregate waste stream, as well as waste treatment methods
that apply to individual waste streams. If your facility treats
various wastewater streams containing the EPCRA section
313 chemical in different ways, the different waste treatment
methods must be listed separately.
If your facility has several pieces of equipment performing a
similar service in a waste treatment sequence, you may
combine the reporting for such equipment. It is not necessary
to enter four codes to cover four scrubber units, for example,
if all four are treating waste streams of similar character (e.g.,
sulfuric 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 should 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
TA.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.
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 should 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
Toxics Release Inventory Reporting Forms and Instructions 47
Treatment applied to any other general waste stream types
would then be listed in the next empty row. In the scenario
below, for instance, the second general waste stream would be
reported in row 7A. 3a. See Figure 5 for an example of a
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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 (PbCrC^.PbO) in an on-site landfill and transfers 16,000 pounds of lead
selenite (PbSeC>4) 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)
Lead (2 Pb atoms)
Chromium (1 Cr atom)
Lead chromate is therefore (% by weight)
(414.4/546.37) = 75.85% lead and
Molecular weight = 546.37
Atomic weight = 207.2 x 2 = 414.4
Atomic weight = 51.996
(51.996/546.37) = 9.52% chromium
Lead Selenite (PbSeO4)
Lead(l Pb atom)
Selenium (1 Se atom)
Lead selenite is therefore (% by weight)
Molecular weight = 350.17
Atomic weight = 207.2
Atomic weight = 78.96
(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
Figure 5. Hypothetical Section 7A
48 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Waste Treatment Codes
A01 Flare
A02 Condenser
A03 Scrubber
A04 Absorber
A05 Electrostatic Precipitator
A06 Mechanical Separation
A07 Other Air Emission Treatment
H040 Incineration-thermal destruction other than use as a
fuel
H071 Chemical reduction with or without precipitation
H073 Cyanide destruction with or without precipitation
H075 Chemical oxidation
H076 Wet air oxidation
H077 Other chemical precipitation with or without pre-
treatment
H081 Biological treatment with or without precipitation
H082 Adsorption
HO 8 3 Air or steam stripping
HI 01 Sludge treatment and/or dewatering
HI 03 Absorption
Hill Stabilization or chemical fixation prior to disposal
HI 12 Macro-encapsulation prior to disposal
H121 Neutralization
HI 22 Evaporation
H123 Settling or clarification
HI24 Phase separation
H129 Other treatment
7A Column c: Range of Influent Concentration
(Deleted)
7A Column d: Waste Treatment Efficiency Estimate
In the space provided, enter the range code, based upon the
codes listed below, indicating the percentage of the EPCRA
section 313 chemical removed from the waste stream through
destruction, biological degradation, chemical conversion, or
physical removal. Note that these range codes are new for the
2005 reporting year, pursuant to the promulgation of the TRI
Reporting Forms Modification Rule, published on July 12,
2005. The waste treatment efficiency (expressed as a range of
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 may evaporate,
biodegrade, or be physically removed from the sludge.
Percent removal can be calculated as follows:
where:
1 =
E =
(I-E)xlOO%
I
amount of the EPCRA section 313 chemical in
the influent waste stream (entering the waste
treatment step or sequence) and
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 code El (greater than 99.9999%) 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 reported as code E6 (equal to or
greater than 0%, but less than or equal to 50%).
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 code E6 (equal to or greater than
0%, but less than or equal to 50%.
EPCRA section 313 chemicals that are strong mineral acids
neutralized to a pH of 6 or above are considered treated at a
100% efficiency.
When calculating waste treatment efficiency, EPCRA section
313(g)(2) requires a facility to use readily available data
(including monitoring data) collected pursuant to other
provisions of law, or, where such data are not readily
available, "reasonable estimates" of the amounts involved.
Toxics Release Inventory Reporting Forms and Instructions 49
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Instructions for Completing Part II of EPA Form R
Waste Treatment Efficiency Range Codes:
El = greater than 99.9999%
E2 = greater than 99.99%, but less than or equal to 99.9999%
E3 = greater than 99%, but less than or equal to 99.99%
E4 = greater than 95%, but less than or equal to 99%
E5 = greater than 50%, but less than or equal to 95%
E6 = equal to or greater than 0%, but less than or equal to
50%
7A Column e
(Deleted)
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.
EPA considers an EPCRA section 313 chemical to be
combusted for energy recovery if the toxic chemical has a
significant heat value and is combusted in an energy recovery
device. 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.)
Energy Recovery Codes
U01 Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
Please note that these codes are new as of the 2005 reporting
year, pursuant to the publication of the TRI Reporting Forms
Modification Rule on July 12,2005. These codes replace the
16 codes used prior to the rule's promulgation.
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, y ou 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
H10 Metal recovery (by retorting, smelting, or chemical or
physical extraction
EGO Solvent recovery (including distillation, evaporation,
fractionation or extraction)
H3 9 Other recovery or reclamation for reuse (including acid
regeneration or other chemical reaction process)
Please note that these codes are new as of the 2005 reporting
year, pursuant to the promulgation of the TRI Reporting
Forms Modification Rule, published on July 12,2005. These
codes replace 16 codes used prior to the rule's promulgation.
Refer to Appendix B for a table displaying a crosswalk
between the old codes and new codes.
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).
5 0 Toxics Release Inventory Reporting Forms and Instructions
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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 7A should be completed slightly differently when you file the Form R for each of the chemicals. The table
accompanying this example shows how Section 7A should be completed for each chemical. First, on each Form R you should
identify the 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 7A. Ib of all three Form Rs
should show: H124 (phase separation), H121 (neutralization), H123 (settling or clarification), andN/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. 1 d 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 E4 when filing for chemical A, E5 for chemical B, and El for chemical C.
Chemical A
7A.la
W
7A.lb
3. H123
6.
1. H124
4. N/A
7.
2. H121
5.
8.
TA.ld
E4
Chemical B
TA.la
W
7A.lb
3. H123
6.
1. H124
4. N/A
7.
2. H121
5.
8.
TA.ld
E5
Chemical C
TA.la
W
TA.lb
3. H123
6.
1. H124
4. N/A
1.
2. H121
5.
8.
TA.ld
El
Note that the quantity removed and/or destroyed is not reported in Section 1 and that the efficiency reported in Section TA. 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 y ou should report "N/A"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 c. However, when completing the Form R for Chemical C y ou should report the entire quantity in Section 8.6 because raising
the pH to T.5 will completely destroy the mineral acid.
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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.
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, you should report only the amount of
the metal portion of the compound as you do when estimating
release and other waste management 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).
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. 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 12onpage40). 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, you should 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. Ib,
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, 2006 (reporting year 2005), the
prior year is 2004. Information available at the facility that
may be used to estimate the prior year's quantities include the
prior year's Form R submission, supporting documentation,
and recycling, energy recovery, treatment, or disposal
operating logs or invoices. When reporting prior year
estimates facilities are not required to use quantities reported
on the previous year's form if better information is available.
52 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
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
2006 and 2007. 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
proj ections, 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.
Relationship to Other Laws
The reporting categories for quantities recycled, used for
energy recovery, treated, and disposed apply to completing
Section 8 of Form R as well as to the rest of Form R. These
categories are to be used only for TRI reporting. They are not
intended for use in determining, under the Resource
Conservation and Recovery Act (RCRA) Subtitle C
regulations, whether a secondary material is a waste when
recycled. These definitions also do not apply to the
information that may be submitted in the Biennial Report
required under RCRA. In addition, these definitions do not
imply any future redefinition of RCRA terms and do not affect
EPA's RCRA authority or authority under any other statute
administered by EPA.
Differences in terminology and reporting requirements for
EPCRA section 313 chemicals reported on Form R and for
hazardous wastes regulated under RCRA occur because
EPCRA and the PPA focus on specific chemicals, while the
RCRA regulations and the Biennial Report focus on waste
streams that may include more than one chemical. For
example, a RCRA hazardous waste 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 Section s 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. Beginning in the 2003 reporting year, Section
8.1 was divided into four Subsections (8.la, 8.1b, 8.1c and
8.Id). Please refer to the following equations that show the
relationship between Sections 5, 6 and 8.la through 8.Id.
EPCRA section 329(8) defines release as "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)." In
Section 8.1 facilities report disposal and other releases. This
includes on-site disposal and other releases in Section 5 and
off-site disposal and other releases in Section 6 (releases plus
transfers to disposal and transfers to POTWs of metals and
metal compounds), but excludes quantities reported in Section
5 and 6 due to remedial actions, catastrophic events, or non-
production related events (see the discussion on Section 8.8).
Metals and metal category compounds reported in 1) Section
6.2 as sent off-site for stabilization/solidification
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 (2005), the company
received approval from the Food and Drug Administration
to begin marketing their product as an over-the-counter
drug beginning in 2006. This approval is publicly known
and does not constitute confidential business information.
As a result of this expanded market, the company
estimates that sales and subsequent production of this drug
will increase their use of the reported EPCRA section 313
chemical by 30% 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 (2005) by
adding 30% to the amount in column B (the amount for the
current reporting year). The second following year (2006)
figure can be calculated by adding an additional 30% to
the amount reported in column C (the amount for the
following year (2005) projection).
(M41—metals) or wastewater treatment (excluding POTWs)
(M62—metals) and/or 2) in Section 6.1 — discharges to
POTWs, should be reported in Section 8.1. These quantities
should NOT be reported in Section 8.7 because the metals are
ultimately disposed.
Sections 8.1a and 8.1b. Toxic chemicals disposed or
otherwise released on site are reported in 8.la or 8.1b as
appropriate. Toxic chemicals sent off site for disposal are
reported in 8. Ic or 8. Id.
§8.la = § 5.4.1 + § 5.5.1A + § 5.5.1B - § 8.8 (on-site release
or disposal due to catastrophic events)1
§ 8.1b = § 5.1+ § 5.2+ § 5.3+ § 5.4.2+ § 5.5.2+ §5.5.3A +
§ 5.5.3B + §5.5.4 - § 8.8 (on-site release or disposal due to
catastrophic events)1
Sections 8.1c and 8. Id. Toxic chemicals transferred off site
to POTWs or other off-site locations should be reported in
8. Ic or 8. Id as appropriate. For example, quantities of atoxic
chemical sent to a POTW and subsequently sent to a landfill
are reported in Sections.Ic. Quantities of the toxic chemical
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Instructions for Completing Part II of EPA Form R
disposed or otherwise released by the POTW to a stream are
reported in Section 8.Id. Metals and metal category
compounds sent to POTWs should be reported in one of these
two sections and should not be reported as treated for
destruction in Section 8.7.
§ 8.1c = § 6.1 (portion of transfer that is untreated and
ultimately disposed of in UIC Class I Wells, RCRA
Subtitle C landfills, and other landfills) + § 6.2 (quantities
associated with M codes M64, M65 and M81) - § 8.8
(off-site disposal due to catastrophic events)1
§ 8.1d = § 6.1 (portion of transfer that is untreated and
ultimately disposed of in UIC Class II-V wells, and
disposal other than to landfills) + § 6.2 (quantities
associated with M codes M10, M41, M62, M66, M67, M73,
M79, M82, M90, M94, M99) - § 8.8 (off-site disposal due
to catastrophic events)1
Some chemicals in addition to metals and metal category
compounds might not be treated for destruction at a POTW.
If you are able to quantify the amounts of a toxic chemical
sent to a POTW that are treated for destruction and disposed
or released from the POTW untreated, you should divide the
amount reported in Section 6.1 between Sections 8.1c and
8. Id and 8.7 (quantity treated off site), as appropriate.
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). For the purposes of reporting on
Form 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)
Note: Metals and metal category compounds cannot be
combusted for energy recovery. For metals and metal
category compounds, you should enterNA in Sections 8.2 and
8.3.
§ 8.2 is reported in Section 8 only
§ 8.3 = § 6.2 (energy recovery) - §8.8 (off-site energy
recovery due to catastrophic events)1
Sections 8.4 and 8.5. These relate to an EPCRA section 313
chemical in a waste that is recycled on-site or is sent off-site
for recycling.
§ 8.4 is reported in Section 8 only
§ 8.5 = § 6.2 (recycling) - § 8.8 (off-site recycling due to
catastrophic events)2
Section 8.6 and 8.7. These relate to an EPCRA section 313
chemical (except for most metals and metal category
compounds) or a waste containing an EPCRA section 313
chemical that is treated for destruction on-site or is sent to a
POTW or other off-site location for treatment for destruction.
Most metal and category compounds are not reported in this
section because they cannot be destroyed (See Appendix B).
§ 8.6 is reported in Section 8 only
§ 8.7 = § 6.1 (excluding most metal/metal category
compounds) + § 6.2 (treatment) - § 8.8 (off-site treatment
due to catastrophic events)1
Some chemicals in addition to metals and metal category
compounds might not be treated for destruction at a POTW.
If you are able to quantify the amounts of a toxic chemical
sent to a POTW that are treated for destruction and disposed
or released from the POTW untreated, you should divide the
amount reported in Section 6.1 between Sections 8.1c-d and
8.7 (quantity treated off site), as appropriate. Facilities should
use their best readily available information to determine the
final disposition of the toxic chemical sent to the POTW.
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 disposed or released directly into the
environment or sent off-site for recycling, energy recovery,
treatment, or disposal during the reporting year due to any of
the following events:
(1) remedial actions;
(2) catastrophic events such as earthquakes, fires, or floods; or
(3) one-time events not associated with normal or routine
production processes.
These quantities should not be included in Section 8.1.
The purpose of this section is to separate quantities recycled,
used for energy recovery, treated, or released, including
disposals that are associated with normal or routine production
operations from those that are not. While all quantities
disposed, 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,
otherwise released onsite or managed as a waste off site due to
remedial actions, catastrophic events, or one time events not
associated with the production process.
2§8.8 includes quantities of toxic chemicals disposed or
54 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
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 Section 8.1 through 8.7 as appropriate. A total
loss of containment resulting from a tank rupture caused by a
tornado would be included in the quantity reported in Section
Similarly, the amount of an EPCRA section 313 chemical
cleaned up from spills resulting from normal operations
during the reporting year would not be included in Section
8.8. However, the quantity of the reported EPCRA section
313 chemical disposed from a remedial action (e.g., RCRA
corrective action) to clean up the environmental
contamination resulting from past practices should be reported
in Section 8.8 because they cannot currently be addressed by
source reduction methods. A remedial action for purposes of
Section 8.8 is a waste cleanup (including RCRA and
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 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
disposal and 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 with production processes, Section 5 of Form R
(on-site disposal and other releases to the environment) and
Section 6 (off-site transfers for further waste management)
must include all on-site disposal and other releases and
transfers for disposal 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 8.8. The quantities reported in each of those sections
should be mutually exclusive. Do not multiple-count
quantities entering sequential reportable activities during the
reporting year.
Quantities of the EPCRA section 313 chemical disposed or
otherwise released into the environment or otherwise managed
as waste off site 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, disposed or released. The ratio or index must be
reported to the nearest tenths or hundredths place (i.e., one or
two digits to the right of the decimal point). 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 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, disposed or released.
Examples of methods available include:
(1) Amount of EPCRA section 313 chemical
manufactured in 2005 divided by the amount of EPCRA
section 313 chemical manufactured in 2004; or
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(2) Amount of product produced in 2005 divided by the
amount of product produced in 2004.
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.
Source reduction means any practice that:
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
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.
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.Ib).
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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 to a landfill for disposal. These quantities
would be reported as follows in Section 8:
Section 8.1c: 500 pounds disposed
Section 8.4: 2,500 pounds recycled
Section 8.6: 2000 pounds treated (5,000 that initially entered — 3,000 that subsequently entered recycling)
To report that 5,000 pounds were treated, 3,000 pounds -were recycled, and that 500 pounds -were sent off-site for disposal would
result in over-counting the quantities of EPCRA section 313 chemical recycled, treated, and disposed by 3,500 pounds.
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 disposed 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).
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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. Perchloroethylene 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). Youestimate 12,500 pounds of toluene recycled, used
for energy recovery, treated, disposed 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, disposed 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, disposed 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.
5 8 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Source Reduction Activities
You must enter in the first column of Section 8.10, "Source
Reduction Activities," the appropriate code(s) indicating the
type of actions taken to reduce the amount of the reported
EPCRA section 313 chemical disposed or otherwise released
(as reported in Section 8.1), used for energy recovery (as
reported in Sections 8.2-8.3), recycled (as reported in
Sections 8.4-8.5), ortreated (as reported in Sections 8.6-8.7).
The list of codes below includes many, but not all, of the
codes provided in the RCRA biennial report. Remember that
source reduction activities include only those actions or
techniques that reduce or eliminate the amounts of the
EPCRA section 313 chemical reported in Sections 8.1 through
8.7. Actions taken to recycle, combust for energy recovery,
treat, or dispose of the EPCRA section 313 chemical are not
considered source reduction activities.
Source Reduction Activity Codes:
Good Operating Practices
W13 Improved maintenance scheduling, record keeping,
or procedures
W14 Changed production schedule to minimize
equipment and feedstock changeovers
W19 Other changes made in operating practices
Inventory Control
W21 Instituted procedures to ensure that materials do not
stay in inventory beyond shelf-life
W22 Began to test outdated material — continue to use if
still effective
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labeling procedures
W25 Instituted clearinghouse to exchange materials that
would otherwise be discarded
W29 Other changes made in inventory control
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 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
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 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.
T01 Internal pollution prevention opportunity audit(s)
T02 External pollution prevention opportunity audit(s)
T03 Materials balance audits
T04 Participative team management
T05 Employee recommendation (independent of a
formal company program
T06 Employee recommendation (under a formal
company progam
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Instructions for Completing Part II of EPA Form R
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 wish to submit 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 using TRI-
ME to submit your report, you can use the pull-down text box
feature to describe your source reduction, recycling, or
pollution control activities. You may submit such additional
information in hard-copy in addition to, or instead of, the
information supplied in the TRI-ME text box feature. If you
wish to submit by regular mail, please use the following
address:
TRI Data Processing Center
P.O. Box 1513
Landham, MD 20703 -1513
To submit hard-copy information for section 8.11 by certified
or overnight mail, use the following address:
TRI Data Processing Center
c/o Computer Science Corporation
Suite 150
8400 Corporate Drive
Landover, MD 20785-2294
(301)429-5005
All information submitted in hard-copy must include the
name, address, and TRIFID number for the facility submitting
the information.
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.
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.
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Facility Eligibility Determination for Alternate Threshold and for Reporting on EPA Form A
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 must submit a Form A for such chemicals meeting the
conditions described below, and should not submit a Form R to
the TRI Data Processing 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 recycling 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 recycling, energy recovery, treatment, and/or disposal. These
quantities 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.
D.6 Trade Secrets
When making a trade secret claim on a Form A submission,
EPA is requiring that a facility submit a unique Form A for
each EPCRA section 313 chemical meeting the conditions
of the alternate threshold. Facilities may assert a trade
secrecy claim for a chemical identity on the Form A as on
the Form R. Reports submitted on a per chemical basis
protect against the disclosure of trade secrets. Form As
with trade secrecy claims, like Form Rs with similar claims,
will be separately handled upon receipt to protect against
disclosure. Commingling trade secret chemical identities
with non-trade secret chemical identities on the same
submission increases the risk of disclosure.
D Do not submit trade secret reports electronically
or on diskette.
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Facility Eligibility Determination for Alternate Threshold and for Reporting on EPA Form A
D.7 Metals and Metal Category Compounds
Formetal 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 must be applied separately to the listed parent metal
and the associated metal compound(s). Threshold determinations
must be made independently for each because they are separately
listed EPCRA section 313 chemicals.
Q If the threshold is exceeded for the listed parent metal
but not the associated metal 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.
Q If both the parent metal and the associated metal
compounds exceed the alternate threshold, then the
facility has the option of filing one Form R for both,
using the metal category compound name and
reporting total releases based on parent metal content.
Q If neither the parent metal nor the associated metal
compounds exceed the alternate threshold, then the
facility must use a separate listing on 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 the 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 must 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 Form R,
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.
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 You should type or print information on the form
in the format requested and 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, you should 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 2005 must be submitted
on or before July 1, 2006.
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 should 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.
D Do not submit trade secret reports electronically or
on diskette.
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Facility Eligibility Determination for Alternate Threshold and for Reporting on EPA Form A
2.2 If "yes" in 2.1, is this copy sanitized or unsanitized?
You should 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 that is
structurally descriptive 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 a senior official with management
responsibility for the person (or persons) completing the form. A
senior management 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 5 9
FR 61488 (November 30,1994). You should 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 must
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, you should 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 TRI-ME. "NA" or "None" are not
acceptable entries.
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 CDX Help Desk toll
free at 1-888-890-1995. If your facility has moved, do not enter
your TRI facility identification number, you should enter "New
Facility."
The TRI Facility Identification Number is established by the first
Form R submitted by a facility at a particular location. This
identification number is retained by the facility even if the
facility changes name, ownership, production processes,
SIC codes, etc. This identification number will stay with
this location. If a new facility moves to this location it
should use this TRI Facility Identification Number.
Establishments of a facility that report separately should
use the TRI Facility Identification Number of the facility.
You should enter "New Facility" in the space for the TRI
Facility Identification number if this is your first
submission.
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, you should 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. You should also enter an email address for this
person. EPA encourages facilities to provide an email
address for its Technical Contact on their TRI submissions
because they will be able to receive important program
updates and email alerts notifying them when their FDP has
been updated and is available on the FDP website. If the
technical contact does not have an email address you
should enter NA. 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
should be familiar with the details of the report so that he or
she can answer questions about the information provided.
4.4 Intentionally Left Blank
4.5 Standard Industrial Classification (SIC) Code
Enter the appropriate four-digit 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
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Facility Eligibility Determination for Alternate Threshold and for Reporting on EPA Form A
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 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. This
upcoming change does NOT affect the 2003 EPCRA section 313
reporting.
4.6 Latitude and Longitude
(Deleted)
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 number can be
obtained, toll free at 800 234-3867 (8:00 AM to 6:00 PM, Local
Time) or on the Web at . If none of your
establishments has been assigned a D & B number, you should
enter NA in box (a). If only some of your establishments have
been assigned Dun & Bradstreet numbers, enter those numbers in
Parti, section4.7.
4.8 EPA Identification Number(s)
(Deleted)
4.9 Facility NPDES Permit Number(s)
(Deleted)
4.10 Underground Injection Well Code (UIC) Identification
Number(s)
(Deleted)
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, you
should enter NA in this space. Corporate names should be
treated as parent company names for companies with
multiple facility sites. For example, the Bestchem
Corporation is not owned or controlled by any other
corporation but has sites throughout the country whose
names begin with Bestchem. In this case, Bestchem
Corporation should be listed as the parent company. Note
that a facility that is a 50:50 joint venture is its own parent
company. When a facility is owned by more than one
company and there is no parent company for the entire
facility (meaning that none of the facility owners directly
owns at least 50 percent of the voting stock of the facility at
issue), the facility should provide the name of the parent
company of either the facility operator or the owner with
the largest ownership interest in the facility. If neither the
operator nor this owner has a parent company, then the NA
box should be checked.
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, you should 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, you should check the NA box.
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), you should enter the applicable category code
in the CAS number space. EPCRA section 313 chemical
64 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Alternate Threshold and for Reporting on EPA Form A
category codes are listed below and can also be found in Table
He and Appendix B-1.
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
NISODioxin 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
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 that is structurally descriptive in Part II, Section 1.3
of your sanitized Form A.
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 an 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 should 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 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 section. You do not need to supply trade secret
substantiation forms for this EPCRA section 313 chemical
because it is your supplier who is claiming the chemical
identity a trade secret
2.1 Generic Chemical Name Provided by Supplier
Enter the generic chemical name in this section only if the
following three conditions apply:
1. You determine that the mixture contains an EPCRA
section 313 chemical but the only identity you have
for that chemical is a generic name;
2. You know either the specific concentration of that
EPCRA section 313 chemical component or a
maximum or average concentration level; and
3. You multiply the concentration level by the total
annual amount of the whole mixture processed or
otherwise used and determine that you meet the
process or otherwise use threshold for that single,
generically identified mixture component.
Toxics Release Inventory Reporting Forms and Instructions 65
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This Page Intentionally Left Blank
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Table I. SIC Codes
10 Metal Mining (except 1011,1081
and 1094)
1021 Copper Ores
1031 Lead and Zinc Ores
1041 Gold Ores
1044 Silver Ores
1061 Ferroalloy Ores, Except Vanadium
1099 Miscellaneous Metal Ores, Not Elsewhere
Classified
12 Coal Mining (except 1241)
1221 Bituminous Coal and Lignite Surface Mining
1222 Bituminous Coal Underground Mining
1231 Anthracite Mining
20 Food and Kindred Products
2011 Meat packing plants
2013 Sausages and other prepared meat products
2015 Poultry slaughtering and processing
2021 Creamery butter
2022 Natural, processed, and imitation cheese
2023 Dry, condensed, and evaporated dairy
products
2024 Ice cream and frozen desserts
2026 Fluid milk
2032 Canned specialties
2033 Canned fruits, vegetables, preserves, jams, and
jellies
2034 Dried and dehydrated fruits, vegetables, and soup
mixes
2035 Pickled fruits and vegetables, vegetable sauces
and seasonings, and salad dressings
2037 Frozen fruits, fruit juices, and vegetables
2038 Frozen specialties, n.e.c.*
2041 Flour and other grain mill products
2043 Cereal breakfast foods
2044 Rice milling
2045 Prepared flour mixes and doughs
2046 Wet corn milling
2047 Dog and cat food
2048 Prepared feeds and feed ingredients for animals
and fowls, except dogs and cats
2051 Bread and other bakery products, except cookies and
crackers
2052 Cookies and crackers
2053 Frozen bakery products, except bread
2061 Cane sugar, except refining
2062 Cane sugar refining
2063 Beet sugar
2064 Candy and other confectionery products
2066 Chocolate and cocoa products
2067 Chewing gum
2068 Salted and roasted nuts and seeds
2074 Cottonseed oil mills
2075 Soybean oil mills
2076 Vegetable oil mills, n.e.c.*
2077 Animal and marine fats and oils
2079 Shortening, table oils, margarine, and other edible fats
and oils, n.e.c.*
2082 Malt beverages
2083 Malt
2084 Wines, brandy, and brandy spirits
2085 Distilled and blended liquors
2086 Bottled and canned soft drinks and carbonated waters
2087 Flavoring extracts and flavoring syrups, n.e.c.*
2091 Canned and cured fish and seafoods
2092 Prepared fresh or frozen fish and seafoods
2095 Roasted coffee
2096 Potato chips, corn chips, and similar snacks
2097 Manufactured ice
2098 Macaroni, spaghetti, vermicelli, and noodles
2099 Food preparations, n.e.c.*
21 Tobacco Products
2111 Cigarettes
2121 Cigars
2131 Chewing and smoking tobacco and snuff
2141 Tobacco stemming and redrying
22 Textile Mill Products
2211 Broadwoven fabric mills, cotton
2221 Broadwoven fabric mills, manmade fiber, and silk
2231 Broadwoven fabric mills, wool (including dyeing and
finishing)
2241 Narrow fabric and other small wares mills: cotton,
wool, silk, and manmade fiber
2251 Women's full length and knee length hosiery, except
socks
2252 Hosiery, n.e.c.*
2253 Knit outerwear mills
2254 Knit underwear and nightwear mills
2257 Weft knit fabric mills
2258 Lace and warp knit fabric mills
2259 Knitting mills, n.e.c.*
2261 Finishers of Broadwoven fabrics of cotton
Toxics Release Inventory Reporting Forms and Instructions 1-1
-------
Table I
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
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
1-2 Toxics Release Inventory Reporting Forms and Instructions
-------
Table I
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 Alkalies and chlorine
2813 Industrial gases
2816 Inorganic pigments
2819 Industrial inorganic chemicals, n.e.c.*
2821 Plastics materials, synthetic resins, and
non-vulcanizable elastomers
2822 Synthetic rubber (vulcanizable elastomers)
2823 Cellulosic manmade fibers
2824 Manmade organic fibers, except cellulosic
2833 Medicinal chemicals and botanical products
2834 Pharmaceutical preparations
3081 Unsupported plastics film and sheet
3082 Unsupported plastics profile shapes
3083 Laminated plastics plate, sheet, and profile shapes
3084 Plastics pipe
3085 Plastics bottles
3086 Plastics foam products
3087 Custom compounding of purchased plastics resins
3088 Plastics plumbing fixtures
3089 Plastics products, n.e.c.*
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.*
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
Toxics Release Inventory Reporting Forms and Instructions 1-3
-------
Table I
3172 Personal leather goods, except women'shandbags
and purses
3199 Leather goods, n.e.c.*
32 Stone, Clay, Glass and Concrete
Products
3211 Flat glass
3221 Glass containers
3229 Pressed and blown glass and glassware, n.e.c.*
3231 Glass products, made of purchased glass
3241 Cement, hydraulic
3251 Brick and structural clay tile
3253 Ceramic wall and floor tile
3255 Clay refractories
3259 Structural clay products, n.e.c.*
3261 Vitreous china plumbing fixtures and china and
earthenware fittings and bathroom accessories
3262 Vitreous china table and kitchen articles
3263 Fine earthenware (whiteware) table and kitchen
articles
3264 Porcelain electrical supplies
3269 Pottery products, n.e.c.*
3271 Concrete block and brick
3272 Concrete products, except block and brick
3273 Ready mixed concrete
3274 Lime
3275 Gypsum products
3281 Cut stone and stone products
3291 Abrasive products
3292 Asbestos products
3295 Minerals and earths, ground or otherwise treated
3296 Mineral wool
3297 Nonclay refractories
3299 Nonmetallic mineral products, n.e.c.*
33 Primary Metal Industries
3312 Steel works, blast furnaces (including coke ovens),
and rolling mills
3313 Electrometallurgical products, except steel
3315 Steel wiredrawing and steel nails and spikes
3316 Cold-rolled steel sheet, strip, and bars
3317 Steel pipe and tubes
3321 Gray and ductile iron foundries
3322 Malleable iron foundries
3324 Steel investment foundries
3325 Steel foundries, n.e.c.*
3331 Primary smelting and refining of copper
3334 Primary production of aluminum
3339 Primary smelting and refining of nonferrous
metals, except copper and aluminum
3341 Secondary smelting and refining of nonferrous metals
3351 Rolling, drawing, and extruding of copper
3353 Aluminum sheet, plate, and foil
3354 Aluminum extruded products
3355 Aluminum rolling and drawing, n.e.c.*
3356 Rolling, drawing, and extruding of nonferrous metals,
except copper and aluminum
3357 Drawing and insulating of nonferrous wire
3363 Aluminum die-castings
3364 Nonferrous die-castings, except aluminum
3365 Aluminum foundries
3366 Copper foundries
3369 Nonferrous foundries, except aluminum and copper
3398 Metal heat treating
3399 Primary metal products, n.e.c.*
34 Fabricated Metal Products, except
Machinery and Transportation
Equipment
3411 Metal cans
3412 Metal shipping barrels, drums, kegs, and pails
3421 Cutlery
3423 Hand and edge tools, except machine tools and
handsaws
3425 Handsaws and saw blades
3429 Hardware, n.e.c.*
3431 Enameled iron and metal sanitary ware
3432 Plumbing fixture fittings and trim
3433 Heating equipment, except electric and warm air
furnaces
3441 Fabricated structural metal
3442 Metal doors, sash, frames, molding, and trim
3443 Fabricated plate work (boiler shops)
3444 Sheet metal work
3446 Architectural and ornamental metal work
3448 Prefabricated metal buildings and components
3449 Miscellaneous structural metal work
3451 Screw machine products
3452 Bolts, nuts, screws, rivets, and washers
3462 Iron and steel forgings
3463 Nonferrous forgings
3465 Automotive stampings
3466 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.*
1-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Table I
3491 Industrial valves
3492 Fluid power valves and hose fittings
3493 Steel springs, except wire
3494 Valves and pipe fittings, n.e.c.*
3495 Wire springs
3496 Miscellaneous fabricated wire products
3497 Metal foil and leaf
3498 Fabricated pipe and pipe fittings
3499 Fabricated metal products, n.e.c.*
35 Industrial and Commercial
Machinery and Computer
Equipment
3511 Steam, gas and hydraulic turbines, and turbine
generator set units
3519 Internal combustion engines, n.e.c.*
3523 Farm machinery and equipment
3524 Lawn and garden tractors and home lawn and
garden equipment
3531 Construction machinery and equipment
3532 Mining machinery and equipment, except oil and
gas field machinery and equipment
3533 Oil and gas field machinery and equipment
3534 Elevators and moving stairways
3535 Conveyors and conveying equipment
3536 Overhead traveling cranes, hoists, and monorail
systems
3537 Industrial trucks, tractors, trailers, and stackers
3541 Machine tools, metal cutting types
3542 Machine tools, metal forming types
3543 Industrial patterns
3544 Special dies and tools, die sets, jigs and fixtures,
and industrial molds
3545 Cutting tools, machine tool accessories, and
machinists' measuring devices
3546 Power driven handtools
3547 Rolling mill machinery and equipment
3548 Electric and gas welding and soldering equipment
3549 Metalworking machinery, n.e.c.*
3552 Textile machinery
3553 Woodworking machinery
3554 Paper industries machinery
3555 Printing trades machinery and equipment
3556 Food products machinery
3559 Special industry machinery, n.e.c.*
3561 Pumps and pumping equipment
3 562 Ball and roller bearings
3563 Air and gas compressors
3564 Industrial and commercial fans and blowers and air
purification equipment
3565 Packaging equipment
3566 Speed changers, industrial high speed drives, and gears
3567 Industrial process furnaces and ovens
3568 Mechanical power transmission equipment, n.e.c.*
3569 General industrial machinery and equipment, n.e.c.*
3571 Electronic computers
3572 Computer storage devices
3575 Computer terminals
3577 Computer peripheral equipment, n.e.c.*
3578 Calculating and accounting machines, except
electronic computers
3579 Office machines, n.e.c.*
3581 Automatic vending machines
3582 Commercial laundry, dry-cleaning, and pressing
machines
3585 Air conditioning and warm air heating equipment and
commercial and industrial refrigeration equipment
3 5 86 Measuring and dispensing pumps
3589 Service industry machinery, n.e.c.*
3592 Carburetors, pistons, piston rings, and valves
3593 Fluid power cylinders and actuators
3 5 94 Fluid power pumps and motors
3596 Scales and balances, except laboratory
3599 Industrial and commercial machinery and equipment,
n.e.c*
36 Electronic and Other Electrical
Equipment and Components, Except
Computer Equipment
3612 Power, distribution, and specialty transformers
3613 Switchgear and switchboard apparatus
3621 Motors and generators
3624 Carbon and graphite products
3625 Relays and industrial controls
3629 Electrical industrial appliances, n.e.c.*
3631 Household cooking equipment
3632 Household refrigerators and home and farm freezers
3633 Household laundry equipment
3634 Electrical housewares and fans
Toxics Release Inventory Reporting Forms and Instructions 1-5
-------
Table I
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.*
parts
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
39 Miscellaneous Manufacturing
Industries
3911 Jewelry, precious metal
3914 Silverware, plated ware, and stainless steel ware
3915 Jewelers' findings and materials, and lapidary work
3931 Musical instruments
1-6 Toxics Release Inventory Reporting Forms and Instructions
-------
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)
Toxics Release Inventory Reporting Forms and Instructions 1-7
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Table II. EPCRA Section 313 Chemical List For Reporting Year 2005
(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:
CAS
Chemical Number
Aluminum (fume or dust) 7429-90-5
Aluminum oxide (fibrous forms) 1344-28-1
Ammonia (includes anhydrous ammonia and aqueous ammonia 7664-41-7
from water dissociable ammonium salts and other sources; 10
percent of total aqueous ammonia is reportable under this listing)
Asbestos (friable) 1332-21-4
Hydrochloric acid (acid aerosols including 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 persons who manufacture 67-63-0
by the strong acid process are subject, no supplier
notification)
Saccharin (only persons who manufacture are 81-07-2
subject, no supplier notification)
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 and should not file a report.
Only if it is being manufactured.
Toxics Release Inventory Reporting Form and Instructions II-l
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There are no supplier notification requirements for isopropyl alcohol and saccharin since the processors and users of these chemicals
are not required to report. Manufacturers of these chemicals do not need to notify their customers that these are reportable EPCRA
section 313 chemicals.
Note: Chemicals may be added to or deleted from the list. The Emergency Planning and Community Right-to-Know Call
Center will provide up-to-date information on the status of these changes. See section B.3.c 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 2005 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.
EPA considers a fume to be 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 in the EPCRA
Section 313 chemical list contain a qualifier relating to
manufacture. For isopropyl alcohol, the qualifier is "only persons
who manufacture by the strong acid process are subject, no
supplier notification." For saccharin, the qualifier is "only
persons who manufacture are subject, no supplier notification."
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 only processes or otherwise uses
either of these EPCRA Section 313 chemicals is not required to
report for these EPCRA Section 313 chemicals. In both cases,
supplier notification does not apply because only manufacturers,
not users, of these two EPCRA Section 313 chemicals 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 these chemicals 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
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
II-2 Toxics Release Inventory Reporting Form and Instructions
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Table II
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'-( 1 -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
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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 Bromacil 1.0
(5-Bromo-6-methyl-3-(l-methylpropyl)-
2,4( lH,3H)-pyrimidinedione)
53404-19-6 Bromacil, lithium salt 1.0
[2,4(lH,3H)-Pyrimidinedione,5-bromo-6-
methyl-3-(l-methylpropyl), lithium salt]
7726-95-6 Bromine 1.0
35691-65-7 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 cyanamide 1.0
Captan 1.0
[lH-Isoindole-l,3(2H)-dione, 3a,4,7,7a-
tetrahy dro-2- [(trichloromethy l)thio] -]
[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-Dihy dro-2-methyl-N-
phenyl-1,4-oxathiin-3 -carboxamide)
120-80-9 Catechol 0.1
2439-01-2 Chinomethionat 1.0
[6-Methyl-l,3-dithiolo[4,5-b]quinoxalin-2-
one]
133-90-4 Chloramben 1.0
[Benzoic acid, 3-amino-2,5-dichloro-]
57.74.9 Chlordane *
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-hexahydro-]
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 Carbaryl
1563-66-2
75-15-0
56-23-5
463-58-1
5234-68-4
II-4 Toxics Release Inventory Reporting Forms and Instructions
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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] sulfonyl]
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,l,l,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-1 -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
a-]
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
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Table II
CAS Number Chemical Name
De Minimis
Limit
53404-60-7 Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-1,3,5-
thiadiazine-2-thione, ion(l-), sodium]
94-82-6 2,4-DB 1.0
1929-73-3 2,4-D butoxyethyl ester 0.1
94-80-4 2,4-D butyl ester 0.1
2971-38-2 2,4-D chlorocrotyl ester 0.1
1163-19-5 Decabromodiphenyl oxide 1.0
13684-56-5 Desmedipham 1.0
1928-43-4 2,4-D 2-ethylhexyl ester 0.1
53404-37-8 2,4-D 2-ethyl-4- 0.1
methyrpentyl ester
2303-16-4 Diallate 1.0
[Carbamothioic acid, bis(l-methylethyl)-S-
(2,3-dichloro-2-propenyl) ester]
615-05-4 2,4-Diaminoanisole 0.1
39156-41-7 2,4-Diaminoanisole sulfate 0.1
101-80-4 4,4'-Diaminodiphenyl ether 0.1
95-80-7 2,4-Diaminotoluene 0.1
25376-45-8 Diaminotoluene (mixed isomers) 0.1
333-41-5 Diazinon 1.0
334-88-3 Diazomethane 1.0
132-64-9 Dibenzofuran 1.0
96-12-8 l,2-Dibromo-3- 0.1
chloropropane (DBCP)
106-93-4 1,2-Dibromoethane 0.1
(Ethylene dibromide)
124-73-2 Dibromotetrafluoroethane 1.0
(Halon 2402)
84-74-2 Dibutyl phthalate 1.0
1918-00-9 Dicamba 1.0
(3,6-Dichloro-2-methoxybenzoic acid)
99-30-9 Dichloran 1.0
[2,6-Dichloro-4-nitroaniline]
95-50-1 1,2-Dichlorobenzene 1.0
541-73-1 1,3-Dichlorobenzene 1.0
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 Dichlorobromometliane
764-41-0 l,4-Dichloro-2-butene 1.0
110-57-6 trans-l,4-Dichloro-2-butene 1.0
1649-08-7 l,2-Dichloro-l,l- 1.0
difluoroethane (HCFC-132b)
75-71-8 Dichlorodifluoromethane (CFC-12) 1.0
107-06-2 1,2-Dichloroethane (Ethylene 0.1
dichloride)
540-59-0 1,2-Dichloroethylene 1.0
CAS Number Chemical Name
De Minimis
Limit
1717-00-6 1,1-Dichloro-l-fluoroethane 1.0
(HCFC-141b)
75-43-4 Dichlorofluoromethane (HCFC-21) 1.0
75-09-2 Dichloromethane (Methylene 0.1
chloride)
127564-92-5 Dichloropentafluoropropane 1.0
13474-88-9 l,l-Dichloro-l,2,2,3,3- 1.0
pentafluoropropane (HCFC-225cc)
111512-56-2 l,l-Dichloro-l,2,3,3,3- 1.0
pentafluoropropane (HCFC-225eb)
422-44-6 1,2-Dichloro-l, 1,2,3,3- 1.0
pentafluoropropane (HCFC-225bb)
431-86-7 1,2-Dichloro-l, 1,3,3,3- 1.0
pentafluoropropane (HCFC-225da)
507-55-1 1,3-Dichloro-l, 1,2,2,3- 1.0
pentafluoropropane (HCFC-225cb)
136013-79-1 1,3-Dichloro-l, 1,2,3,3- 1.0
pentafluoropropane (HCFC-225ea)
128903-21-9 2,2-Dichloro-l,l,1,3,3- 1.0
pentafluoropropane (HCFC-225aa)
422-48-0 2,3-Dichloro-l,l,1,2,3- 1.0
pentafluoropropane (HCFC-225ba)
422-56-0 3,3-Dichloro-l,l,1,2,2- 1.0
pentafluoropropane (HCFC-225ca)
97-23-4 Dichlorophene 1.0
[2,2'-Methylenebis(4-chlorophenol)]
120-83-2 2,4-Dichlorophenol 1.0
78-87-5 1,2-Dichloropropane 1.0
10061-02-6 trans-l,3-Dichloropropene 0.1
78-88-6 2,3-Dichloropropene 1.0
542-75-6 1,3-Dichloropropylene 0.1
76-14-2 Dichlorotetrafluoroethane 1.0
(CFC-114)
34077-87-7 Dichlorotrifluoroethane 1.0
90454-18-5 Dichloro-l,l,2-trifluoroethane 1.0
812-04-4 l,l-Dichloro-l,2,2- 1.0
trifluoroethane (HCFC-123b)
354-23-4 1,2-Dichloro-l, 1,2- 1.0
trifluoroethane (HCFC-123a)
306-83-2 2,2-Dichloro-l,l,l- 1.0
trifluoroethane (HCFC-123)
62-73-7 Dichlorvos 0.1
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
51338-27-3 Diclofop methyl 1.0
[2-[4-(2,4-Dichlorophenoxy)phenoxy]
propanoic acid, methyl ester]
115-32-2 Dicofol 1.0
[Benzenemethanol, 4-chloro-
. alpha. -(4-chloropheny 1)-. alpha. -
(trichloromethyl)-]
77-73-6 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
1.0
1.0
0.1
1.0
1.0
1.0
0.1
0.1
0.1
0.1
1.0
1,2-Diphenylhydrazine 0.1
(Hydrazobenzene)
Dipotassium endothall 1.0
[7-Oxabicyclo(2.2.1)heptane-2,3-dicarboxylic
acid, dipotassium salt]
Dipropyl isocinchomeronate
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
[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 dipropy Ithiocarbamate 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-Phenoxyphenoxy)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-(trifluorometriyl)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, l,l,2-trichloro-l,2,2,-trifluoro-]
76-44-8 Heptachlor *
[l,4,5,6,7,8,8-Heptachloro-3a, 4,7,7a-
tetrahydro-4,7-methano- IH-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 Hexamethylphosphoramide 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]-
1 - [2- [4-(trifluoromethyl)pheny 1] etheny 1] -2-
propeny lidene] hy drazone]
302-01-2 Hydrazine 0.1
10034-93-2 Hydrazine surfate 0.1
CAS Number Chemical Name
De Minimis
Limit
7647-01-0 Hydrochloric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
74-90-8 Hydrogen cyanide 1.0
7664-39-3 Hydrogen fluoride 1.0
123-31-9 Hydroquinone 1.0
35554.44-0 Imazalil 1.0
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl]-lH-imidazole]
55406-53-6 3-Iodo-2-propynyl 1.0
butylcarbamate
13463-40-6 Iron pentacarbonyl 1.0
78-84-2 Isobutyraldehyde 1.0
465-73-6 Isodrin *
25311-71-1 Isofenphos[2-[[Ethoxyl[(l- 1.0
methylethyl)amino]phosphinothioyl]oxy]
benzoic acid 1-methylethyl ester]
67-63-0 Isopropyl alcohol 1.0
(only persons who manufacture by the strong
acid process are subject, no supplier
notification)
80-05-7 4,4'-Isopropylidenediphenol 1.0
120-58-1 Isosafrole 1.0
77501-63-4 Lactofen 1.0
[Benzoic acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy]-2-nitro-, 2-ethoxy-
l-methyl-2-oxoethyl ester]
7439-92-1 Lead *
(when lead is contained in stainless steel,
brass or bronze alloys the de minimis level is
0.1)
58-89-9 Lindane 0.1
[Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(l.alpha.,2.alpha.,3.beta.,4.alpha.,5.alpha.,
6.beta.)-]
330-55-2 Linuron
554-13-2 Lithium carbonate
121-75-5 Malathion
108-31-6 Maleic anhydride
109-77-3 Malononitrile
12427-38-2 Maneb
[Carbamodithioic acid, 1,2-ethanediylbis-,
manganese complex]
7439-96-5 Manganese 1.0
93-65-2 Mecoprop 0.1
149-30-4 2-Mercaptobenzothiazole (MET) 1.0
7439-97-6 Mercury *
150-50-5 Merphos 1.0
126-98-7 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-butyl 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 hydrazine 1.0
Methyl iodide 1.0
Methyl isobutyl ketone 1.0
Methyl isocyanate 1.0
Methyl isothiocyanate 1.0
[Isothiocyanatomethane]
2-Methyllactonitrile 1.0
Methyl methacry late 1.0
N-Methy lolacry 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
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 Mustard gas 0.1
[Ethane, l,l'-thiobis[2-chloro-]
88671-89-0 Myclobutanil 1.0
[.alpha. -Butyl-.alpha. -(4-chlorophenyl)- 1H-
1,2,4-triazole-l-propanenitrile]
142-59-6 Nabam 1.0
300-76-5 Naled 1.0
91-20-3 Naphthalene 0.1
134-32-7 alpha-Naphthylamine 0.1
91-59-8 beta-Naphthylamine 0.1
7440-02-0 Nickel 0.1
1929-82-4 Nitrapyrin 1.0
(2-Chloro-6-(trichloromethyl)pyridine)
7697-37-2 Nitric acid 1.0
139-13-9 Nitrilotriacetic acid 0.1
100-01-6 p-Nitroaniline 1.0
99-59-2 5-Nitro-o-anisidine 1.0
98-95-3 Nitrobenzene 0.1
92-93-3 4-Nitrobiphenyl 0.1
1836-75-5 Nitrofen 0.1
[Benzene, 2,4-dichloro-1 -(4-nitrophenoxy)-]
51-75-2 Nitrogen mustard 0.1
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
55-63-0 Nitroglycerin 1.0
88-75-5 2-Nitrophenol 1.0
100-02-7 4-Nitrophenol 1.0
79-46-9 2-Nitropropane 0.1
924-16-3 N-Nitrosodi-n-butylamine 0.1
55-18-5 N-Nitrosodiethylamine 0.1
62-75-9 N-Nitrosodimethylamine 0.1
86-30-6 N-Nitrosodiphenylamine 1.0
156-10-5 p-Nitrosodiphenylamine 1.0
621-64-7 N-Nitrosodi-n-propylamine 0.1
759-73-9 N-Nitroso-N-ethylurea 0.1
684-93-5 N-Nitroso-N-methylurea 0.1
4549-40-0 N-Nitrosomethylvinylamine 0.1
59-89-2 N-Nitrosomorpholine 0.1
16543-55-8 N-Nitrosonornicotine 0.1
100-75-4 N-Nitrosopiperidine 0.1
99-55-8 5-Nitro-o-toluidine 1.0
27314-13-2 Norflurazon 1.0
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)phenyl]-3(2H)-pyridazinone]
2234-13-1 Octachloronaphthalene 1.0
29082-74-4 Octachlorostyrene *
19044-88-3 Oryzalin 1.0
[4-(Dipropylamino)-3,5-dinitrobenzene
sulfonamide]
20816-12-0 Osmium tetroxide 1.0
Toxics Release Inventory Reporting Form and Instructions II-9
-------
Table II
CAS Number
301-12-2
19666-30-9
42874-03-3
10028-15-6
123-63-7
1910-42-5
56-38-2
1114-71-2
40487-42-1
608-93-5
76-01-7
87-86-5
57-33-0
79-21-0
594-42-3
52645-53-1
85-01-8
108-95-2
26002-80-2
De Minimis
Chemical Name Limit
Oxydemeton methyl 1.0
[S-(2-(Ethylsulfinyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
Oxydiazon 1.0
[3-[2,4-Dichloro-5-(l-
methylethoxy)phenyl]- 5-(l,l-
dimethylethyl)- 1 ,3 ,4-oxadiazol-2(3H)-one]
Oxyfluorfen 1.0
Ozone 1.0
Paraldehyde 1.0
Paraquat dichloride 1.0
Parathion 1.0
[Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl)ester]
Pebulate 1.0
[Butylethylcarbamothioic acid S-propyl
ester]
Pendimethalin *
[N-(l-Ethyrpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine]
Pentachlorobenzene *
Pentachloroethane 1.0
Pentachlorophenol (PCP) 0 . 1
Pentobarbital sodium 1.0
Peracetic acid 1.0
Perchloromethyl mercaptan 1.0
Permethrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid, (3-
phenoxyphenyl) methyl ester]
Phenanthrene 1.0
Phenol 1.0
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
106-50-3
615-28-1
624-18-0
90-43-7
57-41-0
75-44-5
7803-51-2
7723-14-0
85-44-9
1918-02-1
88-89-1
1,3-Phenylenediamine 1.0
p-Phenylenediamine 1.0
1,2-Phenylenediamine dihydro- 1.0
chloride
1,4-Phenylenediamine dihydro- 1.0
chloride
2-Phenylphenol 1.0
Phenytoin 0.1
Phosgene 1.0
Phosphine 1.0
Phosphorus (yellow or white) 1.0
Phthalic anhydride 1.0
Picloram 1.0
Picric acid 1.0
CAS Number
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
De Minimis
Chemical Name Limit
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- 1 ,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- 1H- 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]
11-10 Toxics Release Inventory Reporting Forms and Instructions
-------
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 (only persons who 1.0
manufacture are subject, no 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 l,l,l,2-Tetrachloro-2-fluoroethane 1.0
(HCFC-121a)
354-14-3 1,1,2,2-Tetrachloro-l-fluoroethane 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
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
0.1
0.1
0.1
*
1.0
Toxics Release Inventory Reporting Form and Instructions II-l 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)-, dimethyl 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
12122-67-7 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 Formaldehyde 0.1
51-03-6 Piperonyl butoxide 1.0
51-21-8 Fluorouracil (5-Fluorouracil) 1.0
51-28-5 2,4-Dinitrophenol 1.0
51-75-2 Nitrogen mustard 0.1
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
51-79-6 Urethane (Ethyl carbamate) 0.1
52-68-6 Trichlorfon 1.0
[Phosphonic acid, (2,2,2-trichloro-l-
hydroxyethyl)-, dimethyl ester]
52-85-7 Famphurl.O
53-96-3 2-Acetylaminofluorene 0.1
55-18-5 N-Nitrosodiethylamine 0.1
55-21-0 Benzamide 1.0
55-38-9 Fenthion 1.0
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester, phosphorothioic
acid]
55-63-0 Nitroglycerin 1.0
56-23-5 Carbon tetrachloride 0.1
56-35-9 Bis(tributyltin) oxide 1.0
56-38-2 Parathion 1.0
[Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl) ester]
57-14-7 1,1-Dimethylhydrazine 0.1
57-33-0 Pentobarbital sodium 1.0
57-41-0 Phenytoin 0.1
57-57-8 beta-Propiolactone 0.1
57-74-9 Chlordane *
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-hexahydro-]
58-89-9 Lindane 0.1
[Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(l.alpha.,2.alpha.,3.beta.,4.alpha,
5.alpha.,6.beta.)-]
59-89-2 N-Nitrosomorpholine 0.1
60-09-3 4-Aminoazobenzene 0.1
60-11-7 4-Dimethylaminoazobenzene 0.1
60-34-4 Methyl hydrazine 1.0
60-35-5 Acetamide 0.1
60-51-5 Dimethoate 1.0
61-82-5 Amitrole 0.1
62-53-3 Aniline 1.0
62-55-5 Thioacetamide 0.1
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
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 (only persons who
manufacture are subject, 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's ketone
91-08-7 Toluene-2,6-diisocyanate
91-20-3 Naphthalene
91-22-5 Quinoline
91-59-8 beta-Naphthylamine
91-94-1 3,3'-Dichlorobenzidine
92-52-4 Biphenyl
92-67-1 4-Aminobiphenyl
92-87-5 Benzidine
92-93-3 4-Nitrobiphenyl
93-65-2 Mecoprop
94-11-1 2,4-D isopropyl ester
94-36-0 Benzoyl peroxide
94-58-6 Dihydrosafrole
94.59.7 Safrole
94-74-6 Methoxone
((4-Chloro-2-methylphenoxy) acetic
(MCPA)
94-75-7 2,4-D [Acetic acid, (2,4-
dichlorophenoxy)-]
94-80-4 2,4-D butyl ester
94-82-6 2,4-DB
95.47-6 o-Xylene
95-48-7 o-Cresol
95-50-1 1,2-Dichlorobenzene
95-53-4 o-Toluidine
95-54-5 1,2-Phenylenediamine
95-63-6 1,2,4-Trimethylbenzene
*
1.0
1.0
1.0
1.0
1.0
0.1
1.0
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.
0.
0.
1.0
0.
0.
1.0
0.
0.
0.
0.
0.
1.0
0.
0.
0.
acid)
0.1
0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0
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
De Minimis
CAS Number Chemical Name Limit
106-88-7
106-89-8
106-93-4
106-99-0
107-02-8
107-05-1
107-06-2
107-11-9
107-13-1
107-18-6
107-19-7
107-21-1
107-30-2
108-05-4
108-10-1
108-31-6
108-38-3
108-39-4
108-45-2
108-60-1
108-88-3
108-90-7
108-93-0
108-95-2
109-06-8
109-77-3
109-86-4
110-54-3
110-57-6
110-80-5
110-82-7
110-86-1
111-42-2
111-44-4
111-91-1
114-26-1
115-07-1
115-28-6
115-32-2
116-06-3
117-79-3
117-81-7
118-74-1
119-90-4
1,2-Butylene oxide
Epichlorohydrin
1 ,2-Dibromoethane
(Ethylene dibromide)
1,3 -Butadiene
Acrolein
Allyl chloride
1,2-Dichloroethane (Ethylene
dichloride)
Allylamine
Acrylonitrile
Allyl alcohol
Propargyl alcohol
Ethylene glycol
Chloromethyl methyl ether
Vinyl acetate
Methyl isobutyl ketone
Maleic anhydride
m-Xylene
m-Cresol
1 ,3 -Phenylenediamine
Bis(2-chloro-l-methylethyl) ether
Toluene
Chlorobenzene
Cyclohexanol
Phenol
2-Methylpyridine
Malononitrile
2-Methoxyethanol
n-Hexane
trans-l,4-Dichloro-2-butene
2-Ethoxyethanol
Cyclohexane
Pyridine
Diethanolamine
Bis(2-chloroethyl) ether
Bis(2-chloroethoxy) methane
Propoxur
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
Propylene (Propene)
Chlorendic acid
Dicofol
[Benzenemethanol, 4-chloro-.alpha.-4-
(chlorophenyl)-.alpha.-(trichloromethyl)-
Aldicarb
2-Aminoanthraquinone
Di(2-ethylhexyl) phthalate
Hexachlorobenzene
3 ,3 '-Dimethoxybenzidine
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
1.0
0.1
0.1
*
0.1
CAS Number Chemical Name
De Minimis
Limit
119-93-7 3,3'-Dimethylbenzidine 0.1
(o-Tolidine)
120-12-7 Anthracene 1.0
120-36-5 2,4-DP 0.1
120-58-1 Isosafrole 1.0
120-71-8 p-Cresidine 0.1
120-80-9 Catechol 0.1
120-82-1 1,2,4-Trichlorobenzene .0
120-83-2 2,4-Dichlorophenol .0
121-14-2 2,4-Dinitrotoluene 0.1
121-44-8 Triethylamine .0
121-69-7 N,N-Dimethylaniline .0
121-75-5 Malathion .0
122-34-9 Simazine .0
122-39-4 Diphenylamine .0
122-66-7 1,2-Diphenylhydrazine 0.1
(Hydrazobenzene)
123-31-9 Hydroquinone 1.0
123-38-6 Propionaldehyde 1.0
123-63-7 Paraldehyde 1.0
123-72-8 Butyraldehyde 1.0
123-91-1 1,4-Dioxane 0.1
124-40-3 Dimethylamine 1.0
124-73-2 Dibromotetrafluoroethane 1.0
(Halon 2402)
126-72-7 Tris(2,3-dibromopropyl) 0.1
phosphate
126-98-7 Methacrylonitrile 1.0
126-99-8 Chloroprene 0.1
127-18-4 Tetrachloroethylene 0.1
(Perchloroethylene)
128-03-0 Potassium 1.0
dimethyldithiocarbamate
128-04-1 Sodium dimethyldithiocarbamate 1.0
128-66-5 C.I. Vat Yellow 4 1.0
131-11-3 Dimethyl phthalate 1.0
131-52-2 Sodium pentachlorophenate 1.0
132-27-4 Sodium o-phenylphenoxide 0.1
132-64-9 Dibenzofuran 1.0
133-06-2 Captan 1.0
[ IH-Isoindole-1,3 (2H)-dione, 3a,4,7,7a-
tetrahydro-2-[(trichloromethyl)thio]-]
133-07-3 Folpet 1.0
133-90-4 Chloramben 1.0
[Benzoic acid, 3-amino-2,5-dichloro-]
134-29-2 o-Anisidine hydrochloride 0.1
134-32-7 alpha-Naphthylamine 0.1
135-20-6 Cupferron 0.1
[Benzeneamine, N-hydroxy-N-nitroso,
ammonium salt]
136-45-8 Dipropyl isocinchomeronate 1.0
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-U,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 l-Chloro-1,1,2,2- 1.0
tetrafluoroethane (HCFC-124a)
357-57-3 Brucine 1.0
422-44-6 1,2-Dichloro-l, 1,2,3,3- 1.0
pentafluoropropane (HCFC-225bb)
422-48-0 2,3-Dichloro-l,l,1,2,3- 1.0
pentafluoropropane (HCFC-225ba)
422-56-0 3,3-Dichloro-l,l,1,2,2- 1.0
pentafluoropropane (HCFC-225ca)
431-86-7 1,2-Dichloro-l, 1,3,3,3- 1.0
pentafluoropropane (HCFC-225da)
460-35-5 3-Chloro-l,l,l-trifluoropropane 1.0
(HCFC-253fb)
463-58-1 Carbonyl sulfide 1.0
465-73-6 Isodrin *
492-80-8 C.I. Solvent Yellow 34 0.1
(Auramine)
505-60-2 Mustard gas 0.1
[Ethane, l,l'-thiobis[2-chloro-]
507-55-1 1,3-Dichloro-l, 1,2,2,3- 1.0
pentafluoropropane (HCFC-225cb)
510-15-6 Chlorobenzilate 1.0
[Benzeneacetic acid, 4-chloro-.alpha.-(4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
528-29-0 o-Dinitrobenzene 1.0
532-27-4 2-Chloroacetophenone 1.0
533-74-4 Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-1,3,5-
thiadiazine-2-thione)
534-52-1 4,6-Dinitro-o-cresol 1.0
540-59-0 1,2-Dichloroethylene 1.0
541-41-3 Ethyl chloroformate 1.0
541-53-7 2,4-Dithiobiuret 1.0
541-73-1 1,3-Dichlorobenzene 1.0
542-75-6 1,3-Dichloropropylene 0.1
542-76-7 3-Chloropropionitrile 1.0
542-88-1 Bis(chloromethyl) ether 0.1
554-13-2 Lithium carbonate 1.0
556-61-6 Methyl isothiocyanate 1.0
[Isothiocyanatomethane]
563-47-3 3-Chloro-2-methyl-l-propene 0.1
569-64-2 C.I. Basic Green 4 1.0
584-84-9 Toluene-2,4-diisocyanate 0.1
593-60-2 Vinyl bromide 0.1
594-42-3 Perchloromethyl mercaptan 1.0
606-20-2 2,6-Dinitrotoluene 0.1
608-93-5 Pentachlorobenzene *
612-82-8 3,3'-Dimethylbenzidine 0.1
dihydrochloride (o-Tolidine dihydrochloride)
612-83-9 3,3'-Dichlorobenzidine 0.1
dihydrochloride
11-16 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
615-05-4 2,4-Diaminoanisole 0.1
615-28-1 1,2-Phenylenediamine 1.0
dihydrochloride
621-64-7 N-Nitrosodi-n-propylamine 0.1
624-18-0 1,4-Phenylenediamine 1.0
dihydrochloride
624-83-9 Methyl isocyanate 1.0
630-20-6 1,1,1,2-Tetrachloroethane 1.0
636-21-5 o-Toluidine hydrochloride 0.1
639-58-7 Triphenyltin chloride 1.0
680-31-9 Hexamethylphosphoramide 0.1
684-93-5 N-Nitroso-N-methylurea 0.1
709-98-8 Propanil (N-(3,4-Dichlorophenyl) 1.0
propanamide)
759-73-9 N-Nitroso-N-ethylurea 0.1
759-94-4 Ethyl dipropylthiocarbamate 1.0
(EPTC)
764-41-0 l,4-Dichloro-2-butene 1.0
812-04-4 l,l-Dichloro-l,2,2-trifluoroethane 1.0
(HCFC-123b)
834-12-8 Ametryn 1.0
(N-Ethyl-N'-(l-methylethyl)-6-(methylthio)-
1,3,5,-triazine-2,4-diamine)
842-07-9 C.I. Solvent Yellow 14 1.0
872-50-4 N-Methyl-2-pyrrolidone 1.0
924-16-3 N-Nitrosodi-n-butylamine 0.1
924-42-5 N-Methylolacrylamide 1.0
957-51-7 Diphenamid 1.0
961-11-5 Tetrachlorvinphos 1.0
[Phosphoric acid, 2-chloro-l-(2,4,5-
trichlorophenyl)ethenyldimethyl ester]
989-38-8 C.I. Basic Red 1 1.0
1114-71-2 Pebulate 1.0
[Butylethylcarbamothioic acid S-propyl
ester]
1120-71-4 Propane sultone 0.1
1134-23-2 Cycloate 1.0
1163-19-5 Decabromodiphenyl oxide 1.0
1313-27-5 Molybdenum trioxide 1.0
1314-20-1 Thorium dioxide 1.0
1319-77-3 Cresol (mixed isomers) 1.0
1320-18-9 2,4-D propylene glycol butyl 0.1
ether ester
1330-20-7 Xylene (mixed isomers) 1.0
1332-21-4 Asbestos (friable) 0.1
1335-87-1 Hexachloronaphthalene 1.0
1336-36-3 Polychlorinatedbiphenyls(PCBs) *
1344-28-1 Aluminum oxide (fibrous forms) 1.0
1464-53-5 Diepoxybutane 0.1
1563-66-2 Carbofuran 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'-(l-methylethyl)-l,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-Trimethylphenyl 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,l,l,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(l-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 Nickel 0.1
7440-22-4 Silver 1.0
7440-28-0 Thallium 1.0
7440-36-0 Antimony 1.0
7440-38-2 Arsenic 0.1
7440-39-3 Barium 1.0
7440-41-7 Beryllium 0.1
7440-43-9 Cadmium 0.1
7440-47-3 Chromium 1.0
7440-48-4 Cobalt 0.1
7440-50-8 Copper 1.0
7440-62-2 Vanadium (except when contained 1.0
in an alloy)
7440-66-6 Zinc (fume or dust) 1.0
7550-45-0 Titanium tetrachloride 1.0
7632-00-0 Sodium nitrite 1.0
7637-07-2 Boron trifluoride 1.0
7647-01-0 Hydrochloric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
7664-39-3 Hydrogen fluoride 1.0
7664-41-7 Ammonia 1.0
(includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium
salts and other sources; 10 percent of total
aqueous ammonia is reportable under this
listing)
7664-93-9 Sulfuric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
7696-12-0 Tetramethrin 1.0
[2,2-Dimethy 1-3-(2-methyl-1-
propenyl)cyclopropanecarboxylic acid
(l,3,4,5,6,7-hexahydro-l,3-dioxo-2H-
isoindol-2-yl)methyl ester]
7697-37-2 Nitric acid .0
7723-14-0 Phosphorus (yellow or white) .0
7726-95-6 Bromine .0
7758-01-2 Potassium bromate 0.1
7782-41-4 Fluorine
7782-49-2 Selenium
7782-50-5 Chlorine
7786-34-7 Mevinphos
7803-51-2 Phosphine
8001-35-2 Toxaphene *
8001-58-9 Creosote 0.1
9006-42-2 Metiram 1.0
10028-15-6 Ozone 1.0
10034-93-2 Hydrazine sulfate 0.1
10049-04-4 Chlorine dioxide 1.0
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) cyclopropanecarboxylate]]
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-l,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-ol
methylcarbamate]
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-Dimethy 1-3-(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'-[l,4-Piperazinediylbis (2,2,2-
trichloroethylidene)]bisformamide]
Norflurazon 1.0
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)phenyl]-3(2H)-pyridazinone]
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' -dimethylurea]
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] - IH-imidazole]
l-Bromo-l-(bromomethyl)-l,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
1.0
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
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
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-2-
nitrobenzoic acid, sodium salt]
Chlorotetrafluoroethane 1.0
Chlorsulfuron 1.0
[2-Chloro-N-[[(4-methoxy-6-methyl-
l,3,5-triazin-2-yl)amino] carbonyl]
benzenesulfonamide]
3,3'-Dichlorobenzidine sulfate 0.1
Fenoxaprop ethyl 1.0
[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 l)pheny 1] -
1 - [2- [4-(trifluoromethy l)phenyl] ethenyl] -2-
propenylidene] hy drazone]
Cyhalothrin 1.0
[3-(2-Chloro-3,3,3-trifluoro-1-propenyl)-2,2-
dimethylcyclopropanecarboxylic acid
cyano(3-phenoxyphenyl) methyl ester]
Cyfluthrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid,
cyano(4-fluoro-3 -phenoxyphenyl) methyl
ester]
Fluvalinate 1.0
[N-[2-Chloro-4-(trifluoromethyl)phenyl]DL-
valine(+)-cyano(3-phenoxyphenyl)methyl
ester]
Fluazifop butyl 1.0
[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-
methylsurfonyl)-2-nitrobenzamide]
Fenoxycarb 1.0
[[2-(4-Phenoxy phenoxy)ethyl]carbamic acid
ethyl ester]
11-20 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
DeMinimis appear. However, for purposes of the supplier notification
Limit requirement only, such limits are provided in Appendix D.
74051-80-2 Sethoxydim
[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
[Benzoic 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-.alpha.-(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
1.0 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
N090
•H(5-x)
Where x = 1 to 5
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
Toxics Release Inventory Reporting Form and Instructions 11-21
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Table II
compounds: 1.0)
Includes any unique chemical substance that contains
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 can be made. 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(phenyrisocyanate)
(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
chromium as part of that chemical's infrastructure.
diisocyanate
15646-96-5 2,4,4-Trimethylhexamethylene
diisocyanate
N150 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.) (*) This category includes only those
chemicals listed below. [Note: When completing the
FormR, 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
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
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-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
11-22 Toxics Release Inventory Reporting Forms and Instructions
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Table II
N171 Ethylenebisdithiocarbamic acid, salts and esters
EBDCs) (1.0)
Includes any unique chemical substance that contains
an EBDC or an EBDC salt as part of that chemical's
infrastructure.
N230 Certain Glycol Ethers (1.0)
R-(OCH2CH2)n-OR'
where n= 1, 2, or 3
R = alkyl C7 or less; or
R = phenyl or alkyl substituted phenyl;
R' = H, or alkyl C7 or less; or
OR' consisting of carboxylic acid ester, sulfate, phosphate,
nitrate, or sulfonate.
N420 Lead Compounds (*)
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)
H(10-x)
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)
where x= 10 to 13;
y = 3 to 12; and
the average chlorine content ranges from 40 — 70% with
the limiting molecular formulas C10H19C13 and C13H16C112
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 Compounds (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.
Where x = 1 to 10
N583 Polychlorinated alkanes (Ci0 to Ci3) (1.0, except for
Toxics Release Inventory Reporting Form and Instructions 11-23
-------
Table II
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.
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 Abreviations
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
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Table IV. Country Codes
AA
AC
AE
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
KE
KG
Aruba
Antigua and
Barbuda
United Arab
Emirates
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
Kenya
Kyrgyzstan
CE
CF
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
KN
KQ
Sri Lanka
Congo
(Brazzaville)
Congo (Kinshasa)
China
Chile
Cayman Islands
Cocos (Keeling)
Islands
Cameroon
Comoros
Colombia
Coral Sea Islands
Costa Rica
Central African
Republic
Cuba
Cape Verde
Cook Islands
Cyprus
Denmark
Djibouti
Dominica
Dominican
Republic
Ecuador
Egypt
Ireland
Equatorial Guinea
Estonia
Eritrea
El Salvador
Ethiopia
Europa Island
Czech Republic
French Guiana
Finland
Fiji
Falkland Islands
(Islas Malvinas)
Faroe Islands
French Polynesia
France
French Southern
North Korea
Kingman Reef
GA
GB
GG
GH
GI
GJ
GK
GL
GM
GO
GP
GR
GT
GV
GY
GZ
HA
HK
HM
HO
HR
HU
1C
ID
IM
IN
IO
IP
IR
IS
IT
IV
IZ
JA
JE
JM
JN
JO
JU
KR
KS
and Antarctic
Lands
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 D'lvoire
Iraq
Japan
Jersey
Jamaica
Jan Mayen
Jordan
Juan de Nova
Island
Kiribati
South Korea
IV-1 Toxics Release Inventory Reporting Form and Instructions
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Table IV
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
MX
MY
MZ
NC
NE
NF
NG
NH
NI
NL
NO
NP
NR
NS
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
Mexico
Malaysia
Mozambique
New Caledonia
Niue
Norfolk Island
Niger
Vanuatu
Nigeria
Netherlands
Norway
Nepal
Nauru
Suriname
NT
NU
NZ
PA
PC
PE
PF
PG
PK
PL
PM
PO
PP
PS
PU
QA
RE
RO
RP
RS
RW
SA
SB
SC
SE
SF
SG
SH
SI
SL
SM
SN
SO
SP
ST
SU
sv
sw
sx
SY
Netherlands
Antilles
Nicaragua
New Zealand
Paraguay
Pitcairn Islands
Peru
Paracel Islands
Spratly Islands
Pakistan
Poland
Panama
Portugal
Papua New Guinea
Palau
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
St. Lucia
Sudan
Svalbard
Sweden
South Georgia and
South Sandwich
Islands
Syria
SZ
TD
TE
TH
TI
TK
TL
TN
TO
TP
TS
TT
TU
TV
TW
TX
TZ
UG
UK
UP
UV
UY
UZ
VC
VE
VI
VM
VT
WA
WE
WF
WI
WS
WZ
YI
YM
ZA
ZI
Switzerland
Trinidad and
Tobago
Tromelin Island
Thailand
Tajikistan
Turks and Caicos
Islands
Tokelau
Tonga
Togo
Sao Tome and
Principe
Tunisia
East Timor
Turkey
Tuvalu
Taiwan
Turkmenistan
Tanzania
Uganda
United Kingdom
Ukraine
Burkina Faso
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
Yugoslavia
Yemen
Zambia
Zimbabwe
Toxics Release Inventory Reporting Form and Instructions IV-2
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This Page Intentionally Left Blank
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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, you should 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 should 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 should check Form R, Part I,
Section 4.2c, while contractors at federal facilities should 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:
D Required Form R certification statement;
D List of the chemicals reported on the federal facility's
disk; and
D 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
-------
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, you should 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 should indicate that its submission is a revision.
National Security Data
DO NOT SUBMIT NATIONAL SECURITY DATA TO THE
TRI DATA PROCESSING 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 should 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
should be signed by a federal employee. Contractor employee
signatures are not considered valid on federal reports.
More Help is Available!
Federal facilities may call EPA's EPCRA Call Center to ask
specific questions concerning how to submit their Form R report.
A-2 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix A
For contact information, see the TRI Home Page at
.
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
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
93 Public Finance, Taxation, and
Monetary Policy
9311 Public Finance, Taxation, and Monetary Policy
94 Administration of Human
Resource Programs
94 1 1 Administration of Educational Programs
943 1 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
Toxics Release Inventory Reporting Forms and Instructions A-3
-------
This Page Intentionally Left Blank
-------
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 EPCRA section
313 chemical in waste streams entering and leaving
process equipment.
E: Estimate is based on published emission factors,
such as those relating release quantity to through-put
or equipment type (e.g., air emission factors).
O: Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This would
include applying an estimated removal efficiency to
a treatment, even if the composition of the waste
before treatment was fully identified through
monitoring data.
Toxics Release Inventory Reporting Forms and Instructions B-1
-------
Appendix B
Section 6. Transfers of the Toxic Chemical in Wastes to
Off-Site Locations
Type of Waste Disposal/Treatment/Energy
Recovery/Recycling
M10 Storage Only
M20 Solvents/Organics Recovery
M24 Metals Recovery
M26 Other Reuse or Recovery
M28 Acid Regeneration
M40 Solidification/Stabilization
M41 Solidification/Stabilization-Metals and Metal
Category Compounds only
M50 Incineration/Thermal Treatment
M54 Incineration/Insignificant Fuel Value
M56 Energy Recovery
M61 Wastewater Treatment (Excluding POTW)
M62 Wastewater Treatment (Excluding POTW) — Metals
and Metal Category Compounds only
M64 Other Landfills
M65 RCRA Subtitle C Landfills
M66 Subtitle C Surface Impoundment
M67 Other Surface Impoundments
M69 Other Waste Treatment
M73 Land Treatment
M79 Other Land Disposal
M81 Underground Injection to Class I Wells
M82 Underground Injection to Class II-V Wells
M90 Other Off-Site Management
M92 Transfer to Waste Broker — Energy Recovery
M93 Transfer to Waste Broker — Recycling
M94 Transfer to Waste Broker — Disposal
M95 Transfer to Waste Broker — Waste Treatment
M99 Unknown
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
Chemical Treatment
H040 Incineration-thermal destruction other than use as a
fuel
H071 Chemical reduction with or without precipitation
H073 Cyanide destruction with or without precipitation
H075 Chemical oxidation
H076 Wet air oxidation
H077 Other chemical precipitation with or without pre-
treatment
Biological Treatment
H081 Biological treatment with or without precipitation
Physical Treatment
H082 Adsorption
H083 Air or steam stripping
H101 Sludge treatment and/or dewatering
H103 Absorption
Hill Stabilization or chemical fixation prior to disposal
HI 12 Macro-encapsulation prior to disposal
H121 Neutralization
HI 22 Evaporation
HI23 Settling or clarification
HI24 Phase separation
HI29 Other treatment
Section 7B. On-Site Energy Recovery Processes
U01 Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
Section 7C. On-Site Recycling Processes
H10 Metal recovery (by retorting, smelting, or chemical
or physical extraction)
H20 Solvent recovery (including distillation, evaporation,
fractionation or extraction)
H3 9 Other recovery or reclamation for reuse (including
acid regeneration or other chemical reaction process)
B-2 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix B
Section 8.10. Source Reduction Activity Codes
Good Operating Practices
W13 Improved maintenance scheduling, record keeping,
or procedures
W14 Changed production schedule to minimize
equipment and feedstock changeovers
W19 Other changes in operating practices
Inventory Control
W21 Instituted procedures to ensure that materials do not
stay in inventory beyond shelf-life
W22 Began to test outdated material — continue to use if
still effective
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labeling procedures
W25 Instituted clearinghouse to exchange materials that
would otherwise be discarded
W29 Other changes in inventory control
Spill and Leak Prevention
W31 Improved storage or stacking procedures
W32 Improved procedures for loading, unloading, and
transfer operations
W33 Installed overflow alarms or automatic shut-off
valves
W35 Installed vapor recovery systems
W36 Implemented inspection or monitoring program of
potential spill or leak sources
W39 Other changes made in spill and leak prevention
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
W49 Other raw material modifications made
Process Modifications
W51 Instituted recirculation within a process
W52 Modified equipment, layout, or piping
W53 Use of a different process catalyst
W54 Instituted better controls on operating bulk
containers to minimize discarding of empty
containers
W55 Changed from small volume containers to bulk
containers to minimize discarding of empty
containers
W58 Other process modifications
Cleaning and Degreasing
W59 Modified stripping/cleaning equipment
W60 Changed to mechanical stripping/cleaning devices
(from solvents or other materials)
W61 Changed to aqueous cleaners (from solvents or other
materials)
W63 Modified containment procedures for cleaning units
W64 Improved draining procedures
W65 Redesigned parts racks to reduce drag out
W66 Modified or installed rinse systems
W67 Improved rinse equipment design
W68 Improved rinse equipment operation
W71 Other cleaning and degreasing modifications
Surface Preparation and Finishing
W72 Modified spray systems or equipment
W73 Substituted coating materials used
W74 Improved application techniques
W75 Changed from spray to other system
W78 Other surface preparation and finishing
modifications
Product Modifications
W81 Changed product specifications
W82 Modified design or composition of products
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
Toxics Release Inventory Reporting Forms and Instructions B-3
-------
Appendix B
Reporting the Waste Management of Metals.
This appendix outlines how the TRI-ME 2003 reporting software restricts reporting for metals when the specific data element or
waste management code is not applicable for a particular chemical. Below is a list of metals divided into four groups along with
charts that help explain where quantities of these chemicals can and can not be reported on the Form R using TRI-ME. In
addition, there are charts that explain restrictions on reporting waste management codes for the toxic chemicals in each of the four
groups. This appendix only shows where reporting is restricted in TRI-ME, it does not indicate every situation where a metal
should not be reported in a specific section of the form. For example, TRI-ME does not restrict the reporting of most individually-
listed metal compounds as used for energy recovery (Sections 8.2 and 8.3) even though some of these chemicals do not have a
heat value greater that 5000 British thermal units (Btu) and thus, can not be combusted for energy recovery. It is left to the
facility to decide which of these toxic chemicals can be used for energy recovery. If you are not using TRI-ME this appendix can
serve as a guide to help you understand where it is not appropriate to report certain quantities of toxic chemicals or waste
management codes on your Form R.
Parent Metals:
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Metal Compound
Categories:
Antimony Compounds
Arsenic Compounds
Barium Compounds
Beryllium Compounds
Cadmium Compounds
Chromium Compounds1
Cobalt Compounds
Copper Compounds
Lead Compounds
Manganese Compounds
Mercury Compounds
Nickel Compounds
Selenium Compounds
Silver Compounds
Thallium Compounds
Vanadium Compounds
Zinc Compounds
Metals with Qualifiers:
Aluminum (fume or dust)
Vanadium (except when
in an alloy)
Zinc (fume or dust)
Individually-Listed
Metal Compounds:
Bis(tributylin) oxide
Triphenyltin hydroxide
Triphenyltin chloride
Molybdenum trioxide
Thorium dioxide
Asbestos (friable)
Aluminum oxide (fibrous
forms)
Tributyltin fluoride
Tributyltin methacrylate
Titanium tetrachloride
Boron trifluoride
Metiram
Boron trichloride
Zineb
Maneb
Fenbutatin oxide
Iron pentacarbonyl
Ferbam
C.I. Direct Brown 95
Osmium tetroxide
Aluminum phosphide
C.I. Direct Blue 218
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.
B-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix B
Sections 5.3 - Discharges to Water and 6.1 - Transfers to POTWs
The following chart indicates which metals can be reported as released to water in Section 5.3 or to POTW's in Section 6.1. Only
zinc (fume or dust) and aluminum (fume or dust) are not reported in these sections because the fume or dust form of a toxic
chemical can not exist in water.
Form R Section in Part II
Section 5.3 - Discharges to receiving streams or water
bodies
Section 6. 1- Discharges to POTWs
Parent
Metals
All
All
Metal
Category
Compounds
All
All
Metals with
Qualifiers
Vanadium
(except
when
contained in
an alloy)
Vanadium
(except
when
contained in
an alloy)
Individually-
listed Metal
Compounds
All except
Asbestos
All except
Asbestos
Section 6.2. Transfers to Other Off Site Locations
Any toxic chemical may be reported in Section 6.2, however, TRI-ME will not allow certain M codes to be used when reporting
metals. The chart below indicates which M codes can be reported in Section 6.2 for the four groups of metals. Note that all
disposal M codes other than M41 and M62 can be used for all toxic chemicals. Code M24 is only made available for the four
groups of metals.
Waste Management Code for Section 6.2
M41 and M62 (disposal codes-for metals only)
M56 and M92 (energy recovery codes)
M20 and M28 (recycling codes)
M24, M26 and M93 (recycling codes)
M40, M50, M54, (treatment codes)
M61, M69, M95 (treatment codes)
Parent
Metals
All
None
None
All
None
Barium3
Metal
Category
Compounds
All
None
None
All
None
Barium
Compounds3
Metals with
Qualifiers
Vanadium
(except when
contained in an
alloy)
None
None
All
All except
Vanadium
(except when
contained in an
alloy)
Same as above
Individually-
listed Metal
Compounds
All except
Asbestos
All except
Asbestos
All
All
All
All
Toxics Release Inventory Reporting Forms and Instructions B-5
-------
Appendix B
Section 7A. On-site Waste Treatment Methods and Efficiency
TRI-ME allows any toxic chemical to be reported in Section 7 A, however, it limits reporting in two ways. First, TRI-ME limits
the treatment codes that can be reported based on the General Waste Stream Code selected. If a TRI-ME user selects General
Waste Stream code "A - Gaseous", all Waste Treatment Codes are made available. However, if a user selects from the remaining
three General Waste Stream Codes (W - Wastewater, L - Liquid waste streams, or S - Solid waste streams), the "Air Emissions
Treatment" Waste Treatment Codes are not made available. Second, the software restricts reporting for certain toxic chemicals
with qualifiers. When reporting zinc (fume or dust) or aluminum (fume or dust) TRI-ME will not allow the user to select General
Waste Stream Codes W-Wastewater and L-Liquid waste streams because the fume or dust form of a toxic chemical can not exist
in a liquid or water waste. For asbestos (friable) only S - Solid or A - Gaseous can be selected. When reporting hydrochloric acid
(acid aerosols) or sulfuric acid (acid aerosols) only A - Gaseous can be selected.
Crosswalk for Section 7A, Column B. Waste Treatment Method (s) Sequence
Air Emissions Treatment (applicable to gaseous waste streams only)
(No change - same as previous codes)
A01
A02
A03
A04
A05
A06
A07
Flare
Condenser
Scrubber
Absorber
Electrostatic Precipitator
Mechanical Separation
Other Air Emission Treatment
Previous Codes
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
Biological Treatment:
Bll
B21
B31
B99
Aerobic
Anaerobic
Facultative
Other Biological Treatment
Previous Codes
H081
H081
H081
H081
Biological treatment with or without precipitation
Biological treatment with or without precipitation
Biological treatment with or without precipitation
Biological treatment with or without precipitation
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
Chemical Treatment:
C01
C02
C09
Cll
C21
C31
C41
Chemical Precipitation - Lime or Sodium
Hydroxide
Chemical Precipitation - Sulfide
Chemical Precipitation - Other
Neutralization
Chromium Reduction
Complexed Metals Treatment (other than pH
adjustment)
Cyanide Oxidation - Alkaline Chlorination
H071
H071
H077
H121
H071
H129
H073
Chemical reduction with or without precipitation
Chemical reduction with or without precipitation
Other chemical precipitation with or without pre-
treatment
Neutralization
Chemical reduction with or without precipitation
Other treatment
Cyanide destruction with or without precipitation
B-6 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix B
C42
C43
C44
C45
C46
C99
Cyanide Oxidation - Electrochemical
Cyanide Oxidation - Other
General Oxidation (including Disinfection) -
Chlorination
General Oxidation (including Disinfection) -
Ozonation
General Oxidation (including Disinfection) -
Other
Other Chemical Treatment
H073
H073
H075
H075
H075
H129
Cyanide destruction with or without precipitation
Cyanide destruction with or without precipitation
Chemical oxidation
Chemical oxidation
Chemical oxidation
Other treatment
Incineration/Thermal Treatment: (Note: Only report combustion for the purposes of incineration/thermal treatment in Section
7A. If the method involves combustion for the purposes of energy recover, report as U01, U02, or U03 in Section 7B. If the
method involves combustion for the purposes of materials recovery, report as H39 in Section 7C.)
F01
Fll
F19
F31
F41
Liquid Injection
Rotary Kiln with Liquid Injection Unit
Other Rotary Kiln
Two Stage
Fixed Hearth
Previous Codes
F42
F51
F61
F71
F81
F82
F83
F99
Multiple Hearth
Fluidized Bed
Infra-Red
Fume/Vapor
Pyrolytic destructor
Wet air oxidation
Thermal Drying/Dewatering
Other Incineration/Thermal Treatment
H040
H040
H040
H040
H040
Incineration - thermal destruction other than use
as a fuel
Incineration - thermal destruction other than use
as a fuel
Incineration - thermal destruction other than use
as a fuel
Incineration - thermal destruction other than use
as a fuel
Incineration - thermal destruction other than use
as a fuel
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H040
H040
H040
H040
H040
H076
H122
H040
Incineration - thermal destruction other than use
as a fuel
Incineration - thermal destruction other than use
as a fuel
Incineration - thermal destruction other than use
as a fuel
Incineration - thermal destruction other than use
as a fuel
Incineration - thermal destruction other than use
as a fuel
Wet air oxidation
Evaporation
Incineration - thermal destruction other than use
as a fuel
Physical Treatment:
P01
Equalization
H129
Other treatment
Toxics Release Inventory Reporting Forms and Instructions B-7
-------
Appendix B
P09
Pll
P12
P13
P14
P15
P16
P17
P18
P19
P21
P22
P23
P29
P31
P41
P42
Other blending
Settling/clarification
Filtration
Sludge dewatering (non-thermal)
Air flotation
Oil skimming
Emulsion breaking - thermal
Emulsion breaking - chemical
Emulsion breaking - other
Other liquid phase separation
Adsorption - Carbon
Adsorption - Ion exchange (other than for
recovery/reuse)
Adsorption - Resin
Adsorption - Other
Reverse Osmosis (other than for recover/reuse)
Stripping - Air
Stripping - Steam
Previous Codes
P49
P51
P61
P99
Stripping - Other
Acid Leaching (other than for recovery /reuse)
Solvent Extraction (other than recovery /reuse)
Other Physical Treatment
H129
H123
H124
H101
H124
H124
H124
H124
H124
H124
H082
H082
H082
H082
H129
H083
H083
other treatment
Settling or clarification
Settling or clarification
Sludge treatment and/or dewatering
Phase separation
Phase separation
Phase separation
Phase separation
Phase separation
Phase separation
Adsorption
Adsorption
Adsorption
Adsorption
Other treatment
Air or steam stripping
Air or steam stripping
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H083
H129
H129
H129
Air or steam stripping
Other treatment
Other treatment
Other treatment
Solidification/Stabilization:
G01
G09
Gil
G20
G99
Cement processes (including silicates)
Other Pozzolonic Processes (including silicates)
Asphaltic Techniques
Thermoplastic Techniques
Other Solidification Processes
Hill
Hill
Hill
Hill
Hill
Stabilization or chemical fixation prior to disposal
Stabilization or chemical fixation prior to disposal
Stabilization or chemical fixation prior to disposal
Stabilization or chemical fixation prior to disposal
Stabilization or chemical fixation prior to disposal
B-8 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix B
Section 7B. On-site Energy Recovery Processes
The chart below indicates which energy recovery codes can be reported in TRI-ME in Section 7B for the four groups of metals.
Energy Recovery Code for Section 7B
U01,U02,U03
Parent
Metals
None
Metal
Category
Compounds
None
Metals with
Qualifiers
None
Individually-
listed Metal
Compounds
All except
Asbestos
Section 7C. On-site Recycling Processes
Any chemical can be reported in Section 7C, however, certain waste management codes should not be reported for certain toxic
chemicals. The chart below indicates which codes can be reported in Section 7C when using TRI-ME.
Recycling Code for Section 7C
H10
(this code is for metals only
H20
H39
Parent Metals
All
None
All
Metal Category
Compounds
All
None
All
Metals with
Qualifiers
All
None
All
Individually-
listed Metal
Compounds
All
All
All
Crosswalk for Section 7C. On-site Recycling Processes
Previous Codes
Rll
R12
R13
R14
R19
R21
R22
R23
R24
Solvents/Organics Recovery - Batch Still
Distillation
Solvents/Organics Recovery - Thin-Film
Evaporation
Solvents/Organics Recovery - Fractionation
Solvents/Organics Recovery - Solvent
Extraction
Solvents/Organics Recovery - Other
Metals Recovery - Electrolytic
Metals Recovery - Ion Exchange
Metals Recovery - Acid Leaching
Metals Recovery - Reverse Osmosis
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H20
H20
H20
H20
H20
H10
H10
H10
H10
Solvent Recovery (including distillation,
evaporation, fractionation or extraction)
Solvent Recovery (including distillation,
evaporation, fractionation or extraction)
Solvent Recovery (including distillation,
evaporation, fractionation or extraction)
Solvent Recovery (including distillation,
evaporation, fractionation or extraction)
Solvent Recovery (including distillation,
evaporation, fractionation or extraction)
Metal Recovery (by retorting, smelting, or
chemical or physical extraction)
Metal Recovery (by retorting, smelting, or
chemical or physical extraction)
Metal Recovery (by retorting, smelting, or
chemical or physical extraction)
Metal Recovery (by retorting, smelting, or
chemical or physical extraction)
Toxics Release Inventory Reporting Forms and Instructions B-9
-------
Appendix B
R26
R27
R28
R29
R30
R40
R99
Metals Recovery - Solvent Extraction
Metals Recovery - High Temperature
Metals Recovery - Retorting
Metals Recovery - Secondary Smelting
Metals Recovery - Other
Acid Regeneration
Other Reuse or Recovery
H10
H10
H10
H10
H10
H39
H39
Metal Recovery (by retorting, smelting, or
chemical or physical extraction)
Metal Recovery (by retorting, smelting, or
chemical or physical extraction)
Metal Recovery (by retorting, smelting, or
chemical or physical extraction)
Metal Recovery (by retorting, smelting, or
chemical or physical extraction)
Metal Recovery (by retorting, smelting, or
chemical or physical extraction)
Other recovery or reclamation for reuse (including
acid regeneration or other chemical reaction
process)
Other recovery or reclamation for reuse
(including acid regeneration or other chemical
reaction process)
Section 8. Source Reduction and Recycling Activities
The chart below indicates which metals can be reported in Sections 8.2, 8.3, 8.6 and 8.7 of the Form R when using TRI-ME. Note
that all toxic chemicals can. Appendix B be reported in Sections 8.1, 8.4, 8.5 and 8.8.
Waste Management Activity
Quantity used for energy recovery on site and off
site (Sections 8.2 and 8.3)
Quantity treated for destruction on site and off
site (Sections 8.6 and 8.7)
Parent
Metals
None
None except
Barium
Metal
Category
Compounds
None
None except
Barium
Compounds5
Metals with
Qualifiers
None
All except
Vanadium (except
when contained in
an alloy)
Individually-
listed Metal
Compounds
All except
Asbestos4
All
2 Although TRI-ME does not restrict reporting of most individually-listed metal compounds as transferred off site for
energy recovery, only chemicals with a heat value greater than 5000 British thermal units are combusted in a device that
is an industrial furnace or boiler (40 CFR Section 372.3) should be reported as used for energy recovery.
3 The toxic chemical category barium compounds (MHO) does not include barium sulfate. Because barium sulfate is not
a listed toxic chemical, the conversion in a waste stream of barium or barium compound to barium sulfate is considered
treatment for destruction (40 CFR Section 372.3)
"Although TRI-ME does not restrict reporting of most individually -listed metal compounds in Sections 7B, 8.2 or 8.3,
only chemicals with a heat value greater than 5000 British thermal units that are combusted in a device that is an
industrial furnace or boiler (40 CFR Section 372.3) should be reported in these sections.
5The toxic chemical category barium compounds (N040) does not include barium sulfate. Because barium sulfate is not
a listed toxic chemical, the conversion in a waste stream of barium or a barium compound to barium sulfate is considered
treatment for destruction (40 CFR Section 372.3).
B-10 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
Facility Data Profiles and Common
Errors in Completing Form R Reports
and 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 the Facility
Data Profile (FDP), 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 A Certification Statements, 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 made available by TRI Data
Processing Center to a reporting facility in response to any
submission the TRI Data Processing Center receives. You
may review your FDP on the internet at
http://www.triefdp.org. It is very important that you review
your FDP. If the Technical Contact provided an email El
address in the Form R/Form A, they will receive a real-time
email notifying them when their FDP has been updated and
posted to the FDP website. A submission can include an
original or revised Form R or Form A, or corrections included G
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 TRI Data Processing Center
has entered its data correctly into EPA's national computer
system - i.e. the TRI Data Processing Center "echoes back" the
information that it has received. Second, if the TRI Data
Processing 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.
The FDP does not serve as a means to withdraw a Form R
and/or Form A. For additional information regarding
withdrawal procedures see Section A.5 of this document or go
to . If you have questions regarding your
FDP, please send an email to tri.efdptgjcsc.com or call, 1-301-
429-5005. Facilities that send corrections in response to their
FDPs are encouraged to submit a revision using CDX. For
additional instructions regarding your FDP, please refer to
your FDP.
An FDP is comprised of the following sections:
H Facility Information. This section displays all
facility specific data, including TRI Facility
Identification, facility name, facility address, facility
mailing address, relevant permits (e.g., RCRA,
Toxics Release Inventory Reporting Forms and Instructions C-1
NPDES, and UIC), Standard Industrial Classification
code (SIC), and other facility data. Errors related to
facility information will be provided in this section.
Instructions Page. This page provides instructions
on how to review and respond to the FDP.
Certification Statement Signature Page. This page
provides the Certification Statement to be signed by a
facility owner/operator or senior management official
if using the FDP to make a revision.
Chemical Report Summary. This section lists all
chemicals reported by the facility for each reporting
year covered 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.
Errors/Alerts Identified In This Report: Non-
Technical Data Changes (NDC), Notices of
Technical Errors (NOTE), Notices of Significant
Error (NOSE), and Data Quality Alerts (DQA).
FDPs identify three different types of errors: NDCs,
NOTEs and NOSEs and alerts called Data Quality
Alerts (DQA). See explanations in section B.
Error Summary Page. The Error Summary Page
provides facilities an error/alert count for each
chemical submission.
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 submissions
received during the current calendar year, revisions
or responses to FDPs only. For example, if a facility
originally reported five chemicals for Reporting 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.
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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 and provide Data Quality Alerts, as well as
indicate where the TRI Data Processing Center has made
minor clerical changes 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 identify potential errors with certain data
fields such 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 the TRI Data Processing Center has
corrected for you. It is not necessary to respond to a NDC.
The TRI Data Processing 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 TRI Data Processing Center will
correct this clerical error and display the correct information
on the facility's FDP. If a facility lists a specific glycol ethers
subcategory, the TRI Data Processing 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 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 NOTEs as soon as
possible. These types of errors require that the reporting
facility make corrections on its FDP (or provide the TRI Data
Processing 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
EPA's 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 NOTEs 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 contains the Notice of
Significant Error if applicable. Significant errors prevent
submissions from being entered into the TRI Data Processing
Center data management system or do not allow the TRI Data
Processing 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, submit a revised Form R or
Form A, or provide the TRI Data Processing Center with a
brief explanation why they do not believe that it is an error. 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 separately.
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 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.
For the first time beginning with RY 2004, TRI will provide
Data Quality Alerts (DQA). The DQA informs facilities of
possible reporting issues. It is offered to assist facilities in
ensuring accurate reporting.
C. Common Errors in Completing Form R
Reports and Form A Certification Statements,
including Reporting Determination Errors
General Considerations
Lack of signed Certification Statement. If you
choose not to send your TRI submissions via the
paperless CDX process, you must send a signed
certification statement with your magnetic media
submission or sign Part I, Section 3 of your hard copy
C-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
submission. Although EPA accepts diskette and
paper submissions, EPA strongly encourages you to
send your submission via CDX.
H 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. By using TRI-ME and CDX, errors
such as this would not occur. Each chemical
submission must have its own page one. 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
H 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.
D 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.
H 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.
D Considering 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.
n Overlooking 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 manufacturing of a reportable
chemical (nitrate compounds).
Container Residue
H 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
H Invalid Forms. The correct version of the form for the
reporting year in question must be used. For example,
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 1991-1995 must
not be used to report data for years 1996 and later.
Section 2. Trade Secret Information
n 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 unsanitized 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.
Toxics Release Inventory Reporting Forms and Instructions C-3
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Appendix C
Section 3. Certification
n 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, a
certification letter containing the certification language
as noted in 40 CFR § 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
H "Questionable" entries. Incorrect entries may require
corrections to be made by the facility. The use of the
TRI-ME software would prevent such errors from
occurring. 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
n Reporting chemical abstract service (CAS)
numbers in Section 1.1. Beginning with the 1991
reporting year, EPA has assigned alphanumeric
category codes to the twenty chemical categories for
the purposes of reporting the CAS number field in
Section 1.1. When completing a Form R for a
chemical category, the appropriate code for that
category must be provided in Section 1.1. The CAS
numbers are listed in Table II: "Section 313 Toxic
Chemical List," and if needed, the category codes are
listed in Appendix B: "Reporting Codes for EPA
FormR." Category guidance documents are listed in
the Chemical and Industry Guidance Documents
section in this document.
n 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)."
H 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.
n Failure to consider an EPCRA section 313 chemical
qualifier. Only EPCRA section 313 chemicals in the
form specified in the qualifier require reporting under
section 313 and should be reported on Form R with the
appropriate qualifier in parentheses. For example,
isopropyl alcohol is listed on the EPCRA section 313
chemical list with the qualifier "manufacturing- strong
acid process, no supplier notification." Thus, the
ONLY facilities that should report this EPCRA section
313 chemical are those that manufacture isopropyl
alcohol by the strong acid process.
H Generic chemical name in Section 1.3. A generic
chemical name should only be provided if the section
313 chemical identity is claimed as a trade secret.
Section 2. Mixture Component Identity
H Identifying chemicals used in mixtures. Facilities
should 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.
H 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
H 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
C_4 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix C
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 usually includes the
incorporation of 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.
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
n Incorrectly reporting stack emissions. Fugitive
emissions from general indoor air should 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, should not be overlooked
or reported as fugitive emissions.
H 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."
Section 6. Transfers of the Toxic Chemical in Wastes to
Off-site Locations
n 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.
H 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
H 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 should be
checked on Form R.
H Incorrect reporting of waste treatment methods in
Section 7A. The type of waste stream, waste treatment
efficiency, and waste treatment method for each waste
stream are required to be reported on Form R using
specific codes. The waste treatment codes are listed in
Toxics Release Inventory Reporting Forms and Instructions C-5
-------
Appendix C
n
n
Appendix B: "Reporting Codes for EPA Form R." A
table is also provided in Appendix B that displays a
crosswalk between the old codes and new ones for
reporting year 2005.
Section 7B. On-Site Energy Recovery Processes
n 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 1C. On-Site Recycling Processes
n Reporting on-site recycling methods in Section 1C.
When a quantity is reported in Section 8.4 as recycled
on-site, the type of recovery method must be reported in
Section 1C, and vice versa.
Section 8. Source Reduction and Recycling Activities
For RY 2004, the TRI-ME software will be offering a new
tool: the Section 8 Calculator. The Section 8 Calculator will El
assist users in calculating their Section 8 source reduction and
recycling activity quantities. Also for RY 2004, the TRI-ME
software will populate Section 8 Column A of the Form R for
facilities that load previous year's data.
The entries in this section must be completed, even if your
facility does not engage in source reduction or recycling
activities.
n 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.
n 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.
n 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.
D 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.
n 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
C-6 Toxics Release Inventory Reporting Forms and Instructions
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 Section 8.1 through 8.7 must not
be reported in Section 8.8 and vice versa.
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 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 either Section 8. la or
8.1b.
§8.1a = § 5.4.1 + § 5.5.1A + § 5.5.IB - § 8.8 (on-site
release or disposal due to catastrophic events)1
§ 8.1b = § 5.1 + § 5.2 + § 5.3 + § 5.4.2 + § 5.5.2 + §
5.5.3A + § 5.5.3B + §5.5.4 - § 8.8 (on-site release or
disposal due to catastrophic events)1
Quantities of EPCRA section 313 chemicals transferred
off-site for the purposes of disposal reported in Section
6.2 using the following codes must appear in Section
8.1c:
n M64 Other Landfills
n M65 RCRA Subtitle C Landfills
n M81 Underground Injection to Class I Wells
§ 8. Ic = § 6.1 (portion of transfer that is untreated and
ultimately disposed of in UIC Class I Wells, RCRA
Subtitle C landfills, and other landfills) + § 6.2
(quantities associated with M codes M64, M65 and
M81) - § 8.8 (off-site disposal due to catastrophic
events)1
Metals and metal category compounds transferred off-
site to POTWs in Section 6.1 must appear in Section
8.1c or 8. Id. To report correctly in Sections 8. la
through d, a facility must include quantities that are
disposed or otherwise released to the environment
either on-site or off-site, excluding disposal or other
releases due to catastrophic events or non-production
-------
Appendix C
related activities.
not be included in Section 8.8.
Quantities of EPCRA section 313 chemicals transferred
off-site for the purposes of disposal reported in Section
6.2 using the following codes must appear in Section
8. Id:
n M10 Storage Only
H M41 Solidification/Stabilization — Metals and
Metal Category Compounds Only
n M62 Wastewater Treatment (excluding POTW)
— Metals and Metal Category Compounds Only
n M66 Subtitle C Surface Impoundment
n M67 Other Surface Impoundments
n M73 Land Treatment
n M79 Other Land Disposal
n M82 Underground Injection to Class II-V Wells
n M90 Other Off-Site Management
H M94 Transfer to Waste Broker—Disposal
a M99 Unknown.
§ 8. Id = § 6.1 (portion of transfer that is untreated and
ultimately disposed of in UIC Class II-V wells, and
disposal other than to landfills) + § 6.2 (quantities
associated with M codes M10, M41, M62, M66, M67,
M73, M79, M82, M90, M94, M99) - § 8.8 (off-site
disposal 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 portions of metal
category compounds, and halons. Metals and metal
portions of metal compounds will never be treated or
combusted for energy recovery. 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 must
Reporting quantities in Section 8.3 "Quantity used for
energy recovery off-site." As in Section 8.2, a quantity
must not be reported in this section if the off-site
combustion of the EPCRA section 313 chemical took
place in a system that did not recover energy (e.g.,
incinerator). A quantity of an EPCRA section 313
chemical must not be reported as sent off-site for the
purposes of energy recovery if the EPCRA section 313
chemical does not have a significant heating value.
Examples of EPCRA section 313 chemicals that do not
have significant heating values include metals, metal
portions of metal category compounds, and halons. Metals
and metal portions of metal category compounds will
never be 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:
D M56 Energy Recovery
D M92 Transfer to Waste Broker — Energy Recovery
§ 8.3 = § 6.2 (energy recovery) - § 8.8 (off-site energy
recovery due to catastrophic events)2
Reporting quantities in Section 8.4 "Quantity recycled
on-site." A quantity must be reported in Section 8.4 for
the current reporting year when a method of on-site
recycling is reported in Section 7C, and vice versa. An
error facilities make when completing Form R is to report
the methods of recycling used on-site in Section 7C but
not report the total quantity recovered using those
methods.
In addition, only the amount of the chemical that was
actually recovered is to be reported in Section 8.4. Any
quantities of the EPCRA section 313 chemical associated
with non-production related activities such as catastrophic
releases and remedial actions, as well as other one-time
events not associated with routine production practices
that were recycled on-site must not be included in Section
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:
H M20 Solvents/Organic Recovery
H M24 Metals Recovery
H M26 Other Reuse or Recovery
n M28 Acid Regeneration
1 §8.8 includes quantities of toxic chemicals disposed or
otherwise released on site or managed as a waste off site due to remedial
actions, catastrophic events, or one-time events not associated with the
production processes.
2§8.8 includes quantities of toxic chemical disposed or
otherwise released on-site or managed as waste off-site due to remedial
actions, catastrophic events, or one-time events not associated with the
production processes.
Toxics Release Inventory Reporting Forms and Instructions C-7
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Appendix C
H M93 Transfer to Waste Broker — Recycling.
§8.5 = §6.2 (recycling) - §8.8 (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 7 A, 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. 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 treated for
destruction on-site must not be included in Section 8.8.
Metals generally will not be treated for destruction.
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:
H 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. If you
know, however, that a chemical is not treated for
destruction at the POTW you should report that
quantity in Section 8.1 instead of 8.7.
To report correctly EPCRA section 313 chemicals in
Section 8.7, use the following equation.
§8.7 =§6.1 (excluding most metal/metal category
compounds) + §6.2 (treatment) - §8.8 (off-site
treatment due to catastrophic events)3
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 disposed or released directly to the
environment or transferred off-site for the purposes of
recycling, energy recovery, treatment or disposal.
Quantities reported in Section 8.8 must not be reported
in Section 8.1 through 8.7.
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.
H
M40 Solidification/Stabilization
M50 Incineration/Thermal Treatment
M54 Incineration/Insignificant Fuel Value
M6 1 Wastewater Treatment (excluding POTW)
M69 Other Waste Treatment
3§8.8 includes quantities of toxic chemical disposed or
otherwise 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
D. FDP Messages Used to Report Notices
of Significant Errors
Note: EPA is continually trying to improve the error checking
system for TRI submissions. As a result, a small number
of the error messages in this appendix may be changed by
the time the Reporting Year 2004 submissions are
checked. Most of these messages will remain the same.
You can look for changes to these error messages on the
TRI home page at
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 were 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 chemical name that
are invalid. Respond by providing a valid CAS number
and 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.,
Dioxin and Dioxin-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.
Sections 5 and/or 6 and/or 8 of your Form R. Quantities
reported in these sections must be 0 or greater. Please
respond by providing correct release or other waste
management data.
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)
General Errors for both the Form R and/or Form A
18. InPartI, Section 1 of the Form R or Form A Certification
Statement You did not enter a reporting year. (Note:
EPA has set the year to 2084 as a default.) You must
enter a valid reporting year for your Form R or Form A
Certification Statement. This entry cannot be left blank
and NA may not be used. (NOSE)
10. You have reported a negative number(s) in Part II
19. In Part I, Section 1 of the Form R or Form A Certification
Statement you provided an invalid or future reporting
year. You must enter a valid reporting year for your
Form R or Form A Certification Statement. Valid years
are 1987 through 2002. This entry cannot be left blank
and NA may not be used. (NOSE)
Toxics Release Inventory Reporting Forms and Instructions C-9
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Appendix C
20. 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)
21. 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
22. No selection was made in Part I, Section 2.1 and 2.2
(Trade Secret Information) and a generic chemical name
was not provided in Part II, Section 1.3. Therefore, the
"No" box was selected in Part I, Section 2.1. If this was
incorrect, and you intended to make a trade secret claim
of the identity of the toxic chemical, you must resubmit
following the requirements of 40 CFR Part 350 to claim
trade secret. (NDC)
23. You indicated trade secret in Part I, Section 2.1 (Trade
Secret Information) but made no selection for Part I,
Section 2.2 (sanitized/unsanitized) and did not provide a
generic chemical name in Part II, Section 1.3. EPA
changed your selection in Part I, Section 2.1 to indicate
that a trade secret claim is not being made. If this was
incorrect, and you intended to make a trade secret claim
for the identity of the toxic chemical, you must resubmit
following the requirements of 40 CFR Part 350 to claim
trade secret. (NDC)
24. You made a selection of "No" in Part 1, Section 2.1
(Trade Secret Information) and selected "unsanitized" in
Part 1, Section 2.2. In Part II, Section 1.3 a generic
name was indicated. Part II, Section 1.3 should be
completed only if trade secret is being claimed (Part 1,
Section 2.1). EPA will move the chemical name
information in Part II, Section 1.3 to Part II, Section 1.2.
If this is incorrect and you wish to claim trade secret,
you must resubmit following the requirements of 40 CFR
Part 350. (NDC)
25. In Part I, Section 4.1, you entered NA or did not enter a
county name, city name, state code, and/or zip code.
These fields may not be left blank and NA is not an
acceptable entry. You must provide a county name, city
name, state code, and/or zip code where the facility is
located. (NDC)
26. EPA has corrected the county name, city name, state
code, and/ or zip code that you identified in Part I, Section
4.1. The county name, city name, state code, and/ or zip
code that you identified was either mis-spelled, or
incorrect, or did not match the previous year submissions.
If you feel our correction was made in error, please
resubmit forms with correct information. (NDC)
27. In Part I, Section 4.1, you have used an invalid TRIFID
or you have serf-assigned your own TRIFID or TRIFID
that has been superceded. You may not generate your
own TRIFID. The TRI Data Processing Center assigns
this number to a facility. EPA has corrected this error
and assigned you the correct TRIFID. Please note the
corrected TRIFID and keep it for use in future
submissions. (NDC)
28. No Public Contact name and/or telephone number was
listed. Please provide the name and telephone number
of your Public Contact. (NOTE)
29. No Technical Contact name and/or telephone number
was listed. Please provide the name and telephone
number of your Technical Contact. (NOTE)
30. 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)
31. A valid SIC code was not provided. Please provide at
least one valid primary four-digit SIC code. (NOTE)
32. 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)
33. 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)
34. 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)
35. You did not enter Longitude or Latitude values for the
facility. Please enter a Longitude and Latitude value.
(NOTE)
36. 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)
37. 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)
C-10 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
38. EPA Identification Numbers (RCRA ID. 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)
39. 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)
40. Underground Injection Well Code (UIC) ID. Numbers
(Part I, Section 4.10) are typically 12 digits. Please
check the number(s) you have supplied. If they are
incorrect, please make appropriate changes. If you
believe that they are correct, no further action is
necessary. (NOTE)
41. 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)
42. In Part I, Section 3, you did not provide a printed or
typed name and official title of owner/operator or senior
management official. It cannot be N/A or left blank.
Please provide a name for owner/operator or senior
management official. (NOTE)
43. In Part I, Section 5.1 you did not enter the name of the
parent company. This block cannot be left blank. You
must enter the name for the parent company if it is a U.S.
company. If it is a foreign company then you may check
the [NA] box. (NOTE)
44. The parent company Dun and Bradstreet Number in Part
I, Section 5.2 ( Typically a 9 digit number) cannot be
left blank. However, if your parent company does not
have a Dun and Bradstreet Number check the [NA] box
next to Part I, Section 5.2. (NOTE)
Errors in Part II, Section 1. Toxic Chemical Identity
45. 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)
46. The CAS number you reported was changed to match the
chemical name reported, because the CAS number you
provided was not a valid TRI Chemical. If this was
incorrect, specify a valid CAS number and matching
chemical name. (NDC)
47. The chemical name you reported was changed to match
the CAS number reported, because the chemical name
you provided was not a valid TRI Chemical. If this was
incorrect, specify a valid CAS Number and matching
Chemical Name. (NDC)
48. 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)
49. 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)
50. EPA has changed the TRI chemical category code you
reported in Part II, Section 1.1 fromN151 to N150 (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 matching chemical name.(NDC)
51. 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
52. 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)
53. 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 Section 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)
54. 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
Toxics Release Inventory Reporting Forms and Instructions C-11
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Appendix C
chemical category code (N150). Otherwise please
indicate on the FDP that Section 1.4 should be left blank.
(NOTE)
55. 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)
56. 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)
57. Part II, Section 1.4 of your Form R contains data for
Dioxin and Dioxin-like Compounds. However, you have
indicated both NA and a numeric value (which includes
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
58. 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. Please indicate at least
one of the activity (ies) and use(s) of the EPCRA section
313 chemical occur at your facility. (NOTE)
Errors in Part II, Section 4. Maximum Amount of the
Toxic Chemical Onsite At Any Time During the Calendar
Year
59. 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
60. 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)
61. 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)
62. 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)
63. 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
64. 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
amount or range code, Basis of Estimate, POTW Name
and Location. (NOTE)
65. 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)
66. 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)
67. You provided an incomplete POTW name and address.
Please provide the name and complete address for the
POTW. (NOTE)
68. 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)
69. You did not complete Part II, Section 6.2, "Transfers to
Other Off- site Locations." If you did not transfer the
C-12 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
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)
70. 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)
71. 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)
72. You provided both county and country data. If this is an
extra-national transfer, indicate the off-site name,
address, and Country Code; if a domestic Offsite,
provide the Off-site Name and correct address. (NOTE)
73. 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)
74. 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)
75. 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)
76. You reported an invalid Type of Waste Management
code. For Barium Compounds use only disposal and
certain recycling activities codes, M61—Wastewater
Treatment (Excluding POTW) or M69—Other Waste
Treatment. Consult the Reporting Instructions for metal
and metal compounds and correct with a valid Waste
Management (i.e., "M") code. (NOTE)
77. For non-metals codes M41 and M62 are unacceptable.
Provide the appropriate Disposal or Other Waste
Management code for this non-metal substance.
(NOTE)
78. In Part II, Section 6.2 column C you reported M codes
(M56 and/or M92) for energy recovery, howeveryou left
Section 8.3 columnB blank. Please provide the quantity
used for energy recovery offsite in pounds/year in
Section 8.3 column B. (NOTE)
79. In Part II, Section 6.2 column C you reported M Codes
(M20, M24, M26, M28, M93) for recycling, however
you left Section 8.5 column B blank. Please provide the
quantity recycled offsite in pounds/year in Section 8.5
column B. (NOTE)
80. In Part II, Section 6.2 column C you reported M Codes
(M40, M50, M54, M61, M69, M95) for treatment,
however you left Section 8.7 column B blank. Please
provide the quantity treated offsite in pounds/year in
Section 8.7 column B. (NOTE)
Errors in Part II, Section 7. On-Site Waste Treatment
Methods and Efficiency
81. 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)
82. 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)
83. 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)
84. 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
85. 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
no possibility a release or transfer occurred. You may
Toxics Release Inventory Reporting Forms and Instructions C-13
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Appendix C
enter zero if the release or transfer was equal to or less
than half a pound. (NOTE)
86. 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)
87. 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)
88. There are no data in Part 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)
89. There are missing data in Part II, Section 8.10. Please
provide Source Reduction Activities and Methods
code(s). (NOTE)
90. 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)
91. You have reported a listed metal or metal compound
category in section 8.2, 8.3, 8.6 or 8.7. However, these
chemicals cannot be treated for destruction. Metal or
metal compound category can only be reported as
disposed or recycled. Please report appropriately in
Section 8.1, 8.4, or 8.5. (NOTE)
92. 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)
Errors relating to the reconciliation of data in Part II,
Section 8 and Part II, Sections 5,6, and 7
93. You did not complete Sections8.1-8.7columnBor8.8.
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)
94. 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)
95. 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)
96. 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
the quantity used for energy recovery for Part II, Section
8.2, column B. (NOTE)
97. 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)
98. 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)
99. You reported a value in Part II, Section 8.3 column B,
however you did not provide a corresponding quantity
with an appropriate M Code (M56 and/orM92) for
energy recovery in Section 6.2 column C. Please provide
the appropriate quantity and M Codes for energy
recovery in Section 6.2 column C. (NOTE)
100. You reported a value in Part II, Section 8.5 column B,
however you did not provide a corresponding quantity
with an appropriate M Code (M20, M24, M26, M28,
M93) for recycling in Section 6.2 column C. Please
provide the appropriate quantity and M Codes for
recycling in Section 6.2 column C. (NOTE)
101. You reported a value in Part II, Section 8.7 column B,
however you did not report a quantity in Section 6.1 or a
quantity with an appropriate M Code (M40, M50, M54,
M61, M69, M95) for treatment in Section 6.2 column C.
Please provide a quantity in Section 6.1 or the
appropriate quantity and M Codes for treatment in
Section 6.2 column C. (NOTE)
102. You have reported a listed metal or metal compound
category in Part II, Section 6.1, however you have not
provided a quantity released in section 8.1 column B.
Note that in Section 8, metal or metal compound
category can only be reported as disposed or recycled
and not reported as treated for energy recovery or
treated for destruction. Please provide quantity
released in pounds/year in Section 8.1 column B.
-14 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
(NOTE)
103. You have reported a listed metal or metal compound
category in Part II, Section 6.1, however you have not
provided quantity released in 8. Id ColumnB. Note that
in Section 8, metal or metal compound category can only
be reported as disposed or recycled and not reported as
treated for energy recovery or treated for destruction.
Please provide quantity released in pounds/year Section
8. IB. (NOTE)
Toxics Release Inventory Reporting Forms and Instructions C-15
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This Page Intentionally Left Blank
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Appendix D. Supplier Notification
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:
Q A facility in a covered SIC code (see Table I).
Q A person 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
Forexample, if amixture 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
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
includes intra-company transfers and, therefore, the supplier
notification requirements at 40 CFR Section 372.45 apply.
Note that beginning with the first shipments in 1998, facilities
in SIC codes 20-39 will be required to also notify facilities in
the newly added industry groups.
Supplier Notification Must Include the
Following Information:
(1) A statement that the mixture or other trade name product
contains an EPCRA section 313 chemical or chemicals
subject to the reporting requirements of EPCRA section
313 (40 CFR 372);
(2) The name of each EPCRA section 313 chemical and the
associated Chemical Abstracts Service (CAS) registry
number of each chemical if applicable. (CAS numbers
are not used for chemical categories, since they can
represent several individual EPCRA section 313
chemicals.); and
(3) The percentage, by weight, of each EPCRA section 313
chemical (or all EPCRA section 313
chemicals within a listed category) contained
in the mixture or other trade name product.
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.
Toxics Release Inventory Reporting Forms and Instructions D-l
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Appendix D
How the Notification Must Be Made
The required notification must be provided at least annually in
writing. Acceptable forms of notice include letters, product
labeling, and product literature distributed to customers. If
you are required to prepare and distribute a Material Safety
Data Sheet (MSDS) for the mixture under the Occupational
Safety and Health Act (OSHA) Hazard Communication
Standard, your section 313 notification must be attached to the
MSDS or the MSDS must be modified to include the required
information. (A sample letter and recommended text for
inclusion in an MSDS appear at the end of this appendix.)
You must make it clear to your customers that any copies or
redistribution of the MSDS or other form of notification must
include the section 313 notice. In other words, your customers
should understand their requirement to include the section 313
notification if they give your MSDS to their customers.
When Notification Must Be Provided
You must notify each customer receiving a mixture or other
trade name product containing an EPCRA section 313
chemical with the first shipment of each calendar year. You
may send the notice with subsequent shipments as well, but it
is required that you send it with the first shipment each year.
Once customers have been provided with an MSDS containing
the section 313 information, you may refer to the MSDS by a
written letter in subsequent years (as long as the MSDS is
current).
If EPA adds EPCRA section 313 chemicals to the section 313
list, and your products contain the newly added EPCRA
section 313 chemicals, notify your customers with the first
shipment made during the next calendar year following EP A's
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
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
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 3 0 days of a
change in the product or the discovery of misidentified
EPCRA section 313 chemical(s) in the mixture or
incorrect percentages by weight; and
(2) Identify in the notification the prior shipments of the
mixture or product in that calendar year to which the
new notification applies (e.g., if the revised notification
is made on August 12, indicate which shipments were
affected during the period January 1-August 12).
When Notifications Are Not Required
Supplier notification is not required for a "pure" EPCRA
section 313 chemical unless a trade name is used. The identity
of the EPCRA section 313 chemical will be known based on
label information.
You are not required to make a "negative declaration." That is,
you are not required to indicate that a product contains no
EPCRA section 313 chemicals.
If your mixture or other trade name product contains one of the
EPCRA section 313 chemicals, you are not required to notify
your customers if:
(1) Your mixture or other trade name product contains the
EPCRA section 313 chemical in percentages by weight
of less than the following levels (These are known as de
minimis levels)
Q 0.1 percent if the EPCRA section 313 chemical is
defined as an "OSHA carcinogen;"
Q 1 percent for other EPCRA section 313 chemicals.
is not required when the following PBT chemicals are
contained in mixtures below their respective de minimis
levels:
D-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix D
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
Pentachlorobenzene
Polychlorinated biphenyls
(PCBs)
Polycyclic aromatic
compounds category
Tetrabromobisphenol A
Toxaphene
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
608-93-5
1336-36-3
N590
79-94-7
8001-35-2
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
1.0
0.1
0 i***
1.0
0.1
Trifluralin
1582-09-8
1.0
*The de minimis level is 1.0 for all members except for
2,3,7,8-Tetrachlorodibenzo-p-dioxin which has a 0.1%
de minimis level.
**The de minimis level is 0.1 for inorganic lead
compounds and 1.0 for organic lead compounds
***The de minimis level 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 level.
2) Your mixture or other trade name produt is one of the
following:
Q An article that does not release an EPCRA section
313 chemical under normal conditions of processing
or otherwise use.
Q Foods, drugs, cosmetics, alcoholic beverages,
tobacco, or tobacco products packaged for
distribution to the general public.
Q Any consumer product, as the term is defined in the
Consumer Product Safety Act, packaged for
distribution to the general public. For example, if
you mix or package one-gallon cans of paint
designed for use by the general public, notification is
not required.
3) A waste sent off site for further waste management. The
supplier notification requirements apply only to mixtures and
trade name products. They do not apply to wastes.
4) 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 covered SIC codes
added during the 1997 industry expansion rulemaking,
including facilities whose SIC code is within SIC major group
codes 10 (except 1011, 1081, and 1094), 12 (except 1241);
industry codes 4911 (limited to facilities that combust coal
and/or oil for the purpose of generating power for distribution
in commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating power for distribution
in commerce), or 4939 (limited to facilities that combust coal
and/or oil for the purpose of generating power for distribution
in commerce); or 4953 (limited to facilities regulated under the
Resource Conservation and Recovery Act, subtitle C, 42
U.S.C. Section 6921 et seq.) or 5169, or 5171, or 7389
(limited to facilities primarily engaged in solvents recovery
services on a contract or fee basis).
Toxics Release Inventory Reporting Forms and Instructions D-3
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Appendix D
Trade Secrets
Chemical suppliers may consider the chemical name or the
specific concentration of an EPCRA section 313 chemical in a
mixture or other trade name product to be a trade secret. If
you consider the:
(1) Specific identity of an EPCRA section 313 chemical to be
a trade secret, the notice must contain a generic chemical
name that is descriptive of the structure of that EPCRA section
313 chemical. For example, decabromodiphenyl oxide could be
(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 upperbound. 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
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 sentto recipients of your mixture or other trade
(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
(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
Information retained under 40 CFR 372 must be readily
available for inspection by EPA.
D-4 Toxics Release Inventory Reporting Forms and Instructions
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Appendix D
Sample Notification Letter
January 2, 2005
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:
n Toluene, Chemical Abstract Service (CAS) number 108-88-3, 20 percent, and
H 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. For contact information, please see the TRI Home Page at . 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
should 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
Section 313 Supplier Notification
Furniture Products
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 must 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. 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
AR1
AZ2
CA
CO
DE
FL
GA
HI
IA
ID
IL
IN
KS
LA
MA
MD3
MI4
MN
MO5
MT
ND
NH
NJ
NM6
NV
NY
OH
OK
OR
PA
PR
sc7
SD
TX
UT
VA
VT
WA8
WI
wv
WY
'Arkanasas facilities must report using TRI-ME on
diskette.
2Arizona Emergency Response Commission accepts
electronic submissions, however the Arizona Dept. of
Environmental Quality accepts only paper submissions.
Submissions must be sent to both agencies.
Maryland accepts diskette submissions, but requires that
paper copies be sent as well.
4Michigan accepts Internet submissions; reports submitted
electronically via Internet to EPA's Central Data Exchange
does not require any separate mailing of reports (disk or
paper). Also accepts diskettes.
5Missouri only accepts diskettes created using TRI-ME
software.
6New Mexico requires paper copies in addition to diskette.
'South Carolina only accepts reports submitted
electronically via Internet to EPA's Central Data
Exchange. Facilities submitting by Internet are exempt
from any separate mailing to SC DHEC. If Internet access
is not available, it will be necessary to mail a diskette copy
to SC DHEC.
8Washington strongly encourages electronic submittals by
diskette or via the central data exchange, if available.
If your state is not listed here, please contact your
state office to confirm that paper submissions are
required.
Alabama
Kirk Chandler
AL Emergency Response Commission
AL Department of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
(334) 260-2714; Fax: (334) 272-8131
KFC@adem.state.al.us
Certified Mail/Fed Ex
AL Emergency Response Commission
1890-A Congressman W.L. Dickinson Dr.
Montgomery, AL 36109-2600
Alaska
Camille Stephens
Department of Environmental Conservation
Division of Spill Prevention and Response
410 Willoughby Ave., Suite 300
Juneau, AK 99801-1795
(907) 465-5220; Fax: (907) 465-5244
camille_stephens@dec.state.ak.us
American Samoa
Pati Faiai
American Samoa Environmental Protection Agency
American Samoa Government
Office of the Governor
Pago Pago, AS 96799
International (684) 633-2304
Peter Peshut, Acting Director
American Samoa Environmental Protection Agency
Office of the Governor
(684) 633-2304; Fax: (684) 633-5801
ppeshut@yahoo. com
Arizona
Daniel Roe, Executive Director*
Arizona Emergency Response Commission
5636 East McDowell Road
Phoenix, AZ 85008
(602) 231-6345; Fax: (602) 392-7519
dan.roe@azdema.gov
Toxics Release Inventory Reporting Forms and Instructions E-l
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Appendix E
Bill Quinn*
Arizona Department of Environmental Quality
Pollution Prevention Program, Mail 4415A-1
1110 West Washington Street
Phoenix, AZ 85007-2955
(602) 771-4203; Fax: (602) 771-4246
quinn.bill@azdeq.gov
Arkansas
Kenny Harmon
Hazardous Materials Program Manager
AR Dept. of Emergency Management
P.O. Box 758
Conway, AR 72033-0758
(501) 730-9789; Fax: (501) 703-9754
kenny.harmon@ademstate.ar.us
UPS or FedEx Only
AR Dept. of Emergency Management
1835 S. Doneghey
Conway, AR 72032
John Ward (Questions Only)
AR Dept. of Pollution Control & Ecology
8001 National Drive
Little Rock, AR 72209-8913
(501) 730-9832 Fax: (501) 682-0798
jward@adeq.state.ar.us
California
Dept. of Toxic Substance Control
Attn: Office of Environmental Information
Management
100II Street, 8th Floor
Sacramento, CA 95812
(916) 324-3421 Fax: (916) 324-1788
Colorado
Kirk Mills
Sustainability Program
CO Dept. 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
Commonwealth of Northern Mariana Islands
John I. Castro, Jr. Director
Office of the Govenor
Third Floor, Morgan Bldg., San Jose
P.O. Box 501304
Saipan, MP 96950-1340
International: (670) 664-8500/1;
Fax: (670) 664-8540
deq.director@saipan.com
Connecticut
Mark Decaprio, Acting SERC Administrator
Department of Environmental Protection
State Emergency Response Commission
79 Elm Street, 4th Floor
Hartford, CT 06106-5127
(860) 424-3373; Fax: (860)424-4059
mark.decaprio@po.state.ct.us
Delaware
John E. Parker
Toxic Release Inventory Program
Division of Air and Waste Management, DNREC
156 South State Street
Dover, DE 19901
(302) 739-9431; Fax: (302) 739-3106
john.parker@state.de.us
District of Columbia
Michele Penick
Environmental Planning Specialist
Emergency Response Commission for Title III
2000 14th Street, N.W. 8th Floor
Washington, DC 20009
(202)673-2101,ext. 1159;
Fax: (202) 673-2290
michele .penick@dc.gov
Florida
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
Kent Howell
Georgia Environmental Protection Agency
7 Martin Luther King, Jr. Drive
Room 643
Atlanta, GA 30334
E-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix E
(404) 656-6905; Fax: (404) 562-9095
kent_howell@dnr.state.ga.us
Guam
Francis Damian
Guam Environmental Protection Agency
Air and Land Division
P.O. Box 20439
Barrigada, Guam 96921
International (671) 475-1607;
Fax: (671) 477-9402
fpdamian@guamepa.govguam.net
Hawaii
Curtis Martin
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
Cmartin@eha.health.state.hi.us
Idaho
Mary Halverson
Bureau of Homeland Security
4040 Guard Street, Bldg. 600
Gowen Field
Boise, ID 83705-5004
(208) 422-5723; Fax: (208) 422-4485
mhalverson@bhs. state.id.us
Illinois
Dierdre McQuillen
Office of Environmental Policy & Science #26
Illinois Environmental Protection Agency
1021 North Grand Avenue, East
P.O. Box 19276
Springfield, IL 62794-9276
(217) 558-0073; Fax: (217) 782-8346
dierdre.mcquillen@epa.state.il.us
Certified or Express Mail ONLY
Dierdre McQuillen
OEP & Science #26
Illinois Environmental Protection Agency
1021 North Grand Avenue, East
Springfield, IL 62702
Indiana
Brian Stevens, TRI Database Manager
Indiana Dept. of Environmental Management
OPPTA
402 West Washington Street, Room W041
PO Box 7095
Indianapolis, IN 46207-7095
(317) 233-5433 ** 1 (800) 988-7901
Fax:(317)233-5627
bstevens@dem.state.in.us
Iowa
Adam Broughton
Emergency Response Unit
Iowa Department of Natural Resources
401 SW 7th Street, Suite I
Des Moines, IA 50309
(515) 281-8694 Fax: (515) 725-0218
adam.broghton@dnr. state, ia.us
Kansas
Scott Bangert, Environmental Health Scientist
Kansas Department of Health and Environment
Bureau of Air & Radiation
Asbestos & Hazardous Chemical Information Unit
1000 SW Jackson, Suite 310
Topeka, KS 66612-1366
(785) 296-1689; Fax: (785) 296-1545
sbangert@kdhe.state.ks.us
Kentucky
Larry C. Taylor
Kentucky Department for Environmental Protection
14 Reilly Road
Frankfort, KY 40601-1132
(502) 564-2150 ext. 112; Fax: (502) 564-4245
larryc.taylor@ky.gov
Louisiana
Shelita Williams
LA Department of Environmental Quality
Office of Environmental Assessment
P.O. Box 4314
Baton Rouge, LA 70821-4314
(225) 219-3503; (225) 219-3240 fax
shelita.williams@la.gov
Certified Mail/FEDEX
Shelita Willams
LA Department of Environmental Quality
Toxics Release Inventory Reporting Forms and Instructions E-3
-------
Appendix E
Office of Environmental Assessment
602 N. Fifth Street
Baton Rouge, LA 70802
Maine
Robert S. Gardner
Technological Hazards Specialist
Maine Emergency Management Agency
72 State House Station
Augusta, ME 04333-0072
(207) 624-4400; Fax: (207) 287-3178
In State Only -1-800-452-8735
robert.s.gardner@maine.gov
Maryland
Patricia S. Williams, EPCRA Coordinator
Maryland Department of the Environment
Community Right-to-Know Section
1800 Washington Boulevard, Suite 540
Baltimore, MD 21230-1718
(410) 631-3800; Fax: (410) 537-3873
pwilliams@mde.state.md.us
Massachusetts
John Fischer, Branch Chief
MA Department of Environmental Protection
Bureau of Waste Prevention - TURA Program
1 Winter Street
Boston, MA 02108
(617) 292-5932; Fax: (617) 292-5858
john.fischer@state.ma.us
Technical Assistance can be obtained via the MA
Toxics Use Reduction Institute
On the web at: http://www.mass.gov/ota or by calling
(617)626-1060
Michigan
Robert Jackson
State Emergency Planning and Community
Right-to-Know
Michigan Department of Environmental
Quality
Environmental Science and Services Division
P.O. Box 30457
Lansing, MI 48909
(517) 373-8481; Fax: (517) 241-7966
jacksorc@michigan.gov
Overnight Mail
Robert Jackson
MDEQ ESSD
Constitution Hall, 1 North
525 West Allegan
Lansing, MI 48933
Minnesota
Steve Tomlyanovich
Department of Public Safety
Minnesota EPCRA Program
444 Cedar Street, Suite 223
St. Paul, MN 55101
(651) 282-5396; Fax: (651) 296-0459
steve.tomlyanovich@state.mn.us
Mississippi
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
j ohn_d_burns@deq. state .ms.us
Missouri
Gene Nickel, EEII
Missouri Department of Natural Resources
Environmental Assistance Office
P.O. Box 176
Jefferson City, MO 65102
(573) 526-6627; Fax: (573) 526-5808
1-800-361-4827
gene. nickel@dnr. mo. gov
Certified Mail ONLY
Gene Nickel
Missouri Department of Natural Resources
Environmental Assistance Office
1659 East Elm Street
Jefferson City, MO 65101
Montana
TomEllerhoff
MT Emergency Response Commission DEQ
MetcalfBldg.
1520 East 6th Avenue
Helena, MT 59620-0901
(406) 444-5263; Fax: (406) 444-4386
tellerhoff@state.mt.us
Navajo Nation
Calvert Curly (Acting Division Director)
Navajo Environmental Protection Agency
E-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix E
P.O. Box 339
Window Rock, AZ 86515
(928) 871-7692; Fax: (928) 871-7996
Eugene Guerito, Director
Dept. of Emergency Management
P.O. Box 2908
Window Rock, AZ 86515
(928) 871-6892
Note: recipient of EPCRA Tier II reports
Nebraska
Mark Lohnes
SARA Title III
Nebraska Environmental Quality
P.O. Box 98922
Lincoln, NE 68509-8922
(402) 471-4251; Fax: (402) 471-2909
mark.lohnes@ndeq.state.ne.us
Certified Mail Only
Donnie Zach
SARA Title III and NEPCRA Coordinator
Nebraska Dept of Environmental Quality
Lincoln, NE 68509
Nevada
Alene Coulson
c/o State Emergency Response Commission
555 Wright Way
Carson City, NV 89711-0925
(775) 687-9464; Fax: (775) 687-6396
acoulson@ndep.nv.gov
Questions about the Report Fee should be directed to
the Nevada State Emergency Response Commission
at (775) 687-6973
New Hampshire
Les Carrier
NH Department of Safety
Division of Fire & Emergency Management
Bureau of Emergency Management
10 Hazen Drive
Concord, NH 03305-0002
(603) 271-3294 Fax: (603) 225-7341
Lcartier@safety. state .nh.us
Certified Mail Only:
NH Department of Safety
Richard M. Flynn Fire Academy
Route 106
Concord, NH 03301-8523
New Jersey
Andrew Opperman
Department of Environmental Protection
EPCRA Section 313
Office of Pollution Prevention & Right-To-Know
P.O. Box 433
Trenton, NJ 08625-0433
(609) 777-0518; Fax: (609) 292-1816
andy.opperman@dep.state.nj.us
www.state.nj.us/dep/opppc
New Mexico
Don Shainin, HazMat Coordinator
New Mexico Department of Public Safety
Office of Emergency Services & Security
P.O. Box 1628
Santa Fe,NM 87504-1628
(505) 476-9681; Fax: (505) 476-9695
dshainin@dps.state.nm.us
Certified Mail/Fed Ex
Don Shainin, Hazardous Material Coordinator
Office of Emergency Services & Security
13BataanBlvd.
Santa Fe, NM 87508
New York
Susanne Wither
NY State Department of Environmental
Conservation
Division of Environmental Remediation
625 Broadway, 11th Floor
Albany, NY 12233-8010
(518) 402-9553; Fax: (518) 402-9020
smwither@gw.dec.state.ny.us
North Carolina
Felicia Pyle
NC Division of Emergency Management
4714 Mail Service Center
Raleigh, NC 27699-4714
(919)715-4406
(919) 733-1361 Hotline
1-800-451-1403 (NC Only)
Fax: (919) 733-2860
fpyle@ncem.org
Toxics Release Inventory Reporting Forms and Instructions E-5
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Appendix E
North Dakota
Ray DeBoer
North Dakota Department of Emergency Services
Attn: TRI Coordinator
P.O. Box 5511
Bismarck, ND 58506-5511
(701-) 328-8100; Fax: (701) 328-8181
rdeboer@state.nd.us
Certified Mail
North Dakota Department of Emergency Services
Attn: TRI Coordinator
Fraine Barracks Lane, Building 35
Fraine Barracks
Bismarck, ND 58504
Ohio
Cindy DeWulf
Ohio Environmental Protection Agency
Lazarus Government Center
P.O. Box 1049
Columbus, OH 43216-1049
(614) 644-3606; Fax: (614) 644-3681
cindy.dewulf@epa.state.oh.us
Certified Mail ONLY
Cindy DeWulf
Ohio Environmental Protection Agency
Lazarus Government Center
122 South Front Street
Columbus, OH 43215
Oklahoma
Montressa Elder, Environmental Programs Manager
Department of Environmental Quality
Risk Communication
P.O. Box 1677
Oklahoma City, OK 73101-1677
(405) 702-1017 or (800) 869-1400
Fax: (405) 702-1001
monty.elder@deq.state.ok.us
Certified Mail
OK Dept. of Environmental Quality
707 N. Robinson
Oklahoma City, OK 73102
Oregon
Mariana Ruiz-Temple
Oregon Community Right-to-Know Unit
HazMat Information Manager
4760 Portland Road, Northeast
Salem, OR 97305-1760
(503) 378-1540, ext. 238
Fax: (503) 373-1825
mariana.ruiz-temple@state.or.us
Pennsylvania
Thomas J. Ward, Jr.
Department of Labor and Industry
Bureau of PENNSAFE
Labor and Industry Building - Room 155-E
P.O. Box 68571
Harrisburg, PA 17106-8571
(717) 783-2071; Fax: (717) 783-5099
pennsafe@dli.state.pa.us
Certified Mail ONLY
Thomas J.Ward, Jr.
Bureau of PENNSAFE
Department of Labor and Industry
7th & Forster Streets, Room 1623
Harrisburg, PA 17120
1-888-723-3422
Puerto Rico
Genaro Torres
Emergencies and Title HI-SARA Section 313
Environmental Quality Board
Fernandez Junco Station
P.O. Box 11488
Santurce, PR 00910
(787) 766-2823; Fax: (787) 766-0150
jcaemer@prtc.net
Certified Mail ONLY
Genaro Torres
Director of Superfund and Emergencies
Environmental Quality Board
Emergency Response and Remedial Office
National Plaza #431
Ponce de Leon Avenue
HatoRey, PR00917
Rhode Island
Karen Slattery
Rhode Island Department of Environmental
Management
Office of Air Resources
235 Promenade Street, Suite 230
Providence, RI 02908
Attn: Toxics Release Inventory
E-6 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix E
(401) 222-2808, ext. 7030
Fax: (401) 222-2017
karen. slattery @dem. ri. gov
South Carolina
Michael Juras
Community Right-to-Know
Department of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
(803) 898-4385; Fax: (803) 898-4487
jurasms@dhec.sc.gov
South Dakota
PMB 2020
Lee Ann Smith, TRI Coordinator
SD Department of Environment and Natural
Resources
523 East Capitol
Pierre, SD 57501-3181
(605) 773-3296; Fax: (605) 773-6035
leeann. smith@state. sd.us
Tennessee
Betty Eaves, Administrator
Tennessee Emergency Response Council
Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville, TN 37204
(615) 741-2986; Fax: (615) 741-4173
beaves@tnema.org
Texas
U.S. Postal Service Delivery including Certified Mail
Blake Kidd
Toxics Release Inventory Program, MC 164
Texas Commission Environmental Quality
P.O. Box 13087
Austin, Texas 78711-3087
(512) 239-1441; Fax: (512) 239-1555
toxic@tceq.state.tx.us
TRI Help Line: 512-239-4874
Overnight Express Mail ONLY
Blake Kidd
Toxics Release Inventory Program, MC 164
Texas Commission Environmental Quality
12100 Park 35 Circle, Bldg. E., Third Floor
Austin, Texas 78753
Utah
Michael Zucker
UT Dept. of Environmental Quality
168 North 1950 West
Salt Lake City, UT 84116
ATTN: TRI COORDINATOR
(801) 536-4143; Fax: (801) 536-4242
mzucker@utah. gov
Vermont
Paul Van Hollebeke
VT Dept. Of Environmental Conservation
Environmental Assistance Division
103 South Main Street
Waterbury, VT 05671-0411
(802) 241-3629; Fax: (802) 241-3273
paul.vanhollebeke@anr.state.vt.us
Virgin Islands
Aaron Hutchins
Department of Planning and Natural
Resources
Division of Environmental Protection
Cyril E. King Airport
Terminal Bldg., 2nd Fir.
ST. Thomas, VI00802
St. Croix: (340) 773-1082 Fax: (340) 692-9794
St. Thomas: (340) 774-3320 Fax: (340) 774-9549
hutchins.aaron@vidpnr-dep.org
Virginia
Gregory Allen
Virginia Department of Environmental Quality
SARA Title III Program
P.O. Box 10009
Richmond, VA 23240-0009
(804) 698-4303; Fax: (804) 698-4264
gaallen@deq. virgnia. gov
Certified or Express Mail ONLY
Gregory Allen
SARA Title III Program
Virginia Department of Environmental Quality
629 E. Main Street
Richmond, VA 23219
Washington
Idell Hansen
EPCRA TRI Coordinator
Dept. of Ecology
P.O. Box 47659
Toxics Release Inventory Reporting Forms and Instructions E-7
-------
Appendix E
Olympia, WA 98504-7659
(360) 407-6727 or (800) 633-7585
Fax: (360) 407-6715
ihan461@ecy.wa.gov
Delivery including certified mail:
Idell Hansen
Department of Ecology
Hazardous Waste/Toxics Reduction Program
300 Desmond Drive
Lacey, WA 98503
West Virginia
James J. Gianato
West Virginia Emergency Response Commission
West Virginia Office of Emergency Services
1900 Kanawha Boulevard, Building 1,
Room EB-80
Charleston, WV 25305-0360
(304) 558-5380; Fax: (304) 344-4538
Jgianato@wvoes.state.wv.us
Wisconsin
Michael T. Neuman
Toxics Release Inventory Coordinator
Wisconsin Department of Natural Resources
101 South Webster Street
P.O. Box 7921
Madison, WI 53707-7921
(608) 266-5428; Fax: (608) 266-5226
michael.neuman@dnr.state.wi.us
Wyoming
Kim Lee
SARA Title III Program Manager
Wyoming Office of Homeland Security
Emergency Management Agency
122 W 25th Street.
Herschler Building, 1st Floor East
Cheyenne, WY 82002
(307) 777-7540; Fax: (307) 635-6017
klee@state.wy.us
E-8 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix F. 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 1100
Boston, MA 02114-2023
(617) 918-1829; fax: (617) 918-1810
peavey.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@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. william@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@epa.gov
Region 6 (AR, LA, NM, OK, and TX)
Morton Wakeland
Toxics Section, Multimedia Planning and Permitting
Division
USEPA Region 6 (6PD-T)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
(214) 665-8116; fax: (214) 665-6762
wakeland.morton@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.stephen@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.joyel@epa.gov
Region 9 (AS, AZ, CA, GU, HI, MH, MP, and NV)
Nancy Sockabasin
Toxics Office
USEPA Region 9 (CMD-4)
75 Hawthorne Street
San Francisco, CA 94105-3901
(415) 972-3772; fax: (415) 947-3583
sockabasin.nancy@epa.gov
Region 10 (AK, ID, OR, and WA)
Brook Madrone
Office of Air, Waste & Toxics
(AWT-128)
1200 Sixth Avenue
Seattle, WA 98101-3188
(206) 553-4016
Fax: (206) 553-8509
madrone.brook@epa.gov
Toxics Release Inventory Reporting Forms and Instructions F-l
-------
Appendix G. Other Relevant Materials
Public Data Release
2003 Toxics Release Inventory Public Data Release
Report
EPA released the 2003 TRI data on May 11, 2005. TRI
summary information and data access is available via the
web at http://www.epa.gov/tri/tridata/tri03. The 2003 TRI
Data Release Web site provides fast and easy access to the
data overview and relevant TRI information (including
tables, charts, maps, and a summary of key findings). The
TRI data can be accessed using the TRI Explorer
(http://www.epa.gov/triexplorer) as well as several other
public access tools available on the TRI website. EPA also
released two electronic publications summarizing the 2003
data: the 2003 TRI Public Data Release (PDR) Report
(EPA-260-R-05-001) and the 2003 Public Data Release
eReport. These reports provide an overview of the 2003
TRI reporting year data and other information relating to
TRI data. The reports serve as a supplement to EPA's on-
line tool TRI Explorer where users of TRI data can retrieve
electronic 2003 state fact sheets that provide a snapshot of
each state's releases and other waste management activities
and a description of the information included in the state
fact sheet.
Access to TRI Information On-line
The TRI Home Page 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 2003 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 is an on-line tool
that EPA has created to allow for searches of the TRI data.
It allows the user to search using six criteria: facility,
chemical, year or industry type (SIC code), federal facility
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).
TOXNET® , 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 is an online network concerned
with environmental issues, in particular, matters arising
from the passage of right-to-know provisions embodied in
EPCRA 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
202 234-8494
Other TRI Information
EPA's Integrated Risk Information System (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 the
Emergency Planning and Community Right-to-Know
Act and Section 112(r) of the Clean Air Act (List of
Lists), (October 2001)
G-l Toxics Releases Inventory Forms and Instructions
-------
Appendix G
A paper copy is available from the National Technical
Information Service, 5285 Port Royal Road, Springfield, VA
22161, 703 605-6000, Document Number: PB2003-105834,
$38.00 plus $5.00 shipping and handling.
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 the
Emergency Planning and Community Right-To-Know
(EPCRA) Call Center. For contact information, please see
the TRI Home Page at .
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 from EPA by asking
for publication EPA 749-R-97- 00Ib. 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
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 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
202 566-0799, or fax a request to 202 566-0794, or write to:
U.S. EPA
Pollution Prevention Information Clearinghouse
(PPIC)
EPA West
1200 Pennsylvania Ave. NW
Room 3379 (Mail Code 7407-T)
Washington, DC 20460-0001
Email: ppic@epa.gov
Toxics Release Inventory Reporting Forms and Instructions G-2
-------
Appendix H.
REQUEST FOR WITHDRAWAL
Facility Name
Facility Mailing Address
Date:
TRI Data Processing Center
P.O. Box 1513
Lanham, MD 20703-1513
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 D Form A Certification D
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.
H-l Toxics Release Inventory Reporting Forms and Instructions
-------
Index
Activity Exemptions 15
Activity Index 55
Alternate Threshold 61
Ammonia 21
Ancillary Use 34
Article Component 34
Articles Exemption 15
Auxiliary Facilities 10
B
Byproduct 33
c
CDX1
Central Data Exchange 1
Certification of Form R 29
Chemical Categories 22, 31
Chemical Category Codes 31
Chemical Processing Aid 34
Coal Extraction Activities Exemption 19
Coincidental Manufacture 11, 12,
Container Residue 43
Contractor 8
Facility Identification 29
Facility Identification Number 29
Federal Information Processing Standards (FIPS)
Codes IV-1
Form A 62
Form R 29
Formulation Component 33
Fugitive Air Emissions 36
Full-Time Employee Determination 8
Generic Chemical Name 32, 33, 65
GOCO Facility 30
Guidance Documents vii-ix
I
Import 12, 33
Impurity 12, 33
Internet Submission 1
Joint Venture 31
D
De Minimis Exemption 16-19
Definitions
Establishment 29
Facility 29
Manufacture 11
Otherwise Use 11
Process 11
Dioxin and Dioxin-like Compounds 32, 36
Data Precision 14
Distribution 32
Maximum Amount On Site 36
Discharges to Publicly Owned Treatment Works 41
Discharges to Receiving Streams or Water Bodies 36
Diskette Submissions 2
Disposal to Land On-site 37
Double-Counting 55, 57
Dun & Bradstreet Number 30, 64
E
Employee Threshold Determination 8
EPA Identification Number 30
Executive Order 13148 1
Exemptions 15
Laboratory Activities Exemption 19
Land Treatment/Application Farming 37
Landfills 37
Latitude and Longitude 30
Lead and Lead Compounds 14
M
Manufacture 11, 33
Manufacturing Aid 34
Maximum Amount On-site 34
Metal Compounds 22, 23
Metal Mining Overburden Exemption 19
Mixture Component Identity 32
Motor Vehicle Maintenance Exemption 15
Multi-Establishment Facilities 10
N
NA vs. a Numeric Value 41, 50
Nitrate Compounds 22, 23
Non-Point Air Emissions 36
NPDES Permit Number 31, 64
o
On-Site Reuse Operations 21
Organic Compounds 22
Other Disposal 37
Toxics Release Inventory Reporting Forms and Instructions Index—1
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Index
Otherwise Use 11,34
Otherwise Use Exemptions 15
Overburden 19
Parent Company 31
Partial Facility Indication 29
PBT Chemicals 14, 22,
Data Precision 14
List of 20
Thresholds for 20
Point Air Emissions 36
POTW, Transfers to 41
Primary SIC Code Determination!
Process 11, 33
Produce 33
Production Ratio 55
Public Contact 30
R
Range Codes
Sections 38
Section 6 42
RCRA Subtitle C landfills 37
Reactant 33
Recordkeeping 3
Repackaging 34
Reporting by Establishment 10
Reporting Criteria 1
Reporting deadline 6
Reporting Decision Diagram 9
Reporting Year 29
Reuse 13, 15, 21
Revisions 4
Sale/Distribution 33
Section 5 (Part II) 3 5
Section 6 41
Section 7 47
Section 8 52
SIC Codes 1-1
Apparel and Other Finished Products made
from Fabrics and Other Similar
Materials 1-2
Business Services 1-7
Chemicals and Allied Products 1-3
Coal Mining I-1
Electric, Gas, and Sanitary Services 1-7
Electronic and Other Electric Equipment and
Components, Except Computer
Equipment 1-6
Fabricated Metal Products, Except
Machinery and Transportation
Equipment 1-4
Food and Kindred Products 1-1
Furniture and Fixtures 1-2
Industrial and Commercial Machinery and
Computer Equipment 1-5
Leather and Leather Products 1-4
Lumber and Wood Products, Except
Furniture 1-2
Measuring, Analyzing, and Controlling
Instruments; Photographic, Medical
and Optical Goods; Watches and
Clocks 1-6
Metal Mining I-1
Miscellaneous Manufacturing Industries 1-7
Paper and Allied Products 1-3
Petroleum Refining and
Related Industries 1-3
Primary Metal Industries 1-4
Printing, Publishing, and
Allied Industries 1-3
Rubber and Miscellaneous
Plastics Products 1-3
Stone, Clay, Glass and
Concrete Products 1-4
Textile Mill Products 1-1
Tobacco Products 1-1
Transportation Equipment 1-6
Wholesale Trade-Nondurable Goods 1-7
SIC Manual 8
Significant Figures 38
Source Reduction 52
Stack Air Emissions 36
Stormwater 39, 40
Structural Component Exemption 15
Submitting electronically 1, 2
Submitting Forms 1
Surface Impoundments 37
Technical Contact 30
Threshold Determinations 20-24
Ammonia 21
Chemical Categories 22
On-Site Reuse Operations 21
PBT Chemicals 22
Threshold Worksheets 25-28
Trade Secret 3, 29, 61,62
Transfers to Other Off-Site Locations 41
Transfers to POTWs 41
TRI Facility Identification Number (TRIFID) 29
TRI-MEv, 1
Index -2 Toxics Release Inventory Reporting Forms and Instructions
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Index
U
Underground Injection 37
Underground Injection Well Code Identification
Number 31
W
Waste Rock 19
Waste Treatment Codes 49
Energy Recovery Processes 50
Methods and Efficiency 47, 49
Recycling Processes 50
Waste Treatment On Site 47
Withdrawals 4
Toxics Release Inventory Reporting Forms and Instructions Index—3
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Notes
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