^to sr^f
   *.                           EPA 260-K-07-001
    \                           March 2008

    '   Toxic Chemical Release

       Inventory Reporting Forms

       and Instructions
       Revised 2007 Version
       Section 313
       of the Emergency Planning and
       Community Right-to-Know Act
       (Title III of the Superfund Amendments
       and Reauthorization Act of 1986)

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Table of Contents
Important Information for Reporting Year 2007	v
      New Information for Reporting Year 2007
      Other Important Information for Reporting Year 2007
      Web sites and Points of Contacts for Assistance

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.b.  How to Send Your Disks Containing Form R(s) and/or Form A(s)	2
      A.2.c  How to Submit Paper Form R(s) and/or Form A(s)	3
A.3   Trade Secret Claims	3
A.4   Recordkeeping	4
A.5   Howto Revise or Withdraw TRIData	4
A.6   When the Report Must Be Submitted	7
A.7   Howto Obtain the TRI Reporting Forms	7
B.    How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form
      A	8
B.I   Full-Time Employee Determination	8
B.2   Primary NAICS Code Determination	8
      B.2.a.  Auxiliary Facilities	15
      B.2.b.  Multi-Establishment Facilities	15
      B.2.c.  Property Owners	16
B.3   Activity Determination	16
      B.3.a.  Definitions of Manufacture, Process, and Otherwise Use	16
      B.3.b.  Persistent Bioaccumulative Toxic (PBT) Chemicals and Chemical Categories
             Overview	19
      B.3.c.  Activity Exemptions	20
B.4   Threshold Determinations	27
      B.4.a.  How to Determine if Your Facility Has Exceeded Thresholds	27
      B.4.b.  Threshold Determinations for On-Site Reuse Operations	28
      B.4.c.  Threshold Determinations for Ammonia	29
      B.4.d.  Threshold Determinations for Chemical Categories	29
      B.4.e  Threshold Determination for Persistent Bioaccumulative Toxic (PBT) Chemicals
                  30
      B.4.f.  Mixtures and Other Trade Name Products	30
B.5   Release and Other Waste Management Determinations for Metals, Metal Category
      Compounds, and Nitrate Compounds	30
C.    Instructions for Completing TRI Form R	37
Parti. Facility Identification Information	37
      Section 1.   Reporting Year	37
      Section 2.   Trade Secret Information	37
                  Toxics Release Inventory Reporting Forms and Instructions

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                                   Table of Contents
       Section 3.    Certification	37
       Section 4.    Facility Identification	37
       Section 5.    Parent Company Information	39
Part II. Chemical Specific Information	40
       Section 1.    EPCRA Section 313 Chemical Identity	40
       Section 2.    Mixture Component Identity	41
       Section 3.    Activities and Uses of the EPCRA Section 313 Chemical at the Facility ...42
       Section 4.    Maximum Amount of the EPCRA Section 313 Chemical On-site at Any
             Time during the Calendar Year	45
       Section 5.    Quantity of the EPCRA Section 313 Chemical Entering Each
             Environmental Medium On-site	45
       Section 6.    Transfers of the EPCRA Section 313 Chemical in Wastes to Off-Site
             Locations	52
       Section 7.    On-Site Waste Treatment, Energy Recovery, and Recycling Methods	59
       Section 8.    Source Reduction and Recycling Activities	66
D.     Facility Eligibility Determination for Alternate Threshold and for Reporting on EPA
       Form A	75
D.I    Alternate Threshold	75
D.2    What is the Form A Certification Statement?	75
D.3    What Is the Annual Reportable Amount?	75
D.4    Recordkeeping	76
D.5    Multi-establishment Facilities	76
D.6    Trade Secrets	76
D.7    Metals and Metal Category Compounds	76
E.     Instructions for Completing EPA Form A	78
Parti.  Facility Identification Information	78
       Section 1.    Reporting Year	78
       Section 2.    Trade Secret Information	78
       Section 3.    Certification	78
       Section 4.    Facility Identification	78
       Section 5.    Parent Company Information	80
Part II. Chemical Identification	81
       Section 1.    Toxic Chemical Identity	81
       Section 2.    Mixture Component Identity	82
                   Toxics Release Inventory Reporting Forms and Instructions

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                                  Table of Contents
Figures
Figure 1. EPCRA Section 313 Reporting Decision Diagram	14
Figure 2A. EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet	33
Figure 2B. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100
      Pound Thresholds	34
Figure 2C. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10
      Pound Thresholds	35
Figure 2D. EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like
      Compounds Chemical Category	36
Figure 3. Reporting EPCRA Section 313 Chemicals	44
Figure 4. Hypothetical Section 6.2 Completed for Two Off-Site Locations	58
Figure 5. Hypothetical Section 7A	61

Tables
Table I      NAICS Codes	1-1
Table II      EPCRA Section 313 Chemical List
            (including chemical categories)
            for Reporting Year 2007	II-l
Table III     State Abbreviations	III-l
Table IV     Federal Information Processing Standards (FIPS) Codes	IV-1

Appendices
Appendix A  Federal Facility Reporting Information	A-l
Appendix B  Reporting Codes for EPA Form R and Instructions for Reporting Metals	B-1
Appendix C  Facility Data Profiles and Common Errors in Completing Form R Reports
            and Form A Certification Statements	C-l
Appendix D  Supplier Notification Requirements	D-l
Appendix E  TRI State Contacts	E-l
Appendix F  TRI Regional Contacts	F-l
Appendix G  Other Relevant Section 313 Materials	 G-l
Appendix H  Guidance Documents	H-l
Index
                  Toxics Release Inventory Reporting Forms and Instructions
in

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iv              Toxics Release Inventory Reporting Forms and Instructions

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                      Important Information for Reporting Year 2007
New Information for  Reporting  Year 2007

   •  Please note that the 2007 version of the Toxics Release Inventory (TRI) Reporting Forms and Instructions
     document supersedes previous versions of the document.
   •  TRI-MEweb will be available to all reporting facilities in Reporting Year (RY) 2007. TRI-MEweb is a Web-based
     version of the popular TRI-ME reporting Software. Facility Technical Contacts will be emailed an access key by
     March, 2008. Please note that in order to use TRI-MEweb, certifying officials must register for the application at
     https://cdx.epa.gov. This registration requires the printing, completion,  and mailing of an electronic
     signature agreement. Please allow adequate time for the mailing and processing of this form, which is
     estimated to take a minimum of five (5) business days.


       TRI-MEweb can be accessed anywhere you have a connection to the Internet. Unlike the PC-
       based TRI-ME software, TRI-MEweb requires no downloads or software installs. You no longer
       have to contact your "system administrator" to get rights to install the software because it's
       on the Web!

       TRI-MEweb is similar to its predecessor TRI-ME in that it assists you in preparing your forms,
       but  TRI-MEweb offers so much more. TRI-MEweb is not only  an interactive, intelligent, user-
       friendly reporting application; it also provides many new features:

       •   Enhanced Data Quality and Validation assistance
       •   Quick Lists which allow users to skip over sections of the forms that do not  apply
       •   Enhanced Section 8 Calculator
       •   Prior Year revision capability - There is no longer any need to save disks or find files. EPA will provide the
          data for you
       •   Trend Analysis Reports
       •   Electronic withdrawals

       To learn more about this new solution to TRI reporting, please visit www.epa.gov/tri.
   D   TRI Information Collection Requests (ICRs) The TRI Program's most recent ICRs were approved by the Office
       of Management and Budget (OMB) in early 2008. Copies of the Federal Registr Notices and supporting
       statements are available under Docket ID Number EPA-HQ-TRI-2007-0355 at http://www.regulations.gov.
       Changes in the ICRs and TRI reporting forms include the following:

              • Expanded basis of estimate" codes (Form R only). Starting in 2007, EPA will provide a
              more extensive list of codes for "basis of estimate" in the TRI Reporting Forms and
              Instructions,  including  (Ml)  and  (M2)  for continuous and  periodic/random
              monitoring, respectively; and (El) and (E2) for published and site-specific emission
              factors, respectively. Codes (C) and (O) will remain unchanged. By using these codes,
              facilities will indicate the principal method used to determine the quantities reported
              to TRI.

              • Enhanced Public Contact information (Form R and Form A). EPA has added a place on
              the form where a facility can provide the email address for the "Public Contact"
              on the Form R, in addition to the public contact name and telephone number. EPA
              has also added a "Public Contact" field to the Form A Certification Statement.

                   Toxics Release Inventory Reporting Forms and Instructions               v

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                      Important Information for Reporting Year 2007
              • Revision codes (Form R and Form A). EPA has added revision codes that will help the
              public and TRI Program staff understand the reasons(s) why a facility resubmitted
              a form. The TRI Program will be better able to analyze the reasons why forms are
              being revised and address recurring reporting issues that facilities may be facing.
              Facilities may report up to two revision codes (listed and defined in the TRI
              Reporting Forms and Instructions) indicating the main reason(s) that a form is
              being revised.

              • Withdrawal Codes (Form R and Form A). EPA has added a field for entering
              withdrawal codes. In the past, a facility that wished to withdraw a previously
              submitted form had to submit its request, including the rationale, as a hard copy
              memorandum to the TRI Data Processing Center. The new withdrawal field and
              codes will (1) streamline the withdrawal process for facilities, (2) make it easier
              for EPA to automate the withdrawal process, and (3) improve the Agency's ability
              to analyze the reasons for withdrawals.

   D   New TRI Web page for frequently asked questions. The TRI Web site has a new tool for TRI customers. TRI
       users can scan frequently asked questions and answers, or submit a new question on a variety of TRI topics.
       Users can link to the new tool through the TRI's Web site's "Contact Us" page:
       http://www.epa.gov/tri/contacts.htm.


Other Important Information for RY 2007

Public Availability of 2007 TRI Reports. EPA plans to issue an electronic Facility Data Release (e-FDR)
for RY 2007 in the fall of 2008. The e-FDR provides early  access to the individual forms submitted
by regulated facilities. The annual Public Data Release for RY 2007, which includes summary data,
analyses, and treands, will be released by the Spring of 2009.

   D   Reporting by Federal Facilities. Executive Order (EO) 13148, pertaining to federal facilities
       has been superseded by EO 13423, which was signed on January 24, 2007. Please refer to
       this new EO and the associated Implementing Instructions. (See the TRI Web  site for
       more information.)

   D   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
       Self-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 Web site
       http://www.epa.gov/compliance/incentives/auditing/auditpolicy.html.

   D   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 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
       Web site

vi                 Toxics Release Inventory Reporting Forms and Instructions

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                       Important Information for Reporting Year 2007
        http://www.epa.gov/compliance/incentives/smallbusiness/index.html.

       North American Industry Classification System (NAICS) Codes.  Facilities were first required to report to
       TRI using NAICS codes in place of Standard Industry Classification (SIC) codes for RY 2006. For RY 2007 TRI
       reports, facilities should continue to use 2002 NAICS codes. EPA will publish a rule to adopt OMB's 2007
       NAICS codes so that beginning with RY 2008, for TRI reporting forms that are due by July 1, 2009, facilities
       will be required to use 2007 NAICS codes.
TRI-ME 2007

The TRI-ME 2007 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-MEis 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 an 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 RY 2007
Reporting Forms and Instructions book is contained within  TRI-ME.

TRI-ME allows the user  to submit the forms 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-MEweb
and TRI-ME.

Can I Use or Load Past Year's data into TRI-MEl

You may load prior year data from Reporting Year 2006 submission diskettes or from TRI-ME Reporting Year 2006
facility files. With few exceptions, all of your prior year data will be loaded directly into the Reporting Year 2007 forms.
To load Reporting Year 2005 data into TRI-ME 2007, you must first load your data into TRI-ME  2006. If you have
questions about loading data from 2004 or prior years, please call the bCDX 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.

                    Toxics Release Inventory Reporting Forms and Instructions              vii

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                     Important Information for Reporting Year 2007
                  Web Sites and Points of Contact for Assistance

TRI Information Center:
The TRI Information Center provides a toll free number that facilities may call to obtain guidance
on TRI reporting requirements and help on completing the TRI reporting forms. The TRI
Information Center number is 800.424.9346. Callers in the Washington, D.C. metropolitan area
call 703.412.9810. The TDD is 800.553.7672.

Frequently Asked  Questions (FAQ) Service:
TRI users can scan frequently asked questions or submit a new question through the TRI
Programs FAW service. Access to the service is available from the "Contact Us" page on the TRI
Web site: http://www.epa.gov/tri/contacts.htm.

TRI Technical Support:
For technical questions related to TRI-ME software, TRI-MEweb, and the Central Data Exchange
(CDX), please contact the CDX Hotline at epacdx@csc.com or call toll-free at 888.890.995.

TRI Reporting Materials:
You can use TRI-MEweb, TRI-ME and the TRI Assistance Library to electronically search and
read TRI guidance documents, including this document.  The TRI Web site contains links and
guidance on filling out and submitting TRI reporting forms:
http://www.epa.gov/tri/report/index.htm.

TRI Regional Contacts:
EPA Regional Coordinators often work closely with reporting facilities in their area providing
training, 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.
vin                Toxics Release Inventory Reporting Forms and Instructions

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(IMPORTANT: Type or print; read instructions before completing form)
                                                                       Form Approved OMB Number: 2070-0093
                                                                       Approval Expires: 03/31/2011                Page 1 of 5
    a  EPA
  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
                                                                2.  APPROPRIATE STATE OFFICE
                                                                   (See instructions in Appendix E)
  This section only applies if you are
  revising or withdrawing a previously
  submitted form, otherwise leave blank.
                                   Revision  (enter up to two code(s))
          Withdrawal  (enter up to two code(s))
   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
  2.1
  Are you claiming the toxic chemical identified on page 2 trade secret?
           (Answer question 2.2;
             Yes
                   Attach substantiation forms)
                                         No   (Do not answer 2.2;
                                              Go to Section 3)
                                                                    2.2
Is this copy 	     Sanitized   |_

      (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
 4.1
                                                             TRI Facility ID Number
 Facility or Establishment Name]
                                          Facility or Establishment Name or Mailing Address (If different from street address))
  Street
                                               Ma:
                                                 iling Address
 City/County/State/Zip Code  |
                                         Citv/State/Zip Code T
                                                                                                      Country (Non-US;
  4.2
This report contains information for:                  I   I  An entire
(Important:  Check a or b; check c or d if applicable)   a-  |	|  facility
       Part of a
       facility
A Federal
facility    d.
                                                                                                                    GOCO
 4.3
      Technical Contact Name
                                                                                          Telephone Number (include area code) |
       Email Address
  4.4
       Public Contact Name
                                                                                          Telephone Number (include area code)]
       Email Address
  4.5
       NAICS Code (s)
       (6 digits)
                           Primary
                                                                            d.
  4.6
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
 EPA Form 9350 -1 (Rev. 01/2008) - 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: 03/31/2011                  Page 2 of 5
                                                                                                 FRI Facility ID Number
                                   FORMR
         PART II.  TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM
                                                                                          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: Enteronly 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 Memberof 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
 NAQ
  SECTION 2. MIXTURE COMPONENT IDENTITY
                                                       (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
      Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces and punctuation.)
  SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
                  (Important: Check all that apply.)
3.1   Manufacture the toxic chemical:
                                             3.2
                                                Process the toxic chemical:
 3.3    Otherwise use the toxic chemical:
          Produce
                            mport
      	 If produce or import
    C.     For on-site use/processing
    d.LJ For sale/distribution
    e I   I As a byproduct
    f I   I As an impurity
a.L
b.[
c.[
d.[
e.F
                                              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. |    |  Ancillary or other use
  SECTION 4.1
 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     I  (example: 1,2,3, etc.)
EPA Form 9350 -1 (Rev. 01/2008) - 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: 03/31/2011              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 ON SITE (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
6 1 A 1 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
 EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete.
                                                                        * For Dioxin or Dioxin-like compounds, report in grams/year
                                                                 ' Range Codes: A=l-10 pounds: B=l-499 pounds; C=500 - 999 pounds.

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This side intentionally
      left blank.
  Please do not copy
    double-sided!

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    (IMPORTANT: Type or print; read instructions before completing form)
                                                                Form Approved OMB Number:  2070-0093
                                                                Approval Expires:  03/31/2011                  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
            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
                                                                                                           7A.ld
   7A2a
7A.2b   I
  7A3a
7A.3b  I
                                                                                                          7A.2d
                                                                                                           7A.3d
   7A4a
                  7A.4b
                                                                                                           7A.4d
   7A5a
                  7A.5b
                                                                                                           7A.5d
 If additional pages of Part II, Section 6.2/7 A 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:  | _ |  (example:  1,2,3, etc.)
EPA Form 9350 -1 (Rev. 01/2008) - 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:  03/31/2011                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
          Not Applicable (NA) -
                       Check here if no on-site energy recovery is applied to any waste
                       stream containing the toxic chemical or chemical category.
       Energy Recovery Methods [enter 3-character code(s)]

                     1    I                   I
    SECTION 1C. ON-SITE RECYCLING PROCESSES
         Not Applicable (NA) -
                     Check here if no on-site recycling is applied to any waste
                     stream containing the toxic chemical or chemical category.
       Recycling Methods [enter 3-character code(s)]
  SECTION 8.  SOURCE REDUCTION AND RECYLING ACTIVITIES
                                              Column A
                                              Prior Year
                                              (pounds/year*)
                                                              Column B
                                                              Current Reporting Year
                                                              (pounds/year*)
Column C
Following Year
(pounds/year*)
Column D
Second Following Year
(pounds/year*)
  8.1
  8.1a
Total on-site disposal to Class I
Underground InjectionWells, 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 InjectionWells, RCRA
Subtitle C landfills, and other landfills
 8.1d
Total other off-site disposal or other
releases
  8.2
 Quantity used for energy recovery
 onsite
  8.3
Quantity used for energy recovery
offsite
  8.4
Quantity recycled
onsite
  8.5
        Quantity recycled offsite
  8.6
Quantity treated onsite
  8.7
        Quantity treated offsite
  8.8
Quantity released to the environment as a result of remedial actions, catastrophic events,
 or one-time events not associated with production processes (pounds/year)*
  8.9
        Production ratio or activity index
  8.10
Did your facility engage in any source reduction activities for this chemical during the reporting
year? If not, enter "NA" in Section 8.10.1 and answer Section 8.11.
        Source Reduction Activities
             [enter code(s)]
                                                             Methods to Identify Activity (enter codes)
 8.10.1
 8.10.2
                                                                     b.
 8.10.3
                                                                     b.
 8.10.4
                                                                     b.
 8.11
If you wish to submit additional optional information on source reduction, recycling, or pollution
control activities, check "Yes."
                                                                                                                    Yes
EPA Form 9350 -1 (Rev. 01/2008) - 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: 03/31/2011         Page 1 of
   United States
   Environmental Protection Agency
                                    TOXIC RELEASE INVENTORY
                                                 FORMA
                                                                                          TRI Facility ID Number
 WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center
                                         P. O. Box 1513
 	Lanham, MD 20703-1513
                                                               2. APPROPRIATE STATE OFFICE
                                                                  (See instruction in Appendix E)
  This section only applies if you are revising or
  withdrawing a previously submitted form,
  otherwise leave blank.
                                          Revision (enter up to two code(s))
                                                                                Withdrawal (enter up to two code(s))
  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
2.1
Are you claiming the toxic chemical identified on page 2 trade secret?
      es (Answer question 2.2;
|-Je
              Attach substantiation forms)
No  (Do not answer 2.2;
    Go to Section 3)
                                                                   2.2
Is this copy        Sanitized           Unsanitized
        (Answer only if "YES" in 2.1)
  SECTION 3.  CERTIFICATION   (Important: Read and sign after completing all form sections.)	
Dursuant to 40 CFR 372.27(a)(l), "I hereby certify that to the best of my knowledge and belief for the toxic chemical(s) listed in this
statement, for this reporting year, the annual reportable amount for each chemical, as defined in 40 CFR 372.27(a)(l), did not exceed 5,000
rounds, which included no more than 2,000 pounds of total disposal or other releases to the environment, and that the chemical was
manufactured, or processed, or otherwise used in an amount not exceeding 1 million pounds during this reporting year;" and/or

Dursuant to 40 CFR 372.27(a)(2), "I hereby certify that to the best of my knowledge and belief for the toxic chemical(s) of special concern
isted in this statement, there were zero disposals or other releases to the environment (including disposals or other releases that resulted from
catastrophic events) for this reporting year, the "Annual Reportable Amount of a Chemical of Special Concern" for each such chemical, as
defined in 40 CFR 372.27(a)(2), did not exceed 500 pounds for this reporting year, and that the chemical was manufactured, or processed, or
otherwise used in an amount not exceeding 1 million pounds during this reporting year."	
 Name and offcial 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:  (I
                                      it:  Check c or d if applicable)
                                                                           c. |    | A Federal        d        GOCO
                                                                                  facility           '  I	1
    Technical Contact Name
 4.3
                                                                                   Telephone Number (include area code)
     Email Address
     Public Contact Name
                                                                                   telephone Number (include area code)
4.4
     Email Address
 4.5
     NAICS Code (s)
     (6 digits)
                      Primary
                                         b.
                                                                                           e.
4.6
Dun & Bradstreet
Number (s) (9 digits)
    SECTION 5. COMPANY INFORMATION
5.1
Name of Parent Company
                          NA
5.2
     Parent Company's Dun & Bradstreet Number
                                         NA
EPA Form 9350 -2 (Rev. 01/2008) - Previous editions are obsolete.

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  (IMPORTANT: Type or print; read instructions before completing form)                                                                   Page    of __
                                                      EPA FORM A

                           PART II. CHEMICAL IDENTIFICATION       TRI Facility ID Number
                                Do not use this form for reporting 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.)
    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.)
. .  Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
   *^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^~^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^~
                                       *See the TRI Reporting Forms and Instructions Manual for the TRI-listed Dioxin and Dioxin-like Compounds


EPA Form 9350 -2 (Rev. 01/2008) - Previous editions are  obsolete.                             (Make additional copies of this page, if needed)

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                                        General Information
A. General Information
Reporting to the Toxic Chemical Release Inventory (i.e.,
Toxics Release Inventory (TRI)) is required by section
313  of  the  Emergency Planning  and  Community
Right-to-Know  Act (EPCRA,  or  Title  III  of the
Superfund Amendments  and Reauthorization Act of
1986), Public Law 99-499. The information contained in
the Form R constitutes a "report," and the submission of
a  report to  the appropriate authorities  constitutes
"reporting."

The  Pollution Prevention Act, passed into  law in
October, 1990  (Pub. L. 101-508),  added reporting
requirements to Form R. These requirements affect all
facilities required to submit Form R under section 313
of EPCRA. The data were required beginning with
reports for calendar year 1991.

Reporting is  required to provide  the public with
information on the releases and other waste management
of EPCRA section 313 chemicals in their communities
and to provide  EPA with release and other waste
management  information to  assist  the  Agency in
determining the  need for future regulations. Facilities
must  report the  quantities of routine and accidental
releases,  and  releases resulting from catastrophic or
other one time events of EPCRA section 313 chemicals,
as well as the maximum amount of the EPCRA section
313 chemical on-site during the calendar year and the
amount  contained  in  wastes  managed  on-site or
transferred off-site.

A completed Form R or Form A must be submitted for
each  EPCRA section  313  chemical  manufactured,
processed, or otherwise used at each covered facility as
described in the reporting rules in 40 CFR Part 372
(originally published February 16,1988, in the Federal
Register  and November 30, 1994, in the Federal
Register (for Form A)).
A. 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.

   •  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

   •  The  facility is included in a North American
      Industry Classification System (NAICS) code
      listed on Table I. NAICS codes found in Table I
      correspond to the following Standard Industrial
      Classification  (SIC) Codes: SIC 10  (except
       1011,1081, and 1094), 12 (except 1241), 20-39,
      4911  (limited  to facilities  that combust coal
      and/or oil for the  purpose  of  generating
      electricity for distribution in commerce), 4931
      (limited to facilities that combust coal and/or oil
      for the purpose  of  generating electricity for
      distribution in commerce),  4939 (limited to
      facilities  that combust coal and/or oil for the
      purpose of generating electricity for distribution
      in  commerce),  4953  (limited  to  facilities
      regulated under RCRA Subtitle C, 42 U.S.C.
      section 6921  et seq.), 5169,  5171,  and 7389
      (limited  to  facilities  primarily  engaged  in
      solvents recovery services on a contract or fee
      basis); and

   •  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 13423   extends  these  reporting
requirements to federal facilities, regardless of their SIC
or NAICS 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 web (TRI-MEweb) application via
CDX. TRI-MEweb is an intelligent, web-based version
of the popular TRI-ME software. There are several
advantages to using TRI-MEweb. They are as follows:
your prior year data will be prepopulated,  electronic
signature which allows for paperless filing, higher data
quality and instant confirmation that EPA has received
your submission. Facilities may also submit reports
electronically via the  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-MEweb or the TRI-
ME software, 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-MEweb or the TRI-ME
software to submit your TRI submissions) via CDX.
Both TRI-MEweb and the TRI-ME software allow you to
                      Toxics Release Inventory Reporting Forms and Instructions
                                              1

-------
                                        General Information
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:
.


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 submityour 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. Please note that TRI-MEweb does not support a
diskette submission process.

A.2.b.1   Labeling Your Submission Diskette

Company Name
Date: 6/30/2008
Reporting Year: 2007
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  hand-delivered
submissions only should be addressed to:

    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. 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  confirmed that they accept diskette
submissions:
AK
GA
MD4
NM7
SD
WY
AL
ffl
MI5
NV
TX

AR1
IA
MN
OH
UT

AZ2
ID
MO6
OK
VA

CA
IL
MT
OR
VT

CO
IN3
ND
PA
WA9

DE
KS
NH
PR
WI

FL
LA
NJ
SC8
wv

lArkanasas 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.

Indiana's preferred method of submission is using TRI-
MEweb.

4Maryland accepts diskette submissions, but requires
that paper copies be sent as well.
                      Toxics Release Inventory Reporting Forms and Instructions

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                                         General Information
5Michigan   accepts  Internet  submissions;   reports
submitted electronically via Internet to EPA's Central
Data Exchange do not require any separate mailing of
reports (disk or paper). Also accepts diskettes.

6 Missouri accepts paper submissions created using TRI-
MEweb. All other

submissions must be CDs/diskettes created using the
TRI-ME software.

7New Mexico requires paper copies  in  addition to
diskette.

8 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.

'Washington 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. A list of state
contacts can be found in Appendix E.

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 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  E  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 and2.2, and Part II, Section 1.3, of the instructions.

In summary, a complete report to EPA for an EPCRA
section  313 chemical  claimed as a trade secret  must
include  all of the following:

   • A completed unsanitized version of Form R or
      Form A report including the EPCRA section 313
      chemical identity (staple the pages together); and

   • 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

   • A completed unsanitized version of a trade
      secret  substantiation form (staple the pages
      together); and

   • A sanitized version of a completed trade secret
      substantiation form (staple the pages together).
                       Toxics Release Inventory Reporting Forms and Instructions

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                                        General Information
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 E).

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 submissions. An essential component of this
process involves reviewing a facility's  records for
accuracy  and completeness. EPA recommends that
facilities keep a record for those EPCRA section 313
chemicals for which they did not file EPCRA section
313 reports.

A partial list of records, organized by year, that a facility
should maintain include:

   •  Previous years' EPCRA section 313 reports;

   •  EPCRA  section  313  Reporting  Threshold
      Worksheets;

   •  Engineering calculations and other notes;

   •  Purchase records from suppliers;

   •  Inventory data;

   •  EPA (NPDES) permits and monitoring reports;

   •  EPCRA section 312 Tier II Reports;

   •  Monitoring records;

   •  Flowmeter data;

   •  RCRA Hazardous Waste Generator's Report;

   •  Pretreatment reports filed by the facility with the
      local government;

   •  Invoices from waste management companies;

   •  Manufacturer's    estimates   of    treatment
      efficiencies;

   •  RCRA manifests;

   •  Process  diagrams that indicate emissions and
      other releases; and

   •  Records for those EPCRA section 313 chemicals
      for which they did not file EPCRA section 313
      reports.


A.5      How to Revise or
           Withdraw TRI Data

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?

Submitting a Request to Revise TRI Data

Facilities that  filed  a Form  R  and/or  Form  A
Certification Statement under EPCRA section 313 may
submit a request to revise a form that was previously
submitted, stored  in  the Toxics Release Inventory
Processing System (TRIPS), and made available to the
public through Envirofacts and TRI Explorer. Facilities
                      Toxics Release Inventory Reporting Forms and Instructions

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                                         General Information
may request a revision for one or more of the following
reasons:

        RR1 - New Monitoring Data
        RR2 - New Emission Factor(s)
        RR3 - New Chemical Concentration Data
        RR4 - Recalculation(s)
        RR5 - Other Reason(s)
The revision code(s) should be entered in the "Revision"
box on the first page of the reporting form. You may
enter up to two revision codes on the form.

Please note that 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-MEweb. The preferred method for revising TRI
forms from Reporting Year 2005 through the current
year is to use  TRI-MEweb.  For  more  information
regarding   access   to   TRI-MEweb,  please  visit
http://www.epa.gov/tri.  TRI-MEweb provides several
advantages compared to hard-copy  reporting,  such as
pre-populating the form with the previous year's data,
allowing reporters to electronically sign and submit the
form over the Internet, providing automated data quality
checks, and electronically confirming EPA's receipt of a
submitted form. If you have questions about accessing
TRI-MEweb,  please contact  the  CDX Hotline at
epacdx@csc.com or call toll-free at  1-888-890-1995.

2. TRI-ME via CDX. The preferred method for revising
TRI forms from Reporting Year 2002 through Reporting
Year 2004 is to use the TRI  Made-Easy  (TRI-ME)
software  and  submit the  report via CDX and the
Internet. You can download the TRI-ME software at
http://www.epa.gov/tri.  If  revising a report  from a
particular  reporting year, you must use  the TRI-ME
software for that same reporting year. For example, if
you are revising a form for Reporting Year 2003, you
must use the Reporting Year 2003 version of TRI-ME,
which is available at http://www.epa.gov/tri. If you have
questions  about using the TRI-ME  software  and
submitting a report through CDX, please contact the
CDX Hotline at epacdx@csc.com or call toll-free at 1-
888.890.1995.

3. TRI-ME via Diskette. If you do not have Internet
access and you wish to revise a form for Reporting Year
2005 or a prior year, EPA encourages you to use the
TRI-ME software and to submit your revised report by
diskette to one of  the  addresses 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 need, please
contact EPA at 301.429.5005.

Send revision requests by regular mail to the following
address:

        TRI Data Processing Center
        P.O. Box 1513
        Lanham, MD 20703-1513
        Attention: TRI Revision Request

Send revision requests by certified mail or overnight
mail to the following address:

        TRI Data Processing Center
        c/o Computer Sciences Corporation
        Suite 150
        8400 Corporate Drive
        Landover, MD 20785-2294
        Attention: TRI Revision Request
        Phone: 301.429.5005

4. Hard Copy Form. EPA strongly discourages paper
submissions  due  to the increased possibility of data
entry errors; however,  if necessary, you may revise a
previously submitted hard-copy form by using either 1)
a photocopy  of the original or 2) a blank form.

   •  Photocopy of Original Submission. You may
      submit a photocopy of your original submission
      (from your file) with the corrections  made in
      blue  ink.  Please re-sign and re-date  the
      certification statement on Page 1. For RY 2007
      revisions   and  beyond,  please   enter  the
      appropriate revision code(s). For RY 2006 and
      prior  years, please enter an "X" in the space
      marked "Enter 'X' here  if this is a revision," on
      page 1 of the form.

   •  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.  For  RY  2007
      revisions  and  beyond, please  enter in  the
      appropriate revision code(s). For RY 2006 and
      prior  years, please enter an "X" in the space
      marked "Enter 'X' here  if this is a revision," on
      page 1 of the form.

Send revision requests by regular mail to the following
address:

        TRI Data Processing Center
        P.O. Box 1513
        Lanham, MD 20703-1513
        Attention: TRI Revision Request

Send revision requests by certified mail or overnight
mail to the following address:
                       Toxics Release Inventory Reporting Forms and Instructions

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                                        General Information
        TRI Data Processing Center
        c/o Computer Sciences Corporation
        Suite 150
        8400 Corporate Drive
        Landover, MD 20785-2294
        Attention: TRI Revision Request
        Phone: 301.429.5005

Submitting a Request Withdraw TRI Data

Facilities  that  filed a  Form R and/or Form  A
Certification Statement under EPCRA section 313 may
submit a request to withdraw a form that was previously
submitted,  stored in the Toxics Release Inventory
Processing System (TRIPS), and made available to the
public through Envirofacts and TRI Explorer. EPA may
periodically review withdrawals.

Facilities may request a withdrawal for one or several
reasons, such as:

   •  WT1 - Did not meet the reporting threshold for
      manufacturing, processing, or otherwise use

   •  WT2 - Did not meet the reporting threshold for
      number of employees

   •  WT3 - Not in a covered NAICS Code

   •  WO 1 - Other reason(s)

The  withdrawal code(s)  should  be entered in  the
"Withdrawal" box on the first page  of the reporting
form. You may enter up to two withdrawal codes on the
form.

How do I withdraw my submission(s)?

If you have determined  that your facility wishes to
withdraw a TRI submission, you must send your request
to EPA and the appropriate State agency. For submitting
a withdrawal to EPA, please use one  of the following
methods:

1. TRI-MEweb. The preferred method for requesting a
withdrawal of a previously submitted TRI form from
Reporting Year 2005 through the current year is TRI-
MEweb. For more information regarding access to TRI-
MEweb, please visit http://www.epa.gov/tri or contact
the CDX Hotline at epacdx@csc.com or call toll-free at
1-888-890-1995.

2. TRI-ME via CDX. For the RY 2007 version  of the
software   only,  withdrawals  may   be  submitted
electronically  using  the  TRI-ME  software  and
submitting the report via CDX and the Internet.  You can
download     the     TRI-ME     software     at
http://www.epa.gov/tri. If you  have  questions  about
submitting via CDX, please contact the CDX Hotline at
epacdx@csc.com or call toll-free at 1-888-890-1995
 3. TRI-ME via Diskette. For the RY 2007 version of
 the software only, withdrawals can be submitted via
 diskette to one of the addresses  below. Withdrawals
 submitted on diskette using the prior versions of the
 TRI-ME software will not be accepted.

 Send  withdrawal  requests by regular mail  to  the
 following address:

        TRI Data Processing Center
        P.O. Box 1513
        Lanham,MD 20703-1513
        Attention: TRI Withdrawal Request
 Send withdrawal requests by certified mail or overnight
 mail to the following address:

         TRI Data Processing Center
         c/o Computer Sciences Corporation
         Suite 150
         8400 Corporate Drive
         Landover, MD 20785-2294
         Attention: TRI Withdrawal Request
         Phone: 301.429.5005
 4. Hard Copy Form. All other withdrawal requests
 may be submitted by hard copy as follows:

    •  Reporting Year 2007 Forward. You may submit
       a photocopy of your original submission (from
       your file). Using blue ink, re-sign and re-date the
       certification statement on Page 1 and enter the
       appropriate withdrawal code(s)  in the space
       provided on page 1 of the formA

    •  Reporting Year 2006 and Prior Years. Please
       submit a photocopy of the form you  wish to
       withdraw (from your file), and attach -  as a
       cover page  - page  1  of  the current year's
       reporting form, which includes a field for the
       withdrawal codes. Using blue ink, please sign
       and date the certification statement and enter the
       appropriate withdrawal code(s)  in the space
       provided on page 1 of the current year's form.

 Send  withdrawal  requests  by  regular mail to  the
 following address:

         TRI Data Processing Center
         P.O. Box 1513
         Lanham,MD 20703-1513
         Attention: TRI Withdrawal Request

 Send withdrawal requests by certified mail or overnight
 mail to the following address:

         TRI Data Processing Center
         c/o Computer Sciences Corporation
         Suite 150
	8400 Corporate Drive	
                      Toxics Release Inventory Reporting Forms and Instructions

-------
                                      General Information
       Landover, MD 20785-2294
       Attention: TRI Withdrawal Request
       Phone: 301.429.5005

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). If you
submit using TRI-ME web or TRI-ME via the Central
Data Exchange (CDX), you will receive your Facility
Data Profile (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 e-mail to tri.efdp@csc.com or
call 301.429.5005.


A. 7       How to  Obtain the TRI
           Reporting  Forms

Copies of both forms are included in the first part of this
document.

The forms and related guidance documents may also be
obtained from EPA's TRI Web site:

        http://www.epa.gov/tri
                     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
B. 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 NAICS 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.1       Full-Time Employee
           Determination
The number of full-time employees is dependent only
upon the total number of hours worked by all employees
and other individuals (e.g., contractors) for the facility
during the calendar year and not the number of persons
working. Therefore, a full-time employee, for purposes
of EPCRA section 313 reporting, is defined as 2,000
work  hours  per  year. 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:

   •  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 numberof
      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.

   •  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 NAICS Code
           Determination

Beginning with 2006 EPCRA Section 313 reporting, the
TRI Program is now using North American Industry
Classification System (NAICS)  codes  instead  of
Standard Industrial  Classification (SIC) codes. Please
refer to the TRI Program's final rule titled Community
Right-to-Know; Toxic Chemical Release Reporting
Using North American Industry Classification System
(NAICS) published in the Federal Register on June 6,
2006 (71FR 32464). For Reporting Year 2007, facilities
should use 2002 NAICS codes.

The full list  of NAICS codes for facilities that  must
report to TRI (including exceptions and/or limitations) if
all other threshold determinations are met can be found
in Table I. The facility should determine its own NAICS
code (s), based on its activities on-site, using the NAICS
Manual  and  by  referring  to  the extensive  OMB
crosswalk tables found on the Census Bureau website:
www.census.gov. State agencies and other organizations
may assign NAICS 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 NAICS Manual.

The TRI Information Center  can assist facilities with
determining  which NAICS  codes  are  assigned for
specific business activities as referenced in the NAICS
Manual. Clothbound editions of the NAICS Manual are
available in most major libraries or may be ordered
through  the National Technical Information Service,
5285 Port Royal Road, Springfield, VA 22161, 703-
605-6000. The access number for the hardbound manual
is PB2002-101430, $49.00+ shipping and handling. The
access number for the CD-ROM version with search and
retrieval software is PB2002-502024, $60 + shipping and
handling.
                      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
        Paperwork Reduction Act Notice: The annual public burden related to the Form R, which is
        approved under OMB Control No.  2070-0093, is estimated to average  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 per response for non-PBT chemicals and 35.89 hours per
        responses for PBT chemicals.

             Burden means the total time, effort, or  financial resources expended by persons to
        generate, maintain, retain, or disclose orprovide informationto orforaFederal agency. This
        includes the  time needed to review instructions; develop, acquire,  install, and utilize
        technology and systems for the purposes of collecting, validating, and verifying information,
        processing and maintaining information, and 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 information; search data sources; complete
        and review the collection of information; and transmit or otherwise disclose the information.
        An agency may not conduct or sponsor, and a person is not  required to respond to, a
        collection of information unless it displays a currently valid OMB control number. The OMB
        control numbers for EPA's regulations are listed in 40 CFR Part  9 and 48 CFR Chapter 15.

             Send comments on the Agency's need for this information, the accuracy of the provided
        burden estimates, and any suggested methods for minimizing respondent burden, including
        through the use of automated collection techniques, to the Director,  Collection Strategies
        Division, U.S.  Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW,
        Washington,  D.C. 20460; and to 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 and  OMB control number in any
        correspondence.

             The completed forms  should  be submitted in accordance with the instructions
        accompanying the form, or as specified in the  corresponding regulation.
                  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


Facilities Required to Report to TRI (2002 NAICS)
The facility is included in the following NAICS codes (corresponding to SIC codes 20 through 39):
311*, 312*, 313*, 314*, 315*, 316, 321, 322, 323*, 324, 325*, 326*, 327*, 331, 332, 333, 334*, 335*, 336, 337*,
339*,
111998*, 113310, 211112*, 212234*, 212235*, 212393*, 212399*, 488390*, 511110, 511120, 511130, 511140*,
511191, 511199, 54710, 512230*, 519130**, 516110*, 811490*
*Exceptions and/or limitations exist for these NAICS codes. See table below.
The facility is included in the following NAICS codes (corresponding to SIC codes other than SIC codes 20
through 39):
NAICS 212111, 212112, 212113 [correspond to SIC 12, Coal Mining (except 1241)];
212221, 212222, 212231, 212234, 212299 [correspond to SIC 10, Metal Mining (except 1011, 1081, and 1094)];
221111, 221112, 221113 221119, 221121, 221122, limited to facilities that combust coal and/or oil for the purpose of
generating power for distribution in commerce, (correspond to SIC 4911, 4931, and 4939, Electric Utilities);
424690, 425110, 425120, limited to facilities previously classified in SIC 5169, Chemicals and Allied Products,  Not
Elsewhere Classified;
424710 (corresponds to SIC 5171, Petroleum Bulk Terminals and Plants);
562112, limited to facilities primarily engaged in solvent recovery services on a contract or fee basis, (corresponds to
SIC 7389, Business Services, NEC);
562211, 562212, 562213, 562219, 562920, limited to facilities regulated under the Resource Conservation and
Recovery Act, subtitle C, 42 U.S.C. 6921 et seq. (correspond to SIC 4953, Commercial Hazardous Waste Treatment);
Federal Facilities.
* Exceptions  and/or limitations for NAICS codes in the manufacturing sector (corresponding to SIC codes 20 -
39):
311:
Except 311119 - Exception is limited to facilities primarily engaged in Custom Grain Grinding for Animal Feed
(previously classified under SIC 0723,  Crop Preparation Services for Market, Except Cotton Ginning);
Except 311330 - Exception is limited to facilities primarily engaged in the retail sale of candy, nuts, popcorn and other
confections not for immediate consumption made on the premises (previously classified under SIC 5441, Candy, Nut,
and Confectionery Stores);
Except 311340 - Exception is limited to facilities primarily engaged in the retail sale of candy, nuts, popcorn and other
confections not for immediate consumption made on the premises (previously classified under SIC 5441, Candy, Nut,
and Confectionery Stores);Except 311611 - Exception is limited to facilities primarily engaged in Custom Slaughtering
for individuals (previously classified under SIC 0751, Livestock Services, Except Veterinary, Slaughtering, custom:
for individuals);
Except 311612 - Exception is limited to facilities primarily engaged in the cutting up and resale  of purchased fresh
carcasses for the trade (including boxed beef), (previously classified under SIC 5147, Meats and Meat Products);
Except 311811 - Retail Bakeries (previously classified under SIC 5461, Retail Bakeries);
312:
Except 312112 - Exception is limited to facilities primarily engaged in bottling mineral or spring water (previously
classified under SIC 5149, groceries and Related Products, NEC);
Except 312229 - Exception is limited to facilities primarily engaged in providing Tobacco Sheeting Services
(previously classified under SIC 7389,  Business Services, NEC);
10                    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
313:	
Except 313311 - Exception is limited to facilities primarily engaged in converting
broadwoven piece goods and broadwoven textiles, (previously classified under SIC 5131, Piece Goods Notions, and
Other Dry Goods, broadwoven and non-broadwoven piece good converters), and facilities primarily engaged in
sponging fabric for tailors and dressmakers (previously classified under  SIC 7389, Business Services, NEC (Sponging
fabric for tailors and dressmakers));
Except 313312 - Exception is limited to facilities primarily engaged in converting narrow woven Textiles, and narrow
woven piece goods, (previously classified under SIC 5131, Piece Goods Notions, and Other Dry Goods, converters,
except broadwoven fabric);
314:
Except 314121 - Exception is limited to facilities primarily engaged in making Custom drapery for retail sale
(previously classified under SIC 5714, Drapery, Curtain, and Upholstery Stores);
Except 314129 - Exception is limited to facilities primarily engaged in making Custom slipcovers for retail sale
(previously classified under SIC 5714, Drapery, Curtain, and Upholstery Stores);
Except 314999 - Exception is limited to facilities primarily engaged in Binding carpets and rugs for the trade, Carpet
cutting and binding, and Embroidering on textile products (except apparel) for the trade (previously classified under
SIC 7389, Business Services Not Elsewhere Classified, Embroidering of advertising on shirts and Rug binding for the
trade);
315:
Except 315222 - Exception is limited to custom tailors primarily engaged in making and selling men's and boys' suits,
cut and sewn from purchased fabric (previously classified under SIC 5699, Miscellaneous Apparel and Accessory
Stores (custom tailors));
Except 315223 - Exception is limited to custom tailors primarily engaged in making and selling men's and boys' dress
shirts, cut and sewn from purchased fabric (previously classified under SIC 5699, Miscellaneous Apparel and
Accessory Stores (custom tailors));
Except 315233 - Exception is limited to custom tailors primarily engaged in making and selling bridal dresses or
gowns, or women's, misses' and girls' dresses cut and sewn from purchased fabric (except apparel contractors)(custom
dressmakers) (previously classified under SIC Code 5699, Miscellaneous Apparel and Accessory Stores);
323:
Except 323114 - Exception is limited to facilities primarily engaged in reproducing text, drawings, plans, maps, or
other copy, by blueprinting, photocopying, mimeographing, or other methods of duplication other than printing or
microfilming (i.e., instant printing) (previously classified under SIC 7334, Photocopying and Duplicating Services,
(instant printing));
325:	
Except 325998 - Exception is limited to facilities primarily engaged in Aerosol can filling on a job order or contract
basis (previously classified under SIC 7389, Business Services, NEC (aerosol packaging));
326:	
Except 326212 - Tire Retreading, (previously classified under SIC 7534, Tire Retreading and Repair Shops
(rebuilding));
327:
Excerpt 327112 - Exception is limited to facilities primarily engaged in manufacturing and selling pottery on site
(previously classified under SIC 5719, Misscellaneous Home Furnishing Stores);
                       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
334:
Except 334611 - Software Reproducing (previously classified under SIC 7372 packaged software, (reproduction of
Software);
Except 334612 - Exception is limited to facilities primarily engaged in mass reproducing pre-recorded video cassettes,
and mass reproducing Video tape or disk (previously claaified under SIC 7819, Services Allied Motion Picture
Production (reproduction of video));
335:	
Except 335312 - Exception is limited to facilities primarily engaged in armative rewinding on a factory basis
(previously classified under SIC 7694 (armature rewinding shops/remanufacturing));
337:
Except 337110 - Exception is limited to facilities primarily engaged in the retail  sale of household furniture and that
manufacture custom wood kitchen cabinets and counter tops (previously classified under SIC 5712, Furniture Stores
(custom wood cabinets));
Except 337121 - Exception is limited to facilities primarily engaged in the retail  sale of household furniture and that
manufacture custom made upholstered household furniture (previously classified under SIC 5712, Furniture Stores
(upholstered, custom made furniture));
Except 337122 - Exception is limited to facilities primarily engaged in the retail  sale of household furniture and that
manufacture nonupholstered, household type, custom wood furniture (previously classified under SIC 5712, Furniture
Stores (custom made wood nonupholstered household furniture except cabinets));
339:
Except 339113 - Exception is limited to facilities primarily engaged in manufacturing orthopedic devices to
prescription in a retain environment (previously classified under SIC 5999 Miscellaneous Retail Stores, NEC);
Except 339115 - Exception is limited to lens grinding facilities that are primarily engaged in the retail sale of
eyeglasses and contact lenses to prescription for individuals (previously classified under SIC 5995, Optical Goods
Stores (optical laboratories grinding of lenses to prescription));
Except 339116 - Dental Laboratories (previously classified under SIC 8072, Dental Laboratories);
111998:
Limited to facilities primarily engaged in reducing maple sap to maple syrup (previously classified under SIC 2099,
Food Preparations, NEC, Reducing Maple Sap to Maple Syrup);
211112:
Limited to facilities that recover sulfur from natural gas (previously classified under SIC 2819, Industrial Inorganic
Chemicals, NEC (recovering sulfur from natural gas));
212324:	
Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating kaolin and clay
(previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise Treated (grinding, washing,
separating, etc. of minerals in SIC 1455));
212325:	
Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating clay and
ceramic and refractory minerals (previously classified under SIC 3295, Minerals  and Earths, Ground or Otherwise
Treated (grinding, washing, separating, etc. of minerals in SIC 1459));
212393:
Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating chemical or
fertilizer mineral raw materials (previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise
Treated (grinding, washing, separating, etc. of minerals in SIC 1479));
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
212399:
Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating nonmetallic
minerals (previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise Treated (grinding, washing,
separating, etc. of minerals in SIC 1499));
488390:
Limited to facilities that are primarily engaged in providing routine repair and maintenance of ships and boats from
floating dry docks (previously classified under SIC 3731, Shipbuilding and Repairing (floating dry docks not associated
with a shipyard));
511140:	
Except facilities that are primarily engaged in furnishing services for direct mail advertising including Address list
compilers, Address list publishers, Address list publishers and printing combined, Address list publishing, Business
directory publishers, Catalog of collections publishers, Catalog of collections publishers and printing combined,
Mailing list compilers, Directory compilers, and Mailing list compiling services (previously classified under SIC 7331,
Direct Mail Advertising Services  (mailing list compilers));
512230:
Except facilities primarily engaged in Music copyright authorizing use, Music copyright buying and licensing, and
Music publishers working on their own account (previously classified under SIC 8999, Services, NEC (music
publishing));
516110:
Limited to facilities primarily engaged in Internet newspaper publishing (previously classified under SIC 2711,
Newspapers: Publishing, or Publishing and Printing), Internet periodical publishing (previously classified under SIC
2721, Periodicals: Publishing, or Publishing and Printing), Internet book publishing (previously classified under SIC
2731, Books: Publishing, or Publishing and Printing), Miscellaneous Internet publishing (previously classified under
SIC 2741, Miscellaneous Publishing), Internet greeting card publishers (previously classified under SIC 2771,
Greeting Cards);
541710:	
Limited to facilities that are primarily engaged in Guided missile and space vehicle engine research and development
(previously classified under SIC 3764,  Guided Missile and Space Vehicle Propulsion Units and Propulsion Unit Parts),
and in Guided missile and space vehicle parts (except engines) research and development (previously classified under
SIC 3769, Guided Missile and Space Vehicle Parts and Auxiliary Equipment, Not Elsewhere Classified);
811490:
Limited to facilities that are primarily engaged in repairing and servicing pleasure and sail boats without retailing new
boats (previously classified under SIC 3732, Boat Building and Repairing (pleasure boat building));
                        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
  Does your facility have 10 or more full-
    time employees or the equivalent?

       (see definition under B.I)
                    YES
    Is your facility's primary NAICS 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 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 from threshold calculations)
                    YES
   AN EPCRA SECTION 313 REPORT IS
   REQURED FOR THE CHEMICAL OR
       CHEMICAL CATEGORY
                    YES
     Is the chemical dioxin or dioxin-like
            compounds?
         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 does the waste management of the
                       chemical exceed the Annual Reportable Amount for PBT or non-PBT
                                  chemical as exnlained in Section D.3?
                               NO
                                               YES
    FORM R IS REQUIRED FOR THIS
      CHEMICAL OR CHEMICAL
   CATEGORY (FORM A CANNOT BE
            SUBMITTED)
                            FORM A OR FORM R IS REQUIRED
                            FOR THIS CHEMICAL CATEGORY
                 Figure 1. EPCRA Section 313 Reporting Decision Diagram
14
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     How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
B.2.3.
Auxiliary Facilities
Under the Standard Industrial Classification  (SIC)
system, an auxiliary facility was defined as one that
supported another covered establishment's activities
(e.g.,    research   and   development   laboratories,
warehouses, and storage facilities). An auxiliary facility
could  assume  the SIC code  of another  covered
establishment if its primary function was to service that
other  covered establishment's operations. The  North
American Industry Classification System (NAICS), that
replaces the SIC  system for TRI reporting, does not
recognize the concept of auxiliary facilities and assigns
NAICS codes  to all establishments  based on  the
economic activity. In it's rulemaking, "Toxic Chemical
Release Reporting  Using North American Industry
Classification System," the TRI Program has adopted
NAICS for TRI reporting and also the NAICS treatment
of former "auxiliary facilities" as entities with their own
distinct NAICS code.


B.2.b.         Multi-Establishment
                 Facilities

Your facility may include multiple establishments that
have different NAICS 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
NAICS code criterion:

   •   If the total value added of the products produced,
       shipped, or services provided at establishments
       with covered NAICS codes is greater than 50%
       of  the  value added of the  entire  facility's
       products and services, the entire facility  meets
       the NAICS code criterion.

   •   If any one establishment with a covered NAICS
       code 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
       NAICS 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:

   •  A facility in coating, engraving and allied services
      has two establishments. The first establishment, a
      general automotive repair service, is in NAICS
      code 811113 (SIC 7537), which is not a covered
      NAICS code. However, the second establishment,
      a metal paint shop is inNAICS code 332812 (SIC
      3479, which is a covered NAICS 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 NAICS code  811113) and the value of
      the product is $1500/unit after processing by the
      metal  paint  shop  (in  covered  NAICS  code
      332812). 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 NAICS code 332812  is more
      than 50% of the  product value.  Therefore,  the
      facility's primary NAICS code is 332812, which
      is a covered NAICS code.

   •  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 NAICS
codes. 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.
                       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
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 SectionB.S.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;
                                       or
                                       (2) The EPCRA section 313 chemical that was disposed,
                                       stabilized, or treated for destruction was manufactured as
                                       a result of waste management activities on materials
                                       received  from  off-site for the purposes  of waste
                                       management activities. Relabeling or redistributing of the
                                       EPCRA section 313 chemical where no repackaging of
                                       the  EPCRA section  313  chemical  occurs does not
                                       constitute an otherwise use or processing of the EPCRA
                                       section 313 chemical. (See 62 FR 23846 and Part II,
                                       Section 3.3 of these instructions for further clarification).
16
       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 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.
                        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 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.
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
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 steel, 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)). In addition, PBT chemicals are ineligible
for range reporting for on-site releases and transfers off
site for further waste management. This will not affect
the applicability  of range reporting of the maximum
amount on site as required by EPCRA section 313(g).

All releases and other waste management quantities
greater than 0.1 pounds of a PBT chemical (except the
dioxin and dioxin-like compounds chemical  category)
should be reported at  a level of precision supported by
the accuracy  of  the  underlying data and estimation
techniques on which the estimate  is based. 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 the 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 remains 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 for lead and lead compounds:

     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
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     How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
not be considered for lead not in stainless steel, brass, or
bronze alloys;

     4) If afacility exceeds the 100-pound threshold for
lead other than in stainless steel, brass, or bronze alloys,
the facility may not apply Form A eligibility as a non-
PBTs, range reporting in Sections 5 and 6 of the FormR
or the use of whole numbers and 2 significant digits to
any of the lead they report through they may be eligible
for Form A using the PBT eligibility criteria. If a facility
that exceeds the 25,000/10,000 pound threshold for lead
in stainless steel, brass, or bronze alloy without tripping
the 100-pound threshold for  non-alloyed  lead, the
facility may consider the Form A requirements for non-
PBTs, range reporting in Sections 5 and 6 of the Form
R, and the use of whole numbers and 2 significant
digits.
B.3.C.
Activity Exemptions
Otherwise Use Exemptions. Certain otherwise uses of
listed EPCRA section 313 chemicals are specifically
exempted:

   •   Otherwise use as a structural component of the
       facility;

   •   Otherwise use  in routine janitorial or  facility
       grounds maintenance;

   •   Personal uses by employees or other persons;

   •   Otherwise use of products containing EPCRA
       section 313 chemicals  for  the purpose  of
       maintaining motor vehicles operated  by the
       facility; and

   •   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 ortubing orthe 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
20
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     How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

during normal conditions of processing or otherwise use        and therefore negate the exemption as articles.
 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 EPCPvA 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 EPCPvA 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  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
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    How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

concentration of each individual category member within
the mixture.
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
  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.
De Minimis Application to the Processing or
Otherwise Use of a Mixture
De Minimis Application in the Manufacture of the
Listed Chemical in 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
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.
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 22.)

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.
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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 DeMinimis Value

Q       A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1.25% manganese. Manganese is eligible for the de
minimis exemption at concentrations up to 1 %. The amount of mixture subject to reporting is the quantity containing manganese at
or above the de minimis concentration:

        [(8,000,000) x (1.25% - 0.99%)] - (1.25% + 0.25%)

The average concentration of manganese that is not exempt (above the de minimis) is:
        (1.25% +1.00%) -
  (8,000,OOOXl.25% - 0.99%)'
         (l. 25% -0.25%)
              (l.25%+ 1.00%)'

             .        (2).
= 23,400 pounds
Therefore, the amount of manganese that is subject to threshold determination and release and other waste management estimates
is:

        = 23,400 pounds manganese (which is below the processing threshold for manganese)

In this scenario, because the facility's information pertaining to manganese was available to two decimal places, 0.99 was used to
determine the amount below the de minimis concentrations. If the information was available to one decimal place, 0.9 should be
used, as in the scenario below.

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
is:
 '(8,000,000X1 -2% ~ 0.9%)
           (l.2%+ 1.0%)'
         (l.2%-0.2%)
        = 26,400 pounds manganese (which is above the processing threshold for manganese)
                                                    = 26,4QQpounds
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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 subject to a 0.1% (1000 ppm) de minimis limit. Any amount of chloroform manufactured and separated as
  byproduct must be included in threshold determinations because 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 NAICS
codes 212111,  212112 and 212113, 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 NAICS
codes 212221, 212222, 212231, 212234, and 212299, 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.
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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:

   •  25,000 pounds per toxic chemical or category
      over the calendar year.

You must submit a report for any EPCRA section 313
chemical, which is not listed as a PBT chemical, that is
otherwise used at your facility in excess of the following
threshold:

   •  10,000 pounds per toxic chemical or category
      over the calendar year.

You must submit a report for any EPCRA section 313
chemical, which is listed as a PBT chemical, that is
manufactured, processed or otherwise used at your
facility above the designated threshold for that chemical.

The chemical names, CAS numbers and their reporting
thresholds are listed in the table below. See Table He of
these instructions for lists of individual members of the
dioxin and dioxin-like compounds chemical category
and  the polycyclic  aromatic  compounds  chemical
category.

Chemical or chemical
category name
Aldrin
Benzo[g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds category
(manufacturing; and the
processing or otherwise
use of dioxin and dioxin-
like compounds category
if the dioxin and dioxin-
like compounds are
present as contaminants
in a chemical and if they
were created during the
manufacturing of that
chemical
CAS
number or
chemical
category
code
309-00-2
191-24-2
57-74-9
N150



Threshold
(pounds,
unless
noted
otherwise)
100
10
10
0.1 gram



Heptachlor
Hexachlorobenzene
Chemical or chemical
category name
Isodrin
Lead (this lower
threshold does not apply
to lead when it is
contained in stainless
steel, brass or bronze
alloy)
Lead compounds
Mercury
Mercury compounds
Methoxychlor
Octachloro sty rene
Pendimethalin
Pentachlorobenzene
Poly chlorinated
biphenyls (PCBs)
Polycyclic aromatic
compounds category
(PACs)
Tetrabromobisphenol A
Toxaphene
Trifluralin
76-44-8
118-74-1
CAS
number or
chemical
category
code
465-73-6
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
10
10
Threshold
(pounds,
unless
noted
otherwise)
10
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 2 A 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.
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27

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     How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Complete the appropriate worksheet for each EPCRA
section  313 chemical or  chemical category. (The
worksheets can be found at the end of sectionB.4.) Base
your threshold determination for EPCRA section 313
chemicals  with qualifiers only on the quantity of the
EPCRA section 313 chemical satisfying the qualifier.

Use of the worksheets is divided into three steps:

   •  Step 1 allows you to record the gross amount of
      the EPCRA section 313 chemical or chemical
      category involved in activities throughout the
      facility. Pure forms as well as the amounts of the
      EPCRA section 313 chemical or  chemical
      category present in mixtures or other trade name
      products  must be  considered.  The  types  of
      activity (i.e.,  manufacturing, processing,  or
      otherwise using) for which the EPCRA section
      313 chemical is used must be identified because
      separate thresholds  apply to each  of these
      activities. A record of the information source(s)
      used  should be  kept. Possible  information
      sources include purchase records, inventory data,
      and calculations by a process engineer. The data
      collected in Step 1 will  be totaled for each
      activity to identify the  overall  amount of the
      EPCRA section 313 chemical or  chemical
      category  manufactured (including imported),
      processed, or otherwise used.

   •  Step 2 allows you to identify uses of the EPCRA
      section 313 chemical or chemical category that
      were included in Step 1 but are exempt under
      EPCRA section 313.  Do not include in Step 2
      exempt quantities of the EPCRA section 313
      chemical not included in the calculations in Step
      1.  For example,  if  Freon  contained  in  the
      building's air conditioners was not reported in
      Step  1, you would not include  the amount as
      exempt in Step 2. Step 2 is intended for use
      when a quantity or use of the EPCRA section
      313 chemical is exempt while other quantities
      require reporting. Note the type of exemption for
      future reference. Also identify, if applicable, the
      fraction or percentage of the EPCRA section 313
      chemical  present that  is exempt.  Add  the
      amounts in each activity to obtain a subtotal for
      exempted  amounts of the EPCRA section 313
      chemical or chemical categories at the facility.

   •  Step 3 involves subtracting the result of Step 2
      from the results of Step 1  for each activity.
      Compare this net sum to the applicable activity
      threshold. If the threshold is 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 fromyour
                                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
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     How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
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 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.  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
FormRs.  SeeB.5.)
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     How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
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 andbioaccumulate 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 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:

                                  •  If you only know the upper bound concentration,
                                     you must use it for threshold determinations (40
                                     CFR section 372.30(b)(ii)).

                                  •  If you  know  the  lower  and  upper bound
                                     concentrations  of an  EPCRA   section  313
                                     chemical in a mixture, EPA recommends you use
                                     the midpoint of these two concentrations for
                                     threshold determinations.

                                  •  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.

                                  •  If you have no information other than the lower
                                     bound concentration,  EPA recommends  you
                                     calculate a midpoint assuming an upper bound
                                     concentration of 100%.

                                  •  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
30
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

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 Form R. 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

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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#l: Your facility otherwise uses 12,000 poundsofan 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.
3 2                      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
Facility Name:	
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:	
Reporting Year:	
            Date Worksheet Prepared:
            Prepared By:	
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
1.
2.
3.
4.
Subtotal:
Information Source





Total Weight (Ib)





Percent EPCRA Section
313 Chemical
by Weight





EPCRA Section 313
Chemical Weight
(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,l Ib
Otherwise Used




(C,l Ib
Amount subject to threshold:
Compare to threshold for EPCRA section 313 reporting.
                 (A-AO	Ib (B-BO_
25,000 Ibs 25,000 Ibs     10,000 Ibs
Ib
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R or Form A; retain it for your records.

                        Figure 2A. EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet1
         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
                                                      33

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                       How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Facility Name:	
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:	
Reporting Year:	
                                                      Date Worksheet Prepared:
                                                      Prepared By:	
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or
Other Identifier
1.
2.
3.
4.
Subtotal:
Information
Source





Total Weight (Ib)





Percent EPCRA Section
313 Chemical
by Weight





EPCRA Section 313
Chemical Weight
Ob)





Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (Ib.):
Manufactured




(A) Ib
Processed




(B) Ib
Otherwise Used




(0 Ib
Exempt quantity of the EPCRA Section 313 chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (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
                                                                                                   (A-AO_
                                                                     Ib (B-BO_
Amount subject to threshold:
Compare to threshold for EPCRA section 313 reporting.                                      100 Ibs 100 Ibs          100 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.

        Figure 2B. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100 Pound Thresholds
Ib
        1 Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
34
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
Facility Name:	
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:	
Reporting Year:	
Date Worksheet Prepared:
Prepared By:	
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
1.
2.
3.
4.
Subtotal:
Information Source





Total Weight (Ib)





Percent EPCRA
Section 313 Chemical
by Weight





EPCRA Section 313
Chemical Weight
(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
                                                                                                   (A-AO_
                Ib (B-BO_
Amount subject to threshold:
Compare to threshold for EPCRA section 313 reporting.                                      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 or Form A; retain it for your records.

         Figure 2C. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10 Pound Thresholds
Ib
        1 Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
                                        Toxics Release Inventory Reporting Forms and Instructions
                                        35

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                       How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
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.
                                                                                              Date Worksheet Prepared:
                                                                                              Prepared By:	
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) g
Processed




(B) 	 g
Otherwise Used




(C) g
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




(AO g
Processed




(BO 	 g
Otherwise Used




(C,) g
                                                                                                     (A-AO_
Amount subject to threshold:
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.
.g(c-co_
  Figure 2D. EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like Compounds Chemical Category
        1 Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
36
                                        Toxics Release Inventory Reporting Forms and Instructions

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                              Instructions for Completing TRI Form R
C. Instructions for Completing TRI
    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 2007 reporting year must be submitted
on or before July  1, 2008.

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    See last year's Reporting Forms and Instructions.

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 OR TRI-MEweb. "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 orNAICS 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.
                      Toxics Release Inventory Reporting Forms and Instructions
                                            37

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                               Instructions for Completing TRI Form R
You should enter "New Facility" in the space for the TRI
Facility  Identification  number if this is your first
submission.
                                                4.3
          Technical Contact
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 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.)
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 form. You should also enter an e-
                                                mail address for this person. If you choose to designate
                                                the same person as both the Technical and the Public
                                                Contact, or you do not have a 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 form or signs the Certification Statement
                                                and does not necessarily need to be someone  at the
                                                location of the reporting facility.

                                                4.5       North American Industry
                                                          Classification System (NAICS) Code

                                                The North American Industry Classification System
                                                (NAICS) is the economic classification system that
                                                replaces the 1987 SIC code system for TRI Reporting
                                                beginning with the  RY 2006 EPCRA section 313
                                                reporting (71FR 32464). Enter the appropriate six-digit
                                                North  American  Industry  Classification  System
                                                (NAICS) Code that is the primary NAICS code foryour
                                                facility in Section 4.5(a). For Reporting Year 2007, use
                                                2002 NAICS codes. Enter any other applicable NAICS
                                                for your facility in 4.5 (b)-(f). The table on p.8 of this
                                                document lists the covered NAICS codes. If you do not
                                                know your NAICS  code, consult the  2002 NAICS
                                                Manual (see  Section B.2 of  these  instructions for
                                                ordering  information)  or check  the  SIC to NAICS
                                                crosswalk tables at www.census.gov.

                                                4.6       Latitude and Longitude

                                                     (Deleted)
38
             Toxics Release Inventory Reporting Forms and Instructions

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                             Instructions for Completing TRI Form R
4.7
Dun & Bradstreet Number(s)
Enter the nine-digit number assigned by Dun & Bradstreet
(D & B) for your facility or each establishment withinyour
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)

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 isyour ultimate U.S. parent company. Ifyour
facility has no parent company, you should check the
NAbox.

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.
Ifyour parent company does not have a D & B number,
you should check the NA box.
                      Toxics Release Inventory Reporting Forms and Instructions
                                                                                         39

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                       Instructions for Completing Part II of EPA Form R
Part II.  Chemical Specific
           Information
In Part II, you are to report on:

   •  The  EPCRA  section  313  chemical  being
      reported;
   •  The  general uses and activities involving the
      EPCRA section 313 chemical at your facility;
   •  On-site releases of the EPCRA section 313
      chemical from the facility to air, water, and land;
   •  Quantities of the EPCRA section 313 chemical
      transferred to off-site locations;
   •  Information  for on-site  and  off-site disposal,
      treatment, energy recovery, and recycling of the
      EPCRA section 313 chemical; and
   •  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
N090    Chromium compounds
N096    Cobalt compounds
N100    Copper compounds
N106    Cyanide compounds
N120    Diisocyanates
Nl 50    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)
N5 83    Poly chlorinated alkanes (C10 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
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
40
             Toxics Release Inventory Reporting Forms and Instructions

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                        Instructions for Completing Part II of EPA Form R
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 betweenO.Ol 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
There are  17 individual chemicals listed in the dioxin
and dioxin-like compounds category. Each of these
chemicals  are assigned a number from 1 to  17. These
numbers correspond to the boxes in Section 1.4.  The
individual chemicals in the dioxin  and dioxin-like
compounds category and their number are in the matrix
below:
1
2
3
4
5
6


67562-39-4
55673-89-7
70648-26-9
57117-44-9
72918-21-9
60851-34-5


1, 2,3,4 ,6,7,8-Heptachlorodibenzofuran
1,2,3,4,7,8,9-Heptachlorodibenzofuran
1,2,3,4,7,8-Hexachlorodibenzofuran
1,2,3,6,7,8-Hexachlorodibenzofuran
1,2,3,7,8,9-Hexachlorodibenzofuran
2,3,4 ,6,7,8-Hexachlorodibenzofuran


1
7

8

9
10
11

P

13
14
15
16
17
67562-39-4
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-Hexachlorodibenzo- p-
dioxin
1,2,3,6,7,8-Hexachlorodibenzo- p-
dioxin
1,2,3,7,8,9-Hexachlorodibenzo- p-
dioxin
1 ,2,3,4,6,7,8-Heptachlorodibenzo- p-
dioxin
1,2,3,4,6,7,8,9-
Octachlorodibenzofuran
1 ,2,3,4,6,7,8,9-Octachlorodibenzo- p-
dioxin
1 ,2,3,7,8-Pentachlorodibenzofuran
2,3,4,7,8-Pentachlorodibenzofuran
1,2,3,7,8-Pentachlorodibenzo- p-
dioxin
2,3,7,8-Tetrachlorodibenzofuran
2,3,7,8-Tetrachlorodibenzo-p-dioxin
Section 2.   Mixture Component
                Identity

Do not complete  this section if you have completed
Section 1 of Part II. Report the generic name provided to
you by your supplier in this section if your supplier is
claiming the chemical identity proprietary or trade secret.
Do not answer "yes" in Part I, Section 2.1 on page 1 of
the form if you complete this section. You do not need to
supply trade secret substantiation forms for this EPCRA
section 313 chemical because it is your supplier who is
claiming the chemical identity a trade secret.
 Example  10:  Mixture  Containing
 EPCRA Section 313 Chemical
Unidentified
                                                         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.
                       Toxics Release Inventory Reporting Forms and Instructions
                                              41

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                       Instructions for Completing Part II of EPA Form R
2.1      Generic Chemical Name Provided by
         Supplier

Enter the generic chemical name in this section only if
the following three conditions apply:

     1.) You determine that the mixture contains an
EPCRA section 313 chemical but the only identity you
have for that chemical is a generic name;

     2.) You know either the specific concentration of
that  EPCRA section 313 chemical component or a
maximum or average concentration level; and

     3.) You multiply the concentration level by the
total annual amount of the whole mixture processed or
otherwise used and determine that you meet the process
or otherwise use threshold for that single, genetically
identified mixture component.


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.
42                    Toxics Release Inventory Reporting Forms and Instructions

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                        Instructions for Completing Part II of EPA Form R
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.
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)

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.
                       Toxics Release Inventory Reporting Forms and Instructions
                                              43

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                           Instructions for Completing Part II of EPA Form R
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 1. TOXIC CHEMICAL IDENTITY
                                                    (Important: DO NOT complete this section if you completed Section 2 below.)
   1.1
        CAS Number (Important: Enter onty one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
          334-88-3
   1.2
        Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
          Diazomethane
   1.3
        Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name musl be structurally descriptive)
   1.4  Distribution of Each Member of the Dioxin and Oioxin-like Compounds Category.
        (If there are any numbers in boxes 1-17. (hen every field musl 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      456     7      B      9      10     11     12     13     14     15     16     17
  I"ALJ      I       I      I       I      I      I      I       I      I       I      I       I      I       I      I       I
   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 ol 70- characters, including numbers, letters, spaces, and punctuation}
   SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
                (Important: Check alt that apply.)
   3.1    Manufacture the toxic chemical:
                 3.2  Process the toxic chemical:
3.3  Otherwise use the toxic chemical:
      a.  I X I  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 a chemical processing aid
        As a manufacturing aid
        Ancillary or other use
                                             e.      As an impurity
                           Figure 3. Reporting EPCRA Section 313 Chemicals
44
Toxics Release Inventory Reporting Forms and Instructions

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                        Instructions for Completing Part II of EPA Form R
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.
Weight Range in Pounds
Example  11: Manufacturing and  Processing  Activities  of
EPCRA Section 313 Chemicals

In the two examples below, it is assumed that  the threshold
quantities  for manufacture, process,  or otherwise use (25,000
pounds, 25,000 pounds, and 10,000 pounds, respectively for non-
PBT chemicals; 100 pounds for certain PBT chemicals; 10 pounds
for highly persistent, highly bioaccumulative toxic chemicals; and
0.1 grams for the PBT chemical category comprised of dioxin and
dioxin-like compounds) have been exceeded and the reporting of
EPCRA section 313 chemicals is therefore required.

1. Your facility manufactures diazomethane. Fifty percent is sold as
a product, thus it is processed. The remaining fifty  percent is
reacted with  alpha-naphthylamine,  forming N-methyl-alpha-
naphthylamine and also producing nitrogen gas.

D    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.

D    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.
Range Code
01
02
03
04
05
06
07
08
09
10
11
     From..
         0
       100
     1,000
    10,000
    100,000
  1,000,000
 10,000,000
 50,000,000
100,000,000
500,000,000
1 billion
      To...
        99
       999
     9,999
    99,999
    999,999
  9,999,999
 49,999,999
 99,999,999
499,999,999
999,999,999
more than 1 billion
If the EPCRA section 313  chemical present at your
facility was part of a mixture or other trade name product,
determine the maximum quantity of the EPCRA section
313 chemical present at the  facility by calculating the
weight percent of the EPCRA section 313 chemical only.

Do not include  the weight of the entire mixture or other
trade name product. These data may be found in the Tier
II form your facility may have prepared under Section
312 of EPCRA. See Part 40, Section 372.30(b) of the
Code of Federal Regulations for further information on
how to calculate the weight of the EPCRA section 313
chemical in the mixture or other trade name product. For
EPCRA section 313 chemical categories  (e.g., nickel
compounds), include all chemical compounds in the
category when  calculating the maximum amount, using
the entire weight of each compound. 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
                       Toxics Release Inventory Reporting Forms and Instructions
                                              45

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                        Instructions for Completing Part II of EPA Form R
management quantities greater than 0.1 pound (except
the dioxin  and  dioxin-like  compounds  category),
provided the accuracy and the underlying data on which
the estimate is based supports this level of precision.

For the dioxin  and dioxin-like compounds category,
facilities should report at a level of precision supported
by  the accuracy  of the  underlying  data and  the
estimation techniques on which the estimate is based.
For the dioxin  and dioxin-like compounds chemical
category, which has a reporting threshold of 0.1 gram,
facilities need only report all release and other waste
management quantities  greater than  100 micrograms
(i.e., 0.0001 grams). (See example 12.) Notwithstanding
the numeric precision used when determining reporting
eligibility thresholds, facilities should report on Form R
to the level of accuracy that their data supports, up to
seven digits to the right of the decimal. EPA's reporting
software and data  management systems  support data
precision up to seven digits to the right of the decimal.
Example  12:  Reporting Dioxins  and Dioxin-Like
Compounds

If the total quantity for Section 5.2 of the Form R (i.e.,
stack or point air emissions) is 0.00005 grams or less,
then zero can be entered. If the total quantity is between
0.00005 and 0.0001 grams, then 0.0001 grams can be
entered or the  actual number can be entered  (e.g.,
0.000075).
NA vs. a Numeric Value (e.g., Zero). Generally, NA is
applicable if the waste stream that contains or contained
the EPCRA section 313 chemical is not directed to the
relevant environmental medium, or if leaks, spills and
fugitive emissions cannot occur. If the waste stream that
contains or contained the EPCRA section 313 chemical
is  directed to the environmental medium, or if leaks,
spills or fugitive emissions can occur, NA 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. l.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
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                        Instructions for Completing Part II of EPA Form R
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 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-Siteto
          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 II-VWells
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. aNumeric 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.

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 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
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                        Instructions for Completing Part II of EPA Form R
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). Forthe 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
FormR.

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).

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.
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                        Instructions for Completing Part II of EPA Form R
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 and otherwise managed waste estimate
(Sections  5 &  6), you  are  required to indicate the
principal method used to determine the amount of release
and otherwise managed waste reported. You should enter
a letter code identifying the method that applies to the
largest portion of  the  total estimated release  and
otherwise managed waste quantity.

The codes are as follows:

M1     Estimate is based on continuous monitoring data
        or measurements for the EPCRA section 313
        chemical
M2     Estimate is based on periodic or  random
        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 streams entering and
        leaving process equipment.
E1      Estimate is based on published emission factors,
        such as  those  relating  release quantity to
        through-put  or  equipment  type  (e.g.,  air
        emission factors).
E2      Estimate is  based on site specific 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.

For example,  if 40 percent of stack emissions of the
reported EPCRA §313 chemical were  derived using
source testing data, 30 percent by mass balance, and 30
percent by published chemical-specific emission factors,
you should enter the code letter "M2" for periodic or
random emission monitoring.

If the monitoring data, mass balance, or emission factor
used to estimate the release is not specific to the EPCRA
§313 chemical being reported, the form should identify
the estimate as based on other methods of estimation (O).

If a mass balance calculation yields the flow rate of a
waste, but the quantity  of reported  EPCRA  §313
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                         Instructions for Completing Part II of EPA Form R
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 §313 chemical in the waste.

If the concentration of the EPCRA §313 chemical in the
waste  was  measured   by  continuous  emissions
monitoring equipment and the flow rate of the waste
was determined by mass balance, then the primary basis
of the  estimate  should  be "continuous  emission
monitoring" (Ml).  Even though a  mass  balance
calculation also contributed to the estimate, "continuous
emission  monitoring" should be indicated  because
monitoring data were used to estimate the concentration
of the chemical in waste.

Mass  balance  (C)  should only  be indicated if it is
directly used to calculate the mass (weight) of EPCRA
§313  chemical released. Monitoring  data should be
indicated as the basis of estimate only if the EPCRA
§313 chemical concentration is measured in the waste.
Monitoring data should not be indicated, for example, if
the  monitoring data  relate to a  concentration of the
EPCRA §313 chemical in other process streams within
the facility.

It is  important to  realize  that the  accuracy  and
proficiency of release estimation will improve overtime.
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 in column C. 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
                                 Industrial
                                      Railroad yard areas
                                      Unimproved areas
                                 Streets
                                      Asphaltic
                                      Concrete
                                      Brick
                                      Drives and walks
                                      Roofs
                                 Lawns: Sandy Soil
                                      Flat, 2%
                                      Average, 2 - 7%
                                      Steep, 7%
                                 Lawns: Heavy Soil
                                      Flat, 2%
                                      Average, 2 - 7%
                                      Steep, 7%
Runoff Coefficient
0.70-0.95
0.50-0.70

0.50-0.80
0.60-0.90

0.20-0.40
0.10-0.30

0.70-0.95
0.80-0.95
0.70-0.85
0.70-0.85
0.75-0.95

0.05-0.10
0.10-0.15
0.15-0.20

0.13-0.17
0.18-0.22
0.25-0.35
                                 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:

                                 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.
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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:

                                                             Runoff
         Land Use                % Total Area               Coefficient
         Unimproved area         50        0.20
         Asphaltic streets           10        0.85
         Concrete pavement 40     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 103 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%
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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 43). 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 corner of
                                 each box, the section number is either 6. l.B._. or 6.2._.

                                 If you report a transfer of the listed EPCRA section 313
                                 chemical to one or more POTWs, you should number the
                                 boxes in Section 6.1.B as 6.I.B.I, 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 6.1 .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. LA, estimate the quantity of the reported
                                 EPCRA section 313 chemical transferred to all publicly
                                 owned treatment works  (POTWs) and the basis upon
                                 which the estimate was  made. In Section  6. I.E., 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
52
Toxics Release Inventory Reporting Forms and Instructions

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                        Instructions for Completing Part II of EPA Form R
chemical. The most common transfers of this type will
be  conveyances of  the  toxic  chemical  in facility
wastewater  through  underground  sewage  pipes;
however, materials may also be trucked or transferred
via some other direct methods to a POTW.

If you do  not  discharge wastewater containing  the
reported EPCRA section 313 chemical to a POTW, enter
NA in the box for the POTW's name in Section 6. l.B._
(See discussion of NA vs. a Numeric Value (e.g., Zero)
in the introduction of Section 6).

6.1.A.1   Total Transfers
Enter the  total  amount, in pounds, of the reported
EPCRA section 313 chemical that is contained in the
wastewaters transferred to all POTWs. Do not enter the
total poundage of the wastewaters. If the total amount
transferred is less than 1,000 pounds, you may report a
range by entering the appropriate range code  (range
reporting in section 6.I.A.I does not  apply to PBT
chemicals). The following reporting range codes are to
be used:
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999
6.1.A.2  Basis of Estimate
You must identify the basis foryour 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.

Ml     Estimate  is based on continuous monitoring
        data or measurements for the EPCRA section
        313 chemical.
M2     Estimate  is based on  periodic  or  random
        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  streams
        entering and leaving process equipment.
El      Estimate  is based  on published emission
        factors, such as those relating release quantity
        to  through-put or equipment  type (e.g., air
        emission factors).
E2      Estimate  is based on site  specific 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 streambefore 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 46
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
                       Toxics Release Inventory Reporting Forms and Instructions
                                                                                      53

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                         Instructions for Completing Part II of EPA Form R
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 orprovince 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.
                                  of the EPCRA section 313 chemical that is contained in
                                  the waste transferred to that location. Do not enter the
                                  total quantities 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
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),
                       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
"From "Releases During Cleaning of Equipment." Prepared by PEI Associates, Inc., for the U.S. Environmental Protection Agency,
Office of Pesticides and Toxic Substances, Washington DC, Contract No. 68-02-4248. June 30, 1986.
bThe values listed in this table should only be applied to similar vessel types, unloading methods, and bulk fluid materials. At viscosities
greater than 200 centipoise, the residue quantities can rise dramatically and the information on this table is not applicable.
Tor kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
dFor water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
Tor motor oil, viscosity = 94 centipoise, surface tension = 34.5 dynes/cm2
fFor surfactant solution, viscosity = 3 centipoise, surface tension = 31.4 dynes/cm2
54
Toxics Release Inventory Reporting Forms and Instructions

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                          Instructions for Completing Part II of EPA Form R
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.
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.
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.
If you transfer the EPCRA  section 313 chemical in
wastes to an off-site facility  for distinct and multiple
                         Toxics Release Inventory Reporting Forms and Instructions
                                                 55

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                        Instructions for Completing Part II of EPA Form R
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.
Ml
M2
C
El
E2
O
        Estimate is based on continuous monitoring
        data or measurements for the EPCRA section
        313 chemical.
        Estimate is  based  on periodic  or random
        monitoring data or measurements  for the
        EPCRA section 313  chemical.
        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.
        Estimate is  based  on  published  emission
        factors, such as those relating release quantity
        to through-put  or equipment type  (e.g., air
        emission factors).
        Estimate is based on site specific  emission
        factors, such as those relating release quantity
        to through-put  or equipment type  (e.g., air
        emission factors).
        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/En ergy 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 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:
                                                         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
56
                       Toxics Release Inventory Reporting Forms and Instructions

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                         Instructions for Completing Part II of EPA Form R
M67    Other Surface Impoundments
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
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
                                               57

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                       Instructions for Completing Part II of EPA Form R
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATION
6.2.1
Off-Site EPA Identification Number (RCRA No.)
COD56616
2461
Off-Site Location Name . „ , . 0
Ar-tvio Weicto "JeM-wir-ae



Street Address , _
^ \gn-rli-at C+*-l(W/2
f^nrnHns

tion, Inc.
5432

5 Facility Road
Dumfry
pn

Zip Code

A. Total Transfers (pounds)/year)
(enter range code or estimate)
1.
2.
12,500
NA


3.
4.


on«nn ls locati°n under ex
8U3UU facility or parent co

1. O
2.
3.
4.
County
Bums

jntrol of reporting •—] y vg\ No
mpany
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1 M54
2. M
3. M
4. M
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.

           Figure 4. Hypothetical Section 6.2 Completed for Two Off-Site Locations
58
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 column c and Section 7A column
e were previously deleted from Form R and are not
addressed below.)

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 7 A of Form R.

In  Section  7A, you  must  provide  the following
information if you treat waste  streams containing the
reported EPCRA section 313 chemical on-site:

(a)     The general waste stream types containing the
       EPCRA section 313 chemical being reported;
(b)     The waste treatment method(s) or sequence
       used on  all waste streams containing the
       EPCRA section 313 chemical; 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)
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  that  of process
wastewater.

7A Column b:  Waste Treatment Method(s)
         Sequence
Enter the appropriate waste treatment code from the list
below for each on-site waste treatment method used on a
waste stream containing the EPCRA section  313
chemical, regardless of whether the  waste  treatment
method actually removes the specific EPCRA section
313 chemical being reported. Waste treatment methods
must be reported for each type of waste 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 7A. la had
nine treatment methods applied to it, the ninth method
would be indicated in the first method box for  row
                       Toxics Release Inventory Reporting Forms and Instructions
                                             59

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                          Instructions for Completing Part II of EPA Form R
7A.2a. The numeral "1" would be crossed out, and a "9"         scenario below, for instance, the second general waste
would be inserted.                                           stream would be reported in row 7 A. 3a. See Figure 5 for
                                                            an example of a hypothetical section 7A.
Treatment  applied to any other general waste stream
types would then be listed in the next empty row. In the
                     Example 16: Calculating Releases and Other Waste Management Quantities

Your facility disposes of 14,000 pounds of lead chromate (PbCrO^.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)                                        Molecular weight = 546.37
        Lead (2 Pb atoms)                                   Atomic weight = 207.2 x 2 = 414.4
        Chromium (1 Cr atom)                                       Atomic weight = 51.996

        Lead chromate is therefore (% by weight)

 (414.4/546.37) = 75.85% lead and
                                          (51.996/546.37) = 9.52% chromium

Lead Selenite (PbSeO4)                                      Molecular weight = 350.17
        Lead (1 Pb atom)                                    Atomic weight = 207.2
        Selenium (1 Se atom)                                 Atomic weight = 78.96

        Lead selenite is therefore (% by weight)
                                          (207.2/350.17) = 59.17% lead and
                                          (78.96/350.17) = 22.55% selenium.

The total pounds of lead, chromium, and selenium disposed on or off-site from your facility are as follows:

Lead
Disposal on-site:                   0.7585 x 14,000 = 10,619 pounds from lead chromate
Transfer off-site for disposal: 0.5917 x 16,000 = 9,467 pounds from lead selenite

Chromium
Disposal on-site:                   0.0952 x 14,000 = 1,333 pounds from lead chromate

Selenium
Transfer off-site for disposal: 0.2255 x 16,000 = 3,608 pounds from lead selenite
60                     Toxics Release Inventory Reporting Forms and Instructions

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                        Instructions for Completing Part II of EPA Form R
                                  Figure 5. Hypothetical Section 7A
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 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.  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:
                q-E)xioo%
                i
where:
1 =
        amount of the EPCRA section 313 chemical in
        the influent waste stream (entering the waste
        treatment step or sequence) and
E =     amount of the EPCRA section 313 chemical in
        the effluent waste  stream (exiting the waste
        treatment step or sequence).
Calculate  the  amount of the EPCRA  section  313
chemical in the influent waste stream by multiplying the
concentration (by weight) of the  EPCRA section 313
chemical in the waste stream by the total amount or
weight of the waste stream.  In most cases, the percent
removal compares the treated effluent to the influent for
the particular type of waste stream. For solidification of
wastewater, the waste treatment efficiency can be
reported as code El  (greater than 99.9999%) if no
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                        Instructions for Completing Part II of EPA Form R
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.

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%
                                 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
                                 If your facility  uses more than one  on-site energy
                                 recovery method for the reported EPCRA  section 313
                                 chemical, list the methods used in descending order
                                 (greatest to least) based on the amount of the EPCRA
                                 section 313 chemical entering such methods.

                                 Section  7C On-Site Recycling Processes
                                 In Section 7C, you must report the recycling methods
                                 used on the EPCRA section 313 chemical.

                                 In this section, use the  codes below to report only the
                                 recycling  methods in place  at your facility that are
                                 applied to the EPCRA section 313 chemical. Do not list
                                 any  off-site recycling  activities. (Information about
                                 off-site recycling must be reported in Part II, Section 6,
                                 "Transfers of the Toxic  Chemical in Wastes to Off-Site
                                 Locations.")

                                 NA vs. a Numerical Value (e.g., Zero). If you do not
                                 perform  on-site  recycling for the reported  EPCRA
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                        Instructions for Completing Part II of EPA Form R
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
H20    Solvent   recovery   (including  distillation,
        evaporation, fractionation or extraction)
H39    Other  recovery  or reclamation for  reuse
        (including acid regeneration or other chemical
        reaction process)

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).
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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 sy stem 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. 1 a 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.
7A.ld
E4

 Chemical B
7A.la
W

7A.lb
3.H123
6.
1.H124
4.N/A
7.
2. H121
5.
8.
7A.ld
E5

 Chemical C
7A.la
W

7A.lb
3.H123
6.
1.H124
4.N/A
7.
2. H121
5.
8.
7A.ld
El

 Note that the quantity removed and/or destroyed is not reported in Section 7 and that the efficiency reported in Section 7A. Id
 refers to the amount of EPCRA section 313 chemical destroyed and/or removed from the applicable waste stream. The amount
 actually destroyed should be reported in Section 8.6 (quantity treated on-site). For example, when completing the Form R for
 Chemical B you should report "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 7.5 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.	
                         Toxics Release Inventory Reporting Forms and Instructions                 65

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                        Instructions for Completing Part II of EPA Form R
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 12 on page 43).
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
                                 8.1b,  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, 2008 (reporting year
                                 2007), the prioryear is 2006. 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.

                                 Column B:  Current Reporting Year

                                 Quantities for Sections 8.1 through 8.7 must be reported
                                 for the current reporting year in column B.
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                         Instructions for Completing Part II of EPA Form R
Columns C and D:  Following Year and
          Second Following Year

Quantities  for Sections 8.1  through 8.7  must be
estimated for 2008 and 2009. EPA expects reasonable
future  quantity estimates  using  a   logical basis.
Information available at the facility to estimate quantities
of the  chemical expected during these years include
planned source reduction activities, market projections,
expected contracts,  anticipated new  product  lines,
company growth projections, and production capacity
figures.  Respondents  should  take   into   account
protections available for trade secrets as provided in
EPCRA section 322 (42 USC 11042) for the  chemical
identity.

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 Re portable 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,
   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).
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
(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. Ib as
appropriate. Toxic chemicals sent off site for disposal are
reported in 8. Ic or 8. Id.

§8.1a = § 5.4.1 + § 5.5.1A + § 5.5.1B  - § 8.8 (on-site
release or disposal due to catastrophic events)1
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                         Instructions for Completing Part II of EPA Form R
§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 8.1d. Toxic chemicals transferred off
site to POTWs or other  off-site locations should be
reported  in 8.1c or 8. Id as appropriate. For example,
quantities of a toxic chemical sent to  a  POTW and
subsequently sent to a landfill are reported in Section
8.1c.  Quantities of the toxic  chemical 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. Ic 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  enter NA 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:
                                          28.8 includes quantities of toxic chemicals disposed or
                                  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.
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        (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, 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 8.8.

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%).
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                         Instructions for Completing Part II of EPA Form R
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 2007 divided by the amount of
        EPCRA section 313 chemical manufactured in
        2006; or
 (2)     Amount of product produced in 2007 divided
        by the amount of product produced in 2006.
                                     Example 20: Quantity Released to the Environment as a
                                     Result of Remedial Actions, Castastrophic
                                     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).
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.
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                          Instructions for Completing Part II of EPA Form R
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 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).
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                           Instructions for Completing Part II of EPA Form R
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 1.33 (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).	


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). You estimate 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.	

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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)
TO 3     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
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                        Instructions for Completing Part II of EPA Form R
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-MEweb or TRI-MEto 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
        Lanham, 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.
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                    Facility Eligibility Determination for Alternate Threshold
                    and for Reporting on TRI Form A Certification Statement
D. Facility Eligibility
    Determination for Alternate
    Threshold and for Reporting on
    EPA Form A
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.  Note that the  eligibility
criteria for the Form A were recently expanded by the TRI
Burden Reduction Rule. The new  criteria are explained
below. For more information about the final rule, see the
TRI Homepage at http://www.epa.gov/tri/.


D.1      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. In  addition, the Agency
recently promulgated the "TRI Burden Reduction Rule"
that expands the original eligibility requirements. 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 FormR. The
Form   A  Certification  Statement provides facilities
otherwise  meeting  EPCRA   section  313  reporting
thresholds the option of certifying on Form A provided that
they meet certain criteria for PBT or non-PBT chemicals.
For non-PBT chemicals the total waste management of the
chemical must not exceed 5000 pounds, releases (both on-
and off-site)  must not  exceed 2000 pounds, and the
amounts manufactured or processed or otherwise used must
not exceed one-million pounds. For PBT chemicals the
facility must have zero releases (both on-site and off-site),
total recycling, treatment  and energy recovery of the
chemical must not exceed  500 pounds, and the amounts
manufactured or processed or otherwise used must not
exceed one-million pounds. Note that Form A does not
apply  to  dioxin and dioxin-like compounds. As with
determining section 313 reporting thresholds, amounts
manufactured,  processed,  or otherwise used  are to be
considered independently.  The current eligibility criteria
for the Form A do not apply to years prior to  Reporting
Year 2006 If you fill out a Form A for an EPCRA section
313 chemical, do not fill  out a Form R for  that same
chemical.
D.2      What is the Form A
           Certification Statement?

The Form A 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 database  in the
same manner that information submitted on Form R
appears. An approved Form A has been included in
this Reporting Forms and Instructions package.


D.3      What Is the Annual
           Reportable Amount?
For the purpose of this optional reporting modification,
the annual reportable amount (ARA) is equal to the
combined total  quantities released at the facility2
(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), 8.7  (quantity
treated off-site) and 8.8 (Quantities that were the result
of remedial actions, catastrophic events, or one-time
events not associated with production processes). The
ARAs for PBT and non-PBT chemicals are different
and are explained below.

   •  PBT Chemicals - Releases both on- and off-
      site must be zero (including releases that would
      be  reportable in  Section  8.8) and   total
      recycling, treatment and energy recovery must
      be 500 pounds or less.

   •  Non-PBT  Chemicals  -  Total  waste
      management must be 5000 pounds or less with
                                                       ' Releases of PBTs must be zero
                      Toxics Release Inventory Reporting Forms and Instructions
                                           75

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                    Facility Eligibility Determination for Alternate Threshold
                    and for Reporting on TRI Form A Certification Statement
      the contribution of releases both on- and off-site
      (including releases that would be reportable in
      Section 8.8) limited to 2000 pounds.
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.
                                                            Do not submit trade secret reports
                                                                electronically or on diskette.
                                  D.7      Metals and Metal
                                             Category Compounds
                                  For metal category compounds, the amount applied
                                  toward the ARA is 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.

                                     •  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.

                                     •  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.

                                     •  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
76
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                    Facility Eligibility Determination for Alternate Threshold
                    and for Reporting on TRI Form A Certification Statement
these  listed  substances,  the facility  may  combine the
appropriate information on the o-xylene, p-xylene, and
xylene (mixed isomers)  into  one FormR, but cannot
combine the reports into one listing on Form A.

Facilities that  process o-xylene,  p-xylene, and xylene
(mixed isomers) in separate process streams and do not
exceed the conditions of the alternate threshold for one or
more of the compounds may submit a separate Form A for
each of the forms of xylene meeting the alternate threshold
and report on Form R for those forms that do not. Similar
to reporting  on the  parent metals and their associated
category  compounds  described  above,  facilities  that
separately process all types (i.e., isomers) of xylene with
individual activity levels within  the conditions of the
alternate threshold should file a separate Form A for each
type of xylene.

Beginning with the  1998 reporting year, facilities may
enter as many chemicals as are eligible on a single Form A.
                      Toxics Release Inventory Reporting Forms and Instructions               77

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                            Instructions for Completing EPA Form A
E. Instructions for Completing
    EPA Form A
For all parts of Form A:

   •  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.)

   •  All information on the Form A is required.

   •  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.

   •  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 2007 must be submitted
on or before July 1, 2008.


Section 2.    Trade Secret Information

2.1      Are you claiming the EPCRA Section
         313 chemical identified on page 3 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 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.
                                  Do not submit trade secret reports
                                   electronically or on  diskette. See
                                   last year's Reporting Forms and
                                               Instructions.
                                 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
                                 40 CFR §372.27. 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
78
Toxics Release Inventory Reporting Forms and Instructions

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                             Instructions for Completing EPA Form A
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
MEweb or 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 or NAICS 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 13423 directs federal facilities to comply
with  Right-To-Know Laws and  Pollution  Prevention
Requirements. Please indicate in 4.2A. if the reporting
facility is a federal facility or in 4.2.B 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
          Public Contact
Enter the name and telephone number (including area
code) of a person who can respond to questions from
the public about the form. You should also enter an e-
mail address for this person. If you choose to designate
the same person as both the Technical and the Public
Contact, or you do not have a 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 form or signs the Certification Statement
and does not  necessarily need to be someone at the
location of the reporting facility.

4.5       North American Industry
          Classification System (NAICS)
          Code

Enter the  appropriate  six-digit  North American
Industry Classification System (NAICS) Code that is
the primary NAICS Code for your facility in Section
4.5(a).  (Use 2002 NAICS codes.)  Enter any other
applicable NAICS for your facility in 4.5 (b)-(f). The
tables described on page 8 list the  required NAICS
codes and their exceptions/ limitations. If you do not
know your NAICS code, consult the 2002 NAICS
Manual  (see  Section B.2 of these instructions for
ordering information) or check  the SIC to NAICS
crosswalk tables at www.census.gov.

The North American Industry Classification System
(NAICS) is the economic classification system that
replaces the  1987 SIC code system. A  Federal
Register notice was published on June 6,2006 (71 FR
32464).  NAICS codes are required on TRI reporting
forms beginning with RY 2006.

4.6       Latitude and Longitude

     (Deleted)
                       Toxics Release Inventory Reporting Forms and Instructions
                                                                                            79

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                            Instructions for Completing EPA Form A
4.7
Dun & Bradstreet Number(s)
Enter the nine-digit number assigned by Dun & Bradstreet
(D & B) for your facility or each establishment withinyour
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 Part I, section 4.7.

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 j oint 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
                                             NAbox.

                                             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.
80
            Toxics Release Inventory Reporting Forms and Instructions

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                             Instructions for Completing EPA Form A
           Part II.    Chemical
           Identification
Reporting on the Alternate Threshold Form A Certification
Statement for metals,  metal category compounds, and
mixed isomers differs somewhat from Form R reporting.
Please refer to Section D for these guidelines.

Section 1.   Toxic Chemical Identity

(Important: DO  NOT complete this  section  if you
completed Section 2 of Part II below.)
1.1
CAS Number
Enter the  Chemical Abstracts  Service (CAS) registry
number in Section 1.1 exactly as it appears in Table II of
these instructions for the chemical being reported.  CAS
numbers are cross-referenced with an alphabetical list of
chemical names in Table II. If you are reporting one of the
EPCRA section 313 chemical categories (e.g., chromium
compounds), 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-l.

EPCRA section 313 Chemical Category Codes:
NO 10   Antimony compounds
N020   Arsenic compounds
N040   Barium compounds
N050   Beryllium compounds
N078   Cadmium compounds
N084   Chlorophenols
N090   Chromium compounds
N096   Cobalt compounds
N100   Copper compounds
N106   Cyanide compounds
N120   Diisocyanates
Nl 50   Dioxin and dioxin-like compounds*
N171   Ethylenebisdithiocarbamic acid, salts and esters
        (EBDCs)
N230   Certain glycol ethers
N420   Lead compounds
N450   Manganese compounds
N458   Mercury compounds
N495   Nickel compounds
N503   Nicotine and salts
N511   Nitrate compounds (water dissociable; reportable
        only when in aqueous solution)
N575   Polybrominated biphenyls (PBBs)
N583   Polychlorinated alkanes (CIO to C13)
N590   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
^Facilities cannot take the  alternate threshold for
dioxin and dioxin-like compounds.

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 folio wed 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
                      Toxics Release Inventory Reporting Forms and Instructions
                                                                                          81

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                            Instructions for Completing EPA Form A
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,
       genetically identified mixture component.
82                    Toxics Release Inventory Reporting Forms and Instructions

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                             Table 1.NAICS Codes
1.1   NAICS codes that
       correspond to SIC codes 20
       through 39:
 311     Food Manufacturing
 3111    Animal Food Manufacturing

 31111   Animal Food Manufacturing

 311111    Dog and Cat Food Manufacturing

 311119    Other Animal Food Manufacturing (except
         facilities primarily engaged in Custom Grain
         Grinding for Animal Feed)

 3112    Grain and Oilseed Milling

 31121   Flour Milling and Malt
         Manufacturing

 311211    Flour Milling

 311212    Rice Milling

 311213    Malt Manufacturing

 31122   Starch and Vegetable Fats and
         Oils Manufacturing

 311221    Wet Corn Milling

 311222    Soybean Processing

 311223    Other Oilseed Processing

 311225    Fats and Oils Refining and Blending

 31123   Breakfast Cereal Manuf.

 311230    Breakfast Cereal Manufacturing

 3113    Sugar and Confectionery
         Product Manufacturing

 31131   Sugar Manufacturing

 311311    Sugarcane Mills

 311312    Cane Sugar Refining

 311313    Beet Sugar Manufacturing
31132  Chocolate and Confectionery
        Manufacturing from Cacao
        Beans

3113 20   Chocolate and Confectionery Manufacturing
        from Cacao Beans

31133  Confectionery Manufacturing
        from Purchased Chocolate

311330   Confectionery Manufacturing from Purchased
        Chocolate (except facilities primarily engaged
        in the retail sale of candy, nuts, popcorn and
        other confections not for immediate
        consumption made on the premises)

31134  Nonchocolate Confectionery
        Manufacturing

3113 40   Nonchocolate Confectionery Manufacturing
        (except facilities primarily engaged in the
        retail sale of candy, nuts, popcorn and other
        confections not for immediate consumption
        made on the premises)

3114   Fruit and Vegetable Preserving
        and Specialty Food
        Manufacturing

31141  Frozen Food Manufacturing

311412   Frozen Specialty Food Manufacturing

31142  Fruit and Vegetable Canning,
        Pickling and Drying

311421   Fruit and Vegetable Canning

311422   Specialty Canning

311423   Dried and Dehydrated Food Manufacturing

3115   Dairy Product Manufacturing

31151  Dairy Product (except Frozen)
        Manufacturing

311511   Fluid Milk Manufacturing

311512   Creamery Butter Manufacturing

311513   Cheese Manufacturing

311514   Dry, Condensed, and Evaporated Dairy
        Product Manufacturing
                     Toxics Release Inventory Reporting Form and Instructions
                                     1-1

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                                   Table 1, NAICS Codes
 31152  Ice Cream and Frozen Dessert
         Manufacturing
 311520   Ice Cream and Frozen Dessert Manufacturing
 3116   Animal Slaughtering and
         Processing
 31161  Animal Slaughtering and
         Processing
 311611   Animal (except Poultry) Slaughtering (except
         for facilities primarily engaged in Custom
         Slaughtering for individuals)
 311612   Meat Processed from Carcasses [except for
         facilities primarily engaged in the cutting up
         and resale of purchased fresh carcasses for the
         trade (including boxed beef)]
 311613   Rendering and Meat Byproduct Processing
 311615   Poultry Processing
 3117   Seafood Product Preparation
         and Packaging
 311711   Seafood Canning
 311712   Fresh and Frozen Seafood Processing
 3118   Bakeries and Tortilla
         Manufacturing
 31181  Bread and Bakery Product
         Manufacturing
 311812   Commercial Bakeries
 311813   Frozen Cakes, Pies, and Other Pastries
         Manufacturing
 31182  Cookie, Cracker, and Pasta
         Manufacturing
         Cookie and Cracker Manufacturing
311821
311822

311823

31183
311830
         Flour Mixes and Dough Manufacturing from
         Purchased Flour
         Dry Pasta Manufacturing

          Tortilla Manufacturing
          Tortilla Manufacturing
                                                3119     Other Food Manufacturing
                                                31191    Snack Food Manufacturing
                                                311911     Roasted Nuts and Peanut Butter
                                                         Manufacturing
                                                311919     Other Snack Food Manufacturing
                                                 3119    Coffee and Tea
                                                2        Manufacturing

                                                 311920    Coffee and Tea Manufacturing
                                                 3119    Flavoring Syrup and
                                                3        Concentrate Manufacturing
                                                 311930    Flavoring Syrup and Concentrate
                                                         Manufacturing
                                                 3119    Seasoning and Dressing
                                                4        Manufacturing
                                                 311941    Mayonnaise, Dressing, and Other Prepared
                                                         Sauce Manufacturing
                                                 311942    Spice and Extract Manufacturing
                                                 3119    All Other Miscellaneous Food
                                                9        Manufacturing
                                                 311991    Perishable Prepared Food Manufacturing
                                                 311999    All Other Miscellaneous Food Manufacturing
                                                312      Beverage and Tobacco
                                                         Product Manufacturing
 3121   Beverage Manufacturing
31211   Soft Drink and Ice
        Manufacturing
 312111   Soft Drink Manufacturing
 312112   Bottled Water Manufacturing (except
        facilities primarily engaged in bottling mineral
        or spring water)
 312113   Ice Manufacturing
 3121   Breweries
2
 312120   Breweries
1-2
                   Toxics Release Inventory Reporting Form and Instructions

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                                   Table I, NAICS Codes
31213   Wineries

 312130   Wineries

 3121   Distilleries
4

 312140   Distilleries

 3122   Tobacco Manufacturing

 3122   Tobacco Stemming and
1       Redrying

 312210   Tobacco Stemming and Redrying

 3122   Tobacco Product
2       Manufacturing

 312221   Cigarette Manufacturing

 312229   Other Tobacco Product Manufacturing
        (except for facilities primarily engaged in
        providing Tobacco Sheeting Services)

 313     Textile Mills
 3131
1
 3131   Fiber, Yarn, and Thread Mills

         Fiber, Yarn, and Thread Mills


 313111   Yarn Spinning Mills

 313112   Yarn Texturizing, Throwing, and Twisting
        Mills

 313113   Thread Mills

3132   Fabric Mills

31321  Broadwoven Fabric Mills

313210   Broadwoven Fabric Mills

31322  Narrow  Fabric Mills and
        Schiffli Machine Embroidery

313221   Narrow Fabric Mills

313222   Schiffli Machine Embroidery

31323  Nonwoven Fabric Mills

313230   Nonwoven Fabric Mills
                                                31324  Knit Fabric Mills

                                                313241   Weft Knit Fabric Mills

                                                313249   Other Knit Fabric and Lace Mills

                                                3133    Textile and Fabric Finishing
                                                         and Fabric Coating Mills

                                                31331  Textile and Fabric Finishing
                                                         Mills


                                                313311   Broadwoven Fabric Finishing Mills (except
                                                         facilities primarily engaged in converting
                                                         broadwoven piece goods and broadwoven
                                                         textiles and facilities primarily engaged in
                                                         sponging fabric for tailors and dressmakers)

                                                313312   Textile and Fabric Finishing (except
                                                         Broadwoven Fabric) Mills (except facilities
                                                         primarily engaged in converting narrow woven
                                                         textiles and narrow woven piece goods)

                                                31332  Fabric Coating Mills

                                                313 3 20   Fabric Coating Mills
                                                314     Textile Product Mills
3141   Textile Furnishing Mills

31411  Carpet and Rug Mills

314110   Carpet and Rug Mills

31412  Curtain  and Linen Mills

314121   Curtain and Drapery Mills (except facilities
        primarily engaged in making custom drapery
        for retail sale)

314129   Other Household Textile Product Mills
        (except facilities primarily engaged in making
        custom drapery for retail sale)

3149   Other Textile Product Mills

31491  Textile Bag and Canvas Mills

314911   Textile Bag Mills

314912   Canvas and Related Product Mills

31499  All Other Textile Product Mills

314991   Rope, Cordage, and Twine Mills
                   Toxics Release Inventory Reporting Form and Instructions
                                                                                      1-3

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                                     Table 1, NAICS Codes
 314992    Tire Cord and Tire Fabric Mills

 314999    All Other Miscellaneous Textile Product Mills
          (except facilities engaged in binding carpets
          and rugs for the trade, carpet cutting and
          binding, and embroidering on textile products
          (except apparel) for the trade)
 315     Apparel Manufacturing
 3151    Apparel Knitting Mills

 31511   Hosiery and Sock Mills

 315111    Sheer Hosiery Mills

 315119    Other Hosiery and Sock Mills

 31519   Other Apparel Knitting Mills

 315191    Outerwear Knitting Mills

 315192    Underwear and Nightwear Knitting Mills

 3152    Cut and Sew Apparel
          Manufacturing

 31521   Cut and Sew Apparel
          Contractors

 315211    Men's and Boys' Cut and Sew Apparel
          Contractors

 315212    Women's, Girls', and Infants' Cut and Sew
          Apparel Contractors

 31522   Men's and Boys'  Cut and Sew
          Apparel Manufacturing

 315221    Men's and Boys' Cut and Sew Underwear and
          Nightwear Manufacturing

 315222    Men's and Boys' Cut and Sew Suit, Coat, and
          Overcoat Manufacturing (except custom
          tailors primarily engaged in making and
          selling men's and boy's suits, cut and sewn
          from purchased fabric)

 315223    Men's and Boys' Cut and Sew Shirt (except
          Work Shirt) Manufacturing (except custom
          tailors primarily engaged in making and
          selling men's and boy's dress shirts, cut and
          sewn from purchased fabric)

 315224    Men's and Boys' Cut and Sew Trouser, Slack,
          and Jean Manufacturing
                               315225    Men's and Boys' Cut and Sew Work Clothing
                                        Manufacturing

                               315228    Men's and Boys' Cut and Sew Other
                                        Outerwear Manufacturing

                               31523   Women's and Girls' Cut and
                                        Sew Apparel Manufacturing

                               315231    Women's and Girls' Cut and Sew Lingerie,
                                        Loungewear, and Nightwear Manufacturing

                               315232    Women's and Girls' Cut and Sew Blouse and
                                        Shirt Manufacturing

                               315233    Women's and Girls' Cut and Sew Dress
                                        Manufacturing (except custom tailors
                                        primarily engaged in making and selling bridal
                                        dresses or gowns, or women's, misses' and
                                        girls' dresses cut and sewn from purchased
                                        fabric (except apparel contractors) (custom
                                        dressmakers)

                               315234    Women's and Girls' Cut and Sew Suit, Coat,
                                        Tailored Jacket, and Skirt Manufacturing

                               315239    Women's and Girls' Cut and Sew Other
                                        Outerwear Manufacturing

                               31529   Other Cut and Sew Apparel
                                        Manufacturing

                               315291    Infants' Cut and Sew Apparel Manufacturing

                               315292    Fur and Leather Apparel Manufacturing

                               315299    All Other Cut and Sew Apparel Manufacturing

                               3159    Apparel Accessories and Other
                                        Apparel Manufacturing

                               31599   Apparel Accessories and Other
                                        Apparel Manufacturing

                               315991    Hat, Cap, and Millinery Manufacturing

                               315992    Glove and Mitten Manufacturing

                               315993    Men's and Boys' Neckwear Manufacturing

                               315999    Other Apparel Accessories and Other Apparel
                                        Manufacturing
                               316     Leather and Allied Product
                                        Manufacturing
1-4
Toxics Release Inventory Reporting Form and Instructions

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                                  Table I, NAICS Codes
3161   Leather and Hide Tanning and
        Finishing
31611  Leather and Hide Tanning and
        Finishing
316110   Leather and Hide Tanning and Finishing
3162   Footwear Manufacturing
31621  Footwear Manufacturing
316211   Rubber and Plastics Footwear Manufacturing
316212   House Slipper Manufacturing
316213   Men's Footwear (except Athletic)
        Manufacturing
316214   Women's Footwear (except Athletic)
        Manufacturing
316219   Other Footwear Manufacturing
3169   Other Leather and Allied
        Product Manufacturing
31699  Other Leather and Allied
        Product Manufacturing
        Luggage Manufacturing
        Women's Handbag and Purse Manufacturing
316991
316992
316993
        Personal Leather Good (except Women's
        Handbag and Purse) Manufacturing
316999   All Other Leather Good Manufacturing
321     Wood Product Manufacturing
3211   Sawmills and Wood
        Preservation
321113   Sawmills
321114   Wood Preservation
3212   Veneer, Plywood, and
        Engineered Wood Product
        Manufacturing
32121  Veneer, Plywood, and
        Engineered Wood Product
        Manufacturing
321211   Hardwood Veneer and Plywood
        Manufacturing
321212   Softwood Veneer and Plywood Manufacturing
321213   Engineered Wood Member (except Truss)
        Manufacturing
321214   Truss Manufacturing
321219   Reconstituted Wood Product Manufacturing
3219   Other Wood Product
        Manufacturing
32191  Millwork
321911   Wood Window and Door Manufacturing
321912   Cut Stock, Resawing Lumber, and Planing
321918   Other Millwork (including Flooring)
32192  Wood Container and Pallet
        Manufacturing
321920   Wood Container and Pallet Manufacturing
32199  All Other Wood Product
        Manufacturing
321991   Manufactured Home (Mobile Home)
        Manufacturing
321992   Prefabricated Wood Building Manufacturing
321999   All Other Miscellaneous Wood Product
        Manufacturing
                                                322     Paper Manufacturing
                                                3221    Pulp, Paper, and Paperboard
                                                        Mills
                                                32211   Pulp Mills
                                                322110   Pulp Mills
                                                32212   Paper Mills
                                                322121   Paper (except Newsprint) Mills
                                                322122   Newsprint Mills
                                                32213   Paperboard Mills
                                                322130   Paperboard Mills
                   Toxics Release Inventory Reporting Form and Instructions
                                                                                     1-5

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                                     Table 1, NAICS Codes
 3222    Converted Paper Product
          Manufacturing
 32221   Paperboard Container
          Manufacturing
 322211    Corrugated and Solid Fiber Box
          Manufacturing
 322212    Folding Paperboard Box Manufacturing
 322213    Setup Paperboard Box Manufacturing
 322214    Fiber Can, Tube, Drum, and Similar Products
          Manufacturing
 322215    Nonfolding Sanitary Food Container
          Manufacturing
 32222   Paper Bag and Coated and
          Treated Paper Manufacturing
 322221    Coated and Laminated Packaging Paper and
          Plastics Film Manufacturing
 322222    Coated and Laminated Paper Manufacturing
 322223    Plastics, Foil, and Coated Paper Bag
          Manufacturing
 322224    Uncoated Paper and Multiwall Bag
          Manufacturing
 322225    Laminated Aluminum Foil Manufacturing for
          Flexible Packaging Uses
 322226    Surface-Coated Paperboard Manufacturing
 32223   Stationery Product
          Manufacturing
 322231    Die-Cut Paper and Paperboard Office Supplies
          Manufacturing
 322232    Envelope Manufacturing
 322233    Stationery, Tablet, and Related Product
          Manufacturing
 32229   Other Converted Paper
          Product Manufacturing
 322291    Sanitary Paper Product Manufacturing
 322299    All Other Converted Paper Product
          Manufacturing
323
3231
32311
323110
323113
323114
323115
323116
323117
323118
323119
32312
323121
323122
324

3241

32411
324110
32412

324121
324122
Printing and Related Support
Activities
Printing and Related Support
Activities
Printing
Commercial Lithographic Printing
Commercial Screen Printing
Quick Printing (except facilities primarily
engaged in reproducing text, drawings, plans,
maps, or other copy by blueprinting,
photocopying, mimeographing, or other
methods of duplication other than printing or
microfilming (i.e., instant printing)
Digital Printing
Manifold Business Forms Printing
Books Printing
Blankbook, Looseleaf Binders, and Devices
Manufacturing
Other Commercial Printing
Support Activities for Printing
Tradebinding and Related Work
Prepress Services
Petroleum and Coal Products
Manufacturing
Petroleum and Coal Products
Manufacturing
Petroleum Refineries
Petroleum Refineries
Asphalt Paving, Roofing, and
Saturated Materials
Manufacturing
Asphalt Paving Mixture and Block
Manufacturing
Asphalt Shingle and Coating Materials
Manufacturing
1-6
Toxics Release Inventory Reporting Form and Instructions

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                                  Table I, NAICS Codes
32419  Other Petroleum and Coal
        Products Manufacturing
324191   Petroleum Lubricating Oil and Grease
        Manufacturing
324199   All Other Petroleum and Coal Products
        Manufacturing
325    Chemical Manufacturing
3251   Basic Chemical Manufacturing
32511  Petrochemical Manufacturing
325110   Petrochemical Manufacturing
32512  Industrial Gas Manufacturing
325120   Industrial Gas Manufacturing
32513  Synthetic Dye and Pigment
        Manufacturing
325131   Inorganic Dye and Pigment Manufacturing
325132   Synthetic Organic Dye and Pigment
        Manufacturing
32518  Other Basic Inorganic
        Chemical Manufacturing
        Alkalies and Chlorine Manufacturing
        Carbon Black Manufacturing
325181
325182
325188
        All Other Basic Inorganic Chemical
        Manufacturing
32519  Other Basic Organic Chemical
        Manufacturing
        Gum and Wood Chemical Manufacturing
        Cyclic Crude and Intermediate Manufacturing
        Ethyl Alcohol Manufacturing
325191
325192
325193
325199
        All Other Basic Organic Chemical
        Manufacturing
3252   Resin, Synthetic Rubber, and
        Artificial Synthetic Fibers and
        Filaments Manufacturing
32521  Resin and Synthetic Rubber
        Manufacturing
325211   Plastics Material and Resin Manufacturing
325212   Synthetic Rubber Manufacturing
32522  Artificial and Synthetic Fibers
        and Filaments Manufacturing
325221   Cellulosic Organic Fiber Manufacturing
325222   Noncellulosic Organic Fiber Manufacturing
3253   Pesticide, Fertilizer, and Other
        Agricultural Chemical
        Manufacturing
32531  Fertilizer Manufacturing
325311   Nitrogenous Fertilizer Manufacturing
325312   Phosphatic Fertilizer Manufacturing
325314   Fertilizer (Mixing Only) Manufacturing
32532  Pesticide and Other
        Agricultural Chemical
        Manufacturing
325320   Pesticide and Other Agricultural Chemical
        Manufacturing
3254   Pharmaceutical and Medicine
        Manufacturing
32541  Pharmaceutical and Medicine
        Manufacturing
325411   Medicinal and Botanical Manufacturing
325412   Pharmaceutical Preparation Manufacturing
325413   In-Vitro Diagnostic Substance Manufacturing
325414   Biological Product (except Diagnostic)
        Manufacturing
3255   Paint, Coating, and Adhesive
        Manufacturing
32551  Paint and Coating
        Manufacturing
325510   Paint and Coating Manufacturing
                   Toxics Release Inventory Reporting Form and Instructions
                                                                                     1-7

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                                  Table 1, NAICS Codes
 32552  Adhesive Manufacturing
 325520   Adhesive Manufacturing
 3256   Soap, Cleaning Compound,
         and Toilet Preparation
         Manufacturing
 32561  Soap and Cleaning Compound
         Manufacturing
 325611   Soap and Other Detergent Manufacturing
 325612   Polish and Other Sanitation Good
         Manufacturing
 '325613   Surface Active Agent Manufacturing
 32562  Toilet Preparation
         Manufacturing
 325620   Toilet Preparation Manufacturing
 3259   Other Chemical Product and
         Preparation Manufacturing
 32591  Printing Ink Manufacturing
 325910   Printing Ink Manufacturing
 32592  Explosives Manufacturing
 325920   Explosives Manufacturing
 32599  All Other Chemical Product
         and Preparation
         Manufacturing
 325991   Custom Compounding of Purchased Resins
 325992   Photographic Film, Paper, Plate, and Chemical
         Manufacturing
 325998   All Other Miscellaneous Chemical Product
         and Preparation Manufacturing (except
         facilities primarily engaged in Aerosol can
         filling on a job order or contract Basis)
 326     Plastics and Rubber Products
         Manufacturing
 3261    Plastics Product
         Manufacturing
                            32611   Plastics Packaging Materials
                                     and Unlaminated Film and
                                     Sheet Manufacturing
                            326111    Plastics Bag Manufacturing
                            326112    Plastics Packaging Film and Sheet (including
                                     Laminated) Manufacturing
                            326113    Unlaminated Plastics Film and Sheet (except
                                     Packaging) Manufacturing
                            32612   Plastics, Pipe, Pipe Fitting, and
                                     Unlaminated Profile Shape
                                     Manufacturing
                            326121    Unlaminated Plastics Profile Shape
                                     Manufacturing
                            326122    Plastics Pipe and Pipe Fitting Manufacturing
                            32613   Laminated Plastics Plate, Sheet
                                     (except Packaging), and Shape
                                     Manufacturing
                            326130    Laminated Plastics Plate, Sheet (except
                                     Packaging), and Shape Manufacturing
                            32614   Polystyrene Foam Product
                                     Manufacturing
                            326140    Polystyrene Foam Product Manufacturing
                            32615   Urethane and Other Foam
                                     Product (except Polystyrene)
                                     Manufacturing
                            326150    Urethane and Other Foam Product (except
                                     Polystyrene) Manufacturing
                            32616   Plastics Bottle Manufacturing
                            326160    Plastics Bottle Manufacturing
                            32619   Other Plastics Product
                                     Manufacturing
                            326191    Plastics Plumbing Fixture Manufacturing
                            326192    Resilient Floor Covering Manufacturing
                            326199    All Other Plastics Product Manufacturing
1-8
Toxics Release Inventory Reporting Form and Instructions

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                                 Table I, NAICS Codes
3262   Rubber Product
        Manufacturing
32621  Tire Manufacturing
326211   Tire Manufacturing (except Retreading)
32622  Rubber and Plastics Hoses and
        Belting Manufacturing
326220   Rubber and Plastics Hoses and Belting
        Manufacturing
32629  Other Rubber Product
        Manufacturing
326291   Rubber Product Manufacturing for Mechanical
        Use
326299   All Other Rubber Product Manufacturing
327    Nonmetallic Mineral Product
        Manufacturing
3271   Clay Product and Refractory
        Manufacturing

32711  Pottery, Ceramics, and
        Plumbing Fixture
        Manufacturing
327111   Vitreous China Plumbing Fixture and China
        and Earthenware Bathroom Accessories
        Manufacturing
327112   Vitreous China, Fine Earthenware, and Other
        Pottery Product Manufacturing (except
        facilities primarily engaged in manufacturing
        and selling pottery on site)
327113   Porcelain Electrical Supply Manufacturing

32712  Clay Building Material and
        Refractories Manufacturing
327121   Brick and Structural Clay Tile Manufacturing
327122   Ceramic Wall and Floor Tile Manufacturing
327123   Other Structural Clay Product Manufacturing
327124   Clay Refractory Manufacturing
327125   Nonclay Refractory Manufacturing
3272   Glass and Glass Product
        Manufacturing
32721  Glass and Glass Product
        Manufacturing
327211   Flat Glass Manufacturing
327212   Other Pressed and Blown Glass and Glassware
        Manufacturing
327213   Glass Container Manufacturing
327215   Glass Product Manufacturing Made of
        Purchased Glass
3273   Cement and Concrete Product
        Manufacturing
32731  Cement Manufacturing
327310   Cement Manufacturing
32732  Ready-Mix Concrete
        Manufacturing
327320   Ready-Mix Concrete Manufacturing
32733  Concrete, Pipe, Brick, and
        Block Manufacturing
3273 31   Concrete Block and Brick Manufacturing
327332   Concrete Pipe Manufacturing
32739  Other Concrete Product
        Manufacturing
327390   Other Concrete Product Manufacturing
3274   Lime and Gypsum Product
        Manufacturing
32741  Lime Manufacturing
327410   Lime Manufacturing
32742  Gypsum Product
        Manufacturing
327420   Gypsum Product Manufacturing
3279   Other Nonmetallic Mineral
        Product Manufacturing
                  Toxics Release Inventory Reporting Form and Instructions
                                     1-9

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                                  Table 1, NAICS Codes
 32791  Abrasive Product
         Manufacturing
 327910   Abrasive Product Manufacturing
 32799  All Other Nonmetallic Mineral
         Product Manufacturing
         Cut Stone and Stone Product Manufacturing
327991
327992

327993
327999
         Ground or Treated Mineral and Earth
         Manufacturing
         Mineral Wool Manufacturing
         All Other Miscellaneous Nonmetallic Mineral
         Product Manufacturing
 331     Primary Metal Manufacturing
 3311    Iron and Steel Mills and
         Ferroalloy Manufacturing
 33111  Iron and Steel Mills and
         Ferroalloy Manufacturing
 331111   Iron and Steel Mills
 331112   Electrometallurgical Ferroalloy Product
         Manufacturing
 3312    Steel Product Manufacturing
         from Purchased Steel
 33121  Iron and Steel Pipe and Tube
         Manufacturing from
         Purchased Steel
 331210   Iron and Steel Pipe and Tube Manufacturing
         from Purchased Steel
 33122  Rolling and Drawing of
         Purchased Steel
 331221   Rolled Steel Shape Manufacturing
 3 31222   Steel Wire Drawing
 3313    Alumina and Aluminum
         Production and Processing
 33131  Alumina and Aluminum
         Production and Processing
331311   Alumina Refining
331312   Primary Aluminum Production
331314   Secondary Smelting and Alloying of
        Aluminum
331315   Aluminum Sheet, Plate, and Foil
        Manufacturing
331316   Aluminum Extruded Product Manufacturing
331319   Other Aluminum Rolling and Drawing
3314   Nonferrous Metal (except
        Aluminum) Production and
        Processing
33141  Nonferrous Metal (except
        Aluminum) Smelting and
        Refining
        Primary Smelting and Refining of Copper
                                               331411
                                               331419
                                               331421
                                               331422
                                               331423
        Primary Smelting and Refining of Nonferrous
        Metal (except Copper and Aluminum)
33142  Copper Rolling, Drawing,
        Extruding and Alloying
        Copper Rolling, Drawing, and Extruding
        Copper Wire (except Mechanical) Drawing
        Secondary Smelting, Refining, and Alloying
        of Copper
                                               33149  Nonferrous Metal (except
                                                       Copper and Aluminum)
                                                       Rolling, Drawing, Extruding,
                                                       and Alloying
                                               331491   Nonferrous Metal (except Copper and
                                                       Aluminum) Rolling, Drawing, and Extruding
                                               331492   Secondary Smelting, Refining, and Alloying
                                                       of
                                                       Nonferrous Metal (except Copper and
                                                       Aluminum)
                                               3315   Foundries
                                               33151  Ferrous Metal Foundries
                                               331511   Iron Foundries
                                               331512   Steel Investment Foundries
1-10
                   Toxics Release Inventory Reporting Form and Instructions

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               Table I, NAICS Codes
331513   Steel Foundries (except Investment)
33152  Nonferrous Metal Foundries
331521   Aluminum Die-Casting Foundries
331522   Nonferrous (except Aluminum) Die-Casting
        Foundries
331524   Aluminum Foundries (except Die-Casting)
331525   Copper Foundries (except Die-Casting)
331528   Other Nonferrous Foundries (except Die-
        Casting)
332     Fabricated Metal Product
        Manufacturing
3321   Forging and Stamping
33211  Forging and Stamping
332111   Iron and Steel Forging
332112   Nonferrous Forging
332114   Custom Roll Forming
332115   Crown and Closure Manufacturing
332116   Metal Stamping
332117   Powder Metallurgy Part Manufacturing
3322   Cutlery and Handtool
        Manufacturing
33221  Cutlery and Handtool
        Manufacturing
332211   Cutlery and Flatware (except Precious)
        Manufacturing
332212   Hand and Edge Tool Manufacturing
332213   Saw Blade and Handsaw Manufacturing
332214   Kitchen Utensil, Pot, and Pan Manufacturing
3323   Architectural and Structural
        Metals Manufacturing
33231  Plate Work and Fabricated
        Structural Product
        Manufacturing
                             332311    Prefabricated Metal Building and Component
                                     Manufacturing
                             332312    Fabricated Structural Metal Manufacturing
                             332313    Plate Work Manufacturing
                             33232   Ornamental and Architectural
                                     Metal Products Manufacturing
                             332321    Metal Window and Door Manufacturing
                             332322    Sheet Metal Work Manufacturing
                             332323    Ornamental and Architectural Metal Work
                                     Manufacturing
                             3324    Boiler, Tank, and  Shipping
                                     Container Manufacturing
                             33241   Power Boiler and Heat
                                     Exchanger Manufacturing
                             332410    Power Boiler and Heat Exchanger
                                     Manufacturing
                             33242   Metal Tank (Heavy Gauge)
                                     Manufacturing
                             332420    Metal Tank (Heavy Gauge) Manufacturing
                             33243   Metal Can, Box, and Other
                                     Metal Container (Light Gauge)
                                     Manufacturing
                             332431    Metal Can Manufacturing
                             332439    Other Metal Container Manufacturing
                             3325    Hardware Manufacturing
                             33251   Hardware Manufacturing
                             332510    Hardware Manufacturing
                             3326    Spring and Wire Product
                                     Manufacturing
                             33261   Spring and Wire Product
                                     Manufacturing
                             332611    Spring (Heavy Gauge) Manufacturing
                             332612    Spring (Light Gauge) Manufacturing
                             332618    Other Fabricated Wire Product Manufacturing
Toxics Release Inventory Reporting Form and Instructions
                                                                                    1-11

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                                   Table 1, NAICS Codes
 3327   Machine Shops; Turned
         Product; and Screw, Nut and
         Bolt Manufacturing
 33271  Machine Shops
 332710   Machine Shops
 33272  Turned Product and Screw,
         Nut and Bolt Manufacturing
 332721   Precision Turned Product Manufacturing
 332722   Bolt, Nut, Screw, Rivet, and Washer
         Manufacturing
 3328   Coating, Engraving,  Heat
         Treating, and Allied  Activities
 33281  Coating, Engraving,  Heat
         Treating, and Allied  Activities
 332811   Metal Heat Treating
 332812   Metal Coating, Engraving (except Jewelry and
         Silverware), and Allied Services to
         Manufacturers
 332813   Electroplating, Plating, Polishing, Anodizing,
         and Coloring
 3329   Other Fabricated Metal
         Product Manufacturing
 33291  Metal Valve Manufacturing
 332911   Industrial Valve Manufacturing
 332912   Fluid Power Valve and Hose Fitting
         Manufacturing
 332913   Plumbing Fixture Fitting and Trim
         Manufacturing
 332919   Other Metal Valve and Pipe Fitting
         Manufacturing
 33299  All Other Fabricated Metal
         Product Manufacturing
         Ball and Roller Bearing Manufacturing
         Small Arms Ammunition Manufacturing
332991
332992
332993
         Ammunition (except Small Arms)
         Manufacturing
                                                332994    Small Arms Manufacturing
                                                332995    Other Ordnance and Accessories
                                                         Manufacturing
                                                332996    Fabricated Pipe and Pipe Fitting
                                                         Manufacturing
                                                332997    Industrial Pattern Manufacturing
                                                332998    Enameled Iron and Metal Sanitary Ware
                                                         Manufacturing
                                                332999    All Other Miscellaneous Fabricated Metal
                                                         Product Manufacturing
                                                333     Machinery Manufacturing
3331   Agriculture, Construction, and
        Mining Machinery
        Manufacturing
33311  Agricultural Implement
        Manufacturing
333111   Farm Machinery and Equipment
        Manufacturing
333112   Lawn and Garden Tractor and Home Lawn
        and Garden Equipment Manufacturing
33312  Construction Machinery
        Manufacturing
3 3 3120   Construction Machinery Manufacturing

33313  Mining and Oil and Gas Field
        Machinery Manufacturing
333131   Mining Machinery and Equipment
        Manufacturing
333132   Oil and Gas Field Machinery and Equipment
        Manufacturing
3332   Industrial Machinery
        Manufacturing
33321  Sawmill and Woodworking
        Machinery Manufacturing
333210   Sawmill and Woodworking Machinery
        Manufacturing
1-12
                   Toxics Release Inventory Reporting Form and Instructions

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                                   Table I, NAICS Codes
33322   Plastics and Rubber Industry
         Machinery Manufacturing
3 3 3 220    Plastics and Rubber Industry Machinery
         Manufacturing
33329   Other Industrial Machinery
         Manufacturing
333291    Paper Industry Machinery Manufacturing
333292    Textile Machinery Manufacturing
333293    Printing Machinery and Equipment
         Manufacturing
333294    Food Product Machinery Manufacturing
333295    Semiconductor Machinery Manufacturing
333298    All Other Industrial Machinery Manufacturing
3333    Commercial and Service
         Industry Machinery
         Manufacturing
33331   Commercial and Service
         Industry Machinery
         Manufacturing
333311    Automatic Vending Machine Manufacturing
333312    Commercial Laundry, Drycleaning, and
         Pressing Machine Manufacturing
333313    Office Machinery Manufacturing
333314    Optical Instrument and Lens Manufacturing
333315    Photographic and Photocopying Equipment
         Manufacturing
333319    Other Commercial and Service Industry
         Machinery Manufacturing
3334    Ventilation, Heating, Air-
         Conditioning, and Commercial
         Refrigeration
33341   Equipment Manufacturing
         Ventilation, Heating, Air-
         Conditioning, and Commercial
         Refrigeration Equipment
         Manufacturing
333411   Air Purification Equipment Manufacturing
333412   Industrial and Commercial Fan and Blower
        Manufacturing
333414   Heating Equipment (except Warm Air
        Furnaces) Manufacturing
333415   Air-Conditioning and Warm Air Heating
        Equipment and Commercial and Industrial
        Refrigeration Equipment Manufacturing
3335   Metalworking Machinery
        Manufacturing
33351  Metalworking Machinery
        Manufacturing
333511   Industrial Mold Manufacturing
333512   Machine Tool (Metal Cutting Types)
        Manufacturing
333513   Machine Tool (Metal Forming Types)
        Manufacturing
333514   Special Die and Tool, Die Set, Jig, and Fixture
        Manufacturing
333515   Cutting Tool and Machine Tool Accessory
        Manufacturing
333516   Rolling Mill Machinery and Equipment
        Manufacturing
333518   Other Metalworking Machinery
        Manufacturing
3336   Engine, Turbine, and Power
        Transmission Equipment
        Manufacturing
33361  Engine, Turbine, and Power
        Transmission Equipment
        Manufacturing
333611   Turbine and Turbine Generator Set Units
        Manufacturing
333612   Speed Changer, Industrial High-Speed Drive,
        and Gear Manufacturing
333613   Mechanical Power Transmission Equipment
        Manufacturing
333618   Other Engine Equipment Manufacturing
                   Toxics Release Inventory Reporting Form and Instructions
                                       1-13

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                                  Table 1, NAICS Codes
 3339    Other General Purpose
         Machinery Manufacturing
 33391  Pump and Compressor
         Manufacturing
         Pump and Pumping Equipment Manufacturing
         Air and Gas Compressor Manufacturing
333911
333912
333913
         Measuring and Dispensing Pump
         Manufacturing
 33392  Material Handling Equipment
         Manufacturing
 333921   Elevator and Moving Stairway Manufacturing
 3 3 3 922   Conveyor and Conveying Equipment
         Manufacturing
 333923   Overhead Traveling Crane, Hoist, and
         Monorail System Manufacturing
 333924   Industrial Truck, Tractor, Trailer, and Stacker
         Machinery Manufacturing
 33399  All Other General Purpose
         Machinery Manufacturing
 333991   Power-Driven Handtool Manufacturing
 333992   Welding and Soldering Equipment
         Manufacturing
 333993   Packaging Machinery Manufacturing
 333994   Industrial Process Furnace and Oven
         Manufacturing
 333995   Fluid Power Cylinder and Actuator
         Manufacturing
 333996   Fluid Power Pump and Motor Manufacturing
 333997   Scale and Balance Manufacturing
 333999   All Other Miscellaneous General Purpose
         Machinery Manufacturing
 334     Computer and Electronic
         Product Manufacturing
 3341    Computer and Peripheral
         Equipment Manufacturing
33411  Computer and Peripheral
        Equipment Manufacturing
        Electronic Computer Manufacturing
        Computer Storage Device Manufacturing
        Computer Terminal Manufacturing
334111
334112
334113
334119
        Other Computer Peripheral Equipment
        Manufacturing
                                              3342   Communications Equipment
                                                      Manufacturing
                                              33421  Telephone Apparatus
                                                      Manufacturing
                                              334210   Telephone Apparatus Manufacturing
                                              33422  Radio and Television
                                                      Broadcasting and Wireless
                                                      Communications Equipment
                                                      Manufacturing
                                              334220   Radio and Television Broadcasting and
                                                      Wireless Communications Equipment
                                                      Manufacturing
                                              33429  Other Communications
                                                      Equipment Manufacturing
                                              334290   Other Communications Equipment
                                                      Manufacturing
                                              3343   Audio and Video Equipment
                                                      Manufacturing
                                              33431  Audio and Video Equipment
                                                      Manufacturing
                                              334310   Audio and Video Equipment Manufacturing
                                              3344   Semiconductor and Other
                                                      Electronic Component
                                                      Manufacturing
                                              33441  Semiconductor and Other
                                                      Electronic Component
                                                      Manufacturing
                                              334411   Electron Tube Manufacturing
1-14
                  Toxics Release Inventory Reporting Form and Instructions

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                                     Table I, NAICS Codes
334412    Bare Printed Circuit Board Manufacturing
334413    Semiconductor and Related Device
         Manufacturing
334414    Electronic Capacitor Manufacturing
334415    Electronic Resistor Manufacturing
334416    Electronic Coil, Transformer, and Other
         Inductor Manufacturing
334417    Electronic Connector Manufacturing
334418    Printed Circuit Assembly (Electronic
         Assembly) Manufacturing
334419    Other Electronic Component Manufacturing
3345    Navigational, Measuring,
         Electromedical, and Control
         Instruments Manufacturing
33451   Navigational, Measuring,
         Electromedical, and Control
         Instruments Manufacturing
334510    Electromedical and Electrotherapeutic
         Apparatus Manufacturing
334511    Search, Detection, Navigation, Guidance,
         Aeronautical, and Nautical System and
         Instrument Manufacturing
334512    Automatic Environmental Control
         Manufacturing for Residential, Commercial,
         and Appliance Use
334513    Instruments and Related Products
         Manufacturing for Measuring, Displaying, and
         Controlling Industrial Process Variables
334514    Totalizing Fluid Meter and Counting Device
         Manufacturing
334515    Instrument Manufacturing for Measuring and
         Testing Electricity and Electrical Signals
334516    Analytical Laboratory Instrument
         Manufacturing
334517    Irradiation Apparatus Manufacturing
334518    Watch, Clock, and Part Manufacturing
334519    Other Measuring and Controlling Device
         Manufacturing
3346    Manufacturing and
         Reproducing Magnetic and
         Optical Media
33461   Manufacturing and
         Reproducing Magnetic and
         Optical Media
334612    Prerecorded Compact Disc (except Software),
         Tape, and Record Reproducing (except
         facilities primarily engaged in mass
         reproducing pre-recorded Video Cassettes, and
         mass reproducing Video tape or disk)
334613    Magnetic and Optical Recording Media
         Manufacturing
335     Electrical Equipment,
         Appliance, and Component
         Manufacturing
3351    Electric Lighting Equipment
         Manufacturing
33511   Electric Lamp Bulb and Part
         Manufacturing
335110    Electric Lamp Bulb and Part Manufacturing
33512   Lighting  Fixture
         Manufacturing
335121    Residential Electric Lighting Fixture
         Manufacturing
3 3 5122    Commercial, Industrial, and Institutional
         Electric Lighting Fixture Manufacturing
335129    Other Lighting Equipment Manufacturing
3352    Household Appliance
         Manufacturing
33521   Small Electrical Appliance
         Manufacturing
335211    Electric Housewares and Household Fan
         Manufacturing
335212    Household Vacuum Cleaner Manufacturing
                    Toxics Release Inventory Reporting Form and Instructions
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                                   Table 1, NAICS Codes
 33522  Major Appliance
         Manufacturing
 335221   Household Cooking Appliance Manufacturing
 335222   Household Refrigerator and Home Freezer
         Manufacturing
 335224   Household Laundry Equipment Manufacturing
 335228   Other Major Household Appliance
         Manufacturing
 3353   Electrical Equipment
         Manufacturing
 33531  Electrical Equipment
         Manufacturing
 335311   Power, Distribution, and Specialty
         Transformer Manufacturing
 335312   Motor and Generator Manufacturing (except
         facilities primarily engaged in armature
         rewinding on a factory basis)
 335313   Switchgear and Switchboard Apparatus
         Manufacturing
 335314   Relay and Industrial Control Manufacturing
 3359   Other Electrical Equipment
         and Component
         Manufacturing
 33591  Battery Manufacturing
 335911   Storage Battery Manufacturing
 335912   Primary Battery Manufacturing
 33592  Communication and Energy
         Wire and Cable
         Manufacturing
 335921   Fiber Optic Cable Manufacturing
 335929   Other Communication and Energy Wire
         Manufacturing
 33593  Wiring Device Manufacturing
 335931   Current-Carrying Wiring Device
         Manufacturing
 335932   Noncurrent-Carrying Wiring Device
         Manufacturing
                             33599  All Other Electrical
                                     Equipment
                                     and Component
                                     Manufacturing
                             335991   Carbon and Graphite Product Manufacturing
                             335999   All Other Miscellaneous Electrical Equipment
                                     and Component Manufacturing
                             336     Transportation Equipment
                                     Manufacturing
                             3361    Motor Vehicle Manufacturing
                             33611  Automobile and Light Duty
                                     Motor Vehicle Manufacturing
                             336111   Automobile Manufacturing
                             336112   Light Truck and Utility Vehicle
                                     Manufacturing
                             33612  Heavy Duty Truck
                                     Manufacturing
                             336120   Heavy Duty Truck Manufacturing
                             3362    Motor Vehicle Body and
                                     Trailer Manufacturing
                             33621  Motor Vehicle Body and
                                     Trailer Manufacturing
                             336211   Motor Vehicle Body Manufacturing
                             336212   Truck Trailer Manufacturing
                             336213   Motor Home Manufacturing
                             336214   Travel Trailer and Camper Manufacturing
                             3363    Motor Vehicle Parts
                                     Manufacturing
                             33631  Motor Vehicle Gasoline Engine
                                     and Engine Parts
                                     Manufacturing
                             336311   Carburetor, Piston, Piston Ring, and Valve
                                     Manufacturing
                             336312   Gasoline Engine and Engine Parts
                                     Manufacturing
1-16
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                                 Table I, NAICS Codes
33632  Motor Vehicle Electrical and
        Electronic Equipment
        Manufacturing
336321   Vehicular Lighting Equipment Manufacturing
336322   Other Motor Vehicle Electrical and Electronic
        Equipment Manufacturing
33633  Motor Vehicle Steering and
        Suspension Components
        (except Spring) Manufacturing
336330   Motor Vehicle Steering and Suspension
        Components (except Spring) Manufacturing
33634  Motor Vehicle Brake  System
        Manufacturing
336340   Motor Vehicle Brake System Manufacturing
33635  Motor Vehicle Transmission
        and Power Train Parts
        Manufacturing
336350   Motor Vehicle Transmission and Power Train
        Parts Manufacturing
33636  Motor Vehicle Seating and
        Interior Trim Manufacturing
336360   Motor Vehicle Seating and Interior Trim
        Manufacturing
33637  Motor Vehicle Metal Stamping
336370   Motor Vehicle Metal Stamping
33639  Other Motor Vehicle Parts
        Manufacturing
336391   Motor Vehicle Air-Conditioning
        Manufacturing
336399   All Other Motor Vehicle Parts Manufacturing
3364   Aerospace Product and Parts
        Manufacturing
33641  Aerospace Product and Parts
        Manufacturing
336411   Aircraft Manufacturing
336412   Aircraft Engine and Engine Parts
        Manufacturing
336413   Other Aircraft Parts and Auxiliary Equipment
        Manufacturing
336414   Guided Missile and Space Vehicle
        Manufacturing
336415   Guided Missile and Space Vehicle Propulsion
        Unit and Propulsion Unit Parts Manufacturing
336419   Other Guided Missile and Space Vehicle Parts
        and Auxiliary Equipment Manufacturing
3365   Railroad Rolling Stock
        Manufacturing
33651  Railroad Rolling Stock
        Manufacturing
336510   Railroad Rolling Stock Manufacturing
3366   Ship and Boat Building
33661  Ship and Boat Building
336611   Ship Building and Repairing
336612   Boat Building
3369   Other Transportation
        Equipment Manufacturing
33699  Other Transportation
        Equipment Manufacturing
336991   Motorcycle, Bicycle, and Parts Manufacturing
336992   Military Armored Vehicle, Tank, and Tank
        Component Manufacturing
336999   All Other Transportation Equipment
        Manufacturing
337     Furniture and Related Product
        Manufacturing
3371   Household and Institutional
        Furniture and Kitchen Cabinet
        Manufacturing
33711  Wood Kitchen Cabinet and
        Countertop Manufacturing
                  Toxics Release Inventory Reporting Form and Instructions
                                     1-17

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                                     Table 1, NAICS Codes
 337110    Wood Kitchen Cabinet and Countertop
          Manufacturing (except facilities primarily
          engaged in the retail sale of household
          furniture and that manufacture custom wood
          kitchen cabinets and counter tops)

 33712   Household and Institutional
          Furniture Manufacturing
 337121
 337122
 337124

 337125


 337127

 337129


 3372
         Upholstered Household Furniture
         Manufacturing (except facilities primarily
         engaged in the retail sale of household
         furniture and that manufacture custom made
         upholstered household furniture)

         Nonupholstered Wood Household Furniture
         Manufacturing (except facilities primarily
         engaged in the retail sale of household
         furniture and that manufacture nonupholstered,
         household type, custom wood furniture)

         Metal Household Furniture Manufacturing

         Household Furniture (except Wood and Metal)
         Manufacturing

         Institutional Furniture Manufacturing

         Wood Television, Radio, and Sewing Machine
         Cabinet Manufacturing
         Office Furniture (including
         Fixtures)Manufacturing

33721   Office Furniture (including
         Fixtures)Manufacturing
337211    Wood Office Furniture Manufacturing
337212    Custom Architectural Woodwork and
         Millwork Manufacturing
337214    Office Furniture (except Wood)
         Manufacturing
337215    Showcase, Partition, Shelving, and Locker
         Manufacturing

3379    Other Furniture Related
         Product Manufacturing

33791   Mattress Manufacturing
337910    Mattress Manufacturing

33792   Blind and Shade
         Manufacturing
                                                    37920    Blind and Shade Manufacturing
                                                   339     Miscellaneous Manufacturing
3391    Medical Equipment and
         Supplies Manufacturing

33911   Medical Equipment and
         Supplies Manufacturing
         Laboratory Apparatus and Furniture Manuf.
339111

339112


339113
339114

339115




3399
                                                    339911

                                                    339912

                                                    339913
Surgical and Medical Instrument
Manufacturing

Surgical Appliance and Supplies
Manufacturing (except facilities primarily
engaged in manufacturing orthopedic devices
to prescription in a retail environment)

Dental Equipment and Supplies
Manufacturing

Ophthalmic Goods Manufacturing (except lens
grinding facilities that are primarily engaged
in the retail sale of eyeglasses and contact
lenses to prescription for individuals)
         Other Miscellaneous
         Manufacturing

33991   Jewelry and Silverware
         Manufacturing
         Jewelry (except Costume) Manufacturing
         Silverware and Hollowware Manufacturing
         Jewelers' Material and Lapidary Work
         Manufacturing
339914    Costume Jewelry and Novelty Manufacturing

33992   Sporting and Athletic Goods
         Manufacturing

339920    Sporting and Athletic Goods Manufacturing

33993   Doll, Toy, and Game
         Manufacturing

339931    Doll and Stuffed Toy Manufacturing
339932    Game, Toy, and Children's Vehicle
         Manufacturing
1-18
                    Toxics Release Inventory Reporting Form and Instructions

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                                         Table I, NAICS Codes
33994   Office Supplies (except Paper)
          Manufacturing
          Pen and Mechanical Pencil Manufacturing
          Lead Pencil and Art Good Manufacturing
          Marking Device Manufacturing
339941

339942

339943

339944
          Carbon Paper and Inked Ribbon
          Manufacturing
33995   Sign Manufacturing

339950    Sign Manufacturing

33999   All Other Miscellaneous
          Manufacturing

339991    Gasket, Packing, and Sealing Device
          Manufacturing

339992    Musical Instrument Manufacturing

339993    Fastener, Button, Needle, and Pin
          Manufacturing

339994    Broom, Brush, and Mop Manufacturing

339995    Burial Casket Manufacturing

339999    All Other Miscellaneous Manufacturing

113310    Logging

111998    All Other Miscellaneous Crop Farming
          (Limited to facilities primarily engaged in
          reducing maple sap to maple syrup)

211112    Natural Gas Liquid Extraction (limited to
          facilities that recover sulfur from natural gas)

212324    Kaolin and Ball Clay Mining (limited to
          facilities operating without a mine or quarry
          and that are primarily engaged in beneficiating
          kaolin and clay)

212325    Clay and Ceramic and Refractory Minerals
          Mining (limited to facilities operating without
          a mine or quarry and that are primarily
          engaged in beneficiating clay and ceramic and
          refractory minerals)

212393    Other Chemical and Fertilizer Mineral
          Mining (limited to facilities operating without
          a mine or quarry that are primarily engaged in
          beneficiating chemical or fertilizer mineral
          raw materials)
212399    All Other Nonmetallic Mineral Mining
          (limited to facilities operating without a mine
          or quarry that are primarily engaged in
          beneficiating nonmetallic minerals)

488390    Other Support Activities for Water
          Transportation (limited to facilities that are
          primarily engaged in providing routine repair
          and maintenance of ships and boats from
          floating drydocks)

511110    Newspaper Publishers

511120    Periodical Publishers

511130    Book Publishers

511140    Directory and Mailing List Publishers
          (except Facilities that are primarily engaged in
          furnishing services for direct mail advertising
          including address list compilers, address list
          publishers, address list publishers and printing
          combined, address list publishing, business
          directory publishers, catalog of collections
          publishers, catalog of collections publishers
          and printing combined, mailing list compilers,
          directory compilers, and mailing list compiling
          services)

511191    Greeting Card Publishers

511199    All Other Publishers

512220    Integrated Record Production/Distribution

512230    Music Publishers (except facilities primarily
          Engaged n Music copyright authorizing use,
          Music copyright buying and licensing, and
          Music publishers working on their own
          account)

516110    Internet Publishing and Broadcasting
          (limited to facilities primarily engaged in
          Internet newspaper publishing, Internet
          periodical publishing, internet book
          publishing, Miscellaneous Internet publishing,
          Internet greeting card publishers

541710    Research and Development in the Physical,
          Engineering, and Life Sciences (limited to
          facilities that are primarily engaged in Guided
          missile and space vehicle engine research and
          development, and in Guided missile and space
          vehicle parts (except engines) research and
          development)

811490    Other Personal and Household Goods
          Repair and Maintenance
                       Toxics Release Inventory Reporting Form and Instructions
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Table II.
1.2    NAICS codes that correspond
         to SIC codes other than 20
         through 39:


212       Mining (except Oil  and Gas)

2121      Coal Mining

212111     Bituminous Coal and Lignite Surface
           Mining

212112     Bituminous Coal Underground Mining

212113     Anthracite Mining

2122      Metal Ore Mining

212221     Gold Ore Mining

212222     Silver Ore Mining

212231     Lead Ore and Zinc Ore Mining

212234     Copper Ore and Nickel Ore Mining

212299     All Other Metal Ore Mining
221
Utilities
22111    Electric Power Generation
           (limited to facilities that combust
           coal and/or oil for the purpose of
           generating power for distribution
           in commerce)

221111     Hydroelectric Power Generation

221112     Fossil Fuel Electric Power Generation

221113     Nuclear Electric Power Generation

221119     Other Electric Power Generation

221121     Electric Bulk Power Transmission and
           Control
221122     Electric Power Distribution

424690     Other Chemical and Allied Products
           Merchant Wholesalers

424710     Petroleum Bulk Stations and Terminals

425110     Business to Business Electronic Markets
           (limited to facilities previously classified in
           5169, Chemicals and Allied Products, NEC)

425120     Wholesale Trade Agents and Brokers
           (limited to facilities previously classified in
           5169, Chemicals and Allied Products, NEC)

562112     Hazardous Waste Collection (limited to
           facilities primarily engaged in solvent
           recovery services on a contract or fee basis)

562211     Hazardous Waste Treatment and
           Disposal (limited to facilities regulated
           under the Resource Conservation and
           Recovery  Act, subtitle C, 42 U.S.C. 6921, et
           seq.)

562212     Solid Waste Landfill (limited to facilities
           regulated under the Resource Conservation
           and Recovery Act, subtitle C, 42 U.S.C.
           6921, et seq.)

562213     Solid Waste Combustors and Incinerators
           (Limited to facilities regulated under the
           Resource Conservation and Recovery Act,
           subtitle C, 42 U.S.C.  6921 etseq.)

562219     Other Nonhazardous Waste Treatment
           and Disposal (Limited to facilities regulated
           under the Resource Conservation and
           Recovery  Act, subtitle C, 42 U.S.C. 6921 et
           seq.)

562920     Materials Recovery Facilities (Limited to
           facilities regulated under the Resource
           Conservation and Recovery Act, subtitle C,
           42 U.S.C. 6921 etseq.)
1-20
           Toxics Release Inventory Reporting Form and Instructions

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  Table II.  EPCRA Section 313  Chemical List  For Reporting Year 2007
	(including Toxic Chemical Categories)	

Individually listed EPCRA Section 313 chemicals with CAS numbers are arranged alphabetically starting on page II-3. Following the
alphabetical list, the EPCRA Section 313 chemicals are arranged in CAS number order. Covered chemical categories follow.

Certain EPCRA Section 313 chemicals listed in Table II have parenthetic "qualifiers." These qualifiers indicate that these EPCRA
Section 313 chemicals are subject to the section 313 reporting requirements if manufactured, processed, or otherwise used in a specific
form or when a certain activity is performed. The following chemicals are reportable only if they are manufactured, processed, or
otherwise used in the specific form(s) listed below:
Chemical
Aluminum (fume or dust)
Aluminum oxide (fibrous forms)
Ammonia (includes anhydrous ammonia and aqueous ammonia
from water dissociable ammonium salts and other sources; 10
percent of total aqueous ammonia is reportable under this listing)
Asbestos (friable)
Hydrochloric acid (acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle size)
Phosphorus (yellow or white)
Sulfuric acid (acid aerosols including mists, vapors, gas, fog, and
other airborne forms of any particle size)
Vanadium (except when contained in an alloy)
Zinc (fume or dust)
CAS Number
7429-90-5
1344-28-1
7664-41-7
1332-21-4
7647-01-0
7723-14-0
7664-93-9
7440-62-2
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
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 manufacture of that
chemical.)
Isopropyl alcohol (only persons who manufacture by the strong
acid process are subject, no supplier notification)
Saccharin (only persons who manufacture are subject, no supplier
notification)
CAS
Number
NA
67-63-0
81-07-2
Qualifier
Only if they are manufactured at the
facility; or are processed or otherwise
used when present as contaminants in a
chemical but only if they were created
during the manufacture of that
chemical.
Only if it is being manufactured by the
strong acid process. Facilities that
process or otherwise use isopropyl
alcohol are not covered and should not
file a report.
Only if it is being manufactured.
There are no supplier notification requirements for isopropyl alcohol and saccharin since the processors and users of these chemicals
are not required to report. Manufacturers of these chemicals do not need to notify their customers that these are reportable EPCRA
section 313 chemicals.
                  Toxics Release Inventory Reporting Form and Instructions
II-l

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                            Table II, EPCRA Section 313 Chemical List - RY2007
 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 2007 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 subj ect 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
applies only to distribution of yellow or white phosphorus.
                           Toxics Release Inventory Reporting Form and Instructions
                                                    11-2

-------
                             Table II, EPCRA Section 313 Chemical List - RY2007
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.
                                                   CAS Number    Chemical Name
                                              Deminimis
                                                   Limit
       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).	
a.
Individually-Listed Toxic Chemicals
                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)
834-12-8        Ametryn                             1.0
                (N-Ethyl-N'-(l-methylethyl)-6-(methylthio)-
                l,3,5,-triazine-2,4-diamine)
117-79-3        2-Aminoanthraquinone                0.1
60-09-3         4-Aminoazobenzene                   0.1
92-67-1         4-Aminobiphenyl                     0.1
82-28-0         l-Amino-2-methylanthraquinone        0.1
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]
Arra

CAS Number
71751-41-2
30560-19-1


75-07-0
60-35-5
75-05-8
98-86-2
53-96-3
62476-59-9


107-02-8
79-06-1
79-10-7
nged Alphabetically
62-53-3
90-04-0
md-Q/UQ
Deminimis
Chemical Name
Abamectin [AvermectinBl]
Acephate
(Acetylphosphoramidothioic acid O,S-
dimethyl ester)
Acetaldehyde
Acetamide
Acetonitrile
Acetophenone
2-Acetylaminofluorene
Acifluorfen, sodium salt
Limit
1.0
1.0


0.1
0.1
1.0
1.0
0.1
1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-2-
nitrobenzoic acid, sodium salt]
Acrolein
Acrylamide
Acrylic acid
107-13-lAcrylonitrile
15972-60-8
116-06-3
309-00-2



Alachlor
Aldicarb
Aldrin
[1,4:5, 8-Dimethanonaphthalene,

1.0
0.1
1.0
0.1
1.0
1.0
*

1,2,3,4, 10, 10-hexachloro-l,4,4a,5,8,8a-
hexahydro-(l.alpha.,4.alpha.,4a.beta.,


134-29-2

120-12-7
7440-36-0
7440-38-2
1332-21-4
1912-24-9


7440-39-3
22781-23-3


1861-40-1


17804-35-2
98-87-3
55-21-0
71-43-2
92-87-5
98-07-7
Aniline
o-Anisidine
p-Anisidine
1.0
o-Anisidine hydrochloride
0.1
Anthracene
Antimony
Arsenic
Asbestos (friable)
Atrazine
(6-Chloro-N-ethyl-N'-(l-methylethyl)-l
triazine-2,4-diamine)
Barium
Bendiocarb
[2,2-Dimethyl- 1 ,3 -benzodioxol-4-ol
methylcarbamate]
Benfluralin
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)benzenamine)
Benomyl
Benzal chloride
Benzamide
Benzene
Benzidine
Benzoic trichloride
1.0
0.1



1.0
1.0
0.1
0.1
1.0
,3,5-

1.0
1.0


1.0


1.0
1.0
1.0
0.1
0.1
0.1

                           Toxics Release Inventory Reporting Form and Instructions
                                                                                                       II-3

-------
                            Table II, EPCRA Section 313 Chemical List - RY2007
CAS Number   Chemical Name
Deminimis
     Limit
                (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
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
353-59-3        Bromochlorodifluoromethane           1.0
                (Halonl211)
75-25-2         Bromoform (Tribromomethane)         1.0
74-83-9         Bromomethane                       1.0
                (Methyl bromide)
75-63-8         Bromotrifluoromethane                1.0
                (Halon 1301)
1689-84-5       Bromoxynil                          1.0
                (3,5-Dibromo-4-hydroxybenzonitrile)
1689-99-2       Bromoxynil octanoate                  1.0
                (Octanoic acid, 2,6-dibromo-4-
                cyanophenylester)
357-57-3        Brucine                              1.0
106-99-0        1,3-Butadiene                        0.1
141-32-2        Butyl acrylate                        1.0
71-36-3         n-Butyl alcohol                       1.0
78-92-2         sec-Butyl alcohol                     1.0
75-65-0         tert-Butyl alcohol                     1.0
106-88-7        1,2-Butylene oxide                    0.1
123-72-8        Butyraldehyde                        1.0
7440-43-9       Cadmium                            0.1
156-62-7        Calcium cyanamide                   1.0
133-06-2        Captan                              1.0
                [lH-Isoindole-l,3(2H)-dione, 3a,4,7,7a-
                tetrahydro-2-[(trichloromethyl)thio]-]
63-25-2	Carbaryl [l-Naphthalenol,	LO
CAS Number

1563-66-2
75-15-0
56-23-5
463-58-1
5234-68-4


120-80-9
2439-01-2


133-90-4

57-74-9


115-28-6
90982-32-4



7782-50-5
10049-04-4
79-11-8
532-27-4
4080-31-3

106-47-8
108-90-7
510-15-6


75-68-3

75-45-6

75-00-3
67-66-3
74-87-3
107-30-2
563-47-3
104-12-1
76-06-2
126-99-8
542-76-7
63938-10-3
354-25-6

2837-89-0

1897-45-6

Deminimis
Chemical Name Limit
methylcarbamate]
Carbofuran 1.0
Carbon disulfide 1 . 0
Carbon tetrachloride 0. 1
Carbonyl sulfide 1.0
Carboxin 1.0
(5,6-Dihydro-2-methyl-N-
phenyl- 1 ,4-oxathiin-3 -carboxamide)
Catechol 0.1
Chinomethionat 1.0
[6-Methyl-l,3-dithiolo[4,5-b]quinoxalin-2-
one]
Chloramben 1.0
[Benzoic acid, 3-amino-2,5-dichloro-]
Chlordane *
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-hexahydro-]
Chlorendic acid 0.1
Chlorimuron ethyl 1.0
[Ethyl-2-[[[[(4-chloro-6-methoxyprimidin-2-
yl)amino] carbony IJamino] sulfony 1]
benzoate]
Chlorine 1.0
Chlorine dioxide 1.0
Chloroacetic acid 1.0
2-Chloroacetophenone 1.0
l-(3-Chloroallyl)-3,5,7-triaza- 1.0
1-azoniaadamantane chloride
p-Chloroaniline 0. 1
Chlorobenzene 1.0
Chlorobenzilate 1.0
[Benzeneacetic acid, 4-chloro-.alpha.- (4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
l-Chloro-l,l-difluoroethane 1.0
(HCFC-142b)
Chlorodifluoromethane 1.0
(HCFC-22)
Chloroethane (Ethyl chloride)
Chloroform 0. 1
Chloro methane (Methyl chloride) 1.0
Chloro methyl methyl ether 0.1
3-Chloro-2-methyl-l-propene 0.1
p-Chlorophenyl isocyanate 1.0
Chloropicrin 1.0
Chloroprene 0. 1
3-Chloropropionitrile 1.0
Chlorotetrafluoroethane 1.0
1-Chloro-l, 1,2,2- 1.0
tetrafluoroethane (HCFC-124a)
2-Chloro-l, 1,1,2- 1.0
tetrafluoroethane (HCFC-124)
Chlorothalonil 0.1
[1,3-Benzenedicarbonitrile, 2,4,5,6-
                           Toxics Release Inventory Reporting Form and Instructions
                                                                 II-4

-------
 Table II, EPCRA Section 313 Chemical List - RY2007
CAS Number

95-69-2
75-88-7

75-72-9
460-35-5

5598-13-0


64902-72-3



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


Deminimis
Chemical Name Limit
tetrachloro-]
p-Chloro-o-toluidine
2-Chloro-l,l,l-
trifluoroethane (HCFC-133a)
Chlorotrifluoromethane (CFC-13)
3-Chloro-l,l,l-
trifluoropropane (HCFC-253fb)
Chlorpyrifos methyl
[O,O-Dimethy l-O-(3 , 5 ,6-trichloro-2-
pyridyl)phosphorothioate]
Chlorsulfuron
[2-Chloro-N-[[(4-methoxy-6-methyl-l
triazin-2-yl)amino]carbonyl]
benzenesulfonamide]
Chromium
C.I. Acid Green 3
C.I. Acid Red 114
C.I. Basic Green 4
C.I. Basic Red 1
C. .Direct Black 3 8
C. . Direct Blue 6
C. .Direct Blue 218
C. . Direct Brown 95
C. . Disperse Yellow 3
C. . Food Red 5


1.0

1.0
1.0

1.0


1.0
,3,5-


1.0
1.0
0.1
1.0
1.0
0.1
0.1
1.0
0.1
1.0
0.1
C.I. Food Red 15
C. . Solvent Orange 7
C. . Solvent Yellow 3
C. . Solvent Yellow 14
C. . Solvent Yellow 34
(Auramine)
C.I. Vat Yellow 4
Cobalt
Copper
Creosote
p-Cresidine
m-Cresol
o-Cresol
p-Cresol
Cresol (mixed isomers)
Crotonaldehyde
Cumene
Cumene hydroperoxide
Cupferron
[Benzeneamine, N-hydroxy-
N-nitroso, ammonium salt]
Cyanazine
Cycloate
Cyclohexane
Cyclohexanol
Cyfluthrin
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid,
1.0
0.1
1.0
0.1

1.0

1.0
0.1
0.1
.0
.0
.0
.0
.0
.0
.0
0.1


1.0
1.0
1.0
1.0



                                 CAS Number   Chemical Name
Deminimis
     Limit
                                                 cyano(4-fluoro-3 -phenoxyphenyl) methyl
                                                 ester]
                                 68085-85-8      Cyhalothrin                           1.0
                                                 [3 -(2-Chloro-3,3,3 -trifluoro-1 -propenyl)-
                                                 2,2-dimethylcyclopropane-carboxylic acid
                                                 cyano(3-phenoxyphenyl)methyl ester]
                                 94-75-7         2,4-D
                                                 [Acetic acid, (2,4-dichlorophenoxy)-]
                                 533.74.4        Dazomet                             1.0
                                                 (Tetrahydro-3,5-dimethyl-2H-l,3,5-
                                                 thiadiazine-2-thione)
                                 53404-60-7      Dazomet, sodium salt                  1.0
                                                 [Tetrahydro-3,5-dimethyl-2H-l,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
                                                 methylpentyl 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.
                                 39156-41-7      2,4-Diaminoanisole sulfate             0.
                                 101-80-4        4,4'-Diaminodiphenyl ether             0.
                                 95-80-7         2,4-Diaminotoluene                    0.
                                 25376-45-8      Diaminotoluene (mixed isomers)        0.
                                 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-
                                                 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                   0.1
                                 25321-22-6      Dichlorobenzene (mixed isomers)       0.1
                                 91-94-1         3,3'-Dichlorobenzidine                 0.1
                                 612-83-9        3,3'-Dichlorobenzidine                 0.1
                                                 dihydrochloride
                                 64969-34-2      3,3'-Dichlorobenzidine sulfate	0.1
Toxics Release Inventory Reporting Form and Instructions
       II-5

-------
                             Table II, EPCRA Section 313 Chemical List - RY2007
 CAS Number   Chemical Name
Deminimis
     Limit
 75-27-4         Dichlorobromomethane                0.1
 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
 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, 1,1,3,3-                1.0
                 pentafluoropropane (HCFC-225aa)
 422-48-0        2,3-Dichloro-l,1,1,2,3-
                 pentafluoropropane (HCFC-225ba)
 422-56-0        3,3-Dichloro-l, 1,1,2,2-                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        1,1-Dichloro-1,2,2-                    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, 1,1-                    1.0
                 trifluoroethane (HCFC-123)
 62-73-7         Dichlorvos                           0.1
                 [Phosphoric acid, 2,2-dichloroethenyl
	dimethyl ester]	
CAS Number
51338-27-3


115-32-2

77-73-6
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
Deminimis
Chemical Name Limit
Diclofop methyl
[2-[4-(2,4-Dichlorophenoxy)phenoxy]
propanoic acid, methyl ester]
Dicofol
[Benzenemethanol, 4-chloro-
Dicyclopentadiene
Diepoxybutane
Diethanolamine
Diethatyl ethyl
Di(2-ethylhexyl) phthalate (DEHP)
Diethyl sulfate
Diflubenzuron
Diglycidyl resorcinol ether
Dihydrosafrole
Dimethipin
[2,3-Dihydro-5,6-dimethyl-l,4-dithiin
1,1,4,4-tetraoxide]
Dimethoate
3 , 3 '-Dimethoxybenzidine
3 , 3 '-Dimethoxybenzidine
dihydrochloride (o-Dianisidine
dihydrochloride)
3 , 3 '-Dimethoxybenzidine
1.0


1.0

1.0
0.1
1.0
1.0
0.1
0.1
1.0
0.1
0.1
1.0


1.0
0.1
0.1


0.1
hydrochloride (o-Dianisidine hydrochloride)
124-40-3
2300-66-5
60-11-7
121-69-7
119-93-7
612-82-8


41766-75-0
Dimethylamine
Dimethylamine dicamba
4-Dimethylaminoazobenzene
N,N-Dimethylaniline
3,3'-Dimethylbenzidine (o-Tolidine)
3 , 3 '-Dimethylbenzidine
dihydrochloride (o-Tolidine
dihydrochloride)
3 , 3 '-Dimethylbenzidine
1.0
1.0
0.1
1.0
0.1
0.1


0.1
dihydrofluoride (o-Tolidine dihydrofluoride)
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
Dimethylcarbamyl chloride
Dimethyl
chlorothiophosphate
N,N-Dimethylformamide
1,1 -Dimethyl hydrazine
2,4-Dimethylphenol
Dimethyl phthalate
Dimethyl surfate
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
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
                            Toxics Release Inventory Reporting Form and Instructions
                                                                  II-6

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                              Table II, EPCRA Section 313 Chemical List - RY2007
 CAS Number   Chemical Name
Deminimis
     Limit
 957-51-7        Diphenamid                          1.0
 122-39-4        Diphenylamine                        1.0
 122-66-7        1,2-Diphenylhydrazine                 0.1
                 (Hydrazobenzene)
 2164-07-0       Dipotassium endothall                 1.0
                 [7-Oxabicyclo(2.2. l)heptane-2,3-
                 dicarboxylic acid, dipotassium salt]
 136-45-8        Dipropyl isocinchomeronate            1.0
 138-93-2        Disodium                            1.0
                 cyanodithioimidocarbonate
 94-11-1         2,4-D isopropyl ester                  0.1
 541-53-7        2,4-Dithiobiuret                       1.0
 330-54-1        Diuron                               1.0
 2439-10-3       Dodine [Dodecylguanidine             1.0
                 monoacetate]
 120-36-5        2,4-DP                               0.1
 1320-18-9       2,4-D propylene glycol                 0.1
                 butyl ether ester
 2702-72-9       2,4-D sodium salt                     0.1
 106-89-8        Epichlorohydrin                       0.1
 13194-48-4      Ethoprop                             1.0
                 [Phosphorodithioic acid O-ethyl S,S-
                 dipropyl ester]
 110-80-5        2-Ethoxyethanol                      1.0
 140-88-5        Ethyl acrylate                         0.1
 100-41-4        Ethylbenzene                         0.1
 541-41-3        Ethyl chloroformate                    1.0
 759-94-4        Ethyl dipropylthiocarbamate            1.0
                 (EPTC)
 74-85-1                                         Ethylene
 107-21-1        Ethylene glycol                       1.0
 151-56-4        Ethyleneimine (Aziridine)              0.1
 75-21-8         Ethylene oxide                        0.1
 96-45-7         Ethylene thiourea                     0.1
 75-34-3         Ethylidene dichloride                  1.0
 52-85-7         Famphur                             1.0
 60168-88-9      Fenarimol                            1.0
                 [.alpha. -(2-Chlorophenyl)-.alpha. -(4-
                 chlorophenyl)-5-pyrimidinemethanol]
 13356-08-6      Fenbutatin oxide                      1.0
                 (Hexakis(2-methyl-2-phenylpropyl)
                 distannoxane)
 66441-23-4      Fenoxaprop ethyl                     1.0
                 [2-(4-((6-Chloro-2-
                 benzoxazolylen)oxy)phenoxy)propanoic
                 acid, ethyl ester]
 72490-01-8      Fenoxycarb                           1.0
                 [[2-(4-Phenoxyphenoxy)ethyl]carbamic acid
                 ethyl ester]
 39515-41-8      Fenpropathrin                        1.0
                 [2,2,3,3 -Tetramethylcyclopropane
                 carboxylic acid cyano(3-
	phenoxyphenyl)methyl ester]	
CAS Number   Chemical Name
Deminimis
     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-(l-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-
                               (trifluoromethyl)pheny 1] -]
               7782-41-4       Fluorine                              1.0
               51-21-8          Fluorouracil (5 -Fluorouracil)            1.0
               69409-94-5      Fluvalinate                            1.0
                               [N-[2-Chloro-4-(trifluoromethyl)phenyl]-
                               DL-valine(+)-cyano(3-
                               phenoxyphenyl)methyl ester]
               133-07-3         Folpet                                1.0
               72178-02-0      Fomesafen                            1.0
                               [5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
                               N-methylsuhconyl-2-nitrobenzamide]
               50-00-0          Formaldehyde                         0.1
               64-18-6          Formic acid                           1.0
               76-13-1          FreonllS                            1.0
                               [Ethane, 1, 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-1,3-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)-
                               py rimidinone [3 - [4-(trifluoromethyl)pheny 1] -
                               l-[2-[4-(trifluoromethyl)phenyl]ethenyl]-2-
                               propenylidene] hydrazone]
               302-01-2         Hydrazine                            0.1
               10034-93-2      Hydrazine sulfate                      0.1
               7647-01-0       Hydrochloric acid                     1.0
              	(acid aerosols  including mists, vapors, gas,
                            Toxics Release Inventory Reporting Form and Instructions
                                                                   II-7

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                             Table II, EPCRA Section 313 Chemical List - RY2007
 CAS Number   Chemical Name
Deminimis
     Limit
                 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] - IH-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                              1.0
 554-13-2        Lithium carbonate                     1.0
 121-75-5        Malathion                            1.0
 108-31-6        Maleic anhydride                      1.0
 109-77-3        Malononitrile                         1.0
 12427-38-2      Maneb                               1.0
                 [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
 137-42-8        Metham sodium (Sodium               1.0
                 methyldithiocarbamate)
 67-56-1         Methanol                             1.0
 20354-26-1      Methazole                            1.0
	[2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
CAS Number   Chemical Name
Deminimis
     Limit
                               oxadiazolidine-3,5 -dione]
              2032-65-7       Methiocarb                           1.0
              94.74-6          Methoxone                           0.1
                               ((4-Chloro-2-methylphenoxy) acetic acid)
                               (MCPA)
              3653-48-3       Methoxone sodium salt                 0.1
                               ((4-Chloro-2-methylphenoxy) acetate
                               sodium salt)
              72-43-5          Methoxychlor                           *
                               [Benzene,  l,l'-(2,2,2-
                               trichloroethylidene)bis[4-methoxy-]
              109-86-4         2-Methoxyethanol                     1.0
              96-33-3          Methyl acrylate                        1.0
              1634-04-4       Methyl tert-butyl ether                 1.0
              79-22-1          Methyl chlorocarbonate                 1.0
              101-14-4         4,4'-Methylenebis(2-chloroaniline)       0.1
                               (MBOCA)
              101-61-1         4,4'-Methylenebis(N,N-dimethyl)        0.1
                               benzenamine
              74-95-3          Methylene bromide                    1.0
              101-77-9         4,4'-Methylenedianiline                 0.1
              60-34-4          Methyl hydrazine                      1.0
              74-88-4          Methyl iodide                         1.0
              108-10-1         Methyl isobutyl ketone                 1.0
              624-83-9         Methyl isocyanate                     1.0
              556-61-6         Methyl isothiocyanate                  1.0
                               [Isothiocyanatomethane]
              75-86-5          2-Methyllactonitrile                    1.0
              80-62-6          Methyl methacrylate                   1.0
              924-42-5         N-Methylolacrylamide                 1.0
              298-00-0         Methyl parathion                      1.0
              109-06-8         2-Methylpyridine                      1.0
              872-50-4         N-Methyl-2-pyrrolidone                1.0
              9006-42-2       Metiram                              1.0
              21087-64-9      Metribuzin                           1.0
              7786-34-7       Mevinphos                           1.0
              90-94-8          Michler's ketone                       0.1
              2212-67-1       Molinate                              1.0
                               (lH-Azepine-1-carbothioic acid, hexahydro-
                               , S-ethyl ester)
              1313-27-5       Molybdenum trioxide                  1.0
              76-15-3          Monochloropentafluoroethane           1.0
                               (CFC-115)
              150-68-5         Monuron                              1.0
              505-60-2         Mustard gas                           0.1
                               [Ethane, l,l'-thiobis[2-chloro-]
              88671-89-0      Myclobutanil                          1.0
                               [.alpha.-Butyl-.alpha.-(4-chlorophenyl)-lH-
                               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
                            Toxics Release Inventory Reporting Form and Instructions
                                                                   II-8

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                            Table II, EPCRA Section 313 Chemical List - RY2007
CAS Number   Chemical Name
Deminimis
     Limit
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-l-(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
301-12-2        Oxydemeton methyl                   1.0
                [S-(2-(Ethylsuffinyl)ethyl)O,O-dimethyl
                ester phosphorothioic acid]
19666-30-9      Oxydiazon                            1.0
                [3-[2,4-Dichloro-5-(l-
                methylethoxy)phenyl]- 5-(l,l-
                dimethylethyl)-1,3,4-oxadiazol-2(3H)-one]
42874-03-3      Oxyfluorfen                          1.0
10028-15-6      Ozone                               1.0
123-63-7        Paraldehyde                          1.0
1910-42-5	Paraquat dichloride	LO
CAS Number   Chemical Name
                              Deminimis
                                   Limit
               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
               95-54-5
               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
               51-03-6
               29232-93-7
               1336-36-3

               7758-01-2
               128-03-0

               137-41-7

               41198-08-7
                                                     1.0
                                                     1.0
                                                     0.1
                                                     1.0
                                                     1.0
                                                     1.0
                                                     1.0
Parathion                            1.0
[Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl)ester]
Pebulate
[Butylethylcarbamothioic acid S-propyl
ester]
Pendimethalin
[N-( 1 -Ethylpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine]
Pentachlorobenzene
Pentachloroethane
Pentachlorophenol (PCP)
Pentobarbital sodium
Peracetic acid
Perchloromethyl mercaptan
Permethrin
[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-l-
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester]
1,2-Phenylenediamine
1,3 -Pheny lenediamine
p-Phenylenediamine
1,2-Phenylenediamine dihydro-
chloride
1,4-Phenylenediamine dihydro-
chloride
2-Phenylphenol
Phenytoin
Phosgene
Phosphine
Phosphorus (yellow or white)
Phthalic anhydride
Picloram
Picric acid
Piperonyl butoxide
Pirimiphos methyl
[O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-
dimethylphosphorothioate]
Polychlorinated biphenyls
(PCBs)
Potassium bromate
Potassium dimethyldithio-
carbamate
Potassium N-methyldithio-
carbamate
Profenofos
                                                     1.0
                                                     1.0
                                                     1.0
                                                     1.0

                                                     1.0

                                                     1.0
                                                     0.1
                                                     1.0
                                                     1.0
                                                     1.0
                                                     1.0
                                                     1.0
                                                     1.0
                                                     1.0
                                                     1.0
                                                     0.1
                                                     1.0

                                                     1.0
                                                     1.0
                           Toxics Release Inventory Reporting Form and Instructions
                                                                   II-9

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                             Table II, EPCRA Section 313 Chemical List - RY2007
CAS Number   Chemical Name
                              Deminimis
                                   Limit
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
10453-86-8
81-07-2
94-59-7
7782-49-2
74051-80-2
7440-22-4
122-34-9
26628-22-8
[O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
propyl phosphorothioate]
Prometryn                            1.0
[N,N' -Bis( 1 -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-[(Ethylamino)methoxyphosphinothioyl]
oxy]-2-butenoic acid, 1-methylethyl ester]
Propiconazole                         1.0
[ l-[2-(2,4-Dichlorophenyl)-4-propy 1-1,3 -
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
Propylene oxide
            1.0
            1.0
            1.0
            1.0
Pyridine
Quinoline
Quinone
Quintozene
(Pentachloro nitrobenzene)
Quizalofop-ethyl                       1.0
[2-[4-[(6-Chloro-2-
quinoxalinyl)oxy]phenoxy] propanoic acid
ethyl ester]
Resmethrin                            1.0
[[5-(Phenylmethyl)-3-furanyl]methyl-2,2-
dimethyl-3 -(2-methyl-1 -propenyl)
cyclopropanecarboxylate]
Saccharin (only persons who            1.0
manufacture are subject, no supplier
notification)
Safrole                                0.1
Selenium                             1.0
Sethoxydim                           1.0
[2-[l-(Ethoxyimino)butyl]-5-[2-
(ethylthio)propyl] -3 -hydroxyl-2-cyclohexen-
1-one]
Silver                                1.0
Simazine                             1.0
Sodium azide                          1.0
                   CAS Number   Chemical Name
                                              Deminimis
                                                   Limit
1982-69-0       Sodium dicamba                       1.0
                [3,6-Dichloro-2-methoxybenzoic acid,
                sodium salt]
128-04-1        Sodium dimethyldithiocarbamate
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-(1,1-Dimethy lethy 1)-1,3,4-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)
961-11-5        Tetrachlorvinphos                      1.0
                [Phosphoric acid, 2-chloro-l-(2,4,5-
                trichlorophenyl) ethenyl dimethyl ester]
64-75-5         Tetracycline hydrochloride             1.0
7696-12-0       Tetramethrin                          1.0
                [2,2-Dimethyl-3-(2-methyl-l-propenyl)
                cyclopropanecarboxylic acid (1,3,4,5,6,7-
                hexahydro-l,3-dioxo-2H-isoindol-2-
                yl)methyl ester]
7440-28-0       Thallium                              1.0
148-79-8        Thiabendazole                         1.0
                [2-(4-Thiazolyl)-lH-benzimidazole]
62-55-5         Thioacetamide                         0.1
28249-77-6      Thiobencarb                           1.0
                [Carbamic acid, diethylthio-, S-(p-
                chlorobenzyl)ester]
139-65-1        4,4'-Thiodianiline                      0.1
59669-26-0      Thiodicarb                            1.0
23564-06-9      Thiophanate ethyl	1.0
                            Toxics Release Inventory Reporting Form and Instructions
                                                                                                 11-10

-------
                            Table II, EPCRA Section 313 Chemical List - RY2007
CAS Number   Chemical Name
Deminimis
     Limit
                [[l,2-Phenylenebis(iminocarbonothioyl)]
                biscarbamic acid diethylester]
23564-05-8      Thiophanate methyl
79-19-6         Thiosemicarbazide
62-56-6         Thiourea
137-26-8        Thiram
1314-20-1       Thorium dioxide
7550-45-0       Titanium tetrachloride
108-88-3        Toluene
584-84-9        Toluene-2,4-diisocyanate               0.1
91-08-7         Toluene-2,6-diisocyanate               0.1
26471-62-5      Toluene diisocyanate (mixed            0.1
                isomers)
95-53-4         o-Toluidine                           0.1
636-21-5        o-Toluidine hydrochloride              0.1
8001-35-2       Toxaphene                             *
43121-43-3      Triadimefon                          1.0
                [ 1 -(4-Chlorophenoxy)-3,3-di-methyl-1 -(1H-
                1,2,4- triazol-l-yl)-2-butanone]
2303-17-5       Triallate                              1.0
68-76-8         Triaziquone                           1.0
                [2,5-Cyclohexadiene-l,4-dione, 2,3,5-tris(l-
                aziridinyl)-]
101200-48-0     Tribenuron methyl                     1.0
                [2-[[[[(4-Methoxy-6-methyl-l,3,5-triazin-2-
                yl)-methylamino] -carbonyljamino] sulfonyl]
                benzoic acid methyl ester)
1983-10-4       Tributyltin fluoride                     1.0
2155-70-6       Tributyltin methacrylate                1.0
78-48-8         S,S,S-Tributyltrithio-                   1.0
                phosphate (DBF)
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
75-69-4	Trichlorofluoromethane (CFC-11)	LO
CAS Number   Chemical Name
Deminimis
     Limit
              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]
                           Toxics Release Inventory Reporting Form and Instructions
                                                                 11-11

-------
                            Table II, EPCRA Section 313 Chemical List - RY2007
b.        Individually Listed Toxic Chemicals
          Arranged by CAS Number
                                           CAS Number
                                                           Deminimis
                                                           Chemical Name
                                                  Limit
                                                                           Arranged by CAS Number
CAS Number
Deminimis
Chemical Name
                                 Limit
                 Arranged by CAS Number
50-00-0
51-03-6
51-21-8
51-28-5
51-75-2
51-79-6
52-68-6
52-85-7
53-96-3
55-18-5
55-21-0
55-38-9
55-63-0
56-23-5
56-35-9
56-38-2
57-14-7
57-33-0
57-41-0
57-57-8
57-74-9
58-89-9
59-89-2
60-09-3
60-11-7
60-34-4
60-35-5
60-51-5
61-82-5
62-53-3
62-55-5
62-56-6
62-73-7
62-74-8
                                    0.1
                                    1.0
                                    1.0
                                    1.0
                                    0.1
                                    0.1
                                    1.0
                                    1.0
                                    0.1
                                    0.1
                                    1.0
                                    1.0
Formaldehyde
Piperonyl butoxide
Fluorouracil (5-Fluorouracil)
2,4-Dinitrophenol
Nitrogen mustard
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
Urethane (Ethyl carbamate)
Trichlorfon
[Phosphonic acid, (2,2,2-trichloro-l-
hydroxyethyl)-, dimethyl ester]
Famphur
2-Acetylaminofluorene
N-Nitrosodiethylamine
Benzamide
Fenthion
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester, phosphorothioic
acid]
Nitroglycerin                        1.0
Carbon tetrachloride                  0.1
Bis(tributyltin) oxide                  1.0
Parathion                           1.0
[Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl) ester]
1,1 -Dimethy Ihy drazine
Pentobarbital sodium
Phenytoin
beta-Propiolactone
Chlordane
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-hexahydro-]
Lindane
[Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(l.alpha.,2.alpha.,3.beta.,4.alpha,
5.alpha.,6.beta.)-]
N-Nitrosomorpholine
4-Aminoazobenzene
4-Dimethylaminoazobenzene
Methyl hydrazine
Acetamide
Dimethoate
Amitrole
Aniline
Thioacetamide
Thiourea
Dichlorvos
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
Sodium fluoroacetate
                                    0.1
                                    1.0
                                    0.1
                                    0.1
                                    0.1
                                    0.1
                                    0.1
                                    0.1
                                    1.0
                                    0.1
                                    1.0
                                    0.1
                                    1.0
                                    0.1
                                    0.1
                                    0.1
                                    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,  l,l'-(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)
 75-44-5         Phosgene                           1.0
 75-45-6         Chlorodifluoromethane              1.0
                 (HCFC-22)
 75-55-8         Propyleneimine                      0.1
 75-56-9         Propylene oxide                     0.1
 75-63-8         Bromotrifluoromethane              1.0
	(Halon 1301)	
                           Toxics Release Inventory Reporting Form and Instructions
                                                                                               11-12

-------
 Table II, EPCRA Section 313 Chemical List - RY2007

CAS Number
Deminimis
Chemical Name Limit
Arranged by CAS Number
75-65-0
75-68-3

75-69-4
75-71-8

75-72-9
75-86-5
75-88-7

76-01-7
76-02-8
76-06-2
76-13-1

76-14-2

76-15-3

76-44-8


76-87-9
77-47-4
77-73-6
77-78-1
78-48-8

78-84-2
78-87-5
78-88-6
78-92-2
79-00-5
79-01-6
79-06-1
79-10-7
79-11-8
79-19-6
79-21-0
79-22-1
79-34-5
79-44-7
79-46-9
79-94-7
80-05-7
80-15-9
80-62-6
81-07-2


81-88-9
82-28-0
82-68-8

tert-Butyl alcohol
1 -Chloro- 1 , 1 -difluoroethane
(HCFC-142b)
Trichlorofluoromethane (CFC-11)
Dichlorodifluoromethane
(CFC-12)
Chlorotrifluoromethane (CFC-13)
2-Methyllactonitrile
2-Chloro- 1 ,1,1 -trifluoroethane
(HCFC-133a)
Pentachloroethane
Trichloroacetyl chloride
Chloropicrin
Freon 113
[Ethane, l,l,2-trichloro-l,2,2,-trifluoro-
Dichlorotetrafluoroethane
(CFC-114)
Monochloropentafluoroethane
(CFC-115)
Heptachlor
[l,4,5,6,7,8,8-Heptachloro-3a,4,7,7a-
tetrahydro-4,7-methano- IH-indene]
Triphenyltin hydroxide
Hexachlorocyclopentadiene
Dicyclopentadiene
Dimethyl sulfate
S,S,S-Tributyltrithiophosphate
(DBF)
Isobutyraldehyde
1 ,2-Dichloropropane
2,3 -Dichloropropene
sec-Butyl alcohol
1 , 1 ,2-Trichloroethane
Trichloroethylene
Acrylamide
Acrylic acid
Chloroacetic acid
Thiosemicarbazide
Peracetic acid
Methyl chlorocarbonate
1 , 1 ,2,2-Tetrachloroethane
Dimethylcarbamyl chloride
2-Nitropropane
Tetrabromobisphenol A
4,4'-Isopropylidenediphenol
Cumene hydroperoxide
Methyl methacrylate
Saccharin (only persons who
manufacture are subject, no supplier
notification)
C.I. Food Red 15
1 -Amino-2-methylanthraquinone
Quintozene
[Pentachloro nitrobenzene]
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
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
*
1.0
1.0
1.0
1.0


1.0
0.1
1.0

CAS Number
Deminimis
Chemical Name
Limit
Arranged by CAS Number
84-74-2
85-01-8
85-44-9
86-30-6
87-62-7
87-68-3
87-86-5
88-06-2
88-75-5
88-85-7
88-89-1
90-04-0
90-43-7
90-94-8
91-08-7
91-20-3
91-22-5
91-59-8
91-94-1
92-52-4
92-67-1
92-87-5
92-93-3
93-65-2
94-11-1
94-36-0
94-58-6
94-59-7
94-74-6


94-75-7

94-80-4
94-82-6
95-47-6
95-48-7
95-50-1
95-53-4
95-54-5
95-63-6
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
Dibutyl phthalate
Phenanthrene
Phthalic anhydride
N-Nitrosodiphenylamine
2,6-Xylidine
Hexachloro- 1 ,3 -butadiene
Pentachlorophenol (PCP)
2,4,6-Trichlorophenol
2-Nitrophenol
Dinitrobutyl phenol (Dinoseb)
Picric acid
o-Anisidine
2-Phenylphenol
Michler's ketone
Toluene-2,6-diisocyanate
Naphthalene
Quinoline
beta-Naphthylamine
3 , 3 '-Dichlorobenzidine
Biphenyl
4-Aminobiphenyl
Benzidine
4-Nitrobiphenyl
Mecoprop
2,4-D isopropyl ester
Benzoyl peroxide
Dihydrosafrole
Safrole
Methoxone
((4-Chloro-2-methylphenoxy) acetic
(MCPA)
2,4-D [Acetic acid, (2,4-
dichlorophenoxy)-]
2,4-D butyl ester
2,4-DB
o-Xylene
o-Cresol
1 ,2-Dichlorobenzene
o-Toluidine
1 ,2-Phenylenediamine
1 ,2,4-Trimethylbenzene
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
1.0
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
1.0
1.0
0.1
1.0
0.1
0.1
0.1
1.0
0.1
0.1
1.0
0.1
0.1
0.1
0.1
0.1
1.0
0.1
0.1
0.1
acid)

0.1

0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0
0.1
0.1
1.0
0.1
0.1

0.1
1.0
0.1
1.0

0.1
0.1
Toxics Release Inventory Reporting Form and Instructions
11-13

-------
 Table II, EPCRA Section 313 Chemical List - RY2007

CAS Number
Deminimis
Chemical Name
Limit
Arranged by CAS Number

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
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
(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
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
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

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
3,5-

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
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
CAS Number
Deminimis
Chemical Name
Limit
Arranged by CAS Number
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

Maleic anhydride
m-Xylene
m-Cresol
1 , 3 -Pheny lenediamine
Bis(2-chloro-l-methylethyl) ether
Toluene
Chlorobenzene
Cyclohexanol
Phenol
2-Methylpyridine
Malononitrile
2-Methoxyethanol
n-Hexane
trans- 1 ,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
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
-4-
(chlorophenyl)-.alpha.-(trichloromethyl)-]
116-06-3
117-79-3
117-81-7
118-74-1
119-90-4
119-93-7

120-12-7
120-36-5
120-58-1
120-71-8
120-80-9
120-82-1
120-83-2
121-14-2
121-44-8
121-69-7
121-75-5
122-34-9
122-39-4
122-66-7

123-31-9
123-38-6
123-63-7
123-72-8
Aldicarb
2-Aminoanthraquinone
Di(2-ethylhexyl) phthalate
Hexachlorobenzene
3 , 3 '-Dimethoxybenzidine
3 , 3 '-Dimethy Ibenzidine
(o-Tolidine)
Anthracene
2,4-DP
Isosafrole
p-Cresidine
Catechol
1 ,2,4-Trichlorobenzene
2,4-Dichlorophenol
2,4-Dinitrotoluene
Triethylamine
N,N-Dimethylaniline
Malathion
Simazine
Diphenylamine
1 ,2-Diphenylhydrazine
(Hydrazobenzene)
Hydroquinone
Propionaldehyde
Paraldehyde
Butyraldehyde
1.0
0.1
0.1
*
0.1
0.1

1.0
0.1
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1

1.0
1.0
1.0
1.0
Toxics Release Inventory Reporting Form and Instructions
11-14

-------
 Table II, EPCRA Section 313 Chemical List - RY2007

CAS Number
Deminimis
Chemical Name Limit
Arranged by CAS Number
123-91-1
124-40-3
124-73-2

126-72-7

126-98-7
126-99-8
127-18-4

128-03-0

128-04-1
128-66-5
131-11-3
131-52-2
132-27-4
132-64-9
133-06-2


133-07-3
133-90-4

134-29-2
134-32-7
135-20-6


136-45-8
137-26-8
137-41-7

137-42-8

138-93-2

139-13-9
139-65-1
140-88-5
141-32-2
142-59-6
148-79-8

149-30-4

150-50-5
150-68-5
151-56-4
156-10-5
156-62-7
191-24-2
298-00-0
300-76-5
1,4-Dioxane
Dimethylamine
Dibromotetrafluoroethane
(Halon 2402)
Tris(2, 3 -dibromopropy 1)
phosphate
Methacrylonitrile
Chloroprene
Tetrachloroethylene
(Perchloroethylene)
Potassium
dimethyldithiocarbamate
Sodium dimethyldithiocarbamate
C.I. Vat Yellow 4
Dimethyl phthalate
Sodium pentachlorophenate
Sodium o-phenylphenoxide
Dibenzofuran
Captan
0.1
1.0
1.0

0.1

1.0
0.1
0.1

1.0

1.0
1.0
1.0
1.0
0.1
1.0
1.0
[ IH-Isoindole- 1 ,3 (2H)-dione, 3a,4,7,7a-
tetrahydro-2-[(trichloromethyl)thio]-]
Folpet
Chloramben
[Benzoic acid, 3-amino-2,5-dichloro-]
o-Anisidine hydrochloride
alpha-Naphthylamine
Cupferron
[Benzeneamine, N-hydroxy-N-nitroso,
ammonium salt]
Dipropyl isocinchomeronate
Thiram
Potassium N-methyldithio-
carbamate
Metham sodium (Sodium
methyldithiocarbamate)
Disodium cyanodithioimido-
carbonate
Nitrilotriacetic acid
4,4'-Thiodianiline
Ethyl acrylate
Butyl acrylate
Nabam
Thiabendazole
[2-(4-Thiazolyl)-lH-benzimidazole]
2-Mercaptobenzothiazole
(MET)
Merphos
Monuron
Ethyleneimine (Aziridine)
p-Nitrosodiphenylamine
Calcium cyanamide
Benzo(g,h,i)perylene
Methyl parathion
Naled

1.0
1.0

0.1
0.1
0.1


1.0
1.0
1.0

1.0

1.0

0.1
0.1
0.1
1.0
1.0
1.0

1.0

1.0
1.0
0.1
1.0
1.0
*
1.0
1.0
CAS Number
Deminimis
Chemical Name Limit
Arranged by CAS Number
301-12-2


302-01-2
306-83-2

309-00-2




314-40-9


319-84-6
330-54-1
330-55-2
333-41-5
334-88-3
353-59-3

354-11-0

354-14-3

354-23-4

354-25-6

357-57-3
422-44-6

422-48-0

422-56-0

431-86-7

460-35-5

463-58-1
465-73-6
492-80-8

505-60-2

507-55-1

510-15-6


528-29-0
532-27-4
533-74-4
Oxy demeton methyl 1 . 0
[S-(2-(Ethylsulfinyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
Hydrazine 0.1
2,2-Dichloro-l, 1, 1-trifluoroethane 1.0
(HCFC-123)
Aldrin *
[ 1 ,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.)-]
Bromacil 1.0
(5 -Bromo-6-methy 1-3 -(1 -methy Ipropy 1)-
2,4( lH,3H)-pyrimidinedione)
alpha-Hexachlorocyclohexane 0.1
Diuron 1.0
Linuron 1.0
Diazinon 1.0
Diazomethane 1.0
Bromochlorodifluoromethane 1.0
(Halon 1211)
l,l,l,2-Tetrachloro-2-fluoroethane 1.0
(HCFC-121a)
1,1,2,2-Tetrachloro-l-fluoroethane 1.0
(HCFC-121)
l,2-Dichloro-l,l,2- 1.0
trifluoroethane (HCFC-123a)
l-Chloro-1,1,2,2- 1.0
tetrafluoroethane (HCFC-124a)
Brucine 1.0
1,2-Dichloro-l, 1,2,3,3- 1.0
pentafluoropropane (HCFC-225bb)
2,3-Dichloro-l, 1,1,2,3- 1.0
pentafluoropropane (HCFC-225ba)
3,3-Dichloro-l, 1,1,2,2- 1.0
pentafluoropropane (HCFC-225ca)
1,2-Dichloro-l, 1,3,3,3- 1.0
pentafluoropropane (HCFC-225da)
3-Chloro-l,l,l-trifluoropropane 1.0
(HCFC-253fb)
Carbonyl sulfide 1.0
Isodrin *
C.I. Solvent Yellow 34 0.1
(Auramine)
Mustard gas 0.1
[Ethane, l,l'-thiobis[2-chloro-]
1,3-Dichloro-l, 1,2,2,3- 1.0
pentafluoropropane (HCFC-225cb)
Chlorobenzilate 1 . 0
[Benzeneacetic acid, 4-chloro-.alpha.-(4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
o-Dinitrobenzene 1.0
2-Chloroacetophenone 1.0
Dazomet 1.0
Toxics Release Inventory Reporting Form and Instructions
11-15

-------
 Table II, EPCRA Section 313 Chemical List - RY2007

CAS Number
Deminimis
Chemical Name
Limit
Arranged by CAS Number


534-52-1
540-59-0
541-41-3
541-53-7
541-73-1
542-75-6
542-76-7
542-88-1
554-13-2
556-61-6

563-47-3
569-64-2
584-84-9
593-60-2
594-42-3
606-20-2
608-93-5
612-82-8


612-83-9

615-05-4
615-28-1

621-64-7
624-18-0

624-83-9
630-20-6
636-21-5
639-58-7
680-31-9
684-93-5
709-98-8

759-73-9
759-94-4

764-41-0
812-04-4

834-12-8


842-07-9
872-50-4
924-16-3
924-42-5
957-51-7
961-11-5
(Tetrahydro-3 ,5-dimethyl-2H- 1 ,3 ,5-
thiadiazine-2-thione)
4,6-Dinitro-o-cresol
1 ,2-Dichloroethylene
Ethyl chloroformate
2,4-Dithiobiuret
1 ,3 -Dichlorobenzene
1 ,3 -Dichloropropylene
3 -Chloropropionitrile
Bis(chloromethyl) ether
Lithium carbonate
Methyl isothiocyanate
[Isothiocyanatomethane]
3 -Chloro-2-methyl- 1 -propene
C.I. Basic Green 4
Toluene-2,4-diisocyanate
Vinyl bromide
Perchloromethyl mercaptan
2,6-Dinitrotoluene
Pentachlorobenzene
3 ,3 '-Dimethylbenzidine
dihydrochloride (o-Tolidine
dihydrochloride)
3 ,3 '-Dichlorobenzidine
dihydrochloride
2,4-Diaminoanisole
1 ,2-Phenylenediamine
dihydrochloride
N-Nitrosodi-n-propylamine
1 ,4-Phenylenediamine
dihydrochloride
Methyl isocyanate
1,1, 1 ,2-Tetrachloroethane
o-Toluidine hydrochloride
Triphenyltin chloride
Hexamethylphosphoramide
N-Nitroso-N-methylurea
Propanil (N-(3,4-Dichlorophenyl)
propanamide)
N-Nitroso-N-ethylurea
Ethyl dipropylthiocarbamate
(EPTC)
1 ,4-Dichloro-2-butene
1 , 1 -Dichloro- 1 ,2,2-trifluoroethane
(HCFC-123b)
Ametryn
(N-Ethyl-N' -(1 -methylethyl)-6-


1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0

0.1
1.0
0.1
0.1
1.0
0.1
*
0.1


0.1

0.1
1.0

0.1
1.0

1.0
1.0
0.1
1.0
0.1
0.1
1.0

0.1
1.0

1.0
1.0

1.0

(methylthio)-l,3,5,-triazine-2,4-diamine)
C.I. Solvent Yellow 14
N-Methyl-2-pyrrolidone
N-Nitrosodi-n-butylamine
N-Methylolacrylamide
Diphenamid
Tetrachlorvinphos
1.0
1.0
0.1
1.0
1.0
1.0
CAS Number
Deminimis
Chemical Name Limit
Arranged by CAS Number


989-38-8
1114-71-2


1120-71-4
1134-23-2
1163-19-5
1313-27-5
1314-20-1
1319-77-3
1320-18-9

1330-20-7
1332-21-4
1335-87-1
1336-36-3
1344-28-1
1464-53-5
1563-66-2
1582-09-8


1634-04-4
1649-08-7

1689-84-5

1689-99-2


1717-00-6

1836-75-5

1861-40-1


1897-45-6


1910-42-5
1912-24-9


1918-00-9

1918-02-1
1918-16-7


1928-43-4
1929-73-3
[Phosphoric acid, 2-chloro-l-(2,4,5-
trichlorophenyl)ethenyldimethyl ester]
C.I. Basic Red 1 1.0
Pebulate 1.0
[Butylethylcarbamothioic acid S-propyl
ester]
Propane sultone 0.1
Cycloate 1.0
Decabromodiphenyl oxide 1.0
Molybdenum trioxide 1 . 0
Thorium dioxide 1 . 0
Cresol (mixed isomers) 1.0
2,4-D propylene glycol butyl 0. 1
ether ester
Xylene (mixed isomers) 1.0
Asbestos (friable) 0.1
Hexachloro naphthalene 1 . 0
Fob/chlorinated biphenyls (PCBs) *
Aluminum oxide (fibrous forms) 1.0
Diepoxybutane 0.1
Carbofuran 1.0
Trifluralin *
[Benezeneamine, 2,6-dinitro-N,N-dipropyl-
4-(trifluoromethyl)-]
Methyl tert-buty 1 ether 1 . 0
l,2-Dichloro-l,l-difluoroethane 1.0
(HCFC-132b)
Bromoxynil 1.0
(3,5-Dibromo-4-hydroxybenzonitrile)
Bromoxynil octanoate 1.0
(Octanoic acid, 2,6-dibromo-4-cyanophenyl
ester)
1,1-Dichloro-l-fluoroethane 1.0
(HCFC-141b)
Nitrofen 0.1
[Benzene, 2,4-dichloro- 1 -(4-nitrophenoxy)-]
Benfluralin 1.0
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)benzenamine)
Chlorothalonil 0.1
[1,3-Benzenedicarbonitrile, 2,4,5,6-
tetrachloro-]
Paraquat dichloride 1 . 0
Atrazine 1.0
(6-Chloro-N-ethyl-N' -(1 -methylethyl)- 1,3,5-
triazine-2,4-diamine)
Dicamba 1.0
(3 ,6-Dichloro-2-methoxybenzoic acid)
Picloram 1.0
Propachlor 1.0
[2-Chloro-N-( 1 -methylethyl)-N-
phenylacetamide]
2,4-D 2-ethylhexyl ester 0. 1
2,4-D butoxyethyl ester 0. 1
Toxics Release Inventory Reporting Form and Instructions
11-16

-------
 Table II, EPCRA Section 313 Chemical List - RY2007

CAS Number

1929-82-4

1937-37-7
1982-69-0


1983-10-4
2032-65-7
2155-70-6
2164-07-0


2164-17-2


2212-67-1


2234-13-1
2300-66-5
2303-16-4


2303-17-5
2312-35-8
2439-01-2


2439-10-3

2524-03-0
2602-46-2
2655-15-4

2699-79-8
2702-72-9
2832-40-8
2837-89-0

2971-38-2
3118-97-6
3383-96-8
3653-48-3


3761-53-3
4080-31-3

4170-30-3
4549-40-0
4680-78-8
5234-68-4



Deminimis
Chemical Name Limit
Arranged by CAS Number
Nitrapyrin 1.0
(2-Chloro-6-(trichloromethyl)pyridine)
C.I. Direct Black 3 8 0.1
Sodium dicamba 1.0
[3 ,6-Dichloro-2-methoxybenzoic acid,
sodium salt]
Tributyltin fluoride 1 . 0
Methiocarb 1.0
Tributyltin methacrylate 1 . 0
Dipotassium endothall 1.0
[7-Oxabicyclo(2.2. l)heptane-2,3-
dicarboxylic acid, dipotassium salt]
Fluometuron 1.0
[Urea, N,N-dimethyl-N'-[3-
(trifluoromethy l)pheny 1] -]
Molinate 1.0
(lH-Azepine-1-carbothioic acid, hexahydro-
S-ethyl ester)
Octachloronaphthalene 1.0
Dimethylamine dicamba 1.0
Diallate 1.0
[Carbamothioic acid, bis(l-methylethyl)-S-
(2,3-dichloro-2-propenyl) ester]
Triallate 1.0
Propargite 1.0
Chinomethionat 1.0
[6-Methyl- 1 ,3 -dithiolo [4,5-b]quinoxalin-2-
one]
Dodine 1.0
[Dodecylguanidine monoacetate]
Dimethyl chlorothiophosphate 1.0
C.I. Direct Blue 6 0.1
2,3,5-Trimethylphenyl methyl 1.0
carbamate
Sulfuryl fluoride (Vikane) 1 .0
2,4-D sodium salt 0.1
C.I. Disperse Yellow 3 1.0
2-Chloro-l,l,l,2- 1.0
tetrafluoroethane (HCFC-124)
2,4-D Chlorocrotyl ester 0. 1
C.I. Solvent Orange 7 1.0
Temephos 1.0
Methoxone sodium salt 0. 1
((4-Chloro-2-methylphenoxy) acetate
sodium salt)
C.I. Food Red 5 0.1
l-(3-Chloroallyl)-3,5,7-triaza-l- 1.0
azoniaadamantane chloride
Crotonaldehyde 1.0
N-Nitrosomethylvinylamine 0.1
C.I. Acid Green 3 1.0
Carboxin 1.0
(5,6-Dihydro-2-methyl-N-phenyl-l,4-
oxathiin-3 -carboxamide)

CAS Number

5598-13-0


5902-51-2


6459-94-5
7287-19-6


7429-90-5
7439-92-1



7439.96-5
7439.97-6
7440-02-0
7440-22-4
7440-28-0
7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-47-3
7440-48-4
7440-50-8
7440-62-2

7440-66-6
7550-45-0
7632-00-0
7637-07-2
7647-01-0



7664-39-3
7664-41-7





7664-93-9



7696-12-0





Deminimis
Chemical Name Limit
Arranged by CAS Number
Chlorpyrifos methyl 1.0
[O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate]
Terbacil 1.0
[5-Chloro-3-(l,l-dimethylethyl)-6-methyl-
2,4( lH,3H)-pyrimidinedione]
C.I. Acid Red 114 0.1
Prometryn 1.0
[N,N'-Bis(l-methylethyl)-6-methylthio-
1 ,3 ,5-triazine-2,4-diamine]
Aluminum (fume or dust) 1 .0
Lead *
(when lead is contained in stainless steel,
brass or bronze alloys the de minimis level is
0.1)
Manganese 1.0
Mercury *
Nickel 0.1
Silver 1.0
Thallium 1.0
Antimony 1.0
Arsenic 0.1
Barium 1.0
Beryllium 0.1
Cadmium 0.1
Chromium 1.0
Cobalt 0.1
Copper 1.0
Vanadium (except when contained 1 . 0
in an alloy)
Zinc (fume or dust) .0
Titanium tetrachloride .0
Sodium nitrite .0
Boron trifluoride .0
Hydrochloric acid .0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any
particle size)
Hydrogen fluoride 1 . 0
Ammonia 1.0
(includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium
salts and other sources; 10 percent of total
aqueous ammonia is reportable under this
listing)
Sulfuric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
Tetramethrin 1.0
[2,2-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]
Toxics Release Inventory Reporting Form and Instructions
11-17

-------
Table II, EPCRA Section 313 Chemical List - RY2007

CAS Number
Deminimis
Chemical Name Limit
Arranged by CAS Number
7697-37-2
7723-14-0
7726-95-6
7758-01-2
7782-41-4
7782-49-2
7782-50-5
7786-34-7
7803-51-2
8001-35-2
8001-58-9
9006-42-2
10028-15-6
10034-93-2
10049-04-4
10061-02-6
10294-34-5
10453-86-8



12122-67-7


12427-38-2


13194-48-4


13356-08-6


13463-40-6
13474-88-9

13684-56-5
14484-64-1

15972-60-8
16071-86-6
16543-55-8
17804-35-2
19044-88-3


19666-30-9



20325-40-0


20354-26-1
Nitric acid 1.0
Phosphorus (yellow or white) 1.0
Bromine 1.0
Potassium bromate 0 . 1
Fluorine 1.0
Selenium 1.0
Chlorine 1.0
Mevinphos 1.0
Phosphine 1.0
Toxaphene *
Creosote 0.1
Metiram 1.0
Ozone 1.0
Hydrazine sulfate 0.1
Chlorine dioxide 1.0
trans- 1 , 3 -Dichloropropene 0 . 1
Boron trichloride 1 .0
Resmethrin 1.0
[[5-(Phenylmethyl)-3-furanyl]methyl- 2,2-
dimethyl-3 -(2 -methyl- 1 -propenyl)
cy clopropanecarboxylate] ]
Zineb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
zinc complex]
Maneb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
manganese complex]
Ethoprop 1.0
[Phosphorodithioic acid O-ethyl S,S-
dipropyl ester]
Fenbutatin oxide 1.0
(Hexakis(2-methyl-2-phenylpropyl)
distannoxane)
Iron pentacarbonyl 1 .0
l,l-Dichloro-l,2,2,3,3- 1.0
pentafluoropropane (HCFC-225cc)
Desmedipham 1.0
Ferbam 1.0
[Tris(dimethylcarbamodithioato-S, S ')iron]
Alachlor 1.0
C.I. Direct Brown 95 0.1
N-Nitrosonornicotine 0.1
Benomyl 1.0
Oryzalin 1.0
[4-(Dipropylamino)-3,5-
dinitrobenzenesulfonamide]
Oxydiazon 1.0
[3-[2,4-Dichloro-5-(l-methylethoxy)
phenyl] -5-( 1 , 1 -dimethylethyl)- 1 ,3 ,4-
oxadiazol-2(3H)-one]
3,3'-Dimethoxybenzidine 0.1
dihydrochloride (o-Dianisidine
dihydrochloride)
Methazole 1.0
Deminimis
CAS Number Chemical Name Limit
Arranged by CAS Number
[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-


23564-05-
23564-06-


23950-58-
25311-71-



25321-14-
25321-22-
25376-45-
26002-80-



26471-62-

26628-22-
26644-46-


27314-13-



28057-48-

28249-77-


28407-37-
29082-74-
29232-93-



30560-19-


31218-83-



33089-61-

Toxics Release Inventory Reporting Form
5 Bendiocarb 1.0
[2,2-Dimethyl- 1 ,3 -benzodioxol-4-ol
methylcarbamate]
> Thiophanate methyl 1.0
) 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
I Phenothrin 1.0
[2,2-Dimethy 1-3 -(2 -methyl- 1 -
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester]
i Toluene diisocyanate 0.1
(mixed isomers)
> Sodium azide 1.0
1 Triforine 1.0
[N,N' -[ 1 ,4-Piperazinediylbis (2,2,2-
trichloroethylidene)]bisformamide]
I 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 1.0
1 Octachlorostyrene *
7 Pirimiphos methyl 1.0
[O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-
dimethylphosphorothioate]
I Acephate 1.0
(Acetylphosphoramidothioic acid O,S-
dimethyl ester)
I Propetamphos 1.0
[3-[(Ethylamino)
methoxyphosphinothioyl]oxy]-2-butenoic
acid, 1-methylethyl ester]
[ Amitraz 1.0

and Instructions 11-18

-------
 Table II, EPCRA Section 313 Chemical List - RY2007

CAS Number
Deminimis
Chemical Name Limit
Arranged by CAS Number
34014-18-1


34077-87-7
35367-38-5
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

Tebuthiuron 1.0
[N- [5 -( 1 , 1 -Dimethy lethyl)- 1 , 3 ,4-thiadiazol-
2-yl] -N,N' -dimethylurea]
Dichlorotrifluoroethane 1.0
Diflubenzuron 1.0
Sulprofos 1.0
[O-Ethyl O-[4-(methylthio)phenyl]-
phosphorodithioic acid S-propyl ester]
Imazalil 1.0
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl] - IH-imidazole]
l-Bromo-l-(bromomethyl)-l,3- 1.0
propanedicarbonitrile
Diethatyl ethyl 1.0
2,4-Diaminoanisole sulfate 0.1
Dinocap 1.0
Fenpropathrin 1.0
[2,2,3 ,3 -Tetramethylcyclopropane
carboxylic acid cyano(3-
phenoxyphenyl)methyl ester]
Pendimethalin *
[N-(l-Ethyrpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine]
Profenofos 1.0
[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 1.0
Diclofop methyl 1.0
[2-[4-(2,4-Dichlorophenoxy)-
phenoxy]propanoic acid, methyl ester]
Fenvalerate 1.0
[4-Chloro-alpha-( 1 -methylethyl)-
benzeneacetic acid cyano(3-
phenoxyphenyl)methyl ester]
Permethrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropane carboxylic acid,
(3-phenoxyphenyl)methyl ester]
Bromacil, lithium salt 1.0
[2,4(lH,3H)-Pyrimidinedione, 5-bromo-6-
methyl-3-(l-methylpropyl), lithium salt]
2,4-D 2-ethyl-4-methyrpentyl 0.1
ester
Dazomet, sodium salt 1.0
[Tetrahydro-S ,5-dimethyl-2H- 1 ,3 ,5-
CAS Number
Deminimis
Chemical Name Limit
Arranged by CAS Number

55290-64-7


55406-53-6

57213-69-1
59669-26-0
60168-88-9


60207-90-1


62476-59-9


63938-10-3
64902-72-3



64969-34-2
66441-23-4



67485-29-4




68085-85-8



68359-37-5




69409-94-5



69806-50-4



71751-41-2
72178-02-0


72490-01-8
thiadiazine-2-thione, ion(l-), sodium]
Dimethipin 1.0
[2,3-Dihydro-5,6-dimethyl-l,4-dithiin
1,1,4,4-tetraoxide]
3-Iodo-2-propynylbutyl 1.0
carbamate
Triclopyr triethy lammonium salt 1.0
Thiodicarb 1.0
Fenarimol 1.0
[.alpha.-(2-Chlorophenyl)-.alpha.-(4-
chlorophenyl)-5-pyrimidinemethanol]
Propiconazole 1.0
[l-[2-(2,4-Dichlorophenyl)-4-propyl- 1,3-
dioxolan-2-yl] -methyl- 1H- 1 ,2,4,-triazole]
Acifluorf en, sodium salt 1.0
[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]
Hy dramethylnon 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]
Fluazif op butyl 1.0
[2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]phenoxy]propanoic acid,
butyl ester]
Abamectin [ Avermectin B 1 ] 1.0
Fomesafen 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
N-methylsurfony^^-nitrobenzamide]
Fenoxycarb 1.0
Toxics Release Inventory Reporting Form and Instructions
11-19

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                            Table II, EPCRA Section 313 Chemical List - RY2007
CAS Number
      Deminimis
      Chemical Name
Limit
                Arranged by CAS Number
                [[2-(4-Phenoxy phenoxy)ethyl]carbamic
                acid ethyl ester]
74051-80-2      Sethoxydim                         1.0
                [2-[ 1 -(Ethoxyimino)butyl] -5-[2-
                (ethylthio)propyl] -3 -hydroxyl-2-cyclohexen-
                1-one]
76578-14-8      Quizalofop-ethyl                     1.0
                [2-[4-[(6-Chloro-2-quinoxalinyl)
                oxy]phenoxy]propanoic acid ethyl ester]
77501-63-4      Lactofen                            1.0
                [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)methy lamino] carbony 1]
                amino] surfonyl]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)
definition of an OSHA carcinogen in which case the 0.1% de
minimis concentration applies. The de minimis concentration for
each category is provided in parentheses.  The  de minimis
exemption is not available  for PBT chemicals, therefore an
asterisk appears where a de minimis limit would otherwise appear.
 However, for purposes of the supplier notification requirement
only, such limits are provided in Appendix D.

N010   Antimony Compounds (1.0)
        Includes any unique chemical substance that contains
        antimony as part of that chemical's infrastructure.

N020   Arsenic Compounds (inorganic compounds: 0.1;
        organic compounds: 1.0)
        Includes any unique chemical substance that contains
        arsenic as part of that chemical's infrastructure.

N040   Barium Compounds (1.0)
        Includes any unique chemical substance that contains
        barium as part of that chemical's infrastructure. This
        category does not include:
        Barium sulfate CAS Number 7727-43-7

N050   Beryllium Compounds (0.1)
        Includes any unique chemical substance that
        contains beryllium as part of that chemical's
        infrastructure.

N078   Cadmium Compounds (0.1)
        Includes any unique chemical substance that
        contains cadmium as part of that chemical's
        infrastructure.
N084   Chlorophenols (0.1)
                                                                                        •H(5-x)
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
                              Where x = 1 to 5

          N090    Chromium Compounds
                  (except for chromite ore mined in the Transvaal
                  Region of South Africa and the unreacted ore
                  component of the chromite ore processing residue
                  (COPR). COPR is the solid waste remaining after
                  aqueous extraction of oxidized chromite ore that
                  has been combined with soda ash and kiln roasted
                  at approximately 2,000 deg.F.)
                  (chromium VI compounds: 0.1; chromium III
                  compounds: 1.0)
                  Includes any unique chemical substance that contains
                  chromium as part of that chemical's
                           Toxics Release Inventory Reporting Form and Instructions
                                                                                                    11-20

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                            Table II, EPCRA Section 313 Chemical List - RY2007
        infrastructure.

N096   Cobalt Compounds (inorganic compounds: 0.1;
        organic compounds: 1.0)
        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(phenylisocyanate)
                        (MDI)
        3173-72-6       1,5-Naphthalene
                        diisocyanate
        123-61-5        1,3-Phenylene diisocyanate
        104-49-4        1,4-Phenylene diisocyanate
        9016-87-9       Polymeric diphenylmethane
                        diisocyanate
        16938-22-0      2,2,4-Trimethylhexamethylene
	diisocyanate	
        15646-96-5     2,4,4-Trimethylhexamethylene
                       diisocyanate

N150   Dioxin and Dioxin-Like Compounds
        (Manufacturing; and the processing or otherwise
        use of dioxin 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
o
5
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
                           Toxics Release Inventory Reporting Form and Instructions
                                                    11-21

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                            Table II, EPCRA Section 313 Chemical List - RY2007
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
N503
N511
Nickel Compounds (0.1)
Includes any unique chemical substance that contains
nickel as part of that chemical's infrastructure.

Nicotine and salts (1.0)
Includes any unique chemical substance that contains
nicotine or a nicotine salt as part of that chemical's
infrastructure.

Nitrate compounds (water dissociable; reportable
only when in aqueous solution) (1.0)
                                     H(10-x)
                    Where x = 1 to 10
 N575  Polybrominated Biphenyls (PBBs) (0.1)

N583   Polychlorinated alkanes (C10 to C13) (1.0, except for
        those members of the category that have an average
        chain length of 12 carbons and contain an average
        chlorine content of 60% by weight which are subject
        to the 0.1% de minimis)
N770   Vanadium Compounds (1.0)
        Includes any unique chemical substance that contains
	vanadium as part of that chemical's	
                                                  N590
                                                          N725
                                                          N740
                                                          N746
                                                          N760
CxH2x+2-yC1y
where x= 10 to  13;
y = 3 to 12; and
the average chlorine content ranges from 40 — 70% with
the limiting molecular formulas C^gHi 9613 and C^H
16C112

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

Selenium Compounds (1.0)
Includes any unique chemical substance that contains
selenium as part of that chemical's infrastructure.

Silver Compounds (1.0)
Includes any unique chemical substance that contains
silver as part of that chemical's infrastructure.

Strychnine and salts (1.0)
Includes any unique chemical substance that contains
strychnine or a strychnine salt as part of that chemical's
infrastructure.

Thallium Compounds (1.0)
Includes any unique chemical substance that contains
thallium as part of that chemical's infrastructure.
                                                          infrastructure.
                           Toxics Release Inventory Reporting Form and Instructions
                                                                                                     11-22

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                           Table II, EPCRA Section 313 Chemical List - RY2007
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.
                          Toxics Release Inventory Reporting Form and Instructions                         11-23

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   Table III. State Abbreviations
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Marshall Islands
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
AL
AK
AS
AZ
AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL
IN
IA
KS
KY
LA
ME
MH
MD
MA
MI
MN
MS
MO
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Northern Marianas Islands
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
MT
NE
NV
NH
NJ
NM
NY
NC
ND
MP
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
WI
WY
Toxics Release Inventory Reporting Form and Instruction
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
KN

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
North Korea
Toxics Release L
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
KQ
KR
KS
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
Kingman Reef
Kiribati
South Korea


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

KT
KU
KZ
nventory Reporting Form and Instructions
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
Christmas Island
Kuwait
Kazakhstan
IV-1

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                                Table IV. Country Codes
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
NT

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
Netherlands
Antilles
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
SZ
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
Switzerland
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

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

IV-2
Toxics Release Inventory Reporting Form and Instructions

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Appendix A.   TRI  Federal  Facility Reporting
Information
Special Instructions for TRI
Federal Facility Reporting


A.1  Why  Do Federal

Facilities Need  to

Report?

Executive  Order  13423,  "Strengthening Federal
Environmental   Energy,   and    Transportation
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. Contracts entered into after the date  of
this order for contractor operation of  government-
owned facilities or vehicles require the contractor to
comply with the provisions of this order with respect
to such facilities or vehicles to the same extent as the
agency would be required to comply if the agency
operated facilities or vehicles.

For more information  on  Executive Order  13423
please refer to the implementing instructions,  which
can  be  found  on  the   TRI  home  page  at
http://www.epa.gov/tri


A.2  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.


A.3  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 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.


A.4  Magnetic Media

Reporting

All  federal facilities  are  required to report using
Internet reporting.  If the GOCO submits its reports
on magnetic media to EPA and to the federal facility,
the  federal facility  may  submit  magnetic media
copies of their GOCO TRI reports to EPA provided
that those reports account for all subject activities at
the  facility.   Magnetic  media   reports must be
accompanied by a cover letter which includes:

   •  Required Form R certification statement;
                  Toxics Release Inventory Reporting Forms and Instructions
                                       A-l

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                                        Appendix A
   •  List of the chemicals reported on the federal
      facility's disk; and
   •  List that identifies the contractor(s) [if any] by
      name  and by TRIFID number if they have an
      assigned TRIFID number, and the chemicals
      they reported (which are on the contractors'
      attachment disk(s)).


A.5 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 (TRIFID),
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 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 FormRs (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
       Westinghouse Operations.
                  Site
A.6  How to Report Your

North American Industry

Classification System

(NAICS) Code
Federal facilities should report the NAICS  code
which most closely represents the activities taking
place at the site. Additional guidance on determining
your NAICS  code  is provided in the Forms and
Instructions booklet.  The table on the next page
contains  Public  Administration  NAICS  codes
covering    executive,    legislative,    judicial,
administrative and regulatory activities of the Federal
government.   Government-owned  and  operated
business establishments are classified in major
NAICS groups according to the activity  in which
they are engaged. For example,  a Veterans Hospital
would be classified in Group 806  - Hospitals.


A.7  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.


A.8  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  reporter  should
photocopy the original form and 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.
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                                      Appendix A
A.9  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.


A.10 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. For contact information, see the
TRI Home Page at http://www.epa.gov/tri.


A.11 North American

Industry  Classification

System Codes 921-928

Sector 92 - Public Administration

921    Executive, Legislative, and Other
General Government Support

92111  Executive Offices
92112  Legislative Bodies
92113  Public Finance Activities
92114  Executive and Legislative Offices Combined
92115  American Indian and Alaska Native Tribal
       Governments
92119  General Government, Not Elsewhere
       Classified

922    Justice, Public Order, and Safety
Activities

92211  Courts
92212  Police Protection
92213  Legal Counsel and Prosecution
92214  Correctional Institutions
92215  Parole Offices and Probation Offices
92216  Fire Protection
92219  Other Justice, Public Order and Safety
       Activities
923    Administration of Human
Resource Programs

92311   Administration of Educational Programs
92312   Administration of Public Health Programs
92313   Administration of Human Resource
       Programs (Except Education, Public Health,
       and Veterans' Affairs Programs)
92314   Administration of Veterans Affairs

924    Administration of Environmental
Quality Programs

92411   Administration of Air and Water Resource
       and Solid Waste Management Programs
92412   Administration of Conservation Programs

925    Administration of Housing
Programs, Urban Planning, and
Community Development

92511   Administration of Housing Programs
92512   Administration of Urban Planning and
       Community and Rural Development

926    Administration of Economic
Programs

92611   Administration of General Economic
       Programs
92612   Regulation and Administration of
       Transportation Programs
92613   Regulation and Administration of
       Communications, Electric, Gas, and Other
       Utilities
92614   Regulation of Agricultural Marketing and
       Commodities
92615   Regulation, Licensing, and Inspection of
       Miscellaneous Commercial Sectors

927    Space Research and Technology

92711   Space Research and Technology

928    National Security and
International Affairs

92811   National Security
92812   International Affairs
                 Toxics Release Inventory Reporting Forms and Instructions
                                     A-3

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Appendix B.  Reporting Codes for EPA Form R
and Instructions for Reporting Metals

B.1 Form R Part II

Revision Codes:

RRl New Monitoring Data
RR2 New Emission Factor(s)
RR3 New Chemical Concentration Data
RR4 Recalculations)
RR5 Other Reason(s)
Withdrawal Codes:

WTl Did not meet the reporting threshold for
manufacturing, processing, or otherwise use
WT2 Did not meet the reporting threshold for

number of employees
WT3 Not in a covered NAICS Code
WO1 Other reason(s)

Section 1.1. CAS Number

EPCRA Section 313 Chemical Category
o t/
s
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
N 1 7 lEthy lenebisdithiocarbamic
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
N5 1 1 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 From To
01 0 99
m inn QQQ
UZ 1UU yyy
03 1,000 9,999
04 10,000 99,999
05 100,000 999,999
06 1,000,000 9,999,999
07 10,000,000 49,999,999
08 50,000,000 99,999,999
09 100,000,000 499,999,999
10 500,000,000 999,999,999
11 1 billion 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 Range Obs)
A 1-10
B 11-499
C 500-999

Basis of Estimate

Ml- Estimate is based on continuous
monitoring data or measurements for the
EPCRA section 313 chemical.




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                                           Appendix B
M2- Estimate is based on periodic or random
        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
        streams entering and leaving process
        equipment.

El-     Estimate is based on published emission
        factors, such as those relating release quantity
        to through-put or equipment type (e.g., air
        emission factors).

E2-  Estimate is based on site specific 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.

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) C
        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 C Energy
                                         Recovery
                                  M93   Transfer to Waste Broker C Recycling
                                  M94   Transfer to Waste Broker C Disposal
                                  M95   Transfer to Waste Broker C 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
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                                            Appendix B
H101   Sludge treatment and/or dewatering
H103   Absorption
Hill   Stabilization or chemical fixation prior to
        disposal
H112   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

UOl    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)


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 C 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
W3 5    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
                     Toxics Release Inventory Reporting Forms and Instructions
                                        B-3

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                                           Appendix B
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
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                                          Appendix B
B.2  Reporting  the Waste Management  of Metals

This appendix outlines how the TRI-ME 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 greaterthat 5000 British thermal units (Bru) 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 Compounds
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
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.
                    Toxics Release Inventory Reporting Forms and Instructions
                                                                   B-5

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                                           Appendix B
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
Barium2
Metal Category
Compounds
All
None
None
All
None
Barium
Compounds2
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
Asbestos1
All
All
All
All
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
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                                           Appendix B
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 7 A, 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














Biological Treatment:
Previous Codes
B11
B21
B31
B99
Aerobic
Anaerobic
Facultative
Other Biological
Treatment
New Codes (adapted from RCRA Hazardous Waste
Management 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
Chemical Treatment:
Previous Codes
C01
C02
C09
C11
C21
C31
Chemical Precipitation B
Lime or Sodium
Hydroxide
Chemical Precipitation B
Sulfide
Chemical Precipitation B
Other
Neutralization
Chromium Reduction
Complexed Metals
Treatment (other than pH
adjustment)
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H071
H071
H077
H121
H071
H129
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
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                                     Appendix B
Chemical Treatment:
Previous Codes
C41
C42
C43
C44
C45
C46
C99
Cyanide Oxidation B
Alkaline Chlorination
Cyanide Oxidation B
Electrochemical
Cyanide Oxidation B
Other
General Oxidation
(including Disinfection) B
Chlorination
General Oxidation
(including Disinfection) B
Ozo nation
General Oxidation
(including Disinfection) B
Other
Other Chemical
Treatment
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H073
H073
H073
H075
H075
H075
H129
Cyanide destruction with or without precipitation
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
F11
F19
F31
F41
F42
F51
F61
F71
F81
F82
F83
Liquid Injection
Rotary Kiln with Liquid
Injection Unit
Other Rotary Kiln
Two Stage
Fixed Hearth
Multiple Hearth
Fluidized Bed
Infra-Red
Fume/Vapor
Pyrolytic destructor
Wet air oxidation
Thermal
Drying/Dewatering
H040
H040
H040
H040
H040
H040
H040
H040
H040
H040
H076
H122
Incineration B thermal destruction other than use as
a fuel
Incineration B thermal destruction other than use as
a fuel
Incineration B thermal destruction other than use as
a fuel
Incineration B thermal destruction other than use as
a fuel
Incineration B thermal destruction other than use as
a fuel
Incineration B thermal destruction other than use as
a fuel
Incineration B thermal destruction other than use as
a fuel
Incineration B thermal destruction other than use as
a fuel
Incineration B thermal destruction other than use as
a fuel
Incineration B thermal destruction other than use as
a fuel
Wet air oxidation
Evaporation
B-8
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                   Appendix B
Chemical Treatment:
Previous Codes
F99
Other
Incineration/Thermal
Treatment
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H040
Incineration B thermal destruction other than use as
a fuel
Physical Treatment:
Previous Codes
P01
P09
P11
P12
P13
P14
P15
P16
P17
P18
P19
P21
P22
P23
P29
P31
P41
P42
P49
P51
P61
P99
Equalization
Other blending
Settling/clarification
Filtration
Sludge dewatering (non-thermal)
Air flotation
Oil skimming
Emulsion breaking B thermal
Emulsion breaking B chemical
Emulsion breaking B other
Other liquid phase separation
Adsorption B Carbon
Adsorption B Ion exchange (other
than for recovery/reuse)
Adsorption B Resin
Adsorption B Other
Reverse Osmosis (other than for
recover/reuse)
Stripping B Air
Stripping B Steam
Stripping B Other
Acid Leaching (other than for
recovery/reuse)
Solvent Extraction (other than
recovery/reuse)
Other Physical Treatment
New Codes (adapted from RCRA Hazardous
Waste Management Codes)
H129
H129
H123
H123
H101
H124
H124
H124
H124
H124
H124
H082
H082
H082
H082
H129
H083
H083
H083
H129
H129
H129
Other treatment
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
Air or steam stripping
Other treatment
Other treatment
Other treatment
Toxics Release Inventory Reporting Forms and Instructions
B-9

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                                         Appendix B
Solidification/Stabilization:
Previous Codes
G01
G09
G11
G20
G99
Cement processes
(including silicates)
Other Pozzolonic
Processes
(including silicates)
Asphaltic
Techniques
Thermoplastic
Techniques
Other Solidification
Processes
New Codes (adapted from RCRA Hazardous
Waste Management Codes)
H111
H111
H111
H111
H111
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
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
Asbestos1
Section 7C.  On-site Recycling Processes

Any chemical can be reported in Section 1C, however, certain waste management codes should not be reported for
certain toxic chemicals. The chart below indicates which codes can be reported in Section 1C 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
B-10
Toxics Release Inventory Reporting Forms and Instructions

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                                     Appendix B
Crosswalk for Section 1C. On-site Recycling Processes
Previous Codes
R11
R12
R13
R14
R19
R21
R22
R23
R24
R26
R27
R28
R29
R30
R40
Solvents/Organics
Recovery B Batch Still
Distillation
Solvents/Organics
Recovery B Thin-Film
Evaporation
Solvents/Organics
Recovery B Fractionation
Solvents/Organics
Recovery B Solvent
Extraction
Solvents/Organics
Recovery B Other
Metals Recovery B
Electrolytic
Metals Recovery B Ion
Exchange
Metals Recovery B Acid
Leaching
Metals Recovery B
Reverse Osmosis
Metals Recovery B Solvent
Extraction
Metals Recovery B High
Temperature
Metals Recovery B
Retorting
Metals Recovery B
Secondary Smelting
Metals Recovery B Other
Acid Regeneration
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H20
H20
H20
H20
H20
H10
H10
H10
H10
H10
H10
H10
H10
H10
H39
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)
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)
                  Toxics Release Inventory Reporting Forms and Instructions
B-ll

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                                               Appendix B
Previous Codes
R99
Other Reuse or Recovery
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H39
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 whichmetals 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 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
Barium2
Metal Category
Compounds
None
None except
Barium
Compounds2
Metals with
Qualifiers
None
All except
Vanadium
(except when
contained in an
alloy)
Individually-
listed Metal
Compounds
All except
Asbestos2
All
1 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 that 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.

2 The 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 barium compound to barium sulfate is
considered treatment for destruction (40 CFR Section 372.3).
B-12
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
Certification Statements
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 are 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 activities
involving a reportable chemical, any of which may result in
the erroneous non-reporting of a chemical.
C.1   Facility Data Profile

(FDP)

FDPs are made available by the 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 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 Web site. A submission can
include an  original or revised Form R or Form A,  or
corrections included in a response to  a previous FDP. The
FDP serves two primary purposes. First, EPA wants to give
the reporting facility the opportunity to confirm that the 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 http://www.epa.gov/tri.    If you have
questions regarding your  FDP, please send an  email to
tri.efdp(@,csc.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:
Identification  (TRIFID),  facility  name,  facility
address, facility mailing address, relevant permits
(e.g., RCRA, NPDES, and UIC), North American
Industry Classification System code (NAICS), 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 2007 and revisions to one chemical
for Reporting Year 2006, 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 one type of alert called Data
Quality Alert (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 submitted and
processed Form R or Form A data (i.e., chemical
specific data) are displayed in the chemical reports
under the appropriate facility or subordinate facility
names. The FDP displays  facsimiles for chemical
reports for submissions received during the current
calendar year and revisions or responses to FDPs
only.  For example, if a facility originally reported
five chemicals for Reporting  Year 2007, and
subsequently revises only one chemical submission,
the facility will receive an  FDP for Reporting Year
2007 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.
       Facility Information.  This  section  displays  all
       facility-specific  data,  including  TRI  Facility
                          Toxics Release Inventory Reporting Forms and Instructions
                                       C-l

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                                                Appendix C
C.2  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 afacility 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 NAICS 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 "D.
                                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-2
Toxics Release Inventory Reporting Forms and Instructions

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                                               Appendix C
C.3  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 submission.  Although EPA accepts diskette
       and paper submissions, EPA strongly encourages you
       to send your submission via CDX.

    •   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. Suchforms are considered
       incomplete submissions.

Threshold Determinations

    •   Calculating threshold  determinations. Annual
       quantities manufactured, processed, or otherwise
       used for section 313 chemicals must be calculated,
       not surmised.  The assumption that thresholds are
       exceeded commonly leads to error.
    •   Misclassification of EPCRA section 313 chemical
       activity.  Failure  to correctly classify an EPCRA
       section 313 chemical activity may result in  an
       incorrect threshold determination.   As a result, a
       facility may fail to submit the required Form R.
    •   EPCRA section 313 chemical activity overlooked.
       Many facilities believe that because the section 313
       reporting requirement pertains to manufacturers, only
       the  use of EPCRA  section  313  chemicals  in
       manufacturing processes must be  examined. Any
       activity  involving the  manufacture,  process,  or
       otherwise use of an EPCRA section 313 chemical or
       chemical category must be  included in threshold
       determinations. Commonly  overlooked activities
       include importation of chemicals, generation of waste
       byproducts, processing of naturally occurring metals
       and metal category compounds in ore, manufacturing
       and processing 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.

    •   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. Referto SectionB.4b of this
       document to calculate the weight of an EPCRA
       section 313 chemical in a mixture or other trade name
       product.
    •   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

    •   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.
                          Toxics Release Inventory Reporting Forms and Instructions
                                              C-3

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                                                  Appendix C
Part I.  Facility Identification Information

Section 1. Reporting Year

    •   Invalid Forms.  The correct version of the form for
        the reporting year in question must be used.  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
                                          -   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.
    •   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.

Section 3.  Certification

    •   Missing certification signature.    If you are
        submitting your Form R and/or Form A by hardcopy,
        an original  certification signature must appear on
        page 1 of every Form R and/or Form A submitted to
        EPA.  If you are submitting your Form R and/or
        Form A via diskette, 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

    •   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;
C-4
Toxics Release Inventory Reporting Forms and Instructions

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                                                  Appendix C
Part II.  Chemical-Specific Information

Section 1.  Toxic Chemical Identity

    •   Reporting  chemical  abstract   service  (CAS)
        registry 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 Form R." Category guidance documents are
        listed  in the  Chemical  and Industry Guidance
        Documents section in this document.
    •   Failure to check for  synonyms. Some reportable
        chemicals  (especially glycol ethers and toluene
        diisocyanates) have many synonyms that do not
        readily imply they are in the category. For example,
        benzene,!,3-diisocyanatomethyl may not be readily
        recognized as toluene diisocyanate (mixed isomers).
    •   Invalid chemical identification in Section 1.2. The
        CAS number and the chemical name reported here
        must exactly match the listed official EPCRA section
        313 CAS number and EPCRA section 313 chemical
        name.
    •   Failure  to consider an EPCRA section 313
        chemical qualifier. Only  EPCRA section 313
        chemicals in the form specified  in the qualifier
        require reporting  under section 313 and should be
        reported on Form R with the appropriate qualifier in
        parentheses. For example, isopropyl alcohol is listed
        on the EPCRA section 313 chemical list with the
        qualifier manufacturing-  strong acid process, no
        supplier notification. Thus, the ONLY facilities that
        should report this EPCRA section 313 chemical are
        those  that manufacture  isopropyl alcohol by the
        strong acid process.
    •   Generic chemical name in Section 1.3. A generic
        chemical name should only be provided if the section
        313 chemical identity is claimed as a trade secret.
Section 2. Mixture Component Identity
    •   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.
    •   Mixture names in Section 2.1. Mixture names are to
        be entered here only if the supplier is claiming the
        identity of the EPCRA section 313 chemical a trade
        secret and that is the sole  identification.  Mixture
        names that include the name or CAS number of one
        or more EPCRA section 313 chemicals are not valid
        uses of the mixture name field.

Section 3. Activities and Uses of the Toxic
Chemical at the Facility

    •   Reporting EPCRA section 313 chemical activity.
        EPCRA section 313 chemical activity is commonly
        overlooked or misclassified. Any activity involving
        the manufacture, process,  or otherwise use of an
        EPCRA section 313 chemical must be examined. For
        example, waste treatment operations otherwise use
        EPCRA section 313 chemicals to treat waste streams
        and may coincidentally manufacture an additional
        EPCRA section 313 chemical as a result of the
        treatment reaction. Such activity must be considered.
        Further, EPCRA section 313 chemical activity must
        be correctly  classified as either "manufactured,"
        "processed," or "otherwise used."
    •   Section 3.1 Manufacture means to produce, prepare,
        compound,  or import  an EPCRA  section 313
        chemical.
    •   Section 3.2     Process means the preparation of
        an  EPCRA  section  313  chemical  after  its
        manufacture,   which   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
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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

    •   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.
    •   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

    •   Reporting discharges to POTWs in Section 6.1.
        When quantities of  a listed  mineral acid  are
        neutralized to a pH of 6 or greater,  the quantity
        reported as discharged to a POTW should be reported
        as zero.  It  is incorrect  to  enter  "NA"  (Not
        Applicable), in such a situation.

    •   Reporting other off-site transfers in Section 6.2.
        Any quantities reported in Sections 8.1, 8.3, 8.5, and
        8.7 as sent off-site for disposal, treatment,  energy
        recovery, or recycling, respectively, must also be
        reported in Section 6.2 along  with the receiving
        location and appropriate off-site activity code.

Section 7A.  On-Site Waste Treatment
Methods and Efficiency

    •   Failure to report waste treatment  methods  in
        Section 7A. Waste treatment methods used to  treat
        waste streams  containing  EPCRA  section  313
        chemicals, and the efficiencies of these methods,
        must be reported on Form R. Information must be
        entered for all waste  streams, even if the waste
        treatment method does not affect the EPCRA section
        313 chemical. If no waste treatment is performed on
                                        waste streams containing the EPCRA section 313
                                        chemical, the box marked Not Applicable in Section
                                        7A should be checked on Form R.

                                     •   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 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

                                     •   Reporting on-site energy recovery methods in
                                        Section 7B. When a quantity is reported in Section
                                        8.2 as combusted for energy recovery on-site, the
                                        type  of  energy  recovery  system used must  be
                                        reported in Section 7B, and vice versa.

                                 Section  7C. On-Site Recycling  Processes

                                     •   Reporting on-site recycling methods in Section 1C.
                                        When a quantity is reported in  Section 8.4 as
                                        recycled on-site, the type of recovery method must be
                                        reported in Section 7C, and vice versa.

                                 Section  8.  Source Reduction and Recycling
                                 Activities

                                 For RY 2004, the TRI-ME software will be offering a new
                                 tool: the Section 8 Calculator. The Section 8 Calculator will
                                 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.

                                     •   Columns C and D, the future year projections  for
                                        questions 8.1 through 8.7, must be completed. EPA
                                        expects a reasonable estimate for the future year
                                        projections. Zero can be used in columns C and D to
                                        indicate that the manufacture, process, or otherwise
                                        use of the chemical will be discontinued.  In such
                                        cases, columns C and D for Section 8.1 through 8.7
                                        must all contain zeroes.

                                     •   It is incorrect to use range codes to report quantities
                                        in Section 8.  Range codes can be used  only in
                                        Sections  5 and 6 of Form R.

                                     •   It is incorrect to use the same codes from Section 4
                                        for reporting the maximum amount of the reported
                                        EPCRA  section 313 chemical  on-site  to report
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                                                Appendix C
    quantities in Section 8.

•   Quantities reported in Section 8.1 through 8.7 are
    mutually exclusive and additive. This means that
    quantities of the reported EPCRA section 313
    chemical must not be double-counted in Section 8.1
    through 8.7.

•   Some double-counting  errors have been due  to
    confusion over  the  differences in how on-site
    treatment of an  EPCRA section 313  chemical is
    reported in Section 7A as compared to Section 8. In
    Section 7A, information on the treatment of waste
    streams containing the EPCRA section 313 chemical
    is reported, along with the percent efficiency in terms
    of destruction or removal of the EPCRA section 313
    chemical from each waste stream. In Section 8, only
    the  quantity of the EPCRA section 313  chemical
    actually destroyed through the treatment processes
    reported in Section 7A is reported in Section 8.6 to
    avoid double-counting within Sections 8.1 through
    8.7.

•   Quantities reported in 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.la = § 5.4.1 +  § 5.5.1 A + § 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. Ic:
      -    M64 Other Landfills
      -    M65 RCRA Subtitle C Landfills
          M81 Underground Injection to Class I Wells
    §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
        Metals and metal category compounds transferred
        off-site to POTWs in Section 6.1  must appear in
        Section 8. Ic 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
        related activities.
        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:
          -   M10 Storage Only
              M41 Solidification/Stabilization - Metals and
              Metal Category Compounds Only
              M62 Wastewater Treatment (excluding
              POTW) - Metals and Metal Category
              Compounds Only
              M66 Subtitle C Surface  Impoundment
              M67 Other Surface Impoundments
              M73 Land Treatment
          -   M79 Other Land Disposal
              M82 Underground Injection to Class II-V
              Wells
          -   M90 Other Off-Site Management
              M94 Transfer to Waste Broker—Disposal
          -   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
        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.
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        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 not be  included in Section 8.8.
    •   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:
              M56 Energy Recovery
          -   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
        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.
                                          production practices that were recycled on-site must
                                          not be included in Section 8.8.

                                      •   Reporting  quantities in Section 8.5. "Quantity
                                          recycled off-site." Quantities reported in Section 6.2
                                          as transferred off-site for the purposes of recycling
                                          must be included in Section 8.5 using the following
                                          codes:
                                               M20 Solvents/Organic Recovery
                                            -  M24 Metals Recovery
                                            -  M26 Other Reuse or Recovery
                                               M28 Acid Regeneration
                                            -  M93 Transfer to Waste Broker — Recycling.
                                          §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 7A, while the quantity of the EPCRA
                                          section 313 chemical actually destroyed as a result of
                                          on-site treatment is  reported in  Section 8.6.   If a
                                          quantity is reported in Section 8.6, Section 7A must
                                          be completed but the reverse may not be true. This
                                          may result in apparent discrepancies between Section
                                          7A and Section 8. For example, a facility may treat
                                          wastewater  containing an  EPCRA section  313
                                          chemical by  removing the EPCRA section  313
                                          chemical and then  disposing of it on-site.  The
                                          treatment of the wastewater would be  reported in
                                          Section 7A, with an efficiency estimate based on the
                                          amount of the EPCRA section 313 chemical removed
                                          from the wastewater. Although the waste stream has
                                          been treated because  the  EPCRA section  313
                                          chemical has been removed, the EPCRA section 313
                                          chemical has not been treated because it has not been
                                          destroyed. The facility would report only the amount
                                          of the  EPCRA section 313  chemical  actually
                                          destroyed during treatment in Section  8.6 and the
                                          amount ultimately disposed in Section 8.1 to avoid
                                          double-counting the same quantity in Section 8. In
                                          cases where the EPCRA section 313 chemical is not
                                          destroyed   during  a   treatment  process   and
                                          subsequently enters another activity, such as disposal
                                          (e.g.,   metals  removed  from   wastewater   and
                                          subsequently disposed on-site), the quantity of the
                                          EPCRA section  313 chemical would be reported as
                                          disposed in Section 8.1, not as treated in Section 8.6.
                                          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
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        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:
             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.
        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
        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.
        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.


C.4  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 2007
        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
        http://www.epa.gov/tri
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
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                                               Appendix C
       certified letter. Please be sure to sign the certification
       statement in this FDP to certify your submission data.
9.      You  have  reported   Dioxin  and  Dioxin-like
       Compounds on a Form A. Dioxin and Dioxin-like
       Compounds  are  not  eligible  for the  alternate
       threshold. Thus, this chemical must be reported on a
       Form R. Please resubmit your data on a Form R.
10.     In Part I,  Section lof 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)
11.     In Part I,  Section lof 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)
12.     You have reported a negative number(s) in Part II,
       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.
13.     You did not complete Part II,  Sections 5 and 6.
       Please provide the required information; otherwise
       indicate NA.
14.     You did not complete Part II, Section 7.  Please
       provide the required information; otherwise indicate
       NA.
15.     You did not complete Part II, Section 8.  Please
       provide the required information; otherwise indicate
       NA.
C.5  Messages Used to
Report Notices of Technical
Errors (NOTEs)  and  Non-
technical Data Changes
(NDCs)

Invalid codes throughout Form R
16.      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)
17.      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)
                               18.      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)
                               19.     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

                               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
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                                                   Appendix C
        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.      InPart 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 self-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 NAICS code  was not provided.  Please
        provide at least one valid primary six-digit NAICS
        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)
3 3.     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)
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)  I.D.
        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
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                                                 Appendix C
        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 from N151 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 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 witheitherO 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 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 witheitherO 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)
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                                                 Appendix C
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) anduse(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
        6.1 .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 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)
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                                                   Appendix C
15.     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,
        however you left Section 8.3 column B 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. Ifnoon-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. Ifnoon-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 through 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 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 Sections 8.1  through 8.7
                                         column B or 8.8. If you report releases in Part II,
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                                                   Appendix C
        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 7C.  (NOTE)
98.      You reported one or more on-site recycling process
        codes in Part II, Section 7C 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 recycledforSection8.4 columnB.  (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 8a,  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
        columnB. (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 Column B.
        Note that in Section 8a,  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)
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Appendix  D.    Supplier  Notification  Requirements
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.
D.1  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 a  North American Industry
       Classification System (NAICS) Standard Industrial
       Classification [SIC] codes 20-39;
2.      You manufacture (including import) or process an
       EPCRA section 313 chemical; and
3.      You sell or otherwise distribute a mixture or other
       trade name product containing the  EPCRA section
       313 chemical to either:
            A facility in a covered NAICS code (see
            Table I).
            A person that then may sell the same mixture
            or other trade name product to a firm in a
            covered NAICS 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.
D.2 Who Must Be  Notified

Industries whose primary NAICS code does not correspond to
SIC codes  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 NAICS
code, but because they sell the product  to companies in
covered NAICS 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.
D.3 Supplier Notification

Content

The  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.
For example, if a mixture contains a chemical (i.e., 12 percent
zinc oxide) that is a member of a reportable EPCRA section
313 chemical category (i.e., zinc compounds), the notification
must indicate that the mixture contains a zinc compound at 12
percent by weight. Supplying only the weight percent of the
parent metal (zinc) does not  fulfill  the requirement. The
customer  must be told the weight percent of the entire
compound within an EPCRA section 313 chemical category
present in the mixture.
                          Toxics Release Inventory Reporting Forms and Instructions
                                             D-l

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                                                Appendix D
D.4  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.
D.5 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
       adding, removing, or changing the  percentage by
       weight of an EPCRA section 313 chemical; or
2.      Discover that your previous  notification did not
       properly identify the EPCRA section 313 chemicals
       in the mixture or correctly indicate the percentage by
       weight.
                                In these cases, you must:

                                1.      Supply a new or revised notification within 30 days
                                       of a change in the product  or the discovery of
                                       misidentified EPCRA section 313 chemical(s) in the
                                       mixture or incorrect percentages by weight; and
                                2.      Identify in the notification the prior shipments of the
                                       mixture or product in that calendar year to which the
                                       new  notification  applies (e.g.,  if   the  revised
                                       notification is made on August 12,  indicate which
                                       shipments were affected during the period January 1 -
                                       August 12).


                                D.6  When Notifications Are

                                Not Required

                                Supplier notification is not required for a "pure" EPCRA
                                section 313 chemical unless a trade name is used. The identity
                                of the EPCRA section 313 chemical will be known based on
                                label information.

                                You are not required to make a "negative declaration." That
                                is, you are not required to indicate that a product contains no
                                EPCRA section 313 chemicals.

                                If your mixture or other trade name product contains one of the
                                EPCRA section 313 chemicals, you are not required to notify
                                your customers if:

                                1.      Your mixture or other trade name product contains
                                       the EPCRA section 313 chemical in percentages by
                                       weight of    less than the following levels (These
                                       are known as de minimis levels)
                                         -   0.1 percent if the EPCRA section 313
                                            chemical is defined as an "OSHA
                                            carcinogen;"
                                         -   1 percent for other EPCRA section 313
                                            chemicals.
                                De minimis levels for each EPCRA section 313 chemical and
                                chemical category are listed in Table II.  PBT chemicals
                                (except lead when contained in stainless steel, brass or bronze
                                alloys)  are not eligible  for the  de  minimis  exemption.
                                Therefore, de minimis levels are not provided for these
                                chemicals  in Table II.  However, for  purposes of supplier
                                notification requirements only, such notification is not required
                                when the following PBT chemicals are contained in mixtures
                                below their respective de minimis levels:
D-2
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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
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
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
0.1***

Chemical or chemical
category name
Tetrabromobisphenol A
Toxaphene
Trifluralin
CAS
number or
chemical
category
code
79-94-7
8001-35-2
1582-09-8

Supplier
notification
limit (%)
1.0
0.1
1.0
                                   *The de minimis level is 1.0 for all members except for
                                   2,3,7,8-Tetrachlorodibenzo-/>-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.
                                          Your mixture or other trade name product is one of
                                          the following:
                                               An article that does not release an EPCRA
                                               section 313 chemical under normal
                                               conditions of processing or otherwise use.
                                               Foods, drugs, cosmetics, alcoholic
                                               beverages, tobacco, or tobacco products
                                               packaged for distribution to the general
                                               public.
                                               Any consumer product, as the term is defined
                                               in the Consumer Product Safety Act,
                                               packaged for distribution to the general
                                               public. For example, if you mix or package
                                               one-gallon cans of paint designed for use by
                                               the general public, notification is not
                                               required.
                                          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.
                                          You are initiating distribution of a mixture or other
                                          trade name product containing one or more EPCPxA
                                          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
Toxics Release Inventory Reporting Forms and Instructions
D-3

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                                                 Appendix D
        facilities that combust coal and/or oil for the purpose
        of generating power for distribution in commerce), or
        493 9 (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).
                                4.       If claiming a specific concentration a trade secret,
                                        you should record explanations of why a specific
                                        concentration is considered a trade secret and the
                                        basis for the upper bound concentration limit.
                                Information retained under 40 CFR 372 must be  readily
                                available for inspection by EPA.
 D.7  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
 they consider:

 1.      The specific identity  of an  EPCRA section 313
        chemical   to be a trade secret, the notice must
        contain a generic chemical name that is descriptive of
        the structure of that EPCRA Section 313 chemical
        (for example,  decabromodiphenyl oxide could be
        described as a halogenated aromatic);
 2.      The specific percentage by weight of an EPCRA
        section 313 chemical in the mixture or  other trade
        name product to be a  trade secret, the notice must
        contain a statement that the  EPCRA section 313
        chemical is present at a concentration that does not
        exceed a specified upper bound.  For example, if a
        mixture contains 12 percent toluene and you consider
        the percentage a trade secret, the notification may
        state that the mixture  contains toluene at no more
        than 15 percent by weight. The upper bound value
        chosen  must  be  no   larger than necessary  to
        adequately protect the trade secret.
 If you claim this information to be trade secret, you must have
 documentation that provides the basis for your claim.
 D.8  Recordkeeping

 Requirements

 You are required to keep records of the following for three
 years:

 1.      Notifications sent to recipients of your mixture or
        other trade name product;
 2.      All supporting materials used to develop the notice;
 3.      If claiming a specific EPCRA section 313 chemical
        identity a trade secret, you should record why the
        EPCRA section 313 chemical identity is considered a
        trade secret and  the appropriateness of the generic
	chemical name provided in the notification; and
D-4
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                                               Appendix D
D.9  Sample  Notification Letter

                                               January 2, 2007
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-13 90, contains one or more chemicals subject to
section 313 of Emergency Planning and Community Right-to-Know Act (EPCRA).  We are required to notify you of the presence of
these chemicals in the product under EPCRA section 313. This law requires certain industrial facilities to report on annual emissions
and other waste management of specified EPCRA section 313 chemicals and chemical categories. Our product contains:


    •   Toluene, Chemical Abstract Service (CAS) number 108-88-3, 20 percent,  and

    •   Zinc compounds, 15 percent.


If you are unsure whether you are subj ect 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

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                                          Appendix D
D.10 Sample  Notification  on  an MSDS
                                                 Furniture Products
       Section 313 Supplier Notification

       This product contains the following EPCRA section 313 chemicals subj ect 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

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 Appendix E.    TRI  State Contacts
 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
IN3
KS
LA
MA
MD4
MI5
MN
MO6
MT
ND
NH
NJ
NM7
NV
NY
OH
OK
OR
PA
PR
sc8
SD
TX
UT
VA
VT
WA9
WI
wv
WY





 1 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.

 Indiana's preferred method of submission is using TRI-MEweb.

 4Maryland accepts diskette submissions, but requires that paper copies be sent as well.

 5Michigan 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.

 6 Missouri accepts paper submissions created using TRI-MEweb. All other submissions must be CDs/diskettes
 created using the TRI-ME software.

 7New Mexico requires paper copies in addition to diskette.

 8South 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.

 'Washington strongly encourages electronic submittals by diskette or via the central data exchange, if available.

Toxics Release Inventory State Coordinators
 Please note that a few states and territories have two TRI contacts: a technical contact that provides
 assistance to industries on TRI reporting and receives the TRI reporting forms and a public contact that
 provides assistance to the public in using TRI data.  Where there are two state contacts, the technical
 contacts are identified by an asterisk [*].

 If your state is not listed here, please contact your state office to confirm that paper submissions are required.
                     Toxics Release Inventory Reporting Forms and Instructions
E-l

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                                          Appendix E
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
1350 Coliseum Boulevard
Montgomery, AL 36110-2059

Alaska
Camille Stephens
Department of Environmental Conservation
Division of Spill Prevention and Response
410 Willoughby Ave., Suite 303
P.O. Box 111800
Juneau,AK 99811-1800
Office: (907) 465-5242
Fax: (907) 465-2237
Camille_stephens@alaska.gov

American Samoa
Toafa Vaiagae, Ph.D.*
American Samoa Environmental Protection Agency
American Samoa Government
Office of the Governor
Pago Pago, AS 96799
International (684) 633-2304

Peter Peshut, Manager
American Samoa Environmental Protection Agency
P.O. Box PPA
Pago Pago, AS 96799
Office: (684) 633-2304
Fax:  (684)633-5801
ppeshut@y ahoo. com

Arizona
Mark Howard *
Arizona Emergency Response Commission
5636 East McDowell Road
Phoenix, AZ 85008
Office: (602) 231-6345; Fax: (602) 392-7519
Mark.Howard@azdema.gov

Bill Quinn
Arizona Department of Environmental Quality
Pollution Prevention Unit, Mail Code 4415B-2
1110 West Washington Street
Phoenix, AZ 85007
Office: (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, AR72199
                               (501) 683-6752; Fax: (501) 703-9754
                               kenny .harmon@adem. state .ar.us

                               John Ward
                               AR Department of Environmental Quality
                               5301 Northshore Drive
                               Little Rock, AR 72118
                               Office:  (501) 682-0913; Fax: (501) 682-0933
                               j ward@adeq. state .ar.us

                               UPS or FedEx Only
                               AR Dept. of Emergency Management
                               1835  S. Doneghey
                               Conway, AR 7203 3
                               John Ward (Questions Only)
                               AR Dept. of Pollution Control & Ecology
                               5301 Northshore Drive

                               Little Rock, AR 72118
                               (501) 682-0913; Fax: (501) 682-0798
                               jward@adeq.state.ar.us

                               California
                               Department of Toxic Substance Control
                               Attn:  Office of Environmental Information
                               Management
                               100II Street, 8th floor
                               Sacramento, CA 95812
                               Office: (916) 323-3421; Fax: (916) 324-1788

                               Colorado: cdphePPSaraTitle3@cdphe.state.co.us
                               Kirk Mills
                               Sustainability Program
                               CO Dept. of Public Health and Environment
                               4300  Cherry Creek Drive South
                               Denver, CO 80246-1530
                               Office: (303) 692-2977; Fax: (303) 782-4969

                               Commonwealth of Northern Mariana Islands
                               Frank Rabauliman, Director
                               Office of the Governor
                               Division of Environmental Quality
                               Third Floor, Morgan Bldg., San Jose
                               P.O. Box 501340
                               Saipan, MP 96950-1340
                               International (670) 664-8500/1; Fax: (670) 664-8540
                               deq. director@saipan. com
                                                    * Technical Contact
E-2
Toxics Release Inventory Reporting Forms and Instructions

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                                           Appendix E
Connecticut
Mark Decaprio, SERC Administrator
Department of Environmental Protection
State Emergency Response Commission
79 Elm Street, 4th Floor
Hartford, CT 06106-5127
Office: (860) 424-3373; Fax: (860) 424-4059
mark.decaprio@po.state.ct.us

Delaware
John E. Parker, P.E.
Toxic Release Inventory Program
Emergency Prevention and Response Branch
156 South State Street
Dover, DE 19901
Office: (302) 739-9431; Fax: (302) 739-3106
john.parker@state.de.us

District of Columbia
Chris Voss
Emergency Response Commission for Title III
2000 14th Street, NW, 8th Floor
Washington, DC 20009
Office: (202) 673-2101, ext. 1141;
Fax: (202) 673-2290
chris.voss@dc.gov

Florida
Mary Keaton
State Emergency Response Commission
Florida Department of Community Affairs
2555 Shumard Oak Blvd.
Tallahassee, FL 32399-2100
Office:  (850) 413-9926; Fax: (850) 488-1739
mary.keaton@em.myflorida.com

Georgia
Kent Howell
Georgia Environmental Protection Division
7 Martin Luther King, Jr. Drive, Room 643
Atlanta, GA 30334
Office:  (404)656-6905
Fax: (404) 657-7893
kent_howell@dnr.state.ga.us
Guam
Lorilee Chrisostomo *
Guam Environmental Protection Agency
Air and Land Division
P.O. Box 20439
Barrigada, Guam 96921
International (671) 475-1658;
Fax:(671)477-9402
lorilee.chrisostomo@guamepa.net

Jesus Salas, Administrator
Guam Environmental Protection Agency
P.O. Box 22439, GMF
Barrigada, Guam 96921
International (671) 475-1658; Fax: (671) 477-9402

Hawaii
Clarence Martin
Hawaii State Emergency Response Commission
Hawaii Department of Health
919 Ala Moana Blvd, Room 206
Honolulu, HI 96814
Office: (808) 586-4694; Fax: (808) 586-7537
clarence.martin@doh.hawaii.gov

Idaho
Mary Halverson
Idaho Bureau of Homeland Security
4040 Guard Street, Bldg. 600
Gowen Field
Boise, ID 83705-5004
Office: (208) 422-5723; Fax: (208) 442-4485
mhalverson@bhs.idaho.gov

Illinois
Dierdre McQuillen
Illinois Environmental Protection Agency
1021 North Grand Avenue, East
P.O. Box 19276
Springfield, IL 62794-9276
(217) 558-0073; Fax: (217) 553-8228
dierdre.mcquillen@epa.state.il.us

Certified or Express Mail
Dierdre McQuillen
Illinois Environmental Protection Agency
1021 North Grand Avenue, East
Springfield, IL 62702
                                                      * Technical Contact
                     Toxics Release Inventory Reporting Forms and Instructions
                                          E-3

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                                           Appendix E
Indiana: www.in.gov/idem/prevention/tri
Jennifer Schick
Indiana Dept. of Environmental Management
OPPTA
100 North Senate Avenue
MC 64-00 IOCS W041
Indianapolis, IN 46204-2251
Office: (317) 234-5286; 1 800 988-7901
Fax:(317)233-5627
lgroom@idem.IN.gov

Iowa: www.iowadnr.gov/spills
Elonda Bacon
Emergency Response Unit
Iowa Department of Natural Resources
401SW 7th Street, Suite I
Des Moines, IA 50309
Office: (515) 725-0302; Fax (515) 725-0218
Elonda.bacon@dnr.state.ia.us

Kansas: www.kdhe.state.ks.us
Kimberly Steves, Supervisor
Environmental Radiation, Emergency Preparedness,
and R-T-K
Kansas Department of Health and Environment
Bureau of Air  & Radiation
1000 SW Jackson, Suite 310
Topeka,KS 66612-1366
Office: (785) 296-4359; Fax: (785) 296-1545
ksteves@kdhe.state.ks.us

Kentucky
Larry C. Taylor
Kentucky Department for Environmental Protection
14 Reilly Road
Frankfort, KY 40601-1132
Office: (502) 564-2150 ext. 112
Fax: (502) 564-4245
larryc.taylor@ky.gov

Louisiana
Louisiana Department of Environmental Quality
P.O. Box 4314
Baton Rouge, LA 70821-4314
Attention: Air Quality Assessment Division
(225)219-3168
                                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

                                Delivery A ddress
                                Robert S. Gardner
                                45 Commerce Drive, Suite 2
                                Augusta, ME 04330

                                Maryland
                                Patricia S. Williams
                                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
                                Waste and Toxics Planning
                                MA Department of Environmental Protection
                                One Winter Street
                                Boston, MA 02108
                                (617) 292-5632; Fax: (617) 292-5858
                                john.fischer@state.ma.us

                                Michigan
                                Ruth Borgelt
                                Michigan SARA Title III Program
                                Department of Environmental Quality
                                Environmental Science and Services Division
                                P.O. Box 30457
                                Lansing, MI 48909
                                (517) 373-8481; Fax: (517) 241-7966
                                borgeltr@michigan.gov

                                Overnight Mail
                                Ruth Borgelt
                                Constitution Hall, 1 North
                                525 West Allegan
                                Lansing, MI 48933
                                (517)373-8481
E-4
Toxics Release Inventory Reporting Forms and Instructions

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                                           Appendix E
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 .tomly anovich@state. mn.us

Mississippi
John David Burns
Mississippi Department of Environmental Quality
P.O. Box 10385
Jackson, MS 39289-0385
(601) 961-5005; Fax: (601) 961-5660
j ohn_d_burns@deq. state.ms .us

Missouri
Keith Bertels
Missouri Department of Natural Resources
Environmental Assistance Office
P.O. Box 176
Jefferson City, MO 65102-0176
(573) 751-6892; Fax: (573) 751-9277
keith.bertels@dnr.mo. gov

Certified Mail
Keith Bertels
Missouri Department of Natural Resources
Division of Environmental Quality
1101 Riverside Drive
Jefferson City, MO 65101

Montana
Tom Ellerhoff
MT Emergency Response Commission DEQ
Metcalf Bldg. -1520 East 6th Avenue
 Helena, MT 59620-0901
(406) 444-6780; Fax: (406) 444-4386
tellerhoff@state.mt.us

Navajo Nation
Stephen B. Etsitty, Executive Director *
Navajo Nation Environmental Protection Agency
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) 871-7800
Note: recipient of EPCRA Tier II reports

* Technical Contact
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
Mark Lohnes
SARA Title III and NEPCRA Coordinator
Nebraska Dept of Environmental Quality
1200 N Street, Suite 400
Lincoln, NE 68509

Nevada: www.serc.nv.gov/facilityinfo.htm
 Suzanne Adams
Nevada State Emergency Response Commission
2621 Northgate Lane, Suite 10
Carson City, NV 89706
Office: (775) 687-6973
Fax: (775) 687-8798
sadam@dps.state.nv.us

New Hampshire
Les Cartier
NH Department of Safety
Bureau of Emergency Management
33 Hazen Drive
Concord, NH 03305-0002
Office: (603) 271-3294; Fax: (603) 225-7341
lcartier@safety. state .nh.us

New Jersey: www.state.nj.us/dep/opppc
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

Express Delivery
Andrew  Opperman
Dept. of Environmental Protection
Pollution Prevention & R-T-K
22 S. Clinton Avenue
4 Station Plaza, 3rd Floor
Trenton, NJ 08609
                     Toxics Release Inventory Reporting Forms and Instructions
                                          E-5

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                                          Appendix E
New Mexico
Ron Breland, HazMat Coordinator
NM Department of Homeland Security
 And Emergency Management
P.O. Box 27111
Santa Fe, NM 87504
(505) 476-9681; Fax: (505) 476-9695
ronald.breland@state. nmus

UPS or FedEx
Ron Breland
NM Dept. of Homeland Security
ISBataanBlvd.
Santa Fe, NM 87504

New York
Susanne Wither
NY State Department of Environmental Conservation
Division of Environmental Remediation
625 Broadway, 11th Floor
Albany, NY 12233-7020
Office: (518) 402-9553; Fax: (518) 402-9020
smwither@gw.dec.state.nv.us

North Carolina
Randolph Harrison, EPCRA Coordinator
North Carolina Emergency Management
4714 Mail Service Center
Raleigh, NC 27699
Office: (919) 715-3327; Fax: (919) 733-2860
rharrison@ncem.org

North Dakota
Ray DeBoer
North Dakota Department of Emergency Services
P.O. Box 5511
Bismarck, ND 58506-5511
(701) 328-8100; Fax: (701) 328-8181
rdeboer@state.nd.us

Certified Mail
Ray DeBoer
ND Depart.of Emergency Services
Fraine Barracks Road, Building 35
Bismarck, ND 58506-5511
(701) 328-8100

Ohio
Cindy DeWulf
Ohio Environmental Protection Agency
Lazarus Government Center
50 West Town Street, Suite 700
P.O. Box 1049
Columbus, OH 43215-1049
(614) 644-3606; Fax: (614) 644-3681
cindy .dewulf@epa. state .oh.us
                                Oklahoma
                                Monty Elder
                                Department of Environmental Quality
                                Risk Communication
                                P.O. Box 167
                                Oklahoma City, OK 73101-1677
                                (405) 702-1017; Fax: (405) 702-9132
                                1 (800) 869-1400
                                monty. elder@deq. state .ok.us

                                Certified Mail
                                Monty Elder
                                OK Dept. of Environmental Quality
                                707 N. Robinson
                                Oklahoma City, OK 73102
                                (405) 702-1017

                                Oregon
                                Chris Kuenzi, CR2K Operations Manager
                                Oregon Community Right-to-Know Unit
                                HazMat Information Manager
                                4760 Portland Road, Northeast
                                Salem, OR 97305-1760
                                (503) 378-1540 ext. 238; Fax: (503) 373-1540
                                chris.kuenzi@state.or.us

                                Pennsylvania
                                Thomas J. Ward, Jr.
                                Department of Labor and Industry
                                Bureau of PENNSAFE
                                Labor and Industry Building
                                P.O. Box 68571
                                Harrisburg, PA 17106-8571
                                (717) 783-2071; Fax: (717) 783-5099
                                pennsafe@dli. state.pa.us

                                Certified Mail ONLY
                                Thomas J. Ward, Jr.
                                Bureau of PENNSAFE
                                Department of Labor and Industry
                                7th & Forster Streets, Room 155-E
                                Harrisburg, PA 17120
                                1-888-723-3422
E-6
Toxics Release Inventory Reporting Forms and Instructions

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                                            Appendix E
Puerto Rico
Carlos W. Lopez Freytes
Junta de Agendas Ambientales
Avenida Ponce de Le'on 1308
CarreteraEstatal8838
Sector el Cinco (allado del Jardi Bot'anico)
Rio Piedras, PR 00926
(787) 766-2823; Fax: (787) 766-0150

Mailing Address
Carlos W. Lopez Freytes
Puerto Rico State Emergency Response Commision
P.O. Box 11488
Santurce, PR 00910-1488

Rhode Island
Karen Slattery
RI Department of Environmental Management
Office of Air Resources
235 Promenade  Street, Suite 230
Providence, RI 02908
Attn: Toxic Release Inventory
Office: (401) 222-2808, ext. 7030
Fax:(401)222-2017
karen.slattery@dem.ri.gov

South Carolina
H. Reed Corley, TRI Coordinator
Air Toxics Section
Bureau of Air Quality
SC Department of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
(803) 898-4123; Fax: (803) 898-4117
corleyhr@dhec.sc.gov

South Dakota
PMB 2020
Patricia (Trish) Kindt
SD Department of Environment and Natural
Resources
523 East Capitol
Pierre, SD 57501-3182
(605) 773-3296; (800) 433-2288
Fax: (605) 773-6035
trish.kindt@state. sd.us

Alternate Contact
Kim Mclntosh
Ground Water Quality Program
(605) 773-3296
Kim.mcintosh@state. sd.us
Tennessee
Betty Eaves, Administrator
TERC/Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville, TN 37204
Office: (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 On Environmental Quality
P.O. Box 13087
Austin, Texas 78711-3087
Office: (512) 239-1441; Fax: (512) 239-1500
toxic@tceq. state .tx.us

Overnight Express Mail
Blake Kidd
Toxics Release Inventory Program, MC 164
Texas Commission On Environmental Quality
12100 Park  35 Circle, Bldg. E., Third Floor
Austin, Texas 78753

Utah
Michael Zucker, Environmental Scientist/EPCRA
Coordinator
UT Dept. of Environmental Quality
Div. of Environmental Response and Remediation
168 North 1950 West
Salt Lake City, UT 84116
(801) 536-4143; Fax: (801) 536-4242
mzucker@utah.gov

Vermont
Paul  Van Hollebeke
VT Department of Environmental Conservation
Environmental Assistance Office
103 South Main Street
Waterbury, VT 05671-4911
(802) 241-3629; Fax: (802) 241-3273
paul.vanhollebeke@state.vt.us

Virgin Island
Aaron Hutchins
Department of Planning and Natural Resources
Division of Environmental Protection
Cyril E. King Airport
Terminal Building,
St. Thomas, VI00802
St. Thomas: (340) 774-3320; Fax: (340) 774-9549
St. Croix (340) 773-1082; Fax (340) 692-9794
hutchins. aaron@vidpnr-dep. org
2nd Floor
                      Toxics Release Inventory Reporting Forms and Instructions
                                          E-7

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                                           Appendix E
Virginia
Nichelle McDaniel
VA DEQ - Sara Title III
P.O. Box 1105
Richmond, VA 23218
(804) 698-4159; Fax: (804) 698-4327
ndmcdaniel@deq.virginia.gov

Certified or Express Mail
Nichelle McDaniel
VA DEQ - Sara Title III
VA Emergency Response Council
629 E. Main Street
Richmond, VA 23219

Washington
Diane Fowler
Dept. of Ecology
P.O. Box 47659
HW/Toxics Reduction Program
Olympia, WA 98504-7659
(360) 407-6171; Fax: (360) 407-6715
dfow461@ecy.wa.gov

UPS including certified mail:
Diane Fowler
HW/Toxics Reduction Program
300 Desmond Drive
Lacey, WA 98503
1-800-633-7585, option 2, then option 4

West Virginia
James J. Gianato
West Virginia Division of Homeland Security
  And Emergency Management
1900 Kanawha Boulevard, Building 1,
Room EB-80
Charleston, WV 25305-0360
(304) 558-5380; Fax: (304) 344-4538
Jgianato@wvdmaps.gov

NICS
Deepay Mukerjee
National Institute for Chemical Studies
2300 MacCorkle Avenue, SE
Charleston, WV 25304
(304) 346-6264; Fax: (304) 346-6349
                                Wisconsin
                                Dreux Watermolen
                                Chief Science and Information Services
                                Wisconsin Department of Natural Resources
                                P.O. Box 7921
                                Madison, WI 53707-7921
                                (608) 266-8931; Fax: (608) 266-5226
                                dreux. watermolen@wi. gov

                                Wyoming
                                Kim Lee, WMD Unit Chief
                                Wyoming Office of Homeland Security
                                Herschler Building, 1st Floor East
                                122 W 25th Street
                                Cheyenne, WY 82002
                                Main Line: (307)777-4900
                                (307) 777-7540; Cell:  (307) 214-9594
                                klee@state.wy.us
E-8
Toxics Release Inventory Reporting Forms and Instructions

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Appendix F.    TRI  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)

   Barbara Conklin
   Office of Pollution Prevention, Pesticides and Toxics
   USEPA Region 8 (8P-P3T)
   1595 Winkoop Street
   Denver, CO 80202
   (303) 312-6619; Fax: (303) 312-6044
   Conklin.barbara@epa.gov

Region 9 (AS, AZ, CA, GU, HI, MH, MP, and
NV)

   Nancy Levin
   Toxics Office
   USEPA Region 9 (CED-4)
   75 Hawthorne Street
   San Francisco, CA 94105-3901
   (415) 972-3848; fax: (415) 947-3583
   levin.nancy@epa.gov

Region 10 (AK, ID, OR, and WA)

   Brook Madrone
   Office of Air, Waste & Toxics
   USEPA Region 10 (AWT-128)
   1200 Sixth Avenue
   Suite 900
   Seattle, WA 98101-3140
   (206) 553-4016; Fax: (206) 553-8509
   Madrone.brook@epa.gov
                     Toxics Release Inventory Reporting Forms and Instructions
                                       F-l

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Appendix G.    Other Relevant Section 313  Materials
G.1   Public  Data Release

2006 Toxics Release Inventory Public Data Release
Report

TRI data collected from 1987 through 2006 can be accessed
using the TRI Explorer online tool:

        http://www.epa.gov/triexplorer
as well as several other public access tools available on the
TRI  website.    In  addition, users  can obtain  summary
information and access the TRI data submitted for reporting
years 1996 through 2006 via the web from the TRI Public Data
Release  Internet site at www.epa.gov/tri/tridata/index.htm.
This Internet site provides fast and easy access to the TRI data
submitted for each of these years, as well as an overview of the
data and other relevant TRI information regarding each year
(including  tables, charts, maps, and a summary of key
findings).  EPA has released  two electronic publications
summarizing the 2006 data: the 2006 TRI Public Data Release
(PDR) Brochure (EPA-260-R-07-001) and the 2006 Public
Data Release eReport.  These reports provide an overview of
the 2006 TRI reporting year  data and other information
relating to TRI data. The reports serve as  a supplement to
EPA's TRI Explorer where, for example, users of TRI data can
retrieve  electronic  2006 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.
G.2 Access  to TRI

Information  On-line

The  TRI  Home  Page  http://www.epa.gov/tri  offers
information useful to both novice and experienced users of the
Toxics Release Inventory. It provides a description of what the
TRI database is and how it can be used; access to TRI data;
TRI regulations; and guidance documents for complying with
TRI regulations and using TRI data. You can find out about
TRI products, view or download the 2006 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 also allow you to search the TRI database and other
databases online.

TRI Explorer http://www.epa.gov/triexplorer is an on-line
tool that EPA has created to obtain TRI data. It allows the
user to search the TRI database 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 http://toxnet.nlm.nih.gov/, the National Library of
Medicine's (NLM) Toxicology Data Network, provides free
access to several databases, including the TRI database, that
provides a variety of information on toxic chemicals. As with
EPA's TRI Explorer tool, users of TOXNET 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. Toxicity and
environmental fate data for thousands of chemicals are also
available from TOXNET.
G.3  Other TRI  Information

EPA's  Integrated Risk  Information  System  (IRIS)
http://www.epa.gov/iris is an electronic database containing
information on human health effects that  may result from
exposure to various chemicals, including TRI 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):

        http://www.epa.gov/ceppo/pubs/title3.pdf
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.
                               Toxics Releases Inventory Forms and Instructions
                                              G-l

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                                                  Appendix G
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-OOlb.  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
                            fact sheets 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
G-2
Toxics Releases Inventory Forms and Instructions

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Appendix  H.    Guidance Documents	


H.1  General  Guidance

Many of the TRI guidance documents are available via the Internet http://www.epa.gov/tri.

   •  40 CFR 372, Toxic Chemical Release Reporting; Community Right-to-Know; Final Rule
      A reprint of the final EPCRA section 313 rule as it appeared in the Federal Register (FR) February
      16, 1988  (53 FR 4500) (OTSFR 021688).

   •  Common Synonyms for Chemicals Listed Under Section 313 of the Emergency Planning and
      Community Right-to-Know Act
      March 1995 (EPA 745R-95-008)

      This glossary contains chemical names and their synonyms for substances covered by the reporting
      requirements of EPCRA section 313. The glossary was developed to aid in determining whether a
      facility manufactures, processes, or otherwise uses a chemical subject to EPCRA section 313
      reporting.

   •  EPCRA Section 313 Questions and Answers - Revised 1998 Version
      December 1998 (EPA 745-B-98-004)

      The revised 1998 EPCRA Section 313 Questions and Answers document assists regulated facilities
      in complying with the reporting requirements of EPCRA section 313.  This updated document
      presents  interpretive guidance in the form of answers to  many commonly  asked questions  on
      compliance with EPCRA section 313. In addition, this document includes comprehensive written
      directives to assist covered  facilities in understanding some of the more complicated  regulatory
      issues. This updated guidance document is intended to supplement the instructions for completing
      the Form R and the Alternate Threshold Certification Statement (Form A).

   •  EPCRA Section 313 Questions 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.

   •  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
      13423, frequently have operations  that are different  from the private sector facilities  subject to
      EPCRA.  The document contains questions and answers that address some of those differences.

   •  EPCRA Section 313 Release and Other Waste Management Reporting Requirements
      February 2001 (EPA 260/K-01-001)

      The brochure alerts businesses to their reporting obligations under EPCRA section 313 and assists
      in determining whether their facility is required to report.  The brochure contains the EPA regional
      contacts,  the list of EPCRA section 313 toxic chemicals and a description of the Standard Industrial
      Classification (SIC) codes subject to EPCRA section 313.
                Toxics Release Inventory Reporting Forms and Instructions         H-1

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                                     Appendix H
   •  Toxic Chemical Release Reporting Using North American Industry Classification System
      (NAICS)  Final Rule (71 FR 32464;  June 6, 2006): With this  rulemaking, Toxics Release
      Inventory  (TRI) reporting will require North American Industry Classification System (NAICS)
      codes in place of  Standard Industrial Classification (SIC) codes.   For Reporting Year 2007,
      facilities will continue to report using 2002 NAICS codes.  The 2007 NAICS revision will be
      implemented  for TRI  in  2009,  for TRI Reporting  Year 2008.   North American Industry
      Classification System (NAICS), United States, 2002, Executive Office of the President, Office of
      Management and Budget, NTIS Order Number: PB2002-101430
   •  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.


H.2 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.

   •  Toxic Chemical Release Inventory Reporting Forms and Instructions Revised 2006 Version
      February 2007 (EPA 260-C-06-901)

   •  Toxics Release Inventory: Reporting Modifications Beginning with 1995 Reporting Year
      February 1995 (EPA 745-R-95-009)

   •  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

      http://www.epa.gov/tri/report/index.htnrfforms.


H.3 Chemical-Specific  Guidance

EPA has  developed a group  of guidance documents specific  to  individual  chemicals and chemical
categories.

   •  Emergency Planning and Community Right-to-Know Section 313: List of Toxic Chemicals
      within the Chlorophenols Category
      June 1999 (EPA745-B-99-013)

   •  Toxics Release Inventory List of Toxic Chemicals  within the Glycol Ethers Category and
      Guidance for Reporting
      December 2000 (EPA745-R-00-004)

   •  Emergency Planning  and  Community Right-to-Know  Act Section  313:  Guidance  for
      Reporting Hydrochloric Acid (acid aerosols including  mists, vapors, gas, fog and  other
      airborne forms of any particle size)
H-2             Toxics Release Inventory Reporting Forms and Instructions

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                                   Appendix H
   December 1999 (EPA 745-B-99-014)

•  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 (EPA260-B-01-004)

•  Toxics Release Inventory List of Toxic Chemicals within the Nicotine and Salt Category and
   Guidance for Reporting
   June 1999 (EPA745-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 (EPA260-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 (EPA260-B-01-003)

•  Toxics Release Inventory List of Toxic Chemicals within the Strychnine and Salts Category
   and Guidance for Reporting
   June 1999 (EPA745-R-99-011)

•  Emergency Planning  and Community Right-to-Know  Act Section  313: Guidance for
   Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog and other airborne forms
   of any particle size)
   March 1998 (EPA745-R-97-007)

•  Toxics Release Inventory List of Toxic Chemicals within Warfarin Category
   June 1999 (EPA745-B-99-011)

•  Toxics Release Inventory List of  Toxic  Chemicals within Ethylenebisdithiocarbamic Acid,
   Salts and Esters  Category and List of Mixtures that Contain the Individually listed Chemicals
   Maneb, Metiram, Nabam, and Zineb
   September 2001 (EPA 260-B-01-026)

•  Emergency Planning and  Community Right-to-Know  Act - Section 313:  Guidance for
   Reporting Aqueous Ammonia
   December 2000 (EPA 745-R-00-005)

•  Emergency Planning and  Community Right-to-Know  Act - Section 313:  Guidance for
   Reporting Toxic Chemicals within the Dioxin and Dioxin-like Compounds Category
              Toxics Release Inventory Reporting Forms and Instructions         H-3

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                                    Appendix H
      December 2000 (EPA 745-B-00-021)

H.4 Industry-Specific Guidance
EPA has developed specific guidance documents for certain industries.

   •  EPCRA Section 313: Guidance for Chemical Distribution Facilities
      January 1999 (EPA 745-B-99-005)

   •  EPCRA Section 313: Guidance for Petroleum Terminals and Bulk Storage Facilities
      February 2000 (EPA 745-B-00-002)

   •  EPCRA Section 313: Guidance for Coal Mining Facilities
      February 2000 (EPA 745-B-00-003)

   •  EPCRA Section 313: Guidance for Electricity Generating Facilities
      February 2000 (EPA 745-B-00-004)

   •  EPCRA Section 313 Reporting Guidance for Food Processors
      September 1998 (EPA 745-R-98-011)

   •  EPCRA Section 313 Reporting Guidance for the Leather Tanning and Finishing Industry
      April 2000 (EPA 745-B-00-012)

   •  EPCRA Section 313: Guidance for Metal Mining Facilities
      Januaryl999 (EPA 745-B-99-001)

   •  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)

   •  EPCRA Section 313 Reporting Guidance for the Printing, Publishing, and Packaging Industry
      May 2000 (EPA 745-B-00-005)

   •  EPCRA Section 313:  Guidance for RCRA Subtitle C TSD Facilities and Solvent Recovery
      Facilities
      January 1999 (EPA 745-B-99-004)

   •  EPCRA Section 313 Reporting Guidance for Rubber and Plastics Manufacturing
      May 2000 (EPA 745-B-00-017)

   •  EPCRA Section 313 Reporting Guidance for Semiconductor Manufacturing
      July 1999 (EPA 745-R-99-007)

   •  EPCRA Section 313 Reporting Guidance for the Textile Processing Industry
      May 2000 (EPA 745-B-00-008)

   •  EPCRA  Section 313  Reporting Guidance for Spray  Application and  Electrodeposition of
      Organic Coatings
      December 1998 (EPA 745-R-98-014)
H-4            Toxics Release Inventory Reporting Forms and Instructions

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                                         Index
Ancillary or other use, 44
Article Component, 43

B
Byproduct, 43
Catastrophic Events, 69, 71
CDX, vii, 1, 2, 3, 8, 37, 80
chemical processing aid, 43
Coal Extraction Activities Exemption, 26
Coincidental Manufacture, 17, 18
Container Residue, 55
Laboratory Activities Exemption, 26

M
Manufacture, 17, 18, 24, 26, 43
manufacturing aid, 43
Metal Category Compounds, 30
Metal Mining Overburden Exemption, 26
Methyl Ethyl Ketone (MEK) Delisting, vii
Mixture Component Identity, 32

N
Nitrate Compounds, 30
NPDES Permit, 39, 81
De Minimis Exemption, 22
Discharges to Receiving Streams or Water
   Bodies, 46
Diskette, 2
Disposal to Land, 47
Dun & Bradstreet, 39, 81, 82
o
On-Site Recycling Codes, 64
Other Disposal, 48
Other Surface Impoundments, 48
Otherwise Use, 17, 19, 21, 24, 43
Energy Recovery, 56, 58, 60, 63, 66
EPA Identification Number, 52, 53, 54, 81
EPCRA, iii, vi, vii, 1, 3, 4, 8, 9,  16, 17, 18, 19,
   20, 21, 22, 24, 26, 27, 28, 29, 30, 31, 32, 33,
   34, 35, 36, 37, 38, 40, 41, 42, 43, 44, 45, 46,
   47, 48, 49, 50, 52, 53, 54, 55, 56, 60, 61, 62,
   63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 75,
   76, 77, 79, 80, 82, 83
Facility Identification, 37
Form A, 76
Formulation Component, 43
Fugitive or Non-Point Air Emissions, 46
Full-Time Employee, 9

I
Import, 43
Impurity, 43
PBT, 19, 20, 22, 24, 27, 28, 30, 33, 34, 35, 36,
  41, 45, 46, 48, 52, 53, 54, 63, 64, 67, 71
Process, 4, 17, 18,24,43
Produce, 43
Production Ratio, 72
RCRA Subtitle C landfills, 47
RCRA Subtitle C Surface Impoundments, 48
Reactant, 43
Repackaging, 43
Reporting Year, iii, 2, 5, 33, 34, 35, 36, 67, 71
Revise, 4
Sale/Distribution, 43
SIC Code, 9, 38, 80
Source Reduction, 67, 73
Stormwater Runoff, 51
Submit Paper Form R, 3
Surface Impoundments, 47
84 Toxics Release Inventory Reporting Forms and Instructions

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                                            Index
Technical Contact, 2, 8, 38, 80
Threshold Determinations, 27
Total Transfers, 53
Toxics Release Inventory Assistance Library
  (TRIAL), vii
Trade Secret, 3, 37, 79
TRI-ME, vii, 1, 2, 5, 8, 37, 75, 80
u
Underground Injection, 39, 47, 57, 81

w
Waste Treatment Codes, 62
Withdraw, 4, 6
                    Toxics Release Inventory Reporting Forms and Instructions
                                         85

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