^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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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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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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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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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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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
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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
-------
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
-------
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
-------
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
-------
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
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.2.3.
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
15
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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).
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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.
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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.
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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
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
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
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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.
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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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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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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.
Toxics Release Inventory Reporting Forms and Instructions
25
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
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.
Toxics Release Inventory Reporting Forms and Instructions
27
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
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
28
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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.)
Toxics Release Inventory Reporting Forms and Instructions
29
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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
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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
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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
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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
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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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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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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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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.
50
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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%
Toxics Release Inventory Reporting Forms and Instructions 51
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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
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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
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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
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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
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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
Toxics Release Inventory Reporting Forms and Instructions
61
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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
62
Toxics Release Inventory Reporting Forms and Instructions
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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).
Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Example 17: On-Site Waste Treatment
A process at the facility generates a wastewater stream containing an EPCRA section 313 chemical (chemical A). A second
process generates a wastewater stream containing two EPCRA section 313 chemicals, a metal (chemical B) and a mineral acid
(chemical C). Thresholds for all three chemicals have been exceeded and you are in the process of completing separate Form Rs
for each chemical.
These two wastewater streams are combined and sent to an on-site wastewater treatment system before being discharged to a
POTW. This 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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Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Example 18: Reporting On-Site Energy Recovery
One waste stream generated by your facility contains, among other chemicals, toluene and Freon 113. Threshold quantities are exceeded
for both of these EPCRA section 313 chemicals, and you would, therefore, submit two separate Form R reports. This waste stream is
sent to an on-site industrial furnace that uses the heat generated in a thermal hydrocarbon cracking process at your facility. Because
toluene has a significant heat value (17,440 BTU/pound) and the energy is recovered in an industrial furnace, the code "U02" would be
reported in Section 7B for the Form R submitted for toluene.
However, as Freon 113 does not contribute any value for energy recovery purposes, the combustion of Freon 113 in the industrial
furnace is considered waste treatment, not energy recovery. You would report Freon 113 as entering a waste treatment step (i.e.,
incineration), in Section 7A, column b. In Section 7B the facility should report zero.
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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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§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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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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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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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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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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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
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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
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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.
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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
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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)
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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.
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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
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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.
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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
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
1-15
-------
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
Toxics Release Inventory Reporting Form and Instructions
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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
1-19
-------
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
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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
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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
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
A-2
Toxics Release Inventory Reporting Forms and Instructions
-------
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
-------
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.
Toxics Release Inventory Reporting Forms and Instructions
B-l
-------
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
B-2
Toxics Release Inventory Reporting Forms and Instructions
-------
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
B-4
Toxics Release Inventory Reporting Forms and Instructions
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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
B-6
Toxics Release Inventory Reporting Forms and Instructions
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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
Toxics Release Inventory Reporting Forms and Instructions
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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
Toxics Release Inventory Reporting Forms and Instructions
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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
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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.
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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.
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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;
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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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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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Appendix C
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
C-10
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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
Toxics Release Inventory Reporting Forms and Instructions
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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)
Toxics Release Inventory Reporting Forms and Instructions
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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)
Toxics Release Inventory Reporting Forms and Instructions
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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
Toxics Release Inventory Reporting Forms and Instructions
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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
-------
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
-------
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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This Page Intentionally Left Blank
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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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