EPA 260-K-08-001
                        October 2008
& t
      Toxic Chemical Release
      Inventory Reporting Forms
      and Instructions
      Revised 2008 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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                        Important Information for Reporting Year 2008
Table of Contents
New Information for Reporting Year 2008	v
        Other Important Information for RY 2008	vi
        TRI-ME2008	vii
        Web Sites and Points of Contact for Assistance	viii
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     How to Revise or Withdraw TRI Data	4
A.6     When the Report Must Be Submitted	7
A.7     How to 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	11
        B.2.b.   Multi Establishment Facilities	11
        B.2.c.   Property Owners	12
B.3     Activity Determination	12
        B.3.a.   Definitions of Manufacture, Process, and Otherwise Use	12
        B.3.b.   Persistent Bioaccumulative Toxic (PBT)	15
        B.3.c.   Activity Exemptions	16
B.4     Threshold Determinations	22
        B.4.a.   How to Determine if Your Facility Has Exceeded Thresholds	23
        B.4.b.   Threshold Determinations for On-Site Reuse Operations	24
        B.4.c.   Threshold Determinations for Ammonia	25
        B.4.d.   Threshold Determinations for Chemical Categories	25
        B.4.e    Threshold Determination for Persistent Bioaccumulative Toxic (PBT) Chemicals	26
        B.4.f   Mixtures and Other Trade Name Products	26
B.5     Release and Other Waste Management Determinations for Metals, Metal Category Compounds,
        and Nitrate Compounds	27
C.      Instructions for Completing TRI Form R	33
Parti.   Facility Identification Information	33
        Section 1.   Reporting Year	33
        Section 2.   Trade Secret Information	33
        Section 3.   Certification	33
        Section 4.   Facility Identification	33
        Section 5.   Parent Company Information	35
Part II.  Chemical Specific Information	36
        Section 1.   EPCRA Section 313  Chemical Identity	36
        Section 2.    Mixture Component Identity	37
        Section 3.    Activities and Uses of the EPCRA Section 313 Chemical at the Facility	37
        Section 4.    Maximum Amount of the EPCRA Section 313 Chemical On-site at Any Time
        during the Calendar Year	39
        Section 5.    Quantity of the EPCRA Section 313 Chemical Entering Each Environmental
                    Medium On-site	40

                   Toxics Release Inventory Reporting Forms and Instructions                      i

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        Section 6.   Transfers of the EPCRA Section 313 Chemical in Wastes to Off-Site Locations.. 48
        Section 7.  On-Site Waste Treatment, Energy Recovery, and Recycling Methods	57
        Section 8.  Source Reduction and Recycling Activities	64
D. Instructions for Completing Form R Schedule 1 (Dioxin and Dioxin-like Compounds)	76
D.I     What is the Form R Schedule 1?	76
D.2     Who is required to file a Form R Schedule 1?	76
D.3     What information is  reported on the Form R Schedule 1?	76
E.      Facility Eligibility Determination for Alternate Threshold and for Reporting on EPA Form
        A	79
E.I     Alternate Threshold	79
E.2     What is the Form A Certification Statement?	79
E.3     What Is the Annual Reportable Amount?	79
E.4     Recordkeeping	80
E.5     Multi establishment Facilities	80
E.6     Trade Secrets	80
E.7     Metals and Metal Category Compounds	80
F.      Instructions for Completing EPA Form A	82
Parti.    Facility Identification Information	82
        Section 1.   Reporting Year	82
        Section 2.   Trade Secret Information	82
        Section 3.   Certification	82
        Section 4.   Facility Identification	82
        Section 5.   Parent Company Information	84
Part II.  Chemical Identification	85
        Section 1.   Toxic Chemical Identity	85
        Section 2.   Mixture Component Identity	86
Index   	87
                   Toxics Release Inventory Reporting Forms and Instructions

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                        Important Information for Reporting Year 2008
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	43
Figure 4. Hypothetical Section6.2 Completed for Two Off-Site Locations	60
Figure 5. Hypothetical SectionTA	64

Tables

Table I     NAICS Codes	1-1
Table II    EPCRA Section 313 Chemical List (including chemical categories)
           for Reporting Year 2008	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-l
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                    iii

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iv                 Toxics Release Inventory Reporting Forms and Instructions

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                         Important Information for Reporting Year 2008
New Information for Reporting Year 2008


•   Please note that the 2008 version of the Toxics Release Inventory (TRI) Reporting Forms and Instructions
    document supersedes previous versions of the document.

•   Reporting Year (RY) 2008 will be the last year that the TRI-ME desktop software will be offered. Starting
    RY2009, EPA intends to offer only TRI-MEweb.

•   Toxics Release Inventory (TRI) reporting requirements changed on March 11, 2009, as a result of a
    change in federal law. The 2009 Omnibus Appropriations Act, returned TRI reporting requirements
    back to the rules in effect prior to December 22, 2006. These changes affect TRI reports  due July 1,
    2009.

    The change requires that all reports on persistent, bioaccumulative, and toxic (PBT) chemicals be
    submitted on "Form R," the more detailed form. For all other chemicals the shorter form, "Form A"
    may be used only if the "annual reporting amount" is 500 pounds or less and that the chemical was
    manufactured, processed or otherwise used in an amount not exceeding 1 million pounds during the
    reporting year.  Refer to Section E.3 of this document for information regarding annual reportable
    amounts for Form A.

•   New Reporting Requirements for Dioxin and Dioxin-like Compounds: Beginning with Reporting Year
    2008 facilities that file reports for the dioxin and dioxin-like compounds category may also need to file a
    Form R Schedule 1. The Form R Schedule  1 is a four-page form that mirrors the data elements from Form
    R Part II. Chemical-Specific information  Section 5, 6, and 8 (current year only). The Form R Schedule 1
    requires the reporting of the individual grams data for each member of the dioxin and dioxin-like
    compounds category and is submitted as an adjunct to the Form R. Facilities that have any of the
    information required by Form R Schedule 1 must submit a Form R Schedule 1 in addition to the Form R.
    Since the Form R Schedule 1 captures information  on the individual members of the dioxin and dioxin-like
    compounds category, EPA has removed Part II Section 1.4 of the Form Rthat required the reporting of a
    single  distribution of the members of the category.

•   Facilities will not be able to report Dioxin and Dioxin-like Compounds using the TRI-ME software.
    Instead, they will either need to report using TRI-MEweb or via paper submissions.

•   TRI-MEweb will be available to all reporting facilities in RY 2008, including first time filers. TRI-MEweb
    is a Web-based  version of the popular TRI-ME reporting Software. Facility Technical Contacts will be
    emailed an access key by February, 2009. Please note that, if you are using TRI-MEweb for the first time,
    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           •  Quick Lists
       assistance                                      •  Enhanced Section 8 Calculator

                   Toxics Release Inventory Reporting Forms and Instructions                     v

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    •   Prior Year revision capability                     •   Third Party Load
    •   Trend Analysis Reports                          •   Multi-establishment reporting
    •   Electronic withdrawals                          •   First-time filer reporting

To learn more about this new solution to TRI reporting, please visit www.epa.gov/tri.

Other Important Information for RY 2008


    •   Public Availability of 2008 TRI Reports. EPA plans to issue an electronic Facility Data Release
       (e-FDR) for RY 2008 in the fall of 2009. The e-FDR provides early access to the individual forms
       submitted by regulated facilities. The annual Public Data Release for RY 2008, which includes
       summary data, analyses, and trends, will be released by the Spring of 2010.

    •   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.)

    •   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.

    •   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
       Section223 of the Small Business Regulatory Enforcement Fairness Act (SBREFA) of 1996. For
       more information, see the Agency's Web site
       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. EPA published a rule to adopt OMB's 2007 NAICS codes beginning with
       RY 2008, for TRI reporting forms that are due by July 1, 2009, facilities will be required to use
       2007 NAICS codes.  For a complete listing of covered TRI NAICS codes for RY 2008, including
       NAICS codes changes, exceptions and limitations, refer to the TRI web page at
       www. epa. gov/tri/lawsandre gs/naic/ncode s .htm
vi                 Toxics Release Inventory Reporting Forms and Instructions

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                         Important Information for Reporting Year 2008
TRI-ME 2008 Software


***This is the last year the TRI-ME Software will be offered by EPA***
The TRI-ME 2008 software helps facilities in determining and completing their Emergency Planning and
Community Right-to-Know (EPCRA) Section 313 and Pollution Prevention Act (PPA) Section6607
obligations. TRI-ME is an interactive, intelligent, user friendly software tool that guides facilities through
the TRI reporting experience. By leading prospective reporters through a series of logically ordered
questions, TRI-ME streamlines the analysis needed to determine if a user must complete a Form R Report
or Form A Certification Statement for a particular chemical. For those facilities required to report, the
software provides the user with guidance for each data element on the reporting forms. Additionally, this
software has a one stop guidance feature, the TRI Assistance Library that allows users to search the
statute, regulations, and many EPCRA Section 313 guidance documents by key word. For the more
experienced reporter, TRI-ME allows direct data entry onto electronic versions of the Form R and Form A
Certification Statement. TRI-ME will check the data for common errors and then prepare the forms. All of
the information contained in this RY 2008 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.

TRI-ME RY 2008 will not support the reporting of Dioxin and Dioxin-like Compounds due to the new
Form R Schedule 1  reporting requirements.
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-ME?

You may load prior year data from Reporting Year 2007 submission diskettes or from TRI-ME Reporting
Year 2007 facility files. With few exceptions, all of your prior year data will be loaded directly into the
Reporting Year 2008 forms. To load Reporting Year 2006 data into TRI-ME 2008, you must first load
your data into TRI-ME 2007. If you have questions about loading data from 2005 or prior years, please
visit the TRI Web site at http://www.epa.gov/tri/contacts/contacts.htm.

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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Web Sites and Points of Contact for Assistance


Technical Support:
For TRI information and contacts for technical support refer to the "Contact Us" page at
www.epa.gov/tri/contacts/contacts.htm

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

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.
viii                Toxics Release Inventory Reporting Forms and Instructions

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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number:  2070-0093
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A 170 A FORMR
mf^f TJ X\f\. Section 313 of the Emergency Planning
^'^ Right-to-KnowActof 1986, also Kno-i
United States Superfund Amendments and Reauthor
Environmental Protection Agency
WHERE TO SEND COMPLETED FORMS: 1
This section only applies if you are
revising or withdrawing a previously
submitted form, otherwise leave blank.
. TRI Data Processing Center
P.O. Box 1513
Lanham, MD 20703-1513
TRI Facility
I and Community
wn as ntle ill 01 the Toxic Chen
izationAct
ID Number

lical, Category or Generic Name

2. APPROPRIATE STATE OFFICE
(See instructions in Appendix E)
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 ident
DYes (Answer question 2.2;
Attach substantiation forms)
fied on page 2 trade secret?
No (Do not answer 2.2
T ,, . Sanit^ori Unsonitized
22 Is this copy 	 sanitized | 	 |
(Answer only if "YES" in 2. 1)
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted information is true and
complete and that the amounts and values in this report are accurate based on reasonable estimates using data available to the preparers of this report.
Name and official title of owner/operator or senior management official:

SECTION 4. FACILITY IDENTIFICATION
4.1

Facility or Establishment Name

Street |
City/County/State/Zip Code

4.2
4.3
4.4

4.5
4.6
Signature:

Date Signed:


TRI Facility ID Number
Facility or Establishment Name or Mailing Address (If different from street address) |




Vlailing Address 1

Citv/State/Zirj Code 1




This report contains information for: 1 1 An entire 1 1 Part of a 1
(Important: Check a or b; check c or d if applicable) a- | 	 | facility | 	 | facility c' 1 	
Technical Contact Name
Email Address
Public Contact Name


lelephon



Email Address
NAICS Code (s)
(6 digits)
Primary
a.
Dun & Bradstreet a.
Number (s) (9 digits)
b.

Telephon


b. c.
d. e.





Country (Non-US)|

A Federal 1 1 GOCQ
facility d. | 	 |
3 Number (include area code) |


; Number (include area code)|


f.


SECTION 5. PARENT COMPANY INFORMATION
5.1
5.2
Name of Parent Company NA
Parent Company's Dun &
Bradstreet Numbs

;r NA



 EPA Form  9350 -1 (Rev.  08/2008) - Previous editions are obsolete.

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  (IMPORTANT: Type or print; read instructions before completing form)
                                                                         Form Approved OMB Number: 2070-0093
                                                                         Approval Expires: 03/31/2011                   Page 2 of 5
                                                                                                TRI Facility ID Number
                            FORMR
  PART II. TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM
                                                                                                r°xic chemical> Category or Generic Name
 SECTION 1. TOXIC CHEMICAL IDENTITY         (Important: DO NOT complete this section if you completed Section 2 below.)
 1.1
      CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
 1.2
      Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list. )
 1.3
     Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
  SECTION 2. MIXTURE COMPONENT IDENTITY
                                                       (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
      Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces and punctuation.)
  SECTION 3.  ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
                  (Important: Check all that apply.)
3.1   Manufacture the toxic chemical:
                                             3.2
                                                Process the toxic chemical:
 3.3    Otherwise use the toxic chemical:
    a.     Produce
              b. |   |l
                           mport
           If produce or import
    C.I _ 1  For on-site use/processing
    d.l   1  For sale/distribution
    e 1   1  As a byproduct
    f I   I  As an impurity
a.L
b.[
c.[

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.
 4.1
             (Enter two digit code from instruction package.)
  SECTION 5.   QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVHIONMENTAL 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.     1      1  (example: 1,2,3, etc.)
EPA Form 9350 -1 (Rev. 08/2008) - Previous editions are obsolete.
                                                                              *For Dioxin or Dioxin-like compounds, report in grams/year.
                                                                   ** Range Codes: A= 1-10 pounds; B= 11-499 pounds; C= 500-999 pounds.

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     (IMPORTANT: Type or print; read instructions before completing form)
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                                          FORMR
                 PART II. CHEMICAL - SPECIFIC INFORMATION (CONTINUED)
                                                                                             TRI Facility ID Number
                                                                                      Toxic Chemical, Category or Generic Name
   SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERINGEACH 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. 08/2008) - 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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  Please do not copy
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    (IMPORTANT: Type or print; read instructions before completing form)
                                                                Form Approved OMB Number: 2070-0093
                                                                Approval Expires: 03/31/2011                  Page 4 of 5
                                       FORMR
            PART II. CHEMICAL-SPECIFIC INFORMATION  (CONTINUED)
                                                                                                  TRI Facility ID Number
                                                                                Toxic Chemical, Category or Generic Name
   SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (CONTINUED)
    A. Total Transfers (pounds/year*)
       (enter range code**or estimate)
                          B. Basis of Estimate
                            (enter code)
 c. Type of Waste Treatment/Disposal/
   Recycling/Energy Recovery  (enter code)
   1.
                                          1.
                                                                                        1. M
   2.
                                          2.
                                                                                       2. M
   3.
                                          3.
                                                                                       3. M
   4.
                                          4.
                                                                                        4. M
            Off-Site EPA Identification Number (RCRA ID No.)
 Off-Site Location Name
 Off-Site Address
 City
                                 State
County
                                                             Zip
                         Country
                         (Non-US)
 Is location under control of reporting facility or parent company?
                                                                              Yes
                                                                                                 No
 A. Total Transfers  (pounds/year*)
    (enter range code**or estimate)
                          B. Basis of Estimate
                             (enter code)
C. Type of Waste Treatment/Disposal/
   Recycling/Energy Recovery (enter code)
   1.
                                                                                        1. M
   2.
                                         2.
                                                                                        2. M
   3.
                                         3.
                                                                                        3. M
   4.
                                         4.
                                                                                        4. M
  SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
       Not Applicable (N A) -
         Check here if no on-site waste treatment is applied to any
         waste stream containing the toxic chemical or chemical category.
  a. General
    Waste Stream
    [enter code]
                  b. Waste Treatment Method(s) Sequence
                       [enter 3- or 4- character code(s)]
        d.  Waste Treatment Efficiency
           [enter 2 character code]
    7 A. la
                  7A.lb
                                                                                                           7A.ld
   7A2a
7A.2b   I
  7A3a
7A.3b  I
                                                                                                          7A.2d
                                                                                                           7A.3d
   7A4a
                  7A.4b
                                                                                                           7A.4d
   7A5a
7A.5b  |
                                                                                                           7A.5d
 If additional pages of Part II, Section 6.2/7 A are attached, indicate the total number of pages in this box
 and indicate the Part II, Section 6.2/7 page number in this box:  | _ |  (example:  1,2,3, etc.)
EPA Form 9350 -1 (Rev. 08/2008) - Previous editions are obsolete.
                                                                   *For Dioxin or Dioxin-like compounds, report in grams/year
                                                         "Range Codes: A=l - 10 pounds; B=ll - 499 pounds C= 500-999 pounds.

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   (IMPORTANT:  Type or print; read instructions before completing form)
                                                                              Form Approved OMB Number: 2070-0093
                                                                              Approval Expires:  03/31/2011                Page 5 of 5
                                              FORMR
                  PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
                                                                                                         TRI Facility ID Number
                                                                                                        Toxic Chemical, Category or Generic Name
    SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
          Not Applicable (NA) -
                       Check here if no on-site energy recovery is applied to any waste
                       stream containing the toxic chemical or chemical category.
       Energy Recovery Methods [enter 3-character code(s)]

                     1    I                   I
    SECTION 1C. ON-SITE RECYCLING PROCESSES
          Not Applicable (NA) -
                     Check here if no on-site recycling is applied to any waste
                     stream containing the toxic chemical or chemical category.
       Recycling Methods [enter 3-character code(s)]
  SECTION 8.  SOURCE REDUCTION AND RECYLING ACTIVITIES
                                              Column A
                                              Prior Year
                                              (pounds/year*)
                                                              Column B
                                                              Current Reporting Year
                                                              (pounds/year*)
Column C
Following Year
(pounds/year*)
Column D
Second Following Year
(pounds/year*)
  8.1
  8.1a
Total on-site disposal to Class I
Underground InjectionWells, RCRA
Subtitle C landfills, and other landfills
 8.1b
Total other on-site disposal or other
releases
  8.1c
Total off-site disposal to Class I
Underground InjectionWells, RCRA
Subtitle C landfills, and other landfills
 8.1d
Total other off-site disposal or other
releases
  8.2
 Quantity used for energy recovery
 onsite
  8.3
Quantity used for energy recovery
offsite
  8.4
Quantity recycled
onsite
  8.5
        Quantity recycled offsite
  8.6
Quantity treated onsite
  8.7
        Quantity treated offsite
  8.8
Quantity released to the environment as a result of remedial actions, catastrophic events,
 or one-time events not associated with production processes (pounds/year)*
  8.9
Production ratio or activity index
  8.10
Did your facility engage in any source reduction activities for this chemical during the reporting
year? If not, enter "NA" in Section 8.10.1 and answer Section 8.11.
        Source Reduction Activities
             [enter code(s)]
                                                             Methods to Identify Activity (enter codes)
 8.10.1
 8.10.2
                                                                     b.
 8.10.3
                                                                     b.
 8.10.4
                                                                     b.
 8.11
If you wish to submit additional optional information on source reduction, recycling, or pollution
control activities, check "Yes."
                                                                                                                    Yes
EPA Form 9350 -1 (Rev. 08/2008) - 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 o
  United States
  Environmental Protection Agency
                                        TOXICS RELEASE INVENTORY
                                                     FORMA
 WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center
                                          P. O. Box 1513
                                          Lanham, MD 20703-1513
                                          ATTN: TOXIC CHEMICAL RELEASE INVENTORY
                                                                  2.  APPROPRIATE STATE OFFICE
                                                                     (See instruction in Appendix E)
                              TRI Facility ID Number
  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?
    I Yes  (Answer question 2.2;        I    I No  (Do not answer 2.2;
 	I      Attach substantiation forms)  |	|     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 to the best of my knowledge and belief, for each toxic chemical listed in the statement, the annual reportable amount as defined in 40 CFR
  372.27 (a), did not exceed 500 pounds for this reporting year and that the chemical was manufactured, processed, or otherwise used in an amount not exceeding 1
  million pounds during this reporting year.
 Name and offical title of owner/operator or senior management official:
                                                                       Signature:
                                                                                                        Date Signed:
   SECTION 4. FACILITY IDENTIFICATION
 4.1
                                                    TRI Facility ID Number
 Facility or Establishment Name |
                                                Facility or Establishment Name or Mailing Address (If different from street address) |
 Street
                                                Mailing Address   |
 City/County/State/Zip Code |
                                                City/State/Zip Code |
                                     Country (Non-US)
4.2 This report contains information for: (Important: Check cord if applicable)
                                                                                           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
                         a.
4.7
Dun & Bradstreet
Number (s) (9 digits)
   SECTION 5. PARENT COMPANY INFORMATION
 5.1
     Name of Parent Company
                          NA
 5.2
    Parent Company's Dun & Bradstreet Number
                                         NA
EPA Form 9350 -2 (Rev. 03/2009) - Previous editions are obsolete.

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  (IMPORTANT: Type or print; read instructions before completing form)                                                                   Page    of __
                                                       EPA FORM A
                                    PART II. CHEMICAL IDENTIFICATION           TRIFID
                                 Do not use this form for reporting PBT chemicals including Dioxin and Dioxin-like Compounds*
   SECTION 1. TOXIC CHEMICAL IDENTITY                                                        Report _of _
     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 list of PBT Chemicals (including Dioxin and Dioxin-like Compounds)

EPA Form 9350 -2 (Rev. 03/2009) - Previous editions are obsolete.
                                                                                          (Make additional copies of this page, if needed)

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 (IMPORTANT: Type or print; read instructions before completing form)
                                                                         Form Approved OMB Number: 2025-0007
                                                                         Approval Expires 04/30/2010
Page 1 of 4
FORM R Schedule 1
TRI Facility ID Number

United States
Environmental Protection RART II. CHEMICAL-SPECIFIC IN FORMATION (continued)
SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE

D. Mass (grams) of Each Compound in the category (1-17)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
5.1 NA
Fugitive or non-
point air emissions

















5.2 NA
Stack or point
air emissions

















5 , Discharges to receiving streams or water bodies
(enter data for one stream or water body per box)
5.3.1

















If additional pages of Section 5.3 are attached, indicate the total number of pages in this bo;
and indicate the Section 5.3 page number in this box (example: 1,2,3, etc.)
5.3.2


















<

5.3.3


















EPA Form 9350-3

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(IMPORTANT: Type or print; read instructions before completing form)
                                                                              Form Approved OMB Number: 2025-0007
                                                                              Approval Expires 04/30/2010
Page 2 of 4
FORM R Schedule 1
TRI Facility ID Number

PART II. CHEMICAL-SPECIFIC IN FORMATION (continued)
SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE


C. Mass (grams) of Each Compound in the category (1-17)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Underground Injection
5.4.1 NA
Underground
Injection onsite
to Class I Wells

















5.4.2 NA
Underground
Injection onsite
to Class II-V
Wells

















5.5 Disposal to land onsite
5.5.1. A NA
RCRA Subtitle C
andfills

















5.5.1. B NA
Other landfills

















5.5.2 NA
_and treatment/
application farming

















5.5.3A NA
RCRA Subtitle C
surface
impoundments

















5.5.3B NA
Other surface
mpoundments

















5.5.4 NA
Other disposal

















EPA Form 9350-3

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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2025-0007
Approval Expires:04/30/2010
Page 3 of 4
FORM R Schedule 1

TRI Facility ID Number

PART II. CHEMICAL-SPECIFIC INFORMATION (continued)
SECTION
6. TRANSFERS OF DIOXIN AND DIOXIN-LIKE COMPOUNDS IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1.A.3 Mass (grams) of Each Compound in the Category (1-17)
1
10


2
11


3
12


4
13


5
14


6
15


7
16


8
17


9


6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
6.2.
1.
9
D. Mass (grams)


2.
9

3.
9

4.
9

6.2.
1.
9

9

9

9
1
10
1
10
1
10
1
10








2
11
2
11
2
11
2
11








3
12
3
12
3
12
3
12

of Each Compound in the Category (1-17)









D. Mass (grams)


2.

3.

4.

1
10
1
10
1
10
1
10








2
11
2
11
2
11
2
11








3
12
3
12
3
12
3
12

4
13
4
13
4
13
4
13








5
14
5
14
5
14
5
14









6
15
6
15
6
15
6
15








7
16
7
16
7
16
7
16








8
17
8
17
8
17
8
17








of Each Compound in the Category (1-17)









If additional pages of Section 5.3 are attached, indicate the tota
and indicate the Section 5.3 page number in this box

4
13
4
13
4
13
4
13








5
14
5
14
5
14
5
14









I number of pages in this box
(example: 1,2,3, etc.)
6
15
6
15
6
15
6
15











7
16
7
16
7
16
7
16








8
17
8
17
8
17
8
17









    EPA Form 9350-3

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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2025-0007
Approval Expires:04/30/2010
Page 4 of 4
FORM R Schedule 1
PART II. CHEMICAL-SPECIFIC INFORMATION (continued)
TRI Facility ID Number


SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES FOR DIOXIN AND DIOXIN-LIKE COMPOUNDS (current year only)

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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
8.1a
Total onsite
disposal to
Class 1
Underground
Injection
Wells,
RCRA Subtitle
C landfills, and
other landfills

















8.1b
Total other
onsite disposal
or other
releases

















8.1c
Total offsite
disposal to
Class 1
Underground
Injection
Wells,
RCRA Subtitle
C landfills, and
other landfills

















8.1d
Total other
offsite 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

















    EPA Form 9350-3

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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.
    Section6921  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 pre-populated, 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
                   Toxics Release Inventory Reporting Forms and Instructions
                                            1

-------
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
submission(s) via CDX. Both TRI-MEweb and the
TRI-ME  software  allow   you  to  submit   a
completely paperless report to EPA (Internet and
diskette submissions are not available for trade
secret  claims). If you choose to  submit via the
Internet,  do not send  duplicate paper or diskette
copies of the reports. Please  be aware that if your
facility does not reside in a state  participating in
the TRI  State  Data Exchange  submitting via the
Internet  does  not  satisfy  your  state reporting
requirements for your facility. You must report to
your state  separately  and  in the required  format
specified by your state (i.e., diskette, paper, etc.).

For  questions or  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 submit your TRI Form  R(s) and/or Form A(s)
on magnetic media/diskette using TRI-ME, please
follow the  instructions below.  If you choose  to
submit on diskette, do not submit duplicate CDX
or paper copies of the reports that are on  the
diskette.  Please  note  that  TRI-MEweb  now
supports a diskette submission process.
A.2.b.l Labeling Your Submission Diskette
             Company Name
 Date: 6/30/2009
 Reporting Year: 2008
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.  For more
information  about state  requirements, please see:

                   Toxics Release Inventory Reporting Forms and Instructions

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                                      General Information
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  and 2.2, and Part
II, Section 1.3, of the instructions.

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

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

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
                   Toxics Release Inventory Reporting Forms and Instructions

-------
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 Section312 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 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
                   Toxics Release Inventory Reporting Forms and Instructions

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                                      General Information
      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
revised report to EPA and the  appropriate State
agency. For submitting a revision to EPA, please
use one of the following methods:

1. TRI-MEvteb. 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 refer to the TRI-ME
web            page                       at
http://www.epa.gov/tri/report/software/index.htmtf
usetrime

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 refer to the TRI-ME
web                  page                 at
http://www.epa.gov/tri/report/software/index.htmtf
usetrime.
3.  TRI-ME via Diskette.  If you do  not  have
Internet access and you wish to  revise a form for
Reporting  Year 2004  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
                   Toxics Release Inventory Reporting Forms and Instructions
                                            5

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    2007 revisions and beyond, please enter  all
    information  including  in  the  appropriate
    revision code(s). For RY 2006 and prior years,
    please enter all information including an "X"
    in the space marked "Enter 'X' here if this is a
    revision," on Page 1 of the form.  Please sign
    and date the certification statement on Page  1.

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

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

•   WO1 -  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.  TKT-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/report/software/index.htnrf
usetrime.

2. TRI-ME via CDX. For the RY 2007 and 2008
versions   of  the software,  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.

3. TRI-ME via Diskette. For  the RY 2007 and
2008 versions of the software, 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
                   Toxics Release Inventory Reporting Forms and Instructions

-------
                                     General Information
    on  Page   1   and  enter   the   appropriate
    withdrawal code(s) in the space  provided on
    Page 1 of the form.

•   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
    all  information  including  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
       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

-------
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.I   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 number of full time employees for
    this  facility is equal to 16,500 hours divided
    by 2,000 hours per full time employee, or 8.3
    full time  employees. Therefore, even though
    11 persons worked for this facility during  the
    calendar year, the number of hours worked is
    equivalent to  8.3 full time employees. This
    facility does not meet the  employee criteria
    and is  not subject to EPCRA Section 313
    reporting.

•   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  requires  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
(71  FR 32464). For Reporting Year 2008, facilities
should use 2007 NAICS codes.

For Reporting Year 2008,  facilities  should use
2007 NAICS codes.  EPA published a final rule on
June  9,  2008  to incorporate  2007   Office  of
Management  and Budget (OMB)  revisions and
other corrections to the NAICS codes used for TRI
Reporting.  [Federal Register (FR) notice 73  FR
32466.] With this rule, facilities are required to use
2007 NAICS codes on TRI reporting forms that
are  due on July  1, 2009, covering releases and
other waste management quantities at  the facility
for 2008.

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 and also at the TRI
web                  site                   at
                   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
www. epa. gov/tri/lawsandre gs/naic/ncode s .htm.
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.
      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 or provide information to or for a Federal agency. This
      includes the time needed to review instructions; develop, acquire, install, and utilize technology
      and systems for the 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

-------
    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
         CTTFMTCAT, CATFYIORV
                     YES
   Is this chemical or chemical category identified
   as Persistent, Bioaccumulative, and Toxic
   (PBT)?
          YES
             NO
                       NO
                       NO
                       NO
                        NO
                                                                  STOP
                                    NO EPCRA SECTION
                                          313 REPORTS
                                                      REQUIRED FOR ANY
                                          CHEMICALS
                      Is the amount manufactured, OR processed, OR otherwise used less than
                      or equal to 1,000,000 pounds and is the reportable amount less than or
                      equal to 500 Ibs/year?
                               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
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
B.2.a.   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 its 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 percent 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  Section372.22(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
    in NAICS 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
    percent 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).
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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.

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.3.a.   Definitions of Manufacture,
         Process, and Otherwise Use

Manufacture: The term "manufacture" means to
produce, prepare, compound, or import an  EPCRA
Section 313  chemical. (See  Part II, Section 3.1 of
these instructions for further clarification.)

Import is defined as causing the EPCRA Section
313 chemical to be imported  into the customs
territory  of  the United  States. If you order an
EPCRA  Section 313  chemical  (or  a  mixture
containing the chemical) from a foreign supplier,
then you have  imported the  chemical when that
shipment arrives at your facility directly from a
source outside of the United States. By ordering
the chemical, you have  caused it to be imported,
even  though  you  may have  used  an import
brokerage firm  as an agent to obtain the  EPCRA
Section 313 chemical.

Do Not Overlook Coincidental Manufacture
                              The   term    "manufacture"   also    includes
                              coincidental production of an EPCRA Section 313
                              chemical (e.g., as a byproduct or impurity) as a
                              result of the  manufacture, processing, otherwise
                              use or disposal of another chemical or mixture of
                              chemicals. In the case of coincidental production
                              of an  impurity  (i.e., an  EPCRA  Section  313
                              chemical that remains  in  the product  that is
                              distributed   in   commerce),   the   de   minimis
                              exemption,  discussed  in  Section B.3.c  of these
                              instructions,  applies.  The de  minimis exemption
                              does  not apply to byproducts (e.g., an  EPCRA
                              Section  313 chemical that is separated  from a
                              process stream and further processed or disposed).
                              Certain  EPCRA  Section 313 chemicals  may be
                              manufactured as  a result of wastewater treatment
                              or other  treatment   processes.   For   example,
                              neutralization of wastewater containing nitric acid
                              can result in the coincidental manufacture  of a
                              nitrate   compound  (solution), reportable as  a
                              member of the nitrate compounds category.

                              Process:  The  term   "process"   means   the
                              preparation   of a  listed EPCRA   Section  313
                              chemical, after its manufacture, for distribution in
                              commerce. Processing is usually the incorporation
                              of an EPCRA Section 313 chemical into a product
                              (see Part II,  Section 3.2 of these instructions for
                              further  clarification),  however,  a  facility  may
                              process  an impurity that already exists  in a  raw
                              material  by  distributing   that   impurity   in
                              commerce. Processing includes preparation of the
                              EPCRA  Section  313  chemicals in the same
                              physical state or chemical form as that received by
                              your facility, or preparation that produces a change
                              in physical state or chemical form. The term also
                              applies to the processing of a mixture  or other
                              trade name product (see Section B.4.b  of these
                              instructions) that  contains a listed EPCRA Section
                              313 chemical as one component.

                              Otherwise Use: The term "otherwise use" means
                              any use  of  an EPCRA  Section  313  chemical,
                              including  an  EPCRA  Section  313   chemical
                              contained in a mixture or other trade name product
                              or waste, that  is not  covered  by the  terms
                              manufacture  or  process. Otherwise use of  an
                              EPCRA Section  313 chemical does not include
                              disposal,   stabilization    (without   subsequent
                              distribution  in  commerce),  or  treatment  for
                              destruction unless:

                              (1) The EPCRA Section 313 chemical that was
                              disposed, stabilized, or treated for destruction was
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

received from off-site for the purposes of further    the  purposes  of waste  management  activities.
waste management;                                Relabeling or redistributing of the EPCRA Section
                                                 313  chemical  where  no repackaging  of  the
Or                                               EPCRA  Section 313  chemical occurs does  not
                                                 constitute an otherwise use or processing of the
(2)  The EPCRA Section 313  chemical that was    EPCRA Section 313 chemical.  (See 62 FR 23846
disposed, stabilized, or treated for destruction was    and  Part II,  Section 3.3 of these instructions for
manufactured as a  result  of waste management    further clarification).
activities on materials received from  off-site for
 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  percent 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 percent of the total aqueous  ammonia from the
        solution of ammonium nitrate (see the qualifier for the ammonia listing).

     U 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.
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 Example 2: Typical Process and Manufacture Activities

     U  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.
     U  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.
     U  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 (CuC12) 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.
 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.
     U  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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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
 B.3.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 Section372.45(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
individual members of the dioxin and dioxin-like
compounds category they will also need to file a
Form R Schedule 1 (see instructions in Section D).

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
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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
not be considered for  lead not in stainless steel,
brass, or bronze alloys;

        4)  If  a  facility 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 Form R or the  use of
whole numbers and 2  significant digits to any of
the lead they report though 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 that use of a chemical
                              (40  CFR  Section372.38(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 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.
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
The  articles exemption applies  to the  normal
processing or 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 use,  an item
retains its initial thickness or diameter, in whole or
in part, it meets the first part (i.e., it  must be a
manufactured item which is formed to a specific
shape or design during manufacture) of the article
definition.   If  the  item's  basic  dimensional
characteristics are totally altered during processing
or otherwise use, the item does not meet the  first
part of the definition. An example of items that do
not meet the definition would be items which are
cold extruded,  such  as lead ingots,  which are
formed  into  wire or rods. On the other hand,
cutting a manufactured item into pieces which are
recognizable as the article  would not change the
original dimensions as long as the diameter or the
thickness  of the item  remained the  same; the
articles exemption would continue to apply. Metal
wire may be bent and  sheet  metal  may  be cut,
punched, stamped, or pressed without losing their
article status as long as the diameter of the wire or
tubing  or the thickness of the sheet is not totally
changed.

What constitutes  a release of an EPCRA  Section
313  chemical is important since processing or
otherwise use of articles that result in a release to
the environment (or more than 0.5 pounds) negate
the article status  and precludes eligibility for the
exemption. Cutting,  grinding, melting, or  other
processing of manufactured items could result in a
release of an EPCRA Section 313 chemical during
normal conditions of processing  or otherwise use
and therefore negate the exemption as articles.
 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.
     U EPCRA Section 313 chemicals received in the form of pellets are not articles because the pellet
        form is simply a convenient form for further processing of the material.
De  Minimis   Exemption.  The  de  minimis
exemption  allows facilities to disregard certain
minimal  concentrations of non-PBT chemicals
in mixtures or other trade name products when
making threshold determinations and release and
other waste management calculations. The de
minimis  exemption does  not  apply  to  the
manufacture of an EPCRA Section 313 chemical
except if that EPCRA  Section  313  chemical  is
manufactured as an impurity and remains in the
  product distributed  in  commerce,  or if the
  EPCRA Section 313 chemical is imported below
  the appropriate de minimis level. The de minimis
  exemption  does  not  apply  to  a  byproduct
  manufactured  coincidentally  as  a  result  of
  manufacturing, processing, otherwise use, or any
  waste management activities. The de  minimis
  exemption does not apply to any PBT chemical
  (except lead when  it is  contained in  stainless
  steel, brass or bronze alloy) or PBT chemical
                    Toxics Release Inventory Reporting Forms and Instructions
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category. A list of PBT chemicals may be found
in Section B.4 of these instructions.

When  determining whether  the  de minimis
exemption applies  to  an EPCRA  Section 313
chemical,  the owner/operator must  consider the
concentration of the non-PBT EPCRA  Section
313 chemical in mixtures and other trade  name
products.  If the non-PBT EPCRA  Section 313
chemical  in a mixture or other  trade  name
product  is  manufactured   as  an  impurity,
imported,  processed,  or otherwise  used and  is
below the appropriate  de minimis concentration
level, then the  quantity of the non-PBT EPCRA
Section 313 chemical in that mixture or  other
trade name product does not have to be applied
to threshold determinations  nor  included  in
release    or   other   waste    management
determinations. If  a non-PBT  EPCRA  Section
313 chemical in  a  mixture or other trade  name
product is below  the  appropriate  de minimis
level, all releases and other waste management
activities  associated with the EPCRA  Section
313 chemical in that mixture or other trade  name
product are  exempt from EPCRA  Section 313
reporting.  It is  possible to meet an activity (e.g.,
processing)  threshold  for  an EPCRA  Section
313 chemical on a facility wide basis,  but not be
required to  calculate  releases or  other waste
management  quantities  associated   with  a
particular  process because that process involves
only mixtures or  other trade name products
containing the non-PBT EPCRA  Section 313
chemical below the de minimis level.

EPA interprets the de minimis exemption such
that  once  a non-PBT EPCRA  Section  313
chemical  concentration is at  or above the
                               appropriate de minimis level in the mixture or
                               other    trade    name    product   threshold
                               determinations  and  release  and  other  waste
                               management calculations must be made, even if
                               that chemical  later falls  below the de  minimis
                               level in  the same mixture or other trade name
                               product.  Thus,  EPA 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  percent or 0.1
                               percent; PBT chemicals and chemical categories
                               do not have de minimis levels with regard to this
                               exemption. The 0.1 percent 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 CFRpart 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 percent  de  minimis
                               concentration provided that the other criteria for
                               the de minimis exemption are met. De  minimis
                               levels for chemical categories apply to  the total
                               concentration of all chemicals in  the category
                               within a mixture, not the concentration of each
                               individual category member within the mixture.
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
 Example  5:  De Minimis Applications to  Process  and  Otherwise  Use Scenarios for Non-PBT
 Chemicals

 There are many cases in which the de minimis "limit" is crossed or recrossed by non-PBT chemicals
 within a process or otherwise use scenario. The following examples are meant to illustrate these complex
 reporting scenarios.

 Increasing Concentration To or Above  De  Minimis  Levels During Processing for Non-PBT
 Chemicals

 A manufacturing facility receives toluene that contains chlorobenzene at  a concentration below its de
 minimis limit. Through distillation, the chlorobenzene content in process streams is increased over the de
 minimis concentration of 1 percent. From the point at which the chlorobenzene concentration equals  1
 percent 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  percent,
 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 percent.

 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
Concentration  Ranges
Minimis Value
Straddling  the De
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.
There   may   be  instances   in   which  the
concentration of a non-PBT chemical is given as
a range straddling the de minimis limit. Example
6  illustrates  how the  de minimis  exemption
should be applied in such a scenario.

De Minimis Application in the Manufacture
of the Listed Chemical in a Mixture

The de  minimis exemption generally does not
apply to  the  manufacturing  of an  EPCRA
Section  313 chemical. However, the de minimis
exemption  may apply  to mixtures and  other
trade name   products   containing  non-PBT
EPCRA Section 313 chemicals that are imported
into the United States. (See Example 5.)

The exemption also applies to non-PBT EPCRA
Section  313 chemicals that are  manufactured as
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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.
 Example 6: Concentration Ranges Straddling the De Minimis Value

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

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

 The average concentration of manganese that is not exempt (above the de minimis) is:
        (1.25%+1.00%)) (2)
   (8,000,OOOXl.25% - 0.99%)'
                                x
               (l.25%+ 1.00%)'
                                 = 23,400 pounds
         (l.25%-0.25%)
 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.

 D      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 percent to 1.2 percent manganese. The amount of
 mixture subject to reporting (at or above de minimis limit) is:

         [(8,000,000) H (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%)
                              x
             (l.2%+ 1.0%)
         (l.2%-0.2%)
 = 26,400 pounds manganese (which is above the processing threshold for manganese)
                            = 26,400 pounds
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
 Example 7: De Minimis Application in the Manufacture of a Toxic Chemical in a Mixture

 Manufacture as a Product Impurity

 Toluene  2,4  diisocyanate  reacts with  trace  amounts  of water  to  form  trace  quantities  of 2,4-
 diaminotoluene. The resulting product contains 99 percent toluene 2,4-diisocyanate and 0.05 percent 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 percent 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 percent) remaining in the carbon tetrachloride. The
 separated chloroform at 90 percent concentration is sold  as a byproduct. Chloroform is subject to a 0.1
 percent  (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
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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.
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 that is not listed as a PBT chemical
and which  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 .10,000 pounds per toxic
                                 chemical or category over the calendar year.
                             You must submit a report for any EPCRA Section
                             313 chemical that is listed as a PBT chemical and
                             which is  manufactured,  processed  or  otherwise
                             used  at  your  facility  above  the  designated
                             threshold for that chemical.

                             The PBT 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.
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Chemical or chemical
category name
Aldrin
Benzo [g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds category
(manufacturing; and
the processing or
otherwise use of dioxin
and dioxin-like
compounds category if
the dioxin and dioxin-
like compounds are
present as
contaminants in a
chemical and if they
were created during
the manufacturing of
that chemical
Heptachlor
Hexachlorobenzene
Isodrin
Lead (this lower
threshold does not
apply to lead when it is
contained in stainless
steel, brass or bronze
alloy)
Lead compounds
Mercury
Mercury compounds
Methoxychlor
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Polychlorinated
biphenyls (PCBs)
Polycyclic aromatic
compounds category
(PACs)
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
40487-42-1
608-93-5
1336-36-3
N590
Threshold
(pounds,
unless
noted
otherwise)
100
10
10
0. 1 gram
10
10
10
100
100
10
10
100
10
100
10
10
100
Tetrabromobisphenol
A
Toxaphene
Trifluralin
79-94-7
8001-35-2
1582-09-8
100
10
100
                                       B.4.a.   How to Determine if Your
                                                Facility Has Exceeded
                                                Thresholds

                                       To determine whether your facility has exceeded
                                       an  EPCRA  Section  313  reporting threshold,
                                       compare  quantities  of  EPCRA   Section  313
                                       chemicals that you  manufacture,  process, or
                                       otherwise use to the respective thresholds for those
                                       activities. A worksheet is provided in Figure 2A to
                                       assist facilities in determining whether they exceed
                                       any  of the  reporting  thresholds  for non-PBT
                                       chemicals; Figures 2B-D provide worksheets for
                                       PBT chemicals. This worksheet also provides a
                                       format for maintaining reporting facility records.
                                       Use  of this worksheet is not  required and the
                                       completed worksheet(s) should not  accompany
                                       Form R reports submitted to EPA and the state.

                                       Complete  the appropriate worksheet for  each
                                       EPCRA  Section   313  chemical   or chemical
                                       category. (The worksheets can be found at the end
                                       of section B.4.) Base your threshold determination
                                       for EPCRA Section 313 chemicals  with qualifiers
                                       only on the  quantity  of the EPCRA Section 313
                                       chemical satisfying the qualifier.

                                       Use of the worksheets is divided into three steps:

                                       •  Step 1 allows you to record the gross amount
                                          of  the   EPCRA  Section  313  chemical or
                                          chemical category  involved   in activities
                                          throughout the facility. Pure forms as well as
                                          the  amounts  of the  EPCRA  Section  313
                                          chemical or chemical  category  present in
                                          mixtures or other trade name products must be
                                          considered.  The  types  of  activity   (i.e.,
                                          manufacturing,  processing,   or   otherwise
                                          using) for which the EPCRA Section 313
                                          chemical is used must be identified because
                                          separate  thresholds apply to  each of these
                                          activities.  A   record  of  the  information
                                          source(s) used   should  be  kept.  Possible
                                          information sources include purchase records,
                                          inventory data, and calculations by a process
                                          engineer. The data collected in Step 1 will be
                                          totaled for each activity to identify the overall
          Toxics Release Inventory Reporting Forms and Instructions
23

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    amount of the EPCRA  Section 313 chemical
    or chemical category manufactured (including
    imported), processed, or otherwise used.

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

•   Step 3 involves subtracting the result of Step 2
    from the  results of Step 1  for each activity.
    Compare  this  net  sum  to the  applicable
    activity threshold. If the threshold is exceeded
    for any of the three activities, a facility must
    submit a Form R for that EPCRA  Section 313
    chemical  or chemical category. Do not sum
    quantities of the EPCRA Section 313 chemical
    that   are   manufactured,   processed,  and
    otherwise used at your  facility, because each
    of these activities requires a separate threshold
    determination. For example, if in a calendar
    year you processed 20,000 pounds  of a non-
    PBT  EPCRA  Section 313  chemical and you
    otherwise used  6,000 pounds  of that  same
    chemical, your facility has not exceeded any
    applicable threshold and thus is not required to
    report for that chemical.

Worksheets should be retained to document your
determination for reporting  or not  reporting, but
should not be submitted with the report.

You must submit a report if you  exceed any
threshold for any EPCRA Section 313  chemical or
chemical category. For example, if your facility
processes  22,000  pounds of a non-PBT EPCRA
Section  313  chemical  and also otherwise uses
16,000 pounds of that same  chemical, it has
exceeded  the  otherwise  use  threshold (10,000
pounds for a non-PBT chemical) and your facility
                              must report even though it did not exceed  the
                              process threshold (25,000 pounds for a non-PBT
                              chemical). In  preparing  your  reports, you must
                              consider  all  non  exempted  activities  and  all
                              releases and other waste management quantities of
                              the  EPCRA  Section  313 chemical from your
                              facility,   not  just   releases   and   other  waste
                              management quantities from  the  otherwise  use
                              activity.

                              Also note that threshold determinations are based
                              upon the  actual amounts of an EPCRA Section
                              313  chemical   manufactured,  processed,  or
                              otherwise used over the  course of the  calendar
                              year. The threshold  determination may not relate
                              to the amount  of an EPCRA Section 313  chemical
                              brought  on-site  during  the calendar year.   For
                              example,  if a stockpile of 100,000 pounds of a
                              non-PBT  EPCRA Section 313  chemical is present
                              on-site but only 20,000 pounds of that chemical is
                              applied to  a  process, only the 20,000 pounds
                              processed   is  counted   toward   a   threshold
                              determination, not the entire   100,000 pounds of
                              the stockpile.

                              B.4.b.   Threshold Determinations  for
                                       On-Site Reuse Operations

                              Threshold determinations  of EPCRA Section  313
                              chemicals that are reused  at the facility are based
                              only on the amount of the EPCRA Section  313
                              chemical  that  is  added during the  year, not  the
                              total volume in the system. For example,  a facility
                              operates  a refrigeration unit that contains  15,000
                              pounds of anhydrous ammonia at the beginning of
                              the year. The system is charged with 2,000 pounds
                              of anhydrous  ammonia   during the  year.  The
                              facility has therefore "otherwise used" only 2,000
                              pounds  of anhydrous  ammonia,  a  non-PBT
                              EPCRA Section 313 chemical,  which is below the
                              otherwise use threshold  for anhydrous ammonia
                              and is not required to report (unless  there  are other
                              "otherwise use" activities of ammonia, that when
                              taken together, exceed the reporting threshold). If,
                              however,   the whole  refrigeration  unit  was
                              recharged  with  15,000   pounds  of  anhydrous
                              ammonia  during the year, then the  facility would
                              have exceeded the otherwise  use threshold,  and
                              would be required to report.

                              This does  not  apply to  EPCRA  Section   313
                              chemicals  "recycled"  or "reused" off-site   and
                              returned to  a  facility. Such EPCRA Section  313
                              chemicals returned to a facility are treated as  the
                              equivalent  of newly purchased   material   for
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
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 percent of total  aqueous
ammonia is reportable under this  listing." The
qualifier for ammonia means that anhydrous forms
of ammonia are  100  percent  reportable and
aqueous forms are limited to  10  percent of total
aqueous ammonia. Therefore, when determining
threshold quantities, 100  percent of  anhydrous
ammonia is included but only 10 percent of total
aqueous ammonia is included. If any ammonia
evaporates from aqueous ammonia solutions, 100
percent of the evaporated ammonia is included in
threshold determinations.

For  example,  if a  facility processes  aqueous
ammonia,  it has  processed  100  percent of the
aqueous ammonia in that solution. If the ammonia
remains in  solution, then 10 percent of the total
aqueous  ammonia  is  counted  towards  the
threshold.  If there are any evaporative losses  of
anhydrous ammonia, then 100 percent 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 percent
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
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listed metal. For example, lead chromate is both a
lead compound and  a chromium compound.  In
such cases, if applicable thresholds are exceeded,
you are required to file two separate reports, one
for lead  compounds  and one   for  chromium
compounds. Apply the total weight of the lead
chromate to the threshold determinations for both
lead  compounds  and  chromium  compounds.
(Note:  Only the  amount  of each parent  metal
released or otherwise managed as waste, not the
amount of the compound, would be reported  on
the appropriate sections of both  Form Rs. See
B.5.)

Nitrate    Compounds   (water   dissociable;
reportable only when in aqueous solution)

For  the  category  nitrate  compounds  (water
dissociable; reportable  only when  in aqueous
solution),   the  entire   weight  of  the   nitrate
compound   is   counted  in making  threshold
determinations. A nitrate compound is covered  by
this  listing only when  in water and  only  if
dissociated. If no information is available on the
identity of the type of nitrate that is manufactured,
processed  or otherwise used,  assume that the
nitrate compound exists as sodium nitrate.

B.4.e    Threshold Determination for
         Persistent Bioaccumulative
         Toxic (PBT) Chemicals

There  are  two  separate thresholds  for EPCRA
Section 313 PBT chemicals; these thresholds are
set based on the chemicals' potential to persist and
bioaccumulate    in    the   environment.   The
manufacturing,  processing and   otherwise use
thresholds for PBT chemicals is  100 pounds, while
for the subset of PBTs chemicals  that  are highly
persistent  and  highly bioaccumulative, it  is  10
pounds. One exception is the dioxin and dioxin-
like compounds chemical category. The threshold
for this category is 0.1 gram. The PBT  chemicals,
their CAS numbers or chemical category code, and
their reporting thresholds are listed in a table in the
introductory section of B.4. See Table He of these
instructions for lists of individual members  of the
dioxin   and  dioxin-like  compounds  chemical
category and the polycyclic aromatic compounds
(PACs) chemical category.

B.4.f.   Mixtures and Other Trade
         Name Products

EPCRA  Section  313   chemicals contained  in
mixtures and other trade name  products must  be
                             factored into threshold determinations and release
                             and other waste management calculations.

                             If your  facility  processed or  otherwise  used
                             mixtures or other trade name products during the
                             calendar year, you  are required to  use  the best
                             readily available data (or reasonable estimates  if
                             such data are not readily available)  to determine
                             whether the toxic chemicals in a mixture meet or
                             exceed  the  de   minimis  concentration  and,
                             therefore,   whether  they must  be  included  in
                             threshold  determinations and  release and other
                             waste management calculations. If you know that
                             a mixture or other trade name  product contains a
                             specific EPCRA Section 313 chemical,  combine
                             the amount of the EPCRA Section 313 chemical in
                             the mixture or other trade name 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 Section372.30(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
26
Toxics Release Inventory Reporting Forms and Instructions

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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
    you calculate a midpoint assuming an upper
    bound concentration of 100 percent.
•   In cases where you only have a concentration
    range available, EPA recommends you use the
    midpoint of the range extremes.

B.5   Release and Other  Waste
       Management Determinations
       for Metals, Metal Category
       Compounds, and Nitrate
       Compounds
Metal Category Compounds

Although  the  complete  weight  of  the  metal
category  compounds  must  be used in threshold
determinations  for the metal compounds category,
only the weight of the metal portion of the metal
category compound must be considered for release
and  other  waste  management determinations.
Remember that for metal category compounds that
consist of more than one metal,  release and other
waste management reporting must be based on the
weight of each metal, provided that the appropriate
thresholds have been exceeded.
Metals and Metal Category Compounds

For  compounds  within  the  metal  compound
categories, only the metal portion of the  metal
category  compound  must be   considered  in
determining release and other waste management
quantities  for  the metal  category compounds.
Therefore, if thresholds are separately  exceeded
for both the "parent" metal and its compounds,
EPA allows you to file a combined Form R for the
"parent" metal and its category compounds. This
Form R would contain all of the release  and other
waste  management information  for  both  the
"parent" metal and metal portion of the  related
metal category compounds.  For example, you
exceed thresholds for chromium. You also exceed
thresholds for  chromium compounds. Instead of
filing two Form Rs you can file one combined
Form R. This Form R would  contain information
on quantities of chromium  released  or otherwise
managed  as  waste  and the  quantities  of the
chromium portion of the  chromium compounds
released or otherwise managed as waste.  When
filing one  combined Form  R for an EPCRA
Section 313 metal  and metal compound category,
facilities should identify the chemical reported as
the metal compound category name and code in
Section 1 of the 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
                                         27

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 Example 9: Mixtures and Other Trade Name Products
 Scenario #1: Your facility  otherwise uses  12,000  pounds of an industrial solvent (Solvent X)  for
 equipment cleaning. The Material Safety Data Sheet (MSDS) for the solvent indicates that it contains at
 least 50 percent n-hexane, an EPCRA Section 313  chemical; however, it also states that the solvent
 contains 20 percent 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 percent 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 percent and  the lower bound limit is known to be 80
      percent. Using this information, the specific  concentration is  estimated to be 90 percent (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 percent (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.	
28                 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
l.
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




ro 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




re,) ib
                                                                                                         Ib (B-B1)
                          Ib
Amount subject to threshold:                                                                    0
Compare to threshold for EPCRA Section 313 reporting.                               25,000 Ibs 25,000 Ibs     10,000 Ibs
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R or Form A; retain it for your records.

                              Figure 2A. EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet1
Ib
1    Note: Chemicals listed as PBT have separate thresholds (dioxin and dioxin-like compounds chemical category = 0.1 g; highly persistent, highly bioaccumulative toxic
    chemicals = 10 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
                                                   29

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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
                                                                                                    Ib
                                               Ib
Amount subject to threshold:                                                                0
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 PET Chemicals with 100 Pound Thresholds
Ib
 1 Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
                                                30
Toxics Release Inventory Reporting Forms and Instructions

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                                 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
Amount subject to threshold:
Compare to threshold for EPCRA Section 313 reporting.
          (A-A1)	
10 Ibs 10 Ibs    10 Ibs
Ib
Ib
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 2C. EPCRA Section 313 Reporting Threshold Worksheet for PET Chemicals with 10 Pound Threshold
 1 Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
                                                                   Toxics Release Inventory Reporting Forms and Instructions
                                                           31

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Facility Name:
EPCRA Section 313 Chemical or Chemical Category: Dioxin and Dioxin-Like Compounds
CAS Registry Number: 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 (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 (g.):
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 (g):
Manufactured




(A,) Ib
Processed




(B,) Ib
Otherwise Used




(C,) Ib
                                                                                                   Ib
                                              Ib
Ib
Amount subject to threshold:                                                                0
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.
          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.
                                                32
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
 The reporting year is the calendar year to which
 the reported information applies,  not the year in
 which you are submitting the  report. Information
 for the  2008 reporting year must be submitted on
 or before July 1,2009.

 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 Section A.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
        Facility Identification Number
TRI
 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 visit the TRI
                    Toxics Release Inventory Reporting Forms and Instructions
                                           33

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web                  page                   at
http://www.epa.gov/tri/contacts/contacts.htm   for
more information  or contact 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 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    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 Section372.30(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.)

                              4.3     Technical Contact
                              Enter the name and telephone number  (including
                              area  code)  of a technical representative whom
                              EPA  or state officials may contact for clarification
                              of  the information reported on Form R.  You
                              should also  enter an email address for this person.
                              EPA   encourages  facilities to provide an  email
                              address  for  its  Technical Contact on  their  TRI
                              submissions because they  will be able  to receive
                              important  program  updates  and  email  alerts
                              notifying them when their FDP has been updated
                              and  is available on  the FDP website.  If the
                              technical contact does not have an email address
                              you should enter NA. This contact person does not
34
Toxics Release Inventory Reporting Forms and Instructions

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                               Instructions for Completing TRI Form R
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) Codes
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  (71 FR  32464).
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). For  Reporting Year 2008, use 2007
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
2007 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    Dun & Bradstreet Number(s)
Enter the nine digit number assigned by Dun &
Bradstreet  (D &  B)  for  your  facility  or each
establishment within your facility. These  numbers
code  the  facility  for  financial purposes.  This
number may be  available  from your facility's
treasurer or financial officer. You can also obtain
the numbers  from  your local Dun & Bradstreet
office (check the telephone book White Pages). If
a facility does not subscribe to the D & B service,
a number can be obtained, toll  free at 800 234-
                                         3867 (8:00 AM to 6:00 PM, Local Time) or on the
                                         Web at  .  If  none  of your
                                         establishments  has been assigned a  D &  B
                                         number, you should enter NA in box (a). If only
                                         some of your establishments have been assigned D
                                         & B numbers,  enter those numbers  in  Part  I,
                                         section 4.6.
                                                 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 percent  of the  voting  stock of your
                                         company. If your  facility  is owned by a foreign
                                         entity, enter NA in this space. Corporate  names
                                         should be treated  as parent company names  for
                                         companies  with   multiple  facility  sites.  For
                                         example, the Bestchem Corporation is not  owned
                                         or controlled by any other corporation but has sites
                                         throughout the country whose names  begin with
                                         Bestchem.  In  this case,  Bestchem  Corporation
                                         should be listed as the parent company. Note that a
                                         facility that is a  50:50 joint venture  is its own
                                         parent company.  When a facility is  owned  by
                                         more  than one company and none of the facility
                                         owners directly owns  at least 50 percent of its
                                         voting stock, the facility should provide the name
                                         of  the parent  company  of either  the  facility
                                         operator or the owner with the largest ownership
                                         interest in the  facility.  If neither the operator nor
                                         this owner has a parent  company, then the NA box
                                         should be checked.

                                         5.1    Name of Parent Company
                                         Enter  the  name   of  the corporation or  other
                                         business  entity that is  your ultimate U.S.  parent
                                         company. If your facility has no parent company,
                                         you should check the NA box.

                                         5.2    Parent Company's Dun &  Bradstreet
                                                Number
                                         Enter the  D & B number for your ultimate U.S.
                                         parent company, if applicable. The number may be
                                         obtained from the treasurer or financial officer of
                                         the company.  If your  parent company does not
                                         have a D & B number, you should check the NA
                                         box.
                   Toxics Release Inventory Reporting Forms and Instructions
                                                                                    35

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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
N150   Dioxin and dioxin-like compounds
N171   Ethylenebisdithiocarbamic acid, salts and
        esters (EBDCs)
N230   Certain glycol ethers
N420   Lead compounds	
                            N450   Manganese compounds
                            N458   Mercury compounds
                            N495   Nickel compounds
                            N503   Nicotine and salts
                            N511   Nitrate  compounds  (water  dissociable,
                                    reportable only in aqueous solution)
                            N575   Polybrominated biphenyls (PBBs)
                            N583   Polychlorinated 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.
36
Toxics Release Inventory Reporting Forms and Instructions

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                        Instructions for Completing Part II of EPA Form R
EPA  requests  that  the  EPCRA  Section  313
chemical, chemical category, or generic name also
be placed in the  box marked "Toxic Chemical,
Category,  or Generic Name"  in the upper right-
hand corner on all pages of Form  R. While  this
space is not a required data element, providing this
information will help you in preparing a complete
Form R report.

1.3     Generic Chemical Name
Complete Section 1.3 only if you are claiming the
specific EPCRA  Section 313 chemical identity of
the EPCRA Section 313 chemical as a trade secret
and have marked the trade secret block in Part I,
Section 2.1 on Page 1 of Form R. Enter a generic
chemical name that is descriptive of the chemical
structure. You should limit the generic name to
seventy characters  (e.g., numbers,  letters, spaces,
punctuation) or less. Do not enter  mixture names
in Section 1.3; see Section 2 below.

In-house plant codes and other substitute names
that are not structurally descriptive of the EPCRA
Section 313  chemical identity  being withheld as a
trade secret are not acceptable as a generic  name.
The generic name  must appear on  both sanitized
and unsanitized Form Rs, and the name must be
the same as that used on your substantiation forms.
Section 2.     Mixture Component Identity
Do  not  complete  this  section  if you  have
completed Section 1 of Part II. Report the generic
name provided to you by  your supplier in this
section if your supplier is claiming the chemical
identity proprietary or trade secret. Do not answer
"yes" in Part I, Section 2.1 on Page 1 of the form
if you complete this section. You  do not need to
supply trade secret  substantiation  forms for this
EPCRA Section 313 chemical because it is your
supplier who is claiming the chemical identity a
trade secret.
 Example    10:   Mixture    Containing
 Unidentified   EPCRA   Section    313
 Chemical

 Your facility  uses  20,000 pounds of  a
 solvent  that  your supplier has  told  you
 contains 80 percent "chlorinated aromatic,"
 their generic name for a non-PBT EPCRA
 Section  313 chemical  subject to reporting
 under EPCRA Section  313. You, therefore,
 have used  16,000 pounds of some EPCRA
 Section  313 chemical and that  exceeds the
 "otherwise  use" threshold for  a non-PBT
 chemical. You would file a Form R and enter
 the name "chlorinated aromatic" in the space
 provided in Part II, Section 2.
2.1    Generic  Chemical Name  Provided by
       Supplier
Enter the generic chemical name in this  section
only if the following three conditions apply:

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

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

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

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
                   Toxics Release Inventory Reporting Forms and Instructions
                                           37

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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, Section372.3 of
the Code  of Federal Regulations  for additional
explanations.

3.1     Manufacture the EPCRA Section  313
        Chemical
Persons who  manufacture (including import) the
EPCRA Section 313  chemical must check at least
one of the following:

a.    Produce  —  The  EPCRA   Section  313
     chemical is produced at the facility.
b.    Import   —  The   EPCRA  Section   313
     chemical is  imported by the facility into the
     Customs Territory  of the United States. (See
     Section  B.3.a  of these  instructions  for
     further clarification of import.)

And check at least one of the following:

c.    For on-site use/processing — The EPCRA
     Section  313   chemical   is  produced  or
     imported and  then further  processed or
     otherwise used at  the same facility. If you
     check this block, generally you should  also
     check at least one item in Part II, Section 3.2
     or 3.3.
d.    For  sale/distribution   —   The  EPCRA
     Section  313   chemical   is  produced  or
     imported specifically for sale  or distribution
     outside the manufacturing facility.
e.    As a byproduct — The EPCRA Section 313
     chemical is produced coincidentally during
     the manufacture,  processing,  or otherwise
     use  of  another  chemical  substance  or
     mixture  and,  following  its production,  is
     separated   from   that   other   chemical
     substance or mixture. EPCRA Section  313
     chemicals produced as  a result of waste
     management are also considered byproducts.
f    As an impurity — The EPCRA Section 313
     chemical is produced  coincidentally  as  a
     result of the  manufacture, processing, or
     otherwise use of another chemical but is not
     separated and  remains  in the mixture or
     other trade  name  product with  that other
     chemical.
                              In  summary,  if you are  a manufacturer of the
                              EPCRA Section 313 chemical, you must check (a)
                              and/or (b), and at least one of (c), (d), (e), and (f)
                              in Section 3.1.

                              3.2     Process  the   EPCRA  Section   313
                                     Chemical
                              Persons  who  process  the EPCRA  Section  313
                              chemical must check at least one of the following:

                              a.   As  a reactant —  A natural  or  synthetic
                                  EPCRA  Section  313 chemical  is  used in
                                  chemical reactions  for  the  manufacture of
                                  another chemical  substance or of a product.
                                  Includes but is not limited to, feedstocks, raw
                                  materials, intermediates,  and initiators.
                              b.   As a formulation  component — An EPCRA
                                  Section 313 chemical is  added  to a product
                                  (or  product  mixture)   prior   to   further
                                  distribution  of the  product that  acts  as  a
                                  performance  enhancer  during  use  of the
                                  product.  Examples of EPCRA  Section  313
                                  chemicals used in this capacity include, but
                                  are not limited to, additives, dyes, reaction
                                  diluents,   initiators,   solvents,   inhibitors,
                                  emulsifiers,  surfactants,  lubricants,  flame
                                  retardants, and rheological modifiers.
                              c.
                              d.
                              e.
    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.
    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.
    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:
38
Toxics Release Inventory Reporting Forms and Instructions

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                            Instructions for Completing Part II of EPA Form R
  a.   As a chemical processing aid — An EPCRA
       Section 313  chemical  that  is added to  a
       reaction mixture to aid in the manufacture or
       synthesis of another chemical  substance but
       is not intended to remain in or become part of
       the  product or product  mixture is otherwise
       used as chemical processing aid. Examples of
       such EPCRA Section 313 chemicals include,
       but  are  not  limited to,  process solvents,
       catalysts,    inhibitors,    initiators,   reaction
       terminators, and solution buffers.
  b.   As  a  manufacturing aid —  An EPCRA
       Section   313   chemical  that   aids   the
       manufacturing process but does not become
       part of the  resulting product and is not added
       to    the    reaction   mixture   during   the
                                                            manufacture or synthesis of another chemical
                                                            substance    is   otherwise   used    as   a
                                                            manufacturing aid. Examples include, but are
                                                            not    limited    to,    process    lubricants,
                                                            metalworking  fluids, coolants,  refrigerants,
                                                            and hydraulic fluids.
                                                       c.    Ancillary  or  other  use  —  An   EPCRA
                                                            Section 313 chemical that is used at a facility
                                                            for purposes  other than  aiding   chemical
                                                            processing  or manufacturing  as  described
                                                            above  is  otherwise used as an ancillary or
                                                            other use.  Examples  include,  but  are not
                                                            limited to,  cleaners,  degreasers, lubricants,
                                                            fuels, EPCRA Section 313  chemicals  used
                                                            for treating wastes, and EPCRA Section 313
                                                            chemicals used to treat water at the facility.
    SECTION 1.  TOXIC CHEMICAL IDENTITY
                                               (Important: DO NOT complete this section if you completed Section 2 below.)
    1.1
         CAS Number (important: Enter only one number exactly as it appears on the Section 313 list Enter category code if reporting a chemical category.)
          334-88-3
    1,2
         Toxic Chemical or Chemical Category Name (Important. Enter only one name exactly as it appears on the Section 313 Its!}
          Diazomethane
    1.3
         Generic Chemical Name (Important: Complete only il Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive )
    1.4  Distribution of Each Member of the Dioxin and Dioxin-like Compounds Category.
         (If there are any numbers in boxes 1-17. then every field must be filled in with either 0 or some number between 0.01 and 100. Distribution should
         be reported in percentages and the total should equal 0 or 100%. If you do not have speciation data available, check NA.)
            1     2     3     4     5     6      7      8     9    10    11     12     13    14    15    16    17
    NA
    SECTION 2.  MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
    2.1
         Generic Chemical Name ProvkJed by Supplier (Important Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
    SECTION 3,  ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
               (Important: Check all that apply.)
    3.1   Manufacture the toxic chemical:
                                        3.2  Process the toxic chemical:
                3.3  Otherwise use the toxic chemical:
       a,  X   Produce   b.
                             Import
              If produce or import:
              For on-site use/processing
              For sale/distribution

              As a byproduct
              As an impurity
                                                As a reactant
                                                As a formulation component
                                               As an article component
                                               Repackaging

                                               As an impurity
                       As a chemical processing aid
                 b, I   I As a manufacturing aid
                 c. |   | Ancillary or other use
                         Figure 3. Reporting EPCRA Section 313 Chemicals
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.
                      Toxics Release Inventory Reporting Forms and Instructions
                                                                                                      39

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

                            Do not include the weight of the entire mixture or
                            other trade name product. These data may be found
                            in the Tier II form your facility may have prepared
                            under  Section312  of  EPCRA.   See Part  40,
                            Section372.30(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.
  40
Toxics Release Inventory Reporting Forms and Instructions

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                          Instructions for Completing Part II of EPA Form R
For  all toxic chemicals  (except  the dioxin and
dioxin-like compound  category), do not enter the
values in  Section 5 in gallons, tons,  liters,  or any
measure other than pounds. You must also enter the
values as whole numbers (do  not use scientific
notation).  Numbers following a decimal point are
not acceptable for toxic chemicals other than those
designated as PBT chemicals. For PBT chemicals,
facilities   should  report  release and other  waste
management  quantities  greater  than 0.1  pound
(except the  dioxin  and  dioxin-like  compounds
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 5.5.1.B of Form R.

All releases of the  EPCRA Section 313 chemical to
the air must be classified as either stack or fugitive
emissions,   and included  in  the  total  quantity
reported  for these releases in Sections  5.1  and 5.2.
Instructions for columns A,  B, and C follow the
discussions of Sections 5.1 through 5.5.
                                                   5.1
         Fugitive or Non-Point Air Emissions
Report  the  total of  all releases  of the EPCRA
Section 313 chemical to the air that are not released
through stacks,  vents, ducts,  pipes, or  any other
confined air stream. You must include (1) fugitive
equipment leaks from valves,  pump seals, flanges,
compressors,  sampling  connections,  open-ended
lines,  etc.;  (2)  evaporative  losses  from surface
impoundments and spills; (3) releases from building
ventilation systems; and (4) any other fugitive or
non-point air emissions. Engineering estimates  and
mass balance calculations (using purchase records,
inventories,  engineering  knowledge  or  process
specifications of the quantity of the EPCRA Section
313  chemical entering product, hazardous waste
manifests, or monitoring records) may be useful in
estimating fugitive emissions. You  should check the
NA  box in Section  5.1  if you do not engage in
activities  that result  in  fugitive or non-point air
emissions of this listed toxic chemical. For VOCs,
NA generally would not be applicable.
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5.2
Stack or Point Air Emissions
Report  the  total of all releases  of the EPCRA
Section 313 chemical to the air that occur through
stacks,  confined  vents,  ducts,  pipes,  or  other
confined air streams. You must include storage tank
emissions.  Air releases from air pollution control
equipment  would  generally fall  in  this category.
Monitoring  data, engineering estimates,  and mass
balance calculations may help you to complete this
section. You should check the NA box in Section
5.2 if there are no stack air activities involving  the
waste stream that contains or contained the EPCRA
Section 313 chemical.

5.3     Discharges to Receiving Streams or
        Water Bodies

In Section 5.3 you are to enter all the names of the
streams  or  water bodies  to which  your facility
directly  discharges   the   EPCRA  Section  313
chemical on which you are reporting.  A total  of
three spaces is provided on Page 2 of Form R. Enter
the name of each receiving stream or surface water
body  to which the EPCRA Section 313 chemical
being reported is  directly discharged. Report  the
name of the receiving stream  or water  body as it
appears on the permit for the facility. If the stream is
not included in the NPDES permit or its name is  not
identified in the NPDES permit, enter the name of
the off-site  stream or  water body by which it is
publicly known or enter the first publicly  named
water body to which  the  receiving waters  are a
tributary, if the receiving  waters are unnamed.  Do
not list a  series  of  streams  through  which  the
EPCRA Section 313  chemical flows. Be  sure  to
include all the receiving streams or water bodies that
receive  stormwater runoff from your facility. Do  not
enter names of streams to which off-site treatment
plants discharge. You  should enter NA in Section
5.3.1 if there are no discharges to receiving streams
or water bodies of the waste stream that contains or
contained the EPCRA Section  313 chemical (See
discussion of NA vs. a Numeric Value (e.g., Zero)
in the introduction of Section 5).

Enter the total annual amount of the EPCRA Section
313 chemical released  from all discharge points at
the facility  to each receiving stream or water body.
Include process outfalls such as  pipes  and open
trenches, releases from on-site wastewater treatment
systems, and the  contribution  from stormwater
runoff, if applicable (see instructions for column C
below). Do not include discharges to a  POTW or
other off-site wastewater treatment facilities in this
section. These off-site transfers must be reported in
Part II, Section 6 of Form R. Wastewater analyses
and flowmeter data may provide the quantities you
will need to complete this section.

Discharges of listed acids (e.g.,  hydrogen fluoride,
nitric acid) may be reported as zero if the discharges
have  been  neutralized  to  pH  6 or  above.  If
wastewater containing a listed acid is discharged
below pH 6,  then releases of  the acid  must be
reported.  In this  case, pH measurements may be
used  to  estimate  the  amount  of mineral  acid
released.

5.4.1    Underground Injection On-Site to Class I
        Wells
Enter the  total amount of the EPCRA Section 313
chemical that was injected into Class I wells at the
facility. Chemical analyses, injection rate meters,
and RCRA Hazardous Waste Generator Reports are
good sources for obtaining data that will be useful in
completing this section. You should check the NA
box in Section 5.4.1 if you do not inject the waste
stream  that  contains  or contained  the  EPCRA
Section 313  chemical into Class  I  underground
wells (See discussion of NA vs.  a Numeric Value
(e.g., Zero) in the  introduction of Section 5).

5.4.2    Underground Injection On-site to Class II-
        V Wells
Enter the  total amount of the EPCRA Section 313
chemical that was injected into wells at the facility
other than Class  I wells. Chemical analyses and
injection rate meters are good sources  for obtaining
data that will be  useful in completing this section.
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. a Numeric Value (e.g., Zero)  in the introduction
of Section 5).

5.5     Disposal to Land On-site
Five   predefined  subcategories   for   reporting
quantities released to land within the boundaries of
the facility are provided. Do not report land disposal
at  off-site  locations  in this  section.   Accident
histories and  spill records  may be  useful (e.g.,
release    notification   reports   required   under
Section3 04 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
   42
               Toxics Release Inventory Reporting Forms and Instructions

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                          Instructions for Completing Part II of EPA Form R
disposal activities for the waste stream that contains
or contained the EPCRA Section 313 chemical (See
discussion of NA vs. a Numeric Value  (e.g., Zero)
in the introduction of Section 5). For 5.5.4, facilities
generally  should  report  zero,  recognizing  the
potential for spills or leaks.

5.5.1A RCRA Subtitle C landfills
Enter the total amount of the EPCRA Section 313
chemical that was  placed in  RCRA  Subtitle C
landfills. EPA has not required facilities to estimate
leaks from  landfills because  the  amount of the
EPCRA Section  313 chemical has  already  been
reported as a release.

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 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 5.5.3A or 5.5.3B.
Quantities  of the  EPCRA Section 313  chemical
released  to  surface  impoundments that  are  used
merely as part of a wastewater treatment process
generally  should  not be reported  in  this section.
However, if an impoundment accumulates sludges
containing the EPCRA Section 313 chemical, you
must include an estimate in this section unless the
sludges  are removed and  otherwise  disposed (in
which  case  they  must be  reported under the
appropriate section of the form). For the purposes of
this reporting, storage tanks are not considered to be
a type of disposal and are not to be reported in this
section of Form R.

5.5.3A RCRA Subtitle C Surface Impoundments
Enter the total amount of the EPCRA Section 313
chemical that was placed in  RCRA Subtitle C
surface impoundments.

5.5.3B Oth er Surface Impoun dments
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   Oth er 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  percent 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
                      Toxics Release Inventory Reporting Forms and Instructions
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releases, such as chemical spills, must be included
in your estimate of the quantity released.

Releases of  Less  Than 1,000 Pounds. For total
annual releases or off-site transfers of an EPCRA
Section 313 chemical from the facility of less than
1,000 pounds, the amount may be reported either as
an estimate or by using the range  codes that have
been developed (range reporting in section 5 does
not apply to  PBT chemicals). The reporting range
codes to be used are:
        Code
        A
        B
        C
       Range (pounds)
       1-10
       11-499
       500-999
Do not enter a range code and an estimate in the
same box in column A. Total annual on-site releases
of an EPCRA Section 313 chemical from the facility
of less than 1  pound  may be  reported in one of
several ways.  You should  round the value  to the
nearest pound.  If the estimate  is greater than 0.5
pound, you  should either enter the range code "A"
for "1-10" or enter "1" in column A. If the release is
equal to or less than 0.5 pound, you may round to
zero and enter "0" in column A.

Note that total annual releases of 0.5 pound or less
from the processing or otherwise use of an article
maintain the article status of that item. Thus,  if the
only releases  you  have are from processing  an
article, and  such  releases are equal to  or less than
0.5 pound per year, you are not required to submit a
report  for that EPCRA Section 313 chemical. The
0.5-pound release determination does not apply to
just  a  single article. It applies to the  cumulative
releases from the  processing or otherwise use of the
same type of article (e.g., sheet metal or plastic film)
that occurs over the course of the reporting year.

Releases of 1,000 Pounds or More. For releases to
any medium that amount to 1,000 pounds or more
for the year, you must provide an estimate in pounds
per year in column A. Any  estimate  provided in
column A need not be reported to more than two
significant figures. This estimate should be in whole
numbers. Do not use decimal points.

Calculating  On-Site  Releases.  To  provide the
release information in  column A, EPCRA  Section
313(g)(2) requires a facility to use readily available
data (including monitoring data) collected pursuant
to other provisions of law,  or, where such data are
not readily available, "reasonable estimates" of the
amounts involved.  If  available  data (including
monitoring data) are known to be nonrepresentative,
facilities must make reasonable estimates using the
best readily available information.

Reasonable  estimates  of  the  amounts  released
should be made using published emission factors,
material   balance   calculations,  or   engineering
calculations. You may not  use emission factors or
calculations to estimate releases  if more  accurate
data are available.

No additional monitoring or  measurement of the
quantities  or concentrations of any EPCRA Section
313 chemical  released into the environment, or of
the frequency of such releases, beyond that required
under other provisions of law or regulation or as
part of routine plant operations, is required for the
purpose of completing Form R.

You must estimate the quantity (in  pounds) of the
EPCRA Section 313 chemical  or chemical category
that is  released annually  to  each  environmental
medium on-site. Include only the quantity of the
EPCRA Section 313 chemical in this estimate. If the
EPCRA  Section 313  chemical  present  at  your
facility was part of a mixture or other trade name
product, calculate only the  releases  of the EPCRA
Section  313 chemical, not the  other  components of
the mixture or other trade name product. If you are
only able to estimate the releases of the mixture or
other trade name product as a whole, you should
assume that the release of the  EPCRA Section 313
chemical is proportional to its concentration in the
mixture or other trade name product.  See Part 40,
Section372.30(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
   44
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                          Instructions for Completing Part II of EPA Form R
Part II, Section 5.1.

For aqueous ammonia solutions, releases must be
reported  based on  10  percent  of total aqueous
ammonia.  Ammonia  evaporating  from aqueous
ammonia solutions is considered to be  anhydrous
ammonia; therefore,  100 percent 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:

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  stream before treatment
     was fully identified through monitoring data.

For example, if 40 percent of stack emissions of the
reported EPCRA Section 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 Section  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
Section  313 chemical  in the  waste is based on
solubility  data,  you should  report  "O" because
engineering  calculations were used as the basis of
estimate of the quantity of the EPCRA Section 313
chemical in the waste.

If the  concentration of the  EPCRA  Section  313
chemical in  the waste was measured by 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 Section 313  chemical released. Monitoring
data should be indicated as the basis  of estimate
only  if  the   EPCRA  Section   313   chemical
concentration is measured in the waste. Monitoring
data should not be  indicated,  for example,  if the
monitoring  data relate  to a concentration  of the
EPCRA  Section  313 chemical in  other process
streams within the facility.

It is important to realize that the  accuracy  and
proficiency of release estimation will improve over
time. However, submitters are not  required to use
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new emission factors or estimation techniques to
revise previous Form R submissions.

Section 5 Column C: Percent from Storm water

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)
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                          Instructions for Completing Part II of EPA Form R
Description of Land Area    Runoff Coefficient

Business
   Downtown areas           0.70-0.95
   Neighborhood areas        0.50-0.70
Industrial
   Light areas                0.50-0.80
   Heavy areas               0.60-0.90
Industrial
   Railroad yard areas         0.20-0.40
   Unimproved areas          0.10-0.30
Streets
   Asphaltic                  0.70-0.95
   Concrete                  0.80-0.95
   Brick                     0.70-0.85
   Drives and walks           0.70-0.85
   Roofs                     0.75-0.95
Lawns: Sandy Soil
   Flat, 2 percent             0.05-0.10
   Average, 2-7 percent      0.10-0.15
   Steep, 7 percent            0.15-0.20
Lawns: Heavy Soil
   Flat, 2 percent             0.13-0.17
   Average, 2-7 percent      0.18-0.22
   Steep, 7 percent            0.25-0.35

You should  choose the most appropriate  runoff
coefficient for your site or calculate a weighted-
average  coefficient,  which  takes  into  account
different types of land use at your facility:

Weighted-average runoff coefficient =

  (Area 1  % of total)(Cl) + (Area 2 % of total)(C2)
  + (Area 3  % of total)(C3)  + ...  + (Area i %  of
  total)(Ci)
  where

  Ci =   runoff coefficient for a specific  land use
         of Area i.
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  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 percent
  unimproved area, 10 percent asphaltic streets, and 40 percent concrete pavement.

  The total storm water runoff from your facility is therefore calculated as follows:
          Land Use             % Total Area
          Unimproved area          50
          Asphaltic streets           10
          Concrete pavement         40
  Weighted-average runoff coefficient =  [(50%) x (0.20)] + [(10%) x (0.85)] + [(40%) x (0.90)] = 0.545
                                Runoff
                                Coefficient
                                   0.20
                                   0.85
                                   0.90
   (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%
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
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                          Instructions for Completing Part II of EPA Form R
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 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 6.1.B._. or 6.2._.

If you report a transfer of the listed EPCRA Section
313 chemical to  one or more POTWs, you  should
number the   boxes in Section   6.1.B as 6.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 pages numbered "3"
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 pages numbered "3" and then indicate
 the first and second Page 3. The boxes for the two
 POTWs on the first Page 3 should be numbered
 6.I.B.I and 6.1.B.2, while the box for third POTW
 on the second Page 3 should be numbered 6.I.B.3.

 If you report a transfer of the EPCRA  Section 313
 chemical to one or more other off-site locations, you
 should  number the boxes in section 6.2  as 6.2.1,
 6.2.2, etc.  If you transfer the EPCRA  Section 313
 chemical to more than two other off-site locations,
 you should photocopy Page 4 of Form R as many
 times as necessary and  then  number the  boxes
 consecutively  for  each off-site location. At the
 bottom of Page  4 you will find  instructions for
 indicating the total number of Page 4s that you are
 submitting  as  part of the  Form  R  as  well as
 indicating   the  sequence of  those   pages.  For
 example, your facility transfers the reported EPCRA
 Section  313   chemical  to  three  other  off-site
 locations.  You should  photocopy page  4 once,
 indicate at the bottom of Section 6.2 on each Page 4
 that  there  are  a total  of two  Page 4s and then
 indicate the first and second Page 4. The boxes for
 the two off-site locations  on the first Page 4 would
 be numbered 6.2.1  and 6.2.2, while the box for the
 third off-site location on the  second Page  4 should
 be numbered 6.2.3.

6.1      Discharges to Publicly Owned Treatment
        Works
 In  Section 6.1.A, estimate  the quantity of the
 reported EPCRA Section 313 chemical transferred
 to all publicly owned treatment works (POTWs) and
 the basis upon which the estimate was made. In
 Section  6.I.E., you  should  enter  the  name  and
 address  for  each  POTW to which your facility
 discharges  or  otherwise   transfers  wastewater
 containing  the  reported  EPCRA  Section  313
 chemical. The  most common transfers  of this type
 will be  conveyances of the toxic chemical in facility
 wastewater through  underground  sewage  pipes;
 however,  materials  may  also  be   trucked  or
 transferred  via some  other  direct methods to  a
 POTW.

 If you do  not discharge wastewater containing the
 reported EPCRA Section 313 chemical to a POTW,
 enter NA  in the  box  for the POTW's  name in
 Section  6.1.B._  (See  discussion   of  NA  vs.  a
 Numeric Value (e.g., Zero) in  the  introduction of
 Section 6).
 6.1.A.1 Total Transfers
                      Toxics Release Inventory Reporting Forms and Instructions
                                             49

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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:
                                    6.2
       Transfers to Other Off-Site Locations
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999
6. LA. 2 Basis of Estimate
You must identify the basis for your estimate of the
total quantity of the reported EPCRA Section 313
chemical  in the  wastewater  transferred  to  all
POTWs.  You should enter one of the following
letter codes that applies to the method by which the
largest percentage of the estimate was derived.

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  stream before treatment
     was fully identified through monitoring data.

If you transfer an EPCRA Section  313  chemical to
more than one POTW, you should report the  basis
of estimate that was used to  determine the largest
percentage of the EPCRA Section 313 chemical that
was transferred.
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 for residue quantities  left in  drums and tanks
when emptied.

If appropriate, you must report multiple activities
for each off-site location.  For  example,  if your
facility  sends a reported  EPCRA  Section  313
chemical in a single  waste stream to an off-site
location where  some  of the EPCRA  Section  313
chemical is to be recycled while  the remainder of
the quantity transferred is to be treated, you must
report  both  the  waste  treatment  and  recycle
activities, along  with  the  quantity associated with
each activity.

If your facility transfers an EPCRA  Section  313
chemical to an  off-site location  and  that off-site
location performs more than four activities on  that
chemical, provide the necessary information in Box
6.2.1  for the off-site  facility  and the first four
activities. Provide the  information on the remainder
of the activities in Box 6.2.2 and provide again the
off-site   facility   identification   and   location
information.

If you do not ship or transfer wastes containing the
EPCRA  Section  313  chemical to other off-site
locations, you should  enter NA (See discussion of
NA  vs.  a  Numeric  Value (e.g., Zero)  in  the
introduction of Section 6) in the box for the off-site
location's EPA Identification Number (defined in 40
CFR 260.10 and therefore  commonly referred to as
the RCRA ID Number). This number may be found
on the Uniform Hazardous Waste Manifest, which is
required  by  RCRA  regulations.  If you  ship or
transfer wastes containing an EPCRA Section  313
chemical and the off-site location  does not have an
EPA Identification Number (e.g., it does not accept
RCRA hazardous wastes)  enter NA in the box for
the off-site location EPA Identification Number. If
you ship or transfer hazardous wastes containing an
   50
        Toxics Release Inventory Reporting Forms and Instructions

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                          Instructions for Completing Part II of EPA Form R
EPCRA  Section  313 chemical to a  facility that
treats, stores, or disposes RCRA hazardous wastes,
make  sure   to  include  that facility's   RCRA
Identification Number in the box  for the off-site
location EPA Identification Number. This RCRA ID
is   shown  on  the  RCRA  manifest  that  must
accompany  the  hazardous waste  to  the  off-site
facility.

If you ship or transfer the reported EPCRA Section
313 chemical in wastes to another country, you do
not need to report a RCRA ID for that waste. You
should indicate NA in the RCRA ID field. Enter the
complete address of the non-U.S. facility in the off-
site address fields, the city in the city field, the non-
U.S. state or province in the county field, the postal
code in the zip code  field, and the  foreign country
code in the country field. The most  commonly used
FIPs codes are listed  in Table IV. To obtain a FIPS
code for  a  country  not listed, contact the  TRI
Information  Center. There is nothing to enter in the
state field.

6.2a   Column A: Total Transfers
For each off-site location, enter the total amount, in
pounds   (in  grams  for  dioxin  and  dioxin-like
compounds),  of the EPCRA Section 313  chemical
that  is contained in the waste  transferred to that
location. Do  not enter the total 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
                      Toxics Release Inventory Reporting Forms and Instructions
                                            51

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                Summary of Residue Quantities From Pilot-Scale Experimental Studya'b
                                   (weight percent of drum capacity)
Unloading
Method
Pumping
Pumping
Pouring
Pouring
Gravity
Drain
Gravity
Drain
Gravity
Drain
Vessel Type
Steel drum
Plastic drum
Bung-top steel
drum
Open-top steel
drum
Slope-bottom
steel tank
Dish-bottom
steel tank
Dish-bottom
glass-lined
tank
Value
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Material
Kerosene0
1.93-3.08
2.48
1.69-4.08
2.61
0.244
0.472
0.404
0.032
0.080
0.054
0.020
0.039
0.033
0.031
0.042
0.038
0.024
0.049
0.040
Water"
1.84-2.61
2.29
2.54-4.67
3.28
0.266
0.458
0.403
0.026
0.039
0.034
0.016
0.024
0.019
0.033
0.034
0.034
0.020
0.040
0.033
Motor Oile
1.97-2.23
2.06
1.70-3.48
2.30
0.677
0.787
0.737
0.328
0.368
0.350
0.100
0.121
0.111
0.133
0.191
0.161
0.112
0.134
0.127
Surfactant
Solution'
3.06
3.06
Not
Available
0.485
0.485
0.089
0.089
0.048
0.048
0.058
0.058
0.040
0.040
Trom "Releases During Cleaning of Equipment." Prepared by PEI Associates, Inc., for the U.S. Environmental Protection Agency,
Office of Pesticides and Toxic Substances, Washington DC, Contract No. 68-02-4248. June 30, 1986.
bThe values listed in this table should only be applied to similar vessel types, unloading methods, and bulk fluid materials. At
viscosities greater than 200 centipoise, the residue quantities can rise dramatically and the information on this table is not applicable.
Tor kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
dFor water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
Tor motor oil, viscosity = 94 centipoise, surface tension = 34.5 dynes/cm2
Tor surfactant solution, viscosity = 3 centipoise, surface tension =31.4 dynes/cm2
  Example 14: Container Residue

  You have  determined that a Form R for an EPCRA Section 313 chemical must be submitted. The facility
  purchases  and uses one thousand 55-gallon steel drums that contain a 10 percent 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 percent 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):
   52
Toxics Release Inventory Reporting Forms and Instructions

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                          Instructions for Completing Part II of EPA Form R
      (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.
If you transfer the EPCRA Section 313 chemical in
wastes to an off-site facility for distinct and multiple
purposes, you must report those activities for each
off-site  location,  along with the  quantity of  the
reported  EPCRA Section  313 chemical associated
with  each  activity.  For  example,  your  facility
transfers  a total  of  15,000 pounds of toluene to an
off-site location  that will use 5,000 pounds for the
purposes  of energy  recovery,  will  enter 7,500
pounds into  a recovery process, and will dispose of
the remaining  2,500 pounds. These quantities and
the associated  activity codes  must  be  reported
separately in  Section 6.2.  (See Figure  4 for a
hypothetical Section 6.2 completed for two off-site
locations, one of which  receives  the transfer of
15,000 pounds of toluene  as detailed.) If you have
fewer  than  four total transfers  in  Section 6.2
Column A (see examples in Figure 4), an NA should
be placed in Column A of the first unused row to
indicate the  termination of the sequence. If all four
rows  are used, there is no  need to terminate the
sequence. If there are more than four total transfers,
re-enter the  name of the off-site location, address,
etc. in the next row (6.2.2)  and then you  should
enter NA when the sequence has terminated if there
are fewer than 8  (i.e. anytime there are fewer than 4
transfers  listed in a Section 6.2 block, an NA should
be used to terminate the sequence).
Do not double or multiple count amounts transferred
off-site.  For example, when  a reported EPCRA
Section 313 chemical is sent to an  off-site facility
for sequential activities, you should report the final
disposition of the toxic chemical.

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   Estimate is based on continuous monitoring
      data or measurements for the  EPCRA Section
      313 chemical.
                      Toxics Release Inventory Reporting Forms and Instructions
                                             53

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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.

6.2c   Column C: Type of Waste Management:
       Disposal/ Treatment/Energy
       Recovery/Recycling
You should enter  one of the following  M codes to
identify the  type  of disposal, treatment,  energy
recovery, or recycling methods used by the off-site
location  for the   reported EPCRA Section 313
chemical. You  must use more than one line and
code for a single location when distinct quantities of
the  reported EPCRA  Section  313  chemical are
subject to  different waste  management activities,
including disposal, treatment, energy recovery,  or
recycling. You must use the code that represents the
ultimate disposition of the chemical.

If the EPCRA Section 313 chemical is sent off-site
for further direct reuse (e.g., an EPCRA  Section 313
chemical in  used solvent  that will  be  used  as
lubricant at another facility) and does not undergo a
waste management activity (i.e., release (including
disposal), treatment, energy recovery, or recycling
(recovery))  prior  to  that reuse,  it need not be
reported in section 6.2 or section 8.

Incineration vs. Energy Recovery

You must distinguish between incineration which is
waste treatment, and legitimate energy recovery. For
you to claim that  a reported EPCRA Section 313
                            chemical sent off-site is used for the purposes of
                            energy   recovery   and  not  for  treatment  for
                            destruction, the EPCRA Section 313 chemical must
                            have  a  significant  heating  value  and  must  be
                            combusted in an energy recovery unit such as an
                            industrial boiler, furnace,  or  kiln.  In a situation
                            where the reported EPCRA Section 313 chemical is
                            in a waste  that is combusted in an energy recovery
                            unit, but the EPCRA Section 313 chemical does not
                            have  a  significant 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  waste
                            stream may be treated but the metal contained in the
                            waste  stream  is  not treated  and  is  ultimately
                            released. For example, M41 should be used for a
                            metal or metal category compound that is  stabilized
                            in preparation for disposal.

                            Applicable codes for Part II, Section 6.2, column C
                            are:

                            Disposal
                            M10    Storage Only
                            M41    Solidification/Stabilization - Metals and
                                    Metal Category Compounds only
                            M62   Wastewater Treatment (Excluding POTW) -
                                    Metals and Metal Category Compounds only
                            M64    Other Landfills
   54
Toxics Release Inventory Reporting Forms and Instructions

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                         Instructions for Completing Part II of EPA Form R
M65   RCRA Subtitle C Landfills
M66   Subtitle C Surface Impoundment
M67   Other Surface Impoundments
M73   Land Treatment
M79   Other Land Disposal
M81   Underground Injection to Class I Wells
M82   Underground 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
                                            55

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SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATION
Off-Site EPA Identification Number (RCRA No.)

Off-Site Location Name

Street Address
"
UULDbblb
A m Wast S rvi

i Market Street
City Anywhere

State ro


Zip Code |S location under cc
8U401 facility or parent co
A. Total Transfers (pounds)/year)
(enter range code or estimate) (enter code)
1. 5,000
2. 7,500
3. 2,500
4. NA
i.O
2.C
3.0
4.
2461


County
Hill

ntrol of reporting r- 1 „ rjn NO
mpany
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. M56
2 M20
3. Mt°
4. M
This off-site location receives a transfer of 15,000 pounds of toluene and will combust 5,000 pounds for the
purposes of energy recovery, will enter 7,500 pounds into  a recovery  process, and will dispose of the
remaining 2,500 pounds.
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATION
6.2.2
Off-Site EPA Identification Number (RCRA No.)

Off-Site Location Name

Street Address

City

State


UUL)lb//^
frvnYKlK!

tion, Inc.
5432

5 Facility Road
Dumfry
CO

Zip Code

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


3.
4.


Qf\ff\f\ ls location under ex
OlOUU facility Or parent co

1. O
2.
3.
4.
County
Buins
jntrol of reporting •— i y rjn No
mpany
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
j 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
   56
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 7A 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.
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
percent, 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.
Use a separate line in Section 7A for each general    Waste streams containing the  EPCRA  Section 313
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.
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.	
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                                            57

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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 7A.2a. The  numeral "1" would
                             be crossed out, and a "9" would be inserted.

                             Treatment applied to any other general waste stream
                             types would then be listed in the next empty row. In
                             the scenario below, for instance, the second general
                             waste  stream would be reported in row 7A.3a.  See
                             Figure 5  for an example of a hypothetical section
                             7A.
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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 16: Calculating Releases and Other Waste Management Quantities

Your facility disposes of 14,000 pounds of lead chromate (PbCrO4.PbO) in an on-site landfill and transfers
16,000 pounds of lead selenite (PbSeO4) 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 (percent 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 (percent 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
                    Toxics Release Inventory Reporting Forms and Instructions                    59

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                               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
H083 Air or steam stripping
H101 Sludge treatment and/or dewatering
HI03 Absorption
Hill Stabilization or chemical fixation prior to
      disposal
HI 12 Macro-encapsulation prior to  disposal
H121 Neutralization
HI22 Evaporation
HI23 Settling or clarification
HI24 Phase separation
HI29 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.
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                          Instructions for Completing Part II of EPA Form R
Percent removal can be calculated as follows:
               q-E)xioo%
               i
where:
I =  amount of the EPCRA Section 313 chemical in
     the influent waste stream (entering the  waste
     treatment step or sequence) and
E =  amount of the EPCRA Section 313 chemical in
     the effluent  waste  stream (exiting  the  waste
     treatment step or sequence).

Calculate the amount of the  EPCRA Section 313
chemical in the influent waste stream by multiplying
the concentration (by weight) of the EPCRA Section
313  chemical in the waste  stream by  the total
amount or weight of the waste  stream. In most
cases,  the  percent removal  compares the treated
effluent to the influent  for the particular type  of
waste stream.  For solidification of wastewater, the
waste treatment efficiency can be  reported as code
El  (greater than 99.9999 percent) if no volatile
EPCRA Section 313 chemicals were removed with
the water or evaporated into the air. Percent removal
does not apply to incineration because  the  waste
stream, such as wastewater or  liquids, may not exist
in a  comparable form after waste treatment and the
purpose of incineration as a waste treatment is to
destroy the  EPCRA Section  313  chemical  by
converting  it to carbon dioxide and water or other
byproducts. In cases where the EPCRA Section 313
chemical is incinerated, the percent efficiency must
be based on the amount of the EPCRA Section 313
chemical destroyed or combusted, except for metals
or metal category compounds. In the cases in which
a metal or metal category compound is incinerated,
the efficiency is reported as code  E6 (equal to  or
greater than 0 percent, but less than or equal to 50
percent).

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 percent, but less than or equal to
50 percent.

EPCRA  Section  313  chemicals that  are  strong
mineral acids neutralized to a pH of 6 or above are
considered treated at a 100 percent 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.
                      Toxics Release Inventory Reporting Forms and Instructions
                                            61

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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  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).
   62
Toxics Release Inventory Reporting Forms and Instructions

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                          Instructions for Completing Part II of EPA Form R
Example 17: On-Site Waste Treatment

A process at the facility generates a wastewater stream containing an EPCRA Section 313  chemical (chemical A). A
second process generates a wastewater stream containing two EPCRA Section 313 chemicals, a metal (chemical B) and a
mineral acid (chemical C). Thresholds for all three chemicals have been exceeded and you are in the process of completing
separate Form Rs for each chemical.

These two wastewater streams are combined and sent to an on-site wastewater treatment system  before being discharged to
a POTW. This system consists of an oil/water separator that removes 99 percent of chemical A; a neutralization tank in
which the pH is adjusted to 7.5, thereby destroying 100 percent of the mineral acid (chemical C); and a settling tank where
95 percent of the metal (chemical B) is removed from the water (and eventually landfilled off-site).

Section 7A should be completed slightly differently when you file the Form R for each of the chemicals. The table
accompanying  this example shows how Section 7A should be completed for each chemical. First, on each Form R  you
should identify the type of waste stream in Section 7A.la as wastewater  (aqueous waste, code W). Next, on each Form R
you should list the code for each of the treatment steps that is applied to the entire waste stream, regardless of whether the
operation affects the chemical for which you are completing the Form R (for instance, the first four blocks of Section 7A. Ib
of all three Form Rs should show: H124 (phase separation), H121 (neutralization), H123 (settling or clarification), and N/A
(to signify the end of the treatment system). Note that Section 7A.lb is not chemical specific. It applies to the  entire waste
stream being treated. Section 7A.ld  applies  to the efficiency  of  the entire system in destroying and/or removing the
chemical for which you are preparing the Form R. You should enter E4 when filing for chemical A, E5 for chemical B, and
El for chemical C.

Chemical A
7A.la
W

7A.lb
3.H123
6.
1.H124
4. N/A
7.
2.H121
5.
8.
TA.ld
E4

Chemical B
TA.la
W

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

Chemical C
TA.la
W

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

Note that the quantity removed and/or destroyed is not reported in Section 1 and that the efficiency reported in Section
TA.ld 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 Sections.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 8.1c. However, when completing the Form R for Chemical C  you should report  the entire
quantity in Section 8.6 because raising the pH to T.5 will completely destroy the mineral acid.
                     Toxics Release Inventory Reporting Forms and Instructions
63

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    Example 18: Reporting On-Site Energy Recovery

    One waste stream generated by your facility contains, among other chemicals, toluene and Freon 113.
    Threshold quantities are exceeded for both of these EPCRA Section 313 chemicals, and you would,
    therefore,  submit two separate Form R reports. This waste stream is sent to an on-site industrial
    furnace that uses the heat  generated in a thermal hydrocarbon cracking process at your facility.
    Because toluene  has a significant heat value (17,440 BTU/pound) and the energy is recovered in an
    industrial furnace, the code "U02"  would be reported in Section 7B for the Form R submitted for
    toluene.

    However, as Freon 113 does not contribute any value for energy recovery purposes, the combustion of
    Freon 113 in the industrial  furnace is considered waste treatment, not energy recovery. You would
    report Freon 113 as  entering a waste treatment step (i.e., incineration), in Section 7A, column b. In
    Section 7B the facility should report zero.	
Section 8.   Source Reduction and
              Recycling Activities

This section includes the data elements mandated by
Section6607 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).
                            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.
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                          Instructions for Completing Part II of EPA Form R
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,
2009 (reporting year 2008), the prior year is 2007.
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.

Columns C and D:  Following  Year and  Second
Following Year
Quantities for  Sections 8.1 through  8.7 must be
estimated  for  2009  and  2010.  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
Section322  (42 USC  11042) for  the  chemical
identity.

Relationship to Other Laws

The  reporting  categories  for  quantities  recycled,
used  for  energy  recovery,  treated,  and disposed
apply to completing Section 8 of Form R as well as
to the rest of Form R. These  categories are to be
used only for TRI reporting. They are not intended
for  use   in  determining,  under  the Resource
Conservation and Recovery Act (RCRA) Subtitle C
regulations, whether a secondary material is  a waste
when recycled.  These definitions also do not apply
to the information that may be submitted in the
Biennial Report required under RCRA. In addition,
these  definitions   do  not   imply  any   future
redefinition of RCRA terms and do not affect EPA's
RCRA authority or authority under any other statute
administered by EPA.

Differences  in   terminology   and   reporting
requirements  for  EPCRA  Section  313 chemicals
reported  on  Form  R and  for hazardous  wastes
regulated under RCRA occur because EPCRA and
the PPA  focus on specific chemicals, while the
RCRA regulations and the  Biennial Report focus on
waste streams  that may  include more than  one
chemical.  For example, a  RCRA hazardous waste
containing  an  EPCRA Section 313 chemical  is
recycled  to recover  certain constituents   of  that
waste, but not  the toxic  chemical  reported under
EPCRA  Section  313. The  EPCRA  Section  313
chemical  simply  passes  through  the recycling
process  and  remains  in  the  residual from  the
recycling  process, which  is disposed. While the
waste may be considered recycled under RCRA, the
EPCRA Section 313 chemical constituent would be
considered to be disposed for TRI purposes.

Quantities Reportable in  Sections 8.1 - 8.7
Section 8 of Form R uses data collected to complete
Part  II,  Sections  5  through  7. For this  reason,
Section  8 should be completed last. Sections  8.1,
8.3, 8.5, 8.7, and 8.8 use data collected to complete
Sections  5 and 6 of Form R. The  relationship
between Section s 5, 6, and 8.8 to Sections 8.1, 8.3,
8.5, and 8.7 are  provided below in equation form.

Section 8.1. Beginning in  the  2003  reporting year,
Section 8.1 was divided into four Subsections (8.la,
8.1b, 8.1c  and  8.Id).  Please refer to the following
equations   that   show the  relationship  between
Sections  5,  6  and  8.la  through  8.Id.  EPCRA
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Section329(8)  defines  release  as  "any  spilling,
leaking,  pumping,  pouring,  emitting, emptying,
discharging, injecting, escaping, leaching, dumping,
or  disposing   [on-site   or  off-site]   into   the
environment (including the abandonment of barrels,
containers,  and  other  closed  receptacles)."  In
Section 8.1,  facilities report disposal and  other
releases.  This includes  on-site disposal and other
releases in Section 5 and off-site disposal and other
releases in  Section  6 (releases plus  transfers  to
disposal  and transfers to  POTWs  of metals and
metal compounds), but excludes quantities reported
in  Section  5  and  6  due  to  remedial  actions,
catastrophic  events,  or   non-production  related
events (see the discussion on Section 8.8).
 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 percent 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
 percent to  the amount in column B (the amount
 for the  current  reporting  year).   The  second
 following year (2007) figure  can be  calculated
 by adding an additional 30 percent to the amount
 reported  in  column  C (the  amount  for  the
 following year (2006) projection).
Metals and metal category compounds reported in
1)    Section    6.2   as    sent    off-site    for
stabilization/solidification     (M41Cmetals)     or
wastewater    treatment    (excluding    POTWs)
(M62Cmetals) and/or 2) in Section 6.1 - discharges
to POTWs, should be reported in Section 8.1. These
quantities should NOT be reported in Section 8.7
because the metals are ultimately disposed.
                             Sections 8.1a and 8.1b. Toxic chemicals disposed
                             or otherwise released on site are reported in 8.la or
                             8.1b as appropriate. Toxic chemicals sent off site for
                             disposal are reported in 8.1c or 8.Id.

                             SectionS.la  = Section 5.4.1 + Section 5.5.1A +
                             Section 5.5.1B  B Section 8.8  (on  site  release or
                             disposal due to catastrophic events)1

                             SectionS.lb   =  Section   5.1   +   Section  5.2  +
                             Section5.3  +  Section  5.4.2  +  Section5.5.2  +
                             Section5.5.3A + Section  5.5.3B  + Section5.5.4  -
                             Section 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.

                             SectionS.lc = Section 6.1 (portion of transfer that
                             is untreated and ultimately disposed of  in UIC
                             Class I Wells, RCRA Subtitle  C landfills,  and
                             other   landfills)  +   Section   6.2   (quantities
                             associated with M codes  M64, M65 and  M81)  -
                             Section 8.8  (off site disposal  due to  catastrophic
                             events)1

                             SectionS.ld  = Section6.1 (portion of transfer that
                             is untreated and ultimately disposed of  in UIC
                             Class II-V  wells, and disposal other than to
                             landfills) + Section6.2 (quantities associated with
                             M codes M10, M41, M62, M66, M67, M73, M79,
                             M82, M90,  M94, M99)  -  Section  8.8 (off site
                             disposal due to catastrophic events)1

                             Some chemicals in addition to metals  and metal
                             category  compounds  might  not  be  treated  for
                             destruction at a POTW. If you  are able to  quantify
                             the  amounts of a toxic chemical  sent to a POTW
                             that  are  treated for destruction  and disposed or
                             released  from the POTW  untreated, you should
                             divide the amount reported in Section 6.1  between
                             Sections 8.1c and 8.Id and 8.7 (quantity treated off
                             site), as appropriate.

                             Sections 8.2 and 8.3.  These relate to an  EPCRA
                             Section  313  chemical or a  mixture containing an
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                          Instructions for Completing Part II of EPA Form R
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.

Section 8.2 is reported in Section 8 only

Section  8.3 = Section6.2  (energy  recovery)  -
SectionS.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.

Section 8.4 is reported in Section 8 only

Section 8.5 =  Section 6.2 (recycling) - Section 8.8
(off site recycling due to catastrophic events)

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).

Section8.6 is reported in Section 8 only

SectionS.7   =   Section6.1   (excluding   most
metal/metal category compounds) +  Section6.2
(treatment) -  Section 8.8 (off site treatment due
to catastrophic events)1
Some chemicals  in addition to metals and metal
category  compounds   might not  be  treated  for
destruction at a POTW. If you are able to quantify
the amounts of a toxic chemical sent  to a POTW
that are treated  for destruction  and  disposed  or
released from the  POTW untreated,  you should
divide the amount reported in Section  6.1 between
Sections 8.1c-d and 8.7 (quantity treated off site), as
appropriate. Facilities  should use their best readily
available  information  to  determine  the  final
disposition of the toxic chemical sent to the POTW.

An EPCRA Section 313  chemical or an EPCRA
Section  313 chemical in a mixture that is a waste
under RCRA  must be reported  in  Sections  8.1
through 8.7.

8.8 Quantity Released to  the  Environment as a
Result of Remedial Actions, Catastrophic Events,
or  One  Time  Events   Not  Associated  with
Production Processes

In  Section  8.8,  enter  the  total  quantity of  the
EPCRA Section 313 chemical disposed or released
directly  into the  environment or  sent off-site  for
recycling, energy recovery, treatment, or disposal
during the reporting year due to any of the following
events:

    (1)   remedial actions;
    (2)   catastrophic events such as  earthquakes,
         fires, or floods; or
    (3)   one  time  events  not  associated  with
         normal or routine production processes.

These quantities should not be included in Section
8.1.

The purpose of this section is to separate quantities
recycled,  used for energy recovery, treated,  or
released, including disposals that are associated with
normal  or routine production operations from those
that are  not. While all quantities disposed, released
recycled, combusted for energy recovery, or treated
may ultimately be preventable, this  section separates
the quantities that are  more likely to be reduced or
eliminated by process  oriented  source  reduction
activities  from  those   releases that  are  largely
unpredictable and are less amenable to such source
reduction activities. For example, 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
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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
                             percent increase, not  110 percent).

                             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
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                          Instructions for Completing Part II of EPA Form R
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 2008 divided by the amount
     of    EPCRA   Section   313    chemical
     manufactured in 2007; or

(2)  Amount of product produced in 2008 divided
     by the amount of product produced in 2007.
 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 8.1b).
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8.10   Did Your Facility Engage in Any Source
       Reduction  Activities  for This Chemical
       During the Reporting Year?
Section 8.10 must  be  completed only if  a source
reduction    activity   was  newly   implemented
specifically  (in whole  or  in part) for the  reported
EPCRA Section 313 chemical during  the  reporting
year.  If  your  facility  engaged  in   any  source
reduction  activity for the  reported EPCRA Section
313 chemical  during the reporting year, report the
activity that was implemented  and the method used
to  identify  the   opportunity  for   the   activity
implemented. If your facility did not engage in any
source reduction  activity  for the reported EPCRA
Section 313  chemical, enter NA in Section  8.10.1.

Source reduction means any practice that:

•   Reduces  the  amount   of   any  hazardous
    substance, pollutant,  or contaminant  entering
    any waste stream or otherwise released into the
    environment  (including   fugitive  emissions)
    prior to recycling,  energy recovery, treatment,
    or disposal; and

•   Reduces the hazards  to public health and  the
    environment associated with the release of such
    substances, pollutants, or contaminants.

The  term  includes  equipment  or  technology
modifications, process  or procedure modifications,
reformulation  or redesign of products, substitution
of   raw    materials,   and    improvements   in
housekeeping, maintenance, training,  or inventory
control.
                             The term "source reduction"  does not include any
                             practice that  alters the  physical,  chemical,  or
                             biological   characteristics  or the  volume   of  a
                             hazardous   substance,  pollutant,   or  contaminant
                             through a  process  or activity that itself is not
                             integral to  and necessary  for the  production of a
                             product or the providing of a service.

                             Source reduction activities do  not include recycling,
                             using  for energy recovery, treating, or disposing of
                             an EPCRA  Section  313  chemical. Report in this
                             section  only   the   source   reduction   activities
                             implemented to reduce or eliminate the quantities
                             reported in Sections  8.1 through 8.7. The  focus of
                             the section is only those activities that are applied to
                             reduce routine  or reasonably anticipated  releases
                             and quantities of the reported EPCRA Section 313
                             chemical  recycled,   treated,  used  for   energy
                             recovery, or disposed. Do not report in this section
                             any activities  taken to  reduce or eliminate the
                             quantities reported in Section  8.8. If you have fewer
                             than four source reduction codes in Section 8.10, an
                             NA should be placed in the first column of the first
                             unused  row to  indicate  the termination  of the
                             sequence. If all four rows are  used, there is no need
                             to terminate the sequence. If there are more than
                             four source  reduction codes,  photocopy  Page 5 of
                             Form  R as many  times  as necessary and then
                             number the  boxes consecutively for  each source
                             reduction activity. Enter NA when the sequence has
                             terminated, unless the sequence ends at 4, 8, 12,  16,
                             etc. source reduction codes.
 Example 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, 3,000pounds 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.
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                         Instructions for Completing Part II of EPA Form R
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.	
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                         Instructions for Completing Part II of EPA Form R
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	
                     Toxics Release Inventory Reporting Forms and Instructions                    73

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Example 26: Source Reduction

A facility assembles and paints furniture. Both the glue used to assemble the furniture and the paints contain
EPCRA Section 313 chemicals. By examining the gluing process, the facility discovered that a new drum of
glue is opened at the beginning of each shift, whether the old drum is empty or not. By adding a mechanism
that prevents the drum from being changed before it is empty, the need for disposal of the glue is eliminated
at the source. As a result, this activity is considered source reduction. The painting process at this facility
generates a solvent waste that contains an EPCRA Section 313 chemical that is collected and recovered.
The  recovered solvent is used to clean the painting equipment. The recycling activity does not reduce the
amount of EPCRA Section 313 chemical recycled, and therefore is not considered a  source reduction
activity.	
Source Reduction 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),  or  treated  (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
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                          Instructions for Completing Part II of EPA Form R
W71   Other cleaning and decreasing
       modifications made

Surface Preparation and Finishing
W72   Modified spray systems or equipment
W73   Substituted coating materials used
W74   Improved application techniques
W75   Changed from spray to other system
W78   Other surface preparation and finishing
       modifications made

Product Modifications
W81   Changed product specifications
W82   Modified design or composition of product
W83   Modified packaging
W89   Other product modifications made

Methods to Identify Activity
In columns a  through c  of Section  8.10, the
"Methods to Identify Activity," you must enter one
or more of the following code(s) that correspond to
those   internal   and   external  method(s)  or
information sources you used  to  identify the
possibility   for   a  source  reduction  activity
implementation at your facility. If more than three
methods were used to identify the source reduction
activity, enter only the three codes that contributed
most to the decision to implement the activity.

T01    Internal  pollution  prevention  opportunity
       audit(s)
T02    External pollution prevention  opportunity
       audit(s)
T03    Materials balance audits
T04    Participative team management
T05    Employee  recommendation (independent
       of a formal company program
T06    Employee   recommendation   (under   a
       formal company program
T07    State  government  technical  assistance
       program
T08    Federal  government  technical  assistance
       program
T09    Trade    association/industry    technical
       assistance program
T10    Vendor assistance
Til    Other

8.11    Is Additional Optional Information on
       Source Reduction, Recycling, or
       Pollution Control Activities Included
       with this Report?
Check "Yes" for this data element if you 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-ME to submit your report, you can use the
pull-down text box feature to describe your source
reduction, recycling, or pollution control activities.
You may submit such  additional  information in
hard-copy  in addition to, or  instead of,  the
information supplied  in  the  TRI-ME  text box
feature. If you wish to submit by regular mail,
please use the following address:

       TRI Data Processing Center
       P.O. Box 1513
       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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D. Instructions for Completing
Form R Schedule 1 (Dioxin and
Dioxin-like Compounds)

D. 1  What is the Form R Schedule 1 ?
The Form R Schedule 1 is a four-page form that
mirrors the data elements from Form R Part II
Chemical-Specific Information sections 5, 6, and
8 (current year only). The Form R Schedule 1
requires the reporting of the individual grams
data for each member of the dioxin and dioxin-
like compounds category present, and is
submitted as an adjunct to the Form R.
Beginning with reporting year 2008, facilities
that file Form R reports for the dioxin and
dioxin-like compounds category are required to
determine if they have any of the information
required by the new Form R Schedule 1.
Facilities that have any of the information
required by Form R Schedule 1 must submit a
Form R Schedule 1 in addition to the Form R.
D.2  Who is required to file a Form R
       Schedule 1?

Only facilities that file reports for the dioxin and
dioxin-like compounds category may be required
to file a Form R Schedule 1. Facilities that have
any of the data required by Form R Schedule 1
for the individual members of the dioxin and
dioxin-like compounds category must submit a
Form R Schedule 1, in addition to the Form R.
EPA notes that dioxin and dioxin-like
compounds are not measured as a total quantity;
the measurements are based on the individual
compounds within the category. Emission factors
for dioxin and dioxin-like compounds are also
based on emission factors for the individual
compounds within the category.  EPA's guidance
document for dioxin and dioxin-like compounds
(Emergency Planning And Community Right-
To-Know Act - Section 313: Guidance for
                             Reporting Toxic Chemicals within the Dioxin and
                             Dioxin-like Compounds Category, EPA-745-B-
                             00-021, December 2000) includes tables that
                             contain the emission factors for the individual
                             members of the dioxin and dioxin-like compounds
                             category. Since measured data and emission
                             factor data are based upon data for the individual
                             members of the dioxin and dioxin-like compounds
                             category, the information required by Form R
                             Schedule 1 should be available to facilities that
                             file Form R reports for the dioxin and dioxin-like
                             compounds category.
                             D.3  What information is reported on
                                    the Form R Schedule 1 ?


                             The only data reported on the Form R Schedule 1
                             is the mass quantity information required in
                             sections 5, 6, and 8 (current year only) of the
                             Form R. All of the other information required in
                             sections 5, 6, and 8 of the Form R (off-site
                             location names, stream or water body names, etc.)
                             would be the same so this information is not
                             duplicated on Form R Schedule 1. For example,
                             if a facility reported 5.3306 grams on Form R
                             Section 5.1 for  fugitive or non-point air emissions
                             for the dioxin and dioxin-like compounds
                             category then the facility would report on the
                             Form R Schedule 1 the grams data for each
                             individual member of the category that
                             contributed to the 5.3306 gram total. The sum of
                             the gram quantities reported for each individual
                             member of the category should equal the  total
                             gram quantity reported for the category on Form
                             R for each data element (see examples below).
                             The NA box has the same meaning on Form R
                             Schedule 1 as it does on the Form R and should
                             only be marked if it is marked on the Form R.
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                          Instructions for Completing Part II of EPA Form R
Form R Section 5 Example
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE

5.1
Fugitive or non-point
air emissions
N
A

A. Total Release (pounds/year*)
(Enter a range code** or
estimate)
5.3306
B. Basis of
Estimate
(enter code)
M
C. % From
Stormwater

Form R Schedule 1 Section 5 Example
SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM
ONSITE

D. Mass (grams) of Each Compound in the Category (1-17)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
5.1 NA
Fugitive or non-
point air emissions
0.0035
0.0059
0.0071
0.0008
0.0065
0.0923
0.5720
0.0723
0.0695
0.0399
0.3562
0.1309
0.0132
0.0815
1.4625
0.3126
2.1039
" A
Stack or point
air emissions

















, , Discharges to receiving streams or water bodies
(enter data for one stream or water body per box)
5.3.1

















5.3.2

















5.3.3

















The Form R Schedule 1 provides boxes for recording the gram quantities for all 17 individual members of
the dioxin and dioxin-like compounds category. The boxes on the Form R Schedule 1 for each release type
are divided into 17 boxes.  Each of the boxes (1 -17) correspond to the individual members of the dioxin
category as presented in Table I.
Box#
1
2
3
4
5
6
7
8
9
CAS#
01746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
03268-87-9
51207-31-9
57117-41-6
                                              Table I
                          Chemical Name
                          2,3,7,8-Tetrachlorodibenzo-p-dioxin
                          1,2,3,7,8-Pentachlorodibenzo- p-dioxin
                          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-Octachlorodibenzo-p-dioxin
                          2,3,7,8-Tetrachlorodibenzofuran
                          1,2,3,7,8-Pentachlorodibenzofuran
Abbreviation
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
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                      77

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10       57117-31-4      2,3,4,7,8-Pentachlorodibenzofuran                 2,3,4,7,8-PeCDF
11       70648-26-9      1,2,3,4,7,8-Hexachlorodibenzofuran                1,2,3,4,7,8-HxCDF
12       57117-44-9      1,2,3,6,7,8-Hexachlorodibenzofuran                1,2,3,6,7,8-HxCDF
13       72918-21-9      1,2,3,7,8,9-Hexachlorodibenzofuran                1,2,3,7,8,9-HxCDF
14       60851-34-5      2,3,4,6,7,8-Hexachlorodibenzofuran                2,3,4,6,7,8-HxCDF
15       67562-39-4      1,2,3,4,6,7,8-Heptachlorodibenzofuran             1,2,3,4,6,7,8-HpCDF
16       55673-89-7      1,2,3,4,7,8,9-Heptachlorodibenzofuran             1,2,3,4,7,8,9-HpCDF
17       39001-02-0      1,2,3,4,6,7,8,9-Octachlorodibenzofuran             1,2,3,4,6,7,8,9-OCDF

It is extremely important that facilities enter their grams data for the individual members of the category
based on the box numbers in Table I. This information will be used to calculate toxic equivalency values
using toxic equivalency factors that are specific to each member of the category.  As with reporting on the
Form R, facilities should report on the Form R Schedule 1 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. EPA strongly encourages facilities that
report for the dioxin and dioxin-like compounds category to file their reports electronically to reduce the
potential for errors when transferring the individual grams data from hard copy reports.
  78                 Toxics Release Inventory Reporting Forms and Instructions

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                      Facility Eligibility Determination for Alternate Threshold
                      and for Reporting on EPA Form A Certification Statement
E.    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, effective in Reporting
Year 2008, the TRI Burden Reduction Rule has
been voided by Congress. The criterion for using
Form A has returned to what they were prior to
Reporting Year 2006. The criteria are explained
below. For more information about the final rule,
see the TRI Homepage at http://www.epa.gov/tri/.

E.I   Alternate Threshold

On November 30,  1994, EPA published a final rule
(59 FR 61488) that provides qualifying facilities an
alternate threshold of 1 million pounds. Eligible
facilities wishing to take advantage of this option
may certify on a simplified two-page form referred
to as Form A Certification Statement and do not
have to use Form R. The "TRI Alternate Threshold
for Facilities with Low Annual Reportable
Amounts," provides facilities  otherwise meeting
EPCRA section  313 reporting thresholds the option
of certifying on Form A provided that they do not
exceed 500 pounds for the total annual reportable
amount (defined below) for that chemical, and that
their amounts manufactured or processed or
otherwise used do not exceed one-million pounds.
As with determining section 313 reporting
thresholds, amounts manufactured, processed, or
otherwise used are to be considered independently.
This modification does not apply to forms being
submitted on or before July 1, 1995 (covering the
1994 reporting year). If you fill out a Form A for
an EPCRA section 313 chemical, do not fill out a
Form R for that same chemical.

However, there is an exception to the alternate
threshold rule described in the preceding
paragraph. All PBT chemicals (except certain
instances of reporting lead in stainless steel, brass
or bronze alloys) are excluded from eligibility for
the alternate threshold.

E. 2    What is the Form A Certification
       Statement?

The Form A, which is described as the
"certification statement" in 59 FR 61488, is
intended as a means to reduce the compliance
burden associated with EPCRA section 313. The
Form A must be submitted on an annual basis for
each eligible chemical. Facilities wishing to take
advantage of this burden reducing option must
submit a Form A for such chemicals meeting the
conditions described below, and should not submit
a Form R to the TRI Data Processing Center for
that chemical. The information submitted on the
Form A includes facility identification information
and the chemical or chemical category identity.
The information submitted on the Form A will
appear in the TRI data base in the same manner
that information submitted on Form R appears. An
approved Form A and a magnetic version of
reporting have  been included in this  Reporting
Forms and Instructions package.

 E.3   What Is the Annual Reportable
       Amount (ARA)?

For the purpose of this optional reporting
modification, the annual reportable amount (ARA)
is equal to the combined total quantities released at
the facility (including disposed within the facility),
treated at the facility (as represented by amounts
destroyed or converted by treatment processes),
recovered at the facility as a result of recycling
operations,  combusted for the purpose of energy
recovery at the facility, and amounts transferred
from the facility to off-site locations for the
purpose of recycling, energy recovery, treatment,
and/or disposal.  These quantities correspond to the
sum of amounts reportable for data elements on
EPA Form R (EPA Form 9350-1; Rev. 01/08) 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 onsite),
8.5 (quantity recycled off-site), 8.6 (quantity
treated on-site), and 8.7 (quantity treated off-site).
                      Toxics Release Inventory Reporting Forms and Instructions
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E.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.

E. 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.

E. 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.
                             E. 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.
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                       Facility Eligibility Determination for Alternate Threshold
                      and for Reporting on EPA Form A Certification Statement
Similarly, separate listings  on Form A must  be
submitted for all  other  listed  chemicals even  if
EPA allows one listing on Form R to be filed for
two  or  more listed chemicals  (e.g., o-xylene, p-
xylene and xylene (mixed isomers)). For example,
if a facility  processes in three separate process
streams, xylene (mixed isomers), o-xylene, and p-
xylene,  and exceeds the conditions of the alternate
threshold  for each of these  listed  substances, the
facility  may combine the appropriate information
on  the  o-xylene,  p-xylene, and  xylene  (mixed
isomers) into one Form R, but cannot combine the
reports into one listing on Form A.

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

Beginning with the 1998 reporting  year, facilities
may enter as many chemicals as are eligible on a
single Form A.
                       Toxics Release Inventory Reporting Forms and Instructions                    81

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F.     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 L    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 2008 must be submitted on  or before  July 1,
2009.

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 Section372.27.  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
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                       Facility Eligibility Determination for Alternate Threshold
                      and for Reporting on EPA Form A Certification Statement
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 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  2007 NAICS codes.)  Enter
any other applicable NAICS for your facility in 4.5
(b)-(f). The  tables  in Section B list  the required
NAICS codes  and their exceptions/ limitations. If
you  do not  know your NAICS code, consult the
2007 NAICS  Manual (see Section B.2  of these
instructions  for ordering information)  or check the
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SIC   to    NAICS
www.census.gov.
        crosswalk    tables   at
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. A
subsequent Federal Register  notice was published
on June 9, 2008 (73 FR 32466) to incorporate 2007
OMB revisions and other corrections to the NAICS
codes used for TRI Reporting.

4.6    Dun & Bradstreet Number(s)
Enter the nine digit number assigned by Dun &
Bradstreet  (D & B)  for your  facility or each
establishment within your facility. These numbers
code  the facility  for  financial  purposes. This
number  may  be available  from your  facility's
treasurer or financial officer. You can also obtain
the numbers from your local D & B office (check
the telephone book White Pages). If a facility does
not subscribe to the  D & B service, a number  can
be obtained, toll free at 800 234-3867 (8:00 AM to
6:00  PM, Local   Time) or on  the  Web  at
. If none of your establishments
has been assigned a D & B number,  you should
enter  NA  in box  (a).  If  only some  of your
establishments  have   been  assigned  Dun   &
Bradstreet numbers, enter those numbers in Part I,
Section 4.6.
owns at least 50 percent of the voting stock of the
facility  at issue),  the  facility should provide the
name of the parent company of either the facility
operator or the owner with the largest ownership
interest  in the facility. If neither the operator nor
this owner has a parent company, then the NA box
should be checked.

5.1   Name of Parent Company
Enter the name of the corporation or other business
entity that is your ultimate US parent company. If
your facility has no parent company,  you should
check the NA box.

5.2   Parent Company's Dun & Bradstreet
      Number
Enter the Dun &  Bradstreet (D & B) Number for
your ultimate  US parent company, if applicable.
The number may be obtained from the treasurer or
financial officer of the  company. If your parent
company does  not have  a D  & B  number, you
should check the NA box.
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  percent  of the  voting  stock of  your
company. If  your  facility  is owned by a foreign
entity,  you  should enter  NA  in  this  space.
Corporate names  should  be  treated  as  parent
company  names   for  companies  with multiple
facility   sites.   For  example,   the  Bestchem
Corporation is  not owned or controlled by any
other corporation  but  has  sites  throughout the
country whose names begin with Bestchem. In this
case, Bestchem Corporation should be listed as the
parent company. Note that a facility that is a 50:50
joint venture  is its own parent company. When a
facility is owned by more than  one company and
there is no parent  company  for the entire facility
(meaning that none of the facility owners directly
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                     Facility Eligibility Determination for Alternate Threshold
                     and for Reporting on EPA Form A Certification Statement
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.I.

EPCRA Section 313 Chemical Category Codes:

NO 10  Antimony compounds
N020  Arsenic compounds
N040  Barium compounds
N050  Beryllium compounds
N078  Cadmium compounds
N084  Chlorophenols
N090  Chromium compounds
N096  Cobalt compounds
N100  Copper compounds
N106  Cyanide compounds
N120  Diisocyanates
N150  Dioxin and dioxin-like compounds*
N171  Ethylenebisdithiocarbamic  acid,  salts and
       esters (EBDCs)
N230  Certain glycol ethers
N420  Lead compounds
N450  Manganese compounds
N458  Mercury compounds
N495  Nickel compounds
N503  Nicotine and salts
N511  Nitrate  compounds  (water  dissociable;
       reportable only when in aqueous  solution)
N575  Polybrominated biphenyls (PBBs)
N583  Polychlorinated alkanes (C10 to C13)
N590  Poly cyclic aromatic compounds (PACs)
N725  Selenium compounds
N740  Silver compounds
N746  Strychnine and salts
N760  Thallium compounds
N770  Vanadium compounds
N874  Warfarin and salts
N982  Zinc compounds

* Facilities cannot take the alternate threshold for
chemicals  and chemical categories listed as PBT
chemicals.

If you are making a trade secret claim, you must
report the  specific EPCRA Section 313 chemical
identity   on  your  unsanitized  Form  A  and
unsanitized substantiation form.  Do not report the
name of the EPCRA Section 313 chemical on your
sanitized Form A or sanitized substantiation form.
Include  a generic  name  that  is  structurally
descriptive in  Part II, Section 1.3 of your sanitized
Form A.

1.2   EPCRA Section 313 Chemical or
      Chemical Category Name
Enter the  name  of the  EPCRA  Section  313
chemical or chemical category exactly as it appears
in Table II. If the EPCRA Section 313 chemical
name is followed by a synonym in (parentheses),
report the  chemical by  the  name  that directly
follows the CAS number (i.e., not the synonym). If
the  EPCRA  Section 313 chemical  identity  is
actually a product trade name (e.g., dicofol), the
9th Collective Index  name is listed below it  in
brackets. You  may report either name in this case.
Do  not list the name of a chemical that does not
appear in Table II, such as individual members  of
an  EPCRA Section 313 chemical category. For
example,  if you use silver chloride, do not report
silver chloride with its CAS number. Report this
chemical as "silver compounds" with its category
code N740.

If you are making a trade secret claim, you must
report the  specific EPCRA Section 313 chemical
identity   on  your  unsanitized  Form  A  and
unsanitized substantiation form.  Do not report the
name of the EPCRA Section 313 chemical on your
sanitized Form A or sanitized substantiation form.
Include a  generic name  in Part  II, Section 1.3  of
your sanitized Form A.
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1.3   Generic Chemical Name
Complete Section 1.3 only if you are claiming the
specific EPCRA  Section 313 chemical identity of
the EPCRA Section 313 chemical as a trade secret
and have marked the trade secret block in Part I,
Section  2.1 on Page 1 of Form A. Enter a generic
chemical name that is descriptive of the chemical
structure. You should limit the generic  name to
seventy  characters  (e.g., numbers, letters, spaces,
punctuation) or less. Do not enter mixture names in
Section  1.3; see Section 2 below.

In house plant codes  and other substitute names
that are  not structurally descriptive of the EPCRA
Section  313  chemical identity being withheld as a
trade secret are not acceptable as a generic name.
The generic name  must appear on both sanitized
and unsanitized Form A, and the name must be the
same as that used on your substantiation forms.
Section 2.   Mixture Component
              Identity
Report the  generic name provided to you by your
supplier in this section if your supplier is claiming
the chemical identity proprietary or trade  secret.
Do not answer "yes" in Part I, Section 2.1 on Page
                             1 of the form if you complete this section. You do
                             not need to supply trade secret substantiation forms
                             for this EPCRA Section 313 chemical because it is
                             your supplier who is claiming the chemical identity
                             a trade secret

                             2.1   Generic Chemical Name Provided by
                                   Supplier
                             Enter the  generic chemical name  in this section
                             only if the following three conditions apply:

                             1.   You determine that the mixture contains an
                                 EPCRA Section 313  chemical but  the only
                                 identity  you have  for that  chemical  is  a
                                 generic name;
                             2.   You know either the specific concentration of
                                 that EPCRA Section 313 chemical component
                                 or a maximum or average concentration level;
                                 and
                             3.   You multiply the concentration level by the
                                 total  annual  amount  of  the  whole mixture
                                 processed or otherwise used  and determine
                                 that you meet the process or otherwise use
                                 threshold for that single, generically identified
                                 mixture component.
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                      Facility Eligibility Determination for Alternate Threshold
                      and for Reporting on EPA Form A Certification Statement
                                            Index
Ancillary or other use, 43
Article component, 42
Byproduct, 42
Catastrophic Events, 71, 73
CD, 1
CDX, vii,  1, 2, 7, 87
Chemical processing aid, 42
Coal Extraction Activities Exemption, 25
Coincidental Manufacture, 16, 17
Container Residue, 56
De Minimis Exemption, 21
Discharges to Receiving Streams or Water
  Bodies, 46
Diskette, 2
Disposal to Land, 46
Dun & Bradstreet, 39, 88
Energy Recovery, 58, 61, 65, 66, 68
EPA Identification Number, 53, 54
EPCRA, vi, vii, viii, 1, 3, 4, 5, 6, 7, 9, 10, 14, 15,
  16,  17, 18, 19,  20, 21, 22, 23, 25, 26, 27, 28, 29,
  30,  31, 32, 33,  34, 35, 36, 37, 38, 39, 40, 41, 42,
  43,  44, 45, 46,  47, 48, 49, 50, 52, 53, 54, 55, 56,
  57,  58, 61, 63,  64, 65, 66, 67, 68, 69, 70, 71, 72,
  73,  74, 76, 77,  78, 79, 83, 84, 86, 89, 90
Facility Identification, 86
Form A, 83
Formulation component, 42
Fugitive or Non-Point Air Emissions, 45
Full-Time Employee, 9
Import, 42
Impurity, 42
Laboratory Activities Exemption, 25
Manufacture, 16, 18, 23, 25, 42
Manufacturing aid, 43
Metal Category Compounds, 29
Metal Mining Overburden Exemption, 26
Methyl Ethyl Ketone (MEK) Delisting, vi
Mixture Component Identity, 32
Nitrate Compounds, 31
On-Site Recycling Codes, 66
Other Disposal, 47
Other Surface Impoundments, 47
Otherwise Use, 16, 18, 20, 23, 42
PBT,  10, 18, 19, 20, 21, 22, 23, 26, 27, 28, 29, 30,
  33, 34, 35, 36, 41, 43, 44, 45, 48, 52, 53, 54, 55,
  66, 68, 72, 83, 84
Process, 5, 16, 18,23,42
Produce, 42
Production Ratio, 75
RCRA Subtitle C landfills, 47
RCRA Subtitle C Surface Impoundments, 47
Reactant, 42
Repackaging, 42
Reporting year, 6
Reporting Year, 2, 33, 34, 35, 36, 69
Revise, 5
Sale/distribution, 42
Source Reduction, 68, 78
Stormwater Runoff, 52
Submit Paper Form R, 3
Surface Impoundments, 47
Technical Contact, 2, 7, 38, 87
Threshold Determinations, 26
Total Transfers, 53
Toxics Release Inventory Assistance Library
  (TRIAL), vii
Trade Secret, 3, 37, 86
TRI-ME, vii, 1, 2, 6, 37, 87
Underground Injection, 46, 59
Waste Treatment Codes, 64
Withdraw, 5, 6
                      Toxics Release Inventory Reporting Forms and Instructions
                                          87

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                             Table 1.NAICS Codes
1.1   NAICS codes that
       correspond to  SIC codes 20
       through 39:
 111998   All Other Miscellaneous Crop Farming
         (Limited to facilities primarily engaged in
         reducing maple sap to maple syrup)
 113310   Logging
 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
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                                    Table I. NAICS Codes
 311514   Dry, Condensed, and Evaporated Dairy
         Product Manufacturing
 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
31213   Wineries
1-2
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                                   Table I, NAICS Codes
 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

         Cigarette Manufacturing
 312221

 312229
 3131
1
         Other Tobacco Product Manufacturing
        (except for facilities primarily engaged in
        providing Tobacco Sheeting Services)
 313     Textile Mills
 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

313320    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

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)
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                                    Table I. NAICS Codes

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
3 1 5 1 92 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
3 15221 Men's and Boys' Cut and Sew Underwear and
Nightwear Manufacturing
3 15222 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)
3 15223 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
3 15225 Men's and Boys' Cut and Sew Work Clothing
Manufacturing

3 15228 Men's and Boys' Cut and Sew Other
Outerwear Manufacturing
31523 Women's and Girls' Cut and
Sew Apparel Manufacturing
3 1523 1 Women's and Girls' Cut and Sew Lingerie,
Loungewear, and Nightwear Manufacturing







































3 15232 Women's and Girls' Cut and Sew Blouse and
Shirt Manufacturing
3 15233 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)
3 15234 Women's and Girls' Cut and Sew Suit, Coat,
Tailored Jacket, and Skirt Manufacturing
3 15239 Women's and Girls' Cut and Sew Other
Outerwear Manufacturing
31529 Other Cut and Sew Apparel
Manufacturing
3 15291 Infants' Cut and Sew Apparel Manufacturing

3 1 5292 Fur and Leather Apparel Manufacturing
3 15299 All Other Cut and Sew Apparel Manufacturing
3159 Apparel Accessories and Other
Apparel Manufacturing
31599 Apparel Accessories and Other
Apparel Manufacturing
3 15991 Hat, Cap, and Millinery Manufacturing
3 15992 Glove and Mitten Manufacturing
3 15993 Men's and Boys' Neckwear Manufacturing
3 15999 Other Apparel Accessories and Other Apparel
Manufacturing
316 Leather and Allied Product
Manufacturing
3161 Leather and Hide Tanning and
Finishing
^5
31611 Leather and Hide Tanning and
Finishing

316110 Leather and Hide Tanning and Finishing

3162 Footwear Manufacturing
31621 Footwear Manufacturing
3 162 1 1 Rubber and Plastics Footwear Manufacturing
3 162 12 House Slipper Manufacturing
1-4
Toxics Release Inventory Reporting Form and Instructions

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                                  Table I, NAICS Codes
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
316999
Personal Leather Good (except Women's
Handbag and Purse) Manufacturing
All Other Leather Good and Allied Product
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
                                                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
                   Toxics Release Inventory Reporting Form and Instructions
                                                                                      1-5

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                                    Table I. NAICS Codes
 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 and
         Pouch 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    Printing and Related Support
         Activities
 3231   Printing and Related Support
         Activities
 32311  Printing
 323110   Commercial Lithographic Printing
 323 111   Commercial Gravure Printing
         Commercial Flexographic Printing
         Commercial Screen Printing
323112
323113
323114
         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)
                                                 323115   Digital Printing
                                                 323116   Manifold Business Forms Printing
                                                 323117   Books Printing
                                                 323118   Blankbook, Looseleaf Binders, and Devices
                                                          Manufacturing
                                                 323119   Other Commercial Printing
                                                 32312   Support Activities for Printing
                                                 323121   Tradebinding and Related Work
                                                 323122   Prepress Services
                                                 324     Petroleum and Coal Products
                                                          Manufacturing
                                                 3241    Petroleum and Coal Products
                                                          Manufacturing
                                                 32411   Petroleum Refineries
                                                 324110    Petroleum Refineries
                                                 32412   Asphalt Paving, Roofing, and
                                                          Saturated Materials
                                                          Manufacturing
                                                 324121    Asphalt Paving Mixture and Block
                                                          Manufacturing
                                                 324122    Asphalt Shingle and Coating Materials
                                                          Manufacturing
                                                 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
1-6
                   Toxics Release Inventory Reporting Form and Instructions

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                                 Table I, NAICS Codes
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
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
                  Toxics Release Inventory Reporting Form and Instructions
                                                                                   1-7

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                                  Table I. NAICS Codes
 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 and Pouch 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
                            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
1-8
Toxics Release Inventory Reporting Form and Instructions

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                                  Table I, NAICS Codes
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
32791  Abrasive Product
        Manufacturing
327910   Abrasive Product Manufacturing
32799  All Other Nonmetallic Mineral
        Product Manufacturing
327991   Cut Stone and Stone Product Manufacturing
327992   Ground or Treated Mineral and Earth
        Manufacturing
327993   Mineral Wool Manufacturing
327999   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
                   Toxics Release Inventory Reporting Form and Instructions
                                      1-9

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                                   Table I. NAICS Codes
 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
         Alumina Refining
         Primary Aluminum Production
331311
331312
331314
 331315
Secondary Smelting and Alloying of
Aluminum
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
         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
331421
331422
331423
         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
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
1-10
                   Toxics Release Inventory Reporting Form and Instructions

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                                 Table I, NAICS Codes
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
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
                  Toxics Release Inventory Reporting Form and Instructions
                                     1-11

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                                    Table I. NAICS Codes
 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
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
1-12
                   Toxics Release Inventory Reporting Form and Instructions

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                                    Table I, NAICS Codes
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
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
         Power-Driven Handtool Manufacturing
333991
333992

333993
333994

333995

333996
333997
333999
         Welding and Soldering Equipment
         Manufacturing
         Packaging Machinery Manufacturing
         Industrial Process Furnace and Oven
         Manufacturing
         Fluid Power Cylinder and Actuator
         Manufacturing
         Fluid Power Pump and Motor Manufacturing
         Scale and Balance Manufacturing
         All Other Miscellaneous General Purpose
         Machinery Manufacturing
                    Toxics Release Inventory Reporting Form and Instructions
                                       1-13

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                                    Table I. NAICS Codes

334 Computer and Electronic
Product Manufacturing
3341 Computer and Peripheral
Equipment Manufacturing
33411 Computer and Peripheral
Equipment Manufacturing
334111 Electronic Computer Manufacturing
334112 Computer Storage Device Manufacturing
334113 Computer Terminal Manufacturing
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
3343 10 Audio and Video Equipment Manufacturing
3344 Semiconductor and Other

Electronic Component
Manufacturing




































33441


334411
334412
334413
334414
334415
334416

334417
334418

334419

3345



33451
334510
334511


334512


334513

334514
334515

334516


334517
334518
Semiconductor and Other
Electronic Component
Manufacturing
Electron Tube Manufacturing
Bare Printed Circuit Board Manufacturing
Semiconductor and Related Device
Manufacturing
Electronic Capacitor Manufacturing
Electronic Resistor Manufacturing
Electronic Coil, Transformer, and Other
Inductor Manufacturing
Electronic Connector Manufacturing
Printed Circuit Assembly (Electronic
Assembly) Manufacturing
Other Electronic Component Manufacturing

Navigational, Measuring,
Electromedical, and Control
Instruments Manufacturing

Navigational, Measuring,
Electromedical, and Control
Instruments Manufacturing
Electromedical and Electrotherapeutic
Apparatus Manufacturing
Search, Detection, Navigation, Guidance,
Aeronautical, and Nautical System and
Instrument Manufacturing
Automatic Environmental Control
Manufacturing for Residential, Commercial,
and Appliance Use
Instruments and Related Products
Manufacturing for Measuring, Displaying, and
Controlling Industrial Process Variables
Totalizing Fluid Meter and Counting Device
Manufacturing
Instrument Manufacturing for Measuring and
Testing Electricity and Electrical Signals
Analytical Laboratory Instrument
Manufacturing

Irradiation Apparatus Manufacturing
Watch, Clock, and Part Manufacturing
1-14
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                                  Table I, NAICS Codes
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
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
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                                  Table I. NAICS Codes
 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 Pang, and Valve
         Manufacturing
 336312   Gasoline Engine and Engine Parts
         Manufacturing
                            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
                                    Aircraft Manufacturing
336411
336412
                                                       Aircraft Engine and Engine Parts
                                                       Manufacturing
1-16
Toxics Release Inventory Reporting Form and Instructions

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                                   Table I, NAICS Codes
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

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

3 3 7122    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)

3 3 7124    Metal Household Furniture Manufacturing

337125    Household Furniture (except Wood and Metal)
         Manufacturing

337127    Institutional Furniture Manufacturing

337129    Wood Television, Radio, and Sewing Machine
         Cabinet Manufacturing

3372    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

337920    Blind and Shade Manufacturing
339     Miscellaneous Manufacturing
3391    Medical Equipment and
         Supplies Manufacturing
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                                        Table I. NAICS Codes
 33911
 339112
 339113
 339114
 339115
 3399
 339911

 339912

 339913
 339941

 339942

 339943

 339944
         Medical Equipment and
         Supplies Manufacturing

         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

33994  Office Supplies (except Paper)
         Manufacturing

         Pen and Mechanical Pencil Manufacturing
         Lead Pencil and Art Good Manufacturing
         Marking Device Manufacturing
          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

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
1-18
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                                        Table I, NAICS Codes
 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)


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
           Internet Publishing and Broadcasting and
  519130   Web Search Portals (limited to facilities
           primarily engaged in Internet newspaper
           publishing, Internet periodical publishing,
           internet book publishing, Miscellaneous
           Internet publishing, Internet greeting card
           publishers except web search portals

  5417120  Research and Development in the Physical,
           Engineering, and Life Sciences except
           Biotechnology (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
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

221330     Steam and Air Conditioning Supply
           Limited to facilities engaged in providing
           combinations of electric, gas and other
           services, not elsewhere classified (NEC)
           (previously classified under SIC 4939,
           Combination Utility Services Not Elsewhere
           Classified.)
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                                                     Table II
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 et seq.)

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.)
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   Table II.  EPCRA Section 313 Chemical List For Reporting Year 2008
	(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.
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                               Table II, EPCRA Section 313 Chemical List - RY2008
  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 2008 calendar year
reporting. Some of the EPCRA Section 313 chemicals listed have
parenthetic qualifiers listed next to them.  An EPCRA Section 313
chemical that is listed without a qualifier is subject to reporting in all
forms in which it is manufactured, processed, and otherwise used.

Fume or dust.  Two of the metals on the list (aluminum and zinc)
contain the qualifier "fume or dust." Fume or dust refers to dry forms
of these metals but does not refer to "wet" forms such as solutions or
slurries. As explained in SectionB.S.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.
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,
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                              Table II, EPCRA Section 313 Chemical List- RY2008
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.
         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 Arranged
Alphabetically
 CAS Number   Chemical Name
                                      Deminimis
                                           Limit
 71751-41-2      Abamectin[AvermectinBl]             1.0
 30560-19-1      Acephate                              1.0
                 (Acetylphosphoramidothioic acid O,S-
                 dimethyl ester)
 75-07-0         Acetaldehyde                          0.1
 60-35-5         Acetamide                            0.1
 75-05-8         Acetonitrile                           1.0
 98-86-2         Acetophenone                         1.0
 53-96-3         2-Acetylaminofluorene                 0.1
 62476-59-9      Acifluorfen, sodium salt                1.0
                 [5-(2-Chloro-4-(trifluoromethyl)phenoxy)-2-
                 nitrobenzoic acid, sodium salt]
 107-02-8        Acrolein                              1.0
 79-06-1         Acrylamide                           0.1
 79-10-7         Acrylic acid                           1.0
 107-13-1 Acrylonitrile                                  0.1
 15972-60-8      Alachlor                              1.0
 116-06-3        Aldicarb                              1.0
 309-00-2        Aldrin                                 *
                 [l,4:5,8-Dimethanonaphthalene,
                 l,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a-
                 hexahydro-(l.alpha.,4.alpha.,4a.beta.,
                 5.alpha.,8.alpha.,8a.beta.)-]
 28057-48-9      d-trans-Allethrin                       1.0
                 [d-trans-Chrysanthemic acid of d-allethrone]
 107-18-6        Allyl alcohol
 107-11-9        Allylamine
 107-05-1        Allyl chloride
 7429-90-5       Aluminum (fume or dust)
 20859-73-8      Aluminum phosphide
 1344-28-1       Aluminum oxide (fibrous forms)
 834-12-8        Ametryn                              1.0
                 (N-Ethyl-N=-( 1 -methylethyl)-6-
                 (methylthio)-l,3,5,-triazine-2,4-diamine)
 117-79-3        2-Aminoanthraquinone                 0.1
 60-09-3         4-Aminoazobenzene                   0.1
 92-67-1         4-Aminobiphenyl                      0.1
 82-28-0         l-Amino-2-methylanthraquinone         0.1
 33089-61-1      Amitraz                               1.0
                                                       CAS Number   Chemical Name
                                              Deminimis
                                                   Limit
61-82-5         Amitrole                             0.1
7664-41-7       Ammonia                            1.0
                (includes anhydrous ammonia and aqueous
                ammonia from water dissociable ammonium
                salts and other sources; 10 percent of total
                aqueous ammonia is reportable under this
                listing)
101-05-3        Anilazine                             1.0
                [4,6-Dichloro-N-(2-chlorophenyl)-l,3,5-
                triazin-2 -amine]
62-53-3         Aniline                               1.0
90-04-0         o-Anisidine                           0.1
104-94-9        p-Anisidine                           1.0
134-29-2        o-Anisidine hydrochloride              0.1
120-12-7        Anthracene                           1.0
7440-36-0       Antimony                            1.0
7440-38-2       Arsenic                              0.1
1332-21-4       Asbestos (friable)                     0.1
1912-24-9       Atrazine                             1.0
                (6-Chloro-N-ethyl-N=-( 1 -methylethyl)-
                l,3,5-triazine-2,4-diamine)
7440-39-3       Barium                              1.0
22781-23-3      Bendiocarb                           1.0
                [2,2-Dimethyl-l,3-benzodioxol-4-ol
                methylcarbamate]
1861-40-1       Benfluralin                           1.0
                (N-Butyl-N-ethyl-2,6-dinitro-4-
                (trifluoromethyl)benzenamine)
17804-35-2      Benomyl                             1.0
98-87-3         Benzal chloride                       1.0
55-21-0         Benzamide                           1.0
71-43-2         Benzene                             0.1
92-87-5         Benzidine                            0.1
98-07-7         Benzoic trichloride                    0.1
                (Benzotrichloride)
191-24-2        Benzo(g,h,i)perylene                     *
98-88-4         Benzoyl chloride                      1.0
94-36-0         Benzoyl peroxide                     1.0
100-44-7        Benzyl chloride                       1.0
7440-41-7       Beryllium                            0.1
82657-04-3      Bifenthrin                            1.0
92-52-4         Biphenyl                             1.0
111-91-1        Bis(2-chloroethoxy) methane           1.0
111-44-4        Bis(2-chloroethyl) ether                1.0
542-88-1        Bis(chloromethyl) ether                0.1
108-60-1        Bis(2-chloro-l-methylethyl)ether       1.0
56-35-9         Bis(tributyltin) oxide                   1.0
10294-34-5      Boron trichloride                      1.0
7637-07-2       Boron trifluoride                      1.0
314-40-9        Bromacil                             1.0
                (5-Bromo-6-methyl-3 -(1 -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
                            Toxics Release Inventory Reporting Form and Instructions
                                                                                                       II-3

-------
  Table II, EPCRA Section 313 Chemical List- RY2008


CAS Number

353-59-3

75-25-2
74-83-9

75-63-8

1689-84-5

1689-99-2


357-57-3
106-99-0
141-32-2
71-36-3
78-92-2
75-65-0
106-88-7
123-72-8
7440-43-9
156-62-7
133-06-2


63-25-2

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


120-80-9
2439-01-2


133-90-4

57-74-9


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


Deminimis
Chemical Name
1 , 3 -propanedicarbonitrile
Bromochlorodifluoromethane
(Halonl211)
Bromoform (Tribromomethane)
Bromomethane
(Methyl bromide)
Bromotrifluoromethane
(Halon 1301)
Bromoxynil
(3,5-Dibromo-4-hydroxybenzonitrile)
Bromoxynil octanoate
(Octanoic acid, 2,6-dibromo-4-
cyanophenylester)
Brucine
1,3 -Butadiene
Butyl acrylate
n-Butyl alcohol
sec-Butyl alcohol
tert-Butyl alcohol
1,2-Butylene oxide
Butyraldehyde
Cadmium
Calcium cyanamide
Captan
Limit

1.0

1.0
1.0

1.0

1.0

1.0


1.0
0.1
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
[lH-Isoindole-l,3(2H)-dione, 3a,4,7,7a-
tetrahydro-2-[(trichloromethyl)thio]-]
Carbaryl [1-Naphthalenol,
methylcarbamate]
Carbofuran
Carbon disulfide
Carbon tetrachloride
Carbonyl sulfide
Carboxin
(5,6-Dihydro-2-methyl-N-
phenyl- 1 ,4-oxathiin-3 -carboxamide)
Catechol
Chinomethionat

1.0

1.0
1.0
0.1
1.0
1.0


0.1
1.0
[6-Methyl-l,3-dithiolo[4,5-b]quinoxalin-2-
one]
Chloramben
[Benzoic acid, 3-amino-2,5-dichloro-]
Chlordane
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-hexahydro-]
Chlorendic acid
Chlorimuron ethyl

1.0

*


0.1
1.0
[Ethyl-2-[[[[(4-chloro-6-methoxyprimidin-2-
yl)amino] carbonyl] amino] sulfonyl]
benzoate]
Chlorine
Chlorine dioxide
Chloroacetic acid
2-Chloroacetophenone
1 -(3 -Chloroallyl)-3 , 5 ,7-triaza-
1-azoniaadamantane chloride
p-Chloroaniline
Chlorobenzene


.0
.0
.0
.0
.0

0.1
1.0































































Deminimis
CAS Number
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


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
Chemical Name
Chlorobenzilate
[Benzeneacetic acid, 4-chloro-.alpha.-
chlorophenyl)-.alpha.-hydroxy-, ethyl
1-Chloro-l, 1-difluoroethane
(HCFC-142b)
Chlorodifluoromethane
(HCFC-22)
Chloroethane (Ethyl chloride)
Chloroform
Chloromethane (Methyl chloride)
Chloromethyl methyl ether
3 -Chloro-2 -methyl- 1 -propene
p-Chlorophenyl isocyanate
Chloropicrin
Chloroprene
3 -Chloropropionitrile
Chlorotetrafluoroethane
1-Chloro-l, 1,2,2-
tetrafluoroethane (HCFC-124a)
2-Chloro-l, 1,1,2-
tetrafluoroethane (HCFC-124)
Chlorothalonil
[1,3-Benzenedicarbonitrile, 2,4,5,6-
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-Dimethyl-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.I. Direct Black 38
C.I. Direct Blue 6
C.I. Direct Blue 2 18
C.I. Direct Brown 95
C.I. Disperse Yellow 3
C.I. Food Red 5
C.I. Food Red 15
C.I. Solvent Orange 7
C.I. Solvent Yellow 3
C.I. Solvent Yellow 14
C.I. Solvent Yellow 34
(Auramine)
C.I. Vat Yellow 4
Cobalt
Copper
Limit
1.0
(4-
ester]
1.0

1.0


0.1
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0

1.0

0.1



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
1.0
1.0
0.1
1.0
0.1

1.0

1.0

Toxics Release Inventory Reporting Form and Instructions
II-4

-------
  Table II, EPCRA Section 313 Chemical List- RY2008


CAS Number
8001-58-9
120-71-8
108-39-4
95-48-7
106-44-5
1319-77-3
4170-30-3
98-82-8
80-15-9
135-20-6


21725-46-2
1134-23-2
110-82-7
108-93-0
68359-37-5




68085-85-8



94-75-7

533-74-4


53404-60-7


94-82-6
1929-73-3
94-80-4
2971-38-2
1163-19-5
13684-56-5
1928-43-4
53404-37-8

2303-16-4


615-05-4
39156-41-7
101-80-4
95-80-7
25376-45-8
333-41-5
334-88-3
132-64-9
96-12-8

106-93-4


Deminimis
Chemical Name Limit
Creosote 0.1
p-Cresidine 0.1
m-Cresol .0
o-Cresol .0
p-Cresol .0
Cresol (mixed isomers) .0
Crotonaldehyde .0
Cumene .0
Cumene hydroperoxide .0
Cupferron 0.1
[Benzeneamine, N-hydroxy-
N-nitroso, ammonium salt]
Cyanazine 1.0
Cycloate 1.0
Cyclohexane 1.0
Cyclohexanol 1.0
Cyfluthrin
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid,
cyano(4-fluoro-3 -phenoxyphenyl) methyl
ester]
Cyhalothrin 1.0
[3 -(2-Chloro-3 ,3 ,3 -trifluoro- 1 -propenyl)-
2,2-dimethylcyclopropane-carboxyric acid
cyano(3 -phenoxyphenyl)methyl ester]
2,4-D
[Acetic acid, (2,4-dichlorophenoxy)-]
Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione)
Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione, ion(l-), sodium]
2,4-DB 1.0
2,4-D butoxyethyl ester 0. 1
2,4-D butyl ester 0.1
2,4-D chlorocrotyl ester 0.1
Decabromodiphenyl oxide 1.0
Desmedipham 1.0
2,4-D 2-ethylhexyl ester 0. 1
2,4-D 2-ethyl-4- 0.1
methylpentyl ester
Diallate 1.0
[Carbamothioic acid, bis(l-methylethyl)-S-
(2,3-dichloro-2-propenyl) ester]
2,4-Diaminoanisole 0.1
2,4-Diaminoanisole sulfate 0.1
4,4'-Diaminodiphenyl ether 0.1
2,4-Diaminotoluene 0.1
Diaminotoluene (mixed isomers) 0. 1
Diazinon 1.0
Diazomethane 1.0
Dibenzofuran 1.0
l,2-Dibromo-3-
chloropropane (DBCP)
1,2-Dibromoethane 0.1
(Ethylene dibromide)






























































Deminimis
CAS Number
124-73-2

84-74-2
1918-00-9

99-30-9

95-50-1
541-73-1
106-46-7
25321-22-6
91-94-1
612-83-9

64969-34-2
75-27-4
764-41-0
110-57-6
1649-08-7

75-71-8
107-06-2

540-59-0
1717-00-6

75-43-4
75-09-2

127564-92-5
13474-88-9

111512-56-2

422-44-6

431-86-7

507-55-1

136013-79-1

128903-21-9

422-48-0

422-56-0

97-23-4

120-83-2
78-87-5
10061-02-6
78-88-6
542-75-6
76-14-2

Chemical Name
Dibromotetrafluoroethane
(Halon 2402)
Dibutyl phthalate
Dicamba
(3,6-Dichloro-2-methoxybenzoic acid)
Dichloran
[2,6-Dichloro-4-nitroaniline]
1 ,2-Dichlorobenzene
1 ,3 -Dichlorobenzene
1 ,4-Dichlorobenzene
Dichlorobenzene (mixed isomers)
3 ,3 '-Dichlorobenzidine
3 ,3 '-Dichlorobenzidine
dihydrochloride
3, 3 '-Dichlorobenzidine sulfate
Dichlorobromomethane
1 ,4-Dichloro-2-butene
trans- 1 ,4-Dichloro-2-butene
1,2-Dichloro-l, 1-
difluoroethane (HCFC-132b)
Dichlorodifluoromethane (CFC-12)
1,2-Dichloroethane (Ethylene
dichloride)
1 ,2-Dichloroethylene
1 , 1 -Dichloro- 1 -fluoroethane
(HCFC-141b)
Dichlorofluoromethane (HCFC-21)
Dichloromethane (Methylene
chloride)
Dichloropentafluoropropane
l,l-Dichloro-l,2,2,3,3-
pentafluoropropane (HCFC-225cc)
l,l-Dichloro-l,2,3,3,3-
pentafluoropropane (HCFC-225eb)
1,2-Dichloro-l, 1,2,3,3-
pentafluoropropane (HCFC-225bb)
1,2-Dichloro-l, 1,3,3,3-
pentafluoropropane (HCFC-225da)
1,3-Dichloro-l, 1,2,2,3-
pentafluoropropane (HCFC-225cb)
1,3-Dichloro-l, 1,2,3,3-
pentafluoropropane (HCFC-225ea)
2,2-Dichloro-l, 1,1,3,3-
pentafluoropropane (HCFC-225aa)
2,3-Dichloro-l, 1,1,2,3-
pentafluoropropane (HCFC-225ba)
3,3-Dichloro-l, 1,1,2,2-
pentafluoropropane (HCFC-225ca)
Dichlorophene
[2,2'-Methylenebis(4-chlorophenol)]
2,4-Dichlorophenol
1 ,2-Dichloropropane
trans- 1 , 3 -Dichloropropene
2,3 -Dichloropropene
1 ,3 -Dichloropropylene
Dichlorotetrafluoroethane
(CFC-114)
Limit
1.0

1.0
1.0

1.0

1.0
1.0
0.
0.
0.
0.

0.
0.
1.0
1.0
1.0

1.0
0.1

1.0
1.0

1.0
0.1

1.0
1.0

1.0

1.0

1.0

1.0

1.0

1.0



1.0

1.0

1.0
1.0
0.1
1.0
0.1
1.0

Toxics Release Inventory Reporting Form and Instructions
II-5

-------
  Table II, EPCRA Section 313 Chemical List- RY2008


CAS Number
34077-87-7
90454-18-5
812-04-4

354-23-4

306-83-2

62-73-7


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

124-40-3
2300-66-5
60-11-7
121-69-7
119-93-7
612-82-8


41766-75-0

79-44-7
2524-03-0

68-12-2
57-14-7
105-67-9
131-11-3
77-78-1
99-65-0
528-29-0
100-25-4
88-85-7


Deminimis
Chemical Name
Dichlorotrifluoroethane
Dichloro- 1 , 1 ,2-trifluoroethane
1,1-Dichloro- 1,2,2-
trifluoroethane (HCFC-123b)
1,2-Dichloro- 1,1,2-
trifluoroethane (HCFC-123a)
2,2-Dichloro- 1,1,1 -
trifluoroethane (HCFC-123)
Dichlorvos
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
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
Limit
1.0
1.0
1.0

1.0

1.0

0.1


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)
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)
Dimethylcarbamyl chloride
Dimethyl
chlorothiophosphate
N,N-Dimethylformamide
1 , 1 -Dimethyl hydrazine
2,4-Dimethylphenol
Dimethyl phthalate
Dimethyl sulfate
m-Dinitrobenzene
o-Dinitrobenzene
p-Dinitrobenzene
Dinitrobutyl phenol (Dinoseb)
0.1
1.0

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































































Deminimis
CAS Number
534-52-1
51-28-5
121-14-2
606-20-2
25321-14-6
39300-45-3
123-91-1
957-51-7
122-39-4
122-66-7

2164-07-0


136-45-8
138-93-2

94-11-1
541-53-7
330-54-1
2439-10-3

120-36-5
1320-18-9

2702-72-9
106-89-8
13194-48-4


110-80-5
140-88-5
100-41-4
541-41-3
759-94-4

74-85-1
107-21-1
151-56-4
75-21-8
96-45-7
75-34-3
52-85-7
60168-88-9


13356-08-6


66441-23-4



72490-01-8
Chemical Name Limit
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Dinitrotoluene (mixed isomers)
Dinocap
1,4-Dioxane
Diphenamid
Diphenylamine
1 ,2-Diphenylhydrazine
(Hydrazobenzene)
Dipotassium endothall
[7-Oxabicyclo(2.2. l)heptane-2,3-
dicarboxylic acid, dipotassium salt]
Dipropyl isocinchomeronate
Disodium
cyanodithioimidocarbonate
2,4-D isopropyl ester
2,4-Dithiobiuret
Diuron
Dodine [Dodecylguanidine
monoacetate]
2,4-DP
2,4-D propylene glycol
butyl ether ester
2,4-D sodium salt
Epichlorohydrin
Ethoprop
[Phosphorodithioic acid O-ethyl S,S-
dipropyl ester]
2-Ethoxyethanol
Ethyl acrylate
Ethylbenzene
Ethyl chloroformate
Ethyl dipropylthiocarbamate
(EPTC)
1.0
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
0.1

1.0


1.0
1.0

0.1
1.0
1.0
1.0

0.1
0.1

0.1
0.1
1.0


1.0
0.1
0.1
1.0
1.0

Ethylene
Ethylene glycol
Ethyleneimine (Aziridine)
Ethylene oxide
Ethylene thiourea
Ethylidene dichloride
Famphur
Fenarimol
[.alpha.-(2-Chlorophenyl)-.alpha.-(4-
chlorophenyl)-5-pyrimidinemethanol]
Fenbutatin oxide
(Hexakis(2-methyl-2-phenylpropyl)
distannoxane)
Fenoxaprop ethyl
[2-(4-((6-Chloro-2-
benzoxazolylen)oxy)phenoxy)propanoic
acid, ethyl ester]
Fenoxycarb
1.0
0.1
0.1
0.1
1.0
1.0
1.0


1.0


1.0



1.0
[[2-(4-Phenoxyphenoxy)ethyl]carbamic acid

39515-41-8
ethyl ester]
Fenpropathrin

1.0

Toxics Release Inventory Reporting Form and Instructions
II-6

-------
                              Table II, EPCRA Section 313 Chemical List- RY2008
 CAS Number   Chemical Name
Deminimis
     Limit
                 [2,2,3,3 -Tetramethylcyclopropane
                 carboxylic acid cyano(3-
                 phenoxyphenyl)methyl ester]
 55-38-9         Fenthion                              1.0
                 [O,O-Dimethyl O-[3-methyl-4-
                 (methylthio)phenyl] ester, phosphorothioic
                 acid]
 51630-58-1      Fenvalerate                            1.0
                 [4-Chloro-alpha-( 1 -methylethyl)
                 benzeneacetic acid cyano (3-phenoxyphenyl)
                 methyl ester]
 14484-64-1      Ferbam                               1.0
                 [Tris(dimethylcarbamodithioato- S,S')iron]
 69806-50-4      Fluazifop butyl                        1.0
                 [2-[4-[[5-(Trifluoromethyl)-2-
                 pyridinyl]oxy]phenoxy]propanoic acid, butyl
                 ester]
 2164-17-2       Fruometuron                           1.0
                 [Urea, N,N-dimethyl-N=-[3-
                 (trifluoromethyl)phenyi] -]
 7782-41-4       Fluorine                               1.0
 51-21-8         Fluorouracil (5-Fluorouracil)            1.0
 69409-94-5      Fluvalinate                            1.0
                 [N-[2-Chloro-4-(trifluoromethyl)phenyl]-
                 DL-valine(+)-cyano(3 -
                 phenoxyphenyl)methyl ester]
 133-07-3        Folpet                                 1.0
 72178-02-0      Fomesafen                            1.0
                 [5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
                 N-methylsulfonyl-2-nitrobenzamide]
 50-00-0         Formaldehyde                          0.1
 64-18-6         Formic acid                           1.0
 76-13-1         FreonllS                             1.0
                 [Ethane, 1, 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
 70-30-4         Hexachlorophene
 680-31-9        Hexamethylphosphoramide
 110-54-3        n-Hexane
 51235-04-2      Hexazinone
 67485-29-4      Hydramethylnon
                 [Tetrahydro-5,5-dimethyl-2(lH)-
                 pyrimidinone [3 -[4-(trifluoromethyl)phenyl] -
                 l-[2-[4-(trifluoromethyl)phenyl]ethenyl]-2-
                 propenylidene] hydrazone]
 302-01-2        Hydrazine                             0.1
 10034-93-2      Hydrazine sulfate                      0.1
 7647-01-0       Hydrochloric acid                      1.0
                 (acid aerosols including mists, vapors, gas,
	fog, and other airborne forms of any particle
CAS Number   Chemical Name
Deminimis
     Limit
                  74-90-8
                  7664-39-3
                  123-31-9
                  35554-44-0
                  55406-53-6

                  13463-40-6
                  78-84-2
                  465-73-6
                  25311-71-1
                  67-63-0
                  80-05-7
                  120-58-1
                  77501-63-4
                  7439-92-1
                  58-89-9
                  330-55-2
                  554-13-2
                  121-75-5
                  108-31-6
                  109-77-3
                  12427-38-2
                  7439-96-5
                  93-65-2
                  149-30-4
                  7439.97-6
                  150-50-5
                  126-98-7
                  137-42-8

                  67-56-1
                  20354-26-1
                  2032-65-7
                  94-74-6
                size)
                Hydrogen cyanide                      1.0
                Hydrogen fluoride                      1.0
                Hydroquinone                         1.0
                Imazalil                               1.0
                [l-[2-(2,4-Dichlorophenyl)-2-(2-
                propenyloxy)ethyl]-lH-imidazole]
                3-Iodo-2-propynyl                      1.0
                butylcarbamate
                Iron pentacarbonyl                     1.0
                Isobutyraldehyde                       1.0
                Isodrin                                 *
                Isofenphos[2-[[Ethoxyl[(l-              1.0
                methylethyl)amino]phosphinothioyl]oxy]
                benzoic acid 1-methylethyl ester]
                Isopropyl alcohol                       1.0
                (only persons who manufacture by the strong
                acid process are subject, no supplier
                notification)
                4,4'-Isopropylidenediphenol             1.0
                Isosafrole                             1.0
                Lactofen                              1.0
                [Benzoic acid, 5-[2-Chloro-4-
                (trifluoromethyl)phenoxy] -2-nitro-, 2-
                ethoxy-l-methyl-2-oxoethyl ester]
                Lead                                   *
                (when lead is contained in stainless steel,
                brass or bronze alloys the de minimis level is
                0.1)
                Lindane                               0.1
                [Cyclohexane, 1,2,3,4,5,6-hexachloro-,
                (l.alpha.,2.alpha.,3.beta.,4.alpha.,5.alpha.,
                6.beta.)-]
                Linuron                               1.0
                Lithium carbonate                      1.0
                Malathion                             1.0
                Maleic anhydride                       1.0
                Malononitrile                          1.0
                Maneb                                1.0
                [Carbamodithioic acid,  1,2-ethanediylbis-,
                manganese complex]
                Manganese                            1.0
                Mecoprop                             0.1
                2-Mercaptobenzothiazole (MET)         1.0
                Mercury                                *
                Merphos                              1.0
                Methacrylonitrile                       1.0
                Metham sodium (Sodium                1.0
                methyldithiocarbamate)
                Methanol                             1.0
                Methazole                             1.0
                [2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
                oxadiazolidine-3,5-dione]
                Methiocarb                            1.0
                Methoxone                            0.1
                ((4-Chloro-2-methylphenoxy) acetic acid)
                (MCPA)	
                           Toxics Release Inventory Reporting Form and Instructions
                                                                  II-7

-------
  Table II, EPCRA Section 313 Chemical List- RY2008


CAS Number
3653-48-3


72-43-5


109-86-4
96-33-3
1634-04-4
79-22-1
101-14-4

101-61-1

74-95-3
101-77-9
60-34-4
74-88-4
108-10-1
624-83-9
556-61-6

75-86-5
80-62-6
924-42-5
298-00-0
109-06-8
872-50-4
9006-42-2
21087-64-9
7786-34-7
90-94-8
2212-67-1


1313-27-5
76-15-3

150-68-5
505-60-2

88671-89-0


142-59-6
300-76-5
91-20-3
134-32-7
91-59-8
7440-02-0
1929-82-4

7697-37-2
139-13-9
100-01-6
99-59-2
98-95-3


Deminimis
Chemical Name
Methoxone sodium salt
((4-Chloro-2-methylphenoxy) acetate
sodium salt)
Methoxychlor
[Benzene, 1,1 '-(2,2,2-
trichloroethylidene)bis[4-methoxy-]
2-Methoxyethanol
Methyl acrylate
Methyl tert-butyl ether
Methyl chlorocarbonate
4,4'-Methylenebis(2-chloroaniline)
(MBOCA)
4,4'-Methylenebis(N,N-dimethyl)
benzenamine
Methylene bromide
4,4'-Methylenedianiline
Methyl hydrazine
Methyl iodide
Methyl isobutyl ketone
Methyl isocyanate
Methyl isothiocyanate
[Isothiocyanatomethane]
2-Methyllactonitrile
Methyl methacrylate
N-Methylolacrylamide
Methyl parathion
2-Methylpyridine
N-Methyl-2-pyrrolidone
Metiram
Metribuzin
Mevinphos
Michler's ketone
Molinate
Limit
0.1


*


1.0
1.0
1.0
1.0
0.1

0.1

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

.0
.0
.0
.0
.0
.0
.0
.0
.0
0.1
1.0
(IH-Azepine-l-carbothioic acid, hexahydro-
, S-ethyl ester)
Molybdenum trioxide
Monochloropentafluoroethane
(CFC-115)
Monuron
Mustard gas
[Ethane, 1 , 1 '-thiobis[2-chloro-]
Myclobutanil

1.0
1.0

1.0
0.1

1.0
[.alpha.-Butyl-.alpha.-(4-chlorophenyl)-lH-
1,2,4-triazole-l-propanenitrile]
Nabam
Naled
Naphthalene
alpha-Naphthylamine
beta-Naphthylamine
Nickel
Nitrapyrin
(2-Chloro-6-(trichloromethyl)pyridine)
Nitric acid
Nitrilotriacetic acid
p-Nitroaniline
5-Nitro-o-anisidine
Nitrobenzene

1.0
1.0
0.1
0.1
0.1
0.1
1.0

1.0
0.1
1.0
1.0
0.1































































Deminimis
CAS Number
92-93-3
1836-75-5
Chemical Name Limit
4-Nitrobiphenyl
Nitrofen
0.1
0.1
[Benzene, 2,4-dichloro-l-(4-nitrophenoxy)-
51-75-2


55-63-0
88-75-5
100-02-7
79-46-9
924-16-3
55-18-5
62-75-9
86-30-6
156-10-5
621-64-7
759-73-9
684-93-5
4549-40-0
59-89-2
16543-55-8
100-75-4
99-55-8
27314-13-2



2234-13-1
29082-74-4
19044-88-3


20816-12-0
301-12-2


19666-30-9


Nitrogen mustard
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
Nitroglycerin
2-Nitrophenol
4-Nitrophenol
2-Nitropropane
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
p-Nitrosodiphenylamine
N-Nitrosodi-n-propylamine
N-Nitroso-N-ethylurea
N-Nitro so -N-methy lurea
N-Nitrosomethylvinylamine
N-Nitrosomorpholine
N-Nitrosonornicotine
N-Nitrosopiperidine
5-Nitro-o-toluidine
Norflurazon
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)phenyl] -3 (2H)-
pyridazinone]
Octachloronaphthalene
Octachlorostyrene
Oryzalin
[4-(Dipropylamino)-3,5-dinitrobenzene
sulfonamide]
Osmium tetroxide
Oxydemeton methyl
[S-(2-(Ethylsulfmyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
Oxydiazon
[3-[2,4-Dichloro-5-(l-
methylethoxy)phenyl]- 5 -(1,1-
0.1


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



1.0
*
1.0


1.0
1.0


1.0


dimethylethyl)- 1 ,3 ,4-oxadiazol-2(3H)-one]
42874-03-3
10028-15-6
123-63-7
1910-42-5
56-38-2


1114-71-2


40487-42-1


608-93-5
76-01-7
87-86-5
57-33-0
Oxyfluorfen
Ozone
Paraldehyde
Paraquat dichloride
Parathion
[Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl)ester]
Pebulate
[Butylethylcarbamothioic acid S-propyl
ester]
Pendimethalin
[N-( 1 -Ethylpropyl)-3 ,4-dimethyl-2,6-
dinitrobenzenamine]
Pentachlorobenzene
Pentachloroethane
Pentachlorophenol (PCP)
Pentobarbital sodium
1.0
1.0
1.0
1.0
1.0


1.0


*


*
1.0
0.1
1.0

Toxics Release Inventory Reporting Form and Instructions
II-8

-------
                              Table II, EPCRA Section 313 Chemical List- RY2008
 CAS Number   Chemical Name
Deminimis
     Limit
 79-21-0         Peracetic acid                          1.0
 594-42-3        Perchloromethyl mercaptan             1.0
 52645-53-1      Permethrin                            1.0
                 [3-(2,2-Dichloroethenyl)-2,2-
                 dimethylcyclopropanecarboxylic acid, (3-
                 phenoxyphenyl) methyl ester]
 85-01-8         Phenanthrene                          1.0
 108-95-2        Phenol                                1.0
 26002-80-2      Phenothrin                            1.0
                 [2,2-Dimethyl-3 -(2-methyl-1 -
                 propenyl)cyclopropanecarboxylic acid (3-
                 phenoxyphenyl)methyl ester]
 95-54-5         1,2-Phenylenediamine                  1.0
 108-45-2        1,3-Phenylenediamine                  1.0
 106-50-3        p-Phenylenediamine                    1.0
 615-28-1        1,2-Phenylenediamine dihydro-          1.0
                 chloride
 624-18-0        1,4-Phenylenediamine dihydro-          1.0
                 chloride
 90-43-7         2-Phenylphenol                        1.0
 57-41-0         Phenytoin                             0.1
 75-44-5         Phosgene                              1.0
 7803-51-2       Phosphine                             1.0
 7723-14-0       Phosphorus (yellow or white)            1.0
 85-44-9         Phthalic anhydride                     1.0
 1918-02-1       Picloram                              1.0
 88-89-1         Picric acid                             1.0
 51-03-6         Piperonyl butoxide                     1.0
 29232-93-7      Pirimiphos methyl                      1.0
                 [O-(2-(Diethylamino)-6-methyl-4-
                 pyrimidinyl)-O,O-
                 dimethylphosphorothioate]
 1336-36-3       Polychlorinated biphenyls                *
                 (PCBs)
 7758-01-2       Potassium bromate                     0.1
 128-03-0        Potassium dimethyldithio-               1.0
                 carbamate
 137-41-7        Potassium N-methyldithio-              1.0
                 carbamate
 41198-08-7      Profenofos                             1.0
                 [O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
                 propyl phosphorothioate]
 7287-19-6       Prometryn                             1.0
                 [N,N'-Bis(l-methylethyl)-6-methylthio-
                 l,3,5-triazine-2,4-diamine]
 23950-58-5      Pronamide                             1.0
 1918-16-7       Propachlor                            1.0
                 [2-Chloro-N-( 1 -methylethyl)-N-
                 phenylacetamide]
 1120-71-4       Propane sultone                        0.1
 709-98-8        Propanil                               1.0
                 [N-(3,4-Dichlorophenyl)propanamide]
 2312-35-8       Propargite                             1.0
 107-19-7        Propargyl alcohol                      1.0
 31218-83-4      Propetamphos                          1.0
                 [3-[(Ethylamino)methoxyphosphinothioyl]
	oxy]-2-butenoic acid, 1-methylethyl ester]
CAS Number   Chemical Name
Deminimis
     Limit
                  60207-90-1      Propiconazole                         1.0
                                  [l-[2-(2,4-Dichlorophenyl)-4-propyl-l,3-
                                  dioxolan-2-yl]-methyl-lH-1,2,4,-triazole]
                  57-57-8         beta-Propiolactone                     0.1
                  123-38-6        Propionaldehyde                       1.0
                  114-26-1        Propoxur                              1.0
                                  [Phenol, 2-(l-methylethoxy)-,
                                  methylcarbamate]
                  115-07-1        Propylene (Propene)                    1.0
                  75-55-8         Propyleneimine                        0.1
                  75-56-9         Propylene oxide                        0.1
                  110-86-1        Pyridine                               1.0
                  91-22-5         Quinoline                             1.0
                  106-51-4        Quinone                               1.0
                  82-68-8         Quintozene                            1.0
                                  (Pentachloronitrobenzene)
                  76578-14-8      Quizalofop-ethyl                       1.0
                                  [2-[4-[(6-Chloro-2-
                                  quinoxalinyl)oxy]phenoxy] propanoic acid
                                  ethyl ester]
                  10453-86-8      Resmethrin                            1.0
                                  [[5-(Phenylmethyl)-3-furanyl]methyl-2,2-
                                  dimethyl-3 -(2-methyl-1 -propenyl)
                                  cyclopropanecarboxylate]
                  81 -07-2         Saccharin (only persons who             1.0
                                  manufacture are subject, no supplier
                                  notification)
                  94.59.7         Safrole                                0.1
                  7782-49-2       Selenium                              1.0
                  74051-80-2      Sethoxydim                           1.0
                                  [2-[ 1 -(Ethoxyimino)butyl] -5-[2-
                                  (ethylthio)propyl] -3 -hydroxyl-2-cyclohexen-
                                  1-one]
                  7440-22-4       Silver                                 1.0
                  122-34-9        Simazine                              1.0
                  26628-22-8      Sodium azide                          1.0
                  1982-69-0       Sodium dicamba                       1.0
                                  [3,6-Dichloro-2-methoxybenzoic acid,
                                  sodium salt]
                  128-04-1        Sodium dimethyldithiocarbamate
                  62-74-8         Sodium fluoroacetate                   1.0
                  7632-00-0       Sodium nitrite                         1.0
                  131-52-2        Sodium pentachlorophenate             1.0
                  132-27-4        Sodium o-phenylphenoxide             0.1
                  100-42-5        Styrene                                0.1
                  96-09-3         Styrene oxide                          0.1
                  7664-93-9       Sulfuric acid                          1.0
                                  (acid aerosols including mists, vapors, gas,
                                  fog, and other airborne forms of any particle
                                  size)
                  2699-79-8       Sulfuryl fluoride  (Vikane)               1.0
                  35400-43-2      Sulprofos                              1.0
                                  [O-Ethyl O-[4-(methylthio)phenyl]
                                  phosphorodithioic acid S-propylester]
                  34014-18-1      Tebuthiuron                           1.0
                                  [N-[5-(l,l-Dimethylethyl)-l,3,4-thiadiazol-
                 	2-yl]-N,N'-dimethylurea]	
                           Toxics Release Inventory Reporting Form and Instructions
                                                                  II-9

-------
                              Table II, EPCRA Section 313 Chemical List- RY2008
 CAS Number   Chemical Name
Deminimis
     Limit
 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-1 -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)- IH-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
                 [[ 1,2-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
                 [l-(4-Chlorophenoxy)-3,3-di-methyl-l-(lH-
                 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-
CAS Number   Chemical Name
Deminimis
     Limit
                                  yl)-methylamino] -carbonyl] amino] 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-ll)       1.0
                  95-95-4         2,4,5-Trichlorophenol                  1.0
                  88-06-2         2,4,6-Trichlorophenol                  0.1
                  96-18-4         1,2,3-Trichloropropane                 0.1
                  57213-69-1      Triclopyr triethylammonium salt         1.0
                  121-44-8        Triethylamine                         1.0
                  1582-09-8       Trifluralin                               *
                                  [Benezeneamine, 2,6-dinitro-N,N-dipropyl-
                                  4-(trifluoromethyl)-]
                  26644-46-2      Triforine                              1.0
                                  [N,N'-[l,4-Piperazinediylbis-(2,2,2-
                                  trichloroethylidene)]bisformamide]
                  95-63-6         1,2,4-Trimethylbenzene                1.0
                  2655-15-4       2,3,5-Trimethylphenyl                  1.0
                                  methylcarbamate
                  639-58-7        Triphenyltin chloride                   1.0
                  76-87-9          Triphenyltin hydroxide                1.0
                  126-72-7        Tris(2,3-dibromopropyl)                0.1
                                  phosphate
                  72-57-1         Trypanblue                           0.1
                  51-79-6         Urethane (Ethyl carbamate)             0.1
                  7440-62-2       Vanadium (except when contained       1.0
                                  in an alloy)
                  50471-44-8      Vinclozolin                           1.0
                                  [3 -(3,5 -Dichlorophenyl)-5 -ethenyl-5 -methyl-
                                  2,4-oxazolidinedione]
                  108-05-4        Vinyl acetate                          0.1
                  593-60-2        Vinyl bromide                         0.1
                  75-01-4         Vinyl chloride                         0.1
                  75-35-4         Vinylidene chloride                    1.0
                  108-38-3        m-Xylene                             1.0
                  95.47-6         o-Xylene                              1.0
                  106-42-3        p-Xylene                              1.0
                  1330-20-7       Xylene (mixed isomers)                1.0
                  87-62-7         2,6-Xylidine                          0.1
                  7440-66-6       Zinc (fume or dust)                     1.0
                  12122-67-7      Zineb                                 1.0
                                  [Carbamodithioic acid, 1,2-ethanediyibis-,
                 	zinc complex]	
                           Toxics Release Inventory Reporting Form and Instructions
                                                                 11-10

-------
                               Table II, EPCRA Section 313 Chemical List- RY2008
 b.        Individually Listed Toxic Chemicals Arranged
           by CAS Number
 CAS Number
Deminimis
Chemical Name
Limit
                 Arranged by CAS Number
 50-00-0         Formaldehyde                       0.1
 51-03-6         Piperonyl butoxide                  1.0
 51-21-8         Fluorouracil (5-Fluorouracil)          1.0
 51-28-5         2,4-Dinitrophenol                   1.0
 51-75-2         Nitrogen mustard                    0.1
                 [2-Chloro-N-(2-chloroethyl)-N-
                 methylethanamine]
 51-79-6         Urethane (Ethyl carbamate)           0.1
 52-68-6         Trichlorfon                         1.0
                 [Phosphonic acid, (2,2,2-trichloro-l-
                 hydroxyethyl)-, dimethyl ester]
 52-85-7         Famphur                           1.0
 53-96-3         2-Acetylaminofluorene               0.1
 55-18-5         N-Nitrosodiethylamine               0.1
 55-21-0         Benzamide                         1.0
 55-38-9         Fenthion                           1.0
                 [O,O-Dimethyl O-[3-methyl-4-
                 (methylthio)phenyl] ester, phosphorothioic
                 acid]
 55-63-0         Nitroglycerin                        1.0
 56-23-5         Carbon tetrachloride                 0.1
 56-35-9         Bis(tributyltin) oxide                 1.0
 56-38-2         Parathion                           1.0
                 [Phosphorothioic acid, O,O-diethyl-O-(4-
                 nitrophenyl) ester]
 57-14-7         1,1-Dimethylhydrazine               0.1
 57-33-0         Pentobarbital sodium                 1.0
 57-41-0         Phenytoin                          0.1
 57-57-8         beta-Propiolactone                  0.1
 57-74-9         Chlordane                            *
                 [4,7-Methanoindan, 1,2,4,5,6,7,8,8-
                 octachloro-2,3,3a,4,7,7a-hexahydro-]
 58-89-9         Lindane                            0.1
                 [Cyclohexane, 1,2,3,4,5,6-hexachloro-,
                 (l.alpha.,2.alpha.,3.beta.,4.alpha,
                 5.alpha.,6.beta.)-]
 59-89-2         N-Nitrosomorpholine                 0.1
 60-09-3         4-Aminoazobenzene                 0.1
 60-11-7         4-Dimethylaminoazobenzene          0.1
 60-34-4         Methyl hydrazine                    1.0
 60-35-5         Acetamide                          0.1
 60-51-5         Dimethoate                         1.0
 61-82-5         Amitrole                           0.1
 62-53-3         Aniline                             1.0
 62-55-5         Thioacetamide                      0.1
 62-56-6         Thiourea                           0.1
 62-73-7         Dichlorvos                         0.1
                 [Phosphoric acid, 2,2-dichloroethenyl
                 dimethyl ester]
 62-74-8         Sodium fluoroacetate                 1.0
 62-75-9         N-Nitrosodimethylamine             0.1
 63-25-2         Carbaryl                           1.0
	[1-Naphthalenol, methylcarbamate]	
CAS Number
Deminimis
Chemical Name
Limit
Arranged by CAS Number
64-18-6
64-67-5
64-75-5
67-56-1
67-63-0



67-66-3
67-72-1
68-12-2
68-76-8


70-30-4
71-36-3
71-43-2
71-55-6


72-43-5

Formic acid
Diethyl sulfate
Tetracycline hydrochloride
Methanol
Isopropyl alcohol
(only persons who manufacture by
strong acid process are subject, no
notification)
Chloroform
Hexachloroethane
N,N-Dimethylformamide
Triaziquone
[2,5-Cyclohexadiene-l,4-dione, 2,
tris(l-aziridinyl)-]
Hexachlorophene
n-Butyl alcohol
Benzene
1,1,1 -Trie hloroethane (Methyl
1.0
chloroform)
Methoxychlor
[Benzene, I, I' -(2,2,2-
1.0
0.1
1.0
1.0
1.0
the
supplier

0.1
0.1
1.0
1.0
3,5-

1.0
1.0
0.1



*

trichloroethylidene)bis[4-methoxy-]
72-57-1
74-83-9
74-85-1
74-87-3
74-88-4
74-90-8
74-95-3
75-00-3
75-01-4
75-05-8
75-07-0
75-09-2

75-15-0
75-21-8
75-25-2
75-27-4
75-34-3
75-35-4
75-43-4

75-44-5
75-45-6

75-55-8
75-56-9
75-63-8

75-65-0
75-68-3

75-69-4
75-71-8
Trypan blue
Bromomethane (Methyl bromide)
Ethylene
Chloromethane (Methyl chloride)
Methyl iodide
Hydrogen cyanide
Methylene bromide
Chloroethane (Ethyl chloride)
Vinyl chloride
Acetonitrile
Acetaldehyde
Dichloromethane (Methylene
chloride)
Carbon disulfide
Ethylene oxide
Bromoform (Tribromomethane)
Dichlorobromomethane
Ethylidene dichloride
Vinylidene chloride
Dichlorofluoromethane
(HCFC-21)
Phosgene
Chlorodifluoromethane
(HCFC-22)
Propyleneimine
Propylene oxide
Bromotrifluoromethane
(Halon 1301)
tert-Butyl alcohol
1 -Chloro- 1 , 1 -difluoroethane
(HCFC-142b)
Trichlorofluoromethane (CFC-11)
Dichlorodifluoromethane
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
0.1

1.0
0.1
1.0
0.1
1.0
1.0
1.0

1.0
1.0

0.1
0.1
1.0

1.0
1.0

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

-------
  Table II, EPCRA Section 313 Chemical List- RY2008
CAS Number
Deminimis
Chemical Name Limit
Arranged by CAS Number

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

84-74-2
85-01-8
85-44-9
86-30-6
87-62-7
87-68-3
87-86-5
(CFC-12)
Chlorotrifluoromethane (CFC-13)
2-Methyllactonitrile
2-Chloro-l , 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-lH-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
[Pentachloronitrobenzene]
Dibutyl phthalate
Phenanthrene
Phthalic anhydride
N-Nitrosodiphenylamine
2,6-Xylidine
Hexachloro- 1 , 3 -butadiene
Pentachlorophenol (PCP)

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

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


1.0
0.1
1.0

1.0
1.0
1.0
1.0
0.1
1.0
0.1
CAS Number
Deminimis
Chemical Name
Limit
Arranged by CAS Number
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

98-82-8
98-86-2
98-87-3
98-88-4
98-95-3
99-30-9

99-55-8
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
(B enzotrichloride)
Cumene
Acetophenone
Benzal chloride
Benzoyl chloride
Nitrobenzene
Dichloran [2,6-Dichloro-4-
nitroaniline]
5-Nitro-o-toluidine
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

1.0
1.0
1.0
1.0
0.1
1.0

1.0
Toxics Release Inventory Reporting Form and Instructions
11-12

-------
                              Table II, EPCRA Section 313 Chemical List- RY2008
CAS Number
Deminimis
Chemical Name
Limit
                Arranged by CAS Number
99-59-2         5-Nitro-o-anisidine                  1.0
99-65-0         m-Dinitrobenzene                   1.0
100-01-6        p-Nitroaniline                       1.0
100-02-7        4-Nitrophenol                       1.0
100-25-4        p-Dinitrobenzene                    1.0
100-41-4        Ethylbenzene                       0.1
100-42-5        Styrene                             0.1
100-44-7        Benzyl chloride                     1.0
100-75-4        N-Nitrosopiperidine                  0.1
101-05-3        Anilazine                           1.0
                [4,6-Dichloro-N-(2-chlorophenyl)-l,3,5-
                triazin-2 -amine]
101-14-4        4,4'-Methylenebis(2-chloroaniline)     0.1
                (MBOCA)
101-61-1        4,4'-Methylenebis(N,N-              0.1
                dimethyl)benzenamine
101-77-9        4,4'-Methylenedianiline              0.1
101-80-4        4,4'-Diaminodiphenyl ether           0.1
101-90-6        Diglycidyl resorcinol ether            0.1
104-12-1        p-Chlorophenyl isocyanate            1.0
104-94-9        p-Anisidine                         1.0
105-67-9        2,4-Dimethyrphenol                  1.0
106-42-3        p-Xylene                           1.0
106-44-5        p-Cresol                            1.0
106-46-7        1,4-Dichlorobenzene                 0.1
106-47-8        p-Chloroaniline                     0.1
106-50-3        p-Phenylenediamine                  1.0
106-51-4        Quinone                            1.0
106-88-7        1,2-Butylene oxide                  0.1
106-89-8        Epichlorohydrin                     0.1
106-93-4        1,2-Dibromoethane                  0.1
                (Ethylene dibromide)
106-99-0        1,3-Butadiene                       0.1
107-02-8        Acrolein                            1.0
107-05-1        Allyl chloride                       1.0
107-06-2        1,2-Dichloroethane (Ethylene         0.1
                dichloride)
107-11-9        Allylamine                          1.0
107-13-1        Acrylonitrile                        0.1
107-18-6        Allyl alcohol                        1.0
107-19-7        Propargyl alcohol                   1.0
107-21-1        Ethylene glycol                     1.0
107-30-2        Chloromethyl methyl ether            0.1
108-05-4        Vinyl acetate                        0.1
108-10-1        Methyl isobutyl ketone                .0
108-31-6        Maleic anhydride
108-38-3        m-Xylene
108-39-4        m-Cresol
108-45-2        1,3-Phenylenediamine
108-60-1        Bis(2-chloro-l-methylethyl) ether
108-88-3        Toluene
108-90-7        Chlorobenzene
108-93-0        Cyclohexanol
108-95-2        Phenol
109-06-8        2-Methylpyridine
109-77-3        Malononitrile
CAS Number
Deminimis
Chemical Name Limit
Arranged by CAS Number
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

2-Methoxyethanol
n-Hexane
trans-l,4-Dichloro-2-butene
2-Ethoxyethanol
Cyclohexane
Pyridine
Diethanolamine
Bis(2-chloroethyl) ether
Bis(2-chloroethoxy) methane
Propoxur
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
Propylene (Propene)
Chlorendic acid
Dicofol
[Benzenemethanol, 4-chloro-.alpha.-4-
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

(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
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
Aldicarb
2-Aminoanthraquinone
Di(2-ethylhexyl) phthalate
Hexachlorobenzene
3 , 3 '-Dimethoxybenzidine
3 , 3 '-Dimethylbenzidine
(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
1,4-Dioxane
Dimethylamine
Dibromotetrafluoroethane
(Halon2402)
Tris(2,3 -dibromopropyl)
phosphate
Methacrylonitrile
Chloroprene
Tetrachloroethylene
(Perchloroethylene)
Potassium
dimethyldithiocarbamate
Sodium dimethyldithiocarbamate
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
0.1
1.0
1.0

0.1

1.0
0.1
0.1

1.0

1.0
                           Toxics Release Inventory Reporting Form and Instructions
                                                                                               11-13

-------
                              Table II, EPCRA Section 313 Chemical List- RY2008
CAS Number
Deminimis
Chemical Name
Limit
                Arranged by CAS Number
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
301-12-2
302-01-2
306-83-2

309-00-2
C.I. Vat Yellow 4
Dimethyl phthalate
Sodium pentachlorophenate
Sodium o-phenylphenoxide
Dibenzofuran
Captan
   1.0
   1.0
   1.0
   0.1
   1.0
   1.0
314-40-9
319-84-6
[IH-Isoindole-1,3(2H)-dione, 3a,4,7,7a-
tetrahydro-2-[(trichloromethyl)thio]-]
Folpet                              1.0
Chloramben                         1.0
[Benzoic acid, 3-amino-2,5-dichloro-]
o-Anisidine hydrochloride             0.1
alpna-Naphthylamine                 0.1
Cupferron                           0.1
[Benzeneamine, N-hydroxy-N-nitroso,
ammonium salt]
Dipropyl isocinchomeronate           1.0
Thiram                             1.0
Potassium N-methyldithio-            1.0
carbamate
Metham sodium (Sodium             1.0
methyldithiocarbamate)
Disodium cyanodithioimido -           1.0
carbonate
Nitrilotriacetic acid                   0.1
4,4'-Thiodianiline                    0.1
Ethyl aery late                        0.1
Butyl acrylate                        1.0
Nabam                             1.0
Thiabendazole                       1.0
[2-(4-Thiazolyl)-lH-benzimidazole]
2-Mercaptobenzothiazole             1.0
(MET)
Merphos                            1.0
Monuron                           1.0
Ethyleneimine (Aziridine)             0.1
p-Nitrosodiphenylamine               1.0
Calcium cyanamide                   1.0
Benzo(g,h,i)perylene                  *
Methyl parathion                     1.0
Naled                               1.0
Oxydemeton methyl                  1.0
[S-(2-(Ethylsulfmyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
Hydrazine                           0.1
2,2-Dichloro-l,l,l-trifluoroethane      1.0
(HCFC-123)
Aldrin                               *
[l,4:5,8-Dimethanonaphthalene,
l,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a-
hexahydro-( 1 .alpha. ,4. alpha. ,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
Bromacil                           1.0
(5-Bromo-6-methyl-3 -(1 -methylpropyl)-
2,4(lH,3H)-pyrimidinedione)
alpha-Hexachlorocyclohexane	0.1
CAS Number
Deminimis
Chemical Name
Limit
Arranged by CAS Number
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

Diuron
Linuron
Diazinon
Diazomethane
Bromochlorodifluoromethane
(Halonl211)
1,1, 1 ,2-Tetrachloro-2-fluoroethane
(HCFC-121a)
1 , 1 ,2,2-Tetrachloro- 1 -fluoroethane
(HCFC-121)
1,2-Dichloro- 1,1, 2-
trifluoroethane (HCFC-123a)
l-Chloro-1,1,2,2-
tetrafluoroethane (HCFC-124a)
Brucine
1,2-Dichloro- 1, 1,2,3,3-
pentafluoropropane (HCFC-225bb)
2,3-Dichloro-l, 1,1,2,3-
pentafluoropropane (HCFC-225ba)
3,3-Dichloro-l, 1,1,2,2-
pentafluoropropane (HCFC-225ca)
1,2-Dichloro- 1, 1,3,3,3-
pentafluoropropane (HCFC-225da)
3 -Chloro- 1 ,1,1 -trifluoropropane
(HCFC-253fb)
Carbonyl sulfide
Isodrin
C.I. Solvent Yellow 34
(Auramine)
Mustard gas
[Ethane, 1 , 1 '-thiobis[2-chloro-]
1,3-Dichloro-l, 1,2,2,3-
pentafluoropropane (HCFC-225cb)
Chlorobenzilate
[Benzeneacetic acid, 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
*
0.1

0.1

1.0

1.0
-(4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
528-29-0
532-27-4
533-74-4


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

563-47-3
569-64-2
584-84-9
593-60-2
o-Dinitrobenzene
2-Chloroacetophenone
Dazomet
(Tetrahydro-3,5-dimethyl-2H-l,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-l -propene
C.I. Basic Green 4
Toluene-2,4-diisocyanate
Vinyl bromide
1.0
1.0
1.0


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
                           Toxics Release Inventory Reporting Form and Instructions
                                                                                               11-14

-------
  Table II, EPCRA Section 313 Chemical List- RY2008


CAS Number

Deminimis


Chemical Name Limit
Arranged by CAS Number
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


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
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
Hexamethyrphosphoramide
N-Nitro so -N-methy lurea
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
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
[Phosphoric acid, 2-chloro-l-(2,4,5-
trichlorophenyl)ethenyldimethyl ester]
C.I. Basic Red 1
Pebulate
[Butylethylcarbamothioic acid S-propyl
ester]
Propane sultone
Cycloate
Decabromodiphenyl oxide
Molybdenum trioxide
Thorium dioxide
Cresol (mixed isomers)
2,4-D propylene glycol butyl
ether ester
Xylene (mixed isomers)
Asbestos (friable)
Hexachloronaphthalene
Polychlorinated biphenyls (PCBs)
Aluminum oxide (fibrous forms)
.0
.0
0.1
.0
.0
.0


1.0
1.0


0.1
.0
.0
.0
.0
.0
0.1

1.0
0.1
1.0
*
1.0






























































CAS Number

Deminimis
Chemical Name Limit
Arranged by CAS Number
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
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
Diepoxybutane 0.1
Carbofuran 1.0
Trifluralin *
[Benezeneamine, 2,6-dinitro-N,N-dipropyl-
4-(trifluoromethyl)-]
Methyl tert-butyl 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-l-(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'-(l-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
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 methacry late 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-
(trifluoromethyl)phenyl] -]
Molinate 1.0
(IH-Azepine-l-carbothioic acid,
hexahydro-S-ethyl ester)
Octachloronaphthalene 1 . 0
Dimethylamine dicamba 1.0

Toxics Release Inventory Reporting Form and Instructions
11-15

-------
  Table II, EPCRA Section 313 Chemical List- RY2008


CAS Number

Deminimis
Chemical Name Limit
Arranged by CAS Number
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


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
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-l,3-dithiolo[4,5-b]quinoxarin-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, 1,1,2- 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)
Chlorpyrifos methyl 1.0
[O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate]
Terbacil 1.0
[5-Chloro-3 -(1,1 -dimethylethyl)-6-methyl-
2,4(lH,3H)-pyrimidinedione]
C.I. Acid Red 114 0.1
Prometryn 1.0
[N,N' -Bis( 1 -methylethyl)-6-methylthio-
l,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






























































CAS Number

Deminimis
Chemical Name Limit
Arranged by CAS Number
7440-39-3
7440-41-7
7440-43-9
7440-47-3
7440-48-4
7440-50-8
7440-62-2

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



7664-39-3
7664-41-7





7664-93-9



7696-12-0




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



12122-67-7


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) 1.0
Titanium tetrachloride 1 . 0
Sodium nitrite 1.0
Boron trifluoride 1.0
Hydrochloric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any
particle size)
Hydrogen fluoride 1 . 0
Ammonia 1.0
(includes anhydrous ammonia and aqueous
ammonia from water dissociable
ammonium salts and other sources; 10
percent of total aqueous ammonia is
reportable under this listing)
Sulfuric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any
particle size)
Tetramethrin 1.0
[2,2-Dimethyl-3 -(2 -methyl- 1 -
propenyl)cyclopropanecarboxylic acid
(l,3,4,5,6,7-hexahydro-l,3-dioxo-2H-
isoindol-2-yl)methyl ester]
Nitric acid 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-l,3-Dichloropropene 0.1
Boron trichloride 1.0
Resmethrin 1.0
[[5-(Phenylmethyl)-3-furanyl]methyl- 2,2-
dimethyl-3 -(2 -methyl- 1 -propenyl)
cyclopropanecarboxylate] ]
Zineb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
zinc complex]

Toxics Release Inventory Reporting Form and Instructions
11-16

-------
                              Table II, EPCRA Section 313 Chemical List- RY2008
CAS Number
Deminimis
Chemical Name
Limit
                Arranged by CAS Number
12427-38-2      Maneb                              1.0
                [Carbamodithioic acid, 1,2-ethanediylbis-,
                manganese complex]
13194-48-4      Ethoprop                            1.0
                [Phosphorodithioic acid O-ethyl S,S-
                dipropyl ester]
13356-08-6      Fenbutatin oxide                     1.0
                (Hexakis(2-methyl-2-phenylpropyl)
                distannoxane)
13463-40-6      Iron pentacarbonyl                   1.0
13474-88-9      l,l-Dichloro-l,2,2,3,3-                1.0
                pentafluoropropane (HCFC-225cc)
13684-56-5      Desmedipham                       1.0
14484-64-1      Ferbam                             1.0
                [Tris(dimethylcarbamodithioato-S,S')iron]
15972-60-8      Alachlor                            1.0
16071-86-6      C.I. Direct Brown 95                  0.1
16543-55-8      N-Nitrosonornicotine                 0.1
17804-35-2      Benomyl                            1.0
19044-88-3      Oryzalin                            1.0
                [4-(Dipropylamino)-3,5-
                dinitrobenzenesulfonamide]
19666-30-9      Oxydiazon                          1.0
                [3-[2,4-Dichloro-5-( 1-methylethoxy)
                phenyl]-5-(l,l-dimethylethyl)-l,3,4-
                oxadiazol-2(3H)-one]
20325-40-0      3,3'-Dimethoxybenzidine              0.1
                dihydrochloride (o-Dianisidine
                dihydrochloride)
20354-26-1      Methazole                           1.0
                [2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
                oxadiazolidine-3,5-dione]
20816-12-0      Osmium tetroxide
20859-73-8      Aluminum phosphide
21087-64-9      Metribuzin
21725-46-2      Cyanazine
22781-23-3      Bendiocarb
                [2,2-Dimethyl-l,3-benzodioxol-4-ol
                methylcarbamate]
23564-05-8      Thiophanate methyl                  1.0
23564-06-9      Thiophanate ethyl                    1.0
                [[l,2-Phenylenebis(iminocarbonothioyl)]
                biscarbamic acid diethyl ester]
23950-58-5      Pronamide                          1.0
25311-71-1      Isofenphos                          1.0
                [2-[[Ethoxyl[(l-methylethyl)-
                amino]phosphinothioyl]oxy]benzoicacid
                1-methylethyl ester]
25321-14-6      Dinitrotoluene (mixed isomers)        1.0
25321-22-6      Dichlorobenzene (mixed isomers)      0.1
25376-45-8      Diaminotoluene (mixed isomers)       0.1
26002-80-2      Phenothrin                          1.0
                [2,2-Dimethyl-3 -(2-methyl-l -
                propenyl)cyclopropanecarboxylic acid (3-
                phenoxyphenyl)methyl ester]
26471-62-5	Toluene diisocyanate	0.1
CAS Number
Deminimis
Chemical Name
Limit
                                                               Arranged by CAS Number
                                                               (mixed isomers)
                                               26628-22-8      Sodium azide                        1.0
                                               26644-46-2      Triforine                            1.0
                                                               [N,N'-[l,4-Piperazinediylbis (2,2,2-
                                                               trichloroethylidene)]bisformamide]
                                               27314-13-2      Norflurazon                         1.0
                                                               [4-Chloro-5-(methylamino)-2-[3-
                                                               (trifluoromethyl)phenyl] -3 (2H)-
                                                               pyridazinone]
                                               28057-48-9      d-trans-Allethrin                     1.0
                                                               [d-trans-Chrysanthemic acid of d-
                                                               allethrone]
                                               28249-77-6      Thiobencarb                         1.0
                                                               [Carbamic acid, diethylthio-, S-(p-
                                                               chlorobenzyl)ester]
                                               28407-37-6      C.I. Direct Blue 218                  1.0
                                               29082-74-4      Octachlorostyrene                      *
                                               29232-93-7      Pirimiphos methyl                    1.0
                                                               [O-(2-(Diethylamino)-6-methyl-4-
                                                               pyrimidinyl)-O,O-
                                                               dimethylphosphorothioate]
                                               30560-19-1      Acephate                            1.0
                                                               (Acetylphosphoramidothioic acid O,S-
                                                               dimethyl ester)
                                               31218-83-4      Propetamphos                       1.0
                                                               [3-[(Ethylamino)
                                                               methoxyphosphinothioyl]oxy]-2-butenoic
                                                               acid, 1-methylethyl ester]
                                               33089-61-1      Amitraz                             1.0
                                               34014-18-1      Tebuthiuron                         1.0
                                                               [N-[5-( 1,1-Dimethylethyl)-1,3,4-thiadiazol-
                                                               2-yl]-N,N'-dimethylurea]
                                               34077-87-7      Dichlorotrifluoroethane               1.0
                                               35367-38-5      Diflubenzuron                       1.0
                                               35400-43-2      Sulprofos                            1.0
                                                               [O-Ethyl O-[4-(methylthio)phenyl]-
                                                               phosphorodithioic acid S-propyl ester]
                                               35554.44-0      Imazalil                             1.0
                                                               [l-[2-(2,4-Dichlorophenyl)-2-(2-
                                                               propenyloxy)ethyl]-lH-imidazole]
                                               35691-65-7      l-Bromo-l-(bromomethyl)-l,3-       1.0
                                                               propanedicarbonitrile
                                               38727-55-8      Diethatyl ethyl                       1.0
                                               39156-41-7      2,4-Diaminoanisole sulfate            0.1
                                               39300-45-3      Dinocap                            1.0
                                               39515-41-8      Fenpropathrin                       1.0
                                                               [2,2,3,3 -Tetramethylcyclopropane
                                                               carboxylic acid cyano(3-
                                                               phenoxyphenyl)methyl ester]
                                               40487-42-1      Pendimethalin                         *
                                                               [N-( 1 -Ethylpropyl)-3,4-dimethyl-2,6-
                                                               dinitrobenzenamine]
                                               41198-08-7      Profenofos                          1.0
                                                               [O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
                                                               propyl phosphorothioate]
                                               41766-75-0      3,3'-Dimethylbenzidine               0.1
                           Toxics Release Inventory Reporting Form and Instructions
                                                                                                11-17

-------
                              Table II, EPCRA Section 313 Chemical List- RY2008
CAS Number
Deminimis
Chemical Name
Limit
                Arranged by CAS Number
                dihydrofluoride (o-
                Tolidinedihydrofluoride)
42874-03-3      Oxyfluorfen                         1.0
43121-43-3      Triadimefon                         1.0
                [ 1 -(4-Chlorophenoxy)-3,3 -dimethyl-1 -(1H-
                1,2,4-triazol-l -yl)-2-butanone]
50471-44-8      Vinclozolin                         1.0
                [3-(3,5-Dichlorophenyl)-5-ethenyl-5-
                methyl-2,4-oxazolidinedione]
51235-04-2      Hexazinone                         1.0
51338-27-3      Diclofop methyl                     1.0
                [2-[4-(2,4-Dichlorophenoxy)-
                phenoxyjpropanoic acid, methyl ester]
51630-58-1      Fenvalerate                         1.0
                [4-Chloro-alpha-( 1 -methylethyl)-
                benzeneacetic acid cyano(3-
                phenoxyphenyl)methyl ester]
52645-53-1      Permethrin                          1.0
                [3-(2,2-Dichloroethenyl)-2,2-
                dimethylcyclopropane carboxylic acid,
                (3-phenoxyphenyl)methyl ester]
53404-19-6      Bromacil, lithium salt                1.0
                [2,4(lH,3H)-Pyrimidinedione, 5-bromo-6-
                methyl-3-(l-methylpropyl), lithium salt]
53404-37-8      2,4-D 2-ethyl-4-methylpentyl          0.1
                ester
53404-60-7      Dazomet, sodium salt                1.0
                [Tetrahydro-3,5-dimethyl-2H-l,3,5-
                thiadiazine-2-thione, ion(l-), sodium]
55290-64-7      Dimethipin                         1.0
                [2,3 -Dihydro-5,6-dimethyl-1,4-dithiin
                1,1,4,4-tetraoxide]
55406-53-6      3-Iodo-2-propynylbutyl              1.0
                carbamate
57213-69-1      Triclopyr triethylammonium salt       1.0
59669-26-0      Thiodicarb                          1.0
60168-88-9      Fenarimol                           1.0
                [.alpha. -(2-Chlorophenyl)-.alpha. -(4-
                chlorophenyl)-5-pyrimidinemethanol]
60207-90-1      Propiconazole                       1.0
                [l-[2-(2,4-Dichlorophenyl)-4-propyl- 1,3-
                dioxolan-2-yl]-methyl-lH-1,2,4,-triazole]
62476-59-9      Acifluorfen, sodium salt              1.0
                [5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
                2-nitrobenzoic acid, sodium salt]
63938-10-3      Chlorotetrafluoroethane              1.0
64902-72-3      Chlorsulruron                       1.0
                [2-Chloro-N-[[(4-methoxy-6-methyl-l,3,5-
                triazin-2-yl)amino] carbonyl]
                benzenesulfonamide]
64969-34-2      3,3'-Dichlorobenzidine sulfate         0.1
66441-23-4      Fenoxaprop ethyl                    1.0
                [2-(4-((6-Chloro-2-
                benzoxazolylen)oxy)phenoxy)propanoic
                acid, ethyl ester]
67485-29-4      Hydramethylnon                     1.0
CAS Number
Deminimis
Chemical Name
Limit
                                                                Arranged by CAS Number
                                                                [Tetrahydro-5,5-dimethyl-2(lH)-
                                                                pyrimidinone [3 -[4-
                                                                (trifluoromethyl)phenyl] -1 -[2-[4-
                                                                (trifluoromethyl)phenyl]ethenyl]-2-
                                                                propenylidene] hydrazone]
                                                68085-85-8      Cyhalothrin                          1.0
                                                                [3 -(2-Chloro-3,3,3 -trifluoro-1 -propenyl)-
                                                                2,2-dimethylcyclopropanecarboxylic acid
                                                                cyano(3-phenoxyphenyl) methyl ester]
                                                68359-37-5      Cyfluthrin                           1.0
                                                                [3-(2,2-Dichloroethenyl)-2,2-
                                                                dimethylcyclopropanecarboxylic acid,
                                                                cyano(4-fluoro-3 -phenoxyphenyl) methyl
                                                                ester]
                                                69409-94-5      Fluvalinate                          1.0
                                                                [N-[2-Chloro-4-
                                                                (trifluoromethyl)phenyl]DL-valine(+)-
                                                                cyano(3 -phenoxyphenyl)methyl ester]
                                                69806-50-4      Fluazifop butyl                       1.0
                                                                [2-[4-[[5-(Trifluoromethyl)-2-
                                                                pyridinyl]oxy]phenoxy]propanoic acid,
                                                                butyl ester]
                                                71751-41-2      Abarriectiri[AvermectiriBl]           1.0
                                                72178-02-0      Fomesafen                          1.0
                                                                [5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
                                                                N-methylsulfonyl)-2-nitrobenzamide]
                                                72490-01-8      Fenoxycarb                          1.0
                                                                [[2-(4-Phenoxy phenoxy)ethyl]carbamic
                                                                acid ethyl ester]
                                                74051-80-2      Sethoxydim                          1.0
                                                                [2-[l-(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-l -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-yl)amino]carbonyl]
                                                                amino] sulfonyl]benzoate]
                                                101200-48-0     Tribenuron methyl                    1.0
                                                                [2-[[[[(4-Methoxy-6-methyl-l,3,5-triazin-
                                                                2-yl)methylamino]carbonyl]
                                                                amino]sulfonyl]benzoic acid methyl ester]
                                                111512-56-2     l,l-Dichloro-l,2,3,3,3-               1.0
                                                                pentafluoropropane (HCFC-225eb)
                                                111984-09-9     3,3'-Dimethoxybenzidine              0.1
                            Toxics Release Inventory Reporting Form and Instructions
                                                                                                 11-18

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                             Table II, EPCRA Section 313 Chemical List- RY2008
CAS Number
      Deminimis
      Chemical Name
Limit
                Arranged by CAS Number
               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)
                                                             N090
c.
Chemical Categories
Section 313 requires reporting on the EPCRA Section 313 chemical
categories listed below, in addition to the specific EPCRA Section
313 chemicals listed above.

The  metal  compound categories listed below, unless  otherwise
specified, are defined as including any unique chemical substance that
contains the named metal (e.g., antimony, nickel, etc.) as part of that
chemical's structure.

EPCRA Section 313  chemical categories are subject to the 1% de
minimis concentration unless the substance  involved meets the
definition of an OSHA carcinogen in which case the 0.1% de minimis
concentration applies.   The de minimis  concentration for each
category is provided in parentheses. The de minimis exemption is not
available for PBT chemicals, therefore an asterisk appears where a de
minimis limit would otherwise appear. However, for purposes of the
supplier notification requirement only, such limits are provided in
Appendix D.

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

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

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

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

N078   Cadmium Compounds (0.1)
        Includes any unique chemical substance that
        contains cadmium as part of that chemical's
        infrastructure.

N084   Chlorophenols (0.1)
                                                    N096
                                                    N100
                                                                                  OH
                                  Where x = 1 to 5

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

                     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.

                     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.

                                                           38661-72-2      l,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
                           Toxics Release Inventory Reporting Form and Instructions
                                                                                                  11-19

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                             Table II, EPCRA Section 313 Chemical List- RY2008
N150
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

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 Form R Schedule 1,  enter the data for each
member of the category in the order they are listed here
(i.e., 1-17).]
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
1746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
3268-87-9
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0
2,3,7,8-
Tetrachlorodibenzo-p-dioxin
1,2,3,7,8-
Pentachlorodibenzo-p-dioxin
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-
Octachlorodibenzo-p-dioxin
2,3,7,8-
Tetrachlorodibenzofuran
1,2,3,7,8-
Pentachlorodibenzofuran
2,3,4,7,8-
Pentachlorodibenzofuran
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
1,2,3,4,6,7,8-
Heptachlorodibenzofuran
1,2,3,4,7,8,9-
Heptachlorodibenzofuran
1,2,3,4,6,7,8,9-
Octachlorodibenzofuran
                                                              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.
                           Toxics Release Inventory Reporting Form and Instructions
                                                                                                     11-20

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                             Table II, EPCRA Section 313 Chemical List- RY2008
N450   Manganese Compounds (1.0)
        Includes any unique chemical substance that contains
        manganese as part of that chemical's infrastructure.

N458   Mercury Compounds (*)
        Includes any unique chemical substance that contains
        mercury as part of that chemical's infrastructure.

N495   Nickel Compounds (0.1)
        Includes any unique chemical substance that contains
        nickel as part of that chemical's infrastructure.
N503
N511
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)

                             ,Brx
                                       H(10-x)
                      Where x = 1 to 10
N575   Polybrominated Biphenyls (PBBs) (0.1)

N583   Polychlorinated alkanes (Ci0 to Ci3) (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)

        CxH2x+2-yC1y
        where x= 10 to 13;
        y = 3 to 12; and
        the average chlorine content ranges from 40 C 70% with the
        limiting molecular formulas CjQHigC^ and
        189-64-0       Dibenzo(a,h)pyrene
        191-30-0       Dibenzo(a,l)pyrene
        57-97-6         7,12-Dimethylbenz(a)-anthracene
        193-39-5       Indeno(l,2,3-cd)pyrene
        56-49-5         3-Methylcholanthrene
        3697-24-3      5-Methylchrysene
        5522-43-0      1-Nitropyrene

N725   Selenium Compounds (1.0)
        Includes any unique chemical substance that contains
        selenium as part of that chemical's infrastructure.

N740   Silver Compounds (1.0)
        Includes any unique chemical substance that contains
        silver as part of that chemical's infrastructure.

N746   Strychnine and salts (1.0)
        Includes any unique chemical substance that contains
        strychnine or a strychnine salt as part of that chemical's
        infrastructure.

N760   Thallium Compounds (1.0)
        Includes any unique chemical substance that contains
        thallium as part of that chemical's infrastructure.

N770   Vanadium Compounds (1.0)
        Includes any unique chemical substance that contains
        vanadium as part of that chemical's
        infrastructure.

N874   Warfarin and salts (1.0)
        Includes any unique chemical substance that contains
        warfarin or a warfarin salt as part of that chemical's
        infrastructure.

N982   Zinc Compounds (1.0)
        Includes any unique chemical substance that contains
        zinc as part of that chemical's infrastructure.
N590   Polycyclic aromatic compounds (PACs)  (*)
        This category includes the chemicals listed below.

        56-55-3         Benz(a)anthracene
        205-99-2       Benzo(b)fluoranthene
        205-82-3       Benzo(j)fluoranthene
        207-08-9       Benzo(k)fluoranthene
        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(aj)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
                           Toxics Release Inventory Reporting Form and Instructions
                                                                                                     11-21

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   Table III. State Abbreviations
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Marshall Islands
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
AL
AK
AS
AZ
AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL
IN
IA
KS
KY
LA
ME
MH
MD
MA
MI
MN
MS
MO
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Northern Marianas Islands
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming

MT
NE
NV
NH
NJ
NM
NY
NC
ND
MP
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
WI
WY

Toxics Release Inventory Reporting Form and Instruction
III-l

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          Table IV. Country Codes
AA
AC
AE

AF
AG
AJ
AL
AM
AN
AO
AR
AS
AT

AU
AV
AY
BA
BB
BC
BD
BE
BF
BG
BH
BK

BL
BM
BN
BO
BP
BR
BS
BT
BU
BV
BX
BY
CA
CB
CD
KE
KG
KN
KQ
KR
Aruba
Antigua and Barbuda
United Arab
Emirates
Afghanistan
Algeria
Azerbaijan
Albania
Armenia
Andorra
Angola
Argentina
Australia
Ashmore and C artier
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
Kingman Reef
Kiribati
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
KS
KT
KU
KZ
LA
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
South Korea
Christmas Island
Kuwait
Kazakhstan
Laos
FS

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
LE
LG
LH
LI
LO
French Southern 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 DTvoire
Iraq
Japan
Jersey
Jamaica
Jan Mayen
Jordan
Juan de Nova Island
Lebanon
Latvia
Lithuania
Liberia
Slovakia
Toxics Release Inventory Reporting Form and Instructions
IV-1

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                                Table IV. Country Codes
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
NU
NZ
PA
PC
PE
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
Nicaragua
New Zealand
Paraguay
Pitcairn Islands
Peru
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
TD

TE
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
Trinidad and
Tobago
Tromelin Island
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


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


A.1  Why Do  Federal

Facilities  Need to  Report?

Executive  Order  13423,  "Strengthening  Federal
Environmental    Energy,    and    Transportation
Management," requires  federal  agencies  to comply
with the Emergency Planning and Community Right-
To-Know Act of 1986  (EPCRA) and the Pollution
Prevention Act of 1990 (PPA). Federal facilities have
been subject  to EPCRA section 313 and  PPA since
reporting year 1994. TRI submissions are due to EPA
on  July 1  of the year  following each reporting
(calendar) year. Reporting by the federal facility does
not alter the reporting obligation of on-site contractors.
Contracts entered into after the date of this order for
contractor operation of government-owned facilities or
vehicles require  the contractor  to comply with the
provisions of this order with respect to such facilities
or vehicles  to the same extent as the agency would be
required to  comply if the agency operated facilities or
vehicles.

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


A.2  Identifying Federal

Facility  Reports

Federal facility reports are identified as  federal  by
several  indicators on the form. The facility name and
parent company name are critical indicators and must
be reported as described below.   Another critical
indicator is the federal facility report box, Part I, 4.2c.
Federal facilities only should check this box to indicate
that the report is from a federal agency for a federal
facility; federal facilities should not check  the GOCO
box, (Part I, Section 4.2d of the Form R).  Contractors
located  at federal facilities  (GOCOs) should check the
GOCO box (Part I, Section 4.2d  of the Form R); they
should not  check the box 4.2c.  Facilities should also
complete the partial or complete  facility blocks (Form
R page  2, block 4.2a and 4.2b) as appropriate. If you
are a federal  facility reporting for the  first time, you
should write "new" in the TRI Facility ID (TRIFID)
box, even if a contractor has reported for your facility
in the past.  The contractor will retain the original
TRIFID. You will be assigned a new TRIFID the first
time you report.


A.3  The  "Double

Counting"  Problem

As structured, the law and the executive order require
both regulated industries and the federal government to
report TRI data, sometimes for the same site.  In order
to prevent duplicate data in the TRI database, which
could  result  in  "double counting"  data for some
chemicals and locations, EPA must be able to identify
and distinguish the GOCO  reports submitted by the
federal  contractor from  the federal  facility  reports
which contain data for the same site.  To accomplish
this, federal facility reports should be accompanied by
either  1) exact copies  (paper or electronic)  of all
contractor TRI  reports, including when  the totals
reported by the federal facility are greater than that
reported by the contractor(s), or 2) a cover letter which
includes a list of the facility contractors which submit
TRI reports  to EPA,  identifying  each  contractor by
name, TRI technical contact, and TRI facility name and
address.  Additionally, federal facilities should check
Form R, Part I, Section 4.2c, while contractors at
federal facilities should check Form R, Part I,  Section
4.2d.


A.4  Magnetic  Media

Reporting

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

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

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                                        Appendix A
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 Form Rs (Section 4.1), as  shown in the
following example:

       U.S. DOE Savannah River Site
It is very important that the agency name appear first,
followed by the specific plant or site name.

Federal contractors at GOCO facilities should report
their names as shown in the following example:

       U.S. DOE Savannah River Site -
       Westinghouse Operations.


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.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-2
Toxics Release Inventory Reporting Forms and Instructions

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                                        Appendix A
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
927

92711

928
Affairs

92811
92812
Miscellaneous Commercial Sectors

Space Research and Technology

Space Research and Technology

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

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Appendix  B.   Reporting Codes for EPA Form R
and  Instructions for Reporting Metals
B.1  Form  R Part II

Revision Codes:

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

Withdrawal Codes:

WTl    Did not meet the reporting threshold for
       manufacturing, processing, or otherwise use
WT2    Did not meet the reporting threshold for number
       of employees
WT3    Not in a covered NAICS Code
WO1    Other reason(s)

Section 1.1.   CAS Number

EPCRA Section 313 Chemical Category
Codes

NO 10   Antimony compounds
N020   Arsenic compounds
N040   Barium compounds
N050   Beryllium compounds
N078   Cadmium compounds
N084   Chlorophenols
N090   Chromium compounds
N096   Cobalt compounds
N100   Copper compounds
N106   Cyanide compounds
N120   Diisocyanates
N150   Dioxin and dioxin-like compounds
       N17 lEthylenebisdithiocarbamic
       acid, salts and esters (EBDCs)
N230   Certain glycol ethers
N420   Lead compounds
N450   Manganese compounds
N458   Mercury compounds
N495   Nickel compounds
N503   Nicotine and salts
N511   Nitrate compounds
N575   Polybrominated biphenyls (PBBs)
N583   Polychlorinated alkanes
N590   Poly cyclic aromatic compounds
N725   Selenium compounds
N740   Silver compounds
N746   Strychnine and salts
N760   Thallium compounds
N770   Vanadium compounds
N874   Warfarin and salts
N982   Zinc compounds
Section 4. Maximum Amount of the
Toxic Chemical On-Site at Any Time
During the Calendar Year
        Weight Range in Pounds
Range Code
01
02
03
04
05
06
07
08
09
10
11
     From
        0
       100
     1,000
    10,000
   100,000
  1,000,000
 10,000,000
 50,000,000
100,000,000
500,000,000
   1 billion
            To
            99
           999
          9,999
         99,999
        999,999
       9,999,999
      49,999,999
      99,999,999
     499,999,999
     999,999,999
more than 1 billion
Section 5. Quantity of the Non-PBT
Chemical Entering Each Environmental
Medium On-site and Section 6.
Transfers of the Toxic Chemical in
Wastes to Off-Site Locations

        Total Release or Transfer
       Code              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.

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
                      Toxics Release Inventory Reporting Forms and Instructions
                                    B-l

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                                             Appendix B
        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

                               HO 82   Adsorption
                               H083   Air or steam stripping
                               H101   Sludge treatment and/or dewatering
                               H103   Absorption
                               Hill   Stabilization or chemical fixation prior to
                                       disposal
                               HI 12   Macro-encapsulation prior to disposal
                               HI 21   Neutralization
                               HI 22   Evaporation
                               H123   Settling or clarification
                               HI24   Phase separation
                               H129   Other treatment
B-2
Toxics Release Inventory Reporting Forms and Instructions

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                                             Appendix B
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
W35    Installed vapor recovery systems
W36    Implemented inspection or monitoring program
        of potential spill or leak sources
W39    Other changes made in spill and leak prevention

Raw Material Modifications

W41    Increased purity of raw materials
W42    Substituted raw materials
W49    Other raw material modifications made
Process Modifications

W51    Instituted recirculation within a process
W52    Modified equipment, layout, or piping
W53    Use of a different process catalyst
W54    Instituted better controls on operating bulk
        containers to minimize discarding of empty
        containers
W55    Changed from small volume containers to
        bulk containers to minimize discarding of
        empty containers
W58    Other process modifications

Cleaning and Degreasing

W59    Modified stripping/cleaning equipment
W60    Changed to mechanical stripping/cleaning
        devices (from solvents or other materials)
W61    Changed to aqueous cleaners (from solvents
        or other materials)
W63    Modified containment procedures for
        cleaning units
W64    Improved draining procedures
W65    Redesigned parts racks to reduce drag out
W66    Modified or installed rinse systems
W67    Improved rinse equipment design
W68    Improved rinse equipment operation
W71    Other cleaning and degreasing
        modifications

Surface Preparation and Finishing

W72    Modified spray systems or equipment
W73    Substituted coating materials used
W74    Improved application techniques
W75    Changed from spray to other system
W78    Other surface preparation and finishing
        modifications

Product Modifications

W81    Changed product specifications
W82    Modified design or composition of products
W83    Modified packaging
W89    Other product modifications

Section 8.10.  Methods Used to Identify
Source Reduction Activities

For each source reduction activity, enter up to three of
the following codes that correspond to the method(s)
which contributed most to the  decision to implement
that activity.

TO 1     Internal Pollution Prevention Opportunity
        Audit(s)
T02     External Pollution Prevention Opportunity
        Audit(s)
T03     Materials Balance Audits
T04     Participative Team Management
                          Toxics Release Inventory Reporting Forms and Instructions
                                          B-3

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                                            Appendix B
T05    Employee Recommendation (independent of a          T08    Federal Government Technical Assistance
       formal company program)                                  Program
T06    Employee Recommendation (under a formal            T09    Trade Association/Industry Technical
       company program)                                        Assistance Program
T07    State Government 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 greater that 5000 British thermal units (Btu) and, thus, can not be combusted for energy recovery. It
is left to the facility to decide which of these toxic chemicals can be used for energy recovery. If you are not using TRI-ME
this appendix can serve as a guide to help you understand where it is not appropriate to report certain quantities of toxic
chemicals or waste management codes on your Form R.
Parent Metals:

Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Metal Compound
Categories:

Antimony Compounds
Arsenic Compounds
Barium Compounds
Beryllium Compounds
Cadmium Compounds
Chromium 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 POT W s in Section 6.1.
Only zinc (fume or dust) and aluminum (fume or dust) are not reported in these sections because the fume or dust form of a
toxic chemical can not exist in water.
Form R Section in
Part II
Section 5.3 -
Discharges to
receiving streams
or water bodies
Section 6.1-
Discharges to
POTWs
Parent Metals
All
All
Metal Category
Compounds
All
All
Metals with
Qualifiers
Vanadium (except
when contained in
an alloy)
Vanadium (except
when contained in
an alloy)
Individually-listed
Metal Compounds
All except Asbestos
All except Asbestos
                         Toxics Release Inventory Reporting Forms and Instructions
                                                                     B-5

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                                             Appendix B
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 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 canbe 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














B-6
Toxics Release Inventory Reporting Forms and Instructions

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                  Appendix B
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
C41
C42
C43
C44
C45
C46
C99
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)
Cyanide Oxidation B
Alkaline Chlorination
Cyanide Oxidation B
Electrochemical
Cyanide Oxidation B
Other
General Oxidation
(including Disinfection) B
Chlorination
General Oxidation
(including Disinfection) B
Ozonation
General Oxidation
(including Disinfection) B
Other
Other Chemical
Treatment
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H071
H071
H077
H121
H071
H129
H073
H073
H073
H075
H075
H075
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
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
Toxics Release Inventory Reporting Forms and Instructions
B-7

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                                         Appendix B
Chemical Treatment:
Previous Codes
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
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
F99
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
Other
Incineration/Thermal
Treatment
H040
H040
H040
H040
H040
H040
H040
H040
H040
H040
H076
H122
H040
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
Incineration B thermal destruction other than use as
a fuel
Physical Treatment:
Previous Codes
P01
P09
P11
P12
P13
P14
P15
P16
P17
Equalization
Other blending
Settling/clarification
Filtration
Sludge dewatering (non-thermal)
Air flotation
Oil skimming
Emulsion breaking B thermal
Emulsion breaking B chemical
New Codes (adapted from RCRA Hazardous
Waste Management Codes)
H129
H129
H123
H123
H101
H124
H124
H124
H124
Other treatment
other treatment
Settling or clarification
Settling or clarification
Sludge treatment and/or dewatering
Phase separation
Phase separation
Phase separation
Phase separation
B-8
Toxics Release Inventory Reporting Forms and Instructions

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                                          Appendix B
Physical Treatment:
Previous Codes
P18
P19
P21
P22
P23
P29
P31
P41
P42
P49
P51
P61
P99
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)
H124
H124
H082
H082
H082
H082
H129
H083
H083
H083
H129
H129
H129
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
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
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                                          Appendix B
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 7C when using TRI-ME.
Recycling Code for Section 7C
H10(this code is for metals only
H20
H39
Parent
Metals
All
None
All
Metal Category
Compounds
All
None
All
Metals with
Qualifiers
All
None
All
Individually-
listed Metal
Compounds
All
All
All
Crosswalk for Section 7C. On-site Recycling Processes
Previous Codes
R11
R12
R13
R14
R19
R21
R22
R23
R24
R26
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
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H20
H20
H20
H20
H20
H10
H10
H10
H10
H10
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Metal Recovery (by retorting, smelting, or chemical or
physical extraction)
Metal Recovery (by retorting, smelting, or chemical or
physical extraction)
Metal Recovery (by retorting, smelting, or chemical or
physical extraction)
Metal Recovery (by retorting, smelting, or chemical or
physical extraction)
Metal Recovery (by retorting, smelting, or chemical or
physical extraction)
B-10
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                                                 Appendix B
Previous Codes
R27
R28
R29
R30
R40
R99
Metals Recovery B High
Temperature
Metals Recovery B
Retorting
Metals Recovery B
Secondary Smelting
Metals Recovery B Other
Acid Regeneration
Other Reuse or Recovery
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H10
H10
H10
H10
H39
H39
Metal Recovery (by retorting, smelting, or chemical or
physical extraction)
Metal Recovery (by retorting, smelting, or chemical or
physical extraction)
Metal Recovery (by retorting, smelting, or chemical or
physical extraction)
Metal Recovery (by retorting, smelting, or chemical or
physical extraction)
Other recovery or reclamation for reuse (including acid
regeneration or other chemical reaction process)
Other recovery or reclamation for reuse (including acid
regeneration or other chemical reaction process)
Section 8.  Source Reduction and Recycling Activities

The chart below indicates which metals can be reported in Sections 8.2,8.3,8.6 and 8.7 of the Form R when using TRI-ME.
Note that all toxic chemicals can 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).
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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.efdptgicsc.comorcall 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:

    •   Facility Information.  This  section displays  all
       facility-specific  data,  including  TRI  Facility
       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 2008 and revisions to one chemical
       for Reporting Year 2007, 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  2008,  and
       subsequently revises only one chemical submission,
       the facility will receive an FDP for Reporting Year
       2008 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
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                                               Appendix C
       changes have occurred (i.e., Part I of the Form R or
       A), this section is not provided.


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 TPJ Data Processing  Center has made
minor clerical  changes  to submissions.    As  submission
information is entered into EPA's national database, a series of
automated data quality checks are performed.  The data quality
checks are useful to identify potential errors with certain data
fields such as TRI Facility Identification, facility name, county
spelling, as well as to  perform validation checks to ensure
consistency among data elements within a given Form R or
Form A. These data quality checks, however, cannot detect
whether release, transfer, or waste management quantities were
calculated or entered accurately. Within a FDP notice, there
may be up to three different types of errors identified.

First, a Non-Technical Data Change (NDC) notifies you of
simple, clerical errors that the TRI Data Processing Center has
corrected for you. It is not necessary to respond to a NDC.
The TRI Data Processing Center will correct simple, clerical
errors that are not technical or scientific - a  "non-technical
data change."  For example, if a facility transposes CAS
numbers (e.g., the submitter lists 7623-00-0 for sodium nitrite
instead of 7632-00-0),  the TRI  Data Processing Center will
correct this clerical error and display the correct information
on the facility's FDP. If a facility lists a specific glycol ethers
subcategory, the TRI Data Processing Center will replace this
subcategory with the reportable name Acertain glycol ethers."
The messages used  on FDPs to report non-technical data
changes are shown at  the end of this appendix under  the
heading AE. 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 1 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
                               30 days and respond to the Agency that corrective action has
                               been taken. If a facility fails to respond to the NON within the
                               required time period, the Agency may take further action.

                               Facilities must keep copies, for three years, of submitted Form
                               R reports and Form A certifications  and all documentation
                               used to  complete their submissions.  This documentation
                               should include calculations for threshold determinations, the
                               basis of exemptions applied, and the estimation techniques and
                               data used for all quantities reported on the Form R and Form
                               A.

                               For the first time beginning with RY 2004, TRI will provide
                               Data Quality Alerts (DQA). The DQA informs facilities of
                               possible reporting issues.  It is offered to assist facilities in
                               ensuring accurate reporting.
C-2
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                                               Appendix C
C.3  Common  Errors  in

Completing  Form  R Reports

and  Form  A  Certification

Statements,  including

Reporting  Determination

Errors

General Considerations

    •   Lack of signed  Certification Statement.  If you
       choose not to send your TRI submissions via the
       paperless CDX process, you must send  a  signed
       certification statement with your  magnetic  media
       submission or sign Part I, Section 3 of your hard copy
       submission.  Although  EPA accepts diskette  and
       paper submissions, EPA strongly encourages you to
       send your submission via CDX.

    •   Incomplete Forms. A complete Form R report for a
       single  EPCRA  section  313 chemical or  single
       EPCRA section 313 chemical category consists of
       five pages stapled together.  By using TRI-ME and
       CDX, errors such as this would not occur. Each
       chemical submission must have its own page one.
       EPA cannot enter into  the  database data from a
       package that contains only one page 1, but several
       page 2s, 3s, 4s, and/or 5s. Suchforms are considered
       incomplete submissions.

Threshold Determinations

    •   Calculating  threshold  determinations.  Annual
       quantities manufactured, processed, or otherwise
       used for section 313 chemicals must be calculated,
       not surmised. The assumption that thresholds are
       exceeded commonly leads to error.
    •   Misclassification of EPCRA section 313 chemical
       activity.  Failure to correctly classify an EPCRA
       section 313  chemical activity  may result in an
       incorrect threshold determination.   As a  result, a
       facility may fail to submit the required Form R.
    •   EPCRA section 313 chemical activity overlooked.
       Many facilities believe that because the section 313
       reporting requirement pertains to manufacturers, only
       the use of  EPCRA section 313 chemicals in
       manufacturing processes must be examined. Any
       activity involving  the  manufacture,  process, or
       otherwise use of an EPCRA section 313 chemical or
       chemical category must be included in threshold
       determinations. Commonly  overlooked activities
       include importation of chemicals, generation of waste
       byproducts, processing of naturally  occurring metals
       and metal category compounds in ore, manufacturing
       and processing intermediates, the use of chemicals
       for cleaning of equipment, and the generation of
       byproducts during  combustion of coal and/or oil.
       Facilities should take a  systematic approach to
       identify   all  chemicals  and  mixtures  used  in
       production and non-production capacities, including
       catalysts, well treatment chemicals, and wastewater
       treatment chemicals.

    •   Considering EPCRA section 313 chemicals in
       mixtures and other trade name products. EPCRA
       section  313   chemicals  contained in  mixtures
       (including ores and stainless steel alloys) and other
       trade name products must be factored into threshold
       determinations  and  release  and  other  waste
       management determinations, provided  that the de
       minimis  exemption cannot be taken.  When the
       EPCRA  section 313 chemical being reported  is a
       component in a mixture or other trade name product,
       report only the weight of the EPCRA section  313
       chemical in the mixture. Refer to SectionB.4b of this
       document to calculate the weight of an EPCRA
       section 313 chemical in a mixture or other trade name
       product.
    •   Overlooking    manufacturing.    Coincidental
       manufacturing must not be overlooked. If coal and/or
       fuel oil and other raw materials that contain EPCRA
       section 313  chemicals are used in boilers/burners,
       there is a potential for the coincidental manufacture
       of EPCRA section 313 chemicals such as sulfuric
       acid (acid  aerosols),  hydrochloric   acid  (acid
       aerosols), hydrogen fluoride,  and metal category
       compounds. Additionally, manufacturing of EPCRA
       section 313 chemicals during waste treatment is
       commonly overlooked. For example, the treatment of
       nitric acid may result in the manufacturing of a
       reportable chemical (nitrate compounds).

Container Residue

    •   Overlooking container residue. Container residue
       must not be disregarded in release and other waste
       management calculations.  Even a "RCRA empty"
       drum is expected to contain a residue and it must be
       considered for TRI reporting. Additionally, on-site
       drum rinsing and disposal of the rinsate will result in
       a release and other waste management activity. Refer
       to  Estimating  Releases  and Waste  Treatment
       Efficiencies for Toxic Chemical Reporting Forms.
                          Toxics Release Inventory Reporting Forms and Instructions
                                              C-3

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                                                  Appendix C
Part I. Facility Identification Information

Section 1. Reporting Year

    •   Invalid Forms.  The correct version of the form for
        the reporting year in question must be used.  For
        example,   forms provided  for reporting  years
        1987-1990 must not be used to report  data for
        reporting  years  1991-1995. Form Rs  provided for
        reporting years 1991-1995 must not be used to report
        data for years 1996 and later

Section 2. Trade Secret Information
                                          -   Missing or invalid RCRA, NPDES, or UIC
                                              numbers; and
                                              Incomplete off-site and POTW information
                                              (e.g., missing city name)
                                 If amounts are reported in units other than pounds (e.g., metric
                                 units) or with exponential numbers, EPA  may  require a
                                 revision of the Form R/Form A submitted. The exception is
                                 for the reporting of dioxin and dioxin-like compounds where
                                 the amounts are reported in grams.
    •   Incorrect completion of trade secret information.
        The responses to trade secret questions in  Part I
        Section 2 and Part II Section 1.3 of FormR/Form A
        must be  consistent.  If trade secrecy is indicated, a
        sanitized Form  R/Form A and two trade  secret
        substantiations (one sanitized) must be submitted in
        the  same package as the unsanitized trade  secret
        Form R/Form A. Part II Section 1.3 should be blank
        if no trade  secret claim is being made. Also, if you
        indicate  in Part I,  Section 2.1 that you are not
        claiming trade secret information, leave Part I, 2.2
        blank.

Section 3.  Certification

    •   Missing certification  signature.   If you are
        submitting your Form R and/or Form A by hardcopy,
        an original certification signature must appear on
        page 1 of every Form R and/or Form A submitted to
        EPA.  If you are submitting your Form R  and/or
        Form A via diskette, a certification letter containing
        the  certification language as  noted  in 40 CFR '
        372.85(b)(2),  with  the  signature  of  a  senior
        management  official,   must   accompany  the
        submission. The certification letter must contain the
        certification language.    An   example   of  the
        certification letter is included in Section A of these
        instructions.

Section 4.  Facility Identification

    •   Questionable entries. Incorrect entries may require
        corrections to be made by the facility. The use of the
        TRI-ME software would prevent such errors from
        occurring.   Questionable entries may include:
             Missing or incorrect street address;
             Missing or incorrect ZIP codes;
             Missing County names;
             Invalid SIC codes;
             Missing or invalid Dun & Bradstreet
             numbers;
C-4
Toxics Release Inventory Reporting Forms and Instructions

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                                                  Appendix C
Part II.  Chemical-Specific Information

Section 1.  Toxic Chemical Identity

    •   Reporting  chemical  abstract   service  (CAS)
        registry numbers in Section 1.1.  Beginning with
        the  1991   reporting  year,  EPA has  assigned
        alphanumeric category codes to the twenty chemical
        categories for the purposes of reporting  the CAS
        number field in Section  1.1. When completing a
        Form R for a chemical category, the appropriate code
        for that category  must be provided in Section 1.1.
        The CAS numbers are listed in Table II: "Section 313
        Toxic  Chemical List," and if needed, the category
        codes are listed in Appendix B: "Reporting Codes for
        EPA Form  R." Category guidance documents are
        listed  in the  Chemical  and Industry Guidance
        Documents section in this document.
    •   Failure to check for synonyms. Some reportable
        chemicals  (especially glycol ethers  and toluene
        diisocyanates) have many synonyms that  do not
        readily imply they are in the category. For example,
        benzene,!,3-diisocyanatomethyl may not be readily
        recognized as toluene diisocyanate (mixed isomers).
    •   Invalid chemical identification in Section 1.2. The
        CAS number and the chemical name reported here
        must exactly match the listed official EPCRA section
        313 CAS number and EPCRA section 313 chemical
        name.
    •   Failure  to consider an EPCRA section  313
        chemical qualifier. Only EPCRA  section  313
        chemicals in the form specified  in the  qualifier
        require reporting  under section 313 and should be
        reported on Form R with the appropriate qualifier in
        parentheses. For example, isopropyl alcohol is listed
        on the EPCRA section 313 chemical list with the
        qualifier manufacturing-  strong acid process, no
        supplier notification. Thus, the ONLY facilities that
        should report this EPCRA section 313 chemical are
        those  that manufacture isopropyl alcohol  by the
        strong acid process.
    •   Generic chemical name in Section 1.3. A generic
        chemical name should only be provided if the section
        313 chemical identity is claimed as a trade secret.

Section 2.  Mixture Component Identity

    •   Identifying chemicals  used in mixtures.  Facilities
        should carefully review the most recent MSDS or
        supplier notification for every mixture brought on-
        site to  identify all  section 313  chemicals used during
        a reporting year.  Although some mixtures may not
        have MSDSs, the  best readily available information
        should be used to  determine the presence of EPCRA
        section 313  chemicals in ores and alloys.
    •   Mixture names in Section 2.1. Mixture names are to
        be entered here only if the supplier is claiming the
        identity of the EPCRA section 313 chemical a trade
        secret and that is the sole identification. Mixture
        names that include the name or CAS number of one
        or more EPCRA section 313 chemicals are not valid
        uses of the mixture name field.

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

    •   Reporting EPCRA section 313 chemical activity.
        EPCRA section 313 chemical activity is commonly
        overlooked or misclassified. Any activity involving
        the manufacture, process, or otherwise use of an
        EPCRA section 313 chemical must be examined. For
        example, waste treatment operations otherwise use
        EPCRA section 313 chemicals to treat waste streams
        and may coincidentally manufacture an additional
        EPCRA  section 313 chemical as  a result of the
        treatment reaction. Such activity must be considered.
        Further, EPCRA section 313 chemical activity must
        be correctly  classified as either "manufactured,"
        "processed," or "otherwise used."
    •   Section 3.1 Manufacture means to produce, prepare,
        compound,  or  import  an  EPCRA  section 313
        chemical.
    •   Section 3.2      Process means the preparation of
        an  EPCRA  section  313  chemical  after  its
        manufacture,   which   usually   includes   the
        incorporation of the EPCRA section 313  chemical
        into the final product, for distribution in commerce.
    •   Section 3.3      Otherwise use encompasses any use
        of an EPCRA section 313 chemical that does not fall
        under the terms "manufacture" or "process," and
        includes treatment  for  destruction,  stabilization
        (without subsequent  distribution  in  commerce),
        disposal, and other use of an EPCRA section 313
        chemical, including an EPCRA section 313 chemical
        contained in a mixture or other trade name product.
        Otherwise use of an EPCRA section 313  chemical
        does  not include disposal, stabilization (without
        subsequent distribution in commerce), or treatment
        for destruction unless:
        1.    The EPCRA section 313 chemical that was
             disposed, stabilized, or treated for destruction
             was received from off-site for the purposes of
             further waste management; or
        2.    The EPCRA section 313 chemical that was
             disposed, stabilized, or treated for destruction
             was manufactured as a result of waste
             management activities on materials received
             from off-site for the purposes of further waste
             management activities.
                           Toxics Release Inventory Reporting Forms and Instructions
                                                C-5

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                                                  Appendix C
For example, solvents in paint applied to a manufactured
product are  often  misclassified as processed, instead  of
otherwise used. Because the solvents are not incorporated into
the final product, the solvent is being otherwise used, not
processed.

Section 4.  Maximum Amount of the Toxic
Chemical On-site at Any Time During the
Calendar Year

    •   Maximum amount on-site left blank Failure to
        provide the appropriate code for maximum amount
        on site.

Section 5.  Quantity of the Toxic Chemical
Entering Each Environmental Medium On-site

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

                                 Section 8.  Source Reduction and Recycling
                                 Activities

                                 For RY 2004, the TRI-ME  software will be offering a new
                                 tool: the Section 8 Calculator.  The Section 8 Calculator will
                                 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
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                                            Appendix C
for reporting the maximum amount of the reported
EPCRA  section 313 chemical  on-site to report
quantities in Section 8.
Quantities reported in Section 8.1 through 8.7 are
mutually exclusive and additive. This means that
quantities of the  reported  EPCRA  section 313
chemical must not be double-counted in Section 8.1
through 8.7.
Some double-counting  errors have been due  to
confusion  over  the  differences  in how on-site
treatment of an  EPCRA section 313  chemical is
reported in Section 7 A as compared to Section 8. In
Section 7A, information on the treatment of waste
streams containing the EPCRA section 313 chemical
is reported, along with the percent efficiency in terms
of destruction or removal of the EPCRA section 313
chemical from each waste stream. In Section 8, only
the quantity of the EPCRA section 313  chemical
actually destroyed  through the treatment processes
reported in Section 7A is reported in Section 8.6 to
avoid double-counting within Sections 8.1 through
8.7.
Quantities reported in Section 8.1 through 8.7 must
not be reported in Section 8.8 and vice versa.
Any time a reported EPCRA section 313 chemical is
contained in a waste, and the waste is associated with
routine production-related activities and is recycled,
combusted for energy recovery, treated, disposed, or
otherwise released either on- or off-site, that quantity
of the EPCRA section 313 chemical must be included
in the quantities reported in Sections 8.1 through 8.7
Reporting  quantities in Section 8.1  Quantities of
EPCRA  section 313 chemicals  that are released
(including disposed) on-site and reported in Section 5
of Form R must be reported in either Section 8. la or
8.1b.
§8.1a = § 5.4.1 + § 5.5.1A + § 5.5. IB - § 8.8 (on-site
release or disposal due to catastrophic events)1
§ 8.1b = § 5.1+§ 5.2+ § 5.3+§ 5.4.2+ § 5.5.2+ §
5.5.3A + § 5.5.3B + §5.5.4 - § 8.8 (on-site release or
disposal due to catastrophic events)1
Quantities  of  EPCRA  section  313  chemicals
transferred  off-site for  the purposes  of disposal
reported in Section 6.2  using the following codes
must appear in Section 8. 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 8.1c or 8. Id. To report correctly in Sections
        8. la through d, a facility must include quantities that
        are disposed or otherwise released to the environment
        either on-site or off-site, excluding disposal or other
        releases due to catastrophic events or non-production
        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 BrokerCDisposal
          -   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 withM 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
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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        combusted for energy recovery must not be reported
        if the EPCRA section 313 chemical does not have a
        significant heating value.   Examples  of EPCRA
        section 313 chemicals that do not have significant
        heating values include metals, metal portions of metal
        category compounds, and halons.  Metals and metal
        portions of metal compounds will never be treated or
        combusted for energy recovery. Any quantities of the
        EPCRA  section  313  chemical associated  with
        non-production related activities such as catastrophic
        releases and  remedial actions,  as well as other
        one-time   events   not  associated  with   routine
        production practices that were combusted for energy
        recovery on-site must 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 C 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 1C,
        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
 §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.
                                          as other one-time events not associated with routine
                                          production practices that were recycled on-site must
                                          not be included in Section 8.8.

                                      •   Reporting quantities in Section  8.5. "Quantity
                                          recycled off-site." Quantities reported in Section 6.2
                                          as transferred off-site for the purposes of recycling
                                          must be included in Section 8.5 using the following
                                          codes:
                                               M20 Solvents/Organic Recovery
                                           -   M24 Metals Recovery
                                           -   M26 Other Reuse or Recovery
                                           -   M28 Acid Regeneration
                                           -   M93 Transfer to Waste Broker C 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 7 A 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
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                                                  Appendix C
        production practices that were treated for destruction
        on-site must not be included in Section 8.8.  Metals
        generally will not be treated for destruction.

    •   Reporting quantities  in  Section  8.7 "Quantity
        treated off-site." Quantities reported in Section 6.2
        as transferred off-site for the purposes of treatment
        must be included in Section 8.7 using the following
        codes:
          -   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 C 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 2008
        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
        RorA.
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)( 1)(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
                            Toxics Release Inventory Reporting Forms and Instructions
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                                               Appendix C
       certified letter. Please be sure to sign the certification
       statement in this FDP to certify your submission data.
9.      You  have  reported   Dioxin  and  Dioxin-like
       Compounds on a Form A. Dioxin and Dioxin-like
       Compounds  are  not  eligible  for the  alternate
       threshold.  Thus, this chemical must be reported on a
       Form R. Please resubmit your data on a Form R.
10.     In Part I,  Section  lof the  Form R  or Form A
       Certification Statement You did not enter a reporting
       year. (Note:  EPA has set the year to 2084 as a
       default.) You must enter a valid reporting year for
       your Form R or Form  A Certification Statement.
       This entry  cannot be left blank and NA may not be
       used. (NOSE)
11.     In Part I,  Section  lof the  Form R  or Form A
       Certification Statement you provided an invalid or
       future  reporting year.  You  must enter a valid
       reporting  year  for your Form  R  or  Form A
       Certification Statement. Valid years are  1987 through
       2002. This entry cannot be left blank and NA may
       not be used. (NOSE)
12.     You have reported a negative number(s) in Part II,
       Sections 5  and/or 6 and/or  8  of your Form R.
       Quantities  reported in these sections must be 0 or
       greater. Please respond by providing correct release
       or other waste management data.
13.     You did not complete Part  II,  Sections 5  and 6.
       Please  provide the required information; otherwise
       indicate NA.
14.     You did not complete Part II,  Section 7.  Please
       provide the required information; otherwise indicate
       NA.
15.     You did not complete Part II,  Section 8.  Please
       provide the required information; otherwise indicate
       NA.
C.5  Messages Used to
Report Notices of Technical
Errors (NOTEs)  and  Non-
technical Data Changes
(NDCs)

Invalid codes throughout Form R
16.      You submitted an invalid code. To correct this,
        consult the instructions for the proper table value and
        provide a valid code value. [Specific location on the
        form of the invalid code is given.] (NOTE)
17.      PBT  chemicals  (e.g.,   Dioxin  and Dioxin-like
        Compounds, Lead Compounds, Mercury Compounds
        and Polycyclic Aromatic Compounds (PACs)) are
                                      ineligible for range reporting for on-site releases and
                                      transfers  off-site  for further waste management.
                                      Please provide specific release, transfer, and other
                                      waste management values.(NOTE)
                               18.      For aluminum (fume or dust) or zinc (fume or dust),
                                      the Waste Management codes M56 and M92 are
                                      unacceptable.   Please  provide the proper Waste
                                      Management codes for these chemicals. (NOTE)
                               19.     For asbestos (friable), the Waste Management codes
                                      M56 and M92 are unacceptable. Please provide the
                                      proper Waste Management codes for these chemicals.
                                      (NOTE)

                               General Errors for both the Form R and/or
                               Form A

                               20.     You reported a negative value for a release, transfer
                                      or other waste management quantity. Please provide
                                      a  non-negative value for the specified part and
                                      section. (NOTE)
                               21.     You have reported a value for  a PBT chemical
                                      beyond seven digits to the right of the decimal.
                                      EPA's data  management  systems  support data
                                      precision up to seven digits  to  the right of the
                                      decimal.    EPA  has  truncated  your numeric
                                      submission so the number of digits to the right of the
                                      decimal do not exceed seven.  If this was incorrect,
                                      specify the correct value, not exceeding seven digits
                                      to the right of the decimal. (NDC)

                               Errors in Part I, Facility Identification
                               Information

                               22.     No selection was made in Part I, Section 2.1 and 2.2
                                      (Trade Secret  Information)  and a generic chemical
                                      name  was not provided in Part II,  Section 1.3.
                                      Therefore, the No box was selected in Part I, Section
                                      2.1. If this was incorrect, and you intended to make a
                                      trade  secret  claim  of the identity of the  toxic
                                      chemical,  you must  resubmit  following  the
                                      requirements of 40 CFR Part 350 to claim trade
                                      secret. (NDC)
                               23.     You indicated  trade secret in Part I,  Section 2.1
                                      (Trade Secret Information) but made no selection for
                                      Part I, Section 2.2 (sanitized/unsanitized) and did not
                                      provide a generic chemical name  in Part II, Section
                                      1.3. EPA changed your selection in Part I, Section
                                      2.1 to indicate that a trade secret claim is not being
                                      made.  If this was incorrect, and you intended to
                                      make a trade secret claim for the identity of the toxic
                                      chemical,  you must  resubmit  following  the
                                      requirements of 40 CFR Part 350 to claim trade
                                      secret. (NDC)
                               24.     You made a selection of No in Part 1, Section 2.1
                                      (Trade Secret Information) and selected unsanitized
                                      in Part 1, Section 2.2. In Part  II,  Section 1.3 a
                              	generic name  was  indicated.   Part II, Section 1.3
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                                                   Appendix C
        should be completed only if trade secret is being
        claimed (Part 1, Section 2.1).  EPA will move the
        chemical name information in Part II, Section 1.3 to
        Part II, Section 1.2. If this is incorrect and you wish
        to claim trade secret, you must resubmit following the
        requirements of 40 CFR Part 350. (NDC)
25.     In Part I, Section 4.1, you entered NA or did not
        enter a county name, city name, state code, and/or zip
        code.  These fields may not be left blank and NA is
        not an acceptable entry.  You must provide a county
        name, city name, state code, and/or zip code where
        the facility is located. (NDC)
26.     EPA has corrected the county name, city name, state
        code, and/ or zip code that you identified in Part I,
        Section 4.1.  The county name, city name, state code,
        and/ or zip code that you identified was either mis-
        spelled, or incorrect, or did not match the previous
        year submissions.   If you feel our correction was
        made in error, please resubmit forms with  correct
        information.  (NDC)
27.     In Part I, Section  4.1,  you have used an  invalid
        TRIFID or you have 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)
        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)
        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 I.D. No. Part I
        Section 4.8) are typically 12 characters in length.
        Please check  the number(s) submitted. If they are
        incorrect, please make the appropriate changes.  If
        you believe that they are correct, no further action is
        necessary. (NOTE)
39.      NPDES  Permit Numbers  (Part I,  Section  4.9) are
        typically  9  characters  in length. Please check the
        number(s) submitted. If they are incorrect, please
        make the appropriate changes.  If you believe that
        they are  correct,  no further action is  necessary.
        (NOTE)
40.      Underground  Injection  Well  Code  (UIC) I.D.
        Numbers (Part I, Section 4.10) are typically 12 digits.
        Please check the number(s) you have supplied. If they
        are  incorrect,  please make appropriate changes. If
        you believe that they are correct, no further action is
        necessary. (NOTE)
41.      If this is  a North  American phone number, please
        enter all 10  digits (i.e., include area code).  If this is
        for another country, please begin the phone number
        with "Oil"  as the prefix  to  your  international
        telephone number. (NOTE)
42.      In Part I, Section 3, you did not provide a printed or
        typed name and official title of owner/operator or
        senior management official. It cannot be N/A or left
        blank. Please provide a name for owner/operator or
        senior management official. (NOTE)
43.      In Part I, Section 5.1 you did not enter the  name of
        the parent company. This block cannot be left blank.
        You must enter the name for the  parent company if it
        is a U. S. company. If it is a foreign company then you
        may check the [NA] box. (NOTE)
44.      The parent company Dun and Bradstreet Number in
        Part I,  Section 5.2  (typically  a 9-digit number )
        cannot  be  left blank.  However,  if  your parent
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                                                 Appendix C
        company  does not have a  Dun  and Bradstreet
        Number check the [NA] box next to Part I, Section
        5.2. (NOTE)

Errors in Part II, Section 1. Toxic Chemical
Identity

45.      You have correctly identified the chemical but have
        used  a  synonym for the chemical name. EPA has
        changed the Chemical Name to use the preferred TPJ
        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 with either 0 or a number between 0.01 and 100.
                                        The summation of the 17 fields in Section 1.4 must
                                        equal 100. Please review Part II, Section 1.4 and
                                        enter  values  where  needed  and/or  adjust  the
                                        percentages where needed so that their summation
                                        equals 100%. (NOTE)
                                 56.     You reported numeric values in Part II, Section 1.4
                                        for a chemical that is not Dioxin and Dioxin-like
                                        Compounds. It appears that the information reported
                                        in Part  II,  Section 1.4 is not valid.  If  you are
                                        reporting for Dioxin and Dioxin-like Compounds,
                                        please  indicate on this FDP that  the  chemical
                                        category name in Part II, Section 1.2  should be
                                        Dioxin and Dioxin-like Compounds, or submit a new
                                        Form R. Otherwise, please indicate on this FDP that
                                        the values in Part II, Section 1.4 should be blank.
                                        (NOTE)
                                 57.     Part II, Section 1.4 of your Form R contains data for
                                        Dioxin and Dioxin-like Compounds. However, you
                                        have indicated both NA and a numeric value (which
                                        includes zero). When reporting the distribution of
                                        each  member of  the Dioxin  and  Dioxin-like
                                        Compounds category, you must fill in each of the 17
                                        boxes in Part II, Section 1.4 with either 0 or a number
                                        between 0.01 and 100.  The summation of the 17
                                        fields in Section 1.4 must equal 100.  If you do not
                                        have speciation data available, indicate NA rather
                                        than zero. (NOTE)
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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) and use(s) of the EPCRA
        section 313 chemical occur at your facility. (NOTE)

Errors in Part II, Section 4. Maximum Amount
of the Toxic Chemical Onsite At Any Time
During the Calendar Year

59.      You did not complete Part II, Section 4.1. Please
        provide a valid two digit code for the "maximum
        amount of chemical on-site at any time during the
        calendar year." (NOTE)

Errors in Part II, Section 5. Quantity of the
Toxic Chemical Entering Each Environmental
Medium Onsite

60.      You did not complete Part II, Section 5.3. If you have
        discharged to water, please provide the Stream/Water
        Body name,  the Release estimate  or  range code,
        Basis of Estimate and % from Stormwater; otherwise
        indicate "NA" (Not Applicable). (NOTE)
61.      There  are missing or incomplete data for Part II,
        Section 5.3. If you have discharged to water, please
        provide the Stream/Water Body name, the Release
        estimate or range code, Basis of Estimate and % from
        Stormwater;  otherwise   indicate  "NA"   (Not
        Applicable).  (NOTE)
62.      You did not complete  Part II, Section 5. Please
        provide the Release estimate or range code and Basis
        of Estimate; otherwise  indicate  "NA"   (Not
        Applicable).  (NOTE)
63.      There  are missing or incomplete data for Part II,
        Section 5.  Please provide the Release estimate or
        range code and Basis of Estimate; otherwise indicate
        "NA" (Not Applicable).  (NOTE)

Errors in Part II, Section 6. Transfers of the
Toxic Chemical In Wastes To Off-Site
Locations

64.      You  did  not  complete  Part II,  Section  6.1,
        "discharges to POTW." If you did not discharge
        wastewater containing the section 313 chemical to a
        POTW(s), enter "NA" (Not Applicable), otherwise
        please provide the  Transfer amount  or range code,
        Basis  of Estimate, POTW Name  and  Location.
        (NOTE)
65.      You reported a POTW(s) name and location but did
        not provide a Transfer amount. Please  provide a
        Total Transfer amount or range code and Basis of
        Estimate;  otherwise, if there was no transfer to a
        POTW of wastewater that contains or contained the
        section 313 chemical, delete the POTW location and
        indicate "NA"  (Not Applicable) for the  POTW
        transfer amount.  (NOTE)
66.      You reported a Total Transfer amount or range code
        and Basis of Estimate in Part II Section 6.1 but did
        not indicate a POTW name and location in Section
        6.1 .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
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                                                  Appendix C
        location, you must provide a street address, city and a
        two character country code. (NOTE)
75.     You reported an invalid Type of Waste Management
        code. For metals/metal compounds use only disposal
        and certain recycling activities codes. Consult the
        Reporting   Instructions  for  metal  and  metal
        compounds and  correct  with   a  valid  Waste
        Management (i.e., "M") code.  (NOTE)
76.     You reported an invalid Type of Waste Management
        code. For Barium Compounds use only disposal and
        certain recycling activities codes, M61-Wastewater
        Treatment (Excluding POTW) or M69-Other Waste
        Treatment. Consult the Reporting Instructions for
        metal and metal compounds and correct with a valid
        Waste Management (i.e., "M")  code. (NOTE)
77.     For  non-metals   codes  M41   and  M62  are
        unacceptable.  Provide the appropriate Disposal or
        Other Waste Management code for this non-metal
        substance.  (NOTE)
78.     In Part II, Section 6.2 column C you reported M
        codes (M56  and/or M92)  for  energy  recovery,
        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
        7A. 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 7 A. 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 inPart II, Section 7B. If no on-site
        energy recovery processes are  used for this section
        313  chemical at your  facility,  indicate "NA;"
                                         otherwise please provide at least one three-character
                                         on-site energy recovery process code. (NOTE)
                                 84.     There are no data in Part II, Section 7C. If no on-site
                                         recycling processes are used for this section 313
                                         chemical at your facility, indicate "NA;" otherwise
                                         please provide at least one three-character on-site
                                         recycling process code. (NOTE)

                                 Errors in Part II, Section 8. Source Reduction
                                 and Recycling Activities

                                 85.     There are missing data for Part II, Section 8.1-8.7.
                                         Please provide an estimate or"NA" (Not Applicable)
                                         in each box for section 8.1 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)
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                                                   Appendix C
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,
        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 recycled for Section 8.4 column B. (NOTE)
99.     You reported a value in Part II, Section 8.3 column
        B, however you did not provide a corresponding
        quantity  with  an   appropriate  M  Code   (M56
        and/orM92)  for energy recovery in  Section  6.2
        column C. Please provide the appropriate quantity
        and M Codes for energy recovery in Section 6.2
        column C. (NOTE)
100.    You reported a value in Part II, Section 8.5 column
        B, however you did not provide a corresponding
        quantity with an appropriate M Code  (M20, M24,
        M26, M28, M93) for recycling in Section 6.2 column
        C. Please provide the appropriate quantity and M
        Codes for recycling in Section  6.2  column C.
        (NOTE)
101.     You reported a value in Part II, Section 8.7 column
        B, however you did not report a quantity in Section
        6.1 or a quantity with an appropriate M Code (M40,
        M50, M54, M61, M69, M95) for treatment in Section
        6.2 column C. Please provide a quantity  in Section
        6.1 or the appropriate quantity and M  Codes for
        treatment in Section 6.2 column C. (NOTE)
102.     You have reported a listed metal or metal compound
        category in Part II,  Section 6.1, however you have
        not  provided  a quantity  released in section  8.1
        column B. Note that in Section 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
        column B. (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) code that corresponds
       to 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.
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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 MSD S or other form of notification must
include the section 313 notice. In other words, your customers
should understand their requirement to include the section 313
notification if they give your MSDS to their customers.


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 EPA'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
Toxics Release Inventory Reporting Forms and Instructions

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                       Appendix D
Chemical or chemical
category name
Aldrin
Benzo[g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds
(manufacturing; and the
processing or otherwise
use of dioxin and dioxin-
like compounds if the
dioxin and dioxin-like
compounds are present
as contaminants in a
chemical and if they
were created during the
manufacturing of that
chemical
Heptachlor
Hexachlorobenzene
Isodrin
Lead
Lead compounds
Mercury
Mercury compounds
Methoxychlor
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Polychlorinated
biphenyls (PCBs)
Polycyclic aromatic
compounds category
Tetrabromobisphenol A
Toxaphene
CAS
number or
chemical
category
code
309-00-2
191-24-2
57-74-9
N150
76-44-8
118-74-1
465-73-6
7439-92-1
N420
7439-97-6
N458
72-43-5
29082-74-4
40087-42-1
608-93-5
1336-36-3
N590
79-94-7
8001-35-2
Supplier
notification
limit (%)
1.0
1.0
0.1
1.0*
0.1
0.1
1.0
0.1
0.1**
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1***
1.0
0.1

Chemical or chemical
category name
Trifluralin
CAS
number or
chemical
category
code
1582-09-8

Supplier
notification
limit (%)
1.0
                                   *The de minimis level is 1.0 for all members except for
                                   2,3,7,8-Tetrachlorodibenzo-p-dioxin which has a 0.1%
                                   de minimis level.
                                   **The de minimis level is 0.1 for inorganic lead
                                   compounds and 1.0 for organic lead compounds
                                   ***The de minimis level is 0.1 except for
                                   benzo(a)phenanthrene, dibenzo(a,e)fluoranthene,
                                   benzo(j,k)fluorene, and 3-methylcholanthrene which are
                                   subject to the 1.0% de minimis level.
                                          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 EPCRA
                                          section 313 chemicals and your facility is in any of
                                          the  covered SIC  codes added  during the  1997
                                          industry expansion rulemaking, including facilities
                                          whose SIC code is within SIC major group codes 10
                                          (except 1011, 1081, and 1094),  12 (except 1241);
                                          industry codes 4911 (limited to facilities that combust
                                          coal and/or oil for the purpose of generating power
                                          for  distribution in commerce),  4931  (limited  to
                                          facilities that combust coal and/or oil for the purpose
                                          of generating power for distribution in commerce), or
                                          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,
Toxics Release Inventory Reporting Forms and Instructions
D-3

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                                                Appendix D
        subtitle C, 42 U.S.C. Section 6921 etseq.) or 5169,       Information retained under 40 CFR 372 must be  readily
        or  5171, or 7389 (limited to facilities primarily       available for inspection by EPA.
        engaged in solvents recovery services on a contract
        or fee basis).


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  Record keeping

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
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.
D-4                       Toxics Release Inventory Reporting Forms and Instructions

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                                                Appendix D
D.9  Sample Notification Letter
January 2, 2008

Mr. Edward Burke
Furniture Company of North Carolina
1000 Main Street
Anytown, North Carolina 99999

Dear Mr. Burke:
This letter is to inform you that a product that we sell to you, Furniture Lacquer KXZ-1390, contains one or more chemicals subject to
section 313 of Emergency Planning and Community Right-to-Know Act (EPCRA). We are required to notify you of the presence of
these chemicals in the product under EPCRA section 313. This law requires certain industrial facilities to report on annual emissions
and other waste management of specified EPCRA section 313 chemicals and chemical categories.  Our product contains:


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


    •   Zinc compounds, 15 percent.


If you are unsure whether you are subject to the reporting requirements of EPCRA section 313, or need more information, call EPA's
EPCRA Call Center. 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 subject to the reporting requirements of section 313
      of the Emergency Planning and Community Right-To-Know Act of 1986 (40 CFR 372):
      CAS Number      Chemical Name   Percent by Weight

      108-88-3          Toluene              20%
      NA             Zinc Compounds       15%

       This information must be included in all MSDSs that are copied and distributed for this material.
                                   Material Safety Data Sheet
D-6
Toxics Release Inventory Reporting Forms and Instructions

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Appendix E.     TRI State Contacts	


EPCRA Section 313 requires facilities to submit reports to both EPA and their state. For a current list of state-
designated Section 313 contacts, see the TRI web site at:

State TRI Contact Information and Web Sites: http://www.epa.gov/tri/stateprograms/state_programs.htm
                 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 Waste & Chemical Management
   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 (NAICS 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/titie3.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.

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
                               Toxics Releases Inventory Forms and Instructions
                                              G-l

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                                                  Appendix G
written request at no charge from the Emergency Planning and
Community Right-To-Know  (EPCRA) Call Center.  For
contact  information, please see the TRI Home Page  at
.

Chemicals in the Environment

Issue  number 6 of Chemicals in the Environment (CIE),
published in the Fall of 1997, is devoted entirely to TRI. This
22 page publication contains 19 articles  ranging from the
history of TRI to the future of new TRI products.  Articles
include perspectives from the community, state, Federal, and
International level.  The publication also provides valuable
information on training and contacts within the EPA. CIE is
available free from EPA by asking for publication EPA 749-R-
97- 00Ib. To request copies, contact:

    U.S. Environmental Protection Agency
    Ariel Rios Building
    1200 Pennsylvania Ave., N.W.
    Attn: TRI Documents
    MC: 2844
    Washington, DC 20460

    202 564-9554
    Email:  TRIDOCS@epa.gov

The  Pollution  Prevention  Information  Clearinghouse
(PPIC) 

PPIC  was established as part  of EPA's response to the
Pollution Prevention Act of 1990, which directed the Agency
to compile information, including a database, on management,
technical, and operational approaches to  source reduction.
PPIC  provides  information to the  public  and industries
involved in conservation of natural resources and in reduction
or elimination of pollutants in facilities, workplaces, and
communities.

To request EPA information on pollution prevention or obtain
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 (EPA260/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.

   •  Toxic Chemical Release Reporting Using 2007 North American Industry Classification System (NAICS)
      Final Rule (73 FR 32466; June 9,  2008): This final rule incorporates 2007 Office of Management and Budget
      (OMB) revisions and other corrections to the NAICS codes used for TRI Reporting.
                      Toxics Release Inventory Reporting Forms and Instructions              H-l

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                                          Appendix H
   •  Toxic Chemical Release Reporting Using North American Industry Classification System (NAICS) Final
      Rule (71 FR 32464; June 6,2006): With this rulemaking, Toxics Release Inventory (TRI) reporting will require
      North American Industry Classification System (NAICS) codes in place of Standard Industrial Classification
      (SIC) codes. 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.htm#forms.


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)
      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)


H-2                  Toxics Release Inventory Reporting Forms and Instructions

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                                          Appendix H
   •  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 (EPA745-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 (EPA260-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
      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)


                      Toxics Release Inventory Reporting Forms and Instructions              H-3

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

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

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

   •  EPCRA Section 313: Guidance for Metal Mining Facilities
      Januaryl999 (EPA745-B-99-001)

   •  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 (EPA745-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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