EPA260-B-05-001
January 2005
32W Toxic Chemical Release
t> .^
Inventory Reporting Forms
and Instructions
Revised 2004 Version
313
Community Act
(Title 111 of the Super-fund Amendments
and Reauthorization Act of 1986)
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More Information or Assistance
TRI Regulatory Questions:
If you have a question about a TRI reporting requirement, please refer to our website
for hotline information at:
Internet:
TRI Software Support:
If you have questions about how to install or use the TRI-Made Easy (TRI-ME) software
or the TRI Assistance Library, please contact TRI Software Support at:
TRI Software Support Hotline: 1-877-470-4830
E-mail: trime(5)saic.com
TRI Reporting Materials:
You can use TRI-ME and the TRI Assistance Library to electronically search and read
TRI guidance documents, including this document. The TRI Web page contains links
guidance on filling out and submitting TRI reporting forms:
TRI Regional Contacts:
EPA Regional Coordinators often work closely with reporting facilities in their area,
providing training and outreach, and assistance in completing forms. For a list of TRI
Regional coordinators see Appendix G.
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 F.
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Important Information for Reporting Year 2004
D Early Public Availability of 2004 TRI Reports. U.S. EPA will be conducting an Electronic Facility Data
Release (eFDR) for Reporting Year 2004 forms, making individual forms, as submitted by each facility,
publicly available before the traditional annual Public Data Release. This is in response to requests to make
the TRI data publicly available earlier. This earlier availability will occur before EPA has completed all the
data quality checks, compilations, and trend analysis that are traditionally done as part of the annual Public Data
Release. For information on the annual Public Data Release, and the early release of the individual 2004 TRI
forms, see the Agency's website .
D Simultaneous Reporting to EPA and States. The TRI Program has been working with the States to
implement a State Exchange Pilot. For RY 2004, facilities in certain piloted states will be allowed to submit
information to both EPA and the States simultaneously through the Central Data Exchange (CDX) using the
TRI-ME software. CDX will forward the information to representative States using the National Environment
Exchange Network. This feature will allow facilities to submit their data to both EPA and their State
simultaneously, thereby streamlining the data acceptance and processing features. Once this data flow is fully
functional, States will have the opportunity to drop their individual data collection systems and instead receive
their data via the exchange network. For RY 2005 and beyond, TRI Program expects to have more States
participating in this effort. To view if your State is active in this pilot project, please see the Agency's website
< www.epa.gov/tri/stateexchange/>. Note, that if you are a first time filer, (/'. e., reporting for the first time) and
therefore do not have a TRI Facility Identification Number (TRIFID), you are not allowed to use this feature
and would need to submit reports separately to both EPA and States. However, if you are a first time filer, you
can still submit to EPA through the internet via CDX and take advantage of all its benefits.
D EPA's Audit Policy. If you discover your facility is or may have been in violation of Section 313 ofEPCRA
(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 website
.
D EPA's Small Business Compliance Policy. Ifyouhave 100 or fewer employees and discover that your facility
is or may have been in violation of Section 313 ofEPCRA (TRI Reporting), please refer to EPA's Small
Business Compliance Policy. EPA will eliminate or significantly reduce penalties for small businesses that
meet the conditions of the Policy, including voluntarily discovering violations and promptly disclosing and
correcting them. This Policy implements Section 223 of the Small Business Regulatory Enforcement
Fairness Act (SBREFA) of 1996. For more information, see the Agency's website
.
The following information updates the Reporting Forms and Instructions for Reporting Year 2004 as well as
highlights new resources developed by EPA.
D All references to reporting year 2003 and all other date related references have been changed to reflect the
current reporting year (i.e., reporting year 2003 has been changed to reporting year 2004; prior year 2002
was changed to prior year 2003, etc.). This change was made for the Form R, Form A Certification
Statement, and the instructions.
D EPA's mailing address for TRI submissions changed beginning in reporting year 2002. See page 6 for the
current address.
D See the TRI Home Page at under "Featured Topics" for information regarding the
decision in Barrick Goldstrike Mines Inc. v. Whitman.
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Important Information for Reporting Year 2004
D Appendix C, "Facility Data Profiles, and Common Errors in Completing Form Reports and Form A
Certifications" has been updated.
D The State and Regional contact lists have been updated (Appendices F and G).
D Beginning with 2004 Reporting Year, the de minimis level for naphthalene has been changed from 1.0% to
0.1% since naphthalene is now classified as an OSHA carcinogen.
The following information identifies changes to the TRI Reporting Software.
D Starting with RY 2004, TRI first-time reporters will be eligible to send forms over the Internet via EPA's
Central Data Exchange (CDX). Detailed information regarding this new feature is provided in the TRI-ME
software.
D EPA encourages you to use TRI-ME to submit reports through the Internet via CDX. Previous reporters can
submit via CDX using TRI-ME without sending any paper to EPA. Although EPA recommends submitting
via CDX, EPA does accept diskettes created by the TRI-ME software or other approved software.
Submitting by paper is strongly discouraged.
D Included in this reporting package is a compact disc (CD) that contains the TRI-ME reporting software
(Windows 98, 2000, XP and NT compatible), the EPCRA section 313 Questions and Answers document
and addendum, as well as several industry-specific and chemical-specific guidance documents. The TRI-
ME software and previously mentioned documents are also available via the Internet at www.epa.gov/tri.
d The TRI-ME RY 2004 "Load Data" functionality has been updated. TRI-ME RY 2004 allows you to save
time by loading data from files created by TRI-ME or third party software. You may load current (RY
2004) data created by TRI-ME or third-party software, or may load data from RY 2003 to assist you in
completing this year's forms.
D 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 following information consists of updates to the Reporting Forms and Instructions from previous
reporting years.
d Effective for RY 2003, Part II, Section 5.5.3-Surface Impoundments has been divided into 5.5.3A-RCRA
Subtitle C Surface Impoundments and 5.5.SB-Other Surface Impoundments.
D Effective for RY 2003, Part II, Section 8.1 has been divided into 8. la-Total on-site disposal to Class I
Underground Injection Wells, RCRA Subtitle C landfills, and other landfills, 8. Ib-Total other on-site
disposal or other releases, 8.1c-Total off-site disposal to Class I Underground Injection Wells, RCRA
Subtitle C landfills, and other landfills, and 8. Id-Total other off-site disposal or other releases.
D Effective for RY 2003, the M codes used in Column C of Section 6.2 of the Form R have been updated.
M63 (Surface Impoundment) was deleted and replaced by M codes M66 (RCRA Subtitle C Surface
Impoundment) and M67 (Other Surface Impoundments). M71 (Underground Injection) was deleted and
replaced by M codes M81 (Underground Injection to Class I Wells) and M82 (Underground Injection to
Class II-V Wells).
D Effective for RY 2003, the U codes used in Section 7B of the Form R have been updated. Code
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Important Information for Reporting Year 2004
U09--Other Energy Recovery Methods, has been deleted. This code is not applicable since the only energy
recovery methods are combustion in a kiln, boiler or industrial furnace. Combustion units other than kilns,
boilers and industrial furnaces are used for treatment of the toxic chemical (except for metals and metal
compounds).
Starting with Reporting Year 2002, facilities could provide an email address for the Technical Contact.
EPA encourages all facilities to take advantage of this new opportunity. By providing an email address,
facilities will receive the following benefits:
D Real-time notifications when a Facility Data Profile (FDP) has been updated and posted to the
FDP website
D Receive TRI Program updates and other important notifications.
Use of the ATRS was discontinued after Reporting Year 2001. ATRS 2001, however, may still be used to
revise data for reporting years 1987 to 2001.
Starting with reporting year 2002, facilities can determine their latitude and longitude by using the TRI
Facility Siting Tool found on the TRI Home page. For more information about the siting tool see Appendix
E.
Starting with reporting year 2001, lead and lead compounds are classified as persistent, bioaccumulative
and toxic (PBT) chemicals. The reporting thresholds for lead and lead compounds, except when lead is
contained in stainless steel, brass or bronze alloys, have been lowered to 100 pounds. For specific guidance
on the reporting of lead, see page 15.
Starting with reporting year 2001 the qualifier for isopropyl alcohol has been changed to match exactly the
qualifier that is listed in the Code of Federal Regulations, the new qualifier is "Only persons who
manufacture by the strong acid process are subject, no supplier notification." EPA believes that use of this
qualifier will make it clearer that only facilities that manufacture isopropyl alcohol by the strong acid
process are subject to reporting (i.e., processors and users of isopropyl alcohol are not subject to reporting).
A list of EPCRA section 313 industry-specific and chemical-specific guidance documents and information
on ordering these documents free of charge is provided on page vii.
Starting with reporting year 2000, new chemical activity threshold levels are set for persistent,
bioaccumulative and toxic (PBT) chemicals and chemical categories (Section B.4.e).
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Toxics Release Inventory Reporting Forms and Instructions
Table of Contents
I. TRI Reporting Software v
II. Chemical and Industry Guidance vii
III. General Guidance vii
IV. Chemical-Specific Guidance viii
V. Industry-Specific Guidance ix
A. General Information 1
A.I Who Must Report 1
A.2 How to Report to TRI 1
A.2.a The Toxic Chemical Release Reporting Form, EPA Form R 1
A.2.b The Alternate Threshold Form A Certification Statement 1
A.3 How to Submit Forms 2
A.3.a How to Submit Form R(s) and/or Form A(s) to EPA via the Internet (EPA's Central Data Exchange
(CDX)) 2
A.3.b How to Send Your Disks Containing Form R(s) and/or Form A(s) 2
A.3.b. 1 Labeling Your Submission Diskette 2
A.3.b.2 Submitting by Diskette to States 2
A.3.c How to Submit Paper Form R(s) and/or Form A(s) 3
A.4 Trade Secret Claims 3
A.5 Recordkeeping 4
A.6 How to Revise or Withdraw TRI Data 4
A.7 When the Report Must Be Submitted 6
A.8 How to Obtain Forms and Other Information 7
B. How to Determine if Your Facility Must Submit a Form R or is Eligible to Use the
Form A 9
B.I Full-Time Employee Determination 9
B.2 Primary SIC Code Determination 9
B.2.a. Multi-Establishment Facilities 11
B.2.b. Auxiliary Facilities 12
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) Chemicals and Chemical Categories Overview 14
B.3.c. Activity Exemptions 15
B.4 Threshold Determinations 21
B.4.a. How to Determine if Your Facility Has Exceeded Thresholds 22
B.4.b. Threshold Determinations for On-Site Reuse Operations 23
B.4.c. Threshold Determinations for Ammonia 23
B.4.d. Threshold Determinations for Chemical Categories 23
B.4.e Threshold Determination for Persistent Bioaccumulative Toxic (PBT) Chemicals 24
B.4.f. Mixtures and Other Trade Name Products 24
B.5 Release and Other Waste Management Determinations for Metals, Metal Category Compounds,
and Nitrate Compounds 25
C. Instructions for Completing EPA Form R 31
Part I. Facility Identification Information 31
Section 1. Reporting Year 31
Section 2. Trade Secret Information 31
2.1 Are you claiming the EPCRA section 313 chemical identified on page 2 a trade secret? 31
2.2 If "yes" in 2.1, is this copy sanitized or unsanitized? 31
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Section 3. Certification 31
Section 4. Facility Identification 31
4.1 Facility Name, Location, and TRI Facility Identification Number 31
4.2 Full or Partial Facility Indication 32
4.3 Technical Contact 32
4.4 Public Contact 32
4.5 Standard Industrial Classification (SIC) Code 32
4.6 Latitude and Longitude 33
4.7 Dun & Bradstreet Number 33
4.8 EPA Identification Number 33
4.9 NPDES Permit Number(s) 33
4.10 Underground Injection Well Code (UIC) Identification Number 33
Section 5. Parent Company Information 33
5.1 Name of Parent Company 34
5.2 Parent Company's Dun & Bradstreet Number 34
Part II. Chemical Specific Information 35
Section 1. EPCRA Section 313 Chemical Identity 35
1.1 CAS Number 35
1.2 EPCRA Section 313 Chemical or Chemical Category Name 35
1.3 Generic Chemical Name 36
1.4 Distribution of Each Member of the Dioxin and Dioxin-like Compounds Category 36
Section 2. Mixture Component Identity 36
2.1 Generic Chemical Name Provided by Supplier 36
Section 3. Activities and Uses of the EPCRA Section 313 Chemical at the Facility 37
3.1 Manufacture the EPCRA Section 313 Chemical 37
3.2 Process the EPCRA Section 313 Chemical (incorporative activities) 37
3.3 Otherwise Use the EPCRA Section 313 Chemical (non-incorporative activities) 38
Section 4. Maximum Amount of the EPCRA Section 313 Chemical On-site at Any Time During the Calendar
Year 38
Section 5. Quantity of the EPCRA Section 313 Chemical Entering Each Environmental Medium On-site . . 40
5.1 Fugitive or Non-Point Air Emissions 40
5.2 Stack or Point Air Emissions 41
5.3 Discharges to Receiving Streams or Water Bodies 41
5.4.1 Underground Injection On-Site to Class I Wells 41
5.4.2 Underground Injection On-site to Class II-V Wells 41
5.5 Disposal to Land On-site 41
5.5.1A RCRA Subtitle C landfills 41
5.5. IB Other landfills 41
5.5.2 Land treatment/application farming 41
5.5.3A RCRA Subtitle C Surface Impoundments 42
5.5.3B Other Surface Impoundments 42
5.5.4 OtherDisposal 42
Section 5 Column A: Total Release 42
Section 5 Column B: Basis of Estimate 43
Section 5 Column C: Percent From Stormwater 44
Section 6. Transfers of the EPCRA Section 313 Chemical in Wastes to Off-Site Locations 45
6.1 Discharges to Publicly Owned Treatment Works 46
6.I.A.I Total Transfers 46
6.1.A.2 Basis of Estimate 46
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6.2 Transfers to Other Off-Site Locations 47
6.2a Column A: Total Transfers 47
6.2b Column B: Basis of Estimate 49
6.2c Column C: Type of Waste Management: Disposal/ Treatment/Energy Recovery/Recycling 50
Section 7. On-Site Waste Treatment, Energy Recovery, and Recycling Methods 53
Section 7A On-Site Waste Treatment Methods and Efficiency 53
7A Column a: General Waste Stream 53
7A Column b: Waste Treatment Method(s) Sequence 53
7A Column c: Range of Influent Concentration 56
7A Column d: Waste Treatment Efficiency Estimate 57
7A Column e: Based on Operating Data? 57
Section 7B On-Site Energy Recovery Processes 57
Section 7C On-Site Recycling Processes 58
Section 8. Source Reduction and Recycling Activities 60
D. Facility Eligibility Determination for Alternate Threshold and for
Reporting on EPA Form A 70
D. 1 Alternate Threshold 70
D.2 What is the Form A Certification Statement? 70
D.3 What is the Total Annual Reportable Amount? 70
D.4 Recordkeeping 70
D.5 Multi-establishment Facilities 70
D.6 Trade Secrets 71
D.7 Metals and Metal Category Compounds 71
E. Instructions for Completing EPA Form A 72
Part I. Facility Identification Information 72
Section 1. Reporting Year 72
Section 2. Trade Secret Information 72
2.1 Are you claiming the EPCRA Section 313 chemical identified on page 2 a trade secret? 72
2.2 If "yes" in 2.1, is this copy sanitized or unsanitized? 72
Section 3. Certification 72
Section 4. Facility Identification 72
4.1 Facility Name, Location, and TRI Facility Identification Number 72
4.2 Federal Facility Designation 73
4.3 Technical Contact 73
4.4 Intentionally Left Blank 73
4.5 Standard Industrial Classification (SIC) Code 73
4.6 Latitude and Longitude 73
4.7 Dun & Bradstreet Number(s) 74
4.8 EPA Identification Number(s) 74
4.9 Facility NPDES Permit Number(s) 74
4.10 Underground Injection Well Code (UIC) Identification Number(s) 74
Section 5. Parent Company Information 74
5.1 Name of Parent Company 74
5.2 Parent Company's Dun & Bradstreet Number 74
Part II. Chemical Identification 75
Section 1. Toxic Chemical Identity 75
1.1 CAS Number 75
1.2 EPCRA Section 313 Chemical or Chemical Category Name 75
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1.3 Generic Chemical Name 75
Section 2. Mixture Component Identity 76
2.1 Generic Chemical Name Provided by Supplier 76
Table I SIC codes 10-73 1-1
Table II EPCRA Section 313 Chemical List (including chemical categories) for Reporting Year 2003 II-l
Table III State Abbreviations III-l
Table IV Federal Information Processing Standards (FIPS) Codes IV-1
Appendix A Federal Facility Reporting Information A-l
Appendix B Reporting Codes for EPA Form R and Instructions for Reporting Metals B-l
Appendix C Facility Data Profiles and Common Errors in Completing Form R Reports and Form
A Certifications C-l
Appendix D Supplier Notification Requirements D-l
Appendix E How to Determine Latitude and Longitude From Topographic Maps E-l
Appendix F State Designated Section 313 Contacts F-l
Appendix G Section 313 EPA Regional Contacts G-l
Appendix H Other Relevant Section 313 Materials H-l
Appendix I Sample Revision and Withdrawal Letters 1-1
Index
iv Toxics Release Inventory Reporting Forms and Instructions
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Toxics Release Inventory - Made Easy (TRI-ME) Software 2004
The TRI-ME 2004 software helps facilities in determining and completing their Emergency Planning and Community
Right-to-Know (EPCRA) section 3 13 and Pollution Prevention Act (PPA) section 6607 obligations. TRI-ME is an
interactive, intelligent, user-friendly software tool that guides facilities through the TRI reporting experience. By leading
prospective reporters through a series of logically ordered questions, TRI-ME streamlines the analysis needed to determine
if a user must complete a Form R report or Form A Certification Statement for a particular chemical. For those facilities
required to report, the software provides the user with guidance for each data element on the reporting forms.
Additionally, this software has a one-stop guidance feature, the TRI Assistance Library that allows users to search the
statute, regulations, and many EPCRA section 313 guidance documents by key word. For the more experienced reporter,
TRI-ME allows direct data entry onto electronic versions of the Form R and Form A Certification Statement. TRI-ME
will check the data for common errors and then prepare the forms. All of the information contained in this RY2004
Reporting Forms and Instructions book is contained within TRI-ME.
TRI-ME allows the user to submit the forms on paper, floppy disk, or electronically via an Internet connection. TRI-ME
has the ability to submit electronically over the Internet using EPA's CDX without mailing any paper to EPA. In past
years, facilities had to submit a signed certification statement. Now facilities can certify their submissions electronically
without mailing any paper to EPA. After submission of data to EPA via CDX, a receipt is generated and sent via email to
the facility. Starting with RY 2004, first time reporters will be eligible to submit via CDX. Detailed information
regarding this new feature is provided in the TRI-ME software.
Toxics Release Inventory Assistance Library (TRIAL)
TRIAL is a searchable, indexed file that contains the statutes, the regulations, and most of the key guidance documents a
facility is likely to need for TRI reporting. TRIAL is integrated into TRI-ME.
What Happened to the Automated TRI Reporting Software (ATRS)?
EPA is no longer producing new versions of ATRS . After Reporting Year 200 1 , EPA replaced ATRS with the TRI-ME
software. For Reporting Year 2004, facilities are encouraged to use the TRI-ME software. TRI-ME was distributed as a
pilot for Reporting Year 2000. In Reporting Year 2001, EPA distributed both TRI-ME and ATRS to all TRI reporting
facilities.
Can I Use or Load Past Year's data into TRI-ME?
You may load prior year data from Reporting Year 2003 submission diskettes or from TRI-ME Reporting Year 2003
facility files. With few exceptions, all of your prior year data will be loaded directly into the Reporting Year 2004 forms.
To load Reporting Year 2001 or 2002 data into TRI-ME 2004, you must first load your data into TRI-ME 2003.
Can I Use TRI-ME if I Have My Own TRI Software?
Yes. Some facilities have their own software or use private software to assist in preparing their TRI reports. This "third
party software" is often designed to produce output files that match EPA's Magnetic Media File Formats (sometimes
called the TRI 18 flat files). These file formats can be found on the TRI Home page at . You may load
these flat files directly into TRI-ME and then use TRI-ME to check your forms for common errors. You can then also use
TRI-ME to submit the forms to U.S. EPA and your state.
What Are the Key Features of TRI-ME?
D TRI-ME allows prior TRI reporters to submit a paperless submission through the Internet, via CDX. For the first
time beginning with RY 2004, the TRI-ME software will allow first-time reporters to submit their reports via
CDX.
D An expert desk top software tool that guides facilities through the process of determining whether they must
report based on the SIC codes, number of employees and chemical threshold criteria.
Toxics Release Inventory Reporting Forms and Instructions v
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Toxics Release Inventory - Made Easy (TRI-ME) Software 2004
Walks users through the process of preparing and submitting their forms. Many routine tasks associated with the
preparation and submission of the forms have been eliminated or streamlined.
Assists facilities in understanding each element of the Form R and Form A Certification Statement.
Allows expert users to bypass most of the detailed assistance and directly enter data into the forms.
Enables users to access and search the TRI Assistance Library to find additional guidance from EPA on how to
report. With TRI-ME there is often no need to obtain a paper version of an EPA TRI guidance document.
Contains extensive intelligence to prevent facilities from making common errors.
Alerts users to possible errors so they can double check their forms before submitting them.
Assists users in completing Section 8 of the Form R. 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.
Allows users to load their data from the prior year.
Also enables facilities to submit their forms on a floppy disk or on traditional paper forms to their state.
vi Toxics Release Inventory Reporting Forms and Instructions
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Chemical and Industry Guidance Documents
To receive a copy of any of the EPCRA section 313
documents listed below, check the box(es) next to the
desired document(s). There is no charge for any of these
documents. Be sure to type or clearly print your full
mailing address in the space provided on the third page of
this form (page x). Send this request form to the address
below or call 202 564-9554. Many of these documents are
available via the Internet. For current versions, visit the
TRI Home page .
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave., N.W.
Attn: TRI Documents
MC: 2844T
Washington, DC 20460
202 564-9554
Email: TRIDOCS@epa.gov
I. General Guidance
Q 40 CFR 372, Toxic Chemical Release Reporting;
Community Right-to-Know; Final Rule
A reprint of the final EPCRA section 313 rule as it
appeared in the Federal Register (FR) February 16,
1988 (53 FR 4500) (OTSFR 021688).
Q Common Synonyms for Chemicals Listed Under
Section 313 of the Emergency Planning and
Community Right-to-Know Act
March 1995 (EPA 745-R-95-008)
This glossary contains chemical names and their
synonyms for substances covered by the reporting
requirements of EPCRA section 313. The glossary was
developed to aid in determining whether a facility
manufactures, processes, or otherwise uses a chemical
subject to EPCRA section 313 reporting.
Q EPCRA Section 313 Questions and Answers —
Revised 1998 Version
December 1998 (EPA 745-B-98-004)
The revised 1998 EPCRA Section 313 Questions and
Answers document assists regulated facilities in
complying with the reporting requirements of EPCRA
section 313. This updated document presents interpretive
guidance in the form of answers to many commonly asked
questions on compliance with EPCRA section 313. In
addition, this document includes comprehensive written
directives to assist covered facilities in understanding
some of the more complicated regulatory issues. This
updated guidance document is intended to supplement the
instructions for completing the Form R and the Alternate
Q
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
Addendum for Federal Facilities
May 2000 (EPA 745-R-00-003)
and Answers
This document is an addendum to the EPCRA section
313 Questions and Answers — Revised 1998 Version. It
provides additional assistance to federal facilities in
complying with EPCRA section 313. Federal facilities,
which are subject to compliance under EPCRA through
Executive Order 13148, frequently have operations that
are different from the private sector facilities subject to
EPCRA. The document contains questions and answers
that address some of those differences.
EPCRA Section 313 Release and Other Waste
Management Reporting Requirements
February 2001 (EPA 260/K-0 1-001)
The brochure alerts businesses to their reporting
obligations under EPCRA section 313 and assists in
determining whether their facility is required to report.
The brochure contains the EPA regional contacts, the
list of EPCRA section 313 toxic chemicals and a
description of the Standard Industrial Classification
(SIC) codes subject to EPCRA section 313.
Persistent Bioaccumulative Toxic (PBT) Chemicals;
Final Rule (64 FR 58666)
A reprint of the final rule that appeared in the Federal
Register of October 29, 1999. This rule adds certainPBT
chemicals and chemical categories for reporting year
2000 and beyond under EPCRA section 313, lowers
their activity thresholds and modifies certain reporting
exemptions and requirements for PBT chemicals and
chemical categories. In a separate action, as part of the
October 29, 1999 rulemaking, EPA added vanadium
(except when contained in alloy) and vanadium
compounds. These are not listed as PBT chemicals.
Supplier Notification Requirements
(EPA 560-4-9 1-006)
This pamphlet assists chemical suppliers who may be
subject to the supplier notification requirements, gives
Toxics Release Inventory Reporting Forms and Instructions vii
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Chemical and Industry Guidance Documents
examples of situations which require notification,
describes the trade secret provision, and contains a
sample notification.
Q Toxic Chemical Release Inventory Reporting
Forms and Instructions Revised 20043 Version
January 2005 (EPA 260-B-05-001)
Q Toxics Release Inventory: Reporting
Modifications Beginning with 1995 Reporting
Year
February 1995 (EPA 745-R-95-009)
G 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) and includes a copy of the
trade secret substantiation form.
II. Chemical-Specific Guidance
EPA has developed a group of guidance documents specific
to individual chemicals and chemical categories.
Q Emergency Planning and Community Right-to-
Know Section 313: List of Toxic Chemicals
within the Chlorophenols Category
June 1999 (EPA745-B-99-013)
Q Toxics Release Inventory List of Toxic
Chemicals within the Glycol Ethers Category
and Guidance for Reporting
December 2000 (EPA745-R-00-004)
Q Emergency Planning and Community Right-to-
Know Act Section 313: Guidance for Reporting
Hydrochloric Acid (acid aerosols including
mists, vapors, gas, fog and other airborne
forms of any particle size)
December 1999 (EPA 745-B-99-014)
Q Emergency Planning and Community Right-to-
Know Act - Section 313: Guidance for
Reporting Releases and Other Waste
Mangement Activities of Toxic Chemicals:
Lead and Lead Compounds
November 2001 (EPA-260-B-01-027)
Q Emergency Planning and Community Right-to-
Know Act - Section 313: Guidance for
Reporting Toxic Chemicals: Mercury and
Mercury Compounds Category
August 2001 (EPA 260-B-01-004)
Q Toxics Release Inventory List of Toxic Chemicals
within the Nicotine and Salt Category and
Guidance for Reporting
June 1999 (EPA 745-R-99-010)
Q 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)
Q Emergency Planning and Community Right-to-
Know Act - Section 313: Guidance for Reporting
Toxic Chemicals: Pesticides and Other Persistent
Bioaccumulative Toxic (PBT) Chemicals
August 2001 (EPA 260-B-01-005)
Q Toxics Release Inventory List of Toxic Chemicals
within the Polychlorinated Alkanes Category and
Guidance for Reporting
June 1999 (EPA 745-B-99-023)
Q Emergency Planning and Community Right-to-
Know Act - Section 313: Guidance for Reporting
Toxic Chemicals: Polycyclic Aromatic
Compounds Category
August 2001 (EPA 260-B-01-003)
Q Toxics Release Inventory List of Toxic Chemicals
within the Strychnine and Salts Category and
Guidance for Reporting
June 1999 (EPA 745-R-99-011)
Q 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)
Q Toxics Release Inventory List of Toxic Chemicals
within Warfarin Category
June 1999 (EPA745-B-99-011)
Q Toxics Release Inventory List of Toxic Chemicals
within Ethylenebisdithiocarbamic Acid, Salts and
Esters Category and List of Mixtures that Contain
the Individually listed Chemicals Maneb,
Metiram, Nabam, and Zineb
September 2001 (EPA 260-B-01-026)
Q Emergency Planning and Community Right-to-
Know Act - Section 313: Guidance for Reporting
Q EPCRA Section 313: Guidance for
viii Toxics Release Inventory Reporting Forms and Instructions
-------
Chemical and Industry Guidance Documents
Petroleum Terminals and Bulk Storage
Facilities
February 2000 (EPA 745-B-00-002)
Q Emergency Planning and Community Right-
to-Know Act Section 313 Reporting Guidance
for the Presswood and Laminated Products
Industry
August 2001 (EPA 260-B-01-013)
Q EPCRA Section 313 Reporting Guidance for
the
Printing, Publishing, and Packaging Industry
May 2000 (EPA 745-B-00-005)
Q EPCRA Section 313: Guidance for RCRA
Subtitle C TSD Facilities and Solvent Recovery
Facilities
January 1999 (EPA 745-B-99-004)
Q EPCRA Section 313 Reporting Guidance for
Rubber and Plastics Manufacturing
May 2000 (EPA 745-B-00-017)
Q EPCRA Section 313 Reporting Guidance for
Semiconductor Manufacturing
July 1999 (EPA 745-R-99-007)
Q EPCRA Section 313 Reporting Guidance for
Spray Application and Electrodeposition of
Organic Coatings
December 1998 (EPA 745-R-98-014)
Q EPCRA Section 313 Reporting Guidance forthe
Textile Processing Industry
May 2000 (EPA 745-B-00-008)
Q Aqueous Ammonia
December 2000 (EPA 745-R-00-005)
Q Emergency Planning and Community Right-to-
Know Act - Section 313: Guidance for Reporting
Toxic Chemicals within the Dioxin and Dioxin-
like Compounds Category
December 2000 (EPA 745-B-00-021)
III. Industry-Specific Guidance
EPA has developed a group of individual guidance
documents for certain industries.
Q EPCRA Section 313: Guidance for
Chemical Distribution Facilities
January 1999 (EPA 745-B-99-005)
Q EPCRA Section 313: Guidance for
Coal Mining Facilities
February 2000 (EPA 745-B-00-003)
Q EPCRA Section 313: Guidance for
Electricity Generating Facilities
February 2000 (EPA 745-B-00-004)
Q EPCRA Section 313 Reporting Guidance for Food
Processors
September 1998 (EPA 745-R-98-011)
Q EPCRA Section 313 Reporting Guidance for
the Leather Tanning and Finishing Industry
April 2000 (EPA 745-B-00-012)
Q EPCRA Section 313: Guidance for
Metal Mining Facilities
Januaryl999 (EPA 745-B-99-001)
Toxics Release Inventory Reporting Forms and Instructions ix
-------
Chemical and Industry Guidance Documents
PLEASE TYPE MAILING ADDRESS HERE (DO NOT ATTACH BUSINESS CARDS)
Name/Title
Company Name
Mail Stop
Street Address
P.O. Box
City/State/ZIP Code
x Toxics Release Inventory Reporting Forms and Instructions
-------
Paperwork Reduction Act Notice: The annual public burden related to the Form R,
which is approved under OMB Control No. 2070-0093, is estimated to average 30.2 hours per
response for non-PBT chemicals and 52.1 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 20.6 hours for a facility that certifies one chemical per Form A
Certification Statement. Responding to this information collection requires 1) determining
whether a listed toxic chemical is eligible for certification under the alternate threshold, and
2) completing the Form A Certification Statement. The burden of determining eligibility for
certification and associated recordkeeping is estimated to average 19.2 hours for each
chemical that is certified. The burden of completing the Form A Certification Statement is
estimated to average 1.4 hours, regardless of the number of chemicals being certified. The
total burden per response is the combination of these two, and will vary depending on the
number of listed toxic chemicals being certified.
Burden means the total time, effort, or financial resources expended by persons to
generate, maintain, retain, or disclose or provide information to or for a Federal agency. This
includes the time needed to review instructions; develop, acquire, install, and utilize
technology and systems for the 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 xi
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 01/31/2006 Page 1 of 5
United States
Environmental Protection
Agency
FOMMM
Section 313 of the Emergency Planning and Community
Right-to-Know Act of 1986, also Known as Title III of the
Superfund Amendments and Reauthorization Act
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center
P.O. Box 1513
Lanham, MD 20703-1513
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix F)
Enter "X" here if
this is a revision
For EPA use only |
IMPORTANT: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART 1. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
Are you claiming the toxic chemical identified on page 2 trade secret?
2.1
Yes (Answer question 2.2;
Attach substantiation forms)
No (Do not answer 2.2;
Go to Section 3)
2.2
Is this copy
Sanitized
Unsanitized
(Answer only if "YES" in 2.1)
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted information is true and complete and that
the amounts and values in this report are accurate based on reasonable estimates using data available to the preparers of this report.
Name and official title of owner/operator or senior management official:
Signature:
Date Signed:
SECTION 4. FACILITY IDENTIFICATION
4.1
TRI Facility ID Number
Facility or Establishment Name j
Facility or Establishment Name or Mailing Address (If different from street address) I
Street
Mailing Address j
City/County/State/Zip Code j
City/State/Zip Code j
Country (Non-US)
4.2
rhis report contains information for:
iportant: Check a or b; check c or d if applicable) a.
An entire
facility b.
Part of a
facility
A Federal
facility
GOCO
Technical Contact Name
Telephone Number (include area code) j
Email Address
4.4
Public Contact Name \
Telephone Number (include area code) j
4.5
SIC Code (s) (4 digits)
Primary
b.
d.
e.
f.
4.6
Latitude
Degrees
Minutes
Seconds
Longitude
Degrees
Minutes
Seconds
4.7
Dun & Bradstreet
Number (s) (9 digits)
4.8
EPA Identification Number
(RCRA ID No.) (12 characters)
4.9
Facility NPDES Permit
Number(s) (9 characters)
4.10
Underground Injection Well Code
(UIC) I.D. Number(s) (12 digits)
b.
b.
SECTION 5. PARENT COMPANY INFORMATION
5.1
Name of Parent Company
NA
5.2
Parent Company's Dun & Bradstreet Number
NA
EPA Form 9350-1 (Rev. 02/2004) - Previous editions are obsolete.
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Form Approved OMB Number: 2070-0093
Approval Expires: 01/31/2006 Page 2 of 5
mi Facility ID Number
FOMMM
PART II. TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM
Toxic Chemical, Category or Generic Name
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important: DO NOT complete this section if you completed Section 2 below.)
CAS Number (Important: Enteronly one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part 1. Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
i A Distribution of Each Member of the Dioxin and Dioxin-Iike Compounds Category.
(If there are any numbers in boxes 1-17, then every field must be filled in with either 0 or some number between 0.01 and 100. Distribution should
be reported in percentages and the total should equal 100%. If you do not have speciation data available, indicate NA.)
123456 7 8 9 10 11 12 13 14 15 16 17
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- EH Produce b. D Import
If produce or import
C. LJ For on-site use/processing
d.LJ For sale/distribution
As a byproduct
As an impurity
a.
As a reactant
\)\ \ As a formulation component
C.| I As an article component
d.j j Repackaging
e. j j As an impurity
a. j j As a chemical processing aid
b. j j As a manufacturing aid
C. | | Ancillary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ONSITE AT ANY TIME DURING THE CALENDAR YEAR
4.1
(Enter two digit code from instruction package.)
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
A. Total Release (pounds/year*)
(Enter a range code** or estimate)
B. Basis of Estimate
(enter code)
C. % From Stormwater
5.1
Fugitive or non-point
air emissions
NA
5.2
Stack or point
air emissions
NA
5.3
Discharges to receiving streams or
water bodies (enter one name per box)
Stream or Water Body Name
5.3.1
5.3.2
5.3.3
If additional pages of Part II, Section 5.3 are attached, indicate the total number of pages in this box
and indicate the Part II, Section 5.3 page number in this box.
(example: 1,2,3, etc.)
EPA Form 9350-1 (Rev. 02/2004) - Previous editions are obsolete.
*For Dioxin or Dioxin-like compounds, report in grams/year.
** Range Codes: A= 1-10 pounds; B= 11-499 pounds; C= 500-999 pounds.
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Form Approved OMB Number: 2070-0093
Approval Expires: 01/31/2006
Page 3 of 5
FOMMM
PART II. CHEMICAL - SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE (continued)
NA
A. Total Release (pounds/year*) (enter range
code ** or estimate )
B. Basis of Estimate
(enter code)
5.4.1
Underground Injection onsite
to Class I Wells
5.4.2
Underground Injection onsite
to Class II-V Wells
5.5
Disposal to land onsite
5.5.1A
RCRA Subtitle C landfills
5.5.1B
Other landfills
5.5.2
Land treatment/application
farming
5.5.3A
RCRA Subtitle C
surface impoundments
5.5.3B
Other surface impoundments
5.5.4 Other disposal
SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1. A Total Quantity Transferred to POTWs and Basis of Estimate
6 1 A 1 °a Transfers (pounds/year*)
(enter range code ** or estimate)
6.1. A.2 Basis of Estimate
(enter code)
6.1.B
POTWName
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 | j (example: 1,2,3, etc.)
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
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. 02/2004) - Previous editions are obsolete.
* For Dioxin or Dioxin-like compounds, report in grams/year
' Range Codes: A=l-10 pounds: B=l 1-499 pounds; C=500 - 999 pounds.
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 01/31/2006
Page 4 of 5
FOMMM
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (CONTINUED)
A. Total Transfers (pounds/year*)
(enter range code**or estimate)
B. Basis of Estimate
(enter code)
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1.
1.
1. M
2.
2.
2. M
3.
3.
3. M
4.
4.
4. M
6.2.
Off-Site EPA Identification Number (RCRA ID No.)
Off-Site Location Name
Off-Site Address
City
State
County
Zip
Country
(Non-US)
Is location under control of reporting facility or parent company?
Yes
No
A. Total Transfers (pounds/year*)
(enter range code**or estimate)
B. Basis of Estimate
(enter code)
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1.
1. M
2.
2.
2. M
3.
3.
3. M
4.
4.
4. M
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
Not Applicable (N A) -
Check here if no on-site waste treatment is applied to any
waste stream containing the toxic chemical or chemical category.
a. General
Waste Stream
(enter code)
b. Waste Treatment Method(s) Sequence
[enter 3-character code(s)]
c. Range of Influent
Concentration
d. Waste Treatment
Efficiency
Estimate
e. Based on
Operating Data?
7A.lc
7A.ld
7A.le
Yes
No
a a
7A.2c
7A.2d
7A.2e
Yes
No
7A.3c
7A.3d
7A.3e
Yes
No
7A.4c
7A.4d
7A.4e
Yes
No
7A.5c
7A.5d
7A.5e
Yes
No
If additional pages of Part II, Section 6.2/7A are attached, indicate the total 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.)
EPAForm 9350-1 (Rev. 02/2004) - Previous editions are obsolete.
*For Dioxin or Dioxin-like compounds, report in grams/year
"Range Codes: A=l - 10 pounds; B=ll - 499 pounds C= 500-999 pounds.
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 01/31/2006
Page 5 of 5
FOMMM
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
CnecK here U
Not Applicable (N A) -
no on-site energy recovery is applied to any waste
ling the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character code(s)]
1 2 3
SECTION 1C. ON-SITE RECYCLING PROCESSES
, . , , ^necK nere 11 no
Not Applicable (N A) -
stream conlamir
on-site recycling is applied to any waste
ig the toxic chemical or chemical category.
Recycling Methods [enter 3-character code(s)]
12 3 4 5
67 8 9 10
SECTION 8. SOURCE REDUCTION AND RECYLMG ACTIVITIES
8.1
8.1a
8.1b
8.1c
8.1d
8.2
8.3
8.4
8.5
8.6
8.7
8.8
8.9
8.10
8.10.1
8.10.2
8.10.3
8.10.4
8.11
Total on-site disposal to Class I
Underground InjectionWells, RCRA
Subtitle C landfills, and other landfills
Total other on-site disposal or other
releases
Total off-site disposal to Class I
Underground InjectionWells, RCRA
Subtitle C landfills, and other landfills
Total other off-site disposal or other
releases
Quantity used for energy recovery
onsite
Quantity used for energy recovery
offsite
Quantity recycled
onsite
Quantity recycled offsite
Quantity treated onsite
Quantity treated offsite
Column A
Prior Year
(pounds/year*)
• ,.', ' • ; x<<; x<~ xx*; xx*; xx>; xx*; xx*; xx*; x; *
•V *'/' v.V:yxx^vxx^vxx^vxx^vxx^vxx^vxx^ •>.
Column B
Current Reporting Year
(pounds/year*)
:••'• r^^^y^y^y^y^y^yrf;
Quantity released to the environment as a result of remedial actions, catastrophic events,
or one-time events not associated with production processes (pounds/year)*
Production ratio or activity index
Column C
Following Year
(pounds/year*)
•;%?mmmmmm'f';:
Column D
Second Following Year
(pounds/year*)
'. .." .' ••••••••••••••••••••••••••• •' 'y
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 Methods to Identify Activity (enter codes)
[enter code(s)]
a. b. c.
a. b. c.
a. b. c.
a. b. c.
Is additional information on source reduction, recycling , or pollution control activities included with Yes No
this report? (Check one box)
EPA Form 9350-1 (Rev. 02/2004) - Previous editions are obsolete.
*For Dioxin or Dioxin-like compounds, report in grams/year
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0143
Approval Expires: 01/31/2006 Page "* of ,
United States
Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY
FORMA
WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center 2. APPROPRIATE STATE OFFICE
P.O Box 1513 (See instructions in Appendix F)
Lanham, MD 20703-1513
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
Enter "X" here if this
is a revision
For EPA use only
Important: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART I. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
2.1
Are you claiming the toxic chemical identified on page 2 trade secret?
No (Do not answer 2.2;
Yes (Answer question 2.2;
Attach substantiation forms)
Go to Section 3)
2.2
Is this copy
Sanitized
Unsanitized
(Answer only if "YES" in 2.1)
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that to the best of my knowledge and belief, for each toxic chemical listed in the statement, the annual reportable
amount as defined in 40 CFR 372.27 (a), did not exceed 500 pounds for this reporting year and that the chemical was
manufactured, processed, or otherwise used in an amount not exceeding 1 million pounds during this reporting year.
Name and official title of owner/operator or senior management official:
Signature:
Date Signed:
SECTION 4. FACILITY IDENTIFICATION
4.1
TRI Facility ID Number
Facility or Establishment Name
Facility or Establishment Name or Mailing Address(if different from street address)
Street
Mailing Address
City/County/State/Zip Code
City/State/Zip Code
Country (Non-US)
4.2
This report contains information for:
: check c or d if applicable)
c.
A Federal
facility
GOCO
4.3
Technical Contact Name
Telephone Number (include area code)
Email Address
4.4
Intentionally left blank
4.5
SIC Code (s) (4 digits)
Primary
a.
b.
c.
d.
e.
4.6
Latitude
Degrees
Minutes
Seconds
Longitude
Degrees
Minutes
Seconds
4.7
Dun & Bradstreet
Number(s) (9 digits)
4.8
EPA Identification Number
(RCRA I.D. No.) (12 characters)
4.9
Facility NPDES Permit
Number(s) (9 characters)
4.10
Underground Injection Well Code
(UIC) I.D. Number(s) (12 digits)
a.
b.
SECTION 5. PARENT COMPANY INFORMATION
5.1
Name of Parent Company
NA
5.2
Parent Company's Dun & Bradstreet Number
NA
EPA Form 9350-2 (Rev. 02/2004) - Previous editions are obsolete.
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IMPORTANT: Type or print; read instructions before completing form
Page of
EPA FORM A
PART II. CHEMICAL IDENTIFICATION TRIFID:
Do not use this form for reporting PBT chemicals including Dioxin and Dioxin-like Compounds*
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
* See the TRI Reporting Forms and Instructions Manual for the list of PBT Chemicals (including Dioxin and Dioxin-like Compounds)
EPA Form 9350-2 (Rev. 02/2004) - Previous editions are obsolete. (Make additional copies of this page, if needed)
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A. General Information
Reporting to the Toxic Chemical Release Inventory (i.e., Toxics
Release Inventory (TRI)) is required by section 313 of the
Emergency Planning and Community Right-to-Know Act
(EPCRA, or Title III of the Superfund Amendments and
Reauthorization Act of 1986), Public Law 99-499. The
information contained in the Form R constitutes a "report," and
the submission of a report to the appropriate authorities
constitutes "reporting."
The Pollution Prevention Act, passed into law in October, 1990
(Pub. L. 101-508), added reporting requirements to Form R.
These requirements affect all facilities required to submit Form
R under section 313 of EPCRA. The data were required
beginning with reports for calendar year 1991.
Reporting is required to provide the public with information on
the releases and other waste management of EPCRA section 313
chemicals in their communities and to provide EPA with release
and other waste management information to assist the Agency
in determining the need for future regulations. Facilities must
report the quantities of routine and accidental releases, and
releases resulting from catastrophic or other one time events of
EPCRA section 313 chemicals, as well as the maximum amount
of the EPCRA section 313 chemical on-site during the calendar
year and the amount contained in wastes managed on-site or
transferred off-site.
A completed Form R or Form A must be submitted for each
EPCRA section 313 chemical manufactured, processed, or
otherwise used at each covered facility as described in the
reporting rules in 40 CFR Part 372 (originally published
February 16, 1988, in the Federal Register and November 30,
1994, in the Federal Register (for Form A)).
A.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.
D 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
D The facility is included in Standard Industrial Classification
(SIC) Codes 10 (except 1011, 1081, and 1094), 12 (except
1241), 20-39, 4911 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4931 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4939 (limited to
facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4953
(limited to facilities regulated under RCRA Subtitle C, 42
U.S.C. section6921 etseq.), 5169,5171, and7389 (limited
to facilities primarily engaged in solvents recovery
services on a contract or fee basis); and
D The facility manufactures (defined to include
importing), processes, or otherwise uses any
EPCRA section 313 chemical in quantities greater
than the established threshold in the course of a
calendar year.
Executive Order 13148 extends these reporting
requirements to federal facilities, regardless of their SIC
code.
A.2 How to Report to TRI
A.2.a. The Toxic Chemical Release
Reporting Form, EPA Form R
The five-page EPA Form R consists of two parts:
O Part I, Facility Identification Information (page 1);
and
O Part II, Chemical-Specific Information (pages 2-5).
Most of the information required in Part I of Form R can
be completed, photocopied, and attached to each
chemical-specific report. However, Part I of each Form R
submitted must have an original signature on the
certification statement. In addition the trade secret
designation must be entered as appropriate. Part II must
be completed separately for each EPCRA section 313
chemical or chemical category. Because a complete Form
R consists of at least five unique pages, any submission
containing less than five unique pages is not a valid
submission.
A complete report for any EPCRA section 313 chemical
that is not claimed as a trade secret consists of the
following completed parts:
O Part I with an original signature on the certification
statement (Section 3); and
O Part II.
A.2.b. The Alternate Threshold Form A Certification
Statement
EPA Form A Certification Statement (hereafter referred to
as Form A) was established in 1994. This form is based
on an alternate threshold for facilities with small quantities
of an EPCRA section 313 chemical released or otherwise
Toxics Release Inventory Reporting Forms and Instructions 1
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General Information
managed as waste. The Form A serves to certify that a facility
is not subject to Form R reporting for a specific toxic chemical.
Like the Form R described above, the Form A consists of two
parts, but only consists of a total of two pages.
G Part I, Facility Identification Information, which also
includes the "certification" regarding the eligibility to use
the Form A (page 1); and
G Part II, Chemical Identification (page 2).
Since 1998, the Form A may be used to report multiple
chemicals. Four chemicals may be reported on page 2 of the
form. If more than four chemicals are to be reported, additional
copies of page 2 can be used to report qualifying chemicals.
The Form A must have an original certification statement on
page 1 and contain an appropriate trade secret designation for
the form. A complete report for Form A consists of at least two
pages for each submission.
A.3 How to Submit Forms
A.S.a. How to Submit Form R(s) and/or Form A(s) to
EPA via the Internet (EPA's Central Data Exchange
(CDX))
The preferred method to report to TRI is by the use of the
TRI-Made Easy (TRI-ME) software and submit through the
Internet via CDX. CDX allows facilities to file a paperless
report, significantly reduce data errors, and receive instant
receipt confirmation of your submission.
EPA encourages you to use TRI-ME to submit your TRI
submission(s) via CDX. TRI-ME allows you to submit a
completely paperless report to EPA (Internet and diskette
submissions are not available for trade secret claims). If you
choose to submit via the Internet, do not send duplicate paper
or diskette copies of the reports. Please be aware that
submitting via the Internet to EPA does not satisfy your state
reporting requirements for your facility. You must report to
your state separately and in the required format specified by
your state (i.e., diskette, paper, etc.).
If you have any questions about the CDX submission process,
call toll free: 1- 888-890-1995 between the hours of 8:00
A.M. - 6:00 P.M. Eastern Time. For additional information
about CDX, please see: .
A.S.b. How to Send Your Disks Containing Form R(s)
and/or Form A(s)
If you do not have Internet access, EPA still encourages you
to use the TRI-ME software and submit your reports using a
diskette. If you choose to submit your TRI Form R(s) and or
Form A(s) on magnetic media/diskette using TRI-ME, please
follow the instructions below. If you choose to submit
on diskette, do not submit duplicate CDX or paper
copies of the reports that are on the diskette.
A.3.b.l Labeling Your Submission Diskette
Company
Date: 6/30/2005
Report Year: 2004
Contact:
Name
Density:
Number
HD
1 of 1
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 300
8400 Corporate Drive
Landover, MD 20785-2294
301 429-5005
If you are submitting reports on magnetic media/diskette
to EPA, you must enclose a cover letter signed by the
official listed in Section 3 of Part I of the Form R or Form
A (name and official title of senior management official)
for each separate facility. The TRI-ME software assists
the user in preparing cover letters for both EPA and states.
The letter on page 8 is a sample. Since you are filing by
diskette, do not include duplicate paper copies of the
reports that are on the diskette.
A.3.b.2 Submitting by Diskette to States
Submitters must submit a copy of each Form R or Form A
to the appropriate state agency. As of the publication of
this book and the TRI Reporting Software, the following
states confirmed that they accept diskette submissions:
2 Toxics Release Inventory Reporting Forms and Instructions
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General Information
AK
AL
AZ1
CA
CO
DE
FL
GA
HI
IA
ID
IL
IN
KS
LA
MA
MD2
MI3
MN
MO4
MT
ND
NH
NJ
NM
NV
NY
OH
OK
OR
PA
PR
sc5
SD
TX
UT
VA
VT
WA
WI
WV
WY
'Arizona Emergency Response Commission accepts
electronic submissions, however the Arizona Dept. of Environmental
Quality accepts only paper submissions. Submissions must be sent to
both agencies.
Maryland accepts diskette submissions, but requires that
paper copies be sent as well.
'Michigan accepts Internet submissions; reports submitted
electronically via Internet to EPA's Central Data Exchange does not
require any separate mailing of reports (disk or paper). Also
acceptsdiskettes.
4Missouri only accepts diskettes created using TRI-ME
software.
5South Carolina only accepts reports submitted electronically
via Internet to EPA's Central Data Exchange. Facilities submitting by
Internet are exempt from any separate mailing to SC DHEC. If
Internet access is not available, it will be necessary to mail a diskette
copy to SC DHEC.
If your state is not listed here, please contact your state office to
confirm that paper submissions are required. A list of state
contacts can be found in Appendix F.
A.3.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 300
8400 Corporate Drive
Landover, MD 20785-2294
(301)429-5005
Also send a copy of the report to the state in which the
facility is located ("state" also includes: the District of
Columbia, the Commonwealth of Puerto Rico, Guam,
American Samoa, Marshall Islands, the U.S. Virgin
Islands, the Commonwealth of the Northern Mariana
Islands, and any other jurisdiction and Indian Country.).
Refer to Appendix F for the appropriate state submission
addresses.
Facilities located on Indian land should send a copy to the
Chief Executive Officer of the applicable Indian tribe.
Some tribes have entered into a cooperative agreement
with states; in this case, report submissions should be sent
to the entity designated in the cooperative agreement.
A.4 Trade Secret Claims
For any EPCRA section 313 chemical whose identity is
claimed as trade secret, you must submit to EPA two
versions of the substantiation form as prescribed in 40
CFR Part 350, published July 29, 1988, in the Federal
Register (53 FR 28772) as well as two versions of the
EPCRA section 313 report. One set of reports, the
"unsanitized" version, must provide the actual identity of
the EPCRA section 313 chemical. The other set of
reports, i.e., the "sanitized" version, must provide only a
generic identity of the EPCRA section 313 chemical. If
EPA deems the trade secret substantiation form valid, only
the sanitized set of forms will be made available to the
public.
Use the order form in this document to obtain copies of the
rule and substantiation form. Further explanation of the
trade secret provisions is provided in Part I, Sections 2.1
and 2.2, and Part II, Section 1.3, of the instructions.
In summary, a complete report to EPA for an EPCRA
section 313 chemical claimed as a trade secret must
include all of the following:
D A completed "unsanitized" version of Form R or
Form A report including the EPCRA section 313
chemical identity (staple the pages together); and
D A "sanitized" version of a completed Form R or
Form A report in which the EPCRA section 313
chemical identity items (Part II, Sections 1.1 and
1.2) have been left blank but in which a generic
chemical name has been supplied (Part II,
Section 1.3) (staple the pages together); and
Toxics Release Inventory Reporting Forms and Instructions 3
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General Information
D A completed "unsanitized" version of a trade secret
substantiation form (staple the pages together); and
D A "sanitized" version of a completed trade secret
substantiation form (staple the pages together).
Securely fasten all four reports together.
Some states also require submission of both sanitized and
unsanitized reports for EPCRA section 313 chemicals whose
identity is claimed as a trade secret. Others require only a
sanitized version. Facilities may jeopardize the trade secret
status of an EPCRA section 313 chemical by submitting an
unsanitized version of the EPCRA section 313 report to a state
agency or Indian tribe that does not require unsanitized forms.
You may identify an individual state's submission requirements
by contacting the appropriate state-designated EPCRA section
313 contact (see Appendix F).
Where to send your trade secret submission
Please send only trade secret submissions to the P.O. box below.
To send trade secret submissions by regular mail:
EPCRA Substantiation Packages
P.O. Box 1515
Lanham, MD 20703-1515
To send trade secret submissions by certified mail or overnight
mail (i.e. Fed Ex, UPS, etc.):
TRI Data Processing Center
c/o Computer Sciences Corporation
Suite 300
8400 Corporate Drive
Landover, MD 20785-2294
Attention: EPCRA Substantiation Packages
301 429-5005
A.5 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:
a Previous years' EPCRA section 313 reports;
a EPCRA section 313 Reporting Threshold
Worksheets;
a Engineering calculations and other notes;
a Purchase records from suppliers;
a Inventory data;
a EPA (NPDES) permits and monitoring reports;
a EPCRA section 312 Tier II Reports;
a Monitoring records;
a Flowmeter data;
O RCRA Hazardous Waste Generator's Report;
O Pretreatment reports filed by the facility with the
local government;
O Invoices from waste management companies;
d Manufacturer's estimates of treatment
efficiencies;
O RCRA manifests;
O Process diagrams that indicate emissions and
other releases; and
d Records for those EPCRA section 313 chemicals
for which they did not file EPCRA section 313
reports.
A.6 How to Revise or Withdraw TRI
Data
U.S. EPA has received several questions relating to
withdrawing and revising TRI data submitted by facilities,
such as:
What are the reasons for revising?
How do I revise my submission?
To whom should this request be sent?
What are the reasons for revising?
Facilities that filed a Form R and/or Form A Certification
Statement under EPCRA Section 313 may submit a
request to revise their submission(s) to the Toxics Release
Inventory System (TRIS) database and in the public
version of the database, Envirofacts and TRI Explorer.
Facilities may request a revision for one of several
reasons, such as:
4 Toxics Release Inventory Reporting Forms and Instructions
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General Information
To revise facility identification information
To revise chemical identification information
To revise release and other waste management
activities information
To revise as a result of an EPA/State inspection
To revise as a result of Data Quality Alerts, a Notice of
Technical Error (NOTE), Notice of Significant Error
(NOSE), or a Notice of Noncompliance (NON)
To revise as a result of a voluntary disclosure through
EPA's audit policy.
Note: Late submissions for chemicals not reported in a previous
reporting year are not considered revisions for that year.
How do I revise my subniission(s)?
If you have determined that your facility wishes to revise a TRI
submission, EPA recommends that you send your request to
EPA and the appropriate State agency. For submitting a
revision to EPA, one of the following methods is recommended:
1. TRI-ME via Internet (CDX) - The preferred method to
submitting revised TRI forms is by the use of the TRI Made-
Easy (TRI-ME) software and sub mission through the Internetvia
the CDX. You can download the TRI-ME software at
. There are several advantages to using
CDX. They are as follows: paperless filing, electronic signature
process, significant reduction of data errors, and instant
confirmation of your submission. If you have questions about
submitting forms via CDX, please contact the CDX Hotline at
epacdx@csc.com or call toll free: 1-888-890-1995. Submission
of revisions through CDX is only available for revision of
reports from RY 2002 and forward. For revisions to
submissions form RY 2001 and prior, EPA recommends using
an alternative, such as using ATRS or TRI-ME via diskette.
2. TRI-ME via diskette - If you do not have Internet access,
EPA still encourages you to use the TRI-ME software and to
submit responses by diskette to one of the addresses given
below. All diskette submissions must be accompanied by a
signed Certification Statement. If you do not have the TRI-ME
software for the Reporting Year that you are correcting, please
contact EPA at 202-564-9554.To send request by regular mail:
TRI Data Processing Center
P.O. Box 1513
Lanham,MD 20703-1513
Attention: TRI Revision Request
To send request by certified mail or overnight mail:
TRI Data Processing Center
c/o Computer Sciences Corporation
Suite 300
8400 Corporate Drive
Landover, MD 20785-2294
Attention: TRI Revision Request
301-429-5005
3. Hard Copy Form - Although EPA strongly
discourages paper submissions due to the increased
possibility of data entry errors, you may make corrections
by one of three hard copy methods:
Facility Data Profile (FDP)
Photocopy of Original
• Blank Form
D Facility Data Profile - The FDP presents the
information a facility submitted to EPA, and
includes identified errors with the submissions. If
you use the FDP to make corrections, you must
submit the full Form R or Form A Certification
Statement equivalent for each chemical. You
make your revisions by marking-up the FDP in
blue ink. Also, you must sign and submit the
certification statement on page 3 of the FDP. If
you do not have a copy of the facility FDP, you
can retrieve it from the Internet at
. If you orthe technical contact
have questions about how to respond by using your
FDP, please refer to the instruction page of the
FDP or call 301-429-5005.
D Photocopy of Original Submission - You may
submit a photocopy of your original submission
(from your file) with the corrections made in blue
ink. Reign and re-date the certification statement
on Page 1. Please enter an "X" in the space
marked "Enter 'X' here if this is a revision," on
page 1 of the form.
D Blank Form - Hard copy submissions may be
submitted using the form applicable for that
particular reporting year or the most recent form
available. You can request prior year reporting
forms at tridocs@epa.gov. Please remember to
certify and date the form on page 1.
Where to Send Your Revision Request
When submitting a revision request to EPA regarding the
submission(s) of your TRI Form R and/or Form A
Certification, please send your request to the TRI Data
Processing Center.
To send requests by regular mail:
TRI Data Processing Center
P.O. Box 1513
Lanham, MD 20703-1513
Attention: TRI Revision Request
To send requests by certified mail or overnight mail (i.e.
Fed Ex, UPS, etc.):
TRI Data Processing Center
Toxics Release Inventory Reporting Forms and Instructions 5
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General Information
c/o Computer Sciences Corporation
Suite 300
8400 Corporate Drive
Landover, MD 20785-2294
Attention: TRI Revision Request
301 429-5005
Submitting a Request to EPA to Withdraw TRI
Data
Facilities that filed a Form R and/or Form A Certification under
EPCRA Section 313 may send their requests to EPA to
withdraw the Form R and/or Form A Certification submission(s)
from EPA's database (i.e., the Toxics Release Inventory System
(TRIS)) and from the public version of the database.
In order to have a submission removed from the TRI database,
EPA recommends that facilities send their request to EPA and
the appropriate state agency, if required, by completing a
'Request for Withdrawal' template (provided in Appendix I of
this document). EPA will review each request and notify the
requestor by letter whether or not the withdrawal request has
been accepted. In order to effectively process the request, you
should submit the following information:
D Facility name and TRI Facility Identification Number
(TRIFID).
D Facility mailing address.
D Reporting year.
D Chemical name.
D Technical contact name and phone number.
D Name and phone number of the requester.
D Reason(s) for withdrawal.
D Signature.
Facilities may request a withdrawal for one or several reasons,
such as:
They manufacture, process or otherwise use less than
threshold quantities. (The reporting thresholds are
25,000 pounds for manufacturing or processing and
10,000 pounds for otherwise use except for persistent
bioaccumulative toxic (PBT) chemicals and chemical
categories. PBT chemicals and chemical categories have
reporting thresholds of 10 or 100 pounds except for the
dioxin and dioxin-like compounds category that has a
reporting threshold of 0.1 gram).
• Change in EPA reporting requirements for this chemical.
It is no longer manufactured, processed or otherwise
used above reporting thresholds or it has been deleted
from the EPCRA Section 313 toxic chemical list.
Qualify for one of the following EPCRA Section 313
exemptions:
> de minimis (Please note that de minimis
exemption is not allowed for PBT chemicals
and chemical categories).
> Article.
>• Laboratory activities.
>• Use as structural component.
>• Coal extraction activities.
*• Routine janitorial or facility grounds
maintenance.
*• Use for motor vehicle
maintenance/operation.
>• Personal use by employees or other
persons.
>• Chemical contained in certain intake
water or intake air.
*• Metal mining overburden.
The chemical reported is not an EPCRA Section
313 reportable chemical.
The chemical reported is not in a form listed on the
EPCRA Section 313 toxic chemical list (i.e.,
aerosol, fume or dust, fibrous form, etc.).
Activities involving the reported chemical do not
meet the definition of manufacturing, processing,
or otherwise use.
Qualify for a Form A Certification submission.
Where to send your withdrawal request
When submitting a withdrawal request to EPA regarding
the submission(s) of your TRI Form R and/or Form A
Certification, please send your request to the TRI Data
Processing Center.
To send requests by regular mail:
TRI Data Processing Center
P.O. Box 1513
Lanham,MD 20703-1513
Attention: TRI Withdrawal Request
To send requests by certified mail or overnight mail (i.e.
Fed Ex, UPS, etc.):
TRI Data Processing Center
c/o Computer Sciences Corporation
Suite 300
8400 Corporate Drive
Landover, MD 20785-2294
Attention: TRI Withdrawal Request
301 429-5005
A.7 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
6 Toxics Release Inventory Reporting Forms and Instructions
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General Information
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). RY2004 reports should be
postmarked on or before Friday, July 1, 2005. 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
Facility Data Profile (FDP). The FDP presents the information
you have submitted to EPA. If the Technical Contact provided
an email address in the Form R/Form A, they will receive an
email notifying them when their FDP has been updated and
posted to the FDP website. You can retrieve your FDPs at
. If you have questions regarding your FDP,
please send an email to tri.efdp@csc.com or call, 1-301-429-
5005.
A.8 How to Obtain Forms and Other
Information
A copy of both forms is included in this booklet. Remove the
appropriate form and produce as many photocopies as needed.
Related guidance documents may be obtained from EPA's TRI
Web site and EPA:
U.S. Environmental Protections Agency
Ariel Rios Building
1200 Pennsylvania Ave., N.W.
Attn: TRI Documents
MC: 2844T
Washington, DC 20460
202 564-9554
Email: TRIDOCS@epa.gov
See "Chemical and Industry Specific Documents" section (p. ix)
for the document request form and more information on
available documents.
Questions about completing Form R or Form A may be directed
to the EPCRA Call Center toll free. For contact information
see the TRI Home Page at .
EPA Regional Staff also may be of assistance. Refer to
Appendix G for a list of EPA Regional Offices.
Toxics Release Inventory Reporting Forms and Instructions 7
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General Information
Sample Letter — Reporting by diskette. Send one copy to EPCRA Reporting Center and one to appropriate state
agency (see Appendix F). TRI-ME automatically creates this letter for you if you elect to create a diskette submission.
Facility Name
Facility Address
Facility City/State/Zip Code
TRI Facility ID
Date
TRI Data Processing Center
P.O. Box 1513
Lanham, MD 20703-1513
Attn: Toxic Chemical Release Inventory
Magnetic Media Submission
To Whom It May Concern:
Enclosed please find one (1) microcomputer diskette containing toxic chemical release reporting information for:
YOUR FACILITY NAME
This information is submitted as required under section 313 of the Emergency Planning and Community Right-to-
Know Act of 1986 and section 6607 of the Pollution Prevention Act of 1990.
We are submitting a total of 1 Chemical Report(s) for our facility.
These 1 chemical report(s) are described below:
Chemical Name Reporting Year CAS Number Report Type
Zinc (fume or dust) 2004 7440-66-6 5-page Form R
Our technical point of contact is:
[TECHNICAL CONTACT NAME] Phone Number: 505 555-1212
and is available should any questions or problems arise in your processing of these diskettes.
If the enclosed diskette contains one or more Form R chemicals, then I hereby certify that I have reviewed the enclosed
documents and that, to the best of my knowledge and belief, the submitted information is true and complete and that the
amounts and values in this report(s) are accurate based on reasonable estimates using data available to the preparers of
this report(s).
If the enclosed diskette contains one or more Form A chemicals, then I hereby certify that to the best of my knowledge
and belief, for each toxic chemical listed in the Form A statement, the annual reportable amount as defined in 40 CFR
372.27(a) did not exceed 500 pounds for this reporting year and that the chemical was manufactured, processed or
otherwise used in an amount not exceeding 1 million pounds during the reporting year.
Sincerely,
Signature
8 Toxics Release Inventory Reporting Forms and Instructions
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B. How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A Certification Statement
This section will help you determine whether you must
submit an EPCRA section 313 report (EPA Form R or Form
A Certification Statement). This section discusses EPCRA
section 313 reporting requirements such as the number of
full-time employees, primary SIC code, and chemical activity
threshold quantities. The EPCRA section 313 chemicals and
chemical categories subject to reporting are listed in Table II
(also see 40 CFR 372.65). (See Figure 1 for more
information.)
B.I Full-Time 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:
D 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.
D Another facility consists of six workers and three sales
staff. The six workers each worked 2,000 hours for the
facility during the calendar year. The sales staff also
each worked 2,000 hours during the calendar year
although they may have been on the road half of the
year. In addition, five contract employees were hired
for a period during which each worked 400 hours for
the facility. The total number of hours is equal to the
time worked by the workers (12,000 hours), plus the
time worked by the sales staff for the facility (6,000
hours), plus the time worked by the contract employees
(2,000 hours), or 20,000 hours. Dividing the 20,000
hours by 2,000 yields 10 full-time employees. This
facility has met the full time employee criteria and may
be subject to reporting if the other criteria are met.
B.2 Primary SIC Code Determination
Standard Industrial Classification (SIC) codes 10 (except
1011, 1081, and 1094), 12 (except 1241), 20-39, 4911
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4939 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4953 (limited to
facilities regulated under the RCRA Subtitle C, 42 U.S.C.
section 6921 et seq.\ 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvent recovery services on
a contract or fee basis) are covered by EPCRA section 313
and are listed in Table I. The first two digits of a 4-digit
SIC code define a major business sector, while the last two
digits denote a facility's specialty within the major sector.
For a detailed description of 4-digit SIC codes, refer to the
"Standard Industrial Classification Manual 1987." The
facility should determine its own SIC code (s), based on its
activities on-site, using the SIC Manual. State agencies and
other organizations may assign SIC codes on a different basis
than the one used by the SIC Manual. However, for purposes
of EPCRA section 313 reporting, these state assigned codes
should not be used if they differ from ones assigned using the
SIC Manual.
The EPCRA Call Center can assist facilities with determining
which SIC codes are assigned for specific business activities
as referenced in the SIC Manual. Clothbound editions of the
SIC Manual are available in most major libraries or may be
ordered through the National Technical Information Service,
5285 Port Royal Road, Springfield, VA 22161, 703
605-6000. The access number for the clothbound manual is
PB87-100012, and the price is $36.00 + shipping and
handling.
Facilities should be aware that in several years from now, the
TRI Program will be using North American Industry
Classification System (NAICS) codes instead of SIC codes.
Please refer to the TRI Program's proposed rule titled
"Community Right-to-Know; Toxic Chemical Release
Reporting Using North American Industry Classification
System (NAICS)" published in the Federal Register on
March 21,2003. (66 FR13 872) This upcoming change does
NOT affect 2004 EPCRA Section 313 reporting.
Toxics Release Inventory Reporting Forms and Instructions 9
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Does your facility have 10 or more full-time
employees or the equivalent?
(see definition under B.I)
i
YES
r
Is your facility's primary SIC Code included on the
EPCRA Section 313 list?
or is your facility a Federal facility?
(see B.2 and Table I)
i
YES
r
Does Your Facility Manufacture, Process, or
Otherwise Use Any EPCRA Section 313 Chemicals
and Chemical Categories?
(See Table II. B.3-B.5, andD.l-D.7)
^
YES
r
Does Your Facility Exceed Any of the Thresholds for
a Chemical or Chemical Category (after excluding
quantities that are exempt from threshold calculations)
^
YES
r
AN EPCRA SECTION 313 REPORT IS
REQUIRED FOR THIS CHEMICAL OR
CHEMICAL CATEGORY
^
YES
r
Is the chemical or chemical category identified as
Persistent, Bioaccumulative and Toxic (PBT)?
YES
^
NO
r
NO ^
NO
NO
NO ^
STOP
NO EPCRA
SECTION 3 13
REPORTS
REQUIRED FOR
ANY CHEMICALS
Is the amount manufactured, OR processed, OR otherwise used, less than or equal to 1,000,000 pounds
AND is the reportable amount less than or equal to 500 Ibs/yr
•\' i
NO YES
r '\'
FORM R IS REQUIRED FOR THIS CHEMICAL
OR CHEMICAL CATEGORY
(FORM A CANNOT BE SUBMITTED)
FORMA
OR
FORM R IS REQUIRED FOR THIS CHEMICAL
CATEGORY
Figure 1. EPCRA Section 313 Reporting Decision Diagram
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. Multi-Establishment Facilities
Your facility may include multiple establishments that have
different SIC codes. A multi-establishment facility is a facility
that consists of two or more distinct and separate economic
units. If your facility is a multi-establishment facility,
calculate
the value added of the products produced, shipped, or services
provided from each establishment within the facility and then
use the following rule to determine if your facility meets the
SIC code criterion:
Q If the total value added of the products produced,
shipped, or services provided at establishments with
covered SIC codes, i.e., 10 (except 1011, 1081, and
1094), 12 (except 1241), 20-39, 4911 (limited to
facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4939 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4953 (limited to facilities
regulated under the RCRA Subtitle C, 42 U.S.C. section
6921 et seq.), 5169, 5171, or 7389 (limited to facilities
primarily engaged in solvents recovery services on a
contract or fee basis) is greater than 50% of the value
added of the entire facility's products and services, the
entire facility meets the SIC code criterion.
Q If any one establishment with a covered SIC code, i.e.,
10 (except 1011, 1081, and 1094), 12 (except 1241),
20-39, 4911 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4931 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 493 9 (limited to
facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4953
(limited to facilities regulated under the RCRA Subtitle
C, 42 U.S.C. section 6921 et seq.), 5169, 5171, or 7389
(limited to facilities primarily engaged in solvents
recovery services on a contract or fee basis) has a value
added of services or products shipped or produced that is
greater than any other establishment within the facility
(40 CFR Section 372.22(b)(3)) the facility also meets the
SIC code criterion.
The value added of production or service attributable to a
particular establishment may be isolated by subtracting the
product value obtained from other establishments within the
same facility from the total product or service value of the
facility. This procedure eliminates the potential for "double
counting" production and services in situations where
establishments are engaged in sequential production or service
activities at a single facility.
Examples include:
Q A facility in coating, engraving and allied services has
two establishments. The first establishment, a general
automotive repair service, is in SIC code 7537, which is
not a covered SIC code. However, the second
establishment, a metal paint shop is in SIC code 3479,
which is a covered SIC code. The metal paint shop
paints the parts received from general automotive repair
service. The facility determines the product is worth
$500/unit as received from the general automotive repair
service (in non covered SIC code 7537) and the value of
the product is $1500/unit after processing by the metal
paint shop (in covered SIC code 3479). The value added
by the metal paint shop is obtained by subtracting the
value of the products from the general automotive repair
service from that of the value of the products of the metal
paint shop. (In this example, the value added =
$ 1,500/unit - $500/unit = $ 1,000/unit.) The value added
($l,000/unit) by the establishment in SIC code 3479 is
more than 50% of the product value. Therefore, the
facility's primary SIC code is 3479, which is a covered
SIC code.
Q A food processing establishment in a facility processes
crops grown at the facility in a separate establishment.
To determine the value added of the products of each
establishment the facility could first determine the value
of the crops grown at the agricultural establishment, and
then calculate the contribution of the food processing
establishment by subtracting the crop value from the total
value of the product shipped from the processing
establishment (value of product shipped from processing
- crop value = value of processing establishment).
A covered multi-establishment facility must make EPCRA
section 313 chemical threshold determinations and, if required,
must report all relevant information about releases and other
waste management activities, and source reduction activities
associated with an EPCRA section 313 chemical for the
entire facility, even from establishments that are not in
covered SIC codes (i.e., the covered SIC codes are 10 (except
1011,1081, and 1094), 12 (except 1241), 20-39,4911 (limited
to facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in commerce),
4939 (limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in commerce),
4953 (limited to facilities regulated under the RCRA Subtitle
C, 42 U.S.C. section 6921 et seq.), 5169, 5171, and 7389
(limited to facilities primarily engaged in solvents recovery
services on a contract or fee basis)). EPA realizes, however,
that certain establishments in a multi-establishment facility can
be, for all practical purposes, separate business units.
Therefore, while threshold determinations must be made for
the entire facility, individual establishments may report
Toxics Release Inventory Reporting Forms and Instructions 11
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
releases and other waste management activities separately,
provided that the total releases and other waste management
quantities for the whole facility are represented by the sum
of the releases and other quantities managed as waste
reported by each of the separate establishments and the
compliance determination is based on the entire facility.
B.2.b. Auxiliary Facilities
An auxiliary facility is one that supports another covered
establishment's activities (e.g., research and development
laboratories, warehouses, and storage facilities). An
auxiliary facility can assume the SIC code of another
covered establishment if its primary function is to service
that other covered establishment's operations. For the
purposes of EPCRA section 313, auxiliary facility is defined
as one primarily engaged in performing support services for
another covered establishment or multiple establishments of
a covered facility and is in a different physical location than
the primary facility. In addition, an auxiliary facility
performs an integral role in the primary facility's activities.
In general, an auxiliary facility's basic administrative
services (paperwork, payroll, employment) are performed by
the primary facility. Thus, a separate warehouse facility (i.e.,
one not located within the physical boundaries of a covered
facility) may become a covered facility because it services a
covered establishment in SIC codes 10 (except 1011, 1081,
and 1094), 12 (except 1241), 20-39, 4911 (limited to
facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4939 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4953 (limited to facilities
regulated under the RCRA Subtitle C, 42 U.S.C. section
6921 etseq.), 5169, 5171, and 7389 (limited to facilities
primarily engaged in solvents recovery services on a
contract or fee basis). Auxiliary facilities that are in these
aforementioned codes are required to report if they meet the
employee criterion and reporting thresholds for
manufacture, process, or otherwise use.
B.2.c. Property Owners
You are not required to report if you merely own real estate
on which a facility covered by this rule is located; that is,
you have no other business interest in the operation of that
facility (e.g., your company owns an industrial park). The
operator of that facility, however, is subject to reporting
requirements.
B.3 Activity Determination
B.S.a. Definitions of "Manufacture,"
"Process," and "Otherwise Use"
Manufacture: The term "manufacture" means to produce,
prepare, compound, or import an EPCRA section 313
chemical. (See Part II, Section 3.1 of these instructions for
further clarification.)
Import is defined as causing the EPCRA section 313
chemical to be imported into the customs territory of the
United States. If you order an EPCRA section 313 chemical
(or a mixture containing the chemical) from a foreign
supplier, then you have imported the chemical when that
shipment arrives at your facility directly from a source
outside of the United States. By ordering the chemical, you
have "caused it to be imported," even though you may have
used an import brokerage firm as an agent to obtain the
EPCRA section 313 chemical.
Do Not Overlook Coincidental Manufacture
The term manufacture also includes coincidental production
of an EPCRA section 313 chemical (e.g., as a byproduct or
impurity) as a result of the manufacture, processing,
otherwise use or disposal of another chemical or mixture of
chemicals. In the case of coincidental production of an
impurity (i.e., an EPCRA section 313 chemical that remains
in the product that is distributed in commerce), the de
minimis exemption, discussed in Section B.3.c of these
instructions, applies. The de minimis exemption does not
apply to byproducts (e.g., an EPCRA section 313 chemical
that is separated from a process stream and further processed
or disposed). Certain EPCRA section 313 chemicals may be
manufactured as a result of wastewater treatment or other
treatment processes. For example, neutralization of
wastewater containing nitric acid can result in the
coincidental manufacture of a nitrate compound (solution),
reportable as a member of the nitrate compounds category.
Process: The term "process" means the preparation of a
listed EPCRA section 313 chemical, after its manufacture,
for distribution in commerce. Processing is usually the
incorporation of an EPCRA section 313 chemical into a
product (see Part II, Section 3.2 of these instructions for
further clarification), however, a facility may process an
impurity that already exists in a raw material by distributing
that impurity in commerce. Processing includes preparation
of the EPCRA section 313 chemicals in the same physical
state or chemical form as that received by your facility, or
12 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Example 1: Coincidental Manufacture
Your company, a nitric acid manufacturer, uses aqueous ammonia in a waste treatment system to neutralize an acidic
wastewater stream containing nitric acid. The reaction of ammonia and nitric acid produces a solution of ammonium nitrate.
Ammonium nitrate (solution) is reportable under the nitrate compounds category and is manufactured as a byproduct. If the
ammonium nitrate is produced in a quantity that exceeds the 25,000-pound manufacturing threshold, the facility must report
under the nitrate compounds category.
The aqueous ammonia is considered to be otherwise used and 10% of the total aqueous ammonia would be counted towards
the 10,000-pound otherwise use threshold. Reports for releases of ammonia must also include 10% of the total aqueous
ammonia from the solution of ammonium nitrate (see the qualifier for the ammonia listing).
As another example, combustion of coal or other fuel in boilers/furnaces can result in the coincidental manufacture of metal
category compounds and sulfuric acid (acid aerosols), hydrochloric acid (acid aerosols), and hydrogen fluoride.
Example 2: Typical Process and Manufacture Activities
Q Your company receives toluene, an EPCRA section 313 chemical, from another facility, and reacts the toluene with air
to formbenzoic acid, which the company distributes in commerce. Your company processes toluene and manufactures
and processes benzoic acid. Benzoic acid, however, is not an EPCRA section 313 chemical and thus does not trigger
reporting requirements.
Q Your facility combines toluene purchased from a supplier with various materials to form paint which it then sells. Your
facility processes toluene.
Q Your company receives a nickel compound (nickel compounds is a listed EPCRA section 313 chemical category) as
a bulk solid and performs various size-reduction operations (e.g., grinding) before packaging the compound in 50-
pound bags, which the company sells. Your company processes the nickel compound.
Q Your company receives a prepared mixture of resin and chopped fiber to be used in the injection molding of plastic
products. The resin contains a listed EPCRA section 313 chemical that becomes incorporated into the plastic, which
the company distributes in commerce. Your facility processes the EPCRA section 313 chemical.
Q In the combustion of coal or oil, metal category compounds may be produced from either the parent metal or a metal
compound contained in the coal or oil. If a metal undergoes a change of valence, a metal compound is considered to
be manufactured. For example, during the combustion process copper in valence state zero changes to copper in
valence state +2 in a compound such as copper (II) oxide (CuO). Furthermore, a metallic compound could be
transformed to another metallic compound without a change in valency (e.g., copper (II) chloride (CuCl) is transformed
to copper (II) oxide). The transformation to a new compound by combustion without a change in valence state is also
considered to be "manufactured" for purposes of EPCRA section 313.
Toxics Release Inventory Reporting Forms and Instructions 13
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
preparation that produces a change in physical state or
chemical form. The term also applies to the processing of a
mixture or other trade name product (see Section B.4.b of
these instructions) that contains a listed EPCRA section 313
chemical as one component.
Otherwise Use: The term "otherwise use" means any use of
an EPCRA section 313 chemical, including an EPCRA section
313 chemical contained in a mixture or other trade name
product or waste, that is not covered by the terms
"manufacture" or "process." Otherwise use of an EPCRA
section 313 chemical does not include disposal, stabilization
(without subsequent distribution in commerce), or treatment
for destruction unless:
(1) The EPCRA section 313 chemical that was disposed,
stabilized, or treated for destruction was received from off-site
for the purposes of further waste management;
or
(2) The EPCRA section 313 chemical that was disposed,
stabilized, or treated for destruction was manufactured as a
result of waste management activities on materials received
from off-site for the purposes of waste management activities.
Relabeling or redistributing of the EPCRA section 313
chemical where no repackaging of the EPCRA section 313
chemical occurs does not constitute an otherwise use or
processing of the EPCRA section 313 chemical." (See 62 FR
23846 and Part II, Section 3.3 of these instructions for further
clarification).
Example 3: Typical Otherwise Use Activities
When your facility cleans equipment with toluene, you are otherwise using toluene. Your facility also separates two
components of a mixture by dissolving one component in toluene, and subsequently recovers the toluene from the
process for reuse or disposal. Your facility otherwise uses toluene.
Acoveredfacilityreceivesawaste containing 12,000 pounds of Chemical A, anon-PBT EPCRA section 313 chemical,
from off-site. The facility treats the waste, destroying Chemical A and in the treatment process manufactures 10,500
pounds of Chemical B, another non-PBT EPCRA section 313 chemical. Chemical B is disposed on-site. Since the
waste containing Chemical A was received from off-site for the purpose of waste management, the amount of Chemical
A must be included in the otherwise use threshold determination for Chemical A. The otherwise use threshold for a non-
PBT chemical is 10,000 pounds and since the amount of Chemical A exceeds this threshold, all releases and other waste
management activities for Chemical A must be reported. Chemical B was manufactured in the treatment of a waste
received from off-site. The facility disposed of Chemical B on-site. Since Chemical B was generated from waste
received from off-site for treatment for destruction, disposal, or stabilization, the disposal of Chemical B is considered
to be an otherwise use. Thus, the amount of Chemical B must be considered in the otherwise use threshold
determination. Thus, the reporting threshold for Chemical B has also been exceeded and all releases and other waste
management activities for Chemical B must be reported.
B.S.b. Persistent Bioaccumulative
Toxic (PBT) Chemicals and
Chemical Categories Overview
On October 29, 1999 EPA published a final rule (64 FR
58666) adding certain chemicals and chemical categories to
the EPCRA section 313 list of toxic chemicals and lowering
the reporting threshold for persistent bioaccumulative toxic
(PBT) chemicals. In addition, on January 17, 2001 EPA
published a final rule (66 FR 4500) that classified lead and
lead compounds as PBT chemicals and lowered their
reporting thresholds. The lower reporting thresholds for lead
applies to all lead except when lead is contained in a stainless
steal, brass or bronze alloy.
Dioxin and dioxin-like compounds, lead compounds, mercury
compounds and poly cyclic aromatic compounds (PACs) are
the four PBT chemical categories with lower reporting
thresholds. The 17 members of the dioxin and dioxin-like
compounds category and the 21 members of the PACs
category are listed in Table He of these instructions. The dioxin
and dioxin-like compounds category has the qualifier,
"Manufacturing; and 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 gram. The
table at the beginning of Section B.4 of these instructions lists
14 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
the applicable manufacture, process, and otherwise use
thresholds for the listed PBT chemical.
EPA eliminated the de minimis exemption for all PBT
chemicals (except lead when contained in stainless steel,
brass or bronze alloy). However, this action does not affect
the applicability of the de minimis exemption to the supplier
notification requirements (40 CFR Section 372.45(d)(l)).
All PBT chemicals and chemical categories (hereafter
referred to as PBT chemicals) are excluded from eligibility
for the alternate threshold of one million pounds. Thus the
Form A cannot be used for PBT chemicals (except lead when
it is in stainless steel, brass or bronze alloys when the 100 Ibs
threshold for lead has not been exceeded). In addition, PBT
chemicals are ineligible for range reporting for on-site
releases and transfers off site for further waste management.
This will not affect the applicability of range reporting of the
maximum amount on site as required by EPCRA section
313(g).
All releases and other waste management quantities greater
than 0.1 pounds of a PBT chemical (except the dioxin and
dioxin-like compounds chemical category) should be reported
at a level of precision supported by the accuracy of the
underlying data and estimation techniques on which the
estimate is based. For quantities of 10 pounds or greater,
only whole numbers are required to be reported. If a
facility's release or other waste management estimates
support reporting an amount that is more precise than whole
numbers, then the more precise amount should be reported.
Forthe dioxin and dioxin-like compounds chemical category,
which has a reporting threshold of 0.1 gram, facilities need
only report all release and other waste management quantities
greater than 100 micrograms (i.e., 0.0001 grams).
Notwithstanding the numeric precision used when
determining reporting eligibility thresholds, facilities should
report on Form R to the level of accuracy that their data
supports, up to seven digits to the right of the decimal. EPA's
reporting software and data management systems support
data precision to seven digits to the right of the decimal. If a
facility has information on the distribution of dioxin and
dioxin-like compounds, the facility must report either the
distribution that best represents the distribution of the total
quantity of dioxin and dioxin-like compounds released to all
media, or the facility's one best media specific distribution in
Part II, Section 1.4, of the Form R (40 CFR Section
372.85(b)(15)(ii)).
Lead and Lead Compounds
Beginning January 1, 2001, lead and lead compounds are
classified as PBT chemicals and are subject to the lower
manufacturing, processing and otherwise use threshold of 100
pounds. However, when lead is contained in stainless steel,
brass, or bronze alloys it is subject to the higher 25,000
pound manufacturing and processing thresholds and the
10,000 pound otherwise use threshold. Listed below are some
important guidelines to use when calculating threshold and
release and other waste management quantities:
1) quantities of lead not contained in stainless steel,
brass or bronze alloy are applied to both the 100 pound
threshold and the 25,000/10,000 pound thresholds;
2) quantities of lead that are contained in stainless
steel, brass or bronze alloys are only applied toward the
25,000/10,000 pound thresholds;
3) a facility may take the de minimis exemption for
those quantities of lead in stainless steel, brass, or bronze alloys
that meet the de minimis standard (e.g., manufactured as an
impurity). Accordingly, the de minimis exemption may be
considered for quantities of lead in stainless steel, brass, or
bronze alloys but it may not be considered for lead not in
stainless steel, brass, or bronze alloys;
4) Form A, range reporting in Sections 5 and 6 of the
Form R and the use of whole numbers and 2 significant digits
may not be applied to lead reporting once the lower, 100 pound
threshold has been exceeded. Therefore, if a facility exceeds
the 25,000/10,000 pound threshold does not exceed the 100
pound threshold, the facility may consider Form A, range
reporting in Sections 5 and 6 of the Form R, and the use of
whole numbers and 2 significant digits. Once the 100 pound
threshold is exceeded, however, the facility may not consider
Form A, range reporting in Sections 5 and 6 of the Form R and
the use of whole numbers and 2 significant digits even if the
25,000/10,000 pound threshold is also exceeded; and
5) consolidated reporting between lead and lead
compounds is allowed only on Form R because Form A is never
allowed when reporting lead compounds.
B.3.C. Activity Exemptions
Otherwise Use Exemptions. Certain otherwise uses of listed
EPCRA section 313 chemicals are specifically exempted:
Q Otherwise use as a structural component of the
facility;
Q Otherwise use in routine janitorial or facility grounds
maintenance;
Q Personal uses by employees or other persons;
Q Otherwise use of products containing EPCRA section
313 chemicals for the purpose of maintaining motor
vehicles operated by the facility;
and
Q Otherwise use of EPCRA section 313 chemicals
contained in intake water (used for processing or
non-contact cooling) or in intake air (used either as
compressed air or for combustion).
The exemption of an EPCRA section 313 chemical otherwise
used 1) as a structural component of the facility; or 2) in routine
Toxics Release Inventory Reporting Forms and Instructions 15
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
janitorial or facility grounds maintenance; or 3) for personal
use by an employee cannot be taken for activities involving
process-related equipment.
Articles Exemption. EPCRA section 313 chemicals
contained in articles that are processed or otherwise used at
a covered facility are exempt from threshold determinations
and release and other waste management calculations. The
exemption applies when the facility receives the article from
another facility or when the facility produces the article itself.
The exemption applies only to the quantity of EPCRA section
313 chemical present in the article. If the EPCRA section
313 chemical is manufactured (including imported),
processed, or otherwise used at the covered facility other than
as part of the article, in excess of an applicable threshold
quantity, the facility is required to report (40 CFR Section
372.38(b)). For an EPCRA section 313 chemical in an item
to be exempt as part of the article, the item must meet all the
following criteria in the EPCRA section 313 article
definition; that is, it must be a manufactured item (1) which
is formed to a specific shape or design during manufacture,
(2) which has end use functions dependent in whole or in part
upon its shape or design during end use, and (3) which does
not release a toxic chemical under normal conditions of
processing or otherwise use of the item at the facility.
If the processing or otherwise use of all like items results in
a total release of 0.5 pound or less of an EPCRA section 313
chemical in a reporting year to any environmental medium,
EPA will allow this release to be rounded to zero, and the
manufactured items retain their article status. The 0.5 pound
threshold does not apply to each individual article, but applies
to the sum of all releases from processing or otherwise use of
all like articles. If all the releases of like articles over a
reporting year are completely captured and recycled/reused
on-site or off-site, those items retain their article status. Any
amount that is released and is not recycled/reused will count
toward the 0.5 pound per year cut-off value.
The articles exemption applies to the normal processing or
otherwise use of articles. This exemption does not apply to
the manufacture of the article. EPCRA section 313 chemicals
incorporated into articles produced at a facility must be
factored into threshold determinations and release and other
waste management calculations.
If, in the course of processing or otherwise use, an item
retains its initial thickness or diameter, in whole or in part, it
meets the first part (i.e., it must be a manufactured item
which is formed to a specific shape or design during
manufacture) of the article definition. If the item's basic
dimensional characteristics are totally altered during
processing or otherwise use, the item does not meet the first
part of the definition. An example of items that do not meet
the definition would be items which are cold extruded, such
as lead ingots, which are formed into wire or rods. On the
other hand, cutting a manufactured item into pieces which are
recognizable as the article would not change the original
dimensions as long as the diameter or the thickness of the item
remained the same; the articles exemption would continue to
apply. Metal wire may be bent and sheet metal may be cut,
punched, stamped, or pressed without losing their article status
as long as the diameter of the wire or tubing or the thickness of
the sheet is not totally changed.
An important aspect of the articles exemption is what
constitutes a release of an EPCRA section 313 chemical. Any
processing or otherwise use of like articles that results in a
release to the environment (of more than 0.5 pounds) negates
the article status and precludes eligibility for the exemption.
Cutting, grinding, melting, or other processing of manufactured
items could result in a release of an EPCRA section 313
chemical during normal conditions of processing or otherwise
use and therefore negate the exemption as articles.
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Example 4: Articles Exemption
Nickel that is incorporated into a brass doorknob is processed to manufacture the brass doorknob, and therefore must
be counted toward threshold determinations and release and other waste management calculations. However, the use
of the brass doorknobs elsewhere in the facility does not have to be counted. Disposal of the brass doorknob after its
use does not constitute a "release;" thus, the brass doorknob remains an article.
If an item used in the facility is fragmented, the item is still an article if those fragments being discarded remain
identifiable as the article (e.g., recognizable pieces of a cylinder, pieces of wire). For instance, an eight-foot piece of
wire is cut into two four-foot pieces of wire, without releasing any EPCRA section 313 chemicals. Each four-foot piece
is identifiable as a piece of wire; therefore, the article status for these pieces of wire remains intact.
EPCRA section 313 chemicals received in the form of pellets are not articles because the pellet form is simply a
convenient form for further processing of the material.
De Minimis Exemption. The de minimis exemption allows
facilities to disregard certain minimal concentrations of non-PBT
chemicals in mixtures or other trade name products when making
threshold determinations and release and other waste
management calculations. The de minimis exemption does not
apply to the manufacture of an EPCRA section 313 chemical
except if that EPCRA section 313 chemical is manufactured as an
impurity and remains in the product distributed in commerce, or
if the EPCRA section 313 chemical is imported below the
appropriate de minimis level. The de minimis exemption does not
apply to a byproduct manufactured coincidentally as a result of
manufacturing, processing, otherwise use, or any waste
management activities. The de minimis exemption does not apply
to any PBT chemical (except lead when it is contained in
stainless steel, brass or bronze alloy) or PBT chemical category.
A list of PBT chemicals may be found in Section B.4 of these
instructions.
When determining whether the de minimis exemption applies to
an EPCRA section 313 chemical, the owner/operator must
consider the concentration of the non-PBT EPCRA section 313
chemical in mixtures and other trade name products. If the non-
PBT EPCRA section 313 chemical in a mixture or other trade
name product is manufactured as an impurity, imported,
processed, or otherwise used and is below the appropriate de
minimis concentration level, then the quantity of the non-PBT
EPCRA section 313 chemical in that mixture or other trade name
product does not have to be applied to threshold determinations
nor included in release or other waste management
determinations. If a non-PBT EPCRA section 313 chemical in a
mixture or other trade name product is below the appropriate de
minimis level, all releases and other waste management activities
associated with the EPCRA section 313 chemical in that mixture
or other trade name product are exempt from EPCRA section 313
reporting. It is possible to meet an activity (e.g., processing)
threshold for an EPCRA section 313 chemical on a facility-wide
basis, but not be required to calculate releases or other waste
management quantities associated with a particular process
because that process involves only mixtures or other trade name
products containing the non-PBT EPCRA section 313 chemical
below the de minimis level.
EPA interprets the de minimis exemption such that once a non-
PBT EPCRA section 313 chemical concentration is at or above
the appropriate de minimis level in the mixture or other trade
name product threshold determinations and release and other
waste management calculations must be made, even if that
chemical later falls below the de minimis level in the same
mixture or other trade name product. Thus, EPA considers
reportable all releases and other quantities managed as waste that
occur after the de minimis level has been met or exceeded. If an
EPCRA section 313 chemical in a mixture or other trade name
product at or above de minimis is brought on-site, the de minimis
exemption never applies.
De minimis levels for non-PBT EPCRA section 313 chemicals
and chemical categories are set at concentration levels of either
1% or 0.1%; PBT chemicals and chemical categories do not have
de minimis levels with regard to this exemption. The 0.1% de
minimis levels are dictated by determinations made by the
National Toxicology Program (NTP) in its Annual Report on
Carcinogens, the International Agency for Research and Cancer
(IARC) in its Monographs, or 29 CFR part 1910, subpart Z.
Therefore, once a non-PBT chemical's status under NTP, IARC,
or 29 CFR part 1910, subpart Z indicates that the chemical is a
carcinogen or potential carcinogen, the reporting facility may
disregard levels of the chemical below the 0.1% de minimis
concentration provided that the other criteria for the de minimis
exemption are met. De minimis levels for chemical categories
apply to the total concentration of all chemicals in the category
within a mixture, not the concentration of each individual
category member within the mixture.
De Minimis Application to the Processing or
Otherwise Use of a Mixture
The de minimis exemption applies to the processing or otherwise
use of a non-PBT EPCRA section 313 chemical in a mixture.
Threshold determinations and release and other waste
management calculations begin at the point where the chemical
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
meets or exceeds the de minimis level. If a non-PBT EPCRA Concentration Ranges Straddling the De Minimis Value
section 313 chemical is present in a mixture at a concentration
below the de minimis level, this quantity of the substance does There may be instances in which the concentration of a non-PBT
not have to be included for threshold determinations, release and chemical is given as a range straddling the de minimis limit.
other waste management reporting, or supplier notification Example 6 illustrates how the de minimis exemption should be
requirements. The exemption will apply as long as the mixture applied in such a scenario.
containing de minimis amounts of a non-PBT EPCRA section
313 chemical never equals or goes above the de minimis limit.
Example 5: De Minimis Applications to Process and Otherwise Use Scenarios for Non-PBT Chemicals
There are many cases in which the de minimis "limit" is crossed or recrossed by non-PBT chemicals within a process or otherwise
use scenario. The following examples are meant to illustrate these complex reporting scenarios.
Increasing Concentration To or Above De Minimis Levels During Processing for Non-PBT Chemicals
A manufacturing facility receives toluene that contains chlorobenzene at a concentration below its de minimis limit. Through
distillation, the chlorobenzene content in process streams is increased over the de minimis concentration of 1%. From the point at
which the chlorobenzene concentration equals 1% in process streams, the amount present must be factored into threshold
determinations and release and other waste management estimates. The facility does not need to consider the amount of
chlorobenzene in the raw material when below de minimis levels, i.e., prior to distillation to 1%, when making threshold
determinations. The facility does not have to report emissions of chlorobenzene from storage tanks or any other equipment
associated with that specific process where the chlorobenzene content is less than 1%.
Fluctuating Concentration During Processing for Non-PBT Chemicals
A manufacturer produces an ink product that contains toluene, an EPCRA section 313 chemical, below the de minimis level. The
process used causes the percentage of toluene in the mixture to fluctuate: it rises above the de minimis level for a time but drops
below the level as the process winds down. The facility must consider the chemical toward threshold determinations from the point
at which it first equals the de minimis limit. Once the de minimis limit has been met the exemption cannot be taken.
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Example 6: Concentration Ranges Straddling the De Minimis Value
Q A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1.25% manganese. Manganese is eligible for the
de minimis exemptionat concentrations up to 1%. The amount of mixture subject to reporting is the quantity containing manganese
at or above the de minimis concentration:
[(8,000,000) x (1.25% - 0.99%)] + (1.25% - 0.25%)
The average concentration of manganese that is not exempt (above the de minimis) is:
(1.25%+1.00%)-(2)
(8,000,000) x (1.25%- 0.99%)
(1.25%- 0.25%)
(1.25%+ 1.00%)
(2)
= 23,400 pounds
Therefore, the amount of manganese that is subject to threshold determination and release and other waste management
estimates is:
= 23,400 pounds manganese (which is below the processing threshold for manganese)
In this scenario, because the facility's information pertaining to manganese was available to two decimal places, 0.99 was used to
determine the amount below the de minimis concentrations. If the information was available to one decimal place, 0.9 should be
used, as in the scenario below.
Q As in the previous example, manganese is present in a mixture, of which 8,000,000 pounds is processed. The MSD S states
the mixture contains 0.2% to 1.2% manganese. The amount of mixture subject to reporting (at or above de minimis limit) is:
[(8,000,000) x (1.2% - 0.9%)] + (1.2% - 0.2%)
The average concentration of manganese that is not exempt (at or above de minimis limit) is:
(1.2%+1.0%)-(2)
Therefore, the amount of manganese that is subject to threshold determinations and release and other waste management
estimates is:
(8,000,000) x (1.2%-0.9%)
(1.2%-0.2%)
(1.2%+ 1.0%)
(2)
= 26,400 pounds
= 26,400 pounds manganese (which is above the processing threshold for manganese)
Toxics Release Inventory Reporting Forms and Instructions 19
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Example 7: DeMinimis 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% toluene-2,4-diisocyanate and 0,05% 2,4-diaminotoluene. The 2,4-diaminotoluene would not be subject to EPCRA
section 313 reporting nor would supplier notification be required because the concentration of 2,4-diaminotoluene is below its de
minimis limit of 0.1% in the product.
Manufacture as a Commercial Byproduct and Impurity
Chloroform is a reaction byproduct in the production of carbon tetrachloride. It is removed by distillation to a concentration of less
than 150 ppm (0.0150%) remaining in the carbon tetrachloride. The separated chloroform at 90% concentration is sold as a
byproduct. Chloroform is subj ect to a 0.1 % (1000 ppm) de minimis limit. Any amount of chloroform manufactured and separated
as byproduct must be included in threshold determinations because EPA does not interpret the de minimis exemption to apply to
the manufacture of a chemical as a byproduct. Releases of chloroform prior to and during purification of the carbon tetrachloride
must be reported. The de minimis exemption can, however, be applied to the chloroform remaining in the carbon tetrachloride as
an impurity. Because the concentration of chloroform remaining in the carbon tetrachloride is below the de minimis limit, this
quantity of chloroform is exempt from threshold determinations, release and other waste management reporting, and supplier
notification.
Manufacture as a Waste Byproduct
A small amount of formaldehyde is manufactured as a reaction byproduct during the production of phthalic anhydride. The
formaldehyde is separated from the phthalic anhydride as a waste gas and burned, leaving no formaldehyde in the phthalic
anhydride. The amount of formaldehyde produced and removed must be included in threshold determinations and release and other
waste management estimates even if the formaldehyde were present below the de minimis level in the process stream where it was
manufactured or in the waste stream to which it was separated, because EPA does not interpret mixtures and trade name products
to includes wastes.
De Minimis Application in the Manufacture
of the Listed Chemical in a Mixture
The de minimis exemption generally does not apply to the
manufacturing of an EPCRA section 313 chemical. However, the
de minimis exemption may apply to mixtures and other trade
name products containing non-PBT EPCRA section 313
chemicals that are imported into the United States. (See example
5 on page 18.)
The exemption also applies to non-PBT EPCRA section 313
chemicals that are manufactured as impurities that remain in the
product distributed in commerce below the de minimis levels.
The amount remaining in the product is exempt from threshold
determinations. If the chemical is separated from the final
product, it cannot qualify for the exemption. Any amount that is
separated, or is separate, from the product, is considered a
byproduct and is subject to threshold determinations and release
and other waste management calculations. Any amount of an
EPCRA section 313 chemical that is manufactured in a waste
stream must be considered toward threshold determinations and
release and other waste management calculations and accounted
for on Form R even if that chemical is manufactured below the
de minimis level.
The de minimis exemption also does not apply to situations
where a toxic chemical in waste is diluted to below the de
minimis level.
Laboratory Activities Exemption. EPCRA section 313
chemicals that are manufactured, processed, or otherwise used
in a laboratory at a covered facility under the direct supervision
of a technically qualified individual do not have to be
considered for threshold determinations and release and other
waste management calculations. However, pilot plant scale and
specialty chemical production does not qualify for this
laboratory activities exemption, nor does the use of EPCRA
section 313 chemicals for laboratory support activities, such as
the use of chemicals for equipment maintenance.
Coal Extraction Activities Exemption. If an EPCRA section
313 chemical is manufactured, processed, or otherwise used in
extraction by facilities in SIC code 12, a person is not required
to consider the quantity of the EPCRA section 313 chemical so
manufactured, processed, or otherwise used when considering
threshold determinations and release and other waste
management calculations (See example 8). Reclamation
activities occurring simultaneously with coal extraction
activities (e.g., cast blasting) are included in the exemption.
However, otherwise use of ash, waste rock, or fertilizer for
reclamation purposes are not considered part of extraction; non-
exempt amounts of EPCRA section 313 chemicals contained in
these materials must be considered toward threshold
determinations and release and other waste management
20 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
calculations.
Metal Mining Overburden Exemption. If an EPCRA section
313 chemical that is a constituent of overburden is processed or
otherwise used by facilities in SIC code 10, a person is not
required to consider the quantity of the EPCRA section 313
chemical so processed or otherwise used when considering
threshold determinations and release and other waste
management calculations.
For purposes of EPCRA section 313 reporting, overburden is the
unconsolidated material that overlies a deposit of useful material
or ore. It does not include any portion of the ore or waste rock.
Example 8: Coal mining extraction activities
Included among these are explosives for blasting operations,
solvents, lubricants, and fuels for extraction related equipment
maintenance and use, as well as overburden and mineral
deposits. The EPCRA section 313 chemicals contained in
these materials are exempt from threshold determinations and
release and other waste management calculations, when
manufactured, processed or otherwise used during extraction
activities at coal mines.
B.4 Threshold Determinations
EPCRA section 313 reporting is required if threshold quantities
are exceeded. Separate thresholds apply to the amount of the
EPCRA section 313 chemical that is manufactured, processed or
otherwise used.
You must submit a report for any EPCRA section 313 chemical,
which is not listed as a PBT chemical, that is manufactured or
processed at your facility in excess of the following threshold:
Q 25,000 pounds per toxic chemical or category over the
calendar year.
You must submit a report for any EPCRA section 313 chemical,
which is not listed as a PBT chemical, that is otherwise used at
your facility in excess of the following threshold:
Q 10,000 pounds per toxic chemical or category over the
calendar year.
You must submit a report for any EPCRA section 313 chemical,
which is listed as a PBT chemical, that is manufactured,
processed or otherwise used at your facility above the designated
threshold for that chemical.
The chemical names, CAS numbers and their reporting
thresholds are listed in the table below. See Table He of these
instructions for lists of individual members of the dioxin and
dioxin-like compounds chemical category and the polycyclic
aromatic compounds chemical category.
Chemical or chemical
category name
Aldrin
Benzo [g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds category
(manufacturing; and the
processing or otherwise use
of dioxin and dioxin-like
compounds category if the
dioxin and dioxin-like
compounds are present as
contaminants in a chemical
and if they were created
during the manufacturing of
that chemical
Heptachlor
Hexachlorobenzene
Isodrin
Lead (this lower threshold
does not apply to lead when
it is contained in stainless
steal, brass or bronze alloy)
Lead compounds
Mercury
Mercury compounds
Methoxychlor
CAS
number or
chemical
category
code
309-00-2
191-24-2
57-74-9
N150
76-44-8
118-74-1
465-73-6
7439-92-1
N420
7439-97-6
N458
72-43-5
Threshold
(pounds,
unless
noted
otherwise)
100
10
10
0.1 gram
10
10
10
100
100
10
10
100
(table continued on next page)
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Chemical or chemical
category name
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Polychlorinated biphenyls
(PCBs)
Polycyclic aromatic
compounds category
(PACs)
Tetrabromobisphenol A
Toxaphene
Trifluralin
CAS
number or
chemical
category
code
29082-74-4
40487-42-1
608-93-5
1336-36-3
N590
79-94-7
8001-35-2
1582-09-8
Threshold
(pounds,
unless
noted
otherwise)
10
100
10
10
100
100
10
100
B.4.a. How to Determine if Your
Facility Has Exceeded Thresholds
To determine whether your facility has exceeded an EPCRA
section 313 reporting threshold, compare quantities of EPCRA
section 313 chemicals that you manufacture, process, or
otherwise use to the respective thresholds for those activities. A
worksheet is provided in Figure 2A to assist facilities in
determining whether they exceed any of the reporting thresholds
for non-PBT chemicals; Figures 2B-D provide worksheets for
PBT chemicals. This worksheet also provides a format for
maintaining reporting facility records. Use of this worksheet is
not required and the completed worksheet(s) should not
accompany Form R reports submitted to EPA and the state.
Complete the appropriate worksheet for each EPCRA section
313 chemical or chemical category. (The worksheets can be
found at the end of section B.4.) Base your threshold
determination for EPCRA section 313 chemicals with qualifiers
only on the quantity of the EPCRA section 313 chemical
satisfying the qualifier.
Use of the worksheets is divided into three steps:
Step 1 allows you to record the gross amount of the EPCRA
section 313 chemical or chemical category involved in activities
throughout the facility. Pure forms as well as the amounts of the
EPCRA section 313 chemical or chemical category present in
mixtures or other trade name products must be considered. The
types of activity (i.e., manufacturing, processing, or otherwise
using) for which the EPCRA section 313 chemical is used must
be identified because separate thresholds apply to each of these
activities. A record of the information source(s) used should be
kept. Possible information sources include purchase records,
inventory data, and calculations by a process engineer. The
data collected in Step 1 will be totaled for each activity to
identify the overall amount of the EPCRA section 313 chemical
or chemical category manufactured (including imported),
processed, or otherwise used.
Step 2 allows you to identify uses of the EPCRA section 313
chemical or chemical category that were included in Step 1 but
are exempt under EPCRA section 313. Do not include in Step
2 exempt quantities of the EPCRA section 313 chemical not
included in the calculations in Step 1. For example, if Freon
contained in the building's air conditioners was not reported in
Step 1, you would not include the amount as exempt in Step 2.
Step 2 is intended for use when a quantity or use of the EPCRA
section 313 chemical is exempt while other quantities require
reporting. Note the type of exemption for future reference.
Also identify, if applicable, the fraction or percentage of the
EPCRA section 313 chemical present that is exempt. Add the
amounts in each activity to obtain a subtotal for exempted
amounts of the EPCRA section 313 chemical or chemical
categories at the facility.
Step 3 involves subtracting the result of Step 2 from the results
of Step 1 for each activity. Compare this net sum to the
applicable activity threshold. If the threshold is 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
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actual amounts of an EPCRA section 313 chemical
manufactured, processed, or otherwise used over the course of
the calendar year. The threshold determination may not relate to
the amount of an EPCRA section 313 chemical brought on-site
during the calendar year. For example, if a stockpile of 100,000
pounds of a non-PBT EPCRA section 313 chemical is present
on-site but only 20,000 pounds of that chemical is applied to a
process, only the 20,000 pounds processed is counted toward a
threshold determination, not the entire 100,000 pounds of the
stockpile.
B.4.b. Threshold Determinations
for On-Site Reuse Operations
Threshold determinations of EPCRA section 313 chemicals that
are reused at the facility are based only on the amount of the
EPCRA section 313 chemical that is added during the year, not
the total volume in the system. For example, a facility operates
a refrigeration unit that contains 15,000 pounds of anhydrous
ammonia at the beginning of the year. The system is charged
with 2,000 pounds of anhydrous ammonia during the year. The
facility has therefore "otherwise used" only 2,000 pounds of
anhydrous ammonia, a non-PBT EPCRA section 313 chemical,
which is below the otherwise use threshold for anhydrous
ammonia and is not required to report (unless there are other
"otherwise use" activities of ammonia, that when taken together,
exceed the reporting threshold). If, however, the whole
refrigeration unit was recharged with 15,000 pounds of
anhydrous ammonia during the year, then the facility would have
exceeded the otherwise use threshold, and would be required to
report.
This does not apply to EPCRA section 313 chemicals "recycled"
or "reused" off-site and returned to a facility. Such EPCRA
section 313 chemicals returned to a facility are treated as the
equivalent of newly purchased material for purposes of EPCRA
section 313 threshold determinations.
B.4.c. Threshold Determinations for Ammonia
The listing for ammonia includes the modifier "includes
anhydrous ammonia and aqueous ammonia from water
dissociable ammonium salts and other sources; 10% of total
aqueous ammonia is reportable under this listing". The qualifier
for ammonia means that anhydrous forms of ammonia are 100%
reportable and aqueous forms are limited to 10% of total aqueous
ammonia. Therefore, when determining threshold quantities,
100% of anhydrous ammonia is included but only 10% of total
aqueous ammonia is included. If any ammonia evaporates from
aqueous ammonia solutions, 100% of the evaporated ammonia
is included in threshold determinations.
For example, if a facility processes aqueous ammonia it has
processed 100% of the aqueous ammonia in that solution. If the
ammonia remains in solution, then 10% of the total aqueous
ammonia is counted towards threshold. If there are any
evaporative losses of anhydrous ammonia, then 100% of those
losses must be counted towards the processing threshold. If the
manufacturing, processing, or otherwise use threshold for the
ammonia listing are exceeded, the facility must report 100% of
these evaporative losses in Sections 5 and 8 of the FormR.
B.4.d. Threshold Determinations
for Chemical Categories
A number of chemical compound categories are subject to
reporting. See Table He for a listing of these EPCRA section
313 chemical categories. When preparing threshold
determinations for one of these EPCRA section 313 chemical
categories, all individual members of a category that are
manufactured, processed, or otherwise used must be counted.
Where generic names are used at a facility, threshold
determinations should be based on CAS numbers. Forexample,
Poly-Solv EB does not appear among the reportable chemicals
in Table Ha or lib but its CAS number indicates Poly-Solv EB
is a synonym for ethylene glycol mono-n-butyl ether, a member
of the certain glycol ethers chemical category (code N230). For
chemical compound categories threshold determinations must
be made separately for each of the three activities. Do not
include in these threshold determinations for a category any
chemicals that are also individually listed EPCRA section 313
chemicals (see Table Ha or lib) or chemicals that have been
deleted from a category (e.g., a class of copper phthalocyanine
compounds has been deleted from the copper compounds
category). Individually listed EPCRA 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
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facility that exceeded reporting thresholds for both nickel and
nickel compounds chemical category, that facility could submit
a single Form R for the nickel compounds chemical category,
which would contain release and other waste management
information for both nickel and nickel compounds. Do not put
both names on the Form R.
The case of metal category compounds involving more than one
metal should be noted. Some metal category compounds may
contain more than one listed metal. For example, lead chromate
is both a lead compound and a chromium compound. In such
cases, if applicable thresholds are exceeded, you are required to
file two separate reports, one for lead compounds and one for
chromium compounds. Apply the total weight of the lead
chromate to the threshold determinations for both lead
compounds and chromium compounds. (Note: Only the amount
of each parent metal released or otherwise managed as waste (not
the amount of the compound), would be reported on the
appropriate sections of both Form Rs. 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 chemical's
potential to persist and bioaccumulate in the environment. The
manufacturing, processing and otherwise use thresholds for PBT
chemicals is 100 pounds, while forthe 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 where such data are not
readily available, reasonable estimates to determine whetherthe
toxic chemicals in a mixture meet or exceed the de minimis
concentration and, therefore, must be included in threshold
determinations and release and other waste management
calculations. If you know that a mixture or other trade name
product contains a specific EPCRA section 313 chemical,
combine the amount of the EPCRA section 313 chemical in the
mixture or other trade name product with other amounts of the
same EPCRA section 313 chemical processed or otherwise used
at your facility for threshold determinations and release and
other waste management calculations. If you know that a
mixture contains an EPCRA section 313 chemical but it is
present below the de minimis level, you do not have to consider
the amount of the EPCRA section 313 chemical present in that
mixture for purposes of threshold determinations and release
and other waste management calculations. PBT chemicals are
not eligible for the de minimis exemption except lead when it is
contained in stainless steel, brass or bronze alloy.
Observe the following guidelines in estimating concentrations
of EPCRA section 313 chemicals in mixtures when only limited
information is available:
Q If you only know the upper bound concentration, you must
use it for threshold determinations (40 CFR section
372.30(b)(ii)).
Q If you know the lower and upper bound concentrations of
an EPCRA section 313 chemical in a mixture, EPA
recommends you use the midpoint of these two
concentrations for threshold determinations.
Q If you know only the lower bound concentration, EPA
recommends you subtract out the percentages of any other
known components to determine a reasonable upperbound
concentration, and then determine a midpoint.
Q If you have no information other than the lower bound
concentration, EPA recommends you calculate a midpoint
assuming an upper bound concentration of 100%.
Q In cases where you only have a concentration range
available, EPA recommends you use the midpoint of the
range extremes.
24 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
B.5 Release and Other Waste Management
Determinations for Metals, Metal Category
Compounds, and Nitrate Compounds
Metal Category Compounds
Although the complete weight of the metal category compounds
must be used in threshold determinations for the metal
compounds category, for release and other waste management
determinations, only the weight of the metal portion of the metal
category compound must be considered. Remember that for
metal category compounds that consist of more than one metal,
release and other waste management reporting must be based on
the weight of each metal, provided that the appropriate
thresholds have been exceeded.
Metals and Metal Category Compounds
As stated above, for compounds within the metal compound
categories only the metal portion of the metal category
compound must be considered in determining release and other
waste management quantities forthe metal category compounds.
Therefore, if thresholds are separately exceeded for both the
"parent" metal and its compounds, EPA allows you to file a
combined Form R for the "parent" metal and its category
compounds. This Form R would contain all of the release and
other waste management information for both the "parent"
metal and metal portion of the related metal category
compounds. For example, you exceed thresholds for chromium.
You also exceed thresholds for chromium compounds. Instead
of filing two Form Rs you can file one combined Form R. This
Form R would contain information on quantities of chromium
released or otherwise managed as waste and the quantities of
the chromium portion of the chromium compounds released or
otherwise managed as waste. When filing one combined Form
R for an EPCRA section 313 metal and metal compound
category, facilities should identify the chemical reported as the
metal compound category name and code in Section 1 of the
Form R. Note that this does not apply to the Form A. See the
section in these instructions on the Form A. 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, for release and other waste management calculations
only the nitrate portion of the compound should be reported.
Toxics Release Inventory Reporting Forms and Instructions 25
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Example 9: Mixtures and Other Trade Name Products
Scenario #1: Your facility otherwise uses 12,000 pounds of an industrial solvent (Solvent X) for equipment cleaning. The
Material Safety Data Sheet (MSDS) for the solvent indicates that it contains at least 50% methyl ethyl ketone (MEK), an EPCRA
section 313 chemical; however, it also states that the solvent contains 20% non-hazardous surfactants. This is the only MEK-
containing mixture used at the facility,
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 knownminimum (50%) and the reasonable maximum calculated above (i.e., (80%
+ 50%)/2 = 65%).
3) Multiply total weight of Solvent X otherwise used by 65% (0.65).
12,000 pounds x 0.65 = 7,800 pounds
4) Because the total amount of MEK otherwise used at the facility was less than the 10,000-pound otherwise use
threshold, the facility is not required to file a Form R for MEK.
Scenario #2: Your facility otherwise used 15,000 pounds of Solvent Y to clean printed circuit boards. The MSDS for the
solvent lists only that Solvent Y contains at least 80% of an EPCRA section 313 chemical that is only identified as chlorinated
hydrocarbons,
EPA recommends you follow these steps to determine if the quantity of the EPCRA section 313 chemical in the solvent exceeds
the threshold for otherwise use.
1) Because the specific chemical is unknown, the Form R will be filed for "chlorinated hydrocarbons." This name will
be entered into Part II, Section 2.1, "Mixture Component Identity." (Note: Because your supplier is claiming the
EPCRA section 313 chemical identity a trade secret, you do not have to file substantiation forms.)
2) The upper bound limit is assumed to be 100% and the lower bound limit is known to be 80%. Using this information,
the specific concentration is estimated to be 90% (i.e., the mid-point between upper and lower limits).
(100% + 80%)/2 = 90%
3) The total weight of Solvent Y is multiplied by 90% (0.90) when calculating for thresholds.
15,000x0.90=13,500
4) Because the total amount of chlorinated hydrocarbons exceeds the 10,000-pound otherwise use threshold, you must
file a Form R for this chemical.
26 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Figure 2A. EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet1
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Date Worksheet Prepared:
Prepared By:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
1.
2.
3.
4.
Subtotal:
Information Source
Total Weight (Ib)
Percent EPCRA
Section 313 Chemical
by Weight
EPCRA Section 3 13
Chemical Weight
(Ib)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (Ib.):
Manufactured
(A) Ib
Processed
(B) Ib
Otherwise Used
(0 Ib
Exempt quantity of the EPCRA Section 313 chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (de minimis,
articles, facility, activity)
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical Exempt
from Above (Ib):
Manufactured
(A,) Ib
Processed
(B,) Ib
Otherwise Used
(C,) Ib
Amount subject to threshold:
Ib (B-B,),
.Ib
Ib
Compare to threshold for EPCRA section 313 reporting. 25,000 Ibs 25,000 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.
10,000 Ibs
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 27
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How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Figure 2B. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100 Pound Thresholds
Facility Name:
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 3 13
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 subject to threshold:
Compare to threshold for EPCRA section 313 reporting.
Amount of the EPCRA Section 313 Chemical Exempt
from Above (Ib):
Manufactured
(A,) Ib
Processed
(B,) Ib
Otherwise Used
(C,) Ib
(A-A,) Ib (B-B,) Ib (C-C,) Ib
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; retain it for your records.
1 Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
28 Toxics Release Inventory Reporting Forms and Instructions
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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:
Figure 2C. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10 Pound Thresholds
Date Worksheet Prepared:
Prepared By:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
1.
2.
3.
4.
Subtotal:
Information Source
Total Weight (Ib)
Percent EPCRA
Section 313 Chemical
by Weight
EPCRA Section 3 13
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 subject to threshold:
Compare to threshold for EPCRA section 313 reporting.
Amount of the EPCRA Section 313 Chemical Exempt
from Above (Ib):
Manufactured
(A,) Ib
Processed
(B,) Ib
Otherwise Used
(C,) Ib
(A-A,) Ib (B-B,) Ib (C-C,) Ib
10 Ibs 10 Ibs 10 Ibs
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R; retain it for your records.
1 Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
Toxics Release Inventory Reporting Forms and Instructions 29
-------
How to Determine if Your Facility Must Submit a Form R or is Eligible to use Form A
Figure 2D. EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like Compounds Chemical Category
Date Worksheet Prepared:
Prepared By:
Facility Name:
EPCRA Section 313 Chemical or Chemical Category: Dioxin and Dioxin-Like Compounds
Chemical Category Code: N150
Reporting Year:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
1.
2.
3.
4.
Subtotal:
Information Source
Total Weight (g)
Percent EPCRA
Section 313 Chemical
by Weight
EPCRA Section 3 13
Chemical Weight
(g)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (g.):
Manufactured
(A) 2
Processed
(B) g
Otherwise Used
(0 2
Exempt quantity of the EPCRA Section 313 chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (articles,
facility, activity)1
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical
Exempt from Above (g):
Manufactured
(A,) 2
Processed
(B,) 2
Otherwise Used
(C,) 2
Amount subject to threshold:
.8
Compare to threshold for EPCRA section 313 reporting. 0.1 gram 0.1 gram
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R; retain it for your records.
0.1 gram
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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C. Instructions for Completing EPA Form R
Part I. Facility Identification
Information
Section 1. Reporting Year
This is the calendar year to which the reported information
applies, not the year in which you are submitting the report.
Information for the 2004 reporting year must be submitted on
or before July 1,2005.
Section 2. Trade Secret Information
2.1 Are you claiming the EPCRA section 313 chemical
identified on page 2 a trade secret?
Answer this question only after you have completed the rest of
the report. The specific identity of the EPCRA section 313
chemical being reported in Part II, Section 1, may be designated
as a trade secret. If you are making a trade secret claim, mark
"yes" and proceed to Section 2.2. Only check "yes" if you
manufacture, process, or otherwise use the EPCRA section 313
chemical whose identity is a trade secret. (See page 2 of these
instructions for specific information on trade secrecy claims.)
If you checked "no," proceed to Section 3; do not answer
Section 2.2.
D Do not submit trade secret reports electronically or on
diskette.
2.2 If "yes" in 2.1, is this copy sanitized or unsanitized?
Answer this question only after you have completed the rest of
the report. Check "sanitized" if this copy of the report is the
public version that does not contain the EPCRA section 313
chemical identity but does contain a generic name in its place,
and you have claimed the EPCRA section 313 chemical identity
trade secret in Part I, Section 2.1. Otherwise, check
"unsanitized."
Section 3. Certification
The certification statement must be signed by 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 in the space provided the name and title of
the person who signs the statement. This certification statement
applies to all the information supplied on the form and should
be signed only after the form has been completed.
Section 4. Facility Identification
4.1 Facility Name, Location, and
TRI Facility Identification Number
Enter the full name that the facility presents to the public and its
customers in doing business (e.g., the name that appears on
invoices, signs, and other official business documents). Do not
use a nickname for the facility (e.g., Main Street Plant) unless
that is the legal name of the facility under which it does business.
Also enter the street address, mailing address, city, county, state,
and zip code in the space provided. Do not use a post office box
number as the street address. The street address provided must
be the location where the EPCRA section 313 chemicals are
manufactured, processed, or otherwise used. If your mailing
address and street address are the same, you should enter NA in
the space for the mailing address.
If your facility is not in a county, put the name of your city,
district (for example, District of Columbia), or parish (if you are
in Louisiana) in the county block of the Form R and Form A as
well as in the county field of TRI-ME. "NA" or "None" are not
acceptable entries.
If you have submitted a Form R or Form A for previous reporting
years, a TRI Facility Identification Number has been assigned to
your facility. If you know your TRI Facility Identification
Number, you should complete Section 4. If you do not know
your TRI Facility Identification Number, you should contact the
CDX Help Desk toll free at 1-888-890-1995, or your Regional
TRI Program representative, or you may 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. This
identification number is retained by the facility even if the
facility changes name, ownership, production processes, SIC
codes, etc. This identification number will stay with this
location. If a new facility moves to this location it should use
this TRI Facility Identification Number. Establishments of a
facility that report separately should use the TRI Facility
Identification Number of the facility.
You should enter "New Facility" in the space for the TRI Facility
Identification number if this is your first submission.
Toxics Release Inventory Reporting Forms and Instructions 31
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Instructions for Completing Part I of EPA Form R
4.2 Full or Partial Facility Indication
EPCRA section 313 requires reports by "facilities," which are
defined as "all buildings, equipment, structures, and other
stationary items which are located on a single site or on
contiguous or adjacent sites and which are owned or operated
by the same person (or by any person which controls, is
controlled by, or under common control with such person). A
facility may contain more than one establishment."
EPCRA section 313 defines establishment as "an economic
unit, generally at a single physical location, where business is
conducted or where services or industrial operations are
performed." Under section 372.30(c) of the reporting rule, you
may submit a separate Form R for each establishment, or for
groups of establishments in your facility, provided all releases
and other waste management activities and source reduction
activities involving the EPCRA section 313 chemical from the
entire facility are reported. This allows you the option of
reporting separately on the activities involving an EPCRA
section 313 chemical at each establishment, or group of
establishments (e.g., part of a covered facility), rather than
submitting a single Form R for that EPCRA section 313
chemical for the entire facility. However, if an establishment or
group of establishments does not manufacture, process, or
otherwise use or release or otherwise manage as waste an
EPCRA section 313 chemical, you do not have to submit a
report for that establishment or group of establishments for that
particular chemical. (See also Section B.2.a of these
instructions.)
A covered facility must report all releases and other waste
management activities and source reduction activities of an
EPCRA section 313 chemical if the facility meets a reporting
threshold for that EPCRA section 313 chemical. However, if
the facility is composed of several distinct establishments, EPA
allows these establishments to submit separate reports for the
EPCRA section 313 chemical as long as all releases and other
waste management activities of the EPCRA section 313
chemical from the entire facility are accounted for. Whether
submitting a report for the entire facility or separate reports for
the establishments, the threshold determination must be made
based on the entire facility. Indicate in Section 4.2 whether
your report is for the entire covered facility as a whole or for
part of a covered facility (i.e., one or more establishments).
Federal facilities and contractors at federal facilities
(GOCOs—Government-owned, contractor-operated facilities)
should check either 4.2c or 4.2d, but not both. Federal facilities
should check 4.2c, even if their TRI reports contain release and
other waste management information from contractors located
at the facility. Contractors at federal facilities, which are
required by EPCRA section 313 to file TRI reports
independently of the federal facility, should check 4.2d. This
information is important to prevent duplication of federal
facility data. (See Appendix A for further guidance on these
instructions.)
4.3 Technical Contact
Enter the name and telephone number (including area code) of a
technical representative whom EPA or state officials may contact
for clarification of the information reported on Form R. You
should also enter an email address for this person. EPA
encourages facilities to provide an email address for its Technical
Contact on their TRI submissions because they will be able to
receive important program updates and email alerts notifying
them when their FDP has been updated and is available on the
FDP website. If the technical contact does not have an email
address you should enter NA. This contact person does not have
to be the same person who prepares the report or signs the
certification statement and does not necessarily need to be
someone at the location of the reporting facility. However, this
person should be familiar with the details of the report so that he
or she can answer questions about the information provided.
4.4 Public Contact
Enter the name and telephone number (including area code) of a
person who can respond to questions from the public about the
report. If you choose to designate the same person as both the
technical and the public contact, you may enter " Same as Section
4.3" in this space. This contact person does not have to be the
same person who prepares the report or signs the certification
statement and does not necessarily need to be someone at the
location of the reporting facility. If your facility does not have
a public contact, provide the technical contact name and
telephone number in the public contact name and telephone
number fields.
4.5 Standard Industrial Classification (SIC) Code
Enter the appropriate four-digit Standard Industrial Classification
(SIC) Code that is the primary SIC Code for your facility in
Section 4.5(a). Enter any other applicable SIC Codes for your
facility in 4.5 (b)-(f). Table I lists the SIC codes within 10
(except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4939
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4953
(limited to facilities regulated under the RCRA Subtitle C, 42
U.S.C. section 6921 et seq.), 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvent recovery services on a
contract or fee basis). If the report covers more than one
establishment, enter the primary 4-digit SIC code for each
establishment starting with the primary SIC code for the entire
facility. You are required to enter SIC codes only for those
establishments within the facility that fall within SIC codes 10
(except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil for the purpose
32 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part I of EPA Form R
of generating electricity for distribution in commerce), 4939
(limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4953
(limited to facilities regulated under the RCRA Subtitle C, 42
U.S.C. section 6921 et seq.\ 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvents recovery services on a
contract or fee basis). If you do not know your SIC code,
consult the 1987 SIC Manual (see Section B.2 of these
instructions for ordering information).
The North American Industry Classification System (NAICS)
is a new economic classification system that will replace the
1987 SIC code system. EPA will address the SIC code change,
as it relates to EPCRA, in an upcoming Federal Register notice.
This upcoming change does NOT affect the 2003 EPCRA
section 313 reporting.
4.6 Latitude and Longitude
Enter the latitude and longitude coordinates of your facility.
The latitude and longitude coordinates for your facility should
be taken at the center of production for your facility. Sources
of these data include EPA permits (e.g., NPDES permits),
county property records, facility blueprints, and site plans. You
can determine the latitude and longitude of your facility using
a siting tool found on the TRI Home page at
or in the TRI-
MS software. For information on the siting tool and
instructions on how to determine these coordinates see
Appendix E. Enter only numerical data. Do not preface
numbers with letters such as N or W to denote the hemisphere.
If you are unable to locate an existing latitude and longitude for
your facility, refer to Appendix E for recommended methods to
calculate the coordinates for the center of your facility's
production.
Latitude and longitude coordinates of your facility are very
important for pinpointing the location of reporting facilities and
are required elements on the FormR. EPA encourages facilities
to make the best possible measurements when determining
latitude and longitude. Please check to make sure the latitude
and longitude coordinates of your facility are correct. For the
continental United States readings should be within 24°23'58"
(24 degrees, 23 minutes, and 58 seconds) and 49°22'16"
latitude, and 66°53'06" and 124°50'55" longitude. For Alaska
readings shouldbe within51°10'30" and71°26'04" latitude, and
129°59'29" and 187°39'08" longitude. For Hawaii readings
should be within 18°51'56" and 28°30'59" latitude, and
154°45'21" and 178°26'25" longitude. As with any other data
field, missing, suspect, or incorrect data may generate an error
notice in the Facility Data Profile to be issued to the facility.
(See Appendix C)
4.7 Dun & Bradstreet Number(s)
Enter the nine-digit number assigned by Dun & Bradstreet (D
& B) foryour facility or each establishment withinyour facility.
These numbers code the facility for financial purposes. This
number may be available from your facility's treasurer or
financial officer. You can also obtain the numbers from your
local Dun & Bradstreet office (check the telephone book White
Pages). If a facility does not subscribe to the D & B service, a
number can be obtained, toll free at 800 234-3867 (8:00 AM to
6:00 PM, Local Time) or on the Web at . If
none of your establishments has been assigned a D & B number,
you should enter NA in box (a). If only some of your
establishments have been assigned D & B numbers, enter those
numbers in Part I, section 4.7.
4.8 EPA Identification Number(s)
The EPA Identification Number is a 12-character number
assigned to facilities covered by hazardous waste regulations
under the Resource Conservation and Recovery Act (RCRA).
Facilities not covered by RCRA Subtitle C are not likely to have
an assigned identification number. If your facility is not required
to have an identification number, you should enter NA in box (a).
If your facility has been assigned EPA Identification Numbers,
you must enter those numbers in the spaces provided in Section
4.8.
4.9 NPDES Permit Number(s)
Enter the numbers of any permits your facility holds under the
National Pollutant Discharge Elimination System (NPDES) even
if the permit(s) do not pertain to the EPCRA section 313
chemical being reported. This nine-character permit number is
assigned to your facility by EPA or the state under the authority
of the Clean Water Act. If your facility does not have a permit,
you should enter NA in Section 4.9a.
4.10 Underground Injection
Well Code (UIC) Identification Number(s)
If your facility has a permit to inject a waste that contains or
contained the EPCRA section 313 chemical into Class 1 deep
wells, enter the 12-digit Underground Injection Well Code (UIC)
identification number assigned by EPA or by the state under the
authority of the Safe Drinking Water Act. If your facility does
not hold such a permit(s), you should enter NA in Section 4. lOa.
You are required to provide the UIC number for wells that
receive the EPCRA section 313 chemical being reported in the
current reporting year.
Section 5. Parent Company Information
You must provide information on your parent company. For
purposes of Form R, a parent company is defined as the highest
level company, located in the United States, that directly owns
at least 50% of the voting stock of your company. If your
facility is owned by a foreign entity, enter NA in this space.
Corporate names should be treated as parent company names for
companies with multiple facility sites. For example, the
Bestchem Corporation is not owned or controlled by any other
corporation but has sites throughout the country whose names
Toxics Release Inventory Reporting Forms and Instructions 33
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Instructions for Completing Part II of EPA Form R
begin with Bestchem. In this case, Bestchem Corporation
should be listed as the parent company. Note that a facility that
is a 50:50 joint venture is its own parent company. When a
facility is owned by more than one company and there is no
parent company for the entire facility (meaning that none of the
facility owners directly owns at least 50 percent of the voting
stock of the facility at issue), the facility should provide the
name of the parent company of either the facility operator or the
owner with the largest ownership interest in the facility. If
neither the operator nor this owner has a parent company, then
the NA box should be checked.
5.1 Name of Parent Company
Enter the name of the corporation or other business entity that
is your ultimate 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.
34 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Part II. Chemical Specific Information
In Part II, you are to report on:
D The EPCRA section 313 chemical being reported;
D The general uses and activities involving the EPCRA
section 313 chemical at your facility;
D On-site releases of the EPCRA section 313 chemical from
the facility to air, water, and land;
D Quantities of the EPCRA section 313 chemical
transferred
to off-site locations;
D Information for on-site and off-site disposal, treatment,
energy recovery, and recycling of the EPCRA section 313
chemical; and
D 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 (CIO to C13)
N590 Poly cyclic aromatic compounds (PACs)
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N770 Vanadium compounds
N874 Warfarin and salts
N982 Zinc compounds
If you are making a trade secret claim, you must report the CAS
number or should report the 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 in Part II, Section 1.3 of your sanitized Form R
report.
EPA requests that the EPCRA section 313 chemical, chemical
category, or generic name also be placed in the box marked
"Toxic Chemical, Category, or Generic Name" in the upper
right-hand corner on all pages of Form R. While this space is not
a required data element, providing this information will help you
in preparing a complete Form R report.
Toxics Release Inventory Reporting Forms and Instructions 35
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Instructions for Completing Part II of EPA Form R
1.3 Generic Chemical Name
Complete Section 1.3 only if you are claiming the specific
EPCRA section 313 chemical identity of the EPCRA section
313 chemical as a trade secret and have marked the trade secret
block in Part I, Section 2.1 on page 1 of Form R. Enter a
generic chemical name that is descriptive of the chemical
structure. You should limit the generic name to seventy
characters (e.g., numbers, letters, spaces, punctuation) or less.
Do not enter mixture names in Section 1.3; see Section 2 below.
In-house plant codes and other substitute names that are not
structurally descriptive of the EPCRA section 313 chemical
identity being withheld as a trade secret are not acceptable as a
generic name. The generic name must appear on both sanitized
and unsanitized Form Rs, and the name must be the same as that
used on your substantiation forms.
1.4 Distribution of Each Member of the Dioxin and
Dioxin-like Compounds Category
Report a distribution of the chemicals included in the dioxin and
dioxin-like compounds category. Such distribution shall either
represent the distribution of the total quantity of dioxin and
dioxin-like compounds released to all mediafromyourfacility;
or your facility's one best media-specific distribution. When
reporting dioxin and dioxin-like compounds, if there are any
numbers in boxes 1-17, then every field must be filled in with
either 0 or some number between 0.01 and 100. Distribution
should be reported in percentages and the total should equal
100%. If you do not have speciation data available, you should
indicate NA. If you are not reporting for dioxin and dioxin-like
compounds, leave the entire section blank.
You should not report the quantity of dioxin and dioxin-like
compounds released or otherwise managed as waste in Section
1.4. Quantities released or otherwise managed as waste must be
reported in Sections 5, 6 and 8.
There are 17 individual chemicals listed in the dioxin and
dioxin-like compounds category. Each of these chemicals are
assigned a number from 1 to 17. These numbers correspond to
the boxes in Section 1.4. The individual chemicals in the dioxin
and dioxin-like compounds category and their number are in the
matrix below:
1
2
3
4
5
6
67562-39^1
55673-89-7
70648-26-9
57117^4-9
72918-21-9
60851-34-5
1,2,3,4,6,7,8-Heptachlorodibenzofuran
1,2,3,4,7,8,9-Heptachlorodibenzofuran
1 ,2,3,4 ,7,8-Hexachlorodibenzofuran
1 ,2,3,6,7,8-Hexachlorodibenzofuran
1 ,2,3,7,8,9-Hexachlorodibenzofuran
2,3,4,6,7,8-Hexachlorodibenzofuran
7
8
9
10
11
12
13
14
15
16
17
39227-28-6
57653-85-7
19408-74-3
35822^16-9
39001-02-0
03268-87-9
57117^1-6
57117-31^1
40321-76^1
51207-31-9
01746-01-6
1 ,2,3,4,7,8-Hexachlorodibenzo- p-dioxin
1 ,2,3,6,7,8-Hexachlorodibenzo- p-dioxin
1 ,2,3,7,8,9-Hexachlorodibenzo- p-dioxin
1, 2,3,4 ,6,7,8-Heptachlorodibenzo- p-
dioxin
1, 2,3,4 ,6,7,8,9-Octachlorodibenzofuran
1 ,2,3,4 ,6,7,8,9-Octachlorodibenzo- p-
dioxin
1 ,2,3,7,8-Pentachlorodibenzofuran
2,3,4 ,7,8-Pentachlorodibenzofuran
1 ,2,3,7,8-Pentachlorodibenzo- p-dioxin
2,3,7,8-Tetrachlorodibenzofuran
2,3,7,8-Tetrachlorodibenzo- p-dioxin
Section 2. Mixture Component Identity
Do not complete this section if you have completed Section 1 of
Part II. Report the generic name provided to you by your
supplier in this section if your supplier is claiming the chemical
identity proprietary or trade secret. Do not answer "yes" in Part
I, Section2.1 on page 1 of the form if you complete this section.
You do not need to supply trade secret substantiation forms for
this EPCRA section 313 chemical because it is your supplier
who is claiming the chemical identity a trade secret.
Example 10: Mixture Containing Unidentified
EPCRA Section 313 Chemical
Your facility uses 20,000 pounds of a solvent that your
supplier has told you contains 80% "chlorinated aromatic,"
their generic name for a non-PBT EPCRA section 313
chemical subject to reporting under EPCRA section 313.
You, therefore, 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
36 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
section 313 chemical component or a maximum or
average concentration level; and
3. You multiply the concentration level by the total annual
amount of the whole mixture processed or otherwise used
and determine that you meet the process or otherwise use
threshold for that single, genetically identified mixture
component.
Section 3. Activities and Uses of the EPCRA
Section 313 Chemical at the Facility
Indicate whether the EPCRA section 313 chemical is
manufactured (including imported), processed, or otherwise
used at the facility and the general nature of such activities and
uses at the facility during the calendar year (see figure 3). You
are not required to report on Form R the quantity manufactured,
processed or otherwise used. Report activities that take place
only at your facility, not activities that take place at other
facilities involving your products. You must check all the
boxes in this section that apply. Refer to the definitions of
"manufacture," "process," and "otherwise use" in the general
information section of these instructions or Part 40, Section
372.3 of the Code of Federal Regulations for additional
explanations.
3.1 Manufacture the EPCRA Section 313 Chemical
Persons who manufacture (including import) the EPCRA
section 313 chemical must check at least one of the following:
a. Produce — The EPCRA section 313 chemical is
produced at the facility.
b. Import — The EPCRA section 313 chemical is imported
by the facility into the Customs Territory of the United
States. (See SectionB.S.aoftheseinstructionsforfurther
clarification of import.)
And check at least one of the following:
c. For on-site use/processing — The EPCRA section 313
chemical is produced or imported and then further
processed or otherwise used at the same facility. If you
check this block, generally you should also check at least
one item in Part II, Section 3.2 or 3.3.
d. For sale/distribution — The EPCRA section 313
chemical is produced or imported specifically for sale or
distribution outside the manufacturing facility.
e. As a byproduct — The EPCRA section 313 chemical is
produced coincidentally during the manufacture,
processing, or otherwise use of another chemical
substance or mixture and, following its production, is
separated from that other chemical substance or mixture.
EPCRA section 313 chemicals produced as a result of
waste management are also considered byproducts.
f. As an impurity — The EPCRA section 313 chemical is
produced coincidentally as a result of the manufacture,
processing, or otherwise use of another chemical but is not
separated and remains in the mixture or other trade name
product with that other chemical.
In summary, if you are a manufacturer of the EPCRA section 313
chemical, you must check (a) and/or (b), and at least one of (c),
(d), (e), and (f) in Section 3.1.
3.2 Process the EPCRA Section 313 Chemical
Persons who process the EPCRA section 313 chemical must
check at least one of the following:
a. As a reactant — A natural or synthetic EPCRA section 313
chemical is used in chemical reactions for the manufacture
of another chemical substance or of a product. Includes but
is not limited to, feedstocks, raw materials, intermediates,
and initiators.
b. As a formulation component — An EPCRA section 313
chemical is added to a product (or product mixture) prior to
further distribution of the product that acts as a
performance enhancer during use of the product. Examples
of EPCRA section 313 chemicals used in this capacity
include, but are not limited to, additives, dyes, reaction
diluents, initiators, solvents, inhibitors, emulsifiers,
surfactants, lubricants, flame retardants, and rheological
modifiers.
c. As an article component — An EPCRA section 313
chemical becomes an integral component of an article
distributed for industrial, trade, or consumer use. One
example is the pigment components of paint applied to a
chair that is sold.
d. Repackaging — This consists of processing or preparation
of an EPCRA section 313 chemical (or product mixture) for
distribution in commerce in a different form, state, or
quantity. This includes, but is not limited to, the transfer of
material from a bulk container, such as a tank truck to
smaller containers such as cans or bottles.
e. As an impurity — The EPCRA section 313 chemical is
processed but is not separated and remains in the mixture
or other trade name product with that/those other
chemical(s).
Toxics Release Inventory Reporting Forms and Instructions 37
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Instructions for Completing Part II of EPA Form R
Example 11: Manufacturing and Processing Activities
of EPCRA Section 313 Chemicals
In the two examples below, it is assumed that the threshold
quantities for manufacture, process, or otherwise use (25,000
pounds, 25,000 pounds, and 10,000 pounds, respectively for
non-PBT chemicals; 100 pounds for certain PBT chemicals;
10 pounds for highly persistent, highly bioaccumulative toxic
chemicals; and 0.1 grams for the PBT chemical category
comprised of dioxin and dioxin-like compounds) have been
exceeded and the reporting of EPCRA section 313 chemicals
is therefore required.
1. Your facility manufactures diazomethane. Fifty percent
is sold as a product, thus it is processed. The remaining 50%
is reacted with alpha-naphthylamine, forming N-methyl-
alpha-naphthylamine and also producing nitrogen gas.
G Your company manufactures diazomethane, anEPCRA
section 313 chemical, both for sale/ distribution as a
commercial product and for on-site use/processing as
a feedstock in the N-methyl-alpha-naphthylamine
production process. Because the diazomethane is a
reactant, it is also processed. See Figure 3 for how this
information would be reported in Part II, Section 3 of
FormR.
n Your facility also processes alpha-naphthylamine, as a
reactant to produce N-methyl-alpha-naphthylamine, a
chemical not on the EPCRA section 313 list.
2. Your facility is a commercial distributor of Missouri
bituminous coal, which contains mercury at 1.5 ppm (w:w).
You should check the box on the FormR at Part II, Section
3.2.e for processing mercury as an impurity.
3.3 Otherwise Use the EPCRA Section 313 Chemical (non-
incorporative activities)
Persons who otherwise use the EPCRA section 313 chemical
must check at least one of the following:
a. As a chemical processing aid — An EPCRA section 313
chemical that is added to a reaction mixture to aid in the
manufacture or synthesis of another chemical substance but
is not intended to remain in or become part of the product
or product mixture is otherwise used as chemical
processing aid. Examples of such EPCRA section 313
chemicals include, but are not limited to, process solvents,
catalysts, inhibitors, initiators, reaction terminators, and
solution buffers.
b. As a manufacturing aid — An EPCRA section 313
chemical that aids the manufacturing process but does not
become part of the resulting product and is not added to the
reaction mixture during the manufacture or synthesis of
another chemical substance is otherwise used as a
manufacturing aid. Examples include, but are not limited
to, process lubricants, metalworking fluids, coolants,
refrigerants, and hydraulic fluids.
c. Ancillary or other use — An EPCRA section 313
chemical is used at a facility for purposes other than aiding
chemical processing or manufacturing as described above
is otherwise used as ancillary or other use. Examples
include, but are not limited to, cleaners, degreasers,
lubricants, fuels, EPCRA section 313 chemicals used for
treating wastes, and EPCRA section 313 chemicals used to
treat water at the facility.
Section 4. Maximum Amount of the EPCRA
Section 313 Chemical On-site at Any Time During
the Calendar Year
For data element 4.1 of Part II, insert the code (see codes below)
that indicates the maximum quantity of the EPCRA section 313
chemical (e.g., in storage tanks, process vessels, on-site shipping
containers, or in 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 Maximum Amount On Site.
38 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Figure 3. Hypothetical Sections 1, 2 and 3 of Part II of the Form R.
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important* DO NOT complete this section if you completed Section 2 below.)
1.1
CAS Numtaet (Importapl' Ertef oniy one number exactly as i! appears on the Section 313 list, Entet calegot)! code if teporting a cherrical category;
334-88-3
1.2
Toxic Chemical or Chemical Category Name (Important Entt* only one name esaaiy as it appears on tfw Section 313 its!)
Diazomethane
1.3
Generic Chemical Name {Importani Compete only if Part 1 Section 2 1 is enected "yes" Generic Name rayst be structurally descriptive,!
1.4 Distribution of Each Member of the Dioxin and Dioxirt-iike Compounds Category.
(If there are any numbers in boxes 1-17, Ihcn every field must be filled in with either 0 or some number between 0,01 and 100 Distribution should
be reported in perceniages and the total should equal 0 or 100% If you do not have specation data available, check NA.)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
SECTION 2. MIXTURE COMPONENT IDENTITY (important: DO NOT complete this section if you completed Section 1 above.)
2.1
Genenc Chemical Name Provides by Supplw (Important Maximum of 70 clwacters including numbers, letters spaces anil punctuation i
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. [){J Produce b.
import
If produce or import:
c. I X ^or on~s''e usefprocessmg
X
For sale/distnbuten
As a byproduct
As an impurity
X I As a reactant
As a formulation component
As an article component
Repackaging
As an impurity
As a chemical processing aid
As a manufacturing aid
Ancillary or other use
Weight Range in Pounds
Range Code
01
02
03
04
05
06
07
08
09
10
11
From...
0
100
1,000
10,000
100,000
1,000,000
10,000,000
50,000,000
100,000,000
500,000,000
1 billion
To...
99
999
9,999
99,999
999,999
9,999,999
49,999,999
99,999,999
499,999,999
999,999,999
more than 1 billion
If the EPCRA section 313 chemical present at your facility
was part of a mixture or other trade name product, determine
the maximum quantity of the EPCRA section 313 chemical
present at the facility by calculating the weight percent of the
EPCRA section 313 chemical only.
Do not include the weight of the entire mixture or other trade
name product. These data may be found in the Tier II form
your facility may have prepared under Section 312 of
EPCRA. See Part 40, Section 372.30(b) of the Code of
Federal Regulations for further information on how to
calculate the weight of the EPCRA section 313 chemical in
the mixture or other trade name product. For EPCRA section
313 chemical categories (e.g., nickel compounds), include all
chemical compounds in the category when calculating the
maximum amount, using the entire weight of each compound.
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.
Toxics Release Inventory Reporting Forms and Instructions 39
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Instructions for Completing Part II of EPA Form R
Section 5. Quantity of the EPCRA Section 313
Chemical Entering Each Environmental
Medium On-site
In Section 5, you must account for the total aggregate on-site
releases of the EPCRA section 313 chemical to the
environment from your facility for the calendar year.
On-site releases to the environment include emissions to the
air, discharges to surface waters, and releases to land and
underground injection wells.
For all toxic chemicals (except the dioxin and dioxin-like
compound category), do not enter the values in Section 5 in
gallons, tons, liters, or any measure other than pounds. You
must also enter the values as whole numbers (do not use
scientific notation). Numbers following a decimal point are
not acceptable fortoxic chemicals otherthanthose 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 Section5.5.4, NA generally
would not be applicable, recognizing the possibility of
accidental spills or leaks of the EPCRA section 313 chemical.
An example that illustrates the use of NA vs. a numeric value
(e.g., zero) would be nitric acid involved in a facility's
processing activities. If the facility neutralizes the wastes
containing nitric acid to a pH of 6 or above, then the facility
reports a release of zero for the EPCRA section 313
chemical, not NA. Another example is when the facility has
no underground injection well, in which case NA should be
entered in Part I, Section 4.10 and checked in Part II, Section
5.4.1 and 5.4.2 of Form R. Also, if the facility does not
landfill the acidic waste, NA should be checked in Part II,
Section 5.5.1 .B of Form R.
All releases of the EPCRA section 313 chemical to the air
must be classified as either stack or fugitive emissions, and
included in the total quantity reported for these releases in
Sections 5.1 and 5.2. Instructions for columns A, B, and C
follow the discussions of Sections 5.1 through 5.5.
5.1 Fugitive or Non-Point Air Emissions
Report the total of all releases of the EPCRA section 313
chemical to the air that are not released through stacks, vents,
ducts, pipes, or any other confined air stream. You must
include (1) fugitive equipment leaks from valves, pump seals,
flanges, compressors, sampling connections, open-ended
lines, etc.; (2) evaporative losses from surface impoundments
and spills; (3) releases from building ventilation systems; and
(4) any other fugitive or non-point air emissions.
Engineering estimates and mass balance calculations (using
purchase records, inventories, engineering knowledge or
process specifications of the quantity of the EPCRA section
313 chemical entering product, hazardous waste manifests, or
monitoring records) may be useful in estimating fugitive
emissions. You should check the NA box in Section 5.1 if
you do not engage in activities that result in fugitive or non-
point air emissions of this listed toxic chemical. For VOCs,
NA generally would not be applicable.
5.2 Stack or Point Air Emissions
Report the total of all releases of the EPCRA section 313
chemical to the air that occur through stacks, confined vents,
ducts, pipes, or other confined air streams. You must include
storage tank emissions. Air releases from air pollution
40 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
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 NAvs. aNumeric 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
eachreceiving stream orwaterbody. 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., hydrogenfluoride, 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
section 304 of EPCRA, section 103 of CERCLA, and
accident histories required under section 112(r)(7)(B)(ii) of
the Clean Air Act). Where relevant, you should check the
NA box in sections 5.5.1 A through 5.5.3 if there are no
disposal activities for the waste stream that contains or
contained the EPCRA section 313 chemical (See discussion
of NAvs. aNumeric Value (e.g., Zero) in the introduction of
Section 5). For 5.5.4, facilities generally should report zero,
recognizing the potential for spills or leaks.
5.5.1A RCRA Subtitle C landfills —Enter the total amount
of the EPCRA section 313 chemical that was placed in
RCRA Subtitle C landfills. EPA has not required facilities to
estimate leaks from landfills because the amount of the
EPCRA section 313 chemical has already been reported as a
release.
5.5. IB Other landfills — Enter the total amount of the
EPCRA section 313 chemical that was placed in landfills
other than RCRA Subtitle C landfills. EPA has not required
facilities to estimate leaks from landfills because the amount
of the EPCRA section 313 chemical has already been
reported as a release.
5.5.2 Land treatment/application farming — Land
treatment is adisposal method inwhichawaste 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
Toxics Release Inventory Reporting Forms and Instructions 41
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Instructions for Completing Part II of EPA Form R
be included in this section but must be included in the total
fugitive air releases reported in Part II, Section 5.1 of
FormR.
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 Other Surface Impoundments — Enter the total
amount of the EPCRA section 313 chemical that was placed
in surface impoundments other than RCRA Subtitle C surface
impoundments.
5.5.4 Other Disposal — Includes any amount of an EPCRA
section 313 chemical released to land that does not fit the
categories of landfills, land treatment, or surface
impoundment. This other disposal would include any spills
or leaks of EPCRA section 313 chemicals to land. For
example, 2,000 pounds of benzene leaks from an
underground pipeline into the land at a facility. Because the
pipe was only a few feet from the surface at the erupt point,
30% of the benzene evaporates into the air. The 600 pounds
released to the air would be reported as a fugitive air release
(Part II, Section 5.1) and the remaining 1,400 pounds would
be reported as a release to land, other disposal (Part II,
Section 5.5.4).
Section 5 Column A: Total Release
Only on-site releases of the EPCRA section 313 chemical to
the environment for the calendar year are to be reported in
this section of Form R. The total on-site releases from your
facility do not include transfers or shipments of the EPCRA
section 313 chemical from your facility for sale or
distribution in commerce, or of wastes to other facilities for
disposal, treatment, energy recovery, or recycling (see Part II,
Section 6 of these Instructions). Both routine releases, such
as fugitive air emissions, and accidental or non-routine
releases, such as chemical spills, must be included in your
estimate of the quantity released.
Releases of Less Than 1,000 Pounds. For total annual
releases or off-site transfers of an EPCRA section 313
chemical from the facility of less than 1,000 pounds, the
amount may be reported either as an estimate or by using the
range codes that have been developed (range reporting in
section 5 does not apply to PBT chemicals). The reporting
range codes to be used are:
Code
A
B
C
Range (pounds)
1-10
11-499
500-999
Do not enter a range code and an estimate in the same box in
column A. Total annual on-site releases of an EPCRA
section 313 chemical from the facility of less than 1 pound
may be reported in one of several ways. You should round
the value to the nearest pound. If the estimate is greater than
0.5 pound, you should either enter the range code "A" for
" 1-10" or enter " 1" in column A. If the release is equal to or
less than 0.5 pound, you may round to zero and enter "0" in
column A.
Note that total annual releases of 0.5 pound or less from the
processing or otherwise use of an article maintain the article
status of that item. Thus, if the only releases you have are
from processing an article, and such releases are equal to or
less than 0.5 pound per year, you are not required to submit
a report for that EPCRA section 313 chemical. The 0.5-
pound release determination does not apply to just a single
article. It applies to the cumulative releases from the
processing or otherwise use of the same type of article (e.g.,
sheet metal or plastic film) that occurs over the course of the
reporting year.
Releases of 1,000 Pounds or More. For releases to any
medium that amount to 1,000 pounds or more for the year,
you must provide an estimate in pounds per year in column
A. Any estimate provided in column A need not be reported
to more than two significant figures. This estimate should be
in whole numbers. Do not use decimal points.
Calculating On-Site Releases. To provide the release
information in column A EPCRA section 313(g)(2) requires
42 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
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 shouldbe made
using published emission factors, material balance
calculations, or engineering calculations. You may not use
emission factors or calculations to estimate releases if more
accurate data are available.
No additional monitoring or measurement of the quantities or
concentrations of any EPCRA section 313 chemical released
into the environment, or of the frequency of such releases,
beyond that required under other provisions of law or
regulation or as part of routine plant operations, is required
for the purpose of completing Form R.
You must estimate the quantity (in pounds) of the EPCRA
section 313 chemical or chemical category that is released
annually to each environmental medium on-site. Include only
the quantity of the EPCRA section 313 chemical in this
estimate. If the EPCRA section 313 chemical present at your
facility was part of a mixture or other trade name product,
calculate only the releases of the EPCRA section 313
chemical, not the other components of the mixture or other
trade name product. If you are only able to estimate the
releases of the mixture or other trade name product as a
whole, you should assume that the release of the EPCRA
section 313 chemical is proportional to its concentration in
the mixture or other trade name product. See Part 40, Section
372.30(b) of the Code of Federal Regulations for further
information on how to calculate the concentration and weight
of the EPCRA section 313 chemical in the mixture or other
trade name product.
If you are reporting an EPCRA section 313 chemical category
listed in Table II of these instructions rather than a specific
EPCRA section 313 chemical, you must combine the release
data for all chemicals in the EPCRA section 313 chemical
category (e.g., all listed members of certain glycol ethers or
all listed members of chlorophenols) and report the aggregate
amount for that EPCRA section 313 chemical in that category
separately. For example, if your facility releases 3,000
pounds peryearof 2-chlorophenol, 4,000 pounds peryearof
3 -chlorophenol, and 4,000 pounds peryear of 4-chlorophenol
to air as fugitive emissions, you must report that your facility
releases 11,000 pounds per year of chlorophenols to air as
fugitive emissions in Part II, Section 5.1.
For aqueous ammonia solutions, releases must be reported
based on 10% of total aqueous ammonia. Ammonia
evaporating from aqueous ammonia solutions is considered
to be anhydrous ammonia; therefore, 100% of the anhydrous
ammonia should be reported if it is released to the
environment. For dissociable nitrate compounds, release
estimates should be based on the weight of the nitrate only.
For metal category compounds (e.g., chromium compounds),
report releases of only the parent metal. For example, a user
of various inorganic chromium salts would report the total
chromium released regardless of the chemical compound and
exclude any contribution to mass made by the other portion
of the compound.
Section 5 Column B: Basis of Estimate
For each release estimate, you are required to indicate the
principal method used to determine the amount of release
reported. You should enter a letter code that identifies the
method that applies to the largest portion of the total
estimated release quantity.
The codes are as follows:
M— Estimate is based on monitoring data or measurements
for the EPCRA section 313 chemical.
C— Estimate is based on mass balance calculations, such as
calculation of the amount of the EPCRA section 313
chemical in wastes entering and leaving process
equipment.
E— Estimate is based on published emission factors, such
as those relating release quantity to through-put or
equipment type (e.g., air emission factors).
O— Estimate is based on other approaches such as
engineering calculations (e.g., estimating volatilization
using published mathematical formulas) or best
engineering judgment. This would include applying an
estimated removal efficiency to a treatment, even if the
composition of the waste before treatment was fully
identified through monitoring data.
For example, if 40% of stack emissions of the reported
EPCRA section 313 chemical were derived using monitoring
data, 30% by mass balance, and 30% by emission factors,
you should enter the code letter "M" for monitoring.
If the monitoring data, mass balance, or emission factor used
to estimate the release is not specific to the EPCRA section
313 chemical being reported, the form should identify the
estimate as based on engineering calculations or best
engineering judgment (O).
If a mass balance calculation yields the flow rate of a waste,
but the quantity of reported EPCRA section 313 chemical in
the waste is based on solubility data, you should report "O"
because "engineering calculations" were used as the basis of
estimate of the quantity of the EPCRA section 313 chemical
in the waste.
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Instructions for Completing Part II of EPA Form R
If the concentration of the EPCRA section 313 chemical in
the waste was measured by monitoring equipment and the
flow rate of the waste was determined by mass balance, then
the primary basis of the estimate should be "monitoring" (M).
Even though a mass balance calculation also contributed to
the estimate, "monitoring" should be indicated because
monitoring data were used to estimate the concentration of
the waste.
Mass balance (C) should only be indicated if it is directly
used to calculate the mass (weight) of EPCRA section 313
chemical released. Monitoring data should be indicated as
the basis of estimate only if the EPCRA section 313 chemical
concentration is measured in the waste being released into the
environment. Monitoring data should not be indicated, for
example, if the monitoring data relate to a concentration of
the EPCRA section 313 chemical in other process streams
within the facility.
It is important to realize that the accuracy and proficiency of
release estimation will improve over time. However,
submitters are not required to use new emission factors or
estimation techniques to revise previous FormR submissions.
Section 5 Column C: Percent From Stormwater
This column relates only to Section 5.3—discharges to
receiving streams or water bodies. If your facility has
monitoring data on the amount of the EPCRA section 313
chemical in stormwater runoff (including unchanneled
runoff), you must include that quantity of the EPCRA section
313 chemical in your water release in column A and indicate
the percentage of the total quantity (by weight) of the EPCRA
section 313 chemical contributed by stormwater in column C
(Section 5.3C).
If your facility has monitoring data on the EPCRA section
313 chemical and an estimate of flow rate, you must use these
data to determine the percent stormwater.
If you have monitored stormwater but did not detect the
EPCRA section 313 chemical, enter zero in column C. If
your facility has no stormwater monitoring data for the
chemical, you should enter NA in this space on the form.
If your facility does not have periodic measurements of
stormwater releases of the EPCRA section 313 chemical, but
has submitted chemical-specific monitoring data in permit
applications, then these data must be used to calculate the
percent contribution from stormwater. One way to calculate
the flow rates from stormwater runoff is the Rational Method.
In this method, flow rates, Q, canbe estimated by multiplying
the land area of the facility, A, by the runoff coefficient, C,
and then multiplying that figure by the annual rainfall
intensity, I (i.e., Q = A*C*I). The rainfall intensity, I, is
specific to the geographical area of the country where the
facility is located, and may be obtained from most standard
engineering manuals for hydrology. The flow rate, Q, will
have volumetric dimensions per unit time, and will have to be
converted to units of pounds per year. The runoff coefficient
represents the fraction of rainfall that does not seep into the
ground but runs off as stormwater. The runoff coefficient is
directly related to how the land in the drainage area is used.
(See table below)
Description of Land Area
Business
Downtown areas
Neighborhood areas
Industrial
Light areas
Heavy areas
Industrial
Railroad yard areas
Unimproved areas
Streets
Asphaltic
Concrete
Brick
Drives and walks
Roofs
Lawns: Sandy Soil
Flat, 2%
Average, 2-7%
Steep, 7%
Lawns: Heavy Soil
Flat, 2%
Average, 2-7%
Steep, 7%
Runoff Coefficient
0.70-0.95
0.50-0.70
0.50-0.80
0.60-0.90
0.20-0.40
0.10-0.30
0.70-0.95
0.80-0.95
0.70-0.85
0.70-0.85
0.75-0.95
0.05-0.10
0.10-0.15
0.15-0.20
0.13-0.17
0.18-0.22
0.25-0.35
You should choose the most appropriate runoff coefficient for
your site or calculate a weighted-average coefficient, which
takes into account different types of land use at your facility:
Weighted-average runoff coefficient =
(Area 1 % of total)(Cl) + (Area 2 % of total)(C2) +
(Area 3 % of total)(C3) + ... + (Area i % of total)(Ci)
where
Ci = runoff coefficient for a specific land use of
Area i.
44 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Example 13: Stormwater Runoff
Your facility is located in a semi-arid region of the United States that has an annual precipitation (including snowfall) of 12
inches of rain. (Snowfall should be converted to the equivalent inches of rain; assume one foot of snow is equivalent to one inch
of rain.) The total area covered by your facility is 42 acres (about 170,000 square meters or 1,829,520 square feet). The area
of your facility is 50% unimproved area, 10% asphaltic streets, and 40% concrete pavement.
The total Stormwater runoff from your facility is therefore calculated as follows:
Land Use
Unimproved area
Asphaltic streets
Concrete pavement
% Total Area
50
10
40
Runoff
Coefficient
0.20
0.85
0.90
Weighted-average runoff coefficient = [(50%) x (0.20)] + [(10%) x (0.85)] + [(40%) x (0.90)] = 0.545
(Rainfall) x (land area) x (conversion factor) x (runoff coefficient) = Stormwater runoff
(1 ft/year) x (1,829,520 ft2) x (7.48 gal/ft3) x (0.545) = 7,458,222 gallons/year
Total Stormwater runoff = 7,458,222 gallons/year
Your Stormwater monitoring data shows that the average concentration of zinc in the Stormwater runoff fromyour facility from
a biocide containing a zinc compound is 1.4 milligrams per liter. The total amount of zinc discharged to surface water through
the plant wastewater discharge (non-stormwater) is 250 pounds per year. The total amount of zinc discharged with Stormwater
is:
(7,458,222 gallons stormwater)x(3.785 liters/gallon) = 28,229,370 liters Stormwater
(28,229,370 liters stormwater)x(1.4 mg zinc/liter) x 10~3 g/mg x (1/454) Ib/g = 87 Ib zinc.
The total amount of zinc discharged from all sources of your facility is:
250 pounds zinc from wastewater discharged
+87 pounds zinc from Stormwater runoff
337 pounds zinc total water discharged
The percentage of zinc discharge through Stormwater reported in section 5.3 column C on Form R is:
(87/337)xlOO% = 26%
Section 6. Transfers of the EPCRA Section 313
Chemical in Wastes to Off-Site Locations
You must report in this section the total annual quantity of the
EPCRA section 313 chemical in wastes sent to any off-site
facility for the purposes of disposal, treatment, energy
recovery, or recycling. Report the total amount of the EPCRA
section 313 chemical transferred off-site after any on-site
waste treatment, recycling, or removal is completed.
For all toxic chemicals (except the dioxin and dioxin-like
compounds category), do not enter the values in Section 6 in
gallons, tons, liters, or any measure other than pounds. You
must also enter the values as whole numbers. Numbers
following a decimal point are not acceptable for toxic
chemicals other than those designated as PBT chemicals. For
PBT chemicals, facilities should report release and other waste
management quantities greater than 0.1 pound (except the
dioxin and dioxin-like compounds category) provided the
accuracy and the underlying data on which the estimate is
based supports this level of precision. For the dioxin and
dioxin-like compounds category, facilities should report at a
level of precision supported by the accuracy of the underlying
data and the estimation techniques on which the estimate is
based. However, the smallest quantity that need be reported
on the Form R for the dioxin and dioxin-like compounds
category is 0.0001 grams (See example 12 on page 40).
Notwithstanding the numeric precision used when determining
reporting eligibility thresholds, facilities should report on Form
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Instructions for Completing Part II of EPA Form R
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. l.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 6.1 .B. 1,6.1 .B.2, etc. If you transfer
the EPCRA section 313 chemical to more than two POTWs,
you should photocopy page 3 of Form R as many times as
necessary and then number the boxes consecutively for each
POTW. At the bottom of Part II Section 6.1 of the Form R
you will find instructions for indicating the total number of
page 3s that you are submitting as part of Form R, as well as
indicating the sequence of those pages. For example, your
facility transfers the reported EPCRA section 313 chemical in
wastewaters to three POTWs. You would photocopy page 3
once, indicate at the bottom of each page 3 that there are a
total of two page 3 s and then indicate the first and second page
3. The boxes for the two POTWs on the first page 3 should be
numbered 6.1 .B. 1 and 6.1 .B.2, while the box for third POTW
on the second page 3 should be numbered 6. l.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 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
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 6.1 .A. 1 does
not apply to PBT chemicals). The following reporting range
codes are to be used:
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999
6.1.A.2 Basis of Estimate
You must identify the basis for your estimate of the total
quantity of the reported EPCRA section 313 chemical in the
wastewater transferred to all POTWs. You should enter one
of the following letter codes that applies to the method by
which the largest percentage of the estimate was derived.
M— Estimate is based on monitoring data or measurements
for the EPCRA section 313 chemical as transferred to an
off-site facility.
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Instructions for Completing Part II of EPA Form R
C— Estimate is based on mass balance calculations, such as
calculation of the amount of the EPCRA section 313
chemical in streams entering and leaving process
equipment.
E— Estimate is based on published emission factors, such as
those relating release quantity to through-put or
equipment type (e.g., air emission factors).
O— Estimate is based on other approaches such as
engineering calculations (e.g., estimating volatilization
using published mathematical formulas) or best
engineering judgment. This would include applying an
estimated removal efficiency to a waste stream, even if
the composition of the stream before treatment was fully
identified through monitoring data.
If you transfer an EPCRA section 313 chemical to more than
one POTW, you should report the basis of estimate that was
used to determine the largest percentage of the EPCRA section
313 chemical that was transferred.
6.2 Transfers to Other Off-Site Locations
In Section6.2 enter the EPA Identification Number, name, and
address for each off-site location to which your facility ships
or transfers wastes containing the reported EPCRA section 313
chemical for the purposes of disposal, treatment, energy
recovery, or recycling. Also estimate the quantity of the
reported EPCRA section 313 chemical transferred and the
basis upon which the estimate was made. This would include
any residual chemicals in "empty" containers transferred off-
site. EPA expects that all containers (bags, totes, drums, tank
trucks, etc.) will have a small amount of residual solids and/or
liquids. Please see Example 14 on page 48 for residue
quantities left in drums and tanks when emptied.
If appropriate, you must report multiple activities for each off-
site location. For example, if your facility sends a reported
EPCRA section 313 chemical in a single waste stream to an
off-site location where some of the EPCRA section 313
chemical is to be recycled while the remainder of the quantity
transferred is to be treated, you must report both the waste
treatment and recycle activities, along with the quantity
associated with each activity.
If your facility transfers an EPCRA section 313 chemical to an
off-site location and that off-site location performs more than
four activities on that chemical, provide the necessary
information in Box 6.2.1 for the off-site facility and the first
four activities. Provide the information on the remainder of
the activities in Box 6.2.2 and provide again the off-site
facility identification and location information.
If you do not ship or transfer wastes containing the EPCRA
section 313 chemical to other off-site locations, you should
enter NA (See discussion of NA vs. a Numeric Value (e.g.,
Zero) in the introduction of Section 6) in the box for the off-
site location's EPA Identification Number (defined in 40 CFR
260.10 and therefore commonly referred to as the RCRA ID
Number). This number may be found on the Uniform
Hazardous Waste Manifest, which is required by RCRA
regulations. If you ship or transfer wastes containing an
EPCRA section 313 chemical and the off-site location does not
have an EPA Identification Number (e.g., it does not accept
RCRA hazardous wastes) enter NA in the box for the off-site
location EPA Identification Number. If you ship or transfer
hazardous wastes, containing an EPCRA section 313 chemical,
to a facility that treats, stores, or disposes RCRA hazardous
wastes, make sure to include that facility's RCRA
Identification Number in the box for the off-site location EPA
Identification Number. This RCRA ID is shown on the RCRA
manifest that must accompany the hazardous waste to the off-
site facility.
If you ship or transfer the reported EPCRA section 313
chemical in wastes to another country, you do not need to
report a RCRA ID for that waste. You should indicate NA in
the RCRA ID field. Enter the complete address of the non-
U.S. facility in the off-site address fields, the city in the city
field, the non-U.S. state or province in the county field, the
postal code in the zip code field, and the foreign country code
in the country field. The most commonly used FIPs codes are
listed in Table IV. To obtain a FIPS code for a country not
listed, contact the EPCRA Call Center. There is nothing to
enter in the state field.
6.2a Column A: Total Transfers
For each off-site location, enter the total amount, in pounds (in
grams for dioxin and dioxin-like compounds), of the EPCRA
section 313 chemical that is contained in the waste transferred
to that location. Do not enter the total poundage of the
waste. If you do not ship or transfer wastes containing the
EPCRA section 313 chemical to other off-site locations, you
should enter NA (See discussion of NA vs. a Numeric Value
(e.g., Zero) in the introduction of Section 6) in the box for the
off-site location's EPA Identification Number (defined in 40
CFR 260.10 and therefore commonly referred to as the RCRA
ID Number).
Toxics Release Inventory Reporting Forms and Instructions 47
-------
Instructions for Completing Part II of EPA Form R
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
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 Oil*
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
*For 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
48 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form R
Example 14: Container Residue
You have determined that a Form R for an EPCRA section 313 chemical must be submitted. The facility purchases and uses one
thousand 55-gallon steel drums that contain a 10% solution of the chemical. Further, it is assumed that the physical properties
of the solution are similar to water. The solution is pumped from the drums directly into a mixing vessel and the "empty" drums
are triple-rinsed with water. The rinse water is indirectly discharged to a POTW and the cleaned drums are sent to a drum
reclaimer.
In this example, it can be assumed that all of the residual solution in the drums was transferred to the rinse water. Therefore, the
quantity transferred to the drum reclaimer should be reported as "zero." The annual quantity of residual solution that is
transferred to the rinse water can be estimated by multiplying the mean weight percent of residual solution remaining in water
from pumping a steel drum (2.29% from the preceding table, "Summary of Residue Quantities From Pilot-Scale Experimental
Study") by the total annual weight of solution in the drum (density of solution multiplied by drum volume). If the density is not
known, it may be appropriate to use the density of water (8.34 pounds per gallon):
(2.29%) x (8.34 pounds/gallon) x (55 gallons/drum) x (1,000 drums) = 10,504 pounds solution
The concentration of the EPCRA section 313 chemical in the solution is only 10%.
(10,504 pounds solution) x (io%) = 1,050 pounds
Therefore, 1,050 pounds of the chemical are transferred to the POTW.
If you transfer the EPCRA section 313 chemical in wastes to an
off-site facility for distinct and multiple purposes, you must
report those activities for each off-site location, along with the
quantity of the reported EPCRA section 313 chemical associated
with each activity. For example, your facility transfers a total of
15,000 pounds of toluene to an off-site location that will use
5,000 pounds for the purposes of energy recovery, enter 7,500
pounds into a recovery process, and dispose of the remaining
2,500 pounds. These quantities and the associated activity codes
must be reported separately in Section 6.2. (See Figure 4 for a
hypothetical Section6.2 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.
M— Estimate is based on monitoring data or measurements
for the EPCRA section 313 chemical as transferred to an
off-site facility.
C— Estimate is based on mass balance calculations, such as
calculation of the amount of the EPCRA section 313
chemical in streams entering and leaving process
equipment.
E— Estimate is based on published emission factors, such as
those relating release quantity to throughput or
equipment type (e.g., air emission factors).
O— Estimate is based on other approaches such as
engineering calculations (e.g., estimating volatilization
using published mathematical formulas) or best
engineering judgment. This would include applying an
estimated removal efficiency to a waste stream, even if
the composition of the streambefore treatment was fully
identified through monitoring data.
Toxics Release Inventory Reporting Forms and Instructions 49
-------
Instructions for Completing Part II of EPA Form R
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 locationyou must report
that quantity in Section 8.1.
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))
priorto that reuse, it need not be reported in section 6.2 or section
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, andM99. These codes
are for off-site transfers for further waste management in which
the wastestream may be treated but the metal contained in the
wastestream is not treated and is ultimately released. For
example, M41 should be used for a metal or metal category
compound that is stabilized in preparation for disposal.
Applicable codes for Part II, Section 6.2, column C are:
Disposal
M10 Storage Only
M41 Solidification/Stabilization—Metals and Metal Category
Compounds only
M62 Wastewater Treatment (Excluding POTW) — Metals
and Metal Category Compounds only
M64 Other Landfills
M65 RCRA Subtitle C Landfills
M66 Subtitle C Surface Impoundment
M67 Other Surface Impoundments
M73 Land Treatment
M79 Other Land Disposal
M81 Underground Injection to Class I Wells
M82 Underground Injection to Class II-V Wells
M90 Other Off-Site Management
M94 Transfer to Waste Broker — Disposal
50 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form R
M99 Unknown
Treatment
M40 Solidification/Stabilization
M50 Incineration/Thermal Treatment
M54 Incineration/Insignificant Fuel Value
M61 Wastewater Treatment (Excluding POTW)
M69 Other Waste Treatment
M95 Transfer to Waste Broker — Waste Treatment
Energy Recovery
M56 Energy Recovery
M92 Transfer to Waste Broker — Energy Recovery
Recycling
M20 Solvents/Organics Recovery
M24 Metals Recovery
M26 Other Reuse or Recovery
M28 Acid Regeneration
M93 Transfer to Waste Broker — Recycling
Toxics Release Inventory Reporting Forms and Instructions 51
-------
Instructions for Completing Part II of EPA Form R
Figure 4
Hypothetical Secton 6.2 Completed for Two Off-Site Locations
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATION
6.2.1
Off-Site EPA Identification Number (RCRA No.)
Off-Site Location Name . „
A/^rvio U
Street Address
City
State
UULttoolb
Aaste Services
2461
5 Market Street
Releaseville
CO
Zip Code
A. Total Transfers (pounds)/year)
(enter range code or estimate)
1.
2.
3.
4.
5,000
7,500
2,500
NA
of\Af.] Is location under ct
oU'H) 1 facility or parent co
B. Basis of Estimate
(enter code)
i.O
2.C
3.0
4.
County
TTill
11111
jntrol of reporting |— | Yeg rjg NO
mpany
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. M56
2. M20
3. M65
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, enter 7,500 pounds into a recovery process, and dispose of the remaining 2,500 pounds.
This off-site location receives a transfer of 12,500 pounds of tetrachloroethylene (perchloroethylene) that is part of a waste that is
combusted for the purposes of energy recovery in an industrial furnace. Note that the tetrachloroethylene should be reported using
code M54 to indicate that it is combusted in an energy recovery unit but it does not contribute to the heating value of the waste.
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATION
6.2.2
Off-Site EPA Identification Number (RCRA No.)
Off-Site Location Name „ ,
1 v\tviKiic
Street Address
T; TJo™i,4^ r>^
City
State
Dumfry
^ Zip Code
\*S\J
A. Total Transfers (pounds)/year)
(enter range code or estimate)
1.
2.
12,500
NA
3.
4.
UUL»lt»//2
tion, Inc.
id
sn^nn ls loca*ion under C(
oUjUU facility or parent co
B. Basis of Estimate
(enter code)
1. O
2.
3.
4.
5432
County
Bums
jntrol of reporting Q Yes E] No
mpany
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. M54
2. M
3. M
4. M
52 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form R
Section 7. On-Site Waste Treatment, Energy
Recovery, and Recycling Methods
You must report in this section the methods of waste treatment,
energy recovery, and recycling applied to the reported EPCRA
section 313 chemical in wastes on-site. There are three separate
sections for reporting such activities.
Section 7A On-Site Waste Treatment Methods and Efficiency
Most of the chemical-specific information required by EPCRA
section 313 that is reported on Form R is specific to the EPCRA
section 313 chemical rather than the waste stream containing the
EPCRA section 313 chemical. However, EPCRA section 313
does require that waste treatment methods applied on-site to
waste streams that contain the EPCRA section 313 chemical be
reported. This information is reportable regardless of whether the
facility actively applies treatment or the treatment of the waste
stream occurs passively. This information is collected in Section
7 A of Form R.
In Section 7 A, you must provide the following information if you
treat waste streams containing the reported EPCRA section 313
chemical on-site:
(a) The general waste stream types containing the EPCRA
section 313 chemical being reported;
(b) The waste treatment method(s) or sequence used on all
waste streams containing the EPCRA section 313 chemical;
(c) The range of concentration of the EPCRA section 313
chemicals in the influent to the waste treatment method;
(d) The efficiency of each waste treatment method or waste
treatment sequence in destroying or removing the EPCRA
section 313 chemical; and
(e) Whether the waste treatment efficiency figure was based on
actual operating data.
Use a separate line in Section 7A for each general waste stream
type. Report only information about treatment of waste streams
at your facility, not information about off-site waste treatment.
If you do not perform on-site treatment of waste streams
containing the reported EPCRA section 313 chemical, check the
NA box at the top of Section 7A.
7A Column a: General Waste Stream
For each waste treatment method, indicate the type of waste
stream containing the EPCRA section 313 chemical that is
treated. Enter the letter code that corresponds to the general
waste stream type:
A Gaseous (gases, vapors, airborne particulates)
W Wastewater (aqueous waste)
L Liquid waste streams (non-aqueous waste)
S Solid waste streams (including sludges and slurries)
If a waste is a combination of water and organic liquid and the
organic content is less than 50%, report it as a wastewater (W).
Slurries and sludges containing water should be reported as solid
waste if they contain appreciable amounts of dissolved solids, or
solids that may settle, such that the viscosity or density of the
waste is considerably different from that of process wastewater.
7A Column b: Waste Treatment Method(s) Sequence
Enter the appropriate waste treatment code from the list below for
each on-site waste treatment method used on a waste stream
containing the EPCRA section 313 chemical, regardless of
whether the waste treatment method actually removes the specific
EPCRA section 313 chemical being reported. Waste treatment
methods must be reported for each type of waste stream being
treated (i.e., gaseous waste streams, aqueous waste streams,
liquid non-aqueous waste streams, and solids). Except for the air
emission treatment codes, the waste treatment codes are not
restricted to any medium.
Waste streams containing the EPCRA section 313 chemical may
have a single source or may be aggregates of many sources. For
example, process water from several pieces of equipment at your
facility may be combined prior to waste treatment. Report waste
treatment methods that apply to the aggregate waste stream, as
well as waste treatment methods that apply to individual waste
streams. If your facility treats various wastewater streams
containing the EPCRA section 313 chemical in different ways,
the different waste treatment methods must be listed separately.
If your facility has several pieces of equipment performing a
similar service in a waste treatment sequence, you may combine
the reporting for such equipment. It is not necessary to enter four
codes to cover four scrubber units, for example, if all four are
treating waste streams of similar character (e.g., sulfuric acid mist
emissions), have similar influent concentrations, and have similar
removal efficiencies. If, however, any of these parameters differs
from one unit to the next, each scrubber should be listed
separately.
If you are using the hardcopy paper form, and if your facility
performs more than eight sequential waste treatment methods on
a single general waste stream, continue listing the methods in the
next row and renumber appropriately those waste treatment
method code boxes you used to continue the sequence. For
example, if the general waste stream in box 7A.la had nine
treatment methods applied to it, the ninth method would be
indicated in the first method box for row 7 A.2a. The numeral "1"
would be crossed out, and a "9" would be inserted.
Toxics Release Inventory Reporting Forms and Instructions 53
-------
Instructions for Completing Part II of EPA Form R
Example 16: Calculating Releases and Other Waste Management Quantities
Your facility disposes of 14,000 pounds of lead chromate (PbCrO4.PbO) in an on-site landfill and transfers 16,000 pounds of
lead selenite (PbSeC^) to an off-site land disposal facility. You would therefore be submitting three separate reports on the
following: lead compounds, selenium compounds, and chromium compounds. However, the quantities you would be reporting
would be the pounds of "parent" metal being released on-site or transferred off-site for further waste management. All quantities
are based on mass balance calculations (See Section 5, Column B for information on Basis of Estimate and Section 6.2, Column
C for waste management codes and information on transfers of EPCRA section 313 chemicals in wastes). You would calculate
releases of lead, chromium, and selenium by first determining the percentage by weight of these metals in the materials you use
as follows:
Lead Chromate (PbCrO4.PbO)
Lead (2 Pb atoms)
Chromium (1 Cr atom)
Lead chromate is therefore (% by weight)
Molecular weight = 546.37
Atomic weight =207.2x2 = 414.4
Atomic weight = 51.996
(414.4/546.37) = 75.85% lead and
(51.996/546.37) = 9.52% chromium
Lead Selenite (PbSeO4)
Lead (1 Pb atom)
Selenium (1 Se atom)
Lead selenite is therefore (% by weight)
Molecular weight = 350.17
Atomic weight = 207.2
Atomic weight = 78.96
(207.2/350.17) = 59.17% lead and
(78.96/350.17) = 22.55% selenium.
The total pounds of lead, chromium, and selenium disposed on or off-site from your facility are as follows:
Lead
Disposal on-site:
Transfer off-site for disposal:
Chromium
Disposal on-site:
Selenium
Transfer off-site for disposal:
0.7585 x 14,000 = 10,619 pounds from lead chromate
0.5917 x 16,000 = 9,467 pounds from lead selenite
0.0952 x 14,000 = 1,333 pounds from lead chromate
0.2255 x 16,000 = 3,608 pounds from lead selenite
Treatment applied to any other general waste stream types
would then be listed in the next empty row. In the scenario
above, for instance, the second general waste stream would be
reported in row 7 A. 3 a. See Figure 5 for an example of a
hypothetical Section 7A completed for a nine-step waste
treatment process and a single waste treatment method.
The completion of each waste treatment method sequence
should clearly be marked by using an NA following the last
waste treatment code, except in the situation in which exactly
eight waste treatment methods are listed. For example, if the
waste stream in box 7A. Ib has three waste treatment codes
listed, a NA should be placed in the fourth method box to
indicate the termination of the sequence. If the waste stream
has exactly eight waste treatment codes, there is no need to
enter an NA to terminate the sequence. If the waste stream has
more than eight waste treatment codes: (1) Enter NA in
Column C in the initial row and any subsequent rows in which
54 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form R
the sequence is not terminated to indicate that the given waste
stream continues on the next row (e.g., if waste treatment
codes are continued in 7A.2b from 7A. Ib, a NA should be
indicated in 7 A. lc.); (2) enter NA in the box following the last
waste stream code to indicate the termination of the sequence,
unless the sequence ends in the method box 8 (i.e., there are 8,
16, 24, 32, etc. waste stream codes); and (3) complete the
information for Columns C, D, and E in the last row for a
given sequence. For example, if the sequence terminates in
7A.3b, then fill in all relevant information for C, D, and E in
this row. You do not need to reenter your General Waste
Stream code in column A. See Figure 5 for an example.
If you need additional space to report under Section 7A,
photocopy page 4 of Form R as many times as necessary. At
the bottom of page 4 you will find instructions for indicating
the total number of page 4s that you are submitting as part of
Form R, as well as instructions for indicating the sequence of
those pages.
Waste Treatment Codes
Air Emissions Treatment (applicable to gaseous waste
streams only)
A01 Flare
A02 Condenser
A03 Scrubber
A04 Absorber
A05 Electrostatic Precipitator
A06 Mechanical Separation
A07 Other Air Emission Treatment
Biological Treatment
B11 Aerobic
B21 Anaerobic
B31 Facultative
B99 Other Biological Treatment
Chemical Treatment
CO 1 Chemical Precipitation — Lime or Sodium
Hydroxide
C02 Chemical Precipitation — Sulfide
C09 Chemical Precipitation — Other
Cll Neutralization
C21 Chromium Reduction
C31 Complexed Metals Treatment (other than pH
adjustment)
C41 Cyanide Oxidation — Alkaline Chlorination
C42 Cyanide Oxidation — Electrochemical
C43 Cyanide Oxidation — Other
C44 General Oxidation (including Disinfection) —
Chlorination
C45 General Oxidation (including Disinfection)—
Ozonation
C46 General Oxidation (including Disinfection) —
Other
C99 Other Chemical Treatment
Incineration/Thermal Treatment
F01 Liquid Injection
F11 Rotary Kiln with Liquid Inj ection Unit
F19 Other Rotary Kiln
F31 Two Stage
F41 Fixed Hearth
F42 Multiple Hearth
F51 FluidizedBed
F61 Infra-Red
F71 Fume/Vapor
F81 Pyrolytic Destructor
F82 Wet Air Oxidation
F83 Thermal Drying/Dewatering
F99 Other Incineration/Thermal Treatment
Physical Treatment
P01 Equalization
P09 Other Blending
P11 Settling/Clarification
P12 Filtration
P13 Sludge Dewatering (non-thermal)
P14 Air Flotation
P15 Oil Skimming
P16 Emulsion Breaking — Thermal
P17 Emulsion Breaking — Chemical
P18 Emulsion Breaking — Other
P19 Other Liquid Phase Separation
P21 Adsorption — Carbon
P22 Adsorption — Ion Exchange (other than for
recovery/reuse)
P23 Adsorption — Resin
P29 Adsorption — Other
P31 Reverse Osmosis (other than for recovery/reuse)
P41 Stripping — Air
P42 Stripping — Steam
P49 Stripping — Other
P51 Acid Leaching (other than for recovery/reuse)
P61 Solvent Extraction (other than recovery/reuse)
P99 Other Physical Treatment
Toxics Release Inventory Reporting Forms and Instructions 55
-------
Instructions for Completing Part II of EPA Form R
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
Q Not Applicable (NA) - Check here if no on-site waste treatment is applied to any
waste stream containing the toxic chemical or chemical category.
a. General
Waste Stream
(enter code)
7A.1a
W
7A.2a
7A.3a
A
7A.1b
3
6
b. Waste Treatment Method(s) Sequence
[enter 3-character code(s)]
P17
P21
7A.2b
3
6
1
4
7
9/
7A.3b
3
6
4
7
1
4
7
P12
P61
B21
C44
A01
2
5
8
2
5
8
2
5
8
P18
P42
P11
NA
NA
c. Range of Influent
Concentration
7A.1c
NA
7A.2c
1
7A.3c
1
d . Waste
Treatment
Efficiency
Estimate
7A.1d
%
7A.2d
99 %
7A.3d
91 *
e. Based on
Operating Data?
7A.
Yes
1e
No
7A.2e
Yes
X
No
7A.3e
Yes
X
No
Figure 5. Hypothetical Section 7A
Solidification/Stabilization
G01 Cement Processes (including silicates)
G09 Other Pozzolonic Processes (including silicates)
Gil Asphaltic Processes
G21 Thermoplastic Techniques
G99 Other Solidification Processes
7A Column c: Range of Influent Concentration
The form requires an indication of the range of concentration
of the EPCRA section 313 chemical in the waste stream (i.e.,
the influent) as it typically enters the waste treatment step or
sequence. The concentration is based on the amount or mass
of the EPCRA section 313 chemical in the waste stream as
compared to the total amount or mass of the waste stream.
Enter in the space provided one of the following code numbers
corresponding to the concentration of the EPCRA section 313
chemical in the influent:
1 = Greater than 10,000 parts per million (1%)
2 = 100 parts per million (0.01%) to 10,000 parts per
million (1%)
3 = 1 part per million (0.0001%) to 100 parts per
million (0.01%)
4 = 1 part per billion to 1 part per million
5 = Less than 1 part per billion
Note: Parts per million (ppm) is:
milligrams/kilogram (mass/mass) for solids and
liquids;
cubic centimeters/cubic meter (volume/volume) for
gases;
milligrams/liter for solutions or dispersions of the
chemical in water; and
• milligrams of chemical/kilogram of air for
particulates in air.
If you have paniculate concentrations (at standard temperature
and pressure) as grains/cubic foot of air, multiply by 1766.6 to
convert to parts per million; if in milligrams/cubic meter,
multiply by 0.773 to obtain parts per million. These conversion
factors are for standard conditions of 0° C (32°F) and 760 mm
Hg atmospheric pressure.
56 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
7 A Column d: Waste Treatment Efficiency Estimate
In the space provided, enter the number indicating the
percentage of the EPCRA section 313 chemical removed from
the waste stream through destruction, biological degradation,
chemical conversion, or physical removal. The waste
treatment efficiency (expressed as percent removal) represents
the percentage of the EPCRA section 313 chemical destroyed
or removed (based on amount or mass), not merely changes in
volume or concentration of the EPCRA section 313 chemical
in the waste stream. The efficiency, which can reflect the
overall removal from sequential treatment methods applied to
the general waste stream, refers only to the percent destruction,
degradation, conversion, or removal of the EPCRA section
313 chemical from the waste stream, it does not refer to the
percent conversion or removal of other constituents in the
waste stream. The efficiency also does not refer to the general
efficiency of the treatment method for any waste stream. For
some waste treatment methods, the percent removal will
represent removal by several mechanisms, as in an aeration
basin, where an EPCRA section 313 chemical may evaporate,
biodegrade, or be physically removed from the sludge.
Percent removal can be calculated as follows:
(I-E)xlOO%
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 multiply ing the concentration (by
weight) of the EPCRA section 313 chemical in the waste
stream by the total amount or weight of the waste stream. In
most cases, the percent removal compares the treated effluent
to the influent for the particular type of waste stream. For
solidification of wastewater, the waste treatment efficiency can
be reported as 100% if no volatile EPCRA section 313
chemicals were removed with the water or evaporated into the
air. Percent removal does not apply to incineration because
the waste stream, such as wastewater or liquids, may not exist
in a comparable form after waste treatment and the purpose of
incineration as a waste treatment is to destroy the EPCRA
section 313 chemical by converting it to carbon dioxide and
water or other byproducts. In cases where the EPCRA section
313 chemical is incinerated, the percent efficiency must be
based on the amount of the EPCRA section 313 chemical
destroyed or combusted, except for metals or metal category
compounds. In the cases in which a metal or metal category
compound is incinerated, the efficiency is reported as zero.
Similarly, an efficiency of zero must be reported for any waste
treatment method(s) that does not destroy, chemically convert
or physically remove the EPCRA section 313 chemical from
the waste stream.
For metal category compounds, the calculation of the
reportable concentration and waste treatment efficiency must
be based on the weight of the parent metal, not on the weight
of the metal compound. Metals are not destroyed, only
physically removed or chemically converted from one form
into another. The waste treatment efficiency reported must
represent only physical removal of the parent metal from the
waste stream (except for incineration), not the percent
chemical conversion of the metal compound. If a listed waste
treatment method converts but does not remove a metal (e.g.,
chromium reduction), the method must be reported with a
waste treatment efficiency of zero.
EPCRA section 313 chemicals that are strong mineral acids
neutralized to a pH of 6 or above are considered treated at a
100% efficiency.
When calculating waste treatment efficiency and influent
chemical concentration, 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.
7A Column e: Based on Operating Data?
This column requires you to indicate "Yes" or "No" to whether
the waste treatment efficiency estimate is based on actual
operating data. For example, you would check "Yes" if the
estimate is based on monitoring of influent and effluent wastes
under typical operating conditions.
If the efficiency estimate is based on published data for similar
processes or on equipment supplier's literature, or if you
otherwise estimated either the influent or effluent waste
comparison or the flow rate, check "No."
Section 7B On-Site Energy Recovery Processes
In Section 7B, you must indicate the on-site energy recovery
methods used on the reported EPCRA section 313 chemical.
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
Toxics Release Inventory Reporting Forms and Instructions 57
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Instructions for Completing Part II of EPA Form R
kiln, furnace, or boiler.
NA vs. a Numerical Value (e.g., Zero). If you do not
perform on-site energy recovery for a waste stream that
contains or contained the EPCRA section 313 chemical,
check the NA box at the top of Section 7B and enter NA in
Section 8.2. If you perform on-site energy recovery for the
waste stream that contains or contained the EPCRA section
313 chemical, enter the appropriate code in Section 7B and
enter the appropriate value in Section 8.2. If this quantity is
less than or equal to 0.5 pound, round to zero (unless the
chemical is a listed PBT chemical) and enter zero in 8.2.
(Note: for metals and metal compounds, you should only
report NA in Sections 7B and Section 8.2.)
Energy Recovery Codes
U01 Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
If your facility uses more than one on-site energy recovery
method for the reported EPCRA section 313 chemical, list
the methods used in descending order (greatest to least)
based on the amount of the EPCRA section 313 chemical
entering such methods.
Section 7C On-Site Recycling Processes
In Section 7C, you must report the recycling methods used on
the EPCRA section 313 chemical.
In this section, use the codes below to report only the recycling
methods in place at your facility that are applied to the EPCRA
section 313 chemical. Do not list any off-site recycling
activities. (Information about off-site recycling must be
reported in Part II, Section 6, "Transfers of the Toxic Chemical
in Wastes to Off-Site Locations.")
NA vs. a Numerical Value (e.g., Zero). If you do not
perform on-site recycling for the reported EPCRA 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.
R14 Solvents/Organics Recovery — Solvent Extraction
R19 Solvents/Organics Recovery — Other
R21 Metals Recovery — Electrolytic
R22 Metals Recovery — Ion Exchange
R23 Metals Recovery — Acid Leaching
R24 Metals Recovery — Reverse Osmosis
R26 Metals Recovery — Solvent Extraction
R27 Metals Recovery — High Temperature
R28 Metals Recovery — Retorting
R29 Metals Recovery — Secondary Smelting
R30 Metals Recovery — Other
R40 Acid Regeneration
R99 Other Reuse or Recovery
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).
On-Site Recycling Codes
Rl 1 Solvents/Organics Recovery — Batch Still
Distillation
R12 Solvents/Organics Recovery — Thin-Film
Evaporation
R13 Solvents/Organics Recovery — Fractionation
58 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 anEPCRA section 313 chemical (chemical A). A second
process generates a wastewater stream containing two EPCRA section 313 chemicals, a metal (chemical B) and a mineral
acid (chemical C). Thresholds for all three chemicals have been exceeded and you are in the process of completing separate
Form Rs for each chemical.
These two wastewater streams are combined and sent to an on-site wastewater treatment system before being discharged
to a POTW. This system consists of an oil/water separator that removes 99% of chemical A; a neutralization tank in which
the pH is adjusted to 7.5, thereby destroying 100% of the mineral acid (chemical C); and a settling tank where 95% of the
metal (chemical B) is removed from the water (and eventually landfilled off-site).
Section 7A should be completed slightly differently when you file the Form R for each of the chemicals. The table
accompanying this example shows how Section 7A should be completed for each chemical. First, on each Form R you
should identify the type of waste stream in Section 7A.la as wastewater (aqueous waste, code W). Next, on each Form R
you should list the code for each of the treatment steps that is applied to the entire waste stream, regardless of whether the
operation affects the chemical for whichyou are completing the Form R (for instance, the first four blocks of Section 7 A. Ib
of all three Form Rs should show: P19 (liquid phase separation), Cll (neutralization), Pll (settling/clarification), andN/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. 1 c of each Form R should show the concentration of the specific chemical in the influent
to the first step of the process (oil/water separation). For this example, assume chemicals A, B, and C are all present at
concentrations greaterthan 1%. Therefore, code "1" should be entered. Section 7A. Id applies to the efficiency of the entire
system in destroying and/or removing the chemical for which you are preparing the Form R. You should enter 99% when
filing for chemical A, 95% for chemical B, and 100% for chemical C. Finally, you should report whether the influent
concentration and efficiency estimates are based on operating data for each chemical, as appropriate.
Chemical A
7A.la
W
7A.lb
1. P19 2. Cll
3. Pll 4. N/A 5.
6. 7. 8.
7A.lc
1
7A.ld
99 %
7A.le
Yes No
X
Chemical B
7A.la
W
7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
1
7A.ld
95 %
7A.le
Yes No
X
Chemical C
7A.la
W
7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
1
7A.ld
100 %
7A.le
Yes No
X
Note that the quantity removed and/or destroyed is not reported in Section 7 and that the efficiency reported in Section 7 A. 1 d
refers to the amount of EPCRA section 313 chemical destroyed and/or removed from the applicable waste stream. The
amount actually destroyed should be reported in Section 8.6 (quantity treated on-site). For example, when completing the
Form R for Chemical B you should report "N/A"pounds in Section 8.6 because the metal has been removed from the
wastewater stream, but not actually destroyed. The quantity of Chemical B that is ultimately landfilled off-site should be
reported in Sections 6.2 and 8,lc. However, when completing the Form R for Chemical C you should report the entire
quantity in Section 8.6 because raising the pH to 7.5 will completely destroy the mineral acid.
Toxics Release Inventory Reporting Forms and Instructions 59
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Instructions for Completing Part II of EPA Form R
Example 18: Reporting On-Site Energy Recovery
One waste stream generated by your facility contains,
among other chemicals, toluene and Freon 113. Threshold
quantities are exceeded for both of these EPCRA section
313 chemicals, and you would, therefore, submit two
separate Form R reports. This waste stream is sent to an on-
site industrial furnace that uses the heat generated in a
thermal hydrocarbon cracking process at your facility.
Because toluene has a significant heat value (17,440
BTU/pound) and the energy is recovered in an industrial
furnace, the code "U02" would be reported in Section 7B
for the Form R submitted for toluene.
However, as Freon 113 does not contribute any value for
energy recovery purposes, the combustion of Freon 113 in
the industrial furnace is considered waste treatment, not
energy recovery. You would report Freon 113 as entering
a waste treatment step (i.e., incineration), in Section 7A,
column b. In Section 7B the facility should report zero.
Section 8. Source Reduction
and Recycling Activities
This section includes the data elements mandated by section 6607
of the Pollution Prevention Act of 1990 (PPA).
In Section 8, you must provide information about source
reduction activities and quantities of the EPCRA section 313
chemicals managed as waste. For all appropriate questions,
report only the quantity, in pounds, of the reported EPCRA
section 313 chemical itself (except the dioxin and dioxin-like
compound category). Do not include the weight of water, soil, or
other waste constituents. When reporting on the metal category
compounds, you should report only the amount of the metal
portion of the compound as you do when estimating release and
other waste management amounts.
Sections 8.1 through 8.9 must be completed for each EPCRA
section 313 chemical. Section 8.10 must be completed only if a
source reduction activity was newly implemented specifically (in
whole or in part) for the reported EPCRA section 313 chemical
during the reporting year. Section 8.11 allows you to indicate if
you have attached additional optional information on source
reduction, recycling, or pollution control activities implemented
at any time at your facility.
Sections 8.1 through 8.7 require reporting of quantities for the
current reporting year, the prior year, and quantities anticipated
in both the first year immediately following the reporting year
and the second year following the reporting year (future
estimates).
Do not enter the values in Section 8 in gallons, tons, liters, or any
measure other than pounds. You must also enter the values as
whole numbers. Numbers following a decimal point are not
acceptable for toxic chemicals other than those designated as
PBT chemicals. For PBT chemicals facilities should report
release and other waste management quantities greater than 0.1
pound (except the dioxin and dioxin-like compounds category)
provided the accuracy and the underlying data on which the
estimate is based supports this level of precision. For the dioxin
and dioxin-like compounds category facilities should report at a
level of precision supported by the accuracy of the underlying
data and the estimation techniques on which the estimate is
based. However, the smallest quantity that need be reported on
the Form R for the dioxin and dioxin-like compounds category is
0.0001 grams (See example 12 on page 40). Notwithstanding the
numeric precision used when determining reporting eligibility
thresholds, facilities should report on Form R to the level of
accuracy that their data supports, up to seven digits to the right of
the decimal. EPA's reporting software and data management
systems support data precision to seven digits to the right of the
decimal.
NA vs. a Numeric Value (e.g., Zero). You should enter a
numeric value in the relevant sections of Section 8 if your facility
has released, treated, combusted for energy recovery or recycled
any quantity of an EPCRA section 313 chemical during the
reporting year. If the aggregate quantity of that toxic chemical
was equal to or less than 0.5 pound for a particular waste
management method, you should enter the value zero (unless the
chemical is a PBT chemical) in the relevant section.
However, if there has been no on-site or off-site treatment,
combustion for energy recovery or recycling on the waste stream
containing the EPCRA section 313 chemical, then you should
enter NA in the relevant section. (Note: for metals and metal
category compounds, you should enter NA in Sections 8.2, 8.3,
8.6 and 8.7, as treatment and combustion for energy recovery
generally are not applicable waste management methods for
metals and metal compounds). For Section 8. Ib, NA generally
is not applicable recognizing the potential for spills, leaks, or
fugitive emissions of the EPCRA section 313 chemical. You
should enter NA in Section 8.8 if there were no remedial actions,
catastrophic events such as earthquakes, fires, or floods or
one-time events not associated with normal or routine production
processes for that toxic chemical. If there was a catastrophic
event at your facility, but you were able to prevent any releases
from occurring, then enter zero in Section 8.8.
Column A: Prior Year
Quantities for Sections 8.1 through 8.7 must be reported for the
year immediately preceding the reporting year in column A. For
reports due July 1, 2005 (reporting year 2004), the prior year is
2003. Information available at the facility that may be used to
estimate the prioryear's quantities include the prioryear's Form
R submission, supporting documentation, and recycling, energy
recovery, treatment, or disposal operating logs or invoices. When
reporting prior year estimates facilities are not required to use
60 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
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
2005 and 2006. EPA expects reasonable future quantity
estimates using a logical basis. Information available at the
facility to estimate quantities of the chemical expected during
these years include planned source reduction activities, market
projections, expected contracts, anticipated new product lines,
company growth projections, and production capacity figures.
Respondents should take into account protections available for
trade secrets as provided in EPCRA section 322 (42 USC 11042)
for the chemical identity.
Relationship to Other Laws
The reporting categories for quantities recycled, used for energy
recovery, treated, and disposed apply to completing Section 8 of
Form R as well as to the rest of Form R. These categories are to
be used only for TRI reporting. They are not intended for use in
determining, under the Resource Conservation and Recovery Act
(RCRA) Subtitle C regulations, whether a secondary material is
a waste when recycled. These definitions also do not apply to the
information that may be submitted in the Biennial Report
required under RCRA. In addition, these definitions do not imply
any future redefinition of RCRA terms and do not affect EPA's
RCRA authority or authority under any other statute administered
by EPA.
Differences in terminology and reporting requirements for
EPCRA section 313 chemicals reported on Form R and for
hazardous wastes regulated under RCRA occur because EPCRA
and the PPA focus on specific chemicals, while the RCRA
regulations and the Biennial Report focus on waste streams that
may include more than one chemical. For example, a RCRA
hazardous waste containing an EPCRA section 313 chemical is
recycled to recover certain constituents of that waste, but not the
toxic chemical reported under EPCRA section 313. The EPCRA
sections 13 chemical simply passes through the recycling process
and remains in the residual from the recycling process, which is
disposed. While the waste may be considered recycled under
RCRA, the EPCRA section 313 chemical constituent would be
considered to be disposed for TRI purposes.
Quantities Reportable in Sections 8.1-8.7
Section 8 of Form R uses data collected to complete Part II,
Sections 5 through 7. For this reason, Section 8 should be
completed last. Sections 8.1, 8.3, 8.5, 8.7, and 8.8 use data
collected to complete Sections 5 and 6 of Form R. The
relationship between Section s 5, 6, and 8.8 to Sections 8.1, 8.3,
8.5, and 8.7 are provided below in equation form.
Section 8.1. Beginning in the 2003 reporting year Section 8.1
was divided into four Subsections (8. la, 8.1b, 8.1c and 8. Id).
Please refer to the following equations that show the relationship
between Sections 5, 6 and 8. la through 8. Id. EPCRA section
329(8) defines release as "any spilling, leaking, pumping,
pouring, emitting, emptying, discharging, injecting, escaping,
leaching, dumping, or disposing [on-site or off-site] into the
environment (including the abandonment of barrels, containers,
and other closed receptacles)." In Section 8.1 facilities report
disposal and other releases. This includes on-site disposal and
other releases in Section 5 and off-site disposal and other releases
in Section 6 (releases plus transfers to disposal and transfers to
POTWs of metals and metal compounds), but excludes quantities
reported in Section 5 and 6 due to remedial actions, catastrophic
events, or non-production related events (see the discussion on
Section 8.8.)
Example 19: Reporting Future Estimates
A pharmaceutical manufacturing facility uses an EPCRA
section 313 chemical in the manufacture of a prescription
drag. During the reporting year (2004), the company
received approval from the Food and Drag Administration
to begin marketing their product as an over-the-counter drag
beginning in 2005. 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 drag will increase
their use of the reported EPCRA section 313 chemical by
3 0% per year for the two years following the reporting year.
The facility treats the EPCRA section 313 chemical on-site
and the quantity treated is directly proportional to
production activity. The facility thus estimates the total
quantity of the reported EPCRA section 313 chemical
treated for the following year (2005) by adding 30% to the
amount in column B (the amount for the current reporting
year). The second following year (2006) figure can be
calculated by adding an additional 30% to the amount
reported in column C (the amount for the following year
(2005) projection).
Metals and metal category compounds reported, 1) in Section 6.2
as sent off-site for stabilization/solidification (M41—metals) or
wastewater treatment (excluding POTWs) (M62—metals) and/or,
2) in Section 6.1 — discharges to POTWs should be reported in
Section 8.1. These quantities should NOT be reported in Section
8.7 because the metals are ultimately disposed.
Sections 8.1a and 8.1b. Toxic chemicals disposed or otherwise
released on site are reported in 8. la or 8. Ib as appropriate. Toxic
chemicals sent off site for disposal are reported in 8. Ic or 8. Id.
Toxics Release Inventory Reporting Forms and Instructions 61
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Instructions for Completing Part II of EPA Form R
§8.1a = § 5.4.1 + § 5.5.1A + § 5.5.1B- § 8.8 (on-site release or
disposal due to catastrophic events)1
§ 8.1b = § 5.1 + § 5.2 + § 5.3 + § 5.4.2 + § 5.5.2 + § 5.5.3A + §
5.5.3B + §5.5.4 - § 8.8 (on-site release or disposal due to
catastrophic events)1
Sections 8.1c and 8.Id. Toxic chemicals transferred off site
disposal to POTWs or other off-site locations should be reported
in 8. Ic or 8. Id as appropriate. For example, quantities of a toxic
chemical sent to a POTW and subsequently sent to a landfill are
reported in Section 8.1c. Quantities of the toxic chemical
disposed or otherwise released by the POTW to a stream are
reported in Section 8. Id. Metals and metal category compounds
sent to POTWs should be reported in one of these two sections
and should not be reported as treated for destruction in Section
8.7.
§ 8.1c = § 6.1 (portion of transfer that is untreated and
ultimately disposed of in UIC Class I Wells, RCRA Subtitle
C landfills, and other landfills) + § 6.2 (quantities associated
with M codes M64, M65 and M81) - § 8.8 (off-site disposal
due to catastrophic events)1
§ 8.1d = § 6.1 (portion of transfer that is untreated and
ultimately disposed of in UIC Class II-V wells, and disposal
other than to landfills) + § 6.2 (quantities associated with M
codes M10, M41, M62, M66, M67, M73, M79, M82, M90,
M94, M99) — § 8.8 (off-site disposal due to catastrophic
events)1
Some chemicals in addition to metals and metal category
compounds might not be treated for destruction at a POTW. If
you are able to quantify the amounts of a toxic chemical sent to
a POTW that are treated for destruction and disposed or released
from the POTW untreated, you should divide the amount reported
in Section 6.1 between Sections 8.1c and 8. Id and 8.7 (quantity
treated off site), as appropriate.
Sections 8.2 and 8.3. These relate to an EPCRA section 313
chemical or a mixture containing an EPCRA section 313
chemical that is used for energy recovery on-site or is sent off-
site for energy recovery, unless it is a commercially available fuel
(e.g., fuel oil no. 6). For the purposes of reporting on Form R,
reportable on-site and off-site energy recovery is the combustion
of a waste stream containing an EPCRA section 313 chemical
when:
(a) The combustion unit is integrated into an energy recovery
system (i.e., industrial furnaces, industrial kilns, and
boilers); and
(b) The EPCRA section 313 chemical is combustible and has a
Significant heating value (e.g., 5000 BTU) '§8-8 indudes quantities of toxic chemicals disposed or otherwise
released onsite or managed as a waste off site due to remedial actions,
catastrophic events, or one time events not associated with the production
Note: Metals and metal category compounds cannot be process.
combusted for energy recovery. For metals and metal category
compounds, you should enter NA in Sections 8.2 and 8.3.
§ 8.2 is reported in Section 8 only
§ 8.3 = § 6.2 (energy recovery) - §8.8 (off-site energy recovery
due to catastrophic events)1
Sections 8.4 and 8.5. These relate to an EPCRA section 313
chemical in a waste that is recycled on-site or is sent off-site for
recycling.
§ 8.4 is reported in Section 8 only
§ 8.5 = § 6.2 (recycling) - § 8.8 (off-site recycling due to
catastrophic events)1
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 sectionbecause they
cannot be destroyed (See Appendix B).
§ 8.6 is reported in Section 8 only
§ 8.7 = § 6.1 (excluding most metal/metal category
compounds) + § 6.2 (treatment) - § 8.8 (off-site treatment due
to catastrophic events)1
Some chemicals in addition to metals and metal category
compounds might not be treated for destruction at a POTW. If
you are able to quantify the amounts of a toxic chemical sent to
a POTW that are treated for destruction and disposed or released
fromthe 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
62 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
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 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 anEPCRA 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 FormR (on-site disposal
and other releases to the environment) and Section 6 (off-site
transfers for further waste management) must include all on-site
disposal and other releases and transfers for disposal as
appropriate, regardless of whether they arise from catastrophic,
remedial, or routine process operations.
Avoid Double-Counting in Sections 8.1 Through 8.8
Do not double- or multiple-count quantities in Sections 8.1
through 8.8. The quantities reported in each of those sections
should be mutually exclusive. Do not multiple-count quantities
entering sequential reportable activities during the reporting year.
Quantities of the EPCRA section 313 chemical disposed or
otherwise released into the environment or otherwise managed as
waste off site due to remedial actions; catastrophic events such as
earthquakes, fires, or floods; or unanticipated one-time events not
associated with the production process such as a drunk driver
crashing his/her car into a drum storage area. These quantities
should be reported in Section 8.8 only. For example, 10,000
pounds of diaminoanisole sulfate is released due to a catastrophic
event and is subsequently treated off-site. The 10,000 pounds is
reported in Section 8.8 but the amount subsequently treated off-
site is not reported in Section 8.7.
8.9 Production Ratio or Activity Index
For Section 8.9, you must provide a ratio of reporting year
production to prior year production, or provide an "activity
index" based on a variable other than production that is the
primary influence on the quantity of the reported EPCRA section
313 chemical recycled, used for energy recovery, treated,
disposed or released. The ratio or index must be reported to the
nearest tenths or hundredths place (i.e., one or two digits to the
right of the decimal point). For EPCRA section 313 PBT
chemicals, including the dioxin and dioxin-like compounds
category, you will report the same as for chemicals that are not
listed as PBT (i.e., up to one or two digits to the right of the
decimal point). If the manufacture, processing, or use of the
reported EPCRA section 313 chemical began during the current
reporting year, enter NA as the production ratio or activity index.
Note, this is not to be reported as a percent (i.e., report 1.10 for
a 10% increase, not 110%).
It is important to realize that if your facility reports more than one
reported EPCRA section 313 chemical, the production ratio or
activity index may vary for different chemicals. Forfacilities that
manufacture reported EPCRA section 313 chemicals, the
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quantities of the EPCRA section 313 chemical(s) produced in the
current and prior years provide a good basis for the ratio because
that is the primary business activity associated with the reported
EPCRA section 313 chemical(s). In most cases, the production
ratio or activity index must be based on some variable of
production or activity rather than on EPCRA section 313
chemical or material usage. Indices based on EPCRA section
313 chemical or material usage may reflect the effect of source
reduction activities rather than changes in business activity.
EPCRA section 313 chemical or material usage is therefore not
a basis to be used for the production ratio or activity index where
the EPCRA section 313 chemical is "otherwise-used" (i.e.,
non-incorporative activities such as extraction solvents, metal
degreasers, etc.).
While several methods are available to the facility for
determining this data element, the production ratio or activity
index must be based on the variable that most directly affects the
quantities of the EPCRA section 313 chemical recycled, used for
energy recovery, treated, disposed or released. Examples of
methods available include:
(1) Amount of EPCRA section 313 chemical manufactured in
2004 divided by the amount of EPCRA section 313 chemical
manufactured in 2003; or
(2) Amount of product produced in 2004 divided by the amount
of product produced in 2003.
8.10 Did Your Facility Engage in Any Source Reduction
Activities for This Chemical During the Reporting Year?
Section 8.10 must be completed only if a source reduction
activity was newly implemented specifically (in whole or in part)
for the reported EPCRA section 313 chemical during the
reporting year. If your facility engaged in any source reduction
activity for the reported EPCRA section 313 chemical during the
reporting year, report the activity that was implemented and the
method used to identify the opportunity for the activity
implemented. If your facility did not engage in any source
reduction activity for the reported EPCRA section 313 chemical,
enter NA in Section 8.10.1 and answer Section 8.11.
Source reduction means any practice that:
G 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
G Reduces the hazards to public health and the environment
associated with the release of such substances, pollutants,
or contaminants.
The term includes equipment or technology modifications,
process or procedure modifications, reformulation or redesign of
products, substitution of raw materials, and improvements in
housekeeping, maintenance, training, or inventory control.
The term source reduction does not include any practice that
alters the physical, chemical, or biological characteristics or the
volume of a hazardous substance, pollutant, or contaminant
through a process or activity that itself is not integral to and
necessary for the production of a product or the providing of a
service.
Source reduction activities do not include recycling, using for
energy recovery, treating, or disposing of an EPCRA section 313
chemical. Report in this section only the source reduction
activities implemented to reduce or eliminate the quantities
reported in Sections 8.1 through 8.7. The focus of the section is
only those activities that are applied to reduce routine or
reasonably anticipated releases and quantities of the reported
EPCRA section 313 chemical recycled, treated, used for energy
recovery, or disposed. Do not report in this section any activities
taken to reduce or eliminate the quantities reported in Section 8.8.
If you have fewer than four source reduction codes in Section
8.10, an NA should be placed in the first column of the first
unused row to indicate the termination of the sequence. If all
four rows are used, there is no need to terminate the sequence. If
there are more than four source reduction codes, photocopy page
5 of Form R as many times as necessary and then number the
boxes consecutively for each source reduction activity. Enter NA
when the sequence has terminated, unless the sequence ends at 4,
8, 12, 16, etc. source reduction codes.
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Example 20: Quantity Released to the Environment as a Result of Remedial Actions,
Catastrophic Events, or One-Time Events Not Associated with Production Processes.
A chemical manufacturer produces an EPCRA section 313 chemical in a reactor that operates at low pressure. The reactants and
the EPCRA section 313 chemical product are piped in and out of the reactor at monitored and controlled temperatures. During
normal operations, small amounts of fugitive emissions occur from the valves and flanges in the pipelines.
Due to a malfunction in the control panel (which is state-of-the-art and undergoes routine inspection and maintenance), the
temperature and pressure in the reactor increase, the reactor ruptures, and the EPCRA section 313 chemical is released. Because
the malfunction could not be anticipated and, therefore, could not be reasonably addressed by specific source reduction activities,
the amount released is included in Section 8.8. In this case, much of the EPCRA section 313 chemical is released as a liquid and
pools on the ground. It is estimated that 1,000 pounds of the EPCRA section 313 chemical pooled on the ground and was
subsequently collected and sent off-site for treatment. In addition, it is estimated that another 200 pounds of the EPCRA section
313 chemical vaporized directly to the air from the rupture. The total amount reported in Section 8.8 is the 1,000 pounds that pooled
on the ground (and subsequently sent off-site), plus the 200 pounds that vaporized into the air, a total of 1,200 pounds. The quantity
sent off-site must also be reported in Section 6 (but not in Section 8.7) and the quantity that vaporized must be reported as a fugitive
emission in Section 5 (but not in Section 8. Ib).
Example 21: Avoiding Double-Counting Quantities in Sections 8.1 through 8.7
5,000 pounds of an EPCRA section313 chemical enters a treatment operation. Three thousand pounds of the EPCRA section313
chemical exits the treatment operation and then enters a recycling operation. Five hundred pounds of the EPCRA section 313
chemical are in residues from the recycling operation that is subsequently sent off-site to a landfill for disposal. These quantities
would be reported as follows in Section 8:
Section 8.1c: 500 pounds disposed
Section 8.4: 2,500 pounds recycled
Section 8.6: 2000 pounds treated (5,000 that initially entered — 3,000 that subsequently entered recycling)
To report that 5,000 pounds were treated, 3,000 pounds were recycled, and that 500 pounds were sent off-site for disposal would
result in over-counting the quantities of EPCRA section 313 chemical recycled, treated, and disposed by 3,500 pounds.
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.
Rememberthat 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
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W29 Other changes made in inventory control Product Modifications
Spill and Leak Prevention W81 Changed product specifications
W82 Modified design or composition of product
W31 Improved storage or stacking procedures W83 Modified packaging
W32 Improved procedures for loading, unloading, and W89 Other product modifications made
transfer operations
W33 Installed overflow alarms or automatic shut-off
valves
W3 5 Installed vapor recovery systems
W36 Implemented inspection or monitoring program of
potential spill or leak sources
W39 Other changes made in spill and leak prevention
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
W49 Other raw material modifications made
Process Modifications
W51 Instituted re-circulation within a process
W52 Modified equipment, layout, or piping
W53 Used a different process catalyst
W54 Instituted better controls on operating bulk
containers to minimize discarding of empty
containers
W55 Changed from small volume containers to bulk
containers to minimize discarding of empty
containers
W58 Other process modifications made
Cleaning and Decreasing
W59 Modified stripping/cleaning equipment
W60 Changed to mechanical stripping/cleaning devices
(from solvents or other materials)
W61 Changed to aqueous cleaners (from solvents or
other materials)
W63 Modified containment procedures for cleaning units
W64 Improved draining procedures
W65 Redesigned parts racks to reduce drag out
W66 Modified or installed rinse systems
W67 Improved rinse equipment design
W68 Improved rinse equipment operation
W71 Other cleaning and decreasing modifications made
Surface Preparation and Finishing
W72 Modified spray systems or equipment
W73 Substituted coating materials used
W74 Improved application techniques
W75 Changed from spray to other system
W78 Other surface preparation and finishing
modifications made
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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.
TO 1 Internal pollution prevention opportunity audit(s)
T02 External pollution prevention opportunity audit(s)
T03 Materials balance audits
T04 Participative team management
T05 Employee recommendation (independent of a
formal company program)
T06 Employee recommendation (under a formal
company program)
T07 State government technical assistance program
T08 Federal government technical assistance program
T09 Trade association/industry technical assistance
program
T10 Vendor assistance
Til Other
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Example 22: Determining a Production Ratio
Your facility' s only use of toluene is as a paint carrier for a painting operation. You painted 12,000 refrigerators in the current
reporting year and 10,000 refrigerators during the preceding year. The production ratio for toluene in this case is 1.2
(12,000/10,000) because the number of refrigerators produced is the primary factor determining the quantity of toluene to be
reported in Sections 8.1 through 8.7.
A facility manufactures inorganic pigments, including titanium dioxide. Hydrochloric acid (acid aerosols) is produced as a waste
byproduct during the production process. An appropriate production ratio for hydrochloric acid (acid aerosols) is the annual
titanium dioxide production, not the amount of byproduct generated. If the facility produced 20,000 pounds of titanium dioxide
during the reporting year and 26,000 pounds in the preceding year, the production ratio would be 0.77 (20,000/26,000).
Example 23: Determining an Activity Index
Your facility manufactures organic dyes in a batch process. Different colors of dyes are manufactured, and between color
changes, all equipment must be thoroughly cleaned with solvent containing glycol ethers to reduce color carryover. During the
preceding year, the facility produced 2,000 pounds of yellow dye in January, 9,000 pounds of green dye for February through
September, 2,000 pounds of red dye in November, and another 2,000 pounds of yellow dye in December. This adds up to a total
of 15,000 pounds and four color changeovers. During the reporting year, the facility produced 10,000 pounds of green dye
during the first half of the year and 10,000 pounds of red dye in the second half. If your facility uses glycol ethers in this cleaning
process only, an activity index of 0.5 (based on two color changeovers for the reporting year divided by four changeovers for
the preceding year) is more appropriate than a production ratio of 1.33 (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. Perchloroethy lene is used as a cleaning solvent
for this operation and this is the only use of the EPCRA section 313 chemical in your facility. You would enter NA in Section
8.9 because you have no basis of comparison in the prior year for the purposes of developing the activity index.
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Example 25: Determining the Production Ratio Based on a Weighted Average
At many facilities, a reported EPCRA section 313 chemical is used in more than one production process. In these cases, a
production ratio or activity index can be estimated by weighting the production ratio for each process based on the respective
contribution of each process to the quantity of the reported EPCRA section 313 chemical recycled, used for energy recovery,
treated, or disposed.
Your facility paints bicycles with paint containing toluene. Sixteen thousand bicycles were produced in the reporting year and
14,500 were produced in the prior year. There were no significant design modifications that changed the total surface area to be
painted for each bike. The bicycle production ratio is 1.1 (16,000/14,500). You estimate 12,500 pounds of toluene recycled,
used for energy recovery, treated, disposed or released as a result of bicycle production. Your facility also uses toluene as a
solvent in a glue that is used to make components and add-on equipment for the bicycles. Thirteen thousand components were
manufactured in the reporting year as compared to 15,000 during the prior year. The production ratio for the components using
toluene is 0.87 (13,000/15,000). You estimate 1,000 pounds of toluene treated, recycled, used for energy recovery, disposed or
released as a result of components production. A production ratio can be calculated by weighting each of the production ratios
based on the relative contribution each has to the quantities of toluene treated, recycled, used for energy recovery, disposed or
released during the reporting year (13,500 pounds). The production ratio is calculated as follows:
Production ratio = 1.1 x (12,500/13,500) + 0.87 x (1,000/13,500) = 1.08
Example 26: Source Reduction
A facility assembles and paints furniture. Both the glue used
to assemble the furniture and the paints contain EPCRA
sections 13 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.
8.11 Is Additional Optional Information on Source
Reduction, Recycling, or Pollution Control Activities
Included with this Report?
Check "Yes" for this data element if you have attached to this
report any additional optional information on source
reduction, recycling, or pollution control activities you have
implemented in the reporting year or in prior years for the
reported EPCRA section 313 chemical. If you are not
including additional information, check "No." If you submit
additional optional information, try to limit this information
to one page that summarizes the source reduction, recycling,
or pollution control activities. If there is a contact person at
the facility, other than the technical or public contact provided
in Part I, Section 4, the summary page should include that
person's name and telephone number for individuals who
wish to obtain further information about those activities. Also
submit a copy of this additional information to the appropriate
state agency as part of the Form R submittal to that agency.
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D. Facility Eligibility Determination for Alternate Threshold and for
Reporting on EPA Form A
This section will help to determine whether you can
submit the simplified Form A Certification Statement
(hereafter referred to as Form A). The criteria are based
on the total annual reportable amount of the listed
chemical or chemical category and the amount
manufactured, processed, or otherwise used.
D.I Alternate Threshold
On November 30, 1994, EPA published a final rule (59 FR
61488) that provides qualifying facilities an alternate
threshold of 1 million pounds. Eligible facilities wishing
to take advantage of this option may certify on a simplified
two-page form referred to as Form A Certification
Statement and do not have to use Form R. The "TRI
Alternate Threshold for Facilities with Low Annual
Reportable Amounts," provides facilities otherwise
meeting EPCRA section 313 reporting thresholds the
option of certifying on Form A provided that they do not
exceed 500 pounds for the total annual reportable amount
(defined below) for that chemical, and that their amounts
manufactured or processed or otherwise used do not
exceed one-million pounds. As with determining section
313 reporting thresholds, amounts manufactured,
processed, or otherwise used are to be considered
independently. This modification does not apply to forms
being submitted on or before July 1, 1995 (covering the
1994 reporting year). If you fill out a Form A for an
EPCRA section 313 chemical, do not fill out a Form R for
that same chemical.
However, there is an exception to the alternate threshold
rule described in the preceding paragraph. All PBT
chemicals (except certain instances of reporting lead in
stainless steel, brass or bronze alloys) are excluded from
eligibility for the alternate threshold.
D.2 What is the Form A
Certification Statement?
The Form A, which is described as the "certification
statement" in 59 FR 61488, is intended as a means to
reduce the compliance burden associated with EPCRA
section 313. The Form A must be submitted on an annual
basis for each eligible chemical. Facilities wishing to take
advantage of this burden reducing option must submit a
Form A for such chemicals meeting the conditions
described below, and should not submit a Form R to the
TRI Data Processing Center for that chemical. The
information submitted on the Form A includes facility
identification information and the chemical or chemical
category identity. The information submitted on the Form
A will appear in the TRI data base in the same manner that
information submitted on Form R appears. An approved
Form A and a magnetic version of reporting have been
included in this Reporting Forms and Instructions package.
D.3 What is the Total Annual
Reportable Amount?
For the purpose of this optional reporting modification, the
annual reportable amount is equal to the combined total
quantities released at the facility (including disposed
within the facility), treated at the facility (as represented
by amounts destroyed or converted by treatment
processes), recovered at the facility as a result of recycle
operations, combusted for the purpose of energy recovery
at the facility, and amounts transferred from the facility to
off-site locations for the purpose of recycle, energy
recovery, treatment, and/or disposal. These volumes
correspond to the sum of amounts reportable for data
elements on EPA Form R (EPA Form 9350-1; Rev. 04/97)
as Part II column B of section 8, data elements 8.1
(quantity released), 8.2 (quantity used for energy recovery
on-site), 8.3 (quantity used for energy recovery off-site),
8.4 (quantity recycled on-site), 8.5 (quantity recycled off-
site), 8.6 (quantity treated on-site), and 8.7 (quantity
treated off-site).
D.4 Recordkeeping
Each owner or operator who determines that they are
eligible, and wishes to apply the alternate threshold to a
particular chemical, must retain records substantiating this
determination for a period of three years from the date of
the submission of the Form A. These records must include
sufficient documentation to support calculations as well as
the calculations made by the facility that confirm their
eligibility for each chemical for which the alternate
threshold was applied.
A facility that fits within the category description, and
manufactures, processes or otherwise uses no more than
one-million pounds of an EPCRA section 313 chemical
annually, and whose owner/operator elects to take
advantage of the alternate threshold, is not considered an
EPCRA section 313 covered facility for that chemical for
the purpose of submitting a Form R. This determination
may provide further regulatory relief from other federal or
state regulations that apply to facilities on the basis of their
EPCRA section 313 reporting status. A facility will need
to reference other applicable regulations to determine if
their actual requirements may be affected by this reporting
modification.
D.5 Multi-establishment Facilities
For the purposes of using Form A, the facility must also
make its determination based upon the entire facility's
operations including all of its establishments (see 59 FR
61488 for greater detail). If the facility as a whole is able
to take advantage of the alternate threshold, a single Form
A is required. The eligibility to submit a Form A must be
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made on a whole facility determination. Thus, all of the
information necessary to make the determination must be
assembled to the facility level.
D.6 Trade Secrets
When making a trade secret claim on a Form A
submission, EPA is requiring that a facility submit a
unique Form A for each EPCRA section 313 chemical
meeting the conditions of the alternate threshold.
Facilities may assert a trade secrecy claim for a chemical
identity on the Form A as on the Form R. Reports
submitted on a per chemical basis protect against the
disclosure of trade secrets. Form As with trade secrecy
claims, like Form Rs with similar claims, will be
separately handled upon receipt to protect against
disclosure. Commingling trade secret chemical identities
with non-trade secret chemical identities on the same
submission increases the risk of disclosure.
Q Do not submit trade secret reports electronically
or on diskette.
D.7 Metals and Metal
Category Compounds
For metal category compounds, the category level of 500
pounds applies to the amount of parent metal waste that is
reported on Form R, but the thresholds apply to the
amount of metal category compounds manufactured,
processed, or otherwise used. For Form A certification
involving both listed parent metals and associated metal
compounds, the one million pound alternate threshold
must be applied separately to the listed parent metal and
the associated metal compound(s). Threshold
determinations must be made independently for each
because they are separately listed EPCRA section 313
chemicals.
Q If the threshold is exceeded for the listed parent
metal but not the associated metal category
compounds, then the releases of metal reported
on Form R for the parent metal need not include
the releases from the metal category compounds.
Q If both the parent metal and the associated metal
Q compounds exceed the alternate threshold, then
the facility has the option of filing one Form R
for both, using the metal category compound
name and reporting total releases based on parent
metal content.
Q If neither the parent metal nor the associated
metal compounds exceed the alternate threshold,
then the facility must use a separate listing on
Form A for each, since the reporting thresholds
must be applied to each listed parent metal and all
compounds in the associated compound category.
EPA believes it is appropriate to make this
distinction between filing the Form R and Form A
because the Form R accounts for amounts of
metal released or otherwise managed and Form A
verifies that the alternate threshold for each listed
chemical or chemical category has not been
exceeded.
Similarly, separate listings on Form A 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.
Toxics Release Inventory Reporting Forms and Instructions 71
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E. Instructions for Completing EPA Form A
Beginning with the 1998 reporting year, facilities may enter
as many chemicals as are eligible on a single Form A.
For all parts of Form A:
D 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.)
D All information on the Form A is required.
D 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.
D Do not submit an incomplete form. The certification
statement (Part I, Section 3) specifies that the report
is complete as submitted. See page 1 of these
instructions for the definition of a complete
submission.
Part I. Facility Identification
Information
Section 1. Reporting Year
This is the calendar year to which the reported information
applies, not the year in which you are submitting the report.
Information for the reporting year 2004 must be submitted on
or before July 1,2005.
Section 2. Trade Secret Information
2.1 Are you claiming the EPCRA Section 313 chemical
identified on page 2 a trade secret?
If facilities wish to report more than one eligible chemical on
the same Form A, then they are not able to make trade secrecy
claims. Any trade secrecy claims should be made on a
separate form, and then the process is the same as using the
Form R and as described in the following instructions.
The specific identity of the EPCRA section 313 chemical
being reported in Part II, Section 1, may be designated as a
trade secret. If you are making a trade secret claim, mark
"yes" and proceed to Section 2.2. Only check "yes" if you
manufacture, process, or otherwise use the EPCRA section
313 chemical whose identity is a trade secret. (See page 2 of
these instructions for specific information on trade secrecy
claims.) If you checked "no," proceed to Section 3; do not
answer Section 2.2.
D Do not submit trade secret reports electronically or on
diskette.
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 in its place,
and you have claimed the EPCRA section 313 chemical
identity trade secret in Part I, Section 2.1. Otherwise, check
"unsanitized."
Section 3. Certification
The Form A must be signed by a senior official with
management responsibility for the person (or persons)
completing the form. A senior management official must
certify the accuracy and completeness of the information
reported on the form by signing and dating the Form A. Each
report must contain an original signature. Unlike the
certification statement contained on Form R, the certification
statement provided on the Alternate Threshold Form A
pertains to the facility's eligibility of having met the
conditions as described in Section D or in the Federal
Register 59 FR 61488 (November 30, 1994). You should
print or type in the space provided the name and title of the
person who signs the statement. This certification statement
applies to all the information supplied on the form and should
be signed only after the form has been completed.
Section 4. Facility Identification
4.1 Facility Name, Location, and TRI Facility
Identification Number
Enter the full name that the facility presents to the public and
its customers in doing business (e.g., the name that appears on
invoices, signs, and other official business documents). Do
not use a nickname for the facility (e.g., Main Street Plant)
unless that is the legal name of the facility under which it
does business. Also enter the street address, mailing address,
city, county, state, and zip code in the space provided. Do not
use a post office box number as the street address. The street
address provided must be the location where the EPCRA
section 313 chemicals are manufactured, processed, or
otherwise used. If your mailing address and street address are
the same, you should enter NA in the space for the mailing
address.
If your facility is not in a county, put the name of your city,
district (for example District of Columbia), or parish (if you
are in Louisiana) in the county block of the Form R and Form
A as well as in the County field of TRI-ME. "NA" or "None"
are not acceptable entries.
If you have submitted a Form A or Form R for previous
reporting years, a TRI Facility Identification Number has
72 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing EPA Form A
been assigned to your facility. If you know your TRI Facility
Identification Number, complete Section 4. If you do not
know your TRI Facility Identification Number, contact the
CDX Help Desk toll free at 1-888-890-1995. If your facility
has moved, do not enter your TRI facility identification
number, you should enter "New Facility."
The TRI Facility Identification Number is established by the
first Form R submitted by a facility at a particular location.
This identification number is retained by the facility even if
the facility changes name, ownership, production processes,
SIC codes, etc. This identification number will stay with this
location. If a new facility moves to this location it should use
this TRI Facility Identification Number. Establishments of a
facility that report separately should use the TRI Facility
Identification Number of the facility.
You should enter "New Facility" in the space for the TRI
Facility Identification number if this is your first submission.
4.2 Federal Facility Designation
Executive Order 13148 directs federal facilities to comply
with Right-To-Know Laws and Pollution Prevention
Requirements. Please indicate in 4.2.C. if the reporting
facility is a federal facility or in 4.2.D if the submitter is a
contractor at a federal facility (GOCO). If the reporting
facility is not a federal facility, you should leave this space
blank. Form R allows a facility to report multiple
submissions for the same chemical if the facility is composed
of several distinct establishments. This data element provides
the option of reporting full or partial facility information on
Form R, however, this is not applicable for those facilities
taking advantage of the Alternate Threshold and Form A. An
explanation of this is provided in Section D.
4.3 Technical Contact
Enter the name and telephone number (including area code) of
a technical representative whom EPA or state officials may
contact for clarification of the information reported on Form
A. You should also enter an email address for this person.
EPA encourages facilities to provide an email address for its
Technical Contact on their TRI submissions because they will
be able to receive important program updates and email alerts
notifying them when their FDP has been updated and is
available on the FDP website. If the technical contact does
not have an email address you should enter NA. This contact
person does not have to be the same person who prepares the
report or signs the Form A and does not necessarily need to
be someone at the location of the reporting facility. However,
this person should be familiar with the details of the report so
that he or she can answer questions about the information
provided.
4.4 Intentionally Left Blank
4.5 Standard Industrial Classification (SIC) Code
Enter the appropriate four-digit Standard Industrial
Classification (SIC) Code that is the primary SIC Code for
your facility in Section 4.5(a). Enter any other applicable SIC
Codes for your facility in 4.5 (b)-(f). Table I lists the SIC
codes within 10 (except 1011, 1081, and 1094), 12 (except
1241), 20-39, 4911 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4931 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4939 (limited to
facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4953
(limited to facilities regulated under the RCRA Subtitle C, 42
U.S.C. section 6921 et seq.\ 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvents recovery services on a
contract or fee basis). If the report covers more than one
establishment, enter the primary four-digit SIC code for each
establishment starting with the primary SIC code for the entire
facility. You are required to enter SIC codes only for those
establishments within the facilities that fall within SIC codes
10 (except 1011, 1081, and 1094), 12 (except 1241), 20-39,
4911 (limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4939 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4953 (limited to
facilities regulated under the RCRA Subtitle C, 42 U.S.C.
section 6921 etseq.), 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvents recovery services on a
contract or fee basis). If you do not know your SIC code,
consult the 1987 SIC Manual (see section B.2 of these
instruction for ordering information).
The North American Industry Classification System (NAICS),
is a new economic classification system that will replace the
1987 SIC code system. EPA will address the SIC code
change, as it relates to EPCRA, in an upcoming Federal
Register notice. This upcoming change does NOT affect the
2003 EPCRA section 313 reporting.
4.6 Latitude and Longitude
Enter the latitude and longitude coordinates of your facility.
Sources of these data include EPA permits (e.g., NPDES
permits), county property records, facility blueprints, and site
plans. You can determine the latitude and longitude of your
facility using a siting tool found on the TRI Website at
. For
information on the siting tool and instructions on how to
determine these coordinates see Appendix E. Enter only
numerical data. Do not preface numbers with letters such as
N or W to denote the hemisphere.
Toxics Release Inventory Reporting Forms and Instructions 73
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Instructions for Completing EPA Form A Certification Statement
Latitude and longitude coordinates of your facility are very
important for pinpointing the location of reporting facilities
and are required elements on the Form R. EPA encourages
facilities to make the best possible measurements when
determining latitude and longitude. Please check to make
sure the latitude and longitude coordinates of your facility are
correct. For the continental United States readings should be
within 24°23'58" and 49°22'16" latitude, and 66°53'06" and
124°50'55" longitude. For Alaska readings should be within
51°10'30" and71°26'04" latitude, and 129°59'29" and
187°39'08" longitude. For Hawaii readings should be within
18°51'56" and28°30'59" latitude, and 154°45'21" and
178°26'25" longitude. As with any other data field, missing,
suspect, or incorrect data may generate an error notice in the
Facility Data Profile to be issued to the facility. (See
Appendix C)
4.7 Dun & Bradstreet Number(s)
Enter the nine-digit number assigned by Dun & Bradstreet
(D & B) for your facility or each establishment within your
facility. These numbers code the facility for financial
purposes. This number may be available from your facility's
treasurer or financial officer. You can also obtain the
numbers from your local D & B office (check the telephone
book White Pages). If a facility does not subscribe to the D &
B service, a number can be obtained, toll free at 800 234-3867
(8:00 AM to 6:00 PM, Local Time) or on the Web at
. If none of your establishments has been
assigned a D & B number, you should enter NA in box (a). If
only some of your establishments have been assigned Dun &
Bradstreet numbers, enter those numbers in Part I, section 4.7.
4.8 EPA Identification Number(s)
The EPA Identification Number is a 12-character number
assigned to facilities covered by hazardous waste regulations
under Resource and Conservation and Recovery Act.
Facilities not covered by RCRA are not likely to have an
assigned Identification Number. If your facility is not
required to have an Identification Number, you should enter
NA in box (a). If your facility has been assigned multiple
EPA Identification Numbers, you must enter those numbers in
the spaces provided in Section 4.8.
4.9 Facility NPDES Permit Number(s)
Enter the numbers of any permits your facility holds under the
National Pollutant Discharge Elimination System (NPDES)
even if the permit(s) do not pertain to the EPCRA section 313
chemical being reported. This nine-character permit number
is assigned to your facility by EPA or the state under the
authority of the Clean Water Act. If your facility does not
have a permit, you should enter NA in Section 4.9a.
4.10 Underground Injection Well Code (UIC)
Identification Number(s)
If your facility has a permit to inject a waste containing the
EPCRA section 313 chemical into Class 1 deep wells, enter
the 12-digit Underground Injection Well Code (UIC)
identification number assigned by EPA or by the state under
the authority of the Safe Drinking Water Act. If your facility
does not hold such a permit(s), you should enter NA in
Section 4. lOa. You are required to provide the UIC number
for wells that receive the EPCRA section 313 chemical being
reported in the current reporting year.
Section 5. Parent Company Information
You must provide information on your parent company. For
purposes of the Form A, a parent company is defined as the
highest level company, located in the United States, that
directly owns at least 50% of the voting stock of your
company. If your facility is owned by a foreign entity, you
should enter NA in this space. Corporate names should be
treated as parent company names for companies with
multiple facility sites. For example, the Bestchem
Corporation is not owned or controlled by any other
corporation but has sites throughout the country whose names
begin with Bestchem. In this case, Bestchem Corporation
should be listed as the parent company. Note that a facility
that is a 50:50 joint venture is its own parent company. When
a facility is owned by more than one company and there is no
parent company for the entire facility (meaning that none of
the facility owners directly owns at least 50 percent of the
voting stock of the facility at issue), the facility should
provide the name of the parent company of either the facility
operator or the owner with the largest ownership interest in
the facility. If neither the operator nor this owner has a parent
company, then the NA box should be checked.
5.1 Name of Parent Company
Enter the name of the corporation or other business entity
that is your ultimate US parent company. If your facility has
no parent company, you should check the NA box.
5.2 Parent Company's Dun & Bradstreet Number
Enter the Dun & Bradstreet (D & B) Number for your
ultimate US parent company, if applicable. The number may
be obtained from the treasurer or financial officer of the
company. If your parent company does not have a D & B
number, you should check the NA box.
74 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing 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-l.
EPCRA section 313 Chemical Category Codes
NO 10 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N150 Dioxin and dioxin-like compounds*
N171 Ethylenebisdithiocarbamic acid, salts and
esters (EBDCs)
N230 Certain glycol ethers
N420 Lead compounds*
N450 Manganese compounds
N458 Mercury compounds*
N495 Nickel compounds
N503 Nicotine and salts
N511 Nitrate compounds (water dissociable;
reportable only when in aqueous solution)
N575 Polybrominated biphenyls (PBBs)
N583 Fob/chlorinated alkanes (CIO to C13)
N590 Poly cyclic aromatic compounds (PACs)*
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N770 Vanadium compounds
N874 Warfarin and salts
N982 Zinc compounds
*Facilities cannot take the alternate threshold for
chemicals and chemical categories listed as PBT
chemicals.
If you are making a trade secret claim, you must report the
CAS number or should report the category code on your
unsanitized Form A and unsanitized substantiation form. Do
not include the CAS number or category code on your
sanitized Form A or sanitized substantiation form.
1.2 EPCRA Section 313 Chemical or
Chemical Category Name
Enter the name of the EPCRA section 313 chemical or
chemical category exactly as it appears in Table II. If the
EPCRA section 313 chemical name is followed by a
synonym in (parentheses), report the chemical by the name
that directly follows the CAS number(i.e., notthe synonym).
If the EPCRA section 313 chemical identity is actually a
product trade name (e.g., dicofol), the 9th Collective Index
name is listed below it in brackets. You may report either
name in this case.
Do not list the name of a chemical that does not appear in
Table II, such as individual members of an EPCRA section
313 chemical category. For example, if you use silver
chloride, do not report silver chloride with its CAS number.
Report this chemical as "silver compounds" with its category
code N740.
If you are making a trade secret claim, you must report the
specific EPCRA section 313 chemical identity on your
unsanitized Form A and unsanitized substantiation form. Do
not report the name of the EPCRA section 313 chemical on
your sanitized Form A or sanitized substantiation form.
Include a generic name in Part II, Section 1.3 of your
sanitized Form A.
1.3 Generic Chemical Name
Complete Section 1.3 only if you are claiming the specific
EPCRA section 313 chemical identity of the EPCRA section
313 chemical as a trade secret and have marked the trade
secret block in Part I, Section 2.1 on page 1 of Form A.
Enter a generic chemical name that is descriptive of the
chemical structure. You should limit the generic name to
seventy characters (e.g., numbers, letters, spaces,
punctuation) or less. Do not enter mixture names in Section
1.3; see Section 2 below.
Toxics Release Inventory Reporting Forms and Instructions 75
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Instructions for Completing Part II of EPA Form A
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
sec+tion. You do not need to supply trade secret
substantiation forms for this EPCRA section 313 chemical
because it is your supplier who is claiming the chemical
identity a trade secret.
2.1 Generic Chemical Name Provided by Supplier
Enter the generic chemical name in this section only if the
following three conditions apply:
1. You determine that the mixture contains an EPCRA
section 313 chemical but the only identity you have for
that chemical is a generic name;
2. You know either the specific concentration of that
EPCRA section 313 chemical component or a
maximum or average concentration level; and
3. You multiply the concentration level by the total
annual amount of the whole mixture processed or
otherwise used and determine that you meet the
process or otherwise use threshold for that single,
genetically identified mixture component.
76 Toxics Release Inventory Reporting Forms and Instructions
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Table I. SIC codes
10 Metal Mining (except 1011,1081
and 1094)
1021 Copper Ores
1031 Lead and Zinc Ores
1041 Gold Ores
1044 Silver Ores
1061 Ferroalloy Ores, Except Vanadium
1099 Miscellaneous Metal Ores, Not Elsewhere
Classified
12 Coal Mining (except 1241)
1221 Bituminous Coal and Lignite Surface Mining
1222 Bituminous Coal Underground Mining
1231 Anthracite Mining
20 Food and Kindred Products
2011 Meat packing plants
2013 Sausages and other prepared meat products
2015 Poultry slaughtering and processing
2021 Creamery butter
2022 Natural, processed, and imitation cheese
2023 Dry, condensed, and evaporated dairy
products
2024 Ice cream and frozen desserts
2026 Fluid milk
2032 Canned specialties
2033 Canned fruits, vegetables, preserves, jams, and
jellies
2034 Dried and dehydrated fruits, vegetables, and soup
mixes
2035 Pickled fruits and vegetables, vegetable sauces
and seasonings, and salad dressings
2037 Frozen fruits, fruit juices, and vegetables
2038 Frozen specialties, n.e.c.*
2041 Flour and other grain mill products
2043 Cereal breakfast foods
2044 Rice milling
2045 Prepared flour mixes and doughs
2046 Wet corn milling
2047 Dog and cat food
2048 Prepared feeds and feed ingredients for animals
and fowls, except dogs and cats
2051 Bread and other bakery products, except cookies and
crackers
2052 Cookies and crackers
2053 Frozen bakery products, except bread
2061 Cane sugar, except refining
2062 Cane sugar refining
2063 Beet sugar
2064 Candy and other confectionery products
2066 Chocolate and cocoa products
2067 Chewing gum
2068 Salted and roasted nuts and seeds
2074 Cottonseed oil mills
2075 Soybean oil mills
2076 Vegetable oil mills, n.e.c.*
2077 Animal and marine fats and oils
2079 Shortening, table oils, margarine, and other edible fats
and oils, n.e.c.*
2082 Malt beverages
2083 Malt
2084 Wines, brandy, and brandy spirits
2085 Distilled and blended liquors
2086 Bottled and canned soft drinks and carbonated waters
2087 Flavoring extracts and flavoring syrups, n.e.c.*
2091 Canned and cured fish and seafoods
2092 Prepared fresh or frozen fish and seafoods
2095 Roasted coffee
2096 Potato chips, corn chips, and similar snacks
2097 Manufactured ice
2098 Macaroni, spaghetti, vermicelli, and noodles
2099 Food preparations, n.e.c.*
21 Tobacco Products
2111 Cigarettes
2121 Cigars
2131 Chewing and smoking tobacco and snuff
2141 Tobacco stemming and redrying
22 Textile Mill Products
2211 Broadwoven fabric mills, cotton
2221 Broadwoven fabric mills, manmade fiber, and silk
2231 Broadwoven fabric mills, wool (including dyeing and
finishing)
2241 Narrow fabric and other small wares mills: cotton,
wool, silk, and manmade fiber
*"Not elsewhere classified" indicated by "n.e.c."
Toxics Release Inventory Reporting Forms and Instructions 1-1
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Table I
2251 Women's full length and knee length hosiery,
except socks
2252 Hosiery, n.e.c.*
2253 Knit outerwear mills
2254 Knit underwear and nightwear mills
2257 Weft knit fabric mills
2258 Lace and warp knit fabric mills
2259 Knitting mills, n.e.c.*
2261 Finishers of Broadwoven fabrics of cotton
2262 Finishers of Broadwoven fabrics of manmade
fiber and silk
2269 Finishers of textiles, n.e.c.*
2273 Carpets and rugs
2281 Yarn spinning mills
2282 Yarn texturizing, throwing, twisting, and winding
mills
2284 Thread mills
2295 Coated fabrics, not rubberized
2296 Tire cord and fabrics
2297 Nonwoven fabrics
2298 Cordage and twine
2299 Textile goods, n.e.c.*
23 Apparel and Other Finished
Products made from Fabrics and
Other Similar Materials
2311 Men's and boys' suits, coats, and overcoats
2321 Men's and boys' shirts, except work shirts
2322 Men's and boys' underwear and nightwear
2323 Men's and boys'neckwear
2325 Men's and boys' separate trousers and slacks
2326 Men's and boys' work clothing
2329 Men's and boys' clothing, n.e.c.*
2331 Women's, misses', and juniors' blouses and shirts
2335 Women's, misses', and juniors' dresses
2337 Women's, misses', and juniors' suits, skirts, and
coats
2339 Women's, misses', and juniors', outerwear, n.e.c.*
2341 Women's, misses', children's, and infants'
underwear and nightwear
2342 Brassieres, girdles, and allied garments
2353 Hats, caps, and millinery
2361 Girls', children's and infants' dresses, blouses,
and shirts
2369 Girls', children's and infants' outerwear, n.e.c.*
2371 Fur goods
2381 Dress and work gloves, except knit and all leather
2384 Robes and dressing gowns
2385 Waterproof outerwear
2386 Leather and sheep lined clothing
2387 Apparel belts
2389 Apparel and accessories, n.e.c.*
2391 Curtains and draperies
2392 House furnishings, except curtains and draperies
2393 Textile bags
2394 Canvas and related products
2395 Pleating, decorative and novelty stitching, and tucking
for the trade
2396 Automotive trimmings, apparel findings, and related
products
2397 Schiffli machine embroideries
2399 Fabricated textile products, n.e.c.*
24 Lumber and Wood Products, Except
Furniture
2411 Logging
2421 Sawmills and planing mills, general
2426 Hardwood dimension and flooring mills
2429 Special product sawmills, n.e.c.*
2431 Millwork
2434 Wood kitchen cabinets
2435 Hardwood veneer and plywood
2436 Softwood veneer and plywood
2439 Structural wood members, n.e.c.*
2441 Nailed and lock corner wood boxes and shook
2448 Wood pallets and skids
2449 Wood containers, n.e.c.*
2451 Mobile homes
2452 Prefabricated wood buildings and components
2491 Wood preserving
2493 Reconstituted wood products
2499 Wood products, n.e.c.*
25 Furniture and Fixtures
2511 Wood household furniture, except upholstered
2512 Wood household furniture, upholstered
2514 Metal household furniture
2515 Mattresses, foundations, and convertible beds
2517 Wood television, radio, phonograph, and sewing
machine cabinets
2519 Household furniture, n.e.c.*
2521 Wood office furniture
2522 Office furniture, except wood
2531 Public building and related furniture
2541 Wood office and store fixtures, partitions, shelving,
and lockers
2542 Office and store fixtures, partitions, shelving, and
lockers, except wood
1-2 Toxics Release Inventory Reporting Forms and Instructions
*"Not elsewhere classified" indicated by "n.e.c."
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Table I
2591 Drapery hardware and window blinds and shades
2599 Furniture and fixtures, n.e.c.*
26 Paper and Allied Products
2611 Pulp mills
2621 Paper mills
2631 Paperboard mills
2652 Setup paperboard boxes
2653 Corrugated and solid fiber boxes
2655 Fiber cans, tubes, drums, and similar products
2656 Sanitary food containers, except folding
2657 Folding paperboard boxes, including sanitary
2671 Packaging paper and plastics film, coated and
laminated
2672 Coated and laminated paper, n.e.c.*
2673 Plastics, foil, and coated paper bags
2674 Uncoated paper and multiwall bags
2675 Die-cut paper and paperboard and cardboard
2676 Sanitary paper products
2677 Envelopes
2678 Stationery tablets, and related products
2679 Converted paper and paperboard products, n.e.c.*
27 Printing, Publishing, and Allied
Industries
2711 Newspapers: publishing, or publishing and
printing
2721 Periodicals: publishing, or publishing and
printing
2731 Books: publishing, or publishing and printing
2732 Book printing
2741 Miscellaneous publishing
2752 Commercial printing, lithographic
2754 Commercial printing, gravure
2759 Commercial printing, n.e.c.*
2761 Manifold business forms
2771 Greeting cards
2782 Blank books, looseleaf binders and devices
2789 Bookbinding and related work
2791 Typesetting
2796 Plate making and related services
28 Chemicals and Allied Products
2812 Alkalie s and chlorine
2813 Industrial gases
2816 Inorganic pigments
2819 Industrial inorganic chemicals, n.e.c.*
2821 Plastics materials, synthetic resins, and
non-vulcanizable elastomers
2822 Synthetic rubber (vulcanizable elastomers)
2823 Cellulosic manmade fibers
2824 Manmade organic fibers, except cellulosic
2833 Medicinal chemicals and botanical products
2834 Pharmaceutical preparations
2835 In vitro and in vivo diagnostic substances
2836 Biological products, except diagnostic substances
2841 Soap and other detergents, except specialty cleaners
2842 Specialty cleaning, polishing, and sanitation
preparations
2843 Surface active agents, finishing agents, sulfonated oils,
and assistants
2844 Perfumes, cosmetics, and other toilet preparations
2851 Paints, varnishes, lacquers, enamels, and allied
products
2861 Gum and wood chemicals
2865 Cyclic organic crudes and intermediates, and organic
dyes and pigments
2869 Industrial organic chemicals, n.e.c.*
2873 Nitrogenous fertilizers
2874 Phosphatic fertilizers
2875 Fertilizers, mixing only
2879 Pesticides and agricultural chemicals, n.e.c.*
2891 Adhesives and sealants
2892 Explosives
2893 Printing ink
2895 Carbon black
2899 Chemicals and chemical preparations, n.e.c.*
29 Petroleum Refining and Related
Industries
2911 Petroleum refining
2951 Asphalt paving mixtures and blocks
2952 Asphalt felts and coatings
2992 Lubricating oils and greases
2999 Products of petroleum and coal, n.e.c. *
30 Rubber and Miscellaneous Plastics
Products
3011 Tires and inner tubes
3021 Rubber and plastics footwear
3052 Rubber and plastics hose and belting
3053 Gaskets, packing, and sealing devices
3061 Molded, extruded, and lathe cut mechanical rubber
products
3069 Fabricated rubber products, n.e.c.*
3081 Unsupported plastics film and sheet
3082 Unsupported plastics profile shapes
3083 Laminated plastics plate, sheet, and profile shapes
*"Not elsewhere classified" indicated by "n.e.c."
Toxics Release Inventory Reporting Forms and Instructions 1-3
-------
Table I
3084 Plastics pipe
3085 Plastics bottles
3086 Plastics foam products
3087 Custom compounding of purchased plastics resins
3088 Plastics plumbing fixtures
3089 Plastics products, n.e.c.*
31 Leather and Leather Products
3111 Leather tanning and finishing
3131 Boot and shoe cut stock and findings
3142 House slippers
3143 Men's footwear, except athletic
3144 Women's footwear, except athletic
3149 Footwear, except rubber, n.e.c.*
3151 Leather gloves and mittens
3161 Luggage
3171 Women's handbags and purses
3172 Personal leather goods, except women'shandbags
and purses
3199 Leather goods, n.e.c.*
32 Stone, Clay, Glass and Concrete
Products
3211 Flat glass
3221 Glass containers
3229 Pressed and blown glass and glassware, n.e.c.*
3231 Glass products, made of purchased glass
3241 Cement, hydraulic
3251 Brick and structural clay tile
3253 Ceramic wall and floor tile
3255 Clay refractories
3259 Structural clay products, n.e.c.*
3261 Vitreous china plumbing fixtures and china and
earthenware fittings and bathroom accessories
3262 Vitreous china table and kitchen articles
3263 Fine earthenware (whiteware) table and kitchen
articles
3264 Porcelain electrical supplies
3269 Pottery products, n.e.c.*
3271 Concrete block and brick
3272 Concrete products, except block and brick
3273 Ready mixed concrete
3274 Lime
3275 Gypsum products
3281 Cut stone and stone products
3291 Abrasive products
3292 Asbestos products
3295 Minerals and earths, ground or otherwise treated
3296 Mineral wool
3297 Nonclay refractories
3299 Nonmetallic mineral products, n.e.c.*
33 Primary Metal Industries
3312 Steel works, blast furnaces (including coke ovens), and
rolling mills
3313 Electrometallurgical products, except steel
3315 Steel wiredrawing and steel nails and spikes
3316 Cold-rolled steel sheet, strip, and bars
3317 Steel pipe and tubes
3321 Gray and ductile iron foundries
3322 Malleable iron foundries
3324 Steel investment foundries
3325 Steel foundries, n.e.c.*
3331 Primary smelting and refining of copper
3334 Primary production of aluminum
3339 Primary smelting and refining of nonferrous metals,
except copper and aluminum
3341 Secondary smelting and refining of nonferrous metals
3351 Rolling, drawing, and extruding of copper
3353 Aluminum sheet, plate, and foil
3354 Aluminum extruded products
3355 Aluminum rolling and drawing, n.e.c.*
3356 Rolling, drawing, and extruding of nonferrous metals,
except copper and aluminum
3357 Drawing and insulating of nonferrous wire
3363 Aluminum die-castings
3364 Nonferrous die-castings, except aluminum
3365 Aluminum foundries
3366 Copper foundries
3369 Nonferrous foundries, except aluminum and copper
3398 Metal heat treating
3399 Primary metal products, n.e.c.*
34 Fabricated Metal Products, except
Machinery and Transportation
Equipment
3411 Metal cans
3412 Metal shipping barrels, drums, kegs, and pails
3421 Cutlery
3423 Hand and edge tools, except machine tools and
handsaws
3425 Handsaws and saw blades
3429 Hardware, n.e.c.*
3431 Enameled iron and metal sanitary ware
3432 Plumbing fixture fittings and trim
3433 Heating equipment, except electric and warm air
furnaces
3441 Fabricated structural metal
1-4 Toxics Release Inventory Reporting Forms and Instructions
*"Not elsewhere classified" indicated by "n.e.c."
-------
Table I
3442 Metal doors, sash, frames, molding, and trim
3443 Fabricated plate work (boiler shops)
3444 Sheet metal work
3446 Architectural and ornamental metal work
3448 Prefabricated metal buildings and components
3449 Miscellaneous structural metal work
3451 Screw machine products
3452 Bolts, nuts, screws, rivets, and washers
3462 Iron and steel forgings
3463 Nonferrous forgings
3465 Automotive stampings
3466 Crowns and closures
3469 Metal stampings, n.e.c.*
3471 Electroplating, plating, polishing, anodizing, and
coloring
3479 Coating, engraving and allied services, n.e.c.*
3482 Small arms ammunition
3483 Ammunition, except for small arms
3484 Small arms
3489 Ordnance and accessories, n.e.c.*
3491 Industrial valves
3492 Fluid power valves and hose fittings
3493 Steel springs, except wire
3494 Valves and pipe fittings, n.e.c.*
3495 Wire springs
3496 Miscellaneous fabricated wire products
3497 Metal foil and leaf
3498 Fabricated pipe and pipe fittings
3499 Fabricated metal products, n.e.c.*
35 Industrial and Commercial
Machinery and Computer
Equipment
3511 Steam, gas and hydraulic turbines, and turbine
generator set units
3519 Internal combustion engines, n.e.c.*
3523 Farm machinery and equipment
3524 Lawn and garden tractors and home lawn and
garden equipment
3531 Construction machinery and equipment
3532 Mining machinery and equipment, except oil and
gas field machinery and equipment
3533 Oil and gas field machinery and equipment
3534 Elevators and moving stairways
3535 Conveyors and conveying equipment
3536 Overhead traveling cranes, hoists, and monorail
systems
3537 Industrial trucks, tractors, trailers, and stackers
3541 Machine tools, metal cutting types
3542 Machine tools, metal forming types
3543 Industrial patterns
3544 Special dies and tools, die sets, jigs and fixtures, and
industrial molds
3545 Cutting tools, machine tool accessories, and
machinists' measuring devices
3546 Power driven handtools
3547 Rolling mill machinery and equipment
3548 Electric and gas welding and soldering equipment
3549 Metalworking machinery, n.e.c.*
3552 Textile machinery
3553 Woodworking machinery
3554 Paper industries machinery
3555 Printing trades machinery and equipment
3556 Food products machinery
3559 Special industry machinery, n.e.c.*
3561 Pumps and pumping equipment
3 562 Ball and roller bearings
3563 Air and gas compressors
3564 Industrial and commercial fans and blowers and air
purification equipment
3565 Packaging equipment
3566 Speed changers, industrial high speed drives, and gears
3567 Industrial process furnaces and ovens
3568 Mechanical power transmission equipment, n.e.c.*
3569 General industrial machinery and equipment, n.e.c.*
3571 Electronic computers
3572 Computer storage devices
3575 Computer terminals
3577 Computer peripheral equipment, n.e.c.*
3578 Calculating and accounting machines, except
electronic computers
3579 Office machines, n.e.c.*
3581 Automatic vending machines
3582 Commercial laundry, dry-cleaning, and pressing
machines
3585 Air conditioning and warm air heating equipment and
commercial and industrial refrigeration equipment
3 5 86 Measuring and dispensing pumps
3589 Service industry machinery, n.e.c.*
3592 Carburetors, pistons, piston rings, and valves
3593 Fluid power cylinders and actuators
3 5 94 Fluid power pumps and motors
3596 Scales and balances, except laboratory
3599 Industrial and commercial machinery and equipment,
n.e.c*
36 Electronic and Other Electrical
Equipment and Components, Except
Computer Equipment
3612 Power, distribution, and specialty transformers
*"Not elsewhere classified" indicated by "n.e.c."
Toxics Release Inventory Reporting Forms and Instructions 1-5
-------
Table I
3613 Switchgear and switchboard apparatus
3621 Motors and generators
3624 Carbon and graphite products
3625 Relays and industrial controls
3629 Electrical industrial appliances, n.e.c.*
3631 Household cooking equipment
3632 Household refrigerators and home and farm
freezers
3633 Household laundry equipment
3634 Electrical housewares and fans
3635 Household vacuum cleaners
3639 Household appliances, n.e.c.*
3641 Electric lampbulbs and tubes
3643 Current carrying wiring devices
3644 Noncurrent carrying wiring devices
3645 Residential electric lighting fixtures
3646 Commercial, industrial, and institutional electric
lighting fixtures
3647 Vehicular lighting equipment
3648 Lighting equipment, n.e.c.*
3651 Household audio and video equipment
3652 Phonograph records and pre-recorded audio tapes
and disks
3661 Telephone and telegraph apparatus
3663 Radio and television broadcasting and
communications equipment
3669 Communications equipment, n.e.c.*
3671 Electron tubes
3672 Printed circuit boards
3674 Semiconductors and related devices
3675 Electronic capacitors
3676 Electronic resistors
3677 Electronic coils, transformers, and other inductors
3678 Electronic connectors
3679 Electronic components, n.e.c.*
3691 Storage batteries
3692 Primary batteries, dry and wet
3694 Electric equipment for internal combustion
engines
3695 Magnetic and optical recording media
3699 Electrical machinery, equipment, and supplies,
n.e.c.*
37 Transportation Equipment
3711 Motor vehicles and passenger car bodies
3713 Truck and bus bodies
3714 Motor vehicle parts and accessories
3715 Truck trailers
3716 Motor homes
3721 Aircraft
3724 Aircraft engines and engine parts
3728 Aircraft parts and auxiliary equipment, n.e.c.*
3731 Ship building and repairing
3732 Boat building and repairing
3743 Railroad equipment
3751 Motorcycles, bicycles and parts
3761 Guided missiles and space vehicles
3764 Guided missile and space vehicle propulsionunits and
propulsion unit parts
3769 Guided missile and space vehicle parts and auxiliary
equipment, n.e.c.*
3792 Travel trailers and campers
3795 Tanks and tank components
3799 Transportation equipment, n.e.c.*
38 Measuring, Analyzing, and
Controlling Instruments;
Photographic, Medical and
Optical Goods; Watches and Clocks
3812 Search, detection, navigation, guidance, aeronautical,
and nautical systems and instruments
3821 Laboratory apparatus and furniture
3822 Automatic controls for regulating residential and
commercial environments and appliances
3823 Industrial instruments for measurement, display, and
control of process variables; and related products
3824 Totalizing fluid meters and counting devices
3 825 Instruments for measuring and testing of electricity and
electrical signals
3826 Laboratory analytical instruments
3827 Optical instruments and lenses
3829 Measuring and controlling devices, n.e.c.*
3841 Surgical and medical instruments and apparatus
3842 Orthopedic, prosthetic, and surgical appliances and
supplies
3843 Dental equipment and supplies
3844 X-ray apparatus and tubes and related irradiation
apparatus
3845 Electromedical and electrotherapeutic apparatus
3851 Ophthalmic goods
3861 Photographic equipment and supplies
3873 Watches, clocks, clockwork operated devices, and
parts
39 Miscellaneous Manufacturing
Industries
3911 Jewelry, precious metal
3914 Silverware, plated ware, and stainless steel ware
3915 Jewelers' findings and materials, and lapidary work
1-6 Toxics Release Inventory Reporting Forms and Instructions
*"Not elsewhere classified" indicated by "n.e.c."
-------
Table I
3931 Musical instruments
3 942 Dolls and stuffed toys
3944 Games, toys and children's vehicles; except dolls
and bicycles
3949 Sporting and athletic goods, n.e.c.*
3951 Pens, mechanical pencils, and parts
3952 Lead pencils, crayons, and artists' materials
3953 Marking device s
3955 Carbon paper and inked ribbons
3961 Costume jewelry and costume novelties, except
precious metal
3965 Fasteners, buttons, needles, and pins
3991 Brooms and brushes
3993 Signs and advertising specialties
3995 Burial caskets
3996 Linoleum, asphalted-felt-base, and other hard
surface floor coverings, n.e.c.*
3999 Manufacturing industries, n.e.c.*
49 Electric, Gas, and Sanitary
Services (limited to 4911,4931,4939 and
4953)
4911 Electric Services (limited to facilities that combust
coal and/or oil for the purpose of generating
electricity for distribution in commerce)
4931 Electric and Other Services Combined (limited to
facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce)
4939 Combination utilities, Not Elsewhere Classified
(limited to facilities that combust coal and/or oil
for the purpose of generating electricity for
distribution in commerce)
4953 Refuse Systems (limited to facilities regulated
under the RCRA Subtitle C, 42 U.S.C. section
692letseq.)
51 Wholesale Trade-Nondurable
Goods (limited to 5169 and 5171)
5169 Chemical and Allied Products, Not Elsewhere
Classified
5171 Petroleum Terminals and Bulk Stations
73 Business Services (limited to 7389)
7389 Business Services, Not Elsewhere Classified
(limited to facilities primarily engaged in solvents
recovery services on a contract or fee basis)
*"Not elsewhere classified" indicated by "n.e.c." Toxics Release Inventory Reporting Forms and Instructions 1-7
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This Page Intentionally Left Blank
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Table II. EPCRA Section 313 Chemical List For Reporting Year 2004
(including Toxic Chemical Categories)
Individually listed EPCRA Section 313 chemicals with CAS numbers are arranged alphabetically starting on page II-3. Following
the alphabetical list, the EPCRA Section 313 chemicals are arranged in CAS number order. Covered chemical categories follow.
Certain EPCRA Section 313 chemicals listed in Table II have parenthetic "qualifiers." These qualifiers indicate that these EPCRA
Section 313 chemicals are subject to the section 313 reporting requirements if manufactured, processed, or otherwise used in a specific
form or when a certain activity is performed. The following chemicals are reportable only if they are manufactured, processed, or
otherwise used in the specific form(s) listed below:
Chemical
Aluminum (fume or dust)
Aluminum oxide (fibrous forms)
Ammonia (includes anhydrous ammonia and aqueous ammonia
from water dissociable ammonium salts and other sources; 10
percent of total aqueous ammonia is reportable under this listing)
Asbestos (friable)
CAS
Number
7429-90-5
1344-28-1
7664-41-7
1332-21-4
Hydrochloric acid (acid aerosols including mists, vapors, gas, fog, 7647-01-0
and other airborne forms of any particle size)
Phosphorus (yellow or white) 7723-14-0
Sulfuric acid (acid aerosols including mists, vapors, gas, fog, and 7664-93-9
other airborne forms of any particle size)
Vanadium (except when contained in an alloy) 7440-62-2
Zinc (fume or dust) 7440-66-6
Qualifier
Only if it is a fume or dust form.
Only if it is a fibrous form.
Only 10% of aqueous forms. 100%
of anhydrous forms.
Only if it is a friable form.
Only if it is an aerosol form as
defined.
Only if it is a yellow or white form.
Only if it is an aerosol form as
defined.
Except if it is contained in an alloy.
Only if it is in a fume or dust form.
The qualifier for the following three chemicals is based on the chemical activity rather than the form of the chemical. These chemicals
are subject to EPCRA section 313 reporting requirements only when the indicated activity is performed.
Chemical/ Chemical Category CAS Number
Dioxin and dioxin-like compounds NA
(manufacturing; and the processing or otherwise use
of dioxin and dioxin-like compounds if the dioxin
and dioxin-like compounds are present as
contaminants in a chemical and if they were created
during the manufacture of that chemical.)
Isopropyl alcohol (only persons who manufacture 67-63-0
by the strong acid process are subject, no supplier
notification)
Saccharin (only persons who manufacture are 81-07-2
subject, no supplier notification)
Qualifier
Only if they are manufactured at the
facility; or are processed or otherwise
used when present as contaminants in a
chemical but only if they were created
during the manufacture of that chemical.
Only if it is being manufactured by the
strong acid process. Facilities that process
or otherwise use isopropyl alcohol are not
covered.
Only if it is being manufactured.
There are no supplier notification requirements for isopropyl alcohol and saccharin since the processors and users of these chemicals
are not required to report. Manufacturers of these chemicals do not need to notify their customers that these are reportable EPCRA
section 313 chemicals.
Toxics Release Inventory Reporting Form and Instructions II-1
-------
Table II
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 2004 calendar
year reporting. Some of the EPCRA Section 313 chemicals listed
have parenthetic qualifiers listed next to them. An EPCRA
Section 313 chemical that is listed without a qualifier is subject
to reporting in all forms in which it is manufactured, processed,
and otherwise used.
Fume or dust. Two of the metals on the list (aluminum and
zinc) contain the qualifier "fume or dust." Fume or dust refers to
dry forms of these metals but does not refer to "wet" forms such
as solutions or slurries. As explained in Section B.3.a of these
instructions, the term manufacture includes the generation of an
EPCRA Section 313 chemical as a byproduct or impurity. In
such cases, a facility should determine if, for example, it
generated more than 25,000 pounds of aluminum fume or dust in
the reporting year as a result of its activities. If so, the facility
must report that it manufactures "aluminum (fume or dust)."
Similarly, there may be certain technologies in which one of
these metals is processed in the form of a fume or dust to make
other EPCRA Section 313 chemicals or other products for
distribution in commerce. In reporting releases, the facility
would only report releases of the fume or dust.
EPA considers dusts to consist of solid particles generated by any
mechanical processing of materials including crushing, grinding,
rapid impact, handling, detonation, and decrepitation of organic
and inorganic materials such as rock, ore, and metal. Dusts do
not tend to flocculate, except under electrostatic forces.
EPA considers a fume to be an airborne dispersion consisting of
small solid particles created by condensation from a gaseous
state, in distinction to a gas or vapor. Fumes arise from the
heating of solids such as lead. The condensation is often
accompanied by a chemical reaction, such as oxidation. Fumes
flocculate and sometimes coalesce.
Manufacturing qualifiers. Two of the entries in the EPCRA
Section 313 chemical list contain a qualifier relating to
manufacture. For isopropyl alcohol, the qualifier is "only persons
who manufacture by the strong acid process are subject, no
supplier notification." For saccharin, the qualifier is "only
persons who manufacture are subject, no supplier notification."
For isopropyl alcohol, the qualifier means that only facilities
manufacturing isopropyl alcohol by the strong acid process are
required to report. In the case of saccharin, only manufacturers
of the EPCRA Section 313 chemical are subject to the reporting
requirements. A facility that only processes or otherwise uses
either of these EPCRA Section 313 chemicals would not be
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
II-2 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
yellow or white chemical form triggers reporting. Conversely,
manufacturing, processing, or otherwise use of "black" or "red"
phosphorus does not trigger reporting. Supplier notification also
applies only to distribution of yellow or white phosphorus.
Asbestos (friable). The listing for asbestos is qualified by the
term "friable," referring to the physical characteristic of being
able to be crumbled, pulverized, or reducible to a powder with
hand pressure. Only manufacturing, processing, or otherwise use
of asbestos in the friable form triggers reporting. Supplier
notification applies only to distribution of mixtures or other trade
name products containing friable asbestos.
Aluminum Oxide (fibrous forms). The listing for aluminum
oxide is qualified by the term "fibrous forms." Fibrous refers to
a man-made form of aluminum oxide that is processed to produce
strands or filaments which can be cut to various lengths
depending on the application. Only manufacturing, processing,
or otherwise use of aluminum oxide in the fibrous form triggers
reporting. Supplier notification applies only to distribution of
mixtures or other trade name products containing fibrous forms
of aluminum oxide.
a. Individually-Listed Toxic Chemicals
Arranged Alphabetically
Notes for Sections A and B of following list of TRI
chemicals:
"Color Index" indicated by "C.I."
* There are no de minimis levels for PBT chemicals,
except for supplier notification purposes (see
Appendix D).
CAS Number Chemical Name
De Minimis
Limit
71751-41-2 Abamectin[AvermectinBl] 1.0
30560-19-1 Acephate 1.0
(Acetylphosphoramidothioic acid O,S-
dimethyl ester)
75-07-0 Acetaldehyde 0.1
60-35-5 Acetamide 0.1
75-05-8 Acetonitrile 1.0
98-86-2 Acetophenone 1.0
53-96-3 2-Acetylaminofluorene 0.1
62476-59-9 Acifluorfen, sodium salt 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-2-
nitrobenzoic acid, sodium salt]
107-02-8 Acrolein 1.0
79-06-1 Acrylamide 0.1
79-10-7 Acrylic acid 1.0
107-13-1 Acrylonitrile 0.1
15972-60-8 Alachlor 1.0
116-06-3 Aldicarb 1.0
309-00-2 Aldrin *
[l,4:5,8-Dimethanonaphthalene,
l,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a-
hexahydro-(l.alpha.,4.alpha.,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
28057-48-9 d-trans-Allethrin 1.0
[d-trans-Chrysanthemic acid of d-allethrone]
107-18-6 Allyl alcohol 1.0
107-11-9 Allylamine 1.0
107-05-1 Allyl chloride 1.0
7429-90-5 Aluminum (fume or dust) 1.0
20859-73-8 Aluminum phosphide 1.0
1344-28-1 Aluminum oxide (fibrous forms) 1.0
834-12-8 Ametryn 1.0
(N-Ethyl-N'-(l-methylethyl)-6-(methylthio)-
l,3,5,-triazine-2,4-diamine)
117-79-3 2-Aminoanthraquinone 0.1
60-09-3 4-Aminoazobenzene 0.1
92-67-1 4-Aminobiphenyl 0.1
82-28-0 l-Amino-2-methylanthraquinone 0.1
Toxics Release Inventory Reporting Form and Instructions II-3
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
33089-61-1 Amitraz 1.0
61-82-5 Amitrole 0.1
7664-41-7 Ammonia 1.0
(includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium
salts and other sources; 10 percent of total
aqueous ammonia is reportable under this
listing)
101-05-3 Anilazine 1.0
[4,6-Dichloro-N-(2-chlorophenyl)-l,3,5-
triazin-2-amine]
62-53-3 Aniline 1.0
90-04-0 o-Anisidine 0.1
104-94-9 p-Anisidine 1.0
134-29-2 o-Anisidine hydrochloride 0.1
120-12-7 Anthracene 1.0
7440-36-0 Antimony 1.0
7440-38-2 Arsenic 0.1
1332-21-4 Asbestos (friable) 0.1
1912-24-9 Atrazine 1.0
(6-Chloro-N-ethyl-N' -(1 -methylethyl)-1,3,5-
triazine-2,4-diamine)
7440-39-3 Barium 1.0
22781-23-3 Bendiocarb 1.0
[2,2-Dimethyl-l,3-benzodioxol-4-ol
methylcarbamate]
1861-40-1 Benfluralin 1.0
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)benzenamine)
17804-35-2 Benomyl 1.0
98-87-3 Benzal chloride 1.0
55-21-0 Benzamide 1.0
71-43-2 Benzene 0.1
92-87-5 Benzidine 0.1
98-07-7 Benzoic trichloride 0.1
(Benzotrichloride)
191-24-2 Benzo(g,h,i)perylene *
98-88-4 Benzoyl chloride 1.0
94-36-0 Benzoyl peroxide 1.0
100-44-7 Benzyl chloride 1.0
7440-41-7 Beryllium 0.1
82657-04-3 Bifenthrin 1.0
92-52-4 Biphenyl 1.0
111-91-1 Bis(2-chloroethoxy) methane 1.0
111-44-4 Bis(2-chloroethyl) ether 1.0
542-88-1 Bis(chloromethyl) ether 0.1
108-60-1 Bis(2-chloro-l-methylethyl)ether 1.0
56-35-9 Bis(tributyltin) oxide 1.0
10294-34-5 Boron trichloride 1.0
7637-07-2 Boron trifluoride 1.0
CAS Number Chemical Name
De Minimis
Limit
314-40-9
53404-19-6
7726-95-6
35691-65-7
353-59-3
75-25-2
74-83-9
75-63-8
1689-84-5
1689-99-2
357-57-3
106-99-0
141-32-2
71-36-3
78-92-2
75-65-0
106-88-7
123-72-8
7440-43-9
156-62-7
133-06-2
63-25-2
1563-66-2
75-15-0
56-23-5
463-58-1
5234-68-4
120-80-9
2439-01-2
133-90-4
57-74-9
Bromacil 1.0
(5-Bromo-6-methyl-3-(l-methylpropyl)-
2,4( lH,3H)-pyrimidinedione)
Bromacil, lithium salt 1.0
[2,4(lH,3H)-Pyrimidinedione,5-bromo-6-
methyl-3-(l-methyrpropyl), lithium salt]
Bromine 1.0
l-Bromo-l-(bromomethyl)- 1.0
1,3 -propanedicarbonitrile
Bromochlorodifluoromethane 1.0
(Halonl211)
Bromoform (Tribromomethane) 1.0
Bromomethane 1.0
(Methyl bromide)
Bromotrifluoromethane 1.0
(Halon 1301)
Bromoxynil 1.0
(3,5-Dibromo-4-hydroxybenzonitrile)
Bromoxynil octanoate 1.0
(Octanoic acid, 2,6-dibromo-4-
cyanophenylester)
Brucine 1.0
1,3-Butadiene 0.1
Butyl aery late 1.0
n-Butyl alcohol 1.0
sec-Butyl alcohol 1.0
tert-Butyl alcohol 1.0
1,2-Butylene oxide 0.1
Butyraldehyde 1.0
Cadmium 0.1
Calcium cy anamide 1.0
Captan 1.0
[lH-Isoindole-l,3(2H)-dione, 3a,4,7,7a-
tetrahydro-2-[(trichloromethyl)thio]-]
Carbaryl [1-Naphthalenol, 1.0
methylcarbamate]
Carbofuran 1.0
Carbon disulfide 1.0
Carbon tetrachloride 0.1
Carbonyl sulfide 1.0
Carboxin 1.0
(5,6-Dihydro-2-methyl-N-
phenyl-1,4-oxathiin-3 -carboxamide)
Catechol 0.1
Chinomethionat 1.0
[6-Methyl-l,3-dithiolo[4,5-b]quinoxalin-2-
one]
Chloramben
[Benzoic acid, 3-amino-2,5-dichloro-]
Chlordane
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-hexahydro-]
1.0
II-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
CAS Number Chemical Name
De Minimis
Limit
115-28-6 Chlorendic acid
90982-32-4 Chlorimuron ethyl
[Ethyl-2-[[[[(4-chloro-6-methoxyprimidin-2-
y l)amino] carbony 1] amino] sulfonyl]
benzoate]
7782-50-5 Chlorine
10049-04-4 Chlorine dioxide
79-11-8 Chloroacetic acid
532-27-4 2-Chloroacetophenone
4080-31-3 l-(3-Chloroallyl)-3,5,7-triaza-
1-azoniaadamantane chloride
106-47-8 p-Chloroaniline
108-90-7 Chlorobenzene
510-15-6 Chlorobenzilate
[Benzeneacetic acid, 4-chloro-.alpha.- (4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
75-68-3 l-Chloro-l,l-difluoroethane
(HCFC-142b)
75-45-6 Chlorodifluoromethane
(HCFC-22)
75-00-3 Chloroethane (Ethyl chloride)
67-66-3 Chloroform
74-87-3 Chloromethane (Methyl chloride)
107-30-2 Chloromethyl methyl ether
563 -47-3 3 -Chloro-2-methyl- 1-propene
104-12-1 p-Chlorophenyl isocyanate
76-06-2 Chloropicrin
126-99-8 Chloroprene
542-76-7 3-Chloropropionitrile
63938-10-3 Chlorotetrafluoroethane
354-25-6 1-Chloro-l, 1,2,2-
tetrafluoroethane (HCFC-124a)
2837-89-0 2-Chloro-l, 1,1,2-
tetrafluoroethane (HCFC-124)
1897-45-6 Chlorothalonil
[1,3-Benzenedicarbonitrile, 2,4,5,6-
tetrachloro-]
95-69-2 p-Chloro-o-toluidine
75-88-7 2-Chloro-1,1,1-
trifluoroethane (HCFC-133a)
75-72-9 Chlorotrifluoromethane (CFC-13)
460-35-5 3-Chloro-l,l,l-
trifluoropropane (HCFC-253fb)
5598-13-0 Chlorpyrifos methyl
[O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate]
64902-72-3 Chlorsulfuron
[2-Chloro-N-[[(4-methoxy-6-methyl-l,3,5-
triazin-2-yl)amino]carbonyl]
benzenesulfonamide]
1.0
1.0
Chromium 1.0
C.I. Acid Green 3 1.0
C.I. Acid Red 114 0.1
C.I. Basic Green 4 1.0
C.I. Basic Red 1 1.0
C.I. Direct Black 38 0.1
C.I. Direct Blue 6 0.1
C.I. Direct Blue 218 1.0
C.I. Direct Brown 95 0.1
C.I. Disperse Yellow 3 1.0
C.I. Food Red 5 0.1
C.I. Food Red 15 1.0
C.I. Solvent Orange 7 1.0
C.I. Solvent Yellow 3 0.1
C.I. Solvent Yellow 14 1.0
C.I. Solvent Yellow 34 0.1
(Auramine)
C.I. Vat Yellow 4 1.0
Cobalt 0.1
Copper 1.0
Creosote 0.1
p-Cresidine 0.1
m-Cresol .0
o-Cresol .0
p-Cresol .0
Cresol (mixed isomers) .0
Crotonaldehyde .0
Cumene .0
Cumene hydroperoxide .0
Cupferron 0.1
[Benzeneamine, N-hydroxy-
N-nitroso, ammonium salt]
Cyanazine
Cycloate
Cyclohexane
Cyclohexanol
Cyfluthrin
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid,
cyano(4-fluoro-3 -phenoxyphenyl) methyl
ester]
Cyhalothrin 1.0
[3-(2-CMoro-3,3,3-trifluoro-1-propenyl)-2,2-
dimethylcyclopropane-carboxylic acid
cyano(3 -phenoxyphenyl)methyl ester]
2,4-D 0.1
[Acetic acid, (2,4-dichlorophenoxy)-]
Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione)
0.1
1.0
1-2-
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
*]
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
7440-47-3
4680-78-8
6459-94-5
569-64-2
989-38-8
1937-37-7
2602-46-2
28407-37-6
16071-86-6
2832-40-8
3761-53-3
81-88-9
3118-97-6
97-56-3
842-07-9
492-80-8
128-66-5
7440-48-4
7440-50-8
8001-58-9
120-71-8
108-39-4
95-48-7
106-44-5
1319-77-3
4170-30-3
98-82-8
80-15-9
135-20-6
21725-46-2
1134-23-2
110-82-7
108-93-0
68359-37-5
68085-85-8
94-75-7
533-74-4
Toxics Release Inventory Reporting Form and Instructions II-5
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
CAS Number Chemical Name
De Minimis
Limit
53404-60-7 Dazomet, sodium salt 1.0 1717-00-6
[Tetrahydro-3,5-dimethyl-2H-1,3,5-
thiadiazine-2-thione, ion(l-), sodium]
94-82-6 2,4-DB
1929-73-3 2,4-D butoxyethyl ester
94-80-4 2,4-D butyl ester
2971-38-2 2,4-D chlorocrotyl ester
1163-19-5 Decabromodiphenyl oxide
13684-56-5 Desmedipham
1928-43-4 2,4-D 2-ethylhexyl ester
53404-37-8 2,4-D 2-ethyl-4-
methyrpentyl ester
2303-16-4 Diallate
[Carbamothioic acid, bis(l-methylethyl)-S-
(2,3-dichloro-2-propenyl) ester]
615-05-4 2,4-Diaminoanisole
39156-41-7 2,4-Diaminoanisole sulfate
101-80-4 4,4'-Diaminodiphenyl ether
95-80-7 2,4-Diaminotoluene
25376-45-8 Diaminotoluene (mixed isomers)
333-41-5 Diazinon
334-88-3 Diazomethane
132-64-9 Dibenzofuran
96-12-8 l,2-Dibromo-3-
chloropropane (DBCP)
106-93-4 1,2-Dibromoethane
(Ethylene dibromide)
124-73-2 Dibromotetrafluoroethane
(Halon 2402)
84-74-2 Dibutyl phthalate
1918-00-9 Dicamba
(3,6-Dichloro-2-methoxybenzoic acid)
99-30-9 Dichloran
[2,6-Dichloro-4-nitroaniline]
95-50-1 1,2-Dichlorobenzene
541-73-1 1,3-Dichlorobenzene
106-46-7 1,4-Dichlorobenzene
25321-22-6 Dichlorobenzene (mixed isomers)
91-94-1 3,3'-Dichlorobenzidine
612-83-9 3,3'-Dichlorobenzidine
dihydrochloride
64969-34-2 3,3'-Dichlorobenzidine sulfate
75-27-4 Dichlorobromomethane
764-41-0 l,4-Dichloro-2-butene
110-57-6 trans-l,4-Dichloro-2-butene
1649-08-7 l,2-Dichloro-l,l-
difluoroethane (HCFC-132b)
75-71-8 Dichlorodifluoromethane (CFC-12) 1.0
107-06-2 1,2-Dichloroethane (Ethylene 0.1
dichloride)
540-59-0 1,2-Dichloroethylene 1.0
' 77-73-6
1.0
0.1
0.1
0.1
1.0
1.0
0.1
0.1
1.0
-1
5-
0.1
0.1
0.1
0.1
0.1
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
0.1
0.1
0.1
0.1
1.0
1.0
1.0
75-43-4
75-09-2
127564-92-5
13474-88-9
111512-56-2
422-44-6
431-86-7
507-55-1
136013-79-1
128903-21-9
422-48-0
422-56-0
97-23-4
120-83-2
78-87-5
10061-02-6
78-88-6
542-75-6
76-14-2
34077-87-7
90454-18-5
812-04-4
354-23-4
306-83-2
62-73-7
51338-27-3
115-32-2
1,1-Dichloro-l-fluoroethane 1.0
(HCFC-141b)
Dichlorofluoromethane (HCFC-21) 1.0
Dichloromethane (Methylene 0.1
chloride)
Dichloropentafluoropropane 1.0
l,l-Dichloro-l,2,2,3,3- 1.0
pentafluoropropane (HCFC-225cc)
l,l-Dichloro-l,2,3,3,3- 1.0
pentafluoropropane (HCFC-225eb)
1,2-Dichloro-l, 1,2,3,3- 1.0
pentafluoropropane (HCFC-225bb)
1,2-Dichloro-l, 1,3,3,3- 1.0
pentafluoropropane (HCFC-225da)
1,3-Dichloro-l, 1,2,2,3- 1.0
pentafluoropropane (HCFC-225cb)
1,3-Dichloro-l,1,2,3,3- 1.0
pentafluoropropane (HCFC-225ea)
2,2-Dichloro-l,l,l,3,3- 1.0
pentafluoropropane (HCFC-225aa)
2,3-Dichloro-l,l,1,2,3- 1.0
pentafluoropropane (HCFC-225ba)
3,3-Dichloro-l,l,1,2,2- 1.0
pentafluoropropane (HCFC-225ca)
Dichlorophene 1.0
[2,2'-Methylenebis(4-chlorophenol)]
2,4-Dichlorophenol 1.0
1,2-Dichloropropane 1.0
trans-l,3-Dichloropropene 0.1
2,3-Dichloropropene 1.0
1,3 -Dichloropropy lene 0.1
Dichlorotetrafluoroethane 1.0
(CFC-114)
Dichlorotrifluoroethane 1.0
Dichloro-l,l,2-trifluoroethane 1.0
l,l-Dichloro-l,2,2- 1.0
trifluoroethane (HCFC-123b)
1,2-Dichloro-l, 1,2- 1.0
trifluoroethane (HCFC-123a)
2,2-Dichloro-l,l,l- 1.0
trifluoroethane (HCFC-123)
Dichlorvos 0.1
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
Diclofop methyl 1.0
[2-[4-(2,4-Dichlorophenoxy)phenoxy]
propanoic acid, methyl ester]
Dicofol 1.0
[Benzenemethanol, 4-chloro-
. alpha. -(4-chloropheny 1)-. alpha. -
(trichloromethyl)-]
Dicyclopentadiene 1.0
II-6 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number
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
De Minimis
Chemical Name Limit
Diepoxybutane
Diethanolamine
Diethatyl ethyl
Di(2-ethylhexyl) phthalate (DEHP)
Diethyl sulfate
Diflubenzuron
Diglycidyl resorcinol ether
Dihydrosafrole
Dimethipin
[2,3 -Dihydro-5,6-dimethyl- 1 ,4-dithiin
1,1,4,4-tetraoxide]
Dimethoate
3 ,3 '-Dimethoxybenzidine
3 ,3 '-Dimethoxybenzidine
dihydrochloride (o-Dianisidine
dihydrochloride)
3 ,3 '-Dimethoxybenzidine
0.1
1.0
1.0
0.1
0.1
1.0
0.1
0.1
1.0
1.0
0.1
0.1
0.1
hydrochloride (o-Dianisidine hydrochloride)
124-40-3
2300-66-5
60-11-7
121-69-7
119-93-7
612-82-8
41766-75-0
Dimethylamine
Dimethylamine dicamba
4-Dimethylaminoazobenzene
N,N-Dimethylaniline
3 ,3 '-Dimethylbenzidine (o-Tolidine)
3 ,3 '-Dimethylbenzidine
dihydrochloride (o-Tolidine
dihydrochloride)
3 ,3 '-Dimethylbenzidine
1.0
1.0
0.1
1.0
0.1
0.1
0.1
dihydrofluoride (o-Tolidine dihydrofluoride)
79-44-7
2524-03-0
68-12-2
57-14-7
105-67-9
131-11-3
77-78-1
99-65-0
528-29-0
100-25-4
88-85-7
534-52-1
51-28-5
121-14-2
606-20-2
25321-14-6
39300-45-3
123-91-1
957-51-7
122-39-4
Dimethylcarbamyl chloride
Dimethyl
chlorothiophosphate
N,N-Dimethylformamide
1,1 -Dimethyl hydrazine
2,4-Dimethylphenol
Dimethyl phthalate
Dimethyl sulfate
m-Dinitrobenzene
o-Dinitrobenzene
p-Dinitrobenzene
Dinitrobutyl phenol (Dinoseb)
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Dinitrotoluene (mixed isomers)
Dinocap
1,4-Dioxane
Diphenamid
Diphenylamine
0.1
1.0
1.0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
CAS Number Chemical Name
De Minimis
Limit
122-66-7 1,2-Diphenylhydrazine 0.1
(Hydrazobenzene)
2164-07-0 Dipotassium endothall 1.0
[7-Oxabicyclo(2.2.1)heptane-2,3-dicarboxylic
acid, dipotassium salt]
136-45-8 Dipropyl isocinchomeronate 1.0
138-93-2 Disodium 1.0
cyanodithioimidocarbonate
94-11-1 2,4-D isopropyl ester 0.1
541-53-7 2,4-Dithiobiuret 1.0
330-54-1 Diuron 1.0
2439-10-3 Dodine [Dodecylguanidine 1.0
monoacetate]
120-36-5 2,4-DP 0.1
1320-18-9 2,4-D propylene glycol 0.1
butyl ether ester
2702-72-9 2,4-D sodium salt 0.1
106-89-8 Epichlorohydrin 0.1
13194-48-4 Ethoprop 1.0
[Phosphorodithioic acid O-ethyl S,S-dipropyl
ester]
110-80-5 2-Ethoxyethanol 1.0
140-88-5 Ethyl acrylate 0.1
100-41-4 Ethylbenzene 0.1
541-41-3 Ethyl chloroformate 1.0
759-94-4 Ethyl dipropylthiocarbamate 1.0
(EPTC)
74-85-1 Ethylene 1.0
107-21-1 Ethylene glycol 1.0
151-56-4 Ethyleneimine (Aziridine) 0.1
75-21-8 Ethylene oxide 0.1
96-45-7 Ethylene thiourea 0.1
75-34-3 Ethylidene dichloride 1.0
52-85-7 Famphur 1.0
60168-88-9 Fenarimol 1.0
[.alpha.-(2-Chlorophenyl)-.alpha.-(4-
chlorophenyl)-5-pyrirnidinemethanol]
13356-08-6 Fenbutatin oxide 1.0
(Hexakis(2-methyl-2-phenylpropyl)
distannoxane)
66441-23-4 Fenoxaprop ethyl 1.0
[2-(4-((6-Chloro-2-
benzoxazolylen)oxy)phenoxy)propanoic acid,
ethyl ester]
72490-01-8 Fenoxycarb 1.0
[[2-(4-Phenoxyphenoxy)ethyl]carbamic acid
ethyl ester]
39515-41-8 Fenpropathrin 1.0
[2,2,3,3-Tetramethylcyclopropane carboxylic
acid cyano(3-phenoxyphenyl)methyl ester]
Toxics Release Inventory Reporting Form and Instructions II-7
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
55-38-9
51630-58-1
14484-64-1
69806-50-4
2164-17-2
7782-41-4
51-21-8
69409-94-5
133-07-3
72178-02-0
50-00-0
64-18-6
76-13-1
76-44-8
118-74-1
87-68-3
319-84-6
77-47-4
67-72-1
1335-87-1
70-30-4
680-31-9
110-54-3
51235-04-2
67485-29-4
Fenthion 1.0
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester, phosphorothioic
acid]
Fenvalerate 1.0
[4-Chloro-alpha-( 1 -methylethyl)
benzeneacetic acid cyano (3-
phenoxyphenyl) methyl ester]
Ferbam 1.0
[Tris(dimethylcarbamodithioato- S,S')iron]
Fluazifop butyl 1.0
[2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]phenoxy]propanoic acid,
butyl ester]
Fluometuron 1.0
[Urea, N,N-dimethyl-N'-[3-
(trifluoromethy l)pheny 1] -]
Fluorine 1.0
Fluorouracil (5-Fluorouracil) 1.0
Fluvalinate 1.0
[N-[2-Chloro-4-(trifluoromethyl)phenyl]-
DL-valine(+)-cyano(3 -
phenoxyphenyl)methyl ester]
Folpet 1.0
Fomesafen 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
N-methylsulfonyl-2-nitrobenzamide]
Formaldehyde 0.1
Formic acid 1.0
FreonllS 1.0
[Ethane, 1,1,2-trichloro- 1,2,2,-trifluoro-]
Heptachlor *
[l,4,5,6,7,8,8-Heptachloro-3a, 4,7,7a-
tetrahydro-4,7-methano-lH-indene]
Hexachlorobenzene *
Hexachloro-1,3 -butadiene
alpha-Hexachlorocyclohexane
Hexachlorocyclopentadiene
Hexachloroethane
1.0
0.1
1.0
0.
1
1.0
1.0
0.1
1.0
1.0
1.0
302-01-2
10034-93-2
Hexachloronaphthalene
Hexachlorophene
Hexamethyrphosphoramide
n-Hexane
Hexazinone
Hydramethylnon
[Tetrahydro-5,5-dimethyl-2(lH)-
pyrimidinone[3-[4-(trifluoromethyl)phenyl]-
1 - [2- [4-(trifluoromethy l)pheny 1] etheny 1] -2-
propenylidene]hydrazone]
Hydrazine 0.1
Hydrazine sulfate 0.1
CAS Number Chemical Name
De Minimis
Limit
7647-01-0 Hydrochloric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
74-90-8 Hydrogen cyanide 1.0
7664-39-3 Hydrogen fluoride 1.0
123-31-9 Hydroquinone 1.0
35554.44-0 Imazalil 1.0
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl]-lH-imidazole]
55406-53-6 3-Iodo-2-propynyl 1.0
butylcarbamate
13463-40-6 Iron pentacarbonyl 1.0
78-84-2 Isobutyraldehyde 1.0
465-73-6 Isodrin *
25311-71-1 Isofenphos[2-[[Ethoxyl[(l- 1.0
methylethyl)amino]phosphinothioyl]oxy]
benzoic acid 1-methylethyl ester]
67-63-0 Isopropyl alcohol 1.0
(only persons who manufacture by the strong
acid process are subject, no supplier
notification)
80-05-7 4,4'-Isopropylidenediphenol 1.0
120-58-1 Isosafrole 1.0
77501-63-4 Lactofen 1.0
[Benzoic acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy]-2-nitro-, 2-ethoxy-
l-methyl-2-oxoethyl ester]
7439-92-1 Lead *
(when lead is contained in stainless steel,
brass or bronze alloys the de minimis level is
0.1)
58-89-9 Lindane 0.1
[Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(l.alpha.,2.alpha.,3.beta.,4.alpha.,5.alpha.,
6.beta.)-]
330-55-2 Linuron 1.0
554-13-2 Lithium carbonate 1.0
121-75-5 Malathion 1.0
108-31-6 Maleic anhydride 1.0
109-77-3 Malononitrile 1.0
12427-38-2 Maneb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
manganese complex]
7439-96-5 Manganese 1.0
93-65-2 Mecoprop 0.1
149-30-4 2-Mercaptobenzothiazole (MET) 1.0
7439-97-6 Mercury *
150-50-5 Merphos 1.0
126-98-7 Methacrylonitrile 1.0
II-8 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
Metham sodium (Sodium 1.0
methyldithiocarbamate)
Methanol 1.0
Methazole 1.0
[2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
oxadiazolidine-3,5-dione]
Methiocarb 1.0
Methoxone 0.1
((4-Chloro-2-methylphenoxy) acetic acid)
(MCPA)
Methoxone sodium salt 0.1
((4-Chloro-2-methylphenoxy) acetate
sodium salt)
Methoxychlor *
[Benzene, 1,1 '-(2,2,2-
trichloroethylidene)bis[4-methoxy-]
2-Methoxyethanol 1.0
Methyl aery late 1.0
Methyl tert-buty 1 ether 1.0
Methyl chlorocarbonate 1.0
4,4'-Methylenebis(2-chloroaniline) 0.1
(MBOCA)
4,4'-Methylenebis(N,N-dimethyl) 0.1
benzenamine
Methylene bromide 1.0
4,4'-Methylenedianiline 0.1
Methyl ethyl ketone 1.0
Methyl hydrazine 1.0
Methyl iodide 1.0
Methyl isobuty 1 ketone 1.0
Methyl isocyanate 1.0
Methyl isothiocyanate 1.0
[Isothiocyanatomethane]
2-Methyllactonitrile 1.0
Methyl methacry late 1.0
N-Methylolacry lamide 1.0
Methyl parathion 1.0
2-Methylpyridine 1.0
N-Methyl-2-pyrrolidone 1.0
Metiram 1.0
Metribuzin 1.0
Mevinphos 1.0
Michler' s ketone 0.1
Molinate 1.0
(IH-Azepine-l-carbothioic acid, hexahydro-
, S-ethyl ester)
Molybdenum trioxide 1.0
Monochloropentafluoroethane 1.0
(CFC-115)
Monuron 1.0
67-56-1
20354-26-1
2032-65-7
94-74-6
3653-48-3
72-43-5
109-86-4
96-33-3
1634-04-4
79-22-1
101-14-4
101-61-1
74-95-3
101-77-9
78-93-3
60-34-4
74-88-4
108-10-1
624-83-9
556-61-6
75-86-5
80-62-6
924-42-5
298-00-0
109-06-8
872-50-4
9006-42-2
21087-64-9
7786-34-7
90-94-8
2212-67-1
1313-27-5
76-15-3
150-68-5
CAS Number Chemical Name
De Minimis
Limit
505-60-2 Mustard gas 0.1
[Ethane, l,l'-thiobis[2-chloro-]
88671-89-0 Myclobutanil 1.0
[.alpha. -Butyl-.alpha. -(4-chlorophenyl)- 1H-
1,2,4-triazole-l -propanenitrile]
142-59-6 Nabam 1.0
300-76-5 Naled 1.0
91-20-3 Naphthalene 0.1
134-32-7 alpha-Naphthylamine 0.1
91-59-8 beta-Naphthylamine 0.1
7440-02-0 Nickel 0.1
1929-82-4 Nitrapyrin 1.0
(2-Chloro-6-(trichloromethyl)pyridine)
7697-37-2 Nitric acid 1.0
139-13-9 Nitrilotriacetic acid 0.1
100-01-6 p-Nitroaniline 1.0
99-59-2 5-Nitro-o-anisidine 1.0
98-95-3 Nitrobenzene 0.1
92-93-3 4-Nitrobiphenyl 0.1
1836-75-5 Nitrofen 0.1
[Benzene, 2,4-dichloro-1 -(4-nitrophenoxy)-]
51-75-2 Nitrogen mustard 0.1
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
55-63-0 Nitroglycerin 1.0
88-75-5 2-Nitrophenol 1.0
100-02-7 4-Nitrophenol 1.0
79-46-9 2-Nitropropane 0.1
924-16-3 N-Nitrosodi-n-butylamine 0.1
55-18-5 N-Nitrosodiethylamine 0.1
62-75-9 N-Nitrosodimethylamine 0.1
86-30-6 N-Nitrosodiphenylamine 1.0
156-10-5 p-Nitrosodiphenylamine 1.0
621-64-7 N-Nitrosodi-n-propylamine 0.1
759-73-9 N-Nitroso-N-ethylurea 0.1
684-93-5 N-Nitroso-N-methylurea 0.1
4549-40-0 N-Nitrosomethylvinylamine 0.1
59-89-2 N-Nitrosomorpholine 0.1
16543-55-8 N-Nitrosonornicotine 0.1
100-75-4 N-Nitrosopiperidine 0.1
99-55-8 5-Nitro-o-toluidine 1.0
27314-13-2 Norflurazon 1.0
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)phenyl]-3(2H)-pyridazinone]
2234-13-1 Octachloronaphthalene 1.0
29082-74-4 Octachlorostyrene *
19044-88-3 Oryzalin 1.0
[4-(Dipropylamino)-3,5-dinitrobenzene
sulfonamide]
20816-12-0 Osmium tetroxide 1.0
Toxics Release Inventory Reporting Form and Instructions II-9
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
301-12-2 Oxydemeton methyl 1.0
[S-(2-(Ethylsuffinyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
19666-30-9 Oxydiazon 1.0
[3-[2,4-Dichloro-5-(l-
methylethoxy)phenyl]- 5-(l,l-
dimethylethyl)-l,3,4-oxadiazol-2(3H)-one]
42874-03-3 Oxyfluorfen 1.0
10028-15-6 Ozone 1.0
123-63-7 Paraldehyde 1.0
1910-42-5 Paraquat dichloride 1.0
56-38-2 Parathion 1.0
[Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl)ester]
1114-71-2 Pebulate 1.0
[Butylethylcarbamothioic acid S-propyl
ester]
40487-42-1 Pendimethalin *
[N-(l-Ethyrpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine]
608-93-5 Pentachlorobenzene *
76-01-7 Pentachloroethane 1.0
87-86-5 Pentachlorophenol (PCP) 0.1
57-33-0 Pentobarbital sodium 1.0
79-21-0 Peracetic acid 1.0
594-42-3 Perchloromethyl mercaptan 1.0
52645-53-1 Permethrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid, (3-
phenoxyphenyl) methyl ester]
85-01-8 Phenanthrene 1.0
108-95-2 Phenol 1.0
26002-80-2 Phenothrin 1.0
[2,2-Dimethyl-3-(2-methyl-1 -
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester]
95-54-5 1,2-Phenylenediamine 1.0
108-45-2 1,3-Phenylenediamine 1.0
106-50-3 p-Phenylenediamine 1.0
615-28-1 1,2-Phenylenediamine dihydro- 1.0
chloride
624-18-0 1,4-Phenylenediamine dihydro- 1.0
chloride
90-43-7 2-Phenylphenol 1.0
57-41-0 Phenytoin 0.1
75-44-5 Phosgene 1.0
7803-51-2 Phosphine 1.0
7723-14-0 Phosphorus (yellow or white) 1.0
85-44-9 Phthalic anhydride 1.0
1918-02-1 Picloram 1.0
88-89-1 Picric acid 1.0
11-10 Toxics Release Inventory Reporting Forms and Instructions
CAS Number Chemical Name
De Minimis
Limit
51-03-6
29232-93-7
1336-36-3
7758-01-2
128-03-0
137-41-7
41198-08-7
7287-19-6
23950-58-5
1918-16-7
1120-71-4
709-98-8
2312-35-8
107-19-7
31218-83-4
60207-90-1
57-57-8
123-38-6
114-26-1
115-07-1
75-55-8
75-56-9
110-86-1
91-22-5
106-51-4
82-68-8
76578-14-8
Piperonyl butoxide 1.0
Pirimiphos methyl 1.0
[O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-dimethylphosphorothioate]
Fob/chlorinated biphenyls *
(PCBs)
Potassium bromate 0.1
Potassium dimethyldithio- 1.0
carbamate
Potassium N-methyldithio- 1.0
carbamate
Profenofos 1.0
[O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
propyl phosphorothioate]
Prometryn 1.0
[N,N'-Bis(l-methylethyl)-6-methylthio-l,3,5-
triazine-2,4-diamine]
Pronamide 1.0
Propachlor 1.0
[2-Chloro-N-( 1 -methylethyl)-N-
phenylacetamide]
Propane sultone 0.1
Propanil 1.0
[N-(3,4-Dichlorophenyl)propanamide]
Propargite 1.0
Propargyl alcohol 1.0
Propetamphos 1.0
[3 - [(Ethy lamino)methoxyphosphinothioyl]
oxy]-2-butenoic acid, 1-methylethyl ester]
Propiconazole 1.0
[l-[2-(2,4-Dichlorophenyl)-4-propyl-l,3-
dioxolan-2-yl]-methyl-lH-1,2,4,-triazole]
beta-Propiolactone 0.1
Propionaldehyde 1.0
Propoxur 1.0
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
Propylene (Propene) 1.0
Propyleneimine 0.1
Propylene oxide 0.1
Pyridine 1.0
Quinoline 1.0
Quinone 1.0
Quintozene 1.0
(Pentachloronitrobenzene)
Quizalofop-ethyl 1.0
[2-[4-[(6-Chloro-2-
quinoxalinyl)oxy]phenoxy] propanoic acid
ethyl ester]
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
10453-86-8 Resmethrin 1.0
[[5-(Phenylmethyl)-3-furanyl]methyl-2,2-
dimethyl-3 -(2-methyl-1 -propenyl)
cyclopropanecarboxylate]
81-07-2 Saccharin (only persons who 1.0
manufacture are subject, no supplier
notification)
94-59-7 Safrole 0.1
7782-49-2 Selenium 1.0
74051-80-2 Sethoxydim 1.0
[2-[ 1 -(Ethoxyimino)butyl] -5-[2-
(ethylthio)propyl] -3 -hydroxyl-2-cyclohexen-
1-one]
7440-22-4 Silver 1.0
122-34-9 Simazine 1.0
26628-22-8 Sodium azide 1.0
1982-69-0 Sodium dicamba 1.0
[3,6-Dichloro-2-methoxybenzoic acid,
sodium salt]
128-04-1 Sodium dimethyldithiocarbamate 1.0
62-74-8 Sodium fluoroacetate 1.0
7632-00-0 Sodium nitrite 1.0
131-52-2 Sodium pentachlorophenate 1.0
132-27-4 Sodium o-phenylphenoxide 0.1
100-42-5 Styrene 0.1
96-09-3 Styrene oxide 0.1
7664-93-9 Sulfuric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
2699-79-8 Sulfuryl fluoride (Vikane) 1.0
35400-43-2 Sulprofos 1.0
[O-Ethyl O-[4-(methylthio)phenyl]
phosphorodithioic acid S-propylester]
34014-18-1 Tebuthiuron 1.0
[N-[5-(l,l-Dimethylethyl)-l,3,4-thiadiazol-
2-yl] -N,N' -dimethylurea]
3383-96-8 Temephos 1.0
5902-51-2 Terbacil 1.0
[5-Chloro-3 -(1,1 -dimethylethyl)-6-methyl-
2,4(lH,3H)-pyrimidinedione]
79-94-7 Tetrabromobisphenol A *
630-20-6 1,1,1,2-Tetrachloroethane 1.0
79-34-5 1,1,2,2-Tetrachloroethane 1.0
127-18-4 Tetrachloroethylene 0.1
(Perchloroethylene)
354-11-0 1,1,1,2-Tetrachloro-2-fluoroethane 1.0
(HCFC-121a)
354-14-3 1,1,2,2-Tetrachloro-l-fluoroethane 1.0
(HCFC-121)
CAS Number Chemical Name
De Minimis
Limit
961-11-5
64-75-5
7696-12-0
1.0
7440-28-0
148-79-8
62-55-5
28249-77-6
139-65-1
59669-26-0
23564-06-9
23564-05-8
79-19-6
62-56-6
137-26-8
1314-20-1
7550-45-0
108-88-3
584-84-9
91-08-7
26471-62-5
95-53-4
636-21-5
8001-35-2
43121-43-3
2303-17-5
68-76-8
101200-48-0
1983-10-4
2155-70-6
78-48-8
1.0
1.0
Tetrachlorvinphos
[Phosphoric acid, 2-chloro-l-(2,4,5-
trichlorophenyl) ethenyl dimethyl ester]
Tetracycline hydrochloride
Tetramethrin
[2,2-Dimethyl-3 -(2-methyl-1 -propenyl)
cyclopropanecarboxylic acid (1,3,4,5,6,7-
hexahydro-1,3 -dioxo-2H-isoindol-2-
yl)methyl ester]
Thallium
Thiabendazole
[2-(4-Thiazolyl)- IH-benzimidazole]
Thioacetamide
Thiobencarb
[Carbamic acid, diethylthio-, S-(p-
chlorobenzyl)ester]
4,4'-Thiodianiline
Thiodicarb
Thiophanate ethyl
[[l,2-Phenylenebis(iminocarbonothioyl)]
biscarbamic acid diethylester]
Thiophanate methyl
Thiosemicarbazide
Thiourea
Thiram
Thorium dioxide
Titanium tetrachloride
Toluene
Toluene-2,4-diisocyanate
Toluene-2,6-diisocyanate
Toluene diisocyanate (mixed
isomers)
o-Toluidine
o-Toluidine hydrochloride
Toxaphene
Triadimefon
[l-(4-Chlorophenoxy)-3,3-di-methyl-l-(lH-
1,2,4- triazol-l-yl)-2-butanone]
Triallate 1.0
Triaziquone 1.0
[2,5-Cyclohexadiene-l,4-dione, 2,3,5-tris(l-
aziridinyl)-]
Tribenuron methyl 1.0
[2-[[[[(4-Methoxy-6-methyl-l,3,5-triazin-2-
y l)-methylamino] -carbonyl] amino] sulfony 1]
benzoic acid methyl ester)
Tributy Itin fluoride 1.0
Tributy Itin methacry late 1.0
S,S,S-Tributyltrithio- 1.0
phosphate (DBF)
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
0.1
0.1
0.1
*
1.0
Toxics Release Inventory Reporting Form and Instructions II-1 1
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
52-68-6 Trichlorfon 1.0
[Phosphoric acid,(2,2,2-trichloro-l-hydroxy-
ethyl)-, dimethyl ester]
76-02-8 Trichloroacetyl chloride 1.0
120-82-1 1,2,4-Trichlorobenzene 1.0
71-55-6 1,1,1-Trichloroethane (Methyl 1.0
chloroform)
79-00-5 1,1,2-Trichloroethane 1.0
79-01-6 Trichloroethylene 0.1
75-69-4 Trichlorofluoromethane(CFC-ll) 1.0
95-95-4 2,4,5-Trichlorophenol 1.0
88-06-2 2,4,6-Trichlorophenol 0.1
96-18-4 1,2,3-Trichloropropane 0.1
57213-69-1 Triclopyr triethylammonium salt 1.0
121-44-8 Triethylamine 1.0
1582-09-8 Trifluralin *
[Benezeneamine, 2,6-dinitro-N,N-dipropyl-
4-(trifluoromethyl)-]
26644-46-2 Triforine 1.0
[N,N'-[l,4-Piperazinediylbis-(2,2,2-
trichloroethylidene)]bisformamide]
95-63-6 1,2,4-Trimethylbenzene 1.0
2655-15-4 2,3,5-Trimethylphenyl 1.0
methylcarbamate
639-58-7 Triphenyltin chloride 1.0
76-87-9 Triphenyltin hydroxide 1.0
126-72-7 Tris(2,3-dibromopropyl) 0.1
phosphate
72-57-1 Trypanblue 0.1
51-79-6 Urethane (Ethyl carbamate) 0.1
7440-62-2 Vanadium (except when contained 1.0
in an alloy)
50471-44-8 Vinclozolin 1.0
[3-(3,5-Dichlorophenyl)-5-ethenyl-5-methyl-
2,4-oxazolidinedione]
108-05-4 Vinyl acetate 0.1
593-60-2 Vinyl bromide 0.1
75-01-4 Vinyl chloride 0.1
75-35-4 Vinylidene chloride 1.0
108-38-3 m-Xylene 1.0
95.47-6 o-Xylene 1.0
106-42-3 p-Xylene 1.0
1330-20-7 Xylene (mixed isomers) 1.0
87-62-7 2,6-Xylidine 0.1
7440-66-6 Zinc (fume or dust) 1.0
12122-67-7 Zineb 1.0
[Carbamodithioic acid, 1,2-ethanediyibis-,
zinc complex]
b. Individually Listed Toxic Chemicals
Arranged by CAS Number
CAS Number Chemical Name
De Minimis
Limit
50-00-0 Formaldehyde 0.1
51-03-6 Piperonyl butoxide 1.0
51-21-8 Fluorouracil (5-Fluorouracil) 1.0
51-28-5 2,4-Dinitrophenol 1.0
51-75-2 Nitrogen mustard 0.1
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
51 -79-6 Urethane (Ethyl carbamate) 0.1
52-68-6 Trichlorfon 1.0
[Phosphonic acid, (2,2,2-trichloro-l-
hydroxyethyl)-, dimethyl ester]
52-85-7 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
11-12 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
62-56-6 Thiourea 0.1
62-73-7 Dichlorvos 0.1
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
62-74-8 Sodium fluoroacetate 1.0
62-75-9 N-Nitrosodimethylamine 0.1
63-25-2 Carbaryl 1.0
[1-Naphthalenol, methylcarbamate]
64-18-6 Formic acid 1.0
64-67-5 Diethyl sulfate 0.1
64-75-5 Tetracycline hydrochloride 1.0
67-56-1 Methanol 1.0
67-63-0 Isopropyl alcohol 1.0
(only persons who manufacture by the
strong acid process are subject, no supplier
notification)
67-66-3 Chloroform 0.1
67-72-1 Hexachloroethane 0.1
68-12-2 N,N-Dimethylformamide 1.0
68-76-8 Triaziquone 1.0
[2,5-Cyclohexadiene-l,4-dione, 2,3,5-tris(l-
aziridinyl)-]
70-30-4 Hexachlorophene 1.0
71-36-3 n-Butyl alcohol 1.0
71-43-2 Benzene 0.1
71-55-6 1,1,1-Trichloroethane (Methyl 1.0
chloroform)
72-43-5 Methoxychlor *
[Benzene, 1,1'-(2,2,2-
trichloroethylidene)bis[4-methoxy-]
72-57-1 Trypanblue 0.1
74-83-9 Bromomethane (Methyl bromide) 1.0
74-85-1 Ethylene 1.0
74-87-3 Chloromethane (Methyl chloride) 1.0
74-88-4 Methyl iodide 1.0
74-90-8 Hydrogen cyanide 1.0
74-95-3 Methylene bromide 1.0
75-00-3 Chloroethane (Ethyl chloride) 1.0
75-01-4 Vinyl chloride 0.1
75-05-8 Acetonitrile 1.0
75-07-0 Acetaldehyde 0.1
75-09-2 Dichloromethane (Methylene 0.1
chloride)
75-15-0 Carbon disulfide 1.0
75-21-8 Ethylene oxide 0.1
75-25-2 Bromoform (Tribromomethane) 1.0
75-27-4 Dichlorobromomethane 0.1
75-34-3 Ethylidene dichloride 1.0
75-35-4 Vinylidene chloride 1.0
75-43-4 Dichlorofluoromethane 1.0
(HCFC-21)
CAS Number Chemical Name
De Minimis
Limit
75-44-5 Phosgene
75-45-6 Chlorodifluoromethane
(HCFC-22)
75-55-8 Propyleneimine
75-56-9 Propylene oxide
75-63-8 Bromotrifluoromethane
(Halon 1301)
75-65-0 tert-Butyl alcohol
75-68-3 l-Chloro-l,l-difluoroethane
(HCFC-142b)
75-69-4 Trichlorofluoromethane (CFC-11)
75-71-8 Dichlorodifluoromethane
(CFC-12)
75-72-9 Chlorotrifluoromethane (CFC-13)
75-86-5 2-Methyllactonitrile
75-88-7 2-Chloro-l,l,l-trifluoroethane
(HCFC-133a)
76-01-7 Pentachloroethane
76-02-8 Trichloroacetyl chloride
76-06-2 Chloropicrin
76-13-1 FreonllS
[Ethane, 1,1,2-trichloro-1,2,2,-trifluoro-]
76-14-2 Dichlorotetrafluoroethane 1.0
(CFC-114)
76-15-3 Monochloropentafluoroethane 1.0
(CFC-115)
76-44-8 Heptachlor *
[l,4,5,6,7,8,8-Heptachloro-3a,4,7,7a-
tetrahydro-4,7-methano- IH-indene]
76-87-9 Triphenyltin hydroxide 1.0
77-47-4 Hexachlorocyclopentadiene 1.0
77-73-6 Dicyclopentadiene 1.0
77-78-1 Dimethyl sulfate 0.1
78-48-8 S,S,S-Tributyltrithiophosphate 1.0
(DBF)
78-84-2 Isobutyraldehyde 1.0
78-87-5 1,2-Dichloropropane 1.0
78-88-6 2,3-Dichloropropene 1.0
78-92-2 sec-Butyl alcohol 1.0
78-93-3 Methyl ethyl ketone 1.0
79-00-5 1,1,2-Trichloroethane 1.0
79-01-6 Trichloroethylene 0.1
79-06-1 Acrylamide 0.1
79-10-7 Aery lie acid 1.0
79-11-8 Chloroacetic acid 1.0
79-19-6 Thiosemicarbazide 1.0
79-21-0 Peracetic acid 1.0
79-22-1 Methyl chlorocarbonate 1.0
79-34-5 1,1,2,2-Tetrachloroethane 1.0
79-44-7 Dimethylcarbamyl chloride 0.1
79-46-9 2-Nitropropane 0.1
Toxics Release Inventory Reporting Form and Instructions 11-13
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
CAS Number Chemical Name
De Minimis
Limit
79-94-7 Tetrabromobisphenol A
80-05-7 4,4'-Isopropylidenediphenol
80-15-9 Cumene hydroperoxide
80-62-6 Methyl methacrylate
81-07-2 Saccharin (only persons who
manufacture are subject, no supplier
notification)
81-88-9 C.I. Food Red 15
82-28-0 1 -Amino-2-methylanthraquinone
82-68-8 Quintozene
[Pentachloronitrobenzene]
84-74-2 Dibutyl phthalate
85-01-8 Phenanthrene
85-44-9 Phthalic anhydride
86-30-6 N-Nitrosodiphenylamine
87-62-7 2,6-Xylidine
87-68-3 Hexachloro-l,3-butadiene
87-86-5 Pentachlorophenol (PCP)
88-06-2 2,4,6-Trichlorophenol
88-75-5 2-Nitrophenol
88-85-7 Dinitrobutyl phenol (Dinoseb)
88-89-1 Picric acid
90-04-0 o-Anisidine
90-43-7 2-Phenylphenol
90-94-8 Michler'sketone
91-08-7 Toluene-2,6-diisocyanate
91-20-3 Naphthalene
91-22-5 Quinoline
91-59-8 beta-Naphthylamine
91-94-1 3,3'-Dichlorobenzidine
92-52-4 Biphenyl
92-67-1 4-Aminobiphenyl
92-87-5 Benzidine
92-93-3 4-Nitrobiphenyl
93-65-2 Mecoprop
94-11-1 2,4-D isopropyl ester
94-36-0 Benzoyl peroxide
94-58-6 Dihydrosafrole
94.59.7 Safrole
94-74-6 Methoxone
((4-Chloro-2-methylphenoxy) acetic
(MCPA)
94-75-7 2,4-D [Acetic acid, (2,4-
dichlorophenoxy)-]
94-80-4 2,4-D butyl ester
94-82-6 2,4-DB
95.47-6 o-Xylene
95-48-7 o-Cresol
95-50-1 1,2-Dichlorobenzene
95-53-4 o-Toluidine
95-54-5 1,2-Phenylenediamine
95-63-6 1,2,4-Trimethylbenzene
*
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
1.0
1.0
0.1
1.0
0.
0.
0.
1.0
0.
0.
1.0
0.
0.
0.
0.
0.1
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
95-69-2
95-80-7
95-95-4
96-09-3
96-12-8
96-18-4
96-33-3
96-45-7
97-23-4
97-56-3
98-07-7
98-82-8
98-86-2
98-87-3
98-88-4
98-95-3
99-30-9
99-55-8
99-59-2
99-65-0
100-01-6
100-02-7
100-25-4
100-41-4
100-42-5
100-44-7
100-75-4
101-05-3
101-14-4
101-61-1
101-77-9
101-80-4
101-90-6
104-12-1
104-94-9
105-67-9
106-42-3
106-44-5
106-46-7
106-47-8
106-50-3
106-51-4
p-Chloro-o-toluidine
2,4-Diaminotoluene
2,4,5-Trichlorophenol
Styrene oxide
1,2-Dibromo-3 -chloropropane
(DBCP)
1,2,3 -Trichloropropane
Methyl acrylate
Ethylene thiourea
Dichlorophene
[2,2'-Methylenebis(4-chlorophenol)]
C.I. Solvent Yellow 3
Benzoic trichloride
(Benzotrichloride)
Cumene
Acetophenone
Benzal chloride
Benzoyl chloride
Nitrobenzene
Dichloran [2,6-Dichloro-4-
nitroaniline]
5-Nitro-o-toluidine
5-Nitro-o-anisidine
m-Dinitrobenzene
p-Nitroaniline
4-Nitrophenol
p-Dinitrobenzene
Ethylbenzene
Styrene
Benzyl chloride
N-Nitrosopiperidine
Anilazine
[4,6-Dichloro-N-(2-chlorophenyl)-1,3
triazin-2-amine]
4,4'-Methylenebis(2-chloroaniline)
(MBOCA)
4,4'-Methylenebis(N,N-
dimethyl)benzenamine
4,4'-Methylenedianiline
4,4'-Diaminodiphenyl ether
Diglycidyl resorcinol ether
p-Chlorophenyl isocyanate
p-Anisidine
2,4-Dimethylphenol
p-Xylene
p-Cresol
1,4-Dichlorobenzene
p-Chloroaniline
p-Phenylenediamine
Quinone
,5-
0.1
0.1
1.0
0.1
0.1
0.1
1.0
0.1
1.0
0.1
0.1
.0
.0
.0
.0
0.1
.0
.0
.0
.0
.0
.0
.0
0.1
0.1
1.0
0.1
1.0
0.1
0.1
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
11-14 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
CAS Number Chemical Name
De Minimis
Limit
106-88-7 1,2-Butylene oxide
106-89-8 Epichlorohydrin
106-93-4 1,2-Dibromoethane
(Ethylene dibromide)
106-99-0 1,3-Butadiene
107-02-8 Acrolein
107-05-1 Allyl chloride
107-06-2 1,2-Dichloroethane (Ethylene
dichloride)
107-11-9 Allylamine
107-13-1 Acrylonitrile
107-18-6 Allyl alcohol
107-19-7 Propargyl alcohol
107-21-1 Ethylene glycol
107-30-2 Chloromethyl methyl ether
108-05-4 Vinyl acetate
108-10-1 Methyl isobutyl ketone
108-31-6 Maleic anhydride
108-38-3 m-Xylene
108-39-4 m-Cresol
108-45-2 1,3-Phenylenediamine
108-60-1 Bis(2-chloro-l-methylethyl) ether
108-88-3 Toluene
108-90-7 Chlorobenzene
108-93-0 Cyclohexanol
108-95-2 Phenol
109-06-8 2-Methylpyridine
109-77-3 Malononitrile
109-86-4 2-Methoxyethanol
110-54-3 n-Hexane
110-57-6 trans-l,4-Dichloro-2-butene
110-80-5 2-Ethoxyethanol
110-82-7 Cyclohexane
110-86-1 Pyridine
111-42-2 Diethanolamine
111-44-4 Bis(2-chloroethyl) ether
111-91-1 Bis(2-chloroethoxy) methane
114-26-1 Propoxur
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
115-07-1 Propylene (Propene)
115-28-6 Chlorendic acid
115-32-2 Dicofol
[Benzenemethanol, 4-chloro-.alpha.-4-
(chlorophenyl)-.alpha.-(trichloromethyl)-]
116-06-3 Aldicarb
117-79-3 2-Aminoanthraquinone
117-81-7 Di(2-ethylhexyl) phthalate
118-74-1 Hexachlorobenzene
119-90-4 3,3 '-Dimethoxybenzidine
1.0
0.1
0.1
*
0.1
134-29-2
134-32-7
135-20-6
136-45-8
3,3'-Dimethylbenzidine 0.1
(o-Tolidine)
Anthracene 1.0
2,4-DP 0.1
Isosafrole 1.0
p-Cresidine 0.1
Catechol 0.1
1,2,4-Trichlorobenzene .0
2,4-Dichlorophenol .0
2,4-Dinitrotoluene 0.1
Triethylamine .0
N,N-Dimethylaniline .0
Malathion .0
Simazine .0
Diphenylamine .0
1,2-Diphenylhydrazine 0.1
(Hydrazobenzene)
Hydroquinone 1.0
Propionaldehyde 1.0
Paraldehyde 1.0
Butyraldehyde 1.0
1,4-Dioxane 0.1
Dimethylamine 1.0
Dibromotetrafluoroethane 1.0
(Halon 2402)
Tris(2,3-dibromopropyl) 0.1
phosphate
Methacrylonitrile 1.0
Chloroprene 0.1
Tetrachloroethylene 0.1
(Perchloroethylene)
Potassium 1.0
dimethyldithiocarbamate
Sodium dimethyldithiocarbamate .0
C.I. Vat Yellow 4 .0
Dimethyl phthalate .0
Sodium pentachlorophenate .0
Sodium o-pheny Iphenoxide 0.1
Dibenzofuran
Captan
[ IH-Isoindole-1,3 (2H)-dione, 3a,4,7,7a-
tetrahydro-2-[(trichloromethyl)thio]-]
Folpet 1.0
Chloramben 1.0
[Benzoic acid, 3-amino-2,5-dichloro-]
o-Anisidine hydrochloride 0.1
alpha-Naphthylamine 0.1
Cupferron 0.1
[Benzeneamine, N-hydroxy-N-nitroso,
ammonium salt]
Dipropyl isocinchomeronate 1.0
0.1
0.1
0.1
0.1
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
119-93-7
120-12-7
120-36-5
120-58-1
120-71-8
120-80-9
120-82-1
120-83-2
121-14-2
121-44-8
121-69-7
121-75-5
122-34-9
122-39-4
122-66-7
123-31-9
123-38-6
123-63-7
123-72-8
123-91-1
124-40-3
124-73-2
126-72-7
126-98-7
126-99-8
127-18-4
128-03-0
128-04-1
128-66-5
131-11-3
131-52-2
132-27-4
132-64-9
133-06-2
133-07-3
133-90-4
Toxics Release Inventory Reporting Form and Instructions 11-15
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
137-26-8 Thiram 1.0
137-41-7 Potassium N-methy Idithio- 1.0
carbamate
137-42-8 Metham sodium (Sodium 1.0
methyldithiocarbamate)
138-93-2 Disodium cyanodithioimido- 1.0
carbonate
139-13-9 Nitrilotriacetic acid 0.1
139-65-1 4,4'-Thiodianiline 0.1
140-88-5 Ethyl acrylate 0.1
141-32-2 Butyl acrylate 1.0
142-59-6 Nabam 1.0
148-79-8 Thiabendazole 1.0
[2-(4-Thiazolyl)-lH-benzimidazole]
149-30-4 2-Mercaptobenzothiazole 1.0
(MET)
150-50-5 Merphos 1.0
150-68-5 Monuron 1.0
151-56-4 Ethyleneimine (Aziridine) 0.1
156-10-5 p-Nitrosodiphenylamine 1.0
156-62-7 Calcium cyanamide 1.0
191-24-2 Benzo(g,h,i)perylene *
298-00-0 Methyl parathion 1.0
300-76-5 Naled 1.0
301-12-2 Oxydemeton methyl 1.0
[S-(2-(Ethylsuffinyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
302-01-2 Hydrazine 0.1
306-83-2 2,2-Dichloro-l,l,l-trifluoroethane 1.0
(HCFC-123)
309-00-2 Aldrin *
[1,4:5,8-Dimethanonaphthalene,
1,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a-
hexahydro-(l.alpha.,4.alpha.,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
314-40-9 Bromacil 1.0
(5-Bromo-6-methyl-3-(l-methylpropyl)-
2,4(lH,3H)-pyrimidinedione)
319-84-6 alpha-Hexachlorocyclohexane 0.1
330-54-1 Diuron 1.0
330-55-2 Linuron 1.0
333-41-5 Diazinon 1.0
334-88-3 Diazomethane 1.0
353-59-3 Bromochlorodifluoromethane 1.0
(Halonl211)
354-11-0 1,1,1,2-Tetrachloro-2-fluoroethane 1.0
(HCFC-121a)
354-14-3 1,1,2,2-Tetrachloro-l-fluoroethane 1.0
(HCFC-121)
354-23-4 l,2-Dichloro-l,l,2- 1.0
trifluoroethane (HCFC-123a)
CAS Number Chemical Name
De Minimis
Limit
354-25-6 l-Chloro-1,1,2,2- 1.0
tetrafluoroethane (HCFC-124a)
357-57-3 Brucine 1.0
422-44-6 1,2-Dichloro-l,1,2,3,3- 1.0
pentafluoropropane (HCFC-225bb)
422-48-0 2,3-Dichloro-l,1,1,2,3- 1.0
pentafluoropropane (HCFC-225ba)
422-56-0 3,3-Dichloro-l,1,1,2,2- 1.0
pentafluoropropane (HCFC-225ca)
431-86-7 1,2-Dichloro-l,1,3,3,3- 1.0
pentafluoropropane (HCFC-225da)
460-35-5 3-Chloro-l,l,l-trifluoropropane 1.0
(HCFC-253fb)
463-58-1 Carbonyl sulfide 1.0
465-73-6 Isodrin *
492-80-8 C.I. Solvent Yellow 34 0.1
(Auramine)
505-60-2 Mustard gas 0.1
[Ethane, l,l'-thiobis[2-chloro-]
507-55-1 1,3-Dichloro-l, 1,2,2,3- 1.0
pentafluoropropane (HCFC-225cb)
510-15-6 Chlorobenzilate 1.0
[Benzeneacetic acid, 4-chloro-.alpha.-(4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
528-29-0 o-Dinitrobenzene 1.0
532-27-4 2-Chloroacetophenone 1.0
533-74-4 Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-1,3,5-
thiadiazine-2-thione)
534-52-1 4,6-Dinitro-o-cresol 1.0
540-59-0 1,2-Dichloroethylene 1.0
541-41-3 Ethyl chloroformate 1.0
541-53-7 2,4-Dithiobiuret 1.0
541-73-1 1,3-Dichlorobenzene 1.0
542-75-6 1,3-Dichloropropylene 0.1
542-76-7 3-Chloropropionitrile 1.0
542-88-1 Bis(chloromethyl) ether 0.1
554-13-2 Lithium carbonate 1.0
556-61-6 Methyl isothiocyanate 1.0
[Isothiocyanatomethane]
563-47-3 3-Chloro-2-methyl-l-propene 0.1
569-64-2 C.I. Basic Green 4 1.0
584-84-9 Toluene-2,4-diisocyanate 0.1
593-60-2 Vinyl bromide 0.1
594-42-3 Perchloromethyl mercaptan 1.0
606-20-2 2,6-Dinitrotoluene 0.1
608-93-5 Pentachlorobenzene *
612-82-8 3,3'-Dimethylbenzidine 0.1
dihydrochloride (o-Tolidine dihydrochloride)
612-83-9 3,3'-Dichlorobenzidine 0.1
dihydrochloride
11-16 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
De Minimis
CAS Number Chemical Name Limit
615-05-4
615-28-1
621-64-7
624-18-0
624-83-9
630-20-6
636-21-5
639-58-7
680-31-9
684-93-5
709-98-8
759-73-9
759-94-4
764-41-0
812-04-4
834-12-8
2,4-Diaminoanisole
1 ,2-Phenylenediamine
dihydrochloride
N-Nitrosodi-n-propylamine
1 ,4-Phenylenediamine
dihydrochloride
Methyl isocyanate
1,1, 1 ,2-Tetrachloroethane
o-Toluidine hydrochloride
Triphenyltin chloride
Hexamethyrphosphoramide
N-Nitroso-N-methylurea
Propanil (N-(3,4-Dichlorophenyl)
propanamide)
N-Nitroso-N-ethylurea
Ethyl dipropylthiocarbamate
(EPTC)
1 ,4-Dichloro-2-butene
1 , 1 -Dichloro- 1 ,2,2-trifluoroethane
(HCFC-123b)
Ametryn
0.1
1.0
0.1
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
0.1
1.0
1.0
1.0
1.0
(N-Ethyl-N'-(l-methylethyl)-6-(methylthio)-
842-07-9
872-50-4
924-16-3
924-42-5
957-51-7
961-11-5
989-38-8
1114-71-2
1120-71-4
1134-23-2
1163-19-5
1313-27-5
1314-20-1
1319-77-3
1320-18-9
1330-20-7
1332-21-4
1335-87-1
1336-36-3
1344-28-1
1464-53-5
1563-66-2
1,3,5, -triazine-2,4-diamine)
C.I. Solvent Yellow 14
N-Methyl-2-pyrrolidone
N-Nitrosodi-n-butylamine
N-Methylolacrylamide
Diphenamid
Tetrachlorvinphos
[Phosphoric acid, 2-chloro-l-(2,4,5-
trichlorophenyl)ethenyldimethyl ester]
C.I. Basic Red 1
Pebulate
[Butylethylcarbamothioic acid S-propyl
ester]
Propane sultone
Cycloate
Decabromodiphenyl oxide
Molybdenum trioxide
Thorium dioxide
Cresol (mixed isomers)
2,4-D propylene glycol butyl
ether ester
Xylene (mixed isomers)
Asbestos (friable)
Hexachloronaphthalene
Polychlorinated biphenyls (PCBs)
Aluminum oxide (fibrous forms)
Diepoxybutane
Carbofuran
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
*
1.0
0.1
1.0
CAS Number Chemical Name
De Minimis
Limit
1582-09-8 Trifluralin *
[Benezeneamine, 2,6-dinitro-N,N-dipropyl-4-
(trifluoromethyl)-]
1634-04-4 Methyl tert-butyl ether 1.0
1649-08-7 l,2-Dichloro-l,l-difluoroethane 1.0
(HCFC-132b)
1689-84-5 Bromoxynil 1.0
(3,5-Dibromo-4-hydroxybenzonitrile)
1689-99-2 Bromoxynil octanoate 1.0
(Octanoic acid, 2,6-dibromo-4-cyanophenyl
ester)
1717-00-6 1,1-Dichloro-l-fluoroethane 1.0
(HCFC-141b)
1836-75-5 Nitrofen 0.1
[Benzene, 2,4-dichloro-1 -(4-nitrophenoxy)-]
1861-40-1 Benfluralin 1.0
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)benzenamine)
1897-45-6 Chlorothalonil 0.1
[1,3-Benzenedicarbonitrile, 2,4,5,6-
tetrachloro-]
1910-42-5 Paraquat dichloride 1.0
1912-24-9 Atrazine 1.0
(6-Chloro-N-ethyl-N' -(1 -methylethyl)-1,3,5-
triazine-2,4-diamine)
1918-00-9 Dicamba 1.0
(3,6-Dichloro-2-methoxybenzoic acid)
1918-02-1 Picloram 1.0
1918-16-7 Propachlor 1.0
[2-Chloro-N-( 1 -methylethyl)-N-
phenylacetamide]
1928-43-4 2,4-D 2-ethylhexyl ester 0.1
1929-73-3 2,4-D butoxyethyl ester 0.1
1929-82-4 Nitrapyrin 1.0
(2-Chloro-6-(trichloromethyl)pyridine)
1937-37-7 C.I. Direct Black 38 0.1
1982-69-0 Sodium dicamba 1.0
[3,6-Dichloro-2-methoxybenzoic acid,
sodium salt]
1983-10-4 Tributyltin fluoride 1.0
2032-65-7 Methiocarb 1.0
2155-70-6 Tributyltin methacrylate 1.0
2164-07-0 Dipotassium endothall 1.0
[7-Oxabicyclo(2.2.1)heptane-2,3-dicarboxylic
acid, dipotassium salt]
2164-17-2 Fluometuron 1.0
[Urea, N,N-dimethyl-N'-[3-
(trifluoromethyl)pheny 1] -]
2212-67-1 Molinate 1.0
(lH-Azepine-1-carbothioic acid, hexahydro-
S-ethyl ester)
Toxics Release Inventory Reporting Form and Instructions 11-17
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
2234-13-1 Octachloronaphthalene 1.0
2300-66-5 Dimethylamine dicamba 1.0
2303-16-4 Diallate 1.0
[Carbamothioic acid, bis(l-methylethyl)-S-
(2,3-dichloro-2-propenyl) ester]
2303-17-5 Triallate 1.0
2312-35-8 Propargite 1.0
2439-01-2 Chinomethionat 1.0
[6-Methyl-1,3 -dithiolo [4,5-b]quinoxalin-2-
one]
2439-10-3 Dodine 1.0
[Dodecylguanidine monoacetate]
2524-03-0 Dimethyl chlorothiophosphate 1.0
2602-46-2 C.I. Direct Blue 6 0.1
2655-15-4 2,3,5-Trimethyrphenyl methyl 1.0
carbamate
2699-79-8 Sulfuryl fluoride (Vikane) 1.0
2702-72-9 2,4-D sodium salt 0.1
2832-40-8 C.I. Disperse Yellow 3 1.0
2837-89-0 2-Chloro-l,U,2- 1.0
tetrafluoroethane (HCFC-124)
2971-38-2 2,4-D Chlorocrotyl ester 0.1
3118-97-6 C.I. Solvent Orange 7 1.0
3383-96-8 Temephos 1.0
3653-48-3 Methoxone sodium salt 0.1
((4-Chloro-2-methylphenoxy) acetate
sodium salt)
3761-53-3 C.I. Food Red 5 0.1
4080-31-3 l-(3-Chloroallyl)-3,5,7-triaza-l- 1.0
azoniaadamantane chloride
4170-30-3 Crotonaldehyde 1.0
4549-40-0 N-Nitrosomethylvinylamine 0.1
4680-78-8 C.I. Acid Green 3 1.0
5234-68-4 Carboxin 1.0
(5,6-Dihydro-2-methyl-N-phenyl-l,4-
oxathiin-3 -carboxamide)
5598-13-0 Chlorpyrifos methyl 1.0
[O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate]
5902-51-2 Terbacil 1.0
[5-Chloro-3 -(1,1 -dimethylethyl)-6-methyl-
2,4(lH,3H)-pyrimidinedione]
6459-94-5 C.I. Acid Red 114 0.1
7287-19-6 Prometryn 1.0
[N,N' -Bis( 1 -methylethyl)-6-methylthio-
1,3,5-triazine-2,4-diamine]
7429-90-5 Aluminum (fume or dust) 1.0
7439-92-1 Lead *
(when lead is contained in stainless steel,
brass or bronze alloys the de minimis level is
0.1)
7439-96-5 Manganese 1.0
7439-97-6 Mercury *
CAS Number Chemical Name
De Minimis
Limit
7440-02-0 Nickel 0.1
7440-22-4 Silver 1.0
7440-28-0 Thallium 1.0
7440-36-0 Antimony 1.0
7440-38-2 Arsenic 0.1
7440-39-3 Barium 1.0
7440-41-7 Beryllium 0.1
7440-43-9 Cadmium 0.1
7440-47-3 Chromium 1.0
7440-48-4 Cobalt 0.1
7440-50-8 Copper .0
7440-62-2 Vanadium (except when contained .0
in an alloy)
7440-66-6 Zinc (fume or dust) .0
7550-45-0 Titanium tetrachloride .0
7632-00-0 Sodium nitrite .0
7637-07-2 Boron trifluoride .0
7647-01-0 Hydrochloric acid .0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
7664-39-3 Hydrogen fluoride 1.0
7664-41-7 Ammonia 1.0
(includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium
salts and other sources; 10 percent of total
aqueous ammonia is reportable under this
listing)
7664-93-9 Sulfuric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
7696-12-0 Tetramethrin 1.0
[2,2-Dimethy 1-3-(2-methyl-1-
propenyl)cyclopropanecarboxylic acid
(l,3,4,5,6,7-hexahydro-l,3-dioxo-2H-
isoindol-2-yl)methyl ester]
7697-37-2 Nitric acid .0
7723-14-0 Phosphorus (yellow or white) .0
7726-95-6 Bromine .0
7758-01-2 Potassium bromate 0.1
7782-41-4 Fluorine
7782-49-2 Selenium
7782-50-5 Chlorine
7786-34-7 Mevinphos
7803-51-2 Phosphine
8001-35-2 Toxaphene *
8001-58-9 Creosote 0.1
9006-42-2 Metiram 1.0
10028-15-6 Ozone 1.0
10034-93-2 Hydrazine sulfate 0.1
10049-04-4 Chlorine dioxide 1.0
11-18 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
10061-02-6 trans-l,3-Dichloropropene 0.1
10294-34-5 Boron trichloride 1.0
10453-86-8 Resmethrin 1.0
[[5-(Phenylmethyl)-3-furanyl]methyl-
2,2-dimethyl-3 -(2-methyl-1 -propenyl)
cy clopropanecarboxylate] ]
12122-67-7 Zineb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
zinc complex]
12427-38-2 Maneb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
manganese complex]
13194-48-4 Ethoprop 1.0
[Phosphorodithioic acid O-ethyl S,S-
dipropyl ester]
13356-08-6 Fenbutatin oxide 1.0
(Hexakis(2-methyl-2-phenylpropyl)
distannoxane)
13463-40-6 Iron pentacarbonyl 1.0
13474-88-9 l,l-Dichloro-l,2,2,3,3- 1.0
pentafluoropropane (HCFC-225cc)
13684-56-5 Desmedipham 1.0
14484-64-1 Ferbam 1.0
[Tris(dimethylcarbamodithioato-S, S ')iron]
15972-60-8 Alachlor 1.0
16071-86-6 C.I. Direct Brown 95 0.1
16543-55-8 N-Nitrosonornicotine 0.1
17804-35-2 Benomyl 1.0
19044-88-3 Oryzalin 1.0
[4-(Dipropylamino)-3,5-
dinitrobenzenesulfonamide]
19666-30-9 Oxydiazon 1.0
[3-[2,4-Dichloro-5-(l-methylethoxy)
phenyl] -5-( 1,1 -dimethylethyl)-1,3,4-
oxadiazol-2(3H)-one]
20325-40-0 3,3'-Dimethoxybenzidine 0.1
dihydrochloride (o-Dianisidine
dihydrochloride)
20354-26-1 Methazole 1.0
[2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
oxadiazolidine-3,5-dione]
20816-12-0 Osmium tetroxide 1.0
20859-73-8 Aluminum phosphide 1.0
21087-64-9 Metribuzin 1.0
21725-46-2 Cyanazine 1.0
22781-23-3 Bendiocarb 1.0
[2,2-Dimethyl-l,3-benzodioxol-4-ol
methylcarbamate]
23564-05-8 Thiophanate methyl 1.0
CAS Number Chemical Name
De Minimis
Limit
23564-06-9
23950-58-5
25311-71-1
25321-14-6
25321-22-6
25376-45-8
26002-80-2
26471-62-5
26628-22-8
26644-46-2
27314-13-2
28057-48-9
28249-77-6
28407-37-6
29082-74-4
29232-93-7
30560-19-1
31218-83-4
33089-61-1
34014-18-1
34077-87-7
35367-38-5
Thiophanate ethyl 1.0
[[l,2-Phenylenebis(iminocarbonothioyl)]
biscarbamic acid diethyl ester]
Pronamide 1.0
Isofenphos 1.0
[2-[[Ethoxyl[(l-methylethyl)-
amino]phosphinothioyl]oxy]benzoic acid 1-
methylethyl ester]
Dinitrotoluene (mixed isomers) 1.0
Dichlorobenzene (mixed isomers) 0.1
Diaminotoluene (mixed isomers) 0.1
Phenothrin 1.0
[2,2-Dimethy 1-3-(2-methyl-1-
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester]
Toluene diisocyanate 0.1
(mixed isomers)
Sodium azide 1.0
Triforine 1.0
[N,N'-[ 1,4-Piperazinediylbis (2,2,2-
trichloroethylidene)]bisformamide]
Norflurazon 1.0
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)phenyl]-3(2H)-pyridazinone]
d-trans - Allethrin 1.0
[d-trans-Chrysanthemic acid of d-allethrone]
Thiobencarb 1.0
[Carbamic acid, diethylthio-, S-(p-
chlorobenzyl)ester]
C.I. Direct Blue 218
Octachlorostyrene
Pirimiphos methyl
[O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-dimethylphosphorothioate]
Acephate 1.0
(Acetylphosphoramidothioic acid O,S-
dimethyl ester)
Propetamphos 1.0
[3-[(Ethylamino)
methoxyphosphinothioyl]oxy]-2-butenoic
acid, 1-methylethyl ester]
Amitraz 1.0
Tebuthiuron 1.0
[N-[5-(l,l-Dimethylethyl)-l,3,4-thiadiazol-2-
y 1] -N,N' -dimethy lurea]
Dichlorotrifluoroethane 1.0
Diflubenzuron 1.0
1.0
*
1.0
Toxics Release Inventory Reporting Form and Instructions 11-19
-------
Table II
CAS Number Chemical Name
De Minimis
Limit
35400-43-2
35554-44-0
35691-65-7
38727-55-8
39156-41-7
39300-45-3
39515-41-8
40487-42-1
41198-08-7
41766-75-0
42874-03-3
43121-43-3
50471-44-8
51235-04-2
51338-27-3
51630-58-1
52645-53-1
53404-19-6
53404-37-8
53404-60-7
55290-64-7
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
Sulprofos
[O-Ethyl O-[4-(methylthio)phenyl]-
phosphorodithioic acid S-propyl ester]
Imazalil
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl]-lH-imidazole]
1 -Bromo-1 -(bromomethy 1)-1,3 -
propanedicarbonitrile
Diethatyl ethyl
2,4-Diaminoanisole sulfate
Dinocap
Fenpropathrin
[2,2,3,3 -Tetramethylcyclopropane
carboxylic acid cyano(3-
phenoxyphenyl)methyl ester]
Pendimethalin
[N-(l-Ethyrpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine]
Profenofos
[O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
propyl phosphorothioate]
3,3'-Dimethylbenzidine 0.1
dihydrofluoride (o-Tolidinedihydrofluoride)
Oxyfluorfen 1.0
Triadimefon 1.0
[ 1 -(4-Chlorophenoxy)-3,3-dimethyl-1 -(1H-
1,2,4-triazol- l-yl)-2-butanone]
Vinclozolin 1.0
[3-(3,5-Dichlorophenyl)-5-ethenyl-5-methyl-
2,4-oxazolidinedione]
Hexazinone
Diclofop methyl
[2-[4-(2,4-Dichlorophenoxy)-
phenoxy]propanoic acid, methyl ester]
Fenvalerate
[4-Chloro-alpha-( 1 -methylethyl)-
benzeneacetic acid cyano(3-
phenoxyphenyl)methyl ester]
Permethrin
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropane carboxylic acid,
(3-phenoxyphenyl)methyl ester]
Bromacil, lithium salt
[2,4(lH,3H)-Pyrimidinedione, 5-bromo-6-
methyl-3-(l-methylpropyl), lithium salt]
2,4-D 2-ethyl-4-methylpentyl 0.1
ester
Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-1,3,5-
thiadiazine-2-thione, ion(l-), sodium]
Dimethipin 1.0
[2,3 -Dihydro-5,6-dimethyl-1,4-dithiin
1,1,4,4-tetraoxide]
1.0
1.0
1.0
1.0
1.0
CAS Number Chemical Name
De Minimis
Limit
55406-53-6
57213-69-1
59669-26-0
60168-88-9
60207-90-1
62476-59-9
63938-10-3
64902-72-3
64969-34-2
66441-23-4
67485-29-4
1.0
68085-85-8
68359-37-5
69409-94-5
69806-50-4
71751-41-2
72178-02-0
72490-01-8
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
3-Iodo-2-propynyl butyl
carbamate
Triclopyr triethylammonium salt
Thiodicarb
Fenarimol
[.alpha.-(2-Chlorophenyl)-.alpha.-(4-
chlorophenyl)-5-pyrimidinemethanol]
Propiconazole
[l-[2-(2,4-Dichlorophenyl)-4-propyl-
1,3 -dioxolan-2-yl] -methyl- 1H- 1,2,4,-triazole]
Acifluorfen, sodium salt 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-2-
nitrobenzoic acid, sodium salt]
Chlorotetrafluoroethane
Chlorsulfuron
[2-Chloro-N-[[(4-methoxy-6-methyl-
l,3,5-triazin-2-yl)amino] carbonyl]
benzenesulfonamide]
3,3'-Dichlorobenzidine sulfate
Fenoxaprop ethyl
[2-(4-((6-Chloro-2-
benzoxazolylen)oxy)phenoxy)propanoic acid,
ethyl ester]
Hydramethylnon 1.0
[Tetrahydro-5,5-dimethyl-2(lH)-
py rimidinone [3 - [4-(trifluoromethy l)pheny 1] -
1 - [2- [4-(trifluoromethy l)phenyl] ethenyl] -2-
propenylidene] hy drazone]
Cyhalothrin 1.0
[3-(2-Chloro-3,3,3-trifluoro-1-propenyl)-2,2-
dimethylcyclopropanecarboxylic acid
cyano(3-phenoxyphenyl) methyl ester]
Cyfluthrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid,
cyano(4-fluoro-3 -phenoxyphenyl) methyl
ester]
Fluvalinate 1.0
[N-[2-Chloro-4-(trifluoromethyl)phenyl]DL-
valine(+)-cyano(3-phenoxyphenyl)methyl
ester]
Fluazifop butyl 1.0
[2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]phenoxy]propanoic acid, butyl
ester]
Abamectin [Avermectin B1 ] 1.0
Fomesafen 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-N-
methylsulfonyl)-2-nitrobenzamide]
Fenoxycarb 1.0
[[2-(4-Phenoxy phenoxy)ethyl]carbamic acid
ethyl ester]
11-20 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
CAS Number Chemical Name
DeMinimis appear. However, for purposes of the supplier notification
Limit requirement only, such limits are provided in Appendix D.
74051-80-2 Sethoxydim
[2-[ 1 -(Ethoxyimino)butyl] -5-[2-
(ethylthio)propyl] -3 -hydroxyl-2-cyclohexen-
1-one]
76578-14-8 Quizalofop-ethyl
[2-[4-[(6-Chloro-2-quinoxalinyl)
oxy]phenoxy]propanoic acid ethyl ester]
77501-63-4 Lactofen
[Benzoic acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy]-2-nitro-, 2-
ethoxy-l-methyl-2-oxoethyl ester]
82657-04-3 Bifenthrin 1.0
88671-89-0 Myclobutanil 1.0
[.alpha.-Butyl-.alpha.-(4-chlorophenyl)-lH-
1,2,4-triazole-1 -propanenitrile]
90454-18-5 Dichloro-l,l,2-trifluoroethane 1.0
90982-32-4 Chlorimuron ethyl 1.0
[Ethyl-2-[[[[(4-chloro-6-methoxyprimidin-2-
y l)amino] carbony 1]
amino] sulfony l]benzoate]
101200-48-0 Tribenuron methyl 1.0
[2-[[[[(4-Methoxy-6-methyl-l,3,5-triazin-2-
y l)methylamino] carbony 1]
amino] sulfonyl]benzoic acid methyl ester]
111512-56-2 l,l-Dichloro-l,2,3,3,3- 1.0
pentafluoropropane (HCFC-225eb)
111984-09-9 3,3'-Dimethoxybenzidine 0.1
hydrochloride (o-Dianisidine hydrochloride)
127564-92-5 Dichloropentafluoropropane 1.0
128903-21-9 2,2-Dichloro-l, 1,1,3,3- 1.0
pentafluoropropane (HCFC-225aa)
136013-79-1 1,3-Dichloro-l, 1,2,3,3- 1.0
pentafluoropropane (HCFC-225ea)
c. Chemical Categories
Section 313 requires reporting on the EPCRA Section 313
chemical categories listed below, in addition to the specific
EPCRA Section 313 chemicals listed above.
The metal compound categories listed below, unless otherwise
specified, are defined as including any unique chemical
substance that contains the named metal (e.g., antimony, nickel,
etc.) as part of that chemical's structure.
EPCRA Section 313 chemical categories are subject to the 1%
de minimis concentrationunless the substance involved meets the
definition of an OSHA carcinogen in which case the 0.1% de
minimis concentration applies. The de minimis concentration for
each category is provided in parentheses. The de minimis
exemption is not available for PBT chemicals, therefore an
asterisk appears where a de minimis limit would otherwise
1.0 N010 Antimony Compounds (1.0)
Includes any unique chemical substance that contains
antimony as part of that chemical's infrastructure.
1.0 N020 Arsenic Compounds (inorganic compounds: 0.1;
organic compounds: 1.0)
Includes any unique chemical substance that
1.0 contains arsenic as part of that chemical's
infrastructure.
N040 Barium Compounds (1.0)
Includes any unique chemical substance that
contains barium as part of that chemical's
infrastructure. This category does not include:
Barium sulfate CAS Number 7727-43-7
N050 Beryllium Compounds (0.1)
Includes any unique chemical substance that
contains beryllium as part of that chemical's
infrastructure.
N078 Cadmium Compounds (0.1)
Includes any unique chemical substance that
contains cadmium as part of that chemical's
infrastructure.
N084 Chlorophenols (0.1)
OH
•H(5-x)
Where x = 1 to 5
N090 Chromium Compounds
(except for chromite ore mined in the Transvaal
Region of South Africa and the unreacted ore
component of the chromite ore processing residue
(COPR). COPR is the solid waste remaining after
aqueous extraction of oxidized chromite ore that
has been combined with soda ash and kiln roasted
at approximately 2,000 deg.F.)
(chromium VI compounds: 0.1; chromium III
compounds: 1.0)
Includes any unique chemical substance that contains
chromium as part of that chemical's infrastructure.
Toxics Release Inventory Reporting Form and Instructions 11-21
-------
Table II
N096 Cobalt Compounds (0.1)
Includes any unique chemical substance that contains
cobalt as part of that chemical's infrastructure.
N100 Copper Compounds (1.0)
Includes any unique chemical substance that contains
copper as part of that chemical's infrastructure. This
category does not include copper phthalocyanine
compounds that are substituted with only hydrogen,
and/or chlorine, and/or bromine.
N106 Cyanide Compounds (1.0)
X+CN~ where X = H+ or any other group where a
formal dissociation can be made. For example KCN
or Ca(CN)2.
N120 Diisocyanates (1.0)
This category includes only those chemicals listed
below.
3 8661 -72-2 1,3 -Bis(methylisocyanate) -
cyclohexane
10347-54-3 l,4-Bis(methylisocyanate)-
cyclohexane
2556-36-7 1,4-Cyclohexane
diisocyanate
134190-37-7 Diethyldiisocyanatobenzene
4128-73-8 4,4'-Diisocyanatodiphenyl
ether
75790-87-3 2,4'-Diisocyanatodiphenyl
sulfide
91-93-0 3,3'-Dimethoxybenzidine-
4,4'-diisocyanate
91-97-4 3,3'-Dimethyl-4,4'-
diphenylene diisocyanate
139-25-3 3,3'-Dimethyldiphenyl
methane-4,4'-diisocyanate
822-06-0 Hexamethylene-1,6-
diisocyanate
4098-71-9 Isophorone diisocyanate
75790-84-0 4-Methyldiphenylmethane-3,4-
diisocyanate
5124-30-1 l,l-Methylenebis(4-
isocyanatocyclohexane)
101-68-8 Methylenebis(phenylisocyanate)
(MDI)
3173-72-6 1,5-Naphthalene
diisocyanate
123-61-5 1,3-Phenylene diisocyanate
104-49-4 1,4-Phenylene diisocyanate
9016-87-9 Polymeric diphenylmethane
diisocyanate
16938-22-0 2,2,4-Trimethylhexamethylene
diisocyanate
15646-96-5 2,4,4-Trimethylhexamethylene
diisocyanate
N150 Dioxin and Dioxin-Like Compounds
(Manufacturing; and the processing or otherwise
use of dioxin and dioxin-like compounds if the
dioxin and dioxin-like compounds are present as
contaminants in a chemical and if they were
created during the manufacturing of that
chemical.) (*) This category includes only those
chemicals listed below. [Note: When completing the
FormR, Part II, Section 1.4, enter the distribution
percent estimates for each of the dioxin and dioxin-like
compounds chemical category members in the order
they are listed here (i.e., 1-17).]
1,2,3,4,6,7,8-
Heptachlorodibenzofuran
1,2,3,4,7,8,9-
Heptachlorodibenzofuran
1,2,3,4,7,8-
Hexachlorod-benzofuran
1,2,3,6,7,8-
Hexachlorodibenzofuran
1,2,3,7,8,9-
Hexachlorodibenzofuran
2,3,4,6,7,8-
Hexachlorodibenzofuran
1,2,3,4,7,8-
Hexachlorodibenzo-p-dioxin
1,2,3,6,7,8-
Hexachlorodibenzo-p-dioxin
1,2,3,7,8,9-
Hexachlorodibenzo-p-dioxin
1,2,3,4,6,7,8-
Heptachlorodibenzo-p-dioxin
1,2,3,4,6,7,8,9-
Octachlorodibenzofuran
1,2,3,4,6,7,8,9-
Octachlorodibenzo-p-dioxin
1,2,3,7,8-
Pentachlorodibenzofuran
2,3,4,7,8-
Pentachlorodibenzofuran
1,2,3,7,8-
Pentachlorodibenzo-p-dioxin
2,3,7,8-
Tetrachlorodibenzofuran
2,3,7,8-
Tetrachlorodibenzo-p-dioxin
N171 Ethylenebisdithiocarbamic acid, salts and esters
(EBDCs) (1.0)
Includes any unique chemical substance that contains
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
67562-39-4
55673-89-7
70648-26-9
57117-44-9
72918-21-9
60851-34-5
39227-28-6
57653-85-7
19408-74-3
35822-46-9
39001-02-0
3268-87-9
57117-41-6
57117-31-4
40321-76-4
51207-31-9
1746-01-6
11-22 Toxics Release Inventory Reporting Forms and Instructions
-------
Table II
an EBDC or an EBDC salt as part of that chemical's
infrastructure.
N230 Certain Glycol Ethers (1.0)
R-(OCH2CH2)n-OR'
where n = 1, 2, or 3
R = alkyl C7 or less; or
R = phenyl or alkyl substituted phenyl;
R' = H, or alkyl C7 or less; or
OR' consisting of carboxylic acid ester, sulfate, phosphate,
nitrate, or sulfonate.
N420 Lead Compounds (*)
Includes any unique chemical substance that contains
lead as part of that chemical's infrastructure.
N450 Manganese Compounds (1.0)
Includes any unique chemical substance that contains
manganese as part of that chemical's infrastructure.
N458 Mercury Compounds (*)
Includes any unique chemical substance that contains
mercury as part of that chemical's infrastructure.
N495 Nickel Compounds (0.1)
Includes any unique chemical substance that contains
nickel as part of that chemical's infrastructure.
N503 Nicotine and salts (1.0)
Includes any unique chemical substance that contains
nicotine or a nicotine salt as part of that chemical's
infrastructure.
N511 Nitrate compounds (water dissociable; reportable
only when in aqueous solution) (1.0)
N575 Polybrominated Biphenyls (PBBs) (0.1)
N583
H(10-x)
Where x = 1 to 10
Polychlorinated alkanes (C10 to C13) (1.0, except for
those members of the category that have an average
chain length of 12 carbons and contain an average
chlorine content of 60% by weight which are subject
to the 0.1% de minimis)
CH, , Cl
X 2X+2-J J
where x= 10 to 13;
y = 3 to 12; and
the average chlorine content ranges from 40 — 70% with
the limiting molecular formulas C10H19C13 and C13H16C112
N590 Polycyclic aromatic compounds (PACs) (*)
This category includes the chemicals listed below.
56-55-3 Benzo(a)anthracene
205-99-2 Benzo(b)fluoranthene
205-82-3 Benzo(j)fluoranthene
207-08-9 Benzo(k)fluoranthene
206-44-0 Benzo(j,k)fluorene
189-55-9 Benzo(r,s,t)pentaphene
218-01-9 Benzo(a)phenanthrene
50-32-8 Benzo(a)pyrene
226-36-8 Dibenz(a,h)acridine
224-42-0 Dibenz(a,j)acridine
53-70-3 Dibenzo(a,h)anthracene
194-59-2 7H-Dibenzo(c,g)carbazole
5385-75-1 Dibenzo(a,e)fluoranthene
192-65-4 Dibenzo(a,e)pyrene
189-64-0 Dibenzo(a,h)pyrene
191-30-0 Dibenzo(a,l)pyrene
57.97-6 7,12-Dimethylbenz(a)-
anthracene
193-39-5 Indeno(l,2,3-cd)pyrene
56-49-5 3-Methylcholanthrene
3697-24-3 5-Methylchrysene
5522-43-0 1-Nitropyrene
N725 Selenium Compounds (1.0)
Includes any unique chemical substance that contains
selenium as part of that chemical's infrastructure.
N740 Silver Compounds (1.0)
Includes any unique chemical substance that contains
silver as part of that chemical's infrastructure.
N746 Strychnine and salts (1.0)
Includes any unique chemical substance that contains
strychnine or a strychnine salt as part of that chemical's
infrastructure.
N760 Thallium Compounds (1.0)
Includes any unique chemical substance that contains
thallium as part of that chemical's infrastructure.
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
Toxics Release Inventory Reporting Form and Instructions 11-23
-------
chemical's infrastructure.
N982 Zinc Compounds (1.0)
Includes any unique chemical substance that contains
zinc as part of that chemical's infrastructure.
11-24 Toxics Release Inventory Reporting Forms and Instructions
-------
Table III. State Abbreviations
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Marshall Islands
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
AL
AK
AS
AZ
AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL
IN
IA
KS
KY
LA
ME
MH
MD
MA
MI
MN
MS
MO
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Northern Marianas Islands
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
MT
NE
NV
NH
NJ
NM
NY
NC
ND
MP
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
WI
WY
Toxics Release Inventory Reporting Forms and Instructions III-l
-------
This Page Intentionally Left Blank
-------
Table IV. Federal Information Processing Standards (FIPS) Codes
AA
AC
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
Aruba
Antigua and
Barbuda
United Arab
Emirates
Afghanistan
Algeria
Azerbaijan
Albania
Armenia
Andorra
Angola
Argentina
Australia
Ashmore and
Cartier Islands
Austria
Anguilla
Antarctica
Bahrain
Barbados
Botswana
Bermuda
Belgium
The Bahamas
Bangladesh
Belize
Bosnia and
Herzegovina
Bolivia
Burma
Benin
Belarus
Solomon Islands
Brazil
Bassas da India
Bhutan
Bulgaria
Bouvet Island
Brunei
Burundi
Canada
Cambodia
Chad
CE
CF
CG
CH
CI
CJ
CK
CM
CN
CO
CR
CS
CT
CU
CV
CW
CY
DA
DJ
DO
DR
EC
EG
El
EK
EN
ER
ES
ET
EU
EZ
FG
FI
FJ
FK
FO
FP
FR
FS
Sri Lanka
Congo
(Brazzaville)
Congo (Kinshasa)
China
Chile
Cayman Islands
Cocos (Keeling)
Islands
Cameroon
Comoros
Colombia
Coral Sea Islands
Costa Rica
Central African
Republic
Cuba
Cape Verde
Cook Islands
Cyprus
Denmark
Djibouti
Dominica
Dominican
Republic
Ecuador
Egypt
Ireland
Equatorial Guinea
Estonia
Eritrea
El Salvador
Ethiopia
Europa Island
Czech Republic
French Guiana
Finland
Fiji
Falkland Islands
(Islas Malvinas)
Faroe Islands
French Polynesia
France
French Southern
and Antarctic
Lands
GA The Gambia
GB Gabon
GG Georgia
GH Ghana
GI Gibraltar
GJ Grenada
GK Guernsey
GL Greenland
GM Germany
GO Glorioso Islands
GP Guadeloupe
GR Greece
GT Guatemala
GV Guinea
GY Guyana
GZ Gaza Strip
HA Haiti
HK Hong Kong
HM Heard Island and
McDonald Islands
HO Honduras
HR Croatia
HU Hungary
1C Iceland
ID Indonesia
EVI Isle of Man
IN India
IO British Indian
Ocean Territory
IP Clipperton Island
IR Iran
IS Israel
IT Italy
IV Cote DTvoire
IZ Iraq
JA Japan
JE Jersey
JM Jamaica
JN Jan Mayen
JO Jordan
JU Juan de Nova
Island
Toxics Release Inventory Reporting Form and Instructions IV-1
-------
Table IV
KE
KG
KN
KQ
KR
KS
KT
KU
KZ
LA
LE
LG
LH
LI
LO
LS
LT
LU
LY
MA
MB
MC
MD
MF
MG
MH
MI
MK
ML
MN
MO
MP
MR
MT
MU
MV
MX
MY
MZ
NC
NE
NF
NG
NH
NI
NL
Kenya
Kyrgyzstan
North Korea
Kingman Reef
Kiribati
South Korea
Christmas Island
Kuwait
Kazakhstan
Laos
Lebanon
Latvia
Lithuania
Liberia
Slovakia
Liechtenstein
Lesotho
Luxembourg
Libya
Madagascar
Martinique
Macau
Moldova
Mayotte
Mongolia
Montserrat
Malawi
Macedonia
Mali
Monaco
Morocco
Mauritius
Mauritania
Malta
Oman
Maldives
Mexico
Malaysia
Mozambique
New Caledonia
Niue
Norfolk Island
Niger
Vanuatu
Nigeria
Netherlands
NO
NP
NR
NS
NT
NU
NZ
PA
PC
PE
PF
PG
PK
PL
PM
PO
PP
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
Norway
Nepal
Nauru
Suriname
Netherlands
Antilles
Nicaragua
New Zealand
Paraguay
Pitcairn Islands
Peru
Paracel Islands
Spratly Islands
Pakistan
Poland
Panama
Portugal
Papua New Guinea
Palau
Guinea-Bissau
Qatar
Reunion
Romania
Philippines
Russia
Rwanda
Saudi Arabia
St. Pierre and
Miquelon
St. Kitts and Nevis
Seychelles
South Africa
Senegal
St. Helena
Slovenia
Sierra Leone
San Marino
Singapore
Somalia
Spain
St. Lucia
Sudan
Svalbard
Sweden
South Georgia and
South Sandwich
SY
SZ
TD
TE
TH
TI
TK
TL
TN
TO
TP
TS
TT
TU
TV
TW
TX
TZ
UG
UK
UP
UV
UY
UZ
VC
VE
VI
VM
VT
WA
WE
WF
WI
WS
WZ
YI
YM
ZA
ZI
Islands
Syria
Switzerland
Trinidad and
Tobago
Tromelin Island
Thailand
Tajikistan
Turks and Caicos
Islands
Tokelau
Tonga
Togo
Sao Tome and
Principe
Tunisia
East Timor
Turkey
Tuvalu
Taiwan
Turkmenistan
Tanzania
Uganda
United Kingdom
Ukraine
Burkina Faso
Uruguay
Uzbekistan
St. Vincent and the
Grenadines
Venezuela
British Virgin
Islands
Vietnam
Vatican City
Namibia
West Bank
Wallis and Futuna
Western Sahara
Western Samoa
Swaziland
Yugoslavia
Yemen
Zambia
Zimbabwe
IV-2 Toxics Release Inventory Reporting Form and Instructions
-------
Appendix A. Federal Facility Reporting Information
Special Instructions for TRI Federal
Facility Reporting
Why Do Federal Facilities
Need to Report?
Executive Order 13148, Greening the Government Through
Leadership in Environmental Management, requires federal
agencies to comply with the Emergency Planning and
Community Right-To-Know Act of 1986 (EPCRA) and the
Pollution Prevention Act of 1990 (PPA). Federal facilities
have been subject to EPCRA section 313 and PPA since
reporting year 1994. TRI submissions are due to EPA on
July 1 of the year following each reporting (calendar) year.
Reporting by the federal facility does not alter the reporting
obligation of on-site contractors. "Nothing in this order
alters the obligations under EPCRA, PPA, and CAA
independent of this order for Government-owned,
contractor-operated facilities and Government corporations
owning or operating facilities or subjects such facilities to
EPCRA, PPA, or CAA if they are otherwise excluded.
However, each agency shall include the releases and other
waste management of chemicals for all such facilities to
meet the agency's reporting responsibilities under section
501 of this order." Section 902(c).
Identifying Federal Facility Reports
Federal facility reports are identified as federal by several
indicators on the form. The facility name and parent
company name are critical indicators and must be reported
as described below. Another critical indicator is the federal
facility report box, Part I, 4.2c. Federal facilities only
should check this box to indicate that the report is from a
federal agency for a federal facility; federal facilities should
not check the GOCO box, (Part I, Section 4.2d of the Form
R). Contractors located at federal facilities (GOCOs) should
check the GOCO box (Part I, Section 4.2d of the Form R);
they should not check the box 4.2c. Facilities should also
complete the partial or complete facility blocks (Form R
page 2, block 4.2a and 4.2b) as appropriate. If you are a
federal facility reporting for the first time, you should write
"new" in the TRI Facility ID (TRIFID) box, even if a
contractor has reported for your facility in the past. The
contractor will retain the original TRIFID. You will be
assigned a new TRIFID the first time you report.
The "Double Counting" Problem
As structured, the law and the executive order require both
regulated industries and the federal government to report TRI
data, sometimes for the same site. In order to prevent duplicate
data in the TRI database, which could result in "double counting"
data for some chemicals and locations, EPA must be able to
identify and distinguish the "Government Owned Contractor
Operated" (GOCO) reports submitted by the federal contractor
from the federal facility reports which contain data for the same
site. To accomplish this, federal facility reports should be
accompanied by either 1) exact copies (paper or electronic) of all
contractor TRI reports, including when the totals reported by the
federal facility are greater than that reported by the contractor(s),
or 2) a cover letter which includes a list of the facility contractors
which submit TRI reports to EPA, identifying each contractor by
name, TRI technical contact, and TRI facility name and address.
Additionally, federal facilities should check Form R, Part I,
Section 4.2c, while contractors at federal facilities should check
Form R, Part I, Section 4.2d.
Magnetic Media Reporting
EPA encourages all federal facilities and GOCO facilities to
report using either EPA's Magnetic Media reporting software, or
one of the commercially available packages. If the GOCO
submits its reports on magnetic media to EPA and to the federal
facility, the federal facility may submit magnetic media copies of
their GOCO TRI reports to EPA provided that those reports
account for all subject activities at the facility. Magnetic media
reports must be accompanied by a cover letter which includes:
D Required Form R certification statement;
D List of the chemicals reported on the federal facility's
disk; and
D List that identifies the contractors) [if any] by name
and and by TRIFID number if they have an assigned
TRIFID number, and the chemicals they reported
(which are on the contractors' attachment disk(s))
How to Report Your Facility Name
Facility name is a critical data element. It is used by EPA to
create the TRI facility ID number, which is a unique number
designed to identify a facility site. The facility name and
TRIFID number are used by all TRI data users to link data from
a single site across multiple reporting years. A federal facility is
assigned a new TRIFID number when the federal report is
Toxics Release Inventory Reporting Forms and Instructions A-l
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Appendix A
entered into the Toxics Release Inventory system for the
first time. This TRIFID number, generated when the first
report is entered into the Toxics Release Inventory System,
will be included in future reporting packages sent to the
federal facility, and should be used by the federal facility in
all future reports.
Federal facilities should report their facility name on page 1
of the Form Rs (Section 4.1), as shown in the following
example:
U.S. DOE Savannah River Site
It is very important that the agency name appear first,
followed by the specific plant or site name.
Federal contractors at GOCO facilities should report their
names as shown in the following example:
U.S. DOE Savannah River Site — Westinghouse
Operations.
How to Report Your Standard
Industrial Classification (SIC) Code
Federal facilities should report the SIC code which most
closely represents the activities taking place at the site.
Additional guidance on determining your SIC code is
provided in the Forms and Instructions booklet. The table
on the next page contains Public Administration SIC codes
91-97 covering executive, legislative, judicial,
administrative and regulatory activities of the Federal
government. Government-owned and operated business
establishments are classified in major SIC groups 01-89
according to the activity in which they are engaged. For
example, a Veterans Hospital would be classified in Group
806 — Hospitals.
How to Report Your "Parent
Company" Name
Federal facilities should report their parent company name
on page 2 of the Form Rs (Section 5.1) by reporting their
complete Department or Agency name, as shown in the
following example:
U.S. Department of Energy
Block 5.2, Parent Company's Dun & Bradstreet Number,
should be marked NA.
Federal contractors at GOCO facilities should not report a federal
department or agency name as their parent company. A federal
name in the parent company name field will classify the report
as federal, and the GOCO may be identified as a non-reporter.
How to Revise Your Data After It Has Been
Submitted
Any TRI Form R submitter may voluntarily revise their
submission if they find errors after their reports have been sent
to EPA. If the revision is to a hardcopy report, the facility should
photocopy the original form, you should use a blue or black pen
to mark out the incorrect value and write in the corrected value.
The revised report should be submitted to EPA, with an "X" in
the revision block on page 1 of the Form R. If the revision is to
a diskette, a new diskette should be submitted, containing the
data only for the revised submission, not all the chemicals
originally reported. If a federal facility receives a copy of a
revision from a contractor located at the federal facility, the
facility should revise the federal report, and submit the revised
report to EPA and the appropriate state along with an exact copy
of the contractor's revision. The cover letter from the federal
facility should indicate that its submission is a revision.
National Security Data
DO NOT SUBMIT NATIONAL SECURITY DATA TO THE
TRI DATA PROCES SING CENTER. National security data are
handled through a separate process. Facilities should consult the
Guidance for Implementing Executive Order 12856 documents
(this guidance for Executive Order 12856, which was superceded
by Executive Order 13148, still applies for national security
issues) or call the EPCRA Call Center if their Form R
submission involves a national security data claim.
Who Should Sign Federal Form R
Reports?
Federal Form R reports should be signed by the senior federal
employee on-site. If no federal employee is on-site, federal Form
R reports must be signed by the senior federal employee with
management responsibility for the site. Federal Form R reports
should be signed by a federal employee. Contractor employee
signatures are not considered valid on federal reports.
A-2 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix A
More Help is Available!
Federal facilities may call EPA's EPCRA Call Center to
ask specific questions concerning how to submit their
Form R reports. For contact information, see the TRI
Home Page at .
Standard Industrial Classification
Codes 91-97
Division J — Public Administration
91 Executive, Legislative, and
General Government, Except
Finance
9111 Executive Offices
9121 Legislative Bodies
9131 Executive and Legislative Offices Combined
9199 General Government, Not Elsewhere Classified
92 Justice, Public Order, and
Safety
9211 Courts
9221 Police Protection
9222 Legal Counsel and Prosecution
9223 Correctional Institutions
9224 Fire Protection
9229 Public Order and Safety, Not Elsewhere Classified
93 Public Finance, Taxation, and
Monetary Policy
9311 Public Finance, Taxation, and Monetary Policy
94 Administration of Human
Resource Programs
9411 Administration of Educational Programs
9431 Administration of Public Health Programs
9441 Administration of Social, Human
Resource and Income Maintenance
Programs
9451 Administration of Veterans' Affairs,
Except Health and Insurance
95 Administration of Environmental Quality
and Housing Programs
9511 Air and Water Resource and Solid Waste Management
9512 Land, Mineral, Wildlife, and Forest Conservation
9531 Administration of Housing Programs
9532 Administration of Urban Planning and Community and
Rural Development
96 Administration of Economic
Programs
9611 Administration of General Economic
Programs
9621 Regulation and Administration of
Transportation Programs
9631 Regulation and Administration of
Communications, Electric, Gas, and Other
Utilities
9641 Regulation of Agricultural Marketing and
Commodities
9651 Regulation, Licensing, and Inspection of
Miscellaneous Commercial Sectors
9661 Space Research and Technology
97 National Security and International
Affairs
9711 National Security
9721 International Affairs
Toxics Release Inventory Reporting Forms and Instructions A-3
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This Page Intentionally Left Blank
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Appendix B. Reporting Codes For EPA Form R and Instructions for
Reporting Metals
Form R Part II
Section 1.1. CAS Number
EPCRA Section 313 Chemical Category Codes
NO 10 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N150 Dioxin and dioxin-like compounds
N171 Ethylenebisdithiocarbamic
acid, salts and esters (EBDCs)
N230 Certain glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N503 Nicotine and salts
N511 Nitrate compounds
N575 Polybrominated biphenyls (PBBs)
N583 Polychlorinated alkanes
N590 Poly cyclic aromatic compounds
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N770 Vanadium compounds
N874 Warfarin and salts
N982 Zinc compounds
Section 4. Maximum Amount of the Toxic
Chemical On- Site at Any Time During the
Calendar Year
Weight Range in Pounds
Range Code
01
02
03
04
05
06
07
08
09
10
11
From...
0
100
1,000
10,000
100,000
1,000,000
10,000,000
50,000,000
100,000,000
500,000,000
1 billion
To....
99
999
9,999
99,999
999,999
9,999,999
49,999,999
99,999,999
499,999,999
999,999,999
more than 1 billion
Section 5. Quantity of the Non- PBT Chemical
Entering Each Environmental Medium On-site
and Section 6. Transfers of the Toxic Chemical
in Wastes to Off- Site Locations
Total Release or Transfer
Code
A
B
C
Basis of Estimate
Range Obs)
1-10
11-499
500-999
M: Estimate is based on monitoring data or measurements
for the EPCRA section 313 chemical as transferred to
an off-site facility.
C: Estimate is based on mass balance calculations, such as
calculation of the amount of the EPCPxA section 313
chemical in waste streams entering and leaving process
equipment.
E: Estimate is based on published emission factors, such
as those relating release quantity to through-put or
equipment type (e.g., air emission factors).
O: Estimate is based on other approaches such as
engineering calculations (e.g., estimating volatilization
using published mathematical formulas) or best
Toxics Release Inventory Reporting Forms and Instructions B-l
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Appendix B
engineering judgment. This would include applying
an estimated removal efficiency to a treatment, even if
the composition of the waste before treatment was
fully identified through monitoring data.
Section 6. Transfers of the Toxic Chemical in
Wastes to Off- Site Locations
Type of Waste Disposal/ Treatment/Energy
Recovery/ Recycling
M10 Storage Only
M20 Solvents/Organics Recovery
M24 Metals Recovery
M26 Other Reuse or Recovery
M28 Acid Regeneration
M40 Solidification/Stabilization
M41 Solidification/Stabilization-Metals and Metal
Category Compounds only
M50 Incineration/Thermal Treatment
M54 Incineration/Insignificant Fuel Value
M56 Energy Recovery
M61 Wastewater Treatment (Excluding POTW)
M62 Wastewater Treatment (Excluding POTW) — Metals
and Metal Category Compounds only
M64 Other Landfills
M65 RCRA Subtitle C Landfills
M66 Subtitle C Surface Impoundment
M67 Other Surface Impoundments
M69 Other Waste Treatment
M73 Land Treatment
M79 Other Land Disposal
M81 Underground Injection to Class I Wells
M82 Underground Injection to Class II-V Wells
M90 Other Off-Site Management
M92 Transfer to Waste Broker — Energy Recovery
M93 Transfer to Waste Broker — Recycling
M94 Transfer to Waste Broker — Disposal
M95 Transfer to Waste Broker — Waste Treatment
M99 Unknown
Section 7A. On- Site Waste Treatment Methods
and Efficiency
General Waste Stream
A Gaseous (gases, vapors, airborne particulates)
W Wastewater (aqueous waste)
L Liquid waste streams (non-aqueous waste)
S Solid waste streams (including sludges and slurries)
Waste Treatment Methods
Air Emissions Treatment
A01 Flare
A02 Condenser
A03 Scrubber
A04 Absorber
A05 Electrostatic Precipitator
A06 Mechanical Separation
A07 Other Air Emission Treatment
Biological Treatment
B11 Biological Treatment — Aerobic
B21 Biological Treatment — Anaerobic
B31 Biological Treatment — Facultative
B99 Biological Treatment — Other
Chemical Treatment
CO 1 Chemical Precipitation — Lime or Sodium
Hydroxide
C02 Chemical Precipitation — Sulfide
C09 Chemical Precipitation — Other
C11 Neutralization
C21 Chromium Reduction
C31 Complexed Metals Treatment (other than
pH Adjustment)
C41 Cyanide Oxidation — Alkaline Chlorination
C42 Cyanide Oxidation — Electrochemical
C43 Cyanide Oxidation — Other
C44 General Oxidation (Including Disinfection)—
Chlorination
C45 General Oxidation (Including Disinfection) —
Ozonation
C46 General Oxidation (Including Disinfection) — Other
C99 Other Chemical Treatment
Incineration/ Thermal Treatment
F01 Liquid Injection
F11 Rotary Kiln with Liquid Injection Unit
F19 Other Rotary Kiln
F31 Two Stage
F41 Fixed Hearth
F42 Multiple Hearth
F51 FluidizedBed
F61 Infra-Red
F71 Fume/Vapor
F81 Pyrolytic Destructor
F82 Wet Air Oxidation
F83 Thermal Drying/Dewatering
F99 Other Incineration/Thermal Treatment
B-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix B
Physical Treatment
P01 Equalization
P09 Other Blending
P11 Settling/Clarification
P12 Filtration
P13 Sludge Dewatering (Non-thermal)
P14 Air Flotation
P15 Oil Skimming
P16 Emulsion Breaking — Thermal
P17 Emulsion Breaking — Chemical
P18 Emulsion Breaking — Other
P19 Other Liquid Phase Separation
P21 Adsorption — Carbon
P22 Adsorption — Ion Exchange (Other than for
recovery/reuse)
P23 Adsorption — Resin
P29 Adsorption — Other
P31 Reverse Osmosis (Other than for recovery/reuse)
P41 Stripping — Air
P42 Stripping — Steam
P49 Stripping — Other
P51 Acid Leaching (Other than for recovery/reuse)
P61 Solvent Extraction (Other than for recovery/reuse)
P99 Other Physical Treatment
Solidification/ Stabilization
G01 Cement Processes (Including Silicates)
G09 Other Pozzolonic Processes (Including Silicates)
Gil Asphaltic Processes
G21 Thermoplastic Techniques
G99 Other Solidification Processes
Range of Influent Concentration
1 = Greater than 10,000 parts per million (1 percent)
2 = 100 parts per million (0.01 percent) to 10,000 parts
per million (1 percent)
3 = 1 part per million (0.0001 percent) to 100 parts per
million (0.01 percent)
4 = 1 part per billion to 1 part per million
5 = Less than 1 part per billion
[Note: Parts per million (ppm) is milligrams/kilogram
(mass/mass) for solids and liquids; cubic centimeters/cubic
meter (volume/volume) for gases; milligrams/liter for solutions
or dispersions of the chemical in water; and milligrams of
chemical/kilogram of air for particulates in air. If you have
paniculate concentrations (at standard temperature and pressure)
as grains/cubic foot of air, multiply by 1766.6 to convert to parts
per million; if in milligrams/cubic meters, multiply by 0.773 to
obtain parts per million. Factors are for standard conditions of
0°C (32°F) and 760 mmHg atmospheric pressure.]
Section 7B. On- Site Energy Recovery Processes
U01 Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
Section 7C. On- Site Recycling Processes
Rl 1 Solvents/Organics Recovery — Batch Still
Distillation
R12 Solvents/Organics Recovery — Thin-Film
Evaporation
R13 Solvents/Organics Recovery — Fractionation
R14 Solvents/Organics Recovery — Solvent Extraction
R19 Solvents/Organics Recovery — Other
R21 Metals Recovery — Electrolytic
R22 Metals Recovery — Ion Exchange
R23 Metals Recovery — Acid Leaching
R24 Metals Recovery — Reverse Osmosis
R26 Metals Recovery — Solvent Extraction
R27 Metals Recovery — High Temperature
R28 Metals Recovery — Retorting
R29 Metals Recovery — Secondary Smelting
R30 Metals Recovery — Other
R40 Acid Regeneration
R99 Other Reuse or Recovery
Section 8 .10. Source Reduction Activity Codes
Good Operating Practices
W13 Improved maintenance scheduling, record keeping,
or procedures
W14 Changed production schedule to minimize equipment
and feedstock changeovers
W19 Other changes in operating practices
Inventory Control
W21 Instituted procedures to ensure that materials do not
stay in inventory beyond shelf-life
W22 Began to test outdated material — continue to use if
still effective
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labeling procedures
W25 Instituted clearinghouse to exchange materials that
Toxics Release Inventory Reporting Forms and Instructions B-3
-------
Appendix B
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 810 Methods Used to Identify Source
Reduction Activities
For each source reduction activity, enter up to three of the
following codes that correspond to the method(s) which
contributed most to the decision to implement that activity.
TO 1 Internal Pollution Prevention Opportunity Audit(s)
T02 External Pollution Prevention Opportunity Audit(s)
T03 Materials Balance Audits
T04 Participative Team Management
T05 Employee Recommendation (independent of a
formal company program)
T06 Employee Recommendation (under a formal
company program)
T07 State Government Technical Assistance
Program
T08 Federal Government Technical Assistance Program
T09 Trade Association/Industry Technical
Assistance Program
T10 Vendor Assistance
Til Other
B-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix B
Reporting the Waste Management of Metals.
This appendix outlines how the TRI-ME 2003 reporting software restricts reporting for metals when the specific data element or
waste management code is not applicable for a particular chemical. Below is a list of metals divided into four groups along with
charts that help explain where quantities of these chemicals can and can not be reported on the Form R using TRI-ME. In
addition, there are charts that explain restrictions on reporting waste management codes for the toxic chemicals in each of the four
groups. This appendix only shows where reporting is restricted in TRI-ME, it does not indicate every situation where a metal
should not be reported in a specific section of the form. For example, TRI-ME does not restrict the reporting of most individually-
listed metal compounds as used for energy recovery (Sections 8.2 and 8.3) even though some of these chemicals do not have a
heat value greater that 5000 British thermal units (Btu) and thus, can not be combusted for energy recovery. It is left to the facility
to decide which of these toxic chemicals can be used for energy recovery. If you are not using TRI-ME this appendix can serve as
a guide to help you understand where it is not appropriate to report certain quantities of toxic chemicals or waste management
codes on your Form R.
Parent Metals:
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Metal Compound
Categories:
Antimony Compounds
Arsenic Compounds
Barium Compounds
Beryllium Compounds
Cadmium Compounds
Chromium Compounds1
Cobalt Compounds
Copper Compounds
Lead Compounds
Manganese Compounds
Mercury Compounds
Nickel Compounds
Selenium Compounds
Silver Compounds
Thallium Compounds
Vanadium Compounds
Zinc Compounds
Metals with
Qualifiers:
Aluminum (fume or dust)
Vanadium (except when
in an alloy)
Zinc (fume or dust)
Individually- Listed
Metal Compounds:
Bis(tributylin) oxide
Triphenyltin hydroxide
Triphenyltin chloride
Molybdenum trioxide
Thorium dioxide
Asbestos (friable)
Aluminum oxide (fibrous
forms)
Tributyltin fluoride
Tributyltin methacrylate
Titanium tetrachloride
Boron trifluoride
Metiram
Boron trichloride
Zineb
Maneb
Fenbutatin oxide
Iron pentacarbonyl
Ferbam
C.I. Direct Brown 95
Osmium tetroxide
Aluminum phosphide
C.I. Direct Blue 218
Except for chromite ore mined in the Transvaal Region of South Africa and the unreacted ore component of the
chromite ore processing residue (COPR). COPR is the solid waste remaining after aqueous extraction of oxidized chromite ore
that has been combined with soda ash and kiln roasted at approximately 2,000 deg.F.
Toxics Release Inventory Reporting Forms and Instructions B-5
-------
Appendix B
Sections 5.3 - Discharges to Water and 6.1 - Transfers to POTW's
The following chart indicates which metals can be reported as released to water in Section 5.3 or to POTW's in Section 6.1. Only
zinc (fume or dust) and aluminum (fume or dust) are not reported in these sections because the fume or dust form of a toxic
chemical can not exist in water.
Form R Section in Part II
Section 5.3 - Discharges to receiving streams or water
bodies
Section 6.1- Discharges to POTWs
Parent
Metals
All
All
Metal
Category
Compounds
All
All
Metals with
Qualifiers
Vanadium
(except
when
contained in
an alloy)
Vanadium
(except
when
contained in
an alloy)
Individually-
listed Metal
Compounds
All except
Asbestos
All except
Asbestos
Section 6.2. Transfers to Other Off Site Locations
Any toxic chemical may be reported in Section 6.2, however, TRI-ME will not allow certain M codes to be used when reporting metals. The
chart below indicates which M codes can be reported in Section 6.2 for the four groups of metals. Note that all disposal M codes
other than M41 and M62 can be used for all toxic chemicals. Code M24 is only made available for the four groups of metals.
Waste Management Code for Section
6.2
M41 and M62 (disposal codes-for metals only)
M56 and M92 (energy recovery codes)
M20 and M28 (recycling codes)
M24, M26 and M93 (recycling codes)
M40, M50, M54, (treatment codes)
Parent
Metals
All
None
None
All
None
Metal
Category
Compounds
All
None
None
All
None
Metals with
Qualifiers
Vanadium
(except when
contained in an
alloy)
None
None
All
All except
Vanadium
(except when
contained in an
alloy)
Individually-
listed Metal
Compounds
All except
Asbestos
All except
Asbestos 2
All
All
All
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.
B-6 Toxics Release Inventory Reporting Forms and Instructions
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Appendix B
M61, M69, M95 (treatment codes)
Barium3
Barium
Compounds3
Same as above
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 can be selected.
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
Asbestos4
Section 7C. On-site Recycling Processes
Any chemical can be reported in Section 7C, however, certain waste management codes should not be reported for certain toxic
chemicals. The chart below indicates which codes can be reported in Section 7C when using TRI-ME. Treatment code R99,
which is not listed in this chart, can be reported for any toxic chemical.
Recycling Code for Section 7C
R21, R22, R23, R24, R26, R27, R28, R29, R30
(these codes are for metals only)
R12, R13,R14, R19, R40
Parent Metals
All
None
Metal
Category
Compounds
All
None
Metals with
Qualifiers
All
None
Individually-
listed Metal
Compounds
All
All
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 a barium compound to barium sulfate is considered
treatment for destruction (40 CFR Section 372.3).
Although TRI-ME does not restrict reporting of most individually-listed metal compounds in Sections 7B, 8.2 or 8.3,
only chemicals with a heat value greater than 5000 British thermal units that are combusted in a device that is an industrial
furnace or boiler (40 CFR Section 372.3) should be reported in these sections.
Toxics Release Inventory Reporting Forms and Instructions B-7
-------
Appendix B
Section 8. Source Reduction and Recycling Activities
The chart below indicates which metals can be reported in Sections 8.2, 8.3, 8.6 and 8.7 of the Form R when using TRI-ME. Note
that all toxic chemicals can Appendix B be reported in Sections 8.1, 8.4, 8.5 and 8.8.
Waste Management Activity
Quantity used for energy recovery on site and off site
(Sections 8.2 and 8.3)
Quantity treated for destruction on site and off site
(Sections 8.6 and 8.7)
Parent
Metals
None
None
except
Barium5
Metal
Category
Compounds
None
None except
Barium
Compounds5
Metals with
Qualifiers
None
All except
Vanadium
(except
when
contained in
an alloy)
Individually-
listed Metal
Compounds
All except
Asbestos4
All
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 a barium compound to barium sulfate is considered
treatment for destruction (40 CFR Section 372.3).
B-8 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix C. Facility Data Profiles and Common Errors in Completing
Form R Reports and Form A Certifications
EPA wishes to ensure that facilities submit all required TRI chemical submissions in a timely manner so that the information may be
included in its national database, annual public data release, and other information products. Moreover, EPA seeks to ensure that all
submitted data is complete and accurate. This appendix provides an overview of Facility Data Profiles (FDPs), an important
communication tool that EPA uses to ensure consistent, complete, and accurate submissions from reporting facilities. This appendix
also provides specific guidance to avoid common errors in completing Form Rs and Form A Certification Statements, including errors
in threshold determination, misapplication of exemptions, and overlooking activities involving a reportable chemical, any of which
may result in mistaken non-reporting of a chemical.
A. Facility Data Profile (FDP)
Facility Data Profiles (FDPs) are made available by TRI Data
Processing Center to a reporting facility in response to any
submission the TRI Data Processing Center receives. You may
review your FDP on the internet at http://www.triefdp.org. It is
very important that you review your FDP. If the Technical
Contact provided an email address in the Form R/Form A, they
will receive a real-time email notifying them when their FDP
has been updated and posted to the FDP website. A submission
can include an original or revised Form R or Form A, or
corrections included 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. If the data presented on a facility's FDP do not
match those on the form(s) it submitted, or if the TRI Data
Processing Center has identified errors in a facility's
submissions, or if a facility discovers errors in its submitted
data, the facility may use the FDP to make the needed
corrections. The FDP does not serve as a means to withdraw a
Form R and/or Form A. For additional information regarding
withdrawal procedures see Section A.5 of this document or go
to . If you have questions regarding your
FDP, please send an email to tri.efdp@csc.com or call, 1-301-
429-5005. Facilities that send corrections to their FDPs are
encouraged to submit a revision using CDX. For additional
instructions regarding your FDP, please refer to you FDP.
An FDP is comprised of the following sections:
D Facility Information. This section displays all
facility specific data, including TRI Facility
Identification, facility name, facility address, facility
mailing address, relevant permits (e.g., RCRA,
NPDES, andUIC), Standard Industrial Classification
code (SIC), and other facility data. Errors related to
facility information will be provided in this section.
Instructions Page. This page provides instructions
on how to review and respond to the FDP.
Certification Statement Signature Page. This page
provides the Certification Statement to be signed by
a facility owner/operator or senior management
official if using the FDP to make a revision.
Chemical Report Summary. This section lists all
chemicals reported by the facility for each reporting
year covered by the FDP. For example, if the FDP is
responding to five original chemical submissions for
Reporting Year 1999 and revisions to one chemical
for Reporting Year 1998, a list of all chemicals for
both years will appear.
Errors/Alerts Identified In This Report: Non-
Technical Data Changes (NDC), Notices of
Technical Errors (NOTE), Notices of Significant
Error (NOSE), and Data Quality Alerts (DQA).
FDPs identify three different types of errors: NDCs,
NOTEs and NOSEs and alerts called Data Quality
Alerts (DQA). See explanations in section B.
Error Summary Page. The Error Summary Page
provides facilities an error/alert count for each
chemical submission.
Chemical Reports. All recently processed Form R
or Form A submission data (i.e., chemical specific
data) are displayed here under the appropriate facility
or subordinate facility names. The FDP displays
facsimiles for chemical reports for submissions
received during the current calendar year, revisions
or responses to FDPs only. For example, if a facility
originally reported five chemicals for Reporting Year
1998, and subsequently revises only one chemical
submission, the facility will receive a FDP for
Reporting Year 1998 with only the revised chemical
included in the Chemical Reports section. Hence
there may be fewer chemical reports than chemicals
listed in the Chemical Summary section. If only
Toxics Release Inventory Reporting Forms and Instructions C-l
-------
Appendix C
facility level changes have occurred (i.e., Part I of the
Form R or A), this section is not provided.
B. Levels of Errors Identified in FDPs:
Notice of Non-Technical Data Change
(NDC), Notice of Technical Errors
(NOTE), Notice of Significant Errors
(NOSE). Notice of Noncompliance (NON).
FDP Error Reporting. In addition to "echoing back" the
information a facility has submitted, FDPs are used to identify
potential errors and provide Data Quality Alerts, as well as
indicate where the 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 TPJ Facility Identification, facility name, county spelling, as
well as to perform validation checks to ensure consistency
among data elements within a given Form R or Form A. These
data quality checks, however, cannot detect whether release,
transfer, or waste management quantities were calculated or
entered accurately. Within a FDP notice, there may be up to
three different types of errors identified.
First, a Non-Technical Data Change (NDC) notifies you of
simple, clerical errors that the TRI Data Processing Center has
corrected for you. It is not necessary to respond to a NDC. The
TRI Data Processing Center will correct simple, clerical errors
that are not technical or scientific — a "non-technical data
change." For example, if a facility transposes CAS numbers
(e.g., the submitter lists 7623-00-0 for sodium nitrite instead of
7632-00-0), the TRI Data Processing Center will correct this
clerical error and display the correct information on the
facility's FDP. If a facility lists a specific glycol ethers
subcategory, the TRI Data Processing Center will replace this
subcategory with the reportable name "certain glycol ethers."
The messages used on FDPs to report non-technical data
changes are shown at the end of this appendix under the
heading "E. Messages Used to Report Notices of Technical
Errors (NOTEs) and Non-technical Data Changes (NDCs)."
Second, a Notice of Technical Error (NOTE) highlights
inconsistencies or miscalculations that may distort your
facility's information in EPA's public data products or skew
analyses. Incomplete addresses, no technical or public contact
provided, missing or invalid SIC codes, or the use of range
codes to report PBT chemical releases are all examples of
technical errors. You should respond to NOTEs as soon as
possible. These types of errors require that the reporting facility
make corrections on its FDP (or provide the TRI Data
Processing Center with a brief explanation why they do not
believe that it is an error) or submit a revised Form R or Form
A. Depending upon when your changes are received, there
may or may not be sufficient time to incorporate them into
EPA's database in time for public data release. Technical
errors do not prevent submissions from being entered into the
data management system, but indicate inconsistencies or
miscalculations in the submitted form. These errors can distort
public information products and skew any analyses if not
corrected. The messages used on FDPs to report NOTEs are
shown below at the end of this appendix under the heading "E.
Messages Used to Report Notices of Technical Errors
(NOTEs) and Non-technical Data Changes (NDCs)."
Third, more serious errors are classified as Notices of
Significant Errors (NOSE). The FDP contains the Notice of
Significant Error if applicable. Significant errors prevent
submissions from being entered into the TRI Data Processing
Center data management system or do not allow the TRI Data
Processing Center to verify the authenticity of the submission.
Invalid forms, missing pages, no certification signature, no
chemical name or CAS number are examples of significant
errors. These types of errors require that the reporting facility
make corrections on their FDP, submit a revised Form R or
Form A, or provide the TRI Data Processing Center with a
brief explanation why they do not believe that it is an error. A
facility must respond to a Notice of Significant Error within 21
days of receipt. Failure to respond within the initial 21 day
requirement could result in the issuance of a Notice of
Noncompliance (NON). A Notice of Noncompliance is not
included in a FDP and is mailed separately.
The Agency will issue a conditional Notice of
Noncompliance (NON) to a facility for failure to respond to
a Notice of Significant Error (NOSE) within the required
period. A NON will require a facility to take the corrective
action noted in the NOSE within 21 days and respond to the
Agency that corrective action has been taken. If a facility fails
to respond to the NON within the required time period, the
Agency may take further action.
Facilities must keep copies, for three years, of submitted Form
R reports and Form A certifications and all documentation
used to complete their submissions. This documentation
should include calculations for threshold determinations, the
basis of exemptions applied, and the estimation techniques and
data used for all quantities reported on the Form R and Form
A.
For the first time beginning with RY 2004, TRI will provide
Data Quality Alerts (DQA). The DQA informs facilities of
possible reporting issues. It is offered to assist facilities in
ensuring accurate reporting.
C-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
C. Common Errors in Completing Form R
Reports and Form A Certification Statements,
including Reporting Determination Errors
General Considerations
D 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.
D Incomplete Forms. A complete Form R report for a
single EPCRA section 313 chemical or single EPCRA
section 313 chemical category consists of five pages
stapled together. By using TRI-ME and CDX, errors
such as this would not occur. Each chemical
submission must have its own page one. EPA cannot
enter into the database data from a package that
contains only one page 1, but several page 2s, 3s, 4s,
and/or 5s. Such forms are considered incomplete
submissions.
Threshold Determinations
D Calculating threshold determinations. Annual
quantities manufactured, processed, or otherwise used
for section 313 chemicals must be calculated, not
surmised. The assumption that thresholds are exceeded
commonly leads to error.
D Misclassification of EPCRA section 313 chemical
activity. Failure to correctly classify an EPCRA
section 313 chemical activity may result in an incorrect
threshold determination. As a result, a facility may fail
to submit the required Form R.
D EPCRA section 313 chemical activity overlooked.
Many facilities believe that because the section 313
reporting requirement pertains to manufacturers, only
the use of EPCRA section 313 chemicals in
manufacturing processes must be examined. Any
activity involving the manufacture, process, or
otherwise use of an EPCRA section 313 chemical or
chemical category must be included in threshold
determinations. Commonly overlooked activities
include importation of chemicals, generation of waste
byproducts, processing of naturally occurring metals
and metal category compounds in ore, manufacturing
and processing of reaction intermediates, the use of
chemicals for cleaning of equipment, and the generation
of byproducts during combustion of coal and/or oil.
Facilities should take a systematic approach to identify
all chemicals and mixtures used in production and
non-production capacities, including catalysts, well
treatment chemicals, and wastewater treatment
chemicals.
D Considering EPCRA section 313 chemicals in
mixtures and other trade name products. EPCRA
section 313 chemicals contained in mixtures (including
ores and stainless steel alloys) and other trade name
products must be factored into threshold determinations
and release and other waste management
determinations, provided that the de minimis exemption
cannot be taken. When the EPCRA section 313
chemical being reported is a component in a mixture or
other trade name product, report only the weight of the
EPCRA section 313 chemical in the mixture. Refer to
Section B.4b of this document to calculate the weight
of an EPCRA section 313 chemical in a mixture or
other trade name product.
D 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
D 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
-------
Appendix C
Part I. Facility Identification Information
Section 1. Reporting Year
D 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
D Incorrect completion of trade secret information.
The responses to trade secret questions in Part I
Section 2 and Part II Section 1.3 of Form R/Form A
must be consistent. If trade secrecy is indicated, a
sanitized Form R/Form A and two trade secret
substantiations (one sanitized) must be submitted in the
same package as the unsanitized trade secret Form
R/Form A. Part II Section 1.3 should be blank if no
trade secret claim is being made. Also, if you indicate
in Part I, Section 2.1 that you are not claiming trade
secret information, leave Part I, 2.2 blank.
Section 3. Certification
D 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
D Incorrect latitude and longitude coordinates.
Latitude and longitude coordinates should be
determined using the correct measurement techniques
and reported in degrees, minutes, and seconds. For
additional guidance, see Appendix E of this document.
D "Questionable" entries. Incorrect entries may require
corrections to be made by the facility. The use of the
TRI-ME software would prevent such errors from
occurring. Questionable entries may include:
• Missing or incorrect street address;
• Missing or incorrect ZIP codes;
• Missing County names;
• Invalid SIC codes;
• Missing or invalid Dun & Bradstreet
numbers;
• Missing or invalid RCRA, NPDES, or UIC
numbers; and
• Incomplete off-site and POTW
information (e.g., missing city name)
If amounts are reported in units other than pounds (e.g., metric
units) or with exponential numbers, EPA may require a
revision of the Form R/Form A submitted. The exception is
for the reporting of dioxin and dioxin-like compounds where
the amounts are reported in grams.
Part II. Chemical-Specific Information
Section 1. Toxic Chemical Identity
D Reporting chemical abstract service (CAS) numbers
in Section 1.1. Beginning with the 1991 reporting year,
EPA has assigned alphanumeric category codes to the
twenty chemical categories for the purposes of
reporting the CAS number field in Section 1.1. When
completing a Form R for a chemical category, the
appropriate code for that category must be provided in
Section 1.1. The CAS numbers are listed in Table II:
"Section 313 Toxic Chemical List," and if needed, the
category codes are listed in Appendix B: "Reporting
CodesforEPAFormR." Category guidance documents
are listed in the Chemical and Industry Guidance
Documents section in this document.
D 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)."
D 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.
D 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
C-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix C
313 chemical are those that manufacture isopropyl
alcohol by the strong acid process.
D 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
D 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.
D 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
D Reporting EPCRA section 313 chemical activity.
EPCRA section 313 chemical activity is commonly
overlooked or misclassified. Any activity involving the
manufacture, process, or otherwise use of an EPCRA
section 313 chemical must be examined. For example,
waste treatment operations otherwise use EPCRA
section 313 chemicals to treat waste streams and may
coincidentally manufacture an additional EPCRA
section 313 chemical as a result of the treatment
reaction. Such activity must be considered. Further,
EPCRA section 313 chemical activity must be correctly
classified as either "manufactured," "processed," or
"otherwise used."
Section 3.1 "Manufacture"means to produce, prepare,
compound, or import an EPCRA section
313 chemical.
Section 3.2 "Process" means the preparation of an
EPCRA section 313 chemical after its
manufacture, which usually includes the
incorporation of the EPCRA section 313
chemical into the final product, for
distribution in commerce.
Section 3.3 "Otherwise use" encompasses any use of an
EPCRA section 313 chemical that does not
fall under the terms "manufacture" or
"process," and includes treatment for
destruction, stabilization (without
subsequent distribution in commerce),
disposal, and other use of an EPCRA
section 313 chemical, including an EPCRA
section 313 chemical contained in a mixture
or other trade name product. Otherwise use
of an EPCRA section 313 chemical does not
include disposal, stabilization (without
subsequent distribution in commerce), or
treatment for destruction unless:
1. The EPCRA section 313 chemical that was
disposed, stabilized, or treated for
destruction was received from off-site for
the purposes of further waste management;
or
2. The EPCRA section 313 chemical that was
disposed, stabilized, or treated for
destruction was manufactured as a result of
waste management activities on materials
received from off-site for the purposes of
further waste management activities.
For example, solvents in paint applied to a manufactured
product are often misclassified as processed, instead of
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
D 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
D 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.
D 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
Toxics Release Inventory Reporting Forms and Instructions C-5
-------
Appendix C
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
D 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.
D 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
D 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.
Section 7B. On-Site Energy Recovery Processes
D Incorrect reporting of waste treatment methods in
Section 7A. The type of waste stream, influent
concentration, and waste treatment method for each
waste stream are required to be reported on Form R
using specific codes, along with the waste treatment
efficiency expressed as percent removal. The waste
treatment codes are listed in Appendix B: "Reporting
Codes for EPA Form R," of the Toxic Chemical
Release Inventory Reporting Forms and Instructions.
D 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
D Reporting on-site recycling methods in Section 7C.
When a quantity is reported in Section 8.4 as recycled
on-site, the type of recovery method must be reported
in Section 7C, and vice versa.
Section 8. Source Reduction and Recycling Activities
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.
D 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.
D 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.
D It is incorrect to use the same codes from Section 4 for
reporting the maximum amount of the reported EPCRA
section 313 chemical on-site to report quantities in
Section 8.
D Quantities reported in Section 8.1 through 8.7 are
mutually exclusive and additive. This means that
quantities of the reported EPCRA section 313 chemical
must not be double-counted in Section 8.1 through 8.7.
D Some double-counting errors have been due to
confusion over the differences in how on-site treatment
of an EPCRA section 313 chemical is reported in
Section 7A as compared to Section 8. In Section 7A,
information on the treatment of waste streams
containing the EPCRA section 313 chemical is
reported, along with the percent efficiency in terms of
destruction or removal of the EPCRA section 313
chemical from each waste stream. In Section 8, only the
quantity of the EPCRA section 313 chemical actually
destroyed through the treatment processes reported in
Section 7A is reported in Section 8.6 to avoid
double-counting within Sections 8.1 through 8.7.
C-6 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
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 + § 5.5.1B - § 8.8 (on-site
release or disposal due to catastrophic events)1
§ 8.1b = § 5.1 + § 5.2 + § 5.3 + § 5.4.2 + § 5.5.2 + §
5.5.3A + § 5.5.3B + §5.5.4 - § 8.8 (on-site release or
disposal due to catastrophic events)1
Quantities of EPCRA section 313 chemicals transferred
off-site for the purposes of disposal reported in Section
6.2 using the following codes must appear in Section
8.1c:
a M64 Other Landfills
a M65 RCRA Subtitle C Landfills
D M81 Underground Injection to Class I Wells
§ 8. Ic = § 6.1 (portion of transfer that is untreated and
ultimately disposed of in UIC Class I Wells, RCRA
Subtitle C landfills, and other landfills) + § 6.2
(quantities associated with M codes M64, M65 and
M81) - § 8.8 (off-site disposal due to catastrophic
events)1
Metals and metal category compounds transferred off-
site to POTWs in Section 6.1 must appear in Section
8.1c or 8. Id. To report correctly in Sections 8. la
through d, a facility must include quantities that are
disposed or otherwise released to the environment
either on-site or off-site, excluding disposal or other
releases due to catastrophic events or non-production
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:
d M10 Storage Only
D M41 Solidification/Stabilization — Metals and
Metal Category Compounds Only
D M62 Wastewater Treatment (excluding POTW)
—Metals and Metal Category Compounds Only
D M66 Subtitle C Surface Impoundment
D M67 Other Surface Impoundments
D M73 Land Treatment
D M79 Other Land Disposal
D M82 Underground Inj ection to Class II-V Wells
d M90 Other Off-Site Management
D M94 Transfer to Waste Broker—Disposal
D M99 Unknown.
§8.1d=§6.1 (portion of transfer that is untreated and
ultimately disposed of in UIC Class II-V wells, and
disposal other than to landfills) + § 6.2 (quantities
associated with M codes M10, M41, M62, M66, M67,
M73, M79, M82, M90, M94, M99) - § 8.8 (off-site
disposal due to catastrophic events)1
Reporting quantities in Section 8.2 "Quantity used
for energy recovery on-site." A quantity must be
reported in Section 8.2 for the current (reporting) year
when a method of on-site energy recovery is reported in
Section 7B, and vice versa. An error facilities make
when completing Form R is to report the methods of
energy recovery used on-site in Section 7B but not
report the total quantity associated with those methods.
Another error is to report a quantity in this section if the
combustion of the EPCRA section 313 chemical took
place in a system that did not recover energy (e.g., an
incinerator). A quantity of the EPCRA section 313
chemical combusted for energy recovery must not be
reported if the EPCRA section 313 chemical does not
have a significant heating value. Examples of EPCRA
section 313 chemicals that do not have significant
heating values include metals, metal portions of metal
category compounds, and halons. Metals and metal
portions of metal compounds will never be treated or
combusted for energy recovery. Any quantities of the
EPCRA section 313 chemical associated with
non-production related activities such as catastrophic
releases and remedial actions, as well as other one-time
events not associated with routine production practices
that were combusted for energy recovery on-site must
not be included in Section 8.8.
Reporting quantities in Section 8.3 "Quantity used
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.
Toxics Release Inventory Reporting Forms and Instructions C-7
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Appendix C
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 -
Recovery
- Energy
§ 8.3 = § 6.2 (energy recovery) - § 8.8 (off-site energy
recovery due to catastrophic events)2
Reporting quantities in Section 8.4 "Quantity recycled
on-site." A quantity must be reported in Section 8.4 for
the current reporting year when a method of on-site
recycling is reported in Section 7C, and vice versa. An
error facilities make when completing Form R is to report
the methods of recycling used on-site in Section 7C but
not report the total quantity recovered using those
methods.
In addition, only the amount of the chemical that
was actually recovered is to be reported in Section
8.4. Any quantities of the EPCRA section 313 chemical
associated with non-production related activities such as
catastrophic releases and remedial actions, as well as
other one-time events not associated with routine
production practices that were recycled on-site must not
be included in Section 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:
D M20 Solvents/Organic Recovery
D M24 Metals Recovery
2§8.8 includes quantities of toxic chemical disposed or
otherwise released on-site or managed as waste off-site due to remedial
actions, catastrophic events, or one-time events not associated with the
production processes.
D M26 Other Reuse or Recovery
D M28 Acid Regeneration
D M93 Transfer to Waste Broker — Recycling.
§8.5 = §6.2 (recycling) - §8.8 (off-site recycling due
to catastrophic events)2
Reporting quantities in Section 8.6 "Quantity
treated on-site." Quantities may not always have to be
reported in Section 8.6 when Section 7A is completed.
This is because the information reported in Section 7A
and Section 8 is different. Information on how waste
streams containing the reported EPCRA section 313
chemical are treated is reported in Section 7 A, while the
quantity of the EPCRA section 313 chemical actually
destroyed as a result of on-site treatment is reported in
Section 8.6. If a quantity is reported in Section 8.6,
Section 7 A must be completed but the reverse may not
be true. This may result in apparent discrepancies
between Section 7A and Section 8. For example, a
facility may treat wastewater containing an EPCRA
section 313 chemical by removing the EPCRA section
313 chemical and then disposing of it on-site. The
treatment of the wastewater would be reported in
Section 7A, with an efficiency estimate based on the
amount of the EPCRA section 313 chemical removed
from the wastewater. Although the waste stream has
been treated because the EPCRA section 313 chemical
has been removed, the EPCRA section 313 chemical
has not been treated because it has not been destroyed.
The facility would report only the amount of the
EPCRA section 313 chemical actually destroyed during
treatment in Section 8.6 and the amount ultimately
disposed in Section 8.1 to avoid double-counting the
same quantity in Section 8. In cases where the EPCRA
section 313 chemical is not destroyed during a
treatment process and subsequently enters another
activity, such as disposal (e.g., metals removed from
wastewater and subsequently disposed on-site), the
quantity of the EPCRA section 313 chemical would be
reported as disposed in Section 8.1, not as treated in
Section 8.6. Any quantities of the EPCRA section 313
chemical associated with non-production related
activities such as catastrophic releases and remedial
actions, as well as other one-time events not associated
with routine production practices that were treated for
destruction on-site must not be included in Section 8.8.
Metals generally will not be treated for destruction.
Reporting quantities in Section 8.7 "Quantity
treated off-site." Quantities reported in Section 6.2 as
transferred off-site for the purposes of treatment must
be included in Section 8.7 using the following codes:
C-8 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
D M40 Solidification/Stabilization
D M50 Incineration/Thermal Treatment
D M54 Incineration/Insignificant Fuel Value
D M61 Wastewater Treatment (excluding POTW)
D M69 Other Waste Treatment
D M95 Transfer to Waste Broker — Waste
treatment.
Quantities of anEPCRA section 313 chemical, except
metals and metal category compounds, sent off-site to
a POTW should also be reported in Section 8.7. If you
know, however, that a chemical is not treated for
destruction at the POTW you should report that
quantity in Section 8.1 instead of 8.7.
To report correctly EPCRA section 313 chemicals in
Section 8.7, use the following equation.
§8.7 =§6.1 (excluding most metal/metal category
compounds) + §6.2 (treatment) - §8.8 (off-site
treatment due to catastrophic events)3
Reporting quantities in Section 8.8 "Quantity
released to the environment as a result of remedial
actions, catastrophic events or one-time events not
associated with production processes." The quantities
that are reported in Section 8.8 are associated with
non-production related activities such as catastrophic
releases and remedial actions, as well as one-time
events not associated with routine production practices,
that were disposed or released directly to the
environment or transferred off-site for the purposes of
recycling, energy recovery, treatment or disposal.
Quantities reported in Section 8.8 must not be reported
in Section 8.1 through 8.7.
Reporting the production ratio in Section 8.9. A
production ratio or activity index must be provided in
Section 8.9. A zero is not acceptable and "NA" (Not
Applicable) can be used only when the reported
EPCRA section 313 chemical was not manufactured,
processed, or otherwise used in the year prior to the
reporting year.
Calculating production ratio in Section 8.9. In
calculating a production ratio for "otherwise used"
chemicals, an activity index must be used rather than
quantities purchased or released from year to year.
Reporting source reduction activities in Section 8.10.
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.
It is an error to report a source reduction activity in
Section 8.10 and not report at least one method used to
identify that activity and vice versa.
D. FDP Messages Used to Report Notices
of Significant Errors
Note: EPA is continually trying to improve the error checking
system for TRI submissions. As a result, a small number
of the error messages in this appendix may be changed by
the time the Reporting Year 2004 submissions are
checked. Most of these messages will remain the same.
You can look for changes to these error messages on the
TRI home page at
1. You have used an invalid Form R or Form A by using
either a form not applicable for the reporting year, or a
facsimile form that has not been approved by EPA.
Resubmit your data on a current EPA approved Form R
or A.
2. Pages were missing from the form received. Correct
this by resubmitting a complete certified form for this
chemical substance.
3. Multiple chemicals were reported in your Form R. You
must submit a separate and complete Form R for each
chemical cited.
4. You have provided a valid CAS number and a valid
chemical name, but they do not match. Respond by
providing a valid CAS number and matching chemical
name.
5. You have left part or all of the chemical identification
sections blank. Respond by providing a valid CAS
number and matching chemical name or Mixture
Component Identity.
6. You reported a CAS number and chemical name that
are invalid. Respond by providing a valid CAS number
and matching chemical name.
7. Your form indicated Trade Secret status with an
indication that this form is a Sanitized version, but the
report contains no Generic Chemical Name. You must
provide a Generic Chemical Name for this sanitized
form.
8. You did not sign the Form or certification letter. Per
EPCRA Section 313(g)(l)(B), each submission must
contain an original signature certifying the accuracy
and completeness of the information reported by
signing the certification statement on the Form or
certified letter. Please be sure to sign the certification
statement in this FDP to certify your submission data.
Toxics Release Inventory Reporting Forms and Instructions C-9
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Appendix C
9. You have reported a Persistent Bioaccumulative Toxic
(PBT) chemical on a Form A. PBT chemicals (e.g.,
Dioxin and Dioxin-like Compounds, Lead Compounds,
Mercury Compounds and Polycyclic Aromatic
Compounds (PACs)) are not eligible for the alternate
threshold. Thus, they must be reported on a Form R.
Please resubmit your data on a Form R.
10. 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.
11. You did not complete Part II, Sections 5 and 6. Please
provide the required information; otherwise indicate NA.
12. You did not complete Part II, Section 7. Please provide
the required information; otherwise indicate NA.
13. You did not complete Part II, Section 8. Please provide
the required information; otherwise indicate NA.
E. Messages Used to Report Notices of
Technical Errors (NOTEs) and Non-
technical Data Changes (NDCs)
Invalid codes throughout Form R
14. You submitted an invalid code. To correct this, consult
the instructions for the proper table value and provide
a valid code value. [Specific location on the form of the
invalid code is given.] (NOTE)
15. PBT chemicals (e.g., Dioxin and Dioxin-like
Compounds, Lead Compounds, Mercury Compounds
and Polycyclic Aromatic Compounds (PACs)) are
ineligible for range reporting for on-site releases and
transfers off-site for further waste management. Please
provide specific release, transfer, and other waste
management values. (NOTE)
16. For aluminum (fume or dust) or zinc (fume or dust), the
Waste Management codes M56 and M92 are
unacceptable. Please provide the proper Waste
Management codes for these chemicals. (NOTE)
17. For asbestos (friable), the Waste Management codes
M56 and M92 are unacceptable. Please provide the
proper Waste Management codes for these chemicals.
(NOTE)
General Errors for both the Form R and/or Form A
18. InPartI, Section lof the FormR 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)
19. In Part I, Section 1 of the Form R or Form A Certification
Statement you provided an invalid or future reporting
year. You must enter a valid reporting year for your
Form R or Form A Certification Statement. Valid years
are 1987 through 2002. This entry cannot be left blank
and NA may not be used. (NOSE)
20. You reported a negative value for a release, transfer or
other waste management quantity. Please provide a non-
negative value for the specified part and section. (NOTE)
21. You have reported a value for a PBT chemical beyond
seven digits to the right of the decimal. EPA's data
management systems support data precision up to seven
digits to the right of the decimal. EPA has truncated
your numeric submission so the number of digits to the
right of the decimal do not exceed seven. If this was
incorrect, specify the correct value, not exceeding seven
digits to the right of the decimal. (NDC)
Errors in Part I, Facility Identification Information
22. No selection was made in Part I, Section 2.1 and 2.2
(Trade Secret Information) and a generic chemical name
was not provided in Part II, Section 1.3. Therefore, the
"No" box was selected in Part I, Section 2.1. If this was
incorrect, and you intended to make a trade secret claim
of the identity of the toxic chemical, you must resubmit
following the requirements of 40 CFR Part 350 to claim
trade secret. (NDC)
23. You indicated trade secret in Part I, Section 2.1 (Trade
Secret Information) but made no selection for Part I,
Section 2.2 (sanitized/unsanitized) and did not provide a
generic chemical name in Part II, Section 1.3. EPA
changed your selection in Part I, Section 2.1 to indicate
that a trade secret claim is not being made. If this was
incorrect, and you intended to make a trade secret claim
for the identity of the toxic chemical, you must resubmit
following the requirements of 40 CFR Part 350 to claim
trade secret. (NDC)
24. You made a selection of "No" in Part 1, Section 2.1
(Trade Secret Information) and selected "unsanitized" in
Part 1, Section 2.2. In Part II, Section 1.3 a generic
name was indicated. Part II, Section 1.3 should be
completed only if trade secret is being claimed (Part 1,
Section 2.1). EPA will move the chemical name
information in Part II, Section 1.3 to Part II, Section 1.2.
If this is incorrect and you wish to claim trade secret,
you must resubmit following the requirements of 40 CFR
C-10 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
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 SIC code was not provided. Please provide at
least one valid primary four-digit SIC code. (NOTE)
32. You reported an invalid state code. If the address is in
the US, please use a valid US Postal Service state code
(see Table III of the Reporting Forms and Instructions).
If the address is not in the US, please enter a valid code
in the Country Field (see Table IV of the Reporting
Forms and Instructions) (NOTE)
3 3. Either Box A (An Entire Facility) or Box B (Part of a
Facility) should be checked in Part I, Section 4.2. One
of the 2 boxes must be checked, but not both. (NOTE)
34. If applicable, check either Box C (Federal Facility) or
Box D (GOCO) in Part I, Section 4.2, but do not check
both boxes. (NOTE)
35. You did not enter Longitude or Latitude values for the
facility. Please enter a Longitude and Latitude value.
(NOTE)
36. You entered an invalid Longitude/Latitude value(s).
Longitude degrees must be between 0 and 180, latitude
degrees must be between 0 and 90; minutes and
seconds for either latitude or longitude must be
between 0 and 60. (NOTE)
37. Dun and Bradstreet Numbers (Part I Section 4.7) are
typically 9 characters in length. Please check the
number(s) submitted. If they are incorrect, please make
the appropriate changes. If you believe that they are
correct, no further action is necessary. (NOTE)
38. EPA Identification Numbers (RCRA 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 company does not
Toxics Release Inventory Reporting Forms and Instructions C-l 1
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Appendix C
have a Dun and Bradstreet Number check the [NA] box
next to Part I, Section 5.2. (NOTE)
Errors in Part II, Section 1. Toxic Chemical Identity
45. You have correctly identified the chemical but have used
a synonym for the chemical name. EPA has changed the
Chemical Name to use the preferred TRI nomenclature.
Please specify the correct CAS Number and matching
Chemical Name. (NDC)
46. The CAS number you reported was changed to match the
chemical name reported, because the CAS number you
provided was not a valid TRI Chemical. If this was
incorrect, specify a valid CAS number and matching
chemical name. (NDC)
47. The chemical name you reported was changed to match
the CAS number reported, because the chemical name
you provided was not a valid TRI Chemical. If this was
incorrect, specify a valid CAS Number and matching
Chemical Name. (NDC)
48. You reported a valid TRI CAS Number, a valid
Chemical Name, and a generic Chemical Name.
Therefore, the Generic Chemical Name was deleted. If
this was incorrect, specify the Generic Chemical Name
to be used. (NDC)
49. You reported a valid TRI CAS Number, a valid
Chemical Name, and a Mixture Component Identity.
Therefore, the Mixture Component Identity was deleted.
If this was incorrect, specify the Mixture Component
Identity to be used. (NDC)
50. EPA has changed the TRI chemical category code you
reported in Part II, Section 1.1 fromN151 to N150 (the
code was incorrectly listed in some pages of the
Reporting Forms and Instructions), the correct TRI
chemical category code for Dioxin and Dioxin-like
Compounds. If this is incorrect and you are not
reporting Dioxin and Dioxin-like Compounds, please
specify the correct CAS number or chemical category
code and matching chemical name. (NDC)
51. You have reported for isopropyl alcohol (Only persons
who manufacture by the strong acid process are subject)
(CAS number 67-63-0). If you did not manufacture
isopropyl alcohol by the strong acid process, you have
submitted this form in error and should request that the
form be withdrawn. (NOTE)
Errors in Form R, Part II, Section 1.4. Dioxin and Dioxin-
like Compounds
52. EPA has deleted the entry of zeros in Part II, Section 1.4
because you indicated a CAS number or chemical
category in Part II, Section 1.1 other than Dioxin and
Dioxin-like Compounds. When reporting for a chemical
other than Dioxin and Dioxin-like Compounds, you
should leave Section 1.4 blank. (NDC)
53. You did not complete Section 1.4. If you report Dioxin
and Dioxin-like Compounds in Part II, Sections 1.1 or
1.2, you must complete Section 1.4. Please report the
distribution of chemicals included for Dioxin and
Dioxin-like Compounds. If you do not have speciation
data available, indicate NA. (NOTE)
54. Part II, Section 1.4 of your Form R contains data for
Dioxin and Dioxin-like Compounds. However, you have
indicated a CAS number or chemical category code in
Part II, Section 1.1 other than Dioxin and Dioxin-like
Compounds (N150). If you are reporting for Dioxin and
Dioxin-like Compounds, please provide the proper
chemical category code (N150). Otherwise please
indicate on the FDP that Section 1.4 should be left blank.
(NOTE)
55. You did not provide values in all 17 boxes in Part II,
Section 1.4 and/or the values do not total to 100%.
When reporting the distribution of each member of the
Dioxin and Dioxin-like Compounds category, you must
fill in each of the 17 boxes in Part II, Section 1.4 with
either 0 or a number between 0.01 and 100. The
summation of the 17 fields in Section 1.4 must equal
100. Please review Part II, Section 1.4 and enter values
where needed and/or adjust the percentages where
needed so that their summation equals 100%. (NOTE)
56. You reported numeric values in Part II, Section 1.4 for a
chemical that is not a Dioxin and Dioxin-like
Compounds. It appears that the information reported in
Part II, Section 1.4 is not valid. If you are reporting for
Dioxin and Dioxin-like Compounds, please indicate on
this FDP that the chemical category name in Part II,
Section 1.2 should be Dioxin and Dioxin-like
Compounds, or submit a new Form R. Otherwise,
please indicate on this FDP that the values in Part II,
Section 1.4 should be blank. (NOTE)
57. Part II, Section 1.4 of your Form R contains data for
Dioxin and Dioxin-like Compounds. However, you have
indicated both NA and a numeric value (which includes
zero). When reporting the distribution of each member
of the Dioxin and Dioxin-like Compounds category, you
must fill in each of the 17 boxes in Part II, Section 1.4
with either 0 or a number between 0.01 and 100. The
summation of the 17 fields in Section 1.4 must equal
100. If you do not have speciation data available,
indicate NA rather than zero. (NOTE)
C-12 Toxics Release Inventory Reporting Forms and Instructions
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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.I.B.
Please provide the POTW Name and Location.
(NOTE)
67. You provided an incomplete POTW name and address.
Please provide the name and complete address for the
POTW. (NOTE)
68. There are missing or incomplete data for Part II, Section
6.1. Please provide the transfer amount or range code
and Basis of Estimate for Discharges to POTWs.
(NOTE)
69. You did not complete Part II, Section 6.2, "Transfers to
Other Off- site Locations." If you did not transfer the
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)
Toxics Release Inventory Reporting Forms and Instructions C-13
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Appendix C
74. You provided incomplete off-site name and address data.
For a transfer to a domestic off-site location, you must
provide a street address, city, state, county and zip code.
For a transfer to a foreign off-site location, you must
provide a street address, city and a two character country
code. (NOTE)
75. You reported an invalid Type of Waste Management
code. For metals/metal compounds use only disposal
and certain recycling activities codes. Consult the
Reporting Instructions for metal and metal compounds
and correct with a valid Waste Management (i.e., "M")
code. (NOTE)
76. You reported an invalid Type of Waste Management
code. For Barium Compounds use only disposal and
certain recycling activities codes, M61—Wastewater
Treatment (Excluding POTW) or M69—Other Waste
Treatment. Consult the Reporting Instructions for metal
and metal compounds and correct with a valid Waste
Management (i.e., "M") code. (NOTE)
77. For non-metals codes M41 and M62 are unacceptable.
Provide the appropriate Disposal or Other Waste
Management code for this non-metal substance.
(NOTE)
78. In Part II, Section 6.2 column C you reported M codes
(M56 and/or M92) forenergy recovery, howeveryouleft
Section 8.3 columnB blank. Please provide the quantity
used for energy recovery offsite in pounds/year in
Section 8.3 column B. (NOTE)
79. In Part II, Section 6.2 column C you reported M Codes
(M20, M24, M26, M28, M93) for recycling, however
you left Section 8.5 column B blank. Please provide the
quantity recycled offsite in pounds/year in Section 8.5
column B. (NOTE)
80. In Part II, Section 6.2 column C you reported M Codes
(M40, M50, M54, M61, M69, M95) for treatment,
however you left Section 8.7 column B blank. Please
provide the quantity treated offsite in pounds/year in
Section 8.7 column B. (NOTE)
Errors in Part II, Section 7. On-Site Waste Treatment
Methods and Efficiency
81. There are no data contained in all of Part II, Section 7 A.
If you do not treat wastes containing the EPCRA section
313 chemical at your facility, indicate "NA;" otherwise
please provide the general waste stream code, waste
treatment methods, range of influent concentration,
waste treatment efficiency estimate and whether this is
based on operating data for all on-site waste treatments
for this chemical. (NOTE)
82. There are missing data in Part II, Section 7A. Please
provide the general waste stream code, waste treatment
methods, range of influent concentration, waste
treatment efficiency estimate and whether this is based
on operating data. (NOTE)
83. There are no data in Part II, Section 7B. If no on-site
energy recovery processes are used for this section 313
chemical at your facility, indicate "NA;" otherwise
please provide at least one three-character on-site energy
recovery process code. (NOTE)
84. There are no data in Part II, Section 7C. If no on-site
recycling processes are used for this section 313
chemical at your facility, indicate "NA;" otherwise
please provide at least one three-character on-site
recycling process code. (NOTE)
Errors in Part II, Section 8. Source Reduction and
Recycling Activities
85. There are missing data for Part II, Section 8.1-8.7.
Please provide an estimate or "NA" (Not Applicable) in
each box for section 8.1-8.7, columns A, B, C, and D.
You may only use "NA" (Not Applicable) when there is
no possibility a release or transfer occurred. You may
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)
C-14 Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
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)
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)
92. You reported a negative value for a release, transfer or
other waste management quantity. Please provide a non-
negative value for the specified part and section. (NOTE)
Errors relating to the reconciliation of data in Part II,
Section 8 and Part II, Sections 5,6, and 7
93. You did not complete Sections 8.1-8.7 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 7C. 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)
100. You reported a value in Part II, Section 8.5 column B,
however you did not provide a corresponding quantity
with an appropriate M Code (M20, M24, M26, M28,
M93) for recycling in Section 6.2 column C. Please
provide the appropriate quantity and M Codes for
recycling in Section 6.2 column C. (NOTE)
101. You reported a value in Part II, Section 8.7 column B,
however you did not report a quantity in Section 6.1 or
a quantity with an appropriate M Code (M40, M50,
M54, M61, M69, M95) for treatment in Section 6.2
column C. Please provide a quantity in Section 6.1 or the
appropriate quantity and M Codes for treatment in
Section 6.2 column C. (NOTE)
102. You have reported a listed metal or metal compound
category in Part II, Section 6.1, however you have not
provided a quantity released in section 8.1 column B.
Note that in Section 8, metal or metal compound
category can only be reported as disposed or recycled
and not reported as treated for energy recovery or
treated for destruction. Please provide quantity
released in pounds/year in Section 8.1 column B.
(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 8, metal or metal compound category can only
be reported as disposed or recycled and not reported as
treated for energy recovery or treated for destruction.
Please provide quantity released in pounds/year Section
8.IB. (NOTE)
Toxics Release Inventory Reporting Forms and Instructions C-15
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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.
Who Must Supply Notification
You are covered by the section 313 supplier notification
requirements if you own or operate a facility which meets all
of the following criteria:
(1) Your facility is in Standard Industrial Classification
[SIC] codes 20-39;
(2) You manufacture (including import) or process an
EPCRA section 313 chemical; and
(3) You sell or otherwise distribute a mixture or other trade
name product containing the EPCRA section 313
chemical to either:
Q A facility in a covered SIC code (see Table I).
Q A person that then may sell the same mixture or
other trade name product to a firm in a covered
SIC code (see Table I).
Note that you may be covered by the supplier notification
rules even if you are not covered by the section 313 release
reporting requirements. For example, even if you have
fewer than 10 full-time employees or do not manufacture or
process any of the EPCRA section 313 chemicals in sufficient
quantities to trigger the release and other waste management
reporting requirements, you may still be required to notify
certain customers.
Who Must Be Notified
Also, note that beginning with the 1998 reporting year, seven
new industries are now covered by most of the EPCRA section
313 reporting requirements. These new industries are not
required to comply with most of the supplier notification
requirements. Industries whose primary SIC code is not within
20 through 39 are not required to initiate the distribution of
notifications for EPCRA section 313 chemicals in mixtures or
other trade name products that they send to their customers.
However, if these facilities receive notifications from their
suppliers about EPCRA section 313 chemicals in mixtures or
other trade name products, they should forward the
notifications with the EPCRA section 313 chemicals they send
to other covered users.
An example would be if you sold a lacquer containing toluene
to distributors who then may sell the product to other
manufacturers. The distributors are not in a covered SIC code,
but because they sell the product to companies in covered SIC
codes, they must be notified so that they may pass the notice
along to their customers, as required.
The language of the supplier notification requirements covers
mixtures or other trade name products that are sold or
otherwise distributed. The "otherwise distributes" language
includes intra-company transfers and, therefore, the supplier
notification requirements at 40 CFR Section 372.45 apply.
Note that beginning with the first shipments in 1998, facilities
in SIC codes 20-39 will be required to also notify facilities in
the newly added industry groups.
Supplier Notification Must Include the
Following Information:
(1) A statement that the mixture or other trade name product
contains an EPCRA section 313 chemical or chemicals
subject to the reporting requirements of EPCRA section
313 (40 CFR 372);
(2) The name of each EPCRA section 313 chemical and the
associated Chemical Abstracts Service (CAS) registry
number of each chemical if applicable. (CAS numbers
are not used for chemical categories, since they can
represent several individual EPCRA section 313
chemicals.); and
(3) The percentage, by weight, of each EPCRA
Toxics Release Inventory Reporting Forms and Instructions D-l
-------
Appendix D
section 313 chemical (or all EPCRA section 313
chemicals within a listed category) contained in the
mixture or other trade name product.
For example, if a mixture contains a chemical (i.e., 12 percent
zinc oxide) that is a member of a reportable EPCRA section
313 chemical category (i.e., zinc compounds), the notification
must indicate that the mixture contains a zinc compound at 12
percent by weight. Supplying only the weight percent of the
parent metal (zinc) does not fulfill the requirement. The
customer must be told the weight percent of the entire
compound within an EPCRA section 313 chemical category
present in the mixture.
How the Notification Must Be Made
The required notification must be provided at least annually in
writing. Acceptable forms of notice include letters, product
labeling, and product literature distributed to customers. If
you are required to prepare and distribute a Material Safety
Data Sheet (MSDS) for the mixture under the Occupational
Safety and Health Act (OSHA) Hazard Communication
Standard, your section 313 notification must be attached to the
MSDS or the MSDS must be modified to include the required
information. (A sample letter and recommended text for
inclusion in an MSDS appear at the end of this appendix.)
You must make it clear to your customers that any copies or
redistribution of the MSDS or other form of notification must
include the section 313 notice. In other words, your customers
should understand their requirement to include the section 313
notification if they give your MSDS to their customers.
When Notification Must Be Provided
You must notify each customer receiving a mixture or other
trade name product containing an EPCRA section 313
chemical with the first shipment of each calendar year. You
may send the notice with subsequent shipments as well, but it
is required that you send it with the first shipment each year.
Once customers have been provided with an MSDS containing
the section 313 information, you may refer to the MSDS by a
written letter in subsequent years (as long as the MSDS is
current).
If EPA adds EPCRA section 313 chemicals to the section 313
list, and your products contain the newly added EPCRA
section 313 chemicals, notify your customers with the first
shipment made during the nextcalendaryearfollowingEPA'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).
When Notifications Are Not Required
Supplier notification is not required for a "pure" EPCRA
section 313 chemical unless a trade name is used. The identity
of the EPCRA section 313 chemical will be known based on
label information.
You are not required to make a "negative declaration." That
is, you are not required to indicate that a product contains no
EPCRA section 313 chemicals.
If your mixture or other trade name product contains one of the
EPCRA section 313 chemicals, you are not required to notify
your customers if:
(1) Your mixture or other trade name product contains the
EPCRA section 313 chemical in percentages by weight
of less than the following levels (These are known as de
minimis levels)
Q 0.1 percent if the EPCRA section 313 chemical is
defined as an "OSHA carcinogen;"
Q 1 percent for other EPCRA section 313 chemicals.
De minimis levels for each EPCRA section 313 chemical
D-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix D
and chemical category are listed in Table II. PBT
chemicals (except lead when contained in stainless steel,
brass or bronze alloys) are not eligible for the de minimis
exemption. Therefore, de minimis levels are not provided
for these chemicals in Table II. However, for purposes of
supplier notification requirements only, such notification
is not required when the following PBT chemicals are
contained in mixtures below their respective de minimis
levels:
Chemical or chemical
category name
Aldrin
Benzo [g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds
(manufacturing; and the
processing or otherwise
use of dioxin and dioxin-
like compounds if the
dioxin and dioxin-like
compounds are present as
contaminants in a
chemical and if they were
created during the
manufacturing of that
chemical
Heptachlor
Hexachlorobenzene
Isodrin
Lead
Lead compounds
Mercury
Mercury compounds
Methoxychlor
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
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
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
Fob/chlorinated
biphenyls (PCBs)
Polycyclic aromatic
compounds category
Tetrabromobisphenol A
Toxaphene
Trifluralin
1336-36-3
N590
79-94-7
8001-35-2
1582-09-8
0.1
0 i***
1.0
0.1
1.0
*The de minimis level is 1.0 for all members except for
2,3,7,8-Tetrachlorodibenzo-/>-dioxin which has a 0. 1%
de minimis level.
**The de minimis level is 0.1 for inorganic lead
compounds and 1.0 for organic lead compounds
***The de minimis level is 0.1 except for
benzo(a)phenanthrene, dibenzo(a,e)fluoranthene,
benzo(j,k)fluorene, and 3-methylcholanthrene which are
subject to the 1.0% de minimis level.
(2) Your mixture or other trade name product is one of the
following:
Q An article that does not release an EPCRA section 313
chemical under normal conditions of processing or
otherwise use.
Q Foods, drugs, cosmetics, alcoholic beverages, tobacco,
or tobacco products packaged for distribution to the
general public.
Q Any consumer product, as the term is defined in the
Consumer Product Safety Act, packaged for
distribution to the general public. For example, if you
mix or package one-gallon cans of paint designed for
use by the general public, notification is not required.
(3) A waste sent off site for further waste management.
The supplier notification requirements apply only to
mixtures and trade name products. They do not apply
to wastes.
(4) You are initiating distribution of a mixture or other
trade name product containing one or more EPCPxA
section 313 chemicals and your facility is in any of the
covered SIC codes added during the 1997 industry
expansion rulemaking, including facilities whose SIC
code is within SIC major group codes 10 (except 1011,
1081, and 1094), 12 (except 1241); industry codes 4911
(limited to facilities that combust coal and/or oil for the
purpose of generating power for distribution in
commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating power for
Toxics Release Inventory Reporting Forms and Instructions D-3
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Appendix D
distribution in commerce), or 4939 (limited to
facilities that combust coal and/or oil for the purpose
of generating power for distribution in commerce); or
4953 (limited to facilities regulated under the
Resource Conservation and Recovery Act, subtitle C,
42U.S.C. Section692letseq.) or5169, or 5171, or
7389 (limited to facilities primarily engaged in
solvents recovery services on a contract or fee basis).
Trade Secrets
Chemical suppliers may consider the chemical name or the
specific concentration of an EPCRA section 313 chemical in
a mixture or other trade name product to be a trade secret. If
you consider the:
(1) Specific identity of an EPCRA section 313 chemical to be
a trade secret, the notice must contain a generic chemical
name that is descriptive of the structure of that EPCRA
section 313 chemical. For example, decabromodiphenyl
oxide could be described as a halogenated aromatic.
(2) Specific percentage by weight of an EPCRA section 313
chemical in the mixture or other trade name product to be
a trade secret, your notice must contain a statement that
the EPCRA section 313 chemical is present at a
concentration that does not exceed a specified upper
bound. For example, if a mixture contains 12 percent
toluene and you consider the percentage a trade secret, the
notification may state that the mixture contains toluene at
no more than 15 percent by weight. The upper bound
value chosen must be no larger than necessary to
adequately protect the trade secret.
If you claim this information to be trade secret, you must have
documentation that provides the basis for your claim.
Recordkeeping Requirements
You are required to keep records for three years of the
following:
(1) Notifications sent to recipients of your mixture or other
trade name product;
(2) All supporting materials used to develop the notice;
(3) If claiming a specific EPCRA section 313 chemical
identity a trade secret, you should record why the EPCRA
section 313 chemical identity is considered a trade secret
and the appropriateness of the generic chemical name
provided in the notification; and
(4) If claiming a specific concentration a trade secret, you
should record explanations of why a specific
concentration is considered a trade secret and the basis for
the upper bound concentration limit.
Information retained under 40 CFR 372 must be readily
available for inspection by EPA.
D-4 Toxics Release Inventory Reporting Forms and Instructions
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Appendix D
Sample Notification Letter
January 2, 2004
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:
D Toluene, Chemical Abstract Service (CAS) number 108-88-3, 20 percent, and
D Zinc compounds, 15 percent.
If you are unsure whether you are subject to the reporting requirements of EPCRA section 313, or need more information, call
EPA's EPCRA Call Center. For contact information, please see the TRI Home Page at . Your other suppliers
should also be notifying you about EPCRA section 313 chemicals in the mixtures and other trade name products they sell to you.
Finally, please note that if you repackage or otherwise redistribute this product to industrial customers, a notice similar to this one
should be sent to those customers.
Sincerely,
Emma Sinclair
Sales Manager
Furniture Products
Toxics Release Inventory Reporting Forms and Instructions D-5
-------
Appendix D
Sample Notification on an MSDS 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
-------
Appendix E. How To Determine Latitude and Longitude
Facilities can now use the TRI Facility Siting Tool to find
their latitude and longitude coordinates. This easy-to-use
on-line tool combines interactive maps and aerial
photography to help you get accurate latitude and
longitude coordinates of your facility. The tool provides
coverage for the continental United States, Alaska, and
Hawaii. American Samoa, Guam, and the Mariannas
Islands are not currently available through the siting tool.
You may locate your facility by searching via zip code,
address, or facility name/facility identification number.
The siting tool is the preferred method of obtaining
latitude and longitude for your facility. The siting tool and
its instructions can be found on the Internet at:
EPA's TRI-ME software will also take you directly to the
siting tool if you have Internet access.
Facilities may also utilize a hand held Global Positioning
System (GPS) unit to obtain your facility's latitude and
longitude. Please make sure you read and understand the
manufacture's directions for proper operation.
Latitude and longitude coordinates of reporting facilities
are very important for pinpointing facility location and are
a required data element on Form R. As such, EPA is
encouraging facilities to make the best possible
measurements when determining latitude and longitude.
As with any other data element, missing, suspect, or
incorrect data may result in EPA issuing a Notice of
Technical Error to the facility.
EPA strongly suggests that latitude and longitude
measurements be obtained from the on-line TRI Facility
Siting Tool described above. If you do not have access to
the Internet, latitude and longitude measurements may be
made from U.S. Geological Survey (USGS) topographic
quadrangle maps. These maps are published in varying
degrees of detail. The most detailed version of the
topographic quadrangle map is in 7.5 x 7.5 minute
increments with a scale of 1:24000 (i.e., one inch on the
map represents 2,000 feet). Detailed topographic
quadrangle maps are also available in 7.5 x 15 minute
increments with a scale of 1:250,000 (i.e., one inch on the
map represents approximately four miles). Please use the
USGS topographic quadrangle maps if you are unable to
use the siting tool, otherwise, measurements will not
accurately reflect the location of your facility and could be
identified as an error on your Form R submission.
In order to identify the detailed topographic quadrangle
map in which your facility is located, the USGS has
published an index and a catalog of topographic maps
available for each state. Both the index and the catalog
are available in many libraries or free of charge from
USGS Information Services (address on following page).
The Index to Topographic and Other Map Coverage helps
you to identify the most detailed map in which your
facility is located. To identify the most detailed map,
follow these simple steps on how to use the index:
(1) The beginning of each index contains a map of the
state, broken into numbered quadrangular sections.
The numbered quadrangular sections are called
general areas of interest. Identify the numbered
section in which your facility is located.
(2) The subsequent pages of the index contain detailed
maps of each general area of interest, in numerical
order. Identify the detailed map corresponding to the
numbered general area of interest identified in Step
1.
(3) Within this detailed map, identify the smaller
quadrangular area in which your facility is located.
This smaller quadrangular section is the specific area
of interest. Record first the letter then the number
coordinate for your specific area of interest (e.g.,
E4).
(4) Using the chart found on the same page as the
detailed map of the general area of interest, record
the name of the specific area of interest in which
your facility is located, identified by the letter and
number coordinates (e.g., Richmond).
The name of the specific area of interest and its
corresponding letter and number coordinates identify the
most detailed topographic quadrangle map in which your
facility is located. To identify the map reference code and
file number necessary to order this map, follow these
simple steps for using the Catalog of Topographic and
Other Published Maps for the state in which your facility
is located:
(5) The beginning of the catalog explains the meaning of
the reference code. On the pages following this
explanation, there are charts listed alphabetically by
the name of the specific area of interest with
corresponding file numbers and map reference
codes. Using the name of the specific area of
interest recorded in Step 4, identify the file number
and map reference code from the chart for the map in
which your facility is located (e.g., file number
00692, map reference code 37977-E4-TF-024-00).
(6) Use the file number and map reference code to
obtain the specific topographic quadrangle map in
which your facility is located.
These detailed topographic quadrangle maps are available
in many libraries or for purchase from USGS Information
Services and from private map dealers. The Catalog of
Topographic and Other Published Maps contains a list of
map depository libraries and topographic map dealers for
each state covered in the catalog.
Toxics Release Inventory Reporting Forms and Instructions E-l
-------
Appendix E
To purchase a topographic quadrangle map from the
USGS, you must send a written request to USGS
Information Services, containing the file number, map
reference code, the name of the city, state and zip code in
which your facility is located, payment of $6.00 per map
sheet and a handling charge of $5.00 for each order
mailed.
USGS map products can be ordered from:
USGS Information Services
P.O. Box 25286
Denver Federal Center
Denver, CO 80225
303 202-4700
Email: infoservices@usgs.gov
ALLOW 5 WEEKS FOR DELIVERY
In addition, you may purchase a topographic quadrangle
map from the USGS through a USGS Public Inquiry
Office. The Public Inquiry Offices are listed for each state
on the inside back cover of the Catalog of Topographic
and Other Published Maps.
If you need help in determining your latitude and
longitude, once you have the necessary map, the Earth
Science Information Center can provide assistance:
888 ASK-USGS
ask@usgs.gov
Please call in advance of the section 313 reporting
deadline to avoid unnecessary delays.
Determining Your Facility's
Latitude and Longitude
(See diagram next page.)
Once you have obtained the correct map for your facility
EPA recommends that you follow the five steps below to
determine the latitude and longitude of your facility:
(1) Mark the location of your facility on the map with a
point. If your facility is large, choose a point central
to the production activities of the facility. If certain
structures inyourfacility are represented on the map,
mark one of the structures with a point.
(2) Construct a small rectangle around the point with
fine pencil lines connecting the nearest 2.5' or 5'
graticules. Graticules are intersections of latitude
and longitude lines that are marked on the map edge,
and appear as black crosses at four points in the
interior of the map.
(3) Read and record the latitude and longitude (in
degrees, minutes, and seconds) for the southeast
corner of the small quadrangle drawn in step two.
The latitude and longitude are printed at the edges of
the map.
(4) To determine the increment of latitude above the
latitude line recorded in step 3,
— position the map so that you face west;
— place the ruler in approximately a north-south
alignment, with the "0" on the latitude line
recorded in step 3 with the ruler edge intersecting
the point.
Without moving the ruler, read and record:
— the measurement from the latitude line to the
desired point (the point distance);
— the measurement from the latitude line to the
north line of the small quadrangle (the total
distance).
Determine the number of seconds to be added to the
latitude recorded in step 3 by using the ratio:
Point distance x 150" = increment of latitude
Total distance
between lines
[Note: 150" is the number of seconds of arc for the side of
the small quadrangle on a 7.5' map. If you are using a 15'
map, the multiplication factor is 300" instead of 150" since
each graticule is 5' of latitude or longitude.]
For example:
Point distance
Total distance
99.5
192.0
99.5 x 150"
192.0
77.7"
01'17.7"
(60" = 1'; 77.7" = 60" + 17.7" = 01' 17.7")
Latitude in step 3
Increment
Latitude of point
32°17'30"
+ Ori7.7"
32°18'47.7"
to the nearest second = 32°18'48"
(5) To determine the increment of longitude west of the
longitude line recorded in step 3,
— position the map so that you face south;
E-2 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix E
— place the ruler in approximately an east-west
alignment with the "0" on the longitude line
recorded in step 3 with the ruler edge intersecting
the point.
Without moving the ruler, read and record:
— the measurement from the longitude line to the
desired point (the point distance);
— the measurement from the longitude
line to the west line of the small quadrangle
(the total distance).
Determine the number of seconds to be added to the
longitude recorded in step 3 by using the ratio:
Point distance x 150" = increment of longitude
total distance
between lines
For example:
Point distance
Total distance
65.0
149.9
65.0 xl50" = 65" = 01'05"
149.9
(60" = 1'; 65" = 60" + 05" = Ol'OS")
Longitude in step 3
Increment
Longitude of point
78°05'00"
+ Ol'OS"
78°06'05"
to the nearest second = 78°06'05"
You should use positive coordinates when reporting
longitude.
Note: Use the appropriate address for submission of
Form R reports to your state. In addition, many states
have additional state reporting requirements. Check
with your state contact on any state requirements.
Toxics Release Inventory Reporting Forms and Instructions E-3
-------
Appendix E
Latitude/Longitude Diagram
Point Latitude 32°18'48" North, Longtitude 78°06'05" West
Note: This diagram is based on a USGS 7.5 Minute Series Topographic Map.
It is not drawn to scale.
32°52'30"
CO
o
-------
Appendix F. State Designated Section 313 Contacts
Submitting by Diskette to States: As of the
publication of this book the following states
confirmed that they accept diskette
submissions. Do not send submissions via
email.
AK
AL
AZ1
CA
CO
DE
FL
GA
HI
IA
ID
IL
IN
KS
LA
MD2
MI3
MN
MO4
MT
ND
NH
NJ
NM
NV
NY
OH
OK
OR
PA
PR
sc5
SD
TX
UT
VA
VT
WA
WI
WV
WY
If your state is not listed here, please contact
your state office to confirm that paper
submissions are required.
Alabama
Kirk Chandler
AL Emergency Response Commission
AL Department of Environmental
Management
P.O. Box 301463
Arizona Emergency Response Commission accepts
electronic submissions, however the Arizona Dept. of
Environmental Quality accepts only paper submissions.
Submissions must be sent to both agencies.
Maryland accepts diskette submissions, but requires
that paper copies be sent as well.
'Michigan accepts Internet submissions; reports
submitted electronically via Internet to EPA's Central Data
Exchange does not require any separate mailing of reports (disk
or paper). Also acceptsdiskettes.
4Missouri only accepts diskettes created using TRI-
ME software.
5South Carolina only accepts reports submitted
electronically via Internet to EPA's Central Data Exchange.
Facilities submitting by Internet are exempt from any separate
mailing to SC DHEC. If Internet access is not available, it will
be necessary to mail a diskette copy to SC DHEC.
Montgomery, AL 36130-1463
(334) 260-2714; Fax: (334) 272-8131
KFC@adem.state.al.us
Certified Mail/Fed Ex
AL Emergency Response Commission
1890-A Congressman W.L. Dickinson Dr.
Montgomery, AL 36109-2600
Alaska
Camille Stephens
Department of Environmental Conservation
Division of Spill Prevention and Response
410 Willoughby Ave., Suite 300
Juneau, AK 99801-1795
(907) 465-5220; Fax: (907) 465-5244
camille_stephens@dec.state.ak.us
American Samoa
Pati Faiai
American Samoa Environmental Protection
Agency
American Samoa Government
Office of the Governor
Pago Pago, AS 96799
International (684) 633-2304
Peter Peshut, Acting Director
American Samoa Environmental Protection
Agency
Office of the Governor
(684) 633-2304; Fax: (684) 633-5801
ppeshut@yahoo. com
Arizona
Daniel Roe, Executive Director*
Arizona Emergency Response Commission
5636 East McDowell Road
Phoenix, AZ 85008
(602) 231-6345; Fax: (602) 392-7519
dan.roe@azdema.gov
Bill Quinn*
Arizona Department of Environmental Quality
Pollution Prevention Program, Mail 4415A-1
1110 West Washington Street
Phoenix, AZ 85007-2955
(602) 771-4203; Fax: (602) 771-4138
quinn.bill@ev.state.az.us
Toxics Release Inventory Reporting Forms and Instructions F-l
-------
Appendix F
Arkansas
Kenny Harmon
Hazardous Materials Program Manager
AR Dept. of Emergency Management
P.O. Box 758
Conway, AR 72203-0758
(501) 730-9789; Fax: (501) 703-9754
kenny.harmon@adem.state.ar.us
Certified Mail Only
John Ward
AR Dept. of Pollution Control & Ecology
8001 National Drive
Little Rock, AR 72209-8913
(501) 730-9832 Fax: (501) 682-0798
jward@adeq.state.ar.us
California
Dept. of Toxic Substance Control
Attn: Office of Environmental Information
Management
100II Street, 8th Floor
Sacramento, CA 95812
(916) 324-3421 Fax: (916) 324-1788
Colorado
Kirk Mills
Sustainability Program
CO Dept. of Public Health and Environment
4300 Cherry Creek Drive South
Denver, CO 80246-1530
(303) 692-2977; Fax: (303) 782-4969
kirk.mills@state.co.us
Commonwealth of Northern Mariana Islands
John I. Castro, Jr. Director
Office of the Govenor
Third Floor, Morgan Bldg., San Jose
P.O. Box 501304
Saipan, MP 96950-1340
International: (670) 664-8500/1;
Fax: (670) 664-8540
deq.director@saipan.com
Connecticut
Mark Decaprio, Acting SERC Administrator
Department of Environmental Protection
State Emergency Response Commission
79 Elm Street, 4th Floor
Hartford, CT 06106-5127
(860) 424-3373; Fax: (860)424-4059
mark.decaprio@po.state.ct.us
Delaware
John E. Parker
Toxic Release Inventory Program
Division of Air and Waste Management, DNREC
156 South State Street
Dover, DE 19901
(302) 739-4791; Fax: (302) 739-3106
john.parker@state.de.us
District of Columbia
Michele Penick
Environmental Planning Specialist
Emergency Response Commission for Title III
2000 14th Street, N.W. 8th Floor
Washington, DC 20009
(202)673-2101,ext. 1159;
Fax: (202) 673-2290
michele .penick@dc.gov
Florida
Sam Brackett
State Emergency Response Commission
Florida Department of Community Affairs
2555 Shumard Oak Blvd.
Tallahassee, FL 32399-2100
(850) 413-9970; Fax: (850) 488-1739
sam.brackett@dca. state .fl.us
Georgia
Dr. Bert K. Langley
Georgia Environmental Protection Agency
7 Martin Luther King, Jr. Drive
Room 643
Atlanta, GA 30334
(404) 656-6905; Fax: (404) 562-9095
bert_langley@mail.dnr.state.ga.us
Guam
Francis Damian
Guam Environmental Protection Agency
Air and Land Division
P.O. Box 20439
Barrigada, Guam 96921
International (671) 475-1607;
Fax: (671) 477-9402
fpdamian@guamepa.govguam.net
F- 2 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix F
Hawaii
Denis Shimamoto
Hawaii State Emergency Response Commission
Hawaii Department of Health
919 Ala Moana Blvd, Room 206
Honolulu, HI 96814
(808) 586-4694; Fax: (808) 586-7537
heer@eha.health.state.hi.us
Idaho
Bill Bishop
Bureau of Hazardous Materials
4040 Guard Street, Bldg. 600
Gowen Field
Boise, ID 83705-5004
(208) 422-5725; Fax: (208) 422-4485
bbishop@bds.state.id.us
Illinois
Dierdre McQuillen
Office of Environmental Policy & Science #26
Illinois Environmental Protection Agency
1021 North Grand Avenue, East
P.O. Box 19276
Springfield, IL 62794-9276
(217) 558-0073; Fax: (217) 782-8346
dierdre.mcquillen@epa.state.il.us
Certified or Express Mail ONLY
Dierdre McQuillen
OEP & Science #26
Illinois Environmental Protection Agency
1021 North Grand Avenue, East
Springfield, IL 62702
Indiana
Brian Stevens, TRI Database Manager
Indiana Dept. of Environmental Management
OPPTA
402 West Washington Street, Room W041
PO Box 7095
Indianapolis, IN 46207-7095
(317) 233-5433 ** 1 (800) 988-7901
Fax:(317)233-5627
bstevens@dem.state.in.us
www.in.gov/idem/oppta/tri
Iowa
Emergency Response Unit
Iowa Department of Natural Resources
401 SW 7th Street, Suite I
Des Moines, IA 50309
(515) 281-8694 ** Fax (515) 725-0218
www.iowadnr.com/spills/index.html
Kansas
Scott Bangert, Environmental Health Scientist
Kansas Department of Health and Environment
Bureau of Air & Radiation
Asbestos & Hazardous Chemical Information Unit
1000 SW Jackson, Suite 310
Topeka, KS 66612-1366
(785) 296-1689; Fax: (785) 296-1545
sbangert@kdhe.state.ks.us
Kentucky
Larry C. Taylor
Kentucky Department for Environmental Protection
14 Reilly Road
Frankfort, KY 40601-1132
(502) 564-2150 ext. 112; Fax: (502) 564-4245
larryc.taylor@ky.gov
Louisiana
Linda M. Brown, Environmental Scientist Manager
LA Department of Environmental Quality
Office of Environmental Assessment
P.O. Box 4314
Baton Rouge, LA 70821-4314
(225) 219-3502; (225) 219-3240 fax
linda.brown@la.gov
www.deq. state.la.us/evaluation/tri
Certified Mail/FEDEX
Linda Brown
LA Department of Environmental Quality
Office of Environmental Assessment
602 N. Fifth Street
Baton Rouge, LA 70802
Maine
Robert S. Gardner
Technological Hazards Specialist
Maine Emergency Management Agency
72 State House Station
Augusta, ME 04333-0072
(207) 624-4420; Fax: (207) 287-3178
In State Only -1-800-452-8735
robert.s.gardner@maine.gov
Maryland
Patricia S. Williams, EPCRA Coordinator
Toxics Release Inventory Reporting Forms and Instructions F- 3
-------
Appendix F
Maryland Department of the Environment
Community Right-to-Know
1800 Washington Boulevard, Suite 540
Baltimore, MD 21230-1718
(410) 631-3800; Fax: (410) 537-3873
pwilliams@mde.state.md.us
Massachusetts
Walter Hope
MA Department of Environmental Protection
Bureau
of Waste Prevention - TURA Program
1 Winter Street
Boston, MA 02108
(617) 292-5982; Fax: (617) 292-5858
walter.hope@state.ma.us
Technical Assistance can be obtained via the MA
Toxics Use Reduction Institute
On the web at: http://www.mass.gov/ota or by calling
(617)626-1060
Michigan
Robert Jackson
State Emergency Planning and Community
Right-to-Know
Michigan Department of Environmental
Quality
Environmental Science and Services Division
P.O. Box 30457
Lansing, MI 48909
(517) 373-8481; Fax: (517) 241-7966
jacksorc@michigan.gov
Overnight Mail
Robert Jackson
MDEQ ESSD
Constitution Hall, 1 North
525 West Allegan
Lansing, MI 48933
Minnesota
Steve Tomlyanovich
Department of Public Safety
Minnesota EPCRA Program
444 Cedar Street, Suite 223
St. Paul, MN 55101
(651) 282-5396; Fax: (651) 296-0459
steve.tomlyanovich@state.mn.us
Mississippi
John David Burns, TRI Coordinator
Mississippi Department of Environmental Quality
P.O. Box 20305
Jackson, MS 39289-1305
(601) 961-5005; Fax: (601) 961-5660
j ohn_d_burns@deq. state .ms.us
Missouri
Gene Nickel, EEII
Missouri Department of Natural Resources
Environmental Assistance Office
P.O. Box 176
Jefferson City, MO 65102
(573) 526-6627; Fax: (573) 526-5808
1-800-361-4827
gene. nickel@dnr. mo. gov
Certified Mail ONLY
Gene Nickel
Missouri Department of Natural Resources
Environmental Assistance Office
1659 East Elm Street
Jefferson City, MO 65101
Montana
Tom Ellerhoff
MT Emergency Response Commission DEQ
MetcalfBldg.
1520 East 6th Avenue
Helena, MT 59620-0901
(406) 444-5263; Fax: (406) 444-4386
tellerhoff@state.mt.us
Navaj o Nation
Calvert Curly (Acting Division Director)
Navajo Environmental Protection Agency
P.O. Box 339
Window Rock, AZ 86515
(928) 871-7692; Fax: (928) 871-7996
Eugene Guerito, Director
Dept. of Emergency Management
P.O. Box 2908
Window Rock, AZ 86515
(928) 871-6892
Note: recipient of EPCRA Tier II reports
F-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix F
Nebraska
Mark Lohnes
SARA Title III
Nebraska Environmental Quality
P.O. Box 98922
Lincoln, NE 68509-8922
(402) 471-4251; Fax: (402) 471-2909
mark.lohnes@ndeq.state.ne.us
Certified Mail Only
Donnie Zach
SARA Title III and NEPCRA Coordinator
Nebraska Dept of Environmental Quality
Lincoln, NE 68509
Nevada
Alene Coulson
c/o State Emergency Response Commission
555 Wright Way
Carson City, NV 89711-0925
(775) 687-9464; Fax: (775) 687-6396
acoulson@ndep.nv.gov
Questions about the Report Fee should be directed to
the Nevada State Emergency Response Commission
at (775) 687-6973
New Hampshire
Les Carrier
NH Department of Safety
Division of Fire & Emergency Management
Bureau of Emergency Management
10 Hazen Drive
Concord, NH 03305-0002
603-271-3291 Fax: (603) 225-7341
Lcartier@safety. state .nh.us
Certified Mail Only:
NH Department of Safety
Richard M. Flynn Fire Academy
Route 106
Concord, NH 03301-8523
New Jersey
Andrew Opperman
Department of Environmental Protection
EPCRA Section 313
Office of Pollution Prevention & Right-To-Know
P.O. Box 433
Trenton, NJ 08625-0433
(609) 777-0518; Fax: (609) 292-1816
andy.opperman@dep.state.nj.us
www.state.nj.us/dep/opppc
New Mexico
Don Shainin, HazMat Coordinator
New Mexico Department of Public Safety
Office of Emergency Services & Security
P.O. Box 1628
Santa Fe,NM 87504-1628
(505) 476-9681; Fax: (505) 476-9695
dshainin@dps.state.nmus
Certified Mail/Fed Ex
Don Shainin, Hazardous Material Coordinator
Office of Emergency Services & Security
ISBataanBlvd.
Santa Fe, NM 87508
New York
Susanne Wither
NY State Department of Environmental
Conservation
Division of Environmental Remediation
625 Broadway, 11th Floor
Albany, NY 12233-8010
(518) 402-9553; Fax: (518) 402-9020
smwither@gw.dec.state.ny.us
North Carolina
Felicia Pyle
NC Division of Emergency Management
4714 Mail Service Center
Raleigh, NC 27699-4714
(919)715-4406
(919) 733-1361 Hotline
1-800-451-1403 (NCOnly)
Fax: (919) 733-2860
fpyle@ncem.org
North Dakota
Ray DeBoer
ND State Division of Emergency Management
P.O. Box 5511
Bismarck, ND 58502-5511
(701) 328-8100; Fax: (701) 328-8181
rdeboer@state.nd.us
Toxics Release Inventory Reporting Forms and Instructions F-5
-------
Appendix F
Certified Mail ONLY
Ray DeBoer
ND State Division of Emergency Management
Fraine Barracks Road, Building 35
Bismarck, ND 58506-5511
Ohio
Cindy DeWulf
Ohio Environmental Protection Agency
Lazarus Government Center
P.O. Box 1049
Columbus, OH 43216-1049
(614) 644-3606; Fax: (614) 644-3681
cindy.dewulf@epa.state.oh.us
Certified Mail ONLY
Cindy DeWulf
Ohio Environmental Protection Agency
Lazarus Government Center
122 South Front Street
Columbus, OH 43215
Oklahoma
Montressa Elder, Environmental Programs Manager
Department of Environmental Quality
Risk Communication
P.O. Box 1677
Oklahoma City, OK 73101-1677
(405) 702-1017 or (800) 869-1400
Fax: (405) 702-1001
monty.elder@deq.state.ok.us
Certified Mail
OK Dept. of Environmental Quality
707 N. Robinson
Oklahoma City, OK 73102
Oregon
Mariana Ruiz-Temple
Oregon Community Right-to-Know Unit
HazMat Information Manager
4760 Portland Road, Northeast
Salem, OR 97305-1760
(503) 378-1540, ext. 238
Fax: (503) 373-1825
mariana.ruiz-temple@state.or.us
Pennsylvania
Thomas J. Ward, Jr.
Department of Labor and Industry
Bureau of PENNSAFE
Labor and Industry Building - Room 155-E
P.O. Box 68571
Harrisburg, PA 17106-8571
(717) 783-2071; Fax: (717) 783-5099
pennsafe@dli.state.pa.us
www.dli.state.pa.us
Certified Mail ONLY
Thomas J.Ward, Jr.
Bureau of PENNSAFE
Department of Labor and Industry
7th & Forster Streets, Room 1623
Harrisburg, PA 17120
1-888-723-3422
Puerto Rico
Genaro Torres
Emergencies and Title HI-SARA Section 313
Environmental Quality Board
Fernandez Junco Station
P.O. Box 11488
Santurce, PR 00910
(787) 766-2823; Fax: (787) 766-0150
jcaemer@prtc.net
Certified Mail ONLY
Genaro Torres
Director of Superfund and Emergencies
Environmental Quality Board
Emergency Response and Remedial Office
National Plaza #431
Ponce de Leon Avenue
HatoRey,PR00917
Rhode Island
Karen Slattery
Rhode Island Department of Environmental
Management
Office of Air Resources
235 Promenade Street, Suite 230
Providence, RI 02908
Attn: Toxics Release Inventory
(401) 222-2808, ext. 7030
Fax: (401) 222-2017
karen. slattery @dem. ri. gov
South Carolina
Michael Juras
Community Right-to-Know
Department of Health and Environmental Control
2600 Bull Street
F-6 Toxics Release Inventory Reporting Forms and Instructions
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Appendix F
Columbia, SC 29201
(803) 898-4385; Fax: (803) 898-4487
jurasms@dhec.sc.gov
South Dakota
PMB 2020
Lee Ann Smith, TRI Coordinator
SD Department of Environment and Natural
Resources
523 East Capitol
Pierre, SD 57501-3181
(605) 773-3296; Fax: (605) 773-6035
leeann. smith@state. sd.us
Tennessee
Betty Eaves, Administrator
Tennessee Emergency Response Council
Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville, TN 37204
(615) 741-2986; Fax: (615) 741-4173
beaves@tnema.org
Texas
U.S. Postal Service Delivery including Certified
Mail
Blake Kidd
Toxics Release Inventory Program, MC 164
Texas Commission Environmental Quality
P.O. Box 13087
Austin, Texas 78711-3087
(512) 239-1441; Fax: (512) 239-1555
toxic@tceq.state.tx.us
TRI Help Line: 512-239-4874
Overnight Express Mail ONLY
Blake Kidd
Toxics Release Inventory Program, MC 164
Texas Commission Environmental Quality
12100 Park 35 Circle, Bldg. E., Third Floor
Austin, Texas 78753
Utah
Michael Zucker
UT Dept. of Environmental Quality
168 North 1950 West
Salt Lake City, UT 84116
ATTN: TRI COORDINATOR
(801) 536-4143; Fax: (801) 536-4242
mzucker@utah. gov
Vermont
Paul Van Hollebeke
VT Dept. Of Environmental Conservation
Environmental Assistance Division
103 South Main Street
Waterbury, VT 05671-0411
(802) 241-3629; Fax: (802) 241-3273
paul.vanhollebeke@anr.state.vt.us
Virgin Islands
Hollis L. Griffin
Department of Planning and Natural
Resources
Division of Environmental Protection
Cyril E. King Airport
Terminal Bldg., 2nd Fir.
ST. Thomas, VI00802
St. Croix: (340) 773-0565 Fax: (340) 773-9310
St. Thomas: (340) 774-3320 Fax: (340) 714-9549
hlgrifl2@viaccess.net
Virginia
Dona Huang
Virginia Department of Environmental Quality
SARA Title III Program
P.O. Box 10009
Richmond, VA 23240-0009
(804) 698-4572; Fax: (804) 698-4264
drhuang@deq. virgnia. gov
http://www.deq.virginia.gov/sara3/313.html
Certified or Express Mail ONLY
Dona Huang
SARA Title III Program
Virginia Department of Environmental Quality
629 E. Main Street
Richmond, VA 23219
Washington
Idell Hansen
EPCRA TRI Coordinator
Dept. of Ecology
P.O. Box 47659
Olympia, WA 98504-7659
(360) 407-6727 or (800) 633-7585
Fax: (360) 407-6715
ihan461@ecy.wa.gov
http://www.ecy.wa.gov/epcra
Toxics Release Inventory Reporting Forms and Instructions F-7
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Appendix F
Delivery including certified mail:
Idell Hansen
Department of Ecology
Hazardous Waste/Toxics Reduction Program
300 Desmond Drive
Lacey, WA 98503
West Virginia
Dave Dodrill
West Virginia Emergency Response Commission
West Virginia Office of Emergency Services
1900 Kanawha Boulevard, Building 1,
RoomEB-80
Charleston, WV 25305-0360
(304) 558-5380; Fax: (304) 344-4538
ddodrill@wvoes.state.wv.us
Wisconsin
Michael T. Neuman
Toxics Release Inventory Coordinator
Wisconsin Department of Natural Resources
101 South Webster Street
P.O. Box 7921
Madison, WI 53707-7921
(608) 266-5428; Fax: (608) 266-5226
michael.neuman@dnr.state.wi.us
Wyoming
Bobbi Tenborg
SARA Title III Program Manager
Wyoming Office of Homeland Security
Emergency Management Agency
122 W 25th Street.
Herschler Building, 1st Floor East
Cheyenne, WY 82002
(307) 777-4910; Fax: (307) 635-6017
btenbo@state. wy .us
F-8 Toxics Release Inventory Reporting Forms and Instructions
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Appendix G. Section 313 EPA Regional Contacts
Region 1 (CT, ME, MA, NH, RI, and VT)
Dwight Peavey
Assistance and Pollution Prevention Office
USEPA Region 1 (SPT)
1 Congress Street, Suite 1100
Boston, MA 02114-2023
(617) 918-1829; fax: (617) 918-1810
peavey.dwight@epa.gov
Region 2 (NJ, NY, PR, and VI)
Nora Lopez
Pesticides and Toxic Substances Branch
USEPA Region 2 (MS-105)
2890 Woodbridge Avenue, Building 10
Edison, NJ 08837-3679
(732) 906-6890; fax: (732) 321-6788
lopez.nora@epa.gov
Region 3 (DE, DC, MD, PA, VA, and WV)
William Reilly
Toxics Programs and Enforcement Branch
USEPA Region 3 (3WC33)
1650 Arch Street
Philadelphia, PA 19103-2029
(215) 814-2072; fax: (215) 814-3114
reilly. william@epa. gov
Region 4 (AL, FL, GA, KY, MS, NC, SC, TN)
Ezequiel Velez
EPCRA Enforcement Section
USEPA Region 4
Atlanta Federal Center
6IForsyth Street, S.W.
Atlanta, GA 30303-8960
(404) 562-9191; fax: (404) 562-9163
velez.ezequiel@epa.gov
Region 5 (IL, IN, MI, MN, OH, and WI)
Thelma Codina
Pesticides and Toxics Branch
USEPA Region 5 (DT-8J)
77 West Jackson Boulevard
Chicago, IL 60604
(312) 886-6219; fax: (312) 353-4788
codina.thelma@epa.gov
Region 6 (AR, LA, NM, OK, and TX)
Morton Wakeland
Toxics Section, Multimedia Planning and Permitting
Division
USEPA Region 6 (6PD-T)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
(214) 665-8116; fax: (214) 665-6762
wakeland.morton@epa.gov
Region 7 (IA, KS, MO, and NE)
Stephen Wurtz
Air, RCRA and Toxics Division
USEPA Region 7 (ARTD/CRIB)
901 North 5th Street
Kansas City, KS 66101
(913) 551-7315; fax: (913) 551-7065
wurtz.stephen@epa.gov
Region 8 (CO, MT, ND, SD, UT, and WY)
Joyel Dhieux
Office of Pollution Prevention, Pesticides and Toxics
USEPA Region 8 (8P-P3T)
999 18th Street, Suite 300
Denver, CO 80202-2466
(303) 312-6447; fax: (303) 312-6044
dhieux.joyel@epa.gov
Region 9 (AS, AZ, CA, GU, HI, MH, MP, and NV)
Nancy Sockabasin
Toxics Office
USEPA Region 9 (CMD-4)
75 Hawthorne Street
San Francisco, CA 94105-3901
(415) 972-3772; fax: (415) 947-3583
sockabasin.nancy@epa.gov
Region 10 (AK, ID, OR, and WA)
Christina Colt
Office of Air, Waste, and Toxicx
USEPA Region 10 (OAWT-128)
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-4016; fax: (206) 553-8509
colt.christina@epa.gov
Toxics Release Inventory Reporting Forms and Instructions G-l
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Appendix H. Other Relevant Section 313 Materials
Public Data Release
2002 Toxics Release Inventory Public Data Release
Report
EPA released the 2002 TRI data on June 23, 2004. TRI
summary information and data access is available via the
web at http://www.epa.gov/tri/tridata/tri02. The 2002 TRI
Data Release Web site provides fast and easy access to the
data overview and relevant TRI information (including
tables, charts, maps, and a summary of key findings). The
TRI data can be accessed using the TRI Explorer
(http://www.epa.gov/triexplorer) as well as several other
public access tools available on the TRI website. EPA also
released one electronic publication summarizing the 2002
data: the 2002 TRI Public Data Release (PDR) Report
(EPA-260-R-04-003). This report provides an overview of
the 2002 TRI reporting year data and other information
relating to TRI data. The PDR report serves as a supplement
to EPA's on-line tool TRI Explorer where users of TRI data
can retrieve electronic 2002 state fact sheets that provide a
snapshot of each state's releases and other waste
management activities and a description of the information
included in the state fact sheet.
Access to TRI Information On-line
TOXNET® , the National Library of
Medicine's (NLM) Toxicology Data Network, provides free
access to TRI data. Users can search by chemical or other
name, chemical name fragment, or Chemical Abstracts
Service Registry Number. Also searchable are facility or
parent company name, state, city, county, or zip code.
Search results can be limited to releases greater than a
specified number of pounds, and individual releases can be
summed together to display a total amount.
RTK-Net is an online network concerned
with environmental issues, in particular, matters arising
from the passage of right-to-know provisions embodied in
EPCRA legislation. RTK-net was established by two non-
profit organizations (Unison Institute and OMB Watch) to
provide access to TRI, link TRI with other environmental
data, and exchange information among public interest
groups. RTK-Net is a full-service center providing free
dial-in access privileges to complete database services,
training and technical support, e-mail and electronic
conferences pertaining to issues such as health, activism,
and environmental justice. For more information contact:
RTK-Net
1742 Connecticut Ave., N.W.
Washington, D.C. 20009-1171
202 234-8494
The TRI Home Page offers information
useful to both novice and experienced users of the Toxics
Release Inventory. It provides, in lay terms, a description of
what TRI is, how it can be used, TRI data, and TRI rules
and guidance. You can find out about TRI products, view or
download the 2001 TRI data release reports, and identify
who to contact for more information in EPA regions and
state programs across the country. From the TRI home page,
you can "link" to other EPA and non-EPA sites that allow
you to search the TRI database online.
TRI Explorer is an on-line tool
that EPA has created to allow for searches of the TRI data.
It allows the user to search using six criteria: facility,
chemical, year or industry type (SIC code), federal facility
and geographic area (at the county, state or national level).
The tool will generate three types of reports: (1) Release
Reports (including on- and off-site releases (i.e., off-site
releases include transfers off-site to disposal and metals and
metal compounds transferred to POTWs)); (2) Waste
Transfer Reports (including amounts transferred off-site for
further waste management but not including transfers off-
site to disposal); and (3) Waste Quantity Reports (including
amounts recycled, burned for energy recovery, quantities
treated, and quantities released).
Other TRI Information
EPA's Integrated Risk Information System (IRIS)
is an electronic database containing
information on human health effects that may result from
exposure to various chemicals in the environment. IRIS was
initially developed for EPA staff in response to a growing
demand for consistent information of chemical substances
for use in risk assessments, decision-making and regulatory
activities. The information in IRIS is intended for those
without extensive training in toxicology, but with some
knowledge of health sciences.
Consolidated List of Chemicals Subject to the
Emergency Planning and Community Right-to-Know
Act and Section 112(r) of the Clean Air Act (List of
Lists), (October 2001)
Toxics Releases Inventory Forms and Instructions H-l
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Appendix H
A paper copy is available from the National Technical
Information Service, 5285 Port Royal Road, Springfield, VA
22161, 703 605-6000, Document Number: PB2003-105834,
$38.00 plus $5.00 shipping and handling.
Chemicals in Your Community, A Citizen's Guide to the
Emergency Planning and Community Right-to-Know
Act, December 1999 (EPA 550-99-001)
This booklet is intended to provide a general overview of
the EPCRA requirements and benefits for all audiences.
Part I of the booklet describes the provisions of EPCRA and
Part II describes more fully the authorities and
responsibilities of groups of people affected by the law.
Available through written request at no charge from the
Emergency Planning and Community Right-To-Know
(EPCRA) Call Center. For contact information, please see
the TRI Home Page at .
Chemicals in the Environment
Issue number 6 of Chemicals in the Environment (CIE),
published in the Fall of 1997, is devoted entirely to TRI.
This 22 page publication contains 19 articles ranging from
the history of TRI to the future of new TRI products.
Articles include perspectives from the community, state,
Federal, and International level. The publication also
provides valuable information on training and contacts
within the EPA. CIE is available free from EPA by asking
for publication EPA 749-R-97- 00Ib. To request copies,
contact:
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave., N.W.
Attn: TRI Documents
MC: 2844
Washington, DC 20460
202 564-9554
Email: TRIDOCS@epa.gov
workplaces, and communities.
To request EPA information on pollution prevention or
obtain factsheets on pollution prevention from various state
programs call the PPIC reference and referral service at
202 566-0799, or fax a request to 202 566-0794, or write to:
U.S. EPA
Pollution Prevention Information Clearinghouse
(PPIC)
EPA West
1200 Pennsylvania Ave. NW
Room 3379 (Mail Code 7407-T)
Washington, DC 20460-0001
Email: ppic@epa.gov
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,
H-2 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix I. Sample Withdrawal Letter
REQUEST FOR WITHDRAWAL
Facility Name
Facility Mailing Address
Date:
TRI Data Processing Center
P.O. Box 1513
Lanham, MD 20703-1513
Attention: TRI Withdrawal Request
To whom it may concern:
(Fill in your facility name and TRIFID here) is requesting a withdrawal for the
following submission filed under EPCRA Section 313 from EPA's database (i.e. the Toxics Release
Inventory System (TRIS)):
Chemical Name Reported:
CAS Number/Category Code:
Report Type (please check one): Form R d Form A Certification d
Reporting Year:
Reason(s) for Withdrawal:
Please include a copy of Form R or Form A certification you want to withdraw.
The technical contact is: Insert name here and may be reached at:
Insert telephone number here .
Requester's Name:
Requester's Signature:
Address:
(* if different from facility
address or facility mailing
address)
Please submit a copy of the request to appropriate state agency, if required.
Toxics Release Inventory Reporting Forms and Instructions 1-1
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Index
Activity Exemptions 15
Activity Index 65
Alternate Threshold 70
Ammonia 23
Ancillary Use 38
Article Component 37
Articles Exemption 16
ATRS3
B
Byproduct 37
c
CDX5
Central Data Exchange 5
Certification of Form R 31
Chemical Categories 23, 35
Chemical Category Codes 35
Chemical Processing Aid 38
Chemical Synonym 35
Coal Extraction Activities Exemption 20
Coincidental Manufacture 12, 13, 20
Container Residue 49
Contractor 9
Facility Identification 31
Facility Identification Number 31
Federal Information Processing Standards (FIPS)
Codes IV-1
Form A 72
Form R 31
Formulation Component 37
Fugitive Air Emissions 40
Full-Time Employee Determination 9
Generic Chemical Name 35, 36, 71, 75, 76
GOCO Facility 32
Guidance Documents 7
I
Import 12, 37
Impurity 12, 37
Internet Submission 5
Joint Venture 34
D
De Minimis Exemption 17, 18, 20
Definitions
Establishment 32
Facility 31
Manufacture 12
Otherwise Use 14
Process 12
Dioxin and Dioxin-like Compounds 60
Data Precision 15
Distribution 36
Maximum Amount On Site 39
Discharges to Publicly Owned Treatment Works 46
Discharges to Receiving Streams or Water Bodies 41
Diskette Submissions 5
Disposal to Land On-site 41
Double-Counting 63, 65
Dun & Bradstreet Number 33, 34
E
Employee Threshold Determination 9
EPA Identification Number 33
EPCRA Call Center 7
EPCRA Reporting Center 6
Executive Order 13148 1
Exemptions 15
Laboratory Activities Exemption 20
Land Treatment/Application Farming 41
Landfills 41
Latitude and Longitude 33
Lead and Lead Compounds 15
M
Manufacture 12, 37
Manufacturing Aid 38
Maximum Amount On-site 38
Metal Compounds 23, 25
Metal Mining Overburden Exemption 21
Mixture Component Identity 36
Motor Vehicle Maintenance Exemption 16
Multi-Establishment Facilities 11
N
NA vs. a Numeric Value 40, 60
Nitrate Compounds 24, 25
Non-Point Air Emissions 40
NPDES Permit Number 33
o
On-Site Reuse Operations 23
Organic Compounds 23
Toxics Release Inventory Reporting Forms and Instructions Index—1
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Index
Other Disposal 42
Otherwise Use 14, 38
Otherwise Use Exemptions 15
Overburden 21
Parent Company 33
Partial Facility Indication 32
PBT Chemicals 14, 21, 24, 60
Data Precision 15
List of 21
Thresholds for 21
Point Air Emissions 40
POTW, Transfers to 46
Primary SIC Code Determination 9
Process 12, 37
Produce 37
Production Ratio 64, 68
Public Contact 32
R
Range Codes
Section 5 42
Section 6 46, 47
RCRA Subtitle C landfills 41
RCRA Waste 63
Reactant 37
Recordkeeping 4, 22
Repackaging 37
Reporting by Establishment 11
Reporting Criteria 1
Reporting deadline 5
Reporting Decision Diagram 10
Reporting Year 31
Reuse 14, 16, 50
Revisions 4
Sale/Distribution 37
Section 5 (Part II) 40
Section 6 45
Section 753
Section 8 60
SIC Codes 1-1
Apparel and Other Finished Products made
from Fabrics and Other Similar
Materials 1-2
Business Services 1-7
Chemicals and Allied Products 1-3
Coal Mining 1-1
Electric, Gas, and Sanitary Services 1-7
Electronic and Other Electric Equipment and
Components, Except Computer
Equipment 1-6
Fabricated Metal Products, Except
Machinery and Transportation
Equipment 1-4
Food and Kindred Products 1-1
Furniture and Fixtures 1-2
Industrial and Commercial Machinery and
Computer Equipment 1-5
Leather and Leather Products 1-4
Lumber and Wood Products, Except
Furniture 1-2
Measuring, Analyzing, and Controlling
Instruments; Photographic, Medical
and Optical Goods; Watches and
Clocks 1-6
Metal Mining 1-1
Miscellaneous Manufacturing Industries 1-7
Paper and Allied Products 1-3
Petroleum Refining and
Related Industries 1-3
Primary Metal Industries 1-4
Printing, Publishing, and
Allied Industries 1-3
Rubber and Miscellaneous
Plastics Products 1-3
Stone, Clay, Glass and
Concrete Products 1-4
Textile Mill Products 1-1
Tobacco Products 1-1
Transportation Equipment 1-6
Wholesale Trade-Nondurable Goods 1-7
SIC Manual 9
Significant Figures 43
Source Reduction 60
Stack Air Emissions 40
Stormwater 44, 45
Structural Component Exemption 15
Submitting eletronically 5, 6
Submitting Forms 5
Submitting Separate Reports 32
Surface Impoundments 42
Technical Contact 32
Threshold Determinations 22-24
Ammonia 23
Chemical Categories 23
On-Site Reuse Operations 23
PBT Chemicals 24
Threshold Worksheets 27-30
Trade Secret 3, 31, 35, 71,72
Transfers to Other Off-Site Locations 47
Index -2 Toxics Release Inventory Reporting Forms and Instructions
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Index
Transfers to POTWs 46
TRI Facility Identification Number (TRIFID) 31
TRI-ME2
U
Underground Injection 41
Underground Injection Well Code Identification
Number 33
W
Waste Rock 21
Waste Treatment Codes 55
Energy Recovery Processes 58
Methods and Efficiency 53
Recycling Processes 58
Waste Treatment On Site 53
Withdrawls 4
Toxics Release Inventory Reporting Forms and Instructions Index—3
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Notes
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Notes
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Notes
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oEPA
United States
Environmental Protection
Agency
2844T
Washington, DC 20460
Official Business
Penalty for Private Use $300
PRSRT STD
Postage and
Fees Paid EPA
Permit No. G-35
ATTENTION POSTMASTER
DO NOT X-RAY
Magnetic Media
Included
Attention: Manager of Environmental Programs
EPA 260-B-05-001
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