EPA 260-R-13-001
February 2013
Toxic Chemical Release
Inventory Reporting Forms
and Instructions
Revised 2012 Version
Section 313
of the Emergency Planning and
Community Right-to-Know Act
(Title III of the Superfund Amendments
and Reauthorization Act of 1986)
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Table of Contents
Table of Contents
List of Acronyms i
Important Information for Reporting Year 2012 ii
New Information for Reporting Year 2012 ii
Other Important Information for Reporting Year 2012 iii
TRI-MEweb Reporting Year 2012 version iv
A. General Information 1
A.I Who Must Report 1
A.2 How to Submit Forms 1
A.2.a. How to Submit Form R(s) and/or Form A(s) Certification Statement Electronically to
EPA via the Central Data Exchange (Using the TRI-MEweb Application) 1
A.2.b How to Submit Paper Form R (s) and/or Form A Certification Statement(s) 4
A.3 Trade Secret Claims 5
A.4 Recordkeeping 5
A.5 How to Revise, Withdraw or Cancel TRI Data 6
A.5.1 Revising TRI Data 6
A.5.2 Withdrawing TRI Data 8
A.5.3 Canceling a TRI Submission 9
A.6 When the TRI Report Must Be Submitted 10
A.7 How to Obtain the TRI Reporting Forms 10
B. How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A.. 11
B. 1 Full-Time Employee Determination 11
B.2 Primary NAICS Code Determination 11
B.2.a. Auxiliary Facilities 14
B.2.b. Multi-establishment Facilities 14
B.2.c. Property Owners 15
B.3 Activity Determination 15
B.3.a. Definitions of Manufacture, Process, and Otherwise Use 15
B.S.b.... Persistent Bioaccumulative Toxic (PBT) Chemicals and Chemical Categories Overview
18
B.3.c. Activity Exemptions 19
B.4 Threshold Determinations 25
B.4.a. How to Determine if Your Facility Has Exceeded Thresholds 26
B.4.b. Threshold Determinations for On-Site Reuse Operations 27
B.4.c. Threshold Determinations for Ammonia 27
B.4.d. Threshold Determinations for Chemical Categories 28
B.4.e Threshold Determination for Persistent Bioaccumulative Toxic (PBT) Chemicals .... 29
B.4.f Mixtures and Other Trade Name Products 29
B.5 Release and Other Waste Management Determinations for Metals, Metal Category Compounds,
and Nitrate Compounds 30
C. Instructions for Completing TRI Form R 36
Part I. Facility Identification Information 36
Section 1. Reporting Year 36
Section 2. Trade Secret Information 36
Section 3. Certification 36
Section 4. Facility Identification 36
Section 5. Parent Company Information 39
Part II. Chemical Specific Information 40
Section 1. EPCRA Section 313 Chemical Identity 40
Section 2. Mixture Component Identity 41
Section 3. Activities and Uses of the EPCRA Section 313 Chemical at the Facility 41
Toxics Release Inventory Reporting Forms and Instructions TOC-1
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Table of Contents
Section 4. Maximum Amount of the EPCRA Section 313 Chemical On-site at Any Time during the
Calendar Year 44
Section 5. Quantity of the Toxic Chemical Entering Each Environmental Medium On-site ..45
Section 6. Transfer(s) of the Toxic Chemical in Wastes to Off-Site Locations 52
Section 7. On-Site Waste Treatment, Energy Recovery, and Recycling Methods 61
Section 8. Disposal or Other Releases, Source Reduction, and Recycling Activities 68
D. Instructions for Completing Form R Schedule 1 (Dioxin and Dioxin-like Compounds).... 82
D.I What is the Form R Schedule 1? 82
D.2 Who is required to file a Form R Schedule 1 ? 82
D.3 What information is reported on the Form R Schedule 1 ? 82
E. Facility Eligibility Determination for Alternate Threshold and for Reporting on TRI Form
A Certification Statement 85
E.I Alternate Threshold 85
E.2 What is the Form A Certification Statement? 85
E.3 What Is the Annual Reportable Amount (ARA)? 85
E.4 Recordkeeping 86
E.5 Multi-establishment Facilities 86
E.6 Trade Secrets 86
E.I Metals and Metal Category Compounds 86
F. Instructions for Completing TRI Form A Certification Statement 88
Part I. Facility Identification Information 88
Section 1. Reporting Year 88
Section 2. Trade Secret Information 88
Section 3. Certification 88
Section 4. Facility Identification 89
Section 5. Parent Company Information 91
Part II. Chemical Identification 92
Section 1. Toxic Chemical Identity 92
Section 2. Mixture Component Identity 93
Index 94
Toxics Release Inventory Reporting Forms and Instructions TOC-2
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Table of Contents
Examples
Example 1: Coincidental Manufacture 16
Example 2: Typical Process and Manufacture Activities 17
Example 3: Typical Otherwise Use Activities 17
Example 4: Articles Exemption 20
Example 5: De Minimis Applications to Process and Otherwise Use Scenarios for Non-PBT
Chemicals 22
Example 6: Concentration Ranges Straddling the De Minimis Value 23
Example 7: De Minimis Application in the Manufacture of a Toxic Chemical in a Mixture 24
Example 8: Coal mining extraction activities 25
Example 9: Mixtures and Other Trade Name Products 31
Example 10: Mixture Containing Unidentified EPCRA Section 313 Chemical 41
Example 11: Manufacturing and Processing Activities of EPCRA Section 313 Chemicals 44
Example 12: Reporting Dioxins and Dioxin-Like Compounds 46
Example 13: Stormwater Runoff 52
Example 14: Container Residue 56
Example 15: Reporting Metals and Metal Category Compounds that are sent Off-site 57
Example 16: Calculating Releases and Other Waste Management Quantities 63
Example 17: On-Site Waste Treatment 67
Example 18: Reporting On-Site Energy Recovery 68
Example 19: Reporting Future Estimates 70
Example 20: Avoiding Double-Counting Quantities in Sections 8.1 through 8.7 72
Example 21: Quantity Released to the Environment as a Result of Remedial Actions, Catastrophic
Events, or One-Time Events Not Associated with Production Processes 73
Example 22: Determining a Production Ratio 75
Example 23: Determining an Activity Index 75
Example 24: "NA" is Entered as the Production Ratio or Activity Index 75
Example 25: Determining the Production Ratio Based on a Weighted Average 76
Example 26: Source Reduction 79
Example 27: Green Chemistry 80
Figures
Figure 1. TRI-MEweb' s Preparation, Transmission, Certification and Submission Steps 2
Figure 2. EPCRA Section 313 Reporting Decision Diagram 13
Figure 3A. EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet 32
Figure 3B. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100 Pound
Thresholds 33
Figure 3C. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10 Pound
Threshold 34
Figure 3D. EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like
Compounds Chemical Category 35
Figure 4. Reporting EPCRA Section 313 Chemicals 43
Toxics Release Inventory Reporting Forms and Instructions
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Figure 5. Hypothetical Section 6.2 Completed for Two Off-Site Locations 60
Figure 6. Hypothetical Section 7A 64
Figure 7. Hypothetical Form R, Section 5.1 and Form R Schedule 1, Section 5.1 83
Tables
Table I NAICS Codes 1-1
Table II EPCRA Section 313 Chemical for Reporting Year 2012 (including Toxic Chemical
Categories) II-1
Table III State Abbreviations III-l
Table IV Federal Information Processing Standards (FIPS) Country Codes IV-1
Table V Bureau of Indian Affairs (BIA) Tribal Codes V-l
Appendices
Appendix A Federal Facility Reporting Information A-l
Appendix B Reporting Codes for EPA Form R and Instructions for Reporting Metals B-l
Appendix C Facility Data Profiles and Common Errors in Completing Form R Reports and Form A
Certification Statements C-
Appendix D Supplier Notification Requirements D-
Appendix E TRI State and Tribal Contacts E-
Appendix F TRI Regional Contacts F-
AppendixG Other Relevant Section 313 Materials G-
AppendixH Guidance Documents H-
Appendix I Questions and Answers Regarding Facility Identification Information I-
Toxics Release Inventory Reporting Forms and Instructions
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Toxics Release Inventory Reporting Forms and Instructions
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List of Acronyms
List of Acronyms
ARA Annual Reportable Amount
BIA Bureau of Indian Affairs
CAS Chemical Abstract Services
CBI Confidential Business Information
CDX Central Data Exchange
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
D&B Dun & Bradstreet
DPC Data Processing Center
DQA Data Quality Alert
EBDCs Ethylenebisdithiocarbamic Acid, Salts and Esters
eFDP Electronic Facility Data Profile
EPA Environmental Protection Agency
EPCRA Emergency Planning and Community Right to Know Act
ESA Electronic Signature Agreement
FDP Facility Data Profile
FIPS Federal Information Processing Standard
FR Federal Register
GOCO Government-Owned, Contractor-Operated
IARC International Agency for Research and Cancer
ICR Information Collection Request
MSDS Material Safety Data Sheets
NA Not Applicable
NDC Non-Technical Data Changes
NAICS North American Industry Classification System
NON Notice of Non-Compliance
NOSE Notice of Significant Error
NOTE Notice of Technical Errors
NPDES National Pollutant Discharge Elimination System
NTP National Toxicology Program
OMB Office of Management and Budget
OSHA Occupational Safety and Health Act
P2 Pollution Prevention
PACs Polycyclic Aromatic Compounds
PBBs Polybrominated Biphenyls
PBT Persistent Bioaccumulative Toxic
PCBs Polychlorinated Biphenyls
POTW Publicly Owned Treatment Works
PPA Pollution Prevention Act
RCRA Resource Conservation and Recovery Act
RY Reporting Year
SBREFA Small Business Regulatory Enforcement Fairness Act
SIC Standard Industrial Classification
TDX TRI Data Exchange
TRI Toxics Release Inventory
TRIFID Toxics Release Inventory Facility Identification Number
TRIPS Toxics Release Inventory Processing System
UIC Underground Injection Control
USC United States Code
VOCs Volatile Organic Compounds
Toxics Release Inventory Reporting Forms and Instructions
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Important Information for Reporting Year 2012
Important Information for
Reporting Year 2012
New Information for Reporting Year
2012
Please note that this 2012 version of the Toxics
Release Inventory (TRI) Reporting Forms and
Instructions document supersedes previous versions
of the document.
• Administrative Stay Lifted for TRI
Hydrogen Sulfide (H2S) Reporting
A Federal Register notice was issued on
Monday, October 17, 2011 (76 FR 64022)
announcing that EPA is lifting the
Administrative Stay of the EPCRA section 313
toxic chemical release reporting requirements of
hydrogen sulfide - H2S - (CAS No. 7783-06-4).
Reporting for H2S is required for RY 2012
reporting (i.e., for Form R and Form A
Certification Statements that are due to the
Agency at midnight on July 1, 2013). For more
information about the lifting of the
administrative stay for H2S, see:
http://www.epa.gov/tri/lawsandregs/hydrogensu
Ifide/indexfhtml.
• TRI Reporting for Facilities Located in
Indian country and Clarification of
Additional Opportunities Available to Tribal
Government under the TRI Program
EPA finalized a rule on April 19, 2012 (77 FR
23409) which requires each facility located in
Indian country to submit TRI reports to EPA
and the appropriate tribe, rather than to the state
in which the facility is geographically located.
The final rule also provides the tribal
chairperson or equivalent elected official of a
tribe with the same opportunities as the
governor of a state with regard to TRI-related
requests and petitions. The rule requirements are
applicable for reporting year 2012 for TRI
reports due to the Agency by July 1, 2013.
• Pollution Prevention
In order to promote pollution prevention, EPA
has increased the prominence and accessibility
of the pollution prevention information reported
in Sections 8.10 and 8.11 of the Form R. For
example, the 2011 TRI National Analysis
highlighted the parent companies that reported
the greatest number of
activities. To learn
www. epa. gov/TRI/P2.
source reduction
more, visit
New Green Chemistry Source Reduction
Codes
New source reduction codes that describe green
chemistry practices have been added to the list
of selections available for completing Section
8.10.
New in TRI-MEweb for RY 2012
o New Certification Process in TRI-MEweb
for RY 2012 Reporting
EPA has developed a new certification
component within the TRI-MEweb
application that will allow a facility to
prepare any reporting year TRI Form R/A
and transition directly into the certification
process without leaving the TRI-MEweb
application.
o New Real-Time Electronic Signature
Agreement (ESA) Approval Option for
New Certifying Officials
For this reporting year, EPA has
implemented an alternative method for
certifying officials to apply for and process
an ESA in real-time using a third-party
identity verification vendor named
LexisNexis. Upon registering for a new
CDX account at https ://cdx. epa. gov. all
newly appointed certifying officials will be
prompted to consider using this third-party
verification and authentication service to
obtain their ESA approval in real-time
instead of processing the traditional paper
ESA form for EPA approval.
An ESA form is a statement that declares
that the registrant understands that any
electronic signature executed with the
electronic signature device is as legally
binding as a handwritten signature and is
required by EPA before any certifying
official can certify and submit a TRI form
created in TRI-MEweb.
o TRI-MEweb Pollution Prevention
Upgrades
EPA has made several changes to TRI-
MEweb to facilitate completion of the
Pollution Prevention section of the Form R
(Section 8). For example, TRI-MEweb now
Toxics Release Inventory Reporting Forms and Instructions
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Important Information for Reporting Year 2012
provides a Production Ratio/Activity Index
Wizard to automatically calculate your
Production Ratio/Activity Index (Section
8.9). TRI-MEweb also includes new tips
and guidance for completing Sections 8.9-
8.11 and allows the user to submit
additional information about specific entries
in Sections 8.9-8.10 if desired. (This
information is then included in Sections
8.11 or 9.1 as appropriate.)
Other Important Information for
Reporting Year 2012
EPA's Audit Policy. If you discover your facility is
or may have been in violation of Section 313 of
EPCRA (TRI Reporting), please refer to EPA's
Policy entitled, "Incentives for Self-Policing:
Discovery, Disclosure, Correction, and Prevention
of Violations" (Audit Policy), 65 FR 19618, April
11, 2000. You may qualify for having all gravity-
based penalties waived if your facility meets all nine
(9) conditions of the Audit Policy. For more
information on EPA's Audit Policy, see the
Agency's website:
http://www.epa.gov/compliance/incentives/auditing/
auditpolicy.html.
EPA Enforcement Response Policy for TRI
Revisions. On September 26, 1991, EPA published
in the Federal Register, a "Notice Regarding
Revisions to Toxic Chemical Release Inventory
Reporting Forms under Section 313 of the
Emergency Planning and Community Right-to-
Know Act of 1986" (56 FR 48795-03). Section V
of the Notice refers to the Agency's Enforcement
and Penalties policy regarding Form R errors:
Facilities are reminded that there is a legal
obligation to file an accurate and complete Form R
report for each chemical by July 1 each year. EPA
may take enforcement action and assess civil
administrative penalties regarding corrections to
errors in Form R reports that are not changes based
on previously unavailable information or procedures
which improve the accuracy of the data initially
reported. The kinds of errors which may result in
enforcement and in penalties include but are not
limited to the following: (1) Errors caused by not
using the most readily available information, for
example, not using monitoring data collected for
compliance with other regulations in calculating
releases; (2) omitting a major source of emissions;
(3) a mathematical or transcription or typographical
error which seriously compromises the accuracy of
the information, and; (4) other errors which
seriously affect the utility of the data, particularly
errors in release reporting for which the facility has
no records showing the derivation of the release
calculation, and cannot provide a sufficient
explanation of the report.
EPA's Small Business Compliance Policy. If you
have 100 or fewer employees and discover that your
facility is or may have been in violation of Section
313 of EPCRA (TRI Reporting), please refer to
EPA's Small Business Compliance Policy. EPA will
eliminate or significantly reduce penalties for small
businesses that meet the conditions of the Policy,
including voluntarily discovering violations and
promptly disclosing and correcting them. This
Policy implements Section 223 of the Small
Business Regulatory Enforcement Fairness Act
(SBREFA) of 1996. For more information, see the
Agency's website:
http://www.epa.gov/compliance/incentives/smallbus
iness/index.html.
Parent Company Information. In past years, the
Agency found that many facilities report inaccurate
parent companies and/or Dun and Bradstreet
numbers in Sections 4 and 5 of the TRI reporting
forms. All facilities should verify the accuracy of
facility and parent company information (e.g.,
DUNS number, parent company name). Related
questions and answers are provided in Appendix I.
Please note that beginning in Reporting Year 2009,
EPA started to pre-load standardized parent
company names into the TRI-MEweb software that
were researched from the prior year submission.
This step was taken to improve the accuracy of
parent company names as well as create a standard
format for the names themselves. For example, only
capital letters are used and all periods are
eliminated from the parent names. In addition,
standardized abbreviations are now used for
common terms found in parent names such as 'CO
for Company' and 'INC for Incorporated. ' More
detailed instructions appear in the Parent Company
name sections of TRI-MEweb.
For facilities still using paper TRI forms to report, a
detailed listing of Parent Company names is
provided at:
http://www. epa. sov/tri/report/index. htm.
Toxics Release Inventory Reporting Forms and Instructions
in
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Important Information for Reporting Year 2012
A. To verify the accuracy of your facility and
parent company Dun and Bradstreet number and
name, as required in Section 5 of both Form R
and Form A, go to:
https ://www. dnb .com/product/dlw/form_cc4 .ht
m or call 1-888-814-1435 to verify your
information. Callers to the toll free phone
number should understand that the Dun and
Bradstreet support representatives will need to
verify that callers requesting the DUNS
numbers are agents of the business. Dun and
Bradstreet recommends knowing basic
information such as when the business
originated, officer names, and the name,
address, and phone number for the facility.
B. Facilities reporting to TRI should also make
sure they are providing the parent company
name and Dun and Bradstreet number as of
December 31st of the current reporting year.
TRI-MEweb Reporting Year 2012
version
The TRI-MEweb application helps facilities fulfill
their Emergency Planning and Community Right-to-
Know (EPCRA) Section 313 and Pollution
Prevention Act (PPA) Section 6607 obligations.
TRI-MEweb is an interactive, intelligent, user-
friendly web-based application tool that guides
facilities through the TRI reporting experience. By
leading prospective reporters through a series of
logically ordered questions, TRI-MEweb
streamlines the analysis needed to determine if a
user must complete a Form R Report or if they meet
the thresholds that allow them to use the Form A
Certification Statement for a particular chemical.
The TRI-MEweb software provides the user with
guidance for each data element on the reporting
Form R and Form A Certification Statement. TRI-
MEweb will check the data on the form for common
errors and then prepare it for electronic transmission
to be certified in CDX (see Figure 1 on page 2 for a
flow diagram of the TRI-MEweb reporting process).
All of the information contained in this RY 2012
Reporting Forms and Instructions manual is
contained within the TRI-MEweb application.
EPA strongly recommends the use of TRI-
MEweb to submit information to the TRI
program. However, if you plan to submit hard
copy forms for current year and prior year forms
(RY 2011 and RY 2012), EPA provides
electronically fillable TRI forms at:
http ://www. epa. gov/tri/reporting_materials/forms/
that can be completed using a computer and then
printed, signed, and mailed.
EPA will accept only TRI-MEweb or paper
submissions for RY 2012. The following are
reasons why you should use TRI-MEweb in RY
2012:
• TRI-MEweb will guide reporting facilities
through the RY 2012 changes to the reporting
requirements described earlier in this section.
• A Web-enabled threshold determination tool is
available on the TRI website at:
http ://www. epa. gov/tri/reporting_materials/thres
hold/ to help facilities determine whether they
need to report to TRI. The threshold tool is
useful in determining whether a facility meets
all three threshold indices: number of
employees, covered industry sector and
chemical-specific thresholds.
Toxics Release Inventory Reporting Forms and Instructions
IV
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Important Information for Reporting Year 2012
• TRI-MEweb can be used to revise prior or
current year data (RY 2005-RY 2012). TRI-
MEweb stores data from the previous seven
reporting years for each facility so that users no
longer have to load the data each year.
o If your facility needs to revise forms prior to
RY 2005, EPA only accepts those revisions
on hard-copy TRI forms.
• Facilities that reside in a state or in Indian
Country participating in the TRI Data Exchange
will have their TRI forms sent simultaneously to
EPA and their state TRI representative via the
Environmental Information Exchange Network.
o For states or tribes not on the TRI Data
Exchange (TDX), TRI-MEweb allows
facilities to generate paper/disk/CD
submissions for their state or tribe. Please
note, however, that EPA's Data Processing
Center does not accept disk/CD
submissions.
• Facilities located within Indian country must
find the corresponding Bureau of Indian Affairs
(BIA) three-digit code for the appropriate tribe
in Table V and fill in the code in the tribal name
field in Section 4.1 of Form R or Form A or use
the drop-down menu in TRI-MEweb to find the
BIA code. Currently, there are no tribes
participating in EPA's TRI Data Exchange.
Therefore, hard-copies of TRI forms must be
mailed to the appropriate tribal point of contact.
Facilities using TRI-MEweb to fulfill their
federal and tribal reporting requirements will be
able to print a copy of the TRI form to be
mailed to the appropriate tribal point of contact.
(See Appendix E for link to points of contact
and addresses.)
Uncertified TRI-MEweb Submissions. For Form
R and/or Form A submissions via TRI-MEweb, a
facility's registered certifying official must
electronically sign the submission before it can be
processed and entered into the TRI database.
Uncertified electronic submissions created in TRI-
MEweb are not considered to have completed the
reporting requirement under EPCRA Section 313.
Lack of certification will also prevent the
submission from being processed by EPA.
How to Begin Using the Reporting
Year 2012 TRI-MEweb Reporting
Tool
Getting started. In early 2013, all technical
contacts, preparers, and certifying officials from
reporting facilities that filed TRI reports in the prior
reporting year will be emailed their 6-digit alpha
numeric access key for each facility account in TRI-
MEweb. This unique access key is used to load any
TRI data received by EPA from the past seven
reporting years into its corresponding TRI-MEweb
facility account. Facilities that have not received
their unique 6-digit access key by February should
call the Central Data Exchange (CDX) helpdesk
(888) 890-1995. TRI-MEweb users may also use the
access key that EPA sent to facility contacts in
previous years, however, in some exceptional cases,
the key may have been changed by EPA's Data
Processing Center.
TRI-MEweb is accessed through EPA's Central
Data Exchange (CDX). The TRI-MEweb
application uses EPA's CDX network to transmit
and certify electronic submissions to EPA. CDX
allows facilities to submit a paperless report and
receive instant receipt confirmation of their
submission via the Internet. In addition, facilities
that reside in a state or tribe participating in the TRI
Data Exchange will have their forms sent
simultaneously to EPA and their state or tribal TRI
representative in electronic format.
How to Log into the Reporting Year
2012 TRI-MEweb Tool
Log in to your CDX user account to open the
TRI-MEweb application. Preparers and certifying
officials must have a CDX user account. During the
CDX registration process, both will need to add the
TRI-MEweb application to the CDX user account
before a user can start preparing/certifying their TRI
forms. Your web browser must have a security
setting of TLS 1.0 enabled. Otherwise, the CDX
login web page will appear as if it is broken. For
detailed instructions for changing the security
settings on your Web browser, go to the TRI-
MEweb Resource Web page:
http ://www. epa. gov/tri/reporting_materials/trimewe
b/.
• If you cannot reset the password to your CDX
account or have forgotten your CDX login
name, please call the CDX Hotline (888) 890-
1995.
Toxics Release Inventory Reporting Forms and Instructions
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Important Information for Reporting Year 2012
• For assistance setting up a new CDX user
account, adding your TRI role, adding the TRI-
MEweb application to your CDX user profile,
or for information on how to use the TRI-
MEweb reporting tool, please visit:
http ://www. epa. gov/tri/reporting_materials/trim
eweb/.
CDX login can
https://cdx.epa.gov/.
be accessed at:
Two user roles involved in TRI Reporting. If your
facility is using TRI-MEweb to prepare, transmit,
and certify TRI forms to EPA, the application
requires that two user roles be created. First,
individuals who use TRI-MEweb to prepare and
transmit data to CDX ("preparers") must have a
role, and second, individuals who will certify
pending TRI forms ("certifying officials") must
have a role. Both preparers and certifiers must have
CDX user accounts. TRI-MEweb allows the
certifying official to also prepare TRI forms (dual
role). All newly designated certifying officials with
CDX accounts are required to submit an Electronic
Signature Agreement (ESA) application to EPA for
approval before facilities can certify TRI forms
submitted to EPA and their appropriate state or
tribe. (See Section A.2 for details on ESA
processing)
TRI-MEweb can import previous year data into
current year chemical forms. TRI-MEweb now
has the ability to import prior year data (if RY 2011
data was provided in the previous year by reporting
facility) into each selected current year TRI
chemical form. Importing data is optional; however,
it can accelerate data entry if the same chemicals are
reported to EPA every reporting year.
Easier certification process now built into TRI-
MEweb. EPA has developed a new certification
process within TRI-MEweb that allows a facility to
prepare any reporting year TRI Form R or Form A
Certification Statement and go directly into the
certification process. In past years, certifying
officials had to leave TRI-MEweb to do the
certification process. A user with a dual role
(preparer role and certifying official role) will no
longer need to log out of the system to certify the
forms prepared in the TRI-MEweb application. The
certifying official will simply login into their CDX
account and open TRI-ME-web to certify any TRI
forms with certification pending.
1. New security requirements. All certifying
officials responsible for an ESA approved in a
prior year must comply with new security
standards by choosing and answering 5
questions from a list of 20. One of the answered
questions will be used to verify and authenticate
the identity of the certifying official as part of
the electronic signature process. As part of the
new process, you will also be required to
provide the TRIFID of your reporting facility
and electronically sign a TRIFID Certification
Agreement to obtain access to any pending
submissions. The new certification module in
TRI-MEweb captures and stores this
information for all certifying officials. A user
with a dual role (preparer role and certifying
official role) will no longer need to logout to
begin certifying forms prepared in the TRI-
MEweb application.
2. Electronically sign your current Electronic
Signature Agreement (ESA). If you have an
existing ESA, you must "electronically sign"
that ESA to ensure that it continues to be valid
under the new electronic reporting
requirements. From now on, revalidated ESAs
will be referred to as CDX ESAs. All new
certifying officials must sign a CDX ESA in
TRI-MEweb to allow for expanded reporting
functionality. Certifiers are not required to mail
a hardcopy of this expanded CDX ESA to the
EPA's Data Processing Center for approval.
Certifiers completing this step will be able to
add facility account(s) without having to
generate a new hardcopy ESA.
3. Add the TRI Facility Identification Number
(TRIFID) to the new certification module in
TRI-MEweb. If you are a certifying official
with a current ESA, who is logging into a CDX
user account for the first time, you will be
prompted to proceed directly to the "Manage
TRIFIDs" section under the "Certify" tab. Once
there, you must add all TRIFIDs for which TRI
forms will be transmitted. If any TRI forms
have been previously sent, they will appear
under the "Pending Submission" subtab.
New "real-time" Electronic Signature Agreement
(ESA) approval option for new certifying
officials. EPA now provides an alternative method
for certifying officials to process ESAs in real-time
using a third-party identity verification vendor
named LexisNexis. In the past, all new ESA
applications were required to be mailed in for
approval, a process that took about two weeks. Now
all new certifying officials will be prompted to
consider using LexisNexis to obtain their ESA
approval upon registering for a new CDX account at
Toxics Release Inventory Reporting Forms and Instructions
VI
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Important Information for Reporting Year 2012
https://cdx.epa.gov. ESAs approved using
LexisNexis will receive electronic notification in
seconds, or "real time".
Another significant advantage of the LexisNexis
method, besides obtaining immediate ESA approval,
is that the LexisNexis approval is applicable to
multiple CDX system flows (TRI). Programs like
eTSCA and Risk Management Plan (RMP eSubmit)
will be able to share the security credentials offered
by the CDX ESA obtained under TRI. To obtain this
real-time approval, the certifying official must
provide personal identity authentication information
such as name, address, etc. Please note that EPA
does not collect any personal information from our
users. The use of these third party verification and
identification widgets is common in banking
systems.
However, for those new certifying officials that do
not wish to provide personal information to a third-
party vendor, or who fail the LexisNexis method for
some reason, the traditional paper ESA form will
still be available. The hard-copy ESA approval
process requires the printing, completion, and
mailing of an electronic signature agreement
form (see page 4 for where to send form). Please
allow adequate time for the mailing and
processing of this form, which is estimated to
take a minimum of five (5) business days.
Facilities that do not have a signed ESA, either
electronically or on hardcopy, will not be able to
certify forms in TRI-MEweb. It is suggested that
certifying officials complete their ESA well in
advance of the reporting deadline.
TRI-MEweb can be used to submit revisions or
withdrawals for data reported between RY 2005
through RY 2012. If you need to revise or
withdraw prior or current year data, we encourage
you to submit revisions using the TRI-MEweb
application. If you need to revise or withdraw forms
prior to RY 2005, you must provide these requests
on hardcopy TRI forms.
Facilities are reminded that there is a legal
obligation to file an accurate and complete Form R
report for each chemical by July 1 each year. EPA
may take enforcement action and assess civil
administrative penalties regarding corrections to
errors in Form R reports that are not changes based
on previously unavailable information or procedures
which improve the accuracy of the data initially
reported. The kinds of errors which may result in
enforcement and in penalties include but are not
limited to the following: (1) Errors caused by not
using the most readily available information, for
example, not using monitoring data collected for
compliance with other regulations in calculating
releases; (2) omitting a major source of emissions;
(3) a mathematical or transcription or typographical
error which seriously compromises the accuracy of
the information, and; (4) other errors which
seriously affect the utility of the data, particularly
errors in release reporting for which the facility has
no records showing the derivation of the release
calculation, and cannot provide a sufficient
explanation of the report.
Electronic Facility Data Profile (eFDP). Reporting
facilities may confirm and review their submitted
TRI data to EPA by viewing their electronic Facility
Data Profile (eFDP) on the Internet by logging into
their CDX account and clicking the TRI-MEweb:
TRI Made Easy link from their MyCDX page. This
will open the "Welcome" page of the TRI-MEweb
application. On the "Welcome" page, follow the
instructions for viewing the eFDP. If the Technical
Contact provides an email address in the Form
R/Form A Certification Statement, they will receive
an email notifying them when their eFDP has been
updated and published for review in TRI-MEweb.
TRI-MEweb User Resources
• TRI-MEweb website:
http ://www. epa. gov/tri/reporting_materials/trim
eweb/. Any service notification that may impact
your electronic reporting will be posted on this
webpage. This webpage also contains links to
reference materials that will assist you in
fulfilling your reporting requirements.
• TRI-MEweb Online tutorials:
http ://www. epa. gov/tri/reporting_materials/tutor
ials/tutorial_index. html. If you need additional
assistance on how to perform the different tasks
within the Web-based application reporting tool,
we advise you to view the TRI-MEweb Online
Tutorials These tutorials provide step-by step
instruction on how to use TRI-MEweb.
• TRI Information Center Hotline [(800) 424-
9346 - select option 3] and CDX Help Desk
(888) 890-1995: These hotlines provide
CDX/TRI-MEweb technical support and
reporting requirements assistance to help
reporting facilities meet their TRI reporting
obligations.
Toxics Release Inventory Reporting Forms and Instructions
vn
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General Information
A. General Information
Reporting to the Toxic Chemical Release Inventory
(i.e., Toxics Release Inventory (TRI)) is required by
Section 313 of the Emergency Planning and
Community Right to Know Act (EPCRA, or Title
III of the Superfund Amendments and
Reauthorization Act of 1986), Public Law 99 499.
The information contained in the Form R constitutes
a "report," and the submission of a report to the
appropriate authorities constitutes "reporting."
The Pollution Prevention Act, of October, 1990
(Pub. L. 101 508), added reporting requirements to
the Form R. These requirements affect all facilities
required to submit a Form R under Section 313 of
EPCRA. The data were required beginning with
reports for calendar year 1991.
Reporting is required to provide information to the
public on 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 onetime 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 Code of Federal Regulations (CFR) Part 372
(originally published February 16, 1988, in the
Federal Register and November 30, 1994, in the
Federal Register (for Form A)).
A. 1 Who Must Report
• Section 313 of EPCRA requires that reports be
filed by owners and operators of facilities that
meet all of the following criteria.
• The facility has 10 or more full-time employee
equivalents (i.e., a total of 20,000 hours or
greater; see 40 CFR 372.3); and
• The facility is included in a North American
Industry Classification System (NAICS) code
listed in Table I. NAICS codes found in Table I
correspond to the following Standard Industrial
Classification (SIC) Codes: SIC 10 (except
1011, 1081, and 1094), 12 (except 1241), 20-39,
4911 (limited to facilities that combust coal
and/or oil for the purpose of generating
electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil
for the purpose of generating electricity for
distribution in commerce), 4939 (limited to
facilities that combust coal and/or oil for the
purpose of generating electricity for distribution
in commerce), 4953 (limited to facilities
regulated under RCRA Subtitle C, 42 U.S.C.
Section 6921 et seq.), 5169, 5171, and 7389
(limited to facilities primarily engaged in
solvents recovery services on a contract or fee
basis); and
• The facility manufactures (defined to include
importing), processes, or otherwise uses any
EPCRA Section 313 chemical in quantities
greater than the established threshold in the
course of a calendar year.
Executive Order 13423 extends these reporting
requirements to federal facilities, regardless of their
SIC or NAICS code.
A. 2 How to Submit Forms
Facilities can use TRI-MEweb or paper for
submitting Form R(s) and/or Form A Certification
Statement(s).
A.2.a How to Submit Form R(s) and/or
Form A(s) Certification
Statement Electronically to EPA
via the Central Data Exchange
(Using the TRI-MEweb
Application)
The preferred method to report your toxic chemical
release data to your federal, state or tribal TRI
authorities is by the use of the web-based TRI-
MEweb application via EPA's Environment
Information Exchange Network (EIEN). The EIEN
is a partnership among state, tribes, territories, and
EPA to deliver critical environmental information.
The Central Data Exchange (CDX) is the point of
entry for all TRI reporting facilities to the EIEN for
environmental data submissions to all EIEN
partners. CDX also hosts the TRI-MEweb reporting
tool software. TRI-MEweb allows facilities to file a
Toxics Release Inventory Reporting Forms and Instructions
1
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General Information
paperless report through the Internet, significantly
reducing data errors, and facilities receive instant
receipt confirmation of their submission. There are
several other advantages to using TRI-MEweb for
TRI reporting: prior year TRI form data are
imported into current year forms to expedite
reporting, allowing a certifier to submit an
electronic signature that allows one to file paperless
forms, and error checking software that ensures
higher data quality.
Preparers that use TRI-MEweb to transmit forms
through the Internet via CDX and reside in a state or
tribe participating in the TRI Data Exchange (TDX)
will have their forms sent simultaneously to EPA
and their respective state or tribal officials via the
CDX (Internet submissions are not available for
trade secret claims). Once a TRI submission is
certified, it will be electronically forwarded to state
or tribal officials and your obligation to report to
EPA and your state or tribe will be satisfied.
Please be aware that if your facility does not reside
in a state or tribe participating in the TDX, just
transmitting TRI forms via the Internet does not
satisfy your state or tribal reporting requirements for
your facility. You must report to your state or tribe
separately and in the required format specified by
your state or tribe. However, TRI-MEweb can still
be used by the reporting facility to prepare and print
the proper paper TRI forms for your state or tribal
submission that is not in the TDX. Certifying
officials must sign any TRI forms printed from TRI-
MEweb and physically mail these completed paper
TRI forms to non-TDX states or tribes. Do not send
forms in draft format, or printed copies from the
TRI-MEweb application to EPA's Data Processing
Center.
If you choose to submit your federal submission
using TRI-MEweb via the Internet, do not send
duplicate paper copies of the reports to EPA's Data
Processing Center (DPC).
Electronic Signature Agreement
There are two user roles involved in the reporting
process to EPA of your TRI data; a preparer role
and a certifying official role. Figure 1 illustrates
how these two roles are involved in the TRI
reporting process. The "Preparer" is the person
who will be preparing the TRI forms for
submission in TRI-MEweb but is not authorized to
certify them. The "Certifying Official" is the person
f .-Ma1/ to DPC
Step 1: Enter CDX and access
TRI-MEweb and prepare TRI forms
Step 2: Preparer transmits TRI forms using]
TRI-MEweb to CDX server to be certified
v /
Step 3: Certifying official
approves pending TRI forms
from a facility on CDX server
and submits it to EPA.
Step 4: Confirm TRI submission was
processed by EPA
TRI forms are submitted
successfully to EPA and state
or tribe. Facility meets their
EPCRA Section 313 reporting
requirement.
V J
CDX server
Figure 1. TRI-MEweb's Preparation, Transmission, Certification and Submission Steps
Toxics Release Inventory Reporting Forms and Instructions
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General Information
of authority at a facility or a legal representative of
the facility that will be certifying the data contained
in the transmitted TRI Form R or Form A
Certification Statement in TRI-MEweb to EPA and
their state or tribe. Certifying officials may also
prepare forms (dual role). However, the preparer
role cannot certify TRI forms that have been
transmitted to CDX. Both of these TRI roles
require creating/having a CDX user account and
adding the TRI-MEweb application to their
MyCDX profile. Step-by-step instructions on how
to create your CDX user account for your new
certifying official can be found on the TRI-MEweb
Resource web page:
http ://www. epa. gov/tri/reporting_materials/trimewe
b/.
An Electronic Signature Agreement (ESA) form is
a statement that declares that the registrant
understands that any electronic signature executed
with the electronic signature device is as legally
binding as a handwritten signature and is required
by EPA before any certifying official can certify
and submit a TRI form created in TRI-MEweb. An
ESA request is needed in RY 2012 for certifying
officials that have been newly designated for a
facility. In RY 2012, all existing certifying officials
will be required to electronically sign a one-time
update to their ESA record (see next section for
more information). ESAs are created upon the
certifying official creating a new CDX user account
and applying for a certifying official role. In RY
2012, there are two options available to obtain an
ESA approval from EPA.
Option 1 - LexisNexis real-time ESA approval.
EPA now provides an alternative method for
certifying officials to process ESAs in real-time
using a third-party identity verification vendor
named LexisNexis. This real-time approval is
possible because personal identifying information
is provided voluntarily by the certifying official to a
third-party vendor (EPA does not collect any
personal information from our users) to
authenticate their identity. Third party verification
and identification widgets are commonly used in
the banking system. The most significant benefit
from the LexisNexis method is that users will no
longer need to wait up to 5 business days for an
ESA approval by EPA. This alternate ESA
approval method is optional. If the certifying
official does not wish to provide personal
information to a third-party vendor; they should
submit a paper ESA form instead well in advance
ahead of the July 1 deadline.
Option 2 - Paper ESA form. A printable ESA
form can be generated during the CDX registration
process. The ESA form must be signed and mailed
to EPA's Data Processing Center (DPC in figure 1)
for approval before the certifying official can begin
to certify any TRI forms transmitted by the preparer
to CDX using TRI-MEweb. Hardcopy ESA
approval may take up to five business days, so
please plan accordingly or consider the option one,
LexisNexis. Multiple TRIFIDs can also be added to
a single hardcopy ESA form. All newly assigned
TRIFIDs will be listed in the printout of the ESA
document. TRI-MEweb is updated when the ESA is
approved.
All existing certifying officials in RY 2012. All
existing certifying officials are required to
electronically sign an update to their CDX ESA to
allow for electronic reporting. No hardcopy of this
CDX ESA form is required to be mailed to EPA's
Data Processing Center for approval if a signed
hardcopy ESA has been previously filed because the
user has already had their identify verified with their
originally submitted TRI ESA. This update is only
required in RY 2012. The processing and activation
of this CDX ESA is done in real-time and takes
advantage of a security upgrade to the TRI reporting
process. As a result of this upgrade, all existing
certifying officials will complete the 20-5-1
Questionnaire upon logging into CDX for the first
time during the RY 2012 reporting season. The 20-
5-1 Questionnaire requires you to answer five
personal knowledge questions (e.g., "Favorite
Color," "Name of Pet," "Mother's Name," etc) from
a list of twenty. Upon subsequent logins, one answer
is required from the five questions previously
answered to verify user identity. The new ESA for
electronic reporting will provide the benefit to all
existing certifying officials of being able to add
facility account(s) without having to generate a new
hardcopy ESA to be printed, signed and mailed to
EPA for approval before the certifying official can
certify any pending forms from the newly added
reporting facility. Certifying officials will only need
to add the TRIFID of the new facility account and
their 6-digit access key on the "Manage TRIFIDs"
page under the "Certify" tab in TRI-MEweb to
access the history of any pending submission and
taken action to either cancel or certify any
transmitted chemical form(s). They will also need to
Toxics Release Inventory Reporting Forms and Instructions
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General Information
sign a TRIFID Signature Agreement for any
additional TRIFIDs added to the TRI-MEweb
application
Accidental deletion of ESA in TRI-MEweb. The
TRI-MEweb application also has the capability to
manage user profiles (previously authorized
preparers or certifying officials) that have been
granted access to facility accounts. This capability
includes revoking approved ESA(s) for any
certifying official(s) that have left the facility's
payroll or is no longer authorized to certify forms.
An ESA could also be accidently revoked by the
preparer. If this occurs, there is a 45-day grace
period to get the ESA reactivated by the CDX
helpdesk without having to send a paper form to
EPA for re-approval. An email notification is sent
to the affected certifying official by CDX when any
ESA has been revoked within TRI-MEweb.
Mailing information for EPA's Data Processing
Center can be found below or on the TRI website
under Contact Us:
http://www.epa.gov/tri/index.htm.
Where to send hardcopy ESA forms
Send ESA approval requests by regular mail to the
following address:
Attention: TRI ESA Approval Request
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 2203 8
Send ESA approval requests by certified mail or
overnight mail to the following address:
Attention: TRI ESA Approval Request
CGI Federal, Inc
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
For questions or additional information about CDX,
please see: http://www.epa.gov/cdx.
A.2.b How to Submit Paper Form R (s)
and/or Form A Certification
Statement(s)
It is EPA's ultimate goal to move away from
processing paper submissions and to 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.
Facilities submitting paper forms must use the
corresponding reporting year forms. To facilitate the
completion and processing of paper forms, EPA is
providing electronically fillable reporting forms that
can be completed prior to printing for RY 2011 and
RY 2012 TRI forms. Most paper TRI forms are
submitted and received by EPA for the current
reporting year and the prior year. EPA strongly
encourages facilities to use this new tool to
complete forms prior to printing them. The fillable
reporting forms can be found on URL:
http ://www. epa. gov/tri/reporting_materials/index.ht
ml.
Send paper forms by regular mail to:
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 2203 8
Send paper forms by certified mail or overnight mail
(i.e. Fed Ex, UPS, etc.) to:
CGI Federal, Inc
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
E-mailed submissions will not be accepted.
State and Tribal Submissions. If the facility is in a
state that is not in EPA's TRI Data Exchange (TDX)
system, then the facility must also send a copy of
the report to the state. To verify if your state is or is
not in the TDX system, go to:
http ://www. epa. gov/tri/stakeholders/state/state_exch
ange/index.htm. "State" also includes: the District of
Columbia, the Commonwealth of Puerto Rico,
Guam, American Samoa, Marshall Islands, the U.S.
Virgin Islands, the Commonwealth of the Northern
Mariana Islands, and any other jurisdiction and
Indian country. Refer to Appendix E for the
appropriate state submission addresses.
Facilities that are located within a tribe's Indian
country will need to find their three-digit Bureau of
Toxics Release Inventory Reporting Forms and Instructions
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General Information
Indian Affairs (BIA) tribal code for their Indian
country name in Table V and fill in the code in the
"City/County/Tribe/State/ZIP code" field on the
Form R or Form A in Section 4.1. A hard-copy of
TRI forms must be mailed to the Indian country's
Chief Executive Officer because most Indian
country entities are not members of TDX in RY
2012. 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. Facilities using TRI-
MEweb to fulfill their federal and tribal reporting
requirements under EPCRA Section 313 will be
able to print a hard-copy of the TRI form to be
mailed to their Indian country's Chief Executive
Officer.
A. 3 Trade Secret Claims
For any EPCRA Section 313 chemical whose
identity is claimed as trade secret, you must submit
to EPA two versions of the substantiation form as
prescribed in 40 CFR Part 350, published July 29,
1988, in the Federal Register (53 FR 28772) as well
as two versions of the EPCRA Section 313 report.
The current substantiation form is available on the
TRI website at:
http ://www. epa. gov/tri/reporting_materials/index.ht
ml. One set of reports, the unsanitized version, must
provide the actual identity of the EPCRA Section
313 chemical. The other set of reports, i.e., the
"sanitized" version, must provide a generic class or
category for the chemical that is structurally
descriptive of the EPCRA Section 313 chemical. If
EPA deems the trade secret substantiation form
valid, only the sanitized set of forms will be made
available to the public.
Further explanation of the trade secret provisions is
provided in Part I, Sections 2.1 and 2.2, and Part II,
Section 1.3, of the instructions.
In summary, a complete report to EPA for an
EPCRA Section 313 chemical claimed as a trade
secret must include all of the following:
• A completed unsanitized version of Form R or
Form A report including the EPCRA Section
313 chemical identity (staple the pages
together); and
• A sanitized version of a completed Form R or
Form A report in which the EPCRA Section 313
chemical identity items (Part II, Sections 1.1
and 1.2) have been left blank but in which a
generic chemical name that is structurally
descriptive has been supplied (Part II, Section
1.3) (staple the pages together); and
• A completed unsanitized version of a trade
secret substantiation form (staple the pages
together); and
• A sanitized version of a completed trade secret
substantiation form (staple the pages together).
Securely fasten all four reports together.
Some states or tribes 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 or tribe's submission
requirements by contacting the appropriate state or
tribe designated EPCRA Section 313 contact (see
Appendix E).
Where to send your trade secret submission
Please send only trade secret submissions to the
P.O. Box below. Send trade secret submissions by
regular mail to:
Attention: EPCRA Substantiation Packages
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 2203 8
Send trade secret submissions by certified mail or
overnight mail (i.e. Fed Ex, UPS, etc.) to:
Attention: EPCRA Substantiation Packages
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
A. 4 Recordkeeping
Sound recordkeeping practices are essential for
accurate and efficient TRI reporting. It is in the
facility's interest, as well as EPA's, to maintain
records properly. Facilities must keep a copy of
each report filed for at least three years from the
Toxics Release Inventory Reporting Forms and Instructions
-------
General Information
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.
EPA also recommends keeping records of all
documentation containing your CDX account
information for your preparer(s) and certifying
official(s) that use TRI-MEweb to prepare and
certify the reporting facility's TRI Form R and/or
Form A. These CDX documents include the
Electronic Signature Agreement (ESA) and the
facility's unique 6-digit alphanumeric access key.
Records to maintain include:
• Previous years' EPCRA Section 313 reports;
• EPCRA Section 313 Reporting Threshold
Worksheets;
• Engineering calculations and other notes;
• Purchase records from suppliers;
• Inventory data;
• EPA (NPDES) permits and monitoring reports;
• EPCRA Section 312 Tier II Reports;
• Monitoring records;
• Flowmeter data;
• RCRA Hazardous Waste Generator's Report;
• Pretreatment reports filed by the facility with
the local government;
• Invoices from waste management companies;
• Manufacturer's estimates of treatment
efficiencies;
• RCRA manifests;
• Process diagrams that indicate emissions and
other releases;
• Records for those EPCRA Section 313
chemicals for which they did not file EPCRA
Section 313 reports; and
• CDX account information including unique 6-
digit access key to pre-load facility account into
TRI-MEweb and copies of the Electronic
Signature Agreement (s) submitted to EPA for
approval.
A. 5 How to Revise, Withdraw or
Cancel TRI Data
A.5.1 Revising TRI Data
Facilities that filed a Form R and/or Form A
Certification Statement under EPCRA Section 313
may submit a request to revise a form that was
previously submitted, stored in EPA's historical
database called the Toxics Release Inventory
Processing System (TRIPS), and made available to
the public through Envirofacts and TRI Explorer.
Facilities may request a revision for one or more of
the following reasons:
Revision codes:
• RR1 - New Monitoring Data
• RR2 - New Emission Factor(s)
• RR3 - New Chemical Concentration Data
• RR4 - Recalculation(s)
• RR5 - Other Reason(s)
Please note that late submissions for chemicals not
reported in a previous reporting year are not
considered revisions for that year.
Facilities are reminded that there is a legal
obligation to file an accurate and complete Form R
or Form A report for each chemical by July 1 each
year. EPA may take enforcement action and assess
civil administrative penalties regarding corrections
to errors in Form R reports that are not changes
based on previously unavailable information or
procedures which improve the accuracy of the data
initially reported. The kinds of errors which may
result in enforcement and in penalties include but
are not limited to the following: (1) Errors caused
by not using the most readily available information,
for example, not using monitoring data collected for
Toxics Release Inventory Reporting Forms and Instructions
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General Information
compliance with other regulations in calculating
releases; (2) omitting a major source of emissions;
(3) a mathematical or transcription or typographical
error which seriously compromises the accuracy of
the information, and; (4) other errors which
seriously affect the utility of the data, particularly
errors in release reporting for which the facility has
no records showing the derivation of the release
calculation, and cannot provide a sufficient
explanation of the report.
How do I revise my submission(s)?
If you have determined that your facility wishes to
revise a TRI submission, you must send your
revised report to EPA and the appropriate state or
tribal agency. For submitting a revision to EPA,
please use one of the following methods:
• EPA will accept revisions for Reporting Year
2005 through the current year via TRI-MEweb.
This is EPA's preferred method to submit
revisions.
• EPA will accept revisions prior to Reporting
Year 2005 on paper forms using the TRI form
applicable for the particular year being revised.
Keep in mind that EPA does not key-in paper-
form data into TRI's database until after the
July 1 deadline.
1. TRI-MEweb. The preferred method for revising
TRI forms from Reporting Year 2005 through the
current year is to use TRI-MEweb. TRI-MEweb
provides several advantages compared to hard-copy
reporting, such as automated error-checking
software, automatically updating Section 8
calculations when values are modified, and
electronically confirming EPA's receipt of a
submitted revision. All revisions created using TRI-
MEweb are required to be transmitted to CDX and
certified before being processed by EPA's DPC. If
you have questions about using TRI-MEweb to
revise your Form R/A, please refer to the TRI-
MEweb tutorial page at:
http ://www. epa. gov/tri/reporting_materials/tutorials/
tutorial_index.html.
2. Hard Copy Form. EPA strongly discourages
paper submissions due to the increased possibility of
data entry errors; however, if necessary, you may
revise a previously submitted hard-copy form or
revision by using either 1) a photocopy of the
original TRI Form R or Form A submitted to US
EPA or 2) a blank Form R or Form A or 3) using
your Facility Data Profile report.
• Photocopy of Original Submission. You may
submit a photocopy of your original submission
(from your records) with the corrections made
in blue ink. Please re-sign and re-date the
certification statement in Section 3 of the TRI
Form R or Form A Certification Statement. For
RY 2007 revisions and beyond, please enter the
appropriate revision code(s) in the "Revision"
box on the first page of the reporting form. You
may enter up to two revision codes on the form.
For RY 2006 and prior years, please enter an
"X" in the space marked "Enter 'X' here if this
is a revision," on Page 1 of the form.
• Blank Form. Hard copy submissions may be
submitted using the TRI Form R and/or Form A
applicable for that particular reporting year or
the most recent form available. For revisions
submitted by hard copy, EPA recommends the
use of the most recent form that can be
downloaded from the TRI website. You can also
request prior year reporting forms under the
Contact Us link on the TRI web site. For RY
2011 and current year forms, EPA recommends
using the electronically fillable forms to submit
your revision. RY 2010 and prior year forms are
not electronically fillable and must be
completed by hand. For RY 2007 revisions and
beyond, please enter all information including
the appropriate revision code(s). For RY 2006
and prior years, please enter all information
including an "X" in the space marked "Enter
'X' here if this is a revision," on Page 1 of the
form. Please sign and date the certification
statement on Page 1.
Electronic Facility Data Profile (eFDP).
eFDPs are made available by EPA's Data
Processing Center (DPC) to a reporting facility
in response to any submission EPA's DPC
receives and has processed successfully into
TRI's database. All reporting facilities may
access and print their eFDP report via TRI-
MEweb and make any needed corrections in
blue ink to TRI data that have been submitted
previously to EPA. These hard-copy eFDP
forms with hand-written corrections must be
mailed to EPA's DPC to be keyed into the TRI
database. Please note that a certification
statement on the bottom of the eFDP report that
Toxics Release Inventory Reporting Forms and Instructions
7
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General Information
must be signed by a facility owner/operator or
senior management official if using the eFDP
hard-copy to make a revision. Please go to
Appendix C for more information on the eFDP.
Hard-copy eFDPs with hand-written corrections
are still vulnerable to human error when
manually keyed by the DPC into the TRI
database. Therefore, EPA recommends that
facilities use TRI-MEweb to send corrections in
response to their eFDPs.
Mailing Address for Hard Copy Forms. Send
revision requests by regular mail to the following
address:
Attention: TRI Revision Request
TRI Reporting Center
P.O. Box 10163
Farifax,VA22038
Send revision requests by certified mail or overnight
mail to the following address:
Attention: TRI Revision Request
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
A.5.2 Withdrawing TRI Data
Facilities that filed a Form R and/or Form A
Certification Statement under EPCRA Section 313
may submit a request to withdraw a form that was
previously submitted, stored in the Toxics Release
Inventory Processing System (TRIPS), and made
available to the public through Envirofacts and TRI
Explorer. EPA may periodically review
withdrawals. Facilities may request a withdrawal for
one or several reasons, such as:
Withdrawal codes:
• WT1 - Did not meet the reporting threshold for
manufacturing, processing, or otherwise use
• WT2 - Did not meet the reporting threshold for
number of employees
• WT3 - Not in a covered NAICS Code
• WO1 - Other reason(s)
How do I withdraw my submission(s)?
If you have determined that your facility wishes to
withdraw a TRI submission, you must send your
request to EPA and the appropriate state agency.
Keep in mind that successfully completed
withdrawal requests will permanently delete the
chemical release data provided by the reporting
facility and processed into TRI's publicly available
database.
If the reporting facility needs to make a correction
to data submitted to EPA, a revision is easier to
process by a reporting facility than withdrawing
incorrect TRI forms and resubmitting them to EPA.
For submitting a withdrawal to EPA, please use one
of the following methods:
TRI-MEweb. The preferred method for withdrawing
TRI forms from Reporting Year 2005 through the
current year is to use TRI-MEweb. Withdrawals
can only be done for TRI submissions that have
been properly transmitted, certified and processed
by EPA. If you have questions about using TRI-
MEweb to withdraw your Form R/A, please refer to
the TRI-MEweb tutorial page at:
http ://www. epa. gov/tri/reporting_materials/tutorials/
tutorial_index.html.
Hard Copy Form. All other withdrawal requests
may be submitted by hard copy. The withdrawal
code(s) should be entered in the "Withdrawal" box
on the first page of the reporting form. You may
enter up to two withdrawal codes on the form.
There are two requirements for requesting a
withdrawal on hardcopy, as follows:
• Reporting Year 2007 Forward. You may
submit a photocopy of your original submission
(from your records). Using blue ink, re-sign and
re-date the certification statement on Page 1 and
enter the appropriate withdrawal code(s) in the
space provided on Page 1 of the form.
• Reporting Year 2006 and Prior Years. Please
submit a photocopy of the form you wish to
withdraw (from your file), and attach - as a
cover page - Page 1 of the current year's
reporting form, which includes a field for the
withdrawal codes. Using blue ink, please sign
and date the certification statement and enter all
information including the appropriate
Toxics Release Inventory Reporting Forms and Instructions
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General Information
withdrawal code(s) in the space provided on
Page 1 of the current year's form.
Mailing Address for Hard Copy Forms. Send
withdrawal requests by regular mail to the
following address:
Attention: TRI Withdrawal Request
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 2203 8
Send withdrawal requests by certified mail or
overnight mail to the following address:
Attention: TRI Withdrawal Request
CGI Federal, Inc
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
A.5.3 Canceling a TRI Submission
Cancelling a TRI form is not applicable to hard-
copy TRI forms. However, different situations may
require a TRI-MEweb user to cancel an electronic
TRI submission. For instance, a facility's preparer
or certifying official may determine that a draft
electronic submission(s) requires cancellation
because the facility's chemical release did not, in
fact, meet the reporting thresholds of EPCRA
Section 313.
Another reason why a TRI-MEweb submission may
require cancellation is if a preparer has determined
that a correction is needed on a TRI form that is
pending certification in CDX, but has not yet been
certified. In order to edit a TRI form in TRI-
MEweb that is pending certification to CDX, the
preparer will need to cancel the transmitted
submission with a Pending Certification status in
order to make the additional corrections in TRI-
MEweb and retransmit the original submission or
revision to CDX to be certified. EPA is considering
issuing a Notice of Non-compliance for TRI Forms
that have been transmitted to CDX but are not
certified.
A preparer or a certifying official cannot cancel a
TRI form submission that has already been
transmitted and certified by the certifying official. If
a chemical form has a status of Certified and Sent to
EPA in TRI-MEweb it cannot be called back to be
edited or corrected. To change or remove data that
has already been transmitted, certified and
submitted to EPA to be processed, either revise or
withdraw the submission.
How to Cancel a TRI Submission that has not
been Certified.
If your facility decides not to complete the
certification process for any pending electronic
submission(s) transmitted to CDX by TRI-MEweb,
you should CANCEL the submission(s) using one
of the following methods:
By the Preparer: The preparer may use the TRI-
MEweb application to cancel any unwanted pending
submission(s). In TRI-MEweb, the preparer must
click the "Prepare" tab, choose the Reporting Year
corresponding to the unwanted submission(s) from
the "Select Year" tab, choose the appropriate
facility from the "Select Facility" tab, and select the
chemical form to be cancelled from the Select a
Form page. Next, the preparer must click the
"Review" tab. Then, the preparer must locate the
submission that includes the chemical form they
wish to cancel and select its radio button from the
Pending Submission Summary Table on the
Reporting Summary page. Next, they must click
the "Cancel" button and confirm the cancellation on
the next page. Note: ALL chemical forms that were
included in the selected submission will be
canceled.
By the Certifying Official: The certifying official
may also cancel any unwanted TRI submission(s)
pending certification. The certifying official must
log into their CDX account and click the "TRI-
MEweb: TRI Made Easy - Prepare/Certify
Submission" link from their MyCDX page. This
will open the "Welcome" page of the TRI-MEweb
application and then select the "Certify" tab. If
certifying official does not find the TRIFID for their
reporting facility with pending submissions listed,
they gain access to that facility account by entering
the access key on the "Enter Facility's Access
Information" page and signing the TRIFID
Certification Agreement on the "Manage TRIFIDs
for Certification" page and clicking the "Next"
button. The electronic signature widget will pop-up
to confirm your authorized access to the facility
account. Upon successfully authentication of user
identity, you may begin the cancellation process on
the "Pending Submissions" page under the
"Certify" tab. You may view the content of the
submission by clicking the "View Submission " icon
Toxics Release Inventory Reporting Forms and Instructions
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General Information
to confirm that this is the correct submission to be
cancelled. Select the "Cancel" radio button to
cancel submission and select "Next" to confirm
request. If you have questions about using TRI-
MEweb to cancel your Form R or Form A
Certification Statement submission, please refer to
the TRI-MEweb tutorial page at:
http ://www. epa. gov/tri/reporting_materials/tutorials/
tutorial_index.html
If a facility submitted a hardcopy TRI Form R/A
to meet the July 1 deadline because the reporting
facility could not process their electronic
signature agreements (ESA) on time, should
their certifying official still certify electronically
after the July 1 deadline?
Yes, their certifying official should certify any
pending TRI forms in CDX after the ESA approval
has been processed by the Data Processing Center
after the July 1 deadline. Paper forms are not
encouraged for the submission of TRI data to EPA
because of the likelihood of the presence of errors.
However, facilities may consider submitting a hard-
copy TRI Form R/A if approval of the certifying
official's Electronic Signature Agreement (ESA)
has not been processed by EPA by the July 1
deadline. EPA discourages facilities from
submitting hard-copy forms because of the potential
of reporting errors that will force EPA to issue a
separate Notice of Significant Error (NOSE) to your
facility to correct them. However, this situation is
less likely to occur in RY 2012 with the use of the
new LexisNexis ESA approval method that will
allow for real-time processing of the ESA form.
This new ESA approval alternative should
discourage reporting facilities from mailing
hardcopy TRI forms instead of transmitting,
certifying and submitting their electronic
submission. EPA strongly encourages your facility's
certifying official to log into CDX (using the link
stated above) once their Electronic Signature
Agreement (ESA) has been approved by EPA and
certify any pending submission(s) because your
electronic submission(s) should have already passed
the validation/data error checks in TRI-MEweb,
minimizing any chance of errors in your forms.
Your certifying official should electronically certify
any pending TRI submission even after the July 1
deadline. If a facility certifies any pending
electronic submission(s) after their paper form(s)
has been received and postmarked by the TRI Data
Processing Center, the electronic submission(s)
will be processed and will retain the postmarked
date of the previously filed paper form(s).
A. 6 When the TRI Report Must Be
Submitted
As specified in EPCRA Section 313, the report for
any calendar year must be submitted on or before
midnight on July 1 of the following year whether
using Form R or Form A. If the reporting deadline
falls on a Saturday or Sunday, EPA will accept the
forms which are postmarked on the following
Monday (i.e., the next business day). If your
reporting facility submitted TRI forms using TRI-
MEweb via the Central Data Exchange (CDX), the
preparer will receive their electronic Facility Data
Profile (eFDP) in an expedited fashion under the
"eFDP" tab within the TRI-MEweb application.
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 TRI National Analysis. Always remember to
review your eFDP report to verify that data was
entered correctly and no addition errors were found
after processing by EPA's DPC. The eFDP report is
a receipt of the information your reporting facility
has 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
eFDP has been updated and published in TRI-
MEweb for review. If you have questions regarding
your eFDP, please send an e-mail to
tri.efdp@epacdx.net or call 703-227-7644.
A. 7 How to Obtain the TRI Reporting
Forms
The TRI Form R, Form R Schedule 1, Form A
Certification Statement, and related guidance
documents may be obtained from EPA's TRI
website at: http ://www. epa. gov/tri.
Toxics Release Inventory Reporting Forms and Instructions
10
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
B. How to Determine if Your
Facility Must Submit a
Form R or Is Eligible to Use
Form A
This section will help you determine whether you
must submit an EPCRA Section 313 report (EPA
Form R or Form A Certification Statement). This
section discusses EPCRA Section 313 reporting
requirements such as the number of full-time
employees, primary NAICS code, and chemical
activity threshold quantities. The EPCRA Section
313 chemicals and chemical categories subject to
reporting are listed in Table II (also see 40 CFR
372.65). (See Figure 1 for more information.)
B.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:
• A facility consists of 11 employees who each
worked 1,500 hours for the facility in a calendar
year. Consequently, the total number of hours
worked by all employees for the facility during
the calendar year is 16,500 hours. The number
of full-time employees for this facility is equal
to 16,500 hours divided by 2,000 hours per full-
time employee, or 8.3 full-time employees.
Therefore, even though 11 persons worked for
this facility during the calendar year, the
number of hours worked is equivalent to 8.3
full-time employees. This facility does not meet
the employee criteria and is not subject to
EPCRA Section 313 reporting.
• Another facility consists of six workers and
three sales staff. The six workers each worked
2,000 hours for the facility during the calendar
year. The sales staff also each worked 2,000
hours during the calendar year although they
may have been on the road half of the year. In
addition, five contract employees were hired for
a period during which each worked 400 hours
for the facility. The total number of hours is
equal to the time worked by the workers (12,000
hours), plus the time worked by the sales staff
for the facility (6,000 hours), plus the time
worked by the contract employees (2,000
hours), or 20,000 hours. Dividing the 20,000
hours by 2,000 yields 10 full-time employees.
This facility has met the full-time employee
criteria and may be subject to reporting if the
other criteria are met.
B. 2 Primary NAICS Code
Determination
Beginning with 2006 EPCRA Section 313 reporting,
the TRI Program requires North American Industry
Classification System (NAICS) codes instead of
Standard Industrial Classification (SIC) codes.
Please refer to the TRI Program's final rule titled
Community Right-to-Know; Toxic Chemical
Release Reporting Using North American Industry
Classification System (NAICS) published in the
Federal Register on June 6, 2006 (71 FR 32464).
EPA published a final rule on June 9, 2008 to
incorporate 2007 Office of Management and Budget
(OMB) revisions and other corrections to the
NAICS codes used for TRI Reporting. [Federal
Register (FR) notice 73 FR 32466.] With this rule,
facilities are required to use 2007 NAICS codes on
TRI reporting forms.
The full list of NAICS codes for facilities that must
report to TRI (including exceptions and/or
limitations) if all other threshold determinations are
met can be found in Table I and also at the TRI
website at:
http://www.epa.gov/tri/lawsandregs/naic/ncodes.ht
m. The facility should determine its own NAICS
code(s), based on its activities on-site using the
NAICS Manual and by conducting NAICS keyword
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
and NAICS 2 to 6-digit code searches on the Census
Bureau website at: The NAICS 2012 Manual is available from the
http://www.census.gov/eos/www/naics/. For National Technical Information Service (NTIS)
purposes of EPCRA Section 313 reporting, state website at: http://www.ntis.gov/about/index.aspx.
assigned codes should not be used if they differ
from codes assigned using the NAICS Manual.
Paperwork Reduction Act Notice: The annual public burden related to the Form R, which is approved
under OMB Control No. 2025-0009, is estimated to average 35.71 hours per response for a facility filing a
report on one chemical. The annual public burden related to the Form A, which is also approved under
OMB Control No. 2025-0009, is estimated to average 21.96 hours per response for a facility filing a report
on one chemical.
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 12
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Does your facility have 10 or more full-
time employees or the equivalent?
(see definition under B.I)
YES
Is your facility's primary NAICS Code
included on the EPCRA Section 313 list?
Or is your facility a Federal facility?
(see B.2 and Table I)
YES
Does your facility manufacture, process, or
otherwise use EPCRA Section 313
chemicals and chemical categories?
(see Table IL B.3-B.5, and D.1-D.7)
YES
Does your facility exceed any of the
thresholds for a chemical or chemical
category (after excluding quantities that
are exempt from threshold calculations)
YES
AN EPCRA SECTION 313 REPORT IS
REQUREDFORTHE CHEMICAL OR
CHEMICAL CATEGORY
Is this chemical or chemical category
identified as Persistent. Bioaccumulative. and
Toxic (PBT)?
YES
NO
NO
NO
NO
NO
STOP
NO EPCRA SECTION
313 REPORTS
REQUIRED FOR ANY
CHEMICALS
Is the amount manufactured, OR processed, OR otherwise used less
than or equal to 1,000,000 pounds and is the reportable amount less
than or equal to 500 Ibs/year?
NO
YES
FORM R IS REQUIRED FOR THIS
CHEMICAL OR CHEMICAL
CATEGORY (FORMA CANNOT BE
SUBMITTED)
FORM A OR FORM R IS REQUIRED
FOR THIS CHEMICAL CATEGORY
Figure 2. EPCRA Section 313 Reporting Decision Diagram
Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
B.2.a. Auxiliary Facilities
Under the Standard Industrial Classification (SIC)
system, an auxiliary facility was defined as one that
supported another covered establishment's activities
(e.g., research and development laboratories,
warehouses, and storage facilities). An auxiliary
facility could assume the SIC code of another
covered establishment if its primary function was to
service that other covered establishment's
operations. The North American Industry
Classification System (NAICS), that replaces the
SIC system for TRI reporting, does not recognize
the concept of auxiliary facilities and assigns
NAICS codes to all establishments based on
economic activity. In its rulemaking, "Toxic
Chemical Release Reporting Using North American
Industry Classification System," the TRI Program
has adopted NAICS for TRI reporting and also the
NAICS treatment of former "auxiliary facilities" as
entities with their own distinct NAICS code.
B.2.b. Multi-establishment Facilities
Your facility may include multiple establishments
that have different NAICS codes. A multi-
establishment facility is a facility that consists of
two or more distinct and separate economic units. If
your facility is a multi-establishment facility,
calculate the value added of the products produced,
shipped, or services provided from each
establishment within the facility and then use the
following rule to determine if your facility meets the
NAICS code criterion:
• If the total value added of the products
produced, shipped, or services provided at
establishments with covered NAICS codes is
greater than 50 percent of the value added of the
entire facility's products and services, the entire
facility meets the NAICS code criterion.
• If anyone establishment with a covered NAICS
code has a value added of services or products
shipped or produced that is greater than any
other establishment within the facility (40 CFR
Section 372.22(b)(3)) the facility also meets the
NAICS code criterion.
The value added of production or service
attributable to a particular establishment may be
isolated by subtracting the product value obtained
from other establishments within the same facility
from the total product or service value of the
facility. This procedure eliminates the potential for
"double counting" production and services in
situations where establishments are engaged in
sequential production or service activities at a single
facility.
Examples include:
• A facility in coating, engraving and allied
services has two establishments. The first
establishment, a general automotive repair
service, is in NAICS code 811113 (SIC 7537),
which is not a covered NAICS code. However,
the second establishment, a metal paint shop is
in NAICS code 332812 (SIC 3479, which is a
covered NAICS code). The metal paint shop
paints the parts received from general
automotive repair service. The facility
determines the product is worth $500/unit as
received from the general automotive repair
service (in non-covered NAICS code 811113)
and the value of the product is $1500/unit after
processing by the metal paint shop (in covered
NAICS code 332812). The value added by the
metal paint shop is obtained by subtracting the
value of the products from the general
automotive repair service from that of the value
of the products of the metal paint shop. (In this
example, the value added = $l,500/unit -
$500/unit = $l,000/unit.) The value added
($l,000/unit) by the establishment in NAICS
code 332812 is more than 50 percent of the
product value. Therefore, the facility's primary
NAICS code is 332812, which is a covered
NAICS code.
• A food processing establishment in a facility
processes crops grown at the facility in a
separate establishment. To determine the value
added of the products of each establishment the
facility could first determine the value of the
crops grown at the agricultural establishment,
and then calculate the contribution of the food
processing establishment by subtracting the crop
value from the total value of the product
shipped from the processing establishment
(value of product shipped from processing -
crop value = value of processing establishment).
A covered multi-establishment facility must make
EPCRA Section 313 chemical threshold
determinations and, if required, report all relevant
information about releases and other waste
management activities, and source reduction
activities associated with an EPCRA Section 313
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
chemical for the entire facility, even from
establishments that are not in covered NAICS codes.
EPA realizes, however, that certain establishments
in a multi-establishment facility can be, for all
practical purposes, separate and distinct business
units. Therefore, while threshold determinations
must be made for the entire facility, individual
establishments which compose the entire facility
may report their individual releases and other waste
management activities separately. However, the
total releases and other waste management
quantities for the entire facility must be represented
by the sum of the releases and other quantities
managed as waste reported by each of the separate
establishments.
B.2.c. Property Owners
You are not required to report if you merely own
real estate on which a facility covered by this rule is
located; that is, you have no other business interest
in the operation of that facility (e.g., your company
owns an industrial park). The operator of that
facility, however, is subject to reporting
requirements.
B.3 Activity Determination
B.3.a. Definitions of Manufacture,
Process, and Otherwise Use
Manufacture: The term "manufacture" means to
produce, prepare, compound, or import an EPCRA
Section 313 chemical. (See Part II, Section 3.1 of
these instructions for further clarification.)
Import is defined as causing the EPCRA Section
313 chemical to be imported into the customs
territory of the United States. If you order an
EPCRA Section 313 chemical (or a mixture
containing the chemical) from a foreign supplier,
then you have imported the chemical when that
shipment arrives at your facility directly from a
source outside of the United States. By ordering the
chemical, you have caused it to be imported, even
though you may have used an import brokerage firm
as an agent to obtain the EPCRA Section 313
chemical.
Do Not Overlook Coincidental Manufacture
The term "manufacture" also includes coincidental
production of an EPCRA Section 313 chemical
(e.g., as a byproduct or impurity) as a result of the
manufacture, processing, otherwise use or disposal
of another chemical or mixture of chemicals. In the
case of coincidental production of an impurity (i.e.,
an EPCRA Section 313 chemical that remains in the
product that is distributed in commerce), the de
minimis exemption, discussed in Section B.3.c of
these instructions, applies. The de minimis
exemption does not apply to byproducts (e.g., an
EPCRA Section 313 chemical that is separated from
a process stream and further processed or disposed
of). Certain EPCRA Section 313 chemicals may be
manufactured as a result of wastewater treatment or
other treatment processes. For example,
neutralization of wastewater containing nitric acid
can result in the coincidental manufacture of a
nitrate compound (solution), reportable as a member
of the nitrate compounds category.
Process: The term "process" means the preparation
of a listed EPCRA Section 313 chemical, after its
manufacture, for distribution in commerce.
Processing is usually the incorporation of an
EPCRA Section 313 chemical into a product (see
Part II, Section 3.2 of these instructions for further
clarification). However, a facility may process an
impurity that already exists in a raw material by
distributing that impurity in commerce. Processing
includes preparation of the EPCRA Section 313
chemicals in the same physical state or chemical
form as that received by your facility, or preparation
that produces a change in physical state or chemical
form. The term also applies to the processing of a
mixture or other trade name product (see Section
B.4.b of these instructions) that contains a listed
EPCRA Section 313 chemical as one component.
Otherwise Use: The term "otherwise use" means
any use of an EPCRA Section 313 chemical,
including an EPCRA Section 313 chemical
contained in a mixture or other trade name product
or waste, that is not covered by the terms
manufacture or process. Otherwise use of an
EPCRA Section 313 chemical does not include
disposal, stabilization (without subsequent
distribution in commerce), or treatment for
destruction unless:
(1) The EPCRA Section 313 chemical that was
disposed of, stabilized, or treated for destruction
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
was received from off-site for the purposes of purposes of waste management activities.
further waste management; Relabeling or redistributing of the EPCRA Section
313 chemical where no repackaging of the EPCRA
Or Section 313 chemical occurs does not constitute an
otherwise use or processing of the EPCRA Section
(2) The EPCRA Section 313 chemical that was 313 chemical. (See 62 FR 23846 and Part II, Section
disposed of, stabilized, or treated for destruction 3.3 of these instructions for further clarification).
was manufactured as a result of waste management
activities on materials received from off-site for the
Example 1: Coincidental Manufacture
Q Your company, a nitric acid manufacturer, uses aqueous ammonia in a waste treatment system
to neutralize an acidic wastewater stream containing nitric acid. The reaction of ammonia and
nitric acid produces a solution of ammonium nitrate. Ammonium nitrate (solution) is reportable
under the nitrate compounds category and is manufactured as a byproduct. If the ammonium
nitrate is produced in a quantity that exceeds the 25,000-pound manufacturing threshold, the
facility must report under the nitrate compounds category.
The aqueous ammonia is considered to be otherwise used and 10 percent of the total aqueous
ammonia would be counted towards the 10,000-pound otherwise use threshold. Reports for
releases of ammonia must also include 10 percent of the total aqueous ammonia from the
solution of ammonium nitrate (see the qualifier for the ammonia listing).
U As another example, combustion of coal or other fuel in boilers/furnaces can result in the
coincidental manufacture of metal category compounds and sulfuric acid (acid aerosols),
hydrochloric acid (acid aerosols), and hydrogen fluoride.
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Example 2: Typical Process and Manufacture Activities
Q Your company receives toluene, an EPCRA Section 313 chemical, from another facility, and
reacts the toluene with air to form benzoic acid, which the company distributes in commerce.
Your company processes toluene and manufactures and processes benzoic acid. Benzoic acid,
however, is not an EPCRA Section 313 chemical and thus does not trigger reporting
requirements.
U Your facility combines toluene purchased from a supplier with various materials to form paint
which it then sells. Your facility processes toluene.
U 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.
U Your company receives a prepared mixture of resin and chopped fiber to be used in the injection
molding of plastic products. The resin contains a listed EPCRA Section 313 chemical that
becomes incorporated into the plastic, which the company distributes in commerce. Your
facility processes the EPCRA Section 313 chemical.
U In the combustion of coal or oil, metal category compounds may be produced from either the
parent metal or a metal compound contained in the coal or oil. If a metal undergoes a change of
valence, a metal compound is considered to be manufactured. For example, during the
combustion process copper in valence state zero changes to copper in valence state +2 in a
compound such as copper (II) oxide (CuO). Furthermore, a metallic compound could be
transformed to another metallic compound without a change in valency (e.g., copper (II)
chloride (CuC12) is transformed to copper (II) oxide (CuO)). The transformation to a new
compound by combustion without a change in valence state is also considered to be
"manufactured" for purposes of EPCRA Section 313.
Example 3: Typical Otherwise Use Activities
Q When your facility cleans equipment with toluene, you are otherwise using toluene. Your
facility also separates two components of a mixture by dissolving one component in toluene, and
subsequently recovers the toluene from the process for reuse or disposal. Your facility otherwise
uses toluene.
U A covered facility receives a waste containing 12,000 pounds of Chemical A, a non-PBT
EPCRA Section 313 chemical, from off-site. The facility treats the waste, destroying Chemical
A and in the treatment process manufactures 10,500 pounds of Chemical B, another non-PBT
EPCRA Section 313 chemical. Chemical B is disposed of on-site. Since the waste containing
Chemical A was received from off-site for the purpose of waste management, the amount of
Chemical A must be included in the otherwise use threshold determination for Chemical A. The
otherwise use threshold for a non-PBT chemical is 10,000 pounds and since the amount of
Chemical A exceeds this threshold, all releases and other waste management activities for
Chemical A must be reported. Chemical B was manufactured in the treatment of a waste
received from off-site. The facility disposed of Chemical B on-site. Since Chemical B was
generated from waste received from off-site for treatment for destruction, disposal, or
stabilization, the disposal of Chemical B is considered to be an otherwise use. Thus, the amount
of Chemical B must be considered in the otherwise use threshold determination. Thus, the
reporting threshold for Chemical B has also been exceeded and all releases and other waste
management activities for Chemical B must be reported.
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B.3.b. Persistent Bioaccumulative Toxic
(PBT) Chemicals and Chemical
Categories Overview
On October 29, 1999, EPA published a final rule (64
FR 58666) adding certain chemicals and chemical
categories to the EPCRA Section 313 list of toxic
chemicals and lowering the reporting threshold for
persistent bioaccumulative toxic (PBT) chemicals.
In addition, on January 17, 2001 EPA published a
final rule (66 FR 4500) that classified lead and lead
compounds as PBT chemicals and lowered their
reporting thresholds. The lower reporting thresholds
for lead applies to all lead except when lead is
contained in a stainless steel, brass or bronze alloy.
Dioxin and dioxin-like compounds, lead
compounds, mercury compounds and polycyclic
aromatic compounds (PACs) are the four PBT
chemical categories with lower reporting thresholds.
The 17 members of the dioxin and dioxin-like
compounds category and the 21 members of the
PACs category are listed in Table He of these
instructions. The dioxin and dioxin-like compounds
category has the qualifier, "Manufacturing; and the
processing or otherwise use of dioxin and dioxin-
like compounds if the dioxin and dioxin-like
compounds are present as contaminants in a
chemical and if they were created during the
manufacturing of that chemical."
EPA has added six individual chemicals to the
EPCRA Section 313 list of toxic chemicals that also
had their thresholds lowered:
• benzo(g,h,i)perylene,
• benzo(j,k)fluorene (fluoranthene),
• 3-methylcholanthrene,
• octachlorostyrene,
• pentachlorobenzene, and
• tetrabromobisphenol A (TBBPA).
Benzo(j,k)fluorene and 3-methyl-cholanthrene were
added as members of the polycyclic aromatic
compounds (PACs) chemical category.
EPA lowered the reporting thresholds for PBT
chemicals to either 100 pounds, 10 pounds, or in the
case of the dioxin and dioxin-like compounds
chemical category, to 0.1 grams. The table at the
beginning of Section B.4 of these instructions lists
the applicable manufacture, process, and otherwise
use thresholds for the listed PBT chemicals.
EPA eliminated the de minimis exemption for all
PBT chemicals (except lead when contained in
stainless steel, brass or bronze alloy). However, this
action does not affect the applicability of the de
minimis exemption to the supplier notification
requirements (40 CFR Section 372.45(d) (1)). In
addition, PBT chemicals are ineligible for range
reporting for on-site releases and transfers off-site
for further waste management. This will not affect
the applicability of range reporting of the maximum
amount on-site as required by EPCRA Section
313(g).
All releases and other waste management quantities
greater than 0.1 pounds of a PBT chemical (except
the dioxin and dioxin like compounds chemical
category) should be reported at a level of precision
supported by the accuracy of the underlying data
and estimation techniques on which the estimate is
based. If a facility's release or other waste
management estimates support reporting an amount
that is more precise than whole numbers, then the
more precise amount should be reported.
For the dioxin and dioxin-like compounds chemical
category, which has a reporting threshold of 0.1
grams, facilities need only report all release and
other waste management quantities greater than 100
micrograms (i.e., 0.0001 grams). Notwithstanding
the numeric precision used when determining
reporting eligibility thresholds, facilities should
report on the Form R to the level of accuracy that
their data supports, up to seven digits to the right of
the decimal. EPA's reporting software and data
management systems support data precision to
seven digits to the right of the decimal. If a facility
has information on the individual members of the
dioxin and dioxin-like compounds category they
will also need to file a Form R Schedule 1 (see
instructions in Section D).
Lead and Lead Compounds
Lead and lead compounds are classified as PBT
chemicals and are subject to the lower
manufacturing, processing and otherwise use
threshold of 100 pounds. However, when lead is
contained in stainless steel, brass, or bronze alloys it
remains subject to the higher 25,000 pound
manufacturing and processing thresholds and the
10,000 pound otherwise use threshold.
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Listed below are some important guidelines to use
when calculating threshold and release and other
waste management quantities for lead and lead
compounds:
1) quantities of lead not contained in stainless
steel, brass or bronze alloy are applied to both
the 100 pound threshold and the 25,000/10,000
pound thresholds;
2) quantities of lead that are contained in stainless
steel, brass or bronze alloys are only applied
toward the 25,000/10,000 pound thresholds;
3) a facility may take the de minimis exemption for
those quantities of lead in stainless steel, brass,
or bronze alloys that meet the de minimis
standard (e.g., manufactured as an impurity).
Accordingly, the de minimis exemption may be
considered for quantities of lead in stainless
steel, brass, or bronze alloys but it may not be
considered for lead not in stainless steel, brass,
or bronze alloys;
4) If a facility exceeds the 100-pound threshold for
lead other than in stainless steel, brass, or
bronze alloys, the facility may not apply Form
A eligibility for non-PBTs, range reporting in
Sections 5 and 6 of the Form R or the use of
whole numbers and 2 significant digits to any of
the lead they report. If a facility that exceeds the
25,000/10,000 pound threshold for lead in
stainless steel, brass, or bronze alloy without
tripping the 100-pound threshold for non-
alloyed lead, the facility may consider the Form
A requirements for non-PBTs, range reporting
in Sections 5 and 6 of the Form R, and the use
of whole numbers and 2 significant digits.
B.3.c. Activity Exemptions
Otherwise Use Exemptions. Certain otherwise uses
of listed EPCRA Section 313 chemicals are
specifically exempted:
• Otherwise use as a structural component of the
facility;
• Otherwise use in routine janitorial or facility
grounds maintenance;
• Personal uses by employees or other persons;
• Otherwise use of products containing EPCRA
Section 313 chemicals for the purpose of
maintaining motor vehicles operated by the
facility; and
• Otherwise use of EPCRA Section 313 chemicals
contained in intake water (used for processing
or non-contact cooling) or in intake air (used
either as compressed air or for combustion).
The exemption of an EPCRA Section 313 chemical
otherwise used 1) as a structural component of the
facility; or 2) in routine janitorial or facility grounds
maintenance; or 3) for personal use by an employee
cannot be taken for activities involving process
related equipment.
Articles Exemption. EPCRA Section 313
chemicals contained in articles that are processed or
otherwise used at a covered facility are exempt from
threshold determinations and release and other
waste management calculations. The exemption
applies when the facility receives the article from
another facility or when the facility produces the
article itself. The exemption applies only to the
quantity of EPCRA Section 313 chemical present in
the article. If the EPCRA Section 313 chemical is
manufactured (including imported), processed, or
otherwise used at the covered facility other than as
part of the article, in excess of an applicable
threshold quantity, the facility is required to report
that use of a chemical (40 CFR 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 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
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will count toward the 0.5 pound per year cut off
value.
The articles exemption applies to the normal
processing or use of articles. This exemption does
not apply to the manufacture of the article. EPCRA
Section 313 chemicals incorporated into articles
produced at a facility must be factored into
threshold determinations and release and other
waste management calculations.
If, in the course of processing or use, an item
retains its initial thickness or diameter, in whole or
in part, it meets the first part (i.e., it must be a
manufactured item which is formed to a specific
shape or design during manufacture) of the article
definition. If the item's basic dimensional
characteristics are totally altered during processing
or otherwise use, the item does not meet the first
part of the definition. An example of items that do
not meet the definition would be items that are cold
extruded, such as lead ingots, which are formed into
Example 4: Articles Exemption
U 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.
U If an item used in the facility is fragmented,
the item is still an article if those fragments
being discarded remain identifiable as the
article (e.g., recognizable pieces of a
cylinder, pieces of wire). For instance, an
eight-foot piece of wire is cut into two four-
foot pieces of wire, without releasing any
EPCRA Section 313 chemicals. Each four-
foot piece is identifiable as a piece of wire;
therefore, the article status for these pieces
of wire remains intact.
U EPCRA Section 313 chemicals received in
the form of pellets are not articles because
the pellet form is simply a convenient form
for further processing of the material.
wire or rods. On the other hand, cutting a
manufactured item into pieces that are recognizable
as the article would not change the original
dimensions as long as the diameter or the thickness
of the item remained the same; the articles
exemption would continue to apply. Metal wire may
be bent and sheet metal may be cut, punched,
stamped, or pressed without losing their article
status as long as the diameter of the wire or tubing
or the thickness of the sheet is not totally changed.
What constitutes a release of an EPCRA Section
313 chemical is important since processing or
otherwise use of articles that result in a release to
the environment (or more than 0.5 pounds) negate
the article status and precludes eligibility for the
exemption. Cutting, grinding, melting, or other
processing of manufactured items could result in a
release of an EPCRA Section 313 chemical during
normal conditions of processing or otherwise use
and therefore negate the exemption as articles.
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-
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PBT EPCRA Section 313 chemical in that mixture
or other trade name product does not have to be
applied to threshold determinations nor included in
release or other waste management determinations.
If a non-PBT EPCRA Section 313 chemical in a
mixture or other trade name product is below the
appropriate de minimis level, all releases and other
waste management activities associated with the
EPCRA Section 313 chemical in that mixture or
other trade name product are exempt from EPCRA
Section 313 reporting. It is possible to meet an
activity (e.g., processing) threshold for an EPCRA
Section 313 chemical on a facility wide basis, but
not be required to calculate releases or other waste
management quantities associated with a particular
process because that process involves only mixtures
or other trade name products containing the non-
PBT EPCRA Section 313 chemical below the de
minimis level.
EPA interprets the de minimis exemption such that
once a non-PBT EPCRA Section 313 chemical
concentration is at or above the appropriate de
minimis level in the mixture or other trade name
product threshold determinations and release and
other waste management calculations must be made,
even if that chemical later falls below the de minimis
level in the same mixture or other trade name
product. Thus, EPA considers reportable all releases
and other quantities managed as waste that occur
after the de minimis level has been met or exceeded.
If an EPCRA Section 313 chemical in a mixture or
other trade name product at or above de minimis is
brought on-site, the de minimis exemption never
applies.
De minimis levels for non-PBT EPCRA Section 313
chemicals and chemical categories are set at
concentration levels of either 1 percent or 0.1
percent; PBT chemicals and chemical categories do
not have de minimis levels with regard to this
exemption. The 0.1 percent de minimis levels are
dictated by determinations made by the National
Toxicology Program (NTP) in its Annual Report on
Carcinogens, the International Agency for Research
and Cancer (IARC) in its Monographs, or 29 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 percent de minimis concentration provided
that the other criteria for the de minimis exemption
are met. De minimis levels for chemical categories
apply to the total concentration of all chemicals in
the category within a mixture, not the concentration
of each individual category member within the
mixture.
De Minimis Application to the Processing or
Otherwise Use of a Mixture
The de minimis exemption applies to the processing
or otherwise use of a non-PBT EPCRA Section 313
chemical in a mixture. Threshold determinations and
release and other waste management calculations
begin at the point where the chemical meets or
exceeds the de minimis level. If a non-PBT EPCRA
Section 313 chemical is present in a mixture at a
concentration below the de minimis level, this
quantity of the substance does not have to be
included for threshold determinations, release and
other waste management reporting, or supplier
notification requirements. The exemption will apply
as long as the mixture containing de minimis
amounts of a non-PBT EPCRA Section 313
chemical never equals or goes above the de minimis
limit.
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Example 5:
Chemicals
De Minimis Applications to Process and Otherwise Use Scenarios for Non-PBT
There are many cases in which the de minimis "limit" is crossed or re-crossed by non-PBT chemicals
within a process or otherwise use scenario. The following examples are meant to illustrate these complex
reporting scenarios.
Increasing Concentration To or Above De Minimis Levels During Processing for Non-PBT
Chemicals
A manufacturing facility receives toluene that contains chlorobenzene at a concentration below its de
minimis limit. Through distillation, the chlorobenzene content in process streams is increased over the de
minimis concentration of 1 percent. From the point at which the chlorobenzene concentration equals 1
percent in process streams, the amount present must be factored into threshold determinations and release
and other waste management estimates. The facility does not need to consider the amount of
chlorobenzene in the raw material when below de minimis levels, i.e., prior to distillation to 1 percent,
when making threshold determinations. The facility does not have to report emissions of chlorobenzene
from storage tanks or any other equipment associated with that specific process where the chlorobenzene
content is less than 1 percent.
Fluctuating Concentration During Processing for Non-PBT Chemicals
A manufacturer produces an ink product that contains toluene, an EPCRA Section 313 chemical, below
the de minimis level. The process used causes the percentage of toluene in the mixture to fluctuate: it rises
above the de minimis level for a time but drops below the level as the process winds down. The facility
must consider the chemical toward threshold determinations from the point at which it first equals the de
minimis limit. Once the de minimis limit has been met the exemption cannot be taken.
Concentration Ranges Straddling the De Minimis
Value
There may be instances in which the concentration
of a non-PBT chemical is given as a range
straddling the de minimis limit. Example 6
illustrates how the de minimis exemption should be
applied in such a scenario.
De Minimis Application in the Manufacture of
the Listed Chemical in a Mixture
The de minimis exemption generally does not apply
to the manufacturing of an EPCRA Section 313
chemical. However, the de minimis exemption may
apply to mixtures and other trade name products
containing non-PBT EPCRA Section 313 chemicals
that are imported into the United States. (See
Example 5)
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.
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Example 6: Concentration Ranges Straddling the De Minimis Value
Scenario 1: A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1.25 percent
manganese. Manganese is eligible for the de minimis exemption at concentrations up to 1 percent. The
amount of mixture subject to reporting is the quantity containing manganese at or above the de minimis
concentration:
[(8,000,000) 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)
Therefore, the amount of manganese that is subject to threshold determination and release and other waste
management estimates is:
' (8,000,000) x (1.25% - 0.99%)'
(1.25%-0.25%)
(1.25%+ 1.00%)'
(2)
= 23,4QQ pounds
= 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.
Scenario 2: As in the previous example, manganese is present in a mixture, of which 8,000,000 pounds is
processed. The MSDS states the mixture contains 0.2 percent to 1.2 percent manganese. The amount of
mixture subject to reporting (at or above de minimis limit) is:
[(8,000,000) 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 (l.2% - 0.9%)'
(l.2%-0.2%)
(l.2%+ 1.0%)'
. (2) .
= 26,400 pounds
= 26,400 pounds manganese (which is above the processing threshold for manganese)
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Example 7: De Minimis Application in the Manufacture of a Toxic Chemical in a Mixture
Manufacture as a Product Impurity
Toluene 2,4 diisocyanate reacts with trace amounts of water to form trace quantities of 2,4-
diaminotoluene. The resulting product contains 99 percent toluene 2,4-diisocyanate and 0.05 percent 2,4-
diaminotoluene. The 2,4 diaminotoluene would not be subject to EPCRA Section 313 reporting nor would
supplier notification be required because the concentration of 2,4- diaminotoluene is below its de minimis
limit of 0.1 percent in the product.
Manufacture as a Commercial Byproduct and Impurity
Chloroform is a reaction byproduct in the production of carbon tetrachloride. It is removed by distillation
to a concentration of less than 150 ppm (0.0150 percent) remaining in the carbon tetrachloride. The
separated chloroform at 90 percent concentration is sold as a byproduct. Chloroform is subject to a 0.1
percent (1000 ppm) de minimis limit. Any amount of chloroform manufactured and separated as byproduct
must be included in threshold determinations because EPA does not interpret the de minimis exemption to
apply to the manufacture of a chemical as a byproduct. Releases of chloroform prior to and during
purification of the carbon tetrachloride must be reported. The de minimis exemption can, however, be
applied to the chloroform remaining in the carbon tetrachloride as an impurity. Because the concentration
of chloroform remaining in the carbon tetrachloride is below the de minimis limit, this quantity of
chloroform is exempt from threshold determinations, release and other waste management reporting, and
supplier notification.
Manufacture as a Waste Byproduct
A small amount of formaldehyde is manufactured as a reaction byproduct during the production of
phthalic anhydride. The formaldehyde is separated from the phthalic anhydride as a waste gas and burned,
leaving no formaldehyde in the phthalic anhydride. The amount of formaldehyde produced and removed
must be included in threshold determinations and release and other waste management estimates even if
the formaldehyde were present below the de minimis level in the process stream where it was
manufactured or in the waste stream to which it was separated because EPA does not interpret mixtures
and trade name products to includes wastes.
Laboratory Activities Exemption. EPCRA Section
313 chemicals that are manufactured, processed, or
otherwise used in a laboratory at a covered facility
under the direct supervision of a technically
qualified individual do not have to be considered for
threshold determinations and release and other
waste management calculations. However, pilot
plant scale and specialty chemical production does
not qualify for this laboratory activities exemption,
nor does the use of EPCRA Section 313 chemicals
for laboratory support activities, such as the use of
chemicals for equipment maintenance.
Coal Extraction Activities Exemption. If an
EPCRA Section 313 chemical is manufactured,
processed, or otherwise used in extraction by
facilities in NAICS codes 212111, 212112 and
212113, a person is not required to consider the
quantity of the EPCRA Section 313 chemical so
manufactured, processed, or otherwise used when
considering threshold determinations and release
and other waste management calculations (see
Example 8). Reclamation activities occurring
simultaneously with coal extraction activities (e.g.,
cast blasting) are included in the exemption.
However, otherwise use of ash, waste rock, or
fertilizer for reclamation purposes are not
considered part of extraction; non-exempt amounts
of EPCRA Section 313 chemicals contained in these
materials must be considered toward threshold
determinations and release and other waste
management calculations.
Metal Mining Overburden Exemption. If an
EPCRA Section 313 chemical that is a constituent
of overburden is processed or otherwise used by
facilities in NAICS codes 212221, 212222, 212231,
212234, and 212299, a person is not required to
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consider the quantity of the EPCRA Section 313
chemical so processed or otherwise used when
considering threshold determinations and release
and other waste management calculations.
For purposes of EPCRA Section 313 reporting,
overburden is the unconsolidated material that
overlies a deposit of useful material or ore. It does
not include any portion of the ore or waste rock.
Example 8: Coal mining extraction activities
Included among these are explosives for blasting
operations, solvents, lubricants, and fuels for
extraction related equipment maintenance and
use, as well as overburden and mineral deposits.
The EPCRA Section 313 chemicals contained in
these materials are exempt from threshold
determinations and release and other waste
management calculations, when manufactured,
processed or otherwise used during extraction
activities at coal mines.
B. 4 Threshold Determinations
EPCRA Section 313 reporting is required if
threshold quantities are exceeded. Separate
thresholds apply to the amount of the EPCRA
Section 313 chemical that is manufactured,
processed or otherwise used.
You must submit a report for any EPCRA Section
313 chemical that is not listed as a PBT chemical
and which is manufactured or processed at your
facility in excess of the following threshold:
• 25,000 pounds per toxic chemical or category
over the calendar year.
• You must submit a report for any EPCRA
Section 313 chemical which is not listed as a
PBT chemical and that is otherwise used at your
facility in excess of 10,000 pounds per toxic
chemical or category over the calendar year.
You must submit a report for any EPCRA Section
313 chemical that is listed as a PBT chemical and
which is manufactured, processed or otherwise used
at your facility above the designated threshold for
that chemical.
The PBT chemical names, CAS numbers and their
reporting thresholds are listed in the table below.
See Table He of these instructions for lists of
individual members of the dioxin and dioxin-like
compounds chemical category and the polycyclic
aromatic compounds (PACs) chemical category.
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
Chemical or chemical
category name
Aldrin
Benzo[g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds category
(manufacturing; and the
processing or otherwise
use of dioxin and dioxin-
like compounds category
if the dioxin and dioxin-
like compounds are
present as contaminants
in a chemical and if they
were created during the
manufacturing of that
chemical)
Heptachlor
Hexachlorobenzene
Isodrin
Lead (this lower
threshold does not apply
to lead when it is
contained in stainless
steel, brass or bronze
alloy)
Lead compounds
Mercury
Mercury compounds
Methoxychlor
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Polychlorinated
biphenyls (PCBs)
Polycyclic aromatic
compounds category
(PACs)
Tetrabromobisphenol A
Toxaphene
Trifluralin
CAS number
or chemical
category
code
309-00-2
191-24-2
57-74-9
N150
76-44-8
118-74-1
465-73-6
7439-92-1
N420
7439.97-6
N458
72-43-5
29082-74-4
40487-42-1
608-93-5
1336-36-3
N590
79-94-7
8001-35-2
1582-09-8
Threshold
(pounds,
unless noted
otherwise)
100
10
10
0.1 gram
10
10
10
100
100
10
10
100
10
100
10
10
100
100
10
100
B.4.a. How to Determine if Your
Facility Has Exceeded
Thresholds
To determine whether your facility has exceeded an
EPCRA Section 313 reporting threshold, compare
quantities of EPCRA Section 313 chemicals that
you manufacture, process, or otherwise use to the
respective thresholds for those activities. A
worksheet is provided in Figure 3A to assist
facilities in determining whether they exceed any of
the reporting thresholds for non-PBT chemicals;
Figures 3B-D provide worksheets for PBT
chemicals. (The worksheets can be found at the end
of section B.5.) These worksheets also provide a
format for maintaining reporting facility records.
Use of these worksheets is not required and the
completed worksheet(s) should not accompany
Form R reports submitted to EPA and the state or
tribe.
Complete the appropriate worksheet for each
EPCRA Section 313 chemical or chemical category.
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
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
EPCRA Section 313. Do not include in Step 2
exempt quantities of the EPCRA Section 313
chemical not included in the calculations in Step
1. For example, if Freon contained in the
building's air conditioners was not reported in
Step 1, you would not include the amount as
exempt in Step 2. Step 2 is intended for use
when a quantity or use of the EPCRA Section
313 chemical is exempt while other quantities
require reporting. Note the type of exemption
for future reference. Also identify, if applicable,
the fraction or percentage of the EPCRA
Section 313 chemical present that is exempt.
Add the amounts in each activity to obtain a
subtotal for exempted amounts of the EPCRA
Section 313 chemical or chemical categories at
the facility.
• Step 3 involves subtracting the result of Step 2
from the results of Step 1 for each activity.
Compare this net sum to the applicable activity
threshold. If the threshold is exceeded for any of
the three activities, a facility must submit a
Form R for that EPCRA Section 313 chemical
or chemical category. Do not sum quantities of
the EPCRA Section 313 chemical that are
manufactured, processed, and otherwise used at
your facility, because each of these activities
requires a separate threshold determination. For
example, if in a calendar year you processed
20,000 pounds of a non-PBT EPCRA Section
313 chemical and you otherwise used 6,000
pounds of that same chemical, your facility has
not exceeded any applicable threshold and thus
is not required to report for that chemical.
Worksheets should be retained to document your
determination for reporting or not reporting, but
should not be submitted with the report.
You must submit a report if you exceed any
threshold for any EPCRA Section 313 chemical or
chemical category. For example, if your facility
processes 22,000 pounds of a non-PBT EPCRA
Section 313 chemical and also otherwise uses
16,000 pounds of that same chemical, it has
exceeded the otherwise use threshold (10,000
pounds for a non-PBT chemical) and your facility
must report even though it did not exceed the
process threshold (25,000 pounds for a non-PBT
chemical). In preparing your reports, you must
consider all non-exempted activities and all releases
and other waste management quantities of the
EPCRA Section 313 chemical from your facility,
not just releases and other waste management
quantities from the otherwise use activity.
Also note that threshold determinations are based
upon the actual amounts of an EPCRA Section 313
chemical manufactured, processed, or otherwise
used over the course of the calendar year. The
threshold determination may not relate to the
amount of an EPCRA Section 313 chemical brought
on-site during the calendar year. For example, if a
stockpile of 100,000 pounds of a non-PBT EPCRA
Section 313 chemical is present on-site but only
20,000 pounds of that chemical is applied to a
process, only the 20,000 pounds processed is
counted toward a threshold determination, not the
entire 100,000 pounds of the stockpile.
B.4.b. Threshold Determinations for
On-Site Reuse Operations
Threshold determinations of EPCRA Section 313
chemicals that are reused at the facility are based
only on the amount of the EPCRA Section 313
chemical that is added during the year, not the total
volume in the system. For example, a facility
operates a refrigeration unit that contains 15,000
pounds of anhydrous ammonia at the beginning of
the year. The system is charged with 2,000 pounds
of anhydrous ammonia during the year. The facility
has therefore "otherwise used" only 2,000 pounds of
anhydrous ammonia, a non-PBT EPCRA Section
313 chemical, which is below the otherwise use
threshold for anhydrous ammonia and is not
required to report (unless there are other "otherwise
use" activities of ammonia, that when taken
together, exceed the reporting threshold). If,
however, the whole refrigeration unit was recharged
with 15,000 pounds of anhydrous ammonia during
the year, then the facility would have exceeded the
otherwise use threshold, and would be required to
report.
This does not apply to EPCRA Section 313
chemicals "recycled" or "reused" off-site and
returned to a facility. Such EPCRA Section 313
chemicals returned to a facility are treated as the
equivalent of newly purchased material for purposes
of EPCRA Section 313 threshold determinations.
B.4.c. Threshold Determinations for
Ammonia
The listing for ammonia includes the modifier
"includes anhydrous ammonia and aqueous
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
ammonia from water dissociable ammonium salts
and other sources; 10 percent of total aqueous
ammonia is reportable under this listing." The
qualifier for ammonia means that anhydrous forms
of ammonia are 100 percent reportable and aqueous
forms are limited to 10 percent of total aqueous
ammonia. Therefore, when determining threshold
quantities, 100 percent of anhydrous ammonia is
included but only 10 percent of total aqueous
ammonia is included. If any ammonia evaporates
from aqueous ammonia solutions, 100 percent of the
evaporated ammonia is included in threshold
determinations.
For example, if a facility processes aqueous
ammonia, it has processed 100 percent of the
aqueous ammonia in that solution. If the ammonia
remains in solution, then 10 percent of the total
aqueous ammonia is counted towards the threshold.
If there are any evaporative losses of anhydrous
ammonia, then 100 percent of those losses must be
counted towards the processing threshold. If the
manufacturing, processing, or otherwise use
threshold for the ammonia listing is exceeded, the
facility must report 100 percent of these evaporative
losses in Sections 5 and 8 of the Form R.
B.4.d. Threshold Determinations for
Chemical Categories
A number of chemical compound categories are
subject to reporting. See Table He for a listing of
these EPCRA Section 313 chemical categories.
When preparing threshold determinations for one of
these EPCRA Section 313 chemical categories, all
individual members of a category that are
manufactured, processed, or otherwise used must be
counted. Where generic names are used at a facility,
threshold determinations should be based on CAS
numbers. For example, Poly-Solv EB does not
appear among the reportable chemicals in Table Ha
or lib but its CAS number indicates Poly-Solv EB is
a synonym for ethylene glycol mono-n-butyl ether, a
member of the certain glycol ethers chemical
category (code N230). For chemical compound
categories, threshold determinations must be made
separately for each of the three activities. Do not
include in these threshold determinations for a
category any chemicals that are also individually
listed EPCRA Section 313 chemicals (see Table Ha
or lib). Individually listed EPCRA Section 313
chemicals are subject to their own individual
threshold determination.
Organic Compounds
For the organic compound categories, you are
required to account for the entire weight of all
compounds within a specific compound category
(e.g., glycol ethers) at the facility for BOTH the
threshold determination and release and other waste
management estimates.
Metal Category Compounds
Threshold determinations for metal category
compounds present a special case. If, for example,
your facility processes several different nickel
compounds, base your threshold determination on
the total weight of all nickel compounds processed.
However, if your facility processes both the
"parent" metal (nickel) as well as one or more
nickel compounds, you must make threshold
determinations for both nickel (CAS number 7440-
02-0) and nickel compounds (chemical category
code N495) because they are separately listed
EPCRA Section 313 chemicals. If your facility
exceeds thresholds for both the parent metal and
compounds of that same metal, EPA allows you to
file one combined report (e.g., one report for nickel
compounds, including nickel) because the release
information you will report in connection with metal
category compounds will be the total pounds of the
metal released. If you file one combined report, you
should put the name of the metal compound
category on the Form R. In the example above, the
facility that exceeded reporting thresholds for both
the nickel and nickel compounds chemical category
could submit a single Form R for the nickel
compounds chemical category, which would contain
release and other waste management information for
both nickel and nickel compounds. Do not put both
names on the Form R.
The case of metal category compounds involving
more than one metal should be noted. Some metal
category compounds may contain more than one
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 quantity
of each parent metal released or otherwise managed
as waste, not the quantity of the compound, would
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
be reported on the appropriate sections of both Form
Rs. SeeB.5.)
Nitrate Compounds (water dissociable;
reportable only when in aqueous solution)
For the category nitrate compounds (water
dissociable; reportable only when in aqueous
solution), the entire weight of the nitrate compound
is counted in making threshold determinations. A
nitrate compound is covered by this listing only
when in water and only if dissociated. If no
information is available on the identity of the type
of nitrate that is manufactured, processed or
otherwise used, assume that the nitrate compound
exists as sodium nitrate.
B.4.e Threshold Determination for
Persistent Bioaccumulative Toxic
(PBT) Chemicals
There are two separate thresholds for EPCRA
Section 313 PBT chemicals; these thresholds are set
based on the chemicals' potential to persist and
bioaccumulate in the environment. The
manufacturing, processing and otherwise use
thresholds for PBT chemicals is 100 pounds, while
for the subset of PBTs chemicals that are highly
persistent and highly bioaccumulative, it is 10
pounds. One exception is the dioxin and dioxin-like
compounds chemical category. The threshold for
this category is 0.1 gram. The PBT chemicals, their
CAS numbers or chemical category code, and their
reporting thresholds are listed in a table in the
introductory section of B.4. See Table He of these
instructions for lists of individual members of the
dioxin and dioxin-like compounds chemical
category and the polycyclic aromatic compounds
(PACs) chemical category.
B.4.f. Mixtures and Other Trade Name
Products
EPCRA Section 313 chemicals contained in
mixtures and other trade name products must be
factored into threshold determinations and release
and other waste management calculations.
If your facility processed or otherwise used mixtures
or other trade name products during the calendar
year, you are required to use the best readily
available data (or reasonable estimates if such data
are not readily available) to determine whether the
toxic chemicals in a mixture meet or exceed the de
minimis concentration and, therefore, whether they
must be included in threshold determinations and
release and other waste management calculations. If
you know that a mixture or other trade name
product contains a specific EPCRA Section 313
chemical, combine the amount of the EPCRA
Section 313 chemical in the mixture or other trade
name product with other amounts of the same
EPCRA Section 313 chemical processed or
otherwise used at your facility for threshold
determinations and release and other waste
management calculations. If you know that a
mixture contains an EPCRA Section 313 chemical
but it is present below the de minimis level, you do
not have to consider the amount of the EPCRA
Section 313 chemical present in that mixture for
purposes of threshold determinations and release
and other waste management calculations. PBT
chemicals are not eligible for the de minimis
exemption except lead when it is contained in
stainless steel, brass or bronze alloy.
Observe the following guidelines in estimating
concentrations of EPCRA Section 313 chemicals in
mixtures when only limited information is available:
• If you only know the upper bound
concentration, you must use it for threshold
determinations (40 CFR Section372.30(b)(ii)).
• If you know the lower and upper bound
concentrations of an EPCRA Section 313
chemical in a mixture, EPA recommends you
use the midpoint of these two concentrations for
threshold determinations.
• If you know only the lower bound
concentration, EPA recommends you subtract
out the percentages of any other known
components to determine a reasonable upper
bound concentration, and then determine a
midpoint.
• If you have no information other than the lower
bound concentration, EPA recommends you
calculate a midpoint assuming an upper bound
concentration of 100 percent.
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,
only the weight of the metal portion of the metal
category compound must be considered for release
and other waste management determinations.
Remember that for metal category compounds that
consist of more than one metal, release and other
waste management reporting must be based on the
weight of each metal, provided that the appropriate
thresholds have been exceeded.
Metals and Metal Category Compounds
For compounds within the metal compound
categories, only the metal portion of the metal
category compound must be considered in
determining release and other waste management
quantities for the metal category compounds.
Therefore, if thresholds are separately exceeded for
both the "parent" metal and its compounds, EPA
allows you to file a combined Form R for the
"parent" metal and its category compounds. This
Form R would contain all of the release and other
waste management information for both the
"parent" metal and metal portion of the related
metal category compounds. For example, you
exceed thresholds for chromium. You also exceed
thresholds for chromium compounds. Instead of
filing two Form Rs you can file one combined Form
R. This Form R would contain information on
quantities of chromium released or otherwise
managed as waste and the quantities of the
chromium portion of the chromium compounds
released or otherwise managed as waste. When
filing one combined Form R for an EPCRA Section
313 metal and metal compound category, facilities
should identify the chemical reported as the metal
compound category name and code in Section 1 of
the Form R. Note that this does not apply to the
Form A. See Section E.7 in these instructions on the
Form A. See Appendix B for more information
about reporting the release and other waste
management of metals and metal compounds.
Nitrate Compounds (water dissociable;
reportable only in aqueous solution)
Although the complete weight of the nitrate
compound must be used for threshold
determinations for the nitrate compounds category
only the nitrate portion of the compound should be
used for release and other waste management
calculations.
Toxics Release Inventory Reporting Forms and Instructions
30
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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 percent n-hexane, an EPCRA Section 313 chemical; however, it also states that the solvent
contains 20 percent non-hazardous surfactants. This is the only n-hexane-containing mixture used at the
facility.
EPA recommends you follow these steps to determine if the quantity of the EPCRA Section 313 chemical
in Solvent X exceeds the threshold for otherwise use.
1) Determine a reasonable maximum concentration for the EPCRA Section 313 chemical by
subtracting out the non-hazardous surfactants (i.e., 100% - 20% = 80%).
2) Determine the midpoint between the known minimum (50%) and the reasonable maximum
calculated above (i.e., (80% + 50%)/2 = 65%).
3) Multiply total weight of Solvent X otherwise used by 65% (0.65).
12,000 pounds x 0.65 = 7,800 pounds
4) Because the total amount of n-hexane otherwise used at the facility was less than the 10,000-pound
otherwise use threshold, the facility is not required to file a Form R for n-hexane.
Scenario #2: Your facility otherwise used 15,000 pounds of Solvent Y to clean printed circuit boards.
The MSDS for the solvent lists only that Solvent Y contains at least 80 percent of an EPCRA Section 313
chemical that is only identified as chlorinated hydrocarbons.
EPA recommends you follow these steps to determine if the quantity of the EPCRA Section 313 chemical
in the solvent exceeds the threshold for otherwise use.
1) Because the specific chemical is unknown, the Form R will be filed for "chlorinated hydrocarbons."
This name will be entered into Part II, Section 2.1, "Mixture Component Identity." (Note: Because
your supplier is claiming the EPCRA Section 313 chemical identity a trade secret, you do not have
to file substantiation forms.)
2) The upper bound limit is assumed to be 100 percent and the lower bound limit is known to be 80
percent. Using this information, the specific concentration is estimated to be 90 percent (i.e., the
mid-point between upper and lower limits).
(100% + 80%)/2 = 90%
3) The total weight of Solvent Y is multiplied by 90 percent (0.90) when calculating for thresholds.
15,000x0.90 = 13,500
4) Because the total amount of chlorinated hydrocarbons exceeds the 10,000-pound otherwise use
threshold, you must file a Form R for this chemical.
Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Date Worksheet Prepared:
Prepared By:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
l.
2.
3.
4.
Subtotal:
Information Source
Total Weight (Ib)
Percent EPCRA Section
313 Chemical
by Weight
EPCRA Section 313
Chemical Weight
(Ib)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (Ib):
Manufactured
(A) Ib
Processed
(B) Ib
Otherwise Used
(C) 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)
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical Exempt from
Above (Ib):
Manufactured
(Ai) Ib
Processed
(Bi) Ib
Otherwise Used
(CO Ib
(A-AO_
Ib (B-BO_
Ib
Ib
Amount subject to threshold:
Compare to threshold for EPCRA Section 313 reporting. 25,000 Ib 25,000 Ib 10,000 Ib
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R or Form A; retain it for your records.
Figure 3A. EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet1
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
32
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Date Worksheet Prepared:
Prepared By:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
l.
2.
3.
4.
Subtotal:
Information Source
Total Weight (Ib)
Percent EPCRA Section
313 Chemical
by Weight
EPCRA Section 313
Chemical Weight
(Ib)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (Ib):
Manufactured
(A) Ib
Processed
(B) Ib
Otherwise Used
(C) 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,
.!• -.1x1
activity)
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical Exempt from
Above (Ib):
Manufactured
(Ai) Ib
Processed
(Bi) Ib
Otherwise Used
(CO Ib
(A-AO_
Ib (B-BO_
Ib
Ib
Amount subject to threshold:
Compare to threshold for EPCRA Section 313 reporting. 100 Ib 100 Ib 100 Ib
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R or Form A; retain it for your records.
Figure 3B. EPCRA Section 313 Reporting Threshold Worksheet for PET Chemicals with 100 Pound Thresholds
Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
Toxics Release Inventory Reporting Forms and Instructions
33
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Date Worksheet Prepared:
Prepared By:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
l.
2.
3.
4.
Subtotal:
Information Source
Total Weight (Ib)
Percent EPCRA Section
313 Chemical
by Weight
EPCRA Section 313
Chemical Weight
(Ib)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (Ib):
Manufactured
(A) Ib
Processed
(B) Ib
Otherwise Used
(C) 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,
.!• -.1x1
activity)
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical Exempt from
Above (Ib):
Manufactured
(Ai) Ib
Processed
(Bi) Ib
Otherwise Used
(CO Ib
(A-AO_
Ib (B-BO_
Ib
Ib
Amount subject to threshold:
Compare to threshold for EPCRA Section 313 reporting. 10 Ib 10 Ib 10 Ib
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R or Form A; retain it for your records.
Figure 3C. EPCRA Section 313 Reporting Threshold Worksheet for PET Chemicals with 10 Pound Threshold
Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
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: Dioxin and Dioxin-like Compounds
CAS Registry Number:
Reporting Year:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Date Worksheet Prepared:
Prepared By:
Mixture Name or Other
Identifier
l.
2.
3.
4.
Subtotal:
Information Source
Total Weight (g)
Percent EPCRA Section
313 Chemical
by Weight
EPCRA Section 313
Chemical Weight
(g)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (g):
Manufactured
(A) g
Processed
(B) g
Otherwise Used
(C) g
Exempt quantity of the EPCRA Section 313 chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (articles, facility,
.!• -.1x1
activity)
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical Exempt from
Above (g):
Manufactured
(A,) g
Processed
(BO g
Otherwise Used
(CO g
(A-AO_
(B-BO_
.g (c-co_
.g
Amount subject to threshold:
Compare to threshold for EPCRA Section 313 reporting. 0.1 g 0.1 g 0.1 g
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R or Form A; retain it for your records.
Figure 3D. EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like Compounds Chemical Category
Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
Toxics Release Inventory Reporting Forms and Instructions
35
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Instructions for Completing TRI Form R
C. Instructions for Completing
TRI Form R
The following instructions provide information on
how to enter data on a Form R. Some data entry
fields of a Form R are done differently using the
TRI's electronic reporting tool called TRI-MEweb
than on a hard-copy paper form. TRI-MEweb also
has automatic data quality tools that will assist users
to enter valid data on their Form R and detect any
errors on a Form R. This is why TRI-MEweb is
EPA's preferred method to submit TRI data on a
Form R.
Part I. Facility Identification
Information
Section 1. Reporting Year
The reporting year is the calendar year to which the
reported information applies, not the year in which
you are submitting the report. Information for the
2012 reporting year must be submitted on or before
July 1, 2013.
Section 2. Trade Secret Information
2.1 Are you claiming the EPCRA Section 313
chemical identified on Page 2 a trade
secret?
Answer this question only after you have completed
the rest of the report. The specific identity of the
EPCRA Section 313 chemical being reported in Part
II, Section 1 may be designated as a trade secret. If
you are making a trade secret claim, mark "yes" and
proceed to Section 2.2. Only check "yes" if you
manufacture, process, or otherwise use the EPCRA
Section 313 chemical whose identity is a trade
secret. (See Section A.3 of these instructions for
specific information on trade secrecy claims.) If you
checked "no," proceed to Section 3; do not answer
Section 2.2.
2.2 If "yes" in 2.1, is this copy sanitized or
unsanitized?
Answer this question only after you have completed
the rest of the report. Check "sanitized" if this copy
of the report is the public version that does not
contain the EPCRA Section 313 chemical identity
but does contain a generic name that is structurally
descriptive in its place, and if you have claimed the
EPCRA Section 313 chemical identity trade secret
in Part I, Section
"unsanitized."
2.1. Otherwise, check
Section 3. Certification
The certification statement must be signed by a
senior official with management responsibility for
the person (or persons) completing the form. A
senior management official must certify the
accuracy and completeness of the information
reported on the form by signing and dating the
certification statement. Each report must contain an
original signature. You should print or type the
name and title of the person who signs the statement
in the space provided. This certification statement
applies to all the information supplied on the form
and should be signed only after the form has been
completed.
Section 4. Facility Identification
4.1 Facility Name, Location, TRI Facility
Identification Number and Tribal
Country Name
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 physical street address,
mailing address, city, county, three digit BIA code,
if applicable, state, and ZIP code in the space
provided. The street address provided must be the
location where the EPCRA Section 313 chemicals
are manufactured, processed, or otherwise used.
You may not use PO Box as a facility address. If
your mailing address and street address are the
same, you should enter NA in the space for the
mailing address. If the mailing address is outside of
the US, include the FIPS country code, which may
be found in Table IV.
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-MEweb. "NA" or "None"
are not acceptable entries. TRI-MEweb provides a
drop-down menu for the county name, including
city districts and parish names.
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Instructions for Completing TRI Form R
If your facility is located on Indian country as
defined by 18 USC §1151 you must enter the three
digit Bureau of Indian Affairs (BIA) tribal code in
the "City/County/Tribe/State/ZIP code" field. The
BIA tribal codes are listed in Table V of the RFI.
Facilities using TRI-MEweb to complete their forms
will be asked if they are located within a tribe's
Indian country and, upon answering "yes", be taken
to a look up table to determine the correct BIA code.
If your facility is not located (overwhelming
majority of TRI facilities are not in Indian Country)
in Indian country as defined by 18 USC §1151 you
must enter only the city, county (as applicable), state
and zip code Facilities filing a paper form should
leave blank in the BIA field, if not located within
tribal boundaries. Facilities using TRI-MEweb to
complete their forms will be required to check a
specific checkbox if they are located within tribal
lands and if they do not check that checkbox.
Location information for a facility that has
previously submitted data to EPA.
If your facility has submitted a Form R in previous
reporting years, and your facility is planning on
submitting a TRI Form R, a TRI Facility
Identification Number (TRIFID) has been already
assigned to your facility. If you know your TRIFID,
you should complete Form R Part I Section 4. If you
do not know your TRI Facility Identification
Number, you should visit the TRI Web page at:
http ://www. epa. gov/tri/contacts/contacts .htm for
more information or contact your Regional TRI
Program representative, or utilize Envirofacts on the
Web to look up the address or facility name at:
http ://www. epa. gov/enviro.
Location information for a facility that has
previously submitted data to EPA, but has
changed physical location.
Hard-copy paper Form R: If your facility has
moved do not enter your previously assigned 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 "New Facility" field for each
establishment. Utilize Envirofacts on the Web to
look up the address or facility name at:
http ://www. epa. gov/enviro if you are uncertain if a
TRIFID has been assigned to your new facility
location.
TRI-MEweb: If your facility has moved, you will
need to request that a new TRIFID be assigned to
your facility, add a new facility. To request a new
TRIFID, add a new facility account to TRI-MEweb
and chose to report as a new reporting facility
(option 3). TRI-MEweb will automatically generate
a new TRIFID for your facility. The TRIFID
assigned to your new reporting facility should be
used in all future reporting of TRI data.
Location information for a facility that has
changed ownership, but has not changed physical
location.
The TRI Facility Identification Number (TRIFID) is
established by the first Form R submitted by a
facility at a particular location. Only a change in
address warrants filing as a new facility; otherwise,
the TRI Facility Identification Number is retained
by the facility even if the facility changes name,
ownership, production processes, NAICS codes, etc.
Hard-copy paper Form R: The TRIFID
identification number will always stay with the
physical location of a facility. If a new facility unit
moves to this location it should use this TRIFID.
Establishments of a facility (for facilities that report
by part) that report separately should use the
TRIFID of the primary facility.
TRI-MEweb: If your facility has changed
ownership during the reporting year but not its
physical location, the facility does not require a new
TRIFID. Use the TRIFID assigned to previous
owner. TRI-MEweb can be used to update facility
information due to change of ownership.
Location reporting TRI releases for the first time
to EPA.
Hard-copy paper Form R: If you are preparing a
hard-copy TRI form for the first time for your
facility's location and have never reported to TRI in
prior years, you should enter "New Facility" in the
space on the hardcopy form designated for the TRI
Facility Identification number (TRIFID).
TRI-MEweb: If your facility is reporting for the
first time, upon creating your CDX account, and
adding TRI-MEweb application, you will be
prompted to add a new facility account into TRI-
MEweb. TRI-MEweb will automatically generate a
new TRIFID for your facility. The TRIFID
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Instructions for Completing TRI Form R
assigned to your new reporting facility should be
used in all future reporting of TRI data.
4.2 Full or Partial Facility Indication and
Federal Facility Designation
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.b of these instructions.)
A covered facility must report all releases and other
waste management activities and source reduction
activities of an EPCRA Section 313 chemical if the
facility meets a reporting threshold for that EPCRA
Section 313 chemical. Whether submitting a report
for the entire facility or separate reports for the
establishments, the threshold determination must be
made based on the entire facility. Indicate in Section
4.2 whether your report is for the entire covered
facility as a whole or for part of a covered facility
(i.e., one or more establishments).
Federal facilities and contractors at federal facilities
(GOCOs: Government-owned, contractor-operated
facilities) should check either 4.2c or 4.2d, but not
both. Federal facilities should check 4.2c, even if
their TRI reports contain release and other waste
management information from contractors located at
the facility. Contractors at federal facilities, which
are required by EPCRA Section 313 to file TRI
reports independently of the federal facility, should
check 4.2d. This information is important to prevent
duplication of federal facility data. (See Appendix A
for further guidance on these instructions.)
4.3 Technical Contact
Enter the name and telephone number (including
area code) of a technical representative whom EPA,
state, or tribal 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
the 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 published for
their review. If the technical contact does not have
an email address you should enter NA. This contact
person does not have to be the same person who
prepares the report or signs the certification
statement and does not necessarily need to be
someone at the location of the reporting facility.
However, this person should be familiar with the
details of the report so that he or she can answer
questions about the information provided.
4.4 Public Contact
Enter the name and telephone number (including
area code) of a person who can respond to questions
from the public about the form. You should also
enter an e-mail address for this person. If you
choose to designate the same person as both the
Technical and the Public Contact, or you do not
have a Public Contact, you may enter "Same as
Section 4.3" in this space. This contact person does
not have to be the same person who prepares the
form or signs the Certification Statement and does
not necessarily need to be someone at the location
of the reporting facility.
4.5 North American Industry Classification
System (NAICS) Codes
The North American Industry Classification System
(NAICS) is the economic classification system that
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Instructions for Completing TRI Form R
replaces the 1987 SIC code system for TRI
Reporting beginning with the RY 2006 EPCRA
Section 313 reporting (71 FR 32464). Enter the
appropriate six digit North American Industry
Classification System (NAICS) Code that is the
primary NAICS code for your facility in Section
4.5(a). For Reporting Year 2008 and beyond, use
2007 NAICS codes. Enter any other applicable
NAICS for your facility in 4.5 (b)-(f). Table I lists
the TRI-covered NAICS codes. If you do not know
your NAICS code, consult the 2007 NAICS Manual
(see Section B.2 of these instructions for ordering
information) or check the SIC to NAICS crosswalk
tables at: http://www.census.gov.
4.6 Dun & Bradstreet Number(s)
Enter the nine digit number assigned by Dun &
Bradstreet (D&B) for your facility or each
establishment within your facility. These numbers
code the facility for financial purposes. This number
may be available from your facility's treasurer or
financial officer. You can also obtain the numbers
from Dun & Bradstreet by calling 1-888-814-1435,
or by visiting this website:
https://www.dnb.com/product/dlw/form_cc4.htm. 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, EST) or on the Web at:
http://www.dnb.com. If none of your establishments
has been assigned a D&B number, you should enter
NA in box (a). If only some of your establishments
have been assigned D&B numbers, enter those
numbers in Part I, section 4.6.
Section 5.
Parent Company
Information
You must provide information on your parent
company. For TRI Reporting purposes, your parent
company is the highest level U.S. company which
directly owns at least 50 percent of the voting stock
of your company. If there is no higher level U.S.
company, select the "No U.S. Parent Company
parent (for TRI reporting purposes)" check box.
Corporate names should be treated as parent
company names for companies with multiple facility
sites. For example, the Bestchem Corporation is not
owned or controlled by any other corporation but
has sites throughout the country whose names begin
with Bestchem. In this case, Bestchem Corporation
should be listed as the parent company. Note that a
facility that is a 50:50 joint venture is its own parent
company. When a facility is owned by more than
one company and none of the facility owners
directly owns at least 50 percent of its voting stock,
the facility should provide the name of the parent
company of either the facility operator or the owner
with the largest ownership interest in the facility.
5.1 Name of Parent Company
Enter the name of the corporation or other business
entity that is your highest level U.S. parent
company. If your facility has no higher level U.S.
company, select the "No U.S. Parent Company (for
TRI reporting purposes)" check 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 or by calling 1-888-814-1435, or by
visiting this website:
https ://www. dnb .com/product/dlw/form_cc4 .htm. If
your parent company does not have a D&B number,
you should check the NA box.
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Instructions for Completing Part II of EPA Form R
Part II. Chemical Specific
Information
In Part II, you are to report on:
• The EPCRA Section 313 chemical being
reported;
• The general uses and activities involving the
EPCRA Section 313 chemical at your facility;
• On-site releases of the EPCRA Section 313
chemical from the facility to air, water, and
land;
• Quantities of the EPCRA Section 313 chemical
transferred to off-site locations;
• Information for on-site and off-site disposal,
treatment, energy recovery, and recycling of the
EPCRA Section 313 chemical; and
• Source reduction activities.
Section 1. EPCRA Section 313
Chemical Identity
1.1 CAS Number
Enter the Chemical Abstracts Service (CAS)
registry number in Section 1.1 exactly as it appears
in Table II of these instructions for the chemical
being reported. CAS numbers are cross-referenced
with an alphabetical list of chemical names in Table
II. If you are reporting one of the EPCRA Section
313 chemical categories (e.g., chromium
compounds), you should enter the applicable
category code in the CAS number space. EPCRA
Section 313 chemical category codes are listed
below and can also be found in Table He and
Appendix B.
EPCRA Section 313 Chemical Category Codes:
NO 10 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N150 Dioxin and dioxin-like compounds
N171 Ethylenebisdithiocarbamic acid, salts and
esters (EBDCs)
N230 Certain glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N503 Nicotine and salts
N511 Nitrate compounds (water dissociable,
reportable only in aqueous solution)
N575 Polybrominated biphenyls (PBBs)
N583 Polychlorinated alkanes (C10 to C13)
N590 Polycyclic aromatic compounds (PACs)
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N770 Vanadium compounds
N874 Warfarin and salts
N982 Zinc compounds
If you are making a trade secret claim, you must
report the CAS number or category code on your
unsanitized Form R and unsanitized substantiation
form. Do not include the CAS number or category
code on your sanitized Form R or sanitized
substantiation form.
1.2 EPCRA Section 313 Chemical or
Chemical Category Name
Enter the name of the EPCRA Section 313 chemical
or chemical category exactly as it appears in Table
II. If the EPCRA Section 313 chemical name is
followed by a synonym in parentheses, report the
chemical by the name that directly follows the CAS
number (i.e., not the synonym). If the EPCRA
Section 313 chemical identity is actually a product
trade name (e.g., Dicofol), the Chemical Abstracts
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
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Instructions for Completing Part II of EPA Form R
generic name that is structurally descriptive in Part
II, Section 1.3 of your sanitized Form R report.
EPA requests that the EPCRA Section 313
chemical, chemical category, or generic name also
be placed in the box marked "Toxic Chemical,
Category, or Generic Name" in the upper right-hand
corner on all pages of Form R. While this space is
not a required data element, providing this
information will help you in preparing a complete
Form R report.
1.3 Generic Chemical Name
Complete Section 1.3 only if you are claiming the
specific EPCRA Section 313 chemical identity of
the EPCRA Section 313 chemical as a trade secret
and have marked the trade secret block in Part I,
Section 2.1 on Page 1 of Form R. Enter a generic
chemical name that is descriptive of the chemical
structure. You should limit the generic name to
seventy characters (e.g., numbers, letters, spaces,
punctuation) or less. Do not enter mixture names in
Section 1.3; see Section 2 below.
In-house plant codes and other substitute names that
are not structurally descriptive of the EPCRA
Section 313 chemical identity being withheld as a
trade secret are not acceptable as a generic name.
The generic name must appear on both sanitized and
unsanitized Form Rs, and the name must be the
same as that used on your substantiation forms.
Section 2. Mixture Component
Identity
Do not complete this section if you have completed
Section 1 of Part II. Report the generic name
provided to you by your supplier in this section if
your supplier is claiming the chemical identity
proprietary or trade secret. Do not answer "yes" in
Part I, Section 2.1 on Page 1 of the form if you
complete this section. You do not need to supply
trade secret substantiation forms for this EPCRA
Section 313 chemical because it is your supplier
who is claiming the chemical identity a trade secret.
Example 10: Mixture Containing Unidentified
EPCRA Section 313 Chemical
Your facility uses 20,000 pounds of a solvent that
your supplier has told you contains 80 percent
"chlorinated aromatic," their generic name for a
non-PBT EPCRA Section 313 chemical subject
to reporting under EPCRA Section 313. You,
therefore, have used 16,000 pounds of some
EPCRA Section 313 chemical and that exceeds
the "otherwise use" threshold for a non-PBT
chemical. You would file a Form R and enter the
name "chlorinated aromatic" in the space
provided in Part II, Section 2.
2.1 Generic Chemical Name Provided by
Supplier
Enter the generic chemical name in this section only
if the following three conditions apply:
1.) You determine that the mixture contains
an EPCRA Section 313 chemical but the only
identity you have for that chemical is a generic
name;
2.) You know either the specific
concentration of that EPCRA Section 313 chemical
component or a maximum or average concentration
level; and
3.) You multiply the concentration level by
the total annual amount of the whole mixture
processed or otherwise used and determine that you
meet the process or otherwise use threshold for that
single, generically identified mixture component.
Sections. 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 4). 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 Section B.3.a or
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Instructions for Completing Part II of EPA Form R
Part 40, Section 372.3 of the CFR for additional
explanations.
3.1 Manufacture the EPCRA Section 313
Chemical
Persons who manufacture (including import) the
EPCRA Section 313 chemical must check at least
one of the following:
a. Produce — The EPCRA Section 313
chemical is produced at the facility.
b. Import — The EPCRA Section 313 chemical
is imported by the facility into the Customs
Territory of the United States. (See Section
B.3.a of these instructions for further
clarification of import.)
And check at least one of the following:
c. For on-site use/processing — The EPCRA
Section 313 chemical is produced or imported
and then further processed or otherwise used
at the same facility. If you check this block,
generally you should also check at least one
item in Part II, Section 3.2 or 3.3.
d. For sale/distribution — The EPCRA Section
313 chemical is produced or imported
specifically for sale or distribution outside the
manufacturing facility.
e. As a byproduct — The EPCRA Section 313
chemical is produced coincidentally during
the manufacture, processing, or otherwise use
of another chemical substance or mixture and,
following its production, is separated from
that other chemical substance or mixture.
EPCRA Section 313 chemicals produced as a
result of waste management are also
considered byproducts.
f As an impurity — The EPCRA Section 313
chemical is produced coincidentally as a
result of the manufacture, processing, or
otherwise use of another chemical but is not
separated and remains in the mixture or other
trade name product with that other chemical.
In summary, if you are a manufacturer of the
EPCRA Section 313 chemical, you must check (a)
and/or (b), and at least one of (c), (d), (e), and (f) in
Section 3.1.
3.2 Process the EPCRA Section 313
Chemical
Persons who process the EPCRA Section 313
chemical must check at least one of the following:
a. As a reactant — A natural or synthetic
EPCRA Section 313 chemical is used in
chemical reactions for the manufacture of
another chemical substance or of a product.
Includes but is not limited to, feedstocks, raw
materials, intermediates, and initiators.
b. As a formulation component — An EPCRA
Section 313 chemical is added to a product (or
product mixture) prior to further distribution of
the product that acts as a performance enhancer
during use of the product. Examples of EPCRA
Section 313 chemicals used in this capacity
include, but are not limited to, additives, dyes,
reaction diluents, initiators, solvents, inhibitors,
emulsifiers, surfactants, lubricants, flame
retardants, and rheological modifiers.
c. As an article component — An EPCRA
Section 313 chemical becomes an integral
component of an article distributed for
industrial, trade, or consumer use. One
example is the pigment components of paint
applied to a chair that is sold.
d. Repackaging — This consists of processing or
preparation of an EPCRA Section 313
chemical (or product mixture) for distribution
in commerce in a different form, state, or
quantity. This includes, but is not limited to,
the transfer of material from a bulk container,
such as a tank truck to smaller containers such
as cans or bottles.
e.
As an impurity — The EPCRA Section 313
chemical is processed but is not separated and
remains in the mixture or other trade name
product with that/those other chemical(s).
3.3
Otherwise Use the EPCRA Section 313
Chemical (non-incorporative activities)
Persons who otherwise use the EPCRA Section 313
chemical must check at least one of the following:
a. As a chemical processing aid — An EPCRA
Section 313 chemical that is added to a
reaction mixture to aid in the manufacture or
synthesis of another chemical substance but is
not intended to remain in or become part of the
product or product mixture is otherwise used as
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Instructions for Completing Part II of EPA Form R
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.
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.
Ancillary or other use — An EPCRA Section
313 chemical that is used at a facility for
purposes other than aiding chemical processing
or manufacturing as described above is
otherwise used as an ancillary or other use.
Examples include, but are not limited to,
cleaners, degreasers, lubricants, fuels, EPCRA
Section 313 chemicals used for treating wastes,
and EPCRA Section 313 chemicals used to
treat water at the facility.
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important: DO NOT complete this section if you are reporting a mixture component in Section 2 below.)
1.1
CAS Number (Important Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
334-88-3
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
Diazomethane
1.3
Generic Chemical Name (Important Complete only if Part I, 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.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, tetters, spaces, and punctuation.)
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check all that apply.)
3.1 I Manufacture the toxic chemical:
3.2 I Process the toxic chemical:
3.3! Otherwise use the toxic chemical:
a. [2 Produce b. rj Import
If Produce or Import
c. [/] For on-site use/processing
d. [2 For sale/distribution
e. | | As a byproduct
f. I I As an impurity
a. [2 As a reactant
b. | | As a formulation component
C. | | As an article component
d. Q Repackaging
e. | | As an impurity
a. I I As a cJiemical processing aid
b. | | As a manufacturing aid
c. | | Ancillary or other use
Figure 4. Reporting EPCRA Section 313 Chemicals
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Instructions for Completing Part II of EPA Form R
Section 4. Maximum Amount of the
EPCRA Section 313 Chemical
On-site at Any Time during
the Calendar Year
For data element 4.1 of Part II, insert the code (see
codes below) that indicates the maximum quantity
of the EPCRA Section 313 chemical (e.g., in storage
tanks, process vessels, on-site shipping containers,
or in wastes generated) at your facility at any time
during the calendar year. If the EPCRA Section 313
chemical was present at several locations within
your facility, use the maximum total amount present
at the entire facility at any one time. While range
reporting is not allowed for PBT chemicals
elsewhere on the Form R, range reporting for PBT
chemicals is allowed for the Maximum Amount On-
site.
Example 11: Manufacturing and Processing
Activities of EPCRA Section 313 Chemicals
In the two examples below, it is assumed that the
threshold quantities for manufacture, process, or
otherwise use (25,000 pounds, 25,000 pounds,
and 10,000 pounds, respectively for non-PBT
chemicals; 100 pounds for certain PBT
chemicals; 10 pounds for highly persistent, highly
bioaccumulative toxic chemicals; and 0.1 grams
for the PBT chemical category comprised of
dioxin and dioxin-like compounds) have been
exceeded and the reporting of EPCRA Section
313 chemicals is therefore required.
1. Your facility manufactures diazomethane. Fifty
percent is sold as a product, thus it is processed.
The remaining fifty percent is reacted with alpha-
naphthylamine, forming N-methyl-alpha-
naphthylamine and also producing nitrogen gas.
• Your company manufactures diazomethane,
an EPCRA Section 313 chemical, both for
sale/ distribution as a commercial product
and for on-site use/processing as a feedstock
in the N-methyl-alpha-naphthylamine
production process. Because the
diazomethane is a reactant, it is also
processed. See Figure 4 for how this
information would be reported in Part II,
Section 3 of Form R.
• Your facility also processes alpha-
naphthylamine, as a reactant to produce N-
methyl-alpha-naphthylamine, a chemical not
on the EPCRA Section 313 list.
2. Your facility is a commercial distributor of
Missouri bituminous coal, which contains
mercury at 1.5 ppm (w:w). You should check the
box on the Form R at Part II, Section 3.2.e for
processing mercury as an impurity.
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Weight Range in Pounds
Range
01
02
03
04
05
06
07
08
09
10
11
Code 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 CFR 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.
Weight Range in Grams (Dioxin and Dioxin-like
Compounds)
When reporting for the dioxin and dioxin-like
compounds category use the following gram
quantity range codes:
Range Code
12
13
14
15
16
17
18
19
20
From...
0
0.1
1.0
10
100
1,000
10,000
100,000
1,000,000
To...
0.099
0.99
9.99
99
999
9,999
99,999
999,999
more than
1 million
Sections. Quantity of the Toxic
Chemical Entering Each
Environmental Medium On-
site
In Section 5, you must account for the total
aggregate on-site releases of the EPCRA Section
313 chemical to the environment from your facility
for the calendar year.
On-site releases to the environment include
emissions to the air, discharges to surface waters,
and releases to land and underground injection
wells.
For all toxic chemicals (except the dioxin and
dioxin-like compound category), do not enter the
values in Section 5 in gallons, tons, liters, or any
measure other than pounds. You must also enter the
values as whole numbers (do not use scientific
notation). Numbers following a decimal point are
not acceptable for toxic chemicals other than those
designated as PBT chemicals. For PBT chemicals,
facilities should report release and other waste
management quantities greater than 0.1 pound
(except the dioxin and dioxin-like compounds
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.
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Example 12: Reporting Dioxins and Dioxin-
Like Compounds
If the total quantity for Section 5.2 of the Form R
(i.e., stack or point air emissions) is 0.00005
grams or less, then zero can be entered. If the total
quantity is between 0.00005 and 0.0001 grams,
then 0.0001 grams can be entered or the actual
number can be entered (e.g., 0.000075).
NA vs. a Numeric Value (e.g., Zero). Generally,
NA is applicable if the waste stream that contains or
contained the EPCRA Section 313 chemical is not
directed to the relevant environmental medium, or if
leaks, spills and fugitive emissions cannot occur. If
the waste stream that contains or contained the
EPCRA Section 313 chemical is directed to the
environmental medium, or if leaks, spills or fugitive
emissions can occur, NA should not be used, even if
treatment or emission controls result in a release of
zero. If the annual aggregate release of that chemical
was equal to or less than 0.5 pound, the value
reported is zero (unless the chemical is a listed PBT
chemical).
For Section 5.1, NA generally is not applicable for
volatile organic compounds (VOCs). For Section
5.5.4, NA generally would not be applicable,
recognizing the possibility of accidental spills or
leaks of the EPCRA Section 313 chemical.
An example that illustrates the use of NA vs. a
numeric value (e.g., zero) would be nitric acid
involved in a facility's processing activities. If the
facility neutralizes the wastes containing nitric acid
to a pH of 6 or above, then the facility reports a
release of zero for the EPCRA Section 313
chemical, not NA. Another example is when the
facility has no underground injection well, in which
case NA should be entered in Part I, Section 4.10
and checked in Part II, Section 5.4.1 and 5.4.2 of
Form R. Also, if the facility does not landfill the
acidic waste, NA should be checked in Part II,
Section 5.5.1.B of Form R.
All releases of the EPCRA Section 313 chemical to
the air must be classified as either stack or fugitive
emissions, and included in the total quantity
reported for these releases in Sections 5.1 and 5.2.
Instructions for columns A, B, and C follow the
discussions of Sections 5.1 through 5.5.
5.1 Fugitive or Non-Point Air Emissions
Report the total of all releases of the EPCRA
Section 313 chemical to the air that are not released
through stacks, vents, ducts, pipes, or any other
confined air stream. You must include (1) fugitive
equipment leaks from valves, pump seals, flanges,
compressors, sampling connections, open-ended
lines, etc.; (2) evaporative losses from surface
impoundments and spills; (3) releases from building
ventilation systems; and (4) any other fugitive or
non-point air emissions. Engineering estimates and
mass balance calculations (using purchase records,
inventories, engineering knowledge or process
specifications of the quantity of the EPCRA Section
313 chemical entering product, hazardous waste
manifests, or monitoring records) may be useful in
estimating fugitive emissions. You should check the
NA box in Section 5.1 if you do not engage in
activities that result in fugitive or non-point air
emissions of this listed toxic chemical. For VOCs,
NA generally would not be applicable.
5.2 Stack or Point Air Emissions
Report the total of all releases of the EPCRA
Section 313 chemical to the air that occur through
stacks, confined vents, ducts, pipes, or other
confined air streams. You must include storage tank
emissions. Air releases from air pollution control
equipment would generally fall in this category.
Monitoring data, engineering estimates, and mass
balance calculations may help you to complete this
section. You should check the NA box in Section
5.2 if there are no stack air activities involving the
waste stream that contains or contained the EPCRA
Section 313 chemical.
5.3 Discharges to Receiving Streams or
Water Bodies
In Section 5.3 you are to enter all the names of the
streams or water bodies to which your facility
directly discharges the EPCRA Section 313
chemical on which you are reporting. A total of
three spaces is provided on Page 2 of Form R. If you
discharge the EPCRA Section 313 chemical to more
than three streams or water bodies, you should
photocopy Page 2 of Form R as many times as
necessary and then number the boxes consecutively
for each stream or water body. At the bottom of
Page 2 you will find instructions for indicating the
total number of Page 2s that you are submitting as
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part of the Form R as well as indicating the
sequence of those pages. 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 check the NA box in section 5.3 if there
are no discharges to receiving streams or water
bodies of the waste stream that contains or
contained the EPCRA Section 313 chemical (See
discussion of NA vs. a Numeric Value (e.g., Zero)
in the introduction of Section 5).
Enter the total annual amount of the EPCRA Section
313 chemical released from all discharge points at
the facility to each receiving stream or water body.
Include process outfalls such as pipes and open
trenches, releases from on-site wastewater treatment
systems, and the contribution from stormwater
runoff, if applicable (see instructions for column C
below). Do not include discharges to a POTW or
other off-site wastewater treatment facilities in this
section. These off-site transfers must be reported in
Part II, Section 6 of Form R. Wastewater analyses
and flowmeter data may provide the quantities you
will need to complete this section.
Discharges of listed acids (e.g., hydrogen fluoride,
nitric acid) may be reported as zero if the discharges
have been neutralized to pH 6 or above. If
wastewater containing a listed acid is discharged
below pH 6, then releases of the acid must be
reported. In this case, pH measurements may be
used to estimate the amount of mineral acid
released.
5.4.1 Underground Injection On-Site to Class I
Wells
Enter the total amount of the EPCRA Section 313
chemical that was injected into Class I wells at the
facility. Chemical analyses, injection rate meters,
and RCRA Hazardous Waste Generator Reports are
good sources for obtaining data that will be useful in
completing this section. You should check the NA
box in Section 5.4.1 if you do not inject the waste
stream that contains or contained the EPCRA
Section 313 chemical into Class I underground wells
(See discussion of NA vs. a Numeric Value (e.g.,
Zero) in the introduction of Section 5).
5.4.2 Underground Injection On-site to Class II-
V Wells
Enter the total amount of the EPCRA Section 313
chemical that was injected into wells at the facility
other than Class I wells. Chemical analyses and
injection rate meters are good sources for obtaining
data that will be useful in completing this section.
You should check the NA box in Section 5.4.2 if
you do not inject the waste stream that contains or
contained the EPCRA Section 313 chemical into
Class II-V underground wells (See discussion of NA
vs. a Numeric Value (e.g., Zero) in the introduction
of Section 5).
5.5 Disposal to Land On-site
Six 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 NA vs. a Numeric Value (e.g., Zero)
in the introduction of Section 5). For 5.5.4, facilities
generally should report zero, recognizing the
potential for spills or leaks.
5.5.1A RCRA Subtitle C Landfills
Enter the total amount of the EPCRA Section 313
chemical that was placed in RCRA Subtitle C
landfills. EPA has not required facilities to estimate
leaks from landfills because the amount of the
EPCRA Section 313 chemical has already been
reported as a release.
5.5. IB Other Landfills
Enter the total amount of the EPCRA Section 313
chemical that was placed in landfills other than
RCRA Subtitle C landfills. EPA has not required
facilities to estimate leaks from landfills because the
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amount of the EPCRA Section 313 chemical has
already been reported as a release.
5.5.2 Land Treatment/Application Farming
Land treatment is a disposal method in which a
waste containing an EPCRA Section 313 chemical
is applied onto or incorporated into soil. While this
disposal method is considered a release to land, any
volatilization of EPCRA Section 313 chemicals into
the air occurring during the disposal operation must
not be included in this section but must be included
in the total fugitive air releases reported in Part II,
Section 5.1 of Form R.
Surface Impoundments
A surface impoundment is a natural topographic
depression, man-made excavation, or diked area
formed primarily of earthen materials (although
some may be lined with man-made materials), that
is designed to hold an accumulation of liquid wastes
or wastes containing free liquids. Examples of
surface impoundments are holding, settling, storage,
and elevation pits; ponds, and lagoons. If the pit,
pond, or lagoon is intended for storage or holding
without discharge, it would be considered to be a
surface impoundment used as a final disposal
method. A facility must determine, to the best of its
ability, the percentage of a volatile chemical, e.g.,
benzene, that is in waste sent to a surface
impoundment that evaporates during the reporting
year. The facility must report this as a fugitive air
emission in section 5.1. The balance should be
reported in either section 5.5.3A or 5.5.3B.
Quantities of the EPCRA Section 313 chemical
released to surface impoundments that are used
merely as part of a wastewater treatment process
generally should not be reported in this section.
However, if an impoundment accumulates sludges
containing the EPCRA Section 313 chemical, you
must include an estimate in this section unless the
sludges are removed and otherwise disposed of (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 percent of the
benzene evaporates into the air. The 600 pounds
released to the air would be reported as a fugitive air
release (Part II, Section 5.1) and the remaining
1,400 pounds would be reported as a release to land,
other disposal (Part II, Section 5.5.4).
Section 5 Column A: Total Release
Only on-site releases of the EPCRA Section 313
chemical to the environment for the calendar year
are to be reported in this section of Form R. The
total on-site releases from your facility do not
include transfers or shipments of the EPCRA
Section 313 chemical from your facility for sale or
distribution in commerce, or of wastes to other
facilities for disposal, treatment, energy recovery, or
recycling (see Part II, Section 6 of these
Instructions). Both routine releases, such as fugitive
air emissions, and accidental or non-routine
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
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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 pounds, you may round to
zero and enter "0" in column A.
Note that total annual releases of 0.5 pound or less
from the processing or otherwise use of an article
maintain the article status of that item. Thus, if the
only releases you have are from processing an
article, and such releases are equal to or less than
0.5 pound per year, you are not required to submit a
report for that EPCRA Section 313 chemical. The
0.5-pound release determination does not apply to
just a single article. It applies to the cumulative
releases from the processing or otherwise use of the
same type of article (e.g., sheet metal or plastic film)
that occurs over the course of the reporting year.
Releases of 1,000 Pounds or More. For releases to
any medium that amount to 1,000 pounds or more
for the year, you must provide an estimate in pounds
per year in column A. Any estimate provided in
column A need not be reported to more than two
significant figures. This estimate should be in whole
numbers. Do not use decimal points.
Calculating On-Site Releases. To provide the
release information in column A, EPCRA Section
313(g) (2) requires a facility to use readily available
data (including monitoring data) collected pursuant
to other provisions of law, or, where such data are
not readily available, "reasonable estimates" of the
amounts involved. If available data (including
monitoring data) are known to be non-
representative, facilities must make reasonable
estimates using the best readily available
information.
Reasonable estimates of the amounts released
should be made using published emission factors,
material balance calculations, or engineering
calculations. You may not use emission factors or
calculations to estimate releases if more accurate
data are available.
No additional monitoring or measurement of the
quantities or concentrations of any EPCRA Section
313 chemical released into the environment, or of
the frequency of such releases, beyond that required
under other provisions of law or regulation or as part
of routine plant operations, is required for the
purpose of completing Form R.
You must estimate the quantity (in pounds) of the
EPCRA Section 313 chemical or chemical category
that is released annually to each environmental
medium on-site. Include only the quantity of the
EPCRA Section 313 chemical in this estimate. If the
EPCRA Section 313 chemical present at your
facility was part of a mixture or other trade name
product, calculate only the releases of the EPCRA
Section 313 chemical, not the other components of
the mixture or other trade name product. If you are
only able to estimate the releases of the mixture or
other trade name product as a whole, you should
assume that the release of the EPCRA Section 313
chemical is proportional to its concentration in the
mixture or other trade name product. See Part 40,
Section 372.30(b) of the CFR for further
information on how to calculate the concentration
and weight of the EPCRA Section 313 chemical in
the mixture or other trade name product.
If you are reporting an EPCRA Section 313
chemical category listed in Table II of these
instructions rather than a specific EPCRA Section
313 chemical, you must combine the release data for
all chemicals in the EPCRA Section 313 chemical
category (e.g., all listed members of certain glycol
ethers or all listed members of chlorophenols) and
report the aggregate amount for that EPCRA Section
313 chemical in that category separately. For
example, if your facility releases 3,000 pounds per
year of 2-chlorophenol, 4,000 pounds per year of 3-
chlorophenol, and 4,000 pounds per year of 4-
chlorophenol to air as fugitive emissions, you must
report that your facility releases 11,000 pounds per
year of chlorophenols to air as fugitive emissions in
Part II, Section 5.1.
For aqueous ammonia solutions, releases must be
reported based on 10 percent of total aqueous
ammonia. Ammonia evaporating from aqueous
ammonia solutions is considered to be anhydrous
ammonia; therefore, 100 percent of the anhydrous
ammonia should be reported if it is released to the
environment.
For dissociable nitrate compounds, release estimates
should be based on the weight of the nitrate only.
For metal category compounds (e.g., chromium
compounds), report releases of only the parent
metal. For example, a user of various inorganic
chromium salts would report the total chromium
released regardless of the chemical compound and
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exclude any contribution to mass made by the other
portion of the compound.
Section 5 Column B: Basis of Estimate
For each release and otherwise managed waste
estimate (Sections 5 & 6), you are required to
indicate the principal method used to determine the
amount of release and otherwise managed waste
reported. You should enter a letter code identifying
the method that applies to the largest portion of the
total estimated release and otherwise managed waste
quantity.
The codes are as follows:
Ml Estimate is based on continuous monitoring
data or measurements for the EPCRA Section
313 chemical.
M2 Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA Section 313 chemical.
C Estimate is based on mass balance
calculations, such as calculation of the amount
of the EPCRA Section 313 chemical in
streams entering and leaving process
equipment.
El Estimate is based on published emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
E2 Estimate is based on-site specific emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
O Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment
was fully identified through monitoring data.
For example, if 40 percent of stack emissions of the
reported EPCRA Section 313 chemical were derived
using source testing data, 30 percent by mass
balance, and 30 percent by published chemical-
specific emission factors, you should enter the code
letter "M2" for periodic or random emission
monitoring.
If the monitoring data, mass balance, or emission
factor used to estimate the release is not specific to
the EPCRA Section 313 chemical being reported,
the form should identify the estimate based on other
methods of estimation (O).
If a mass balance calculation yields the flow rate of
a waste, but the quantity of reported EPCRA Section
313 chemical in the waste is based on solubility
data, you should report "O" because engineering
calculations were used as the basis of estimate of the
quantity of the EPCRA Section 313 chemical in the
waste.
If the concentration of the EPCRA Section 313
chemical in the waste was measured by continuous
emissions monitoring equipment and the flow rate
of the waste was determined by mass balance, then
the primary basis of the estimate should be
"continuous emission monitoring" (Ml). Even
though a mass balance calculation also contributed
to the estimate, "continuous emission monitoring"
should be indicated because monitoring data were
used to estimate the concentration of the chemical in
waste.
Mass balance (C) should only be indicated if it is
directly used to calculate the mass (weight) of
EPCRA Section 313 chemical released. Monitoring
data should be indicated as the basis of estimate
only if the EPCRA Section 313 chemical
concentration is measured in the waste. Monitoring
data should not be indicated, for example, if the
monitoring data relate to a concentration of the
EPCRA Section 313 chemical in other process
streams within the facility.
It is important to realize that the accuracy and
proficiency of release estimation will improve over
time. However, submitters are not required to use
new emission factors or estimation techniques to
revise previous Form R submissions.
Section 5 Column C: Percent from Stormwater
This column relates only to Section 5.3 - discharges
to receiving streams or water bodies. If your facility
has monitoring data on the amount of the EPCRA
Section 313 chemical in stormwater runoff
(including unchanneled runoff), you must include
that quantity of the EPCRA Section 313 chemical in
your water release in column A and indicate the
percentage of the total quantity (by weight) of the
EPCRA Section 313 chemical contributed by
stormwater in column C (Section 5.3C).
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If your facility has monitoring data on the EPCRA
Section 313 chemical and an estimate of flow rate,
you must use these data to determine the percent
stormwater.
If you have monitored stormwater but did not detect
the EPCRA Section 313 chemical, enter zero in
column C. If your facility has no stormwater
monitoring data for the chemical, you should enter
NA in this space on the form.
If your facility does not have periodic measurements
of stormwater releases of the EPCRA Section 313
chemical, but has submitted chemical-specific
monitoring data in permit applications, then these
data must be used to calculate the percent
contribution from stormwater. One way to calculate
the flow rates from stormwater runoff is the
Rational Method. In this method, flow rates, Q, can
be estimated by multiplying the land area of the
facility, A, by the runoff coefficient, C, and then
multiplying that figure by the annual rainfall
intensity, I (i.e., Q = A * C x 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 Runoff Coefficient Description of Land Area Runoff Coefficient
Business
Downtown areas 0.70-0.95
Neighborhood areas 0.50-0.70
Industrial
Light areas 0.50-0.80
Heavy areas 0.60-0.90
Industrial
Railroad yard areas 0.20-0.40
Unimproved areas 0.10-0.30
Streets
Asphaltic 0.70-0.95
Concrete 0.80-0.95
Brick 0.70-0.85
Drives and walks 0.70-0.85
Roofs 0.75-0.95
Lawns: Sandy Soil
Flat, 2 percent 0.05-0.10
Average, 2-7 percent 0.10-0.15
Steep, 7 percent 0.15-0.20
Lawns: Heavy Soil
Flat, 2 percent 0.13-0.17
Average, 2-7 percent 0.18-0.22
Steep, 7 percent 0.25-0.35
You should choose the most appropriate runoff coefficient for your site or calculate a weighted-average
coefficient, which takes into account different types of land use at your facility:
Weighted-average runoff coefficient =
(Area 1 % of total)(Cl) + (Area 2 % of total)(C2) + (Area 3 % of total)(C3) + ... + (Area i % of total)(Ci)
where
Ci = runoff coefficient for a specific land use of Area i.
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Example 13: Stormwater Runoff
Your facility is located in a semi-arid region of the United States that has an annual precipitation
(including snowfall) of 12 inches of rain. (Snowfall should be converted to the equivalent inches of rain;
assume one foot of snow is equivalent to one inch of rain.) The total area covered by your facility is 42
acres (about 170,000 square meters or 1,829,520 square feet). The area of your facility is 50 percent
unimproved area, 10 percent asphaltic streets, and 40 percent concrete pavement.
The total Stormwater runoff from your facility is therefore calculated as follows:
Runoff
Coefficient
0.20
0.85
0.90
Land Use % Total Area
Unimproved area 50
Asphaltic streets 10
Concrete pavement 40
Weighted-average runoff coefficient =[(50%) x (0.20)] + [(10%) x (0.85)] x [(40%) x (0.90)] = 0.545
(Rainfall) x (land area) x (conversion factor) x (runoff coefficient) = Stormwater runoff
(1 ft/year) x (1,829,520 ft2) x (7.48 gal/ft3) x (0.545) = 7,458,222 gallons/year
Total Stormwater runoff = 7,458,222 gallons/year
Your Stormwater monitoring data shows that the average concentration of zinc in the Stormwater runoff
from your facility from a biocide containing a zinc compound is 1.4 milligrams per liter. The total amount
of zinc discharged to surface water through the plant wastewater discharge (non-stormwater) is 250
pounds per year. The total amount of zinc discharged with Stormwater is:
(7,458,222 gallons Stormwater) x (3.785 liters/gallon) = 28,229,370 liters Stormwater
(28,229,370 liters Stormwater) x (1.4 mg zinc/liter) x 1Q3 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) x 100% = 26%
Section 6. Transfer(s) of the Toxic
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.
Dioxin and dioxin-like compounds category.
Facilities should report at a level of precision
supported by the accuracy of the underlying data
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Instructions for Completing Part II of EPA Form R
and the estimation techniques on which the estimate
is based. 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. The smallest quantity that needs to be
reported on the Form R for the dioxin and dioxin-
like compounds category is 0.0001 grams (see
Example 12).
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 check the "NA"
box for the POTW's name in Section 6.1._ If you do
not ship or transfer wastes containing the reported
EPCRA Section 313 chemical to other off-site
locations, you should check the "NA" box in
Section 6.2._
Important: Number the boxes for reporting the
information for each sequential 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.[ ]._.or 6.2.[ ]. This section is required
only for paper filers; TRI-MEweb does this task
automatically for the reporting facility.
If you report a transfer of the listed EPCRA Section
313 chemical to one or more off-site locations,
POTWs, you should number the boxes in Section
6.1 as 6.1.1, 6.1.2, etc. If you transfer the EPCRA
Section 313 chemical to more than one POTW, you
should photocopy Page 3 of Form R as many times
as necessary and then number the boxes
consecutively for each POTW (e.g., 6.1.2, 6.1.3,
etc.). At the bottom of each page 3 that is submitted,
indicate the total number of pages numbered "3"
that you are submitting as part of Form R, as well as
indicating the sequence of those pages. For
example, your facility transfers the reported EPCRA
Section 313 chemical in wastewaters to two
POTWs. You would photocopy Page 3 once,
indicate at the bottom of each Page 3 that there are a
total of two pages numbered "3" and then indicate
the first and second Page 3. The box for the first
POTW on the first Page 3 should be numbered 6.1.1
and while the box for second POTW on the second
Page 3 should be numbered 6.1.2.
If you report a transfer of the EPCRA Section 313
chemical to one or more other off-site locations, you
should number the boxes in section 6.2 as 6.2.1,
6.2.2, etc. If you transfer the EPCRA Section 313
chemical to more than two other off-site locations,
you should photocopy Page 4 of Form R as many
times as necessary and then number the boxes
consecutively for each off-site location. At the
bottom of Page 4 you will find instructions for
indicating the total number of Page 4s that you are
submitting as part of the Form R as well as
indicating the sequence of those pages. For
example, your facility transfers the reported EPCRA
Section 313 chemical to three other off-site
locations. You should photocopy page 4 once,
indicate at the bottom of Section 6.2 on each Page 4
that there are a total of two Page 4s and then
indicate the first and second Page 4. The boxes for
the two off-site locations on the first Page 4 would
be numbered 6.2.1 and 6.2.2, while the box for the
third off-site location on the second Page 4 should
be numbered 6.2.3. Please note that section 6.2
starts on Page 3 and continues on Page 4.
6.1 Discharges to Publicly Owned Treatment
Works
In Section 6.1.[ ], 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. In Section 6.l.[ ]A or Section 6.1.[ ]B (for
columns A and B, respectively, estimate the
quantity of the reported EPCRA Section 313
chemical transferred to each POTW and the basis
upon which the estimate was made, respectively.
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If you do not discharge wastewater containing the
reported EPCRA Section 313 chemical to a POTW,
enter NA in the box in Section 6.1.. (See discussion
of NA vs. a Numeric Value (e.g., Zero) in the
introduction of Section 6).
6. l.[ ]A. Quantity Transferred to Each POTW
Enter the total amount, in pounds, of the reported
EPCRA Section 313 chemical that is contained in
the wastewaters transferred to each POTW. 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.
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. l.f ]B 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 each
POTW. You should enter one of the following letter
codes that applies to the method by which the
largest percentage of the estimate was derived.
Ml Estimate is based on continuous monitoring
data or measurements for the EPCRA Section
313 chemical.
M2 Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA Section 313 chemical.
C Estimate is based on mass balance
calculations, such as calculation of the amount
of the EPCRA Section 313 chemical in
streams entering and leaving process
equipment.
El Estimate is based on published emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
E2 Estimate is based on-site specific emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
O Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment
was fully identified through monitoring data.
If you transfer an EPCRA Section 313 chemical to
more than one POTW, you should report the basis
of estimate that was used to determine the largest
percentage of the EPCRA Section 313 chemical that
was transferred.
6.2 Transfers to Other Off-Site Locations
In Section 6.2 enter the EPA Identification Number
(defined in 40 CFR 260.10 and therefore commonly
referred to as the RCRA ID 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. The RCRA ID 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 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
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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 check the NA box in Section
6.2, "Transfers to Other Off-Site Locations."
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 Federal
Information Processing Standards (FIPS) in the
country field. The most commonly used FIPS
country codes are listed in Table IV. To obtain a
FIPS code for a country not listed, contact the TRI
Information Center. There is nothing to enter in the
state field.
6.2a Column A: Total Transfers
For each off-site location, enter the total amount, in
pounds (in grams for dioxin and dioxin-like
compounds), of the EPCRA Section 313 chemical
that is contained in the waste transferred to that
location. Do not enter the total quantities of the
waste. If you do not ship or transfer wastes
containing the EPCRA Section 313 chemical to
other off-site locations, you should enter NA (See
discussion of NA vs. a Numeric Value (e.g., Zero)
in the introduction of Section 6) in the box for the
off-site location's EPA Identification Number
(defined in 40 CFR 260.10 and therefore commonly
referred to as the RCRA ID Number).
If the total amount transferred is less than 1,000
pounds, you may report a range by entering the
appropriate range code (range reporting in section
6.2 does not apply to PBT chemicals). The
following reporting range codes are to be used:
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999
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Summary of Residue Quantities From Pilot-Scale Experimental Studya'b
(weight percent of drum capacity)
Unloading
Method
Pumping
Pumping
Pouring
Pouring
Gravity
Drain
Gravity
Drain
Gravity
Drain
Vessel Type
Steel drum
Plastic drum
Bung-top steel
drum
Open-top steel
drum
Slope-bottom
steel tank
Dish-bottom
steel tank
Dish-bottom
glass-lined
tank
Value
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Material
Kerosene0
1.93-3.08
2.48
1.69-4.08
2.61
0.244
0.472
0.404
0.032
0.080
0.054
0.020
0.039
0.033
0.031
0.042
0.038
0.024
0.049
0.040
Water"
1.84-2.61
2.29
2.54-4.67
3.28
0.266
0.458
0.403
0.026
0.039
0.034
0.016
0.024
0.019
0.033
0.034
0.034
0.020
0.040
0.033
Motor Oile
1.97-2.23
2.06
1.70-3.48
2.30
0.677
0.787
0.737
0.328
0.368
0.350
0.100
0.121
0.111
0.133
0.191
0.161
0.112
0.134
0.127
Surfactant
Solution'
3.06
3.06
Not
Available
0.485
0.485
0.089
0.089
0.048
0.048
0.058
0.058
0.040
0.040
aFrom "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.
b The 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.
°For kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
dFor water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
eFor motor oil, viscosity = 94 centipoise, surface tension = 34.5 dynes/cm
fFor surfactant solution, viscosity = 3 centipoise, surface tension = 31.4 dynes/cm2
Example 14: Container Residue
You have determined that a Form R for an EPCRA Section 313 chemical must be submitted. The facility
purchases and uses one thousand 55-gallon steel drums that contain a 10 percent solution of the chemical.
Further, it is assumed that the physical properties of the solution are similar to water. The solution is
pumped from the drums directly into a mixing vessel and the "empty" drums are triple-rinsed with water.
The rinse water is indirectly discharged to a POTW and the cleaned drums are sent to a drum reclaimer.
In this example, it can be assumed that all of the residual solution in the drums was transferred to the rinse
water. Therefore, the quantity transferred to the drum reclaimer should be reported as "zero." The annual
quantity of residual solution that is transferred to the rinse water can be estimated by multiplying the
mean weight percent of residual solution remaining in water from pumping a steel drum (2.29 percent
from the preceding table, "Summary of Residue Quantities From Pilot-Scale Experimental Study") by the
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total annual weight of solution in the drum (density of solution multiplied by drum volume). If the density
is not known, it may be appropriate to use the density of water (8.34 pounds per gallon):
(2.29%) x (8.34 pounds/gallon) x (55 gallons/drum) x (1,000 drums) = 10,504 pounds solution
The concentration of the EPCRA Section 313 chemical in the solution is only 10%.
(10,504 pounds solution) x (10%) = 1,050 pounds
Therefore, 1,050 pounds of the chemical are transferred to the POTW.
Example 15: Reporting Metals and Metal
Category Compounds that are sent Off-site
A facility manufactures a product containing
elemental copper, exceeding the processing
threshold for copper. Various metal fabrication
operations for the process produce a wastewater
stream that contains some residual copper and
off-specification copper material. The
wastewater is collected and sent directly to a
POTW. Periodic monitoring data show that 500
pounds of copper were transferred to the POTW
in the reporting year. The POTW eventually
releases these chemicals to a stream. The off-
specification products (containing copper) are
collected and sent off-site to a RCRA Subtitle C
landfill. Sampling analyses of the product
combined with hazardous waste manifests were
used to determine that 1,200 pounds of copper in
the off-spec product were sent to the off-site
landfill.
Therefore, the facility must report 500 pounds in
Sections 6.1 and 8.Id, and 1200 pounds in
Sections 6.2 (waste code M65 (RCRA Subtitle C
Landfill) should be used) and 8. Id.
Note that for EPCRA Section 313 chemicals that
are not metals or metal category compounds, the
quantity sent for treatment at POTWs and to
other off-site treatment locations must be
reported in Section 8.7 - Quantity Treated Off-
site. However, if you know that some or all of
the chemical is not treated for destruction at the
off-site location you must report that quantity in
Section 8.1.
If you transfer the EPCRA Section 313 chemical in
wastes to an off-site facility for distinct and multiple
purposes, you must report those activities for each
off-site location, along with the quantity of the
reported EPCRA Section 313 chemical associated
with each activity. For example, your facility
transfers a total of 15,000 pounds of toluene to an
off-site location that will use 5,000 pounds for the
purposes of energy recovery, will enter 7,500
pounds into a recovery process, and will dispose of
the remaining 2,500 pounds. These quantities and
the associated activity codes must be reported
separately in Section 6.2. (See Figure 5 for a
hypothetical Section 6.2 completed for two off-site
locations, one of which receives the transfer of
15,000 pounds of toluene as detailed.) If you have
fewer than four total transfers in Section 6.2
Column A (see examples in Figure 5), 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
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applies to the method by which the largest
percentage of the estimate was derived.
Ml Estimate is based on continuous monitoring
data or measurements for the EPCRA Section
313 chemical.
M2 Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA Section 313 chemical.
C Estimate is based on mass balance
calculations, such as calculation of the
amount of the EPCRA Section 313 chemical
in streams entering and leaving process
equipment.
El Estimate is based on published emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
E2 Estimate is based on site specific emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
O Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying an estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment
was fully identified through monitoring data.
6.2c Column C: Type of Waste Management:
Disposal/ Treatment/Energy
Recovery/Recycling
You should enter one of the following M codes to
identify the type of disposal, treatment, energy
recovery, or recycling methods used by the off-site
location for the reported EPCRA Section 313
chemical. You must use more than one line and
code for a single location when distinct quantities of
the reported EPCRA Section 313 chemical are
subject to different waste management activities,
including disposal, treatment, energy recovery, or
recycling. You must use the code that represents the
ultimate disposition of the chemical.
If the EPCRA Section 313 chemical is sent off-site
for further direct reuse (e.g., an EPCRA Section 313
chemical in used solvent that will be used as
lubricant at another facility) and does not undergo a
waste management activity (i.e., release (including
disposal), treatment, energy recovery, or recycling
(recovery)) prior to that reuse, it need not be
reported in section 6.2 or section 8.
Incineration vs. Energy Recovery
You must distinguish between incineration which is
waste treatment, and legitimate energy recovery. For
you to claim that a reported EPCRA Section 313
chemical sent off-site is used for the purposes of
energy recovery and not for treatment for
destruction, the EPCRA Section 313 chemical must
have a significant heating value and must be
combusted in an energy recovery unit such as an
industrial boiler, furnace, or kiln. In a situation
where the reported EPCRA Section 313 chemical is
in a waste that is combusted in an energy recovery
unit, but the EPCRA Section 313 chemical does not
have a significant heating value, e.g., CFCs, you
should use code M54, Incineration/Insignificant
Fuel Value, to indicate that the EPCRA Section 313
chemical was incinerated in an energy recovery unit
but did not contribute to the heating value of the
waste.
Metals and Metal Category Compounds
Metals and metal category compounds will be
managed in waste either by being released
(including disposed of) or by being recycled.
Remember that the release and other waste
management information that you report for metal
category compounds will be the total amount of the
parent metal released or recycled and NOT the
whole metal category compound. The metal has no
heat value and thus cannot be combusted for energy
recovery and cannot be treated because it cannot be
destroyed. Thus, transfers of metals and metal
category compounds for further waste management
should be reported as either a transfer for recycling
or a transfer for disposal. The applicable waste
management codes for transfers of metals and metal
category compounds for recycling are M24, metals
recovery, M93, waste broker - recycling, or M26,
other reuse/recovery. Applicable codes for transfers
for disposal include M10, M41, M62, M64, M65,
M66, M67, M73, M79, M81, M82, M90, M94, and
M99. These codes are for off-site transfers for
further waste management in which the waste
stream may be treated but the metal contained in the
waste stream is not treated and is ultimately
released. For example, M41 should be used for a
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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
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
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SECTION 6.TRANSFER(S) OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
n
6.T.
POTW Name
POTW Address
City
County!
I StateT
JzFJ
A. Quantity Transferred to this POTW
(pounds/year*) (Enter range code**or estimate)
B, Basis of Estimate
(Enter code)
o
tf additional pages of Part II, Section 6.1 are attached, indicate the total number of pages in this box
and indicate the Part II, Section 6.1 page number In this box.! I (Example: 1,2, 3, etc.)
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
NA
6.2, Off-Site EPA Identification Number (RCRA10 No.)
COD56616246
Acme Waste Services
Off-Site Address: [ 5 Market Street
city Anywhere
| County ] Hill
|State|CO [ZIP [80461 [ Country jnon-US) I
Is this location ynder control of reporting facility or parent company?
Yes
r/1 No
This off-site location receives a transfer of 15,000 pounds of toluene and will combust 5,000 pounds for the
purposes of energy recovery, will enter 7,500 pounds into a recovery process, and will dispose of the
remaining 2,500 pounds.
SECTION 6.2. TRANSFERS TO OTHER OFF-SITE LOCATION (CONTINUED)
A. Total Transfer (pounds/year*)
(Enter a range code** or estimate)
i. 5,000
2. 7,500
3. 2,500
4. NA
B. Basts of Estimate
(Enter code)
i. O
2. C
3. O
4.
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (Enter code)
I.M 56
2.M 20
3.M 60
4. M
6.2.. Off-Site EPA Identification Number (RCfiA ID No.) COD 1 6772543
Off-Site Location Name: | Combustion, Inc.
Off-Site Address: |25 Facility Road
city Dumfry
County [Bums |state|CO [ZIP J80500 | Country (non-US) |
Is this location under control of reporting facility or parent company? Yes | | No | / |
A. Total Transfer (pounds/year*)
(Enter a range code** or estimate)
i. 12,500
2. NA
3.
4.
B. Basis of Estimate
(Enter code)
i. O
2.
3.
4.
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (Enter code)
I.M 54
2. M
3. M
4. M
This off-site location receives a transfer of 12,500 pounds of tetrachloroethylene (perchloroethylene) that is
part of a waste that is combusted for the purposes of energy recovery in an industrial furnace. Note that the
tetrachloroethylene should be reported using code M54 to indicate that it is combusted in an energy recovery
unit but it does not contribute to the heating value of the waste.
Figure 5. Hypothetical Section 6.2 Completed for Two Off-Site Locations
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Section 7. On-Site Waste Treatment,
Energy Recovery, and
Recycling Methods
You must report in this section the methods of waste
treatment, energy recovery, and recycling applied to
the reported EPCRA Section 313 chemical in wastes
on-site. There are three separate sections for
reporting such activities. Section 7A column c and
Section 7A column e were deleted from Form R in
2005. Section 7A column d remained on the form
until 2010. In 2011, column d was renamed column
c which is addressed below.
Section 7A: On-Site Waste Treatment
Methods and Efficiency
Most of the chemical-specific information required
by EPCRA Section 313 that is reported on Form R
is specific to the EPCRA Section 313 chemical
rather than the waste stream containing the EPCRA
Section 313 chemical. However, EPCRA Section
313 does require that waste treatment methods
applied on-site to waste streams that contain the
EPCRA Section 313 chemical be reported. This
information is reportable regardless of whether the
facility actively applies treatment or the treatment of
the waste stream occurs passively. This information
is collected in Section 7A of Form R.
In Section 7A, you must provide the following
information if you treat waste streams containing
the reported EPCRA Section 313 chemical on-site:
(a) The general waste stream types containing the
EPCRA Section 313 chemical being reported;
(b) The waste treatment method(s) or sequence
used on all waste streams containing the
EPCRA Section 313 chemical; and
(c) The efficiency of each waste treatment
method or waste treatment sequence in
destroying or removing the EPCRA Section
313 chemical.
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
percent, report it as a wastewater (W). Slurries and
sludges containing water should be reported as solid
waste if they contain appreciable amounts of
dissolved solids, or solids that may settle, such that
the viscosity or density of the waste is considerably
different from that of process wastewater.
7A Column b: Waste Treatment Method(s)
Sequence
Enter the appropriate waste treatment code from the
list below for each on-site waste treatment method
used on a waste stream containing the EPCRA
Section 313 chemical, regardless of whether the
waste treatment method actually removes the
specific EPCRA Section 313 chemical being
reported. Waste treatment methods must be reported
for each type of waste stream being treated (i.e.,
gaseous waste streams, aqueous waste streams,
liquid non-aqueous waste streams, and solids).
Except for the air emission treatment codes, the
waste treatment codes are not restricted to any
medium.
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
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sequence, you may combine the reporting for such
equipment. It is not necessary to enter four codes to
cover four scrubber units, for example, if all four are
treating waste streams of similar character (e.g.,
sulfuric acid mist emissions), have similar influent
concentrations, and have similar removal
efficiencies. If, however, any of these parameters
differs from one unit to the next, each scrubber
should be listed separately.
If you are using the hardcopy paper form, and if
your facility performs more than eight sequential
waste treatment methods on a single general waste
stream, continue listing the methods in the next row
and renumber appropriately those waste treatment
method code boxes you used to continue the
sequence. For example, if the general waste stream
in box 7A.la had nine treatment methods applied to
it, the ninth method would be indicated in the first
method box for row 7A.2a. The numeral "1" would
be crossed out, and a "9" would be inserted.
Treatment applied to any other general waste stream
types would then be listed in the next empty row. In
the scenario below, for instance, the second general
waste stream would be reported in row 7A.3a. See
Figure 6 for an example of a hypothetical section
7A.
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Example 16: Calculating Releases and Other Waste Management Quantities
Your facility disposes of 14,000 pounds of lead chromate (PbCrCH.PbO) in an on-site landfill and
transfers 16,000 pounds of lead selenite (PbSeO4) to an off-site land disposal facility. You would
therefore be submitting three separate reports on the following: lead compounds, selenium compounds,
and chromium compounds. However, the quantities you would be reporting would be the pounds of
"parent" metal being released on-site or transferred off-site for further waste management. All quantities
are based on mass balance calculations (See Section 5, Column B for information on Basis of Estimate
and Section 6.2, Column C for waste management codes and information on transfers of EPCRA Section
313 chemicals in wastes). You would calculate releases of lead, chromium, and selenium by first
determining the percentage by weight of these metals in the materials you use as follows:
Lead Chromate (PbCrO4.PbO) Molecular weight = 546.37
Lead (2 Pb atoms) Atomic weight = 207.2 x 2 = 414.4
Chromium (1 Cr atom) Atomic weight = 51.996
Lead chromate is therefore (percent by weight):
(414.4/546.37) = 75.85% lead and
(51.996/546.37) = 9.52% chromium.
Lead Selenite (PbSeO4) Molecular weight = 350.17
Lead (1 Pb atom) Atomic weight = 207.2
Selenium (1 Se atom) Atomic weight = 78.96
Lead selenite is therefore (percent by weight):
(207.2/350.17) = 59.17% lead and
(78.96/350.17) = 22.55% selenium.
The total pounds of lead, chromium, and selenium disposed of on or off-site from your facility are as
follows:
Lead
Disposal on-site: 0.7585 x 14,000 = 10,619 pounds from lead chromate
Transfer off-site for disposal: 0.5917 x 16,000 = 9,467 pounds from lead selenite
Chromium
Disposal on-site: 0.0952 x 14,000 = 1,333 pounds from lead chromate
Selenium
Transfer off-site for disposal: 0.2255 x 16,000 = 3,608 pounds from lead selenite
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SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
^\ Not Applicable (NA) - Check here if no on-site waste treatment method is applied to any waste stream containing the toxic chemical or chemical category.
a. General Waste Stream
(Enter cede)
7A,la
W
7A.2a
7A.3a
A
b. Waste Treatment Method(s) Sequence
(Enter 3- or 4-character code(s))
TA.Ib
3
6
H101
H082
7A.2b
3
6
7A.3b
3
6
1
4
/
1
4
7
1
4
7
Hi 23
H129
H081
H077
A01
2
5
8
2
S
8
2
5
8
H124
H083
H075
NA
NA
c. Waste Treatment Efficiency
(Enter 2 character code)
7 A. 1C
7A.2C
E4
7A.3C
E5
Figure 6. Hypothetical Section 7A
Waste Treatment Codes
A01 Flare
A02 Condenser
A03 Scrubber
A04 Absorber
A05 Electrostatic Precipitator
A06 Mechanical Separation
A07 Other Air Emission Treatment
H040 Incineration—thermal destruction other than
use as a fuel
H071 Chemical reduction with or without
precipitation
H073 Cyanide destruction with or without
precipitation
H075 Chemical oxidation
H076 Wet air oxidation
H077 Other chemical precipitation with or without
pre-treatment
HO 81 Biological treatment with or without
precipitation
H082 Adsorption
HO 8 3 Air or steam stripping
H101 Sludge treatment and/or dewatering
HI03 Absorption
Hill Stabilization or chemical fixation prior to
disposal
HI 12 Macro-encapsulation prior to disposal
H121 Neutralization
HI22 Evaporation
HI23 Settling or clarification
HI24 Phase separation
HI29 Other treatment
7A Column c: Waste Treatment Efficiency
Estimate
In the space provided, enter the range code, based
upon the codes listed below, indicating the
percentage of the EPCRA Section 313 chemical
removed from the waste stream through destruction,
biological degradation, chemical conversion, or
physical removal. The waste treatment efficiency
(expressed as a range of percent removal) represents
the percentage of the EPCRA Section 313 chemical
destroyed or removed (based on amount or mass),
not merely changes in volume or concentration of
the EPCRA Section 313 chemical in the waste
stream. The efficiency, which can reflect the overall
removal from sequential treatment methods applied
to the general waste stream, refers only to the
percent destruction, degradation, conversion, or
removal of the EPCRA Section 313 chemical from
the waste stream; it does not refer to the percent
conversion or removal of other constituents in the
waste stream. The efficiency also does not refer to
the general efficiency of the treatment method for
any waste stream. For some waste treatment
methods, the percent removal will represent removal
by several mechanisms, as in an aeration basin,
where an EPCRA Section 313 chemical may
evaporate, biodegrade, or be physically removed
from the sludge.
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Percent removal can be calculated as follows:
where:
I = amount of the EPCRA Section 313 chemical in
the influent waste stream (entering the waste
treatment step or sequence) and
E = amount of the EPCRA Section 313 chemical in
the effluent waste stream (exiting the waste
treatment step or sequence).
Calculate the amount of the EPCRA Section 313
chemical in the influent waste stream by multiplying
the concentration (by weight) of the EPCRA Section
313 chemical in the waste stream by the total
amount or weight of the waste stream. In most
cases, the percent removal compares the treated
effluent to the influent for the particular type of
waste stream. For solidification of wastewater, the
waste treatment efficiency can be reported as code
El (greater than 99.9999 percent) if no volatile
EPCRA Section 313 chemicals were removed with
the water or evaporated into the air. Percent removal
does not apply to incineration because the waste
stream, such as wastewater or liquids, may not exist
in a comparable form after waste treatment and the
purpose of incineration as a waste treatment is to
destroy the EPCRA Section 313 chemical by
converting it to carbon dioxide and water or other
byproducts. In cases where the EPCRA Section 313
chemical is incinerated, the percent efficiency must
be based on the amount of the EPCRA Section 313
chemical destroyed or combusted, except for metals
or metal category compounds. In the cases in which
a metal or metal category compound is incinerated,
the efficiency is reported as code E6 (equal to or
greater than 0 percent, but less than or equal to 50
percent).
Similarly, an efficiency of zero must be reported for
any waste treatment method(s) that does not destroy,
chemically convert or physically remove the
EPCRA Section 313 chemical from the waste
stream.
For metal category compounds, the calculation of
the reportable concentration and waste treatment
efficiency must be based on the weight of the parent
metal, not on the weight of the metal compound.
Metals are not destroyed, only physically removed
or chemically converted from one form into another.
The waste treatment efficiency reported must
represent only physical removal of the parent metal
from the waste stream (except for incineration), not
the percent chemical conversion of the metal
compound. If a listed waste treatment method
converts but does not remove a metal (e.g.,
chromium reduction), the method must be reported
with a waste treatment efficiency of code E6 (equal
to or greater than 0 percent, but less than or equal to
50 percent.
EPCRA Section 313 chemicals that are strong
mineral acids neutralized to a pH of 6 or above are
considered treated at 100 percent efficiency.
When calculating waste treatment efficiency,
EPCRA Section 313(g)(2) requires a facility to use
readily available data (including monitoring data)
collected pursuant to other provisions of law, or,
where such data are not readily available,
"reasonable estimates" of the amounts involved.
Waste Treatment Efficiency Range Codes:
E1 = greater than 99.9999%
E2 = greater than 99.99%, but less than or equal
to 99.9999%
E3 = greater than 99%, but less than or equal to
99.99%
E4 = greater than 95%, but less than or equal to
99%
E5 = greater than 50%, but less than or equal to
95%
E6 = equal to or greater than 0%, but less than or
equal to 50%
Section 7B On-site Energy Recovery Processes
In Section 7B, you must indicate the on-site energy
recovery methods used on the reported EPCRA
Section 313 chemical.
EPA considers an EPCRA Section 313 chemical to
be combusted for energy recovery if the toxic
chemical has a significant heat value and is
combusted in an energy recovery device. If a
reported EPCRA Section 313 chemical is
incinerated on-site but does not contribute energy to
the process (e.g., chlorofluorocarbons), it must be
considered waste treated on-site and reported in
Section 7A. Metals and metal category compounds
cannot be combusted for energy recovery and
should NOT be reported in this section. Do not
include the combustion of fuel oils, such as fuel oil
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#6, in this section. Energy recovery may take place
only in an industrial kiln, furnace, or boiler.
NA vs. a Numerical Value (e.g., Zero). If you do
not perform on-site energy recovery for a waste
stream that contains or contained the EPCRA
Section 313 chemical, check the NA box at the top
of Section 7B and enter NA in Section 8.2. If you
perform on-site energy recovery for the waste
stream that contains or contained the EPCRA
Section 313 chemical, enter the appropriate code in
Section 7B and enter the appropriate value in
Section 8.2. If this quantity is less than or equal to
0.5 pound, round to zero (unless the chemical is a
listed PBT chemical) and enter zero in 8.2. (Note:
for metals and metal compounds, you should only
report NA in Sections 7B and Section 8.2.)
Energy Recovery Codes
U01 Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
If your facility uses more than one on-site energy
recovery method for the reported EPCRA Section
313 chemical, list the methods used in descending
order (greatest to least) based on the amount of the
EPCRA Section 313 chemical entering such
methods.
Section 7C On-site Recycling Processes
In Section 7C, you must report the recycling
methods used on the EPCRA Section 313 chemical.
In this section, use the codes below to report only
the recycling methods in place at your facility that
are applied to the EPCRA Section 313 chemical. Do
not list any off-site recycling activities. (Information
about off-site recycling must be reported in Part II,
Section 6, "Transfers of the Toxic Chemical in
Wastes to Off-site Locations.")
NA vs. a Numerical Value (e.g., Zero). If you do
not perform on-site recycling for the reported
EPCRA Section 313 chemical, check the NA box at
the top of Section 7C and enter NA in Section 8.4. If
you perform on-site recycling for the reported
EPCRA Section 313 chemical, enter the appropriate
code in Section 7C and enter the appropriate value
in Section 8.4. If this quantity is less than or equal to
0.5 pound, round to zero (unless the chemical is a
listed PBT chemical) and enter 0 in Section 8.4.
On-Site Recycling Codes
H10 Metal recovery (by retorting, smelting, or
chemical or physical extraction
H20 Solvent recovery (including distillation,
evaporation, fractionation or extraction)
H39 Other recovery or reclamation for reuse
(including acid regeneration or other chemical
reaction process)
If your facility uses more than one on-site recycling
method for an EPCRA Section 313 chemical, enter
the codes in the space provided in descending order
(greatest to least) based on the volume of the
reported EPCRA Section 313 chemical recovered by
each process. If your facility uses more than ten
separate methods for recycling the reported EPCRA
Section 313 chemical on-site, then list the ten
activities that recover the greatest amount of the
EPCRA Section 313 chemical (again, in descending
order).
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Example 17: On-Site Waste Treatment
A process at the facility generates a wastewater stream containing an EPCRA Section 313 chemical (chemical A). A
second process generates a wastewater stream containing two EPCRA Section 313 chemicals, a metal (chemical B)
and a mineral acid (chemical C). Thresholds for all three chemicals have been exceeded and you are in the process of
completing separate Form Rs for each chemical.
These two wastewater streams are combined and sent to an on-site wastewater treatment system before being
discharged to a POTW. This system consists of an oil/water separator that removes 99 percent of chemical A; a
neutralization tank in which the pH is adjusted to 7.5, thereby destroying 100 percent of the mineral acid (chemical
C); and a settling tank where 95 percent of the metal (chemical B) is removed from the water (and eventually
landfilled off-site).
Section 7A should be completed slightly differently when you file the Form R for each of the chemicals. The table
accompanying this example shows how Section 7A should be completed for each chemical. First, on each Form R
you should identify the type of waste stream in Section 7A.la as wastewater (aqueous waste, code W). Next, on each
Form R you should list the code for each of the treatment steps that is applied to the entire waste stream, regardless
of whether the operation affects the chemical for which you are completing the Form R (for instance, the first four
blocks of Section 7A.lb of all three Form Rs should show: H124 (phase separation), H121 (neutralization), H123
(settling or clarification), and N/A (to signify the end of the treatment system). Note that Section 7A.lb is not
chemical specific. It applies to the entire waste stream being treated. Section 7A.lc applies to the efficiency of the
entire system in destroying and/or removing the chemical for which you are preparing the Form R. You should enter
E4 when filing for chemical A, E5 for chemical B, and El for chemical C.
Chemical A
7A.la
W
7A.lb
3.H123
6.
1. H124
4. N/A
7.
2. H121
5.
8.
7A.lc
E4
Chemical B
7A.la
W
7A.lb
3.H123
6.
1. H124
4. N/A
7.
2. H121
5.
8.
7A.lc
E5
Chemical C
7A.la
W
7A.lb
3.H123
6.
1. H124
4. N/A
7.
2. H121
5.
8.
7A.lc
El
Note that the quantity removed and/or destroyed is not reported in Section 7 and that the efficiency reported in
Section 7A.lc 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 8.1c. However, when completing the Form R for
chemical C, you should report the entire quantity in Section 8.6 because raising the pH to 7.5 will completely destroy
the mineral acid.
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Example 18: Reporting On-Site Energy Recovery
One waste stream generated by your facility contains, among other chemicals, toluene and Freon 113.
Threshold quantities are exceeded for both of these EPCRA Section 313 chemicals, and you would,
therefore, submit two separate Form R reports. This waste stream is sent to an on-site industrial furnace
that uses the heat generated in a thermal hydrocarbon cracking process at your facility. Because toluene
has a significant heat value (17,440 BTU/pound) and the energy is recovered in an industrial furnace, the
code "U02" would be reported in Section 7B for the Form R submitted for toluene.
However, as Freon 113 does not contribute any value for energy recovery purposes, the combustion of
Freon 113 in the industrial furnace is considered waste treatment, not energy recovery. You would report
Freon 113 as entering a waste treatment step (i.e., incineration), in Section 7A, column b. In Section 7B
the facility should report zero.
Section 8. Disposal or Other Releases,
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, (or, for the dioxin and dioxin-
like compounds category, grams) of the reported
EPCRA Section 313 chemical itself. 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
submit additional optional information on source
reduction, recycling, or pollution control activities
implemented for the reported EPCRA Section 313
chemical 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 (or, for the
dioxin and dioxin-like compounds category, grams).
For non-PBT chemicals, 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 (except the dioxin and dioxin-like
compounds category), facilities should report
release and other waste management quantities
greater than 0.1 pound provided the accuracy and
the underlying data on which the estimate is based
supports this level of precision.
For the dioxin and dioxin-like compounds category,
facilities should report at a level of precision
supported by the accuracy of the underlying data
and the estimation techniques on which the estimate
is based. However, the smallest quantity that need
be reported on the Form R for the dioxin and dioxin-
like compounds category is 0.0001 grams (see
Example 12). Notwithstanding the numeric
precision used when determining reporting
eligibility thresholds, facilities should report on
Form R to the level of accuracy that their data
supports, up to seven digits to the right of the
decimal. EPA's reporting software and data
management systems support data precision to
seven digits to the right of the decimal.
NA vs. a Numeric Value (e.g., Zero). You should
enter a numeric value in the relevant sections of
Section 8 if your facility has released, treated,
combusted for energy recovery or recycled any
quantity of an EPCRA Section 313 chemical during
the reporting year. If the aggregate quantity of that
toxic chemical was equal to or less than 0.5 pound
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for a particular waste management method, you
should enter the value zero (unless the chemical is a
PBT chemical) in the relevant section. In the case
of PBTs (excluding dioxin) if the aggregate quantity
of the toxic chemical is equal to or less than 0.1
pound for a particular waste management method,
you should enter the value zero in the relevant
section. For dioxin, if the aggregate quantity is
equal to or less than .0001 grams for a particular
waste management method, you should enter the
value zero in the relevant section. For both PBTs
and dioxin, the accuracy of the underlying data on
which the estimate is based must support the
specified level of precision in order to round to zero.
However, if there has been no on-site or off-site
treatment, combustion for energy recovery, or
recycling of the waste stream containing the EPCRA
Section 313 chemical, then you should enter NA in
the relevant section. (Note: for metals and metal
category compounds, you should enter NA in
Sections 8.2, 8.3, 8.6 and 8.7, as treatment and
combustion for energy recovery generally are not
applicable waste management methods for metals
and metal compounds). For Section 8.1b, NA
generally is not applicable recognizing the potential
for spills, leaks, or fugitive emissions of the EPCRA
Section 313 chemical. You should enter NA in
Section 8.8 if there were no remedial actions,
catastrophic events such as earthquakes, fires, or
floods or one-time events not associated with
normal or routine production processes for that toxic
chemical. If there was a catastrophic event at your
facility, but you were able to prevent any releases
from occurring, then enter zero in Section 8.8.
Relationship to Other Laws
The reporting categories for quantities recycled,
used for energy recovery, treated, and disposed of
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 categories also do not apply to
the information that may be submitted in the
Biennial Report required under RCRA. In addition,
these categories 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, assume that a RCRA
hazardous waste containing an EPCRA Section 313
chemical is recycled to recover certain constituents
of that waste, but not the toxic chemical reported
under EPCRA Section 313. The EPCRA Section
313 chemical simply passes through the recycling
process and remains in the residual from the
recycling process, which is disposed of. While the
waste may be considered recycled under RCRA, for
TRI purposes, the EPCRA Section 313 chemical
constituent would be considered to be disposed of
(as part of the residual from the recycling process).
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 8.8.
Years for Which Quantities for Sections 8.1 - 8.7
Must Be Reported
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, 2012 (reporting year
2011), the prior year is 2010. Information available
at the facility that may be used to estimate the prior
year's quantities include the prior year's Form R
submission, supporting documentation, and
recycling, energy recovery, treatment, or disposal
operating logs or invoices. When reporting prior
year estimates, facilities are not required to use
quantities reported on the previous year's form if
better information is available. TRI-MEweb
prepopulates this column on the TRI form if the
facility reported the previous year.
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 the following two years.
EPA expects reasonable future quantity estimates
using a logical basis. Information available at the
facility to estimate quantities of the chemical
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expected during these years include (but are not
limited to) 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.
Example 19: Reporting Future Estimates
A pharmaceutical manufacturing facility uses an
EPCRA Section 313 chemical in the manufacture
of a prescription drug. During the reporting year
(2011), the company received approval from the
Food and Drug Administration to begin marketing
their product as an over-the-counter drug
beginning in 2012. This approval is publicly
known and does not constitute confidential
business information. As a result of this expanded
market, the company estimates that sales and
subsequent production of this drug will increase
their use of the reported EPCRA Section 313
chemical by 30 percent per year for the two years
following the reporting year. The facility treats
the EPCRA Section 313 chemical on-site and the
quantity treated is directly proportional to
production activity. The facility thus estimates the
total quantity of the reported EPCRA Section 313
chemical treated for the following year (2012) by
adding 30 percent to the amount in column B (the
amount for the current reporting year). The
second following year (2013) figure can be
calculated by adding an additional 30 percent to
the amount reported in column C (the amount for
the following year (2012) projection).
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. The relationship
between Sections 5, 6, and 8.8 to Sections 8.1, 8.3,
8.5, and 8.7 are provided below in equation form.
Note on Equations. Where an equation includes a
value followed by a parenthetical, this means that
the equation is referring only to the portion of that
value described by the parenthetical. For example,
"Section 6.2 (recycling)" refers to the portion of the
value for Section 6.2 that is recycled, while
"Section 6.2 (treatment)" refers to the portion of
the value for Section 6.2 that is treated.
Section 8.1. In Section 8.1, facilities report disposal
and other releases. This includes on-site disposal
and other releases reported in Section 5 and off-site
disposal and other releases reported in Section 6, but
excludes quantities reported in Section 5 and 6 due
to remedial actions, catastrophic events, or non-
production related one-time events (see the
discussion on Section 8.8). Note that EPCRA
Section 329(8) defines release as "any spilling,
leaking, pumping, pouring, emitting, emptying,
discharging, injecting, escaping, leaching, dumping,
or disposing into the environment (including the
abandonment of barrels, containers, and other closed
receptacles)."
Metals and metal category compounds reported in 1)
Section 6.2 as sent off-site for
stabilization/solidification (M41) or wastewater
treatment (excluding POTWs) (M62) and/or 2)
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 not ultimately destroyed.
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,
8.8, and 8. la through 8. Id.
Sections 8.1a and 8.1b. Toxic chemicals disposed
of or otherwise released on-site are reported in 8. la
or 8.1b as appropriate. Toxic chemicals sent off-site
for disposal are reported in 8. Ic or 8. Id.
Section 8.1a = Section 5.4.1 + Section 5.5.1A +
Section 5.5.1B - Section 8.8 (on-site disposal to
landfills or UIC Class I Wells)2
2§ 8.8 includes quantities of toxic chemicals disposed of
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 process. In
each equation, the parenthetical following "Section 8.8"
indicates which portion of § 8.8 is subtracted.
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Section 8.1b = Section 5.1 + Section 5.2 + Section
5.3 + Section 5.4.2 + Section 5.5.2 + Section
5.5.3A + Section 5.5.3B + Section 5.5.4 - Section
8.8 (on-site disposal or other releases, other than
disposal to landfills or UIC Class I Wells)
Sections 8.1c and 8.Id. Toxic chemicals transferred
off-site to POTWs or other off-site locations and
then disposed of or otherwise released should be
reported in 8. Ic or 8. Id as appropriate. For example,
quantities of a toxic chemical sent to a landfill, or
sent to a POTW and subsequently sent to a landfill
are reported in Section 8.1c, while quantities of a
toxic chemical sent to a surface impoundment, or
sent to a POTW and subsequently released 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.
Section 8.1c = Section 6.1 (portion of transfer
that is untreated and ultimately disposed of in
landfills or UIC Class I Wells) + Section 6.2
(quantities associated with M codes M64, M65
and M81) - Section 8.8 (off-site disposal to
landfills or UIC Class I Wells)3
Section 8.Id = Section 6.1 (portion of transfer
that is untreated and ultimately disposed of or
otherwise released, other than disposal to
landfills or UIC Class I Wells) + Section 6.2
(quantities associated with M codes M10, M41,
M62, M66, M67, M73, M79, M82, M90, M94,
and M99) - Section 8.8 (off-site disposal or other
releases, other than disposal to landfills or UIC
Class I Wells)3
Some chemicals in addition to metals and metal
category compounds might not be treated for
destruction at a POTW. If you know that some or all
of a chemical is not treated for destruction at the
POTW, you should report that quantity in Section
8.1 (as indicated in the equations above) instead of
Section 8.7 (which is the quantity treated off-site).
3 § 8.8 includes quantities of toxic chemicals disposed of
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 process. In
each equation, the parenthetical following "Section 8.8"
indicates which portion of § 8.8 is subtracted.
Sections 8.2 and 8.3. These relate to an EPCRA
Section 313 chemical or a mixture containing an
EPCRA Section 313 chemical that is used for
energy recovery on-site or is sent off-site for energy
recovery, unless it is a commercially available fuel
(e.g., fuel oil no. 6). For the purposes of reporting on
Form R, reportable on-site and off-site energy
recovery is the combustion of a waste stream
containing an EPCRA Section 313 chemical when:
(a) The combustion unit is integrated into an
energy recovery system (i.e., industrial
furnaces, industrial kilns, and boilers); and
(b) The EPCRA Section 313 chemical is
combustible and has a significant heating
value (e.g., 5000 BTU)
Note: Metals and metal category compounds cannot
be combusted for energy recovery. For metals and
metal category compounds, you should enter NA in
Sections 8.2 and 8.3.
Quantities used for energy recovery off-site that are
reported in Section 8.8 are excluded from Section
8.3.
Section 8.2 is not related to Sections 5 or 6
Section 8.3 = Section 6.2 (energy recovery) -
Section 8.8 (off-site energy recovery)3
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. Quantities
recycled off-site that are reported in Section 8.8 are
excluded from Section 8.5.
Section 8.4 is not related to Sections 5 or 6
Section 8.5 = Section 6.2 (recycling) - Section 8.8
(off-site recycling)3
Section 8.6 and 8.7. These relate to an EPCRA
Section 313 chemical (except for most metals and
metal category compounds) or a waste containing an
EPCRA Section 313 chemical that is treated for
destruction on-site or is sent to a POTW or other
off-site location for treatment for destruction. Most
metal and category compounds are not reported in
this section because they cannot be destroyed (see
Appendix B). Quantities treated off-site that are
reported in Section 8.8 are excluded from Section
8.7.
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Section 8.6 is not related to Sections 5 or 6
Section 8.7 = Section 6.1 (portion of transfer that
is ultimately treated) + Section 6.2 (treatment) -
Section 8.8 (off-site treatment)3
Some chemicals in addition to metals and metal
category compounds might not be treated for
destruction at a POTW. If you know that some or all
of a chemical is not treated for destruction at the
POTW, you should report that quantity in Section
8.1 instead of Section 8.7. Facilities should use their
best readily available information to determine the
final disposition of the toxic chemical sent to the
POTW, and then distribute the amount reported in
Section 6.1 among Sections 8.1c, 8.Id, and 8.7, as
appropriate.
Example 20: Avoiding Double-Counting
Quantities in Sections 8.1 through 8.7
5,000 pounds of an EPCRA Section 313
chemical enters a treatment operation. Three
thousand pounds of the EPCRA Section 313
chemical exits the treatment operation and then
enters a recycling operation. Five hundred
pounds of the EPCRA Section 313 chemical are
in residues from the recycling operation that is
subsequently sent off-site to a landfill for
disposal. These quantities would be reported as
follows in Section 8:
Section 8.1c: 500 pounds disposed of
Section 8.4: 2,500 pounds recycled
Section 8.6: 2,000 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 of
by 3,500 pounds.
8.8 Quantity Released to the Environment as a
Result of Remedial Actions, Catastrophic Events,
or One-Time Events Not Associated with
Production Processes
In Section 8.8, enter the total quantity of the EPCRA
Section 313 chemical disposed of 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 Sections
8.1, 8.3, 8.5, or 8.7.
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 released,
recycled, combusted for energy recovery, or treated
may ultimately be preventable, this section separates
the quantities that are more likely to be reduced or
eliminated by process oriented source reduction
activities from those releases that are largely
unpredictable and are less amenable to such source
reduction activities. For example, spills that occur as
a routine part of production operations and could be
reduced or eliminated by improved handling,
loading, or unloading procedures are included in the
quantities reported in Section 8.1 through 8.7 as
appropriate. A total loss of containment resulting
from a tank rupture caused by a tornado would be
included in the quantity reported in Section 8.8.
Similarly, the amount of an EPCRA Section 313
chemical cleaned up from spills resulting from
normal operations during the reporting year would
not be included in Section 8.8. However, the
quantity of the reported EPCRA Section 313
chemical disposed of 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
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boundary. Most remedial activities involve
collecting and treating contaminated material.
Also, releases caused by catastrophic events are to
be incorporated into the quantity reported in Section
8.8. Such releases may be caused by natural
disasters (e.g., hurricanes and earthquakes) or by
large scale accidents (e.g., fires and explosions). In
addition, releases due to one-time events not
associated with production (e.g., terrorist bombing)
are to be included in Section 8.8. These amounts are
generally unanticipated and cannot be addressed by
routine process oriented accident prevention
techniques. By checking your documentation for
calculating estimates made for Part II, Section 5,
"Quantity of the Toxic Chemical Entering Each
Environmental Medium On-site," you may be able
to identify disposal and release amounts from the
above sources. Emergency notifications under
CERCLA and EPCRA as well as accident histories
required under the Clean Air Act may provide
useful information. You should also check facility
incident reports and maintenance records to identify
one time or catastrophic events.
Note: While the information reported in Section 8.8
represents only remedial, catastrophic, or one-time
events not associated with production processes,
Section 5 of Form R (on-site disposal and other
releases to the environment) and Section 6 (off-site
transfers for further waste management) must
include all on-site disposal and other releases and
transfers for disposal as appropriate, regardless of
whether they arise from catastrophic, remedial, or
routine process operations.
Avoid Double Counting in Sections 8.1 Through
8.8
Do not double or multiple count quantities in
Sections 8.1 through 8.8. The quantities reported in
each of those sections should be mutually exclusive.
Do not multiple count quantities entering sequential
reportable activities during the reporting year.
Do not include in Sections 8.1 through 8.7 any
quantities of the EPCRA Section 313 chemical
disposed of 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.
Example 21: Quantity Released to the Environment as a Result of Remedial Actions, Catastrophic
Events, or One-Time Events Not Associated with Production Processes.
A chemical manufacturer produces an EPCRA Section 313 chemical in a reactor that operates at low
pressure. The reactants and the EPCRA Section 313 chemical product are piped in and out of the reactor
at monitored and controlled temperatures. During normal operations, small amounts of fugitive emissions
occur from the valves and flanges in the pipelines.
Due to a malfunction in the control panel (which is state-of-the-art and undergoes routine inspection and
maintenance), the temperature and pressure in the reactor increase, the reactor ruptures, and the EPCRA
Section 313 chemical is released. Because the malfunction could not be anticipated and, therefore, could
not be reasonably addressed by specific source reduction activities, the amount released is included in
Section 8.8. In this case, much of the EPCRA Section 313 chemical is released as a liquid and pools on
the ground. It is estimated that 1,000 pounds of the EPCRA Section 313 chemical pooled on the ground
and was subsequently collected and sent off-site for treatment. In addition, it is estimated that another 200
pounds of the EPCRA Section 313 chemical vaporized directly to the air from the rupture. The total
amount reported in Section 8.8 is the 1,000 pounds that pooled on the ground (and subsequently sent off-
site), plus the 200 pounds that vaporized into the air, a total of 1,200 pounds. The quantity sent off-site
must also be reported in Section 6 (but not in Section 8.7) and the quantity that vaporized must be
reported as a fugitive emission in Section 5 (but not in Section 8. Ib).
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8.9 Production Ratio or Activity Index
For Section 8.9, you must provide either a
production ratio or an activity index. The production
ratio or activity index allows year-to-year changes in
release and other waste management quantities to be
viewed within the context of production.
Production Ratio vs. Activity Index
A production ratio is a ratio of reporting year
production to prior year production. Calculate a
production ratio for the chemical when production
levels most directly affect the quantity of the
chemical managed as waste.
An activity index is also a ratio of current year to
prior year values, but it is used when a variable
other than production is the primary influence on the
quantity of the reported EPCRA Section 313
chemical managed as waste. An Activity Index may
be applicable when the EPCRA Section 313
chemical is "otherwise used" (e.g., non-
incorporative activities such as extraction solvents,
or metal degreasers).
What Variable is Used to Calculate This Ratio?
The production ratio or activity index must be based
on the variable(s) that most directly affect(s) the
quantity of the EPCRA Section 313 chemical
generated as waste (i.e., recycled, used for energy
recovery, treated, disposed or otherwise released). If
an EPCRA Section 313 chemical is used in the
production of refrigerators, for example, the
production ratio would be based on the number of
refrigerators produced (see Example 22).
In most cases, the production ratio or activity index
must be based on a variable other than the quantity
of the EPCRA Section 313 chemical manufactured,
processed, or otherwise used. This is because
indices based on chemical or material usage may
reflect the effect of source reduction activities (e.g.,
process improvements) rather than changes in
business activity. If the reported EPCRA Section
313 chemical is itself the end product, however, the
quantities of the EPCRA Section 313 chemical(s)
produced in the current and prior years do provide a
good basis for the production ratio.
Reporting Tips:
• New for this reporting year, TRI-MEweb now
includes a production ratio/activity index wizard
to help you calculate your ratio automatically.
• 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
all EPCRA 313 chemicals, including PBT
chemicals. A zero is not an acceptable response
unless the calculated value is less than l/200th,
which can then be rounded to zero.
• If the manufacture, processing, or other use of
the reported EPCRA Section 313 chemical
began during the current reporting year, select
NA as the production ratio or activity index.
• The ratio or index is not to be reported as a
percent change between years (i.e., for a 10
percent increase, you would report the ratio
1.10, not 10% or 10).
• Some facilities may use the same EPCRA
Section 313 chemical in more than one
production process. In this case, 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 of (see Example
25).
• 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.
• Details regarding the method used to calculate
the Production Ratio/Activity Index can be
included in Section 9.1, "Additional
Information." This information will provide
context for the production ratio and may help
TRI data users better understand changes in
releases or other waste management quantities.
In Example 22, the facility could report, "Used
the number of refrigerators painted as the
production variable, because our facility
otherwise uses toluene to paint refrigerators" in
order to provide more information in Section
9.1.
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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 of
or released.
A facility that manufactures thermoplastic composite parts for aircraft uses toluene as a wipe solvent to
clean molds. The solvent is stored in 55-gallon drums and is transferred to 1-gallon dispensers. The molds
are cleaned on an as-needed basis that is not necessarily a function of the parts production rate. Operators
cleaned 5,200 molds during the reporting year, but only cleaned 2,000 molds in the previous year. An
activity index of 2.6 (5,200/2,000) represents the activities involving toluene usage in the facility. If the
molds were cleaned after 1,000 parts were manufactured, a production ratio would equal the activity index
and either could be used as the basis for the index.
A facility manufactures surgical instruments and cleans the metal parts with 1,1,1-trichloromethane in a
vapor degreaser. The degreasing unit is operated in a batch mode and the metal parts are cleaned
according to an irregular schedule. The activity index can be based upon the total time the metal parts are
in the degreasing operation. If the degreasing unit operated 3,900 hours during the reporting year and
3,000 hours the prior year, the activity index is 1.3 (3,900/3,000).
Example 24: "NA" is Entered as the Production Ratio or Activity Index
Your facility began production of semiconductor chips during this reporting year. Perchloroethylene is
used as a cleaning solvent for this operation and this is the only use of the EPCRA Section 313 chemical
in your facility. You would enter NA in Section 8.9 because you have no basis of comparison in the prior
year for the purposes of developing the activity index.
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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 of.
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 of 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 of 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 of 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
8.10 Did Your Facility Engage in Any Newly
Implemented Source Reduction Activities for
This Chemical During the Reporting Year?
Section 8.10 must be completed if a source
reduction activity involving the reported EPCRA
Section 313 chemical was newly implemented at
your facility. An activity is considered newly
implemented if it went into effect, in whole or in
part, during this reporting year.
What Is Source Reduction?
Source reduction, as defined by the Pollution
Prevention Act, means any practice that:
• Reduces the amount of any hazardous
substance, pollutant, or contaminant entering
any waste stream or otherwise released into the
environment (including fugitive emissions) prior
to recycling, energy recovery, treatment, or
disposal; and
• Reduces the hazards to public health and the
environment associated with the release of such
substances, pollutants, or contaminants.
The term "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 include 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.
How Does Source Reduction Relate to the
Quantities Reported in Sections 8.1-8.8?
Source reduction activities reduce the amount of the
reported EPCRA Section 313 chemical disposed of
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).
Recycling, energy recovery, and treatment are not
themselves considered source reduction activities
because these practices occur after the chemical has
entered a waste stream.
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The focus of the section includes only those
activities that are applied to reduce routine or
reasonably anticipated releases or other quantities of
the reported EPCRA Section 313 chemical managed
as waste). Thus, you do not report in this section any
activities taken to reduce or eliminate the quantities
reported in Section 8.8.
Why Is Reporting on Source Reduction Activities
Important?
The Pollution Prevention Act established the
national policy "that pollution should be prevented
or reduced at the source whenever feasible..."
Reporting on source reduction activities provides
important information for assessing progress
towards this goal.
To promote pollution prevention, EPA has increased
the prominence and accessibility of the pollution
prevention information reported in Sections 8.10
and 8.11 of the Form R. For example, the 2011 TRI
National Analysis highlighted the parent companies
that reported the greatest number of source
reduction activities. To learn more, visit
www. epa. gov/TRI/P2.
How Do I Report Source Reduction Activities
and Methods?
Instructions on how to report source reduction
activities (as defined above) and the methods used
to identify such activities are provided below.
TRI-MEweb
• If Your Facility Implemented Source
Reduction Activities. If your facility
implemented a new source reduction activity for
the reported EPCRA Section 313 chemical
during the reporting year, report the activity or
activities that were implemented by selecting
the most relevant activity code(s) from the drop
down list in TRI-MEweb (see W-codes listed
below).
For each "Source Reduction Activity" reported,
you must also enter one or more code(s) that
correspond to the internal and external
method(s) or information sources you used to
identify the possibility for implementing a
source reduction activity 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.
For each source reduction code you enter in
TRI-MEweb, a button to the right of the entry
opens a text box that allows you to provide
additional details on that source reduction
practice. Similarly, to describe how each source
reduction practice was identified, a button to the
right of the entry opens a text box that allows
you to enter additional information on the
identification method(s) you selected. Optional
additional information about source reduction
provided via these text boxes is then added to
the next section of the Form R (Section 8.11,
Optional Pollution Prevention Information)
preceded by the W- or T-code to which it
relates.
• If Your Facility Did Not Implement Source
Reduction Activities. If your facility did not
implement any new source reduction activity for
the reported EPCRA Section 313 chemical,
check the "NA" box in Section 8.10. TRI-
MEweb then provides a text box that you may
use to provide information on any barriers your
facility might be facing with regard to the
implementation of source reduction activities.
(This information is then added to your entry in
Section 8.11; see Section 8.11 instructions for
additional information on barriers to P2.)
Hard-Copy Reporting
• If Your Facility Implemented Source
Reduction Activities. If using a paper form,
source reduction activity codes must be entered
in the first column of Sections 8.10.1 through
8.10.4. Next, indicate any methods to identify
the reported source reduction activity using the
T-codes provided below.
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.
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Instructions for Completing Part II of EPA Form R
• If Your Facility Did Not Implement Source
Reduction Activities. If your facility did not
implement any new source reduction activity for
the reported EPCRA Section 313 chemical,
check the "NA" box in Section 8.10.
Source Reduction Activity Codes
Source reduction activity codes are listed below. In
recent years many facilities have implemented green
chemistry and green engineering practices to
prevent pollution. In order to more closely represent
these practices, EPA has developed six new source
reduction codes. These codes are represented as:
W15; W43; W50; W56; W57; and W84 and are
provided in the list of source reductions below.
Scenarios as to when these codes should be used are
provided in Example 27.
Good Operating Practices
W13 Improved maintenance scheduling, record
keeping, or procedures
W14 Changed production schedule to minimize
equipment and feedstock changeovers
W15 Introduced in-line product quality
monitoring or other process analysis system
W19 Other changes made in operating practices
Inventory Control
W21 Instituted procedures to ensure that
materials do not stay in inventory beyond
shelf-life
W22 Began to test outdated material — continue
to use if still effective
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labeling procedures
W25 Instituted clearinghouse to exchange
materials that would otherwise be discarded
W29 Other changes made in inventory control
Spill and Leak Prevention
W31 Improved storage or stacking procedures
W32 Improved procedures for loading,
unloading, and transfer operations
W33 Installed overflow alarms or automatic shut-
off valves
W35 Installed vapor recovery systems
W36 Implemented inspection or monitoring
program of potential spill or leak sources
W39 Other changes made in spill and leak
prevention
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
W43 Substituted a feedstock or reagent chemical
with a different chemical
W49 Other raw material modifications made
Process Modifications
W50 Optimized reaction conditions or otherwise
increased efficiency of synthesis
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
W56 Reduced or eliminated use of an organic
solvent
W57 Used biotechnology in manufacturing
process
W58 Other process modifications made
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 made
Surface Preparation and Finishing
W72 Modified spray systems or equipment
W73 Substituted coating materials used
W74 Improved application techniques
W75 Changed from spray to other system
W78 Other surface preparation and finishing
modifications made
Product Modifications
W81 Changed product specifications
W82 Modified design or composition of product
W83 Modified packaging
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Instructions for Completing Part II of EPA Form R
W84 Developed a new chemical product to T05
replace a previous chemical product
W89 Other product modifications made T06
Methods to Identify Source Reduction Activities T07
T01 Internal pollution prevention opportunity T08
audit(s)
T02 External pollution prevention opportunity T09
audit(s)
T03 Materials balance audits T10
T04 Participative team management Til
Employee recommendation (independent of
a formal company program
Employee recommendation (under a formal
company program
State government technical assistance
program
Federal government technical assistance
program
Trade association/industry technical
assistance program
Vendor assistance
Other
Example 26: Source Reduction
A facility assembles and paints furniture. Both the glue used to assemble the furniture and the paints
contain EPCRA Section 313 chemicals. By examining the gluing process, the facility discovered that a
new drum of glue is opened at the beginning of each shift, whether the old drum is empty or not. By
adding a mechanism that prevents the drum from being changed before it is empty, the need for disposal
of the glue is eliminated at the source. As a result, this activity is considered source reduction.
The painting process at this facility generates a solvent waste that contains an EPCRA Section 313
chemical that is collected and recovered. The recovered solvent is used to clean the painting equipment.
The recycling activity does not reduce the amount of EPCRA Section 313 chemical recycled, and
therefore is not considered a source reduction activity.
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Instructions for Completing Part II of EPA Form R
Example 27: Green Chemistry
Six new source reduction codes that could describe green chemistry and green engineering practices were
added for Reporting Year 2012. These codes are listed below with a description of when to use each code
to report a green chemistry or engineering activity.
W15 Introduced in-line product quality monitoring or other process analysis system. Select this code if
the introduction of such a system led to a reduction in the amount of the EPCRA Section 313
chemical generated as waste.
W43 Substituted a feedstock or reagent chemical with a different chemical. Select this code if the
EPCRA Section 313 chemical was a feedstock or reagent chemical and you replaced it (in whole
or in part) with a different chemical.
o For raw material substitutions not at the level of the individual chemical (e.g., the
substitution of natural gas for coal), select instead W42 Substituted raw materials.
o If use of a feedstock or reagent chemical was reduced or eliminated because of a change in
the final product, select instead one of the codes listed under Product Modifications.
W50 Optimized reaction conditions or otherwise increased efficiency of synthesis. Select this code if
the amount of the EPCRA Section 313 chemical generated as waste was reduced by increasing the
overall efficiency of the synthesis.
o If efficiency of syntheses was improved by using of a different catalyst, select instead
W53 Used a different process catalyst.
W56 Reduced or eliminated use of an organic solvent. Select this code if the EPCRA Section 313
chemical was used as a solvent in the process and the process was modified such that the EPCRA
Section 313 chemical was either replaced or no longer used in as large a quantity.
W57 Used biotechnology in manufacturing process. Select this code if the use of biotechnology in the
process reduced or eliminated the use of the TRI chemical.
W84 Developed a new chemical product to replace previous chemical product. Select this code if the
EPCRA Section 313 chemical had been produced at the facility but was replaced it (in whole or in
part) with the production of a different chemical or chemicals.
8.11 Optional Pollution Prevention
Information
In Section 8.11, you have the opportunity to provide
more detail about activities your facility undertook
to reduce releases of the EPCRA Section 313
chemical, including source reduction, recycling,
energy recovery, treatment or other pollution
controls. EPA encourages you to provide detail in
Section 8.11, as it offers your organization the
opportunity to showcase its achievements in
preventing pollution.
If you are using TRI-MEweb to submit your report,
you can use the provided text boxes to describe your
source reduction, recycling, or pollution control
activities. If you are filing by paper, you may
provide a description in the box provided on the
Form R.
While EPA welcomes submissions about recycling
and pollution control activities, the Agency is most
interested in collecting information about innovative
and effective source reduction activities, such as
green chemistry or green engineering practices. In
addition, the Agency wishes to encourage reporters
to provide enough detailed information about their
most effective source reduction activities to spur
other facilities to adopt similar practices, as well as
to inform the public about such activities being
implemented in their communities.
To encourage submissions with additional pollution
prevention information, EPA is increasing the
prominence and accessibility of this information.
Visit www. epa. gov/TRI/P2 to learn how to access
this information and to view examples of optional
pollution prevention information highlighted in
EPA's annual TRI National Analysis report.
The following tips can help you provide meaningful
additional information.
Be Specific:
• Which processes
affected?
and products were
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Instructions for Completing Part II of EPA Form R
• Which technologies and materials were
used?
• Which release (to air, water land) or waste
management quantities changed?
• Were there other benefits (e.g., costs,
product quality?)
• Who provided the idea or assisted with
implementation?
• Why did you implement this activity?
Enter useful URLs:
• For equipment manufacturers
• To other information sources related to the
activity described
If you wish to provide additional information that is
not related to pollution prevention or other
environmentally friendly practices, use Section 9.1.
Barriers to Implementing Pollution Prevention
Activities
You may also provide details on any barriers your
facility faces in implementing additional source
reduction, recycling or pollution control activities. If
you choose to provide this information, EPA
encourages you to describe specifically how one of
these barrier categories applies to your facility:
1. Insufficient capital to install new source
reduction equipment or implement new
source reduction activities/initiatives.
2. Require technical information on pollution
prevention techniques applicable to specific
production processes.
3. Concern that product quality may decline as
a result of source reduction.
4. Source reduction activities were
implemented but were unsuccessful.
5. Specific regulatory/permit burdens
6. Pollution prevention previously
implemented- additional reduction does not
appear technically or economically feasible.
7. Other
EPA believes this information is valuable in giving
a full picture of the source reduction activities your
facility engages in and what barriers you face in the
implementation of source reduction activities. EPA
also believes this information may allow for an
exchange between those that have knowledge of
source reduction practices, such as the EPA P2
Program, and those that are seeking additional help.
In addition, it will better enable EPA to identify
those technological areas for which EPA can
support basic research to identify alternative
technologies that are less polluting.
9.1 Miscellaneous, Optional, and Additional
Information for Your Form R Report
Your facility may provide additional information
pertaining to any portion of your Form R
submission in the box provided on the hard-copy
form, or in the drop-down text box provided in TRI-
MEweb. Your submissions to Section 9.1 regarding
miscellaneous, additional, optional information may
provide the Agency and/or the public with useful
data that helps explain why your facility submitted
data in one or more data elements that might appear
unusual or inconsistent with previous TRI Form R
submissions or with other data supplied by your
facility during this reporting year. Such additional
data may help EPA reduce the need for additional
data quality control as well as additional TRI-related
enforcement and compliance efforts. Do not
submit information you consider to be CBI or
otherwise protected on your Form R.
Other topics you may wish to address in Section 9.1
include:
• Changes in production levels
• Facility closures
• Staffing changes
• Calculation methods, e.g., emission factors
• Variable(s) used to calculate production
ratio or activity index (Section 8.9)
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Instructions for Completing Form R Schedule l(Dioxin and Dioxin-like Compounds)
D. Instructions for Completing
Form R Schedule 1 (Dioxin and
Dioxin-like Compounds)
D. 1 What is the Form R Schedule 1 ?
The Form R Schedule 1 is a four-page form that
mirrors the data elements from Form R Part II
Chemical-Specific Information sections 5, 6, and 8
(current year only). The Form R Schedule 1 requires
the reporting of the individual grams data for each
member of the dioxin and dioxin-like compounds
category present, and is submitted as an adjunct to
the Form R. Beginning with reporting year 2008,
facilities that file Form R reports for the dioxin and
dioxin-like compounds category are required to
determine if they have any of the information
required by the new Form R Schedule 1. Facilities
that have any of the information required by Form R
Schedule 1 must submit a Form R Schedule 1 in
addition to the Form R. Note: Beginning in
RY2008, the listing order of the 17 members of the
dioxin and dioxin-like compounds category
changed.
D.2 Who is required to file a Form R
Schedule 1?
Only facilities that file reports for the dioxin and
dioxin-like compounds category may be required to
file a Form R Schedule 1. Facilities that have any of
the data required by Form R Schedule 1 for the
individual members of the dioxin and dioxin-like
compounds category must submit a Form R
Schedule 1, in addition to the Form R. EPA notes
that dioxin and dioxin-like compounds are not
measured as a total quantity; the measurements are
based on the individual compounds within the
category. Emission factors for dioxin and dioxin-
like compounds are also based on emission factors
for the individual compounds within the category.
EPA's guidance document for dioxin and dioxin-
like compounds (Emergency Planning And
Community Right-To-Know Act - Section 313:
Guidance for Reporting Toxic Chemicals within the
Dioxin and Dioxin-like Compounds Category, EPA-
745-B-00-021, December 2000) includes tables that
contain the emission factors for the individual
members of the dioxin and dioxin-like compounds
category. Since measured data and emission factor
data are based upon data for the individual members
of the dioxin and dioxin-like compounds category,
the information required by Form R Schedule 1
should be available to facilities that file Form R
reports for the dioxin and dioxin-like compounds
category.
D.3 What information is reported on
the Form R Schedule 1?
The only data reported on the Form R Schedule 1 is
the mass quantity information required in sections 5,
6, and 8 (current year only) of the Form R. All of
the other information required in sections 5, 6, and 8
of the Form R (off-site location names, stream or
water body names, etc.) would be the same so this
information is not duplicated on Form R Schedule 1.
For example, if a facility reported 5.3306 grams on
Form R Section 5.1 for fugitive or non-point air
emissions for the dioxin and dioxin-like compounds
category then the facility would report on the Form
R Schedule 1 the grams data for each individual
member of the category that contributed to the
5.3306 gram total. The sum of the gram quantities
reported for each individual member of the category
should equal the total gram quantity reported for the
category on Form R for each data element (see
examples in Figure 7). The NA box has the same
meaning on Form R Schedule 1 as it does on the
Form R and should only be marked if it is marked
on the Form R.
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Instructions for Completing Form R Schedule l(Dioxin and Dioxin-like Compounds)
Form R Section 5 Example
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ON-SITE
5.1
Fugitive or non -point
air emissions
NA Q
A. Total Release (pounds/year*)
(Enter a range code** or estimate)
5.3306
B. Basis of Estimate
(Enter code)
M2
C. Percent from Stormwater
Form R Schedule 1 Section 5 Example
SECTION 5, QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM ON-SITE
P
t
o
w
-C
C.
"o
G
s.
s
-C
w
S
~s
en
i
Q
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
5.1 NA
Fugitive or non-
point air emissions
0.0035
0.0059
0.0071
0.0008
0.0065
0.0923
0.5720
0.0723
0.0695
0.0399
0.3562
0.1309
0.0132
0.0815
1.4625
0.3126
2.1039
5.2 NA
Stacker point
air emissions
Discharges to receiving streams or water bodies
(Enter data for one stream or water body per box) NA j |
5.3.1
5.3.2
5.3.3
If additional pages of Section 5.3 are attached, indicate the total number of pages in this box 1
and indicate the Section 5.3 page number in this box (Example: 1 , 2, 3, etc.)
The Form R Schedule 1 provides boxes for recording the gram quantities for all 17 individual members of
the dioxin and dioxin-like compounds category. The boxes on the Form R Schedule 1 for each release type
are divided into 17 boxes. Each of the boxes (1-17) corresponds to the individual members of the dioxin
category as presented in Table I.
Figure 7. Hypothetical Form R, Section 5.1 and Form R Schedule 1, Section 5.1
Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Form R Schedule l(Dioxin and Dioxin-like Compounds)
Abbreviation
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,678,9-OCDF
It is extremely important that facilities enter their grams data for the individual members of the category
based on the box numbers in Table I (do not use the listing order from the 2007 or earlier versions of the
reporting instructions). This information will be used to calculate toxic equivalency values using toxic
equivalency factors that are specific to each member of the category. As with reporting on the Form R,
facilities should report on the Form R Schedule 1 to the level of accuracy that their data supports, up to seven
digits to the right of the decimal. EPA's reporting software and data management systems support data
precision to seven digits to the right of the decimal. EPA strongly encourages facilities that report for the
dioxin and dioxin-like compounds category to file their reports electronically to reduce the potential for
errors when transferring the individual grams data from hard copy reports.
Table I
Box#
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
CAS#
01746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
03268-87-9
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0
Chemical Name
2,3,7,8-Tetrachlorodibenzo-p-dioxin
1,2,3, 7,8-Pentachlorodibenzo- p-dioxin
1,2,3,4,7,8-Hexachlorodibenzo- p-dioxin
1,2,3, 6,7,8-Hexachlorodibenzo- p-dioxin
1,2,3, 7,8, 9-Hexachlorodibenzo- p-dioxin
1,2,3,4,6,7,8-Heptachlorodibenzo- p-dioxin
1,2,3,4,6,7,8, 9-Octachlorodibenzo- p-dioxin
2, 3 , 7, 8 -Tetrachlorodibenzofuran
1,2,3, 7,8-Pentachlorodibenzofuran
2,3,4,7,8-Pentachlorodibenzofuran
1,2,3,4,7,8-Hexachlorodibenzofuran
1,2,3, 6,7,8-Hexachlorodibenzofuran
1,2,3, 7,8, 9-Hexachlorodibenzofuran
2,3,4,6,7,8-Hexachlorodibenzofuran
1,2,3,4,6,7,8-Heptachlorodibenzofuran
1,2,3,4,7,8,9-Heptachlorodibenzofuran
1,2,3,4,6,7,8, 9-Octachlorodibenzofuran
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Facility Eligibility Determination for Alternate Threshold
and for Reporting on TRI Form A Certification Statement
E. Facility Eligibility
Determination for Alternate
Threshold and for
Reporting on TRI Form A
Certification Statement
This section will help to determine whether you can
submit the simplified Form A Certification
Statement (hereafter referred to as Form A). The
criteria are based on the total annual reportable
amount of the listed chemical or chemical category
and the amount manufactured, processed, or
otherwise used. Note that, effective in Reporting
Year 2008, the TRI Burden Reduction Rule has
been voided by Congress. The criterion for using
Form A has returned to what they were prior to
Reporting Year 2006. The criteria are explained
below. For more information about the final rule,
see the TRI homepage at:
http://www.epa.gov/tri/lawsandregs/index.htm.
E.I Alternate Threshold
On November 30, 1994, EPA published a final rule
(59 FR 61488) that provides qualifying facilities an
alternate threshold of 1 million pounds. Eligible
facilities wishing to take advantage of this option
may certify on a simplified two-page form referred
to as Form A Certification Statement and do not
have to use Form R. The "TRI Alternate Threshold
for Facilities with Low Annual Reportable
Amounts," provides facilities otherwise meeting
EPCRA section 313 reporting thresholds the option
of certifying on Form A provided that they do not
exceed 500 pounds for the total annual reportable
amount (defined below) for that chemical, and that
their amounts manufactured or processed or
otherwise used do not exceed one-million pounds.
As with determining section 313 reporting
thresholds, amounts manufactured, processed, or
otherwise used are to be considered independently.
This modification does not apply to forms being
submitted on or before July 1, 1995 (covering the
1994 reporting year). If you fill out a Form A for an
EPCRA section 313 chemical, do not fill out a Form
R for that same chemical.
However, there is an exception to the alternate
threshold rule described in the preceding paragraph.
All PBT chemicals (except certain instances of
reporting lead in stainless steel, brass or bronze
alloys) are excluded from eligibility for the alternate
threshold.
E.2 What is the Form A Certification
Statement?
The Form A, which is described as the "certification
statement" in 59 FR 61488, is intended as a means
to reduce the compliance burden associated with
EPCRA section 313. If a facility chooses to use
Form A as a substitute for Form R for any eligible
chemical, it must be submitted on an annual basis.
Facilities wishing to take advantage of this burden
reducing option may only submit Form A for
chemicals that meet the conditions described in
section E.I, Alternate Threshold, and should not
submit a Form R to the TRI Data Processing Center
for the same chemicals. 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 has been included in this
Reporting Forms and Instructions document.
E. 3 What Is the Annual Reportable
Amount (ARA)?
For the purpose of this optional reporting
modification, the annual reportable amount (ARA)
is equal to the combined total quantities released at
the facility (including disposed of within the
facility), treated at the facility (as represented by
amounts destroyed or converted by treatment
processes), recovered at the facility as a result of
recycling operations, combusted for the purpose of
energy recovery at the facility, and amounts
transferred from the facility to off-site locations for
the purpose of recycling, energy recovery,
treatment, and/or disposal. These quantities
correspond to the sum of amounts reportable for
data elements on EPA Form R (EPA Form 9350-1;
Rev. 10/09) as Part II column B of section 8, data
elements 8.1 (quantity released), 8.2 (quantity used
for energy recovery on-site), 8.3 (quantity used for
energy recovery off-site), 8.4 (quantity recycled
onsite), 8.5 (quantity recycled off-site), 8.6 (quantity
treated on-site), and 8.7 (quantity treated off-site).
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Facility Eligibility Determination for Alternate Threshold
and for Reporting on TRI Form A Certification Statement
E.4 Recordkeeping
Each owner or operator who determines that they
are eligible, and wishes to apply the alternate
threshold to a particular chemical, must retain
records substantiating this determination for a
period of three years from the date of the submission
of the Form A. These records must include
sufficient documentation to support calculations as
well as the calculations made by the facility that
confirm their eligibility for each chemical for which
the alternate threshold was applied.
A facility that fits within the category description,
and manufactures, processes or otherwise uses no
more than one million pounds of an EPCRA Section
313 chemical annually, and whose owner/operator
elects to take advantage of the alternate threshold, is
not considered an EPCRA Section 313 covered
facility for that chemical for the purpose of
submitting a Form R. This determination may
provide further regulatory relief from other federal
or state regulations that apply to facilities on the
basis of their EPCRA Section 313 reporting status.
A facility will need to reference other applicable
regulations to determine if their actual requirements
may be affected by this reporting modification.
E.5 Multi-establishment Facilities
For the purposes of using Form A, the facility must
also make its determination based upon the entire
facility's operations including all of its
establishments (see 59 FR 61488 for greater detail).
If the facility as a whole is able to take advantage of
the alternate threshold, a single Form A is required.
The eligibility to submit a Form A must be made on
a whole facility determination. Thus, all of the
information necessary to make the determination
must be assembled to the facility level.
E.6 Trade Secrets
When making a trade secret claim on a Form A
submission, EPA is requiring that a facility submit a
unique Form A for each EPCRA Section 313
chemical meeting the conditions of the alternate
threshold. Facilities may assert a trade secrecy claim
for a chemical identity on the Form A as on the
Form R. Reports submitted on a per chemical basis
protect against the disclosure of trade secrets. Form
As with trade secrecy claims, like Form Rs with
similar claims, will be separately handled upon
receipt to protect against disclosure. Commingling
trade secret chemical identities with non-trade secret
chemical identities on the same submission
increases the risk of disclosure.
Do not submit
trade secret reports electronically.
E. 7 Metals and Metal Category
Compounds
For metal category compounds, the amount applied
toward the ARA is the amount of parent metal waste
that is reported on Form R, but the thresholds apply
to the amount of metal category compounds
manufactured, processed, or otherwise used. For
Form A certification involving both listed parent
metals and associated metal compounds, the one
million pound alternate threshold must be applied
separately to the listed parent metal and the
associated metal compound(s). Threshold
determinations must be made independently for
each because they are separately listed EPCRA
Section 313 chemicals.
• If the threshold is exceeded for the listed parent
metal but not the associated metal category
compounds, then the releases of metal reported
on Form R for the parent metal need not include
the releases from the metal category
compounds.
• If both the parent metal and the associated metal
compounds exceed the alternate threshold, then
the facility has the option of filing one Form R
for both, using the metal category compound
name and reporting total releases based on
parent metal content.
• If neither the parent metal nor the associated
metal compounds exceed the alternate threshold,
then the facility must use a separate listing on
Form A for each, since the reporting thresholds
must be applied to each listed parent metal and
all compounds in the associated compound
category. EPA believes it is appropriate to make
the distinction between filing the Form R and
Form A because the Form R accounts for
amounts of metal released or otherwise
managed and Form A verifies that the alternate
threshold for each listed chemical or chemical
category has not been exceeded.
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Facility Eligibility Determination for Alternate Threshold
and for Reporting on TRI Form A Certification Statement
Similarly, separate listings on Form A must be
submitted for all other listed chemicals even if EPA
allows one listing on Form R to be filed for two or
more listed chemicals (e.g., o-xylene, p-xylene and
xylene (mixed isomers)). For example, if a facility
processes in three separate process streams, xylene
(mixed isomers), o-xylene, and p-xylene, and
exceeds the conditions of the alternate threshold for
each of these listed substances, the facility may
combine the appropriate information on the o-
xylene, p-xylene, and xylene (mixed isomers) into
one Form R, but cannot combine the reports into
one listing on Form A.
Facilities that process o-xylene, p-xylene, and
xylene (mixed isomers) in separate process streams
and do not exceed the conditions of the alternate
threshold for one or more of the compounds may
submit a separate Form A for each of the forms of
xylene meeting the alternate threshold and report on
Form R for those forms that do not. Similar to
reporting on the parent metals and their associated
category compounds described above, facilities that
separately process all types (i.e., isomers) of xylene
with individual activity levels within the conditions
of the alternate threshold should file a separate Form
A for each type of xylene.
Beginning with the 1998 reporting year, facilities
may enter as many chemicals as are eligible on a
single Form A Certification Statement.
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Instructions for Completing TRIFormA Certification Statement
F. Instructions for Completing
TRI Form A Certification
Statement
The following instructions provide information on
how to enter data on a Form A. Some data entry
fields of a Form A are done differently using the
TRI's electronic reporting tool called TRI-MEweb
than on a hard-copy paper form. TRI-MEweb also
has automatic data quality tools that will assist users
to enter valid data on their Form R and detect any
errors on a Form A. This is why TRI-MEweb is
EPA's preferred method to submit TRI data on a
Form A Certification Statement.
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 2012 must be submitted on or before July 1,
2013.
Section 2. Trade Secret Information
2.1 Are you claiming the EPCRA Section 313
chemical identified on Page 3 a trade
secret?
If facilities wish to report more than one eligible
chemical on the same Form A, then they are not able
to make trade secrecy claims. Any trade secrecy
claims should be made on a separate form, and then
the process is the same as using the Form R and as
described in the following instructions.
The specific identity of the EPCRA Section 313
chemical being reported in Part II, Section 1, may be
designated as a trade secret. If you are making a
trade secret claim, mark "yes" and proceed to
Section 2.2. Only check "yes" if you manufacture,
process, or otherwise use the EPCRA Section 313
chemical whose identity is a trade secret. (See Page
3 of these instructions for specific information on
trade secrecy claims.) If you checked "no," proceed
to Section 3; do not answer Section 2.2.
2.2 If "yes" in 2.1, is this copy sanitized or
unsanitized?
You should check "sanitized" if this copy of the
report is the public version that does not contain the
EPCRA Section 313 chemical identity but does
contain a generic name that is structurally
descriptive in its place, and you have claimed the
EPCRA Section 313 chemical identity trade secret
in Part I, Section 2.1. Otherwise, check
"unsanitized."
Section 3. Certification
The Form A 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 Form
A. Each report must contain an original signature.
Unlike the certification statement contained on
Form R, the certification statement provided on the
Alternate Threshold Form A pertains to the facility's
eligibility of having met the conditions as described
in 40 CFR Section 372.27. You should print or type
in the space provided the name and title of the
person who signs the statement. This certification
statement applies to all the information supplied on
the form and should be signed only after the form
has been completed. Failure to certify submissions
will lead to a Notice of Non-Compliance. Please
see Appendix C.2 Levels of Errors Identified in
eFDPs.
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Instructions for Completing TRIFormA Certification Statement
Section 4. Facility Identification
4.1 Facility Name, Location, TRI Facility
Identification Number and Tribal
Country Name
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, three digit tribal code, if
applicable, 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 the mailing address is outside of
the US, include the FIPS country code, which may
be found in Table IV.
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-MEweb. "NA" or
"None" are not acceptable entries. TRI-MEweb
provides a drop-down menu for the county name,
including city districts and parish names.
If your facility is located in Indian country as
defined by 18 USC §1151, you must enter the three
digit Bureau of Indian Affairs (BIA) tribal code in
the "City/County/Tribe/State/ZIP code" field. The
BIA tribal codes are listed in Table V of the RFI.
Facilities using TRI-MEweb to complete their forms
will be asked if they are located within tribal lands
and, upon answering "yes", be taken to a look up
table to determine the correct BIA code.
If your facility is not located in Indian country as
defined by 18 USC §1151, you must enter only the
city, county (as applicable), state and ZIP code.
EPA will provide a default blank space for BIA
code upon submitting the report to the data
processing center. Facilities using TRI-MEweb to
complete their forms will be asked if they are
located within tribal lands and, upon answering
"no", a default blank field will be entered for the
tribal code field.
If you have submitted a 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,
complete Section 4. If you do not know your TRI
Facility Identification Number, contact the CDX
Help Desk toll free at 1-888-890-1995. If your
facility has moved, do not enter your TRI facility
identification number, you should enter "New
Facility."
The TRI Facility Identification Number is
established by the first Form R submitted by a
facility at a particular location. This identification
number is retained by the facility even if the facility
changes name, ownership, production processes,
SIC or NAICS codes, etc. This identification
number will stay with this location. If a new facility
moves to this location it should use this TRI Facility
Identification Number. Establishments of a facility
that report separately should use the TRI Facility
Identification Number of the facility.
Location information for a facility that has
previously submitted data to EPA.
If your facility has submitted a Form A in previous
reporting years, and is planning to submit another
Form A, a TRI Facility Identification Number
(TRIFID) has been already been assigned to your
facility. If you know your TRIFID, you should
complete Form A Section 4. If you do not know
your TRI Facility Identification Number, you should
visit the TRI Web page at http://www.epa.gov/tri for
more information or contact your Regional TRI
Program representative, or utilize Envirofacts on the
Web to look up the address or facility name
http ://www. epa. gov/enviro and retrieve your
assigned TRIFID.
Location information for a facility that has
previously submitted data to EPA, but has
changed physical location.
Hard-copy paper Form A Certification Statement:
If your facility has moved, do not enter your
previously assigned TRI Facility Identification
Number (TRIFID), enter "New Facility". If you are
filing a separate Form A for each establishment at
your facility, you should use the same TRIFID for
each establishment. You can also utilize Envirofacts
on the Web to look up the address or facility name
http ://www. epa. gov/enviro if you are uncertain if a
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Instructions for Completing TRIFormA Certification Statement
TRIFID has been assigned to your new facility's
location.
TRI-MEweb: If your facility has moved, you will
need to request a new TRIFID to be assigned to
your facility, add a new facility account to TRI-
MEweb and chose to report as a new reporting
facility. TRI-MEweb will automatically generate a
new TRIFID to your facility. The TRIFID assigned
to your new reporting facility should be used in all
future reporting of TRI data.
Location information for a facility that has
changed ownership, but has not changed physical
location.
The TRIFID is established by the first Form A
submitted by a facility at a particular location. Only
a change in address warrants filing as a new facility;
otherwise, the TRIFID is retained by the facility
even if the facility changes name, ownership,
production processes, NAICS codes, etc.
Hard-copy paper Form A: The TRIFID
identification number will stay with the physical
location, even if change of ownership occurs. If a
new facility unit moves to this location it should use
the TRIFID assigned to location. Establishments of
a facility (facilities that report by part) that report
separately should use the TRIFID assigned the
primary facility's location.
TRI-MEweb: If your facility has changed
ownership during the reporting year, the facility
does not require a new TRIFID. TRI-MEweb can be
used to change facility information due to change of
ownership. TRI-MEweb also assists facilities and
their establishments that report by part.
Location reporting TRI releases for the first time
to EPA.
Hard-copy paper Form A Certification Statement:
You should enter "New Facility" in the space for the
TRI Facility Identification number if this is your
first submission.
TRI-MEweb: If your facility is reporting for the
first time, upon creating your CDX account and
adding the TRI-MEweb application, you will be
prompt to add a new facility account into TRI-
MEweb. TRI-MEweb will automatically generate a
new TRIFID to your facility. The TRIFID assigned
to your new reporting facility should be used in all
future reporting of TRI data.
4.2 Federal Facility Designation
Executive Order 13423 directs federal facilities to
comply with Right-To-Know Laws and Pollution
Prevention Requirements. Please indicate in 4.2c. if
the reporting facility is a federal facility or in 4.2d 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.
4.3 Technical Contact
Enter the name and telephone number (including
area code) of a technical representative whom EPA,
state, or tribal 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
the 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 published for
their review.
If the technical contact does not have an email
address you should enter NA. This contact person
does not have to be the same person who prepares
the report or signs the Form A and does not
necessarily need to be someone at the location of the
reporting facility. However, this person should be
familiar with the details of the report so that he or
she can answer questions about the information
provided.
4.4 Public Contact
Enter the name and telephone number (including
area code) of a person who can respond to questions
from the public about the form. You should also
enter an e-mail address for this person. If you
choose to designate the same person as both the
Technical and the Public Contact, or you do not
have a Public Contact, you may enter "Same as
Section 4.3" in this space. This contact person does
not have to be the same person who prepares the
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Instructions for Completing TRIFormA Certification Statement
form or signs the Certification Statement and does
not necessarily need to be someone at the location of
the reporting facility.
4.5 North American Industry Classification
System (NAICS) Code
Enter the appropriate six-digit North American
Industry Classification System (NAICS) Code that
is the primary NAICS Code for your facility in
Section 4.5(a). (Use 2007 NAICS codes.) Enter any
other applicable NAICS for your facility in 4.5 (b)-
(f). If you do not know your NAICS code, consult
the 2007 NAICS Manual (see Section B.2 of these
instructions for ordering information) or check the
SIC to NAICS crosswalk tables at
http ://www.census. gov.
The North American Industry Classification System
(NAICS) is the economic classification system that
replaced the 1987 SIC code system. A Federal
Register notice was published on June 6, 2006 (71
FR 32464) adopting NAICS codes for TRI
reporting. A subsequent Federal Register notice was
published on June 9, 2008 (73 FR 32466) to
incorporate 2007 OMB revisions and other
corrections to the NAICS codes used for TRI
Reporting.
4.6 Dun & Bradstreet Number(s)
Enter the nine digit number assigned by 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 by calling 1-888-
814-1435 or visiting this website:
https ://www. dnb .com/product/dlw/form_cc4 .htm.
If a facility does not subscribe to the D&B service, a
number can be obtained, toll free at 1-800-234-3867
(8:00 AM to 6:00 PM, Local Time) or on the Web at
http://www.dnb.com. If none of your establishments
has been assigned a D&B number, you should enter
NA in box (a). If only some of your establishments
have been assigned Dun & Bradstreet numbers,
enter those numbers in Part I, Section 4.6.
Section 5.
Parent Company
Information
You must provide information on your parent
company. For TRI Reporting purposes, your parent
company is as the highest level company, located in
the United States, that directly owns at least 50
percent of the voting stock of your company. If
there is no higher level U.S. company, select the
"No U.S. Parent Company parent (for TRI reporting
purposes)" check box. 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
there is no higher level U.S. company, select the
"No U.S. Parent Company (for TRI reporting
purposes)" check box.
5.2 Parent Company's Dun & Bradstreet
Number
Enter the 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 or you may call 1-888-814-1435 or
visit this website:
https ://www. dnb .com/product/dlw/form_cc4 .htm.
If your parent company does not have a D&B
number, you should check the NA box.
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Instructions for Completing TRIFormA 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 E.7
for these guidelines.
Section 1. Toxic Chemical Identity
(Important: DO NOT complete this section if you
completed Section 2 of Part II below.)
1.1 CAS Number
Enter the Chemical Abstracts Service (CAS)
registry number in Section 1.1 exactly as it appears
in Table II of these instructions for the chemical
being reported. CAS numbers are cross-referenced
with an alphabetical list of chemical names in
Table II. If you are reporting one of the EPCRA
Section 313 chemical categories (e.g., chromium
compounds), you should enter the applicable
category code in the CAS number space. EPCRA
Section 313 chemical category codes are listed
below and can also be found in Table He and
Appendix B.I.
EPCRA Section 313 Chemical Category Codes:
NO 10 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N150 Dioxin and dioxin-like compounds*
N171 Ethylenebisdithiocarbamic acid, salts and
esters (EBDCs)
N230 Certain glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N503 Nicotine and salts
N511 Nitrate compounds (water dissociable;
reportable only when in aqueous solution)
N575 Polybrominated biphenyls (PBBs)
N583 Polychlorinated alkanes (C10 to C13)
N590 Polycyclic aromatic compounds (PACs)
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N770 Vanadium compounds
N874 Warfarin and salts
N982 Zinc compounds
* Facilities cannot take the alternate threshold for
chemicals and chemical categories listed as PBT
chemicals.
If you are making a trade secret claim, you must
report the specific EPCRA Section 313 chemical
identity on your unsanitized Form A and
unsanitized substantiation form. Do not report the
name of the EPCRA Section 313 chemical on your
sanitized Form A or sanitized substantiation form.
Include a generic name that is structurally
descriptive in Part II, Section 1.3 of your sanitized
Form A.
1.2 EPCRA Section 313 Chemical or
Chemical Category Name
Enter the name of the EPCRA Section 313
chemical or chemical category exactly as it appears
in Table II. If the EPCRA Section 313 chemical
name is followed by a synonym in (parentheses),
report the chemical by the name that directly
follows the CAS number (i.e., not the synonym). If
the EPCRA Section 313 chemical identity is
actually a product trade name (e.g., dicofol), the
Chemical Abstracts 9th Collective Index name is
listed below it in brackets. You may report either
name in this case.
Do not list the name of a chemical that does not
appear in Table II, such as individual members of
an EPCRA Section 313 chemical category. For
example, if you use silver chloride, do not report
silver chloride with its CAS number. Report this
chemical as "silver compounds" with its category
code N740.
If you are making a trade secret claim, you must
report the specific EPCRA Section 313 chemical
identity on your unsanitized Form A and
unsanitized substantiation form. Do not report the
name of the EPCRA Section 313 chemical on your
sanitized Form A or sanitized substantiation form.
Include a generic name in Part II, Section 1.3 of
your sanitized Form A.
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1.3 Generic Chemical Name
Complete Section 1.3 only if you are claiming the
specific EPCRA Section 313 chemical identity of
the EPCRA Section 313 chemical as a trade secret
and have marked the trade secret block in Part I,
Section 2.1 on Page 1 of Form A. Enter a generic
chemical name that is descriptive of the chemical
structure. You should limit the generic name to
seventy characters (e.g., numbers, letters, spaces,
punctuation) or less. Do not enter mixture names in
Section 1.3; see Section 2 below.
In house plant codes and other substitute names
that are not structurally descriptive of the EPCRA
Section 313 chemical identity being withheld as a
trade secret are not acceptable as a generic name.
The generic name must appear on both sanitized
and unsanitized Form A, and the name must be the
same as that used on your substantiation forms.
Section 2. Mixture Component
Identity
Report the generic name provided to you by your
supplier in this section if your supplier is claiming
the chemical identity proprietary or trade secret.
Do not answer "yes" in Part I, Section 2.1 on Page
1 of the form if you complete this section. You do
not need to supply trade secret substantiation forms
for this EPCRA Section 313 chemical because it is
your supplier who is claiming the chemical identity
a trade secret.
2.1 Generic Chemical Name Provided by
Supplier
Enter the generic chemical name in this section
only if the following three conditions apply:
1. You determine that the mixture contains an
EPCRA Section 313 chemical but the only
identity you have for that chemical is a
generic name;
2. You know either the specific concentration of
that EPCRA Section 313 chemical component
or a maximum or average concentration level;
and
3. You multiply the concentration level by the
total annual amount of the whole mixture
processed or otherwise used and determine
that you meet the process or otherwise use
threshold for that single, generically identified
mixture component.
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Index
Index
Ancillary or other use, 43
article component, 42
byproduct, 42
Catastrophic Events, 72, 73
CDX, 10, 89
chemical processing aid, 42
Coal Extraction Activities Exemption, 24
Coincidental Manufacture, 15, 16
Container Residue, 56
De Minimis Exemption, 20
Discharges to Receiving Streams or Water Bodies,
46
Disposal to Land, 47
Dun & Bradstreet, 39, 91
Energy Recovery, 58, 61, 65, 66, 68
EPA Identification Number, 53
EPCRA, hi, 1, 5, 6, 8, 10, 11, 12, 13, 14, 15, 16,
17, 18, 19, 20, 21, 22, 24, 25, 26, 27, 28, 29, 30,
31, 32, 33, 34, 35, 36, 38, 39, 40, 41, 42, 43, 44,
45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57,
58, 61, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73,
74, 75, 76, 79, 80, 86, 88, 89, 92, 93
Facility Identification, 88
Form A, 85
formulation component, 42
Full-Time Employee, 11
Import, 42
impurity, 42
Laboratory Activities Exemption, 24
Manufacture, 15, 17, 22, 24, 42
manufacturing aid, 43
Metal Category Compounds, 28
Metal Mining Overburden Exemption, 24
Mixture Component Identity, 31
Nitrate Compounds, 30
On-Site Recycling Codes, 66
Other Disposal, 48
Other Surface Impoundments, 48
Otherwise Use, 15, 17, 19, 22, 42
PBT, 12, 17, 18, 20, 21, 22, 25, 26, 27, 29, 32, 33,
34, 35, 41, 44, 45, 46, 48, 52, 53, 54, 55, 66, 68,
69
Process, 6, 15, 17, 22, 42
Produce, 42
Production Ratio, 75
RCRA Subtitle C landfills, 47
RCRA Subtitle C Surface Impoundments, 48
reactant, 42
Repackaging, 42
Reporting Year, 32, 33, 34, 35, 69
sale/distribution, 42
Source Reduction, 68, 79
Stormwater Runoff, 52
Surface Impoundments, 48
Technical Contact, 38, 90
Threshold Determinations, 25
Total Transfers, 54
Trade Secret, 5, 36, 88
TRI-ME, 89
Underground Injection, 47, 59
Waste Treatment Codes, 64
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Table I. NAICS Codes
1.1 NAICS codes that
correspond to SIC codes 20
through 39:
113310 Logging
311 Food Manufacturing
3111 Animal Food Manufacturing
31111 Animal Food Manufacturing
311111 Dog and Cat Food Manufacturing
311119 Other Animal Food Manufacturing (except
facilities primarily engaged in Custom Grain
Grinding for Animal Feed)
3112 Grain and Oilseed Milling
31121 Flour Milling and Malt
Manufacturing
311211 Flour Milling
311212 Rice Milling
311213 Malt Manufacturing
31122 Starch and Vegetable Fats and
Oils Manufacturing
311221 Wet Corn Milling
311222 Soybean Processing
311223 Other Oilseed Processing
311225 Fats and Oils Refining and Blending
31123 Breakfast Cereal Manuf.
311230 Breakfast Cereal Manufacturing
3113 Sugar and Confectionery
Product Manufacturing
31131 Sugar Manufacturing
311311 Sugarcane Mills
311312 Cane Sugar Refining
311313 Beet Sugar Manufacturing
31132 Chocolate and Confectionery
Manufacturing from Cacao
Beans
311320 Chocolate and Confectionery Manufacturing
from Cacao Beans
31133 Confectionery Manufacturing
from Purchased Chocolate
311330 Confectionery Manufacturing from Purchased
Chocolate (except facilities primarily
engaged in the retail sale of candy, nuts,
popcorn and other confections not for
immediate consumption made on the
premises)
31134 Nonchocolate Confectionery
Manufacturing
311340 Nonchocolate Confectionery Manufacturing
(except facilities primarily engaged in the
retail sale of candy, nuts, popcorn and other
confections not for immediate consumption
made on the premises)
3114 Fruit and Vegetable
Preserving and Specialty Food
Manufacturing
31141 Frozen Food Manufacturing
311411 Frozen Fruit, Juice, and Vegetable
Manufacturing
311412 Frozen Specialty Food Manufacturing
31142 Fruit and Vegetable Canning,
Pickling and Drying
311421 Fruit and Vegetable Canning
311422 Specialty Canning
311423 Dried and Dehydrated Food Manufacturing
3115 Dairy Product Manufacturing
31151 Dairy Product (except Frozen)
Manufacturing
311511 Fluid Milk Manufacturing
311512 Creamery Butter Manufacturing
311513 Cheese Manufacturing
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Table I. NAICS Codes
311514 Dry, Condensed, and Evaporated Dairy
Product Manufacturing
31152 Ice Cream and Frozen Dessert
Manufacturing
311520 Ice Cream and Frozen Dessert Manufacturing
3116 Animal Slaughtering and
Processing
31161 Animal Slaughtering and
Processing
311611 Animal (except Poultry) Slaughtering (except
for facilities primarily engaged in Custom
Slaughtering for individuals)
311612 Meat Processed from Carcasses [except for
facilities primarily engaged in the cutting up
and resale of purchased fresh carcasses for the
trade (including boxed beef)]
311613 Rendering and Meat Byproduct Processing
311615 Poultry Processing
3117 Seafood Product Preparation
and Packaging
311711 Seafood Canning
311712 Fresh and Frozen Seafood Processing
3118 Bakeries and Tortilla
Manufacturing
31181 Bread and Bakery Product
Manufacturing
311812 Commercial Bakeries
311813 Frozen Cakes, Pies, and Other Pastries
Manufacturing
31182 Cookie, Cracker, and Pasta
Manufacturing
311821 Cookie and Cracker Manufacturing
311822 Flour Mixes and Dough Manufacturing from
Purchased Flour
311823 Dry Pasta Manufacturing
31183 Tortilla Manufacturing
311830 Tortilla Manufacturing
3119 Other Food Manufacturing
31191 Snack Food Manufacturing
311911 Roasted Nuts and Peanut Butter
Manufacturing
311919 Other Snack Food Manufacturing
31192 Coffee and Tea Manufacturing
311920 Coffee and Tea Manufacturing
31193 Flavoring Syrup and
Concentrate Manufacturing
311930 Flavoring Syrup and Concentrate
Manufacturing
31194 Seasoning and Dressing
Manufacturing
311941 Mayonnaise, Dressing, and Other Prepared
Sauce Manufacturing
311942 Spice and Extract Manufacturing
31199 All Other Miscellaneous Food
Manufacturing
311991 Perishable Prepared Food Manufacturing
311999 All Other Miscellaneous Food Manufacturing
312 Beverage and Tobacco
Product Manufacturing
3121 Beverage Manufacturing
31211 Soft Drink and Ice
Manufacturing
312111 Soft Drink Manufacturing
312112 Bottled Water Manufacturing (except
facilities primarily engaged in bottling
mineral or spring water)
312113 Ice Manufacturing
31212 Breweries
312120 Breweries
31213 Wineries
312130 Wineries
31214 Distilleries
Toxics Release Inventory Reporting Forms and Instructions
1-2
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Table I. NAICS Codes
312140 Distilleries
3122 Tobacco Manufacturing
31221 Tobacco Stemming and
Red ry ing
312210 Tobacco Stemming and Redrying
31222 Tobacco Product
Manufacturing
312221 Cigarette Manufacturing
312229 Other Tobacco Product Manufacturing
(except for facilities primarily engaged in
providing Tobacco Sheeting Services)
313 Textile Mills
3131 Fiber, Yarn, and Thread Mills
31311 Fiber, Yarn, and Thread Mills
313111 Yarn Spinning Mills
313112 Yarn Texturizing, Throwing, and Twisting
Mills
313113 Thread Mills
3132 Fabric Mills
31321 Broadwoven Fabric Mills
313210 Broadwoven Fabric Mills
31322 Narrow Fabric Mills and
Schiffli Machine Embroidery
313221 Narrow Fabric Mills
313222 Schiffli Machine Embroidery
31323 Nonwoven Fabric Mills
313230 Nonwoven Fabric Mills
31324 Knit Fabric Mills
313241 Weft Knit Fabric Mills
313249 Other Knit Fabric and Lace Mills
3133 Textile and Fabric Finishing
and Fabric Coating Mills
31331 Textile and Fabric Finishing
Mills
313311
313312
31332
313320
314
3141
31411
314110
31412
314121
314129
3149
31491
314911
314912
31499
314991
314992
314999
315
3151
31511
Broadwoven Fabric Finishing Mills (except
facilities primarily engaged in converting
broadwoven piece goods and broadwoven
textiles and facilities primarily engaged in
sponging fabric for tailors and dressmakers)
Textile and Fabric Finishing (except
Broadwoven Fabric) Mills (except facilities
primarily engaged in converting narrow
woven textiles and narrow woven piece
goods)
Fabric Coating Mills
Fabric Coating Mills
Textile Product Mills
Textile Furnishing Mills
Carpet and Rug Mills
Carpet and Rug Mills
Curtain and Linen Mills
Curtain and Drapery Mills (except facilities
primarily engaged in making custom drapery
for retail sale)
Other Household Textile Product Mills
(except facilities primarily engaged in making
custom drapery for retail sale)
Other Textile Product Mills
Textile Bag and Canvas Mills
Textile Bag Mills
Canvas and Related Product Mills
All Other Textile Product
Mills
Rope, Cordage, and Twine Mills
Tire Cord and Tire Fabric Mills
All Other Miscellaneous Textile Product
Mills (except facilities engaged in binding
carpets and rugs for the trade, carpet cutting
and binding, and embroidering on textile
products (except apparel) for the trade)
Apparel Manufacturing
Apparel Knitting Mills
Hosiery and Sock Mills
Toxics Release Inventory Reporting Forms and Instructions
1-3
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Table I. NAICS Codes
315111 Sheer Hosiery Mills
315119 Other Hosiery and Sock Mills
31519 Other Apparel Knitting Mills
315191 Outerwear Knitting Mills
315192 Underwear and Nightwear Knitting Mills
3152 Cut and Sew Apparel
Manufacturing
31521 Cut and Sew Apparel
Contractors
315211 Men's and Boys' Cut and Sew Apparel
Contractors
315212 Women's, Girls', and Infants' Cut and Sew
Apparel Contractors
31522 Men's and Boys' Cut and Sew
Apparel Manufacturing
315221 Men's and Boys' Cut and Sew Underwear
and Nightwear Manufacturing
315222 Men's and Boys' Cut and Sew Suit, Coat, and
Overcoat Manufacturing (except custom
tailors primarily engaged in making and
selling men's and boy's suits, cut and sewn
from purchased fabric)
315223 Men's and Boys' Cut and Sew Shirt (except
Work Shirt) Manufacturing (except custom
tailors primarily engaged in making and
selling men's and boy's dress shirts, cut and
sewn from purchased fabric)
315224 Men's and Boys' Cut and Sew Trouser,
Slack, and Jean Manufacturing
315225 Men's and Boys' Cut and Sew Work Clothing
Manufacturing
315228 Men's and Boys' Cut and Sew Other
Outerwear Manufacturing
31523 Women's and Girls' Cut and
Sew Apparel Manufacturing
315231 Women's and Girls' Cut and Sew Lingerie,
Loungewear, and Nightwear Manufacturing
315232 Women's and Girls' Cut and Sew Blouse and
Shirt Manufacturing
315233 Women's and Girls' Cut and Sew Dress
Manufacturing (except custom tailors
primarily engaged in making and selling
bridal dresses or gowns, or women's, misses'
and girls' dresses cut and sewn from
purchased fabric (except apparel contractors)
(custom dressmakers)
315234 Women's and Girls' Cut and Sew Suit, Coat,
Tailored Jacket, and Skirt Manufacturing
315239 Women's and Girls' Cut and Sew Other
Outerwear Manufacturing
31529 Other Cut and Sew Apparel
Manufacturing
315291 Infants' Cut and Sew Apparel Manufacturing
315292 Fur and Leather Apparel Manufacturing
315299 All Other Cut and Sew Apparel
Manufacturing
3159 Apparel Accessories and
Other Apparel Manufacturing
31599 Apparel Accessories and
Other Apparel Manufacturing
315991 Hat, Cap, and Millinery Manufacturing
315992 Glove and Mitten Manufacturing
315993 Men's and Boys' Neckwear Manufacturing
315999 Other Apparel Accessories and Other Apparel
Manufacturing
316 Leather and Allied Product
Manufacturing
3161 Leather and Hide Tanning
and Finishing
31611 Leather and Hide Tanning
and Finishing
316110 Leather and Hide Tanning and Finishing
3162 Footwear Manufacturing
31621 Footwear Manufacturing
316211 Rubber and Plastics Footwear Manufacturing
316212 House Slipper Manufacturing
316213 Men's Footwear (except Athletic)
Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
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Table I. NAICS Codes
316214 Women's Footwear (except Athletic)
Manufacturing
316219 Other Footwear Manufacturing
3169 Other Leather and Allied
Product Manufacturing
31699 Other Leather and Allied
Product Manufacturing
316991 Luggage Manufacturing
316992 Women's Handbag and Purse Manufacturing
316993 Personal Leather Good (except Women's
Handbag and Purse) Manufacturing
316999 All Other Leather Good Manufacturing
321 Wood Product Manufacturing
3211 Sawmills and Wood
Preservation
321113 Sawmills
321114 Wood Preservation
3212 Veneer, Plywood, and
Engineered Wood Product
Manufacturing
32121 Veneer, Plywood, and
Engineered Wood Product
Manufacturing
321211 Hardwood Veneer and Plywood
Manufacturing
321212 Softwood Veneer and Plywood
Manufacturing
321213 Engineered Wood Member (except Truss)
Manufacturing
321214 Truss Manufacturing
321219 Reconstituted Wood Product Manufacturing
3219 Other Wood Product
Manufacturing
32191 Millwork
321911 Wood Window and Door Manufacturing
321912 Cut Stock, Resawing Lumber, and Planing
321918 Other Millwork (including Flooring)
32192 Wood Container and Pallet
Manufacturing
321920 Wood Container and Pallet Manufacturing
32199 All Other Wood Product
Manufacturing
321991 Manufactured Home (Mobile Home)
Manufacturing
321992 Prefabricated Wood Building Manufacturing
321999 All Other Miscellaneous Wood Product
Manufacturing
322 Paper Manufacturing
3221 Pulp, Paper, and Paperboard
Mills
32211 Pulp Mills
322110 Pulp Mills
32212 Paper Mills
3 22121 Paper (except Newsprint) Mills
322122 Newsprint Mills
32213 Paperboard Mills
3 2213 0 Paperboard Mills
3222 Converted Paper Product
Manufacturing
32221 Paperboard Container
Manufacturing
322211 Corrugated and Solid Fiber Box
Manufacturing
322212 Folding Paperboard Box Manufacturing
322213 Setup Paperboard Box Manufacturing
322214 Fiber Can, Tube, Drum, and Similar Products
Manufacturing
322215 Nonfolding Sanitary Food Container
Manufacturing
32222 Paper Bag and Coated and
Treated Paper Manufacturing
3 22221 Coated and Laminated Packaging Paper and
Plastics Film Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
1-5
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Table I. NAICS Codes
322222 Coated and Laminated Paper Manufacturing
322223 Plastics, Foil, and Coated Paper Bag
Manufacturing
322224 Uncoated Paper and Multiwall Bag
Manufacturing
322225 Laminated Aluminum Foil Manufacturing for
Flexible Packaging Uses
322226 Surface-Coated Paperboard Manufacturing
32223 Stationery Product
Manufacturing
322231 Die-Cut Paper and Paperboard Office
Supplies
Manufacturing
322232 Envelope Manufacturing
322233 Stationery, Tablet, and Related Product
Manufacturing
32229 Other Converted Paper
Product Manufacturing
322291 Sanitary Paper Product Manufacturing
322299 All Other Converted Paper Product
Manufacturing
323 Printing and Related Support
Activities
3231 Printing and Related Support
Activities
32311 Printing
323110 Commercial Lithographic Printing
323113 Commercial Screen Printing
323114 Quick Printing (except facilities primarily
engaged in reproducing text, drawings, plans,
maps, or other copy by blueprinting,
photocopying, mimeographing, or other
methods of duplication other than printing or
microfilming (i.e., instant printing)
323115 Digital Printing
323116 Manifold Business Forms Printing
323117 Books Printing
323118 Blankbook, Looseleaf Binders, and Devices
Manufacturing
323119 Other Commercial Printing
32312 Support Activities for Printing
323121 Tradebinding and Related Work
323122 Prepress Services
324 Petroleum and Coal Products
Manufacturing
3241 Petroleum and Coal Products
Manufacturing
32411 Petroleum Refineries
324110 Petroleum Refineries
32412 Asphalt Paving, Roofing, and
Saturated Materials
Manufacturing
3 24121 Asphalt Paving Mixture and B lock
Manufacturing
324122 Asphalt Shingle and Coating Materials
Manufacturing
32419 Other Petroleum and Coal
Products Manufacturing
3 24191 Petroleum Lubricating Oil and Grease
Manufacturing
324199 All Other Petroleum and Coal Products
Manufacturing
325 Chemical Manufacturing
3251 Basic Chemical
Manufacturing
32511 Petrochemical Manufacturing
325110 Petrochemical Manufacturing
32512 Industrial Gas Manufacturing
325120 Industrial Gas Manufacturing
32513 Synthetic Dye and Pigment
Manufacturing
325131 Inorganic Dye and Pigment Manufacturing
325132 Synthetic Organic Dye and Pigment
Manufacturing
32518 Other Basic Inorganic
Chemical Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
1-6
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Table I. NAICS Codes
325181 Alkalies and Chlorine Manufacturing
325182 Carbon Black Manufacturing
325188 All Other Basic Inorganic Chemical
Manufacturing
32519 Other Basic Organic Chemical
Manufacturing
325191 Gum and Wood Chemical Manufacturing
325192 Cyclic Crude and Intermediate Manufacturing
325193 Ethyl Alcohol Manufacturing
325199 All Other Basic Organic Chemical
Manufacturing
3252 Resin, Synthetic Rubber, and
Artificial Synthetic Fibers and
Filaments Manufacturing
32521 Resin and Synthetic Rubber
Manufacturing
325211 Plastics Material and Resin Manufacturing
325212 Synthetic Rubber Manufacturing
32522 Artificial and Synthetic Fibers
and Filaments Manufacturing
325221 Cellulosic Organic Fiber Manufacturing
325222 Noncellulosic Organic Fiber Manufacturing
3253 Pesticide, Fertilizer, and Other
Agricultural Chemical
Manufacturing
32531 Fertilizer Manufacturing
325311 Nitrogenous Fertilizer Manufacturing
325312 Phosphatic Fertilizer Manufacturing
325314 Fertilizer (Mixing Only) Manufacturing
32532 Pesticide and Other
Agricultural Chemical
Manufacturing
325320 Pesticide and Other Agricultural Chemical
Manufacturing
3254 Pharmaceutical and Medicine
Manufacturing
32541 Pharmaceutical and Medicine
Manufacturing
325411 Medicinal and Botanical Manufacturing
325412 Pharmaceutical Preparation Manufacturing
325413 In-Vitro Diagnostic Substance Manufacturing
325414 Biological Product (except Diagnostic)
Manufacturing
3255 Paint, Coating, and Adhesive
Manufacturing
32551 Paint and Coating
Manufacturing
325510 Paint and Coating Manufacturing
32552 Adhesive Manufacturing
325520 Adhesive Manufacturing
3256 Soap, Cleaning Compound,
and Toilet Preparation
Manufacturing
32561 Soap and Cleaning Compound
Manufacturing
325611 Soap and Other Detergent Manufacturing
325612 Polish and Other Sanitation Good
Manufacturing
'325613 Surface Active Agent Manufacturing
32562 Toilet Preparation
Manufacturing
325620 Toilet Preparation Manufacturing
3259 Other Chemical Product and
Preparation Manufacturing
32591 Printing Ink Manufacturing
325910 Printing Ink Manufacturing
32592 Explosives Manufacturing
325920 Explosives Manufacturing
32599 All Other Chemical Product
and Preparation
Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
1-7
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Table I. NAICS Codes
325991 Custom Compounding of Purchased Resins
325992 Photographic Film, Paper, Plate, and
Chemical
Manufacturing
325998 All Other Miscellaneous Chemical Product
and Preparation Manufacturing (except
facilities primarily engaged in Aerosol can
filling on a job order or contract Basis)
326 Plastics and Rubber Products
Manufacturing
3261 Plastics Product
Manufacturing
32611 Plastics Packaging Materials
and Unlaminated Film and
Sheet Manufacturing
326111 Plastics Bag Manufacturing
326112 Plastics Packaging Film and Sheet (including
Laminated) Manufacturing
326113 Unlaminated Plastics Film and Sheet (except
Packaging) Manufacturing
32612 Plastics, Pipe, Pipe Fitting, and
Unlaminated Profile Shape
Manufacturing
326121 Unlaminated Plastics Profile Shape
Manufacturing
326122 Plastics Pipe and Pipe Fitting Manufacturing
32613 Laminated Plastics Plate,
Sheet
(except Packaging), and Shape
Manufacturing
326130 Laminated Plastics Plate, Sheet (except
Packaging), and Shape Manufacturing
32614 Polystyrene Foam Product
Manufacturing
326140 Polystyrene Foam Product Manufacturing
32615 Urethane and Other Foam
Product (except Polystyrene)
Manufacturing
326150 Urethane and Other Foam Product (except
Polystyrene) Manufacturing
32616 Plastics Bottle Manufacturing
326160 Plastics Bottle Manufacturing
32619 Other Plastics Product
Manufacturing
3 26191 Plastics Plumbing Fixture Manufacturing
326192 Resilient Floor Covering Manufacturing
326199 All Other Plastics Product Manufacturing
3262 Rubber Product
Manufacturing
32621 Tire Manufacturing
3 26211 Tire Manufacturing (except Retreading)
32622 Rubber and Plastics Hoses and
Belting Manufacturing
326220 Rubber and Plastics Hoses and Belting
Manufacturing
32629 Other Rubber Product
Manufacturing
326291 Rubber Product Manufacturing for
Mechanical Use
326299 All Other Rubber Product Manufacturing
327 Nonmetallic Mineral Product
Manufacturing
3271 Clay Product and Refractory
Manufacturing
32711 Pottery, Ceramics, and
Plumbing Fixture
Manufacturing
327111 Vitreous China Plumbing Fixture and China
and Earthenware Bathroom Accessories
Manufacturing
327112 Vitreous China, Fine Earthenware, and Other
Pottery Product Manufacturing (except
facilities primarily engaged in manufacturing
and selling pottery on site)
3 27113 Porcelain Electrical Supply Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
1-8
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Table I. NAICS Codes
32712 Clay Building Material and
Refractories Manufacturing
327121 Brick and Structural Clay Tile Manufacturing
327122 Ceramic Wall and Floor Tile Manufacturing
327123 Other Structural Clay Product Manufacturing
327124 Clay Refractory Manufacturing
327125 Nonclay Refractory Manufacturing
3272 Glass and Glass Product
Manufacturing
32721 Glass and Glass Product
Manufacturing
327211 Flat Glass Manufacturing
327212 Other Pressed and Blown Glass and
Glassware Manufacturing
327213 Glass Container Manufacturing
327215 Glass Product Manufacturing Made of
Purchased Glass
3273 Cement and Concrete Product
Manufacturing
32731 Cement Manufacturing
327310 Cement Manufacturing
32732 Ready-Mix Concrete
Manufacturing
327320 Ready-Mix Concrete Manufacturing
32733 Concrete, Pipe, Brick, and
Block Manufacturing
3273 31 Concrete Block and Brick Manufacturing
327332 Concrete Pipe Manufacturing
32739 Other Concrete Product
Manufacturing
327390 Other Concrete Product Manufacturing
3274 Lime and Gypsum Product
Manufacturing
32741 Lime Manufacturing
327410 Lime Manufacturing
32742 Gypsum Product
Manufacturing
3 27420 Gypsum Product Manufacturing
3279 Other Nonmetallic Mineral
Product Manufacturing
32791 Abrasive Product
Manufacturing
327910 Abrasive Product Manufacturing
32799 All Other Nonmetallic Mineral
Product Manufacturing
327991 Cut Stone and Stone Product Manufacturing
327992 Ground or Treated Mineral and Earth
Manufacturing
327993 Mineral Wool Manufacturing
327999 All Other Miscellaneous Nonmetallic Mineral
Product Manufacturing
331 Primary Metal Manufacturing
3311 Iron and Steel Mills and
Ferroalloy Manufacturing
33111 Iron and Steel Mills and
Ferroalloy Manufacturing
331111 Iron and Steel Mills
331112 Electrometalrurgical Ferroalloy Product
Manufacturing
3312 Steel Product Manufacturing
from Purchased Steel
33121 Iron and Steel Pipe and Tube
Manufacturing from
Purchased Steel
331210 Iron and Steel Pipe and Tube Manufacturing
from Purchased Steel
33122 Rolling and Drawing of
Purchased Steel
331221 Rolled Steel Shape Manufacturing
331222 Steel Wire Drawing
Toxics Release Inventory Reporting Forms and Instructions
1-9
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Table I. NAICS Codes
3313 Alumina and Aluminum
Production and Processing
33131 Alumina and Aluminum
Production and Processing
331311 Alumina Refining
331312 Primary Aluminum Production
331314 Secondary Smelting and Alloying of
Aluminum
331315 Aluminum Sheet, Plate, and Foil
Manufacturing
331316 Aluminum Extruded Product Manufacturing
331319 Other Aluminum Rolling and Drawing
3314 Nonferrous Metal (except
Aluminum) Production and
Processing
33141 Nonferrous Metal (except
Aluminum) Smelting and
Refining
331411 Primary Smelting and Refining of Copper
331419 Primary Smelting and Refining of Nonferrous
Metal (except Copper and Aluminum)
33142 Copper Rolling, Drawing,
Extruding and Alloying
331421 Copper Rolling, Drawing, and Extruding
331422 Copper Wire (except Mechanical) Drawing
331423 Secondary Smelting, Refining, and Alloying
of Copper
33149 Nonferrous Metal (except
Copper and Aluminum)
Rolling, Drawing, Extruding,
and Alloying
331491 Nonferrous Metal (except Copper and
Aluminum) Rolling, Drawing, and Extruding
331492 Secondary Smelting, Refining, and Alloying
of
Nonferrous Metal (except Copper and
Aluminum)
3315 Foundries
33151 Ferrous Metal Foundries
331511 Iron Foundries
331512 Steel Investment Foundries
331513 Steel Foundries (except Investment)
33152 Nonferrous Metal Foundries
331521 Aluminum Die-Casting Foundries
3 31522 Nonferrous (except Aluminum) Die-Casting
Foundries
3 31524 Aluminum Foundries (except Die-Casting)
331525 Copper Foundries (except Die-Casting)
331528 Other Nonferrous Foundries (except Die-
Casting)
332 Fabricated Metal Product
Manufacturing
3321 Forging and Stamping
33211 Forging and Stamping
332111 Iron and Steel Forging
332112 Nonferrous Forging
332114 Custom Roll Forming
332115 Crown and Closure Manufacturing
332116 Metal Stamping
332117 Powder Metallurgy Part Manufacturing
3322 Cutlery and Handtool
Manufacturing
33221 Cutlery and Handtool
Manufacturing
3 32211 Cutlery and Flatware (except Precious)
Manufacturing
332212 Hand and Edge Tool Manufacturing
3 32213 Saw Blade and Handsaw Manufacturing
332214 Kitchen Utensil, Pot, and Pan Manufacturing
3323 Architectural and Structural
Metals Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
1-10
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Table I. NAICS Codes
33231 Plate Work and Fabricated
Structural Product
Manufacturing
332311 Prefabricated Metal Building and Component
Manufacturing
332312 Fabricated Structural Metal Manufacturing
332313 Plate Work Manufacturing
33232 Ornamental and Architectural
Metal Products
Manufacturing
332321 Metal Window and Door Manufacturing
332322 Sheet Metal Work Manufacturing
332323 Ornamental and Architectural Metal Work
Manufacturing
3324 Boiler, Tank, and Shipping
Container Manufacturing
33241 Power Boiler and Heat
Exchanger Manufacturing
332410 Power Boiler and Heat Exchanger
Manufacturing
33242 Metal Tank (Heavy Gauge)
Manufacturing
332420 Metal Tank (Heavy Gauge) Manufacturing
33243 Metal Can, Box, and Other
Metal Container (Light
Gauge) Manufacturing
332431 Metal Can Manufacturing
332439 Other Metal Container Manufacturing
3325 Hardware Manufacturing
33251 Hardware Manufacturing
332510 Hardware Manufacturing
3326 Spring and Wire Product
Manufacturing
33261 Spring and Wire Product
Manufacturing
332611 Spring (Heavy Gauge) Manufacturing
332612 Spring (Light Gauge) Manufacturing
3 32618 Other Fabricated Wire Product Manufacturing
3327 Machine Shops; Turned
Product; and Screw, Nut and
Bolt Manufacturing
33271 Machine Shops
332710 Machine Shops
33272 Turned Product and Screw,
Nut and Bolt Manufacturing
3 32721 Precision Turned Product Manufacturing
332722 Bolt, Nut, Screw, Rivet, and Washer
Manufacturing
3328 Coating, Engraving, Heat
Treating, and Allied Activities
33281 Coating, Engraving, Heat
Treating, and Allied Activities
332811 Metal Heat Treating
332812 Metal Coating, Engraving (except Jewelry
and Silverware), and Allied Services to
Manufacturers
332813 Electroplating, Plating, Polishing, Anodizing,
and Coloring
3329 Other Fabricated Metal
Product Manufacturing
33291 Metal Valve Manufacturing
332911 Industrial Valve Manufacturing
332912 Fluid Power Valve and Hose Fitting
Manufacturing
332913 Plumbing Fixture Fitting and Trim
Manufacturing
332919 Other Metal Valve and Pipe Fitting
Manufacturing
33299 All Other Fabricated Metal
Product Manufacturing
332991 Ball and Roller Bearing Manufacturing
332992 Small Arms Ammunition Manufacturing
332993 Ammunition (except Small Arms)
Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
1-11
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Table I. NAICS Codes
332994 Small Arms Manufacturing
332995 Other Ordnance and Accessories
Manufacturing
332996 Fabricated Pipe and Pipe Fitting
Manufacturing
332997 Industrial Pattern Manufacturing
332998 Enameled Iron and Metal Sanitary Ware
Manufacturing
332999 All Other Miscellaneous Fabricated Metal
Product Manufacturing
333 Machinery Manufacturing
3331 Agriculture, Construction, and
Mining Machinery
Manufacturing
33311 Agricultural Implement
Manufacturing
333111 Farm Machinery and Equipment
Manufacturing
333112 Lawn and Garden Tractor and Home Lawn
and Garden Equipment Manufacturing
33312 Construction Machinery
Manufacturing
333120 Construction Machinery Manufacturing
33313 Mining and Oil and Gas Field
Machinery Manufacturing
333131 Mining Machinery and Equipment
Manufacturing
333132 Oil and Gas Field Machinery and Equipment
Manufacturing
3332 Industrial Machinery
Manufacturing
33321 Sawmill and Woodworking
Machinery Manufacturing
333210 Sawmill and Woodworking Machinery
Manufacturing
33322 Plastics and Rubber Industry
Machinery Manufacturing
333220 Plastics and Rubber Industry Machinery
Manufacturing
33329 Other Industrial Machinery
Manufacturing
333291 Paper Industry Machinery Manufacturing
333292 Textile Machinery Manufacturing
333293 Printing Machinery and Equipment
Manufacturing
333294 Food Product Machinery Manufacturing
333295 Semiconductor Machinery Manufacturing
333298 All Other Industrial Machinery
Manufacturing
3333 Commercial and Service
Industry Machinery
Manufacturing
33331 Commercial and Service
Industry Machinery
Manufacturing
333311 Automatic Vending Machine Manufacturing
333312 Commercial Laundry, Drycleaning, and
Pressing Machine Manufacturing
333313 Office Machinery Manufacturing
333314 Optical Instrument and Lens Manufacturing
333315 Photographic and Photocopying Equipment
Manufacturing
333319 Other Commercial and Service Industry
Machinery Manufacturing
3334 Ventilation, Heating, Air-
Conditioning, and Commercial
Refrigeration
33341 Equipment Manufacturing
Ventilation, Heating, Air-
Conditioning, and Commercial
Refrigeration Equipment
Manufacturing
333411 Air Purification Equipment Manufacturing
333412 Industrial and Commercial Fan and Blower
Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
1-12
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Table I. NAICS Codes
333414 Heating Equipment (except Warm Air
Furnaces) Manufacturing
333415 Air-Conditioning and Warm Air Heating
Equipment and Commercial and Industrial
Refrigeration Equipment Manufacturing
3335 Metalworking Machinery
Manufacturing
33351 Metalworking Machinery
Manufacturing
333511 Industrial Mold Manufacturing
333512 Machine Tool (Metal Cutting Types)
Manufacturing
333513 Machine Tool (Metal Forming Types)
Manufacturing
333514 Special Die and Tool, Die Set, Jig, and
Fixture Manufacturing
333515 Cutting Tool and Machine Tool Accessory
Manufacturing
333516 Rolling Mill Machinery and Equipment
Manufacturing
333518 Other Metalworking Machinery
Manufacturing
3336 Engine, Turbine, and Power
Transmission Equipment
Manufacturing
33361 Engine, Turbine, and Power
Transmission Equipment
Manufacturing
333611 Turbine and Turbine Generator Set Units
Manufacturing
333612 Speed Changer, Industrial High-Speed Drive,
and Gear Manufacturing
333613 Mechanical Power Transmission Equipment
Manufacturing
333618 Other Engine Equipment Manufacturing
3339 Other General Purpose
Machinery Manufacturing
33391 Pump and Compressor
Manufacturing
333911 Pump and Pumping Equipment
Manufacturing
333912 Air and Gas Compressor Manufacturing
333913 Measuring and Dispensing Pump
Manufacturing
33392 Material Handling Equipment
Manufacturing
333921 Elevator and Moving Stairway Manufacturing
333922 Conveyor and Conveying Equipment
Manufacturing
333923 Overhead Traveling Crane, Hoist, and
Monorail System Manufacturing
333924 Industrial Truck, Tractor, Trailer, and Stacker
Machinery Manufacturing
33399 All Other General Purpose
Machinery Manufacturing
333991 Power-Driven Handtool Manufacturing
333992 Welding and Soldering Equipment
Manufacturing
333993 Packaging Machinery Manufacturing
333994 Industrial Process Furnace and Oven
Manufacturing
333995 Fluid Power Cylinder and Actuator
Manufacturing
333996 Fluid Power Pump and Motor Manufacturing
333997 Scale and Balance Manufacturing
333999 All Other Miscellaneous General Purpose
Machinery Manufacturing
334 Computer and Electronic
Product Manufacturing
3341 Computer and Peripheral
Equipment Manufacturing
33411 Computer and Peripheral
Equipment Manufacturing
334111 Electronic Computer Manufacturing
3341 12 Computer Storage Device Manufacturing
334113 Computer Terminal Manufacturing
334119 Other Computer Peripheral Equipment
Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
1-13
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Table I. NAICS Codes
3342 Communications Equipment
Manufacturing
33421 Telephone Apparatus
Manufacturing
334210 Telephone Apparatus Manufacturing
33422 Radio and Television
Broadcasting and Wireless
Communications Equipment
Manufacturing
334220 Radio and Television Broadcasting and
Wireless Communications Equipment
Manufacturing
33429 Other Communications
Equipment Manufacturing
334290 Other Communications Equipment
Manufacturing
3343 Audio and Video Equipment
Manufacturing
33431 Audio and Video Equipment
Manufacturing
334310 Audio and Video Equipment Manufacturing
3344 Semiconductor and Other
Electronic Component
Manufacturing
33441 Semiconductor and Other
Electronic Component
Manufacturing
334411 Electron Tube Manufacturing
334412 Bare Printed Circuit Board Manufacturing
334413 Semiconductor and Related Device
Manufacturing
334414 Electronic Capacitor Manufacturing
334415 Electronic Resistor Manufacturing
334416 Electronic Coil, Transformer, and Other
Inductor Manufacturing
334417 Electronic Connector Manufacturing
334418 Printed Circuit Assembly (Electronic
Assembly) Manufacturing
3 34419 Other Electronic Component Manufacturing
3345 Navigational, Measuring,
Electromedical, and Control
Instruments Manufacturing
33451 Navigational, Measuring,
Electromedical, and Control
Instruments Manufacturing
334510 Electromedical and Electrotherapeutic
Apparatus Manufacturing
334511 Search, Detection, Navigation, Guidance,
Aeronautical, and Nautical System and
Instrument Manufacturing
334512 Automatic Environmental Control
Manufacturing for Residential, Commercial,
and Appliance Use
334513 Instruments and Related Products
Manufacturing for Measuring, Displaying,
and Controlling Industrial Process Variables
334514 Totalizing Fluid Meter and Counting Device
Manufacturing
334515 Instrument Manufacturing for Measuring and
Testing Electricity and Electrical Signals
334516 Analytical Laboratory Instrument
Manufacturing
334517 Irradiation Apparatus Manufacturing
334518 Watch, Clock, and Part Manufacturing
334519 Other Measuring and Controlling Device
Manufacturing
3346 Manufacturing and
Reproducing Magnetic and
Optical Media
33461 Manufacturing and
Reproducing Magnetic and
Optical Media
334612 Prerecorded Compact Disc (except Software),
Tape, and Record Reproducing (except
facilities primarily engaged in mass
reproducing pre-recorded Video Cassettes,
and mass reproducing Video tape or disk)
3 34613 Magnetic and Optical Recording Media
Manufacturing
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Table I. NAICS Codes
335 Electrical Equipment,
Appliance, and Component
Manufacturing
3351 Electric Lighting Equipment
Manufacturing
3351 1 Electric Lamp Bulb and Part
ft
Manufacturing
335110 Electric Lamp Bulb and Part Manufacturing
33512 Lighting Fixture
Manufacturing
335121 Residential Electric Lighting Fixture
Manufacturing
335122 Commercial, Industrial, and Institutional
Electric Lighting Fixture Manufacturing
335 129 Other Lighting Equipment Manufacturing
3352 Household Appliance
Manufacturing
33521 Small Electrical Appliance
Manufacturing
33521 1 Electric Housewares and Household Fan
Manufacturing
335212 Household Vacuum Cleaner Manufacturing
33522 Major Appliance
Manufacturing
335221 Household Cooking Appliance
Manufacturing
335222 Household Refrigerator and Home Freezer
Manufacturing
335224 Household Laundry Equipment
Manufacturing
335228 Other Major Household Appliance
Manufacturing
3353 Electrical Equipment
Manufacturing
33531 Electrical Equipment
Manufacturing
335311 Power, Distribution, and Specialty
Transformer Manufacturing
335312 Motor and Generator Manufacturing (except
facilities primarily engaged in armature
rewinding on a factory basis)
335313 Switchgear and Switchboard Apparatus
Manufacturing
335314 Relay and Industrial Control Manufacturing
3359 Other Electrical Equipment
and Component
Manufacturing
33591 Battery Manufacturing
33591 1 Storage Battery Manufacturing
335912 Primary Battery Manufacturing
33592 Communication and Energy
Wire and Cable
Manufacturing
335921 Fiber Optic Cable Manufacturing
335929 Other Communication and Energy Wire
Manufacturing
33593 Wiring Device Manufacturing
335931 Current-Carrying Wiring Device
Manufacturing
335932 Noncurrent-Carrying Wiring Device
Manufacturing
33599 All Other Electrical
Equipment and
Component Manufacturing
335991 Carbon and Graphite Product Manufacturing
335999 All Other Miscellaneous Electrical Equipment
and Component Manufacturing
336 Transportation Equipment
Manufacturing
3361 Motor Vehicle Manufacturing
33611 Automobile and Light Duty
Motor Vehicle Manufacturing
336111 Automobile Manufacturing
3361 12 Light Truck and Utility Vehicle
Manufacturing
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Table I. NAICS Codes
33612 Heavy Duty Truck
Manufacturing
336120 Heavy Duty Truck Manufacturing
3362 Motor Vehicle Body and
Trailer Manufacturing
33621 Motor Vehicle Body and
Trailer Manufacturing
336211 Motor Vehicle Body Manufacturing
336212 Truck Trailer Manufacturing
336213 Motor Home Manufacturing
336214 Travel Trailer and Camper Manufacturing
3363 Motor Vehicle Parts
Manufacturing
33631 Motor Vehicle Gasoline
Engine and Engine Parts
Manufacturing
336311 Carburetor, Piston, Piston Ring, and Valve
Manufacturing
336312 Gasoline Engine and Engine Parts
Manufacturing
33632 Motor Vehicle Electrical and
Electronic Equipment
Manufacturing
336321 Vehicular Lighting Equipment Manufacturing
336322 Other Motor Vehicle Electrical and Electronic
Equipment Manufacturing
33633 Motor Vehicle Steering and
Suspension Components
(except Spring)
Manufacturing
336330 Motor Vehicle Steering and Suspension
Components (except Spring) Manufacturing
33634 Motor Vehicle Brake System
Manufacturing
336340 Motor Vehicle Brake System Manufacturing
33635 Motor Vehicle Transmission
and Power Train Parts
Manufacturing
336350 Motor Vehicle Transmission and Power Train
Parts Manufacturing
33636 Motor Vehicle Seating and
Interior Trim Manufacturing
336360 Motor Vehicle Seating and Interior Trim
Manufacturing
33637 Motor Vehicle Metal Stamping
336370 Motor Vehicle Metal Stamping
33639 Other Motor Vehicle Parts
Manufacturing
336391 Motor Vehicle Air-Conditioning
Manufacturing
336399 All Other Motor Vehicle Parts Manufacturing
3364 Aerospace Product and Parts
Manufacturing
33641 Aerospace Product and Parts
Manufacturing
3 36411 Aircraft Manufacturing
336412 Aircraft Engine and Engine Parts
Manufacturing
3 36413 Other Aircraft Parts and Auxiliary Equipment
Manufacturing
336414 Guided Missile and Space Vehicle
Manufacturing
336415 Guided Missile and Space Vehicle Propulsion
Unit and Propulsion Unit Parts Manufacturing
3 36419 Other Guided Missile and Space Vehicle
Parts and Auxiliary Equipment
Manufacturing
3365 Railroad Rolling Stock
Manufacturing
33651 Railroad Rolling Stock
Manufacturing
336510 Railroad Rolling Stock Manufacturing
3366 Ship and Boat Building
Toxics Release Inventory Reporting Forms and Instructions
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Table I. NAICS Codes
33661 Ship and Boat Building
336611 Ship Building and Repairing
336612 Boat Building
3369 Other Transportation
Equipment Manufacturing
33699 Other Transportation
Equipment Manufacturing
336991 Motorcycle, Bicycle, and Parts Manufacturing
336992 Military Armored Vehicle, Tank, and Tank
Component Manufacturing
336999 All Other Transportation Equipment
Manufacturing
337 Furniture and Related
Product Manufacturing
3371 Household and Institutional
Furniture and Kitchen
Cabinet Manufacturing
33711 Wood Kitchen Cabinet and
Countertop Manufacturing
337110 Wood Kitchen Cabinet and Countertop
Manufacturing (except facilities primarily
engaged in the retail sale of household
furniture and that manufacture custom wood
kitchen cabinets and counter tops)
33712 Household and Institutional
Furniture Manufacturing
337121 Upholstered Household Furniture
Manufacturing (except facilities primarily
engaged in the retail sale of household
furniture and that manufacture custom made
upholstered household furniture)
337122 Nonupholstered Wood Household Furniture
Manufacturing (except facilities primarily
engaged in the retail sale of household
furniture and that manufacture
nonupholstered, household type, custom
wood furniture)
337124 Metal Household Furniture Manufacturing
337125 Household Furniture (except Wood and
Metal) Manufacturing
337127 Institutional Furniture Manufacturing
337129 Wood Television, Radio, and Sewing
Machine Cabinet Manufacturing
3372 Office Furniture (including
Fixtures)Manufacturing
33721 Office Furniture (including
Fixtures)Manufacturing
3 37211 Wood Office Furniture Manufacturing
337212 Custom Architectural Woodwork and
Millwork Manufacturing
337214 Office Furniture (except Wood)
Manufacturing
337215 Showcase, Partition, Shelving, and Locker
Manufacturing
3379 Other Furniture Related
Product Manufacturing
33791 Mattress Manufacturing
337910 Mattress Manufacturing
33792 Blind and Shade
Manufacturing
337920 Blind and Shade Manufacturing
339 Miscellaneous Manufacturing
3391 Medical Equipment and
Supplies Manufacturing
33911 Medical Equipment and
Supplies Manufacturing
339111 Laboratory Apparatus and Furniture Manuf.
339112 Surgical and Medical Instrument
Manufacturing
339113 Surgical Appliance and Supplies
Manufacturing (except facilities primarily
engaged in manufacturing orthopedic devices
to prescription in a retail environment)
339114 Dental Equipment and Supplies
Manufacturing
339115 Ophthalmic Goods Manufacturing (except
lens
grinding facilities that are primarily engaged
in the retail sale of eyeglasses and contact
lenses to prescription for individuals)
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Table I. NAICS Codes
3399 Other Miscellaneous
Manufacturing
33991 Jewelry and Silverware
Manufacturing
339911 Jewelry (except Costume) Manufacturing
339912 Silverware and Hollowware Manufacturing
339913 Jewelers' Material and Lapidary Work
Manufacturing
339914 Costume Jewelry and Novelty Manufacturing
33992 Sporting and Athletic Goods
Manufacturing
339920 Sporting and Athletic Goods Manufacturing
33993 Doll, Toy, and Game
Manufacturing
339931 Doll and Stuffed Toy Manufacturing
339932 Game, Toy, and Children's Vehicle
Manufacturing
33994 Office Supplies (except Paper)
Manufacturing
339941 Pen and Mechanical Pencil Manufacturing
339942 Lead Pencil and Art Good Manufacturing
339943 Marking Device Manufacturing
339944 Carbon Paper and Inked Ribbon
Manufacturing
33995 Sign Manufacturing
339950 Sign Manufacturing
33999 All Other Miscellaneous
Manufacturing
339991 Gasket, Packing, and Sealing Device
Manufacturing
339992 Musical Instrument Manufacturing
339993 Fastener, Button, Needle, and Pin
Manufacturing
339994 Broom, Brush, and Mop Manufacturing
339995 Burial Casket Manufacturing
339999 All Other Miscellaneous Manufacturing
113310 Logging
111998 All Other Miscellaneous Crop Farming
(Limited to facilities primarily engaged in
reducing maple sap to maple syrup)
211112 Natural Gas Liquid Extraction (limited to
facilities that recover sulfur from natural gas)
212324 Kaolin and Ball Clay Mining (limited to
facilities operating without a mine or quarry
and that are primarily engaged in
beneficiating kaolin and clay)
212325 Clay and Ceramic and Refractory
Minerals Mining (limited to facilities
operating without a mine or quarry and that
are primarily engaged in beneficiating clay
and ceramic and refractory minerals)
212393 Other Chemical and Fertilizer Mineral
Mining (limited to facilities operating
without a mine or quarry that are primarily
engaged in beneficiating chemical or fertilizer
mineral raw materials)
212399 All Other Nonmetallic Mineral Mining
(limited to facilities operating without a mine
or quarry that are primarily engaged in
beneficiating nonmetallic minerals)
488390 Other Support Activities for Water
Transportation (limited to facilities that are
primarily engaged in providing routine repair
and maintenance of ships and boats from
floating drydocks)
511110 Newspaper Publishers
511120 Periodical Publishers
511130 Book Publishers
511140 Directory and Mailing List Publishers
(except Facilities that are primarily engaged
in furnishing services for direct mail
advertising including address list compilers,
address list publishers, address list publishers
and printing combined, address list
publishing, business directory publishers,
catalog of collections publishers, catalog of
collections publishers and printing combined,
mailing list compilers, directory compilers,
and mailing list compiling services)
511191 Greeting Card Publishers
511199 All Other Publishers
512220 Integrated Record Production/Distribution
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Table I. NAICS Codes
512230 Music Publishers (except facilities primarily
Engaged in Music copyright authorizing use,
Music copyright buying and licensing, and
Music publishers working on their own
account)
516110 Internet Publishing and Broadcasting and
web search portals (limited to facilities
primarily engaged in Internet newspaper
publishing, Internet periodical publishing,
internet book publishing, Miscellaneous
Internet publishing, Internet greeting card
publishers except web search portals
541710 Research and Development in the Physical,
Engineering, and Life Sciences except
Biotechnology (limited to facilities that are
primarily engaged in Guided missile and
space vehicle engine research and
development, and in Guided missile and
space vehicle parts (except engines) research
and development)
811490 Other Personal and Household Goods
Repair and Maintenance (limited to
facilities that are primarily engaged in
repairing and servicing pleasure and sail
boats without retailing new boats
(previously classified under SIC 3732, Boat
Building and Repairing (pleasure boat
building)
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Table II
1.2 NAICS codes that correspond
to SIC codes other than 20
through 39:
212 Mining (except Oil and Gas)
2121
212111
212112
212113
2122
212221
212222
212231
212234
212299
221
Coal Mining
Bituminous Coal and Lignite Surface
Mining
Bituminous Coal Underground Mining
Anthracite Mining
Metal Ore Mining
Gold Ore Mining
Silver Ore Mining
Lead Ore and Zinc Ore Mining
Copper Ore and Nickel Ore Mining
All Other Metal Ore Mining
Utilities
22111 Electric Power Generation
(limited to facilities that combust
coal and/or oil for the purpose of
generating power for distribution
in commerce)
221111 Hydroelectric Power Generation
221112 Fossil Fuel Electric Power Generation
221113 Nuclear Electric Power Generation
221119 Other Electric Power Generation
221121 Electric Bulk Power Transmission and
Control
221122 Electric Power Distribution
221330 Steam and Air Conditioning Supply
Limited to facilities engaged in providing
combinations of electric, gas and other
services, not elsewhere classified (NEC)
(previously classified under SIC 4939,
Combination Utility Services Not
Elsewhere Classified.)
424690 Other Chemical and Allied Products
Merchant Wholesalers
424710 Petroleum Bulk Stations and Terminals
425110 Business to Business Electronic Markets
(limited to facilities previously classified in
5169, Chemicals and Allied Products, NEC)
425120 Wholesale Trade Agents and Brokers
(limited to facilities previously classified in
5169, Chemicals and Allied Products, NEC)
562112 Hazardous Waste Collection (limited to
facilities primarily engaged in solvent
recovery services on a contract or fee basis)
562211 Hazardous Waste Treatment and
Disposal (limited to facilities regulated
under the Resource Conservation and
Recovery Act, subtitle C, 42 U.S.C. 6921, et
seq.)
562212 Solid Waste Landfill (limited to facilities
regulated under the Resource Conservation
and Recovery Act, subtitle C, 42 U.S.C.
6921, etseq)
562213 Solid Waste Combustors and
Incinerators (Limited to facilities regulated
under the Resource Conservation and
Recovery Act, subtitle C, 42 U.S.C. 6921 et
seq.)
562219 Other Nonhazardous Waste Treatment
and Disposal (Limited to facilities
regulated under the Resource Conservation
and Recovery Act, subtitle C, 42 U.S.C.
6921 etseq.)
562920 Materials Recovery Facilities (Limited to
facilities regulated under the Resource
Conservation and Recovery Act, subtitle C,
42 U.S.C. 6921 etseq.)
Toxics Release Inventory Reporting Forms and Instructions
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Table II. EPCRA Section 313 Chemical List For Reporting Year 2012
(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/ Chemical Category
Aluminum (fume or dust)
Aluminum oxide (fibrous forms)
Ammonia (includes anhydrous ammonia and aqueous ammonia
from water dissociable ammonium salts and other sources; 10
percent of total aqueous ammonia is reportable under this listing)
Asbestos (friable)
Hydrochloric acid (acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle size)
Nitrate compounds (water dissociable; reportable only when in
aqueous solution)
Phosphorus (yellow or white)
Sulfuric acid (acid aerosols including mists, vapors, gas, fog, and
other airborne forms of any particle size)
Vanadium (except when contained in an alloy)
Zinc (fume or dust)
CAS Number
7429-90-5
1344-28-1
7664-41-7
1332-21-4
7647-01-0
NA
7723-14-0
7664-93-9
7440-62-2
7440-66-6
Qualifier
Only if it is a fume or dust form.
Only if it is a fibrous form.
Only 10% of aqueous forms. 100% of
anhydrous forms.
Only if it is a friable form.
Only if it is an aerosol form as
defined.
Only if in aqueous solution
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.
Ply if it is in a fume or dust form.
The qualifier for the following three chemicals is based on the chemical activity rather than the form of the chemical. These
chemicals are subject to EPCRA section 313 reporting requirements only when the indicated activity is performed.
Chemical/ Chemical Category
Dioxin and dioxin-like compounds (manufacturing; and the
processing or otherwise use of dioxin and dioxin-like compounds if
the dioxin and dioxin-like compounds are present as contaminants
in a chemical and if they were created during the manufacture of
that chemical.)
Isopropyl alcohol (only persons who manufacture by the strong
acid process are subject, no supplier notification)
Saccharin (only persons who manufacture are subject, no supplier
notification)
CAS
Number
NA
67-63-0
81-07-2
Qualifier
Only if they are manufactured at the
facility; or are processed or otherwise
used when present as contaminants in a
chemical but only if they were created
during the manufacture of that
chemical.
Only if it is being manufactured by the
strong acid process. Facilities that
process or otherwise use isopropyl
alcohol are not covered and should not
file a report.
Only if it is being manufactured.
There are no supplier notification requirements for isopropyl alcohol and saccharin since the processors and users of these chemicals
are not required to report. Manufacturers of these chemicals do not need to notify their customers that these are reportable EPCRA
section 313 chemicals.
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Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
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 % limits 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 2009 calendar
year reporting. Some of the EPCRA Section 313 chemicals
listed have parenthetic qualifiers listed next to them. An
EPCRA Section 313 chemical that is listed without a qualifier is
subject to reporting in all forms in which it is manufactured,
processed, and otherwise used.
Fume or dust. Two of the metals on the list (aluminum and
zinc) contain the qualifier "fume or dust." Fume or dust refers to
dry forms of these metals but does not refer to "wet" forms such
as solutions or slurries. As explained in Section B.3.a of these
instructions, the term manufacture includes the generation of an
EPCRA Section 313 chemical as a byproduct or impurity. In
such cases, a facility should determine if, for example, it
generated more than 25,000 pounds of aluminum fume or dust in
the reporting year as a result of its activities. If so, the facility
must report that it manufactures "aluminum (fume or dust)."
Similarly, there may be certain technologies in which one of
these metals is processed in the form of a fume or dust to make
other EPCRA Section 313 chemicals or other products for
distribution in commerce. In reporting releases, the facility
would only report releases of the fume or dust.
EPA considers dusts to consist of solid particles generated by
any mechanical processing of materials including crushing,
grinding, rapid impact, handling, detonation, and decrepitation
of organic and inorganic materials such as rock, ore, and metal.
Dusts do not tend to flocculate, except under electrostatic forces.
EPA considers a fume to be an airborne dispersion consisting of
small solid particles created by condensation from a gaseous
state, in distinction to a gas or vapor. Fumes arise from the
heating of solids such as lead. The condensation is often
accompanied by a chemical reaction, such as oxidation. Fumes
flocculate and sometimes coalesce.
Manufacturing qualifiers. Two of the entries in the EPCRA
Section 313 chemical list contain a qualifier relating to
manufacture. For isopropyl alcohol, the qualifier is "only
persons who manufacture by the strong acid process are subject,
no supplier notification." For saccharin, the qualifier is "only
persons who manufacture are subject, no supplier notification."
For isopropyl alcohol, the qualifier means that only facilities
manufacturing isopropyl alcohol by the strong acid process are
required to report. In the case of saccharin, only manufacturers
of the EPCRA Section 313 chemical are subject to the reporting
requirements. A facility that only processes or otherwise uses
either of these EPCRA Section 313 chemicals is not required to
report for these EPCRA Section 313 chemicals. In both cases,
supplier notification does not apply because only manufacturers,
not users, of these two EPCRA Section 313 chemicals must
report.
Ammonia (includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium salts and other
sources; 10 percent of total aqueous ammonia is reportable
under this listing). The qualifier for ammonia means that
anhydrous forms of ammonia are 100% reportable and aqueous
forms are limited to 10% of total aqueous ammonia. Therefore
when determining threshold and releases and other waste
management quantities all anhydrous ammonia is included but
only 10% of total aqueous ammonia is included. Any
evaporation of ammonia from aqueous ammonia solutions is
considered anhydrous ammonia and should be included in
threshold determinations and release and other waste
management calculations.
Sulfuric acid and Hydrochloric acid (acid aerosols including
mists, vapors, gas, fog, and other airborne forms of any
particle size). The qualifier for sulfuric acid and hydrochloric
acid means that the only forms of these chemicals that are
reportable are airborne forms. Aqueous solutions are not
covered by this listing but any aerosols generated from aqueous
solutions are covered.
Nitrate compounds (water dissociable; reportable only when
in aqueous solution). The qualifier for the nitrate compounds
category limits the reporting to nitrate compounds that dissociate
in water, generating nitrate ion. For the purposes of threshold
determinations the entire weight of the nitrate compound must
be included in all calculations. For the purposes of reporting
releases and other waste management quantities only the weight
of the nitrate ion should be included in the calculations of these
quantities.
Phosphorus (yellow or white). The listing for phosphorus is
qualified by the term "yellow or white." This means that only
manufacturing, processing, or otherwise use of phosphorus in
the yellow or white chemical form triggers reporting.
Conversely, manufacturing, processing, or otherwise use of
"black" or "red" phosphorus does not trigger reporting. Supplier
notification also 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
Toxics Release Inventory Reporting Forms and Instructions
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Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
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.
Notes for Sections A and B of following list of
TRI chemicals:
"Color Index" indicated by "C.I."
* There are no de minimis levels for PBT
chemicals, except for supplier notification
purposes (see Appendix D).
a.
Individually-Listed Toxic Chemicals Arranged
Alphabetically
CAS Number Chemical Name
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,
1,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a-
hexahydro-(1 .alpha. ,4. alpha. ,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
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
CAS Number Chemical Name
De minimis
% Limit
82-28-0
81-49-2
33089-61-1
61-82-5
7664-41-7
101-05-3
62-53-3
90-04-0
104-94-9
134-29-2
120-12-7
7440-36-0
7440-38-2
1332-21-4
1912-24-9
7440-39-3
22781-23-3
1861-40-1
17804-35-2
98-87-3
55-21-0
71-43-2
92-87-5
98-07-7
191-24-2
98-88-4
94-36-0
100-44-7
7440-41-7
82657-04-3
92-52-4
3296-90-0
111-91-1
111-44-4
542-88-1
108-60-1
56-35-9
10294-34-5
7637-07-2
314-40-9
53404-19-6
l-Amino-2-methylanthraquinone 0.1
l-Amino-2,4-dibromoanthraquinone 0.1
Amitraz 1.0
Amitrole 0.1
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)
Anilazine 1.0
[4,6-Dichloro-N-(2-chlorophenyl)-l,3,5-
triazin-2-amine]
Aniline 1.0
o-Anisidine 0.1
p-Anisidine 1.0
o-Anisidine hydrochloride 0.1
Anthracene 1.0
Antimony 1.0
Arsenic 0.1
Asbestos (friable) 0.1
Atrazine 1.0
(6-Chloro-N-ethyl-N=-(l-methylethyl)-
l,3,5-triazine-2,4-diamine)
Barium 1.0
Bendiocarb 1.0
[2,2-Dimethyl-l,3-benzodioxol-4-ol
methylcarbamate]
Benfluralin 1.0
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)benzenamine)
Benomyl 1.0
Benzal chloride 1.0
Benzamide 1.0
Benzene 0.1
Benzidine 0.1
Benzoic trichloride 0.1
(Benzotrichloride)
Benzo(g,h,i)perylene *
Benzoyl chloride 1.0
Benzoyl peroxide 1.0
Benzyl chloride 1.0
Beryllium 0.1
Bifenthrin 1.0
Biphenyl 1.0
2,2-bis(Bromomethyl)-l,3-propanediol 0.1
Bis(2-chloroethoxy) methane 1.0
Bis(2-chloroethyl) ether 1.0
Bis(chloromethyl) ether 0.1
Bis(2-chloro-l-methylethyl)ether 1.0
Bis(tributyltin) oxide 1.0
Boron trichloride 1.0
Boron trifluoride 1.0
Bromacil 1.0
(5-Bromo-6-methyl-3 -(1 -methylpropyl)-
2,4(lH,3H)-pyrimidinedione)
Bromacil, lithium salt 1.0
[2,4(lH,3H)-Pyrimidinedione,5-bromo-6-
Toxics Release Inventory Reporting Forms and Instructions
II-3
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Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
methyl-3-(l-methylpropyl), lithium salt]
7726-95-6 Bromine 1.0
35691-65-7 l-Bromo-l-(bromomethyl)- 1.0
1,3 -propanedicarbonitrile
353-59-3 Bromochlorodifluoromethane 1.0
(Halonl211)
75-25-2 Bromoform (Tribromomethane) 1.0
74-83-9 Bromomethane 1.0
(Methyl bromide)
75-63-8 Bromotrifluoromethane 1.0
(Halon 1301)
1689-84-5 Bromoxynil 1.0
(3,5 -Dibromo -4 -hydro xybenzonitrile)
1689-99-2 Bromoxynil octanoate 1.0
(Octanoic acid, 2,6-dibromo-4-
cyanophenylester)
357-57-3 Brucine 1.0
106-99-0 1,3-Butadiene 0.1
141-32-2 Butyl acrylate 1.0
71-36-3 n-Butyl alcohol 1.0
78-92-2 sec-Butyl alcohol 1.0
75-65-0 tert-Butyl alcohol 1.0
106-88-7 1,2-Butylene oxide 0.1
123-72-8 Butyraldehyde 1.0
7440-43-9 Cadmium 0.1
156-62-7 Calcium cyanamide 1.0
133-06-2 Captan 1.0
[lH-Isoindole-l,3(2H)-dione, 3a,4,7,7a-
tetrahydro-2-[(trichloromethyl)thio]-]
63-25-2 Carbaryl [1-Naphthalenol, 1.0
methylcarbamate]
1563-66-2 Carbofuran 1.0
75-15-0 Carbon disulfide 1.0
56-23-5 Carbon tetrachloride 0.1
463-58-1 Carbonyl sulfide 1.0
5234-68-4 Carboxin 1.0
(5,6-Dihydro-2-methyl-N-
phenyl-1,4-oxathiin-3 -carboxamide)
120-80-9 Catechol 0.1
2439-01-2 Chinomethionat 1.0
[6-Methyl-l,3-dithiolo[4,5-b]quinoxalin-2-
one]
133-90-4 Chloramben 1.0
[Benzoic acid, 3-amino-2,5-dichloro-]
57-74-9 Chlordane *
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-hexahydro-]
115-28-6 Chlorendic acid 0.1
90982-32-4 Chlorimuron ethyl 1.0
[Ethyl-2-[[[[(4-chloro-6-methoxyprimidin-2-
yl)amino] carbonyl] amino] sulfonyl]
benzoate]
7782-50-5 Chlorine 1.0
10049-04-4 Chlorine dioxide 1.0
79-11-8 Chloroacetic acid 1.0
532-27-4 2-Chloroacetophenone 1.0
4080-31-3 l-(3-Chloroallyl)-3,5,7-triaza- LO^
CAS Number
106-47-8
108-90-7
510-15-6
75-68-3
75-45-6
75-00-3
67-66-3
74-87-3
107-30-2
563-47-3
104-12-1
76-06-2
126-99-8
542-76-7
63938-10-3
354-25-6
2837-89-0
1897-45-6
95-69-2
75-88-7
75-72-9
460-35-5
5598-13-0
64902-72-3
7440-47-3
4680-78-8
6459-94-5
569-64-2
989-38-8
1937-37-7
2602-46-2
28407-37-6
16071-86-6
2832-40-8
3761-53-3
81-88-9
3118-97-6
97-56-3
842-07-9
492-80-8
De minimis
Chemical Name % Limit
1-azoniaadamantane chloride
p-Chloroaniline
Chlorobenzene
Chlorobenzilate
[Benzeneacetic acid, 4-chloro-.alpha.-
chlorophenyl)-.alpha.-hydroxy-, ethyl
1-Chloro-l, 1-difluoroethane
(HCFC-142b)
Chlorodifluoromethane
(HCFC-22)
Chloroethane (Ethyl chloride)
Chloroform
Chloromethane (Methyl chloride)
Chloromethyl methyl ether
3-Chloro-2-methyl-l-propene
p-Chlorophenyl isocyanate
Chloropicrin
Chloroprene
3 -Chloropropionitrile
Chlorotetrafluoroethane
1-Chloro-l, 1,2,2-
tetrafluoroethane (HCFC-124a)
2-Chloro-l, 1,1,2-
tetrafluoroethane (HCFC-124)
Chlorothalonil
[1,3-Benzenedicarbonitrile, 2,4,5,6-
tetrachloro-]
p-Chloro-o-toluidine
2-Chloro-l,l,l-
trifluoroethane (HCFC-133a)
Chlorotrifluoromethane (CFC-13)
3-Chloro-l,l,l-
trifluoropropane (HCFC-253fb)
Chlorpyrifos methyl
[O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate]
Chlorsulfuron
[2-Chloro-N-[[(4-methoxy-6-methyl-l
triazin-2-yl)amino]carbonyl]
benzenesulfonamide]
Chromium
C.I. Acid Green 3
C.I. Acid Red 114
C.I. Basic Green 4
C.I. Basic Red 1
C.I. Direct Black 38
C.I. Direct Blue 6
C.I. Direct Blue 218
C.I. Direct Brown 95
C.I. Disperse Yellow 3
C.I. Food Red 5
C.I. Food Red 15
C.I. Solvent Orange 7
C.I. Solvent Yellow 3
C.I. Solvent Yellow 14
C.I. Solvent Yellow 34
(Auramine)
0.1
1.0
1.0
(4-
ester]
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
1.0
1.0
,3,5-
1.0
1.0
0.1
1.0
1.0
0.1
0.1
1.0
0.1
1.0
0.1
1.0
1.0
0.1
1.0
0.1
Toxics Release Inventory Reporting Forms and Instructions
II-4
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Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
128-66-5 C.I. Vat Yellow 4 1.0
7440-48-4 Cobalt 0.1
7440-50-8 Copper 1.0
8001-58-9 Creosote 0.1
120-71-8 p-Cresidine 0.1
108-39-4 m-Cresol 1.0
95-48-7 o-Cresol 1.0
106-44-5 p-Cresol 1.0
1319-77-3 Cresol (mixed isomers) 1.0
4170-30-3 Crotonaldehyde 1.0
98-82-8 Cumene 1.0
80-15-9 Cumene hydroperoxide 1.0
135-20-6 Cupferron 0.1
[Benzeneamine, N-hydroxy-
N-nitroso, ammonium salt]
21725-46-2 Cyanazine 1.0
1134-23-2 Cycloate 1.0
110-82-7 Cyclohexane 1.0
108-93-0 Cyclohexanol 1.0
68359-37-5 Cyfluthrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid,
cyano(4-fluoro-3-phenoxyphenyl) methyl
ester]
68085-85-8 Cyhalothrin 1.0
[3-(2-Chloro-3,3,3-trifluoro-l-propenyl)-
2,2-dimethylcyclopropane-carboxylic acid
cyano(3-phenoxyphenyl)methyl ester]
94-75-7 2,4-D 0.1
[Acetic acid, (2,4-dichlorophenoxy)-]
533-74-4 Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione)
53404-60-7 Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione, ion(l-), sodium]
94-82-6 2,4-DB 1.0
1929-73-3 2,4-D butoxyethyl ester 0.1
94-80-4 2,4-D butyl ester 0.1
2971-38-2 2,4-D chlorocrotyl ester 0.1
1163-19-5 Decabromodiphenyl oxide 1.0
13684-56-5 Desmedipham 1.0
1928-43-4 2,4-D 2-ethylhexyl ester 0.1
53404-37-8 2,4-D 2-ethyl-4- 0.1
methylpentyl ester
2303-16-4 Diallate 1.0
[Carbamothioic acid, bis(l-methylethyl)-S-
(2,3-dichloro-2-propenyl) ester]
615-05-4 2,4-Diaminoanisole 0.
39156-41-7 2,4-Diaminoanisole sulfate 0.
101-80-4 4,4'-Diaminodiphenyl ether 0.
95-80-7 2,4-Diaminotoluene 0.
25376-45-8 Diaminotoluene (mixed isomers) 0.
333-41-5 Diazinon 1.0
334-88-3 Diazomethane 1.0
132-64-9 Dibenzoruran 1.0
96-12-8 l,2-Dibromo-3- 0.1
chloropropane (DBCP)
CAS Number
106-93-4
124-73-2
84-74-2
1918-00-9
99-30-9
95-50-1
541-73-1
106-46-7
25321-22-6
91-94-1
612-83-9
64969-34-2
75-27-4
764-41-0
110-57-6
1649-08-7
75-71-8
107-06-2
540-59-0
1717-00-6
75-43-4
75-09-2
127564-92-5
13474-88-9
111512-56-2
422-44-6
431-86-7
507-55-1
136013-79-1
128903-21-9
422-48-0
422-56-0
97-23-4
120-83-2
78-87-5
10061-02-6
78-88-6
542-75-6
De minimis
Chemical Name % Limit
1 ,2-Dibromoethane
(Ethylene dibromide)
Dibromotetrafluoroethane
(Halon2402)
Dibutyl phthalate
Dicamba
(3 ,6-Dichloro-2-methoxybenzoic acid)
Dichloran
[2,6-Dichloro-4-nitroaniline]
1 ,2-Dichlorobenzene
1 , 3 -Dichlorobenzene
1 ,4-Dichlorobenzene
Dichlorobenzene (mixed isomers)
3 , 3 '-Dichlorobenzidine
3 , 3 '-Dichlorobenzidine
dihydrochloride
3, 3 '-Dichlorobenzidine sulfate
Dichlorobromomethane
1 ,4-Dichloro-2-butene
trans- 1 ,4-Dichloro-2-butene
1,2-Dichloro- 1,1-
difluoroethane (HCFC-132b)
Dichlorodifluoromethane (CFC-12)
1,2-Dichloroethane (Ethylene
dichloride)
1 ,2-Dichloroethylene
1 , 1 -Dichloro- 1 -fluoroethane
(HCFC-141b)
Dichlorofluoromethane (HCFC-21)
Dichloromethane (Methylene
chloride)
Dichloropentafluoropropane
1,1 -Dichloro- 1,2,2,3, 3-
pentafluoropropane (HCFC-225cc)
l,l-Dichloro-l,2,3,3,3-
pentafluoropropane (HCFC-225eb)
1,2-Dichloro- 1,1, 2,3, 3-
pentafluoropropane (HCFC-225bb)
1,2-Dichloro- 1, 1,3,3,3-
pentafluoropropane (HCFC-225da)
1,3-Dichloro-l, 1,2,2,3-
pentafluoropropane (HCFC-225cb)
1,3-Dichloro-l, 1,2,3,3-
pentafluoropropane (HCFC-225ea)
2,2-Dichloro- 1,1, 1,3,3 -
pentafluoropropane (HCFC-225aa)
2,3-Dichloro-l, 1,1,2,3-
pentafluoropropane (HCFC-225ba)
3,3-Dichloro-l, 1,1,2,2-
pentafluoropropane (HCFC-225ca)
Dichlorophene
[2,2'-Methylenebis(4-chlorophenol)]
2,4-Dichlorophenol
1 ,2-Dichloropropane
trans- 1 ,3 -Dichloropropene
2,3-Dichloropropene
1 , 3 -Dichloropropylene
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
1.0
0.1
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
Toxics Release Inventory Reporting Forms and Instructions
II-5
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Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
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
77-73-6
1464-53-5
111-42-2
38727-55-8
117-81-7
64-67-5
35367-38-5
101-90-6
94-58-6
55290-64-7
60-51-5
119-90-4
20325-40-0
111984-09-9
124-40-3
2300-66-5
60-11-7
121-69-7
119-93-7
612-82-8
41766-75-0
79-44-7
2524-03-0
68-12-2
57-14-7
105-67-9
131-11-3
77-78-1
99-65-0
528-29-0
100-25-4
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)
l,2-Dichloro-l,l,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-
Dicyclopentadiene 1.0
Diepoxybutane 0.1
Diethanolamine 1.0
Diethatyl ethyl 1.0
Di(2-ethylhexyl) phthalate (DEHP) 0.1
Diethyl sulfate 0.1
Diflubenzuron 1.0
Diglycidyl resorcinol ether 0.1
Dihydrosafrole 0.1
Dimethipin 1.0
[2,3-Dihydro-5,6-dimethyl-l,4-dithiin
1,1,4,4-tetraoxide]
Dimethoate 1.0
3,3'-Dimethoxybenzidine 0.1
3,3'-Dimethoxybenzidine 0.1
dihydrochloride (o-Dianisidine
dihydrochloride)
3,3'-Dimethoxybenzidine 0.1
hydrochloride (o-Dianisidine hydrochloride)
Dimethylamine 1.0
Dimethylamine dicamba 1.0
4-Dimethylaminoazobenzene 0.1
N,N-Dimethylaniline 1.0
3,3'-Dimethylbenzidine (o-Tolidine) 0.1
3,3'-Dimethylbenzidine 0.1
dihydrochloride (o-Tolidine
dihydrochloride)
3,3'-Dimethylbenzidine 0.1
dihydrofluoride (o-Tolidine dihydrofluoride)
Dimethylcarbamyl chloride
Dimethyl
chlorothiophosphate
N,N-Dimethylformamide
1,1-Dimethyl hydrazine
2,4-Dimethylphenol
Dimethyl phthalate
Dimethyl sulfate
m-Dinitrobenzene
o-Dinitrobenzene
p-Dinitrobenzene
0.1
1.0
1.0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
CAS Number Chemical Name
De minimis
% Limit
88-85-7 Dinitrobutyl phenol (Dinoseb) 1.0
534-52-1 4,6-Dinitro-o-cresol 1.0
51-28-5 2,4-Dinitrophenol 1.0
121-14-2 2,4-Dinitrotoluene 0.1
606-20-2 2,6-Dinitrotoluene 0.1
25321-14-6 Dinitrotoluene (mixed isomers) 1.0
39300-45-3 Dinocap 1.0
123-91-1 1,4-Dioxane 0.1
957-51-7 Diphenamid 1.0
122-39-4 Diphenylamine 1.0
122-66-7 1,2-Diphenylhydrazine 0.1
(Hydrazobenzene)
2164-07-0 Dipotassium endothall 1.0
[7-Oxabicyclo(2.2. l)heptane-2,3-
dicarboxylic acid, dipotassium salt]
136-45-8 Dipropyl isocinchomeronate 1.0
138-93-2 Disodium 1.0
cyanodithioimidocarbonate
94-11-1 2,4-D isopropyl ester 0.1
541-53-7 2,4-Dithiobiuret 1.0
330-54-1 Diuron 1.0
2439-10-3 Dodine [Dodecylguanidine 1.0
monoacetate]
120-36-5 2,4-DP 0.1
1320-18-9 2,4-D propylene glycol 0.1
butyl ether ester
2702-72-9 2,4-D sodium salt 0.1
106-89-8 Epichlorohydrin 0.1
13194-48-4 Ethoprop 1.0
[Phosphorodithioic acid O-ethyl S,S-
dipropyl ester]
110-80-5 2-Ethoxyethanol 1.0
140-88-5 Ethyl acrylate 0.1
100-41-4 Ethylbenzene 0.1
541-41-3 Ethyl chloroformate 1.0
759-94-4 Ethyl dipropylthiocarbamate 1.0
(EPTC)
74-85-1 Ethylene 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 -pyrimidinemethanol]
13356-08-6 Fenbutatin oxide 1.0
(Hexakis(2-methyl-2-phenylpropyl)
distannoxane)
66441-23-4 Fenoxaprop ethyl 1.0
[2-(4-((6-Chloro-2-
benzoxazolylen)oxy)phenoxy)propanoic
acid, ethyl ester]
72490-01-8 Fenoxycarb 1.0
[[2-(4-Phenoxyphenoxy)ethyl]carbamic acid
Toxics Release Inventory Reporting Forms and Instructions
II-6
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Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
ethyl ester]
39515-41-8 Fenpropathrin 1.0
[2,2,3,3 -Tetramethylcyclopropane
carboxylic acid cyano(3-
phenoxyphenyl)methyl ester]
55-38-9 Fenthion 1.0
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester, phosphorothioic
acid]
51630-58-1 Fenvalerate 1.0
[4-Chloro-alpha-( 1 -methylethyl)
benzeneacetic acid cyano (3-
phenoxyphenyl) methyl ester]
14484-64-1 Ferbam 1.0
[Tris(dimethylcarbamodithioato- S, S')iron]
69806-50-4 Fluazifop butyl 1.0
[2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]phenoxy]propanoic acid,
butyl ester]
2164-17-2 Fluometuron 1.0
[Urea, N,N-dimethyl-N=-[3-
(trifluoromethy l)phenyl] -]
7782-41-4 Fluorine 1.0
51-21-8 Fluorouracil (5-Fluorouracil) 1.0
69409-94-5 Fluvalinate 1.0
[N-[2-Chloro-4-(trifluoromethyl)phenyl]-
DL-valine(+)-cyano(3-
phenoxyphenyl)methyl ester]
133-07-3 Folpet 1.0
72178-02-0 Fomesafen 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
N-methylsulfony 1-2 -nitrobenzamide]
50-00-0 Formaldehyde 0.1
64-18-6 Formic acid 1.0
76-13-1 FreonllS 1.0
[Ethane, 1, l,2-trichloro-l,2,2,-trifluoro-]
110-00-9 Furan 0.1
556-52-5 Glycidol 0.1
76-44-8 Heptachlor *
[l,4,5,6,7,8,8-Heptachloro-3a, 4,7,7a-
tetrahydro-4,7-methano-lH-indene]
118-74-1 Hexachlorobenzene *
87-68-3 Hexachloro-1,3-butadiene 1.0
319-84-6 alpha-Hexachlorocyclohexane 0.1
77-47-4 Hexachlorocyclopentadiene 1.0
67-72-1 Hexachloroethan 0.1
1335-87-1 Hexachloronaphthalene 1.0
70-30-4 Hexachlorophene 1.0
680-31-9 Hexamethylphosphoramide 0.1
110-54-3 n-Hexane 1.0
51235-04-2 Hexazinone 1.0
67485-29-4 Hydramethylnon 1.0
[Tetrahydro-5,5-dimethyl-2(lH)-
pyrimidinone[3 -[4-(trifluoromethyl)phenyi] -
l-[2-[4-(trifluoromethyl)phenyl]ethenyl]-2-
propenylidene]hydrazone]
302-01-2 Hydrazine 0.1
10034-93-2 Hydrazine sulfate OJ_
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
7783-06-4 Hydrogen sulfide 1.0
123-31-9 Hydroquinone 1.0
35554-44-0 Imazalil 1.0
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl] -IH-imidazole]
55406-53-6 3-Iodo-2-propynyl 1.0
butylcarbamate
13463-40-6 Iron pentacarbonyl 1.0
78-84-2 Isobutyraldehyde 1.0
465-73-6 Isodrin *
25311-71-1 Isofenphos[2-[[Ethoxyl[(l- 1.0
methylethyl)amino]phosphinothioyl]oxy]
benzoic acid 1-methylethyl ester]
78-79-5 Isoprene 0.1
67-63-0 Isopropyl alcohol 1.0
(only persons who manufacture by the
strong acid process are subject, no supplier
notification)
80-05-7 4,4'-Isopropylidenediphenol 1.0
120-58-1 Isosafrole 1.0
77501-63-4 Lactofen 1.0
[Benzoic acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy]-2-nitro-, 2-
ethoxy-l-methyl-2-oxoethyl ester]
7439-92-1 Lead *
(when lead is contained in stainless steel,
brass or bronze alloys the de minimis level is
0.1)
58-89-9 Lindane 0.1
[Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(l.alpha.,2.alpha.,3.beta.,4.alpha.,5.alpha.,
6.beta.)-]
330-55-2 Linuron 1.0
554-13-2 Lithium carbonate 1.0
121-75-5 Malathion 1.0
108-31-6 Maleic anhydride 1.0
109-77-3 Malononitrile 1.0
12427-38-2 Maneb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
manganese complex]
7439-96-5 Manganese 1.0
93-65-2 Mecoprop 0.1
149-30-4 2-Mercaptobenzothiazole (MET) 1.0
7439-97-6 Mercury *
150-50-5 Merphos 1.0
126-98-7 Methacrylonitrile 1.0
137-42-8 Metham sodium (Sodium 1.0
methyldithiocarbamate)
67-56-1 Methanol 1.0
20354-26-1 Methazole 1.0
[2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
Toxics Release Inventory Reporting Forms and Instructions
II-7
-------
Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
oxadiazolidine-3,5 -dione]
2032-65-7 Methiocarb 1.0
94.74-6 Methoxone 0.1
((4-Chloro-2-methylphenoxy) acetic acid)
(MCPA)
3653-48-3 Methoxone sodium salt 0.1
((4-Chloro-2-methylphenoxy) acetate
sodium salt)
72-43-5 Methoxychlor *
[Benzene, l,l'-(2,2,2-
trichloroethylidene)bis [4 -methoxy-]
109-86-4 2-Methoxyethanol 1.0
96-33-3 Methyl acrylate 1.0
1634-04-4 Methyl tert-butyl ether 1.0
79-22-1 Methyl chlorocarbonate 1.0
101-14-4 4,4'-Methylenebis(2-chloroaniline) 0.1
(MBOCA)
101-61-1 4,4'-Methylenebis(N,N-dimethyl) 0.1
benzenamine
74-95-3 Methylene bromide 1.0
101-77-9 4,4'-Methylenedianiline 0.1
93-15-2 Methyleugenol 0.1
60-34-4 Methyl hydrazine 1.0
74-88-4 Methyl iodide 1.0
108-10-1 Methyl isobutyl ketone 1.0
624-83-9 Methyl isocyanate 1.0
556-61-6 Methyl isothiocyanate 1.0
[Isothiocyanato methane]
75-86-5 2-Methyllactonitrile 1.0
80-62-6 Methyl methacry late 1.0
924-42-5 N-Methylolacrylamide 1.0
298-00-0 Methyl parathion 1.0
109-06-8 2-Methylpyridine 1.0
872-50-4 N-Methyl-2-pyrrolidone 1.0
9006-42-2 Metiram 1.0
21087-64-9 Metribuzin 1.0
7786-34-7 Mevinphos 1.0
90-94-8 Michler's ketone 0.1
2212-67-1 Molinate 1.0
(lH-Azepine-1-carbothioic acid, hexahydro-
, S-ethyl ester)
1313 -27-5 Molybdenum trioxide 1.0
76-15-3 Monochloropentafluoroethane 1.0
(CFC-115)
150-68-5 Monuron 1.0
505-60-2 Mustard gas 0.1
[Ethane, l,l'-thiobis[2-chloro-]
88671-89-0 Myclobutanil 1.0
[.alpha.-Butyl-.alpha.-(4-chlorophenyl)-1H-
1,2,4 -triazole-1 -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)
CAS Number Chemical Name
De minimis
% Limit
7697-37-2
139-13-9
100-01-6
91-23-6
99-59-2
98-95-3
92-93-3
1836-75-5
51-75-2
55-63-0
75-52-5
88-75-5
100-02-7
79-46-9
924-16-3
55-18-5
62-75-9
86-30-6
156-10-5
621-64-7
759-73-9
684-93-5
4549-40-0
59-89-2
16543-55-8
100-75-4
99-55-8
27314-13-2
2234-13-1
29082-74-4
19044-88-3
20816-12-0
301-12-2
19666-30-9
42874-03-3
10028-15-6
123-63-7
1910-42-5
56-38-2
1114-71-2
Nitric acid
Nitrilotriacetic acid
p-Nitroaniline
o-Nitroanisole
5 -Nitro -o -anisidine
Nitrobenzene
4-Nitrobiphenyl
Nitrofen
1.0
0.1
1.0
0.1
1.0
0.1
0.1
0.1
[Benzene, 2,4-dichloro-l-(4-nitrophenoxy)-]
Nitrogen mustard 0.1
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
Nitro glycerin 1.0
Nitro me thane 0.1
2-Nitrophenol 1.0
4-Nitrophenol 1.0
2-Nitropropane 0.1
N-Nitrosodi-n-butylamine 0.1
N-Nitrosodiethylamine 0.1
N-Nitrosodimethylamine 0.1
N-Nitrosodiphenylamine 1.0
p-Nitrosodiphenylamine 1.0
N-Nitrosodi-n-propylamine 0.1
N-Nitroso-N-ethylurea 0.1
N-Nitroso-N-methylurea 0.1
N-Nitrosomethylvinylamine 0.1
N-Nitrosomorpholine 0.1
N-Nitrosonornicotine 0.1
N-Nitrosopiperidine 0.1
5-Nitro-o-toluidine 1.0
Norflurazon 1.0
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)phenyl] -3 (2H)-
pyridazinone]
Octachloronaphthalene 1.0
Octachlorostyrene *
Oryzalin 1.0
[4-(Dipropylamino)-3,5-dinitrobenzene
sulfonamide]
Osmium tetroxide 1.0
Oxydemeton methyl 1.0
[S-(2-(Ethylsulfinyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
Oxydiazon 1.0
[3-[2,4-Dichloro-5-(l-
methylethoxy)phenyl] - 5 -(1,1 -
dimethylethyl)-1,3,4-oxadiazol-2(3H)-one]
Oxyfluorfen 1.0
Ozone 1.0
Paraldehyde 1.0
Paraquat dichloride 1.0
Parathion 1.0
[Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl)ester]
Pebulate 1.0
[Butylethylcarbamothioic acid S-propyl
ester]
Toxics Release Inventory Reporting Forms and Instructions
II-8
-------
Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
40487-42-1
608-93-5
76-01-7
87-86-5
57-33-0
79-21-0
594-42-3
52645-53-1
85-01-8
108-95-2
77-09-8
26002-80-2
95-54-5
108-45-2
106-50-3
615-28-1
624-18-0
90-43-7
57-41-0
75-44-5
7803-51-2
7723-14-0
85-44-9
1918-02-1
88-89-1
51-03-6
29232-93-7
1336-36-3
7758-01-2
128-03-0
137-41-7
41198-08-7
7287-19-6
23950-58-5
1918-16-7
Pendimethalin *
[N-( 1 -Ethylpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine]
Pentachlorobenzene *
Pentachloroethane 1.0
Pentachlorophenol (PCP) 0.1
Pentobarbital sodium 1.0
Peracetic acid 1.0
Perchloromethyl mercaptan 1.0
Permethrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid, (3-
phenoxyphenyl) methyl ester]
Phenanthrene 1.0
Phenol 1.0
Phenolphthalein 0.1
Phenothrin 1.0
[2,2-Dimethyl-3-(2-methyl-l-
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester]
1,2-Phenylenediamine 1.0
1,3-Phenylenediamine 1.0
p-Phenylenediamine 1.0
1,2-Phenylenediamine dihydro- 1.0
chloride
1,4-Phenylenediamine dihydro- 1.0
chloride
2-Phenylphenol 1.0
Phenytoin 0.1
Phosgene 1.0
Phosphine 1.0
Phosphorus (yellow or white) 1.0
Phthalic anhydride 1.0
Picloram 1.0
Picric acid 1.0
Piperonyl butoxide 1.0
Pirimiphos methyl 1.0
[O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-
dimethylphosphorothioate]
Fob/chlorinated biphenyls *
(PCBs)
Potassium bromate 0.1
Potassium dimethyldithio- 1.0
carbamate
Potassium N-methyldithio- 1.0
carbamate
Profenofos 1.0
[O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
propyl phosphorothioate]
Prometryn 1.0
[N,N'-Bis(l-methylethyl)-6-methylthio-
1,3,5 -triazine-2,4-diamine]
Pronamide 1.0
Propachlor
[2-Chloro-N-( 1 -methylethyl)-N-
phenylacetamide]
1.0
CAS Number Chemical Name
De minimis
% Limit
1120-71-4 Propane sultone 0.1
709-98-8 Propanil 1.0
[N-(3,4-Dichlorophenyl)propanamide]
2312-35-8 Propargite 1.0
107-19-7 Propargyl alcohol 1.0
31218-83-4 Propetamphos 1.0
[3-[(Ethylamino)methoxyphosphinothioyl]
oxy]-2-butenoic acid, 1-methylethyl ester]
60207-90-1 Propiconazole 1.0
[l-[2-(2,4-Dichlorophenyl)-4-propyl-l,3-
dioxolan-2-yl]-methyl-1H-1,2,4,-triazole]
57-57-8 beta-Propiolactone 0.1
123-38-6 Propionaldehyde 1.0
114-26-1 Propoxur 1.0
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
115-07-1 Propylene (Propene) 1.0
75-55-8 Propyleneimine 0.1
75-56-9 Propylene oxide 0.1
110-86-1 Pyridine 1.0
91-22-5 Quinoline 1.0
106-51-4 Quinone 1.0
82-68-8 Quintozene 1.0
(Pentachloronitrobenzene)
76578-14-8 Quizalofop-ethyl 1.0
[2-[4-[(6-Chloro-2-
quinoxalinyl)oxy]phenoxy] propanoic acid
ethyl ester]
10453-86-8 Resmethrin 1.0
[[5-(Phenylmethyl)-3-furanyl]methyl-2,2-
dimethyl-3 -(2 -methyl-1 -propenyl)
cyclopropanecarboxylate]
81-07-2 Saccharin (only persons who 1.0
manufacture are subject, no supplier
notification)
94.59.7 Safrole 0.1
7782-49-2 Selenium 1.0
74051-80-2 Sethoxydim 1.0
[2-[l-(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
Toxics Release Inventory Reporting Forms and Instructions
II-9
-------
Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
1.0
size)
2699-79-8 Sulfuryl fluoride (Vikane)
35400-43-2 Sulprofos
[O-Ethyl O-[4-(methylthio)phenyl]
phosphorodithioic acid S-propylester]
34014-18-1 Tebuthiuron
[N-[5-( 1,1 -Dimethylethyl)-1,3,4-thiadiazol-
2-yl] -N,N' -dimethylurea]
3383-96-8 Temephos 1.0
5902-51-2 Terbacil 1.0
[5 -Chloro-3 -(1,1 -dimethylethy 1) -6 -methyl-
2,4(lH,3H)-pyrimidinedione]
79-94-7 Tetrabromobisphenol A *
630-20-6 1,1,1,2-Tetrachloroethane
79-34-5 1,1,2,2-Tetrachloroethane
127-18-4 Tetrachloroethylene
(Perchloroethylene)
354-11-0 l,l,l,2-Tetrachloro-2-fluoroethane
(HCFC-121a)
354-14-3 1,1,2,2-Tetrachloro-l-fluoroethane
(HCFC-121)
961-11-5 Tetrachlorvinphos
[Phosphoric acid, 2-chloro-l-(2,4,5-
trichlorophenyl) ethenyl dimethyl ester]
64-75-5 Tetracycline hydrochloride
116-14-3 Tetrafluoroethylene
509-14-8 Tetranitromethane
7696-12-0 Tetramethrin
[2,2-Dimethyl-3-(2-methyl-l-propenyl)
cyclopropanecarboxylic acid (1,3,4,5,6,7-
hexahydro-l,3-dioxo-2H-isoindol-2-
yl)methyl ester]
7440-28-0 Thallium
148-79-8 Thiabendazole
[2-(4-Thiazolyl)-lH-benzimidazole]
62-55-5 Thioacetamide
28249-77-6 Thiobencarb
[Carbamic acid, diethylthio-, S-(p-
chlorobenzyl)ester]
139-65-1 4,4'-Thiodianiline
59669-26-0 Thiodicarb
23564-06-9 Thiophanate ethyl
[[l,2-Phenylenebis(iminocarbonothioyl)]
biscarbamic acid diethylester]
23564-05-8 Thiophanate methyl
79-19-6 Thiosemicarbazide
62-56-6 Thiourea
137-26-8 Thiram
1314-20-1 Thorium dioxide
7550-45-0 Titanium tetrachloride
108-88-3 Toluene
584-84-9 Toluene-2,4-diisocyanate
91-08-7 Toluene-2,6-diisocyanate
26471-62-5 Toluene diisocyanate (mixed
isomers)
95-53-4 o-Toluidine
636-21-5 o-Toluidine hydrochloride
8001-35-2 Toxaphene
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.
CAS Number Chemical Name
De minimis
% Limit
43121-43-3 Triadimefon 1.0
[ 1-(4-Chlorophenoxy)-3,3-di-methyl-1-(1H-
1,2,4- triazol-l-yl)-2-butanone]
2303-17-5 Triallate 1.0
68-76-8 Triaziquone 1.0
[2,5-Cyclohexadiene-l,4-dione, 2,3,5-tris(l-
aziridinyl)-]
101200-48-0 Tribenuron methyl 1.0
[2-[[[[(4-Methoxy-6-methyl-l,3,5-triazin-2-
yl)-methylamino]-carbonyl]amino]sulfonyl]
benzoic acid methyl ester)
1983-10-4 Tributyltin fluoride 1.0
2155-70-6 Tributyltin methacrylate 1.0
78-48-8 S,S,S-Tributyltrithio- 1.0
phosphate (DBF)
52-68-6 Trichlorfon 1.0
[Phosphoric acid,(2,2,2-trichloro-l-hydroxy-
ethyl)-, dimethyl ester]
76-02-8 Trichloroacetyl chloride 1.0
120-82-1 1,2,4-Trichlorobenzene 1.0
71-55-6 1,1,1-Trichloroethane (Methyl 1.0
chloroform)
79-00-5 1,1,2-Trichloroethane 1.0
79-01-6 Trichloroethylene 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
75-02-5 Vinyl fluoride 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
Toxics Release Inventory Reporting Forms and Instructions
11-10
-------
Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
1330-20-7
87-62-7
7440-66-6
12122-67-7
Xylene (mixed isomers)
2,6-Xylidine
Zinc (fume or dust)
Zineb
1.0
0.1
1.0
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
Arranged by CAS Number
50-00-0 Formaldehyde 0.1
51-03-6 Piperonyl butoxide 1.0
51-21-8 Fluorouracil (5-Fluorouracil) 1.0
51-28-5 2,4-Dinitrophenol 1.0
51-75-2 Nitrogen mustard 0.1
[2-Chloro-N-(2-chloroethyl)-N-
methyletnanamine]
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
De minimis
CAS Number Chemical Name % Limit
Arranged by CAS Number
62-55-5
62-56-6
62-73-7
62-74-8
62-75-9
63-25-2
64-18-6
64-67-5
64-75-5
67-56-1
67-63-0
Thioacetamide
Thiourea
Dichlorvos
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
Sodium fluoroacetate
N-Nitrosodimethylamine
Carbaryl
[1-Naphthalenol, methylcarbamate]
Formic acid
Diethyl sulfate
Tetracycline hydrochloride
Methanol
Isopropyl alcohol
(only persons who manufacture by the
0.1
0.1
0.1
1.0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
strong acid process are subject, no supplier
67-66-3
67-72-1
68-12-2
68-76-8
70-30-4
71-36-3
71-43-2
71-55-6
72-43-5
72-57-1
74-83-9
74-85-1
74-87-3
74-88-4
74-90-8
74-95-3
75-00-3
75-01-4
75-02-5
75-05-8
75-07-0
75-09-2
75-15-0
75-21-8
75-25-2
75-27-4
75-34-3
75-35-4
75-43-4
75-44-5
75-45-6
75-52-5
notification)
Chloroform
Hexachloroethane
N,N-Dimethylformamide
Triaziquone
[2,5-Cyclohexadiene-l,4-dione, 2,3,5-
tris(l-aziridinyl)-]
Hexachlorophene
n-Butyl alcohol
Benzene
1,1,1 -Trie hloroethane (Methyl
chloroform)
Methoxychlor
[Benzene, 1, 1 '-(2,2,2-
trichloroethy lidene)bis [4 -methoxy-]
Trypan blue
Bromomethane (Methyl bromide)
Ethylene
Chloromethane (Methyl chloride)
Methyl iodide
Hydrogen cyanide
Methylene bromide
Chloroethane (Ethyl chloride)
Vinyl chloride
Vinyl fluoride
Acetonitrile
Acetaldehyde
Dichloromethane (Methylene
chloride)
Carbon disulfide
Ethylene oxide
Bromoform (Tribromomethane)
Dichlorobromomethane
Ethylidene dichloride
Vinylidene chloride
Dichlorofluoro methane
(HCFC-21)
Phosgene
Chlorodifluoro methane
(HCFC-22)
Nitromethane
0.1
0.1
1.0
1.0
1.0
1.0
0.1
1.0
*
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
0.1
0.1
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
Toxics Release Inventory Reporting Forms and Instructions
11-11
-------
Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
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-lH-indene]
76-87-9 Triphenyltin hydroxide 1.0
77-09-8 Phenolphthalein 0.1
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)
78-79-5 Isoprene 0.1
78-84-2 Isobutyraldehyde 1.0
78-87-5 1,2-Dichloropropane 1.0
78-88-6 2,3-Dichloropropene 1.0
78-92-2 sec-Butyl alcohol 1.0
79-00-5 1,1,2-Trichloroethane 1.0
79-01-6 Trichloroethylene 0.1
79-06-1 Acrylamide 0.1
79-10-7 Acrylic 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
79-94-7 Tetrabromobisphenol A *
80-05-7 4,4'-Isopropylidenediphenol 1.0
80-15-9 Cumene hydroperoxide 1.0
80-62-6 Methyl methacrylate 1.0
81-07-2 Saccharin (only persons who 1.0
manufacture are subject, no supplier
notification)
De minimis
CAS Number Chemical Name % Limit
Arranged by CAS Number
81-49-2
81-88-9
82-28-0
82-68-8
84-74-2
85-01-8
85-44-9
86-30-6
87-62-7
87-68-3
87-86-5
88-06-2
88-75-5
88-85-7
88-89-1
90-04-0
90-43-7
90-94-8
91-08-7
91-20-3
91-22-5
91-23-6
91-59-8
91-94-1
92-52-4
92-67-1
92-87-5
92-93-3
93-15-2
93-65-2
94-11-1
94-36-0
94-58-6
94-59-7
94-74-6
94-75-7
94-80-4
94-82-6
95-47-6
95-48-7
95-50-1
95-53-4
95-54-5
95-63-6
95-69-2
95-80-7
95-95-4
96-09-3
96-12-8
96-18-4
96-33-3
96-45-7
1 -Amino-2,4-dibromoanthraquinone
C.I. Food Red 15
1 -Amino-2-methylanthraquinone
Quintozene
[Pentachloronitrobenzene]
Dibutyl phthalate
Phenanthrene
Phthalic anhydride
N-Nitrosodiphenylamine
2,6-Xylidine
Hexachloro- 1 ,3 -butadiene
Pentachlorophenol (PCP)
2,4,6-Trichlorophenol
2-Nitrophenol
Dinitrobutyl phenol (Dinoseb)
Picric acid
o-Anisidine
2-Phenylphenol
Michler's ketone
Toluene-2,6-diisocyanate
Naphthalene
Quinoline
o-Nitroanisole
beta-Naphthylamine
3 ,3 '-Dichlorobenzidine
Biphenyl
4-Aminobiphenyl
Benzidine
4-Nitrobiphenyl
Methyleugenol
Mecoprop
2,4-D isopropyl ester
Benzoyl peroxide
Dihydrosafrole
Safrole
Methoxone
((4-Chloro-2-methylphenoxy) acetic
(MCPA)
2,4-D [Acetic acid, (2,4-
dichlorophenoxy) -]
2,4-D butyl ester
2,4-DB
o-Xylene
o-Cresol
1 ,2-Dichlorobenzene
o-Toluidine
1 ,2-Phenylenediamine
1 ,2,4-Trimethylbenzene
p-Chloro-o-toluidine
2,4-Diaminotoluene
2,4,5-Trichlorophenol
Styrene oxide
1 ,2-Dibromo-3 -chloropropane
(DBCP)
1,2,3 -Trichloropropane
Methyl acrylate
Ethylene thiourea
0.1
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.
0.
1.0
0.
0.
0.
0.
0.
0.
1.0
0.
0.
0.
acid)
0.1
0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0
0.1
0.1
1.0
0.1
0.1
0.1
1.0
0.1
Toxics Release Inventory Reporting Forms and Instructions
11-12
-------
Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
De minimis
CAS Number Chemical Name % Limit
Arranged by CAS Number
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
106-88-7
106-89-8
106-93-4
106-99-0
107-02-8
107-05-1
107-06-2
107-11-9
107-13-1
107-18-6
107-19-7
107-21-1
107-30-2
108-05-4
Dichlorophene
[2,2'-Methylenebis(4-chlorophenol)]
C.I. Solvent Yellow 3
Benzole trichloride
(Benzotrichloride)
Cumene
Acetophenone
Benzal chloride
Benzoyl chloride
Nitrobenzene
Dichloran [2,6-Dichloro-4-
nitro aniline]
5 -Nitro -o -toluidine
5 -Nitro -o -anisidine
m-Dinitrobenzene
p-Nitroaniline
4-Nitrophenol
p-Dinitrobenzene
Ethylbenzene
Styrene
Benzyl chloride
N-Nitrosopiperidine
Anilazine
[4,6-Dichloro-N-(2-chlorophenyl)-l,3
triazin-2-amine]
4,4'-Methylenebis(2-chloro aniline)
(MBOCA)
4,4'-Methylenebis(N,N-
dimethyl)benzenamine
4,4'-Methylenedianiline
4,4'-Diaminodiphenyl ether
Diglycidyl resorcinol ether
p-Chlorophenyl isocyanate
p-Anisidine
2,4-Dimethylphenol
p-Xylene
p-Cresol
1 ,4 -Dichlorobenzene
p-Chloroaniline
p-Phenylenediamine
Quinone
1,2-Butylene oxide
Epichlorohydrin
1 ,2 -Dibromoethane
(Ethylene dibromide)
1,3 -Butadiene
Acrolein
Allyl chloride
1,2-Dichloroethane (Ethylene
dichloride)
Allylamine
Acrylonitrile
Allyl alcohol
Propargyl alcohol
Ethylene glycol
Chloromethyl methyl ether
Vinyl acetate
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
5-
0.1
0.1
0.1
0.1
0.1
.0
.0
.0
.0
.0
0.1
0.1
1.0
1.0
0.1
0.1
0.1
0.1
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
0.1
0.1
De minimis
CAS Number Chemical Name % Limit
Arranged by CAS Number
108-10-1
108-31-6
108-38-3
108-39-4
108-45-2
108-60-1
108-88-3
108-90-7
108-93-0
108-95-2
109-06-8
109-77-3
109-86-4
110-00-9
110-54-3
110-57-6
110-80-5
110-82-7
110-86-1
111-42-2
111-44-4
111-91-1
114-26-1
115-07-1
115-28-6
115-32-2
Methyl isobutyl ketone
Maleic anhydride
m-Xylene
m-Cresol
1 ,3 -Phenylenediamine
Bis(2-chloro-l-methylethyl) ether
Toluene
Chlorobenzene
Cyclohexanol
Phenol
2-Methylpyridine
Malononitrile
2-Methoxyethanol
Furan
n-Hexane
trans-l,4-Dichloro-2-butene
2-Ethoxyethanol
Cyclohexane
Pyridine
Diethanolamine
Bis(2-chloroethyl) ether
Bis(2-chloroethoxy) methane
Propoxur
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
Propylene (Propene)
Chlorendic acid
Dicofol
[Benzenemethanol, 4-chloro-.alpha.-4-
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
(chlorophenyl)-.alpha.-(trichloromethyl)-]
116-06-3
116-14-3
117-79-3
117-81-7
118-74-1
119-90-4
119-93-7
120-12-7
120-36-5
120-58-1
120-71-8
120-80-9
120-82-1
120-83-2
121-14-2
121-44-8
121-69-7
121-75-5
122-34-9
122-39-4
122-66-7
123-31-9
123-38-6
123-63-7
123-72-8
Aldicarb
Tetrafluoroethylene
2-Aminoanthraquinone
Di(2-ethylhexyl) phthalate
Hexachlorobenzene
3 ,3 '-Dimethoxybenzidine
3 ,3 '-Dimethylbenzidine
(o-Tolidine)
Anthracene
2,4-DP
Isosafrole
p-Cresidine
Catechol
1 ,2,4-Trichlorobenzene
2,4-Dichlorophenol
2,4-Dinitrotoluene
Triethylamine
N,N-Dimethylaniline
Malathion
Simazine
Diphenylamine
1 ,2-Diphenylhydrazine
(Hydrazobenzene)
Hydroquinone
Propionaldehyde
Paraldehyde
Butyraldehyde
1.0
0.
0.
0.
*
0.
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
1.0
0.1
1.0
1.0
1.0
1.0
Toxics Release Inventory Reporting Forms and Instructions
11-13
-------
Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
123-91-1 1,4-Dioxane 0.1
124-40-3 Dimethylamine 1.0
124-73-2 Dibromotetrafluoroethane 1.0
(Halon 2402)
126-72-7 Tris(2,3-dibromopropyl) 0.1
phosphate
126-98-7 Methacrylonitrile 1.0
126-99-8 Chloroprene 0.1
127-18-4 Tetrachloroethylene 0.1
(Perchloroethylene)
128-03-0 Potassium 1.0
dimethyldithiocarbamate
128-04-1 Sodium dimethyldithiocarbamate 1.0
128-66-5 C.I. Vat Yellow 4 1.0
131-11-3 Dimethyl phthalate 1.0
131-52-2 Sodium pentachlorophenate 1.0
132-27-4 Sodium o-phenylphenoxide 0.1
132-64-9 Dibenzofuran 1.0
133-06-2 Captan 1.0
[lH-Isoindole-l,3(2H)-dione, 3a,4,7,7a-
tetrahydro-2-[(trichloromethyl)thio]-]
133-07-3 Folpet 1.0
133-90-4 Chloramben 1.0
[Benzoic acid, 3-amino-2,5-dichloro-]
134-29-2 o-Anisidine hydrochloride 0.1
134-32-7 alpha-Naphthylamine 0.1
135-20-6 Cupferron 0.1
[Benzeneamine, N-hydroxy-N-nitroso,
ammonium salt]
136-45-8 Dipropyl isocinchomeronate 1.0
137-26-8 Thiram 1.0
137-41-7 Potassium N-methyldithio- 1.0
carbamate
137-42-8 Metham sodium (Sodium 1.0
methyldithiocarbamate)
138-93-2 Disodium cyanodithioimido- 1.0
carbonate
139-13-9 Nitrilotriacetic acid 0.1
139-65-1 4,4'-Thiodianiline 0.1
140-88-5 Ethyl acrylate 0.1
141-32-2 Butyl acrylate 1.0
142-59-6 Nabam 1.0
148-79-8 Thiabendazole 1.0
[2-(4-Thiazolyl)-lH-benzimidazole]
149-30-4 2-Mercaptobenzothiazole 1.0
(MET)
150-50-5 Merphos 1.0
150-68-5 Monuron 1.0
151-56-4 Ethyleneimine (Aziridine) 0.1
156-10-5 p-Nitrosodiphenylamine 1.0
156-62-7 Calcium cyanamide 1.0
191-24-2 Benzo(g,h,i)perylene *
298-00-0 Methyl parathion 1.0
300-76-5 Naled 1.0
301-12-2 Oxydemeton methyl 1.0
[S-(2-(Ethylsulfinyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
De minimis
CAS Number Chemical Name % Limit
Arranged by CAS Number
302-01-2
306-83-2
309-00-2
314-40-9
319-84-6
330-54-1
330-55-2
333-41-5
334-88-3
353-59-3
354-11-0
354-14-3
354-23-4
354-25-6
357-57-3
422-44-6
422-48-0
422-56-0
431-86-7
460-35-5
463-58-1
465-73-6
492-80-8
505-60-2
507-55-1
509-14-8
510-15-6
528-29-0
532-27-4
533-74-4
Hydrazine 0.1
2,2-Dichloro-l , 1 , 1 -trifluoroethane 1 .0
(HCFC-123)
Aldrin *
[ 1 ,4 : 5,8-Dimethanonaphthalene,
l,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a-
hexahydro-(l.alpha.,4.alpha.,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
Bromacil 1.0
(5-Bromo-6-methyl-3-(l-methylpropyl)-
2,4( lH,3H)-pyrimidinedione)
alpha-Hexachlorocyclohexane 0.1
Diuron 1.0
Linuron 1.0
Diazinon 1.0
Diazo methane 1.0
Bromochlorodifluoromethane 1.0
(Halon 12 11)
1,1,1 ,2-Tetrachloro-2-fluoroethane 1 .0
(HCFC-121a)
1 , 1 ,2,2-Tetrachloro- 1 -fluoroethane 1 .0
(HCFC-121)
l,2-Dichloro-l,l,2- 1.0
trifluoroethane (HCFC-123a)
l-Chloro-1,1,2,2- 1.0
tetrafluoroethane (HCFC-124a)
Brucine 1.0
1,2-Dichloro-l, 1,2,3,3- 1.0
pentafluoropropane (HCFC-225bb)
2,3-Dichloro-l, 1,1,2,3- 1.0
pentafluoropropane (HCFC-225ba)
3,3-Dichloro-l, 1,1,2,2- 1.0
pentafluoropropane (HCFC-225ca)
1,2-Dichloro-l, 1,3,3,3- 1.0
pentafluoropropane (HCFC-225da)
3-Chloro-l,l,l-trifluoropropane 1.0
(HCFC-253fb)
Carbonyl sulfide 1.0
Isodrin *
C.I. Solvent Yellow 34 0.1
(Auramine)
Mustard gas 0.1
[Ethane, l,l'-thiobis[2-chloro-]
1,3-Dichloro-l, 1,2,2,3- 1.0
pentafluoropropane (HCFC-225cb)
Tetranitromethane 0.1
Chlorobenzilate 1.0
[Benzeneacetic acid, 4-chloro-.alpha.-(4-
chlorophenyl)-.alpha.-hydroxy-, ethyl
ester]
o-Dinitrobenzene 1.0
2-Chloroacetophenone 1.0
Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione)
Toxics Release Inventory Reporting Forms and Instructions
11-14
-------
Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number
De minimis
Chemical Name % Limit
Arranged by CAS Number
534-52-1
540-59-0
541-41-3
541-53-7
541-73-1
542-75-6
542-76-7
542-88-1
554-13-2
556-52-5
556-61-6
563-47-3
569-64-2
584-84-9
593-60-2
594-42-3
606-20-2
608-93-5
612-82-8
612-83-9
615-05-4
615-28-1
621-64-7
624-18-0
624-83-9
630-20-6
636-21-5
639-58-7
680-31-9
684-93-5
709-98-8
759-73-9
759-94-4
764-41-0
812-04-4
834-12-8
842-07-9
872-50-4
924-16-3
924-42-5
957-51-7
961-11-5
4,6-Dinitro-o-cresol
1 ,2 -Dichloroethylene
Ethyl chloroformate
2,4-Dithiobiuret
1,3 -Dichlorobenzene
1,3 -Dichloropropylene
3 -Chloropropionitrile
Bis(chloromethyl) ether
Lithium carbonate
Glycidol
Methyl isothiocyanate
[Isothiocyanatomethane]
3 -Chloro -2 -methyl- 1 -propene
C.I. Basic Green 4
Toluene-2,4-diisocyanate
Vinyl bromide
Perchloromethyl mercaptan
2,6-Dinitrotoluene
Pentachlorobenzene
3 ,3 '-Dimethylbenzidine
dihydrochloride (o-Tolidine
dihydrochloride)
3 ,3 '-Dichlorobenzidine
dihydrochloride
2,4-Diaminoanisole
1 ,2 -Pheny lenediamine
dihydrochloride
N-Nitrosodi-n-propylamine
1 ,4 -Pheny lenediamine
dihydrochloride
Methyl isocyanate
1,1,1 ,2-Tetrachloroethane
o-Toluidine hydrochloride
Triphenyltin chloride
Hexamethylphosphoramide
N-Nitroso-N-methylurea
Propanil (N-(3,4-Dichlorophenyl)
propanamide)
N-Nitroso-N-ethylurea
Ethyl dipropylthiocarbamate
(EPTC)
l,4-Dichloro-2-butene
1 , 1 -Dichloro- 1 ,2,2-trifluoroethane
(HCFC-123b)
Ametryn
(N-Ethyl-N' -( 1 -methylethyl)-6-
.0
.0
.0
.0
.0
0.1
1.0
0.1
1.0
0.1
1.0
0.1
1.0
0.1
0.1
1.0
0.1
*
0.1
0.1
0.1
1.0
0.1
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
0.1
1.0
1.0
1.0
1.0
(methylthio)-l,3,5,-triazine-2,4-diamine)
C.I. Solvent Yellow 14
N-Methyl-2-pyrrolidone
N-Nitrosodi-n-butylamine
N-Methylolacrylamide
Diphenamid
Tetrachlorvinphos
[Phosphoric acid, 2-chloro-l-(2,4,5-
trichlorophenyl)ethenyldimethyl ester]
1.0
1.0
0.1
1.0
1.0
1.0
De minimis
CAS Number
Chemical Name % Limit
Arranged by CAS Number
989-38-8
1114-71-2
1120-71-4
1134-23-2
1163-19-5
1313-27-5
1314-20-1
1319-77-3
1320-18-9
1330-20-7
1332-21-4
1335-87-1
1336-36-3
1344-28-1
1464-53-5
1563-66-2
1582-09-8
1634-04-4
1649-08-7
1689-84-5
1689-99-2
1717-00-6
1836-75-5
1861-40-1
1897-45-6
1910-42-5
1912-24-9
1918-00-9
1918-02-1
1918-16-7
1928-43-4
1929-73-3
1929-82-4
1937-37-7
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
Fob/chlorinated biphenyls (PCBs)
Aluminum oxide (fibrous forms)
Diepoxybutane
Carbofuran
Trifluralin
[Benezeneamine, 2,6-dinitro-N,N-
dipropyl-4 -(trifluoromethy 1) -]
Methyl tert-butyl ether
1,2-Dichloro-l, 1-difluoroethane
(HCFC-132b)
Bromoxynil
(3,5-Dibromo-4-hydroxybenzonitrile)
Bromoxynil octanoate
(Octanoic acid, 2,6-dibromo-4-
cyanophenyl ester)
1 , 1 -Dichloro- 1 -fluoroethane
(HCFC-141b)
Nitrofen
[Benzene, 2,4-dichloro-l-(4-
nitrophenoxy)-]
Benfluralin
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)benzenamine)
Chlorothalonil
[1,3-Benzenedicarbonitrile, 2,4,5,6-
tetrachloro-]
Paraquat dichloride
Atrazine
(6-Chloro-N-ethyl-N' -( 1 -methylethyl)-
l,3,5-triazine-2,4-diamine)
Dicamba
(3 ,6-Dichloro-2-methoxybenzoic acid)
Picloram
Propachlor
[2-Chloro-N-( 1 -methylethyl)-N-
phenylacetamide]
2,4-D 2-ethylhexyl ester
2,4-D butoxyethyl ester
Nitrapyrin
(2-Chloro-6-(trichloromethyl)pyridine)
C.I. Direct Black 38
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
*
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
0.1
Toxics Release Inventory Reporting Forms and Instructions
11-15
-------
Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
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. l)heptane-2,3-
dicarboxylic acid, dipotassium salt]
2164-17-2 Fluometuron 1.0
[Urea, N,N-dimethyl-N'-[3-
(trifluoromethyl)phenyl] -]
2212-67-1 Molinate 1.0
(IH-Azepine-l-carbothioic acid,
hexahydro-S-ethyl ester)
2234-13-1 Octachloronaphthalene 1.0
2300-66-5 Dimethylamine dicamba 1.0
2303-16-4 Diallate 1.0
[Carbamothioic acid, bis(l-methylethyl)-S-
(2,3-dichloro-2-propenyl) ester]
2303-17-5 Triallate 1.0
2312-35-8 Propargite 1.0
2439-01-2 Chinomethionat 1.0
[6-Methyl-1,3 -dithiolo [4,5 -b]quinoxalin-2-
one]
2439-10-3 Dodine 1.0
[Dodecylguanidine monoacetate]
2524-03-0 Dimethyl chlorothiophosphate 1.0
2602-46-2 C.I. Direct Blue 6 0.1
2655-15-4 2,3,5-Trimethylphenyl methyl 1.0
carbamate
2699-79-8 Sulfuryl fluoride (Vikane) 1.0
2702-72-9 2,4-D sodium salt 0.1
2832-40-8 C.I. Disperse Yellow 3 1.0
2837-89-0 2-Chloro-l,1,1,2- 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
3296-90-0 2,2-bis(Bromomethyl)-l,3-propanediol 0.1
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-1,4-
oxathiin-3 -carboxamide)
5598-13-0 Chlorpyrifos methyl 1.0
[O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate]
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
5902-51-2 Terbacil 1.0
[5 -Chloro-3 -(1,1 -dimethy lethyl)-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-
l,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 *
7440-02-0 Nickel 0.1
7440-22-4 Silver 1.0
7440-28-0 Thallium 1.0
7440-36-0 Antimony 1.0
7440-38-2 Arsenic 0.1
7440-39-3 Barium 1.0
7440-41-7 Beryllium 0.1
7440-43-9 Cadmium 0.1
7440-47-3 Chromium 1.0
7440-48-4 Cobalt 0.1
7440-50-8 Copper 1.0
7440-62-2 Vanadium (except when contained 1.0
in an alloy)
7440-66-6 Zinc (fume or dust) 1.0
7550-45-0 Titanium tetrachloride 1.0
7632-00-0 Sodium nitrite 1.0
7637-07-2 Boron trifluoride 1.0
7647-01-0 Hydrochloric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any
particle size)
7664-39-3 Hydrogen fluoride 1.0
7664-41-7 Ammonia 1.0
(includes anhydrous ammonia and aqueous
ammonia from water dissociable
ammonium salts and other sources; 10
percent of total aqueous ammonia is
reportable under this listing)
7664-93-9 Sulfuric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any
particle size)
7696-12-0 Tetramethrin 1.0
[2,2-Dimethyl-3-(2-methyl-l-
propenyl)cyclopropanecarboxylic acid
(l,3,4,5,6,7-hexahydro-l,3-dioxo-2H-
isoindol-2-yl)methyl ester]
7697-37-2 Nitric acid 1.0
7723-14-0 Phosphorus (yellow or white) 1.0
7726-95-6 Bromine 1.0
7758-01-2 Potassium bromate 0.1
7782-41-4 Fluorine 1.0
7782-49-2 Selenium 1.0
Toxics Release Inventory Reporting Forms and Instructions
11-16
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Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
7782-50-5 Chlorine 1.0
7783-06-4 Hydrogen sulfide 1.0
7786-34-7 Mevinphos 1.0
7803-51-2 Phosphine 1.0
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
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-
dimethy 1-3 -(2 -methyl-1 -propenyl)
cyclopropanecarboxylate]]
12122-67-7 Zineb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
zinc complex]
12427-38-2 Maneb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
manganese complex]
13194-48-4 Ethoprop 1.0
[Phosphorodithioic acid O-ethyl S,S-
dipropyl ester]
13356-08-6 Fenbutatin oxide 1.0
(Hexakis(2-methyl-2-phenylpropyl)
distannoxane)
13463-40-6 Iron pentacarbonyl 1.0
13474-88-9 l,l-Dichloro-l,2,2,3,3- 1.0
pentafluoropropane (HCFC-225cc)
13684-56-5 Desmedipham 1.0
14484-64-1 Ferbam 1.0
[Tris(dimethylcarbamodithioato-S,S')iron]
15972-60-8 Alachlor 1.0
16071-86-6 C.I. Direct Brown 95 0.1
16543-55-8 N-Nitrosonornicotine 0.1
17804-35-2 Benomyl 1.0
19044-88-3 Oryzalin 1.0
[4-(Dipropylamino)-3,5-
dinitrobenzenesulfonamide]
19666-30-9 Oxydiazon 1.0
[3-[2,4-Dichloro-5-(l-methylethoxy)
phenyl]-5-(l,l-dimethylethyl)-l,3,4-
oxadiazol-2(3H)-one]
20325-40-0 3,3'-Dimethoxybenzidine 0.1
dihydrochloride (o-Dianisidine
dihydrochloride)
20354-26-1 Methazole 1.0
[2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
oxadiazolidine-3,5-dione]
20816-12-0 Osmium tetroxide .0
20859-73-8 Aluminum phosphide .0
21087-64-9 Metribuzin .0
21725-46-2 Cyanazine .0
22781-23-3 Bendiocarb .0
[2,2-Dimethyl-1,3 -benzodioxol-4-ol
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
23564-05-8
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
35400-43-2
methylcarbamate]
Thiophanate methyl 1.0
Thiophanate ethyl 1.0
[[l,2-Phenylenebis(iminocarbonothioyl)]
biscarbamic acid diethyl ester]
Pronamide 1.0
Isofenphos 1.0
[2-[[Ethoxyl[(l-methylethyl)-
amino]phosphinothioyl]oxy]benzoic acid
1-methylethyl ester]
Dinitrotoluene (mixed isomers) 1.0
Dichlorobenzene (mixed isomers) 0.1
Diaminotoluene (mixed isomers) 0.1
Phenothrin 1.0
[2,2-Dimethyl-3-(2-methyl-l-
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester]
Toluene diisocyanate 0.1
(mixed isomers)
Sodium azide 1.0
Triforine 1.0
[N,N'-[l,4-PiperazinediyIbis (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 1.0
Octachlorostyrene *
Pirimiphos methyl 1.0
[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-( 1,1 -Dimethylethyl)-1,3,4-
thiadiazol-2-yl]-N,N'-dimethylurea]
Dichlorotrifluoroethane 1.0
Diflubenzuron 1.0
Sulprofos
[O-Ethyl O-[4-(methylthio)phenyl]-
phosphorodithioic acid S-propyl ester]
1.0
Toxics Release Inventory Reporting Forms and Instructions
11-17
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Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
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
55406-53-6
57213-69-1
59669-26-0
60168-88-9
Imazalil 1.0
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl] -IH-imidazole]
l-Bromo-l-(bromomethyl)-l,3- 1.0
propanedicarbonitrile
Diethatyl ethyl 1.0
2,4-Diaminoanisole sulfate 0.1
Dinocap 1.0
Fenpropathrin 1.0
[2,2,3,3 -Tetramethylcyclopropane
carboxylic acid cyano(3-
phenoxyphenyl)methyl ester]
Pendimethalin *
[N-(l-Ethyrpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine]
Profenofos 1.0
[O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
propyl phosphorothioate]
3,3'-Dimethylbenzidine 0.1
dihydrofluoride (o-
Tolidinedihydrofluoride)
Oxyfluorfen 1.0
Triadimefon 1.0
[ 1 -(4-Chlorophenoxy)-3,3 -dimethyl-1 -(1H-
1,2,4-triazol-1 -yl)-2-butanone]
Vinclozolin 1.0
[3-(3,5-Dichlorophenyl)-5-ethenyl-5-
methyl-2,4-oxazolidinedione]
Hexazinone 1.0
Diclofop methyl 1.0
[2-[4-(2,4-Dichlorophenoxy)-
phenoxyjpropanoic acid, methyl ester]
Fenvalerate 1.0
[4-Chloro -alpha-( 1 -methy lethy 1) -
benzeneacetic acid cyano(3-
phenoxyphenyl)methyl ester]
Permethrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropane carboxylic acid,
(3-phenoxyphenyl)methyl ester]
Bromacil, lithium salt 1.0
[2,4(lH,3H)-Pyrimidinedione, 5-bromo-6-
methyl-3-(l-methyIpropyl), lithium salt]
2,4-D 2-ethyl-4-methylpentyl 0.1
ester
Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione, ion(l-), sodium]
Dimethipin 1.0
[2,3-Dihydro-5,6-dimethyl-l,4-dithiin
1,1,4,4-tetraoxide]
3-Iodo-2-propynyl butyl 1.0
carbamate
Triclopyr triethy lammonium salt 1.0
Thiodicarb 1.0
Fenarimol 1.0
[.alpha.-(2-Chlorophenyl)-.alpha.-(4-
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
chlorophenyl)-5-pyrimidinemethanol]
60207-90-1 Propiconazole 1.0
[l-[2-(2,4-Dichlorophenyl)-4-propyl- 1,3-
dioxolan-2-yl]-methyl-lH-l,2,4,-triazole]
62476-59-9 Acifluorfen, sodium salt 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
2-nitrobenzoic acid, sodium salt]
63938-10-3 Chlorotetrafluoroethane 1.0
64902-72-3 Chlorsulfuron 1.0
[2-Chloro-N-[[(4-methoxy-6-methyl-l,3,5-
triazin-2-yl)amino] carbonyl]
benzenesulfonamide]
64969-34-2 3,3'-Dichlorobenzidine sulfate 0.1
66441-23-4 Fenoxaprop ethyl 1.0
[2-(4-((6-Chloro-2-
benzoxazolylen)oxy)phenoxy)propanoic
acid, ethyl ester]
67485-29-4 Hydramethylnon 1.0
[Tetrahydro-5,5-dimethyl-2(lH)-
pyrimidinone[3 -[4-
(trifluoromethyl)phenyl]-l-[2-[4-
(trifluoromethyl)phenyl]ethenyl]-2-
propenylidene]hydrazone]
68085-85-8 Cyhalothrin 1.0
[3-(2-Chloro-3,3,3-trifluoro-1-propenyl)-
2,2-dimethylcyclopropanecarboxylic acid
cyano(3-phenoxyphenyl) methyl ester]
68359-37-5 Cyfluthrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid,
cyano(4-fluoro-3 -phenoxyphenyl) methyl
ester]
69409-94-5 Fluvalinate 1.0
[N-[2-Chloro-4-
(trifluoromethyl)phenyl]DL-valine(+)-
cyano(3 -phenoxyphenyl)methyl ester]
69806-50-4 Fluazifop butyl 1.0
[2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]phenoxy]propanoic acid,
butyl ester]
71751-41-2 Abamectin[AvermectinBl] 1.0
72178-02-0 Fomesafen 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
N-methylsulfonyl)-2-nitrobenzamide]
72490-01-8 Fenoxycarb 1.0
[[2-(4-Phenoxy phenoxy)ethyl]carbamic
acid ethyl ester]
74051-80-2 Sethoxydim 1.0
[2-[l-(Ethoxyimino)butyl]-5-[2-
(ethylthio)propyl] -3 -hydroxyl-2-
cyclohexen-1 -one]
76578-14-8 Quizalofop-ethyl 1.0
[2-[4-[(6-Chloro-2-quinoxalinyl)
oxy]phenoxy]propanoic acid ethyl ester]
77501-63-4 Lactofen 1.0
[Benzoic acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy] -2-nitro-, 2-
Toxics Release Inventory Reporting Forms and Instructions
11-18
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Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
ethoxy-l-methyl-2-oxoethyl ester]
82657-04-3 Bifenthrin 1.0
88671-89-0 Myclobutanil 1.0
[.alpha.-Butyl-.arpha.-(4-chlorophenyl)-
1H-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-yl)amino]carbonyl]
amino] sulfonyljbenzoate]
101200-48-0 Tribenuron methyl 1.0
[2-[[[[(4-Methoxy-6-methyl-l,3,5-triazin-
2-yl)methylamino]carbonyl]
amino] sulfonyljbenzoic acid methyl ester]
111512-56-2 l,l-Dichloro-l,2,3,3,3- 1.0
pentafluoropropane (HCFC-225eb)
111984-09-9 3,3'-Dimethoxybenzidine 0.1
hydrochloride (o-Dianisidine
hydrochloride)
127564-92-5 Dichloropentafluoropropane 1.0
128903-21-9 2,2-Dichloro-l,1,1,3,3- 1.0
pentafluoropropane (HCFC-225aa)
136013-79-1 1,3-Dichloro-l,1,2,3,3- 1.0
pentafluoropropane (HCFC-225ea)
c.
Chemical Categories
Section 313 requires reporting on the EPCRA Section 313
chemical categories listed below, in addition to the specific
EPCRA Section 313 chemicals listed above.
The metal compound categories listed below, unless otherwise
specified, are defined as including any unique chemical
substance that contains the named metal (e.g., antimony, nickel,
etc.) as part of that chemical's structure.
EPCRA Section 313 chemical categories are subject to the 1%
de minimis concentration unless the substance involved meets
the definition of an OSHA carcinogen in which case the 0.1% de
minimis concentration applies. The de minimis concentration for
each category is provided in parentheses. The de minimis
exemption is not available for PBT chemicals, therefore an
asterisk appears where a de minimis limit would otherwise
appear. However, for purposes of the supplier notification
requirement only, such limits are provided in Appendix D.
N010 Antimony Compounds (1.0)
Includes any unique chemical substance that contains
antimony as part of that chemical's infrastructure.
N020 Arsenic Compounds (inorganic compounds: 0.1;
organic compounds: 1.0)
Includes any unique chemical substance that contains
arsenic as part of that chemical's infrastructure.
N040 Barium Compounds (1.0)
Includes any unique chemical substance that contains
barium as part of that chemical's infrastructure. This
category does not include:
Barium sulfate CAS Number 7727-43-7
N050 Beryllium Compounds (0.1)
Includes any unique chemical substance that contains
beryllium as part of that chemical's infrastructure.
N078 Cadmium Compounds (0.1)
Includes any unique chemical substance that contains
cadmium as part of that chemical's infrastructure.
N084 Chlorophenols (0.1)
N090
N096
N100
N106
N120
Where x = 1 to 5
Chromium Compounds
(except for chromite ore mined in the Transvaal
Region of South Africa and the unreacted ore
component of the chromite ore processing residue
(COPR). COPR is the solid waste remaining after
aqueous extraction of oxidized chromite ore that has
been combined with soda ash and kiln roasted at
approximately 2,000 °F.)
(chromium VI compounds: 0.1; chromium III
compounds: 1.0)
Includes any unique chemical substance that contains
chromium as part of that chemical's
infrastructure.
Cobalt Compounds (inorganic compounds: 0.1;
organic compounds: 1.0)
Includes any unique chemical substance that contains
cobalt as part of that chemical's infrastructure.
Copper Compounds (1.0)
Includes any unique chemical substance that contains
copper as part of that chemical's infrastructure. This
category does not include copper phthalocyanine
compounds that are substituted with only hydrogen,
and/or chlorine, and/or bromine.
Cyanide Compounds (1.0)
X^CN~ where X = if or any other group where a
formal dissociation can be made. For example KCN or
Ca(CN)2
Diisocyanates (1.0)
This category includes only those chemicals listed
below.
CAS Number
38661-72-2
10347-54-3
2556-36-7
Chemical Name
l,3-Bis(methylisocyanate) -
cyclohexane
l,4-Bis(methyrisocyanate)-
cyclohexane
1,4-Cyclohexane
Toxics Release Inventory Reporting Forms and Instructions
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Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
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 Form R Schedule 1, enter
the data for each member of the category in the order
they are listed here (i.e., 1-17).]
Box
#
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
CAS
Number
1746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
3268-87-9
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0
Chemical Name
2,3,7,8-
Tetrachlorodibenzo -p-dioxin
1,2,3,7,8-
Pentachlorodibenzo-p-dioxin
1,2,3,4,7,8-
Hexachlorodibenzo -p-dioxin
1,2,3,6,7,8-
Hexachlorodibenzo -p-dioxin
1,2,3,7,8,9-
Hexachlorodibenzo -p-dioxin
1,2,3,4,6,7,8-
Heptachlorodibenzo-p-dioxin
1,2,3,4,6,7,8,9-
Octachlorodibenzo-p-dioxin
2,3,7,8-
Tetrachlorodibenzofuran
1,2,3,7,8-
Pentachlorodibenzofuran
2,3,4,7,8-
Pentachlorodibenzofuran
1,2,3,4,7,8-
Hexachlorod-benzofuran
1,2,3,6,7,8-
Hexachlorodibenzofuran
1,2,3,7,8,9-
Hexachlorodibenzofuran
2,3,4,6,7,8-
Hexachlorodibenzofuran
1,2,3,4,6,7,8-Heptachlorodibenzofuran
1,2,3,4,7,8,9-
Heptachlorodibenzofuran
1,2,3,4,6,7,8,9-
Octachlorodibenzofuran
N171 Ethylenebisdithiocarbamic acid, salts and esters
EBDCs) (1.0)
Includes any unique chemical substance that contains
an EBDC or an EBDC salt as part of that chemical's
infrastructure.
N230 Certain Glycol Ethers (1.0)
R-(OCH2CH2)n-OR'
where:
n = 1,2, or 3;
R = Alkyl C7 or less; or
R = phenyl or alkyl substituted phenyl;
R' = H or alkyl C7 or less; or
OR' consisting of carboxylic acid ester, sulfate,
phosphate, nitrate, or sulfonate.
N420 Lead Compounds (*)
Includes any unique chemical substance that contains
lead as part of that chemical's infrastructure.
Toxics Release Inventory Reporting Forms and Instructions
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Table II. EPCRA Section 313 Chemical List for Reporting Year 2012
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)
,Brx
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)
Includes those chemicals defined by the following
formula:
Where x= 10 to 13;
y = 3 to 12; and
where the average chlorine content ranges from 40-
70% with the limiting molecular formulas
CioHi9Cl3 and
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
42397-64-8 1,6-Dinitropyrene
42397-65-9 1,8-Dinitropyrene
193-39-5 Indeno(l,2,3-cd)pyrene
56-49-5 3-Methylcholanthrene
3697-24-3 5-Methylchrysene
7496-02-8 6-Nitrochrysene
5522-43-0 1-Nitropyrene
57835-92-4 4-Nitropyrene
N725 Selenium Compounds (1.0)
Includes any unique chemical substance that contains
selenium as part of that chemical's infrastructure.
N740 Silver Compounds (1.0)
Includes any unique chemical substance that contains
silver as part of that chemical's infrastructure.
N746 Strychnine and salts (1.0)
Includes any unique chemical substance that contains
strychnine or a strychnine salt as part of that
chemical's infrastructure.
N760 Thallium Compounds (1.0)
Includes any unique chemical substance that contains
thallium as part of that chemical's infrastructure.
N770 Vanadium compounds (1.0)
Includes any unique chemical substance that contains
vanadium as part of that chemical's infrastructure.
N874 Warfarin and salts (1.0)
Includes any unique chemical substance that contains
warfarin or a warfarin salt as part of that chemical's
infrastructure.
N982 Zinc Compounds (1.0)
Includes any unique chemical substance that contains
zinc as part of that chemical's infrastructure.
N590 Polycyclic aromatic compounds (PACs) (*)
This category includes the chemicals listed below.
CAS Number
56-55-3
205-99-2
205-82-3
207-08-9
206-44-0
189-55-9
218-01-9
50-32-8
226-36-8
224-42-0
53-70-3
194-59-2
Chemical Name
Benz(a)anthracene
Benzo(b)fluoranthene
Benzo (j)fluoranthene
Benzo(k)fluoranthene
Benzo (j,k)fluorene
Benzo (r, s,t)pentaphene
Benzo(a)phenanthrene
Benzo(a)pyrene
Dibenz(a,h)acridine
Dibenz(a,j )acridine
Dibenzo(a,h)anthracene
7H-Dibenzo(c,g)carbazole
Toxics Release Inventory Reporting Forms and Instructions
11-21
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Table III. State Abbreviations
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Marshall Islands
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
AL
AK
AS
AZ
AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL
IN
IA
KS
KY
LA
ME
MH
MD
MA
MI
MN
MS
MO
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Northern Marianas Islands
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
MT
NE
NV
NH
NJ
NM
NY
NC
ND
MP
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
WI
WY
Toxics Release Inventory Reporting Forms and Instructions
III-l
-------
Table IV. Federal Information Processing Standards (FIPS)
Country Codes
AA
AC
AE
AF
AG
AJ
AL
AM
AN
AO
AR
AS
AT
AU
AV
AY
BA
BB
BC
BD
BE
BF
BG
BH
BK
BL
BM
BN
BO
BP
BR
BS
BT
BU
BV
BX
BY
CA
CB
CD
KE
KG
KN
KQ
KR
Aruba
Antigua and Barbuda
United Arab
Emirates
Afghanistan
Algeria
Azerbaijan
Albania
Armenia
Andorra
Angola
Argentina
Australia
Ashmore and Cartier
Islands
Austria
Anguilla
Antarctica
Bahrain
Barbados
Botswana
Bermuda
Belgium
The Bahamas
Bangladesh
Belize
Bosnia and
Herzegovina
Bolivia
Burma
Benin
Belarus
Solomon Islands
Brazil
Bassas da India
Bhutan
Bulgaria
Bouvet Island
Brunei
Burundi
Canada
Cambodia
Chad
Kenya
Kyrgyzstan
North Korea
Kingman Reef
Kiribati
CE
CF
CG
CH
CI
CJ
CK
CM
CN
CO
CR
CS
CT
CU
CV
CW
CY
DA
DJ
DO
DR
EC
EG
El
EK
EN
ER
ES
ET
EU
EZ
FG
FI
FJ
FK
FO
FP
FR
KS
KT
KU
KZ
LA
Sri Lanka
Congo
(Brazzaville)
Congo (Kinshasa)
China
Chile
Cayman Islands
Cocos (Keeling)
Islands
Cameroon
Comoros
Colombia
Coral Sea Islands
Costa Rica
Central African
Republic
Cuba
Cape Verde
Cook Islands
Cyprus
Denmark
Djibouti
Dominica
Dominican
Republic
Ecuador
Egypt
Ireland
Equatorial Guinea
Estonia
Eritrea
El Salvador
Ethiopia
Europa Island
Czech Republic
French Guiana
Finland
Fiji
Falkland Islands
(Islas Malvinas)
Faroe Islands
French Polynesia
France
South Korea
Christmas Island
Kuwait
Kazakhstan
Laos
FS
GA
GB
GG
GH
GI
GJ
GK
GL
GM
GO
GP
GR
GT
GV
GY
GZ
HA
HK
HM
HO
HR
HU
1C
ID
IM
IN
IO
IP
IR
IS
IT
IV
IZ
JA
JE
JM
JN
JO
JU
LE
LG
LH
LI
LO
French Southern and
Antarctic Lands
The Gambia
Gabon
Georgia
Ghana
Gibraltar
Grenada
Guernsey
Greenland
Germany
Glorioso Islands
Guadeloupe
Greece
Guatemala
Guinea
Guyana
Gaza Strip
Haiti
Hong Kong
Heard Island and
McDonald Islands
Honduras
Croatia
Hungary
Iceland
Indonesia
Isle of Man
India
British Indian Ocean
Territory
Clipperton Island
Iran
Israel
Italy
Cote D'lvoire
Iraq
Japan
Jersey
Jamaica
Jan Mayen
Jordan
Juan de Nova Island
Lebanon
Latvia
Lithuania
Liberia
Slovakia
Toxics Release Inventory Reporting Forms and Instructions
IV-1
-------
Table IV. Federal Information Processing Standards (FIPS) Country Codes
LS
LT
LU
LY
MA
MB
MC
MD
MF
MG
MH
MI
MK
ML
MN
MO
MP
MR
MT
MU
MV
MX
MY
MZ
NC
NE
NF
NG
NH
NI
NL
NO
NP
NR
NS
NT
NU
NZ
PA
PC
PE
Liechtenstein
Lesotho
Luxembourg
Libya
Madagascar
Martinique
Macau
Moldova
Mayotte
Mongolia
Montserrat
Malawi
Macedonia
Mali
Monaco
Morocco
Mauritius
Mauritania
Malta
Oman
Maldives
Mexico
Malaysia
Mozambique
New Caledonia
Niue
Norfolk Island
Niger
Vanuatu
Nigeria
Netherlands
Norway
Nepal
Nauru
Suriname
Netherlands Antilles
Nicaragua
New Zealand
Paraguay
Pitcairn Islands
Peru
PF
PG
PK
PL
PM
PO
PP
PS
PU
QA
RE
RO
RP
RS
RW
SA
SB
SC
SE
SF
SG
SH
SI
SL
SM
SN
SO
SP
ST
SU
sv
sw
sx
SY
SZ
TD
TE
Paracel Islands
Spratly Islands
Pakistan
Poland
Panama
Portugal
Papua New Guinea
Palau
Guinea-Bissau
Qatar
Reunion
Romania
Philippines
Russia
Rwanda
Saudi Arabia
St. Pierre and
Miquelon
St. Kitts and Nevis
Seychelles
South Africa
Senegal
St. Helena
Slovenia
Sierra Leone
San Marino
Singapore
Somalia
Spain
St. Lucia
Sudan
Svalbard
Sweden
South Georgia and
South Sandwich
Islands
Syria
Switzerland
Trinidad and
Tobago
Tromelin Island
TH
TI
TK
TL
TN
TO
TP
TS
TT
TU
TV
TW
TX
TZ
UG
UK
UP
UV
UY
UZ
VC
VE
VI
VM
VT
WA
WE
WF
WI
WS
WZ
YI
YM
ZA
ZI
Thailand
Tajikistan
Turks and Caicos
Islands
Tokelau
Tonga
Togo
Sao Tome and
Principe
Tunisia
East Timor
Turkey
Tuvalu
Taiwan
Turkmenistan
Tanzania
Uganda
United Kingdom
Ukraine
Burkina Faso
Uruguay
Uzbekistan
St. Vincent and the
Grenadines
Venezuela
British Virgin
Islands
Vietnam
Vatican City
Namibia
West Bank
Wallis and Futuna
Western Sahara
Western Samoa
Swaziland
Yugoslavia
Yemen
Zambia
Zimbabwe
Toxics Release Inventory Reporting Forms and Instructions
IV-2
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Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name BIA Tribe
Absentee-Shawnee Tribe of Indians of Oklahoma
Agua Caliente Band of Cahuilla Indians of the Agua
Caliente Indian Reservation, California
Ak Chin Indian Community of the Maricopa ( Ak
Chin) Indian Reservation, Arizona
Alabama-Coushatta Tribes of Texas
Alabama-Quassarte Tribal Town, Oklahoma
Alturas Indian Rancheria, California
Apache Tribe of Oklahoma
Arapahoe Tribe of the Wind River Reservation,
Wyoming
Aroostook Band of Micmac Indians of Maine
Assiniboine and Sioux Tribes of the Fort Peck Indian
Reservation, Montana
Augustine Band of Cahuilla Indians, California
(formerly the Augustine Band of Cahuilla Mission
Indians of the Augustine Reservation)
Bad River Band of the Lake Superior Tribe of
Chippewa Indians of the Bad River Reservation,
Wisconsin
Bay Mills Indian Community, Michigan
Bear River Band of the Rohnerville Rancheria,
California
Berry Creek Rancheria of Maidu Indians of
California
Big Lagoon Rancheria, California
Big Pine Band of Owens Valley Paiute Shoshone
Indians of the Big Pine Reservation, California
Big Sandy Rancheria of Mono Indians of California
Big Valley Band of Porno Indians of the Big Valley
Rancheria, California
Blackfeet Tribe of the Blackfeet Indian Reservation
of Montana
Blue Lake Rancheria, California
Bridgeport Paiute Indian Colony of California
Buena Vista Rancheria of Me-Wuk Indians of
California
Burns Paiute Tribe of the Burns Paiute Indian Colony
of Oregon
Cabazon Band of Mission Indians, California
Cachil DeHe Band of Wintun Indians of the Colusa
Indian Community of the Colusa Rancheria,
California
Caddo Nation of Oklahoma
Canto Indian Tribe of the Laytonville Rancheria,
California
Code
820
584
612
830
901
502
809
281
31
206
567
430
470
560
504
554
530
506
507
201
558
691
508
144
568
512
806
524
Indian Country Name BIA Tribe
Cahuilla Band of Mission Indians of the Cahuilla
Reservation, California
California Valley Miwok Tribe, California
Campo Band of Diegueno Mission Indians of the
Campo Indian Reservation, California
Capitan Grande Band of Diegueno Mission Indians of
California: Barona Group of Capitan Grande Band of
Mission Indians of the Barona Reservation,
California; Viejas (Baron Long) Group of Capitan
Grande Band of Mission Indians of the Viejas
Reservation, California
Catawba Indian Nation (aka Catawba Tribe of South
Carolina)
Cayuga Nation of New York
Cedarville Rancheria, California
Chemehuevi Indian Tribe of the Chemehuevi
Reservation, California
Cher-Ae Heights Indian Community of the Trinidad
Rancheria, California
Cherokee Nation, Oklahoma
Cheyenne and Arapaho Tribes, Oklahoma (formerly
the Cheyenne-Arapaho Tribes of Oklahoma)
Cheyenne River Sioux Tribe of the Cheyenne River
Reservation, South Dakota
Chickasaw Nation, Oklahoma
Chicken Ranch Rancheria of Me-Wuk Indians of
California
Chippewa-Cree Indians of the Rocky Boy's
Reservation, Montana
Chitimacha Tribe of Louisiana
Choctaw Nation of Oklahoma
Citizen Potawatomi Nation, Oklahoma
Cloverdale Rancheria of Porno Indians of California
Cocopah Tribe of Arizona
Coeur D'Alene Tribe of the Coeur D'Alene
Reservation, Idaho
Cold Springs Rancheria of Mono Indians of
California
Colorado River Indian Tribes of the Colorado River
Indian Reservation, Arizona and California
Comanche Nation, Oklahoma
Confederated Salish & Kootenai Tribes of the
Flathead Reservation, Montana
Confederated Tribes and Bands of the Yakama
Nation, Washington
Code
569
628
570
571
32
13
621
695
566
905
801
340
906
523
205
970
907
821
510
602
181
511
603
808
203
124
Toxics Release Inventory Reporting Form and Instructions
V-l
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Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name BIA Tribe
Confederated Tribes of Siletz Indians of Oregon
(previously listed as the Confederated Tribes of the
Siletz Reservation)
Confederated Tribes of the Chehalis Reservation,
Washington
Confederated Tribes of the Colville Reservation,
Washington
Confederated Tribes of the Coos, Lower Umpqua and
Siuslaw Indians of Oregon
Confederated Tribes of the Goshute Reservation,
Nevada and Utah
Confederated Tribes of the Grand Ronde Community
of Oregon
Confederated Tribes of the Umatilla Reservation,
Oregon
Confederated Tribes of the Warm Springs
Reservation of Oregon
Coquille Tribe of Oregon
Cortina Indian Rancheria of Wintun Indians of
California
Coushatta Tribe of Louisiana
Cow Creek Band of Umpqua Indians of Oregon
Cowlitz Indian Tribe, Washington
Coyote Valley Band of Porno Indians of California
Crow Creek Sioux Tribe of the Crow Creek
Reservation, South Dakota
Crow Tribe of Montana
Death Valley Timbi-Sha Shoshone Band of
California
Delaware Nation, Oklahoma
Delaware Tribe of Indians, Oklahoma
Dry Creek Rancheria of Porno Indians of California
Duckwater Shoshone Tribe of the Duckwater
Reservation, Nevada
Eastern Band of Cherokee Indians of North Carolina
Eastern Shawnee Tribe of Oklahoma
Elem Indian Colony of Porno Indians of the Sulphur
Bank Rancheria, California
Elk Valley Rancheria, California
Ely Shoshone Tribe of Nevada
Enterprise Rancheria of Maidu Indians of California
Ewiiaapaayp Band of Kumeyaay Indians, California
Federated Indians of Graton Rancheria, California
Flandreau Santee Sioux Tribe of South Dakota
Forest County Potawatomi Community, Wisconsin
Fort Belknap Indian Community of the Fort Belknap
Reservation of Montana
Code
142
105
101
152
681
141
143
145
155
513
971
153
132
638
342
202
693
807
816
515
642
1
921
632
559
644
517
573
622
341
434
204
Indian Country Name BIA Tribe
Fort Bidwell Indian Community of the Fort Bidwell
Reservation of California
Fort Independence Indian Community of Paiute
Indians of the Fort Independence Reservation,
California
Fort McDermitt Paiute and Shoshone Tribes of the
Fort McDermitt Indian Reservation, Nevada and
Oregon
Fort McDowell Yavapai Nation, Arizona
Fort Mojave Indian Tribe of Arizona, California &
Nevada
Fort Sill Apache Tribe of Oklahoma
Gila River Indian Community of the Gila River
Indian Reservation, Arizona
Grand Traverse Band of Ottawa and Chippewa
Indians, Michigan
Greenville Rancheria of Maidu Indians of California
Grindstone Indian Rancheria of Wintun- Wailaki
Indians of California
Habematolel Porno of Upper Lake, California
Hannahville Indian Community, Michigan
Havasupai Tribe of the Havasupai Reservation,
Arizona
Ho-Chunk Nation of Wisconsin
Hoh Indian Tribe of the Hoh Indian Reservation,
Washington
Hoopa Valley Tribe, California
Hopi Tribe of Arizona
Hopland Band of Porno Indians of the Hopland
Rancheria, California
Houlton Band of Maliseet Indians of Maine
Hualapai Indian Tribe of the Hualapai Indian
Reservation, Arizona
lipay Nation of Santa Ysabel, California (formerly
the Santa Ysabel Band of Diegueno Mission Indians
of the Santa Ysabel Reservation)
Inaja Band of Diegueno Mission Indians of the Inaja
and Cosmit Reservation, California
lone Band of Miwok Indians of California
Iowa Tribe of Kansas and Nebraska
Iowa Tribe of Oklahoma
Jackson Rancheria of Me-Wuk Indians of California
Jamestown S'Klallam Tribe of Washington
Jamul Indian Village of California
Jena Band of Choctaw Indians, Louisiana
Jicarilla Apache Nation, New Mexico
Code
518
525
646
613
604
803
614
468
545
519
636
471
605
439
106
561
608
521
19
606
592
574
529
860
822
522
129
575
34
701
Toxics Release Inventory Reporting Form and Instructions
V-2
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Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name BIA Tribe
Kaibab Band of Paiute Indians of the Kaibab Indian
Reservation, Arizona
Kalispel Indian Community of the Kalispel
Reservation, Washington
Karuk Tribe (formerly the Karuk Tribe of California)
Kashia Band of Porno Indians of the Stewarts Point
Rancheria, California
Kaw Nation, Oklahoma
Kewa Pueblo, New Mexico (formerly the Pueblo of
Santo Domingo)
Keweenaw Bay Indian Community, Michigan
Kialegee Tribal Town, Oklahoma
Kickapoo Traditional Tribe of Texas
Kickapoo Tribe of Indians of the Kickapoo
Reservation in Kansas
Kickapoo Tribe of Oklahoma
Kiowa Indian Tribe of Oklahoma
Klamath Tribes, Oregon
Kootenai Tribe of Idaho
La Jolla Band of Luiseno Indians, California
(formerly the La Jolla Band of Luiseno Mission
Indians of the La Jolla Reservation)
La Posta Band of Diegueno Mission Indians of the La
Posta Indian Reservation, California
Lac Courte Oreilles Band of Lake Superior Chippewa
Indians of Wisconsin
Lac du Flambeau Band of Lake Superior Chippewa
Indians of the Lac du Flambeau Reservation of
Wisconsin
Lac Vieux Desert Band of Lake Superior Chippewa
Indians, Michigan
Las Vegas Tribe of Paiute Indians of the Las Vegas
Indian Colony, Nevada
Little River Band of Ottawa Indians, Michigan
Little Traverse Bay Bands of Odawa Indians,
Michigan
Los Coyotes Band of Cahuilla and Cupeno Indians,
California (formerly the Los Coyotes Band of
Cahuilla & Cupeno Indians of the Los Coyotes
Reservation)
Lovelock Paiute Tribe of the Lovelock Indian
Colony, Nevada
Lower Brule Sioux Tribe of the Lower Brule
Reservation, South Dakota
Lower Elwha Tribal Community of the Lower Elwha
Reservation, Washington
Lower Lake Rancheria, California
Code
617
103
555
547
810
717
475
902
826
861
823
802
140
183
576
577
431
432
479
648
482
483
578
649
343
125
625
Indian Country Name BIA Tribe
Lower Sioux Indian Community in the State of
Minnesota
Lummi Tribe of the Lummi Reservation, Washington
Lytton Rancheria of California
Makah Indian Tribe of the Makah Indian
Reservation, Washington
Manchester Band of Porno Indians of the
Manchester-Point Arena Rancheria, California
Manzanita Band of Diegueno Mission Indians of the
Manzanita Reservation, California
Mashantucket Pequot Tribe of Connecticut
Mashpee Wampanoag Tribe, Massachusetts
Match-e-be-nash-she-wish Band of Pottawatomi
Indians of Michigan
Mechoopda Indian Tribe of Chico Rancheria,
California
Menominee Indian Tribe of Wisconsin
Mesa Grande Band of Diegueno Mission Indians of
the Mesa Grande Reservation, California
Mescalero Apache Tribe of the Mescalero
Reservation, New Mexico
Miami Tribe of Oklahoma
Miccosukee Tribe of Indians of Florida
Middletown Rancheria of Porno Indians of California
Minnesota Chippewa Tribe, Minnesota (Six
component reservations: Bois Forte Band (Nett
Lake); Fond du Lac Band; Grand Portage Band;
Leech Lake Band; Mille Lacs Band; White Earth
Band)
Mississippi Band of Choctaw Indians, Mississippi
Moapa Band of Paiute Indians of the Moapa River
Indian Reservation, Nevada
Modoc Tribe of Oklahoma
Mohegan Indian Tribe of Connecticut
Mooretown Rancheria of Maidu Indians of California
Morongo Band of Mission Indians, California
(formerly the Morongo Band of Cahuilla Mission
Indians of the Morongo Reservation)
Muckleshoot Indian Tribe of the Muckleshoot
Reservation, Washington
Muscogee (Creek) Nation, Oklahoma
Narragansett Indian Tribe of Rhode Island
Navajo Nation, Arizona, New Mexico & Utah
Nez Perce Tribe, Idaho (previously listed as Nez
Perce Tribe of Idaho)
Nisqually Indian Tribe of the Nisqually Reservation,
Washington
Code
402
107
509
108
527
579
20
35
484
531
440
580
702
925
26
528
400
980
650
927
33
626
582
109
908
27
780
182
110
Toxics Release Inventory Reporting Form and Instructions
V-3
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Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name BIA Tribe
Nooksack Indian Tribe of Washington
Northern Cheyenne Tribe of the Northern Cheyenne
Indian Reservation, Montana
Northfork Rancheria of Mono Indians of California
Northwestern Band of Shoshoni Nation of Utah
/AH7ru-iV»nl?-i f-i\
(Washakie)
Nottawaseppi Huron Band of the Potawatomi,
Michigan (formerly the Huron Potawatomi, Inc.)
Oglala Sioux Tribe of the Pine Ridge Reservation,
South Dakota
Ohkay Owingeh, New Mexico (formerly the Pueblo
of San Juan)
Omaha Tribe of Nebraska
Oneida Nation of New York
Oneida Tribe of Indians of Wisconsin
Onondaga Nation of New York
Osage Nation, Oklahoma (formerly the Osage Tribe)
Otoe-Missouria Tribe of Indians, Oklahoma
Ottawa Tribe of Oklahoma
Paiute Indian Tribe of Utah (Cedar Band of Paiutes,
Kanosh Band of Paiutes, Koosharem Band of Paiutes,
Indian Peaks Band of Paiutes, and Shivwits Band of
Paiutes) (formerly Paiute Indian Tribe of Utah (Cedar
City Band of Paiutes, Kanosh Band of Paiutes,
Koosharem Band of Paiutes, Indian Peaks Band of
Paiutes, and Shivwits Band of Paiutes))
Paiute-Shoshone Indians of the Bishop Community
of the Bishop Colony, California
Paiute-Shoshone Indians of the Lone Pine
Community of the Lone Pine Reservation, California
Paiute-Shoshone Tribe of the Fallen Reservation and
Colony, Nevada
Pala Band of Luiseno Mission Indians of the Pala
Reservation, California
Pascua Yaqui Tribe of Arizona
Paskenta Band of Nomlaki Indians of California
Passamaquoddy Tribe of Maine
Pauma Band of Luiseno Mission Indians of the
Pauma & Yuima Reservation, California
Pawnee Nation of Oklahoma
Pechanga Band of Luiseno Mission Indians of the
Pechanga Reservation, California
Penobscot Tribe of Maine
Peoria Tribe of Indians of Oklahoma
Picayune Rancheria of Chukchansi Indians of
California
Pinoleville Porno Nation, California (formerly the
Pinoleville Rancheria of Porno Indians of California)
Code
111
207
532
195
481
344
714
380
11
433
6
930
811
922
692
549
624
645
583
665
533
14
585
812
586
18
926
534
535
Indian Country Name BIA Tribe
Pit River Tribe, California (includes XL Ranch, Big
Bend, Likely, Lookout, Montgomery Creek and
Roaring Creek Rancherias)
Pokagon Band of Potawatomi Indians, Michigan and
Indiana
Ponca Tribe of Indians of Oklahoma
Ponca Tribe of Nebraska
Port Gamble Indian Community of the Port Gamble
Reservation, Washington
Potter Valley Tribe, California
Prairie Band of Potawatomi Nation, Kansas
Prairie Island Indian Community in the State of
Minnesota
Pueblo of Acoma, New Mexico
Pueblo of Cochiti, New Mexico
Pueblo of Isleta, New Mexico
Pueblo of Jemez, New Mexico
Pueblo of Laguna, New Mexico
Pueblo of Nambe, New Mexico
Pueblo of Picuris, New Mexico
Pueblo of Pojoaque, New Mexico
Pueblo of San Felipe, New Mexico
Pueblo of San Ildefonso, New Mexico
Pueblo of Sandia, New Mexico
Pueblo of Santa Ana, New Mexico
Pueblo of Santa Clara, New Mexico
Pueblo of Taos, New Mexico
Pueblo of Tesuque, New Mexico
Pueblo of Zia, New Mexico
Puyallup Tribe of the Puyallup Reservation,
Washington
Pyramid Lake Paiute Tribe of the Pyramid Lake
Reservation, Nevada
Quapaw Tribe of Indians, Oklahoma
Quartz Valley Indian Community of the Quartz
Valley Reservation of California
Quechan Tribe of the Fort Yuma Indian Reservation,
California & Arizona
Quileute Tribe of the Quileute Reservation,
Washington
Quinault Tribe of the Quinault Reservation,
Washington
Ramona Band of Cahuilla, California (formerly the
Ramona Band or Village of Cahuilla Mission Indians
of California)
Code
536
480
813
381
113
537
862
403
703
704
705
706
707
708
709
710
712
713
711
715
716
718
719
720
115
651
920
563
696
116
117
597
Toxics Release Inventory Reporting Form and Instructions
V-4
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Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name BIA Tribe
Red Cliff Band of Lake Superior Chippewa Indians
of Wisconsin
Red Lake Band of Chippewa Indians, Minnesota
Redding Rancheria, California
Redwood Valley Rancheria of Porno Indians of
California
Reno-Sparks Indian Colony, Nevada
Resighini Rancheria, California
Rincon Band of Luiseno Mission Indians of the
Rincon Reservation, California
Robinson Rancheria of Porno Indians of California
Rosebud Sioux Tribe of the Rosebud Indian
Reservation, South Dakota
Round Valley Indian Tribes of the Round Valley
Reservation, California
Sac & Fox Nation of Missouri in Kansas and
Nebraska
Sac & Fox Nation, Oklahoma
Sac & Fox Tribe of the Mississippi in Iowa
Saginaw Chippewa Indian Tribe of Michigan
Saint Regis Mohawk Tribe, New York (formerly the
St. Regis Band of Mohawk Indians of New York)
Salt River Pima-Maricopa Indian Community of the
Salt River Reservation, Arizona
Samish Indian Tribe, Washington
San Carlos Apache Tribe of the San Carlos
Reservation, Arizona
San Juan Southern Paiute Tribe of Arizona
San Manuel Band of Mission Indians, California
(previously listed as the San Manual Band of Serrano
Mission Indians of the San Manual Reservation)
San Pasqual Band of Diegueno Mission Indians of
California
Santa Rosa Band of Cahuilla Indians, California
(formerly the Santa Rosa Band of Cahuilla Mission
Indians of the Santa Rosa Reservation)
Santa Rosa Indian Community of the Santa Rosa
Rancheria, California
Santa Ynez Band of Chumash Mission Indians of the
Santa Ynez Reservation, California
Santee Sioux Nation, Nebraska
Sauk-Suiattle Indian Tribe of Washington
Sault Ste. Marie Tribe of Chippewa Indians of
Michigan
Scotts Valley Band of Porno Indians of California
Seminole Nation of Oklahoma
Code
435
409
538
539
653
556
587
516
345
540
863
824
490
472
7
615
133
616
689
588
589
590
542
591
382
119
469
503
909
Indian Country Name BIA Tribe
Seminole Tribe of Florida (Dania, Big Cypress,
Brighton, Hollywood & Tampa Reservations)
Seneca Nation of New York
Seneca-Cayuga Tribe of Oklahoma
Shakopee Mdewakanton Sioux Community of
Minnesota
Shawnee Tribe, Oklahoma
Sherwood Valley Rancheria of Porno Indians of
California
Shingle Springs Band of Miwok Indians, Shingle
Springs Rancheria (Verona Tract), California
Shoalwater Bay Tribe of the Shoalwater Bay Indian
Reservation, Washington
Shoshone Tribe of the Wind River Reservation,
Wyoming
Shoshone-Bannock Tribes of the Fort Hall
Reservation of Idaho
Shoshone-Paiute Tribes of the Duck Valley
Reservation, Nevada
Sisseton-Wahpeton Oyate of the Lake Traverse
Reservation, South Dakota
Skokomish Indian Tribe of the Skokomish
Reservation, Washington
Skull Valley Band of Goshute Indians of Utah
Smith River Rancheria, California
Snoqualmie Tribe, Washington
Soboba Band of Luiseno Indians, California
Sokaogon Chippewa Community, Wisconsin
Southern Ute Indian Tribe of the Southern Ute
Reservation, Colorado
Spirit Lake Tribe, North Dakota
Spokane Tribe of the Spokane Reservation,
Washington
Squaxin Island Tribe of the Squaxin Island
Reservation, Washington
St. Croix Chippewa Indians of Wisconsin
Standing Rock Sioux Tribe of North & South Dakota
Stillaguamish Tribe of Washington
Stockbridge Munsee Community, Wisconsin
Summit Lake Paiute Tribe of Nevada
Suquamish Indian Tribe of the Port Madison
Reservation, Washington
Susanville Indian Rancheria, California
Swinomish Indians of the Swinomish Reservation,
Washington
Sycuan Band of the Kumeyaay Nation
Table Mountain Rancheria of California
Code
21
12
923
411
911
629
546
118
282
180
641
347
120
682
564
126
593
437
750
303
102
121
436
302
139
438
655
114
550
122
594
551
Toxics Release Inventory Reporting Form and Instructions
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Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name BIA Tribe
Te-Moak Tribe of Western Shoshone Indians of
Nevada (Four constituent bands: Battle Mountain
Band; Elko Band; South Fork Band and Wells Band)
Thlopthlocco Tribal Town, Oklahoma
Three Affiliated Tribes of the Fort Berthold
Reservation, North Dakota
Tohono O'odham Nation of Arizona
Tonawanda Band of Seneca Indians of New York
Tonkawa Tribe of Indians of Oklahoma
Tonto Apache Tribe of Arizona
Torres Martinez Desert Cahuilla Indians, California
(formerly the Torres-Martinez Band of Cahuilla
Mission Indians of California)
Tulalip Tribes of the Tulalip Reservation,
Washington
Tule River Indian Tribe of the Tule River
Reservation, California
Tunica-Biloxi Indian Tribe of Louisiana
Tuolumne Band of Me-Wuk Indians of the Tuolumne
Rancheria of California
Turtle Mountain Band of Chippewa Indians of North
Dakota
Tuscarora Nation of New York
Twenty-Nine Palms Band of Mission Indians of
California
United Auburn Indian Community of the Auburn
Rancheria of California
United Keetoowah Band of Cherokee Indians in
Oklahoma
Upper Sioux Community, Minnesota
Upper Skagit Indian Tribe of Washington
Ute Indian Tribe of the Uintah & Ouray Reservation,
Utah
Ute Mountain Tribe of the Ute Mountain
Reservation, Colorado, New Mexico & Utah
Code
640
903
301
610
8
814
674
595
123
553
336
634
304
9
598
637
904
401
131
687
751
Indian Country Name BIA Tribe
Utu Utu Gwaitu Paiute Tribe of the Benton Paiute
Reservation, California
Walker River Paiute Tribe of the Walker River
Reservation, Nevada
Wampanoag Tribe of Gay Head (Aquinnah) of
Massachusetts
Washoe Tribe of Nevada & California (Carson
Colony, Dresslerville Colony, Woodfords
Community, Stewart Community, & Washoe
Ranches)
White Mountain Apache Tribe of the Fort Apache
Reservation, Arizona
Wichita and Affiliated Tribes (Wichita, Keechi,
Waco & Tawakonie), Oklahoma
Winnebago Tribe of Nebraska
Winnemucca Indian Colony of Nevada
Wiyot Tribe, California (formerly the Table Bluff
Reservation — Wiyot Tribe)
Wyandotte Nation, Oklahoma
Yankton Sioux Tribe of South Dakota
Yavapai-Apache Nation of the Camp Verde Indian
Reservation, Arizona
Yavapai-Prescott Tribe of the Yavapai Reservation,
Arizona
Yerington Paiute Tribe of the Yerington Colony &
Campbell Ranch, Nevada
Yocha Dehe Wintun Nation, California (formerly the
Rumsey Indian Rancheria of Wintun Indians of
California)
Yomba Shoshone Tribe of the Yomba Reservation,
Nevada
Ysleta Del Sur Pueblo of Texas
Yurok Tribe of the Yurok Reservation, California
Zuni Tribe of the Zuni Reservation, New Mexico
Code
520
656
30
672
607
804
383
659
565
924
346
601
618
660
541
661
725
562
721
Toxics Release Inventory Reporting Form and Instructions
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Appendix A. TRI Federal Facility Reporting
Information
Special Instructions for TRI Federal
Facility Reporting
A.1 Why Do Federal
Facilities Need to Report?
Executive Order 13423, "Strengthening Federal
Environmental Energy, and Transportation
Management," requires federal agencies to comply with
the Emergency Planning and Community Right-To-
Know Act of 1986 (EPCRA) and the Pollution
Prevention Act of 1990 (PPA). Federal facilities have
been subject to EPCRA section 313 and PPA since
reporting year 1994. TRI submissions are due to EPA on
July 1 of the year following each reporting (calendar)
year. Reporting by the federal facility does not alter the
reporting obligation of on-site contractors. Contracts
entered into after the date of this order for contractor
operation of government-owned facilities or vehicles
require the contractor to comply with the provisions of
this order with respect to such facilities or vehicles to the
same extent as the agency would be required to comply if
the agency operated facilities or vehicles.
For more information on Executive Order 13423 please
refer to the implementing instructions, which can be
found on the TRI home page at http://www.epa.gov/tri
A.2 Identifying Federal
Facility Reports
Federal facility reports are identified as federal by several
indicators on the form. The facility name and parent
company name are critical indicators and must be
reported as described below. Another critical indicator is
the federal facility report box, Part I, 4.2c. Federal
facilities only should check this box to indicate that the
report is from a federal agency for a federal facility;
federal facilities should not check the GOCO box, (Part I,
Section 4.2d of the Form R). Contractors located at
federal facilities (GOCOs) should check the GOCO box
(Part I, Section 4.2d of the Form R); they should not
check the box 4.2c. Facilities should also complete the
partial or complete facility blocks (Form R page 2, block
4.2a and 4.2b) as appropriate. If you are a federal facility
reporting for the first time, you should write "new" in the
TRI Facility ID (TRIFID) box, even if a contractor has
reported for your facility in the past. The contractor will
retain the original TRIFID. You will be assigned a new
TRIFID the first time you report.
A.3 The "Double
Counting" Problem
As structured, the law and the executive order require
both regulated industries and the federal government to
report TRI data, sometimes for the same site. In order to
prevent duplicate data in the TRI database, which could
result in "double counting" data for some chemicals and
locations, EPA must be able to identify and distinguish
the GOCO reports submitted by the federal contractor
from the federal facility reports which contain data for
the same site. To accomplish this, federal facility reports
should be accompanied by either 1) exact copies (paper
or electronic) of all contractor TRI reports, including
when the totals reported by the federal facility are greater
than that reported by the contractor(s), or 2) a cover letter
which includes a list of the facility contractors which
submit TRI reports to EPA, identifying each contractor
by name, TRI technical contact, and TRI facility name
and address. Additionally, federal facilities should check
Form R, Part I, Section 4.2c, while contractors at federal
facilities should check Form R, Part I, Section 4.2d.
A.4 How to Report Your
Facility Name
Facility name is a critical data element. It is used by EPA
to create the TRI facility ID number (TRIFID), which is a
unique number designed to identify a facility site. The
facility name and TRIFID number are used by all TRI
data users to link data from a single site across multiple
reporting years. A federal facility is assigned a new
TRIFID number when the federal report is entered into
the Toxics Release Inventory system for the first time.
This TRIFID number, generated when the first report is
entered into the Toxics Release Inventory System, will be
included in future reporting packages sent to the federal
facility, and should be used by the federal facility in all
future reports.
Federal facilities should report their facility name on page
1 of the Form Rs (Section 4.1), as shown in the following
example:
U.S. DOE Savannah River Site
It is very important that the agency name appear first,
followed by the specific plant or site name.
Federal contractors at GOCO facilities should report their
names as shown in the following example:
U.S. DOE Savannah River Site - Westinghouse
Operations.
Toxics Release Inventory Reporting Forms and Instructions
A-l
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Appendix A
A.5 How to Report Your
North American Industry
Classification System
(NAICS) Code
Federal facilities should report the NAICS code which
most closely represents the activities taking place at the
site. Additional guidance on determining your NAICS
code is provided in the Forms and Instructions booklet.
The table on the next page contains Public
Administration NAICS codes covering executive,
legislative, judicial, administrative and regulatory
activities of the Federal government. Government-owned
and operated business establishments are classified in
major NAICS groups according to the activity in which
they are engaged. For example, a Veterans Hospital
would be classified in Group 806 - Hospitals.
A.6 How to Report Your
"Parent Company" Name
Federal facilities should report their parent company
name on page 2 of the Form Rs (Section 5.1) by reporting
their complete Department or Agency name, as shown in
the following example:
U.S. Department of Energy
Block 5.2, Parent Company's Dun & Bradstreet Number,
should be marked NA.
Federal contractors at GOCO facilities should not report a
federal department or agency name as their parent
company. A federal name in the parent company name
field will classify the report as federal, and the GOCO
may be identified as a non-reporter.
A.7 How to Revise Your
Data After It Has Been
Submitted
Any TRI Form R submitter may voluntarily revise their
submission if they find errors after their reports have
been sent to EPA. If the revision is to a hardcopy report,
the facility reporter should photocopy the original form
and use a blue or black pen to mark out the incorrect
value and write in the corrected value. The revised report
should be submitted to EPA, with an "X" in the revision
block on page 1 of the Form R. If the revision is to a
diskette, a new diskette should be submitted, containing
the data only for the revised submission, not all the
chemicals originally reported. If a federal facility receives
a copy of a revision from a contractor located at the
federal facility, the facility should revise the federal
report, and submit the revised report to EPA and the
appropriate state along with an exact copy of the
contractor's revision. The cover letter from the federal
facility should indicate that its submission is a revision.
A.8 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.9 More Help is
Available!
Federal facilities may call the EPA/TRI Information
Center to ask specific questions concerning how to
submit their Form R report. For contact information, see
the TRI Home Page at http://www.epa.gov/tri/
A.10 North American
Industry Classification
System Codes 921-928
Sector 92 - Public Administration
921 Executive, Legislative, and Other
General Government Support
92111 Executive Offices
92112 Legislative Bodies
92113 Public Finance Activities
92114 Executive and Legislative Offices Combined
92115 American Indian and Alaska Native Tribal
Governments
92119 General Government, Not Elsewhere Classified
922 Justice, Public Order, and Safety
Activities
92211 Courts
92212 Police Protection
92213 Legal Counsel and Prosecution
92214 Correctional Institutions
92215 Parole Offices and Probation Offices
92216 Fire Protection
92219 Other Justice, Public Order and Safety Activities
Toxics Release Inventory Reporting Forms and Instructions
A-2
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Appendix A
923 Administration of Human Resource
Programs
92311 Administration of Educational Programs
92312 Administration of Public Health Programs
92313 Administration of Human Resource Programs
(Except Education, Public Health, and Veterans'
Affairs Programs)
92314 Administration of Veterans Affairs
924 Administration of Environmental
Quality Programs
92411 Administration of Air and Water Resource and
Solid Waste Management Programs
92412 Administration of Conservation Programs
925 Administration of Housing Programs,
Urban Planning, and Community
Development
92511 Administration of Housing Programs
92512 Administration of Urban Planning and
Community and Rural Development
926 Administration of Economic
Programs
92611 Administration of General Economic Programs
92612 Regulation and Administration of Transportation
Programs
92613 Regulation and Administration of
Communications, Electric, Gas, and Other
Utilities
92614 Regulation of Agricultural Marketing and
Commodities
92615 Regulation, Licensing, and Inspection of
Miscellaneous Commercial Sectors
927 Space Research and Technology
92711 Space Research and Technology
928 National Security and International
Affairs
92811 National Security
92812 International Affairs
Toxics Release Inventory Reporting Forms and Instructions
A-3
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Appendix B. Reporting Codes for EPA Form R
and Instructions for Reporting Metals
B.1 Form R Part II
Revision Codes:
RRl New Monitoring Data
RR2 New Emission Factor(s)
RR3 New Chemical Concentration Data
RR4 Recalculation(s)
RR5 Other Reason(s)
Withdrawal Codes:
WT1 Did not meet the reporting threshold for
manufacturing, processing, or otherwise use
WT2 Did not meet the reporting threshold for number
of employees
WT3 Not in a covered NAICS Code
WO1 Other reason(s)
Section 1.1. CAS Number
EPCRA Section 313 Chemical Category
Codes
NO 10 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N150 Dioxin and dioxin-like compounds
N17 lEthylenebisdithiocarbamic
acid, salts and esters (EBDCs)
N230 Certain glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N503 Nicotine and salts
N511 Nitrate compounds
N575 Polybrominated biphenyls (PBBs)
N583 Fob/chlorinated alkanes
N590 Poly cyclic aromatic compounds
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N770 Vanadium compounds
N874
N982
Warfarin and salts
Zinc compounds
Section 4. Maximum Amount of the
Toxic Chemical On-Site at Any Time
During the Calendar Year
Range(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
Sections. 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
Range (pounds)
1-10
11-499
500-999
Code
A
B
C
Basis of Estimate
Ml- Estimate is based on continuous monitoring
data or measurements for the EPCRA
section 313 chemical.
M2- Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA section 313 chemical.
C- Estimate is based on mass balance
calculations, such as calculation of the
amount of the EPCRA section 313 chemical
in streams entering and leaving process
equipment.
Toxics Release Inventory Reporting Forms and Instructions
B-l
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Appendix B
El- Estimate is based on published emission factors,
such as those relating release quantity to
through-put or equipment type (e.g., air
emission factors).
E2- Estimate is based on site specific emission
factors, such as those relating release quantity to
through-put or equipment type (e.g., air
emission factors).
O- Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying an estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment was
fully identified through monitoring data.
Section 6. Transfers of the Toxic Chemical
in Wastes to Off-Site Locations
Type of Waste Disposal/Treatment/Energy
Recovery/Recycling
M10 Storage Only
M20 Solvents/Organics Recovery
M24 Metals Recovery
M26 Other Reuse or Recovery
M28 Acid Regeneration
M40 Solidification/Stabilization
M41 Solidification/Stabilization-Metals and Metal
Category Compounds only
M50 Incineration/Thermal Treatment
M54 Incineration/Insignificant Fuel Value
M56 Energy Recovery
M61 Wastewater Treatment (Excluding POTW)
M62 Wastewater Treatment (Excluding POTW) -
Metals and Metal Category Compounds only
M64 Other Landfills
M65 RCRA Subtitle C Landfills
M66 Subtitle C Surface Impoundment
M67 Other Surface Impoundments
M69 Other Waste Treatment
M73 Land Treatment
M79 Other Land Disposal
M81 Underground Injection to Class I Wells
M82 Underground Injection to Class II-V Wells
M90 Other Off-Site Management
M92 Transfer to Waste Broker - Energy Recovery
M93 Transfer to Waste Broker - Recycling
M94 Transfer to Waste Broker - Disposal
M95 Transfer to Waste Broker - Waste Treatment
M99 Unknown
Section 7A. On-Site Waste Treatment
Methods and Efficiency
General Waste Stream
A Gaseous (gases, vapors, airborne
particulates)
W Wastewater (aqueous waste)
L Liquid waste streams (non-aqueous waste)
S Solid waste streams (including sludges and
slurries)
Waste Treatment Methods
Air Emissions Treatment
A01 Flare
A02 Condenser
A03 Scrubber
A04 Absorber
A05 Electrostatic Precipitator
A06 Mechanical Separation
A07 Other Air Emission Treatment
Chemical Treatment
H040 Incineration—thermal destruction other than
use as a fuel
H071 Chemical reduction with or without
precipitation
H073 Cyanide destruction with or without
precipitation
H075 Chemical oxidation
H076 Wet air oxidation
H077 Other chemical precipitation with or
without pre-treatment
Biological Treatment
H081 Biological treatment with or without
precipitation
Physical Treatment
H082 Adsorption
H083 Air or steam stripping
H101 Sludge treatment and/or dewatering
H103 Absorption
Hill Stabilization or chemical fixation prior to
disposal
H112 Macro-encapsulation prior to disposal
H121 Neutralization
HI 22 Evaporation
H123 Settling or clarification
HI24 Phase separation
H129 Other treatment
Section 7B. On-Site Energy Recovery
Processes
UOl Industrial Kiln
U02 Industrial Furnace
Toxics Release Inventory Reporting Forms and Instructions
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-------
Appendix B
U03 Industrial Boiler
Section 7C. On-Site Recycling Processes
H10 Metal recovery (by retorting, smelting, or
chemical or physical extraction)
H20 Solvent recovery (including distillation,
evaporation, fractionation or extraction)
H3 9 Other recovery or reclamation for reuse
(including acid regeneration or other chemical
reaction process)
Section 8.10. Source Reduction Activity
Codes
Good Operating Practices
W13 Improved maintenance scheduling, record
keeping, or procedures
W14 Changed production schedule to minimize
equipment and feedstock changeovers
W15 Introduced in-line product quality monitoring or
other process analysis system
W19 Other changes in operating practices
Inventory Control
W21 Instituted procedures to ensure that materials do
not stay in inventory beyond shelf-life
W22 Began to test outdated material - continue to
use if still effective
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labeling procedures
W25 Instituted clearinghouse to exchange materials
that would otherwise be discarded
W29 Other changes in inventory control
Spill and Leak Prevention
W31 Improved storage or stacking procedures
W32 Improved procedures for loading, unloading,
and transfer operations
W33 Installed overflow alarms or automatic shut-off
valves
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
W43 Substituted a feedstock or reagent chemical with
a different chemical
W49 Other raw material modifications made
Process Modifications
W50 Optimized reaction conditions or otherwise
increased efficiency of synthesis
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
W56 Reduced or eliminated use of an organic
solvent
W57 Used biotechnology in manufacturing
process
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
W84 Developed a new chemical product to
replace a previous chemical product
W89 Other product modifications
Section 8.10. Methods Used to Identify
Source Reduction Activities
For each source reduction activity, enter up to three
of the following codes that correspond to the
method(s) which contributed most to the decision to
implement that activity.
TO 1 Internal Pollution Prevention Opportunity
Audit(s)
T02 External Pollution Prevention Opportunity
Audit(s)
Toxics Release Inventory Reporting Forms and Instructions
B-3
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Appendix B
T03 Materials Balance Audits T08 Federal Government Technical Assistance
T04 Participative Team Management Program
T05 Employee Recommendation (independent of a T09 Trade Association/Industry Technical
formal company program) Assistance Program
T06 Employee Recommendation (under a formal T10 Vendor Assistance
company program) Til Other
T07 State Government Technical Assistance
Program
Toxics Release Inventory Reporting Forms and Instructions B-4
-------
Appendix B
B.2 Reporting the Waste Management of Metals
This appendix outlines how the TRI-MEweb 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 cannot be reported on the
Form R using TRI-MEweb. 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-
MEweb, it does not indicate every situation where a metal should not be reported in a specific section of the form. For
example, TRI-MEweb 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 than 5000 British
thermal units (Btu) and, thus, cannot 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-MEweb this appendix can serve as a guide to
help you understand where it is not appropriate to report certain quantities of toxic chemicals or waste management
codes on your Form R.
Parent Metals:
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Metal Compound
Categories:
Antimony Compounds
Arsenic Compounds
Barium Compounds
Beryllium Compounds
Cadmium Compounds
Chromium Compounds
Cobalt Compounds
Copper Compounds
Lead Compounds
Manganese Compounds
Mercury Compounds
Nickel Compounds
Selenium Compounds
Silver Compounds
Thallium Compounds
Vanadium Compounds
Zinc Compounds
Metals with Qualifiers:
Aluminum (fume or dust)
Vanadium (except when in an
alloy)
Zinc (fume or dust)
Individually-Listed
Metal Compounds:
Bis(tributylin) oxide
Triphenyltin hydroxide
Triphenyltin chloride
Molybdenum trioxide
Thorium dioxide
Asbestos (friable)
Aluminum oxide (fibrous
forms)
Tributyltin fluoride
Tributyltin methacrylate
Titanium tetrachloride
Boron trifluoride
Metiram
Boron trichloride
Zineb
Maneb
Fenbutatin oxide
Iron pentacarbonyl
Ferbam
C.I. Direct Brown 95
Osmium tetroxide
Aluminum phosphide
C.I. Direct Blue 218
Sections 5.3 - Discharges to Water and 6.1 - Transfers to POTWs
The following chart indicates which metals can be reported as released to water in Section 5.3 or to POTWs 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 cannot exist in water.
Form R Section in
Part II
Section 5.3 -
Discharges to
receiving streams or
water bodies
Section 6.1-
Discharges to
POTWs
Parent Metals
All
All
Metal Category
Compounds
All
All
Metals with
Qualifiers
Vanadium (except
when contained in an
alloy)
Vanadium (except
when contained in an
alloy)
Individually-listed
Metal Compounds
All except Asbestos
All except Asbestos
Toxics Release Inventory Reporting Forms and Instructions
B-5
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Appendix B
Section 6.2. Transfers to Other Off-Site Locations
Any toxic chemical may be reported in Section 6.2. However, TRI-MEweb will not allow certain M codes to be used
when reporting metals. The chart below indicates which M codes can be reported in Section 6.2 for the four groups of
metals. Note that all disposal M codes other than M41 and M62 can be used for all toxic chemicals. Code M24 is only
made available for the four groups of metals.
Waste Management Code for
Section 6.2
M41 and M62 (disposal codes-for
metals only)
M56 and M92 (energy recovery
codes)
M20 and M28 (recycling codes)
M24, M26 and M93 (recycling
codes)
M40, M50, M54, (treatment codes)
M61, M69, M95 (treatment codes)
Parent
Metals
All
None
None
All
None
Barium2
Metal Category
Compounds
All
None
None
All
None
Barium
Compounds2
Metals with
Qualifiers
Vanadium (except
when contained in an
alloy)
None
None
All
All except Vanadium
(except when
contained in an alloy)
Same as above
Individually-
listed Metal
Compounds
All except
Asbestos
All except
Asbestos1
All
All
All
All
Section 7A. On-site Waste Treatment Methods and Efficiency
TRI-MEweb allows any toxic chemical to be reported in Section 7A, however, it limits reporting in two ways. First,
TRI-MEweb limits the treatment codes that can be reported based on the General Waste Stream Code selected. If a
TRI-MEweb 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-MEweb 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 cannot exist in a liquid or water waste.
For asbestos (friable) only S - Solid or A - Gaseous can be selected. When reporting hydrochloric acid (acid aerosols)
or sulfuric acid (acid aerosols) only A - Gaseous can be selected.
Crosswalk for Section 7 A, Column B. Waste Treatment Method (s) Sequence
Air Emissions Treatment (applicable to gaseous waste streams only)
(No change — same as previous codes)
A01
A02
A03
A04
A05
A06
A07
Flare
Condenser
Scrubber
Absorber
Electrostatic Precipitator
Mechanical Separation
Other Air Emission Treatment
Toxics Release Inventory Reporting Forms and Instructions
B-6
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Appendix B
Biological Treatment:
Previous Codes
Bll
B21
B31
B99
Aerobic
Anaerobic
Facultative
Other Biological
Treatment
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
H081
H081
H081
H081
Biological treatment with or without precipitation
Biological treatment with or without precipitation
Biological treatment with or without precipitation
Biological treatment with or without precipitation
Chemical Treatment:
Previous Codes
C01
C02
C09
Cll
C21
C31
C41
C42
C43
C44
C45
C46
C99
Chemical Precipitation B
Lime or Sodium Hydroxide
Chemical Precipitation B
Sulfide
Chemical Precipitation B
Other
Neutralization
Chromium Reduction
Complexed Metals
Treatment (other than pH
adjustment)
Cyanide Oxidation B
Alkaline Chlorination
Cyanide Oxidation B
Electrochemical
Cyanide Oxidation B Other
General Oxidation
(including Disinfection) B
Chlorination
General Oxidation
(including Disinfection) B
Ozonation
General Oxidation
(including Disinfection) B
Other
Other Chemical Treatment
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
H071
H071
H077
H121
H071
H129
H073
H073
H073
H075
H075
H075
H129
Chemical reduction with or without precipitation
Chemical reduction with or without precipitation
Other chemical precipitation with or without pre-
treatment
Neutralization
Chemical reduction with or without precipitation
Other treatment
Cyanide destruction with or without precipitation
Cyanide destruction with or without precipitation
Cyanide destruction with or without precipitation
Chemical oxidation
Chemical oxidation
Chemical oxidation
Other treatment
Toxics Release Inventory Reporting Forms and Instructions
B-7
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Appendix B
Chemical Treatment:
Previous Codes
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
Incineration/Thermal Treatment: (Note: Only report combustion for the purposes of incineration/thermal
treatment in Section 7 A. If the method involves combustion for the purposes of energy recover, report as U01,
U02, or U03 in Section 7B. If the method involves combustion for the purposes of materials recovery, report as
H39 in Section 7C.)
F01
Fll
F19
F31
F41
F42
F51
F61
F71
F81
F82
F83
F99
Liquid Injection
Rotary Kiln with Liquid
Injection Unit
Other Rotary Kiln
Two Stage
Fixed Hearth
Multiple Hearth
Fluidized Bed
Infra-Red
Fume/Vapor
Pyrolytic destructor
Wet air oxidation
Thermal
Drying/Dewatering
Other Incineration/Thermal
Treatment
H040
H040
H040
H040
H040
H040
H040
H040
H040
H040
H076
H122
H040
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Wet air oxidation
Evaporation
Incineration B thermal destruction other than use as a
fuel
Physical Treatment:
Previous Codes
P01
P09
Pll
P12
P13
P14
P15
P16
P17
P18
Equalization
Other blending
Settling/clarification
Filtration
Sludge dewatering (non-thermal)
Air flotation
Oil skimming
Emulsion breaking B thermal
Emulsion breaking B chemical
Emulsion breaking B other
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H129
H129
H123
H123
H101
H124
H124
H124
H124
H124
Other treatment
other treatment
Settling or clarification
Settling or clarification
Sludge treatment and/or dewatering
Phase separation
Phase separation
Phase separation
Phase separation
Phase separation
Toxics Release Inventory Reporting Forms and Instructions
B-8
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Appendix B
Physical Treatment:
Previous Codes
P19
P21
P22
P23
P29
P31
P41
P42
P49
P51
P61
P99
Other liquid phase separation
Adsorption B Carbon
Adsorption B Ion exchange (other
than for recovery/reuse)
Adsorption B Resin
Adsorption B Other
Reverse Osmosis (other than for
recover/reuse)
Stripping B Air
Stripping B Steam
Stripping B Other
Acid Leaching (other than for
recovery/reuse)
Solvent Extraction (other than
recovery/reuse)
Other Physical Treatment
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H124
H082
H082
H082
H082
H129
H083
H083
H083
H129
H129
H129
Phase separation
Adsorption
Adsorption
Adsorption
Adsorption
Other treatment
Air or steam stripping
Air or steam stripping
Air or steam stripping
Other treatment
Other treatment
Other treatment
Solidification/Stabilization:
Previous Codes
G01
G09
Gil
G20
G99
Cement processes
(including silicates)
Other Pozzolonic
Processes (including
silicates)
Asphaltic Techniques
Thermoplastic
Techniques
Other Solidification
Processes
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
Hill
Hill
Hill
Hill
Hill
Stabilization or chemical fixation prior to
disposal
Stabilization or chemical fixation prior to
disposal
Stabilization or chemical fixation prior to
disposal
Stabilization or chemical fixation prior to
disposal
Stabilization or chemical fixation prior to
disposal
Section 7B. On-site Energy Recovery Processes
The chart below indicates which energy recovery codes can be reported in TRI-MEweb in Section 7B for the four
groups of metals.
Energy Recovery Code for Section
7B
U01, U02, U03
Parent
Metals
None
Metal
Category
Compounds
None
Metals with
Qualifiers
None
Individually-
listed Metal
Compounds
All except
Asbestos1
Toxics Release Inventory Reporting Forms and Instructions
B-9
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Appendix B
Section 7C. On-site Recycling Processes
Any chemical can be reported in Section 1C. However, certain waste management codes should not be reported for
certain toxic chemicals. The chart below indicates which codes can be reported in Section 7C when using TRI-MEweb.
Recycling Code for Section 7C
H10 (this code is for metals only)
H20
H39
Parent
Metals
All
None
All
Metal Category
Compounds
All
None
All
Metals with
Qualifiers
All
None
All
Individually-
listed Metal
Compounds
All
All
All
Crosswalk for Section 7C. On-site Recycling Processes
Previous Codes
Rll
R12
R13
R14
R19
R21
R22
R23
R24
R26
R27
Solvents/Organics Recovery
B Batch Still Distillation
Solvents/Organics Recovery
B Thin-Film Evaporation
Solvents/Organics Recovery
B Fractionation
Solvents/Organics Recovery
B Solvent Extraction
Solvents/Organics Recovery
B Other
Metals Recovery B
Electrolytic
Metals Recovery B Ion
Exchange
Metals Recovery B Acid
Leaching
Metals Recovery B Reverse
Osmosis
Metals Recovery B Solvent
Extraction
Metals Recovery B High
Temperature
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
H20
H20
H20
H20
H20
H10
H10
H10
H10
H10
H10
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Toxics Release Inventory Reporting Forms and Instructions
B-10
-------
Appendix B
Previous Codes
R28
R29
R30
R40
R99
Metals Recovery B Retorting
Metals Recovery B Secondary
Smelting
Metals Recovery B Other
Acid Regeneration
Other Reuse or Recovery
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
H10
H10
H10
H39
H39
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Other recovery or reclamation for reuse (including acid
regeneration or other chemical reaction process)
Other recovery or reclamation for reuse (including acid
regeneration or other chemical reaction process)
Section 8. Source Reduction and Recycling Activities
The chart below indicates which metals can be reported in Sections 8.2, 8.3, 8.6 and 8.7 of the Form R when using
TRI-MEweb. Note that all toxic chemicals can be reported in Sections 8.1, 8.4, 8.5 and 8.8.
Waste Management Activity
Quantity used for energy recovery
on site and off site (Sections 8.2
and 8.3)
Quantity treated for destruction on
site and off site (Sections 8.6 and
8.7)
Parent
Metals
None
None
except
Barium2
Metal Category
Compounds
None
None except
Barium
Compounds2
Metals with
Qualifiers
None
All except
Vanadium
(except when
contained in an
alloy)
Individually-
listed Metal
Compounds
All except
Asbestos2
All
1 Although TRI-MEweb does not restrict reporting of most individually-listed metal compounds as transferred off site for
energy recovery, only chemicals with a heat value greater than 5000 British thermal units that are combusted in a device
that is an industrial furnace or boiler (40 CFR Section 372.3) should be reported as used for energy recovery.
2 The toxic chemical category barium compounds (N040) does not include barium sulfate. Because barium sulfate is not a
listed toxic chemical, the conversion in a waste stream of barium or barium compound to barium sulfate is considered
treatment for destruction (40 CFR Section 372.3).
Toxics Release Inventory Reporting Forms and Instructions
B-ll
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Appendix C. Electronic Facility Data Profiles and
Common Errors in Completing Form R Reports and
Form A Certification Statements
EPA wishes to ensure that facilities submit all required TRI
chemical submissions in a timely manner so that the
information may be included in its national database, annual
public data release, now known as the TRI National
Analysis and other information products. Moreover, EPA
seeks to ensure that all submitted data are complete and
accurate. This appendix provides an overview of the
Electronic Facility Data Profile (eFDP), an important
document that EPA uses as a receipt to our reporting
facilities to ensure consistent, complete, and accurate
submissions. This appendix also provides specific guidance
to avoid common errors in completing Form Rs and Form A
Certification Statements, including errors in threshold
determination, misapplication of exemptions, and activities
involving a reportable chemical, any of which may result in
the erroneous non-reporting of a chemical. Most errors in
this appendix often occur on paper form submissions.
Using TRI-MEweb to electronically submit your TRI forms
can help avoid errors because the software checks for errors
before submission. If errors are identified in your eFDP, the
preferred method to revise your TRI form is by the use of
the TRI-MEweb application via EPA's Central Data
Exchange (CDX).
C.1 Electronic Facility Data
Profile (eFDP)
The eFDP report are made available via TRI-MEweb to a
reporting facility in response to any submission the TRI
Data Processing Center receives either through a paper form
or an electronic submission that has completed processing
into EPA database. If the Technical contact, preparer or
certifying official provided an email address in the Form
R/Form A, they will receive a real-time email notifying
them when their eFDP has been updated. The email will
contain information explaining how to create a CDX user
account and how to add the TRI-MEweb application.
Beginning in April 2012, all reporting facilities that reported
electronically using TRI-MEweb or mailed a hard-copy TRI
form to EPA's Data Processing Center (DPC), will obtain
and review their eFDP report within the TRI-MEweb
application. Any reporting facility's official may confirm
and review their submitted TRI data to EPA by viewing
their electronic Facility Data Profile (eFDP) on the Internet
by logging into their CDX account and clicking the TRI-
MEweb: TRI Made Easy Web link from their MyCDX page.
This will open the "Welcome" page of the TRI-MEweb
application. On the "Welcome" page, they can follow the
instructions for viewing the eFDP. It is very important that
you review your eFDP report because EPA may have
transcribed your data incorrectly into the database from
paper submissions or your reporting facility may have
incorrectly entered an incorrect waste quantity in your TRI-
MEweb submission, or your reporting facility incorrectly
listed the chemical category. Reviewing the eFDP allows
reporting facilities to conduct final checks of the data
submitted to EPA before it is released to the public. If you
have questions regarding your eFDP, please send an email
to helpdesk@epacdx.net or call 1 (888) 890-1955.
An eFDP report is comprised of the following sections:
Facility Information. This section displays all facility-
specific data, including TRI Facility Identification
(TRIFID), facility name, facility address, facility
mailing address, North American Industry
Classification System code (NAICS), and other
facility data. Errors related to facility information
will be marked in this section.
Instructions Page. This page provides instructions on
how to review and respond to the eFDP.
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 eFDP to make a revision.
Chemical Report Summary. This section lists all
chemicals reported by the facility for each
reporting year covered by the eFDP. For example,
if the eFDP is responding to five original chemical
submissions for Reporting Year 2012 and revisions
to one chemical for Reporting Year 2011, 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).
eFDPs identify three different types of errors:
NDCs, NOTEs and NOSEs and one type of alert
called Data Quality Alert (DQA). See explanations
in section B.
Error Summary Page. The Error Summary Page
provides facilities an error/alert count for each
chemical submission.
Chemical Reports. All recently submitted and
processed Form R or Form A data (i.e., chemical
specific data) are displayed in the chemical reports
under the appropriate facility or subordinate
facility names. The eFDP report displays facsimiles
for chemical reports for submissions received
during the current calendar year and revisions or
responses to eFDPs only. For example, if a facility
originally reported five chemicals for Reporting
Year 2012, and subsequently revises only one
Toxics Release Inventory Reporting Forms and Instructions
C-l
-------
Appendix C
chemical submission, the facility will receive an
eFDP for Reporting Year 2012 with only the
revised chemical included in the Chemical Reports
section. Hence there may be fewer chemical
reports than chemicals listed in the Chemical
Summary section. If only facility level changes
have occurred (i.e., Part I of the Form R or A), this
section is not provided.
Data Quality Alerts. TRI provides Data Quality
Alerts (DQA) in eFDP reports. The DQA informs
facilities of possible reporting errors by flagging
data trends that are outside the norm. For example,
if a facility reports a change in the release of a
chemical that is over 25% compared to last year, a
DQA will be triggered. This is offered to assist
facilities in ensuring accurate reporting.
C.2 Levels of Errors Identified
in eFDPs: Notice of Non-
Technical Data Change (NDC),
Notice of Technical Errors
(NOTE), Notice of Significant
Errors (NOSE), Notice of
Noncompliance (NON)
eFDP Error Reporting. In addition to echoing back the
information a facility has submitted, eFDPs are used to
identify potential errors and provide Data Quality Alerts.
Errors are more likely to be submitted on paper forms
because forms submitted through TRI-MEweb benefit from
built-in software to detect some errors during data entry,
prompting the user to correct them before the forms are
transmitted, certified, and submitted to EPA. Errors are still
possible on forms submitted through TRI-MEweb and this
appendix will indicate whether specific errors can occur on
paper forms or TRI-MEweb submissions or both.
As submission information is entered into EPA's national
database, a series of automated data quality checks are
performed. Some error messages will indicate where the
TRI Data Processing Center has made minor clerical
changes to submissions. The data quality checks are useful
to identify potential errors with certain data fields such as
TRI Facility Identification, facility name, county spelling, as
well as to perform validation checks to ensure consistency
among data elements within a given Form R or Form A.
These data quality checks, however, cannot detect whether
release, transfer, or waste management quantities were
calculated or entered accurately.
Within an eFDP report, there may be up to three different
types of errors identified.
Non-Technical Data Change (NDC)
Applies to: Paper forms only
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 eFDP. 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 eFDPs to report non-technical data changes are shown at
the end of this appendix under the heading "C.5 Messages
Used to Report Notices of Technical Errors (NOTEs) and
Non-technical Data Changes (NDCs)." This type of error is
flagged for correction during data entry when using TRI-
MEweb and needs to be addressed by the facility before
submission is submitted and processed by EPA. Therefore,
NDC's are not possible in a TRI-MEweb submission.
Notice of Technical Error (NOTE)
Applies to: Paper forms only
A Notice of Technical Error (NOTE) highlights
inconsistencies or miscalculations that may distort your
facility's information in EPA's public data products or skew
analyses. Incomplete addresses, no technical or public
contact provided, missing or invalid NAICS codes, or the
use of range codes to report PBT chemical releases are all
examples of technical errors. You should respond to NOTEs
as soon as possible. These types of errors could be corrected
by the reporting facility on its eFDP (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 before your report has
been released to the public 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 eFDPs to report NOTEs
are shown below at the end of this appendix under the
heading "C.5 Messages Used to Report Notices of Technical
Errors (NOTEs) and Non-technical Data Changes (NDCs)."
This type of error is flagged for correction during data entry
when using TRI-MEweb and need to be addressed by
facility before submission is submitted and processed by
EPA. Therefore, NOTE'S are not possible in a TRI-MEweb
submission.
Toxics Release Inventory Reporting Forms and Instructions
C-2
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Appendix C
Notices of Significant Errors (NOSE)
Applies to: Paper forms and TRI-MEweb submissions
The most serious errors are classified as Notices of
Significant Errors (NOSE). The eFDP 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 chemical
name or CAS number are examples of significant errors.
These types of errors could be corrected by the reporting
facility on their eFDP, or the reporting facility could submit
a revised Form R or Form A, or the reporting facility could
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 an eFDP and is mailed separately.
Reporters will receive a NOSE for failure to certify a
submission (i.e. not signing paper forms). This includes any
electronic submission that is not certified in the TRI-
MEweb system as of July 1st, 2012 for which the user has
not submitted certification via another reporting media, such
as paper.
Notice of Noncompliance (NON)
Applies to: Paper forms and TRI-MEweb submissions
The Agency will issue a Notice of Noncompliance (NON)
to a facility for failure to respond to a Notice of Significant
Error (NOSE) within the required period. A NON suggests
that a facility should take corrective action within 30 days
and respond to the Agency that corrective action has been
taken. If a facility fails to respond to the NON within the
required time period, the Agency may take further action.
Record Keeping
Facilities must keep copies, for three years, of submitted
Form R reports and Form A certifications and all
documentation used to complete their submissions in
accordance with 40 CFR 372.10. 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. TRI-MEweb stores several years worth (7 years in
RY 2012) of submitted chemical release data that can be
accessed to be printed for your records.
C.3 Common Errors in
Completing Form R Reports
and Form A Certification
Statements.
The following section lists the most common errors that
reporting facilities have encountered when submitting paper
or TRI-ME web submissions to EPA. Some of these errors
are not detected nor listed on an eFDP report. Errors that
are not detectable are hard to evaluate by EPA because they
could be valid submissions and can only be determined to
be incorrect by the reporting facility. Reporting facilities
should review their submission to ensure these common
errors are not present in their forms before submitting them
to EPA.
General Considerations
Applies to: Paper forms only
Lack of signed certification statement. If you choose
not to send your TRI submissions via the paperless
CDX process, you must sign and submit Part I,
Section 3 of your hard copy submission. Although
EPA accepts paper submissions, EPA strongly
encourages you to send your submission via TRI-
MEweb and CDX. This error type is listed on an
eFDP as a NOSE.
Incomplete Forms. A complete Form R report for a
single EPCRA section 313 chemical or single
EPCRA section 313 chemical category consists of
six pages stapled together. By using TRI-MEweb
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, 5s and/or 6s. Such forms
are considered incomplete submissions. This error
type is listed on an eFDP as a NOSE.
Threshold Determinations
Applies to: Paper forms and TRI-MEweb submissions
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. This error type
is not detected nor listed on an eFDP report.
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.
This error type is not detected nor listed on an
Toxics Release Inventory Reporting Forms and Instructions
C-3
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Appendix C
eFDP report.
EPCRA section 313 chemical activity overlooked.
Many facilities believe that because the section 313
reporting requirement pertains to manufacturers,
only the use of EPCRA section 313 chemicals in
manufacturing processes must be examined. Any
activity involving the manufacture, process, or
otherwise use of an EPCRA section 313 chemical
or chemical category must be included in threshold
determinations. Commonly overlooked activities
include importation of chemicals, generation of
waste byproducts, processing of naturally
occurring metals and metal category compounds in
ore, manufacturing and processing intermediates,
the use of chemicals for cleaning of equipment, and
the generation of byproducts during combustion of
coal and/or oil. Facilities should take a systematic
approach to identify all chemicals and mixtures
used in production and non-production capacities,
including catalysts, well treatment chemicals, and
wastewater treatment chemicals. This error type is
not detected nor listed on an eFDP report.
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.4f of this document to calculate the
weight of an EPCRA section 313 chemical in a
mixture or other trade name product. This error
type is not detected nor listed on an eFDP report.
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). This
error type is not detected nor listed on an eFDP
report.
Container Residue
Overlooking container residue. Container residue
must not be disregarded in release and other waste
management calculations. Even a "RCRA empty"
drum is expected to contain a residue and it must
be considered for TRI reporting. Additionally,
on-site drum rinsing and disposal of the rinsate will
result in a release and other waste management
activity. Refer to Estimating Releases and Waste
Treatment Efficiencies for Toxic Chemical
Reporting Forms. This error type is not detected
nor listed on an eFDP report.
Part I. Facility Identification Information
Section 1. Reporting Year
• Invalid Paper forms: Hard copy submissions may be
submitted using the TRI Form R and/or Form A
Certification Statement applicable for that particular
reporting year. EPA provides printable TRI forms from
RY 2003 through RY 2012 on the TRI website at
http://www.epa.gov/tri/reporting_materials/forms/. For
reporters submitting RY 2011 and RY 2012 hard-copy
forms, EPA recommends entering data using the
electronically finable fields in the RY 2011 and RY
2012 forms. RY 2010 and prior year forms are not
electronically finable and must be completed by hand
or typewriter. You can also request older reporting
forms under the Contact Us link on the TRI web site for
TRI forms prior to RY 2003. Please sign and date the
certification statement on Page 1 prior to mailing your
TRI form(s) to EPA's DPC. This error type is listed on
an eFDP as a NOSE.
• Invalid TRI-MEweb Forms: Users that prepare TRI
forms using TRI-MEweb must pick the reporting year
before starting to enter any chemical release data. Users
may start a blank form or choose to import prior year
data into current year forms from the Form Summary
Table on the TRI-MEweb Welcome page after clicking
on the (+) sign next to TRIFID of the reporting facility.
If the preparer transmitted, certified and submitted a
form with an incorrect reporting year selected, a
revision of this form cannot change the reporting year
field. Instead, the incorrect reporting year form must be
withdrawn and resubmitted under the correct reporting
year. This error type is not detected nor listed on an
eFDP report.
Section 2. Trade Secret Information
Applies to: Paper forms only
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
Toxics Release Inventory Reporting Forms and Instructions
C-4
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Appendix C
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. This error type is listed on an eFDP as a
NOSE.
Section 3. Certification
Applies to: Paper forms only
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 Certification
Statement submitted to EPA. Missing signatures
will prevent forms from being processed by EPA.
This error type is listed on an eFDP as a NOSE.
Applies to: TRI-MEweb submissions only
Uncertified TRI-MEweb submissions If you are
submitting your Form R and/or Form A via TRI-
MEweb and CDX, you must electronically sign the
submission before it can be loaded into the TRI
database, Uncertified electronic submissions will
not be accepted and result in a Notice of Non-
Compliance (NON) if they remain uncertified after
the July 1st reporting deadline and you have not
reported by another means. If your eFDP report is
not created in TRI-MEweb after certifying your
electronic submission, this may indicate that the
certification process was not completed correctly.
This error type is listed on an eFDP as a NOSE.
Section 4. Facility Identification
Questionable entries. Incorrect entries may be
corrected by the reporting facility though a
revision. The use of the TRI-MEweb software may
prevent such errors from occurring. Questionable
entries may include:
Applies to: Paper forms and TRI-MEweb
submissions
Incorrect street address;
Incorrect ZIP codes;
Invalid County names;
- Invalid NAICS codes;
Invalid Dun & Bradstreet numbers;
Note: These error types are not detected nor
listed on an eFDP report.
Applies to: Paper forms only
Missing street address;
Missing ZIP codes
Missing County Names
Note: These error types are listed on an
eFDP as a NOSE.
Part II. Chemical-Specific Information
Section 1. Toxic Chemical Identity
Applies to: Paper forms only
Reporting chemical abstract service (CAS) registry
numbers in Section 1.1. In 1992, EPA assigned
alphanumeric category codes to the twenty
chemical categories for the purposes of reporting
the CAS number field in Section 1.1. Incorrect use
of chemical category codes have caused errors on
TRI forms requiring forms to be withdrawn and re-
submitted. When completing a Form R for a
chemical category, the appropriate code for that
category must be provided in Section 1.1. The CAS
numbers are listed in Table II: "Section 313 Toxic
Chemical List," and if needed, the category codes
are listed in Appendix B: "Reporting Codes for
EPA Form R." Category guidance documents are
listed in the Chemical and Industry Guidance
Documents section in this document. This error
type is not detected nor listed on an eFDP report.
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. This error type is listed on an
eFDP as a NOTE.
Applies to: Paper forms and TRI-MEweb submissions
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). This error type is not detected nor
listed on an eFDP report.
Generic chemical name used in Section 1.3. A
generic chemical name should only be provided if
the section 313 chemical identity is claimed as a
trade secret. Generic names should not be used if
no trade secret submissions are being claimed by a
reporting facility. This error type is listed on an
eFDP as a NOSE.
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
Toxics Release Inventory Reporting Forms and Instructions
C-5
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Appendix C
example, isopropyl alcohol is listed on the EPCRA
section 313 chemical list with the qualifier
manufacturing- strong acid process, no supplier
notification. Thus, the ONLY facilities that should
report this EPCRA section 313 chemical are those
that manufacture isopropyl alcohol by the strong
acid process. This error type is not detected nor
listed on an eFDP report.
Section 2. Mixture Component Identity
Applies to: Paper forms and TRI-MEweb submissions
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. This error type is not detected nor listed
on an eFDP report.
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. This error type is not detected nor listed on
an eFDP report.
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 of, 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 of, 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.
This error type is not detected nor listed on an
eFDP report.
Section 3. Activities and Uses of the Toxic
Chemical at the Facility
Applies to: Paper forms and TRI-MEweb submissions
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
Section 4. Maximum Amount of the Toxic
Chemical On-site at Any Time During the
Calendar Year
Applies to: Paper forms only
Maximum amount on-site left blank. Form has failed
to provide the appropriate code for maximum
amount on site. This error type is listed on an eFDP
as a NOSE.
Incorrect units of measure. 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. This error type is not detected nor listed on
an eFDP report.
Toxics Release Inventory Reporting Forms and Instructions
C-6
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Appendix C
Section 5. Quantity of the Toxic Chemical
Entering Each Environmental Medium On-site
Applies to: Paper forms and TRI-MEweb submissions
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. This
error type is not detected nor listed on an eFDP
report.
Overlooking releases to land. Section 313 chemicals
placed in stockpiles or in surface impoundments
should be reported as a "release to land" even if no
Section 313 chemicals leak from these sources.
Quantities of Section 313 chemicals land-treated
should be reported as a release to land. This error
type is not detected nor listed on an eFDP report.
Section 6. Transfers of the Toxic Chemical in
Wastes to Off-site Locations
Applies to: Paper forms and TRI-MEweb submissions
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. This error type is
not detected nor listed on an eFDP report.
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. This error type is not detected nor listed on
an eFDP report.
Section 7A. On-Site Waste Treatment
Methods and Efficiency
Applies to: Paper forms and TRI-MEweb submissions
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. This error type is not detected nor listed
on an eFDP report.
Incorrect reporting of waste treatment methods in
Section 7A. The type of waste stream, waste
treatment efficiency, and waste treatment method
for each waste stream are required to be reported
on Form R using specific codes. The waste
treatment codes are listed in Appendix B:
Reporting Codes for EPA Form R. A table is also
provided in Appendix B that displays a crosswalk
between the old codes and new ones for reporting
year 2005. This error type is not detected nor listed
on an eFDP report.
Section 7B. On-Site Energy Recovery
Processes
Applies to: Paper forms and TRI-MEweb submissions
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. This error
type is not detected nor listed on an eFDP report.
Section 1C. On-Site Recycling Processes
Applies to: Paper forms and TRI-MEweb submissions
Reporting on-site recycling methods in Section 1C.
When a quantity is reported in Section 8.4 as
recycled on-site, the type of recovery method must
be reported in Section 7C, and vice versa. This
error type is not detected nor listed on an eFDP
report.
Section 8. Source Reduction and Recycling
Activities
The TRI-MEweb software offers a Section 8 Calculator.
The Section 8 Calculator will assist users in calculating their
Section 8 source reduction and recycling activity quantities.
Please note that if you use range codes to report data in
sections 5 and 6, TRI-MEweb will default to the mid-point
of the range when performing section 8 calculations.
The entries in this section must be completed, even if your
facility does not engage in source reduction or recycling
activities.
Applies to: Paper forms and TRI-MEweb submissions
Toxics Release Inventory Reporting Forms and Instructions
C-7
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Appendix C
• 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.
Paper forms: Listed on an eFDP as a NOSE.
TRI-MEweb: TRI-MEweb submissions will not be
allowed to be submitted to EPA with this error
type.
Applies to: Paper forms only
• It is incorrect to use range codes to report
quantities in Section 8. Range codes can be
used only in Sections 5 and 6 of Form R.
• It is incorrect to use the same codes from
Section 4 for reporting the maximum amount
of the reported EPCRA Section 313 chemical
on-site to report quantities in Section 8.
• Quantities reported in Section 8.1 through 8.7
are mutually exclusive and additive. This
means that quantities of the reported EPCRA
Section 313 chemical must not be
double-counted in Section 8.1 through 8.7.
• Some double-counting errors have been due to
confusion over the differences in how on-site
treatment of an EPCRA Section 313 chemical
is reported in Section 7A as compared to
Section 8. In Section 7A, information on the
treatment of waste streams containing the
EPCRA Section 313 chemical is reported,
along with the percent efficiency in terms of
destruction or removal of the EPCRA Section
313 chemical from each waste stream. In
Section 8, only the quantity of the EPCRA
Section 313 chemical actually destroyed
through the treatment processes reported in
Section 7A is reported in Section 8.6 to avoid
double-counting within Sections 8.1 through
8.7.
• Quantities reported in Section 8.1 through 8.7
must not be reported in Section 8.8 and vice
versa.
• Any time a reported EPCRA Section 313
chemical is contained in a waste, and the waste
is associated with routine production-related
activities and is recycled, combusted for
energy recovery, treated, disposed of, 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
All calculation errors will be listed on an eFDP as a
NOSE.
Reporting quantities in Section 8.1 Quantities of
EPCRA Section 313 chemicals that are released
(including disposed of) on-site and reported in
Section 5 of Form R must be reported in either
Section 8. la or 8. Ib.
§8.1a = § 5.4.1 + § 5.5.1A + § 5.5.1B - § 8.8
(on-site disposal to landfills or UIC Class I Wells)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
disposal or other releases, other than disposal to
landfills or UIC Class I Wells)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:
- M64 Other Landfills
- M65 RCRA Subtitle C Landfills
M81 Underground Injection to Class I Wells
§8.1c = §6.1 (portion of transfer that is untreated
and ultimately disposed of in landfills or UIC Class
I Wells) + § 6.2 (quantities associated with M
codes M64, M65, and M81) - § 8.8 (off-site
disposal to landfills or UIC Class I Wells)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 of or otherwise released
to the environment either on-site or off-site,
excluding disposal or other releases due to
catastrophic events or non-production related
activities.
Quantities of EPCRA Section 313 chemicals
transferred off-site for the purposes of disposal
reported in Section 6.2 using the following codes
must appear in Section 8. Id:
- M10 Storage Only
M41 Solidification/Stabilization - Metals and
Metal Category Compounds Only
M62 Wastewater Treatment (excluding
POTW) - Metals and Metal Category
Compounds Only
M66 Subtitle C Surface Impoundment
M67 Other Surface Impoundments
M73 Land Treatment
M79 Other Land Disposal
M82 Underground Injection to Class II-V
Wells
- M90 Other Off-Site Management
M94 Transfer to Waste Broker - Disposal
- M99 Unknown.
Toxics Release Inventory Reporting Forms and Instructions
C-8
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Appendix C
§ 8. Id = § 6.1 (portion of transfer that is untreated
and ultimately disposed of or otherwise released,
other than disposal to landfills or UIC Class I
Wells) + § 6.2 (quantities associated with M codes
M10, M41, M62, M66, M67, M73, M79, M82,
M90, M94, and M99) - § 8.8 (off-site disposal or
other releases due to catastrophic events, other than
disposal to landfills or UIC Class I Wells)1
All calculation errors will be listed on an eFDP as a
NOSE.
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.
All calculation errors will be listed on an eFDP as a
NOSE.
Reporting quantities in Section 8.3 "Quantity used
for energy recovery off-site." As in Section 8.2, a
quantity must not be reported in this section if the
off-site combustion of the EPCRA Section 313
chemical took place in a system that did not
recover energy (e.g., incinerator). A quantity of an
EPCRA Section 313 chemical must not be reported
as sent off-site for the purposes of energy recovery
if the EPCRA Section 313 chemical does not have
a significant heating value. Examples of EPCRA
Section 313 chemicals that do not have significant
heating values include metals and metal portions
of metal category compounds. Metals and metal
portions of metal category compounds will never
be combusted for energy recovery. Quantities must
be reported in Section 8.3 that are reported in
Section 6.2 as transferred off-site for the purposes
of combustion for energy recovery using the
following codes:
- M56 Energy Recovery
M92 Transfer to Waste Broker - Energy
Recovery
§ 8.3 = § 6.2 (energy recovery) - § 8.8 (off-site
energy recovery)2
All calculation errors will be listed on an eFDP as a
NOSE.
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 a facility may 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.
All calculation errors will be listed on an eFDP as a
NOSE.
Reporting quantities in Section 8.5. "Quantity
recycled off-site." Quantities reported in Section
6.2 as transferred off-site for the purposes of
recycling must be included in Section 8.5 using the
following codes:
M20 Solvents/Organic Recovery
- M24 Metals Recovery
M26 Other Reuse or Recovery
- M28 Acid Regeneration
1 §8.8 includes quantities of toxic chemicals disposed of or otherwise
released on site or managed as a waste off site due to remedial actions,
catastrophic events, or one-time events not associated with the production
processes.
2§8.8 includes quantities of toxic chemical disposed of or otherwise
released on-site or managed as waste off-site due to remedial actions,
catastrophic events, or one-time events not associated with the production
processes.
Toxics Release Inventory Reporting Forms and Instructions
C-9
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Appendix C
- M93 Transfer to Waste Broker - Recycling.
§8.5 = §6.2 (recycling) - §8.8 (off-site recycling)2
All calculation errors will be listed on an eFDP as a
NOSE.
Reporting quantities in Section 8.6 "Quantity
treated on-site." Quantities may not always have
to be reported in Section 8.6 when Section 7A is
completed. This is because the information
reported in Section 7A and Section 8 is different.
Information on how waste streams containing the
reported EPCRA Section 313 chemical are treated
is reported in Section 7A, while the quantity of the
EPCRA Section 313 chemical actually destroyed
as a result of on-site treatment is reported in
Section 8.6. If a quantity is reported in Section 8.6,
Section 7A must be completed but the reverse may
not be true. This may result in apparent
discrepancies between Section 7A and Section 8.
For example, a facility may treat wastewater
containing an EPCRA Section 313 chemical by
removing the EPCRA Section 313 chemical and
then disposing of it on-site. The treatment of the
wastewater would be reported in Section 7A, with
an efficiency estimate based on the amount of the
EPCRA Section 313 chemical removed from the
wastewater. Although the chemical in the waste
stream has been treated because the 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 of 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 of on-site),
the quantity of the EPCRA Section 313 chemical
would be reported as disposed of 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.
All calculation errors will be listed on an eFDP as a
NOSE.
Reporting quantities in Section 8.7 "Quantity
treated off-site." Quantities reported in Section
6.2 as transferred off-site for the purposes of
treatment must be included in Section 8.7 using the
following codes:
M40 Solidification/Stabilization
- M50 Incineration/Thermal Treatment
- M54 Incineration/Insignificant Fuel Value
M61 Wastewater Treatment (excluding
POTW)
- M69 Other Waste Treatment
- M95 Transfer to Waste Broker - Waste
treatment.
Quantities of an EPCRA Section 313 chemical,
except metals and metal category compounds, sent
off-site to a POTW should also be reported in
Section 8.7. If you know, however, that a chemical
is not treated for destruction at the POTW you
should report that quantity in Section 8.1 instead of
8.7.
To report correctly EPCRA Section 313 chemicals
in Section 8.7, use the following equation.
§8.7 =§6.1 (portion of transfer that is ultimately
treated) + §6.2 (treatment) - §8.8 (off-site
treatment)3
All calculation errors will be listed on an eFDP as a
NOSE.
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 of 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.
Applies to: Paper forms and TRI-MEweb submissions
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. TRI-MEweb in RY
3§8.8 includes quantities of toxic chemical disposed of 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.
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2012 is providing an optional worksheet to help
calculate the production ratio.
Calculating production ratio in Section 8.9. In
calculating a production ratio for otherwise used
chemicals, an activity index must be used rather
than quantities purchased or released from year to
year.
Reporting source reduction activities in Section 8.10.
It is an error to report a source reduction activity in
Section 8.10 and not report at least one method
used to identify that activity and vice versa.
All calculation errors will be listed on an eFDP as a
NOSE.
C.4 eFDP 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 2012 submissions are checked.
Most of these messages will remain the same. You
can look for changes to these error messages on the
TRI home page at http://www.epa.gov/tri
Applies to: Paper forms only
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 have reported Dioxin and Dioxin-like
Compounds on a Form A. Dioxin and Dioxin-like
Compounds are not eligible for the alternate
threshold. Thus, this chemical must be reported on
a Form R. Please resubmit your data on a Form R.
9. In Part I, Section lof the Form R or Form A
Certification Statement You did not enter a
reporting year. (Note: EPA has set the year to 2084
as a default.) You must enter a valid reporting year
for your Form R or Form A Certification
Statement. This entry cannot be left blank and NA
may not be used. (NOSE)
10. In Part I, Section lof the Form R or Form A
Certification Statement you provided an invalid or
future reporting year. You must enter a valid
reporting year for your Form R or Form A
Certification Statement. Valid years are 1987
through 2012. This entry cannot be left blank and
NA may not be used. (NOSE)
11. 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.
12. You did not complete Part II, Sections 5 and 6.
Please provide the required information; otherwise
indicate NA.
13. You did not complete Part II, Section 7. Please
provide the required information; otherwise
indicate NA.
14. You did not complete Part II, Section 8. Please
provide the required information; otherwise
indicate NA.
C.5 Messages Used to Report
Notices of Technical Errors
(NOTEs) and Non-technical
Data Changes (NDCs)
Invalid codes throughout Form R
Applies to: Paper forms only
15. 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)
16. 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,
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transfer, and other waste management
values. (NOTE)
17. 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)
18. 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
Applies to: Paper forms only
19. 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)
20. 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 does 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
Applies to: Paper forms only
21. 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)
22. 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)
23. You made a selection of No in Part 1, Section 2.1
(Trade Secret Information) and selected
unsanitized in Part 1, Section 2.2. In Part II,
Section 1.3 a generic name was indicated. Part II,
Section 1.3 should be completed only if trade
secret is being claimed (Part 1, Section 2.1). EPA
will move the chemical name information in Part
II, Section 1.3 to Part II, Section 1.2. If this is
incorrect and you wish to claim trade secret, you
must resubmit following the requirements of 40
CFR Part 350. (NDC)
24. 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)
25. 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 misspelled, 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)
26. 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 superseded. 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)
27. No Public Contact name and/or telephone number
was listed. Please provide the name and telephone
number of your Public Contact. (NOTE)
28. No Technical Contact name and/or telephone
number was listed. Please provide the name and
telephone number of your Technical Contact.
(NOTE)
29. 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)
30. A valid NAICS code was not provided. Please
provide at least one valid primary six-digit NAICS
code. (NOTE)
31. 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)
32. 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)
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33. 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)
34. Dun and Bradstreet Numbers (Part I Section 4.6)
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)
35. 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)
36. 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)
37. 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)
38. The parent company Dun and Bradstreet Number
in Part I, Section 5.2 (typically a 9-digit number)
cannot be left blank. However, if your parent
company does not have a Dun and Bradstreet
Number check the [NA] box next to Part I, Section
5.2. (NOTE)
Errors in Part II, Section 1. Toxic Chemical
Identity
Applies to: Paper forms only
39. 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)
40. 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)
41. 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)
42. 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)
43. 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)
44. EPA has changed the TRI chemical category code
you reported in Part II, Section 1.1 from N151 to
N150 (the code was incorrectly listed in some
pages of the Reporting Forms and Instructions), the
correct TRI chemical category code for Dioxin and
Dioxin-like Compounds. If this is incorrect and
you are not reporting Dioxin and Dioxin-like
Compounds, please specify the correct CAS
number or chemical category code and matching
chemical name. (NDC)
45. 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 Part II, Section 3. Activities and Uses
of Toxic Chemical at The Facility
Applies to: Paper forms only
46. 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
Applies to: Paper forms only
47. 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
Applies to: Paper forms only
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
Applicable). (NOTE)
indicate "NA" (Not
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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
Applies to: Paper forms only
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. l.B. Please provide the POTW Name and
Location. (NOTE)
67. You provided an incomplete POTW name and
address. Please provide the name and complete
address for the POTW. (NOTE)
68. There are missing or incomplete data for Part II,
Section 6.1. Please provide the transfer amount or
range code and Basis of Estimate for Discharges to
POTWs. (NOTE)
69. You did not complete Part II, Section 6.2,
"Transfers to Other Off-site Locations." If you did
not transfer the waste containing the Section 313
chemical to other off-site locations, enter "NA"
(Not Applicable), otherwise please provide Offsite
EPA ID, Name, Location, Transfer amount or
range code, Basis of Estimate, and type of Waste
Management code. (NOTE)
70. You reported an Off-site Transfer amount or range
code and Basis of Estimate in Part II Section 6.2
but did not indicate an Off-site name and location
in Section 6.2. Please provide the Off-site Name
and Location. (NOTE)
71. You reported an Off-site name and location but did
not provide a Transfer amount. Please provide a
Total Transfer amount or range code, Basis of
Estimate and type of Waste Management code;
otherwise, if there was no transfer to this Off-site
location, delete the Off-site name and location and
indicate "NA" (Not Applicable) in the Off-site
EPA Identification Number (RCRA ID No.) field.
(NOTE)
72. You provided both county and country data. If this
is an extra-national transfer, indicate the off-site
name, address, and Country Code; if a domestic
Offsite, provide the Off-site Name and correct
address. (NOTE)
73. You reported an Off-site name and location, but
there are missing or incomplete data for the off-site
transfer amount, basis of estimate and type of
waste management code. Please provide the Off-
site Transfer amount or range code, Basis of
Estimate, and type of Waste Management code.
(NOTE)
74. You provided incomplete off-site name and
address data. For a transfer to a domestic off-site
location, you must provide a street address, city,
state, county and zip code. For a transfer to a
foreign off-site location, you must provide a street
address, city and a two character country code.
(NOTE)
75. You reported an invalid Type of Waste
Management code. For metals/metal compounds
use only disposal and certain recycling activities
codes. Consult the Reporting Instructions for metal
and metal compounds and correct with a valid
Waste Management (i.e., "M") code. (NOTE)
76. You reported an invalid Type of Waste
Management code. For Barium Compounds use
only disposal and certain recycling activities codes,
M61-Wastewater Treatment (Excluding POTW) or
M69-Other Waste Treatment. Consult the
Reporting Instructions for metal and metal
compounds and correct with a valid Waste
Management (i.e., "M") code. (NOTE)
77. For non-metals codes M41 and M62 are
unacceptable. Provide the appropriate Disposal or
Other Waste Management code for this non-metal
substance. (NOTE)
78. In Part II, Section 6.2 column C you reported M
codes (M56 and/or M92) for energy recovery,
however you left Section 8.3 column B blank.
Please provide the quantity used for energy
recovery offsite in pounds/year in Section 8.3
column B. (NOTE)
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Appendix C
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
Applies to: Paper forms only
81. There are no data contained in all of Part II,
Section 7A. If you do not treat wastes containing
the EPCRA Section 313 chemical at your facility,
indicate "NA;" otherwise please provide the
general waste stream code, waste treatment
methods, range of influent concentration, waste
treatment efficiency estimate and whether this is
based on operating data for all on-site waste
treatments for this chemical. (NOTE)
82. There are missing data in Part II, Section 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
Applies to: Paper forms only
85. There are missing data for Part II, Section 8.1-8.7.
Please provide an estimate or "NA" (Not
Applicable) in each box for section 8.1 through 8.7,
columns A, B, C, and D. You may only use "NA"
(Not Applicable) when there is no possibility a
release or transfer occurred. You may enter zero if
the release or transfer was equal to or less than half
a pound. (NOTE)
86. There are missing data in Part II, Section 8.8.
Please provide an estimate or "NA" (Not
Applicable). You may only use "NA" (Not
Applicable) when there is no possibility a release
or transfer occurred. You may enter zero if the
release or transfer was equal to or less than half a
pound. (NOTE)
87. There are no data in Part II, Section 8.9. Please
provide a production ratio, an activity index, or
"NA" (Not Applicable) if the chemical
manufacture or use began during the current
reporting year. (NOTE)
88. There are no data in Part II, Section 8.10. If your
facility did not engage in any source reduction
activity for the reported chemical, enter "NA" (Not
Applicable) and answer 8.11. Otherwise please
provide Source Reduction Activities and Methods
code(s). (NOTE)
89. There are missing data in Part II, Section 8.10.
Please provide Source Reduction Activities and
Methods code(s). (NOTE)
90. 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 of or recycled. Please
report appropriately in Section 8.1, 8.4, or 8.5.
(NOTE)
91. 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?
Applies to: Paper forms only
92. You did not complete Sections 8.1 through 8.7
column B or 8.8. If you report releases in Part II,
Section 5 and/or an off-site transfer in Section 6.2
and/or quantities transferred off-site to POTWs in
Section 6.1, you must report an estimate in Part II,
Sections 8.1 through 8.7 column B and/or Section
8.8. (NOTE)
93. 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)
94. 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)
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Appendix C
95. 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)
96. You reported an estimate in Part II, Section 8.4,
column B "Quantity Recycled On-site" but did not
provide an on-site recycling code in Part II, Section
1C. Please provide an on-site recycling code for
Part II, Section 7C. (NOTE)
97. 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)
98. 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)
99. 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)
100. 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)
10I.You have reported a listed metal or metal
compound category in Part II, Section 6.1, however
you have not provided a quantity released in
section 8.1 column B. Note that in Section 8a,
metal or metal compound category can only be
reported as disposed of 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)
102.You have reported a listed metal or metal
compound category in Part II, Section 6.1, however
you have not provided quantity released in 8. Id
Column B. Note that in Section 8a, metal or metal
compound category can only be reported as
disposed of or recycled and not reported as treated
for energy recovery or treated for destruction.
Please provide quantity released in pounds/year
Section 8. IB. (NOTE)
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Appendix D. Supplier Notification Requirements
EPA requires some suppliers of mixtures or other trade
name products containing one or more of the EPCRA
section 313 chemicals to notify their customers. This
requirement has been in effect since January 1, 1989.
This appendix explains which suppliers must notify their
customers, who must be notified, what form the notice
must take, and when it must be sent.
D.1 Who Must Supply
Notification
You are covered by the section 313 supplier notification
requirements if you own or operate a facility which meets
all of the following criteria:
1. Your facility is in a North American Industry
Classification System (NAICS) code that
corresponds to Standard Industrial Classification
[SIC] codes 20-39;
2. You manufacture (including import) or process
an EPCRA section 313 chemical; and
3. You sell or otherwise distribute a mixture or
other trade name product containing the EPCRA
section 313 chemical to either:
- A facility in a covered NAICS code (see
Table I).
- A person that then may sell the same
mixture or other trade name product to a
firm in a covered NAICS code (see Table
I).
Note that you may be covered by the supplier
notification rules even if you are not covered by the
section 313 release reporting requirements. For
example, even if you have fewer than 10 full-time
employees or do not manufacture or process any of the
EPCRA section 313 chemicals in sufficient quantities to
trigger the release and other waste management reporting
requirements, you may still be required to notify certain
customers.
D.2 Who Must Be Notified
Industries whose primary NAICS code does not
correspond to SIC codes 20 through 39 are not required
to initiate the distribution of notifications for EPCRA
section 313 chemicals in mixtures or other trade name
products that they send to their customers.
However, if these facilities receive notifications from
their suppliers about EPCRA section 313 chemicals in
mixtures or other trade name products, they should
forward the notifications with the EPCRA section 313
chemicals they send to other covered users.
An example would be if you sold a lacquer containing
toluene to distributors who then may sell the product to
other manufacturers. The distributors are not in a
covered NAICS code, but because they sell the product to
companies in covered NAICS codes, they must be
notified so that they may pass the notice along to their
customers, as required.
The language of the supplier notification requirements
covers mixtures or other trade name products that are
sold or otherwise distributed. The "otherwise distributes"
language includes intra-company transfers and, therefore,
the supplier notification requirements at 40 CFR Section
372.45 apply.
D.3 Supplier Notification
Content
The supplier notification must include the following
information:
1. A statement that the mixture or other trade name
product contains an EPCRA section 313
chemical or chemicals subject to the reporting
requirements of EPCRA section 313 (40 CFR
372);
2. The name of each EPCRA section 313 chemical
and the associated Chemical Abstracts Service
(CAS) registry number of each chemical if
applicable. (CAS numbers are not used for
chemical categories, since they can represent
several individual EPCRA section 313
chemicals.); and
3. The percentage, by weight, of each EPCRA
section 313 chemical (or all EPCRA section 313
chemicals within a listed category) contained in
the mixture or other trade name product.
For example, if a mixture contains a chemical (i.e., 12
percent zinc oxide) that is a member of a reportable
EPCRA section 313 chemical category (i.e., zinc
compounds), the notification must indicate that the
mixture contains a zinc compound at 12 percent by
weight. Supplying only the weight percent of the parent
metal (zinc) does not fulfill the requirement. The
customer must be told the weight percent of the entire
compound within an EPCRA section 313 chemical
category present in the mixture.
Toxics Release Inventory Reporting Forms and Instructions
D-l
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Appendix D
D.4 How the Notification
Must Be Made
The required notification must be provided at least
annually in writing. Acceptable forms of notice include
letters, product labeling, and product literature distributed
to customers. If you are required to prepare and
distribute a Material Safety Data Sheet (MSDS) for the
mixture under the Occupational Safety and Health Act
(OSHA) Hazard Communication Standard, your section
313 notification must be attached to the MSDS or the
MSDS must be modified to include the required
information. (A sample letter and recommended text for
inclusion in an MSDS appear at the end of this appendix.)
You must make it clear to your customers that any copies
or redistribution of the MSDS or other form of
notification must include the section 313 notice. In other
words, your customers should understand their
requirement to include the section 313 notification if they
give your MSDS to their customers.
D.5 When Notification
Must Be Provided
You must notify each customer receiving a mixture or
other trade name product containing an EPCRA section
313 chemical with the first shipment of each calendar
year. You may send the notice with subsequent
shipments as well, but it is required that you send it with
the first shipment each year. Once customers have been
provided with an MSDS containing the section 313
information, you may refer to the MSDS by a written
letter in subsequent years (as long as the MSDS is
current).
If EPA adds EPCRA section 313 chemicals to the section
313 list, and your products contain the newly added
EPCRA section 313 chemicals, notify your customers
with the first shipment made during the next calendar
year following EPA's final decision to add the chemical
to the list. For example, if EPA adds chemical ABC to
the list in September 1998, supplier notification for
chemical ABC would have begun with the first shipment
in 1999.
You must send a new or revised notice to your customers
if you:
1. Change a mixture or other trade name product
by adding, removing, or changing the percentage
by weight of an EPCRA section 313 chemical;
or
2. Discover that your previous notification did not
properly identify the EPCRA section 313
chemicals in the mixture or correctly indicate
the percentage by weight.
In these cases, you must:
1. Supply a new or revised notification within 30
days of a change in the product or the discovery
of misidentified EPCRA section 313 chemical(s)
in the mixture or incorrect percentages by
weight; and
2. Identify in the notification the prior shipments of
the mixture or product in that calendar year to
which the new notification applies (e.g., if the
revised notification is made on August 12,
indicate which shipments were affected during
the period January 1-August 12).
D.6 When Notifications
Are Not Required
Supplier notification is not required for a "pure" EPCRA
section 313 chemical unless a trade name is used. The
identity of the EPCRA section 313 chemical will be
known based on label information.
You are not required to make a "negative declaration."
That is, you are not required to indicate that a product
contains no EPCRA section 313 chemicals.
If your mixture or other trade name product contains one
of the EPCRA section 313 chemicals, you are not
required to notify your customers if:
1. Your mixture or other trade name product
contains the EPCRA section 313 chemical in
percentages by weight of less than the following
levels (These are known as de minimis levels)
- 0.1 percent if the EPCRA section 313
chemical is defined as an "OSHA
carcinogen;"
- 1 percent for other EPCRA section 313
chemicals.
De minimis levels for each EPCRA section 313 chemical
and chemical category are listed in Table II. PBT
chemicals (except lead when contained in stainless steel,
brass or bronze alloys) are not eligible for the de minimis
exemption. Therefore, de minimis levels are not provided
for these chemicals in Table II. However, for purposes of
supplier notification requirements only, such notification
is not required when the following PBT chemicals are
contained in mixtures below their respective de minimis
levels:
Toxics Release Inventory Reporting Forms and Instructions
D-2
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Appendix D
Chemical or chemical
category name
Aldrin
Benzo[g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds
(manufacturing; and the
processing or otherwise
use of dioxin and dioxin-
like compounds if the
dioxin and dioxin-like
compounds are present
as contaminants in a
chemical and if they
were created during the
manufacturing of that
chemical
Heptachlor
Hexachlorobenzene
Isodrin
Lead
Lead compounds
Mercury
Mercury compounds
Methoxychlor
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Polychlorinated
biphenyls (PCBs)
Polycyclic aromatic
compounds category
Tetrabromobisphenol A
Toxaphene
CAS
number or
chemical
category
code
309-00-2
191-24-2
57-74-9
N150
76-44-8
118-74-1
465-73-6
7439-92-1
N420
7439-97-6
N458
72-43-5
29082-74-4
40087-42-1
608-93-5
1336-36-3
N590
79-94-7
8001-35-2
Supplier
notification
limit (%)
1.0
1.0
0.1
1.0*
0.1
0.1
1.0
0.1
0.1**
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1***
1.0
0.1
CAS
Chemicaiorchemica, "£££ „»„
category name category |imi,(%)
code
Trifluralin 1582-09-8 1.0
*The de minimis level is 1.0 for all members except for
2,3,7,8-Tetrachlorodibenzo-p-dioxin which has a 0. 1%
de minimis level.
**The de minimis level is 0.1 for inorganic lead
compounds and 1.0 for organic lead compounds
***The de minimis level is 0.1 except for
benzo(a)phenanthrene, dibenzo(a,e)fluoranthene,
benzo(j,k)fluorene, and 3-methylcholanthrene which are
subject to the 1.0% de minimis level.
2. Your mixture or other trade name product is one
of the following:
An article that does not release an EPCRA
section 313 chemical under normal
conditions of processing or otherwise use.
beverages, tobacco, or tobacco products
packaged for distribution to the general
public.
Any consumer product, as the term is
defined in the Consumer Product Safety
Act, packaged for distribution to the
general public. For example, if you mix
or package one-gallon cans of paint
designed for use by the general public,
notification is not required.
3. A waste sent off site for further waste
management. The supplier notification
requirements apply only to mixtures and trade
name products. They do not apply to wastes.
4. You are initiating distribution of a mixture or
other trade name product containing one or more
EPCRA section 313 chemicals and your facility
is in any of the covered SIC codes added during
the 1997 industry expansion rulemaking,
including facilities whose SIC code is within
SIC major group codes 10 (except 1011, 1081,
and 1094), 12 (except 1241); industry codes
4911 (limited to facilities that combust coal
and/or oil for the purpose of generating power
for distribution in commerce), 493 1 (limited to
facilities that combust coal and/or oil for the
purpose of generating power for distribution in
commerce), or 4939 (limited to facilities that
combust coal and/or oil for the purpose of
generating power for distribution in commerce);
or 4953 (limited to facilities regulated under the
Toxics Release Inventory Reporting Forms and Instructions
D-3
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Appendix D
Resource Conservation and Recovery Act,
subtitle C, 42 U.S.C. Section 6921 et seq.) or
5169, or 5171, or 7389 (limited to facilities
primarily engaged in solvents recovery services
on a contract or fee basis).
D.7 Trade Secrets
Chemical suppliers may consider the chemical name or
the specific concentration of an EPCRA section 313
chemical in a mixture or other trade name product to be a
trade secret. If they consider:
1. The specific identity of an EPCRA section 313
chemical to be a trade secret, the notice must
contain a generic chemical name that is
descriptive of the structure of that EPCRA
Section 313 chemical (for example,
decabromodiphenyl oxide could be described as
a halogenated aromatic);
2. The specific percentage by weight of an EPCRA
section 313 chemical in the mixture or other
trade name product to be a trade secret, the
notice must contain a statement that the EPCRA
section 313 chemical is present at a
concentration that does not exceed a specified
upper bound. For example, if a mixture contains
12 percent toluene and you consider the
percentage a trade secret, the notification may
state that the mixture contains toluene at no
more than 15 percent by weight. The upper
bound value chosen must be no larger than
necessary to adequately protect the trade secret.
If you claim this information to be trade secret, you must
have documentation that provides the basis for your
claim.
D.8 Record keeping
Requirements
You are required to keep records of the following for
three years:
1. Notifications sent to recipients of your mixture
or other trade name product;
2. All supporting materials used to develop the
notice;
3. If claiming a specific EPCRA section 313
chemical identity a trade secret, you should
record why the EPCRA section 313 chemical
identity is considered a trade secret and the
appropriateness of the generic chemical name
provided in the notification; and
4. If claiming a specific concentration a trade
secret, you should record explanations of why a
specific concentration is considered a trade
secret and the basis for the upper bound
concentration limit.
Information retained under 40 CFR 372 must be readily
available for inspection by EPA.
Toxics Release Inventory Reporting Forms and Instructions
D-4
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Appendix D
D.9 Sample Notification Letter
January 2, 2009
Mr. Edward Burke
Furniture Company of North Carolina
1000 Main Street
Anytown, North Carolina 99999
Dear Mr. Burke:
This letter is to inform you that a product that we sell to you, Furniture Lacquer KXZ-1390, contains one or more
chemicals subject to section 313 of Emergency Planning and Community Right-to-Know Act (EPCRA). We are
required to notify you of the presence of these chemicals in the product under EPCRA section 313. This law requires
certain industrial facilities to report on annual emissions and other waste management of specified EPCRA section 313
chemicals and chemical categories. Our product contains:
Toluene, Chemical Abstract Service (CAS) number 108-88-3, 20 percent, and
Zinc compounds, 15 percent.
If you are unsure whether you are subject to the reporting requirements of EPCRA section 313, or need more
information, call the EPA/TRI Information Center. For contact information, please see the TRI Home Page at
http://www.epa.gov/tri. Your other suppliers should also be notifying you about EPCRA section 313 chemicals in the
mixtures and other trade name products they sell to you.
Finally, please note that if you repackage or otherwise redistribute this product to industrial customers, a notice similar
to this one should be sent to those customers.
Sincerely,
Emma Sinclair
Sales Manager
Furniture Products
Toxics Release Inventory Reporting Forms and Instructions D-5
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Appendix D
D.10 Sample Notification on an MSDS Furniture
Products
Section 313 Supplier Notification
This product contains the following EPCRA section 313 chemicals subject to the reporting requirements
of section 313 of the Emergency Planning and Community Pdght-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
Toxics Release Inventory Reporting Forms and Instructions
D-6
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Appendix E. TRI State and Tribal Contacts
EPCRA Section 313 requires facilities to submit reports to both EPA and their state or tribe (if located in
Indian country as defined by 18 USC §1151). For a current list of state and tribal designated Section 313
contacts, see the TRI web site at:
State TRI Contact Information and Web Sites: http://www.epa.gov/tri/stateprograms/state_programs.htm
Tribal TRI Contact Information and Web Sites: http ://www. epa. gov/tri/contacts/contacts tribal.html
Toxics Release Inventory Reporting Forms and Instructions E-1
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Appendix F. TRI Regional Contacts
Region 1 (CT, ME, MA, NH, RI, and VT)
Dwight Peavey
Assistance and Pollution Prevention Office
USEPA Region 1 (SPT)
1 Congress Street, Suite 1100
Boston, MA 02114-2023
(617) 918-1829; fax: (617) 918-1810
peavey.dwight@epa.gov
Region 2 (NJ, NY, PR, and VI)
Nora Lopez
Pesticides and Toxic Substances Branch
USEPA Region 2 (MS-105)
2890 Woodbridge Avenue, Building 10
Edison, NJ 08837-3679
(732) 906-6890; fax: (732) 321-6788
lopez.nora@epa.gov
Region 3 (DE, DC, MD, PA, VA, and WV)
William Reilly
Toxics Programs and Enforcement Branch
USEPA Region 3 (3WC33)
1650 Arch Street
Philadelphia, PA 19103-2029
(215) 814-2072; fax: (215) 814-3114
reilly.william@epa.gov
Region 4 (AL, FL, GA, KY, MS, NC, SC, TN)
Ezequiel Velez
EPCRA Enforcement Section
USEPA Region 4
Atlanta Federal Center
61 Forsyth Street, S.W.
Atlanta, GA 30303-8960
(404) 562-9191; fax: (404) 562-9163
velez.ezequiel@epa.gov
Region 5 (IL, IN, MI, MN, OH, and WI)
Thelma Codina
Pesticides and Toxics Branch
USEPA Region 5 (DT-8J)
77 West Jackson Boulevard
Chicago, IL 60604
(312) 886-6219; fax: (312) 353-4788
codina.thelma@epa.gov
Region 6 (AR, LA, NM, OK, and TX)
Morton Wakeland
Toxics Section, Multimedia Planning and
Permitting Division
USEPA Region 6 (6PD-T)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
(214) 665-8116; fax: (214) 665-6762
wakeland.morton@epa.gov
Region 7 (IA, KS, MO, and NE)
Stephen Wurtz
Air, RCRA and Toxics Division
USEPA Region 7 (ARTD/CRIB)
901 North 5th Street
Kansas City, KS 66101
(913) 551-7315; fax: (913) 551-7065
wurtz.stephen@epa.gov
Region 8 (CO, MT, ND, SD, UT, and WY)
Barbara Conklin
Office of Pollution Prevention, Pesticides and
Toxics
USEPA Region 8 (8P-P3T)
1595 Winkoop Street
Denver, CO 80202
(303) 312-6619; fax: (303) 312-6044
conklin.barbara@epa.gov
Region 9 (AS, AZ, CA, GU, HI, MH, MP,
and NV)
Lily Lee
Toxics Office, Communities and Ecosystems
Division
USEPA Region 9 (CED-4)
75 Hawthorne Street
San Francisco, CA 94105-3901
(415) 947-4187; fax: (415) 947-3583
lee.lily@epa.gov
Region 10 (AK, ID, OR, and WA)
Gabriela Carvalho
USEPA Region 10 (AWT-128)
1200 Sixth Avenue
Suite 900
Seattle, WA 98101-3140
(206) 553-4016; fax: (206) 553-7176
carvalho.gabriela@epa.gov
Toxics Release Inventory Reporting Forms and Instructions
F-l
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Appendix G. Other Relevant Section 313 Materials
G.I TRI National Analysis
2012 Toxics Release Inventory National Analysis
EPA summarizes the latest TRI data in a report
called the TRI National Analysis. The National
Analysis is an annual report that includes
information about toxic chemical releases to the
environment, how toxic chemicals are managed at
TRI facilities (i.e. recycled, treated and burned for
energy), and how facilities are working to reduce
toxic chemicals they generate and release. The TRI
National Analysis Overview document includes
national trends and figures, while other websites
linked from the National Analysis homepage
include more localized analyses of states, certain
urban areas and watersheds. The National Analysis
homepage can be accessed at
www. epa. gov/tri/NationalAnalysis.
To conduct your own analysis, TRI data collected
from 1987 through 2011 can be accessed using the
TRI Explorer online tool:
http ://www. epa. gov/triexplorer
as well as several other public access tools available
on the TRI website at
http ://www. epa. gov/tri/tridata/index.htm.
G.2. Access to TRI Information On-line
The TRI Home Page http ://www. epa. gov/tri offers
information useful to both novice and experienced
users of the Toxics Release Inventory. It provides a
description of what the TRI database is and how it
can be used; access to TRI data; TRI regulations;
and guidance documents for complying with TRI
regulations and using TRI data. You can find out
about TRI products, view or download the 2012 TRI
reports, and identify who to contact for more
information in EPA regions and state programs
across the country. From the TRI home page, you
can link to other EPA and non-EPA sites that also
allow you to search the TRI database and other
databases online.
TRI Explorer http ://www. epa. gov/triexplorer is an
on-line tool that EPA has created to obtain TRI data.
It allows the user to search the TRI database using
six criteria: facility, chemical, year or industry type
(NAICS code), federal facility and geographic area
(at the county, state or national level). The tool will
generate three types of reports: (1) Release Reports
(including on- and off-site releases (i.e., off-site
releases include transfers off-site to disposal and
metals and metal compounds transferred to
POTWs)); (2) Waste Transfer Reports (including
amounts transferred off-site for further waste
management but not including transfers off-site to
disposal); and (3) Waste Quantity Reports
(including amounts recycled, burned for energy
recovery, quantities treated, and quantities released).
TOXNET http://toxnet.nlm.nih.gov the National
Library of Medicine's (NLM) Toxicology Data
Network, provides free access to several databases,
including the TRI database, that provides a variety
of information on toxic chemicals. As with EPA's
TRI Explorer tool, users of TOXNET can search by
chemical or other name, chemical name fragment,
or Chemical Abstracts Service Registry Number.
Also searchable are facility or parent company
name, state, city, county, or zip code. Search results
can be limited to releases greater than a specified
number of pounds, and individual releases can be
summed together to display a total amount.
Toxicity and environmental fate data for thousands
of chemicals are also available from TOXNET.
G.3 Other TRI Information
EPA's Integrated Risk Information System
(IRIS) http ://www. epa. gov/iris is an electronic
database containing information on human health
effects that may result from exposure to various
chemicals, including TRI chemicals, in the
environment. IRIS was initially developed for EPA
staff in response to a growing demand for consistent
information of chemical substances for use in risk
assessments, decision-making and regulatory
activities. The information in IRIS is intended for
those without extensive training in toxicology, but
with some knowledge of health sciences.
Consolidated List of Chemicals Subject to the
Emergency Planning and Community Right-to-
Know Act and Section 112(r) of the Clean Air
Act (List of Lists), (October 2001):
http ://www. epa. gov/ceppo/pubs/title3 .pdf
A paper copy is available from the National
Technical Information Service, 5285 Port Royal
Road, Springfield, VA 22161, 703 605-6000,
Document Number: PB2003-105834, $38.00 plus
Toxics Release Inventory Reporting Forms and Instructions
G-l
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Appendix G
$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 and is available through
written request at no charge from the EPA/TRI
Information Center. For contact information, please
see the TRI Home Page at http://www.epa.gov/tri.
Chemicals in the Environment
Issue number 6 of Chemicals in the Environment
(CIE), published in the Fall of 1997, is devoted
entirely to TRI. This 22 page publication contains
19 articles ranging from the history of TRI to the
future of new TRI products. Articles include
perspectives from the community, state, Federal,
and International level. The publication also
provides valuable information on training and
contacts within the EPA. CIE is available free from
EPA by asking for publication EPA 749-R-97-
00Ib. To request copies, contact:
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave., N.W.
Attn: TRI Documents
MC: 2844
Washington, DC 20460
202 564-9554
Email: TRIDOCS@epa.gov
The Pollution Prevention Information
Clearinghouse (PPIC)
http://www.epa.gov/oppt/ppic/index.html
PPIC was established as part of EPA's response to
the Pollution Prevention Act of 1990, which
directed the Agency to compile information,
including a database, on management, technical, and
operational approaches to source reduction. PPIC
provides information to the public and industries
involved in conservation of natural resources and in
reduction or elimination of pollutants in facilities,
workplaces, and communities.
To request EPA information on pollution prevention
or obtain fact sheets on pollution prevention from
various state programs call the PPIC reference and
referral service at 202 566-0799, or fax a request to
202566-0794, or write to:
U.S. EPA
Pollution Prevention Information Clearinghouse
(PPIC)
EPA West
1200 Pennsylvania Ave. NW
Room 3379 (Mail Code 7407-T)
Washington, DC 20460-0001
Email: ppic@epa.gov
Toxics Release Inventory Reporting Forms and Instructions
G-2
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Appendix H. Guidance Documents
H.1 General Guidance
Many of the TRI guidance documents are available via the Internet http ://www. epa. gov/tri.
• 40 CFR 372, Toxic Chemical Release Reporting; Community Right-to-Know; Final Rule
A reprint of the final EPCRA section 313 rule as it appeared in the Federal Register (FR) February 16, 1988 (53
FR 4500) (OTSFR 021688).
• Common Synonyms for Chemicals Listed Under Section 313 of the Emergency Planning and Community
Right-to-Know Act
March 1995 (EPA 745R-95-008)
This glossary contains chemical names and their synonyms for substances covered by the reporting requirements
of EPCRA section 313. The glossary was developed to aid in determining whether a facility manufactures,
processes, or otherwise uses a chemical subject to EPCRA section 313 reporting.
• EPCRA Section 313 Questions and Answers - Revised 1998 Version
December 1998 (EPA 745-B-98-004)
The revised 1998 EPCRA Section 313 Questions and Answers document assists regulated facilities in complying
with the reporting requirements of EPCRA section 313. This updated document presents interpretive guidance
in the form of answers to many commonly asked questions on compliance with EPCRA section 313. In
addition, this document includes comprehensive written directives to assist covered facilities in understanding
some of the more complicated regulatory issues. This updated guidance document is intended to supplement the
instructions for completing the Form R and the Alternate Threshold Certification Statement (Form A).
• EPCRA Section 313 Questions and Answers - Addendum to the Revised 1998 Version
December 2004 (EPA-260-B-04-002)
As a result of Executive Order 13148, regulatory actions, and legal decisions over the past five years, some of
the Qs & As contained in the 1998 Q &A Document were updated. The 1998 Q & A Document remains valid
guidance in all other respects.
• EPCRA Section 313 Questions and Answers Addendum for Federal Facilities
May 2000 (EPA 745-R-00-003)
This document is an addendum to the EPCRA section 313 Questions and Answers: Revised 1998 Version. It
provides additional assistance to federal facilities in complying with EPCRA section 313. Federal facilities,
which are subject to compliance under EPCRA through Executive Order 13423, frequently have operations that
are different from the private sector facilities subject to EPCRA. The document contains questions and answers
that address some of those differences.
• EPCRA Section 313 Release and Other Waste Management Reporting Requirements
February 2001 (EPA 260/K-01-001)
The brochure alerts businesses to their reporting obligations under EPCRA section 313 and assists in
determining whether their facility is required to report. The brochure contains the EPA regional contacts, the list
of EPCRA section 313 toxic chemicals and a description of the Standard Industrial Classification (SIC) codes
subject to EPCRA section 313.
• Toxic Chemical Release Reporting Using 2007 North American Industry Classification System (NAICS)
Final Rule (73 FR 32466; June 9, 2008): This final rule incorporates 2007 Office of Management and Budget
(OMB) revisions and other corrections to the NAICS codes used for TRI Reporting.
• Toxic Chemical Release Reporting Using North American Industry Classification System (NAICS) Final
Rule (71 FR 32464; June 6,2006): With this rulemaking, Toxics Release Inventory (TRI) reporting will require
North American Industry Classification System (NAICS) codes in place of Standard Industrial Classification
Toxics Release Inventory Reporting Forms and Instructions H-1
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Appendix H
(SIC) codes. North American Industry Classification System (NAICS), United States, 2002, Executive Office of
the President, Office of Management and Budget, NTIS Order Number: PB2002-101430
• Persistent Bioaccumulative Toxic (PBT) Chemicals; Final Rule (64 FR 58666)
A reprint of the final rule that appeared in the Federal Register of October 29, 1999. This rule adds certain PBT
chemicals and chemical categories for reporting year 2000 and beyond under EPCRA section 313, lowers their
activity thresholds and modifies certain reporting exemptions and requirements for PBT chemicals and chemical
categories. In a separate action, as part of the October 29, 1999 rulemaking, EPA added vanadium (except when
contained in alloy) and vanadium compounds. These are not listed as PBT chemicals.
H.2 Supplier Notification Requirements
(EPA 560-4-91-006)
This pamphlet assists chemical suppliers who may be subject to the supplier notification requirements, gives examples
of situations which require notification, describes the trade secret provision, and contains a sample notification.
• Toxic Chemical Release Inventory Reporting Forms and Instructions Revised 2006 Version
February 2007 (EPA 260-C-06-901)
• Toxics Release Inventory: Reporting Modifications Beginning with 1995 Reporting Year
February 1995 (EPA 745-R-95-009)
• Trade Secrets Rule and Substantiation Form
• (53 FR 28772)
A reprint of the final rule that appeared in the Federal Register of July 29, 1988. This rule implements the trade
secrets provision of the Emergency Planning and Community Right-to-Know Act (section 322). The current
trade secret substantiation form can be accessed at http://www.epa.gov/tri/report/index.htnrfforms
H.3 Chemical-Specific Guidance
EPA has developed a group of guidance documents specific to individual chemicals and chemical categories.
• Emergency Planning and Community Right-to-Know Section 313: List of Toxic Chemicals within the
Chlorophenols Category
June 1999 (EPA745-B-99-013)
• Toxics Release Inventory List of Toxic Chemicals within the Glycol Ethers Category and Guidance for
Reporting
December 2000 (EPA745-R-00-004)
• Emergency Planning and Community Right-to-Know Act Section 313: Guidance for Reporting
Hydrochloric Acid (acid aerosols including mists, vapors, gas, fog and other airborne forms of any
particle size)
December 1999 (EPA745-B-99-014)
• Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Releases
and Other Waste Management Activities of Toxic Chemicals: Lead and Lead Compounds
November 2001 (EPA-260-B-01-027)
• Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
Chemicals: Mercury and Mercury Compounds Category
August 2001 (EPA 260-B-01-004)
• Toxics Release Inventory List of Toxic Chemicals within the Nicotine and Salt Category and Guidance for
Reporting
June 1999 (EPA745-R-99-010)
Toxics Release Inventory Reporting Forms and Instructions H-2
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Appendix H
• Toxics Release Inventory List of Toxic Chemicals within the Water Dissociable Nitrate Compounds
Category and Guidance for Reporting
December 2000 (EPA 745-R-00-006)
• Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
Chemicals: Pesticides and Other Persistent Bioaccumulative Toxic (PBT) Chemicals
August 2001 (EPA 260-B-01-005)
• Toxics Release Inventory List of Toxic Chemicals within the Polychlorinated Alkanes Category and
Guidance for Reporting
June 1999 (EPA 745-B-99-023)
• Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
Chemicals: Polycyclic Aromatic Compounds Category
August 2001 (EPA 260-B-01-003)
• Toxics Release Inventory List of Toxic Chemicals within the Strychnine and Salts Category and Guidance
for Reporting
June 1999 (EPA745-R-99-011)
• Emergency Planning and Community Right-to-Know Act Section 313: Guidance for Reporting Sulfuric
Acid (acid aerosols including mists, vapors, gas, fog and other airborne forms of any particle size)
March 1998 (EPA745-R-97-007)
• Toxics Release Inventory List of Toxic Chemicals within Warfarin Category
June 1999 (EPA745-B-99-011)
• Toxics Release Inventory List of Toxic Chemicals within Ethylenebisdithiocarbamic Acid, Salts and
Esters Category and List of Mixtures that Contain the Individually listed Chemicals Maneb, Metiram,
Nabam, and Zineb
September 2001 (EPA 260-B-01-026)
• Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Aqueous
Ammonia
December 2000 (EPA 745-R-00-005)
• Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
Chemicals within the Dioxin and Dioxin-like Compounds Category
December 2000 (EPA 745-B-00-021)
H.4 Industry-Specific Guidance
EPA has developed specific guidance documents for certain industries.
• EPCRA Section 313: Guidance for Chemical Distribution Facilities
January 1999 (EPA 745-B-99-005)
• EPCRA Section 313: Guidance for Petroleum Terminals and Bulk Storage Facilities
February 2000 (EPA 745-B-00-002)
• EPCRA Section 313: Guidance for Coal Mining Facilities
February 2000 (EPA 745-B-00-003)
• EPCRA Section 313: Guidance for Electricity Generating Facilities
February 2000 (EPA 745-B-00-004)
• EPCRA Section 313 Reporting Guidance for Food Processors
Toxics Release Inventory Reporting Forms and Instructions H-3
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Appendix H
September 1998 (EPA745-R-98-011)
• EPCRA Section 313 Reporting Guidance for the Leather Tanning and Finishing Industry
April 2000 (EPA 745-B-00-012)
• EPCRA Section 313: Guidance for Metal Mining Facilities
Januaryl999 (EPA745-B-99-001)
• Emergency Planning and Community Right-to-Know Act Section 313 Reporting Guidance for the
Presswood and Laminated Products Industry
August 2001 (EPA 260-B-01-013)
• EPCRA Section 313 Reporting Guidance for the Printing, Publishing, and Packaging Industry
May 2000 (EPA 745-B-00-005)
• EPCRA Section 313: Guidance for RCRA Subtitle C TSD Facilities and Solvent Recovery Facilities
January 1999 (EPA 745-B-99-004)
• EPCRA Section 313 Reporting Guidance for Rubber and Plastics Manufacturing
May 2000 (EPA 745-B-00-017)
• EPCRA Section 313 Reporting Guidance for Semiconductor Manufacturing
July 1999 (EPA 745-R-99-007)
• EPCRA Section 313 Reporting Guidance for the Textile Processing Industry
May 2000 (EPA 745-B-00-008)
• EPCRA Section 313 Reporting Guidance for Spray Application and Electrodeposition of Organic
Coatings
December 1998 (EPA745-R-98-014)
Toxics Release Inventory Reporting Forms and Instructions H-4
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Appendix I. Questions and Answers Regarding
Facility Identification Information
1.1 Categories
This document provides additional information about TRI
reporting procedures based on some frequently asked
questions. The questions and their answers are organized
into three groups:
Section 1.2 Identifying the parent company.
Section 1.3 Reporting after a change in name or
ownership.
Section 1.4 Reporting for multiple sites and/or owners.
1.2 Identifying the Parent
Company
A. Question
When a facility changes ownership after a Form R has
been submitted, who is required to respond to a Notice of
Noncompliance (NON) related to the Form R? Is the
current or prior owner/operator required to respond to the
NON?
A. Answer
The current owner/operator has the primary responsibility
for responding to a NON. However, all prior
owners/operators back to January 1 of the reporting year
may also be held responsible if the current
owner/operator does not respond to the NON in an
accurate, complete, and timely manner.
(Source: 1997 EPCRA Section 313 Questions and
Answers Document, Question 31 (EPA 745-B-97-008)).
B. Question
Who is the parent company for a 50/50 joint venture?
B. Answer
The 50/50 joint venture is its own parent company.
(Source: 1997 EPCRA Section 313 Questions and
Answers Document, Question #33 (EPA 745-B-97-008)).
1.3 Reporting After a
Change in Name or
Ownership
A. Question
The owner/operator of a covered facility is preparing
Form Rs for a facility. The facility and its parent
company both changed their names after the reporting
year. What names should be reported by the
owner/operator (for both the facility and the parent
company) on the Form Rs covering the reporting year?
A. Answer
The facility should report the names used by the facility
and parent company during that reporting year. When the
owner/operator submits Form Rs for the next reporting
year, these reports should reflect the names used by the
facility and parent company during the new reporting
year. Note that the TRI facility identification number
will not change.
(Source: 1997 EPCRA Section 313 Questions and
Answers Document, Question #457 (EPA 745-B-97-
008)).
B. Question
If a covered facility does not have a Dun & Bradstreet
(D&B) number but the parent corporation does, should
this number be reported?
B. Answer
Report the D&B number for the facility. If a facility does
not have a D&B number, enter "NA" in Part I, Section
4.7. The corporate D&B number should be entered in
Part I, Section 5.2 relating to parent company
information.
(Source: 1997 EPCRA Section 313 Questions and
Answers Document, Question #464 (EPA 745-B-97-
008)).
C. Question
Mom and Pop Plastics is a wholly owned subsidiary of a
major chemical company which is a wholly owned
subsidiary of Big Oil Corporation, located in St. Paul,
Minnesota. Which is the parent company?
C. Answer
Big Oil Corporation is the parent company.
(Source: 1997 EPCRA Section 313 Questions and
Answers Document, Question #35 (EPA 745-B-97-008)).
C. Question
In October 2009, Facility X changes ownership and is
purchased by Company Y. For the 2009 reporting year,
which facility is obligated to submit the Form R or Form
A, and whose name and what TRI identification number
should be on the form?
C. Answer
The owner or operator of the facility on the annual July 1
reporting deadline (i.e., Company Y) is primarily
responsible for reporting the data for the entire previous
Toxics Release Inventory Reporting Forms and Instructions
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Appendix I
year's operations at that facility. Any other owner or
operator of the facility before the reporting deadline may
also be held liable. The form submitted for a given
reporting year must reflect the names used by the facility
and its parent company on December 31 of that reporting
year, even if the facility changed its name or ownership at
any time during the reporting year. In this scenario,
because Facility X changed ownership before December
31 of the reporting year, Company Y's name should
appear on the form. The TRI identification number is
location-specific; thus, the identification number will stay
the same even if the facility changes names, production
processes, or NAICS codes.
(Source: Monthly Call Center Report Question EPA530-
R-98—5j; October 1998).
1.4 Reporting for Multiple
Sites and/or Owners
A. Question
If two plants are separate establishments under the same
site management, must they have separate D&B
numbers?
A. Answer
They may have separate D&B numbers, especially if they
are distinctly separate business units. However, different
divisions of a company located at the same facility
usually do not have separate D&B numbers.
(Source: 1997 EPCRA Section 313 Questions and
Answers Document, Question #465 (EPA 745-B-97-
008)).
B. Question
An electricity generating facility (EOF) is comprised of
multiple independent owners. Each individual owner runs
his/her own separate operation, but each has a financial
interest in the operation of the entire facility. What name
should be entered as the parent company in Part I,
Section 5.1 of the Form R? Should the facility report
under one holding company name?
B. Answer
The EOF should enter in Part I, Section 5.1 of the Form R
the name of the holding or parent company, consortium,
joint venture, or other entity that owns, operates, or
controls the facility.
(Source: Question #2, Addendum to the Guidance
Documents for the Newly Added Industries (EPA 745-B-
98-001)).
C. Question
A covered facility sells one of its establishments to a new
owner. The operator of the newly sold establishment,
however, does not change. The same operator operates
the newly sold establishment and the rest of the facility.
Although the facility makes its threshold determinations
based on the activities at the entire facility (including the
newly sold establishment), the facility chooses to report
separately for the different establishments. What parent
name should the newly sold establishment use, the parent
name of the owner or the parent name of the operator
(i.e., the same as the rest of the facility)?
C. Answer
All establishments of a covered facility must report the
parent name of the facility. Therefore, in the instance
described above, the newly sold establishment should use
the parent name of the facility operator (i.e., the same
parent name the rest of the facility is using).
(Source: Spring Training 1998).
D. Question
Company A purchases a facility from Company B
between January 1, 2006 and June 30, 2006. For the
2005 reporting year, which company's name and
identification number should appear on the Form R or
Form A submission?
D. Answer
In the case that a facility is purchased between January 1
and June 30, the form submitted for the previous year
must reflect the name used by the facility on December
31 of that reporting year. In this example, company B's
name should appear on the form because it owned the
facility for the duration of the reporting year. The TRI
identification number is location-specific; thus, the
identification number will stay the same even if the
facility changes names, production processes, or NAICS
codes.
With regard to reporting, the owner or operator of the
facility on the annual July 1 reporting deadline (Company
A) is primarily responsible for reporting the data for the
previous year's operations at that facility. However, all
prior owners and operators back to January 1 of the year
covered in the report may also be held responsible if the
current owner or operator does not submit a report.
(Source: Monthly Call Center Report Question EPA530-
R-98—5j; October 1998)
Toxics Release Inventory Reporting Forms and Instructions
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Appendix I
E. Question
Two distinct NAICS code operations that are covered
under EPCRA Section 313 (e.g., an electricity generating
unit and a cement plant) are located on adjacent
properties and are owned by the same parent company.
The two operations are operated completely
independently of one another (e.g., separate accounting
procedures, employees, etc.). Are these two operations
considered one facility under EPCRA Section 313?
E. Answer
Yes. Under EPCRA Section 313, a facility is 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." Because these two operations are located
on adjacent properties and are owned by the same person
they are considered one facility for EPCRA Section 313
reporting purposes. Additional information can be found
in the 2009 Toxic Release Inventory Reporting Forms
and Instructions.
F. Question
A piece of contiguous property consists of three covered
sites with various buildings, structures and equipment.
The three sites are owned by two different companies -
Company A and Company B. All three sites operate
completely independently of each other and have separate
personnel, finances, and environmental reporting
systems. Site 1 and its buildings and structures are
owned and operated by Company A and site 3 and its
buildings and structures are owned and operated by
Company B. The middle site, site 2 and its surrounding
buildings and structures, are owned by Company A and
operated by Company B. Are all three sites and their
buildings and structures considered separate facilities
under EPCRA Section 313? Who is responsible for
reporting for each?
F. Answer
Under 40 CFR Section 372.3 a facility is 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." Because all buildings and structures
located on sites 1 and 2 are located on contiguous
property and are owned by the same person, they are
considered one facility. Because all buildings and
structures located on sites 2 and 3 are located on
contiguous property and are operated by the same person,
they are also considered one facility. Therefore, for
purposes of determining thresholds, the toxic chemicals
manufactured, processed, and otherwise used at site 2
must be counted toward both Facility A's and Facility
B's threshold determinations. Because the operator is
primarily responsible for reporting, estimating and
reporting releases and other waste management
calculations for sites 2 and 3 are the primary
responsibility of Company B, and the release and other
waste management reporting for site 1 is the primary
responsibility of Company A. EPA allows the release
and other waste management reporting to be done in this
manner to avoid "double counting" releases and waste
management activities at site 2. However, provided
thresholds have been exceeded, if no reports are received
from a covered facility, determinations can be found in
the 2009 Toxic Release Inventory Reporting Forms and
Instructions.
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