EPA 260-R-09-006

October 2009

Toxic Chemical Release

Inventory Reporting Forms

and Instructions

Revised 2009 Version

Section 313

of the Emergency Planning and

Community Right-to-Know Act

(Title III of the Superfund Amendments

and Reauthorization Act of 1986)
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Important Information for Reporting Year 2009

Toxics Release Inventory Reporting Forms and Instructions i

Table of Contents

New Information for Reporting Year 2009 ..............................................................................................v

Other Important Information for RY 2009....................................................................................vi

TRI-ME 2009................................................................................................................................vii

Web Sites and Points of Contact for Assistance .........................................................................viii

A. General Information ....................................................................................................................1

A.1 Who Must Report...........................................................................................................................1

A.2 How to Submit Forms....................................................................................................................1

A.2.a. How to Submit Form R(s) and/or Form A(s) to EPA via the Internet (EPA’s Central

Data Exchange (CDX))..................................................................................................................1

A.2.b How to Submit Paper Form R(s) and/or Form A(s) .......................................................2

A.3 Trade Secret Claims.......................................................................................................................3

A.4 Recordkeeping................................................................................................................................3

A.5 How to Revise or Withdraw TRI Data...........................................................................................4

A.6 When the Report Must Be Submitted.............................................................................................6

A.7 How to Obtain the TRI Reporting Forms.......................................................................................6

B. How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A....7

B.1 Full-Time Employee Determination ..............................................................................................7

B.2 Primary NAICS Code Determination.............................................................................................7

B.2.a. Auxiliary Facilities.......................................................................................................10

B.2.b. Multi-establishment Facilities ......................................................................................10

B.2.c. Property Owners...........................................................................................................11

B.3 Activity Determination.................................................................................................................11

B.3.a. Definitions of Manufacture, Process, and Otherwise Use............................................11

B.3.b. Persistent Bioaccumulative Toxic (PBT) .....................................................................14

B.3.c. Activity Exemptions.....................................................................................................15

B.4 Threshold Determinations............................................................................................................21

B.4.a. How to Determine if Your Facility Has Exceeded Thresholds....................................22

B.4.b. Threshold Determinations for On-Site Reuse Operations............................................23

B.4.c. Threshold Determinations for Ammonia......................................................................24

B.4.d. Threshold Determinations for Chemical Categories ....................................................24

B.4.e Threshold Determination for Persistent Bioaccumulative Toxic (PBT) Chemicals.....25

B.4.f. Mixtures and Other Trade Name Products...................................................................25

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

and Nitrate Compounds................................................................................................................26

C. Instructions for Completing TRI Form R................................................................................32

Part I. Facility Identification Information ...............................................................................................32

Section 1. Reporting Year.........................................................................................................32

Section 2. Trade Secret Information .........................................................................................32

Section 3. Certification .............................................................................................................32

Section 4. Facility Identification...............................................................................................32

Section 5. Parent Company Information...................................................................................34

Part II. Chemical Specific Information ....................................................................................................35

Section 1. EPCRA Section 313 Chemical Identity ...................................................................35

Section 2. Mixture Component Identity...................................................................................36

Section 3. Activities and Uses of the EPCRA Section 313 Chemical at the Facility ..............36

Section 4. Maximum Amount of the EPCRA Section 313 Chemical On-site at Any Time

during the Calendar Year .............................................................................................................38

Section 5. Quantity of the EPCRA Section 313 Chemical Entering Each Environmental

Medium On-site ......................................................................................................39

Section 6. Transfers of the EPCRA Section 313 Chemical in Wastes to Off-Site Locations..46
ii Toxics Release Inventory Reporting Forms and Instructions

Section 7. On-Site Waste Treatment, Energy Recovery, and Recycling Methods...................55

Section 8. Source Reduction and Recycling Activities.............................................................62

D. Instructions for Completing Form R Schedule 1 (Dioxin and Dioxin-like Compounds)...............74

D.1 What is the Form R Schedule 1? ..................................................................................................74

D.2 Who is required to file a Form R Schedule 1? .............................................................................74

D.3 What information is reported on the Form R Schedule 1?...........................................................74

E. Facility Eligibility Determination for Alternate Threshold and for Reporting on EPA Form

A...................................................................................................................................................77

E.1 Alternate Threshold......................................................................................................................77

E.2 What is the Form A Certification Statement? ..............................................................................77

E.3 What Is the Annual Reportable Amount? ....................................................................................77

E.4 Recordkeeping..............................................................................................................................78

E.5 Multi establishment Facilities ......................................................................................................78

E.6 Trade Secrets................................................................................................................................78

E.7 Metals and Metal Category Compounds......................................................................................78

F. Instructions for Completing EPA Form A...............................................................................80

Part I. Facility Identification Information ..............................................................................................80

Section 1. Reporting Year........................................................................................................80

Section 2. Trade Secret Information ........................................................................................80

Section 3. Certification ............................................................................................................80

Section 4. Facility Identification..............................................................................................80

Section 5. Parent Company Information..................................................................................82

Part II. Chemical Identification ................................................................................................................83

Section 1. Toxic Chemical Identity..........................................................................................83

Section 2. Mixture Component Identity...................................................................................84

Index ......................................................................................................................................................85
Important Information for Reporting Year 2009

Toxics Release Inventory Reporting Forms and Instructions iii

Figures

Figure 1. EPCRA Section 313 Reporting Decision Diagram ....................................................................... 9

Figure 2A. EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet ............................ 28

Figure 2B. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100 Pound

Thresholds................................................................................................................................................... 29

Figure 2C. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10 Pound

Thresholds................................................................................................................................................... 30

Figure 2D. EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like Compounds

Chemical Category...................................................................................................................................... 31

Figure 3. Reporting EPCRA Section 313 Chemicals.................................................................................. 38

Figure 4. Hypothetical Section6.2 Completed for Two Off-Site Locations ............................................... 56

Figure 5. Hypothetical Section7A............................................................................................................... 60

Tables

Table I NAICS Codes ........................................................................................................................I-1

Table II EPCRA Section 313 Chemical List (including chemical categories)

for Reporting Year 2009...................................................................................................... II-1

Table III State Abbreviations.............................................................................................................III-1

Table IV Federal Information Processing Standards (FIPS) Codes...................................................IV-1

Appendices

Appendix A Federal Facility Reporting Information ...............................................................................A-1

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

Appendix C Facility Data Profiles and Common Errors in Completing Form R Reports and Form A

Certification Statements..................................................................................................... C-1

Appendix D Supplier Notification Requirements ....................................................................................D-1

Appendix E TRI State Contacts............................................................................................................... E-1

Appendix F TRI Regional Contacts .........................................................................................................F-1

Appendix G Other Relevant Section 313 Materials................................................................................ G-1

Appendix H Guidance Documents...........................................................................................................H-1

Appendix I Questions and Answers Regarding Facility Identification Information.........................I-1
iv Toxics Release Inventory Reporting Forms and Instructions

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Important Information for Reporting Year 2009

Toxics Release Inventory Reporting Forms and Instructions v

New Information for Reporting Year 2009

Please note that this 2009 version of the Toxics Release Inventory (TRI) Reporting Forms and Instructions

document supersedes previous versions of the document.

If you are submitting your Form R and/or Form A via TRI-MEweb, the facility’s registered certifying

official must electronically sign the submission before it can be entered into the TRI database. Uncertified

electronic submissions will not be accepted, will prevent the submission from being processed, and will

result in a Notice of Significant Error (NOSE) if they remain uncertified after the July 1st reporting deadline.

A facility must respond to a Notice of Significant Error within 21 days of receipt. Failure to respond within

the initial 21 day requirement could result in the issuance of a Notice of Noncompliance (NON). A Notice

of Noncompliance is not included in a Facility Data Profile (FDP) and is mailed separately.

This is a reminder that the TRI program is no longer supporting the desktop version of TRI-ME. EPA

will accept only TRI-MEweb or paper submissions for RY 2009. We encourage you to file reports

for RY 2009 using the TRI-MEweb application.

• If you need to revise prior or current year data (RY2005-RY2009), we encourage you to

submit revisions using the TRI-MEweb application. This will give you quicker access to

your facility data profile.

• If you need to revise forms prior to RY2004, EPA will accept revisions on magnetic media

(e.g., CD, 3.5” disks) using the TRI-ME software or on paper forms.

• For states not on the state data exchange, TRI-MEweb allows facilities to generate disk/CD

submissions for their state. However, please note, that submissions generated of such media

type using TRI-MEweb will not be accepted by EPA.

TRI-MEweb will be available to all reporting facilities in RY 2009, including first-time filers. TRI-MEweb

is a web-based version of the popular TRI-Made Easy (TRI-ME) reporting software. Facility Technical

Contacts will be emailed an access key by February, 2010. The facility access key is used to load your

facility data if you have reported in prior years using TRI-ME software. Please note that, if you are using

TRI-MEweb for the first time, certifying officials must register for the application at https://cdx.epa.gov.

This registration requires the printing, completion, and mailing of an electronic signature agreement.

Please allow adequate time for the mailing and processing of this form, which is estimated to take a

minimum of five (5) business days.

TRI-MEweb can be accessed anywhere you have a connection to the Internet. Unlike the PC-based TRI-ME

software, TRI-MEweb requires no downloads or software installs. You no longer have to contact your

“system administrator” to get rights to install the software because it’s on the Web!

TRI-MEweb is similar to its predecessor TRI-ME CD/desktop in that it assists you in preparing your forms,

but TRI-MEweb offers so much more. TRI-MEweb is not only an interactive, intelligent, user-friendly

reporting application; it also provides many new features:

Enhanced Data Quality and Validation

assistance

Quick Lists

Enhanced Section 8 Calculator

Prior Year revision capability

Trend Analysis Reports

Electronic withdrawals/revisions

Third Party Load

Multi-establishment reporting

First-time filer reporting

To learn more about this new solution to TRI reporting, please visit http://www.epa.gov/tri.
vi Toxics Release Inventory Reporting Forms and Instructions

EPA is placing a renewed emphasis on data quality in TRI reports. Specifically, the Agency has found that

many facilities report inaccurate parent companies and/or DUNS numbers in Sections 4 and 5 of the TRI

reporting forms. EPA asks all facilities to verify the accuracy of facility and parent company information

(e.g., Dun and Bradstreet number, parent company name). Some tips for reporting accurate information

follow, and related questions and answers are provided in Appendix I.

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.htm 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

number are an agent 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 of the parent company as of December 31st of the

reporting year.

EPA is also looking at using quick lists to verify the names of publicly owned treatment works

(POTW) and off-site location RCRA ID’s in Form R Part II Section 6.1. B and 6.2. These quick lists

will contain accurate facility location data that is registered and maintained by EPA’s Federal

Registry System.

Other Important Information for RY 2009

Early Data Release of 2009 TRI Reports. EPA has adopted a new strategy to provide the public

with quicker access to the Toxics Release Inventory (TRI) data. The facility locator tool

(http://www.epa.gov/tri-efdr/) provides early access to the individual forms submitted by

regulated facilities. The annual TRI National Analysis (Public Data Release) for RY 2008, which

includes summary data, analyses, and trends, will be released by the spring of 2010.

EPA’s Audit Policy. If you discover your facility is or may have been in violation of Section 313

of EPCRA (TRI Reporting), please refer to EPA’s Policy entitled, “Incentives for Self-Policing:

Discovery, Disclosure, Correction, and Prevention of Violations” (Audit Policy), 65 FR 19618,

April 11, 2000. You may qualify for having all gravity based penalties waived if your facility

meets all nine (9) conditions of the Audit Policy. For more information on EPA’s Audit Policy,

see the Agency’s web site http://www.epa.gov/compliance/incentives/auditing/auditpolicy.html

EPA’s Small Business Compliance Policy. If you have 100 or fewer employees and discover

that your facility is or may have been in violation of Section 313 of EPCRA (TRI Reporting),

please refer to EPA’s Small Business Compliance Policy. EPA will eliminate or significantly

reduce penalties for small businesses that meet the conditions of the Policy, including voluntarily

discovering violations and promptly disclosing and correcting them. This Policy implements

Section 223 of the Small Business Regulatory Enforcement Fairness Act (SBREFA) of 1996. For

more information, see the Agency’s web site

http://www.epa.gov/compliance/incentives/smallbusiness/index.html.
Important Information for Reporting Year 2009

Toxics Release Inventory Reporting Forms and Instructions vii

TRI-MEweb 2009 Application

The TRI-MEweb 2009 application helps facilities in determining and completing their Emergency

Planning and Community Right-to-Know (EPCRA) Section 313 and Pollution Prevention Act (PPA)

Section 6607 obligations. TRI-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 may complete Form A Certification Statement for a particular

chemical. For those facilities required to report, the software provides the user with guidance for each

data element on the reporting forms. Additionally, this web-based application has a one-stop guidance

feature, the TRI Assistance Library that allows users to search the statute, regulations, and many EPCRA

Section 313 guidance documents by key word. For the more experienced reporter, TRI-MEweb allows

direct data entry onto electronic versions of the Form R and Form A Certification Statement. TRI-MEweb

will check the data for common errors and then prepare the forms. All of the information contained in this

RY 2009 Reporting Forms and Instructions book is contained within TRI-MEweb application.

TRI-MEweb allows the user to submit the forms via the Internet through CDX. TRI-MEweb supports

submitting electronically over the Internet using EPA’s CDX without mailing any paper to EPA.

Toxics Release Inventory Assistance Library (TRIAL)

TRIAL is a searchable, indexed file that contains the statutes, the regulations, and most of the key

guidance documents a facility is likely to need for TRI reporting. TRIAL is integrated into TRI-MEweb

help menu.

Can I Use TRI-MEweb if I Have My Own TRI Software?

Yes. Some facilities have their own software or use private commercially-available software to assist in

preparing their TRI reports. This “third party software” will need to be designed to produce XML data

files that match EPA’s XML schema. These file formats can be found on the TRI home page at

http://www.epa.gov/tri. You may load these flat files directly into TRI-MEweb and then use TRI-MEweb

to check your forms for data quality errors. You can then also use TRI-MEweb to submit the forms to U.S.

EPA and your state.
viii Toxics Release Inventory Reporting Forms and Instructions

Web Sites and Points of Contact for Assistance

Technical Support:

For TRI information and contacts for technical support refer to the “Contact Us” page at

http://www.epa.gov/tri/contacts/contacts.htm

Frequently Asked Questions (FAQ) Service:

TRI users can scan frequently asked questions or submit a new question through the TRI Programs’ FAQ

service. Access to the service is available from the “Contact Us” page on the TRI web site:

http://www.epa.gov/tri/contacts/contacts.htm

TRI Reporting Materials:

You can use TRI-MEweb and the TRI Assistance Library to electronically search and read TRI guidance

documents, including this document. The TRI web site contains links and guidance on filling out and

submitting TRI reporting forms: http://www.epa.gov/tri/report/index.htm

TRI Regional Contacts:

EPA Regional Coordinators often work closely with reporting facilities in their area providing training,

outreach, and assistance in completing forms. For a list of TRI Regional Coordinators, see Appendix F.

TRI State Contacts:

EPCRA Section 313 requires facilities to submit reports to both EPA and their state. For a list of statedesignated Section 313 contacts, see Appendix E.

Mailing Addresses Associated with TRI Federal Reporting Requirements:

Please see Section A for specific information on what documents must be sent to the Federal government

when submitting Forms R and A, trade secret submissions, and data revision and withdrawal requests.

The addresses where documentation can be sent are provided below. Additional information is provided

in Section A and Appendix E with respect to separate state reporting requirements.

Forms R and A

When mailing by U.S. Postal Service,

send to:

To send paper forms by certified mail or

overnight mail (i.e. Fed Ex, UPS, etc.), send to:

TRI Reporting Center

P.O. Box 10163

Fairfax, VA 22038

CGI Federal, Inc

c/o EPA Reporting Center

12601 Fair Lakes Circle

Fairfax, VA 22033

Also send a copy of the report to the state in which the facility is located. “State” also includes: the

District of Columbia, the Commonwealth of Puerto Rico, Guam, American Samoa, Marshall

Islands, the U.S. Virgin Islands, the Commonwealth of the Northern Mariana Islands, and any other

jurisdiction and Indian Country. Refer to Appendix E for the appropriate state submission

addresses.

Facilities located on Indian land should send a copy to the Chief Executive Officer of the applicable

Indian tribe. Some tribes have entered into a cooperative agreement with states; in this case, report

submissions should be sent to the entity designated in the cooperative agreement.
Important Information for Reporting Year 2009

Toxics Release Inventory Reporting Forms and Instructions ix

Trade Secret Submissions

When mailing by U.S. Postal Service, send

to:

To send trade secret submissions by certified mail

or overnight mail (i.e. Fed Ex, UPS, etc.), send to:

EPCRA Substantiation Packages

TRI Reporting Center

P.O. Box 10163

Fairfax, VA 22038

Attention: EPCRA Substantiation Packages

CGI Federal, Inc.

c/o EPA Reporting Center

12601 Fair Lakes Circle

Fairfax, VA 22033

703-227-7644

TRI Data Revision Requests

When mailing by U.S. Postal Service, send

to:

To send revision requests by certified mail or

overnight mail (i.e. Fed Ex, UPS, etc.), send to:

Attention: TRI Revision Request

TRI Reporting Center

P.O. Box 10163

Fairfax, VA 22038

Attention: TRI Revision Request

CGI Federal, Inc.

c/o EPA Reporting Center

12601 Fair Lakes Circle

Fairfax, VA 22033

Withdrawal Requests

When mailing by U.S. Postal Service, send

to:

To send revision requests by certified mail or

overnight mail (i.e. Fed Ex, UPS, etc.), send to:

Attention: TRI Withdrawal Request

TRI Reporting Center

P.O. Box 10163

Fairfax, VA 22038

Attention: TRI Withdrawal Request

CGI Federal, Inc.

c/o EPA Reporting Center

12601 Fair Lakes Circle

Fairfax, VA 22033
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United States

Environmental Protection Agency

 FORM R

Section 313 of the Emergency Planning and Community

Right-to-Know Act of 1986, also Known as Title III of the

Superfund Amendments and Reauthorization Act

 WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center 2. APPROPRIATE STATE OFFICE

 P. O. Box 10163 (See instructions in Appendix E)

 Fairfax, VA 22038

IMPORTANT: See instructions to determine when “Not Applicable (NA)” boxes should be checked.

 PART 1. FACILITY IDENTIFICATION INFORMATION

SECTION 1. REPORTING YEAR

SECTION 2. TRADE SECRET INFORMATION

2.1

Are you claiming the toxic chemical identified on page 2 trade secret?

Yes (Answer question 2.2;

 Attach substantiation forms)

No (Do not answer 2.2;

 Go to Section 3)

2.2 Is this copy Sanitized Unsanitized

 (Answer only if “YES” in 2.1)

SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)

I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted information is true and

complete and that the amounts and values in this report are accurate based on reasonable estimates using data available to the preparers of this report.

Name and official title of owner/operator or senior management official: Signature: Date Signed:

SECTION 4. FACILITY IDENTIFICATION

4.1 TRI Facility ID Number

Facility or Establishment Name Facility or Establishment Name or Mailing Address (If different from street address)

Street Mailing Address

City/State/Zip Code Country (Non-US)

4.2 This report contains information for:

(Important: Check a or b; check c or d if applicable) b.

An entire

facility

 Part of a

 facility c. A Federal

facility d. GOCO

4.3 Technical Contact Name Telephone Number (include area code)

4.4

Telephone Number (include area code)

4.5 NAICS Code (s)

(6 digits)

Primary

 a. b. c. d. e. f.

4.6 Dun & Bradstreet

Number (s) (9 digits)

SECTION 5. PARENT COMPANY INFORMATION

5.1

5.2

Name of Parent Company

Parent Company’s Dun & Bradstreet Number

NA

NA

EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.

Email Address

Public Contact Name

City/County/State/Zip Code

TRI Facility ID Number

Toxic Chemical, Category or Generic Name

EPA

Form Approved OMB Number: 2025-0009

 (IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 03/31/2011 Page 1 of 5

a.

 b.

Revision (enter up to two code(s)) Withdrawal (enter up to two code(s))

a.

This section only applies if you are

revising or withdrawing a previously

submitted form, otherwise leave blank.

Email Address

Form Approved OMB Number: 2025-0009

(IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 03/31/2011 Page 2 of 5

FORM R

PART II. TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM

2.1

SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY

(Important: Check all that apply.)

4.1

EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.

TRI Facility ID Number

Toxic Chemical, Category or Generic Name

CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)

1.1

1.2

Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)

1.3

Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked “yes”. Generic Name must be structurally descriptive.)

SECTION 1. TOXIC CHEMICAL IDENTITY (Important: DO NOT complete this section if you completed Section 2 below.)

SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)

Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces and punctuation.)

3.1 Manufacture the toxic chemical: 3.2 Process the toxic chemical: 3.3 Otherwise use the toxic chemical:

a. Produce b. Import

If produce or import

c.

d.

e.

f.

For on-site use/processing

For sale/distribution

As a byproduct

As an impurity

a.

b.

c.

d.

e.

As a reactant

As a formulation component

As an article component

Repackaging

As an impurity

a.

b.

c.

As a chemical processing aid

As a manufacturing aid

Ancillary or other use

SECTION 4. MAXIMUMAMOUNTOFTHETOXIC CHEMICALON SITEATANYTIME DURINGTHE CALENDARYEAR

(Enter two digit code from instruction package.)

SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE

A. Total Release (pounds/year*)

(Enter a range code** or estimate)

B. Basis of Estimate

(enter code)

C. % From Stormwater

5.1 Fugitive or non-point

air emissions

NA

5.2 Stack or point

air emissions

NA

5.3 Discharges to receiving streams or

water bodies (enter one name per box)

Stream or Water Body Name

5.3.1

5.3.2

5.3.3

If additional pages of Part II, Section 5.3 are attached, indicate the total number of pages in this box

and indicate the Part II, Section 5.3 page number in this box. (example: 1,2,3, etc.)

*For Dioxin or Dioxin-like compounds, report in grams/year.

** Range Codes: A= 1-10 pounds; B= 11-499 pounds; C= 500-999 pounds.

FORM R

PART II. CHEMICAL - SPECIFIC INFORMATION (CONTINUED)

EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.

TRI Facility ID Number

Toxic Chemical, Category or Generic Name

Page 3 of 5

SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ON SITE (continued)

NA A. Total Release (pounds/year*) (enter range

code ** or estimate )

B. Basis of Estimate

(enter code)

5.4.1

5.4.2

5.5

5.5.1A

5.5.1B

Underground Injection onsite

to Class I Wells

Underground Injection onsite

to Class II-V Wells

Disposal to land onsite

RCRA Subtitle C landfills

Other landfills

5.5.2

5.5.3A

5.5.4

Land treatment/application

farming

RCRA Subtitle C

surface impoundments

Other disposal

SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS

6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)

6.1.A Total Quantity Transferred to POTWs and Basis of Estimate

6.1.A.1Total Transfers (pounds/year*)

(enter range code ** or estimate)

6.1.A.2 Basis of Estimate

(enter code)

6.1.B POTW Name

POTW Address

City State County Zip

6.1.B POTW Name

City State County Zip

If 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 (example: 1,2,3, etc.)

SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS

6.2. Off-Site EPA Identification Number (RCRAID No.)

Off-Site Location Name

Off-Site Address

City State County Zip

Is location under control of reporting facility or parent company?

Country

(Non-US)

Yes No

* For Dioxin or Dioxin-like compounds, report in grams/year

** Range Codes: A=1-10 pounds: B=1-499 pounds; C=500 - 999 pounds.

5.5.3B Other surface impoundments

POTW Address

Form Approved OMB Number: 2025-0009

(IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 03/31/2011

Page 4 of 5

FORM R

PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)

EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.

TRI Facility ID Number

Toxic Chemical, Category or Generic Name

SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (CONTINUED)

A. Total Transfers (pounds/year*)

(enter range code**or estimate)

B. Basis of Estimate

(enter code)

C. Type of Waste Treatment/Disposal/

Recycling/Energy Recovery (enter code)

1.

2.

3.

4.

1.

2.

3.

4.

1.

2.

3.

4.

M

M

M

M

6.2 Off-Site EPA Identification Number (RCRA ID No.)

Off-Site Location Name

Off-Site Address

City County Zip Country

(Non-US) State

Is location under control of reporting facility or parent company? Yes No

A. Total Transfers (pounds/year*)

(enter range code**or estimate)

B. Basis of Estimate

(enter code)

C. Type of Waste Treatment/Disposal/

Recycling/Energy Recovery (enter code)

1.

2.

3.

4.

1.

2.

3.

4.

1.

2.

3.

4.

M

M

M

M

SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY

Not Applicable (NA) -

Check here if no on-site waste treatment is applied to any

waste stream containing the toxic chemical or chemical category.

a. General

Waste Stream

[enter code]

b. Waste Treatment Method(s) Sequence

[enter 3- or 4- character code(s)]

d. Waste Treatment Efficiency

[enter 2 character code]

7A.1a 7A.1b 1

4

7

2

5

8

3

6

7A.1d

7A.2a 7A.2b

3

6

1

4

7

2

5

8

7A.3a

3

6

1

4

7

2

5

8

7A.4a

7A.3b

7A.4b

3

6

1

4

7

2

5

8

7A.5a 7A.5b

3

6

1

4

7

2

5

8

If additional pages of Part II, Section 6.2/7A are attached, indicate the total number of pages in this box

and indicate the Part II, Section 6.2/7 page number in this box: (example: 1,2,3,etc.)

*For Dioxin or Dioxin-like compounds, report in grams/year

**Range Codes: A=1 - 10 pounds; B=11 - 499 pounds C= 500-999 pounds.

Form Approved OMB Number: 2025-0009

(IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 03/31/2011

7A.2d

7A.3d

7A.4d

7A.5d

FORM R

PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)

EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete. *For Dioxin or Dioxin-like compounds, report in grams/year.

TRI Facility ID Number

Toxic Chemical, Category or Generic Name

Page 5 of 5

SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES

NotApplicable (NA) - Check here if no on-site energy recovery is applied to any waste

stream containing the toxic chemical or chemical category.

Energy Recovery Methods [enter 3-character code(s)]

2 3

SECTION 7C. ON-SITE RECYCLING PROCESSES

NotApplicable (NA) - Check here if no on-site recycling is applied to any waste

stream containing the toxic chemical or chemical category.

Recycling Methods [enter 3-character code(s)]

1

2 3

SECTION 8. SOURCE REDUCTION AND RECYLING ACTIVITIES

Column A

Prior Year

(pounds/year*)

Column B

Current Reporting Year

(pounds/year*)

Column C

Following Year

(pounds/year*)

Column D

Second Following Year

(pounds/year*)

8.1

8.2 Quantity used for energy recovery

onsite

8.3 Quantity used for energy recovery

offsite

8.4 Quantity recycled

onsite

8.5 Quantity recycled offsite

8.6 Quantity treated onsite

8.7 Quantity treated offsite

8.8 Quantity released to the environment as a result of remedial actions, catastrophic events,

or one-time events not associated with production processes (pounds/year)*

8.9 Production ratio or activity index

8.10 Did your facility engage in any source reduction activities for this chemical during the reporting

year? If not, enter “NA” in Section 8.10.1 and answer Section 8.11.

Source Reduction Activities

[enter code(s)]

Methods to Identify Activity (enter codes)

8.10.1 a. b. c.

8.10.2 a. b. c.

8.10.3 a. b. c.

8.10.4 a. b. c.

8.11

Total on-site disposal to Class I

Underground InjectionWells, RCRA

Subtitle C landfills, and other landfills

Total other on-site disposal or other

releases

Total off-site disposal to Class I

Underground Injection Wells, RCRA

Subtitle C landfills, and other landfills

Total other off-site disposal or other

releases

8.1a

8.1b

8.1c

8.1d

1

Form Approved OMB Number: 2025-0009

(IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 03/31/2011

If you wish to submit additional optional information on source reduction, recycling, or pollution

control activities, check “Yes.”

Yes

Form Approved OMB Number: 2025-0010

(IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 03/31/2011 Page 1 of

TOXICS RELEASE INVENTORY

FORM A

WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center 2. APPROPRIATE STATE OFFICE

P. O. Box 10163 (See instruction in Appendix E)

Fairfax, VA 22038

ATTN: TOXIC CHEMICAL RELEASE INVENTORY

IMPORTANT: See instructions to determine when “Not Applicable (NA)” boxes should be checked.

PART 1. FACILITY IDENTIFICATION INFORMATION

SECTION 1. REPORTING YEAR

SECTION 2. TRADE SECRET INFORMATION

2.1 Are you claiming the toxic chemical identified on page 2 trade secret?

Yes (Answer question 2.2;

Attach substantiation forms)

No (Do not answer 2.2;

Go to Section 3)

2.2 Is this copy Sanitized Unsanitized

(Answer only if “YES” in 2.1)

SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)

I hereby certify that to the best of my knowledge and belief, for each toxic chemical listed in the statement, the annual reportable amount as defined in 40 CFR

372.27 (a), did not exceed 500 pounds for this reporting year and that the chemical was manufactured, processed, or otherwise used in an amount not exceeding 1

million pounds during this reporting year.

Name and offical title of owner/operator or senior management official: Signature: Date Signed:

SECTION 4. FACILITY IDENTIFICATION

4.1 TRI Facility ID Number

Facility or Establishment Name Facility or Establishment Name or Mailing Address (If different from street address)

Street Mailing Address

City/State/Zip Code Country (Non-US)

4.2 This report contains information for: (Important: Check c or d if applicable)

c.

A Federal

facility d.

GOCO

4.3 Technical Contact Name Telephone Number (include area code)

4.4

4.5 NAICS Code (s)

(6 digits)

Primary

a. b. c. d. e. f.

4.7

Dun & Bradstreet

Number (s) (9 digits)

SECTION 5. PARENT COMPANY INFORMATION

5.1

5.2

Name of Parent Company

Parent Company’s Dun & Bradstreet Number

NA

NA

EPA Form 9350 -2 (Rev. 10/2009) - Previous editions are obsolete.

Email Address

City/County/State/Zip Code

a.

b.

United States

Environmental Protection Agency

Public Contact Name

Email Address

Telephone Number (include area code)

This section only applies if you are revising

or withdrawing a previously submitted form,

otherwise leave blank.

Revision (enter up to two code(s) Withdrawal (enter up to two code(s)

TRI Facility ID Number

(IMPORTANT: Type or print; read instructions before completing form) Page of

EPA FORM A

PART II. CHEMICAL IDENTIFICATION TRIFID:

EPA Form 9350 -2 (Rev. 10/2009) - Previous editions are obsolete.

CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.) 1.1

1.2 Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)

1.3 Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked “yes”. Generic Name must be structurally descriptive.)

SECTION 1. TOXIC CHEMICAL IDENTITY

Do not use this form for reporting PBT chemicals including Dioxin and Dioxin-like Compounds*

Report of

SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above)

2.1

Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)

SECTION 1. TOXIC CHEMICAL IDENTITY Report of

CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)

1.1

Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.) 1.2

Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked “yes”. Generic Name must be structurally descriptive.)

1.3

SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above)

Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)

SECTION 1. TOXIC CHEMICAL IDENTITY Report of

CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)

1.1

Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)

1.2

SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)

Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)

2.1

2.1

SECTION 1. TOXIC CHEMICAL IDENTITY Report of

CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)

1.1

1.2

Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)

1.3

1.3

Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked “yes”. Generic Name must be structurally descriptive.)

Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked “yes”. Generic Name must be structurally descriptive.)

SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)

2.1 Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)

*See the TRI Reporting Forms and Instructions Manual for the list of PBT Chemicals (including Dioxin and Dioxin-like Compounds)

(Make additional copies of this page, if needed)

EPA Form 9350-3

(IMPORTANT: Type or print; read instructions before completing form)

Form Approved OMB Number: 2025-0007

Approval Expires 04/30/2010 Page 1 of 4

TRI Facility ID Number FORM R Schedule 1

United States

Environmental Protection

Agency PART II. CHEMICAL-SPECIFIC IN FORMATION (continued)

SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE

5.1 NA 5.2 NA 5.3 Discharges to receiving streams or water bodies

(enter data for one stream or water body per box)

Fugitive or nonpoint air emissionsStack or point

air emissions

5.3.1 5.3.2 5.3.3

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16 D. Mass (grams) of Each C

o

m

p

ound in the cate

g

ory (1-17)

17

If additional pages of Section 5.3 are attached, indicate the total number of pages in this box

and indicate the Section 5.3 page number in this box (example: 1,2,3, etc.)

EPA Form 9350-3

(IMPORTANT: Type or print; read instructions before completing form)

Form Approved OMB Number: 2025-0007

Approval Expires 04/30/2010 Page 2 of 4

TRI Facility ID Number FORM R Schedule 1

PART II. CHEMICAL-SPECIFIC IN FORMATION (continued)

SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE

Underground Injection 5.5 Disposal to land onsite

5.4.1 NA 5.4.2 NA 5.5.1.A NA 5.5.1.B NA 5.5.2 NA 5.5.3A NA 5.5.3B NA 5.5.4 NA

Underground

Injection onsite

to Class I Wells

Underground

Injection onsite

to Class II-V

Wells

RCRA Subtitle C

landfills

Other landfills Land treatment/

application farming

RCRA Subtitle C

surface

impoundments

Other surface

impoundments

Other disposal

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

C. Mass (grams) of Each C

o

m

p

ound in the cate

g

ory (1-17)

17

EPA Form 9350-3

(IMPORTANT: Type or print; read instructions before completing form)

Form Approved OMB Number: 2025-0007

Approval Expires:04/30/2010 Page 3 of 4

TRI Facility ID Number

FORM R Schedule 1

PART II. CHEMICAL-SPECIFIC INFORMATION (continued)

SECTION 6. TRANSFERS OF DIOXIN AND DIOXIN-LIKE COMPOUNDS IN WASTES TO OFF-SITE LOCATIONS

6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)

6.1.A.3 Mass (grams) of Each Compound in the Category (1-17)

1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 16 17

6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS

6.2.___ D. Mass (grams) of Each Compound in the Category (1-17)

1. 1 2

3 45 6 7 8

9

10 11 12 13 14 15 16 17

2. 1 2

3 45 6 7 8

9

10 11 12 13 14 15 16 17

3. 1 2

3 45 6 7 8

9

10 11 12 13 14 15 16 17

4. 1 2

3 45 6 7 8

9

10 11 12 13 14 15 16 17

6.2.___ D. Mass (grams) of Each Compound in the Category (1-17)

1. 1 2

3 45 6 7 8

9

10 11 12 13 14 15 16 17

2. 1 2

3 45 6 7 8

9

10 11 12 13 14 15 16 17

3. 1 2

3 45 6 7 8

9

10 11 12 13 14 15 16 17

4. 1 2

3 45 6 7 8

9

10 11 12 13 14 15 16 17

If additional pages of Section 5.3 are attached, indicate the total number of pages in this box

and indicate the Section 5.3 page number in this box (example: 1,2,3, etc.)

EPA Form 9350-3

(IMPORTANT: Type or print; read instructions before completing form)

Form Approved OMB Number: 2025-0007

Approval Expires:04/30/2010 Page 4 of 4

TRI Facility ID Number FORM R Schedule 1

PART II. CHEMICAL-SPECIFIC INFORMATION (continued)

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

8.1a 8.1b 8.1c 8.1d 8.2 8.3 8.4 8.5 8.6 8.7 8.8

Total onsite

disposal to

Class 1

Underground

Injection

Wells,

RCRA Subtitle

C landfills, and

other landfills

Total other

onsite disposal

or other

releases

Total offsite

disposal to

Class 1

Underground

Injection

Wells,

RCRA Subtitle

C landfills, and

other landfills

Total other

offsite disposal

or other

releases

Quantity used

for energy

recovery

onsite

Quantity used

for energy

recovery

offsite

Quantity

recycled

onsite

Quantity

recycled

offsite

Quantity

treated

onsite

Quantity

treated

offsite

Quantity released

to the environment

as a result of

remedial actions,

catastrophic

events, or onetime events not

associated with

production

processes

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

Column f. Mass (grams) of Each Compound in the cate

g

ory (1-17)

17

General Information

Toxics Release Inventory Reporting Forms and Instructions 1

A. General Information

Reporting to the Toxic Chemical Release

Inventory (i.e., Toxics Release Inventory (TRI)) is

required by Section 313 of the Emergency

Planning and Community Right to Know Act

(EPCRA, or Title III of the Superfund

Amendments and Reauthorization Act of 1986),

Public Law 99 499. The information contained in

the Form R constitutes a “report,” and the

submission of a report to the appropriate

authorities constitutes “reporting.”

The Pollution Prevention Act, passed into law in

October, 1990 (Pub. L. 101 508), added reporting

requirements to Form R. These requirements

affect all facilities required to submit Form R

under Section 313 of EPCRA. The data were

required beginning with reports for calendar year

1991.

Reporting is required to provide the public with

information on the releases and other waste

management of EPCRA Section 313 chemicals in

their communities and to provide EPA with

release and other waste management information

to assist the Agency in determining the need for

future regulations. Facilities must report the

quantities of routine and accidental releases, and

releases resulting from catastrophic or other one

time events of EPCRA Section 313 chemicals, as

well as the maximum amount of the EPCRA

Section 313 chemical on-site during the calendar

year and the amount contained in wastes managed

on-site or transferred off-site.

A completed Form R or Form A must be

submitted for each EPCRA Section 313 chemical

manufactured, processed, or otherwise used at

each covered facility as described in the reporting

rules in 40 CFR Part 372 (originally published

February 16, 1988, in the Federal Register and

November 30, 1994, in the Federal Register (for

Form A)).

A.1 Who Must Report

Section 313 of EPCRA requires that reports be

filed by owners and operators of facilities that

meet all of the following criteria.

The facility has 10 or more full-time employee

equivalents (i.e., a total of 20,000 hours or

greater; see 40 CFR 372.3); and

The facility is included in a North American

Industry Classification System (NAICS) code

listed 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.

Section6921 et seq.), 5169, 5171, and 7389

(limited to facilities primarily engaged in

solvents recovery services on a contract or fee

basis); and

The facility manufactures (defined to include

importing), processes, or otherwise uses any

EPCRA Section 313 chemical in quantities

greater than the established threshold in the

course of a calendar year.

Executive Order 13423 extends these reporting

requirements to federal facilities, regardless of

their SIC or NAICS code.

A.2 How to Submit Forms

Starting this reporting year, facilities can only use

TRI-MEweb or paper for submitting Form R(s)

and/or Form A(s).

A.2.a. How to Submit Form R(s)

and/or Form A(s) Electronically

to EPA via the Central Data

Exchange (Using the TRIMEweb Application)

The preferred method to report to TRI is by the

use of the TRI-Made Easy web (TRI-MEweb)

application via EPA’s Central Data Exchange

(CDX). TRI-MEweb is an intelligent, web-based

version of the popular TRI-ME software. There are

several advantages to using TRI-MEweb. They are
2 Toxics Release Inventory Reporting Forms and Instructions

as follows: your prior year data will be prepopulated, electronic signature that allows for

paperless filing, higher data quality and instant

confirmation that EPA has received your

submission. Facilities will be able to submit

reports electronically via TRI-MEweb and submit

their forms through the Internet via CDX. CDX

allows facilities to file a paperless report,

significantly reducing data errors, and receive

instant receipt confirmation of their submission.

Facilities that use TRI-MEweb to submit through

the Internet via CDX, and reside in a state

participating in the TRI State Data Exchange, will

have their forms sent simultaneously to EPA and

their respective state officials via the

Environmental Information Exchange Network.

Once a TRI submission is certified, it will be

electronically forwarded to state officials and your

obligation to report to EPA and your state will be

satisfied.

EPA encourages you to use TRI-MEweb to submit

your TRI submission(s). TRI-MEweb allows you

to submit a completely paperless report to EPA

(Internet submissions are not available for trade

secret claims). If you choose to submit via the

Internet, do not send duplicate paper copies of the

reports to the data processing center. Please be

aware that if your facility does not reside in a state

participating in the TRI State Data Exchange,

submitting via the Internet does not satisfy your

state reporting requirements for your facility. You

must report to your state separately and in the

required format specified by your state.

Former TRI-ME desktop/CD filers that have

submitted their reports through CDX in prior

reporting years, will need to “edit your current

account profile” in their My CDX account to add

the new TRI-MEweb application into their CDX

account. In addition, any active registered

certifying official within TRI-ME desktop/CD will

also need to add TRI-MEweb into their CDX

account profile and list all TRIFIDs assigned to

the certifying official into their profile. All

assigned TRIFIDs will be listed in an electronic

signature agreement (ESA) document that will

need to be printed, signed and sent by mail to

EPA’s Data Processing Center for approval.

ESA’s typically require five (5) business days to

be processed and approved. ESA’s for TRIMEweb are only required once for new certifiers

and for former TRI-ME desktop/CD active

certifying officials. ESA’s needs to be approved

by EPA before a certifying official can proceed to

finalize the certification of a facility’s Form R or

A submission and fulfill their EPCRA Section 313

reporting requirements.

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(s)

It is EPA’s ultimate goal to move away from

processing paper submissions and receive all TRI

submissions via CDX. Although EPA strongly

discourages paper submissions due to increased

possibility of errors, paper submissions are

currently still accepted. Paper submissions must be

sent to both EPA and the state (or the designated

official of an Indian tribe). If a report is not

received by both EPA and the state (or the

designated official of an Indian tribe), the

submitter is considered out of compliance and

subject to enforcement action. Facilities

submitting paper forms must use the current

reporting year forms; out-of-date forms will

considered out of compliance. Send paper forms

by regular mail to:

TRI Reporting Center

P.O. Box 10163

Fairfax, VA 22038

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

Also send a copy of the report to the state in which

the facility is located. “State” also includes: the

District of Columbia, the Commonwealth of

Puerto Rico, Guam, American Samoa, Marshall

Islands, the U.S. Virgin Islands, the

Commonwealth of the Northern Mariana Islands,

and any other jurisdiction and Indian Country.

Refer to Appendix E for the appropriate state

submission addresses.

Facilities located on Indian land should send a

copy to the Chief Executive Officer of the

applicable Indian tribe. Some tribes have entered

into a cooperative agreement with states; in this

case, report submissions should be sent to the

entity designated in the cooperative agreement.
General Information

Toxics Release Inventory Reporting Forms and Instructions 3

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/report/index.htm#forms.

One set of reports, the unsanitized version, must

provide the actual identity of the EPCRA Section

313 chemical. The other set of reports, i.e., the

“sanitized” version, must provide a generic class

or category for the chemical that is structurally

descriptive of the EPCRA Section 313 chemical. If

EPA deems the trade secret substantiation form

valid, only the sanitized set of forms will be made

available to the public.

Use the order form in this document to obtain

copies of the rule and substantiation form. Further

explanation of the trade secret provisions is

provided in Part I, Sections 2.1 and 2.2, and Part

II, Section 1.3, of the instructions.

In summary, a complete report to EPA for an

EPCRA Section 313 chemical claimed as a trade

secret must include all of the following:

A completed unsanitized version of Form R or

Form A report including the EPCRA Section

313 chemical identity (staple the pages

together); and

A sanitized version of a completed Form R or

Form A report in which the EPCRA Section

313 chemical identity items (Part II, Sections

1.1 and 1.2) have been left blank but in which

a generic chemical name that is structurally

descriptive has been supplied (Part II, Section

1.3) (staple the pages together); and

A completed unsanitized version of a trade

secret substantiation form (staple the pages

together); and

A sanitized version of a completed trade secret

substantiation form (staple the pages together).

Securely fasten all four reports together.

Some states also require submission of both

sanitized and unsanitized reports for EPCRA

Section 313 chemicals whose identity is claimed

as a trade secret. Others require only a sanitized

version. Facilities may jeopardize the trade secret

status of an EPCRA Section 313 chemical by

submitting an unsanitized version of the EPCRA

Section 313 report to a state agency or Indian tribe

that does not require unsanitized forms. You may

identify an individual state’s submission

requirements by contacting the appropriate state

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 22038

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 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
4 Toxics Release Inventory Reporting Forms and Instructions

records for accuracy and completeness. EPA

recommends that facilities keep a record for those

EPCRA Section 313 chemicals for which they did

not file EPCRA Section 313 reports.

A partial list of records, organized by year, that a

facility should maintain include:

Previous years’ EPCRA Section 313 reports;

EPCRA Section 313 Reporting Threshold

Worksheets;

Engineering calculations and other notes;

Purchase records from suppliers;

Inventory data;

EPA (NPDES) permits and monitoring

reports;

EPCRA Section312 Tier II Reports;

Monitoring records;

Flowmeter data;

RCRA Hazardous Waste Generator’s Report;

Pretreatment reports filed by the facility with

the local government;

Invoices from waste management companies;

Manufacturer’s estimates of treatment

efficiencies;

RCRA manifests;

Process diagrams that indicate emissions and

other releases; and

Records for those EPCRA Section 313

chemicals for which they did not file EPCRA

Section 313 reports.

A.5 How to Revise or Withdraw TRI

Data

EPA has received several questions relating to

withdrawing and revising TRI data submitted by

facilities, such as:

What are the reasons for revising?

How do I revise my submission?

To whom should this request be sent?

Submitting a Request to Revise TRI Data

Facilities that filed a Form R and/or Form A

Certification Statement under EPCRA Section 313

may submit a request to revise a form that was

previously submitted, stored in the Toxics Release

Inventory Processing System (TRIPS), and made

available to the public through Envirofacts and

TRI Explorer. Facilities may request a revision for

one or more of the following reasons:

RR1 - New Monitoring Data

RR2 - New Emission Factor(s)

RR3 - New Chemical Concentration Data

RR4 - Recalculation(s)

RR5 - Other Reason(s)

The revision code(s) should be entered in the

“Revision” box on the first page of the reporting

form. You may enter up to two revision codes on

the form.

Please note that late submissions for chemicals not

reported in a previous reporting year are not

considered revisions for that year.

How do I revise my submission(s)?

If you have determined that your facility wishes to

revise a TRI submission, you must send your

revised report to EPA and the appropriate state

agency. For submitting a revision to EPA, please

use one of the following methods:

EPA will accept revisions for Reporting

Year 2005 through current year via TRIMEweb and paper.

EPA will accept all revisions prior to

Reporting Year 2004 and beyond on

magnetic media created using TRI-ME

software or paper.

1. TRI-MEweb. The preferred method for revising

TRI forms from Reporting Year 2005 through the

current year is to use TRI-MEweb. For more

information regarding access to TRI-MEweb,

please visit http://www.epa.gov/tri. TRI-MEweb

provides several advantages compared to hardcopy reporting, such as pre-populating the form

with the previous year’s data, allowing reporters to

electronically sign and submit the form over the

Internet, providing automated data quality checks,

and electronically confirming EPA’s receipt of a

submitted form. If you have questions about

accessing TRI-MEweb, please refer to the TRI-ME

web page at

http://www.epa.gov/tri/report/software/index.htm#

usetrime

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
General Information

Toxics Release Inventory Reporting Forms and Instructions 5

or revisions for Reporting Year 2004 and beyond

by using either 1) a photocopy of the original or 2)

a blank form.

Photocopy of Original Submission. You may

submit a photocopy of your original

submission (from your file) with the

corrections made in blue ink. Please re-sign

and re-date the certification statement on Page

1. For RY 2007 revisions and beyond, please

enter the appropriate revision code(s). For RY

2006 and prior years, please enter an “X” in

the space marked “Enter ‘X’ here if this is a

revision,” on Page 1 of the form.

Blank Form. Hard copy submissions may be

submitted using the form applicable for that

particular reporting year or the most recent

form available. You can request prior year

reporting forms at tridocs@epa.gov. For RY

2007 revisions and beyond, please enter 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.

Send revision requests by regular mail to the

following address:

Attention: TRI Revision Request

TRI Reporting Center

P.O. Box 10163

Farifax, VA 22038

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

Submitting a Request to Withdraw TRI Data

Facilities that filed a Form R and/or Form A

Certification Statement under EPCRA Section 313

may submit a request to withdraw a form that was

previously submitted, stored in the Toxics Release

Inventory Processing System (TRIPS), and made

available to the public through Envirofacts and

TRI Explorer. EPA may periodically review

withdrawals. Facilities may request a withdrawal

for one or several reasons, such as:

WT1 - Did not meet the reporting threshold

for manufacturing, processing, or otherwise

use

WT2 - Did not meet the reporting threshold

for number of employees

WT3 - Not in a covered NAICS Code

WO1 - Other reason(s)

The withdrawal code(s) should be entered in the

“Withdrawal” box on the first page of the

reporting form. You may enter up to two

withdrawal codes on the form.

How do I withdraw my submission(s)?

If you have determined that your facility wishes to

withdraw a TRI submission, you must send your

request to EPA and the appropriate state agency.

For submitting a withdrawal to EPA, please use

one of the following methods:

1. TRI-MEweb. The preferred method for

requesting a withdrawal of a previously submitted

TRI form from Reporting Year 2005 through the

current year is TRI-MEweb. For more information

regarding access to TRI-MEweb, please visit

http://www.epa.gov/tri/report/software/index.htm#

usetrime

2. TRI-ME via CDX. For the RY 2002 through

2004 versions of the software, withdrawals may be

submitted electronically using the TRI-ME

software and submitting the report via CDX and

the Internet. You can download the TRI-ME

software at http://www.epa.gov/tri

3. Hard Copy Form. All other withdrawal

requests may be submitted by hard copy as

follows:

Reporting Year 2007 Forward. You may

submit a photocopy of your original

submission (from your file). Using blue ink,

re-sign and re-date the certification statement

on Page 1 and enter the appropriate

withdrawal code(s) in the space provided on

Page 1 of the form.

Reporting Year 2006 and Prior Years. Please

submit a photocopy of the form you wish to
6 Toxics Release Inventory Reporting Forms and Instructions

withdraw (from your file), and attach – as a

cover page – Page 1 of the current year’s

reporting form, which includes a field for the

withdrawal codes. Using blue ink, please sign

and date the certification statement and enter

all information including the appropriate

withdrawal code(s) in the space provided on

Page 1 of the current year’s form.

Send withdrawal requests by regular mail to the

following address:

Attention: TRI Withdrawal Request

TRI Reporting Center

P.O. Box 10163

Fairfax, VA 22038

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.6 When the Report Must Be

Submitted

As specified in EPCRA Section 313, the report for

any calendar year must be submitted on or before

July 1 of the following year whether using Form R

or Form A. If the reporting deadline falls on a

Saturday or Sunday, EPA will accept the forms

which are postmarked on the following Monday

(i.e., the next business day). If you submit using

TRI-MEweb via the Central Data Exchange

(CDX), you will receive your Facility Data Profile

(FDP) in an expedited fashion. Any voluntary

revision to a report can be submitted anytime

during the calendar year for the current or any

previous reporting year. However, voluntary

revisions for the current reporting year should be

submitted by July 31 in order to be included in that

year’s TRI National Analysis. Always remember

to review your FDP. The FDP presents the

information you have submitted to EPA. If the

Technical Contact provided an email address in

the Form R/Form A, they will receive an email

notifying them when their FDP has been updated

and posted to the FDP website. You can retrieve

your FDPs at http://www.triefdp.org. If you have

questions regarding your FDP, please send an email to tri.efdp@epacdx.net or call 703-227-7644.

A.7 How to Obtain the TRI

Reporting Forms

Copies of both forms are included in the first part

of this document. The forms and related guidance

documents may also be obtained from EPA’s TRI

web site: http://www.epa.gov/tri
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

Toxics Release Inventory Reporting Forms and Instructions 7

B. How to Determine if Your

Facility Must Submit a

Form R or Is Eligible to

Use Form A

This section will help you determine whether you

must submit an EPCRA Section 313 report (EPA

Form R or Form A Certification Statement). This

section discusses EPCRA Section 313 reporting

requirements such as the number of full-time

employees, primary NAICS code, and chemical

activity threshold quantities. The EPCRA Section

313 chemicals and chemical categories subject to

reporting are listed in Table II (also see 40 CFR

372.65). (See Figure 1 for more information.)

B.1 Full-Time Employee

Determination

The number of full-time employees is dependent

only upon the total number of hours worked by all

employees and other individuals (e.g., contractors)

for the facility during the calendar year and not the

number of persons working. Therefore, a full-time

employee, for purposes of EPCRA Section 313

reporting, is defined as 2,000 work hours per year.

When making the full-time employee

determination, the facility must consider all paid

vacation and sick leave used as hours worked by

each employee. In addition, EPA interprets the

hours worked by an employee to include paid

holidays. To determine the number of full-time

employees working for your facility, add up the

hours worked by all employees during the

calendar year, including contract employees and

sales and support staff working for the facility, and

divide the total by 2,000 hours. The result is the

number of full-time employees. In other words, if

the total number of hours worked by all employees

for your facility is 20,000 hours or more, your

facility meets the ten employee threshold.

Examples:

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).

Beginning with Reporting Year 2008, facilities

should use 2007 NAICS codes. EPA published a

final rule on June 9, 2008 to incorporate 2007

Office of Management and Budget (OMB)

revisions and other corrections to the NAICS

codes used for TRI Reporting. [Federal Register

(FR) notice 73 FR 32466.] With this rule, facilities

are required to use 2007 NAICS codes on TRI

reporting forms that are due on July 1, 2009,

covering releases and other waste management

quantities at the facility for 2008.

The full list of NAICS codes for facilities that

must report to TRI (including exceptions and/or
8 Toxics Release Inventory Reporting Forms and Instructions

limitations) if all other threshold determinations

are met can be found in Table I and also at the TRI

web site at

http://www.epa.gov/tri/lawsandregs/naic/ncodes.ht

m.

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 referring to the extensive

OMB crosswalk tables found on the Census

Bureau website: http://www.census.gov. State

agencies and other organizations may assign

NAICS codes on a different basis than the one

used by the SIC Manual. However, for purposes of

EPCRA Section 313 reporting, these state

assigned codes should not be used if they differ

from ones assigned using the NAICS Manual.

The TRI Information Center can assist facilities

with determining which NAICS codes are

assigned for specific business activities as

referenced in the NAICS Manual. Clothbound

editions of the NAICS Manual are available in

most major libraries or may be ordered through the

National Technical Information Service, 5285 Port

Royal Road, Springfield, VA 22161, 703-605

6000. The access number for the hardbound

manual is PB2002-101430, $49.00+ shipping and

handling. The access number for the CD-ROM

version with search and retrieval software is

PB2002-502024, $60 + shipping and handling.

Paperwork Reduction Act Notice: The annual public burden related to the Form R, which is

approved under OMB Control No. 2070-0093, is estimated to average 29.6 hours per response

for non-PBT chemicals and 51.3 hours per response for PBT chemicals. The annual public

burden related to the Form A, which is approved under OMB Control No. 2070-0143, is

estimated to average 20.5 hours per response for a facility filing on one non-PBT chemical, and

35.89 hours per response for a facility filing on one PBT 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.
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

Toxics Release Inventory Reporting Forms and Instructions 9

Figure 1. EPCRA Section 313 Reporting Decision Diagram

Is your facility’s primary NAICS Code

included on the EPCRA Section 313

list? Or is your facility a Federal facility?

(see B.2 and Table 1)

Does your facility manufacture, process, or

otherwise use EPCRA Section 313

chemicals and chemical categories?

(see Table II, B.3-B.5, and D.1-D.7)

Does your facility exceed any of the

thresholds for a chemical or chemical

category (after excluding quantities that

are exempt from threshold calculations)

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 lbs/year?

FORM R IS REQUIRED FOR THIS

CHEMICAL OR CHEMICAL

CATEGORY (FORM A CANNOT BE

SUBMITTED)

FORM A OR FORM R IS REQUIRED

FOR THIS CHEMICAL CATEGORY

STOP

NO EPCRA SECTION

313 REPORTS

REQUIRED FOR ANY

CHEMICALS

NO

NO

NO

NO

NO

NO

YES

YES

YES

YES

YES

YES

YES

Does your facility have 10 or more fulltime employees or the equivalent?

(see definition under B.1)

AN EPCRA SECTION 313 REPORT

IS REQURED FOR THE CHEMICAL OR

CHEMICAL CATEGORY

Is this chemical or chemical category identified

as Persistent, Bioaccumulative, and Toxic

(PBT)?
10 Toxics Release Inventory Reporting Forms and Instructions

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 multiestablishment facility is a facility that consists of

two or more distinct and separate economic units.

If your facility is a multi-establishment facility,

calculate the value added of the products

produced, shipped, or services provided from each

establishment within the facility and then use the

following rule to determine if your facility meets

the NAICS code criterion:

If the total value added of the products

produced, shipped, or services provided at

establishments with covered NAICS codes is

greater than 50 percent of the value added of

the entire facility’s products and services, the

entire facility meets the NAICS code criterion.

If any one establishment with a covered

NAICS code has a value added of services or

products shipped or produced that is greater

than any other establishment within the

facility (40 CFR 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 =

$1,500/unit - $500/unit = $1,000/unit.) The

value added ($1,000/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, must report all

relevant information about releases and other

waste management activities, and source reduction

activities associated with an EPCRA Section 313

chemical for the entire facility, even from
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

Toxics Release Inventory Reporting Forms and Instructions 11

establishments that are not in covered NAICS

codes. EPA realizes, however, that certain

establishments in a multi-establishment facility

can be, for all practical purposes, separate and

distinct business units. Therefore, while threshold

determinations must be made for the entire

facility, individual establishments which compose

the entire facility may report their individual

releases and other waste management activities

separately. However, the total releases and other

waste management quantities for the entire facility

must be represented by the sum of the releases and

other quantities managed as waste reported by

each of the separate establishments.

B.2.c. Property Owners

You are not required to report if you merely own

real estate on which a facility covered by this rule

is located; that is, you have no other business

interest in the operation of that facility (e.g., your

company owns an industrial park). The operator of

that facility, however, is subject to reporting

requirements.

B.3 Activity Determination

B.3.a. Definitions of Manufacture,

Process, and Otherwise Use

Manufacture: The term “manufacture” means to

produce, prepare, compound, or import an EPCRA

Section 313 chemical. (See Part II, Section 3.1 of

these instructions for further clarification.)

Import is defined as causing the EPCRA Section

313 chemical to be imported into the customs

territory of the United States. If you order an

EPCRA Section 313 chemical (or a mixture

containing the chemical) from a foreign supplier,

then you have imported the chemical when that

shipment arrives at your facility directly from a

source outside of the United States. By ordering

the chemical, you have caused it to be imported,

even though you may have used an import

brokerage firm as an agent to obtain the EPCRA

Section 313 chemical.

Do Not Overlook Coincidental Manufacture

The term “manufacture” also includes

coincidental production of an EPCRA Section 313

chemical (e.g., as a byproduct or impurity) as a

result of the manufacture, processing, otherwise

use or disposal of another chemical or mixture of

chemicals. In the case of coincidental production

of an impurity (i.e., an EPCRA Section 313

chemical that remains in the product that is

distributed in commerce), the de minimis

exemption, discussed in Section B.3.c of these

instructions, applies. The de minimis exemption

does not apply to byproducts (e.g., an EPCRA

Section 313 chemical that is separated from a

process stream and further processed or disposed).

Certain EPCRA Section 313 chemicals may be

manufactured as a result of wastewater treatment

or other treatment processes. For example,

neutralization of wastewater containing nitric acid

can result in the coincidental manufacture of a

nitrate compound (solution), reportable as a

member of the nitrate compounds category.

Process: The term “process” means the

preparation of a listed EPCRA Section 313

chemical, after its manufacture, for distribution in

commerce. Processing is usually the incorporation

of an EPCRA Section 313 chemical into a product

(see Part II, Section 3.2 of these instructions for

further clarification). However, a facility may

process an impurity that already exists in a raw

material by distributing that impurity in

commerce. Processing includes preparation of the

EPCRA Section 313 chemicals in the same

physical state or chemical form as that received by

your facility, or preparation that produces a change

in physical state or chemical form. The term also

applies to the processing of a mixture or other

trade name product (see Section B.4.b of these

instructions) that contains a listed EPCRA Section

313 chemical as one component.

Otherwise Use: The term “otherwise use” means

any use of an EPCRA Section 313 chemical,

including an EPCRA Section 313 chemical

contained in a mixture or other trade name product

or waste, that is not covered by the terms

manufacture or process. Otherwise use of an

EPCRA Section 313 chemical does not include

disposal, stabilization (without subsequent

distribution in commerce), or treatment for

destruction unless:

(1) The EPCRA Section 313 chemical that was

disposed, stabilized, or treated for destruction was

received from off-site for the purposes of further

waste management;

Or
12 Toxics Release Inventory Reporting Forms and Instructions

(2) The EPCRA Section 313 chemical that was

disposed, stabilized, or treated for destruction was

manufactured as a result of waste management

activities on materials received from off-site for

the purposes of waste management activities.

Relabeling or redistributing of the EPCRA Section

313 chemical where no repackaging of the

EPCRA Section 313 chemical occurs does not

constitute an otherwise use or processing of the

EPCRA Section 313 chemical. (See 62 FR 23846

and Part II, Section 3.3 of these instructions for

further clarification).

Example 1: Coincidental Manufacture

Your company, a nitric acid manufacturer, uses aqueous ammonia in a waste treatment system

to neutralize an acidic wastewater stream containing nitric acid. The reaction of ammonia and

nitric acid produces a solution of ammonium nitrate. Ammonium nitrate (solution) is reportable

under the nitrate compounds category and is manufactured as a byproduct. If the ammonium

nitrate is produced in a quantity that exceeds the 25,000-pound manufacturing threshold, the

facility must report under the nitrate compounds category.

The aqueous ammonia is considered to be otherwise used and 10 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).

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.
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

Toxics Release Inventory Reporting Forms and Instructions 13

Example 2: Typical Process and Manufacture Activities

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.

Your facility combines toluene purchased from a supplier with various materials to form paint

which it then sells. Your facility processes toluene.

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.

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.

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 (CuCl2) 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

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.

A covered facility receives a waste containing 12,000 pounds of Chemical A, a non-PBT

EPCRA Section 313 chemical, from off-site. The facility treats the waste, destroying Chemical

A and in the treatment process manufactures 10,500 pounds of Chemical B, another non-PBT

EPCRA Section 313 chemical. Chemical B is disposed on-site. Since the waste containing

Chemical A was received from off-site for the purpose of waste management, the amount of

Chemical A must be included in the otherwise use threshold determination for Chemical A. The

otherwise use threshold for a non-PBT chemical is 10,000 pounds and since the amount of

Chemical A exceeds this threshold, all releases and other waste management activities for

Chemical A must be reported. Chemical B was manufactured in the treatment of a waste

received from off-site. The facility disposed of Chemical B on-site. Since Chemical B was

generated from waste received from off-site for treatment for destruction, disposal, or

stabilization, the disposal of Chemical B is considered to be an otherwise use. Thus, the amount

of Chemical B must be considered in the otherwise use threshold determination. Thus, the

reporting threshold for Chemical B has also been exceeded and all releases and other waste
14 Toxics Release Inventory Reporting Forms and Instructions

management activities for Chemical B must be reported.

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

IIc of these instructions. The dioxin and dioxinlike compounds category has the qualifier,

“Manufacturing; and the processing or otherwise

use of dioxin and dioxin-like compounds if the

dioxin and dioxin-like compounds are present as

contaminants in a chemical and if they were

created during the manufacturing of that

chemical.”

EPA has added six individual chemicals to the

EPCRA Section 313 list of toxic chemicals that

also had their thresholds lowered:

benzo(g,h,i)perylene, benzo(j,k)fluorene

(fluoranthene), 3-methylcholanthrene,

octachlorostyrene, pentachlorobenzene, and

tetrabromobisphenol A (TBBPA).

Benzo(j,k)fluorene and 3-methylcholanthrene

were added as members of the polycyclic aromatic

compounds (PACs) chemical category.

EPA lowered the reporting thresholds for PBT

chemicals to either 100 pounds, 10 pounds, or in

the case of the dioxin and dioxin-like compounds

chemical category, to 0.1 grams. The table at the

beginning of Section B.4 of these instructions lists

the applicable manufacture, process, and otherwise

use thresholds for the listed PBT chemicals.

EPA eliminated the de minimis exemption for all

PBT chemicals (except lead when contained in

stainless steel, brass or bronze alloy). However,

this action does not affect the applicability of the

de minimis exemption to the supplier notification

requirements (40 CFR Section 372.45(d)(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

Beginning January 1, 2001, lead and lead

compounds are classified as PBT chemicals and

are subject to the lower manufacturing, processing

and otherwise use threshold of 100 pounds.

However, when lead is contained in stainless steel,

brass, or bronze alloys it remains subject to the

higher 25,000 pound manufacturing and

processing thresholds and the 10,000 pound

otherwise use threshold. Listed below are some

important guidelines to use when calculating
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

Toxics Release Inventory Reporting Forms and Instructions 15

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 though they may be eligible

for Form A using the PBT eligibility criteria. If a

facility that exceeds the 25,000/10,000 pound

threshold for lead in stainless steel, brass, or

bronze alloy without tripping the 100-pound

threshold for non-alloyed lead, the facility may

consider the Form A requirements for non-PBTs,

range reporting in Sections 5 and 6 of the Form R,

and the use of whole numbers and 2 significant

digits.

B.3.c. Activity Exemptions

Otherwise Use Exemptions. Certain otherwise

uses of listed EPCRA Section 313 chemicals are

specifically exempted:

Otherwise use as a structural component of the

facility;

Otherwise use in routine janitorial or facility

grounds maintenance;

Personal uses by employees or other persons;

Otherwise use of products containing EPCRA

Section 313 chemicals for the purpose of

maintaining motor vehicles operated by the

facility; and

Otherwise use of EPCRA Section 313

chemicals contained in intake water (used for

processing or non contact cooling) or in intake

air (used either as compressed air or for

combustion).

The exemption of an EPCRA Section 313

chemical otherwise used 1) as a structural

component of the facility; or 2) in routine

janitorial or facility grounds maintenance; or 3) for

personal use by an employee cannot be taken for

activities involving process related equipment.

Articles Exemption. EPCRA Section 313

chemicals contained in articles that are processed

or otherwise used at a covered facility are exempt

from threshold determinations and release and

other waste management calculations. The

exemption applies when the facility receives the

article from another facility or when the facility

produces the article itself. The exemption applies

only to the quantity of EPCRA Section 313

chemical present in the article. If the EPCRA

Section 313 chemical is manufactured (including

imported), processed, or otherwise used at the

covered facility other than as part of the article, in

excess of an applicable threshold quantity, the

facility is required to report that use of a chemical

(40 CFR Section372.38(b)). For an EPCRA

Section 313 chemical in an item to be exempt as

part of the article, the item must meet all the

following criteria in the EPCRA Section 313

article definition; that is, it must be a

manufactured item (1) which is formed to a

specific shape or design during manufacture, (2)

which has end use functions dependent in whole or

in part upon its shape or design during end use,

and (3) which does not release a toxic chemical

under normal conditions of processing or use of

the item at the facility.

If the processing or otherwise use of all like items

results in a total release of 0.5 pound or less of an

EPCRA Section 313 chemical in a reporting year

to any environmental medium, EPA will allow this

release to be rounded to zero, and the

manufactured items retain their article status. The

0.5 pound threshold does not apply to each

individual article, but applies to the sum of all

releases from processing or otherwise use of all

like articles. If all the releases of like articles over
16 Toxics Release Inventory Reporting Forms and Instructions

a reporting year are completely captured and

recycled/reused on-site or off-site, those items

retain their article status. Any amount that is

released and is not recycled/reused will count

toward the 0.5 pound per year cut off value.

The articles exemption applies to the normal

processing or 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 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.

Example 4: Articles Exemption

Nickel that is incorporated into a brass doorknob is processed to manufacture the brass

doorknob, and therefore must be counted toward threshold determinations and release and other

waste management calculations. However, the use of the brass doorknobs elsewhere in the

facility does not have to be counted. Disposal of the brass doorknob after its use does not

constitute a “release;” thus, the brass doorknob remains an article.

If an item used in the facility is fragmented, the item is still an article if those fragments being

discarded remain identifiable as the article (e.g., recognizable pieces of a cylinder, pieces of

wire). For instance, an eight-foot piece of wire is cut into two four-foot pieces of wire, without

releasing any EPCRA Section 313 chemicals. Each four-foot piece is identifiable as a piece of

wire; therefore, the article status for these pieces of wire remains intact.

EPCRA Section 313 chemicals received in the form of pellets are not articles because the pellet

form is simply a convenient form for further processing of the material.

De Minimis Exemption. The de minimis

exemption allows facilities to disregard certain

minimal concentrations of non-PBT chemicals

in mixtures or other trade name products when

making threshold determinations and release and

other waste management calculations. The de

minimis exemption does not apply to the

manufacture of an EPCRA Section 313 chemical

except if that EPCRA Section 313 chemical is

manufactured as an impurity and remains in the

product distributed in commerce, or if the

EPCRA Section 313 chemical is imported below

the appropriate de minimis level. The de minimis

exemption does not apply to a byproduct

manufactured coincidentally as a result of

manufacturing, processing, otherwise use, or any

waste management activities. The de minimis

exemption does not apply to any PBT chemical

(except lead when it is contained in stainless

steel, brass or bronze alloy) or PBT chemical

category. A list of PBT chemicals may be found

in Section B.4 of these instructions.
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

Toxics Release Inventory Reporting Forms and Instructions 17

When determining whether the de minimis

exemption applies to an EPCRA Section 313

chemical, the owner/operator must consider the

concentration of the non-PBT EPCRA Section

313 chemical in mixtures and other trade name

products. If the non-PBT EPCRA Section 313

chemical in a mixture or other trade name

product is manufactured as an impurity,

imported, processed, or otherwise used and is

below the appropriate de minimis concentration

level, then the quantity of the non-PBT EPCRA

Section 313 chemical in that mixture or other

trade name product does not have to be applied

to threshold determinations nor included in

release or other waste management

determinations. If a non-PBT EPCRA Section

313 chemical in a mixture or other trade name

product is below the appropriate de minimis

level, all releases and other waste management

activities associated with the EPCRA Section

313 chemical in that mixture or other trade name

product are exempt from EPCRA Section 313

reporting. It is possible to meet an activity (e.g.,

processing) threshold for an EPCRA Section

313 chemical on a facility wide basis, but not be

required to calculate releases or other waste

management quantities associated with a

particular process because that process involves

only mixtures or other trade name products

containing the non-PBT EPCRA Section 313

chemical below the de minimis level.

EPA interprets the de minimis exemption such

that once a non-PBT EPCRA Section 313

chemical concentration is at or above the

appropriate de minimis level in the mixture or

other trade name product threshold

determinations and release and other waste

management calculations must be made, even if

that chemical later falls below the de minimis

level in the same mixture or other trade name

product. Thus, EPA considers reportable all

releases and other quantities managed as waste

that occur after the de minimis level has been

met or exceeded. If an EPCRA Section 313

chemical in a mixture or other trade name

product at or above de minimis is brought onsite, 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.
18 Toxics Release Inventory Reporting Forms and Instructions

Example 5: De Minimis Applications to Process and Otherwise Use Scenarios for Non-PBT

Chemicals

There are many cases in which the de minimis “limit” is crossed or recrossed by non-PBT chemicals

within a process or otherwise use scenario. The following examples are meant to illustrate these complex

reporting scenarios.

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

Chemicals

A manufacturing facility receives toluene that contains chlorobenzene at a concentration below its de

minimis limit. Through distillation, the chlorobenzene content in process streams is increased over the de

minimis concentration of 1 percent. From the point at which the chlorobenzene concentration equals 1

percent in process streams, the amount present must be factored into threshold determinations and release

and other waste management estimates. The facility does not need to consider the amount of

chlorobenzene in the raw material when below de minimis levels, i.e., prior to distillation to 1 percent,

when making threshold determinations. The facility does not have to report emissions of chlorobenzene

from storage tanks or any other equipment associated with that specific process where the chlorobenzene

content is less than 1 percent.

Fluctuating Concentration During Processing for Non-PBT Chemicals

A manufacturer produces an ink product that contains toluene, an EPCRA Section 313 chemical, below

the de minimis level. The process used causes the percentage of toluene in the mixture to fluctuate: it rises

above the de minimis level for a time but drops below the level as the process winds down. The facility

must consider the chemical toward threshold determinations from the point at which it first equals the de

minimis limit. Once the de minimis limit has been met the exemption cannot be taken.

De Minimis Application to the Processing or

Otherwise Use of a Mixture

The de minimis exemption applies to the

processing or otherwise use of a non-PBT

EPCRA Section 313 chemical in a mixture.

Threshold determinations and release and other

waste management calculations begin at the

point where the chemical meets or exceeds the

de minimis level. If a non-PBT EPCRA Section

313 chemical is present in a mixture at a

concentration below the de minimis level, this

quantity of the substance does not have to be

included for threshold determinations, release

and other waste management reporting, or

supplier notification requirements. The

exemption will apply as long as the mixture

containing de minimis amounts of a non-PBT

EPCRA Section 313 chemical never equals or

goes above the de minimis limit.

Concentration Ranges Straddling the De

Minimis Value

There may be instances in which the

concentration of a non-PBT chemical is given as

a range straddling the de minimis limit. Example

6 illustrates how the de minimis exemption

should be applied in such a scenario.

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

Toxics Release Inventory Reporting Forms and Instructions 19

amount remaining in the product is exempt from

threshold determinations. If the chemical is

separated from the final product, it cannot

qualify for the exemption. Any amount that is

separated, or is separate, from the product, is

considered a byproduct and is subject to

threshold determinations and release and other

waste management calculations. Any amount of

an EPCRA Section 313 chemical that is

manufactured in a waste stream must be

considered toward threshold determinations and

release and other waste management

calculations and accounted for on Form R even

if that chemical is manufactured below the de

minimis level.

Example 6: Concentration Ranges Straddling the De Minimis Value

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) (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)

x pounds x23,400

2

1.25% 1.00%

1.25% 0.25%

8,000,000 1.25% 0.99%

Therefore, the amount of manganese that is subject to threshold determination and release and other waste

management estimates is:

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

In this scenario, because the facility’s information pertaining to manganese was available to two decimal

places, 0.99 was used to determine the amount below the de minimis concentrations. If the information

was available to one decimal place, 0.9 should be used, as in the scenario below.

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) (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:

x pounds x26,400

2

1.2% 1.0%

1.2% 0.2%

8,000,000 1.2% 0.9%

= 26,400 pounds manganese (which is above the processing threshold for manganese)
20 Toxics Release Inventory Reporting Forms and Instructions

Example 7: De Minimis Application in the Manufacture of a Toxic Chemical in a Mixture

Manufacture as a Product Impurity

Toluene 2,4 diisocyanate reacts with trace amounts of water to form trace quantities of 2,4-

diaminotoluene. The resulting product contains 99 percent toluene 2,4-diisocyanate and 0.05 percent 2,4-

diaminotoluene. The 2,4 diaminotoluene would not be subject to EPCRA Section 313 reporting nor

would supplier notification be required because the concentration of 2,4- diaminotoluene is below its de

minimis limit of 0.1 percent in the product.

Manufacture as a Commercial Byproduct and Impurity

Chloroform is a reaction byproduct in the production of carbon tetrachloride. It is removed by distillation

to a concentration of less than 150 ppm (0.0150 percent) remaining in the carbon tetrachloride. The

separated chloroform at 90 percent concentration is sold as a byproduct. Chloroform is subject to a 0.1

percent (1000 ppm) de minimis limit. Any amount of chloroform manufactured and separated as

byproduct must be included in threshold determinations because EPA does not interpret the de minimis

exemption to apply to the manufacture of a chemical as a byproduct. Releases of chloroform prior to and

during purification of the carbon tetrachloride must be reported. The de minimis exemption can, however,

be applied to the chloroform remaining in the carbon tetrachloride as an impurity. Because the

concentration of chloroform remaining in the carbon tetrachloride is below the de minimis limit, this

quantity of chloroform is exempt from threshold determinations, release and other waste management

reporting, and supplier notification.

Manufacture as a Waste Byproduct

A small amount of formaldehyde is manufactured as a reaction byproduct during the production of

phthalic anhydride. The formaldehyde is separated from the phthalic anhydride as a waste gas and burned,

leaving no formaldehyde in the phthalic anhydride. The amount of formaldehyde produced and removed

must be included in threshold determinations and release and other waste management estimates even if

the formaldehyde were present below the de minimis level in the process stream where it was

manufactured or in the waste stream to which it was separated because EPA does not interpret mixtures

and trade name products to includes wastes.

The de minimis exemption also does not apply to

situations where a toxic chemical in waste is

diluted to below the de minimis level.

Laboratory Activities Exemption. EPCRA

Section 313 chemicals that are manufactured,

processed, or otherwise used in a laboratory at a

covered facility under the direct supervision of a

technically qualified individual do not have to be

considered for threshold determinations and

release and other waste management calculations.

However, pilot plant scale and specialty chemical

production does not qualify for this laboratory

activities exemption, nor does the use of EPCRA

Section 313 chemicals for laboratory support

activities, such as the use of chemicals for

equipment maintenance.

Coal Extraction Activities Exemption. If an

EPCRA Section 313 chemical is manufactured,

processed, or otherwise used in extraction by

facilities in NAICS codes 212111, 212112 and

212113, a person is not required to consider the

quantity of the EPCRA Section 313 chemical so

manufactured, processed, or otherwise used when

considering threshold determinations and release

and other waste management calculations (see

Example 8). Reclamation activities occurring

simultaneously with coal extraction activities (e.g.,

cast blasting) are included in the exemption.

However, otherwise use of ash, waste rock, or

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

Toxics Release Inventory Reporting Forms and Instructions 21

threshold determinations and release and other

waste management calculations.

Metal Mining Overburden Exemption. If an

EPCRA Section 313 chemical that is a constituent

of overburden is processed or otherwise used by

facilities in NAICS codes 212221, 212222,

212231, 212234, and 212299, a person is not

required to consider the quantity of the EPCRA

Section 313 chemical so processed or otherwise

used when considering threshold determinations

and release and other waste management

calculations.

For purposes of EPCRA Section 313 reporting,

overburden is the unconsolidated material that

overlies a deposit of useful material or ore. It does

not include any portion of the ore or waste rock.

Example 8: Coal mining extraction activities

Included among these are explosives for

blasting operations, solvents, lubricants, and

fuels for extraction related equipment

maintenance and use, as well as overburden

and mineral deposits. The EPCRA Section 313

chemicals contained in these materials are

exempt from threshold determinations and

release and other waste management

calculations, when manufactured, processed or

otherwise used during extraction activities at

coal mines.

B.4 Threshold Determinations

EPCRA Section 313 reporting is required if

threshold quantities are exceeded. Separate

thresholds apply to the amount of the EPCRA

Section 313 chemical that is manufactured,

processed or otherwise used.

You must submit a report for any EPCRA Section

313 chemical that is not listed as a PBT chemical

and which is manufactured or processed at your

facility in excess of the following threshold:

25,000 pounds per toxic chemical or category

over the calendar year.

You must submit a report for any EPCRA

Section 313 chemical which is not listed as a

PBT chemical 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 IIc of these instructions for lists of

individual members of the dioxin and dioxin-like

compounds chemical category and the polycyclic

aromatic compounds chemical category.
22 Toxics Release Inventory Reporting Forms and Instructions

Chemical or chemical

category name

CAS

number or

chemical

category

code

Threshold

(pounds,

unless

noted

otherwise)

Aldrin 309-00-2 100

Benzo[g,h,i]perylene 191-24-2 10

Chlordane 57-74-9 10

Dioxin and dioxin-like

compounds category

(manufacturing; and

the processing or

otherwise use of dioxin

and dioxin-like

compounds category if

the dioxin and dioxinlike compounds are

present as

contaminants in a

chemical and if they

were created during

the manufacturing of

that chemical

N150 0.1 gram

Heptachlor 76-44-8 10

Hexachlorobenzene 118-74-1 10

Isodrin 465-73-6 10

Lead (this lower

threshold does not

apply to lead when it is

contained in stainless

steel, brass or bronze

alloy)

7439-92-1 100

Lead compounds N420 100

Mercury 7439-97-6 10

Mercury compounds N458 10

Methoxychlor 72-43-5 100

Octachlorostyrene 29082-74-4 10

Pendimethalin 40487-42-1 100

Pentachlorobenzene 608-93-5 10

Polychlorinated

biphenyls (PCBs)

1336-36-3 10

Polycyclic aromatic

compounds category

(PACs)

N590 100

Tetrabromobisphenol 79-94-7 100

A

Toxaphene 8001-35-2 10

Trifluralin 1582-09-8 100

B.4.a. How to Determine if Your

Facility Has Exceeded

Thresholds

To determine whether your facility has exceeded

an EPCRA Section 313 reporting threshold,

compare quantities of EPCRA Section 313

chemicals that you manufacture, process, or

otherwise use to the respective thresholds for those

activities. A worksheet is provided in Figure 2A to

assist facilities in determining whether they exceed

any of the reporting thresholds for non-PBT

chemicals; Figures 2B-D provide worksheets for

PBT chemicals. This worksheet also provides a

format for maintaining reporting facility records.

Use of this worksheet is not required and the

completed worksheet(s) should not accompany

Form R reports submitted to EPA and the state.

Complete the appropriate worksheet for each

EPCRA Section 313 chemical or chemical

category. (The worksheets can be found at the end

of section B.4.) Base your threshold determination

for EPCRA Section 313 chemicals with qualifiers

only on the quantity of the EPCRA Section 313

chemical satisfying the qualifier.

Use of the worksheets is divided into three steps:

Step 1 allows you to record the gross amount

of the EPCRA Section 313 chemical or

chemical category involved in activities

throughout the facility. Pure forms as well as

the amounts of the EPCRA Section 313

chemical or chemical category present in

mixtures or other trade name products must be

considered. The types of activity (i.e.,

manufacturing, processing, or otherwise

using) for which the EPCRA Section 313

chemical is used must be identified because

separate thresholds apply to each of these

activities. A record of the information

source(s) used should be kept. Possible

information sources include purchase records,

inventory data, and calculations by a process

engineer. The data collected in Step 1 will be

totaled for each activity to identify the overall

amount of the EPCRA Section 313 chemical

or chemical category manufactured (including

imported), processed, or otherwise used.
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

Toxics Release Inventory Reporting Forms and Instructions 23

Step 2 allows you to identify uses of the

EPCRA Section 313 chemical or chemical

category that were included in Step 1 but are

exempt under EPCRA Section 313. Do not

include in Step 2 exempt quantities of the

EPCRA Section 313 chemical not included in

the calculations in Step 1. For example, if

Freon contained in the building’s air

conditioners was not reported in Step 1, you

would not include the amount as exempt in

Step 2. Step 2 is intended for use when a

quantity or use of the EPCRA Section 313

chemical is exempt while other quantities

require reporting. Note the type of exemption

for future reference. Also identify, if

applicable, the fraction or percentage of the

EPCRA Section 313 chemical present that is

exempt. Add the amounts in each activity to

obtain a subtotal for exempted amounts of the

EPCRA Section 313 chemical or chemical

categories at the facility.

Step 3 involves subtracting the result of Step 2

from the results of Step 1 for each activity.

Compare this net sum to the applicable

activity threshold. If the threshold is exceeded

for any of the three activities, a facility must

submit a Form R for that EPCRA Section 313

chemical or chemical category. Do not sum

quantities of the EPCRA Section 313 chemical

that are manufactured, processed, and

otherwise used at your facility, because each

of these activities requires a separate threshold

determination. For example, if in a calendar

year you processed 20,000 pounds of a nonPBT 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
24 Toxics Release Inventory Reporting Forms and Instructions

purposes of EPCRA Section 313 threshold

determinations.

B.4.c. Threshold Determinations for

Ammonia

The listing for ammonia includes the modifier

“includes anhydrous ammonia and aqueous

ammonia from water dissociable ammonium salts

and other sources; 10 percent of total aqueous

ammonia is reportable under this listing.” The

qualifier for ammonia means that anhydrous forms

of ammonia are 100 percent reportable and

aqueous forms are limited to 10 percent of total

aqueous ammonia. Therefore, when determining

threshold quantities, 100 percent of anhydrous

ammonia is included but only 10 percent of total

aqueous ammonia is included. If any ammonia

evaporates from aqueous ammonia solutions, 100

percent of the evaporated ammonia is included in

threshold determinations.

For example, if a facility processes aqueous

ammonia, it has processed 100 percent of the

aqueous ammonia in that solution. If the ammonia

remains in solution, then 10 percent of the total

aqueous ammonia is counted towards the

threshold. If there are any evaporative losses of

anhydrous ammonia, then 100 percent of those

losses must be counted towards the processing

threshold. If the manufacturing, processing, or

otherwise use threshold for the ammonia listing 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 IIc 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 IIa or IIb 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 IIa or IIb).

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

Toxics Release Inventory Reporting Forms and Instructions 25

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 be reported on

the appropriate sections of both Form Rs. See

B.5.)

Nitrate Compounds (water dissociable;

reportable only when in aqueous solution)

For the category nitrate compounds (water

dissociable; reportable only when in aqueous

solution), the entire weight of the nitrate

compound is counted in making threshold

determinations. A nitrate compound is covered by

this listing only when in water and only if

dissociated. If no information is available on the

identity of the type of nitrate that is manufactured,

processed or otherwise used, assume that the

nitrate compound exists as sodium nitrate.

B.4.e Threshold Determination for

Persistent Bioaccumulative

Toxic (PBT) Chemicals

There are two separate thresholds for EPCRA

Section 313 PBT chemicals; these thresholds are

set based on the chemicals’ potential to persist and

bioaccumulate in the environment. The

manufacturing, processing and otherwise use

thresholds for PBT chemicals is 100 pounds, while

for the subset of PBTs chemicals that are highly

persistent and highly bioaccumulative, it is 10

pounds. One exception is the dioxin and dioxinlike 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 IIc of these

instructions for lists of individual members of the

dioxin and dioxin-like compounds chemical

category and the polycyclic aromatic compounds

(PACs) chemical category.

B.4.f. Mixtures and Other Trade

Name Products

EPCRA Section 313 chemicals contained in

mixtures and other trade name products must be

factored into threshold determinations and release

and other waste management calculations.

If your facility processed or otherwise used

mixtures or other trade name products during the

calendar year, you are required to use the best

readily available data (or reasonable estimates if

such data are not readily available) to determine

whether the toxic chemicals in a mixture meet or

exceed the de minimis concentration and,

therefore, whether they must be included in

threshold determinations and release and other

waste management calculations. If you know that

a mixture or other trade name product contains a

specific EPCRA Section 313 chemical, combine

the amount of the EPCRA Section 313 chemical in

the mixture or other trade name product with other

amounts of the same EPCRA Section 313

chemical processed or otherwise used at your

facility for threshold determinations and release

and other waste management calculations. If you

know that a mixture contains an EPCRA Section

313 chemical but it is present below the de

minimis level, you do not have to consider the

amount of the EPCRA Section 313 chemical

present in that mixture for purposes of threshold

determinations and release and other waste

management calculations. PBT chemicals are not

eligible for the de minimis exemption except lead

when it is contained in stainless steel, brass or

bronze alloy.

Observe the following guidelines in estimating

concentrations of EPCRA Section 313 chemicals

in mixtures when only limited information is

available:

If you only know the upper bound

concentration, you must use it for threshold

determinations (40 CFR Section372.30(b)(ii)).

If you know the lower and upper bound

concentrations of an EPCRA Section 313

chemical in a mixture, EPA recommends you

use the midpoint of these two concentrations

for threshold determinations.

If you know only the lower bound

concentration, EPA recommends you subtract

out the percentages of any other known

components to determine a reasonable upper

bound concentration, and then determine a

midpoint.

If you have no information other than the

lower bound concentration, EPA recommends
26 Toxics Release Inventory Reporting Forms and Instructions

you calculate a midpoint assuming an upper

bound concentration of 100 percent.

In cases where you only have a concentration

range available, EPA recommends you use the

midpoint of the range extremes.

B.5 Release and Other Waste

Management Determinations

for Metals, Metal Category

Compounds, and Nitrate

Compounds

Metal Category Compounds

Although the complete weight of the metal

category compounds must be used in threshold

determinations for the metal compounds category,

only the weight of the metal portion of the metal

category compound must be considered for release

and other waste management determinations.

Remember that for metal category compounds that

consist of more than one metal, release and other

waste management reporting must be based on the

weight of each metal, provided that the appropriate

thresholds have been exceeded.

Metals and Metal Category Compounds

For compounds within the metal compound

categories, only the metal portion of the metal

category compound must be considered in

determining release and other waste management

quantities for the metal category compounds.

Therefore, if thresholds are separately exceeded

for both the “parent” metal and its compounds,

EPA allows you to file a combined Form R for the

“parent” metal and its category compounds. This

Form R would contain all of the release and other

waste management information for both the

“parent” metal and metal portion of the related

metal category compounds. For example, you

exceed thresholds for chromium. You also exceed

thresholds for chromium compounds. Instead of

filing two Form Rs you can file one combined

Form R. This Form R would contain information

on quantities of chromium released or otherwise

managed as waste and the quantities of the

chromium portion of the chromium compounds

released or otherwise managed as waste. When

filing one combined Form R for an EPCRA

Section 313 metal and metal compound category,

facilities should identify the chemical reported as

the metal compound category name and code in

Section 1 of the Form R. Note that this does not

apply to the Form A. See the section in these

instructions on the Form A. See Appendix B for

more information about reporting the release and

other waste management of metals and metal

compounds.

Nitrate Compounds (water dissociable;

reportable only in aqueous solution)

Although the complete weight of the nitrate

compound must be used for threshold

determinations for the nitrate compounds category

only the nitrate portion of the compound should be

used for release and other waste management

calculations.
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

Toxics Release Inventory Reporting Forms and Instructions 27

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.

15,000 x 0.90 = 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.




32 Toxics Release Inventory Reporting Forms and Instructions

C. Instructions for

Completing TRI Form R

Part I. Facility Identification

Information

Section 1. Reporting Year

The reporting year is the calendar year to which

the reported information applies, not the year in

which you are submitting the report. Information

for the 2009 reporting year must be submitted on

or before July 1, 2010.

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.

See last year’s Reporting Forms and

Instructions.

2.2 If “yes” in 2.1, is this copy sanitized or

unsanitized?

Answer this question only after you have

completed the rest of the report. Check “sanitized”

if this copy of the report is the public version that

does not contain the EPCRA Section 313 chemical

identity but does contain a generic name that is

structurally descriptive in its place, and if you

have claimed the EPCRA Section 313 chemical

identity trade secret in Part I, Section 2.1.

Otherwise, check “unsanitized.”

Section 3. Certification

The certification statement must be signed by a

senior official with management responsibility for

the person (or persons) completing the form. A

senior management official must certify the

accuracy and completeness of the information

reported on the form by signing and dating the

certification statement. Each report must contain

an original signature. You should print or type the

name and title of the person who signs the

statement in the space provided. This certification

statement applies to all the information supplied

on the form and should be signed only after the

form has been completed.

Section 4. Facility Identification

4.1 Facility Name, Location, and TRI

Facility Identification Number

Enter the full name that the facility presents to the

public and its customers in doing business (e.g.,

the name that appears on invoices, signs, and other

official business documents). Do not use a

nickname for the facility (e.g., Main Street Plant)

unless that is the legal name of the facility under

which it does business. Also enter the street

address, mailing address, city, county, state, and

zip code in the space provided. Do not use a post

office box number as the street address. The street

address provided must be the location where the

EPCRA Section 313 chemicals are manufactured,

processed, or otherwise used. If your mailing

address and street address are the same, you

should enter NA in the space for the mailing

address.

If your facility is not in a county, put the name of

your city, district (for example, District of

Columbia), or parish (if you are in Louisiana) in

the county block of the Form R and Form A as

well as in the county field of TRI-ME OR TRIMEweb. “NA” or “None” are not acceptable

entries.

If you have submitted a Form R or Form A for

previous reporting years, a TRI Facility

Identification Number has been assigned to your

facility. If you know your TRI Facility

Identification Number, you should complete

Section 4. If you do not know your TRI Facility

Identification Number, you should visit the TRI

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

http://www.epa.gov/enviro. If your facility has

moved, do not enter your TRI Facility

Identification Number, enter “New Facility”. If
Instructions for Completing TRI Form R

Toxics Release Inventory Reporting Forms and Instructions 33

you are filing a separate Form R for each

establishment at your facility, you should use the

same TRI Facility Identification Number for each

establishment.

The TRI Facility Identification Number is

established by the first Form R submitted by a

facility at a particular location. Only a change in

address warrants filing as a new facility;

otherwise, the TRI Facility Identification Number

is retained by the facility even if the facility

changes name, ownership, production processes,

SIC or NAICS codes, etc. This identification

number will stay with this location. If a new

facility moves to this location it should use this

TRI Facility Identification Number.

Establishments of a facility that report separately

should use the TRI Facility Identification Number

of the facility.

You should enter “New Facility” in the space for

the TRI Facility Identification number if this is

your first submission.

4.2 Full or Partial Facility Indication

EPCRA Section 313 requires reports by

“facilities,” which are defined as “all buildings,

equipment, structures, and other stationary items

which are located on a single site or on contiguous

or adjacent sites and which are owned or operated

by the same person (or by any person which

controls, is controlled by, or under common

control with such person). A facility may contain

more than one establishment.”

EPCRA Section 313 defines establishment as “an

economic unit, generally at a single physical

location, where business is conducted or where

services or industrial operations are performed.”

Under Section 372.30(c) of the reporting rule, you

may submit a separate Form R for each

establishment, or for groups of establishments in

your facility, provided all releases and other waste

management activities and source reduction

activities involving the EPCRA Section 313

chemical from the entire facility are reported. This

allows you the option of reporting separately on

the activities involving an EPCRA Section 313

chemical at each establishment, or group of

establishments (e.g., part of a covered facility),

rather than submitting a single Form R for that

EPCRA Section 313 chemical for the entire

facility. However, if an establishment or group of

establishments does not manufacture, process, or

otherwise use or release or otherwise manage as

waste an EPCRA Section 313 chemical, you do

not have to submit a report for that establishment

or group of establishments for that particular

chemical. (See also Section B.2.a of these

instructions.)

A covered facility must report all releases and

other waste management activities and source

reduction activities of an EPCRA Section 313

chemical if the facility meets a reporting threshold

for that EPCRA Section 313 chemical. Whether

submitting a report for the entire facility or

separate reports for the establishments, the

threshold determination must be made based on

the entire facility. Indicate in Section 4.2 whether

your report is for the entire covered facility as a

whole or for part of a covered facility (i.e., one or

more establishments).

Federal facilities and contractors at federal

facilities (GOCOs: Government-owned,

contractor-operated facilities) should check either

4.2c or 4.2d, but not both. Federal facilities should

check 4.2c, even if their TRI reports contain

release and other waste management information

from contractors located at the facility.

Contractors at federal facilities, which are required

by EPCRA Section 313 to file TRI reports

independently of the federal facility, should check

4.2d. This information is important to prevent

duplication of federal facility data. (See Appendix

A for further guidance on these instructions.)

4.3 Technical Contact

Enter the name and telephone number (including

area code) of a technical representative whom

EPA or state officials may contact for clarification

of the information reported on Form R. You

should also enter an email address for this person.

EPA encourages facilities to provide an email

address for its Technical Contact on their TRI

submissions because they will be able to receive

important program updates and email alerts

notifying them when their FDP has been updated

and is available on the FDP website. If the

technical contact does not have an email address

you should enter NA. This contact person does not

have to be the same person who prepares the

report or signs the certification statement and does

not necessarily need to be someone at the location

of the reporting facility. However, this person
34 Toxics Release Inventory Reporting Forms and Instructions

should be familiar with the details of the report so

that he or she can answer questions about the

information provided.

4.4 Public Contact

Enter the name and telephone number (including

area code) of a person who can respond to

questions from the public about the form. You

should also enter an e-mail address for this person.

If you choose to designate the same person as both

the Technical and the Public Contact, or you do

not have a Public Contact, you may enter “Same

as Section 4.3” in this space. This contact person

does not have to be the same person who prepares

the form or signs the Certification Statement and

does not necessarily need to be someone at the

location of the reporting facility.

4.5 North American Industry Classification

System (NAICS) Codes

The North American Industry Classification

System (NAICS) is the economic classification

system that replaces the 1987 SIC code system for

TRI Reporting beginning with the RY 2006

EPCRA Section 313 reporting (71 FR 32464).

Enter the appropriate six digit North American

Industry Classification System (NAICS) Code that

is the primary NAICS code for your facility in

Section 4.5(a). For Reporting Year 2008 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 web site:

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, 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 D&B

numbers, enter those numbers in Part I, section

4.6.

Section 5. Parent Company

Information

You must provide information on your parent

company. For purposes of the Form R, a parent

company is defined as the highest level company,

located in the United States, that directly owns at

least 50 percent of the voting stock of your

company. If your facility is owned by a foreign

entity, enter NA in this space. Corporate names

should be treated as parent company names for

companies with multiple facility sites. For

example, the Bestchem Corporation is not owned

or controlled by any other corporation but has sites

throughout the country whose names begin with

Bestchem. In this case, Bestchem Corporation

should be listed as the parent company. Note that a

facility that is a 50:50 joint venture is its own

parent company. When a facility is owned by

more than one company and none of the facility

owners directly owns at least 50 percent of its

voting stock, the facility should provide the name

of the parent company of either the facility

operator or the owner with the largest ownership

interest in the facility. If neither the operator nor

this owner has a parent company, then the NA box

should be checked.

5.1 Name of Parent Company

Enter the name of the corporation or other

business entity that is your ultimate U.S. parent

company. If your facility has no parent company,

you should check the NA box.

5.2 Parent Company’s Dun & Bradstreet

Number

Enter the D&B number for your ultimate U.S.

parent company, if applicable. The number may be

obtained from the treasurer or financial officer of

the company or by calling 1-888-814-1435, or by

visiting this web site:

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.
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 35

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 crossreferenced 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 IIc and Appendix B.

EPCRA Section 313 Chemical Category Codes:

N010 Antimony compounds

N020 Arsenic compounds

N040 Barium compounds

N050 Beryllium compounds

N078 Cadmium compounds

N084 Chlorophenols

N090 Chromium compounds

N096 Cobalt compounds

N100 Copper compounds

N106 Cyanide compounds

N120 Diisocyanates

N150 Dioxin and dioxin-like compounds

N171 Ethylenebisdithiocarbamic acid, salts and

esters (EBDCs)

N230 Certain glycol ethers

N420 Lead compounds

N450 Manganese compounds

N458 Mercury compounds

N495 Nickel compounds

N503 Nicotine and salts

N511 Nitrate compounds (water dissociable,

reportable only in aqueous solution)

N575 Polybrominated biphenyls (PBBs)

N583 Polychlorinated alkanes (C10 to C13)

N590 Polycyclic aromatic compounds (PACs)

N725 Selenium compounds

N740 Silver compounds

N746 Strychnine and salts

N760 Thallium compounds

N770 Vanadium compounds

N874 Warfarin and salts

N982 Zinc compounds

If you are making a trade secret claim, you must

report the CAS number or category code on your

unsanitized Form R and unsanitized substantiation

form. Do not include the CAS number or category

code on your sanitized Form R or sanitized

substantiation form.

1.2 EPCRA Section 313 Chemical or

Chemical Category Name

Enter the name of the EPCRA Section 313

chemical or chemical category exactly as it

appears in Table II. If the EPCRA Section 313

chemical name is followed by a synonym in

parentheses, report the chemical by the name that

directly follows the CAS number (i.e., not the

synonym). If the EPCRA Section 313 chemical

identity is actually a product trade name (e.g.,

Dicofol), the 9th Collective Index name is listed

below it in brackets. You may report either name

in this case.

Do not list the name of a chemical that does not

appear in Table II, such as individual members of

an EPCRA Section 313 chemical category. For

example, if you use silver chloride, do not report

silver chloride with its CAS number. Report this

chemical as “silver compounds” with its category

code, N740.

If you are making a trade secret claim, you must

report the specific EPCRA Section 313 chemical

identity on your unsanitized Form R and

unsanitized substantiation form. Do not report the

name of the EPCRA Section 313 chemical on your
36 Toxics Release Inventory Reporting Forms and Instructions

sanitized Form R or sanitized substantiation form.

Include a generic name that is structurally

descriptive in Part II, Section 1.3 of your sanitized

Form R report.

EPA requests that the EPCRA Section 313

chemical, chemical category, or generic name also

be placed in the box marked “Toxic Chemical,

Category, or Generic Name” in the upper righthand corner on all pages of Form R. While this

space is not a required data element, providing this

information will help you in preparing a complete

Form R report.

1.3 Generic Chemical Name

Complete Section 1.3 only if you are claiming the

specific EPCRA Section 313 chemical identity of

the EPCRA Section 313 chemical as a trade secret

and have marked the trade secret block in Part I,

Section 2.1 on Page 1 of Form R. Enter a generic

chemical name that is descriptive of the chemical

structure. You should limit the generic name to

seventy characters (e.g., numbers, letters, spaces,

punctuation) or less. Do not enter mixture names

in Section 1.3; see Section 2 below.

In-house plant codes and other substitute names

that are not structurally descriptive of the EPCRA

Section 313 chemical identity being withheld as a

trade secret are not acceptable as a generic name.

The generic name must appear on both sanitized

and unsanitized Form Rs, and the name must be

the same as that used on your substantiation forms.

Section 2. Mixture Component

Identity

Do not complete this section if you have

completed Section 1 of Part II. Report the generic

name provided to you by your supplier in this

section if your supplier is claiming the chemical

identity proprietary or trade secret. Do not answer

“yes” in Part I, Section 2.1 on Page 1 of the form

if you complete this section. You do not need to

supply trade secret substantiation forms for this

EPCRA Section 313 chemical because it is your

supplier who is claiming the chemical identity a

trade secret.

Example 10: Mixture Containing

Unidentified EPCRA Section 313

Chemical

Your facility uses 20,000 pounds of a

solvent that your supplier has told you

contains 80 percent “chlorinated aromatic,”

their generic name for a non-PBT EPCRA

Section 313 chemical subject to reporting

under EPCRA Section 313. You, therefore,

have used 16,000 pounds of some EPCRA

Section 313 chemical and that exceeds the

“otherwise use” threshold for a non-PBT

chemical. You would file a Form R and enter

the name “chlorinated aromatic” in the space

provided in Part II, Section 2.

2.1 Generic Chemical Name Provided by

Supplier

Enter the generic chemical name in this section

only if the following three conditions apply:

1.) You determine that the mixture

contains an EPCRA Section 313 chemical but the

only identity you have for that chemical is a

generic name;

2.) You know either the specific

concentration of that EPCRA Section 313

chemical component or a maximum or average

concentration level; and

3.) You multiply the concentration level

by the total annual amount of the whole mixture

processed or otherwise used and determine that

you meet the process or otherwise use threshold

for that single, generically identified mixture

component.

Section 3. Activities and Uses of the

EPCRA Section 313

Chemical at the Facility

Indicate whether the EPCRA Section 313

chemical is manufactured (including imported),

processed, or otherwise used at the facility and the

general nature of such activities and uses at the

facility during the calendar year (see Figure 3).

You are not required to report on Form R the

quantity manufactured, processed or otherwise

used. Report activities that take place only at your

facility, not activities that take place at other

facilities involving your products. You must check

all the boxes in this section that apply. Refer to the
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 37

definitions of “manufacture,” “process,” and

“otherwise use” in the general information section

of these instructions or Part 40, Section 372.3 of

the Code of Federal Regulations for additional

explanations.

3.1 Manufacture the EPCRA Section 313

Chemical

Persons who manufacture (including import) the

EPCRA Section 313 chemical must check at least

one of the following:

a. Produce — The EPCRA Section 313

chemical is produced at the facility.

b. Import — The EPCRA Section 313

chemical is imported by the facility into the

Customs Territory of the United States. (See

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:
38 Toxics Release Inventory Reporting Forms and Instructions

a. As a chemical processing aid — An EPCRA

Section 313 chemical that is added to a

reaction mixture to aid in the manufacture or

synthesis of another chemical substance but

is not intended to remain in or become part of

the product or product mixture is otherwise

used as chemical processing aid. Examples of

such EPCRA Section 313 chemicals include,

but are not limited to, process solvents,

catalysts, inhibitors, initiators, reaction

terminators, and solution buffers.

b. As a manufacturing aid — An EPCRA

Section 313 chemical that aids the

manufacturing process but does not become

part of the resulting product and is not added

to the reaction mixture during the

manufacture or synthesis of another chemical

substance is otherwise used as a

manufacturing aid. Examples include, but are

not limited to, process lubricants,

metalworking fluids, coolants, refrigerants,

and hydraulic fluids.

c. Ancillary or other use — An EPCRA

Section 313 chemical that is used at a facility

for purposes other than aiding chemical

processing or manufacturing as described

above is otherwise used as an ancillary or

other use. Examples include, but are not

limited to, cleaners, degreasers, lubricants,

fuels, EPCRA Section 313 chemicals used

for treating wastes, and EPCRA Section 313

chemicals used to treat water at the facility.

Figure 3. Reporting EPCRA Section 313 Chemicals

Section 4. Maximum Amount of the

EPCRA Section 313

Chemical On-site at Any

Time during the Calendar

Year

For data element 4.1 of Part II, insert the code (see

codes below) that indicates the maximum quantity

of the EPCRA Section 313 chemical (e.g., in storage

tanks, process vessels, on-site shipping containers,

or in wastes generated) at your facility at any time

during the calendar year. If the EPCRA Section 313

chemical was present at several locations within

your facility, use the maximum total amount present

at the entire facility at any one time. While range

reporting is not allowed for PBT chemicals

elsewhere on the Form R, range reporting for PBT

chemicals is allowed for the Maximum Amount Onsite.
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 39

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 alphanaphthylamine, forming N-methyl-alphanaphthylamine 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 3 for how this

information would be reported in Part II,

Section 3 of Form R.

Your facility also processes alphanaphthylamine, as a reactant to produce Nmethyl-alpha-naphthylamine, a chemical not

on the EPCRA Section 313 list.

2. Your facility is a commercial distributor of

Missouri bituminous coal, which contains mercury

at 1.5 ppm (w:w). You should check the box on the

Form R at Part II, Section 3.2.e for processing

mercury as an impurity.

Weight Range in Pounds

Range Code From... To...

01 0 99

02 100 999

03 1,000 9,999

04 10,000 99,999

05 100,000 999,999

06 1,000,000 9,999,999

07 10,000,000 49,999,999

08 50,000,000 99,999,999

09 100,000,000 499,999,999

10 500,000,000 999,999,999

11 1 billion more than 1 billion

If the EPCRA Section 313 chemical present at your

facility was part of a mixture or other trade name

product, determine the maximum quantity of the

EPCRA Section 313 chemical present at the facility

by calculating the weight percent of the EPCRA

Section 313 chemical only.

Do not include the weight of the entire mixture or

other trade name product. These data may be found

in the Tier II form your facility may have prepared

under Section 312 of EPCRA. See Part 40, Section

372.30(b) of the Code of Federal Regulations for

further information on how to calculate the weight

of the EPCRA Section 313 chemical in the mixture

or other trade name product. For EPCRA Section

313 chemical categories (e.g., nickel compounds),

include all chemical compounds in the category

when calculating the maximum amount, using the

entire weight of each compound. When reporting

for dioxin and dioxin-like compounds you should

convert the maximum amount from grams to pounds

before choosing the appropriate range code in

Section 4 of Part II.

Section 5. Quantity of the EPCRA

Section 313 Chemical

Entering Each

Environmental Medium Onsite

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.
40 Toxics Release Inventory Reporting Forms and Instructions

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.

Example 12: Reporting Dioxins and DioxinLike 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
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 41

manifests, or monitoring records) may be useful in

estimating fugitive emissions. You should check the

NA box in Section 5.1 if you do not engage in

activities that result in fugitive or non-point air

emissions of this listed toxic chemical. For VOCs,

NA generally would not be applicable.

5.2 Stack or Point Air Emissions

Report the total of all releases of the EPCRA

Section 313 chemical to the air that occur through

stacks, confined vents, ducts, pipes, or other

confined air streams. You must include storage tank

emissions. Air releases from air pollution control

equipment would generally fall in this category.

Monitoring data, engineering estimates, and mass

balance calculations may help you to complete this

section. You should check the NA box in Section

5.2 if there are no stack air activities involving the

waste stream that contains or contained the EPCRA

Section 313 chemical.

5.3 Discharges to Receiving Streams or

Water Bodies

In Section 5.3 you are to enter all the names of the

streams or water bodies to which your facility

directly discharges the EPCRA Section 313

chemical on which you are reporting. A total of

three spaces is provided on Page 2 of Form R. Enter

the name of each receiving stream or surface water

body to which the EPCRA Section 313 chemical

being reported is directly discharged. Report the

name of the receiving stream or water body as it

appears on the permit for the facility. If the stream is

not included in the NPDES permit or its name is not

identified in the NPDES permit, enter the name of

the off-site stream or water body by which it is

publicly known or enter the first publicly named

water body to which the receiving waters are a

tributary, if the receiving waters are unnamed. Do

not list a series of streams through which the

EPCRA Section 313 chemical flows. Be sure to

include all the receiving streams or water bodies that

receive stormwater runoff from your facility. Do not

enter names of streams to which off-site treatment

plants discharge. You should enter NA in Section

5.3.1 if there are no discharges to receiving streams

or water bodies of the waste stream that contains or

contained the EPCRA Section 313 chemical (See

discussion of NA vs. a Numeric Value (e.g., Zero)

in the introduction of Section 5).

Enter the total annual amount of the EPCRA Section

313 chemical released from all discharge points at

the facility to each receiving stream or water body.

Include process outfalls such as pipes and open

trenches, releases from on-site wastewater treatment

systems, and the contribution from stormwater

runoff, if applicable (see instructions for column C

below). Do not include discharges to a POTW or

other off-site wastewater treatment facilities in this

section. These off-site transfers must be reported in

Part II, Section 6 of Form R. Wastewater analyses

and flowmeter data may provide the quantities you

will need to complete this section.

Discharges of listed acids (e.g., hydrogen fluoride,

nitric acid) may be reported as zero if the discharges

have been neutralized to pH 6 or above. If

wastewater containing a listed acid is discharged

below pH 6, then releases of the acid must be

reported. In this case, pH measurements may be

used to estimate the amount of mineral acid

released.

5.4.1 Underground Injection On-Site to Class I

Wells

Enter the total amount of the EPCRA Section 313

chemical that was injected into Class I wells at the

facility. Chemical analyses, injection rate meters,

and RCRA Hazardous Waste Generator Reports are

good sources for obtaining data that will be useful in

completing this section. You should check the NA

box in Section 5.4.1 if you do not inject the waste

stream that contains or contained the EPCRA

Section 313 chemical into Class I underground

wells (See discussion of NA vs. a Numeric Value

(e.g., Zero) in the introduction of Section 5).

5.4.2 Underground Injection On-site to Class IIV 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).
42 Toxics Release Inventory Reporting Forms and Instructions

5.5 Disposal to Land On-site

Five predefined subcategories for reporting

quantities released to land within the boundaries of

the facility are provided. Do not report land disposal

at off-site locations in this section. Accident

histories and spill records may be useful (e.g.,

release notification reports required under Section

304 of EPCRA, Section 103 of CERCLA, and

accident histories required under

Section112(r)(7)(B)(ii) of the Clean Air Act).

Where relevant, you should check the NA box in

sections 5.5.1A through 5.5.3 if there are no

disposal activities for the waste stream that contains

or contained the EPCRA Section 313 chemical (See

discussion of NA vs. 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.

5.5.1B Other landfills

Enter the total amount of the EPCRA Section 313

chemical that was placed in landfills other than

RCRA Subtitle C landfills. EPA has not required

facilities to estimate leaks from landfills because the

amount of the EPCRA Section 313 chemical has

already been reported as a release.

5.5.2 Land treatment/application farming

Land treatment is a disposal method in which a

waste containing an EPCRA Section 313 chemical

is applied onto or incorporated into soil. While this

disposal method is considered a release to land, any

volatilization of EPCRA Section 313 chemicals into

the air occurring during the disposal operation must

not be included in this section but must be included

in the total fugitive air releases reported in Part II,

Section 5.1 of Form R.

Surface Impoundments

A surface impoundment is a natural topographic

depression, man-made excavation, or diked area

formed primarily of earthen materials (although

some may be lined with man-made materials), that

is designed to hold an accumulation of liquid wastes

or wastes containing free liquids. Examples of

surface impoundments are holding, settling, storage,

and elevation pits; ponds, and lagoons. If the pit,

pond, or lagoon is intended for storage or holding

without discharge, it would be considered to be a

surface impoundment used as a final disposal

method. A facility must determine, to the best of its

ability, the percentage of a volatile chemical, e.g.,

benzene, that is in waste sent to a surface

impoundment that evaporates during the reporting

year. The facility must report this as a fugitive air

emission in section 5.1. The balance should be

reported in either section 5.5.3A or 5.5.3B.

Quantities of the EPCRA Section 313 chemical

released to surface impoundments that are used

merely as part of a wastewater treatment process

generally should not be reported in this section.

However, if an impoundment accumulates sludges

containing the EPCRA Section 313 chemical, you

must include an estimate in this section unless the

sludges are removed and otherwise disposed (in

which case they must be reported under the

appropriate section of the form). For the purposes of

this reporting, storage tanks are not considered to be

a type of disposal and are not to be reported in this

section of Form R.

5.5.3A RCRA Subtitle C Surface Impoundments

Enter the total amount of the EPCRA Section 313

chemical that was placed in RCRA Subtitle C

surface impoundments.

5.5.3B 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).
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 43

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 Range (pounds)

A 1-10

B 11-499

C 500-999

Do not enter a range code and an estimate in the

same box in column A. Total annual on-site releases

of an EPCRA Section 313 chemical from the facility

of less than 1 pound may be reported in one of

several ways. You should round the value to the

nearest pound. If the estimate is greater than 0.5

pound, you should either enter the range code “A“

for “1-10” or enter “1” in column A. If the release is

equal to or less than 0.5 pound, you may round to

zero and enter “0” in column A.

Note that total annual releases of 0.5 pound or less

from the processing or otherwise use of an article

maintain the article status of that item. Thus, if the

only releases you have are from processing an

article, and such releases are equal to or less than

0.5 pound per year, you are not required to submit a

report for that EPCRA Section 313 chemical. The

0.5-pound release determination does not apply to

just a single article. It applies to the cumulative

releases from the processing or otherwise use of the

same type of article (e.g., sheet metal or plastic film)

that occurs over the course of the reporting year.

Releases of 1,000 Pounds or More. For releases to

any medium that amount to 1,000 pounds or more

for the year, you must provide an estimate in pounds

per year in column A. Any estimate provided in

column A need not be reported to more than two

significant figures. This estimate should be in whole

numbers. Do not use decimal points.

Calculating On-Site Releases. To provide the

release information in column A, EPCRA Section

313(g)(2) requires a facility to use readily available

data (including monitoring data) collected pursuant

to other provisions of law, or, where such data are

not readily available, “reasonable estimates” of the

amounts involved. If available data (including

monitoring data) are known to be nonrepresentative, facilities must make reasonable

estimates using the best readily available

information.

Reasonable estimates of the amounts released

should be made using published emission factors,

material balance calculations, or engineering

calculations. You may not use emission factors or

calculations to estimate releases if more accurate

data are available.

No additional monitoring or measurement of the

quantities or concentrations of any EPCRA Section

313 chemical released into the environment, or of

the frequency of such releases, beyond that required

under other provisions of law or regulation or as

part of routine plant operations, is required for the

purpose of completing Form R.

You must estimate the quantity (in pounds) of the

EPCRA Section 313 chemical or chemical category

that is released annually to each environmental

medium on-site. Include only the quantity of the

EPCRA Section 313 chemical in this estimate. If the

EPCRA Section 313 chemical present at your

facility was part of a mixture or other trade name

product, calculate only the releases of the EPCRA

Section 313 chemical, not the other components of

the mixture or other trade name product. If you are

only able to estimate the releases of the mixture or

other trade name product as a whole, you should

assume that the release of the EPCRA Section 313

chemical is proportional to its concentration in the

mixture or other trade name product. See Part 40,

Section372.30(b) of the Code of Federal

Regulations for further information on how to

calculate the concentration and weight of the
44 Toxics Release Inventory Reporting Forms and Instructions

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

exclude any contribution to mass made by the other

portion of the compound.

Section 5 Column B: Basis of Estimate

For each release and otherwise managed waste

estimate (Sections 5 & 6), you are required to

indicate the principal method used to determine the

amount of release and otherwise managed waste

reported. You should enter a letter code identifying

the method that applies to the largest portion of the

total estimated release and otherwise managed waste

quantity.

The codes are as follows:

M1 Estimate is based on continuous monitoring

data or measurements for the EPCRA Section

313 chemical

M2 Estimate is based on periodic or random

monitoring data or measurements for the

EPCRA Section 313 chemical

C Estimate is based on mass balance

calculations, such as calculation of the amount

of the EPCRA Section 313 chemical in

streams entering and leaving process

equipment.

E1 Estimate is based on published emission

factors, such as those relating release quantity

to through-put or equipment type (e.g., air

emission factors).

E2 Estimate is based on-site specific emission

factors, such as those relating release quantity

to through-put or equipment type (e.g., air

emission factors).

O Estimate is based on other approaches such as

engineering calculations (e.g., estimating

volatilization using published mathematical

formulas) or best engineering judgment. This

would include applying an estimated removal

efficiency to a waste stream, even if the

composition of the stream before treatment

was fully identified through monitoring data.

For example, if 40 percent of stack emissions of the

reported EPCRA Section 313 chemical were derived

using source testing data, 30 percent by mass

balance, and 30 percent by published chemicalspecific emission factors, you should enter the code

letter “M2” for periodic or random emission

monitoring.

If the monitoring data, mass balance, or emission

factor used to estimate the release is not specific to

the EPCRA Section 313 chemical being reported,

the form should identify the estimate as based on

other methods of estimation (O).

If a mass balance calculation yields the flow rate of

a waste, but the quantity of reported EPCRA

Section 313 chemical in the waste is based on

solubility data, you should report “O” because

engineering calculations were used as the basis of

estimate of the quantity of the EPCRA Section 313

chemical in the waste.

If the concentration of the EPCRA Section 313

chemical in the waste was measured by continuous

emissions monitoring equipment and the flow rate

of the waste was determined by mass balance, then

the primary basis of the estimate should be

“continuous emission monitoring” (M1). 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.
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 45

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).

If your facility has monitoring data on the EPCRA

Section 313 chemical and an estimate of flow rate,

you must use these data to determine the percent

stormwater.

If you have monitored stormwater but did not detect

the EPCRA Section 313 chemical, enter zero in

column C. If your facility has no stormwater

monitoring data for the chemical, you should enter

NA in this space on the form.

If your facility does not have periodic measurements

of stormwater releases of the EPCRA Section 313

chemical, but has submitted chemical-specific

monitoring data in permit applications, then these

data must be used to calculate the percent

contribution from stormwater. One way to calculate

the flow rates from stormwater runoff is the

Rational Method. In this method, flow rates, Q, can

be estimated by multiplying the land area of the

facility, A, by the runoff coefficient, C, and then

multiplying that figure by the annual rainfall

intensity, I (i.e., Q = A*C*I). The rainfall intensity,

I, is specific to the geographical area of the country

where the facility is located, and may be obtained

from most standard engineering manuals for

hydrology. The flow rate, Q, will have volumetric

dimensions per unit time, and will have to be

converted to units of pounds per year. The runoff

coefficient represents the fraction of rainfall that

does not seep into the ground but runs off as

stormwater. The runoff coefficient is directly related

to how the land in the drainage area is used. (See

table below)

Description of Land Area 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:
46 Toxics Release Inventory Reporting Forms and Instructions

Weighted-average runoff coefficient =

(Area 1 % of total)(C1) + (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.

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

Land Use % Total Area Coefficient

Unimproved area 50 0.20

Asphaltic streets 10 0.85

Concrete pavement 40 0.90

Weighted-average runoff coefficient = [(50%) x (0.20)] + [(10%) x (0.85)] + [(40%) x (0.90)] = 0.545

(Rainfall) x (land area) x (conversion factor) x (runoff coefficient) = stormwater runoff

(1 ft/year) x (1,829,520 ft2) x (7.48 gal/ft3) x (0.545) = 7,458,222 gallons/year

Total stormwater runoff = 7,458,222 gallons/year

Your stormwater monitoring data shows that the average concentration of zinc in the stormwater runoff

from your facility from a biocide containing a zinc compound is 1.4 milligrams per liter. The total

amount of zinc discharged to surface water through the plant wastewater discharge (non-stormwater) is

250 pounds per year. The total amount of zinc discharged with stormwater is:

(7,458,222 gallons stormwater)x(3.785 liters/gallon) = 28,229,370 liters stormwater

(28,229,370 liters stormwater)x(1.4 mg zinc/liter) x 103g/mg x (1/454) lb/g = 87 lb 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)x100% = 26%

Section 6. Transfers of the EPCRA

Section 313 Chemical in

Wastes to Off-Site Locations

You must report in this section the total annual

quantity of the EPCRA Section 313 chemical in

wastes sent to any off-site facility for the purposes

of disposal, treatment, energy recovery, or

recycling. Report the total amount of the EPCRA

Section 313 chemical transferred off-site after any

on-site waste treatment, recycling, or removal is

completed.

For all toxic chemicals (except the dioxin and

dioxin-like compounds category), do not enter the

values in Section 6 in gallons, tons, liters, or any

measure other than pounds. You must also enter the

values as whole numbers. Numbers following a

decimal point are not acceptable for toxic chemicals
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 47

other than those designated as PBT chemicals. For

PBT chemicals, facilities should report release and

other waste management quantities greater than 0.1

pound (except the dioxin and dioxin-like

compounds category) provided the accuracy and the

underlying data on which the estimate is based

supports this level of precision. For the dioxin and

dioxin-like compounds category, facilities should

report at a level of precision supported by the

accuracy of the underlying data and the estimation

techniques on which the estimate is based.

However, the smallest quantity that need be reported

on the Form R for the dioxin and dioxin-like

compounds category is 0.0001 grams (see Example

12). Notwithstanding the numeric precision used

when determining reporting eligibility thresholds,

facilities should report on Form R to the level of

accuracy that their data supports, up to seven digits

to the right of the decimal. EPA’s reporting software

and data management systems support data

precision to seven digits to the right of the decimal.

NA vs. a Numeric Value (e.g., Zero). You must

enter a numeric value if you transfer an EPCRA

Section 313 chemical to a POTW or transfer wastes

containing that toxic chemical to other off-site

locations. If the aggregate amount transferred was

less than 0.5 pound, then you should enter zero

(unless the chemical is listed as a PBT chemical).

Also report zero for transfers of listed mineral acids

(i.e., hydrogen fluoride and nitric acid) if they have

been neutralized to a pH of 6 or above prior to

discharge to a POTW; do not check NA.

However, if you do not discharge wastewater

containing the reported EPCRA Section 313

chemical to a POTW, you should enter NA in the

box for the POTW’s name in Section 6.1.B._ If you

do not ship or transfer wastes containing the

reported EPCRA Section 313 chemical to other offsite locations, you should enter NA in the box for

the off-site location’s EPA Identification Number in

Section 6.2._.

Important: You must number the boxes for

reporting the information for each POTW or other

off-site location in Sections 6.1 and 6.2. In the upper

left hand corner of each box, the section number is

either 6.1.B._. or 6.2._.

If you report a transfer of the listed EPCRA Section

313 chemical to one or more POTWs, you should

number the boxes in Section 6.1.B as 6.1.B.1,

6.1.B.2, etc. If you transfer the EPCRA Section 313

chemical to more than two POTWs, you should

photocopy Page 3 of Form R as many times as

necessary and then number the boxes consecutively

for each POTW. At the bottom of Part II Section 6.1

of the Form R you will find instructions for

indicating the total number of pages numbered “3”

that you are submitting as part of Form R, as well as

indicating the sequence of those pages. For

example, your facility transfers the reported EPCRA

Section 313 chemical in wastewaters to three

POTWs. You would photocopy Page 3 once,

indicate at the bottom of each Page 3 that there are a

total of two pages numbered “3” and then indicate

the first and second Page 3. The boxes for the two

POTWs on the first Page 3 should be numbered

6.1.B.1 and 6.1.B.2, while the box for third POTW

on the second Page 3 should be numbered 6.1.B.3.

If you report a transfer of the EPCRA Section 313

chemical to one or more other off-site locations, you

should number the boxes in section 6.2 as 6.2.1,

6.2.2, etc. If you transfer the EPCRA Section 313

chemical to more than two other off-site locations,

you should photocopy Page 4 of Form R as many

times as necessary and then number the boxes

consecutively for each off-site location. At the

bottom of Page 4 you will find instructions for

indicating the total number of Page 4s that you are

submitting as part of the Form R as well as

indicating the sequence of those pages. For

example, your facility transfers the reported EPCRA

Section 313 chemical to three other off-site

locations. You should photocopy page 4 once,

indicate at the bottom of Section 6.2 on each Page 4

that there are a total of two Page 4s and then

indicate the first and second Page 4. The boxes for

the two off-site locations on the first Page 4 would

be numbered 6.2.1 and 6.2.2, while the box for the

third off-site location on the second Page 4 should

be numbered 6.2.3.

6.1 Discharges to Publicly Owned Treatment

Works

In Section 6.1.A, estimate the quantity of the

reported EPCRA Section 313 chemical transferred

to all POTWs and the basis upon which the estimate

was made. In Section 6.1.B., 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
48 Toxics Release Inventory Reporting Forms and Instructions

transferred via some other direct methods to a

POTW.

If you do not discharge wastewater containing the

reported EPCRA Section 313 chemical to a POTW,

enter NA in the box for the POTW’s name in

Section 6.1.B._ (See discussion of NA vs. a

Numeric Value (e.g., Zero) in the introduction of

Section 6).

6.1.A.1 Total Transfers

Enter the total amount, in pounds, of the reported

EPCRA Section 313 chemical that is contained in

the wastewaters transferred to all POTWs. Do not

enter the total poundage of the wastewaters. If the

total amount transferred is less than 1,000 pounds,

you may report a range by entering the appropriate

range code (range reporting in section 6.1.A.1 does

not apply to PBT chemicals). The following

reporting range codes are to be used:

Code Reporting Range (in pounds)

A 1-10

B 11-499

C 500-999

6.1.A.2 Basis of Estimate

You must identify the basis for your estimate of the

total quantity of the reported EPCRA Section 313

chemical in the wastewater transferred to all

POTWs. You should enter one of the following

letter codes that applies to the method by which the

largest percentage of the estimate was derived.

M1 Estimate is based on continuous monitoring

data or measurements for the EPCRA Section

313 chemical.

M2 Estimate is based on periodic or random

monitoring data or measurements for the

EPCRA Section 313 chemical.

C Estimate is based on mass balance

calculations, such as calculation of the amount

of the EPCRA Section 313 chemical in

streams entering and leaving process

equipment.

E1 Estimate is based on published emission

factors, such as those relating release quantity

to through-put or equipment type (e.g., air

emission factors).

E2 Estimate is based on-site specific emission

factors, such as those relating release quantity

to through-put or equipment type (e.g., air

emission factors).

O Estimate is based on other approaches such as

engineering calculations (e.g., estimating

volatilization using published mathematical

formulas) or best engineering judgment. This

would include applying an estimated removal

efficiency to a waste stream, even if the

composition of the stream before treatment

was fully identified through monitoring data.

If you transfer an EPCRA Section 313 chemical to

more than one POTW, you should report the basis

of estimate that was used to determine the largest

percentage of the EPCRA Section 313 chemical that

was transferred.

6.2 Transfers to Other Off-Site Locations

In Section 6.2 enter the EPA Identification Number,

name, and address for each off-site location to

which your facility ships or transfers wastes

containing the reported EPCRA Section 313

chemical for the purposes of disposal, treatment,

energy recovery, or recycling. Also estimate the

quantity of the reported EPCRA Section 313

chemical transferred and the basis upon which the

estimate was made. This would include any residual

chemicals in “empty” containers transferred off-site.

EPA expects that all containers (bags, totes, drums,

tank trucks, etc.) will have a small amount of

residual solids and/or liquids. Please see Example

14 for residue quantities left in drums and tanks

when emptied.

If appropriate, you must report multiple activities

for each off-site location. For example, if your

facility sends a reported EPCRA Section 313

chemical in a single waste stream to an off-site

location where some of the EPCRA Section 313

chemical is to be recycled while the remainder of

the quantity transferred is to be treated, you must

report both the waste treatment and recycle

activities, along with the quantity associated with

each activity.

If your facility transfers an EPCRA Section 313

chemical to an off-site location and that off-site

location performs more than four activities on that

chemical, provide the necessary information in Box

6.2.1 for the off-site facility and the first four

activities. Provide the information on the remainder

of the activities in Box 6.2.2 and provide again the

off-site facility identification and location

information.
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 49

If you do not ship or transfer wastes containing the

EPCRA Section 313 chemical to other off-site

locations, you should enter NA (See discussion of

NA vs. a Numeric Value (e.g., Zero) in the

introduction of Section 6) in the box for the off-site

location’s EPA Identification Number (defined in 40

CFR 260.10 and therefore commonly referred to as

the RCRA ID Number). This number may be found

on the Uniform Hazardous Waste Manifest, which is

required by RCRA regulations. If you ship or

transfer wastes containing an EPCRA Section 313

chemical and the off-site location does not have an

EPA Identification Number (e.g., it does not accept

RCRA hazardous wastes) enter NA in the box for

the off-site location EPA Identification Number. If

you ship or transfer hazardous wastes containing an

EPCRA Section 313 chemical to a facility that

treats, stores, or disposes RCRA hazardous wastes,

make sure to include that facility’s RCRA

Identification Number in the box for the off-site

location EPA Identification Number. This RCRA ID

is shown on the RCRA manifest that must

accompany the hazardous waste to the off-site

facility.

If you ship or transfer the reported EPCRA Section

313 chemical in wastes to another country, you do

not need to report a RCRA ID for that waste. You

should indicate NA in the RCRA ID field. Enter the

complete address of the non-U.S. facility in the offsite address fields, the city in the city field, the nonU.S. state or province in the county field, the postal

code in the zip code field, and the foreign country

code in the country field. The most commonly used

FIPs codes are listed in Table IV. To obtain a FIPS

code for a country not listed, contact the TRI

Information Center. There is nothing to enter in the

state field.

6.2a Column A: Total Transfers

For each off-site location, enter the total amount, in

pounds (in grams for dioxin and dioxin-like

compounds), of the EPCRA Section 313 chemical

that is contained in the waste transferred to that

location. Do not enter the total quantities of the

waste. If you do not ship or transfer wastes

containing the EPCRA Section 313 chemical to

other off-site locations, you should enter NA (See

discussion of NA vs. a Numeric Value (e.g., Zero)

in the introduction of Section 6) in the box for the

off-site location’s EPA Identification Number

(defined in 40 CFR 260.10 and therefore commonly

referred to as the RCRA ID Number).

If the total amount transferred is less than 1,000

pounds, you may report a range by entering the

appropriate range code (range reporting in section

6.2 does not apply to PBT chemicals). The

following reporting range codes are to be used:

Code Reporting Range (in pounds)

A 1-10

B 11-499

C 500-999
50 Toxics Release Inventory Reporting Forms and Instructions

Summary of Residue Quantities From Pilot-Scale Experimental Studya,b

(weight percent of drum capacity)

Material

Unloading

Method Vessel Type Value

Kerosenec Waterd Motor Oile Surfactant

Solutionf

Pumping Steel drum Range

Mean

1.93 - 3.08

2.48

1.84 - 2.61

2.29

1.97 - 2.23

2.06

3.06

3.06

Pumping Plastic drum Range

Mean

1.69 - 4.08

2.61

2.54 - 4.67

3.28

1.70 - 3.48

2.30

Not

Available

Pouring Bung-top steel

drum

Range

Mean

0.244 -

0.472

0.404

0.266 -

0.458

0.403

0.677 -

0.787

0.737

0.485

0.485

Pouring Open-top steel

drum

Range

Mean

0.032 -

0.080

0.054

0.026 -

0.039

0.034

0.328 -

0.368

0.350

0.089

0.089

Gravity

Drain

Slope-bottom

steel tank

Range

Mean

0.020 -

0.039

0.033

0.016 -

0.024

0.019

0.100 -

0.121

0.111

0.048

0.048

Gravity

Drain

Dish-bottom

steel tank

Range

Mean

0.031 -

0.042

0.038

0.033 -

0.034

0.034

0.133 -

0.191

0.161

0.058

0.058

Gravity

Drain

Dish-bottom

glass-lined

tank

Range

Mean

0.024 -

0.049

0.040

0.020 -

0.040

0.033

0.112 -

0.134

0.127

0.040

0.040

a

From “Releases During Cleaning of Equipment.” Prepared by PEI Associates, Inc., for the U.S. Environmental Protection Agency,

Office of Pesticides and Toxic Substances, Washington DC, Contract No. 68-02-4248. June 30, 1986.

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.

c

For kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2

d

For water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2

e

For motor oil, viscosity = 94 centipoise, surface tension = 34.5 dynes/cm2

f

For surfactant solution, viscosity = 3 centipoise, surface tension = 31.4 dynes/cm2

Example 14: Container Residue

You have determined that a Form R for an EPCRA Section 313 chemical must be submitted. The facility

purchases and uses one thousand 55-gallon steel drums that contain a 10 percent solution of the chemical.

Further, it is assumed that the physical properties of the solution are similar to water. The solution is

pumped from the drums directly into a mixing vessel and the “empty” drums are triple-rinsed with water.

The rinse water is indirectly discharged to a POTW and the cleaned drums are sent to a drum reclaimer.

In this example, it can be assumed that all of the residual solution in the drums was transferred to the rinse

water. Therefore, the quantity transferred to the drum reclaimer should be reported as “zero.” The annual

quantity of residual solution that is transferred to the rinse water can be estimated by multiplying the mean

weight percent of residual solution remaining in water from pumping a steel drum (2.29 percent from the

preceding table, “Summary of Residue Quantities From Pilot-Scale Experimental Study”) by the total

annual weight of solution in the drum (density of solution multiplied by drum volume). If the density is not

known, it may be appropriate to use the density of water (8.34 pounds per gallon):

(2.29%) x (8.34 pounds/gallon) x (55 gallons/drum) x (1,000 drums) = 10,504 pounds solution
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 51

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 offspecification 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 8.1d, and 1200 pounds in

Sections 6.2 (waste code M65 (RCRA Subtitle

C Landfill) should be used) and 8.1d.

Note that for EPCRA Section 313 chemicals

that are not metals or metal category

compounds, the quantity sent for treatment at

POTWs and to other off-site treatment locations

must be reported in Section 8.7 - Quantity

Treated Off-site. However, if you know that

some or all of the chemical is not treated for

destruction at the off-site location you must

report that quantity in Section 8.1.

If you transfer the EPCRA Section 313 chemical in

wastes to an off-site facility for distinct and multiple

purposes, you must report those activities for each

off-site location, along with the quantity of the

reported EPCRA Section 313 chemical associated

with each activity. For example, your facility

transfers a total of 15,000 pounds of toluene to an

off-site location that will use 5,000 pounds for the

purposes of energy recovery, will enter 7,500

pounds into a recovery process, and will dispose of

the remaining 2,500 pounds. These quantities and

the associated activity codes must be reported

separately in Section 6.2. (See Figure 4 for a

hypothetical Section 6.2 completed for two off-site

locations, one of which receives the transfer of

15,000 pounds of toluene as detailed.) If you have

fewer than four total transfers in Section 6.2

Column A (see examples in Figure 4), an NA should

be placed in Column A of the first unused row to

indicate the termination of the sequence. If all four

rows are used, there is no need to terminate the

sequence. If there are more than four total transfers,

re-enter the name of the off-site location, address,

etc. in the next row (6.2.2) and then you should

enter NA when the sequence has terminated if there

are fewer than 8 (i.e. anytime there are fewer than 4

transfers listed in a Section 6.2 block, an NA should

be used to terminate the sequence).

Do not double or multiple count amounts transferred

off-site. For example, when a reported EPCRA

Section 313 chemical is sent to an off-site facility

for sequential activities, you should report the final

disposition of the toxic chemical.

6.2b Column B: Basis of Estimate

You must identify the basis for your estimates of the

quantities of the reported EPCRA Section 313

chemical in waste transferred to each off-site

location. Enter one of the following letter codes that

applies to the method by which the largest

percentage of the estimate was derived.

M1 Estimate is based on continuous monitoring

data or measurements for the EPCRA Section

313 chemical.

M2 Estimate is based on periodic or random

monitoring data or measurements for the

EPCRA Section 313 chemical.

C Estimate is based on mass balance

calculations, such as calculation of the
52 Toxics Release Inventory Reporting Forms and Instructions

amount of the EPCRA Section 313 chemical

in streams entering and leaving process

equipment.

E1 Estimate is based on published emission

factors, such as those relating release quantity

to through-put or equipment type (e.g., air

emission factors).

E2 Estimate is based on site specific emission

factors, such as those relating release quantity

to through-put or equipment type (e.g., air

emission factors).

O Estimate is based on other approaches such as

engineering calculations (e.g., estimating

volatilization using published mathematical

formulas) or best engineering judgment. This

would include applying an estimated removal

efficiency to a waste stream, even if the

composition of the stream before treatment

was fully identified through monitoring data.

6.2c Column C: Type of Waste Management:

Disposal/ Treatment/Energy

Recovery/Recycling

You should enter one of the following M codes to

identify the type of disposal, treatment, energy

recovery, or recycling methods used by the off-site

location for the reported EPCRA Section 313

chemical. You must use more than one line and

code for a single location when distinct quantities of

the reported EPCRA Section 313 chemical are

subject to different waste management activities,

including disposal, treatment, energy recovery, or

recycling. You must use the code that represents the

ultimate disposition of the chemical.

If the EPCRA Section 313 chemical is sent off-site

for further direct reuse (e.g., an EPCRA Section 313

chemical in used solvent that will be used as

lubricant at another facility) and does not undergo a

waste management activity (i.e., release (including

disposal), treatment, energy recovery, or recycling

(recovery)) prior to that reuse, it need not be

reported in section 6.2 or section 8.

Incineration vs. Energy Recovery

You must distinguish between incineration which is

waste treatment, and legitimate energy recovery. For

you to claim that a reported EPCRA Section 313

chemical sent off-site is used for the purposes of

energy recovery and not for treatment for

destruction, the EPCRA Section 313 chemical must

have a significant heating value and must be

combusted in an energy recovery unit such as an

industrial boiler, furnace, or kiln. In a situation

where the reported EPCRA Section 313 chemical is

in a waste that is combusted in an energy recovery

unit, but the EPCRA Section 313 chemical does not

have a significant heating value, e.g., CFCs, you

should use code M54, Incineration/Insignificant

Fuel Value, to indicate that the EPCRA Section 313

chemical was incinerated in an energy recovery unit

but did not contribute to the heating value of the

waste.

Metals and Metal Category Compounds

Metals and metal category compounds will be

managed in waste either by being released

(including disposed) or by being recycled.

Remember that the release and other waste

management information that you report for metal

category compounds will be the total amount of the

parent metal released or recycled and NOT the

whole metal category compound. The metal has no

heat value and thus cannot be combusted for energy

recovery and cannot be treated because it cannot be

destroyed. Thus, transfers of metals and metal

category compounds for further waste management

should be reported as either a transfer for recycling

or a transfer for disposal. The applicable waste

management codes for transfers of metals and metal

category compounds for recycling are M24, metals

recovery, M93, waste broker - recycling, or M26,

other reuse/recovery. Applicable codes for transfers

for disposal include M10, M41, M62, M64, M65,

M66, M67, M73, M79, M81, M82, M90, M94, and

M99. These codes are for off-site transfers for

further waste management in which the waste

stream may be treated but the metal contained in the

waste stream is not treated and is ultimately

released. For example, M41 should be used for a

metal or metal category compound that is stabilized

in preparation for disposal.

Applicable codes for Part II, Section 6.2, column C

are:

Disposal

M10 Storage Only

M41 Solidification/Stabilization - Metals and

Metal Category Compounds only

M62 Wastewater Treatment (Excluding POTW) -

Metals and Metal Category Compounds only

M64 Other Landfills

M65 RCRA Subtitle C Landfills

M66 Subtitle C Surface Impoundment

M67 Other Surface Impoundments

M73 Land Treatment

M79 Other Land Disposal
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 53

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
54 Toxics Release Inventory Reporting Forms and Instructions

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.

This off-site location receives a transfer of 12,500 pounds of tetrachloroethylene (perchloroethylene) that is

part of a waste that is combusted for the purposes of energy recovery in an industrial furnace. Note that the

tetrachloroethylene should be reported using code M54 to indicate that it is combusted in an energy recovery

unit but it does not contribute to the heating value of the waste.

Figure 4. Hypothetical Section 6.2 Completed for Two Off-Site Locations
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 55

Section 7. On-Site Waste Treatment,

Energy Recovery, and

Recycling Methods

You must report in this section the methods of waste

treatment, energy recovery, and recycling applied to

the reported EPCRA Section 313 chemical in wastes

on-site. There are three separate sections for

reporting such activities. (Section 7A column c and

Section 7A column e were previously deleted from

Form R and are not addressed below.)

Section 7A: On-Site Waste Treatment

Methods and Efficiency

Most of the chemical-specific information required

by EPCRA Section 313 that is reported on Form R

is specific to the EPCRA Section 313 chemical

rather than the waste stream containing the EPCRA

Section 313 chemical. However, EPCRA Section

313 does require that waste treatment methods

applied on-site to waste streams that contain the

EPCRA Section 313 chemical be reported. This

information is reportable regardless of whether the

facility actively applies treatment or the treatment of

the waste stream occurs passively. This information

is collected in Section 7A of Form R.

In Section 7A, you must provide the following

information if you treat waste streams containing

the reported EPCRA Section 313 chemical on-site:

(a) The general waste stream types containing the

EPCRA Section 313 chemical being reported;

(b) The waste treatment method(s) or sequence

used on all waste streams containing the

EPCRA Section 313 chemical; and

(c) The efficiency of each waste treatment

method or waste treatment sequence in

destroying or removing the EPCRA Section

313 chemical.

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.
56 Toxics Release Inventory Reporting Forms and Instructions

If your facility has several pieces of equipment

performing a similar service in a waste treatment

sequence, you may combine the reporting for such

equipment. It is not necessary to enter four codes to

cover four scrubber units, for example, if all four are

treating waste streams of similar character (e.g.,

sulfuric acid mist emissions), have similar influent

concentrations, and have similar removal

efficiencies. If, however, any of these parameters

differs from one unit to the next, each scrubber

should be listed separately.

If you are using the hardcopy paper form, and if

your facility performs more than eight sequential

waste treatment methods on a single general waste

stream, continue listing the methods in the next row

and renumber appropriately those waste treatment

method code boxes you used to continue the

sequence. For example, if the general waste stream

in box 7A.1a had nine treatment methods applied to

it, the ninth method would be indicated in the first

method box for row 7A.2a. The numeral “1” would

be crossed out, and a “9” would be inserted.

Treatment applied to any other general waste stream

types would then be listed in the next empty row. In

the scenario below, for instance, the second general

waste stream would be reported in row 7A.3a. See

Figure 5 for an example of a hypothetical section

7A.
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 57

Example 16: Calculating Releases and Other Waste Management Quantities

Your facility disposes of 14,000 pounds of lead chromate (PbCrO4.PbO) in an on-site landfill and transfers

16,000 pounds of lead selenite (PbSeO4) to an off-site land disposal facility. You would therefore be

submitting three separate reports on the following: lead compounds, selenium compounds, and chromium

compounds. However, the quantities you would be reporting would be the pounds of “parent” metal being

released on-site or transferred off-site for further waste management. All quantities are based on mass

balance calculations (See Section 5, Column B for information on Basis of Estimate and Section 6.2,

Column C for waste management codes and information on transfers of EPCRA Section 313 chemicals in

wastes). You would calculate releases of lead, chromium, and selenium by first determining the percentage

by weight of these metals in the materials you use as follows:

Lead Chromate (PbCrO4.PbO) Molecular weight = 546.37

Lead (2 Pb atoms) Atomic weight = 207.2 x 2 = 414.4

Chromium (1 Cr atom) Atomic weight = 51.996

Lead chromate is therefore ( percent by weight)

(414.4/546.37) = 75.85% lead and

(51.996/546.37) = 9.52% chromium

Lead Selenite (PbSeO4) Molecular weight = 350.17

Lead (1 Pb atom) Atomic weight = 207.2

Selenium (1 Se atom) Atomic weight = 78.96

Lead selenite is therefore ( percent by weight)

(207.2/350.17) = 59.17% lead and

(78.96/350.17) = 22.55% selenium.

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

Lead

Disposal on-site: 0.7585 x 14,000 = 10,619 pounds from lead chromate

Transfer off-site for disposal: 0.5917 x 16,000 = 9,467 pounds from lead selenite

Chromium

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

Selenium

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

H101

H082

H123

H129

H081

H124

H083

H075

H077

A01

E4

E5

9 NA

NA

W

A

Figure 5. Hypothetical Section 7A

Waste Treatment Codes

A01 Flare

A02 Condenser

A03 Scrubber

A04 Absorber

A05 Electrostatic Precipitator

A06 Mechanical Separation

A07 Other Air Emission Treatment

H040 Incineration--thermal destruction other than

use as a fuel

H071 Chemical reduction with or without

precipitation

H073 Cyanide destruction with or without

precipitation

H075 Chemical oxidation

H076 Wet air oxidation

H077 Other chemical precipitation with or without

pre-treatment

H081 Biological treatment with or without

precipitation

H082 Adsorption

H083 Air or steam stripping

H101 Sludge treatment and/or dewatering

H103 Absorption

H111 Stabilization or chemical fixation prior to

disposal

H112 Macro-encapsulation prior to disposal

H121 Neutralization

H122 Evaporation

H123 Settling or clarification

H124 Phase separation

H129 Other treatment

7A Column d: Waste Treatment Efficiency

Estimate

In the space provided, enter the range code, based

upon the codes listed below, indicating the

percentage of the EPCRA Section 313 chemical

removed from the waste stream through destruction,

biological degradation, chemical conversion, or

physical removal. The waste treatment efficiency

(expressed as a range of percent removal) represents

the percentage of the EPCRA Section 313 chemical

destroyed or removed (based on amount or mass),

not merely changes in volume or concentration of

the EPCRA Section 313 chemical in the waste

stream. The efficiency, which can reflect the overall

removal from sequential treatment methods applied

to the general waste stream, refers only to the

percent destruction, degradation, conversion, or

removal of the EPCRA Section 313 chemical from

the waste stream; it does not refer to the percent

conversion or removal of other constituents in the

waste stream. The efficiency also does not refer to

the general efficiency of the treatment method for

any waste stream. For some waste treatment

methods, the percent removal will represent removal

by several mechanisms, as in an aeration basin,

where an EPCRA Section 313 chemical may

evaporate, biodegrade, or be physically removed

from the sludge.
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 59

Percent removal can be calculated as follows:

(I - E) x 100%

I

where:

I = amount of the EPCRA Section 313 chemical in

the influent waste stream (entering the waste

treatment step or sequence) and

E = amount of the EPCRA Section 313 chemical in

the effluent waste stream (exiting the waste

treatment step or sequence).

Calculate the amount of the EPCRA Section 313

chemical in the influent waste stream by multiplying

the concentration (by weight) of the EPCRA Section

313 chemical in the waste stream by the total

amount or weight of the waste stream. In most

cases, the percent removal compares the treated

effluent to the influent for the particular type of

waste stream. For solidification of wastewater, the

waste treatment efficiency can be reported as code

E1 (greater than 99.9999 percent) if no volatile

EPCRA Section 313 chemicals were removed with

the water or evaporated into the air. Percent removal

does not apply to incineration because the waste

stream, such as wastewater or liquids, may not exist

in a comparable form after waste treatment and the

purpose of incineration as a waste treatment is to

destroy the EPCRA Section 313 chemical by

converting it to carbon dioxide and water or other

byproducts. In cases where the EPCRA Section 313

chemical is incinerated, the percent efficiency must

be based on the amount of the EPCRA Section 313

chemical destroyed or combusted, except for metals

or metal category compounds. In the cases in which

a metal or metal category compound is incinerated,

the efficiency is reported as code E6 (equal to or

greater than 0 percent, but less than or equal to 50

percent).

Similarly, an efficiency of zero must be reported for

any waste treatment method(s) that does not destroy,

chemically convert or physically remove the

EPCRA Section 313 chemical from the waste

stream.

For metal category compounds, the calculation of

the reportable concentration and waste treatment

efficiency must be based on the weight of the parent

metal, not on the weight of the metal compound.

Metals are not destroyed, only physically removed

or chemically converted from one form into another.

The waste treatment efficiency reported must

represent only physical removal of the parent metal

from the waste stream (except for incineration), not

the percent chemical conversion of the metal

compound. If a listed waste treatment method

converts but does not remove a metal (e.g.,

chromium reduction), the method must be reported

with a waste treatment efficiency of code E6 (equal

to or greater than 0 percent, but less than or equal to

50 percent.

EPCRA Section 313 chemicals that are strong

mineral acids neutralized to a pH of 6 or above are

considered treated at a 100 percent efficiency.

When calculating waste treatment efficiency,

EPCRA Section 313(g)(2) requires a facility to use

readily available data (including monitoring data)

collected pursuant to other provisions of law, or,

where such data are not readily available,

“reasonable estimates” of the amounts involved.

Waste Treatment Efficiency Range Codes:

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

#6, in this section. Energy recovery may take place

only in an industrial kiln, furnace, or boiler.
60 Toxics Release Inventory Reporting Forms and Instructions

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).
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 61

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.1a 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.1b

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.1b is not chemical specific. It applies to the entire waste

stream being treated. Section 7A.1d 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

E1 for chemical C.

Chemical A

7A.1a 7A.1b 1. H124 2. H121 7A.1d

W 3. H123 4. N/A 5. E4

6. 7. 8.

Chemical B

7A.1a 7A.1b 1. H124 2. H121 7A.1d

W 3. H123 4. N/A 5. E5

6. 7. 8.

Chemical C

7A.1a 7A.1b 1. H124 2. H121 7A.1d

W 3. H123 4. N/A 5. E1

6. 7. 8.

Note that the quantity removed and/or destroyed is not reported in Section 7 and that the efficiency reported in Section

7A.1d 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 Section8.6 (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.
62 Toxics Release Inventory Reporting Forms and Instructions

Example 18: Reporting On-Site Energy Recovery

One waste stream generated by your facility contains, among other chemicals, toluene and Freon 113.

Threshold quantities are exceeded for both of these EPCRA Section 313 chemicals, and you would,

therefore, submit two separate Form R reports. This waste stream is sent to an on-site industrial

furnace that uses the heat generated in a thermal hydrocarbon cracking process at your facility.

Because toluene has a significant heat value (17,440 BTU/pound) and the energy is recovered in an

industrial furnace, the code “U02” would be reported in Section 7B for the Form R submitted for

toluene.

However, as Freon 113 does not contribute any value for energy recovery purposes, the combustion of

Freon 113 in the industrial furnace is considered waste treatment, not energy recovery. You would

report Freon 113 as entering a waste treatment step (i.e., incineration), in Section 7A, column b. In

Section 7B the facility should report zero.

Section 8. Source Reduction and

Recycling Activities

This section includes the data elements mandated by

Section6607 of the Pollution Prevention Act of 1990

(PPA).

In Section 8, you must provide information about

source reduction activities and quantities of the

EPCRA Section 313 chemicals managed as waste.

For all appropriate questions, report only the

quantity, in pounds, of the reported EPCRA Section

313 chemical itself (except the dioxin and dioxinlike compound category). Do not include the weight

of water, soil, or other waste constituents. When

reporting on the metal category compounds, you

should report only the amount of the metal portion

of the compound as you do when estimating release

and other waste management amounts.

Sections 8.1 through 8.9 must be completed for each

EPCRA Section 313 chemical. Section 8.10 must be

completed only if a source reduction activity was

newly implemented specifically (in whole or in part)

for the reported EPCRA Section 313 chemical

during the reporting year. Section 8.11 allows you to

indicate if you have attached additional optional

information on source reduction, recycling, or

pollution control activities implemented at any time

at your facility.

Sections 8.1 through 8.7 require reporting of

quantities for the current reporting year, the prior

year, and quantities anticipated in both the first year

immediately following the reporting year and the

second year following the reporting year (future

estimates).

Do not enter the values in Section 8 in gallons, tons,

liters, or any measure other than pounds. You must

also enter the values as whole numbers. Numbers

following a decimal point are not acceptable for

toxic chemicals other than those designated as PBT

chemicals. For PBT chemicals facilities should

report release and other waste management

quantities greater than 0.1 pound (except the dioxin

and dioxin-like compounds category) provided the

accuracy and the underlying data on which the

estimate is based supports this level of precision.

For the dioxin and dioxin-like compounds category

facilities should report at a level of precision

supported by the accuracy of the underlying data

and the estimation techniques on which the estimate

is based. However, the smallest quantity that need

be reported on the

Form R for the dioxin and dioxin-like compounds

category is 0.0001 grams (see Example 12).

Notwithstanding the numeric precision used when

determining reporting eligibility thresholds,

facilities should report on Form R to the level of

accuracy that their data supports, up to seven digits

to the right of the decimal. EPA’s reporting software

and data management systems support data

precision to seven digits to the right of the decimal.

NA vs. a Numeric Value (e.g., Zero). You should

enter a numeric value in the relevant sections of

Section 8 if your facility has released, treated,

combusted for energy recovery or recycled any

quantity of an EPCRA Section 313 chemical during

the reporting year. If the aggregate quantity of that

toxic chemical was equal to or less than 0.5 pound

for a particular waste management method, you

should enter the value zero (unless the chemical is a

PBT chemical) in the relevant section.
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 63

However, if there has been no on-site or off-site

treatment, combustion for energy recovery or

recycling on the waste stream containing the

EPCRA Section 313 chemical, then you should

enter NA in the relevant section. (Note: for metals

and metal category compounds, you should enter

NA in Sections 8.2, 8.3, 8.6 and 8.7, as treatment

and combustion for energy recovery generally are

not applicable waste management methods for

metals and metal compounds). For Section 8.1b, NA

generally is not applicable recognizing the potential

for spills, leaks, or fugitive emissions of the EPCRA

Section 313 chemical. You should enter NA in

Section 8.8 if there were no remedial actions,

catastrophic events such as earthquakes, fires, or

floods or one time events not associated with normal

or routine production processes for that toxic

chemical. If there was a catastrophic event at your

facility, but you were able to prevent any releases

from occurring, then enter zero in Section 8.8.

Column A: Prior Year

Quantities for Sections 8.1 through 8.7 must be

reported for the year immediately preceding the

reporting year in column A. For reports due July 1,

2009 (reporting year 2008), the prior year is 2007.

Information available at the facility that may be

used to estimate the prior year’s quantities include

the prior year’s Form R submission, supporting

documentation, and recycling, energy recovery,

treatment, or disposal operating logs or invoices.

When reporting prior year estimates facilities are

not required to use quantities reported on the

previous year’s form if better information is

available.

Column B: Current Reporting Year

Quantities for Sections 8.1 through 8.7 must be

reported for the current reporting year in column B.

Columns C and D: Following Year and Second

Following Year

Quantities for Sections 8.1 through 8.7 must be

estimated for 2009 and 2010. EPA expects

reasonable future quantity estimates using a logical

basis. Information available at the facility to

estimate quantities of the chemical expected during

these years include planned source reduction

activities, market projections, expected contracts,

anticipated new product lines, company growth

projections, and production capacity figures.

Respondents should take into account protections

available for trade secrets as provided in EPCRA

Section322 (42 USC 11042) for the chemical

identity.

Relationship to Other Laws

The reporting categories for quantities recycled,

used for energy recovery, treated, and disposed

apply to completing Section 8 of Form R as well as

to the rest of Form R. These categories are to be

used only for TRI reporting. They are not intended

for use in determining, under the Resource

Conservation and Recovery Act (RCRA) Subtitle C

regulations, whether a secondary material is a waste

when recycled. These definitions also do not apply

to the information that may be submitted in the

Biennial Report required under RCRA. In addition,

these definitions do not imply any future

redefinition of RCRA terms and do not affect EPA’s

RCRA authority or authority under any other statute

administered by EPA.

Differences in terminology and reporting

requirements for EPCRA Section 313 chemicals

reported on Form R and for hazardous wastes

regulated under RCRA occur because EPCRA and

the PPA focus on specific chemicals, while the

RCRA regulations and the Biennial Report focus on

waste streams that may include more than one

chemical. For example, a RCRA hazardous waste

containing an EPCRA Section 313 chemical is

recycled to recover certain constituents of that

waste, but not the toxic chemical reported under

EPCRA Section 313. The EPCRA Section 313

chemical simply passes through the recycling

process and remains in the residual from the

recycling process, which is disposed. While the

waste may be considered recycled under RCRA, the

EPCRA Section 313 chemical constituent would be

considered to be disposed for TRI purposes.

Quantities Reportable in Sections 8.1 - 8.7

Section 8 of Form R uses data collected to complete

Part II, Sections 5 through 7. For this reason,

Section 8 should be completed last. Sections 8.1,

8.3, 8.5, 8.7, and 8.8 use data collected to complete

Sections 5 and 6 of Form R. The relationship

between Section s 5, 6, and 8.8 to Sections 8.1, 8.3,

8.5, and 8.7 are provided below in equation form.

Section 8.1. Beginning in the 2003 reporting year,

Section 8.1 was divided into four Subsections (8.1a,

8.1b, 8.1c and 8.1d). Please refer to the following

equations that show the relationship between

Sections 5, 6 and 8.1a through 8.1d. EPCRA
64 Toxics Release Inventory Reporting Forms and Instructions

Section 329(8) defines release as “any spilling,

leaking, pumping, pouring, emitting, emptying,

discharging, injecting, escaping, leaching, dumping,

or disposing [on-site or off-site] into the

environment (including the abandonment of barrels,

containers, and other closed receptacles).” In

Section 8.1, facilities report disposal and other

releases. This includes on-site disposal and other

releases in Section 5 and off-site disposal and other

releases in Section 6 (releases plus transfers to

disposal and transfers to POTWs of metals and

metal compounds), but excludes quantities reported

in Section 5 and 6 due to remedial actions,

catastrophic events, or non-production related

events (see the discussion on Section 8.8).

Example 19: Reporting Future Estimates

A pharmaceutical manufacturing facility uses an

EPCRA Section 313 chemical in the

manufacture of a prescription drug. During the

reporting year (2005), the company received

approval from the Food and Drug

Administration to begin marketing their product

as an over-the-counter drug beginning in 2006.

This approval is publicly known and does not

constitute confidential business information. As

a result of this expanded market, the company

estimates that sales and subsequent production of

this drug will increase their use of the reported

EPCRA Section 313 chemical by 30 percent per

year for the two years following the reporting

year. The facility treats the EPCRA Section 313

chemical on-site and the quantity treated is

directly proportional to production activity. The

facility thus estimates the total quantity of the

reported EPCRA Section 313 chemical treated

for the following year (2005) by adding 30

percent to the amount in column B (the amount

for the current reporting year). The second

following year (2007) figure can be calculated

by adding an additional 30 percent to the amount

reported in column C (the amount for the

following year (2006) projection).

Metals and metal category compounds reported in

1) Section 6.2 as sent off-site for

stabilization/solidification (M41Cmetals) or

wastewater treatment (excluding POTWs)

(M62Cmetals) and/or 2) in Section 6.1 - discharges

to POTWs, should be reported in Section 8.1. These

quantities should NOT be reported in Section 8.7

because the metals are ultimately disposed.

Sections 8.1a and 8.1b. Toxic chemicals disposed

or otherwise released on-site are reported in 8.1a or

8.1b as appropriate. Toxic chemicals sent off-site

for disposal are reported in 8.1c or 8.1d.

Section 8.1a = Section 5.4.1 + Section 5.5.1A +

Section 5.5.1B B Section 8.8 (on-site release or

disposal due to catastrophic events)

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 release or disposal due to

catastrophic events)

Sections 8.1c and 8.1d. Toxic chemicals transferred

off-site to POTWs or other off-site locations should

be reported in 8.1c or 8.1d as appropriate. For

example, quantities of a toxic chemical sent to a

POTW and subsequently sent to a landfill are

reported in Section 8.1c. Quantities of the toxic

chemical disposed or otherwise released by the

POTW to a stream are reported in Section 8.1d.

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

UIC Class I Wells, RCRA Subtitle C landfills,

and other landfills) + Section 6.2 (quantities

associated with M codes M64, M65 and M81) -

Section 8.8 (off-site disposal due to catastrophic

events)

Section 8.1d = Section6.1 (portion of transfer that

is untreated and ultimately disposed of in UIC

Class II-V wells, and disposal other than to

landfills) + Section 6.2 (quantities associated with

M codes M10, M41, M62, M66, M67, M73, M79,

M82, M90, M94, M99) - Section 8.8 (off-site

disposal due to catastrophic events)

Some chemicals in addition to metals and metal

category compounds might not be treated for

destruction at a POTW. If you are able to quantify

the amounts of a toxic chemical sent to a POTW

that are treated for destruction and disposed or

released from the POTW untreated, you should

divide the amount reported in Section 6.1 between

Sections 8.1c and 8.1d and 8.7 (quantity treated offsite), as appropriate.

Sections 8.2 and 8.3. These relate to an EPCRA

Section 313 chemical or a mixture containing an
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 65

EPCRA Section 313 chemical that is used for

energy recovery on-site or is sent off-site for energy

recovery, unless it is a commercially available fuel

(e.g., fuel oil no. 6). For the purposes of reporting

on Form R, reportable on-site and off-site energy

recovery is the combustion of a waste stream

containing an EPCRA Section 313 chemical when:

(a) The combustion unit is integrated into an

energy recovery system (i.e., industrial

furnaces, industrial kilns, and boilers); and

(b) The EPCRA Section 313 chemical is

combustible and has a significant heating

value (e.g., 5000 BTU)

Note: Metals and metal category compounds cannot

be combusted for energy recovery. For metals and

metal category compounds, you should enter NA in

Sections 8.2 and 8.3.

Section 8.2 is reported in Section 8 only

Section 8.3 = Section6.2 (energy recovery)

Section8.8 (off-site energy recovery due to

catastrophic events)

Sections 8.4 and 8.5. These relate to an EPCRA

Section 313 chemical in a waste that is recycled onsite or is sent off-site for recycling.

Section 8.4 is reported in Section 8 only

Section 8.5 = Section 6.2 (recycling) - Section 8.8

(off-site recycling due to catastrophic events)

Section 8.6 and 8.7. These relate to an EPCRA

Section 313 chemical (except for most metals and

metal category compounds) or a waste containing an

EPCRA Section 313 chemical that is treated for

destruction on-site or is sent to a POTW or other

off-site location for treatment for destruction. Most

metal and category compounds are not reported in

this section because they cannot be destroyed (See

Appendix B).

Section 8.6 is reported in Section 8 only

Section 8.7 = Section 6.1 (excluding most

metal/metal category compounds) + Section 6.2

(treatment) - Section 8.8 (off-site treatment due

to catastrophic events)

Some chemicals in addition to metals and metal

category compounds might not be treated for

destruction at a POTW. If you are able to quantify

the amounts of a toxic chemical sent to a POTW

that are treated for destruction and disposed or

released from the POTW untreated, you should

divide the amount reported in Section 6.1 between

Sections 8.1c-d and 8.7 (quantity treated off-site), as

appropriate. Facilities should use their best readily

available information to determine the final

disposition of the toxic chemical sent to the POTW.

An EPCRA Section 313 chemical or an EPCRA

Section 313 chemical in a mixture that is a waste

under RCRA must be reported in Sections 8.1

through 8.7.

8.8 Quantity Released to the Environment as a

Result of Remedial Actions, Catastrophic Events,

or One Time Events Not Associated with

Production Processes

In Section 8.8, enter the total quantity of the

EPCRA Section 313 chemical disposed or released

directly into the environment or sent off-site for

recycling, energy recovery, treatment, or disposal

during the reporting year due to any of the following

events:

(1) remedial actions;

(2) catastrophic events such as earthquakes,

fires, or floods; or

(3) one time events not associated with

normal or routine production processes.

These quantities should not be included in Section

8.1.

The purpose of this section is to separate quantities

recycled, used for energy recovery, treated, or

released, including disposals that are associated with

normal or routine production operations from those

that are not. While all quantities disposed, released

recycled, combusted for energy recovery, or treated

may ultimately be preventable, this section separates

the quantities that are more likely to be reduced or

eliminated by process oriented source reduction

activities from those releases that are largely

unpredictable and are less amenable to such source

reduction activities. For example, spills that occur as

a routine part of production operations and could be

reduced or eliminated by improved handling,

loading, or unloading procedures are included in the

quantities reported in Section 8.1 through 8.7 as
66 Toxics Release Inventory Reporting Forms and Instructions

appropriate. A total loss of containment resulting

from a tank rupture caused by a tornado would be

included in the quantity reported in Section 8.8.

Similarly, the amount of an EPCRA Section 313

chemical cleaned up from spills resulting from

normal operations during the reporting year would

not be included in Section 8.8. However, the

quantity of the reported EPCRA Section 313

chemical disposed from a remedial action (e.g.,

RCRA corrective action) to clean up the

environmental contamination resulting from past

practices should be reported in Section 8.8 because

they cannot currently be addressed by source

reduction methods. A remedial action for purposes

of Section 8.8 is a waste cleanup (including RCRA

and CERCLA operations) within the facility

boundary. Most remedial activities involve

collecting and treating contaminated material.

Also, releases caused by catastrophic events are to

be incorporated into the quantity reported in Section

8.8. Such releases may be caused by natural

disasters (e.g., hurricanes and earthquakes) or by

large scale accidents (e.g., fires and explosions). In

addition, releases due to one-time events not

associated with production (e.g., terrorist bombing)

are to be included in Section 8.8. These amounts are

generally unanticipated and cannot be addressed by

routine process oriented accident prevention

techniques. By checking your documentation for

calculating estimates made for Part II, Section 5,

“Quantity of the Toxic Chemical Entering Each

Environmental Medium On-site,” you may be able

to identify disposal and release amounts from the

above sources. Emergency notifications under

CERCLA and EPCRA as well as accident histories

required under the Clean Air Act may provide

useful information. You should also check facility

incident reports and maintenance records to identify

one time or catastrophic events.

Note: While the information reported in Section 8.8

represents only remedial, catastrophic, or one time

events not associated with production processes,

Section 5 of Form R (on-site disposal and other

releases to the environment) and Section 6 (off-site

transfers for further waste management) must

include all on-site disposal and other releases and

transfers for disposal as appropriate, regardless of

whether they arise from catastrophic, remedial, or

routine process operations.

Avoid Double Counting in Sections 8.1 Through

8.8

Do not double or multiple count quantities in

Sections 8.1 through 8.8. The quantities reported in

each of those sections should be mutually exclusive.

Do not multiple count quantities entering sequential

reportable activities during the reporting year.

Quantities of the EPCRA Section 313 chemical

disposed or otherwise released into the environment

or otherwise managed as waste off-site due to

remedial actions; catastrophic events such as

earthquakes, fires, or floods; or unanticipated one

time events not associated with the production

process such as a drunk driver crashing his/her car

into a drum storage area. These quantities should be

reported in Section 8.8 only. For example, 10,000

pounds of diaminoanisole sulfate is released due to a

catastrophic event and is subsequently treated offsite. The 10,000 pounds is reported in Section 8.8

but the amount subsequently treated off-site is not

reported in Section 8.7.

8.9 Production Ratio or Activity Index

For Section 8.9, you must provide a ratio of

reporting year production to prior year production,

or provide an “activity index” based on a variable

other than production that is the primary influence

on the quantity of the reported EPCRA Section 313

chemical recycled, used for energy recovery,

treated, disposed or released. The ratio or index

must be reported to the nearest tenths or hundredths

place (i.e., one or two digits to the right of the

decimal point). For EPCRA Section 313 PBT

chemicals, including the dioxin and dioxin-like

compounds category, you will report the same as for

chemicals that are not listed as PBT (i.e., up to one

or two digits to the right of the decimal point). If the

manufacture, processing, or use of the reported

EPCRA Section 313 chemical began during the

current reporting year, enter NA as the production

ratio or activity index. Note, this is not to be

reported as a percent (i.e., report 1.10 for a 10

percent increase, not 110 percent).

It is important to realize that if your facility reports

more than one reported EPCRA Section 313

chemical, the production ratio or activity index may

vary for different chemicals. For facilities that

manufacture reported EPCRA Section 313

chemicals, the quantities of the EPCRA Section 313

chemical(s) produced in the current and prior years

provide a good basis for the ratio because that is the

primary business activity associated with the

reported EPCRA Section 313 chemical(s). In most
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 67

cases, the production ratio or activity index must be

based on some variable of production or activity

rather than on EPCRA Section 313 chemical or

material usage. Indices based on EPCRA Section

313 chemical or material usage may reflect the

effect of source reduction activities rather than

changes in business activity. EPCRA Section 313

chemical or material usage is therefore not a basis to

be used for the production ratio or activity index

where the EPCRA Section 313 chemical is

“otherwise used” (i.e., non incorporative activities

such as extraction solvents, metal degreasers, etc.).

While several methods are available to the facility

for determining this data element, the production

ratio or activity index must be based on the variable

that most directly affects the quantities of the

EPCRA Section 313 chemical recycled, used for

energy recovery, treated, disposed or released.

Examples of methods available include:

(1) Amount of EPCRA Section 313 chemical

manufactured in 2009 divided by the amount

of EPCRA Section 313 chemical

manufactured in 2008; or

(2) Amount of product produced in 2009 divided

by the amount of product produced in 2008.

Example 20: Quantity Released to the

Environment as a Result of Remedial

Actions, Castastrophic Events, or One-Time

Events Not Associated with Production

Processes.

A chemical manufacturer produces an EPCRA

Section 313 chemical in a reactor that operates

at low pressure. The reactants and the EPCRA

Section 313 chemical product are piped in and

out of the reactor at monitored and controlled

temperatures. During normal operations, small

amounts of fugitive emissions occur from the

valves and flanges in the pipelines.

Due to a malfunction in the control panel

(which is state-of-the-art and undergoes routine

inspection and maintenance), the temperature

and pressure in the reactor increase, the reactor

ruptures, and the EPCRA Section 313 chemical

is released. Because the malfunction could not

be anticipated and, therefore, could not be

reasonably addressed by specific source

reduction activities, the amount released is

included in Section 8.8. In this case, much of

the EPCRA Section 313 chemical is released as

a liquid and pools on the ground. It is estimated

that 1,000 pounds of the EPCRA Section 313

chemical pooled on the ground and was

subsequently collected and sent off-site for

treatment. In addition, it is estimated that

another 200 pounds of the EPCRA Section 313

chemical vaporized directly to the air from the

rupture. The total amount reported in Section

8.8 is the 1,000 pounds that pooled on the

ground (and subsequently sent off-site), plus

the 200 pounds that vaporized into the air, a

total of 1,200 pounds. The quantity sent off-site

must also be reported in Section 6 (but not in

Section 8.7) and the quantity that vaporized

must be reported as a fugitive emission in

Section 5 (but not in Section 8.1b).
68 Toxics Release Inventory Reporting Forms and Instructions

8.10 Did Your Facility Engage in Any Source

Reduction Activities for This Chemical

During the Reporting Year?

Section 8.10 must be completed only if a source

reduction activity was newly implemented

specifically (in whole or in part) for the reported

EPCRA Section 313 chemical during the reporting

year. If your facility engaged in any source

reduction activity for the reported EPCRA Section

313 chemical during the reporting year, report the

activity that was implemented and the method used

to identify the opportunity for the activity

implemented. If your facility did not engage in any

source reduction activity for the reported EPCRA

Section 313 chemical, enter NA in Section 8.10.1.

Source reduction means any practice that:

Reduces the amount of any hazardous

substance, pollutant, or contaminant entering

any waste stream or otherwise released into the

environment (including fugitive emissions)

prior to recycling, energy recovery, treatment,

or disposal; and

Reduces the hazards to public health and the

environment associated with the release of such

substances, pollutants, or contaminants.

The term includes equipment or technology

modifications, process or procedure modifications,

reformulation or redesign of products, substitution

of raw materials, and improvements in

housekeeping, maintenance, training, or inventory

control.

The term “source reduction” does not include any

practice that alters the physical, chemical, or

biological characteristics or the volume of a

hazardous substance, pollutant, or contaminant

through a process or activity that itself is not

integral to and necessary for the production of a

product or the providing of a service.

Source reduction activities do not include recycling,

using for energy recovery, treating, or disposing of

an EPCRA Section 313 chemical. Report in this

section only the source reduction activities

implemented to reduce or eliminate the quantities

reported in Sections 8.1 through 8.7. The focus of

the section is only those activities that are applied to

reduce routine or reasonably anticipated releases

and quantities of the reported EPCRA Section 313

chemical recycled, treated, used for energy

recovery, or disposed. Do not report in this section

any activities taken to reduce or eliminate the

quantities reported in Section 8.8. If you have fewer

than four source reduction codes in Section 8.10, an

NA should be placed in the first column of the first

unused row to indicate the termination of the

sequence. If all four rows are used, there is no need

to terminate the sequence. If there are more than

four source reduction codes, photocopy Page 5 of

Form R as many times as necessary and then

number the boxes consecutively for each source

reduction activity. Enter NA when the sequence has

terminated, unless the sequence ends at 4, 8, 12, 16,

etc. source reduction codes.

Example 21: Avoiding Double-Counting Quantities in Sections 8.1 through 8.7

5,000 pounds of an EPCRA Section 313 chemical enters a treatment operation. Three thousand pounds of

the EPCRA Section 313 chemical exits the treatment operation and then enters a recycling operation. Five

hundred pounds of the EPCRA Section 313 chemical are in residues from the recycling operation that is

subsequently sent off-site to a landfill for disposal. These quantities would be reported as follows in

Section 8:

Section 8.1c: 500 pounds disposed

Section 8.4: 2,500 pounds recycled

Section 8.6: 2000 pounds treated (5,000 that initially entered - 3,000 that subsequently entered recycling)

To report that 5,000 pounds were treated, 3,000 pounds were recycled, and that 500 pounds were sent offsite for disposal would result in over-counting the quantities of EPCRA Section 313 chemical recycled,

treated, and disposed by 3,500 pounds.
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Toxics Release Inventory Reporting Forms and Instructions 69

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).
70 Toxics Release Inventory Reporting Forms and Instructions

Example 23: Determining an Activity Index

Your facility manufactures organic dyes in a batch process. Different colors of dyes are manufactured, and

between color changes, all equipment must be thoroughly cleaned with solvent containing glycol ethers to

reduce color carryover. During the preceding year, the facility produced 2,000 pounds of yellow dye in

January, 9,000 pounds of green dye for February through September, 2,000 pounds of red dye in

November, and another 2,000 pounds of yellow dye in December. This adds up to a total of 15,000 pounds

and four color changeovers. During the reporting year, the facility produced 10,000 pounds of green dye

during the first half of the year and 10,000 pounds of red dye in the second half. If your facility uses glycol

ethers in this cleaning process only, an activity index of 0.5 (based on two color changeovers for the

reporting year divided by four changeovers for the preceding year) is more appropriate than a production

ratio of 1.33 (based on 20,000 pounds of dye produced in the current year divided by 15,000 pounds in the

preceding year). In this case, an activity index, rather than a production ratio, better reflects the factors that

influence the amount of solvent recycled, used for energy recovery, treated, or disposed or released.

A facility that manufactures thermoplastic composite parts for aircraft uses toluene as a wipe solvent to

clean molds. The solvent is stored in 55-gallon drums and is transferred to 1-gallon dispensers. The molds

are cleaned on an as-needed basis that is not necessarily a function of the parts production rate. Operators

cleaned 5,200 molds during the reporting year, but only cleaned 2,000 molds in the previous year. An

activity index of 2.6 (5,200/2,000) represents the activities involving toluene usage in the facility. If the

molds were cleaned after 1,000 parts were manufactured, a production ratio would equal the activity index

and either could be used as the basis for the index.

A facility manufactures surgical instruments and cleans the metal parts with 1,1,1-trichloromethane in a

vapor degreaser. The degreasing unit is operated in a batch mode and the metal parts are cleaned according

to an irregular schedule. The activity index can be based upon the total time the metal parts are in the

degreasing operation. If the degreasing unit operated 3,900 hours during the reporting year and 3,000 hours

the prior year, the activity index is 1.3 (3,900/3,000).

Example 24: “NA” is Entered as the Production Ratio or Activity Index

Your facility began production of semiconductor chips during this reporting year. Perchloroethylene is used

as a cleaning solvent for this operation and this is the only use of the EPCRA Section 313 chemical in your

facility. You would enter NA in Section 8.9 because you have no basis of comparison in the prior year for

the purposes of developing the activity index.
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Toxics Release Inventory Reporting Forms and Instructions 71

Example 25: Determining the Production Ratio Based on a Weighted Average

At many facilities, a reported EPCRA Section 313 chemical is used in more than one production process. In

these cases, a production ratio or activity index can be estimated by weighting the production ratio for each

process based on the respective contribution of each process to the quantity of the reported EPCRA Section

313 chemical recycled, used for energy recovery, treated, or disposed.

Your facility paints bicycles with paint containing toluene. Sixteen thousand bicycles were produced in the

reporting year and 14,500 were produced in the prior year. There were no significant design modifications

that changed the total surface area to be painted for each bike. The bicycle production ratio is 1.1

(16,000/14,500). You estimate 12,500 pounds of toluene recycled, used for energy recovery, treated,

disposed or released as a result of bicycle production. Your facility also uses toluene as a solvent in a glue

that is used to make components and add-on equipment for the bicycles. Thirteen thousand components

were manufactured in the reporting year as compared to 15,000 during the prior year. The production ratio

for the components using toluene is 0.87 (13,000/15,000). You estimate 1,000 pounds of toluene treated,

recycled, used for energy recovery, disposed or released as a result of components production. A production

ratio can be calculated by weighting each of the production ratios based on the relative contribution each

has to the quantities of toluene treated, recycled, used for energy recovery, disposed or released during the

reporting year (13,500 pounds). The production ratio is calculated as follows:

Production ratio = 1.1 x (12,500/13,500) + 0.87 x (1,000/13,500) = 1.08
72 Toxics Release Inventory Reporting Forms and Instructions

Example 26: Source Reduction

A facility assembles and paints furniture. Both the glue used to assemble the furniture and the paints contain

EPCRA Section 313 chemicals. By examining the gluing process, the facility discovered that a new drum of

glue is opened at the beginning of each shift, whether the old drum is empty or not. By adding a mechanism

that prevents the drum from being changed before it is empty, the need for disposal of the glue is eliminated

at the source. As a result, this activity is considered source reduction. The painting process at this facility

generates a solvent waste that contains an EPCRA Section 313 chemical that is collected and recovered.

The recovered solvent is used to clean the painting equipment. The recycling activity does not reduce the

amount of EPCRA Section 313 chemical recycled, and therefore is not considered a source reduction

activity.

Source Reduction Activities

You must enter in the first column of Section 8.10,

“Source Reduction Activities,” the appropriate

code(s) indicating the type of actions taken to

reduce the amount of the reported EPCRA Section

313 chemical disposed or otherwise released (as

reported in Section 8.1), used for energy recovery

(as reported in Sections 8.2–8.3), recycled (as

reported in Sections 8.4–8.5), or treated (as

reported in Sections 8.6–8.7). The list of codes

below includes many, but not all, of the codes

provided in the RCRA biennial report. Remember

that source reduction activities include only those

actions or techniques that reduce or eliminate the

amounts of the EPCRA Section 313 chemical

reported in Sections 8.1 through 8.7. Actions taken

to recycle, combust for energy recovery, treat, or

dispose of the EPCRA Section 313 chemical are

not considered source reduction activities.

Source Reduction Activity Codes:

Good Operating Practices

W13 Improved maintenance scheduling, record

keeping, or procedures

W14 Changed production schedule to minimize

equipment and feedstock changeovers

W19 Other changes made in operating practices

Inventory Control

W21 Instituted procedures to ensure that

materials do not stay in inventory beyond

shelf-life

W22 Began to test outdated material — continue

to use if still effective

W23 Eliminated shelf-life requirements for

stable materials

W24 Instituted better labeling procedures

W25 Instituted clearinghouse to exchange

materials that would otherwise be

discarded

W29 Other changes made in inventory control

Spill and Leak Prevention

W31 Improved storage or stacking procedures

W32 Improved procedures for loading,

unloading, and transfer operations

W33 Installed overflow alarms or automatic

shut-off valves

W35 Installed vapor recovery systems

W36 Implemented inspection or monitoring

program of potential spill or leak sources

W39 Other changes made in spill and leak

prevention

Raw Material Modifications

W41 Increased purity of raw materials

W42 Substituted raw materials

W49 Other raw material modifications made

Process Modifications

W51 Instituted re-circulation within a process

W52 Modified equipment, layout, or piping

W53 Used a different process catalyst

W54 Instituted better controls on operating bulk

containers to minimize discarding of empty

containers

W55 Changed from small volume containers to

bulk containers to minimize discarding of

empty containers

W58 Other process modifications made

Cleaning and Decreasing

W59 Modified stripping/cleaning equipment

W60 Changed to mechanical stripping/cleaning

devices (from solvents or other materials)

W61 Changed to aqueous cleaners (from

solvents or other materials)

W63 Modified containment procedures for

cleaning units

W64 Improved draining procedures

W65 Redesigned parts racks to reduce drag out

W66 Modified or installed rinse systems

W67 Improved rinse equipment design

W68 Improved rinse equipment operation
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 73

W71 Other cleaning and decreasing

modifications made

Surface Preparation and Finishing

W72 Modified spray systems or equipment

W73 Substituted coating materials used

W74 Improved application techniques

W75 Changed from spray to other system

W78 Other surface preparation and finishing

modifications made

Product Modifications

W81 Changed product specifications

W82 Modified design or composition of product

W83 Modified packaging

W89 Other product modifications made

Methods to Identify Activity

In columns a through c of Section 8.10, the

“Methods to Identify Activity,” you must enter one

or more of the following code(s) that correspond to

those internal and external method(s) or

information sources you used to identify the

possibility for a source reduction activity

implementation at your facility. If more than three

methods were used to identify the source reduction

activity, enter only the three codes that contributed

most to the decision to implement the activity.

T01 Internal pollution prevention opportunity

audit(s)

T02 External pollution prevention opportunity

audit(s)

T03 Materials balance audits

T04 Participative team management

T05 Employee recommendation (independent

of a formal company program

T06 Employee recommendation (under a

formal company program

T07 State government technical assistance

program

T08 Federal government technical assistance

program

T09 Trade association/industry technical

assistance program

T10 Vendor assistance

T11 Other

8.11 Is Additional Optional Information on

Source Reduction, Recycling, or

Pollution Control Activities Included

with this Report?

Check “Yes” for this data element if you wish to

submit any additional optional information on

source reduction, recycling, or pollution control

activities you have implemented in the reporting

year or in prior years for the reported EPCRA

Section 313 chemical. If you are using TRI-MEweb

to submit your report, you can use the pull-down

text box feature to describe your source reduction,

recycling, or pollution control activities. You may

submit such additional information in hard-copy in

addition to, or instead of, the information supplied

in the TRI-MEweb text box feature. If you wish to

submit by regular mail, please use the following

address:

TRI Reporting Center

P.O. Box 10163

Fairfax, VA 22038

To submit hard-copy information for Section 8.11

by certified or overnight mail, use the following

address:

CGI Federal, Inc.

c/o EPA Reporting Center

12601 Fair Lakes Circle

Fairfax, VA 22033

All information submitted in hard-copy must

include the name, address, and TRIFID number for

the facility submitting the information.

If there is a contact person at the facility, other than

the technical or public contact provided in Part I,

Section 4, the summary page should include that

person’s name and telephone number for

individuals who wish to obtain further information

about those activities. Also submit a copy of this

additional information to the appropriate state

agency as part of the Form R submittal to that

agency.
74 Toxics Release Inventory Reporting Forms and Instructions

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 dioxinlike compounds category present, and is

submitted as an adjunct to the Form R.

Beginning with reporting year 2008, facilities

that file Form R reports for the dioxin and

dioxin-like compounds category are required to

determine if they have any of the information

required by the new Form R Schedule 1.

Facilities that have any of the information

required by Form R Schedule 1 must submit a

Form R Schedule 1 in addition to the Form R.

D.2 Who is required to file a Form R

Schedule 1?

Only facilities that file reports for the dioxin and

dioxin-like compounds category may be required

to file a Form R Schedule 1. Facilities that have

any of the data required by Form R Schedule 1

for the individual members of the dioxin and

dioxin-like compounds category must submit a

Form R Schedule 1, in addition to the Form R.

EPA notes that dioxin and dioxin-like

compounds are not measured as a total quantity;

the measurements are based on the individual

compounds within the category. Emission factors

for dioxin and dioxin-like compounds are also

based on emission factors for the individual

compounds within the category. EPA’s guidance

document for dioxin and dioxin-like compounds

(Emergency Planning And Community RightTo-Know Act - Section 313: Guidance for

Reporting Toxic Chemicals within the Dioxin and

Dioxin-like Compounds Category, EPA-745-B00-021, December 2000) includes tables that

contain the emission factors for the individual

members of the dioxin and dioxin-like compounds

category. Since measured data and emission

factor data are based upon data for the individual

members of the dioxin and dioxin-like compounds

category, the information required by Form R

Schedule 1 should be available to facilities that

file Form R reports for the dioxin and dioxin-like

compounds category.

D.3 What information is reported on

the Form R Schedule 1?

The only data reported on the Form R Schedule 1

is the mass quantity information required in

sections 5, 6, and 8 (current year only) of the

Form R. All of the other information required in

sections 5, 6, and 8 of the Form R (off-site

location names, stream or water body names, etc.)

would be the same so this information is not

duplicated on Form R Schedule 1. For example,

if a facility reported 5.3306 grams on Form R

Section 5.1 for fugitive or non-point air emissions

for the dioxin and dioxin-like compounds

category then the facility would report on the

Form R Schedule 1 the grams data for each

individual member of the category that

contributed to the 5.3306 gram total. The sum of

the gram quantities reported for each individual

member of the category should equal the total

gram quantity reported for the category on Form

R for each data element (see examples below).

The NA box has the same meaning on Form R

Schedule 1 as it does on the Form R and should

only be marked if it is marked on the Form R.
Instructions for Completing Part II of EPA Form R

Toxics Release Inventory Reporting Forms and Instructions 75

Form R Section 5 Example

SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE

A. Total Release (pounds/year*)

(Enter a range code** or

estimate)

B. Basis of

Estimate

(enter code)

C. % From

Stormwater

5.1 Fugitive or non-point

air emissions

N

A

5.3306 M

Form R Schedule 1 Section 5 Example

SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM

ONSITE

5.1 NA 5.2 N

A

5.3 Discharges to receiving streams or water bodies

(enter data for one stream or water body per box)

Fugitive or nonpoint air emissionsStack or point

air emissions 5.3.1 5.3.2 5.3.3

1 0.0035

2 0.0059

3 0.0071

4 0.0008

5 0.0065

6 0.0923

7 0.5720

8 0.0723

9 0.0695

10 0.0399

11 0.3562

12 0.1309

13 0.0132

14 0.0815

15 1.4625

16 0.3126

17 2.1039

The Form R Schedule 1 provides boxes for recording the gram quantities for all 17 individual members of

the dioxin and dioxin-like compounds category. The boxes on the Form R Schedule 1 for each release type

are divided into 17 boxes. Each of the boxes (1-17) correspond to the individual members of the dioxin

category as presented in Table I.

Table I

Box # CAS# Chemical Name Abbreviation

1 01746–01–6 2,3,7,8-Tetrachlorodibenzo- p-dioxin 2,3,7,8-TCDD

2 40321–76–4 1,2,3,7,8-Pentachlorodibenzo- p-dioxin 1,2,3,7,8-PeCDD

3 39227–28–6 1,2,3,4,7,8-Hexachlorodibenzo- p-dioxin 1,2,3,4,7,8-HxCDD

4 57653–85–7 1,2,3,6,7,8-Hexachlorodibenzo- p-dioxin 1,2,3,6,7,8-HxCDD

5 19408–74–3 1,2,3,7,8,9-Hexachlorodibenzo- p-dioxin 1,2,3,7,8,9-HxCDD

6 35822–46–9 1,2,3,4,6,7,8-Heptachlorodibenzo- p-dioxin 1,2,3,4,6,7,8-HpCDD

7 03268–87–9 1,2,3,4,6,7,8,9-Octachlorodibenzo- p-dioxin 1,2,3,4,6,7,8,9-OCDD

8 51207–31–9 2,3,7,8-Tetrachlorodibenzofuran 2,3,7,8-TCDF

9 57117–41–6 1,2,3,7,8-Pentachlorodibenzofuran 1,2,3,7,8-PeCDF
76 Toxics Release Inventory Reporting Forms and Instructions

10 57117–31–4 2,3,4,7,8-Pentachlorodibenzofuran 2,3,4,7,8-PeCDF

11 70648–26–9 1,2,3,4,7,8-Hexachlorodibenzofuran 1,2,3,4,7,8-HxCDF

12 57117–44–9 1,2,3,6,7,8-Hexachlorodibenzofuran 1,2,3,6,7,8-HxCDF

13 72918–21–9 1,2,3,7,8,9-Hexachlorodibenzofuran 1,2,3,7,8,9-HxCDF

14 60851–34–5 2,3,4,6,7,8-Hexachlorodibenzofuran 2,3,4,6,7,8-HxCDF

15 67562–39–4 1,2,3,4,6,7,8-Heptachlorodibenzofuran 1,2,3,4,6,7,8-HpCDF

16 55673–89–7 1,2,3,4,7,8,9-Heptachlorodibenzofuran 1,2,3,4,7,8,9-HpCDF

17 39001–02–0 1,2,3,4,6,7,8,9-Octachlorodibenzofuran 1,2,3,4,6,7,8,9-OCDF

It is extremely important that facilities enter their grams data for the individual members of the category

based on the box numbers in Table I (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.
Facility Eligibility Determination for Alternate Threshold

and for Reporting on EPA Form A Certification Statement

Toxics Release Inventory Reporting Forms and Instructions 77

E. Facility Eligibility

Determination for Alternate

Threshold and for

Reporting on EPA Form A

This section will help to determine whether you

can submit the simplified Form A Certification

Statement (hereafter referred to as Form A). The

criteria are based on the total annual reportable

amount of the listed chemical or chemical category

and the amount manufactured, processed, or

otherwise used. Note that, effective in Reporting

Year 2008, the TRI Burden Reduction Rule has

been voided by Congress. The criterion for using

Form A has returned to what they were prior to

Reporting Year 2006. The criteria are explained

below. For more information about the final rule,

see the TRI homepage at http://www.epa.gov/tri/.

E.1 Alternate Threshold

On November 30, 1994, EPA published a final rule

(59 FR 61488) that provides qualifying facilities an

alternate threshold of 1 million pounds. 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.1, 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 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).
78 Toxics Release Inventory Reporting Forms and Instructions

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.
Facility Eligibility Determination for Alternate Threshold

and for Reporting on EPA Form A Certification Statement

Toxics Release Inventory Reporting Forms and Instructions 79

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, pxylene and xylene (mixed isomers)). For example,

if a facility processes in three separate process

streams, xylene (mixed isomers), o-xylene, and pxylene, 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.
80 Toxics Release Inventory Reporting Forms and Instructions

F. Instructions for Completing

EPA Form A

For all parts of Form A:

You should type or print information on the

form in the format requested and use black ink.

(Using blue ink for the certification signature is

suggested as a means of indicating its

originality.)

All information on the Form A is required.

Do not leave items in Parts I and II on the

Form A blank unless specifically directed to do

so; if an item does not apply to you, you should

enter NA in the space provided. If your

information does not fill all the spaces

provided for a type of information, enter NA,

in the next blank space in the sequence.

Do not submit an incomplete form. The

certification statement (Part I, Section 3)

specifies that the report is complete as

submitted. See Page 1 of these instructions for

the definition of a complete submission.

Part 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 2009 must be submitted on or before July 1,

2010.

Section 2. Trade Secret Information

2.1 Are you claiming the EPCRA Section 313

chemical identified on Page 3 a trade

secret?

If facilities wish to report more than one eligible

chemical on the same Form A, then they are not

able to make trade secrecy claims. Any trade

secrecy claims should be made on a separate form,

and then the process is the same as using the Form

R and as described in the following instructions.

The specific identity of the EPCRA Section 313

chemical being reported in Part II, Section 1, may

be designated as a trade secret. If you are making a

trade secret claim, mark “yes” and proceed to

Section 2.2. Only check “yes” if you manufacture,

process, or otherwise use the EPCRA Section 313

chemical whose identity is a trade secret. (See Page

3 of these instructions for specific information on

trade secrecy claims.) If you checked “no,” proceed

to Section 3; do not answer Section 2.2.

Do not submit trade secret reports

electronically. See last year’s Reporting

Forms and Instructions.

2.2 If “yes” in 2.1, is this copy sanitized or

unsanitized?

You should check “sanitized” if this copy of the

report is the public version that does not contain

the EPCRA Section 313 chemical identity but does

contain a generic name that is structurally

descriptive in its place, and you have claimed the

EPCRA Section 313 chemical identity trade secret

in Part I, Section 2.1. Otherwise, check

“unsanitized.”

Section 3. Certification

The Form A must be signed by a senior official

with management responsibility for the person (or

persons) completing the form. A senior

management official must certify the accuracy and

completeness of the information reported on the

form by signing and dating the Form A. Each

report must contain an original signature. Unlike

the certification statement contained on Form R,

the certification statement provided on the

Alternate Threshold Form A pertains to the

facility’s eligibility of having met the conditions as

described in 40 CFR 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 FDPs.

Section 4. Facility Identification

4.1 Facility Name, Location, and TRI

Facility Identification Number

Enter the full name that the facility presents to the

public and its customers in doing business (e.g., the

name that appears on invoices, signs, and other

official business documents). Do not use a

nickname for the facility (e.g., Main Street Plant)

unless that is the legal name of the facility under

which it does business. Also enter the street

address, mailing address, city, county, state, and

zip code in the space provided. Do not use a post
Facility Eligibility Determination for Alternate Threshold

and for Reporting on EPA Form A Certification Statement

Toxics Release Inventory Reporting Forms and Instructions 81

office box number as the street address. The street

address provided must be the location where the

EPCRA Section 313 chemicals are manufactured,

processed, or otherwise used. If your mailing

address and street address are the same, you should

enter NA in the space for the mailing address.

If your facility is not in a county, put the name of

your city, district (for example District of

Columbia), or parish (if you are in Louisiana) in

the county block of the Form R and Form A as well

as in the County field of TRI-MEweb . “NA” or

“None” are not acceptable entries.

If you have submitted a Form A or Form R for

previous reporting years, a TRI Facility

Identification Number has been assigned to your

facility. If you know your TRI Facility

Identification Number, complete Section 4. If you

do not know your TRI Facility Identification

Number, contact the CDX Help Desk toll free at 1-

888-890-1995. If your facility has moved, do not

enter your TRI facility identification number, you

should enter “New Facility.”

The TRI Facility Identification Number is

established by the first Form R submitted by a

facility at a particular location. This identification

number is retained by the facility even if the

facility changes name, ownership, production

processes, SIC or NAICS codes, etc. This

identification number will stay with this location. If

a new facility moves to this location it should use

this TRI Facility Identification Number.

Establishments of a facility that report separately

should use the TRI Facility Identification Number

of the facility.

You should enter “New Facility” in the space for

the TRI Facility Identification number if this is

your first submission.

4.2 Federal Facility Designation

Executive Order 13423 directs federal facilities to

comply with Right-To-Know Laws and Pollution

Prevention Requirements. Please indicate in 4.2A.

if the reporting facility is a federal facility or in

4.2.B if the submitter is a contractor at a federal

facility (GOCO). If the reporting facility is not a

federal facility, you should leave this space blank.

Form R allows a facility to report multiple

submissions for the same chemical if the facility is

composed of several distinct establishments. This

data element provides the option of reporting full

or partial facility information on Form R, however,

this is not applicable for those facilities taking

advantage of the Alternate Threshold and Form A.

4.3 Technical Contact

Enter the name and telephone number (including

area code) of a technical representative whom EPA

or state officials may contact for clarification of the

information reported on Form A. You should also

enter an email address for this person. EPA

encourages facilities to provide an email address

for its Technical Contact on their TRI submissions

because they will be able to receive important

program updates and email alerts notifying them

when their FDP has been updated and is available

on the FDP website. If the technical contact does

not have an email address you should enter NA.

This contact person does not have to be the same

person who prepares the report or signs the Form A

and does not necessarily need to be someone at the

location of the reporting facility. However, this

person should be familiar with the details of the

report so that he or she can answer questions about

the information provided.

4.4 Public Contact

Enter the name and telephone number (including

area code) of a person who can respond to

questions from the public about the form. You

should also enter an e-mail address for this person.

If you choose to designate the same person as both

the Technical and the Public Contact, or you do not

have a Public Contact, you may enter “Same as

Section 4.3” in this space. This contact person does

not have to be the same person who prepares the

form or signs the Certification Statement and does

not necessarily need to be someone at the location

of the reporting facility.

4.5 North American Industry Classification

System (NAICS) Code

Enter the appropriate six digit North American

Industry Classification System (NAICS) Code that

is the primary NAICS Code for your facility in

Section 4.5(a). (Use 2007 NAICS codes.) Enter

any other applicable NAICS for your facility in 4.5

(b)-(f). The tables in Section B list the required

NAICS codes and their exceptions/ limitations. If

you do not know your NAICS code, consult the

2007 NAICS Manual (see Section B.2 of these
82 Toxics Release Inventory Reporting Forms and Instructions

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 replaces the 1987 SIC code system. A

Federal Register notice was published on June 6,

2006 (71 FR 32464). NAICS codes are required on

TRI reporting forms beginning with RY 2006. A

subsequent Federal Register notice was published

on June 9, 2008 (73 FR 32466) to incorporate 2007

OMB revisions and other corrections to the NAICS

codes used for TRI Reporting.

4.6 Dun & Bradstreet Number(s)

Enter the nine digit number assigned by 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 web site:

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 purposes of the Form A, a parent

company is defined as the highest level company,

located in the United States, that directly owns at

least 50 percent of the voting stock of your

company. If your facility is owned by a foreign

entity, you should enter NA in this space.

Corporate names should be treated as parent

company names for companies with multiple

facility sites. For example, the Bestchem

Corporation is not owned or controlled by any

other corporation but has sites throughout the

country whose names begin with Bestchem. In this

case, Bestchem Corporation should be listed as the

parent company. Note that a facility that is a 50:50

joint venture is its own parent company. When a

facility is owned by more than one company and

there is no parent company for the entire facility

(meaning that none of the facility owners directly

owns at least 50 percent of the voting stock of the

facility at issue), the facility should provide the

name of the parent company of either the facility

operator or the owner with the largest ownership

interest in the facility. If neither the operator nor

this owner has a parent company, then the NA box

should be checked.

5.1 Name of Parent Company

Enter the name of the corporation or other business

entity that is your ultimate US parent company. If

your facility has no parent company, you should

check the NA box.

5.2 Parent Company’s Dun & Bradstreet

Number

Enter the 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 web site:

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.
Facility Eligibility Determination for Alternate Threshold

and for Reporting on EPA Form A Certification Statement

Toxics Release Inventory Reporting Forms and Instructions 83

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 IIc and

Appendix B.1.

EPCRA Section 313 Chemical Category Codes:

N010 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

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.
84 Toxics Release Inventory Reporting Forms and Instructions

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.
Facility Eligibility Determination for Alternate Threshold

and for Reporting on EPA Form A Certification Statement

Toxics Release Inventory Reporting Forms and Instructions 85

Index

Ancillary or other use, 38

article component, 37

byproduct, 37

Catastrophic Events, 67, 69

CD, 1

CDX, vii, 2, 6, 83

chemical processing aid, 38

Coal Extraction Activities Exemption, 20

Coincidental Manufacture, 11, 12

Container Residue, 52

De Minimis Exemption, 16

Discharges to Receiving Streams or Water

Bodies, 41

Disposal to Land, 42

Dun & Bradstreet, 34, 84

Energy Recovery, 54, 57, 61, 62, 64

EPA Identification Number, 49, 50

EPCRA, vi, vii, viii, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11,

12, 13, 14, 15, 16, 17, 18, 20, 21, 22, 23, 24, 25,

26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38,

39, 40, 41, 42, 43, 44, 45, 46, 48, 49, 50, 51, 52,

53, 54, 57, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68,

69, 70, 72, 73, 74, 75, 80, 82, 85, 86

Facility Identification, 82

Form A, 79

formulation component, 37

Fugitive or Non-Point Air Emissions, 41

Full-Time Employee, 7

Import, 37

impurity, 37

Laboratory Activities Exemption, 20

Manufacture, 11, 13, 18, 20, 37

manufacturing aid, 38

Metal Category Compounds, 24

Metal Mining Overburden Exemption, 21

Mixture Component Identity, 27

Nitrate Compounds, 26

On-Site Recycling Codes, 62

Other Disposal, 43

Other Surface Impoundments, 43

Otherwise Use, 11, 13, 15, 18, 37

PBT, 8, 13, 14, 15, 16, 17, 18, 21, 22, 23, 25, 28,

29, 30, 31, 36, 39, 40, 41, 43, 48, 49, 50, 51, 62,

64, 68

Process, 4, 11, 13, 18, 37

Produce, 37

Production Ratio, 71

RCRA Subtitle C landfills, 42

RCRA Subtitle C Surface Impoundments, 43

reactant, 37

Repackaging, 37

Reporting Year, 28, 29, 30, 31, 65

Revise, 4

sale/distribution, 37

Source Reduction, 64, 74

Stormwater Runoff, 48

Submit Paper Form R, 2

Surface Impoundments, 43

Technical Contact, 6, 33, 83

Threshold Determinations, 21

Total Transfers, 49

Toxics Release Inventory Assistance Library

(TRIAL), vii

Trade Secret, 2, 32, 82

TRI-ME, vii, 1, 32, 83

Underground Injection, 42, 55

Waste Treatment Codes, 60

Withdraw, 4, 5
Table 1. NAICS Codes

Toxics Release Inventory Reporting Form and Instructions I-1

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

311412 Frozen Specialty Food Manufacturing

31142 Fruit and Vegetable Canning,

Pickling and Drying

311421 Fruit and Vegetable Canning

311422 Specialty Canning

311423 Dried and Dehydrated Food Manufacturing

3115 Dairy Product Manufacturing

31151 Dairy Product (except Frozen)

Manufacturing

311511 Fluid Milk Manufacturing

311512 Creamery Butter Manufacturing

311513 Cheese Manufacturing

311514 Dry, Condensed, and Evaporated Dairy

Product Manufacturing
Table I. NAICS Codes

I-2 Toxics Release Inventory Reporting Form and Instructions

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

312140 Distilleries
Table I. NAICS Codes

Toxics Release Inventory Reporting Form and Instructions I-3

3122 Tobacco Manufacturing

31221 Tobacco Stemming and

Redrying

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 Broadwoven Fabric Finishing Mills (except

facilities primarily engaged in converting

broadwoven piece goods and broadwoven

textiles and facilities primarily engaged in

sponging fabric for tailors and dressmakers)

313312 Textile and Fabric Finishing (except

Broadwoven Fabric) Mills (except facilities

primarily engaged in converting narrow

woven textiles and narrow woven piece

goods)

31332 Fabric Coating Mills

313320 Fabric Coating Mills

314 Textile Product Mills

3141 Textile Furnishing Mills

31411 Carpet and Rug Mills

314110 Carpet and Rug Mills

31412 Curtain and Linen Mills

314121 Curtain and Drapery Mills (except facilities

primarily engaged in making custom drapery

for retail sale)

314129 Other Household Textile Product Mills

(except facilities primarily engaged in making

custom drapery for retail sale)

3149 Other Textile Product Mills

31491 Textile Bag and Canvas Mills

314911 Textile Bag Mills

314912 Canvas and Related Product Mills

31499 All Other Textile Product

Mills

314991 Rope, Cordage, and Twine Mills

314992 Tire Cord and Tire Fabric Mills

314999 All Other Miscellaneous Textile Product

Mills (except facilities engaged in binding

carpets and rugs for the trade, carpet cutting

and binding, and embroidering on textile

products (except apparel) for the trade)

315 Apparel Manufacturing
Table I. NAICS Codes

I-4 Toxics Release Inventory Reporting Form and Instructions

3151 Apparel Knitting Mills

31511 Hosiery and Sock Mills

315111 Sheer Hosiery Mills

315119 Other Hosiery and Sock Mills

31519 Other Apparel Knitting Mills

315191 Outerwear Knitting Mills

315192 Underwear and Nightwear Knitting Mills

3152 Cut and Sew Apparel

Manufacturing

31521 Cut and Sew Apparel

Contractors

315211 Men’s and Boys’ Cut and Sew Apparel

Contractors

315212 Women’s, Girls’, and Infants’ Cut and Sew

Apparel Contractors

31522 Men’s and Boys’ Cut and Sew

Apparel Manufacturing

315221 Men’s and Boys’ Cut and Sew Underwear

and Nightwear Manufacturing

315222 Men’s and Boys’ Cut and Sew Suit, Coat, and

Overcoat Manufacturing (except custom

tailors primarily engaged in making and

selling men’s and boy’s suits, cut and sewn

from purchased fabric)

315223 Men’s and Boys’ Cut and Sew Shirt (except

Work Shirt) Manufacturing (except custom

tailors primarily engaged in making and

selling men’s and boy’s dress shirts, cut and

sewn from purchased fabric)

315224 Men’s and Boys’ Cut and Sew Trouser,

Slack, and Jean Manufacturing

315225 Men’s and Boys’ Cut and Sew Work Clothing

Manufacturing

315228 Men’s and Boys’ Cut and Sew Other

Outerwear Manufacturing

31523 Women’s and Girls’ Cut and

Sew Apparel Manufacturing

315231 Women’s and Girls’ Cut and Sew Lingerie,

Loungewear, and Nightwear Manufacturing

315232 Women’s and Girls’ Cut and Sew Blouse and

Shirt Manufacturing

315233 Women’s and Girls’ Cut and Sew Dress

Manufacturing (except custom tailors

primarily engaged in making and selling

bridal dresses or gowns, or women’s, misses’

and girls’ dresses cut and sewn from

purchased fabric (except apparel contractors)

(custom dressmakers)

315234 Women’s and Girls’ Cut and Sew Suit, Coat,

Tailored Jacket, and Skirt Manufacturing

315239 Women’s and Girls’ Cut and Sew Other

Outerwear Manufacturing

31529 Other Cut and Sew Apparel

Manufacturing

315291 Infants’ Cut and Sew Apparel Manufacturing

315292 Fur and Leather Apparel Manufacturing

315299 All Other Cut and Sew Apparel

Manufacturing

3159 Apparel Accessories and

Other Apparel Manufacturing

31599 Apparel Accessories and

Other Apparel Manufacturing

315991 Hat, Cap, and Millinery Manufacturing

315992 Glove and Mitten Manufacturing

315993 Men’s and Boys’ Neckwear Manufacturing

315999 Other Apparel Accessories and Other Apparel

Manufacturing

316 Leather and Allied Product

Manufacturing

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
Table I. NAICS Codes

Toxics Release Inventory Reporting Form and Instructions I-5

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

322121 Paper (except Newsprint) Mills

322122 Newsprint Mills

32213 Paperboard Mills

322130 Paperboard Mills

3222 Converted Paper Product

Manufacturing

32221 Paperboard Container

Manufacturing

322211 Corrugated and Solid Fiber Box

Manufacturing

322212 Folding Paperboard Box Manufacturing

322213 Setup Paperboard Box Manufacturing

322214 Fiber Can, Tube, Drum, and Similar Products

Manufacturing

322215 Nonfolding Sanitary Food Container

Manufacturing

32222 Paper Bag and Coated and

Treated Paper Manufacturing

322221 Coated and Laminated Packaging Paper and

Plastics Film Manufacturing
Table I. NAICS Codes

I-6 Toxics Release Inventory Reporting Form and Instructions

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

324121 Asphalt Paving Mixture and Block

Manufacturing

324122 Asphalt Shingle and Coating Materials

Manufacturing

32419 Other Petroleum and Coal

Products Manufacturing

324191 Petroleum Lubricating Oil and Grease

Manufacturing

324199 All Other Petroleum and Coal Products

Manufacturing

325 Chemical Manufacturing

3251 Basic Chemical

Manufacturing

32511 Petrochemical Manufacturing

325110 Petrochemical Manufacturing

32512 Industrial Gas Manufacturing

325120 Industrial Gas Manufacturing

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
Table I. NAICS Codes

Toxics Release Inventory Reporting Form and Instructions I-7

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
Table I. NAICS Codes

I-8 Toxics Release Inventory Reporting Form and Instructions

325991 Custom Compounding of Purchased Resins

325992 Photographic Film, Paper, Plate, and

Chemical

Manufacturing

325998 All Other Miscellaneous Chemical Product

and Preparation Manufacturing (except

facilities primarily engaged in Aerosol can

filling on a job order or contract Basis)

326 Plastics and Rubber Products

Manufacturing

3261 Plastics Product

Manufacturing

32611 Plastics Packaging Materials

and Unlaminated Film and

Sheet Manufacturing

326111 Plastics Bag Manufacturing

326112 Plastics Packaging Film and Sheet (including

Laminated) Manufacturing

326113 Unlaminated Plastics Film and Sheet (except

Packaging) Manufacturing

32612 Plastics, Pipe, Pipe Fitting, and

Unlaminated Profile Shape

Manufacturing

326121 Unlaminated Plastics Profile Shape

Manufacturing

326122 Plastics Pipe and Pipe Fitting Manufacturing

32613 Laminated Plastics Plate,

Sheet

(except Packaging), and Shape

Manufacturing

326130 Laminated Plastics Plate, Sheet (except

Packaging), and Shape Manufacturing

32614 Polystyrene Foam Product

Manufacturing

326140 Polystyrene Foam Product Manufacturing

32615 Urethane and Other Foam

Product (except Polystyrene)

Manufacturing

326150 Urethane and Other Foam Product (except

Polystyrene) Manufacturing

32616 Plastics Bottle Manufacturing

326160 Plastics Bottle Manufacturing

32619 Other Plastics Product

Manufacturing

326191 Plastics Plumbing Fixture Manufacturing

326192 Resilient Floor Covering Manufacturing

326199 All Other Plastics Product Manufacturing

3262 Rubber Product

Manufacturing

32621 Tire Manufacturing

326211 Tire Manufacturing (except Retreading)

32622 Rubber and Plastics Hoses and

Belting Manufacturing

326220 Rubber and Plastics Hoses and Belting

Manufacturing

32629 Other Rubber Product

Manufacturing

326291 Rubber Product Manufacturing for

Mechanical Use

326299 All Other Rubber Product Manufacturing

327 Nonmetallic Mineral Product

Manufacturing

3271 Clay Product and Refractory

Manufacturing

32711 Pottery, Ceramics, and

Plumbing Fixture

Manufacturing

327111 Vitreous China Plumbing Fixture and China

and Earthenware Bathroom Accessories

Manufacturing

327112 Vitreous China, Fine Earthenware, and Other

Pottery Product Manufacturing (except

facilities primarily engaged in manufacturing

and selling pottery on site)

327113 Porcelain Electrical Supply Manufacturing
Table I. NAICS Codes

Toxics Release Inventory Reporting Form and Instructions I-9

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

327331 Concrete Block and Brick Manufacturing

327332 Concrete Pipe Manufacturing

32739 Other Concrete Product

Manufacturing

327390 Other Concrete Product Manufacturing

3274 Lime and Gypsum Product

Manufacturing

32741 Lime Manufacturing

327410 Lime Manufacturing

32742 Gypsum Product

Manufacturing

327420 Gypsum Product Manufacturing

3279 Other Nonmetallic Mineral

Product Manufacturing

32791 Abrasive Product

Manufacturing

327910 Abrasive Product Manufacturing

32799 All Other Nonmetallic Mineral

Product Manufacturing

327991 Cut Stone and Stone Product Manufacturing

327992 Ground or Treated Mineral and Earth

Manufacturing

327993 Mineral Wool Manufacturing

327999 All Other Miscellaneous Nonmetallic Mineral

Product Manufacturing

331 Primary Metal Manufacturing

3311 Iron and Steel Mills and

Ferroalloy Manufacturing

33111 Iron and Steel Mills and

Ferroalloy Manufacturing

331111 Iron and Steel Mills

331112 Electrometallurgical Ferroalloy Product

Manufacturing

3312 Steel Product Manufacturing

from Purchased Steel

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
Table I. NAICS Codes

I-10 Toxics Release Inventory Reporting Form and Instructions

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

331522 Nonferrous (except Aluminum) Die-Casting

Foundries

331524 Aluminum Foundries (except Die-Casting)

331525 Copper Foundries (except Die-Casting)

331528 Other Nonferrous Foundries (except DieCasting)

332 Fabricated Metal Product

Manufacturing

3321 Forging and Stamping

33211 Forging and Stamping

332111 Iron and Steel Forging

332112 Nonferrous Forging

332114 Custom Roll Forming

332115 Crown and Closure Manufacturing

332116 Metal Stamping

332117 Powder Metallurgy Part Manufacturing

3322 Cutlery and Handtool

Manufacturing

33221 Cutlery and Handtool

Manufacturing

332211 Cutlery and Flatware (except Precious)

Manufacturing

332212 Hand and Edge Tool Manufacturing

332213 Saw Blade and Handsaw Manufacturing

332214 Kitchen Utensil, Pot, and Pan Manufacturing

3323 Architectural and Structural

Metals Manufacturing
Table I. NAICS Codes

Toxics Release Inventory Reporting Form and Instructions I-11

33231 Plate Work and Fabricated

Structural Product

Manufacturing

332311 Prefabricated Metal Building and Component

Manufacturing

332312 Fabricated Structural Metal Manufacturing

332313 Plate Work Manufacturing

33232 Ornamental and Architectural

Metal Products

Manufacturing

332321 Metal Window and Door Manufacturing

332322 Sheet Metal Work Manufacturing

332323 Ornamental and Architectural Metal Work

Manufacturing

3324 Boiler, Tank, and Shipping

Container Manufacturing

33241 Power Boiler and Heat

Exchanger Manufacturing

332410 Power Boiler and Heat Exchanger

Manufacturing

33242 Metal Tank (Heavy Gauge)

Manufacturing

332420 Metal Tank (Heavy Gauge) Manufacturing

33243 Metal Can, Box, and Other

Metal Container (Light

Gauge) Manufacturing

332431 Metal Can Manufacturing

332439 Other Metal Container Manufacturing

3325 Hardware Manufacturing

33251 Hardware Manufacturing

332510 Hardware Manufacturing

3326 Spring and Wire Product

Manufacturing

33261 Spring and Wire Product

Manufacturing

332611 Spring (Heavy Gauge) Manufacturing

332612 Spring (Light Gauge) Manufacturing

332618 Other Fabricated Wire Product

Manufacturing

3327 Machine Shops; Turned

Product; and Screw, Nut and

Bolt Manufacturing

33271 Machine Shops

332710 Machine Shops

33272 Turned Product and Screw,

Nut and Bolt Manufacturing

332721 Precision Turned Product Manufacturing

332722 Bolt, Nut, Screw, Rivet, and Washer

Manufacturing

3328 Coating, Engraving, Heat

Treating, and Allied Activities

33281 Coating, Engraving, Heat

Treating, and Allied Activities

332811 Metal Heat Treating

332812 Metal Coating, Engraving (except Jewelry

and Silverware), and Allied Services to

Manufacturers

332813 Electroplating, Plating, Polishing, Anodizing,

and Coloring

3329 Other Fabricated Metal

Product Manufacturing

33291 Metal Valve Manufacturing

332911 Industrial Valve Manufacturing

332912 Fluid Power Valve and Hose Fitting

Manufacturing

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
Table I. NAICS Codes

I-12 Toxics Release Inventory Reporting Form and Instructions

332993 Ammunition (except Small Arms)

Manufacturing

332994 Small Arms Manufacturing

332995 Other Ordnance and Accessories

Manufacturing

332996 Fabricated Pipe and Pipe Fitting

Manufacturing

332997 Industrial Pattern Manufacturing

332998 Enameled Iron and Metal Sanitary Ware

Manufacturing

332999 All Other Miscellaneous Fabricated Metal

Product Manufacturing

333 Machinery Manufacturing

3331 Agriculture, Construction, and

Mining Machinery

Manufacturing

33311 Agricultural Implement

Manufacturing

333111 Farm Machinery and Equipment

Manufacturing

333112 Lawn and Garden Tractor and Home Lawn

and Garden Equipment Manufacturing

33312 Construction Machinery

Manufacturing

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, AirConditioning, and Commercial

Refrigeration

33341 Equipment Manufacturing

Ventilation, Heating, AirConditioning, and Commercial

Refrigeration Equipment

Manufacturing

333411 Air Purification Equipment Manufacturing
Table I. NAICS Codes

Toxics Release Inventory Reporting Form and Instructions I-13

333412 Industrial and Commercial Fan and Blower

Manufacturing

333414 Heating Equipment (except Warm Air

Furnaces) Manufacturing

333415 Air-Conditioning and Warm Air Heating

Equipment and Commercial and Industrial

Refrigeration Equipment Manufacturing

3335 Metalworking Machinery

Manufacturing

33351 Metalworking Machinery

Manufacturing

333511 Industrial Mold Manufacturing

333512 Machine Tool (Metal Cutting Types)

Manufacturing

333513 Machine Tool (Metal Forming Types)

Manufacturing

333514 Special Die and Tool, Die Set, Jig, and

Fixture Manufacturing

333515 Cutting Tool and Machine Tool Accessory

Manufacturing

333516 Rolling Mill Machinery and Equipment

Manufacturing

333518 Other Metalworking Machinery

Manufacturing

3336 Engine, Turbine, and Power

Transmission Equipment

Manufacturing

33361 Engine, Turbine, and Power

Transmission Equipment

Manufacturing

333611 Turbine and Turbine Generator Set Units

Manufacturing

333612 Speed Changer, Industrial High-Speed Drive,

and Gear Manufacturing

333613 Mechanical Power Transmission Equipment

Manufacturing

333618 Other Engine Equipment Manufacturing

3339 Other General Purpose

Machinery Manufacturing

33391 Pump and Compressor

Manufacturing

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

334112 Computer Storage Device Manufacturing
Table I. NAICS Codes

I-14 Toxics Release Inventory Reporting Form and Instructions

334113 Computer Terminal Manufacturing

334119 Other Computer Peripheral Equipment

Manufacturing

3342 Communications Equipment

Manufacturing

33421 Telephone Apparatus

Manufacturing

334210 Telephone Apparatus Manufacturing

33422 Radio and Television

Broadcasting and Wireless

Communications Equipment

Manufacturing

334220 Radio and Television Broadcasting and

Wireless Communications Equipment

Manufacturing

33429 Other Communications

Equipment Manufacturing

334290 Other Communications Equipment

Manufacturing

3343 Audio and Video Equipment

Manufacturing

33431 Audio and Video Equipment

Manufacturing

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

334419 Other Electronic Component Manufacturing

3345 Navigational, Measuring,

Electromedical, and Control

Instruments Manufacturing

33451 Navigational, Measuring,

Electromedical, and Control

Instruments Manufacturing

334510 Electromedical and Electrotherapeutic

Apparatus Manufacturing

334511 Search, Detection, Navigation, Guidance,

Aeronautical, and Nautical System and

Instrument Manufacturing

334512 Automatic Environmental Control

Manufacturing for Residential, Commercial,

and Appliance Use

334513 Instruments and Related Products

Manufacturing for Measuring, Displaying,

and Controlling Industrial Process Variables

334514 Totalizing Fluid Meter and Counting Device

Manufacturing

334515 Instrument Manufacturing for Measuring and

Testing Electricity and Electrical Signals

334516 Analytical Laboratory Instrument

Manufacturing

334517 Irradiation Apparatus Manufacturing

334518 Watch, Clock, and Part Manufacturing

334519 Other Measuring and Controlling Device

Manufacturing

3346 Manufacturing and

Reproducing Magnetic and

Optical Media

33461 Manufacturing and

Reproducing Magnetic and

Optical Media

334612 Prerecorded Compact Disc (except Software),

Tape, and Record Reproducing (except

facilities primarily engaged in mass

reproducing pre-recorded Video Cassettes,

and mass reproducing Video tape or disk)
Table I. NAICS Codes

Toxics Release Inventory Reporting Form and Instructions I-15

334613 Magnetic and Optical Recording Media

Manufacturing

335 Electrical Equipment,

Appliance, and Component

Manufacturing

3351 Electric Lighting Equipment

Manufacturing

33511 Electric Lamp Bulb and Part

Manufacturing

335110 Electric Lamp Bulb and Part Manufacturing

33512 Lighting Fixture

Manufacturing

335121 Residential Electric Lighting Fixture

Manufacturing

335122 Commercial, Industrial, and Institutional

Electric Lighting Fixture Manufacturing

335129 Other Lighting Equipment Manufacturing

3352 Household Appliance

Manufacturing

33521 Small Electrical Appliance

Manufacturing

335211 Electric Housewares and Household Fan

Manufacturing

335212 Household Vacuum Cleaner Manufacturing

33522 Major Appliance

Manufacturing

335221 Household Cooking Appliance

Manufacturing

335222 Household Refrigerator and Home Freezer

Manufacturing

335224 Household Laundry Equipment

Manufacturing

335228 Other Major Household Appliance

Manufacturing

3353 Electrical Equipment

Manufacturing

33531 Electrical Equipment

Manufacturing

335311 Power, Distribution, and Specialty

Transformer Manufacturing

335312 Motor and Generator Manufacturing (except

facilities primarily engaged in armature

rewinding on a factory basis)

335313 Switchgear and Switchboard Apparatus

Manufacturing

335314 Relay and Industrial Control Manufacturing

3359 Other Electrical Equipment

and Component

Manufacturing

33591 Battery Manufacturing

335911 Storage Battery Manufacturing

335912 Primary Battery Manufacturing

33592 Communication and Energy

Wire and Cable

Manufacturing

335921 Fiber Optic Cable Manufacturing

335929 Other Communication and Energy Wire

Manufacturing

33593 Wiring Device Manufacturing

335931 Current-Carrying Wiring Device

Manufacturing

335932 Noncurrent-Carrying Wiring Device

Manufacturing

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
Table I. NAICS Codes

I-16 Toxics Release Inventory Reporting Form and Instructions

336112 Light Truck and Utility Vehicle

Manufacturing

33612 Heavy Duty Truck

Manufacturing

336120 Heavy Duty Truck Manufacturing

3362 Motor Vehicle Body and

Trailer Manufacturing

33621 Motor Vehicle Body and

Trailer Manufacturing

336211 Motor Vehicle Body Manufacturing

336212 Truck Trailer Manufacturing

336213 Motor Home Manufacturing

336214 Travel Trailer and Camper Manufacturing

3363 Motor Vehicle Parts

Manufacturing

33631 Motor Vehicle Gasoline

Engine and Engine Parts

Manufacturing

336311 Carburetor, Piston, Piston Ring, and Valve

Manufacturing

336312 Gasoline Engine and Engine Parts

Manufacturing

33632 Motor Vehicle Electrical and

Electronic Equipment

Manufacturing

336321 Vehicular Lighting Equipment Manufacturing

336322 Other Motor Vehicle Electrical and Electronic

Equipment Manufacturing

33633 Motor Vehicle Steering and

Suspension Components

(except Spring)

Manufacturing

336330 Motor Vehicle Steering and Suspension

Components (except Spring) Manufacturing

33634 Motor Vehicle Brake System

Manufacturing

336340 Motor Vehicle Brake System Manufacturing

33635 Motor Vehicle Transmission

and Power Train Parts

Manufacturing

336350 Motor Vehicle Transmission and Power Train

Parts Manufacturing

33636 Motor Vehicle Seating and

Interior Trim Manufacturing

336360 Motor Vehicle Seating and Interior Trim

Manufacturing

33637 Motor Vehicle Metal Stamping

336370 Motor Vehicle Metal Stamping

33639 Other Motor Vehicle Parts

Manufacturing

336391 Motor Vehicle Air-Conditioning

Manufacturing

336399 All Other Motor Vehicle Parts Manufacturing

3364 Aerospace Product and Parts

Manufacturing

33641 Aerospace Product and Parts

Manufacturing

336411 Aircraft Manufacturing

336412 Aircraft Engine and Engine Parts

Manufacturing

336413 Other Aircraft Parts and Auxiliary Equipment

Manufacturing

336414 Guided Missile and Space Vehicle

Manufacturing

336415 Guided Missile and Space Vehicle Propulsion

Unit and Propulsion Unit Parts Manufacturing

336419 Other Guided Missile and Space Vehicle

Parts and Auxiliary Equipment

Manufacturing

3365 Railroad Rolling Stock

Manufacturing

33651 Railroad Rolling Stock

Manufacturing

336510 Railroad Rolling Stock Manufacturing

3366 Ship and Boat Building
Table I. NAICS Codes

Toxics Release Inventory Reporting Form and Instructions I-17

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

337211 Wood Office Furniture Manufacturing

337212 Custom Architectural Woodwork and

Millwork Manufacturing

337214 Office Furniture (except Wood)

Manufacturing

337215 Showcase, Partition, Shelving, and Locker

Manufacturing

3379 Other Furniture Related

Product Manufacturing

33791 Mattress Manufacturing

337910 Mattress Manufacturing

33792 Blind and Shade

Manufacturing

337920 Blind and Shade Manufacturing

339 Miscellaneous Manufacturing

3391 Medical Equipment and

Supplies Manufacturing

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
Table I. NAICS Codes

I-18 Toxics Release Inventory Reporting Form and Instructions

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)

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
Table I. NAICS Codes

Toxics Release Inventory Reporting Form and Instructions I-19

512220 Integrated Record Production/Distribution

512230 Music Publishers (except facilities primarily

Engaged n Music copyright authorizing use,

Music copyright buying and licensing, and

Music publishers working on their own

account)

516110 Internet Publishing and Broadcasting 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

1.2 NAICS codes that correspond

to SIC codes other than 20

through 39:

212 Mining (except Oil and Gas)

2121 Coal Mining

212111 Bituminous Coal and Lignite Surface Mining

212112 Bituminous Coal Underground Mining

212113 Anthracite Mining

2122 Metal Ore Mining

212221 Gold Ore Mining

212222 Silver Ore Mining

212231 Lead Ore and Zinc Ore Mining

212234 Copper Ore and Nickel Ore Mining

212299 All Other Metal Ore Mining

221 Utilities

22111 Electric Power Generation

(limited to facilities that combust

coal and/or oil for the purpose of

generating power for distribution

in commerce)

221111 Hydroelectric Power Generation

221112 Fossil Fuel Electric Power Generation

221113 Nuclear Electric Power Generation

221119 Other Electric Power Generation

221121 Electric Bulk Power Transmission and

Control

221122 Electric Power Distribution

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
Table I. NAICS Codes

I-20 Toxics Release Inventory Reporting Form and Instructions

425110 Business to Business Electronic Markets

(limited to facilities previously classified in

5169, Chemicals and Allied Products, NEC)

425120 Wholesale Trade Agents and Brokers

(limited to facilities previously classified in

5169, Chemicals and Allied Products, NEC)

562112 Hazardous Waste Collection (limited to

facilities primarily engaged in solvent

recovery services on a contract or fee basis)

562211 Hazardous Waste Treatment and Disposal

(limited to facilities regulated under the

Resource Conservation and Recovery Act,

subtitle C, 42 U.S.C. 6921, et seq.)

562212 Solid Waste Landfill (limited to facilities

regulated under the Resource Conservation

and Recovery Act, subtitle C, 42 U.S.C.

6921, et seq.)

562213 Solid Waste Combustors and Incinerators

(Limited to facilities regulated under the

Resource Conservation and Recovery Act,

subtitle C, 42 U.S.C. 6921 et seq.)

562219 Other Nonhazardous Waste Treatment

and Disposal (Limited to facilities regulated

under the Resource Conservation and

Recovery Act, subtitle C, 42 U.S.C. 6921 et

seq.)

562920 Materials Recovery Facilities (Limited to

facilities regulated under the Resource

Conservation and Recovery Act, subtitle C,

42 U.S.C. 6921 et seq.)
This Page Intentionally Left Blank
Table II. EPCRA Section 313 Chemical List For Reporting Year 2009

(including Toxic Chemical Categories)

Toxics Release Inventory Reporting Form and Instructions II-1

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 CAS Number Qualifier

Aluminum (fume or dust) 7429-90-5 Only if it is a fume or dust form.

Aluminum oxide (fibrous forms) 1344-28-1 Only if it is a fibrous form.

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)

7664-41-7 Only 10% of aqueous forms. 100% of

anhydrous forms.

Asbestos (friable) 1332-21-4 Only if it is a friable form.

Hydrochloric acid (acid aerosols including mists, vapors, gas,

fog, and other airborne forms of any particle size)

7647-01-0 Only if it is an aerosol form as

defined.

Nitrate compounds (water dissociable; reportable only when in

aqueous solution)

NA Only if in aqueous solution

Phosphorus (yellow or white) 7723-14-0 Only if it is a yellow or white form.

Sulfuric acid (acid aerosols including mists, vapors, gas, fog, and

other airborne forms of any particle size) 7664-93-9

Only if it is an aerosol form as

defined.

Vanadium (except when contained in an alloy) 7440-62-2 Except if it is contained in an alloy.

Zinc (fume or dust) 7440-66-6 Only if it is in a fume or dust form.

The qualifier for the following three chemicals is based on the chemical activity rather than the form of the chemical. These chemicals

are subject to EPCRA section 313 reporting requirements only when the indicated activity is performed.

Chemical/ Chemical Category CAS

Number Qualifier

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.)

NA 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.

Isopropyl alcohol (only persons who manufacture by the strong

acid process are subject, no supplier notification)

67-63-0 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.

Saccharin (only persons who manufacture are subject, no supplier

notification)

81-07-2 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.
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-2

Note: Chemicals may be added to or deleted from the list. The Emergency Planning and Community Right-to-Know Call Center

will provide up-to-date information on the status of these changes. See section B.3.c of the instructions for more information on the

de minimis values listed below. There are no de minimis levels for PBT chemicals since the de minimis exemption is not available

for these chemicals (an asterisk appears where a de minimis limit would otherwise appear in Table II). However, for purposes of the

supplier notification requirement only, such limits are provided in Appendix D.

Chemical Qualifiers

This table contains the list of individual EPCRA Section 313

chemicals and categories of chemicals subject to 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

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
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-3

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

Deminimis

CAS Number Chemical Name % Limit

71751-41-2 Abamectin [Avermectin B1] 1.0

30560-19-1 Acephate 1.0

(Acetylphosphoramidothioic acid O,Sdimethyl 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 *

[1,4:5,8-Dimethanonaphthalene,

1,2,3,4,10,10-hexachloro-1,4,4a,5,8,8ahexahydro-(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=-(1-methylethyl)-6-

(methylthio)-1,3,5,-triazine-2,4-diamine)

117-79-3 2-Aminoanthraquinone 0.1

60-09-3 4-Aminoazobenzene 0.1

92-67-1 4-Aminobiphenyl 0.1

82-28-0 1-Amino-2-methylanthraquinone 0.1

33089-61-1 Amitraz 1.0

61-82-5 Amitrole 0.1

7664-41-7 Ammonia 1.0

(includes anhydrous ammonia and aqueous

ammonia from water dissociable ammonium

Deminimis

CAS Number Chemical Name % Limit

salts and other sources; 10 percent of total

aqueous ammonia is reportable under this

listing)

101-05-3 Anilazine 1.0

[4,6-Dichloro-N-(2-chlorophenyl)-1,3,5-

triazin-2-amine]

62-53-3 Aniline 1.0

90-04-0 o-Anisidine 0.1

104-94-9 p-Anisidine 1.0

134-29-2 o-Anisidine hydrochloride 0.1

120-12-7 Anthracene 1.0

7440-36-0 Antimony 1.0

7440-38-2 Arsenic 0.1

1332-21-4 Asbestos (friable) 0.1

1912-24-9 Atrazine 1.0

(6-Chloro-N-ethyl-N=-(1-methylethyl)-

1,3,5-triazine-2,4-diamine)

7440-39-3 Barium 1.0

22781-23-3 Bendiocarb 1.0

[2,2-Dimethyl-1,3-benzodioxol-4-ol

methylcarbamate]

1861-40-1 Benfluralin 1.0

(N-Butyl-N-ethyl-2,6-dinitro-4-

(trifluoromethyl)benzenamine)

17804-35-2 Benomyl 1.0

98-87-3 Benzal chloride 1.0

55-21-0 Benzamide 1.0

71-43-2 Benzene 0.1

92-87-5 Benzidine 0.1

98-07-7 Benzoic trichloride 0.1

(Benzotrichloride)

191-24-2 Benzo(g,h,i)perylene *

98-88-4 Benzoyl chloride 1.0

94-36-0 Benzoyl peroxide 1.0

100-44-7 Benzyl chloride 1.0

7440-41-7 Beryllium 0.1

82657-04-3 Bifenthrin 1.0

92-52-4 Biphenyl 1.0

111-91-1 Bis(2-chloroethoxy) methane 1.0

111-44-4 Bis(2-chloroethyl) ether 1.0

542-88-1 Bis(chloromethyl) ether 0.1

108-60-1 Bis(2-chloro-1-methylethyl)ether 1.0

56-35-9 Bis(tributyltin) oxide 1.0

10294-34-5 Boron trichloride 1.0

7637-07-2 Boron trifluoride 1.0

314-40-9 Bromacil 1.0

(5-Bromo-6-methyl-3-(1-methylpropyl)-

2,4(1H,3H)-pyrimidinedione)

53404-19-6 Bromacil, lithium salt 1.0

[2,4(1H,3H)-Pyrimidinedione,5-bromo-6-

methyl-3-(1-methylpropyl), lithium salt]

7726-95-6 Bromine 1.0

35691-65-7 1-Bromo-1-(bromomethyl)- 1.0

1,3-propanedicarbonitrile

353-59-3 Bromochlorodifluoromethane 1.0

(Halon 1211)

75-25-2 Bromoform (Tribromomethane) 1.0
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-4

Deminimis

CAS Number Chemical Name % Limit

74-83-9 Bromomethane 1.0

(Methyl bromide)

75-63-8 Bromotrifluoromethane 1.0

(Halon 1301)

1689-84-5 Bromoxynil 1.0

(3,5-Dibromo-4-hydroxybenzonitrile)

1689-99-2 Bromoxynil octanoate 1.0

(Octanoic acid, 2,6-dibromo-4-

cyanophenylester)

357-57-3 Brucine 1.0

106-99-0 1,3-Butadiene 0.1

141-32-2 Butyl acrylate 1.0

71-36-3 n-Butyl alcohol 1.0

78-92-2 sec-Butyl alcohol 1.0

75-65-0 tert-Butyl alcohol 1.0

106-88-7 1,2-Butylene oxide 0.1

123-72-8 Butyraldehyde 1.0

7440-43-9 Cadmium 0.1

156-62-7 Calcium cyanamide 1.0

133-06-2 Captan 1.0

[1H-Isoindole-1,3(2H)-dione, 3a,4,7,7atetrahydro-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-Nphenyl-1,4-oxathiin-3-carboxamide)

120-80-9 Catechol 0.1

2439-01-2 Chinomethionat 1.0

[6-Methyl-1,3-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-methoxyprimidin2-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 1-(3-Chloroallyl)-3,5,7-triaza- 1.0

1-azoniaadamantane chloride

106-47-8 p-Chloroaniline 0.1

108-90-7 Chlorobenzene 1.0

510-15-6 Chlorobenzilate 1.0

[Benzeneacetic acid, 4-chloro-.alpha.- (4-

chlorophenyl)-.alpha.-hydroxy-, ethyl ester]

75-68-3 1-Chloro-1,1-difluoroethane 1.0

(HCFC-142b)

75-45-6 Chlorodifluoromethane 1.0

Deminimis

CAS Number Chemical Name % Limit

(HCFC-22)

75-00-3 Chloroethane (Ethyl chloride) 1.0

67-66-3 Chloroform 0.1

74-87-3 Chloromethane (Methyl chloride) 1.0

107-30-2 Chloromethyl methyl ether 0.1

563-47-3 3-Chloro-2-methyl-1-propene 0.1

104-12-1 p-Chlorophenyl isocyanate 1.0

76-06-2 Chloropicrin 1.0

126-99-8 Chloroprene 0.1

542-76-7 3-Chloropropionitrile 1.0

63938-10-3 Chlorotetrafluoroethane 1.0

354-25-6 1-Chloro-1,1,2,2- 1.0

tetrafluoroethane (HCFC-124a)

2837-89-0 2-Chloro-1,1,1,2- 1.0

tetrafluoroethane (HCFC-124)

1897-45-6 Chlorothalonil 0.1

[1,3-Benzenedicarbonitrile, 2,4,5,6-

tetrachloro-]

95-69-2 p-Chloro-o-toluidine 0.1

75-88-7 2-Chloro-1,1,1- 1.0

trifluoroethane (HCFC-133a)

75-72-9 Chlorotrifluoromethane (CFC-13) 1.0

460-35-5 3-Chloro-1,1,1- 1.0

trifluoropropane (HCFC-253fb)

5598-13-0 Chlorpyrifos methyl 1.0

[O,O-Dimethyl-O-(3,5,6-trichloro-2-

pyridyl)phosphorothioate]

64902-72-3 Chlorsulfuron 1.0

[2-Chloro-N-[[(4-methoxy-6-methyl-1,3,5-

triazin-2-yl)amino]carbonyl]

benzenesulfonamide]

7440-47-3 Chromium 1.0

4680-78-8 C.I. Acid Green 3 1.0

6459-94-5 C.I. Acid Red 114 0.1

569-64-2 C.I. Basic Green 4 1.0

989-38-8 C.I. Basic Red 1 1.0

1937-37-7 C.I. Direct Black 38 0.1

2602-46-2 C.I. Direct Blue 6 0.1

28407-37-6 C.I. Direct Blue 218 1.0

16071-86-6 C.I. Direct Brown 95 0.1

2832-40-8 C.I. Disperse Yellow 3 1.0

3761-53-3 C.I. Food Red 5 0.1

81-88-9 C.I. Food Red 15 1.0

3118-97-6 C.I. Solvent Orange 7 1.0

97-56-3 C.I. Solvent Yellow 3 0.1

842-07-9 C.I. Solvent Yellow 14 1.0

492-80-8 C.I. Solvent Yellow 34 0.1

(Auramine)

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
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-5

Deminimis

CAS Number Chemical Name % Limit

80-15-9 Cumene hydroperoxide 1.0

135-20-6 Cupferron 0.1

[Benzeneamine, N-hydroxyN-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-1-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-1,3,5-

thiadiazine-2-thione)

53404-60-7 Dazomet, sodium salt 1.0

[Tetrahydro-3,5-dimethyl-2H-1,3,5-

thiadiazine-2-thione, ion(1-), 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(1-methylethyl)-S-

(2,3-dichloro-2-propenyl) ester]

615-05-4 2,4-Diaminoanisole 0.1

39156-41-7 2,4-Diaminoanisole sulfate 0.1

101-80-4 4,4'-Diaminodiphenyl ether 0.1

95-80-7 2,4-Diaminotoluene 0.1

25376-45-8 Diaminotoluene (mixed isomers) 0.1

333-41-5 Diazinon 1.0

334-88-3 Diazomethane 1.0

132-64-9 Dibenzofuran 1.0

96-12-8 1,2-Dibromo-3- 0.1

chloropropane (DBCP)

106-93-4 1,2-Dibromoethane 0.1

(Ethylene dibromide)

124-73-2 Dibromotetrafluoroethane 1.0

(Halon 2402)

84-74-2 Dibutyl phthalate 1.0

1918-00-9 Dicamba 1.0

(3,6-Dichloro-2-methoxybenzoic acid)

99-30-9 Dichloran 1.0

[2,6-Dichloro-4-nitroaniline]

95-50-1 1,2-Dichlorobenzene 1.0

541-73-1 1,3-Dichlorobenzene 1.0

Deminimis

CAS Number Chemical Name % Limit

106-46-7 1,4-Dichlorobenzene 0.1

25321-22-6 Dichlorobenzene (mixed isomers) 0.1

91-94-1 3,3'-Dichlorobenzidine 0.1

612-83-9 3,3'-Dichlorobenzidine 0.1

dihydrochloride

64969-34-2 3,3'-Dichlorobenzidine sulfate 0.1

75-27-4 Dichlorobromomethane 0.1

764-41-0 1,4-Dichloro-2-butene 1.0

110-57-6 trans-1,4-Dichloro-2-butene 1.0

1649-08-7 1,2-Dichloro-1,1- 1.0

difluoroethane (HCFC-132b)

75-71-8 Dichlorodifluoromethane (CFC-12) 1.0

107-06-2 1,2-Dichloroethane (Ethylene 0.1

dichloride)

540-59-0 1,2-Dichloroethylene 1.0

1717-00-6 1,1-Dichloro-1-fluoroethane 1.0

(HCFC-141b)

75-43-4 Dichlorofluoromethane (HCFC-21) 1.0

75-09-2 Dichloromethane (Methylene 0.1

chloride)

127564-92-5 Dichloropentafluoropropane 1.0

13474-88-9 1,1-Dichloro-1,2,2,3,3- 1.0

pentafluoropropane (HCFC-225cc)

111512-56-2 1,1-Dichloro-1,2,3,3,3- 1.0

pentafluoropropane (HCFC-225eb)

422-44-6 1,2-Dichloro-1,1,2,3,3- 1.0

pentafluoropropane (HCFC-225bb)

431-86-7 1,2-Dichloro-1,1,3,3,3- 1.0

pentafluoropropane (HCFC-225da)

507-55-1 1,3-Dichloro-1,1,2,2,3- 1.0

pentafluoropropane (HCFC-225cb)

136013-79-1 1,3-Dichloro-1,1,2,3,3- 1.0

pentafluoropropane (HCFC-225ea)

128903-21-9 2,2-Dichloro-1,1,1,3,3- 1.0

pentafluoropropane (HCFC-225aa)

422-48-0 2,3-Dichloro-1,1,1,2,3- 1.0

pentafluoropropane (HCFC-225ba)

422-56-0 3,3-Dichloro-1,1,1,2,2- 1.0

pentafluoropropane (HCFC-225ca)

97-23-4 Dichlorophene 1.0

[2,2'-Methylenebis(4-chlorophenol)]

120-83-2 2,4-Dichlorophenol 1.0

78-87-5 1,2-Dichloropropane 1.0

10061-02-6 trans-1,3-Dichloropropene 0.1

78-88-6 2,3-Dichloropropene 1.0

542-75-6 1,3-Dichloropropylene 0.1

76-14-2 Dichlorotetrafluoroethane 1.0

(CFC-114)

34077-87-7 Dichlorotrifluoroethane 1.0

90454-18-5 Dichloro-1,1,2-trifluoroethane 1.0

812-04-4 1,1-Dichloro-1,2,2- 1.0

trifluoroethane (HCFC-123b)

354-23-4 1,2-Dichloro-1,1,2- 1.0

trifluoroethane (HCFC-123a)

306-83-2 2,2-Dichloro-1,1,1- 1.0

trifluoroethane (HCFC-123)

62-73-7 Dichlorvos 0.1

[Phosphoric acid, 2,2-dichloroethenyl

dimethyl ester]
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-6

Deminimis

CAS Number Chemical Name % Limit

51338-27-3 Diclofop methyl 1.0

[2-[4-(2,4-Dichlorophenoxy)phenoxy]

propanoic acid, methyl ester]

115-32-2 Dicofol 1.0

[Benzenemethanol, 4-chloro77-73-6 Dicyclopentadiene 1.0

1464-53-5 Diepoxybutane 0.1

111-42-2 Diethanolamine 1.0

38727-55-8 Diethatyl ethyl 1.0

117-81-7 Di(2-ethylhexyl) phthalate (DEHP) 0.1

64-67-5 Diethyl sulfate 0.1

35367-38-5 Diflubenzuron 1.0

101-90-6 Diglycidyl resorcinol ether 0.1

94-58-6 Dihydrosafrole 0.1

55290-64-7 Dimethipin 1.0

[2,3-Dihydro-5,6-dimethyl-1,4-dithiin

1,1,4,4-tetraoxide]

60-51-5 Dimethoate 1.0

119-90-4 3,3'-Dimethoxybenzidine 0.1

20325-40-0 3,3'-Dimethoxybenzidine 0.1

dihydrochloride (o-Dianisidine

dihydrochloride)

111984-09-9 3,3'-Dimethoxybenzidine 0.1

hydrochloride (o-Dianisidine hydrochloride)

124-40-3 Dimethylamine 1.0

2300-66-5 Dimethylamine dicamba 1.0

60-11-7 4-Dimethylaminoazobenzene 0.1

121-69-7 N,N-Dimethylaniline 1.0

119-93-7 3,3'-Dimethylbenzidine (o-Tolidine) 0.1

612-82-8 3,3'-Dimethylbenzidine 0.1

dihydrochloride (o-Tolidine

dihydrochloride)

41766-75-0 3,3'-Dimethylbenzidine 0.1

dihydrofluoride (o-Tolidine dihydrofluoride)

79-44-7 Dimethylcarbamyl chloride 0.1

2524-03-0 Dimethyl 1.0

chlorothiophosphate

68-12-2 N,N-Dimethylformamide 1.0

57-14-7 1,1-Dimethyl hydrazine 0.1

105-67-9 2,4-Dimethylphenol 1.0

131-11-3 Dimethyl phthalate 1.0

77-78-1 Dimethyl sulfate 0.1

99-65-0 m-Dinitrobenzene 1.0

528-29-0 o-Dinitrobenzene 1.0

100-25-4 p-Dinitrobenzene 1.0

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(2.2.1)heptane-2,3-

Deminimis

CAS Number Chemical Name % Limit

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,Sdipropyl 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

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]
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-7

Deminimis

CAS Number Chemical Name % Limit

69806-50-4 Fluazifop butyl 1.0

[2-[4-[[5-(Trifluoromethyl)-2-

pyridinyl]oxy]phenoxy]propanoic acid,

butyl ester]

2164-17-2 Fluometuron 1.0

[Urea, N,N-dimethyl-N=-[3-

(trifluoromethyl)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-methylsulfonyl-2-nitrobenzamide]

50-00-0 Formaldehyde 0.1

64-18-6 Formic acid 1.0

76-13-1 Freon 113 1.0

[Ethane, 1,1,2-trichloro-1,2,2,-trifluoro-]

76-44-8 Heptachlor *

[1,4,5,6,7,8,8-Heptachloro-3a, 4,7,7atetrahydro-4,7-methano-1H-indene]

118-74-1 Hexachlorobenzene *

87-68-3 Hexachloro-1,3-butadiene 1.0

319-84-6 alpha-Hexachlorocyclohexane 0.1

77-47-4 Hexachlorocyclopentadiene 1.0

67-72-1 Hexachloroethane 0.1

1335-87-1 Hexachloronaphthalene 1.0

70-30-4 Hexachlorophene 1.0

680-31-9 Hexamethylphosphoramide 0.1

110-54-3 n-Hexane 1.0

51235-04-2 Hexazinone 1.0

67485-29-4 Hydramethylnon 1.0

[Tetrahydro-5,5-dimethyl-2(1H)-

pyrimidinone[3-[4-(trifluoromethyl)phenyl]-

1-[2-[4-(trifluoromethyl)phenyl]ethenyl]-2-

propenylidene]hydrazone]

302-01-2 Hydrazine 0.1

10034-93-2 Hydrazine sulfate 0.1

7647-01-0 Hydrochloric acid 1.0

(acid aerosols including mists, vapors, gas,

fog, and other airborne forms of any particle

size)

74-90-8 Hydrogen cyanide 1.0

7664-39-3 Hydrogen fluoride 1.0

123-31-9 Hydroquinone 1.0

35554-44-0 Imazalil 1.0

[1-[2-(2,4-Dichlorophenyl)-2-(2-

propenyloxy)ethyl]-1H-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[(1- 1.0

methylethyl)amino]phosphinothioyl]oxy]

Deminimis

CAS Number Chemical Name % Limit

benzoic acid 1-methylethyl ester]

67-63-0 Isopropyl alcohol 1.0

(only persons who manufacture by the

strong acid process are subject, no supplier

notification)

80-05-7 4,4'-Isopropylidenediphenol 1.0

120-58-1 Isosafrole 1.0

77501-63-4 Lactofen 1.0

[Benzoic acid, 5-[2-Chloro-4-

(trifluoromethyl)phenoxy]-2-nitro-, 2-

ethoxy-1-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-,

(1.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 (MBT) 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-1,2,4-

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, 1,1'-(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
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-8

Deminimis

CAS Number Chemical Name % Limit

60-34-4 Methyl hydrazine 1.0

74-88-4 Methyl iodide 1.0

108-10-1 Methyl isobutyl ketone 1.0

624-83-9 Methyl isocyanate 1.0

556-61-6 Methyl isothiocyanate 1.0

[Isothiocyanatomethane]

75-86-5 2-Methyllactonitrile 1.0

80-62-6 Methyl methacrylate 1.0

924-42-5 N-Methylolacrylamide 1.0

298-00-0 Methyl parathion 1.0

109-06-8 2-Methylpyridine 1.0

872-50-4 N-Methyl-2-pyrrolidone 1.0

9006-42-2 Metiram 1.0

21087-64-9 Metribuzin 1.0

7786-34-7 Mevinphos 1.0

90-94-8 Michler’s ketone 0.1

2212-67-1 Molinate 1.0

(1H-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, 1,1'-thiobis[2-chloro-]

88671-89-0 Myclobutanil 1.0

[.alpha.-Butyl-.alpha.-(4-chlorophenyl)-1H1,2,4-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)

7697-37-2 Nitric acid 1.0

139-13-9 Nitrilotriacetic acid 0.1

100-01-6 p-Nitroaniline 1.0

99-59-2 5-Nitro-o-anisidine 1.0

98-95-3 Nitrobenzene 0.1

92-93-3 4-Nitrobiphenyl 0.1

1836-75-5 Nitrofen 0.1

[Benzene, 2,4-dichloro-1-(4-nitrophenoxy)-]

51-75-2 Nitrogen mustard 0.1

[2-Chloro-N-(2-chloroethyl)-Nmethylethanamine]

55-63-0 Nitroglycerin 1.0

88-75-5 2-Nitrophenol 1.0

100-02-7 4-Nitrophenol 1.0

79-46-9 2-Nitropropane 0.1

924-16-3 N-Nitrosodi-n-butylamine 0.1

55-18-5 N-Nitrosodiethylamine 0.1

62-75-9 N-Nitrosodimethylamine 0.1

86-30-6 N-Nitrosodiphenylamine 1.0

156-10-5 p-Nitrosodiphenylamine 1.0

621-64-7 N-Nitrosodi-n-propylamine 0.1

759-73-9 N-Nitroso-N-ethylurea 0.1

684-93-5 N-Nitroso-N-methylurea 0.1

Deminimis

CAS Number Chemical Name % Limit

4549-40-0 N-Nitrosomethylvinylamine 0.1

59-89-2 N-Nitrosomorpholine 0.1

16543-55-8 N-Nitrosonornicotine 0.1

100-75-4 N-Nitrosopiperidine 0.1

99-55-8 5-Nitro-o-toluidine 1.0

27314-13-2 Norflurazon 1.0

[4-Chloro-5-(methylamino)-2-[3-

(trifluoromethyl)phenyl]-3(2H)-

pyridazinone]

2234-13-1 Octachloronaphthalene 1.0

29082-74-4 Octachlorostyrene *

19044-88-3 Oryzalin 1.0

[4-(Dipropylamino)-3,5-dinitrobenzene

sulfonamide]

20816-12-0 Osmium tetroxide 1.0

301-12-2 Oxydemeton methyl 1.0

[S-(2-(Ethylsulfinyl)ethyl) O,O-dimethyl

ester phosphorothioic acid]

19666-30-9 Oxydiazon 1.0

[3-[2,4-Dichloro-5-(1-

methylethoxy)phenyl]- 5-(1,1-

dimethylethyl)-1,3,4-oxadiazol-2(3H)-one]

42874-03-3 Oxyfluorfen 1.0

10028-15-6 Ozone 1.0

123-63-7 Paraldehyde 1.0

1910-42-5 Paraquat dichloride 1.0

56-38-2 Parathion 1.0

[Phosphorothioic acid, O,O-diethyl-O-(4-

nitrophenyl)ester]

1114-71-2 Pebulate 1.0

[Butylethylcarbamothioic acid S-propyl

ester]

40487-42-1 Pendimethalin *

[N-(1-Ethylpropyl)-3,4-dimethyl-2,6-

dinitrobenzenamine]

608-93-5 Pentachlorobenzene *

76-01-7 Pentachloroethane 1.0

87-86-5 Pentachlorophenol (PCP) 0.1

57-33-0 Pentobarbital sodium 1.0

79-21-0 Peracetic acid 1.0

594-42-3 Perchloromethyl mercaptan 1.0

52645-53-1 Permethrin 1.0

[3-(2,2-Dichloroethenyl)-2,2-

dimethylcyclopropanecarboxylic acid, (3-

phenoxyphenyl) methyl ester]

85-01-8 Phenanthrene 1.0

108-95-2 Phenol 1.0

26002-80-2 Phenothrin 1.0

[2,2-Dimethyl-3-(2-methyl-1-

propenyl)cyclopropanecarboxylic acid (3-

phenoxyphenyl)methyl ester]

95-54-5 1,2-Phenylenediamine 1.0

108-45-2 1,3-Phenylenediamine 1.0

106-50-3 p-Phenylenediamine 1.0

615-28-1 1,2-Phenylenediamine dihydro- 1.0

chloride

624-18-0 1,4-Phenylenediamine dihydro- 1.0

chloride

90-43-7 2-Phenylphenol 1.0
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-9

Deminimis

CAS Number Chemical Name % Limit

57-41-0 Phenytoin 0.1

75-44-5 Phosgene 1.0

7803-51-2 Phosphine 1.0

7723-14-0 Phosphorus (yellow or white) 1.0

85-44-9 Phthalic anhydride 1.0

1918-02-1 Picloram 1.0

88-89-1 Picric acid 1.0

51-03-6 Piperonyl butoxide 1.0

29232-93-7 Pirimiphos methyl 1.0

[O-(2-(Diethylamino)-6-methyl-4-

pyrimidinyl)-O,Odimethylphosphorothioate]

1336-36-3 Polychlorinated biphenyls *

(PCBs)

7758-01-2 Potassium bromate 0.1

128-03-0 Potassium dimethyldithio- 1.0

carbamate

137-41-7 Potassium N-methyldithio- 1.0

carbamate

41198-08-7 Profenofos 1.0

[O-(4-Bromo-2-chlorophenyl)-O-ethyl-Spropyl phosphorothioate]

7287-19-6 Prometryn 1.0

[N,N’-Bis(1-methylethyl)-6-methylthio1,3,5-triazine-2,4-diamine]

23950-58-5 Pronamide 1.0

1918-16-7 Propachlor 1.0

[2-Chloro-N-(1-methylethyl)-Nphenylacetamide]

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

[1-[2-(2,4-Dichlorophenyl)-4-propyl-1,3-

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-(1-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-

Deminimis

CAS Number Chemical Name % Limit

dimethyl-3-(2-methyl-1-propenyl)

cyclopropanecarboxylate]

81-07-2 Saccharin (only persons who 1.0

manufacture are subject, no supplier

notification)

94-59-7 Safrole 0.1

7782-49-2 Selenium 1.0

74051-80-2 Sethoxydim 1.0

[2-[1-(Ethoxyimino)butyl]-5-[2-

(ethylthio)propyl]-3-hydroxyl-2-

cyclohexen-1-one]

7440-22-4 Silver 1.0

122-34-9 Simazine 1.0

26628-22-8 Sodium azide 1.0

1982-69-0 Sodium dicamba 1.0

[3,6-Dichloro-2-methoxybenzoic acid,

sodium salt]

128-04-1 Sodium dimethyldithiocarbamate 1.0

62-74-8 Sodium fluoroacetate 1.0

7632-00-0 Sodium nitrite 1.0

131-52-2 Sodium pentachlorophenate 1.0

132-27-4 Sodium o-phenylphenoxide 0.1

100-42-5 Styrene 0.1

96-09-3 Styrene oxide 0.1

7664-93-9 Sulfuric acid 1.0

(acid aerosols including mists, vapors, gas,

fog, and other airborne forms of any particle

size)

2699-79-8 Sulfuryl fluoride (Vikane) 1.0

35400-43-2 Sulprofos 1.0

[O-Ethyl O-[4-(methylthio)phenyl]

phosphorodithioic acid S-propylester]

34014-18-1 Tebuthiuron 1.0

[N-[5-(1,1-Dimethylethyl)-1,3,4-thiadiazol2-yl]-N,N’-dimethylurea]

3383-96-8 Temephos 1.0

5902-51-2 Terbacil 1.0

[5-Chloro-3-(1,1-dimethylethyl)-6-methyl2,4(1H,3H)-pyrimidinedione]

79-94-7 Tetrabromobisphenol A *

630-20-6 1,1,1,2-Tetrachloroethane 1.0

79-34-5 1,1,2,2-Tetrachloroethane 1.0

127-18-4 Tetrachloroethylene 0.1

(Perchloroethylene)

354-11-0 1,1,1,2-Tetrachloro-2-fluoroethane 1.0

(HCFC-121a)

354-14-3 1,1,2,2-Tetrachloro-1-fluoroethane 1.0

(HCFC-121)

961-11-5 Tetrachlorvinphos 1.0

[Phosphoric acid, 2-chloro-1-(2,4,5-

trichlorophenyl) ethenyl dimethyl ester]

64-75-5 Tetracycline hydrochloride 1.0

7696-12-0 Tetramethrin 1.0

[2,2-Dimethyl-3-(2-methyl-1-propenyl)

cyclopropanecarboxylic acid (1,3,4,5,6,7-

hexahydro-1,3-dioxo-2H-isoindol-2-

yl)methyl ester]
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-10

Deminimis

CAS Number Chemical Name % Limit

7440-28-0 Thallium 1.0

148-79-8 Thiabendazole 1.0

[2-(4-Thiazolyl)-1H-benzimidazole]

62-55-5 Thioacetamide 0.1

28249-77-6 Thiobencarb 1.0

[Carbamic acid, diethylthio-, S-(pchlorobenzyl)ester]

139-65-1 4,4'-Thiodianiline 0.1

59669-26-0 Thiodicarb 1.0

23564-06-9 Thiophanate ethyl 1.0

[[1,2-Phenylenebis(iminocarbonothioyl)]

biscarbamic acid diethylester]

23564-05-8 Thiophanate methyl 1.0

79-19-6 Thiosemicarbazide 1.0

62-56-6 Thiourea 0.1

137-26-8 Thiram 1.0

1314-20-1 Thorium dioxide 1.0

7550-45-0 Titanium tetrachloride 1.0

108-88-3 Toluene 1.0

584-84-9 Toluene-2,4-diisocyanate 0.1

91-08-7 Toluene-2,6-diisocyanate 0.1

26471-62-5 Toluene diisocyanate (mixed 0.1

isomers)

95-53-4 o-Toluidine 0.1

636-21-5 o-Toluidine hydrochloride 0.1

8001-35-2 Toxaphene *

43121-43-3 Triadimefon 1.0

[1-(4-Chlorophenoxy)-3,3-di-methyl-1-(1H1,2,4- triazol-1-yl)-2-butanone]

2303-17-5 Triallate 1.0

68-76-8 Triaziquone 1.0

[2,5-Cyclohexadiene-1,4-dione, 2,3,5-tris(1-

aziridinyl)-]

101200-48-0 Tribenuron methyl 1.0

[2-[[[[(4-Methoxy-6-methyl-1,3,5-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 (DEF)

52-68-6 Trichlorfon 1.0

[Phosphoric acid,(2,2,2-trichloro-l-hydroxyethyl)-, 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-11) 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-dipropyl4-(trifluoromethyl)-]

Deminimis

CAS Number Chemical Name % Limit

26644-46-2 Triforine 1.0

[N,N’-[1,4-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 Trypan blue 0.1

51-79-6 Urethane (Ethyl carbamate) 0.1

7440-62-2 Vanadium (except when contained 1.0

in an alloy)

50471-44-8 Vinclozolin 1.0

[3-(3,5-Dichlorophenyl)-5-ethenyl-5-

methyl-2,4-oxazolidinedione]

108-05-4 Vinyl acetate 0.1

593-60-2 Vinyl bromide 0.1

75-01-4 Vinyl chloride 0.1

75-35-4 Vinylidene chloride 1.0

108-38-3 m-Xylene 1.0

95-47-6 o-Xylene 1.0

106-42-3 p-Xylene 1.0

1330-20-7 Xylene (mixed isomers) 1.0

87-62-7 2,6-Xylidine 0.1

7440-66-6 Zinc (fume or dust) 1.0

12122-67-7 Zineb 1.0

[Carbamodithioic acid, 1,2-ethanediyibis-,

zinc complex]
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-11

b. Individually Listed Toxic Chemicals Arranged

by CAS Number

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

50-00-0 Formaldehyde 0.1

51-03-6 Piperonyl butoxide 1.0

51-21-8 Fluorouracil (5-Fluorouracil) 1.0

51-28-5 2,4-Dinitrophenol 1.0

51-75-2 Nitrogen mustard 0.1

[2-Chloro-N-(2-chloroethyl)-Nmethylethanamine]

51-79-6 Urethane (Ethyl carbamate) 0.1

52-68-6 Trichlorfon 1.0

[Phosphonic acid, (2,2,2-trichloro-1-

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-,

(1.alpha.,2.alpha.,3.beta.,4.alpha,

5.alpha.,6.beta.)-]

59-89-2 N-Nitrosomorpholine 0.1

60-09-3 4-Aminoazobenzene 0.1

60-11-7 4-Dimethylaminoazobenzene 0.1

60-34-4 Methyl hydrazine 1.0

60-35-5 Acetamide 0.1

60-51-5 Dimethoate 1.0

61-82-5 Amitrole 0.1

62-53-3 Aniline 1.0

62-55-5 Thioacetamide 0.1

62-56-6 Thiourea 0.1

62-73-7 Dichlorvos 0.1

[Phosphoric acid, 2,2-dichloroethenyl

dimethyl ester]

62-74-8 Sodium fluoroacetate 1.0

62-75-9 N-Nitrosodimethylamine 0.1

63-25-2 Carbaryl 1.0

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

[1-Naphthalenol, methylcarbamate]

64-18-6 Formic acid 1.0

64-67-5 Diethyl sulfate 0.1

64-75-5 Tetracycline hydrochloride 1.0

67-56-1 Methanol 1.0

67-63-0 Isopropyl alcohol 1.0

(only persons who manufacture by the

strong acid process are subject, no supplier

notification)

67-66-3 Chloroform 0.1

67-72-1 Hexachloroethane 0.1

68-12-2 N,N-Dimethylformamide 1.0

68-76-8 Triaziquone 1.0

[2,5-Cyclohexadiene-1,4-dione, 2,3,5-

tris(1-aziridinyl)-]

70-30-4 Hexachlorophene 1.0

71-36-3 n-Butyl alcohol 1.0

71-43-2 Benzene 0.1

71-55-6 1,1,1-Trichloroethane (Methyl 1.0

chloroform)

72-43-5 Methoxychlor *

[Benzene, 1,1'-(2,2,2-

trichloroethylidene)bis[4-methoxy-]

72-57-1 Trypan blue 0.1

74-83-9 Bromomethane (Methyl bromide) 1.0

74-85-1 Ethylene 1.0

74-87-3 Chloromethane (Methyl chloride) 1.0

74-88-4 Methyl iodide 1.0

74-90-8 Hydrogen cyanide 1.0

74-95-3 Methylene bromide 1.0

75-00-3 Chloroethane (Ethyl chloride) 1.0

75-01-4 Vinyl chloride 0.1

75-05-8 Acetonitrile 1.0

75-07-0 Acetaldehyde 0.1

75-09-2 Dichloromethane (Methylene 0.1

chloride)

75-15-0 Carbon disulfide 1.0

75-21-8 Ethylene oxide 0.1

75-25-2 Bromoform (Tribromomethane) 1.0

75-27-4 Dichlorobromomethane 0.1

75-34-3 Ethylidene dichloride 1.0

75-35-4 Vinylidene chloride 1.0

75-43-4 Dichlorofluoromethane 1.0

(HCFC-21)

75-44-5 Phosgene 1.0

75-45-6 Chlorodifluoromethane 1.0

(HCFC-22)

75-55-8 Propyleneimine 0.1

75-56-9 Propylene oxide 0.1

75-63-8 Bromotrifluoromethane 1.0

(Halon 1301)

75-65-0 tert-Butyl alcohol 1.0

75-68-3 1-Chloro-1,1-difluoroethane 1.0

(HCFC-142b)

75-69-4 Trichlorofluoromethane (CFC-11) 1.0

75-71-8 Dichlorodifluoromethane 1.0

(CFC-12)

75-72-9 Chlorotrifluoromethane (CFC-13) 1.0
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-12

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

75-86-5 2-Methyllactonitrile 1.0

75-88-7 2-Chloro-1,1,1-trifluoroethane 1.0

(HCFC-133a)

76-01-7 Pentachloroethane 1.0

76-02-8 Trichloroacetyl chloride 1.0

76-06-2 Chloropicrin 1.0

76-13-1 Freon 113 1.0

[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 *

[1,4,5,6,7,8,8-Heptachloro-3a,4,7,7atetrahydro-4,7-methano-1H-indene]

76-87-9 Triphenyltin hydroxide 1.0

77-47-4 Hexachlorocyclopentadiene 1.0

77-73-6 Dicyclopentadiene 1.0

77-78-1 Dimethyl sulfate 0.1

78-48-8 S,S,S-Tributyltrithiophosphate 1.0

(DEF)

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)

81-88-9 C.I. Food Red 15 1.0

82-28-0 1-Amino-2-methylanthraquinone 0.1

82-68-8 Quintozene 1.0

[Pentachloronitrobenzene]

84-74-2 Dibutyl phthalate 1.0

85-01-8 Phenanthrene 1.0

85-44-9 Phthalic anhydride 1.0

86-30-6 N-Nitrosodiphenylamine 1.0

87-62-7 2,6-Xylidine 0.1

87-68-3 Hexachloro-1,3-butadiene 1.0

87-86-5 Pentachlorophenol (PCP) 0.1

88-06-2 2,4,6-Trichlorophenol 0.1

88-75-5 2-Nitrophenol 1.0

88-85-7 Dinitrobutyl phenol (Dinoseb) 1.0

88-89-1 Picric acid 1.0

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

90-04-0 o-Anisidine 0.1

90-43-7 2-Phenylphenol 1.0

90-94-8 Michler’s ketone 0.1

91-08-7 Toluene-2,6-diisocyanate 0.1

91-20-3 Naphthalene 0.1

91-22-5 Quinoline 1.0

91-59-8 beta-Naphthylamine 0.1

91-94-1 3,3'-Dichlorobenzidine 0.1

92-52-4 Biphenyl 1.0

92-67-1 4-Aminobiphenyl 0.1

92-87-5 Benzidine 0.1

92-93-3 4-Nitrobiphenyl 0.1

93-65-2 Mecoprop 0.1

94-11-1 2,4-D isopropyl ester 0.1

94-36-0 Benzoyl peroxide 1.0

94-58-6 Dihydrosafrole 0.1

94-59-7 Safrole 0.1

94-74-6 Methoxone 0.1

((4-Chloro-2-methylphenoxy) acetic acid)

(MCPA)

94-75-7 2,4-D [Acetic acid, (2,4- 0.1

dichlorophenoxy)-]

94-80-4 2,4-D butyl ester 0.1

94-82-6 2,4-DB 1.0

95-47-6 o-Xylene 1.0

95-48-7 o-Cresol 1.0

95-50-1 1,2-Dichlorobenzene 1.0

95-53-4 o-Toluidine 0.1

95-54-5 1,2-Phenylenediamine 1.0

95-63-6 1,2,4-Trimethylbenzene 1.0

95-69-2 p-Chloro-o-toluidine 0.1

95-80-7 2,4-Diaminotoluene 0.1

95-95-4 2,4,5-Trichlorophenol 1.0

96-09-3 Styrene oxide 0.1

96-12-8 1,2-Dibromo-3-chloropropane 0.1

(DBCP)

96-18-4 1,2,3-Trichloropropane 0.1

96-33-3 Methyl acrylate 1.0

96-45-7 Ethylene thiourea 0.1

97-23-4 Dichlorophene 1.0

[2,2'-Methylenebis(4-chlorophenol)]

97-56-3 C.I. Solvent Yellow 3 0.1

98-07-7 Benzoic trichloride 0.1

(Benzotrichloride)

98-82-8 Cumene 1.0

98-86-2 Acetophenone 1.0

98-87-3 Benzal chloride 1.0

98-88-4 Benzoyl chloride 1.0

98-95-3 Nitrobenzene 0.1

99-30-9 Dichloran [2,6-Dichloro-4- 1.0

nitroaniline]

99-55-8 5-Nitro-o-toluidine 1.0

99-59-2 5-Nitro-o-anisidine 1.0

99-65-0 m-Dinitrobenzene 1.0

100-01-6 p-Nitroaniline 1.0

100-02-7 4-Nitrophenol 1.0

100-25-4 p-Dinitrobenzene 1.0

100-41-4 Ethylbenzene 0.1
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-13

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

100-42-5 Styrene 0.1

100-44-7 Benzyl chloride 1.0

100-75-4 N-Nitrosopiperidine 0.1

101-05-3 Anilazine 1.0

[4,6-Dichloro-N-(2-chlorophenyl)-1,3,5-

triazin-2-amine]

101-14-4 4,4'-Methylenebis(2-chloroaniline) 0.1

(MBOCA)

101-61-1 4,4'-Methylenebis(N,N- 0.1

dimethyl)benzenamine

101-77-9 4,4'-Methylenedianiline 0.1

101-80-4 4,4'-Diaminodiphenyl ether 0.1

101-90-6 Diglycidyl resorcinol ether 0.1

104-12-1 p-Chlorophenyl isocyanate 1.0

104-94-9 p-Anisidine 1.0

105-67-9 2,4-Dimethylphenol 1.0

106-42-3 p-Xylene 1.0

106-44-5 p-Cresol 1.0

106-46-7 1,4-Dichlorobenzene 0.1

106-47-8 p-Chloroaniline 0.1

106-50-3 p-Phenylenediamine 1.0

106-51-4 Quinone 1.0

106-88-7 1,2-Butylene oxide 0.1

106-89-8 Epichlorohydrin 0.1

106-93-4 1,2-Dibromoethane 0.1

(Ethylene dibromide)

106-99-0 1,3-Butadiene 0.1

107-02-8 Acrolein 1.0

107-05-1 Allyl chloride 1.0

107-06-2 1,2-Dichloroethane (Ethylene 0.1

dichloride)

107-11-9 Allylamine 1.0

107-13-1 Acrylonitrile 0.1

107-18-6 Allyl alcohol 1.0

107-19-7 Propargyl alcohol 1.0

107-21-1 Ethylene glycol 1.0

107-30-2 Chloromethyl methyl ether 0.1

108-05-4 Vinyl acetate 0.1

108-10-1 Methyl isobutyl ketone 1.0

108-31-6 Maleic anhydride 1.0

108-38-3 m-Xylene 1.0

108-39-4 m-Cresol 1.0

108-45-2 1,3-Phenylenediamine 1.0

108-60-1 Bis(2-chloro-1-methylethyl) ether 1.0

108-88-3 Toluene 1.0

108-90-7 Chlorobenzene 1.0

108-93-0 Cyclohexanol 1.0

108-95-2 Phenol 1.0

109-06-8 2-Methylpyridine 1.0

109-77-3 Malononitrile 1.0

109-86-4 2-Methoxyethanol 1.0

110-54-3 n-Hexane 1.0

110-57-6 trans-1,4-Dichloro-2-butene 1.0

110-80-5 2-Ethoxyethanol 1.0

110-82-7 Cyclohexane 1.0

110-86-1 Pyridine 1.0

111-42-2 Diethanolamine 1.0

111-44-4 Bis(2-chloroethyl) ether 1.0

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

111-91-1 Bis(2-chloroethoxy) methane 1.0

114-26-1 Propoxur 1.0

[Phenol, 2-(1-methylethoxy)-,

methylcarbamate]

115-07-1 Propylene (Propene) 1.0

115-28-6 Chlorendic acid 0.1

115-32-2 Dicofol 1.0

[Benzenemethanol, 4-chloro-.alpha.-4-

(chlorophenyl)-.alpha.-(trichloromethyl)-]

116-06-3 Aldicarb 1.0

117-79-3 2-Aminoanthraquinone 0.1

117-81-7 Di(2-ethylhexyl) phthalate 0.1

118-74-1 Hexachlorobenzene *

119-90-4 3,3'-Dimethoxybenzidine 0.1

119-93-7 3,3'-Dimethylbenzidine 0.1

(o-Tolidine)

120-12-7 Anthracene 1.0

120-36-5 2,4-DP 0.1

120-58-1 Isosafrole 1.0

120-71-8 p-Cresidine 0.1

120-80-9 Catechol 0.1

120-82-1 1,2,4-Trichlorobenzene 1.0

120-83-2 2,4-Dichlorophenol 1.0

121-14-2 2,4-Dinitrotoluene 0.1

121-44-8 Triethylamine 1.0

121-69-7 N,N-Dimethylaniline 1.0

121-75-5 Malathion 1.0

122-34-9 Simazine 1.0

122-39-4 Diphenylamine 1.0

122-66-7 1,2-Diphenylhydrazine 0.1

(Hydrazobenzene)

123-31-9 Hydroquinone 1.0

123-38-6 Propionaldehyde 1.0

123-63-7 Paraldehyde 1.0

123-72-8 Butyraldehyde 1.0

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

[1H-Isoindole-1,3(2H)-dione, 3a,4,7,7atetrahydro-2-[(trichloromethyl)thio]-]

133-07-3 Folpet 1.0

133-90-4 Chloramben 1.0
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-14

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

[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)-1H-benzimidazole]

149-30-4 2-Mercaptobenzothiazole 1.0

(MBT)

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]

302-01-2 Hydrazine 0.1

306-83-2 2,2-Dichloro-1,1,1-trifluoroethane 1.0

(HCFC-123)

309-00-2 Aldrin *

[1,4:5,8-Dimethanonaphthalene,

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

5.alpha.,8.alpha.,8a.beta.)-]

314-40-9 Bromacil 1.0

(5-Bromo-6-methyl-3-(1-methylpropyl)-

2,4(1H,3H)-pyrimidinedione)

319-84-6 alpha-Hexachlorocyclohexane 0.1

330-54-1 Diuron 1.0

330-55-2 Linuron 1.0

333-41-5 Diazinon 1.0

334-88-3 Diazomethane 1.0

353-59-3 Bromochlorodifluoromethane 1.0

(Halon 1211)

354-11-0 1,1,1,2-Tetrachloro-2-fluoroethane 1.0

(HCFC-121a)

354-14-3 1,1,2,2-Tetrachloro-1-fluoroethane 1.0

(HCFC-121)

354-23-4 1,2-Dichloro-1,1,2- 1.0

trifluoroethane (HCFC-123a)

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

354-25-6 1-Chloro-1,1,2,2- 1.0

tetrafluoroethane (HCFC-124a)

357-57-3 Brucine 1.0

422-44-6 1,2-Dichloro-1,1,2,3,3- 1.0

pentafluoropropane (HCFC-225bb)

422-48-0 2,3-Dichloro-1,1,1,2,3- 1.0

pentafluoropropane (HCFC-225ba)

422-56-0 3,3-Dichloro-1,1,1,2,2- 1.0

pentafluoropropane (HCFC-225ca)

431-86-7 1,2-Dichloro-1,1,3,3,3- 1.0

pentafluoropropane (HCFC-225da)

460-35-5 3-Chloro-1,1,1-trifluoropropane 1.0

(HCFC-253fb)

463-58-1 Carbonyl sulfide 1.0

465-73-6 Isodrin *

492-80-8 C.I. Solvent Yellow 34 0.1

(Auramine)

505-60-2 Mustard gas 0.1

[Ethane, 1,1'-thiobis[2-chloro-]

507-55-1 1,3-Dichloro-1,1,2,2,3- 1.0

pentafluoropropane (HCFC-225cb)

510-15-6 Chlorobenzilate 1.0

[Benzeneacetic acid, 4-chloro-.alpha.-(4-

chlorophenyl)-.alpha.-hydroxy-, ethyl

ester]

528-29-0 o-Dinitrobenzene 1.0

532-27-4 2-Chloroacetophenone 1.0

533-74-4 Dazomet 1.0

(Tetrahydro-3,5-dimethyl-2H-1,3,5-

thiadiazine-2-thione)

534-52-1 4,6-Dinitro-o-cresol 1.0

540-59-0 1,2-Dichloroethylene 1.0

541-41-3 Ethyl chloroformate 1.0

541-53-7 2,4-Dithiobiuret 1.0

541-73-1 1,3-Dichlorobenzene 1.0

542-75-6 1,3-Dichloropropylene 0.1

542-76-7 3-Chloropropionitrile 1.0

542-88-1 Bis(chloromethyl) ether 0.1

554-13-2 Lithium carbonate 1.0

556-61-6 Methyl isothiocyanate 1.0

[Isothiocyanatomethane]

563-47-3 3-Chloro-2-methyl-1-propene 0.1

569-64-2 C.I. Basic Green 4 1.0

584-84-9 Toluene-2,4-diisocyanate 0.1

593-60-2 Vinyl bromide 0.1

594-42-3 Perchloromethyl mercaptan 1.0

606-20-2 2,6-Dinitrotoluene 0.1

608-93-5 Pentachlorobenzene *

612-82-8 3,3'-Dimethylbenzidine 0.1

dihydrochloride (o-Tolidine

dihydrochloride)

612-83-9 3,3'-Dichlorobenzidine 0.1

dihydrochloride

615-05-4 2,4-Diaminoanisole 0.1

615-28-1 1,2-Phenylenediamine 1.0

dihydrochloride

621-64-7 N-Nitrosodi-n-propylamine 0.1

624-18-0 1,4-Phenylenediamine 1.0
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-15

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

dihydrochloride

624-83-9 Methyl isocyanate 1.0

630-20-6 1,1,1,2-Tetrachloroethane 1.0

636-21-5 o-Toluidine hydrochloride 0.1

639-58-7 Triphenyltin chloride 1.0

680-31-9 Hexamethylphosphoramide 0.1

684-93-5 N-Nitroso-N-methylurea 0.1

709-98-8 Propanil (N-(3,4-Dichlorophenyl) 1.0

propanamide)

759-73-9 N-Nitroso-N-ethylurea 0.1

759-94-4 Ethyl dipropylthiocarbamate 1.0

(EPTC)

764-41-0 1,4-Dichloro-2-butene 1.0

812-04-4 1,1-Dichloro-1,2,2-trifluoroethane 1.0

(HCFC-123b)

834-12-8 Ametryn 1.0

(N-Ethyl-N’-(1-methylethyl)-6-

(methylthio)-1,3,5,-triazine-2,4-diamine)

842-07-9 C.I. Solvent Yellow 14 1.0

872-50-4 N-Methyl-2-pyrrolidone 1.0

924-16-3 N-Nitrosodi-n-butylamine 0.1

924-42-5 N-Methylolacrylamide 1.0

957-51-7 Diphenamid 1.0

961-11-5 Tetrachlorvinphos 1.0

[Phosphoric acid, 2-chloro-1-(2,4,5-

trichlorophenyl)ethenyldimethyl ester]

989-38-8 C.I. Basic Red 1 1.0

1114-71-2 Pebulate 1.0

[Butylethylcarbamothioic acid S-propyl

ester]

1120-71-4 Propane sultone 0.1

1134-23-2 Cycloate 1.0

1163-19-5 Decabromodiphenyl oxide 1.0

1313-27-5 Molybdenum trioxide 1.0

1314-20-1 Thorium dioxide 1.0

1319-77-3 Cresol (mixed isomers) 1.0

1320-18-9 2,4-D propylene glycol butyl 0.1

ether ester

1330-20-7 Xylene (mixed isomers) 1.0

1332-21-4 Asbestos (friable) 0.1

1335-87-1 Hexachloronaphthalene 1.0

1336-36-3 Polychlorinated biphenyls (PCBs) *

1344-28-1 Aluminum oxide (fibrous forms) 1.0

1464-53-5 Diepoxybutane 0.1

1563-66-2 Carbofuran 1.0

1582-09-8 Trifluralin *

[Benezeneamine, 2,6-dinitro-N,Ndipropyl-4-(trifluoromethyl)-]

1634-04-4 Methyl tert-butyl ether 1.0

1649-08-7 1,2-Dichloro-1,1-difluoroethane 1.0

(HCFC-132b)

1689-84-5 Bromoxynil 1.0

(3,5-Dibromo-4-hydroxybenzonitrile)

1689-99-2 Bromoxynil octanoate 1.0

(Octanoic acid, 2,6-dibromo-4-

cyanophenyl ester)

1717-00-6 1,1-Dichloro-1-fluoroethane 1.0

(HCFC-141b)

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

1836-75-5 Nitrofen 0.1

[Benzene, 2,4-dichloro-1-(4-

nitrophenoxy)-]

1861-40-1 Benfluralin 1.0

(N-Butyl-N-ethyl-2,6-dinitro-4-

(trifluoromethyl)benzenamine)

1897-45-6 Chlorothalonil 0.1

[1,3-Benzenedicarbonitrile, 2,4,5,6-

tetrachloro-]

1910-42-5 Paraquat dichloride 1.0

1912-24-9 Atrazine 1.0

(6-Chloro-N-ethyl-N’-(1-methylethyl)-

1,3,5-triazine-2,4-diamine)

1918-00-9 Dicamba 1.0

(3,6-Dichloro-2-methoxybenzoic acid)

1918-02-1 Picloram 1.0

1918-16-7 Propachlor 1.0

[2-Chloro-N-(1-methylethyl)-Nphenylacetamide]

1928-43-4 2,4-D 2-ethylhexyl ester 0.1

1929-73-3 2,4-D butoxyethyl ester 0.1

1929-82-4 Nitrapyrin 1.0

(2-Chloro-6-(trichloromethyl)pyridine)

1937-37-7 C.I. Direct Black 38 0.1

1982-69-0 Sodium dicamba 1.0

[3,6-Dichloro-2-methoxybenzoic acid,

sodium salt]

1983-10-4 Tributyltin fluoride 1.0

2032-65-7 Methiocarb 1.0

2155-70-6 Tributyltin methacrylate 1.0

2164-07-0 Dipotassium endothall 1.0

[7-Oxabicyclo(2.2.1)heptane-2,3-

dicarboxylic acid, dipotassium salt]

2164-17-2 Fluometuron 1.0

[Urea, N,N-dimethyl-N’-[3-

(trifluoromethyl)phenyl]-]

2212-67-1 Molinate 1.0

(1H-Azepine-1-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(1-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
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-16

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

2832-40-8 C.I. Disperse Yellow 3 1.0

2837-89-0 2-Chloro-1,1,1,2- 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

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 1-(3-Chloroallyl)-3,5,7-triaza-1- 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]

5902-51-2 Terbacil 1.0

[5-Chloro-3-(1,1-dimethylethyl)-6-methyl2,4(1H,3H)-pyrimidinedione]

6459-94-5 C.I. Acid Red 114 0.1

7287-19-6 Prometryn 1.0

[N,N’-Bis(1-methylethyl)-6-methylthio1,3,5-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

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

(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-1-

propenyl)cyclopropanecarboxylic acid

(1,3,4,5,6,7-hexahydro-1,3-dioxo-2Hisoindol-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

7782-50-5 Chlorine 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-1,3-Dichloropropene 0.1

10294-34-5 Boron trichloride 1.0

10453-86-8 Resmethrin 1.0

[[5-(Phenylmethyl)-3-furanyl]methyl- 2,2-

dimethyl-3-(2-methyl-1-propenyl)

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,Sdipropyl ester]

13356-08-6 Fenbutatin oxide 1.0

(Hexakis(2-methyl-2-phenylpropyl)

distannoxane)

13463-40-6 Iron pentacarbonyl 1.0

13474-88-9 1,1-Dichloro-1,2,2,3,3- 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
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-17

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

[4-(Dipropylamino)-3,5-

dinitrobenzenesulfonamide]

19666-30-9 Oxydiazon 1.0

[3-[2,4-Dichloro-5-(1-methylethoxy)

phenyl]-5-(1,1-dimethylethyl)-1,3,4-

oxadiazol-2(3H)-one]

20325-40-0 3,3'-Dimethoxybenzidine 0.1

dihydrochloride (o-Dianisidine

dihydrochloride)

20354-26-1 Methazole 1.0

[2-(3,4-Dichlorophenyl)-4-methyl-1,2,4-

oxadiazolidine-3,5-dione]

20816-12-0 Osmium tetroxide 1.0

20859-73-8 Aluminum phosphide 1.0

21087-64-9 Metribuzin 1.0

21725-46-2 Cyanazine 1.0

22781-23-3 Bendiocarb 1.0

[2,2-Dimethyl-1,3-benzodioxol-4-ol

methylcarbamate]

23564-05-8 Thiophanate methyl 1.0

23564-06-9 Thiophanate ethyl 1.0

[[1,2-Phenylenebis(iminocarbonothioyl)]

biscarbamic acid diethyl ester]

23950-58-5 Pronamide 1.0

25311-71-1 Isofenphos 1.0

[2-[[Ethoxyl[(1-methylethyl)-

amino]phosphinothioyl]oxy]benzoic acid

1-methylethyl ester]

25321-14-6 Dinitrotoluene (mixed isomers) 1.0

25321-22-6 Dichlorobenzene (mixed isomers) 0.1

25376-45-8 Diaminotoluene (mixed isomers) 0.1

26002-80-2 Phenothrin 1.0

[2,2-Dimethyl-3-(2-methyl-1-

propenyl)cyclopropanecarboxylic acid (3-

phenoxyphenyl)methyl ester]

26471-62-5 Toluene diisocyanate 0.1

(mixed isomers)

26628-22-8 Sodium azide 1.0

26644-46-2 Triforine 1.0

[N,N’-[1,4-Piperazinediylbis (2,2,2-

trichloroethylidene)]bisformamide]

27314-13-2 Norflurazon 1.0

[4-Chloro-5-(methylamino)-2-[3-

(trifluoromethyl)phenyl]-3(2H)-

pyridazinone]

28057-48-9 d-trans-Allethrin 1.0

[d-trans-Chrysanthemic acid of dallethrone]

28249-77-6 Thiobencarb 1.0

[Carbamic acid, diethylthio-, S-(pchlorobenzyl)ester]

28407-37-6 C.I. Direct Blue 218 1.0

29082-74-4 Octachlorostyrene *

29232-93-7 Pirimiphos methyl 1.0

[O-(2-(Diethylamino)-6-methyl-4-

pyrimidinyl)-O,Odimethylphosphorothioate]

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

30560-19-1 Acephate 1.0

(Acetylphosphoramidothioic acid O,Sdimethyl ester)

31218-83-4 Propetamphos 1.0

[3-[(Ethylamino)

methoxyphosphinothioyl]oxy]-2-butenoic

acid, 1-methylethyl ester]

33089-61-1 Amitraz 1.0

34014-18-1 Tebuthiuron 1.0

[N-[5-(1,1-Dimethylethyl)-1,3,4-

thiadiazol-2-yl]-N,N’-dimethylurea]

34077-87-7 Dichlorotrifluoroethane 1.0

35367-38-5 Diflubenzuron 1.0

35400-43-2 Sulprofos 1.0

[O-Ethyl O-[4-(methylthio)phenyl]-

phosphorodithioic acid S-propyl ester]

35554-44-0 Imazalil 1.0

[1-[2-(2,4-Dichlorophenyl)-2-(2-

propenyloxy)ethyl]-1H-imidazole]

35691-65-7 1-Bromo-1-(bromomethyl)-1,3- 1.0

propanedicarbonitrile

38727-55-8 Diethatyl ethyl 1.0

39156-41-7 2,4-Diaminoanisole sulfate 0.1

39300-45-3 Dinocap 1.0

39515-41-8 Fenpropathrin 1.0

[2,2,3,3-Tetramethylcyclopropane

carboxylic acid cyano(3-

phenoxyphenyl)methyl ester]

40487-42-1 Pendimethalin *

[N-(1-Ethylpropyl)-3,4-dimethyl-2,6-

dinitrobenzenamine]

41198-08-7 Profenofos 1.0

[O-(4-Bromo-2-chlorophenyl)-O-ethyl-Spropyl phosphorothioate]

41766-75-0 3,3'-Dimethylbenzidine 0.1

dihydrofluoride (oTolidinedihydrofluoride)

42874-03-3 Oxyfluorfen 1.0

43121-43-3 Triadimefon 1.0

[1-(4-Chlorophenoxy)-3,3-dimethyl-1-(1H1,2,4-triazol-1-yl)-2-butanone]

50471-44-8 Vinclozolin 1.0

[3-(3,5-Dichlorophenyl)-5-ethenyl-5-

methyl-2,4-oxazolidinedione]

51235-04-2 Hexazinone 1.0

51338-27-3 Diclofop methyl 1.0

[2-[4-(2,4-Dichlorophenoxy)-

phenoxy]propanoic acid, methyl ester]

51630-58-1 Fenvalerate 1.0

[4-Chloro-alpha-(1-methylethyl)-

benzeneacetic acid cyano(3-

phenoxyphenyl)methyl ester]

52645-53-1 Permethrin 1.0

[3-(2,2-Dichloroethenyl)-2,2-

dimethylcyclopropane carboxylic acid,

(3-phenoxyphenyl)methyl ester]

53404-19-6 Bromacil, lithium salt 1.0

[2,4(1H,3H)-Pyrimidinedione, 5-bromo-6-
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-18

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

methyl-3-(1-methylpropyl), lithium salt]

53404-37-8 2,4-D 2-ethyl-4-methylpentyl 0.1

ester

53404-60-7 Dazomet, sodium salt 1.0

[Tetrahydro-3,5-dimethyl-2H-1,3,5-

thiadiazine-2-thione, ion(1-), sodium]

55290-64-7 Dimethipin 1.0

[2,3-Dihydro-5,6-dimethyl-1,4-dithiin

1,1,4,4-tetraoxide]

55406-53-6 3-Iodo-2-propynyl butyl 1.0

carbamate

57213-69-1 Triclopyr triethylammonium salt 1.0

59669-26-0 Thiodicarb 1.0

60168-88-9 Fenarimol 1.0

[.alpha.-(2-Chlorophenyl)-.alpha.-(4-

chlorophenyl)-5-pyrimidinemethanol]

60207-90-1 Propiconazole 1.0

[1-[2-(2,4-Dichlorophenyl)-4-propyl- 1,3-

dioxolan-2-yl]-methyl-1H-1,2,4,-triazole]

62476-59-9 Acifluorfen, sodium salt 1.0

[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-

2-nitrobenzoic acid, sodium salt]

63938-10-3 Chlorotetrafluoroethane 1.0

64902-72-3 Chlorsulfuron 1.0

[2-Chloro-N-[[(4-methoxy-6-methyl-1,3,5-

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(1H)-

pyrimidinone[3-[4-

(trifluoromethyl)phenyl]-1-[2-[4-

(trifluoromethyl)phenyl]ethenyl]-2-

propenylidene]hydrazone]

68085-85-8 Cyhalothrin 1.0

[3-(2-Chloro-3,3,3-trifluoro-1-propenyl)-

2,2-dimethylcyclopropanecarboxylic acid

cyano(3-phenoxyphenyl) methyl ester]

68359-37-5 Cyfluthrin 1.0

[3-(2,2-Dichloroethenyl)-2,2-

dimethylcyclopropanecarboxylic acid,

cyano(4-fluoro-3-phenoxyphenyl) methyl

ester]

69409-94-5 Fluvalinate 1.0

[N-[2-Chloro-4-

(trifluoromethyl)phenyl]DL-valine(+)-

cyano(3-phenoxyphenyl)methyl ester]

69806-50-4 Fluazifop butyl 1.0

[2-[4-[[5-(Trifluoromethyl)-2-

pyridinyl]oxy]phenoxy]propanoic acid,

butyl ester]

71751-41-2 Abamectin [Avermectin B1] 1.0

72178-02-0 Fomesafen 1.0

[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-

De minimis

CAS Number Chemical Name % Limit

Arranged by CAS Number

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-[1-(Ethoxyimino)butyl]-5-[2-

(ethylthio)propyl]-3-hydroxyl-2-

cyclohexen-1-one]

76578-14-8 Quizalofop-ethyl 1.0

[2-[4-[(6-Chloro-2-quinoxalinyl)

oxy]phenoxy]propanoic acid ethyl ester]

77501-63-4 Lactofen 1.0

[Benzoic acid, 5-[2-Chloro-4-

(trifluoromethyl)phenoxy]-2-nitro-, 2-

ethoxy-1-methyl-2-oxoethyl ester]

82657-04-3 Bifenthrin 1.0

88671-89-0 Myclobutanil 1.0

[.alpha.-Butyl-.alpha.-(4-chlorophenyl)-

1H-1,2,4-triazole-1-propanenitrile]

90454-18-5 Dichloro-1,1,2-trifluoroethane 1.0

90982-32-4 Chlorimuron ethyl 1.0

[Ethyl-2-[[[[(4-chloro-6-methoxyprimidin2-yl)amino]carbonyl]

amino]sulfonyl]benzoate]

101200-48-0 Tribenuron methyl 1.0

[2-[[[[(4-Methoxy-6-methyl-1,3,5-triazin2-yl)methylamino]carbonyl]

amino]sulfonyl]benzoic acid methyl ester]

111512-56-2 1,1-Dichloro-1,2,3,3,3- 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-1,1,1,3,3- 1.0

pentafluoropropane (HCFC-225aa)

136013-79-1 1,3-Dichloro-1,1,2,3,3- 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 minimislimit would otherwise appear.
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-19

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)

OH

Cl x

H(5-x)

Where x = 1 to 5

N090 Chromium Compounds

(except for chromite ore mined in the Transvaal

Region of South Africa and the unreacted ore

component of the chromite ore processing residue

(COPR). COPR is the solid waste remaining after

aqueous extraction of oxidized chromite ore that has

been combined with soda ash and kiln roasted at

approximately 2,000 deg.F.)

(chromium VI compounds: 0.1; chromium III

compounds: 1.0)

Includes any unique chemical substance that contains

chromium as part of that chemical’s

infrastructure.

N096 Cobalt Compounds (inorganic compounds: 0.1;

organic compounds: 1.0)

Includes any unique chemical substance that contains

cobalt as part of that chemical’s infrastructure.

N100 Copper Compounds (1.0)

Includes any unique chemical substance that contains

copper as part of that chemical’s infrastructure. This

category does not include copper phthalocyanine

compounds that are substituted with only hydrogen,

and/or chlorine, and/or bromine.

N106 Cyanide Compounds (1.0)

X

+CN- where X = H+ or any other group where a

formal dissociation can be made. For example KCN

or Ca(CN)2.

N120 Diisocyanates (1.0)

This category includes only those chemicals listed

below.

38661-72-2 1,3-Bis(methylisocyanate) -

cyclohexane

10347-54-3 1,4-Bis(methylisocyanate)-

cyclohexane

2556-36-7 1,4-Cyclohexane

diisocyanate

134190-37-7 Diethyldiisocyanatobenzene

4128-73-8 4,4'-Diisocyanatodiphenyl

ether

75790-87-3 2,4'-Diisocyanatodiphenyl

sulfide

91-93-0 3,3'-Dimethoxybenzidine4,4'-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 1,1-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
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-20

the category in the order they are listed here (i.e., 1-17).]

1 1746-01-6 2,3,7,8-

Tetrachlorodibenzo-p-dioxin

2 40321-76-4 1,2,3,7,8-

Pentachlorodibenzo-p-dioxin

3 39227-28-6 1,2,3,4,7,8-

Hexachlorodibenzo-p-dioxin

4 57653-85-7 1,2,3,6,7,8-

Hexachlorodibenzo-p-dioxin

5 19408-74-3 1,2,3,7,8,9-

Hexachlorodibenzo-p-dioxin

6 35822-46-9 1,2,3,4,6,7,8-

Heptachlorodibenzo-p-dioxin

7 3268-87-9 1,2,3,4,6,7,8,9-

Octachlorodibenzo-p-dioxin

8 51207-31-9 2,3,7,8-

Tetrachlorodibenzofuran

9 57117-41-6 1,2,3,7,8-

Pentachlorodibenzofuran

10 57117-31-4 2,3,4,7,8-

Pentachlorodibenzofuran

11 70648-26-9 1,2,3,4,7,8-

Hexachlorod-benzofuran

12 57117-44-9 1,2,3,6,7,8-

Hexachlorodibenzofuran

13 72918-21-9 1,2,3,7,8,9-

Hexachlorodibenzofuran

14 60851-34-5 2,3,4,6,7,8-

Hexachlorodibenzofuran

15 67562-39-4 1,2,3,4,6,7,8-

Heptachlorodibenzofuran

16 55673-89-7 1,2,3,4,7,8,9-

Heptachlorodibenzofuran

17 39001-02-0 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.

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)

Brx

H(10-x)

Where x = 1 to 10

N575 Polybrominated Biphenyls (PBBs) (0.1)

N583 Polychlorinated alkanes (C10 to C13) (1.0, except for

those members of the category that have an average

chain length of 12 carbons and contain an average

chlorine content of 60% by weight which are subject

to the 0.1% de minimis)

CxH2x+2-yCly

where x = 10 to 13;

y = 3 to 12; and

the average chlorine content ranges from 40 C 70% with

the limiting molecular formulas C10H19Cl3and C13H

16Cl12

N590 Polycyclic aromatic compounds (PACs) (*)

This category includes the chemicals listed below.

56-55-3 Benz(a)anthracene

205-99-2 Benzo(b)fluoranthene

205-82-3 Benzo(j)fluoranthene

207-08-9 Benzo(k)fluoranthene

206-44-0 Benzo(j,k)fluorene

189-55-9 Benzo(r,s,t)pentaphene

218-01-9 Benzo(a)phenanthrene

50-32-8 Benzo(a)pyrene

226-36-8 Dibenz(a,h)acridine

224-42-0 Dibenz(a,j)acridine

53-70-3 Dibenzo(a,h)anthracene

194-59-2 7H-Dibenzo(c,g)carbazole
Table II. EPCRA Section 313 Chemical List – RY2009

Toxics Release Inventory Reporting Form and Instructions II-21

5385-75-1 Dibenzo(a,e)fluoranthene

192-65-4 Dibenzo(a,e)pyrene

189-64-0 Dibenzo(a,h)pyrene

191-30-0 Dibenzo(a,l)pyrene

57-97-6 7,12-Dimethylbenz(a)-anthracene

193-39-5 Indeno(1,2,3-cd)pyrene

56-49-5 3-Methylcholanthrene

3697-24-3 5-Methylchrysene

5522-43-0 1-Nitropyrene

N725 Selenium Compounds (1.0)

Includes any unique chemical substance that contains

selenium as part of that chemical’s infrastructure.

N740 Silver Compounds (1.0)

Includes any unique chemical substance that contains silver

as part of that chemical’s infrastructure.

N746 Strychnine and salts (1.0)

Includes any unique chemical substance that contains

strychnine or a strychnine salt as part of that chemical’s

infrastructure.

N760 Thallium Compounds (1.0)

Includes any unique chemical substance that contains

thallium as part of that chemical’s infrastructure.

N770 Vanadium Compounds (1.0)

Includes any unique chemical substance that contains

vanadium as part of that chemical's

infrastructure.

N874 Warfarin and salts (1.0)

Includes any unique chemical substance that contains

warfarin or a warfarin salt as part of that chemical’s

infrastructure.

N982 Zinc Compounds (1.0)

Includes any unique chemical substance that contains zinc

as part of that chemical’s infrastructure.
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Table III. State Abbreviations

Toxics Release Inventory Reporting Form and Instruction III-1

Alabama AL

Alaska AK

American Samoa AS

Arizona AZ

Arkansas AR

California CA

Colorado CO

Connecticut CT

Delaware DE

District of Columbia DC

Florida FL

Georgia GA

Guam GU

Hawaii HI

Idaho ID

Illinois IL

Indiana IN

Iowa IA

Kansas KS

Kentucky KY

Louisiana LA

Maine ME

Marshall Islands MH

Maryland MD

Massachusetts MA

Michigan MI

Minnesota MN

Mississippi MS

Missouri MO

Montana MT

Nebraska NE

Nevada NV

New Hampshire NH

New Jersey NJ

New Mexico NM

New York NY

North Carolina NC

North Dakota ND

Northern Marianas Islands MP

Ohio OH

Oklahoma OK

Oregon OR

Pennsylvania PA

Puerto Rico PR

Rhode Island RI

South Carolina SC

South Dakota SD

Tennessee TN

Texas TX

Utah UT

Vermont VT

Virginia VA

Virgin Islands VI

Washington WA

West Virginia WV

Wisconsin WI

Wyoming WY
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Table IV. Country Codes

Toxics Release Inventory Reporting Form and Instructions IV-1

AA Aruba

AC Antigua and Barbuda

AE United Arab

Emirates

AF Afghanistan

AG Algeria

AJ Azerbaijan

AL Albania

AM Armenia

AN Andorra

AO Angola

AR Argentina

AS Australia

AT Ashmore and Cartier

Islands

AU Austria

AV Anguilla

AY Antarctica

BA Bahrain

BB Barbados

BC Botswana

BD Bermuda

BE Belgium

BF The Bahamas

BG Bangladesh

BH Belize

BK Bosnia and

Herzegovina

BL Bolivia

BM Burma

BN Benin

BO Belarus

BP Solomon Islands

BR Brazil

BS Bassas da India

BT Bhutan

BU Bulgaria

BV Bouvet Island

BX Brunei

BY Burundi

CA Canada

CB Cambodia

CD Chad

CE Sri Lanka

CF Congo

(Brazzaville)

CG Congo (Kinshasa)

CH China

CI Chile

CJ Cayman Islands

CK Cocos (Keeling)

Islands

CM Cameroon

CN Comoros

CO Colombia

CR Coral Sea Islands

CS Costa Rica

CT Central African

Republic

CU Cuba

CV Cape Verde

CW Cook Islands

CY Cyprus

DA Denmark

DJ Djibouti

DO Dominica

DR Dominican

Republic

EC Ecuador

EG Egypt

EI Ireland

EK Equatorial Guinea

EN Estonia

ER Eritrea

ES El Salvador

ET Ethiopia

EU Europa Island

EZ Czech Republic

FG French Guiana

FI Finland

FJ Fiji

FK Falkland Islands

(Islas Malvinas)

FO Faroe Islands

FP French Polynesia

FR France

FS French Southern and

Antarctic Lands

GA The Gambia

GB Gabon

GG Georgia

GH Ghana

GI Gibraltar

GJ Grenada

GK Guernsey

GL Greenland

GM Germany

GO Glorioso Islands

GP Guadeloupe

GR Greece

GT Guatemala

GV Guinea

GY Guyana

GZ Gaza Strip

HA Haiti

HK Hong Kong

HM Heard Island and

McDonald Islands

HO Honduras

HR Croatia

HU Hungary

IC Iceland

ID Indonesia

IM Isle of Man

IN India

IO British Indian Ocean

Territory

IP Clipperton Island

IR Iran

IS Israel

IT Italy

IV Cote D'Ivoire

IZ Iraq

JA Japan

JE Jersey

JM Jamaica

JN Jan Mayen

JO Jordan

JU Juan de Nova Island

KE Kenya

KG Kyrgyzstan

KN North Korea

KQ Kingman Reef

KR Kiribati

KS South Korea

KT Christmas Island

KU Kuwait

KZ Kazakhstan

LA Laos

LE Lebanon

LG Latvia

LH Lithuania

LI Liberia

LO Slovakia
Table IV. Country Codes

IV-2 Toxics Release Inventory Reporting Form and Instructions

LS Liechtenstein

LT Lesotho

LU Luxembourg

LY Libya

MA Madagascar

MB Martinique

MC Macau

MD Moldova

MF Mayotte

MG Mongolia

MH Montserrat

MI Malawi

MK Macedonia

ML Mali

MN Monaco

MO Morocco

MP Mauritius

MR Mauritania

MT Malta

MU Oman

MV Maldives

MX Mexico

MY Malaysia

MZ Mozambique

NC New Caledonia

NE Niue

NF Norfolk Island

NG Niger

NH Vanuatu

NI Nigeria

NL Netherlands

NO Norway

NP Nepal

NR Nauru

NS Suriname

NT Netherlands Antilles

NU Nicaragua

NZ New Zealand

PA Paraguay

PC Pitcairn Islands

PE Peru

PF Paracel Islands

PG Spratly Islands

PK Pakistan

PL Poland

PM Panama

PO Portugal

PP Papua New Guinea

PS Palau

PU Guinea-Bissau

QA Qatar

RE Reunion

RO Romania

RP Philippines

RS Russia

RW Rwanda

SA Saudi Arabia

SB St. Pierre and

Miquelon

SC St. Kitts and Nevis

SE Seychelles

SF South Africa

SG Senegal

SH St. Helena

SI Slovenia

SL Sierra Leone

SM San Marino

SN Singapore

SO Somalia

SP Spain

ST St. Lucia

SU Sudan

SV Svalbard

SW Sweden

SX South Georgia and

South Sandwich

Islands

SY Syria

SZ Switzerland

TD Trinidad and

Tobago

TE Tromelin Island

TH Thailand

TI Tajikistan

TK Turks and Caicos

Islands

TL Tokelau

TN Tonga

TO Togo

TP Sao Tome and

Principe

TS Tunisia

TT East Timor

TU Turkey

TV Tuvalu

TW Taiwan

TX Turkmenistan

TZ Tanzania

UG Uganda

UK United Kingdom

UP Ukraine

UV Burkina Faso

UY Uruguay

UZ Uzbekistan

VC St. Vincent and the

Grenadines

VE Venezuela

VI British Virgin

Islands

VM Vietnam

VT Vatican City

WA Namibia

WE West Bank

WF Wallis and Futuna

WI Western Sahara

WS Western Samoa

WZ Swaziland

YI Yugoslavia

YM Yemen

ZA Zambia

ZI Zimbabwe
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Toxics Release Inventory Reporting Forms and Instructions A-1

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 RightTo-Know Act of 1986 (EPCRA) and the Pollution

Prevention Act of 1990 (PPA). Federal facilities have

been subject to EPCRA section 313 and PPA since

reporting year 1994. TRI submissions are due to EPA

on July 1 of the year following each reporting

(calendar) year. Reporting by the federal facility does

not alter the reporting obligation of on-site contractors.

Contracts entered into after the date of this order for

contractor operation of government-owned facilities or

vehicles require the contractor to comply with the

provisions of this order with respect to such facilities

or vehicles to the same extent as the agency would be

required to comply if the agency operated facilities or

vehicles.

For more information on Executive Order 13423 please

refer to the implementing instructions, which can be

found on the TRI home page at http://www.epa.gov/tri

A.2 Identifying Federal

Facility Reports

Federal facility reports are identified as federal by

several indicators on the form. The facility name and

parent company name are critical indicators and must

be reported as described below. Another critical

indicator is the federal facility report box, Part I, 4.2c.

Federal facilities only should check this box to indicate

that the report is from a federal agency for a federal

facility; federal facilities should not check the GOCO

box, (Part I, Section 4.2d of the Form R). Contractors

located at federal facilities (GOCOs) should check the

GOCO box (Part I, Section 4.2d of the Form R); they

should not check the box 4.2c. Facilities should also

complete the partial or complete facility blocks (Form

R page 2, block 4.2a and 4.2b) as appropriate. If you

are a federal facility reporting for the first time, you

should write "new" in the TRI Facility ID (TRIFID)

box, even if a contractor has reported for your facility

in the past. The contractor will retain the original

TRIFID. You will be assigned a new TRIFID the first

time you report.

A.3 The “Double

Counting” Problem

As structured, the law and the executive order require

both regulated industries and the federal government to

report TRI data, sometimes for the same site. In order

to prevent duplicate data in the TRI database, which

could result in “double counting” data for some

chemicals and locations, EPA must be able to identify

and distinguish the GOCO reports submitted by the

federal contractor from the federal facility reports

which contain data for the same site. To accomplish

this, federal facility reports should be accompanied by

either 1) exact copies (paper or electronic) of all

contractor TRI reports, including when the totals

reported by the federal facility are greater than that

reported by the contractor(s), or 2) a cover letter which

includes a list of the facility contractors which submit

TRI reports to EPA, identifying each contractor by

name, TRI technical contact, and TRI facility name and

address. Additionally, federal facilities should check

Form R, Part I, Section 4.2c, while contractors at

federal facilities should check Form R, Part I, Section

4.2d.

A.4 Magnetic Media

Reporting

All federal facilities are required to report using

Internet reporting. If the GOCO submits its reports on

magnetic media to EPA and to the federal facility, the

federal facility may submit magnetic media copies of

their GOCO TRI reports to EPA provided that those

reports account for all subject activities at the facility.

Magnetic media reports must be accompanied by a

cover letter which includes:

 Required Form R certification statement;

 List of the chemicals reported on the federal

facility’s disk; and

 List that identifies the contractor(s) [if any] by

name and by TRIFID number if they have an

assigned TRIFID number, and the chemicals

they reported (which are on the contractors’

attachment disk(s)).
Appendix A

A-2 Toxics Release Inventory Reporting Forms and Instructions

A.5 How to Report Your

Facility Name

Facility name is a critical data element. It is used by

EPA to create the TRI facility ID number (TRIFID),

which is a unique number designed to identify a facility

site. The facility name and TRIFID number are used

by all TRI data users to link data from a single site

across multiple reporting years. A federal facility is

assigned a new TRIFID number when the federal

report is entered into the Toxics Release Inventory

system for the first time. This TRIFID number,

generated when the first report is entered into the

Toxics Release Inventory System, will be included in

future reporting packages sent to the federal facility,

and should be used by the federal facility in all future

reports.

Federal facilities should report their facility name on

page 1 of the Form Rs (Section 4.1), as shown in the

following example:

U.S. DOE Savannah River Site

It is very important that the agency name appear first,

followed by the specific plant or site name.

Federal contractors at GOCO facilities should report

their names as shown in the following example:

U.S. DOE Savannah River Site -

Westinghouse Operations.

A.6 How to Report Your

North American Industry

Classification System

(NAICS) Code

Federal facilities should report the NAICS code which

most closely represents the activities taking place at the

site. Additional guidance on determining your NAICS

code is provided in the Forms and Instructions booklet.

The table on the next page contains Public

Administration NAICS codes covering executive,

legislative, judicial, administrative and regulatory

activities of the Federal government. Governmentowned and operated business establishments are

classified in major NAICS groups according to the

activity in which they are engaged. For example, a

Veterans Hospital would be classified in Group 806 -

Hospitals.

A.7 How to Report Your

“Parent Company” Name

Federal facilities should report their parent company

name on page 2 of the Form Rs (Section 5.1) by

reporting their complete Department or Agency name,

as shown in the following example:

U.S. Department of Energy

Block 5.2, Parent Company’s Dun & Bradstreet

Number, should be marked NA.

Federal contractors at GOCO facilities should not

report a federal department or agency name as their

parent company. A federal name in the parent

company name field will classify the report as federal,

and the GOCO may be identified as a non-reporter.

A.8 How to Revise Your

Data After It Has Been

Submitted

Any TRI Form R submitter may voluntarily revise their

submission if they find errors after their reports have

been sent to EPA. If the revision is to a hardcopy

report, the facility reporter should photocopy the

original form and use a blue or black pen to mark out

the incorrect value and write in the corrected value.

The revised report should be submitted to EPA, with an

“X” in the revision block on page 1 of the Form R. If

the revision is to a diskette, a new diskette should be

submitted, containing the data only for the revised

submission, not all the chemicals originally reported. If

a federal facility receives a copy of a revision from a

contractor located at the federal facility, the facility

should revise the federal report, and submit the revised

report to EPA and the appropriate state along with an

exact copy of the contractor’s revision. The cover

letter from the federal facility should indicate that its

submission is a revision.

A.9 Who Should Sign

Federal Form R Reports?

Federal Form R reports should be signed by the senior

federal employee on-site. If no federal employee is onsite, 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.
Appendix A

Toxics Release Inventory Reporting Forms and Instructions A-3

A.10 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.11 North American

Industry Classification

System Codes 921-928

Sector 92 - Public Administration

921 Executive, Legislative, and Other

General Government Support

92111 Executive Offices

92112 Legislative Bodies

92113 Public Finance Activities

92114 Executive and Legislative Offices Combined

92115 American Indian and Alaska Native Tribal

Governments

92119 General Government, Not Elsewhere

Classified

922 Justice, Public Order, and Safety

Activities

92211 Courts

92212 Police Protection

92213 Legal Counsel and Prosecution

92214 Correctional Institutions

92215 Parole Offices and Probation Offices

92216 Fire Protection

92219 Other Justice, Public Order and Safety

Activities

923 Administration of Human Resource

Programs

92311 Administration of Educational Programs

92312 Administration of Public Health Programs

92313 Administration of Human Resource Programs

(Except Education, Public Health, and

Veterans’ Affairs Programs)

92314 Administration of Veterans Affairs

924 Administration of Environmental

Quality Programs

92411 Administration of Air and Water Resource

and Solid Waste Management Programs

92412 Administration of Conservation Programs

925 Administration of Housing

Programs, Urban Planning, and

Community Development

92511 Administration of Housing Programs

92512 Administration of Urban Planning and

Community and Rural Development

926 Administration of Economic

Programs

92611 Administration of General Economic

Programs

92612 Regulation and Administration of

Transportation Programs

92613 Regulation and Administration of

Communications, Electric, Gas, and Other

Utilities

92614 Regulation of Agricultural Marketing and

Commodities

92615 Regulation, Licensing, and Inspection of

Miscellaneous Commercial Sectors

927 Space Research and Technology

92711 Space Research and Technology

928 National Security and International

Affairs

92811 National Security

92812 International Affairs
Toxics Release Inventory Reporting Forms and Instructions B-1

Appendix B. Reporting Codes for EPA Form R

and Instructions for Reporting Metals

B.1 Form R Part II

Revision Codes:

RR1 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

N010 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

N171Ethylenebisdithiocarbamic

acid, salts and esters (EBDCs)

N230 Certain glycol ethers

N420 Lead compounds

N450 Manganese compounds

N458 Mercury compounds

N495 Nickel compounds

N503 Nicotine and salts

N511 Nitrate compounds

N575 Polybrominated biphenyls (PBBs)

N583 Polychlorinated alkanes

N590 Polycyclic aromatic compounds

N725 Selenium compounds

N740 Silver compounds

N746 Strychnine and salts

N760 Thallium compounds

N770 Vanadium compounds

N874 Warfarin and salts

N982 Zinc compounds

Section 4. Maximum Amount of the

Toxic Chemical On-Site at Any Time

During the Calendar Year

Range(pounds)

Range Code From To

01 0,000,000 0,000,099

02 0,000,100 0,000,999

03 0,001,000 0,009,999

04 0,010,000 0,099,999

05 0,100,000 0,999,999

06 1,000,000 9,999,999

07 10,000,000 49,999,999

08 50,000,000 99,999,999

09 100,000,000 499,999,999

10 500,000,000 999,999,999

11 1 billion more than 1 billion

Section 5. Quantity of the Non-PBT

Chemical Entering Each Environmental

Medium On-site and Section 6.

Transfers of the Toxic Chemical in

Wastes to Off-Site Locations

Total Release or Transfer

Code Range (pounds)

A 001-10

B 011-499

C 500-999

Basis of Estimate

M1- Estimate is based on continuous monitoring

data or measurements for the EPCRA

section 313 chemical.

M2- Estimate is based on periodic or random

monitoring data or measurements for the

EPCRA section 313 chemical.
Appendix B

B-2 Toxics Release Inventory Reporting Forms and Instructions

C- Estimate is based on mass balance calculations,

such as calculation of the amount of the EPCRA

section 313 chemical in streams entering and

leaving process equipment.

E1- Estimate is based on published emission factors,

such as those relating release quantity to

through-put or equipment type (e.g., air emission

factors).

E2- Estimate is based on site specific emission

factors, such as those relating release quantity to

through-put or equipment type (e.g., air emission

factors).

O- Estimate is based on other approaches such as

engineering calculations (e.g., estimating

volatilization using published mathematical

formulas) or best engineering judgment. This

would include applying an estimated removal

efficiency to a waste stream, even if the

composition of the stream before treatment was

fully identified through monitoring data.

Section 6. Transfers of the Toxic Chemical

in Wastes to Off-Site Locations

Type of Waste Disposal/Treatment/Energy

Recovery/Recycling

M10 Storage Only

M20 Solvents/Organics Recovery

M24 Metals Recovery

M26 Other Reuse or Recovery

M28 Acid Regeneration

M40 Solidification/Stabilization

M41 Solidification/Stabilization-Metals and Metal

Category Compounds only

M50 Incineration/Thermal Treatment

M54 Incineration/Insignificant Fuel Value

M56 Energy Recovery

M61 Wastewater Treatment (Excluding POTW)

M62 Wastewater Treatment (Excluding POTW) C

Metals and Metal Category Compounds only

M64 Other Landfills

M65 RCRA Subtitle C Landfills

M66 Subtitle C Surface Impoundment

M67 Other Surface Impoundments

M69 Other Waste Treatment

M73 Land Treatment

M79 Other Land Disposal

M81 Underground Injection to Class I Wells

M82 Underground Injection to Class II-V Wells

M90 Other Off-Site Management

M92 Transfer to Waste Broker C Energy Recovery

M93 Transfer to Waste Broker C Recycling

M94 Transfer to Waste Broker C Disposal

M95 Transfer to Waste Broker C Waste

Treatment

M99 Unknown

Section 7A. On-Site Waste Treatment

Methods and Efficiency

General Waste Stream

A Gaseous (gases, vapors, airborne

particulates)

W Wastewater (aqueous waste)

L Liquid waste streams (non-aqueous waste)

S Solid waste streams (including sludges and

slurries)

Waste Treatment Methods

Air Emissions Treatment

A01 Flare

A02 Condenser

A03 Scrubber

A04 Absorber

A05 Electrostatic Precipitator

A06 Mechanical Separation

A07 Other Air Emission Treatment

Chemical Treatment

H040 Incineration--thermal destruction other than

use as a fuel

H071 Chemical reduction with or without

precipitation

H073 Cyanide destruction with or without

precipitation

H075 Chemical oxidation

H076 Wet air oxidation

H077 Other chemical precipitation with or without

pre-treatment

Biological Treatment

H081 Biological treatment with or without

precipitation

Physical Treatment

H082 Adsorption

H083 Air or steam stripping

H101 Sludge treatment and/or dewatering

H103 Absorption

H111 Stabilization or chemical fixation prior to

disposal

H112 Macro-encapsulation prior to disposal

H121 Neutralization

H122 Evaporation

H123 Settling or clarification

H124 Phase separation

H129 Other treatment
Appendix B

Toxics Release Inventory Reporting Forms and Instructions B-3

Section 7B. On-Site Energy Recovery

Processes

U01 Industrial Kiln

U02 Industrial Furnace

U03 Industrial Boiler

Section 7C. On-Site Recycling Processes

H10 Metal recovery (by retorting, smelting, or

chemical or physical extraction)

H20 Solvent recovery (including distillation,

evaporation, fractionation or extraction)

H39 Other recovery or reclamation for reuse

(including acid regeneration or other chemical

reaction process)

Section 8.10. Source Reduction Activity

Codes

Good Operating Practices

W13 Improved maintenance scheduling, record

keeping, or procedures

W14 Changed production schedule to minimize

equipment and feedstock changeovers

W19 Other changes in operating practices

Inventory Control

W21 Instituted procedures to ensure that materials do

not stay in inventory beyond shelf-life

W22 Began to test outdated material C continue to use

if still effective

W23 Eliminated shelf-life requirements for stable

materials

W24 Instituted better labeling procedures

W25 Instituted clearinghouse to exchange materials

that would otherwise be discarded

W29 Other changes in inventory control

Spill and Leak Prevention

W31 Improved storage or stacking procedures

W32 Improved procedures for loading, unloading, and

transfer operations

W33 Installed overflow alarms or automatic shut-off

valves

W35 Installed vapor recovery systems

W36 Implemented inspection or monitoring program

of potential spill or leak sources

W39 Other changes made in spill and leak prevention

Raw Material Modifications

W41 Increased purity of raw materials

W42 Substituted raw materials

W49 Other raw material modifications made

Process Modifications

W51 Instituted recirculation within a process

W52 Modified equipment, layout, or piping

W53 Use of a different process catalyst

W54 Instituted better controls on operating bulk

containers to minimize discarding of empty

containers

W55 Changed from small volume containers to

bulk containers to minimize discarding of

empty containers

W58 Other process modifications

Cleaning and Degreasing

W59 Modified stripping/cleaning equipment

W60 Changed to mechanical stripping/cleaning

devices (from solvents or other materials)

W61 Changed to aqueous cleaners (from solvents

or other materials)

W63 Modified containment procedures for

cleaning units

W64 Improved draining procedures

W65 Redesigned parts racks to reduce drag out

W66 Modified or installed rinse systems

W67 Improved rinse equipment design

W68 Improved rinse equipment operation

W71 Other cleaning and degreasing

modifications

Surface Preparation and Finishing

W72 Modified spray systems or equipment

W73 Substituted coating materials used

W74 Improved application techniques

W75 Changed from spray to other system

W78 Other surface preparation and finishing

modifications

Product Modifications

W81 Changed product specifications

W82 Modified design or composition of products

W83 Modified packaging

W89 Other product modifications

Section 8.10. Methods Used to Identify

Source Reduction Activities

For each source reduction activity, enter up to three of

the following codes that correspond to the method(s)

which contributed most to the decision to implement

that activity.

T01 Internal Pollution Prevention Opportunity

Audit(s)

T02 External Pollution Prevention Opportunity

Audit(s)

T03 Materials Balance Audits

T04 Participative Team Management
Appendix B

B-4 Toxics Release Inventory Reporting Forms and Instructions

T05 Employee Recommendation (independent of a

formal company program)

T06 Employee Recommendation (under a formal

company program)

T07 State Government Technical Assistance Program

T08 Federal Government Technical Assistance

Program

T09 Trade Association/Industry Technical

Assistance Program

T10 Vendor Assistance

T11 Other
Appendix B

Toxics Release Inventory Reporting Forms and Instructions B-5

B.2 Reporting the Waste Management of Metals

This appendix outlines how the TRI-ME reporting software restricts reporting for metals when the specific data element or

waste management code is not applicable for a particular chemical. Below is a list of metals divided into four groups along

with charts that help explain where quantities of these chemicals can and can not be reported on the Form R using TRI-ME.

In addition, there are charts that explain restrictions on reporting waste management codes for the toxic chemicals in each of

the four groups. This appendix only shows where reporting is restricted in TRI-ME, it does not indicate every situation where

a metal should not be reported in a specific section of the form. For example, TRI-ME does not restrict the reporting of most

individually-listed metal compounds as used for energy recovery (Sections 8.2 and 8.3) even though some of these chemicals

do not have a heat value greater that 5000 British thermal units (Btu) and, thus, can not be combusted for energy recovery. It

is left to the facility to decide which of these toxic chemicals can be used for energy recovery. If you are not using TRI-ME

this appendix can serve as a guide to help you understand where it is not appropriate to report certain quantities of toxic

chemicals or waste management codes on your Form R.

Parent Metals:

Antimony

Arsenic

Barium

Beryllium

Cadmium

Chromium

Cobalt

Copper

Lead

Manganese

Mercury

Nickel

Selenium

Silver

Thallium

Metal Compound

Categories:

Antimony Compounds

Arsenic Compounds

Barium Compounds

Beryllium Compounds

Cadmium Compounds

Chromium Compounds

Cobalt Compounds

Copper Compounds

Lead Compounds

Manganese Compounds

Mercury Compounds

Nickel Compounds

Selenium Compounds

Silver Compounds

Thallium Compounds

Vanadium Compounds

Zinc Compounds

Metals with

Qualifiers:

Aluminum (fume or dust)

Vanadium (except when

in an alloy)

Zinc (fume or dust)

Individually-Listed

Metal Compounds:

Bis(tributylin) oxide

Triphenyltin hydroxide

Triphenyltin chloride

Molybdenum trioxide

Thorium dioxide

Asbestos (friable)

Aluminum oxide (fibrous

forms)

Tributyltin fluoride

Tributyltin

methacrylate

Titanium

tetrachloride

Boron trifluoride

Metiram

Boron trichloride

Zineb

Maneb

Fenbutatin oxide

Iron pentacarbonyl

Ferbam

C.I. Direct Brown

95

Osmium tetroxide

Aluminum

phosphide

C.I. Direct Blue

218

Sections 5.3 - Discharges to Water and 6.1 - Transfers to POTWs

The following chart indicates which metals can be reported as released to water in Section 5.3 or to POTW’s in Section 6.1.

Only zinc (fume or dust) and aluminum (fume or dust) are not reported in these sections because the fume or dust form of a

toxic chemical can not exist in water.

Form R Section in

Part II Parent Metals Metal CategoryCompounds

Metals with

Qualifiers

Individually-listed

Metal Compounds

Section 5.3 -

Discharges to

receiving streams or

water bodies

All All Vanadium (except

when contained in an

alloy)

All except Asbestos

Section 6.1-

Discharges to

POTWs

All All Vanadium (except

when contained in an

alloy)

All except Asbestos
Appendix B

B-6 Toxics Release Inventory Reporting Forms and Instructions

Section 6.2. Transfers to Other Off-Site Locations

Any toxic chemical may be reported in Section 6.2. However, TRI-ME will not allow certain M codes to be used when

reporting metals. The chart below indicates which M codes can be reported in Section 6.2 for the four groups of metals.

Note that all disposal M codes other than M41 and M62 can be used for all toxic chemicals. Code M24 is only made

available for the four groups of metals.

Waste Management Code for

Section 6.2

Parent

Metals

Metal Category

Compounds

Metals with

Qualifiers

Individuallylisted Metal

Compounds

M41 and M62 (disposal codes for

metals only)

All All Vanadium (except

when contained in an

alloy)

All except

Asbestos

M56 and M92 (energy recovery

codes)

None None None All except

Asbestos1

M20 and M28 (recycling codes) None None None All

M24, M26 and M93 (recycling

codes)

All All All All

M40, M50, M54, (treatment codes) None None All except Vanadium

(except when

contained in an alloy)

All

M61, M69, M95 (treatment codes) Barium2 Barium

Compounds2

Same as above All

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

TRI-ME allows any toxic chemical to be reported in Section 7A, however, it limits reporting in two ways. First, TRI-ME

limits the treatment codes that can be reported based on the General Waste Stream Code selected. If a TRI-ME user selects

General Waste Stream code “A – Gaseous”, all Waste Treatment Codes are made available. However, if a user selects from

the remaining three General Waste Stream Codes (W - Wastewater, L - Liquid waste streams, or S - Solid waste streams), the

“Air Emissions Treatment” Waste Treatment Codes are not made available. Second, the software restricts reporting for

certain toxic chemicals with qualifiers. When reporting zinc (fume or dust) or aluminum (fume or dust) TRI-ME will not

allow the user to select General Waste Stream Codes W-Wastewater and L-Liquid waste streams because the fume or dust

form of a toxic chemical can not exist in a liquid or water waste. For asbestos (friable) only S - Solid or A - Gaseous can be

selected. When reporting hydrochloric acid (acid aerosols) or sulfuric acid (acid aerosols) only A - Gaseous can be selected.

Crosswalk for Section 7A, Column B. Waste Treatment Method (s) Sequence

Air Emissions Treatment (applicable to gaseous waste streams only)

(No change — same as previous codes)

A01 Flare

A02 Condenser

A03 Scrubber

A04 Absorber

A05 Electrostatic Precipitator

A06 Mechanical Separation

A07 Other Air Emission Treatment
Appendix B

Toxics Release Inventory Reporting Forms and Instructions B-7

Biological Treatment:

Previous Codes New Codes (adapted from RCRA Hazardous Waste Management

Codes)

B11 Aerobic H081 Biological treatment with or without precipitation

B21 Anaerobic H081 Biological treatment with or without precipitation

B31 Facultative H081 Biological treatment with or without precipitation

B99 Other Biological

Treatment

H081 Biological treatment with or without precipitation

Chemical Treatment:

Previous Codes New Codes (adapted from RCRA Hazardous Waste Management

Codes)

C01 Chemical Precipitation B

Lime or Sodium Hydroxide

H071 Chemical reduction with or without precipitation

C02 Chemical Precipitation B

Sulfide

H071 Chemical reduction with or without precipitation

C09 Chemical Precipitation B

Other

H077 Other chemical precipitation with or without pretreatment

C11 Neutralization H121 Neutralization

C21 Chromium Reduction H071 Chemical reduction with or without precipitation

C31 Complexed Metals

Treatment (other than pH

adjustment)

H129 Other treatment

C41 Cyanide Oxidation B

Alkaline Chlorination

H073 Cyanide destruction with or without precipitation

C42 Cyanide Oxidation B

Electrochemical

H073 Cyanide destruction with or without precipitation

C43 Cyanide Oxidation B Other H073 Cyanide destruction with or without precipitation

C44 General Oxidation

(including Disinfection) B

Chlorination

H075 Chemical oxidation

C45 General Oxidation

(including Disinfection) B

Ozonation

H075 Chemical oxidation

C46 General Oxidation

(including Disinfection) B

Other

H075 Chemical oxidation

C99 Other Chemical Treatment H129 Other treatment
Appendix B

B-8 Toxics Release Inventory Reporting Forms and Instructions

Chemical Treatment:

Previous Codes New Codes (adapted from RCRA Hazardous Waste Management

Codes)

Incineration/Thermal Treatment: (Note: Only report combustion for the purposes of incineration/thermal

treatment in Section 7A. If the method involves combustion for the purposes of energy recover, report as U01,

U02, or U03 in Section 7B. If the method involves combustion for the purposes of materials recovery, report as

H39 in Section 7C.)

F01 Liquid Injection H040 Incineration B thermal destruction other than use as a

fuel

F11 Rotary Kiln with Liquid

Injection Unit

H040 Incineration B thermal destruction other than use as a

fuel

F19 Other Rotary Kiln H040 Incineration B thermal destruction other than use as a

fuel

F31 Two Stage H040 Incineration B thermal destruction other than use as a

fuel

F41 Fixed Hearth H040 Incineration B thermal destruction other than use as a

fuel

F42 Multiple Hearth H040 Incineration B thermal destruction other than use as a

fuel

F51 Fluidized Bed H040 Incineration B thermal destruction other than use as a

fuel

F61 Infra-Red H040 Incineration B thermal destruction other than use as a

fuel

F71 Fume/Vapor H040 Incineration B thermal destruction other than use as a

fuel

F81 Pyrolytic destructor H040 Incineration B thermal destruction other than use as a

fuel

F82 Wet air oxidation H076 Wet air oxidation

F83 Thermal Drying/Dewatering H122 Evaporation

F99 Other Incineration/Thermal

Treatment

H040 Incineration B thermal destruction other than use as a

fuel

Physical Treatment:

Previous Codes New Codes (adapted from RCRA Hazardous Waste

Management Codes)

P01 Equalization H129 Other treatment

P09 Other blending H129 other treatment

P11 Settling/clarification H123 Settling or clarification

P12 Filtration H123 Settling or clarification

P13 Sludge dewatering (non-thermal) H101 Sludge treatment and/or dewatering

P14 Air flotation H124 Phase separation

P15 Oil skimming H124 Phase separation

P16 Emulsion breaking B thermal H124 Phase separation

P17 Emulsion breaking B chemical H124 Phase separation
Appendix B

Toxics Release Inventory Reporting Forms and Instructions B-9

Physical Treatment:

Previous Codes New Codes (adapted from RCRA Hazardous Waste

Management Codes)

P18 Emulsion breaking B other H124 Phase separation

P19 Other liquid phase separation H124 Phase separation

P21 Adsorption B Carbon H082 Adsorption

P22 Adsorption B Ion exchange (other

than for recovery/reuse)

H082 Adsorption

P23 Adsorption B Resin H082 Adsorption

P29 Adsorption B Other H082 Adsorption

P31 Reverse Osmosis (other than for

recover/reuse)

H129 Other treatment

P41 Stripping B Air H083 Air or steam stripping

P42 Stripping B Steam H083 Air or steam stripping

P49 Stripping B Other H083 Air or steam stripping

P51 Acid Leaching (other than for

recovery/reuse)

H129 Other treatment

P61 Solvent Extraction (other than

recovery/reuse)

H129 Other treatment

P99 Other Physical Treatment H129 Other treatment

Solidification/Stabilization:

Previous Codes New Codes (adapted from RCRA Hazardous Waste

Management Codes)

G01 Cement processes

(including silicates)

H111 Stabilization or chemical fixation prior to

disposal

G09 Other Pozzolonic

Processes (including

silicates)

H111 Stabilization or chemical fixation prior to

disposal

G11 Asphaltic Techniques H111 Stabilization or chemical fixation prior to

disposal

G20 Thermoplastic

Techniques

H111 Stabilization or chemical fixation prior to

disposal

G99 Other Solidification

Processes

H111 Stabilization or chemical fixation prior to

disposal

Section 7B. On-site Energy Recovery Processes

The chart below indicates which energy recovery codes can be reported in TRI-ME in Section 7B for the four groups of

metals.

Energy Recovery Code for Section

7B

Parent

Metals

Metal

Category

Compounds

Metals with

Qualifiers

Individuallylisted Metal

Compounds

U01, U02, U03 None None None All except

Asbestos1
Appendix B

B-10 Toxics Release Inventory Reporting Forms and Instructions

Section 7C. On-site Recycling Processes

Any chemical can be reported in Section 7C. However, certain waste management codes should not be reported for certain

toxic chemicals. The chart below indicates which codes can be reported in Section 7C when using TRI-ME.

Recycling Code for Section 7C Parent

Metals

Metal Category

Compounds

Metals with

Qualifiers

Individuallylisted Metal

Compounds

H10(this code is for metals only All All All All

H20 None None None All

H39 All All All All

Crosswalk for Section 7C. On-site Recycling Processes

Previous Codes New Codes (adapted from RCRA Hazardous Waste Management

Codes)

R11 Solvents/Organics Recovery B

Batch Still Distillation

H20 Solvent Recovery (including distillation, evaporation,

fractionation or extraction)

R12 Solvents/Organics Recovery B

Thin-Film Evaporation

H20 Solvent Recovery (including distillation, evaporation,

fractionation or extraction)

R13 Solvents/Organics Recovery B

Fractionation

H20 Solvent Recovery (including distillation, evaporation,

fractionation or extraction)

R14 Solvents/Organics Recovery B

Solvent Extraction

H20 Solvent Recovery (including distillation, evaporation,

fractionation or extraction)

R19 Solvents/Organics Recovery B

Other

H20 Solvent Recovery (including distillation, evaporation,

fractionation or extraction)

R21 Metals Recovery B

Electrolytic

H10 Metal Recovery (by retorting, smelting, or chemical or physical

extraction)

R22 Metals Recovery B Ion

Exchange

H10 Metal Recovery (by retorting, smelting, or chemical or physical

extraction)

R23 Metals Recovery B Acid

Leaching

H10 Metal Recovery (by retorting, smelting, or chemical or physical

extraction)

R24 Metals Recovery B Reverse

Osmosis

H10 Metal Recovery (by retorting, smelting, or chemical or physical

extraction)

R26 Metals Recovery B Solvent

Extraction

H10 Metal Recovery (by retorting, smelting, or chemical or physical

extraction)

R27 Metals Recovery B High

Temperature

H10 Metal Recovery (by retorting, smelting, or chemical or physical

extraction)
Appendix B

Toxics Release Inventory Reporting Forms and Instructions B-11

Previous Codes New Codes (adapted from RCRA Hazardous Waste Management

Codes)

R28 Metals Recovery B Retorting H10 Metal Recovery (by retorting, smelting, or chemical or physical

extraction)

R29 Metals Recovery B Secondary

Smelting

H10 Metal Recovery (by retorting, smelting, or chemical or physical

extraction)

R30 Metals Recovery B Other H10 Metal Recovery (by retorting, smelting, or chemical or physical

extraction)

R40 Acid Regeneration H39 Other recovery or reclamation for reuse (including acid

regeneration or other chemical reaction process)

R99 Other Reuse or Recovery H39 Other recovery or reclamation for reuse (including acid

regeneration or other chemical reaction process)

Section 8. Source Reduction and Recycling Activities

The chart below indicates which metals can be reported in Sections 8.2, 8.3, 8.6 and 8.7 of the Form R when using TRI-ME.

Note that all toxic chemicals can be reported in Sections 8.1, 8.4, 8.5 and 8.8.

Waste Management Activity Parent

Metals

Metal Category

Compounds

Metals with

Qualifiers

Individuallylisted Metal

Compounds

Quantity used for energy recovery

on site and off site (Sections 8.2

and 8.3)

None None None All except

Asbestos2

Quantity treated for destruction on

site and off site (Sections 8.6 and

8.7)

None

except

Barium2

None except

Barium

Compounds2

All except

Vanadium

(except when

contained in an

alloy)

All

1

1 Although TRI-ME does not restrict reporting of most individually-listed metal compounds as transferred off site for

energy recovery, only chemicals with a heat value greater than 5000 British thermal units that are combusted in a device

that is an industrial furnace or boiler (40 CFR Section 372.3) should be reported as used for energy recovery.

2 The toxic chemical category barium compounds (N040) does not include barium sulfate. Because barium sulfate is not a

listed toxic chemical, the conversion in a waste stream of barium or barium compound to barium sulfate is considered

treatment for destruction (40 CFR Section 372.3).
Toxics Release Inventory Reporting Forms and Instructions C-1

Appendix C. Facility Data Profiles and Common

Errors in Completing Form R Reports and Form A

Certification Statements

EPA wishes to ensure that facilities submit all required TRI

chemical submissions in a timely manner so that the

information may be included in its national database, National

Analysis (formerly called the public Data Release (PDR)), and

other information products. Moreover, EPA seeks to ensure

that all submitted data are complete and accurate. This

appendix provides an overview of the Facility Data Profile

(FDP), an important communication tool that EPA uses to

ensure consistent, complete, and accurate submissions from

reporting facilities. This appendix also provides specific

guidance to avoid common errors in completing Form Rs and

Form A Certification Statements, including errors in threshold

determination, misapplication of exemptions, and activities

involving a reportable chemical, any of which may result in the

erroneous non-reporting of a chemical.

C.1 Facility Data Profile

(FDP)

FDPs are made available by the TRI Data Processing Center

to a reporting facility in response to any submission the TRI

Data Processing Center receives. You may review your FDP

on the Internet at http://www.triefdp.org. It is very important

that you review your FDP. If the Technical Contact provided

an email address in the Form R/Form A, they will receive a

real-time email notifying them when their FDP has been

updated and posted to the FDP Web site. A submission can

include an original or revised Form R or Form A, or

corrections included in a response to a previous FDP. The

FDP serves two primary purposes. First, EPA wants to give

the reporting facility the opportunity to confirm that the TRI

Data Processing Center has entered its data correctly into

EPA’s national computer system i.e. the TRI Data Processing

Center echoes back the information that it has received.

Second, if the TRI Data Processing Center identifies potential

errors in the forms a facility has submitted, the FDP indicates

what these errors are and requests that the facility provide EPA

with corrections. The FDP does not serve as a means to

withdraw a Form R and/or Form A. For additional information

regarding withdrawal procedures see Section A.5 of this

document or go to http://www.epa.gov/tri. If you have

questions regarding your FDP, please send an email to

tridpc@epacdx.net or call,(703) 227-7644. Facilities that send

corrections in response to their FDPs are encouraged to submit

a revision using CDX. For additional instructions regarding

your FDP, please refer to your FDP.

An FDP is comprised of the following sections:

 Facility Information. This section displays all

facility-specific data, including TRI Facility

Identification (TRIFID), facility name, facility

address, facility mailing address, relevant permits

(e.g., RCRA, NPDES, and UIC), North American

Industry Classification System code (NAICS), and

other facility data. Errors related to facility

information will be marked in this section.

 Instructions Page. This page provides instructions

on how to review and respond to the FDP.

 Certification Statement Signature Page. This page

provides the Certification Statement to be signed by a

facility owner/operator or senior management official

if using the FDP to make a revision.

 Chemical Report Summary. This section lists all

chemicals reported by the facility for each reporting

year covered by the FDP. For example, if the FDP is

responding to five original chemical submissions for

Reporting Year 2009 and revisions to one chemical

for Reporting Year 2007, a list of all chemicals for

both years will appear.

 Errors/Alerts Identified In This Report: NonTechnical Data Changes (NDC), Notices of

Technical Errors (NOTE), Notices of Significant

Error (NOSE), and Data Quality Alerts (DQA).

FDPs identify three different types of errors: NDCs,

NOTEs and NOSEs and one type of alert called Data

Quality Alert (DQA). See explanations in section B.

 Error Summary Page. The Error Summary Page

provides facilities an error/alert count for each

chemical submission.

 Chemical Reports. All recently submitted and

processed Form R or Form A data (i.e., chemical

specific data) are displayed in the chemical reports

under the appropriate facility or subordinate facility

names. The FDP displays facsimiles for chemical

reports for submissions received during the current

calendar year and revisions or responses to FDPs

only. For example, if a facility originally reported

five chemicals for Reporting Year 2009, and

subsequently revises only one chemical submission,

the facility will receive an FDP for Reporting Year

2009 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
Appendix C

C-2 Toxics Release Inventory Reporting Forms and Instructions

changes have occurred (i.e., Part I of the Form R or

A), this section is not provided.

C.2 Levels of Errors

Identified in FDPs: Notice of

Non-Technical Data Change

(NDC), Notice of Technical

Errors (NOTE), Notice of

Significant Errors (NOSE),

Notice of Noncompliance

(NON)

FDP Error Reporting. In addition to echoing back the

information a facility has submitted, FDPs are used to identify

potential errors and provide Data Quality Alerts, as well as

indicate where the TRI Data Processing Center has made

minor clerical changes to submissions. As submission

information is entered into EPA’s national database, a series of

automated data quality checks are performed. The data quality

checks are useful to identify potential errors with certain data

fields such as TRI Facility Identification, facility name, county

spelling, as well as to perform validation checks to ensure

consistency among data elements within a given Form R or

Form A. These data quality checks, however, cannot detect

whether release, transfer, or waste management quantities were

calculated or entered accurately. Within a FDP notice, there

may be up to three different types of errors identified.

TRI-MEweb Error Reporting. One of the advantages of

using the online electronic TRI-MEweb reporting system is that

it will notify submitters of several classes of common errors,

decreasing the potential for reporting errors on the initial

submission that will have to be corrected later.

First, a Non-Technical Data Change (NDC) notifies you of

simple, clerical errors that the TRI Data Processing Center has

corrected for you. It is not necessary to respond to a NDC.

The TRI Data Processing Center will correct simple, clerical

errors that are not technical or scientific - a “non-technical

data change.” For example, if a facility transposes CAS

numbers (e.g., the submitter lists 7623-00-0 for sodium nitrite

instead of 7632-00-0), the TRI Data Processing Center will

correct this clerical error and display the correct information

on the facility’s FDP. If a facility lists a specific glycol ethers

subcategory, the TRI Data Processing Center will replace this

subcategory with the reportable name Acertain glycol ethers.”

The messages used on FDPs to report non-technical data

changes are shown at the end of this appendix under the

heading AE. Messages Used to Report Notices of Technical

Errors (NOTEs) and Non-technical Data Changes (NDCs).”

Second, a Notice of Technical Error (NOTE) highlights

inconsistencies or miscalculations that may distort your

facility’s information in EPA’s public data products or skew

analyses. Incomplete addresses, no technical or public contact

provided, missing or invalid NAICS codes, or the use of range

codes to report PBT chemical releases are all examples of

technical errors. You should respond to NOTEs as soon as

possible. These types of errors require that the reporting

facility make corrections on its FDP (or provide the TRI Data

Processing Center with a brief explanation why they do not

believe that it is an error) or submit a revised Form R or Form

A. Depending upon when your changes are received, there

may or may not be sufficient time to incorporate them into

EPA’s database in time for public data release. Technical

errors do not prevent submissions from being entered into the

data management system, but indicate inconsistencies or

miscalculations in the submitted form. These errors can distort

public information products and skew any analyses if not

corrected. The messages used on FDPs to report NOTEs are

shown below at the end of this appendix under the heading “D.

Messages Used to Report Notices of Technical Errors

(NOTEs) and Non-technical Data Changes (NDCs).”

Third, more serious errors are classified as Notices of

Significant Errors (NOSE). The FDP contains the Notice of

Significant Error if applicable. Significant errors prevent

submissions from being entered into the TRI Data Processing

Center data management system or do not allow the TRI Data

Processing Center to verify the authenticity of the submission.

Invalid forms, missing pages, no certification signature, no

chemical name or CAS number are examples of significant

errors. These types of errors require that the reporting facility

make corrections on their FDP, submit a revised Form R or

Form A, or provide the TRI Data Processing Center with a

brief explanation why they do not believe that it is an error. A

facility must respond to a Notice of Significant Error within 21

days of receipt. Failure to respond within the initial 21 day

requirement could result in the issuance of a Notice of

Noncompliance (NON). A Notice of Noncompliance is not

included in a FDP and is mailed separately.

The Agency will issue a Notice of Noncompliance (NON) to

a facility for failure to respond to a Notice of Significant Error

(NOSE) within the required period. A NON will require a

facility to take the corrective action noted in the NOSE within

30 days and respond to the Agency that corrective action has

been taken. If a facility fails to respond to the NON within the

required time period, the Agency may take further action.

Facilities must keep copies, for three years, of submitted Form

R reports and Form A certifications and all documentation

used to complete their submissions. This documentation

should include calculations for threshold determinations, the

basis of exemptions applied, and the estimation techniques and

data used for all quantities reported on the Form R and Form

A.

For the first time beginning with RY 2004, TRI will provide

Data Quality Alerts (DQA). The DQA informs facilities of
Appendix C

Toxics Release Inventory Reporting Forms and Instructions C-3

possible reporting issues, such as a large percentage change in

reported amounts of the same chemical between years. It is

offered to assist facilities in ensuring accurate reporting.

C.3 Common Errors in

Completing Form R Reports

and Form A Certification

Statements, including

Reporting Determination

Errors

General Considerations

 Lack of signed Certification Statement. If you

choose not to send your TRI submissions via the

paperless CDX process, you must sign Part I, Section

3 of your hard copy submission. Although EPA

accepts paper submissions, EPA strongly encourages

you to send your submission via CDX.

 Incomplete Forms. A complete Form R report for a

single EPCRA section 313 chemical or single

EPCRA section 313 chemical category consists of

five pages stapled together. By using TRI-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, and/or 5s. Such forms are considered

incomplete submissions.

Threshold Determinations

 Calculating threshold determinations. Annual

quantities manufactured, processed, or otherwise

used for section 313 chemicals must be calculated,

not surmised. The assumption that thresholds are

exceeded commonly leads to error.

 Misclassification of EPCRA section 313 chemical

activity. Failure to correctly classify an EPCRA

section 313 chemical activity may result in an

incorrect threshold determination. As a result, a

facility may fail to submit the required Form R.

 EPCRA section 313 chemical activity overlooked.

Many facilities believe that because the section 313

reporting requirement pertains to manufacturers, only

the use of EPCRA section 313 chemicals in

manufacturing processes must be examined. Any

activity involving the manufacture, process, or

otherwise use of an EPCRA section 313 chemical or

chemical category must be included in threshold

determinations. Commonly overlooked activities

include importation of chemicals, generation of waste

byproducts, processing of naturally occurring metals

and metal category compounds in ore, manufacturing

and processing intermediates, the use of chemicals

for cleaning of equipment, and the generation of

byproducts during combustion of coal and/or oil.

Facilities should take a systematic approach to

identify all chemicals and mixtures used in

production and non-production capacities, including

catalysts, well treatment chemicals, and wastewater

treatment chemicals.

 Considering EPCRA section 313 chemicals in

mixtures and other trade name products. EPCRA

section 313 chemicals contained in mixtures

(including ores and stainless steel alloys) and other

trade name products must be factored into threshold

determinations and release and other waste

management determinations, provided that the de

minimis exemption cannot be taken. When the

EPCRA section 313 chemical being reported is a

component in a mixture or other trade name product,

report only the weight of the EPCRA section 313

chemical in the mixture. Refer to Section B.4b of this

document to calculate the weight of an EPCRA

section 313 chemical in a mixture or other trade name

product.

 Overlooking manufacturing. Coincidental

manufacturing must not be overlooked. If coal and/or

fuel oil and other raw materials that contain EPCRA

section 313 chemicals are used in boilers/burners,

there is a potential for the coincidental manufacture

of EPCRA section 313 chemicals such as sulfuric

acid (acid aerosols), hydrochloric acid (acid

aerosols), hydrogen fluoride, and metal category

compounds. Additionally, manufacturing of EPCRA

section 313 chemicals during waste treatment is

commonly overlooked. For example, the treatment of

nitric acid may result in the manufacturing of a

reportable chemical (nitrate compounds).

Container Residue

 Overlooking container residue. Container residue

must not be disregarded in release and other waste

management calculations. Even a “RCRA empty”

drum is expected to contain a residue and it must be

considered for TRI reporting. Additionally, on-site

drum rinsing and disposal of the rinsate will result in

a release and other waste management activity. Refer

to Estimating Releases and Waste Treatment

Efficiencies for Toxic Chemical Reporting Forms.
Appendix C

C-4 Toxics Release Inventory Reporting Forms and Instructions

Part I. Facility Identification Information

Section 1. Reporting Year

 Invalid Forms. The correct version of the form for

the reporting year in question must be used. For

example, forms provided for reporting years

1987-1990 must not be used to report data for

reporting years 1991-1995. Form Rs provided for

reporting years 1991-1995 must not be used to report

data for years 1996 and later

Section 2. Trade Secret Information

 Incorrect completion of trade secret information.

The responses to trade secret questions in Part I

Section 2 and Part II Section 1.3 of Form R/Form A

must be consistent. If trade secrecy is indicated, a

sanitized Form R/Form A and two trade secret

substantiations (one sanitized) must be submitted in

the same package as the unsanitized trade secret

Form R/Form A. Part II Section 1.3 should be blank

if no trade secret claim is being made. Also, if you

indicate in Part I, Section 2.1 that you are not

claiming trade secret information, leave Part I, 2.2

blank.

Section 3. Certification

 Missing certification signature. If you are

submitting your Form R and/or Form A by hardcopy,

an original certification signature must appear on

page 1 of every Form R and/or Form A submitted to

EPA. If you are submitting your Form R and/or

Form A via 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 Significant Error (NOSE) if they remain

uncertified after the July 1st reporting deadline.

Section 4. Facility Identification

 Questionable entries. Incorrect entries may require

corrections to be made by the facility. The use of the

TRI-MEweb software prevents most errors from

occurring. Questionable entries may include:

– Missing or incorrect street address;

– Missing or incorrect ZIP codes;

– Missing County names;

– Invalid SIC codes;

– Missing or invalid Dun & Bradstreet

numbers;

– Missing or invalid RCRA, NPDES, or UIC

numbers; and

– Incomplete off-site and POTW information

(e.g., missing city name)

If amounts are reported in units other than pounds (e.g., metric

units) or with exponential numbers, EPA may require a

revision of the Form R/Form A submitted. The exception is

for the reporting of dioxin and dioxin-like compounds where

the amounts are reported in grams.
Appendix C

Toxics Release Inventory Reporting Forms and Instructions C-5

Part II. Chemical-Specific Information

Section 1. Toxic Chemical Identity

 Reporting chemical abstract service (CAS)

registry numbers in Section 1.1. Beginning with

the 1991 reporting year, EPA has assigned

alphanumeric category codes to the twenty chemical

categories for the purposes of reporting the CAS

number field in Section 1.1. When completing a

Form R for a chemical category, the appropriate code

for that category must be provided in Section 1.1.

The CAS numbers are listed in Table II: “Section 313

Toxic Chemical List,” and if needed, the category

codes are listed in Appendix B: “Reporting Codes for

EPA Form R.” Category guidance documents are

listed in the Chemical and Industry Guidance

Documents section in this document.

 Failure to check for synonyms. Some reportable

chemicals (especially glycol ethers and toluene

diisocyanates) have many synonyms that do not

readily imply they are in the category. For example,

benzene,1,3-diisocyanatomethyl may not be readily

recognized as toluene diisocyanate (mixed isomers).

 Invalid chemical identification in Section 1.2. The

CAS number and the chemical name reported here

must exactly match the listed official EPCRA section

313 CAS number and EPCRA section 313 chemical

name.

 Failure to consider an EPCRA section 313

chemical qualifier. Only EPCRA section 313

chemicals in the form specified in the qualifier

require reporting under section 313 and should be

reported on Form R with the appropriate qualifier in

parentheses. For example, isopropyl alcohol is listed

on the EPCRA section 313 chemical list with the

qualifier manufacturing- strong acid process, no

supplier notification. Thus, the ONLY facilities that

should report this EPCRA section 313 chemical are

those that manufacture isopropyl alcohol by the

strong acid process.

 Generic chemical name in Section 1.3. A generic

chemical name should only be provided if the section

313 chemical identity is claimed as a trade secret.

Section 2. Mixture Component Identity

 Identifying chemicals used in mixtures. Facilities

should carefully review the most recent MSDS or

supplier notification for every mixture brought onsite to identify all section 313 chemicals used during

a reporting year. Although some mixtures may not

have MSDSs, the best readily available information

should be used to determine the presence of EPCRA

section 313 chemicals in ores and alloys.

 Mixture names in Section 2.1. Mixture names are to

be entered here only if the supplier is claiming the

identity of the EPCRA section 313 chemical a trade

secret and that is the sole identification. Mixture

names that include the name or CAS number of one

or more EPCRA section 313 chemicals are not valid

uses of the mixture name field.

Section 3. Activities and Uses of the Toxic

Chemical at the Facility

 Reporting EPCRA section 313 chemical activity.

EPCRA section 313 chemical activity is commonly

overlooked or misclassified. Any activity involving

the manufacture, process, or otherwise use of an

EPCRA section 313 chemical must be examined. For

example, waste treatment operations otherwise use

EPCRA section 313 chemicals to treat waste streams

and may coincidentally manufacture an additional

EPCRA section 313 chemical as a result of the

treatment reaction. Such activity must be considered.

Further, EPCRA section 313 chemical activity must

be correctly classified as either “manufactured,”

“processed,” or “otherwise used.”

 Section 3.1 Manufacture means to produce, prepare,

compound, or import an EPCRA section 313

chemical.

 Section 3.2 Process means the preparation of

an EPCRA section 313 chemical after its

manufacture, which usually includes the

incorporation of the EPCRA section 313 chemical

into the final product, for distribution in commerce.

 Section 3.3 Otherwise use encompasses any use

of an EPCRA section 313 chemical that does not fall

under the terms “manufacture” or “process,” and

includes treatment for destruction, stabilization

(without subsequent distribution in commerce),

disposal, and other use of an EPCRA section 313

chemical, including an EPCRA section 313 chemical

contained in a mixture or other trade name product.

Otherwise use of an EPCRA section 313 chemical

does not include disposal, stabilization (without

subsequent distribution in commerce), or treatment

for destruction unless:

1. The EPCRA section 313 chemical that was

disposed, stabilized, or treated for destruction

was received from off-site for the purposes of

further waste management; or

2. The EPCRA section 313 chemical that was

disposed, stabilized, or treated for destruction

was manufactured as a result of waste

management activities on materials received

from off-site for the purposes of further waste

management activities.
Appendix C

C-6 Toxics Release Inventory Reporting Forms and Instructions

For example, solvents in paint applied to a manufactured

product are often misclassified as processed, instead of

otherwise used. Because the solvents are not incorporated into

the final product, the solvent is being otherwise used, not

processed.

Section 4. Maximum Amount of the Toxic

Chemical On-site at Any Time During the

Calendar Year

 Maximum amount on-site left blank. Failure to

provide the appropriate code for maximum amount

on site.

Section 5. Quantity of the Toxic Chemical

Entering Each Environmental Medium On-site

 Incorrectly reporting stack emissions. Fugitive

emissions from general indoor air should not be

reported as stack missions when released from a

single building vent. Additionally, stack emissions

from storage tanks, including loading, working, and

breathing losses from tanks, should not be

overlooked or reported as fugitive emissions.

 Overlooking releases to land. Section 313

chemicals placed in stockpiles or in surface

impoundments should be reported as a “release to

land” even if no section 313 chemicals leak from

these sources. Quantities of section 313 chemicals

land-treated should be reported as a release to land.

Section 6. Transfers of the Toxic Chemical in

Wastes to Off-site Locations

 Reporting discharges to POTWs in Section 6.1.

When quantities of a listed mineral acid are

neutralized to a pH of 6 or greater, the quantity

reported as discharged to a POTW should be

reported as zero. It is incorrect to enter “NA” (Not

Applicable), in such a situation.

 Reporting other off-site transfers in Section 6.2.

Any quantities reported in Sections 8.1, 8.3, 8.5, and

8.7 as sent off-site for disposal, treatment, energy

recovery, or recycling, respectively, must also be

reported in Section 6.2 along with the receiving

location and appropriate off-site activity code.

Section 7A. On-Site Waste Treatment

Methods and Efficiency

 Failure to report waste treatment methods in

Section 7A. Waste treatment methods used to treat

waste streams containing EPCRA section 313

chemicals, and the efficiencies of these methods,

must be reported on Form R. Information must be

entered for all waste streams, even if the waste

treatment method does not affect the EPCRA section

313 chemical. If no waste treatment is performed on

waste streams containing the EPCRA section 313

chemical, the box marked Not Applicable in Section

7A should be checked on Form R.

 Incorrect reporting of waste treatment methods in

Section 7A. The type of waste stream, waste

treatment efficiency, and waste treatment method for

each waste stream are required to be reported on

Form R using specific codes. The waste treatment

codes are listed in Appendix B: Reporting Codes for

EPA Form R. A table is also provided in Appendix

B that displays a crosswalk between the old codes

and new ones for reporting year 2005.

Section 7B. On-Site Energy Recovery

Processes

 Reporting on-site energy recovery methods in

Section 7B. When a quantity is reported in Section

8.2 as combusted for energy recovery on-site, the

type of energy recovery system used must be reported

in Section 7B, and vice versa.

Section 7C. On-Site Recycling Processes

 Reporting on-site recycling methods in Section

7C. When a quantity is reported in Section 8.4 as

recycled on-site, the type of recovery method must be

reported in Section 7C, and vice versa.

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.

 Columns C and D, the future year projections for

questions 8.1 through 8.7, must be completed. EPA

expects a reasonable estimate for the future year

projections. Zero can be used in columns C and D to

indicate that the manufacture, process, or otherwise

use of the chemical will be discontinued. In such

cases, columns C and D for Section 8.1 through 8.7

must all contain zeroes.

 It is incorrect to use range codes to report quantities

in Section 8. Range codes can be used only in

Sections 5 and 6 of Form R.

 It is incorrect to use the same codes from Section 4
Appendix C

Toxics Release Inventory Reporting Forms and Instructions C-7

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, or

otherwise released either on- or off-site, that quantity

of the EPCRA section 313 chemical must be included

in the quantities reported in Sections 8.1 through 8.7

 Reporting quantities in Section 8.1 Quantities of

EPCRA section 313 chemicals that are released

(including disposed) on-site and reported in Section 5

of Form R must be reported in either Section 8.1a or

8.1b.

§8.1a = § 5.4.1 + § 5.5.1A + § 5.5.1B - § 8.8 (on-site

release or disposal due to catastrophic events)1

§ 8.1b = § 5.1 + § 5.2 + § 5.3 + § 5.4.2 + § 5.5.2 + §

5.5.3A + § 5.5.3B + §5.5.4 - § 8.8 (on-site release or

disposal due to catastrophic events)1

Quantities of EPCRA section 313 chemicals

transferred off-site for the purposes of disposal

reported in Section 6.2 using the following codes

must appear in Section 8.1c:

– M64 Other Landfills

– M65 RCRA Subtitle C Landfills

– M81 Underground Injection to Class I Wells

§ 8.1c = § 6.1 (portion of transfer that is untreated

and ultimately disposed of in UIC Class I Wells,

RCRA Subtitle C landfills, and other landfills) + §

6.2 (quantities associated with M codes M64, M65

and M81) - § 8.8 (off-site disposal due to

catastrophic events)1

Metals and metal category compounds transferred

off-site to POTWs in Section 6.1 must appear in

Section 8.1c or 8.1d. To report correctly in Sections

8.1a through d, a facility must include quantities that

are disposed or otherwise released to the environment

either on-site or off-site, excluding disposal or other

releases due to catastrophic events or non-production

related activities.

Quantities of EPCRA section 313 chemicals

transferred off-site for the purposes of disposal

reported in Section 6.2 using the following codes

must appear in Section 8.1d:

– M10 Storage Only

– M41 Solidification/Stabilization - Metals and

Metal Category Compounds Only

– M62 Wastewater Treatment (excluding

POTW) - Metals and Metal Category

Compounds Only

– M66 Subtitle C Surface Impoundment

– M67 Other Surface Impoundments

– M73 Land Treatment

– M79 Other Land Disposal

– M82 Underground Injection to Class II-V

Wells

– M90 Other Off-Site Management

– M94 Transfer to Waste BrokerCDisposal

– M99 Unknown.

§ 8.1d = § 6.1 (portion of transfer that is untreated

and ultimately disposed of in UIC Class II-V wells,

and disposal other than to landfills) + § 6.2

(quantities associated with M codes M10, M41, M62,

M66, M67, M73, M79, M82, M90, M94, M99) -- §

8.8 (off-site disposal due to catastrophic events)1

 Reporting quantities in Section 8.2 “Quantity

used for energy recovery on-site.” A quantity must

be reported in Section 8.2 for the current (reporting)

year when a method of on-site energy recovery is

reported in Section 7B, and vice versa. An error

facilities make when completing Form R is to report

the methods of energy recovery used on-site in

Section 7B but not report the total quantity associated

with those methods. Another error is to report a

quantity in this section if the combustion of the

EPCRA section 313 chemical took place in a system

that did not recover energy (e.g., an incinerator). A

quantity of the EPCRA section 313 chemical

1

§8.8 includes quantities of toxic chemicals disposed or otherwise released

on site or managed as a waste off site due to remedial actions, catastrophic

events, or one-time events not associated with the production processes.
Appendix C

C-8 Toxics Release Inventory Reporting Forms and Instructions

combusted for energy recovery must not be reported

if the EPCRA section 313 chemical does not have a

significant heating value. Examples of EPCRA

section 313 chemicals that do not have significant

heating values include metals, metal portions of metal

category compounds, and halons. Metals and metal

portions of metal compounds will never be treated or

combusted for energy recovery. Any quantities of the

EPCRA section 313 chemical associated with

non-production related activities such as catastrophic

releases and remedial actions, as well as other

one-time events not associated with routine

production practices that were combusted for energy

recovery on-site must not be included in Section 8.8.

 Reporting quantities in Section 8.3 “Quantity used

for energy recovery off-site.” As in Section 8.2, a

quantity must not be reported in this section if the

off-site combustion of the EPCRA section 313

chemical took place in a system that did not recover

energy (e.g., incinerator). A quantity of an EPCRA

section 313 chemical must not be reported as sent

off-site for the purposes of energy recovery if the

EPCRA section 313 chemical does not have a

significant heating value. Examples of EPCRA

section 313 chemicals that do not have significant

heating values include metals, metal portions of metal

category compounds, and halons. Metals and metal

portions of metal category compounds will never be

combusted for energy recovery. Quantities must be

reported in Section 8.3 that are reported in Section

6.2 as transferred off-site for the purposes of

combustion for energy recovery using the following

codes:

– M56 Energy Recovery

– M92 Transfer to Waste Broker C Energy

Recovery

§ 8.3 = § 6.2 (energy recovery) - § 8.8 (off-site

energy recovery due to catastrophic events)2

 Reporting quantities in Section 8.4 “Quantity

recycled on-site.” A quantity must be reported in

Section 8.4 for the current reporting year when a

method of on-site recycling is reported in Section 7C,

and vice versa. An error facilities make when

completing Form R is to report the methods of

recycling used on-site in Section 7C but not report

the total quantity recovered using those methods.

In addition, only the amount of the chemical that was

actually recovered is to be reported in Section 8.4.

Any quantities of the EPCRA section 313 chemical

associated with non-production related activities such

as catastrophic releases and remedial actions, as well

2

§8.8 includes quantities of toxic chemical disposed or otherwise released

on-site or managed as waste off-site due to remedial actions, catastrophic

events, or one-time events not associated with the production processes.

as other one-time events not associated with routine

production practices that were recycled on-site must

not be included in Section 8.8.

 Reporting quantities in Section 8.5. “Quantity

recycled off-site.” Quantities reported in Section 6.2

as transferred off-site for the purposes of recycling

must be included in Section 8.5 using the following

codes:

– M20 Solvents/Organic Recovery

– M24 Metals Recovery

– M26 Other Reuse or Recovery

– M28 Acid Regeneration

– M93 Transfer to Waste Broker C Recycling.

§8.5 = §6.2 (recycling) - §8.8 (off-site recycling due

to catastrophic events)2

 Reporting quantities in Section 8.6 “Quantity

treated on-site.” Quantities may not always have to

be reported in Section 8.6 when Section 7A is

completed. This is because the information reported

in Section 7A and Section 8 is different. Information

on how waste streams containing the reported

EPCRA section 313 chemical are treated is reported

in Section 7A, while the quantity of the EPCRA

section 313 chemical actually destroyed as a result of

on-site treatment is reported in Section 8.6. If a

quantity is reported in Section 8.6, Section 7A must

be completed but the reverse may not be true. This

may result in apparent discrepancies between Section

7A and Section 8. For example, a facility may treat

wastewater containing an EPCRA section 313

chemical by removing the EPCRA section 313

chemical and then disposing of it on-site. The

treatment of the wastewater would be reported in

Section 7A, with an efficiency estimate based on the

amount of the EPCRA section 313 chemical removed

from the wastewater. Although the waste stream has

been treated because the EPCRA section 313

chemical has been removed, the EPCRA section 313

chemical has not been treated because it has not been

destroyed. The facility would report only the amount

of the EPCRA section 313 chemical actually

destroyed during treatment in Section 8.6 and the

amount ultimately disposed in Section 8.1 to avoid

double-counting the same quantity in Section 8. In

cases where the EPCRA section 313 chemical is not

destroyed during a treatment process and

subsequently enters another activity, such as disposal

(e.g., metals removed from wastewater and

subsequently disposed on-site), the quantity of the

EPCRA section 313 chemical would be reported as

disposed in Section 8.1, not as treated in Section 8.6.

Any quantities of the EPCRA section 313 chemical

associated with non-production related activities such

as catastrophic releases and remedial actions, as well

as other one-time events not associated with routine
Appendix C

Toxics Release Inventory Reporting Forms and Instructions C-9

production practices that were treated for destruction

on-site must not be included in Section 8.8. Metals

generally will not be treated for destruction.

 Reporting quantities in Section 8.7 “Quantity

treated off-site.” Quantities reported in Section 6.2

as transferred off-site for the purposes of treatment

must be included in Section 8.7 using the following

codes:

– M40 Solidification/Stabilization

– M50 Incineration/Thermal Treatment

– M54 Incineration/Insignificant Fuel Value

– M61 Wastewater Treatment (excluding

POTW)

– M69 Other Waste Treatment

– M95 Transfer to Waste Broker C Waste

treatment.

Quantities of an EPCRA section 313 chemical,

except metals and metal category compounds, sent

off-site to a POTW should also be reported in Section

8.7. If you know, however, that a chemical is not

treated for destruction at the POTW you should

report that quantity in Section 8.1 instead of 8.7.

To report correctly EPCRA section 313 chemicals in

Section 8.7, use the following equation.

§8.7 =§6.1 (excluding most metal/metal category

compounds) + §6.2 (treatment) - §8.8 (off-site

treatment due to catastrophic events)3

 Reporting quantities in Section 8.8 Quantity

released to the environment as a result of

remedial actions, catastrophic events or one-time

events not associated with production processes.

The quantities that are reported in Section 8.8 are

associated with non-production related activities such

as catastrophic releases and remedial actions, as well

as one-time events not associated with routine

production practices, that were disposed or released

directly to the environment or transferred off-site for

the purposes of recycling, energy recovery, treatment

or disposal. Quantities reported in Section 8.8 must

not be reported in Section 8.1 through 8.7.

 Reporting the production ratio in Section 8.9. A

production ratio or activity index must be provided in

Section 8.9. A zero is not acceptable and NA (Not

Applicable) can be used only when the reported

EPCRA section 313 chemical was not manufactured,

processed, or otherwise used in the year prior to the

reporting year.

 Calculating production ratio in Section 8.9. In

3§8.8 includes quantities of toxic chemical disposed or otherwise released

on-site or managed as waste off-site due to remedial actions, catastrophic

events, or one-time events not associated with the production processes.

calculating a production ratio for otherwise used

chemicals, an activity index must be used rather than

quantities purchased or released from year to year.

 Reporting source reduction activities in Section

8.10. It is an error to report a source reduction

activity in Section 8.10 and not report at least one

method used to identify that activity and vice versa.

C.4 FDP Messages Used to

Report Notices of

Significant Errors

Note: EPA is continually trying to improve the error

checking system for TRI submissions. As a result, a

small number of the error messages in this appendix

may be changed by the time the Reporting Year 2009

submissions are checked. Most of these messages

will remain the same. You can look for changes to

these error messages on the TRI home page at

http://www.epa.gov/tri

1. You have used an invalid Form R or Form A by using

either a form not applicable for the reporting year, or

a facsimile form that has not been approved by EPA.

Resubmit your data on a current EPA approved Form

R or A.

2. Pages were missing from the form received. Correct

this by resubmitting a complete certified form for this

chemical substance.

3. Multiple chemicals were reported in your Form R.

You must submit a separate and complete Form R for

each chemical cited.

4. You have provided a valid CAS number and a valid

chemical name, but they do not match. Respond by

providing a valid CAS number and matching

chemical name.

5. You have left part or all of the chemical identification

sections blank. Respond by providing a valid CAS

number and matching chemical name or Mixture

Component Identity.

6. You reported a CAS number and chemical name that

are invalid. Respond by providing a valid CAS

number and matching chemical name.

7. Your form indicated Trade Secret status with an

indication that this form is a Sanitized version, but

the report contains no Generic Chemical Name. You

must provide a Generic Chemical Name for this

sanitized form.

8. You did not sign the Form Per EPCRA Section

313(g)(1)(B), each submission must contain an

original signature certifying the accuracy and

completeness of the information reported by signing

the certification statement on the Form or certified
Appendix C

C-10 Toxics Release Inventory Reporting Forms and Instructions

letter. Please be sure to sign the certification

statement in this FDP to certify your submission data.

9. You have reported Dioxin and Dioxin-like

Compounds on a Form A. Dioxin and Dioxin-like

Compounds are not eligible for the alternate

threshold. Thus, this chemical must be reported on a

Form R. Please resubmit your data on a Form R.

10. In Part I, Section 1of the Form R or Form A

Certification Statement You did not enter a reporting

year. (Note: EPA has set the year to 2084 as a

default.) You must enter a valid reporting year for

your Form R or Form A Certification Statement.

This entry cannot be left blank and NA may not be

used. (NOSE)

11. In Part I, Section 1of the Form R or Form A

Certification Statement you provided an invalid or

future reporting year. You must enter a valid

reporting year for your Form R or Form A

Certification Statement. Valid years are 1987 through

2002. This entry cannot be left blank and NA may

not be used. (NOSE)

12. You have reported a negative number(s) in Part II,

Sections 5 and/or 6 and/or 8 of your Form R.

Quantities reported in these sections must be 0 or

greater. Please respond by providing correct release

or other waste management data.

13. You did not complete Part II, Sections 5 and 6.

Please provide the required information; otherwise

indicate NA.

14. You did not complete Part II, Section 7. Please

provide the required information; otherwise indicate

NA.

15. You did not complete Part II, Section 8. Please

provide the required information; otherwise indicate

NA.

C.5 Messages Used to

Report Notices of Technical

Errors (NOTEs) and Nontechnical Data Changes

(NDCs)

Invalid codes throughout Form R

16. You submitted an invalid code. To correct this,

consult the instructions for the proper table value and

provide a valid code value. [Specific location on the

form of the invalid code is given.] (NOTE)

17. PBT chemicals (e.g., Dioxin and Dioxin-like

Compounds, Lead Compounds, Mercury Compounds

and Polycyclic Aromatic Compounds (PACs)) are

ineligible for range reporting for on-site releases and

transfers off-site for further waste management.

Please provide specific release, transfer, and other

waste management values.(NOTE)

18. For aluminum (fume or dust) or zinc (fume or dust),

the Waste Management codes M56 and M92 are

unacceptable. Please provide the proper Waste

Management codes for these chemicals. (NOTE)

19. For asbestos (friable), the Waste Management codes

M56 and M92 are unacceptable. Please provide the

proper Waste Management codes for these chemicals.

(NOTE)

General Errors for both the Form R and/or

Form A

20. You reported a negative value for a release, transfer

or other waste management quantity. Please provide

a non-negative value for the specified part and

section. (NOTE)

21. You have reported a value for a PBT chemical

beyond seven digits to the right of the decimal.

EPA’s data management systems support data

precision up to seven digits to the right of the

decimal. EPA has truncated your numeric

submission so the number of digits to the right of the

decimal do not exceed seven. If this was incorrect,

specify the correct value, not exceeding seven digits

to the right of the decimal. (NDC)

Errors in Part I, Facility Identification

Information

22. No selection was made in Part I, Section 2.1 and 2.2

(Trade Secret Information) and a generic chemical

name was not provided in Part II, Section 1.3.

Therefore, the No box was selected in Part I, Section

2.1. If this was incorrect, and you intended to make a

trade secret claim of the identity of the toxic

chemical, you must resubmit following the

requirements of 40 CFR Part 350 to claim trade

secret. (NDC)

23. You indicated trade secret in Part I, Section 2.1

(Trade Secret Information) but made no selection for

Part I, Section 2.2 (sanitized/unsanitized) and did not

provide a generic chemical name in Part II, Section

1.3. EPA changed your selection in Part I, Section

2.1 to indicate that a trade secret claim is not being

made. If this was incorrect, and you intended to

make a trade secret claim for the identity of the toxic

chemical, you must resubmit following the

requirements of 40 CFR Part 350 to claim trade

secret. (NDC)

24. You made a selection of No in Part 1, Section 2.1

(Trade Secret Information) and selected unsanitized

in Part 1, Section 2.2. In Part II, Section 1.3 a

generic name was indicated. Part II, Section 1.3
Appendix C

Toxics Release Inventory Reporting Forms and Instructions C-11

should be completed only if trade secret is being

claimed (Part 1, Section 2.1). EPA will move the

chemical name information in Part II, Section 1.3 to

Part II, Section 1.2. If this is incorrect and you wish

to claim trade secret, you must resubmit following the

requirements of 40 CFR Part 350. (NDC)

25. In Part I, Section 4.1, you entered NA or did not

enter a county name, city name, state code, and/or zip

code. These fields may not be left blank and NA is

not an acceptable entry. You must provide a county

name, city name, state code, and/or zip code where

the facility is located. (NDC)

26. EPA has corrected the county name, city name, state

code, and/ or zip code that you identified in Part I,

Section 4.1. The county name, city name, state code,

and/ or zip code that you identified was either 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)

27. In Part I, Section 4.1, you have used an invalid

TRIFID or you have self-assigned your own TRIFID

or TRIFID that has been superceded. You may not

generate your own TRIFID. The TRI Data Processing

Center assigns this number to a facility. EPA has

corrected this error and assigned you the correct

TRIFID. Please note the corrected TRIFID and keep

it for use in future submissions. (NDC)

28. No Public Contact name and/or telephone number

was listed. Please provide the name and telephone

number of your Public Contact. (NOTE)

29. No Technical Contact name and/or telephone number

was listed. Please provide the name and telephone

number of your Technical Contact. (NOTE)

30. The Federal Facility box was not checked on your

form but we believe you are a Federal Facility.

Unless you respond that you are not a Federal

Facility, we will continue to treat you as a Federal

Facility. (NOTE)

31. A valid NAICS code was not provided. Please

provide at least one valid primary six-digit NAICS

code. (NOTE)

32. You reported an invalid state code. If the address is

in the US, please use a valid US Postal Service state

code (see Table III of the Reporting Forms and

Instructions). If the address is not in the US, please

enter a valid code in the Country Field (see Table IV

of the Reporting Forms and Instructions) (NOTE)

33. Either Box A (An Entire Facility) or Box B (Part of a

Facility) should be checked in Part I, Section 4.2.

One of the 2 boxes must be checked, but not both.

(NOTE)

34. If applicable, check either Box C (Federal Facility) or

Box D (GOCO) in Part I, Section 4.2, but do not

check both boxes. (NOTE)

35. You did not enter Longitude or Latitude values for

the facility. Please enter a Longitude and Latitude

value. (NOTE)

36. You entered an invalid Longitude/Latitude value(s).

Longitude degrees must be between 0 and 180,

latitude degrees must be between 0 and 90; minutes

and seconds for either latitude or longitude must be

between 0 and 60. (NOTE)

37. Dun and Bradstreet Numbers (Part I Section 4.7) are

typically 9 characters in length. Please check the

number(s) submitted. If they are incorrect, please

make the appropriate changes. If you believe that

they are correct, no further action is necessary.

(NOTE)

38. EPA Identification Numbers (RCRA I.D. No. Part I

Section 4.8) are typically 12 characters in length.

Please check the number(s) submitted. If they are

incorrect, please make the appropriate changes. If

you believe that they are correct, no further action is

necessary. (NOTE)

39. NPDES Permit Numbers (Part I, Section 4.9) are

typically 9 characters in length. Please check the

number(s) submitted. If they are incorrect, please

make the appropriate changes. If you believe that

they are correct, no further action is necessary.

(NOTE)

40. Underground Injection Well Code (UIC) I.D.

Numbers(Part I, Section 4.10) are typically 12 digits.

Please check the number(s) you have supplied. If they

are incorrect, please make appropriate changes. If

you believe that they are correct, no further action is

necessary. (NOTE)

41. If this is a North American phone number, please

enter all 10 digits (i.e., include area code). If this is

for another country, please begin the phone number

with "011" as the prefix to your international

telephone number. (NOTE)

42. In Part I, Section 3, you did not provide a printed or

typed name and official title of owner/operator or

senior management official. It cannot be N/A or left

blank. Please provide a name for owner/operator or

senior management official. (NOTE)

43. In Part I, Section 5.1 you did not enter the name of

the parent company. This block cannot be left blank.

You must enter the name for the parent company if it

is a U.S. company. If it is a foreign company then you

may check the [NA] box. (NOTE)

44. The parent company Dun and Bradstreet Number in

Part I, Section 5.2 (typically a 9-digit number )

cannot be left blank. However, if your parent
Appendix C

C-12 Toxics Release Inventory Reporting Forms and Instructions

company does not have a Dun and Bradstreet

Number check the [NA] box next to Part I, Section

5.2. (NOTE)

Errors in Part II, Section 1. Toxic Chemical

Identity

45. You have correctly identified the chemical but have

used a synonym for the chemical name. EPA has

changed the Chemical Name to use the preferred TRI

nomenclature. Please specify the correct CAS

Number and matching Chemical Name. (NDC)

46. The CAS number you reported was changed to match the

chemical name reported, because the CAS number

you provided was not a valid TRI Chemical. If this

was incorrect, specify a valid CAS number and

matching chemical name. (NDC)

47. The chemical name you reported was changed to

match the CAS number reported, because the

chemical name you provided was not a valid TRI

Chemical. If this was incorrect, specify a valid CAS

Number and matching Chemical Name. (NDC)

48. You reported a valid TRI CAS Number, a valid

Chemical Name, and a generic Chemical Name.

Therefore, the Generic Chemical Name was deleted.

If this was incorrect, specify the Generic Chemical

Name to be used. (NDC)

49. You reported a valid TRI CAS Number, a valid

Chemical Name, and a Mixture Component Identity.

Therefore, the Mixture Component Identity was

deleted. If this was incorrect, specify the Mixture

Component Identity to be used. (NDC)

50. EPA has changed the TRI chemical category code

you reported in Part II, Section 1.1 from N151 to

N150 (the code was incorrectly listed in some pages

of the Reporting Forms and Instructions), the correct

TRI chemical category code for Dioxin and Dioxinlike Compounds. If this is incorrect and you are not

reporting Dioxin and Dioxin-like Compounds, please

specify the correct CAS number or chemical category

code and matching chemical name.(NDC)

51. You have reported for isopropyl alcohol (Only

persons who manufacture by the strong acid process

are subject) (CAS number 67-63-0). If you did not

manufacture isopropyl alcohol by the strong acid

process, you have submitted this form in error and

should request that the form be withdrawn. (NOTE)

Errors in Form R, Part II, Section 1.4. Dioxin

and Dioxin-like Compounds

52. EPA has deleted the entry of zeros in Part II, Section

1.4 because you indicated a CAS number or chemical

category in Part II, Section 1.1 other than Dioxin and

Dioxin-like Compounds. When reporting for a

chemical other than Dioxin and Dioxin-like

Compounds, you should leave Section 1.4 blank.

(NDC)

53. You did not complete Section 1.4. If you report

Dioxin and Dioxin-like Compounds in Part II,

Sections 1.1 or 1.2, you must complete Section 1.4.

Please report the distribution of chemicals included

for Dioxin and Dioxin-like Compounds. If you do

not have speciation data available, indicate NA.

(NOTE)

54. Part II, Section 1.4 of your Form R contains data for

Dioxin and Dioxin-like Compounds. However, you

have indicated a CAS number or chemical category

code in Part II, Section 1.1 other than Dioxin and

Dioxin-like Compounds (N150). If you are reporting

for Dioxin and Dioxin-like Compounds, please

provide the proper chemical category code (N150).

Otherwise please indicate on the FDP that Section 1.4

should be left blank. (NOTE)

55. You did not provide values in all 17 boxes in Part II,

Section 1.4 and/or the values do not total to 100%.

When reporting the distribution of each member of

the Dioxin and Dioxin-like Compounds category, you

must fill in each of the 17 boxes in Part II, Section

1.4 with either 0 or a number between 0.01 and 100.

The summation of the 17 fields in Section 1.4 must

equal 100. Please review Part II, Section 1.4 and

enter values where needed and/or adjust the

percentages where needed so that their summation

equals 100%. (NOTE)

56. You reported numeric values in Part II, Section 1.4

for a chemical that is not Dioxin and Dioxin-like

Compounds. It appears that the information reported

in Part II, Section 1.4 is not valid. If you are

reporting for Dioxin and Dioxin-like Compounds,

please indicate on this FDP that the chemical

category name in Part II, Section 1.2 should be

Dioxin and Dioxin-like Compounds, or submit a new

Form R. Otherwise, please indicate on this FDP that

the values in Part II, Section 1.4 should be blank.

(NOTE)

57. Part II, Section 1.4 of your Form R contains data for

Dioxin and Dioxin-like Compounds. However, you

have indicated both NA and a numeric value (which

includes zero). When reporting the distribution of

each member of the Dioxin and Dioxin-like

Compounds category, you must fill in each of the 17

boxes in Part II, Section 1.4 with either 0 or a number

between 0.01 and 100. The summation of the 17

fields in Section 1.4 must equal 100. If you do not

have speciation data available, indicate NA rather

than zero. (NOTE)
Appendix C

Toxics Release Inventory Reporting Forms and Instructions C-13

Errors in Part II, Section 3. Activities and Uses

of Toxic Chemical At The Facility

58. You did not indicate in Part II, Section 3 which

activity(ies) or use(s) of the EPCRA section 313

chemical occur at your facility. Please indicate at

least one of the activity(ies) and use(s) of the EPCRA

section 313 chemical occur at your facility. (NOTE)

Errors in Part II, Section 4. Maximum Amount

of the Toxic Chemical Onsite At Any Time

During the Calendar Year

59. You did not complete Part II, Section 4.1. Please

provide a valid two digit code for the “maximum

amount of chemical on-site at any time during the

calendar year.” (NOTE)

Errors in Part II, Section 5. Quantity of the

Toxic Chemical Entering Each Environmental

Medium Onsite

60. You did not complete Part II, Section 5.3. If you have

discharged to water, please provide the Stream/Water

Body name, the Release estimate or range code,

Basis of Estimate and % from Stormwater; otherwise

indicate “NA” (Not Applicable). (NOTE)

61. There are missing or incomplete data for Part II,

Section 5.3. If you have discharged to water, please

provide the Stream/Water Body name, the Release

estimate or range code, Basis of Estimate and % from

Stormwater; otherwise indicate “NA” (Not

Applicable). (NOTE)

62. You did not complete Part II, Section 5. Please

provide the Release estimate or range code and Basis

of Estimate; otherwise indicate “NA” (Not

Applicable). (NOTE)

63. There are missing or incomplete data for Part II,

Section 5. Please provide the Release estimate or

range code and Basis of Estimate; otherwise indicate

“NA” (Not Applicable). (NOTE)

Errors in Part II, Section 6. Transfers of the

Toxic Chemical In Wastes To Off-Site

Locations

64. You did not complete Part II, Section 6.1,

“discharges to POTW.” If you did not discharge

wastewater containing the section 313 chemical to a

POTW(s), enter “NA” (Not Applicable), otherwise

please provide the Transfer amount or range code,

Basis of Estimate, POTW Name and Location.

(NOTE)

65. You reported a POTW(s) name and location but did

not provide a Transfer amount. Please provide a

Total Transfer amount or range code and Basis of

Estimate; otherwise, if there was no transfer to a

POTW of wastewater that contains or contained the

section 313 chemical, delete the POTW location and

indicate “NA” (Not Applicable) for the POTW

transfer amount. (NOTE)

66. You reported a Total Transfer amount or range code

and Basis of Estimate in Part II Section 6.1 but did

not indicate a POTW name and location in Section

6.1.B. Please provide the POTW Name and Location.

(NOTE)

67. You provided an incomplete POTW name and

address. Please provide the name and complete

address for the POTW. (NOTE)

68. There are missing or incomplete data for Part II,

Section 6.1. Please provide the transfer amount or

range code and Basis of Estimate for Discharges to

POTWs. (NOTE)

69. You did not complete Part II, Section 6.2, “Transfers

to Other Off- site Locations.” If you did not transfer

the waste containing the section 313 chemical to

other off-site locations, enter “NA” (Not Applicable),

otherwise please provide Offsite EPA ID, Name,

Location, Transfer amount or range code, Basis of

Estimate, and type of Waste Management code.

(NOTE)

70. You reported an Off-site Transfer amount or range

code and Basis of Estimate in Part II Section 6.2 but

did not indicate an Off-site name and location in

Section 6.2. Please provide the Off-site Name and

Location. (NOTE)

71. You reported an Off-site name and location but did

not provide a Transfer amount. Please provide a

Total Transfer amount or range code, Basis of

Estimate and type of Waste Management code;

otherwise, if there was no transfer to this Off-site

location, delete the Off-site name and location and

indicate “NA” (Not Applicable) in the Off-site EPA

Identification Number (RCRA ID No.) field.

(NOTE)

72. You provided both county and country data. If this is

an extra-national transfer, indicate the off-site name,

address, and Country Code; if a domestic Offsite,

provide the Off-site Name and correct address.

(NOTE)

73. You reported an Off-site name and location, but there

are missing or incomplete data for the off-site transfer

amount, basis of estimate and type of waste

management code. Please provide the Off-site

Transfer amount or range code, Basis of Estimate,

and type of Waste Management code. (NOTE)

74. You provided incomplete off-site name and address

data. For a transfer to a domestic off-site location,

you must provide a street address, city, state, county

and zip code. For a transfer to a foreign off-site
Appendix C

C-14 Toxics Release Inventory Reporting Forms and Instructions

location, you must provide a street address, city and a

two character country code. (NOTE)

75. You reported an invalid Type of Waste Management

code. For metals/metal compounds use only disposal

and certain recycling activities codes. Consult the

Reporting Instructions for metal and metal

compounds and correct with a valid Waste

Management (i.e., “M”) code. (NOTE)

76. You reported an invalid Type of Waste Management

code. For Barium Compounds use only disposal and

certain recycling activities codes, M61-Wastewater

Treatment (Excluding POTW) or M69-Other Waste

Treatment. Consult the Reporting Instructions for

metal and metal compounds and correct with a valid

Waste Management (i.e., “M”) code. (NOTE)

77. For non-metals codes M41 and M62 are

unacceptable. Provide the appropriate Disposal or

Other Waste Management code for this non-metal

substance. (NOTE)

78. In Part II, Section 6.2 column C you reported M

codes (M56 and/or M92) for energy recovery,

however you left Section 8.3 column B blank. Please

provide the quantity used for energy recovery offsite

in pounds/year in Section 8.3 column B. (NOTE)

79. In Part II, Section 6.2 column C you reported M

Codes (M20, M24, M26, M28, M93) for recycling,

however you left Section 8.5 column B blank. Please

provide the quantity recycled offsite in pounds/year

in Section 8.5 column B. (NOTE)

80. In Part II, Section 6.2 column C you reported M

Codes (M40, M50, M54, M61, M69, M95) for

treatment, however you left Section 8.7 column B

blank. Please provide the quantity treated offsite in

pounds/year in Section 8.7 column B. (NOTE)

Errors in Part II, Section 7. On-Site Waste

Treatment Methods and Efficiency

81. There are no data contained in all of Part II, Section

7A. If you do not treat wastes containing the EPCRA

section 313 chemical at your facility, indicate “NA;”

otherwise please provide the general waste stream

code, waste treatment methods, range of influent

concentration, waste treatment efficiency estimate

and whether this is based on operating data for all onsite waste treatments for this chemical. (NOTE)

82. There are missing data in Part II, Section 7A. Please

provide the general waste stream code, waste

treatment methods, range of influent concentration,

waste treatment efficiency estimate and whether this

is based on operating data. (NOTE)

83. There are no data in Part II, Section 7B. If no on-site

energy recovery processes are used for this section

313 chemical at your facility, indicate “NA;”

otherwise please provide at least one three-character

on-site energy recovery process code. (NOTE)

84. There are no data in Part II, Section 7C. If no on-site

recycling processes are used for this section 313

chemical at your facility, indicate “NA;” otherwise

please provide at least one three-character on-site

recycling process code. (NOTE)

Errors in Part II, Section 8. Source Reduction

and Recycling Activities

85. There are missing data for Part II, Section 8.1-8.7.

Please provide an estimate or “NA” (Not Applicable)

in each box for section 8.1 through 8.7, columns A,

B, C, and D. You may only use “NA” (Not

Applicable) when there is no possibility a release or

transfer occurred. You may enter zero if the release

or transfer was equal to or less than half a pound.

(NOTE)

86. There are missing data in Part II, Section 8.8. Please

provide an estimate or “NA” (Not Applicable). You

may only use “NA” (Not Applicable) when there is

no possibility a release or transfer occurred. You

may enter zero if the release or transfer was equal to

or less than half a pound. (NOTE)

87. There are no data in Part II, Section 8.9. Please

provide a production ratio, an activity index, or “NA”

(Not Applicable) if the chemical manufacture or use

began during the current reporting year. (NOTE)

88. There are no data in Part II, Section 8.10. If your

facility did not engage in any source reduction

activity for the reported chemical, enter “NA” (Not

Applicable) and answer 8.11. Otherwise please

provide Source Reduction Activities and Methods

code(s). (NOTE)

89. There are missing data in Part II, Section 8.10.

Please provide Source Reduction Activities and

Methods code(s). (NOTE)

90. Neither box was checked in section 8.11. Please

check one of the boxes in section 8.11 indicating if

additional information on source reduction, recycling,

or pollution control activities is included with your

Form R report. (NOTE)

91. You have reported a listed metal or metal compound

category in section 8.2, 8.3, 8.6 or 8.7. However,

these chemicals cannot be treated for destruction.

Metal or metal compound category can only be

reported as disposed or recycled. Please report

appropriately in Section 8.1, 8.4, or 8.5. (NOTE)

92. You reported a negative value for a release, transfer

or other waste management quantity. Please provide a

non-negative value for the specified part and section.

(NOTE)
Appendix C

Toxics Release Inventory Reporting Forms and Instructions C-15

Errors relating to the reconciliation of data in

Part II, Section 8 and Part II, Sections 5, 6, and

7

93. You did not complete Sections 8.1 through 8.7

column B or 8.8. If you report releases in Part II,

Section 5 and/or an off-site transfer in Section 6.2

and/or quantities transferred off-site to POTWs in

Section 6.1, you must report an estimate in Part II,

Sections 8.1 through 8.7 column B and/or Section

8.8. (NOTE)

94. You did not complete Sections 5, 6, or 7. If you enter

an estimate in Part II, Sections 8.1 through 8.7,

column B and/or Section 8.8, you must also report

releases in Part II, Section 5 and/or off-site transfers

in Section 6.2 and/or quantities transferred off-site to

POTWs in Section 6.1 and/or waste treatment, energy

recovery, or recycling codes in Section 7. Please

provide data for Sections 5, 6, and/or 7. (NOTE)

95. You reported an estimate in Part II, Section 8.2,

column B, “Quantity Used for Energy Recovery Onsite,” but did not provide an on-site energy recovery

code in Part II, Section 7B. Please provide an on-site

energy recovery code for Part II, Section 7B.

(NOTE)

96. You reported an “On-site Energy Recovery Process”

code in Part II, Section 7B, but you did not provide

an estimate of the quantity used for energy recovery

in Part II, Section 8.2, column B. Please provide an

estimate of the quantity used for energy recovery for

Part II, Section 8.2, column B. (NOTE)

97. You reported an estimate in Part II, Section 8.4,

column B “Quantity Recycled On-site” but did not

provide an on-site recycling code in Part II, Section

7C. Please provide an on-site recycling code for Part

II, Section 7C. (NOTE)

98. You reported one or more on-site recycling process

codes in Part II, Section 7C but did not provide an

estimate in Part II, Section 8.4, column B, “Quantity

Recycled On-site.” Please provide an estimate of the

quantity recycled for Section 8.4 column B. (NOTE)

99. You reported a value in Part II, Section 8.3 column

B, however you did not provide a corresponding

quantity with an appropriate M Code (M56

and/orM92) for energy recovery in Section 6.2

column C. Please provide the appropriate quantity

and M Codes for energy recovery in Section 6.2

column C. (NOTE)

100. You reported a value in Part II, Section 8.5 column

B, however you did not provide a corresponding

quantity with an appropriate M Code (M20, M24,

M26, M28, M93) for recycling in Section 6.2 column

C. Please provide the appropriate quantity and M

Codes for recycling in Section 6.2 column C.

(NOTE)

101. You reported a value in Part II, Section 8.7 column

B, however you did not report a quantity in Section

6.1 or a quantity with an appropriate M Code (M40,

M50, M54, M61, M69, M95) for treatment in Section

6.2 column C. Please provide a quantity in Section

6.1 or the appropriate quantity and M Codes for

treatment in Section 6.2 column C. (NOTE)

102. You have reported a listed metal or metal compound

category in Part II, Section 6.1, however you have

not provided a quantity released in section 8.1

column B. Note that in Section 8a, metal or metal

compound category can only be reported as disposed

or recycled and not reported as treated for energy

recovery or treated for destruction. Please provide

quantity released in pounds/year in Section 8.1

column B. (NOTE)

103. You have reported a listed metal or metal compound

category in Part II, Section 6.1, however you have

not provided quantity released in 8.1d Column B.

Note that in Section 8a, metal or metal compound

category can only be reported as disposed or recycled

and not reported as treated for energy recovery or

treated for destruction. Please provide quantity

released in pounds/year Section 8.1B. (NOTE)
Toxics Release Inventory Reporting Forms and Instructions D-1

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 chemicalsthey 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.
Appendix D

D-2 Toxics Release Inventory Reporting Forms and Instructions

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:
Appendix D

Toxics Release Inventory Reporting Forms and Instructions D-3

Chemical or chemical

category name

CAS

number or

chemical

category

code

Supplier

notification

limit (%)

Aldrin 309-00-2 1.0

Benzo[g,h,i]perylene 191-24-2 1.0

Chlordane 57-74-9 0.1

Dioxin and dioxin-like

compounds

(manufacturing; and the

processing or otherwise

use of dioxin and dioxinlike 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

N150 1.0*

Heptachlor 76-44-8 0.1

Hexachlorobenzene 118-74-1 0.1

Isodrin 465-73-6 1.0

Lead 7439-92-1 0.1

Lead compounds N420 0.1**

Mercury 7439-97-6 1.0

Mercury compounds N458 1.0

Methoxychlor 72-43-5 1.0

Octachlorostyrene 29082-74-4 1.0

Pendimethalin 40087-42-1 1.0

Pentachlorobenzene 608-93-5 1.0

Polychlorinated

biphenyls (PCBs)

1336-36-3 0.1

Polycyclic aromatic

compounds category

N590 0.1***

Tetrabromobisphenol A 79-94-7 1.0

Toxaphene 8001-35-2 0.1

Chemical or chemical

category name

CAS

number or

chemical

category

code

Supplier

notification

limit (%)

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.

– Foods, drugs, cosmetics, alcoholic

beverages, tobacco, or tobacco products

packaged for distribution to the general

public.

– Any consumer product, as the term is defined

in the Consumer Product Safety Act,

packaged for distribution to the general

public. For example, if you mix or package

one-gallon cans of paint designed for use by

the general public, notification is not

required.

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), 4931 (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 Resource Conservation and Recovery Act,
Appendix D

D-4 Toxics Release Inventory Reporting Forms and Instructions

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 Recordkeeping

Requirements

You are required to keep records of the following for three

years:

1. Notifications sent to recipients of your mixture or

other trade name product;

2. All supporting materials used to develop the notice;

3. If claiming a specific EPCRA section 313 chemical

identity a trade secret, you should record why the

EPCRA section 313 chemical identity is considered a

trade secret and the appropriateness of the generic

chemical name provided in the notification; and

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.
Appendix D

Toxics Release Inventory Reporting Forms and Instructions D-5

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
Appendix D

D-6 Toxics Release Inventory Reporting Forms and Instructions

D.10 Sample Notification on an MSDS Furniture Products

Section 313 Supplier Notification

This product contains the following EPCRA section 313 chemicals subject to the reporting requirements of section 313

of the Emergency Planning and Community Right-To-Know Act of 1986 (40 CFR 372):

CAS Number Chemical Name Percent by Weight

108-88-3 Toluene 20%

NA Zinc Compounds 15%

This information must be included in all MSDSs that are copied and distributed for this material.

Material Safety Data Sheet
Toxics Release Inventory Reporting Forms and Instructions E-1

Appendix E. TRI State Contacts

EPCRA Section 313 requires facilities to submit reports to both EPA and their state. For a current list of

state designated Section 313 contacts, see the TRI web site at:

State TRI Contact Information and Web Sites: http://www.epa.gov/tri/stateprograms/state_programs.htm
Toxics Release Inventory Reporting Forms and Instructions F-1

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)

Nancy Levin

Toxics Office

USEPA Region 9 (CED-4)

75 Hawthorne Street

San Francisco, CA 94105-3901

(415) 972-3848; fax: (415) 947-3583

levin.nancy@epa.gov

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

Brook Madrone

Office of Waste & Chemical Management

USEPA Region 10 (AWT-128)

1200 Sixth Avenue

Suite 900

Seattle, WA 98101-3140

(206) 553-4016; Fax: (206) 553-8509

Madrone.brook@epa.gov
Toxics Releases Inventory Forms and Instructions G-1

Appendix G. Other Relevant Section 313 Materials

G.1 Public Data Release

2007 Toxics Release Inventory Public Data Release

Report

TRI data collected from 1987 through 2007 can be accessed

using the TRI Explorer online tool:

http://www.epa.gov/triexplorer

as well as several other public access tools available on the

TRI website. In addition, users can obtain summary

information and access the TRI data submitted for reporting

years 1996 through 2007 via the web from the TRI Public Data

Release Internet site at

http://www.epa.gov/tri/tridata/index.htm. This Internet site

provides fast and easy access to the TRI data submitted for

each of these years, as well as an overview of the data and

other relevant TRI information regarding each year (including

tables, charts, maps, and a summary of key findings). EPA has

released two electronic publications summarizing the 2007

data: the 2007 TRI Public Data Release (PDR) Brochure

(EPA-260-R-09-001) and the 2007 Public Data Release

eReport. These reports provide an overview of the 2007 TRI

reporting year data and other information relating to TRI data.

The reports serve as a supplement to EPA’s TRI Explorer

where, for example, users of TRI data can retrieve electronic

2007 state fact sheets that provide a snapshot of each state’s

releases and other waste management activities and a

description of the information included in the state fact sheet.

G.2 Access to TRI

Information On-line

The TRI Home Page http://www.epa.gov/tri offers

information useful to both novice and experienced users of the

Toxics Release Inventory. It provides a description of what the

TRI database is and how it can be used; access to TRI data;

TRI regulations; and guidance documents for complying with

TRI regulations and using TRI data. You can find out about

TRI products, view or download the 2007 TRI data release

reports, and identify who to contact for more information in

EPA regions and state programs across the country. From the

TRI home page, you can link to other EPA and non-EPA sites

that also allow you to search the TRI database and other

databases online.

TRI Explorer http://www.epa.gov/triexplorer is an on-line

tool that EPA has created to obtain TRI data. It allows the

user to search the TRI database using six criteria: facility,

chemical, year or industry type (NAICS code), federal facility

and geographic area (at the county, state or national level).

The tool will generate three types of reports: (1) Release

Reports (including on- and off-site releases (i.e., off-site

releases include transfers off-site to disposal and metals and

metal compounds transferred to POTWs)); (2) Waste Transfer

Reports (including amounts transferred off-site for further

waste management but not including transfers off-site to

disposal); and (3) Waste Quantity Reports (including amounts

recycled, burned for energy recovery, quantities treated, and

quantities released).

TOXNET http://toxnet.nlm.nih.gov the National Library of

Medicine’s (NLM) Toxicology Data Network, provides free

access to several databases, including the TRI database, that

provides a variety of information on toxic chemicals. As with

EPA’s TRI Explorer tool, users of TOXNET can search by

chemical or other name, chemical name fragment, or Chemical

Abstracts Service Registry Number. Also searchable are

facility or parent company name, state, city, county, or zip

code. Search results can be limited to releases greater than a

specified number of pounds, and individual releases can be

summed together to display a total amount. Toxicity and

environmental fate data for thousands of chemicals are also

available from TOXNET.

G.3 Other TRI Information

EPA’s Integrated Risk Information System (IRIS)

http://www.epa.gov/iris is an electronic database containing

information on human health effects that may result from

exposure to various chemicals, including TRI chemicals, in the

environment. IRIS was initially developed for EPA staff in

response to a growing demand for consistent information of

chemical substances for use in risk assessments, decisionmaking and regulatory activities. The information in IRIS is

intended for those without extensive training in toxicology, but

with some knowledge of health sciences.

Consolidated List of Chemicals Subject to the Emergency

Planning and Community Right-to-Know Act and Section

112(r) of the Clean Air Act (List of Lists), (October 2001):

http://www.epa.gov/ceppo/pubs/title3.pdf

A paper copy is available from the National Technical

Information Service, 5285 Port Royal Road, Springfield, VA

22161, 703 605-6000, Document Number: PB2003-105834,

$38.00 plus $5.00 shipping and handling.

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
Appendix G

G-2 Toxics Releases Inventory Forms and Instructions

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-R97- 001b. 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

factsheets on pollution prevention from various state programs

call the PPIC reference and referral service at 202 566-0799,

or fax a request to 202 566-0794, or write to:

U.S. EPA

Pollution Prevention Information Clearinghouse (PPIC)

EPA West

1200 Pennsylvania Ave. NW

Room 3379 (Mail Code 7407-T)

Washington, DC 20460-0001

Email: ppic@epa.gov
Toxics Release Inventory Reporting Forms and Instructions H-1

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.
Appendix H

H-2 Toxics Release Inventory Reporting Forms and Instructions

 Toxic Chemical Release Reporting Using North American Industry Classification System (NAICS) Final

Rule (71 FR 32464; June 6, 2006): With this rulemaking, Toxics Release Inventory (TRI) reporting will require

North American Industry Classification System (NAICS) codes in place of Standard Industrial Classification

(SIC) codes. North American Industry Classification System (NAICS), United States, 2002, Executive Office of

the President, Office of Management and Budget, NTIS Order Number: PB2002-101430

 Persistent Bioaccumulative Toxic (PBT) Chemicals; Final Rule (64 FR 58666)

A reprint of the final rule that appeared in the Federal Register of October 29, 1999. This rule adds certain PBT

chemicals and chemical categories for reporting year 2000 and beyond under EPCRA section 313, lowers their

activity thresholds and modifies certain reporting exemptions and requirements for PBT chemicals and chemical

categories. In a separate action, as part of the October 29, 1999 rulemaking, EPA added vanadium (except when

contained in alloy) and vanadium compounds. These are not listed as PBT chemicals.

H.2 Supplier Notification Requirements

(EPA 560-4-91-006)

This pamphlet assists chemical suppliers who may be subject to the supplier notification requirements, gives examples

of situations which require notification, describes the trade secret provision, and contains a sample notification.

 Toxic Chemical Release Inventory Reporting Forms and Instructions Revised 2006 Version

February 2007 (EPA 260-C-06-901)

 Toxics Release Inventory: Reporting Modifications Beginning with 1995 Reporting Year

February 1995 (EPA 745-R-95-009)

 Trade Secrets Rule and Substantiation Form

 (53 FR 28772)

A reprint of the final rule that appeared in the Federal Register of July 29, 1988. This rule implements the trade

secrets provision of the Emergency Planning and Community Right-to-Know Act (section 322). The current

trade secret substantiation form can be accessed at http://www.epa.gov/tri/report/index.htm#forms

H.3 Chemical-Specific Guidance

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

 Emergency Planning and Community Right-to-Know Section 313: List of Toxic Chemicals within the

Chlorophenols Category

June 1999 (EPA745-B-99-013)

 Toxics Release Inventory List of Toxic Chemicals within the Glycol Ethers Category and Guidance for

Reporting

December 2000 (EPA745-R-00-004)

 Emergency Planning and Community Right-to-Know Act Section 313: Guidance for Reporting

Hydrochloric Acid (acid aerosols including mists, vapors, gas, fog and other airborne forms of any

particle size)

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

 Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Releases

and Other Waste Management Activities of Toxic Chemicals: Lead and Lead Compounds

November 2001 (EPA-260-B-01-027)

 Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic

Chemicals: Mercury and Mercury Compounds Category

August 2001 (EPA 260-B-01-004)
Appendix H

Toxics Release Inventory Reporting Forms and Instructions H-3

 Toxics Release Inventory List of Toxic Chemicals within the Nicotine and Salt Category and Guidance for

Reporting

June 1999 (EPA 745-R-99-010)

 Toxics Release Inventory List of Toxic Chemicals within the Water Dissociable Nitrate Compounds

Category and Guidance for Reporting

December 2000 (EPA 745-R-00-006)

 Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic

Chemicals: Pesticides and Other Persistent Bioaccumulative Toxic (PBT) Chemicals

August 2001 (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 (EPA 745-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)
Appendix H

H-4 Toxics Release Inventory Reporting Forms and Instructions

 EPCRA Section 313: Guidance for Electricity Generating Facilities

February 2000 (EPA 745-B-00-004)

 EPCRA Section 313 Reporting Guidance for Food Processors

September 1998 (EPA 745-R-98-011)

 EPCRA Section 313 Reporting Guidance for the Leather Tanning and Finishing Industry

April 2000 (EPA 745-B-00-012)

 EPCRA Section 313: Guidance for Metal Mining Facilities

January1999 (EPA 745-B-99-001)

 Emergency Planning and Community Right-to-Know Act Section 313 Reporting Guidance for the

Presswood and Laminated Products Industry

August 2001 (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 (EPA 745-R-98-014)
Toxics Release Inventory Reporting Forms and Instructions I-1

Appendix I. Questions and Answers Regarding

Facility Identification Information

I.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 I.2 Identifying the parent company.

Section I.3 Reporting after a change in name or

ownership.

Section I.4 Reporting for multiple sites and/or owners.

I.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)).

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)).

I.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

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
Appendix I

I-2 Toxics Release Inventory Reporting Forms and Instructions

responsible for reporting the data for the entire previous

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-R98---5j; October 1998).

I.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 (EGF) 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 EGF 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-B98-001)).

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-R98---5j; October 1998)

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?
Appendix I

Toxics Release Inventory Reporting Forms and Instructions I-3

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.