EPA 260 - R - 09 - 006 October 200 9 

# 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 Reautho rization 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 S ignificant Error (NOSE) if they remain uncertified after the July 1 st 

### 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 -M Eweb will be available to all reporting facilities in RY 2009, including first- time filers. TRI -ME web 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 -M E web 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

-ME web 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 -ME web is similar to its predecessor TRI -ME CD/desktop in that it assists you in preparing your forms, but TRI -ME web offers so much more. TRI -ME web 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 p arent c ompany name and Dun and Bradstreet number of the p arent c ompany as of December 31 st 

### of the reporting year. EPA is also looking at using quick lists to verif y 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 Busines s 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 3 13 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 -ME web 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. Acces s 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

-ME web and the TRI Assistance Library to electronically search and read TRI guidance documents, including this document. The TRI web site contains links and guidance on filling out and submitting TRI reporting forms: http://www.epa.gov/tri/report/index.htm TRI Regional Contacts: EPA Regional Coordinators often work closely with reporting facilities in their area providing training, outreach, and assistance in completing forms. For a list of TRI Regional Coordinators, see Appendix F . TRI State Contacts: EPCRA Section 313 requires facilities to submit reports to both EPA and their state. For a list of state designated Section 313 contacts, see Appendix E . 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 220 33 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 220 33

# This Page Intentionally Left BlankUnited 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. 

### Withdrawal (enter up to two code(s)) Revision (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 AddressForm 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 de scriptive.) 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 punctu ation.)

3.1 Manufacture the toxic chemical: 3.2 Process the toxic chemical: Otherwise use the toxic chemical: 3.3 Produce a. 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.1 Total Transfers (pounds/year*) (enter range code ** or estimate) 6.1.A.2 Basis of Estimate (enter code) 6.1.B POTW Name POTW Address City State County Zip 6.1.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

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# 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 Dio xin-like compounds, report in grams/year. TRI Facility ID Number Toxic Chemical, Category or Generic Name

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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.” YesForm 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 u sed 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 de scriptive.) 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 de scriptive.) 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 de scriptive.)

Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked “yes”. Generic Name must be structurally de scriptive.) 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. CHEMI CAL - 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 non point air emissions Stack 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 1 3 14 15 16D.Mass(grams)ofEachCompoundinthecategory(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 FOR MATION (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 N A 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 16C.Mass(grams)ofEachCompoundinthecategory(1-17)

17EPA 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 4 5 6 7 8 9 10 11 12 13 14 15 16 17 2. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 3 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 4. 1 2 3 4 5 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 4 5 6 7 8 9 10 11 12 13 14 15 16 17 2. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 3. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 4. 1 2 3 4 5 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 O MB 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 8.1 b 8.1 c 8.1 d 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

re cycled offsite Quantity

treated onsite Quantity

treated offsite Quantity released

to the environment as a result of remedial actions, catastrophic events, or one time events not associated with production processes 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16Columnf.Mass(grams)ofEachCompoundinthecategory(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

-ME web ) application via EPA’s Central Data Exchange (CDX). TRI

-ME web is an intelligent, web -based version of the popular TRI -ME software. There are several advantages to using TRI -ME web . They are

### 2 Toxics Release Inventory Reporting Forms and Instructions

as follows: your prior year data will be pre populated, electronic signature that allows for paperless filing, higher data quality and instant confirmation that EPA has received y our 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

-ME web 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 -ME web to submit your TRI submission(s) . TRI -ME web 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 form s 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 o f 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 revi sion 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 u se TRI -ME web . For more information regarding access to TRI -ME web , please visit http://www.epa.gov/tri . TRI -ME web 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

-ME web , 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 increa sed 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 Fairf ax, 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

-ME web . For more information regarding access to TRI -ME web , 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.ep a.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 pag e – 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 -ME web 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 e mail 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 Subm it 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 Eligib le 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

- Tim e 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 con sists 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 code s 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 Subm it 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 I s 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



# S TOP 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 full time 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 multi establishment facility is a facility that consists of two or more distinct and separate economic units. If your facility is a multi - establishment facility, calculate the value added of the products produced, shipped, or services provided from each establishment within the facility and then use the following rule to determine if your facility meets the NAICS code criterion: If the total value added of the products produced, shipped, or services provided at establishments with covered NAICS codes is greater than 50 percent of the value added of the entire facility’s products and services, the entire facility meets the NAICS code criterion. If any one establishment with a covered NAICS code has a value added of services or products shipped or produced that is greater than any other establishment within the facility (40 CFR 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 pro duct 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 Subm it 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 3 13 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 c ontaining 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 chemic al, 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 Subm it 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 31 3 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 diss olving 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 dioxin like compounds category has the qualifier, “Manufacturing; and the processing or otherwise use of dioxin and dioxin - like compounds if the dioxin and dioxin - like compounds are present as contaminants in a chemical and if they were created during the manufacturing of that chemical.” EPA has added six individual chemicals to the EPCRA Section 313 list of toxic chemicals that also had their thresholds lowered: benzo(g,h,i)perylene, benzo(j,k)fluorene (fluoranthene), 3 - methylcholanthrene, octachlorostyrene, pentachlorobenzene, and tetrabromobisphenol A (TBBPA). Benzo(j,k)fluorene and 3 - methylcholanthrene were added as members of the polycyclic aromatic compounds (PACs) chemical category. EPA lowered the reporting thresholds for PBT chemicals to either 100 pounds, 10 pounds, or in the case of the dioxin and dioxin - like compounds chemical category, to 0.1 grams. The table at the beginning of Section B.4 of these instructions lists the applicable manufacture, process, and otherwise use thresholds for the listed PBT chemicals . EPA eliminated the de minimis exemption for all PBT chemicals (except lead when contained in stainless steel, brass or bronze alloy). However, this action does not affect the applicability of the de minimis exemption to the supplier notificati on 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 Subm it 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 2 5,000/10,000 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 proc essing 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 facilitie s 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 m inimis 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 Subm it 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 S ection 313 chemical, the owner/operator must consider the concentration of the non - PBT EPCRA Section 313 chemical in mixtures and other trade name products. If the non - PBT EPCRA Section 313 chemical in a mixture or other trade name product is manufactured as an impurity, imported, processed, or otherwise used and is below the appropriate de minimis concentration level, then the quantity of the non - PBT EPCRA Section 313 chemical in that mixture or other trade name product does not have to be applied to threshold determinations nor included in release or other waste management determinations. If a non - PBT EPCRA Section 313 chemical in a mixture or other trade name product is below the appropriate de minimis level, all releases and other waste management activities associated with the EPCRA Section 313 chemical in that mixture or other trade name product are exempt from EPCRA Section 313 reporting. It is possible to meet an activity (e.g., processing) threshold for an EPCRA Section 313 chemical on a facility wide basis, but not be required to calculate releases or other waste management quantities associated with a particular process because that process involves only mixtures or other trade name products containing the non - PBT EPCRA Section 313 chemical below the de minimis level. EPA interprets the de minimis exemption such that once a non - PBT EPCRA Section 313 chemical concentration is at or above the appropriate de minimis level in the mixture or other trade name product threshold determinations and release and other waste management calculations must be made, even if that chemical later falls below the de minimis level in the same mixture or other trade name product. Thus, EPA considers reportable all releases and other quantities managed as waste that occur after the de minimis level has been met or exceeded. If an EPCRA Section 313 chemical in a mixture or other trade name product at or above de minimis is brought on site, the de minimis exemption never applies. De minimis levels for non- PBT EPCRA Section 313 chemicals and chemical categories are set at concentration levels of either 1 percent or 0.1 percent; PBT chemicals and chemical categories do not have de minimis levels with regard to this exemption . The 0.1 percent de minimis levels are dictated by determinations made by the National Toxicology Program (NTP) in its Annual Report on Carcinogens, the International Agency for Research and Cancer (IARC) in its Monographs, or 29 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 c oncentration 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 categ ory 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 recro ssed 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 scen ario. 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 Subm it 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) 

### pounds

x x 400 , 23 2 % 00 . 1 % 25 . 1 % 25 . 0 % 25 . 1 %

99 . 0 % 25 . 1 000 , 000 , 8 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 determin ations and release and other waste management estimates is: 

### pounds x x 400 , 26 2 % 0 . 1 % 2 . 1 % 2 . 0 % 2 . 1 %

9 . 0 % 2 . 1 000 , 000 , 8 = 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 sc ale 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 consi der 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 Subm it 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 dioxin like compounds are present as contaminants in a chemical and i f 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 w orksheets 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 3 13 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 Subm it 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 thes e activities requires a separate threshold determination. For example, if in a calendar year you processed 20,000 pounds of a non PBT EPCRA Section 313 chemical and you otherwise used 6,000 pounds of that same chemical, your facility has not exceeded any applicable threshold and thus is not required to report for that chemical. Worksheets should be retained to document your determination for reporting or not reporting, but should not be submitted with the report. You must submit a report if you exceed any threshold for any EPCRA Section 313 chemical or chemical category. For example, if your facility processes 22,000 pounds of a non - PBT EPCRA Section 313 chemical and also otherwise uses 16,000 pounds of that same chemical, it has exceeded the otherwise use threshold (10,000 pounds for a non - PBT chemical) and your facility must report even though it did not exceed the process threshold (25,000 pounds for a non - PBT chemical). In preparing your reports, you must consider all non - exempted activities and all releases and other waste management quantities of the EPCRA Section 313 chemical from your facility, not just releases and other waste management quantities from the otherwise use activity. Also note that threshold determinations are based upon the actual amounts of an EPCRA Section 313 chemical manufactured, processed, or otherwise used over the course of the calendar year. The threshold determination may not relate to the amount of an EPCRA Section 313 chemical brought on- site during the calendar year. For example, if a stockpile of 100,000 pounds of a non- PBT EPCRA Section 313 chemical is present on- site but only 20,000 pounds of that chemical is applied to a process, only the 20,000 pounds processed is counted toward a threshold determination, not the entire 100,000 pounds of the stockpile. 

## B.4.b. Threshold Determinations for On - Site Reuse Operations Threshold determinations of EPCRA Section 313 chemicals that are reused at the facility are b ased 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 f or 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 b e 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 categ ory 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 Subm it 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 dioxin like compounds chemical category. The threshold for this category is 0.1 gram. The PBT chemicals, their CAS numbers or chemical category code, and their reporting thresholds are listed in a table in the introductory section of B.4. See Table 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 avail able 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 relea se 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 Subm it 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) B ecause 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 c lean 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 TRI

ME web . “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 “facilitie s,” 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 f

or 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 financi al 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 S

pecific Information In Part II, you are to report on: The EPCRA Section 313 chemical being reported; The general uses and activities involving the EPCRA Section 313 chemical at your facility; On- site releases of the EPCRA Section 313 chemical from the facility to air, water, and land; Quantities of the EPCRA Section 313 chemical transferred to off - site locations; Information for on- site and off - site disposal, treatment, energy recovery, and recycling of the EPCRA Section 313 chemical; and Source reduction activities. 

## Section 1. EPCRA Section 313

Chemical Identity 1.1 CAS Number Enter the Chemical Abstracts Service (CAS) registry number in Section 1.1 exactly as it appears in Table II of these instructions for the chemical being reported. CAS numbers are cross referenced with an alphabetical list of chemical names in Table II. If you are reporting one of the EPCRA Section 313 chemical categories (e.g., chromium compounds), you should enter the applicable category code in the CAS number space. EPCRA Section 313 chemical category codes are listed below and can also be found in Table 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 diss ociable, 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 exc eeds 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 chemic al 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 o f (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 comp onent

— 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 transf er 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 On site.

### 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 N methyl - alpha- naphthylamine, a chemical not on the EPCRA Section 313 list. 2. Your facility is a commercial distributor of Missouri bituminous coal, which contains mercury at 1.5 ppm (w:w). You should check the box on the Form R at Part II, Section 3.2.e for processing mercury as an impurity. Weight Range in Pounds Range Code 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 On site In Section 5, you must account for the total aggregate on- site releases of the EPCRA Section 313 chemical to the environment from your facility for the calendar year.

### 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 Dioxin Like Compounds If the total quantity for Section 5.2 of the Form R (i.e., stack or point air emissions) is 0.00005 grams or less, then zero can be entered. If the total quantity is between 0.00005 and 0.0001 grams, then 0.0001 grams can be entered or the actual number can be entered (e.g., 0.000075). NA vs. a Numeric Value (e.g., Zero). Generally, NA is applicable if the waste stream that contains or contained the EPCRA Section 313 chemical is not directed to the relevant environmental medium, or if leaks, spills and fugitive emissions cannot occur. If the waste stream that contains or contained the EPCRA Section 313 chemical is directed to the environmental medium, or if leaks, spills or fugitive emissions can occur, NA should not be used, even if treatment or emission controls result in a release of zero. If the annual aggregate release of that chemical was equal to or less than 0.5 pound, the value reported is zero (unless the chemical is a listed PBT chemical). For Section 5.1, NA generally is not applicable for volatile organic compounds (VOCs). For Section 5.5.4, NA generally would not be applicable, recognizing the possibility of accidental spills or leaks of the EPCRA Section 313 chemical. An example that illustrates the use of NA vs. a numeric value (e.g., zero) would be nitric acid involved in a facility’s processing activities. If the facility neutralizes the wastes containing nitric acid to a pH of 6 or above, then the facility reports a release of zero for the EPCRA Section 313 chemical, not NA. Another example is when the facility has no underground injection well, in which case NA should be entered in Part I, Section 4.10 and checked in Part II, Section 5.4.1 and 5.4.2 of Form R. Also, if the facility does not landfill the acidic waste, NA should be checked in Part II, Section 5.5.1.B of Form R. All releases of the EPCRA Section 313 chemical to the air must be classified as either stack or fugitive emissions, and included in the total quantity reported for these releases in Sections 5.1 and 5.2. Instructions for columns A, B, and C follow the discussions of Sections 5.1 through 5.5. 5.1 Fugitive or Non - Point Air Emissions Report the total of all releases of the EPCRA Section 313 chemical to the air that are not released through stacks, vents, ducts, pipes, or any other confined air stream. You must include (1) fugitive equipment leaks from valves, pump seals, flanges, compressors, sampling connections, open - ended lines, etc.; (2) evaporative losses from surface impoundments and spills; (3) releases from building ventilation systems; and (4) any other fugitive or non-point air emissions. Engineering estimates and mass balance calculations (using purchase records, inventories, engineering knowledge or process specifications of the quantity of the EPCRA Section 313 chemical entering product, hazardous waste

### 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 stre am 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 inj ected 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 metho d. 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 non representative, facilities must make reasonable estimates using the best readily available information. Reasonable estimates of the amounts released should be made using published emission factors, material balance calculations, or engineering calculations. You may not use emission factors or calculations to estimate releases if more accurate data are available. No additional monitoring or measurement of the quantities or concentrations of any EPCRA Section 313 chemical released into the environment, or of the frequency of such releases, beyond that required under other provisions of law or regulation or as part of routine plant operations, is required for the purpose of completing Form R. You must estimate the quantity (in pounds) of the EPCRA Section 313 chemical or chemical category that is released annually to each environmental medium on- site. Include only the quantity of the EPCRA Section 313 chemical in this estimate. If the EPCRA Section 313 chemical present at your facility was part of a mixture or other trade name product, calculate only the releases of the EPCRA Section 313 chemical, not the other components of the mixture or other trade name product. If you are only able to estimate the releases of the mixture or other trade name product as a whole, you should assume that the release of the EPCRA Section 313 chemical is proportional to its concentration in the mixture or other trade name product. See Part 40, Section372.30(b) of the Co de 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 chemical specific emission factors, you should enter the code letter “M2” for periodic or random emission monitoring. If the monitoring data, mass balance, or emission factor used to estimate the release is not specific to the EPCRA Section 313 chemical being reported, the form should identify the estimate as based on other methods of estimation (O). If a mass balance calculation yields the flow rate of a waste, but the quantity of reported EPCRA Section 313 chemical in the waste is based on solubility data, you should report “O” because engineering calculations were used as the basis of estimate of the quantity of the EPCRA Section 313 chemical in the waste. If the concentration of the EPCRA Section 313 chemical in the waste was measured by continuous emissions monitoring equipment and the flow rate of the waste was determined by mass balance, then the primary basis of the estimate should be “continuous emission monitoring” (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 - specif ic 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 0.7 0 - 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 10 3 

### g/mg x (1/454) lb/g = 87 lb zinc. The total amount of zinc discharged from all sources of your facility is:

250 pound s 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. T ransfers 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 dispo sal, 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 thos e 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 thre sholds, 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 nec essary 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 percentag e 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. Plea se 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 w astes 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 non U.S. state or province in the county field, the postal code in the zip code field, and the foreign country code in the country field. The most commonly used FIPs codes are listed in Table IV. To obtain a FIPS code for a country not listed, contact the TRI Information Center. There is nothing to enter in the state field. 6.2a Column A: Total Transfers For each off

- site location, enter the total amount, in pounds (in grams for dioxin and dioxin - like compounds), of the EPCRA Section 313 chemical that is contained in the waste transferred to that location. Do not enter the total quantities of the waste. If you do not ship or transfer wastes containing the EPCRA Section 313 chemical to other off - site locations, you should enter NA (See discussion of NA vs. a Numeric Value (e.g., Zero) in the introduction of Section 6) in the box for the off - site location’s EPA Identification Number (defined in 40 CFR 260.10 and therefore commonly referred to as the RCRA ID Number). If the total amount transferred is less than 1,000 pounds, you may report a range by entering the appropriate range code (range reporting in section 6.2 does not apply to PBT chemicals). The following reporting range codes are to be used: Code 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 Study a,b



### (weight percent of drum capacity) Material Unloading Method Vessel Type Value Kerosenec 

### Waterd 

### Motor Oil e 

### 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

Me an 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 ves sel 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%) = 1,0 50 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 8.1 d, 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 dispos e 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 emis sion 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., es timating 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 p arent 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 comp ounds 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 5 5 

## 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 o ccurs 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 inf ormation 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 w aste 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 hardc opy 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 c ontinue 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 o f 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) (414.4/54 6.37) = 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 s tream 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 cas es 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 bas ed 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 1 00 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 co des 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 signif icant heat value (17,440 BTU/pound) and the energy is recovered in an industrial furnace, the code “U02” would be reported in Section 7B for the Form R submitted for toluene. However, as Freon 113 does not contribute any value for energy recovery purposes , the combustion of Freon 113 in the industrial furnace is considered waste treatment, not energy recovery. You would report Freon 113 as entering a waste treatment step (i.e., incineration), in Section 7A, column b. In Section 7B the facility should report zero. 

## Section 8. Source Reduction and

Recycling Activities This section includes the data elements mandated by Section6607 of the Pollution Prevention Act of 1990 (PPA). In Section 8, you must provide information about source reduction activities and quantities of the EPCRA Section 313 chemicals managed as waste. For all appropriate questions, report only the quantity, in pounds, of the reported EPCRA Section 313 chemical itself (except the dioxin and dioxin like c ompound 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 estimate s). 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, facilitie s 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 chemic al 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 af fect 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 s ales 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 comp ounds 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, R CRA 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 chemical s 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 S ection 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 on site or is sent off

- site for recycling. Section 8.4 is reported in Section 8 only Section 8.5 = Section 6.2 (recycling) - Section 8.8 (off - site recycling due to catastrophic events) Section 8.6 and 8.7. These relate to an EPCRA Section 313 chemical (except for most metals and metal category compounds) or a waste containing an EPCRA Section 313 chemical that is treated for destruction on- site or is sent to a POTW or other off - site location for treatment for destruction. Most metal and category compounds are not reported in this section because they cannot be destroyed (See Appendix B). 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 th at 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 ef fect 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 - s ite 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.

### Instructions for Completing Part II of EPA Form R

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 p ounds 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. Diff erent 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 mold s 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 produ ction 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.

### Instructions for Completing Part II of EPA Form R

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 c an 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 b ike. 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 elimin ated 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 cle an 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 dioxin like compounds category present, and is submitted as an adjunct to the Form R. Beginning with reporting year 2008, facilities that file Form R reports for the dioxin and dioxin- like compounds category are required to determine if they have any of the information required by the new Form R Schedule 1. Facilities that have any of the information required by Form R Schedule 1 must submit a Form R Schedule 1 in addition to the Form R. 

## D.2 Who is required to file a Form R Schedule 1? Only facilities that file reports for the dioxin and dioxin- like compounds category may be required to file a Form R Schedule 1. Facilities that have any of the data required by Form R Schedule 1 for the individual members of the dioxin and dioxin- like compounds category must submit a Form R Schedule 1 , in addition to the Form R. EPA notes that dioxin and dioxin- like compounds are not measured as a total quantity; the measurements are based on the individual compounds within the category. Emission factors for dioxin and dioxin - like compounds are also b ased 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 Di oxin and Dioxin- like Compounds Category, EPA - 745 - B 00 - 021, December 2000) includes tables that contain the emission factors for the individual members of the dioxin and dioxin - like compounds category. Since measured data and emission factor data are based upon data for the individual members of the dioxin and dioxin - like compounds category, the information required by Form R Schedule 1 should be available to facilities that file Form R reports for the dioxin and dioxin - like compounds category. 

## D.3 What information is reported on the Form R Schedule 1? The only data reported on the Form R Schedule 1 is the mass quantity information required in sections 5, 6, and 8 (current year only) of the Form R. All of the other information required in sections 5, 6, and 8 of the Form R (off - site location names, stream or water body names, etc.) would be the same so this information is not duplicated on Form R Schedule 1. For example, if a facility reported 5.3306 grams on Form R Section 5.1 for fugitive or non -point air emissions for the dioxin and dioxin - like compounds category then the facility would report on the Form R Schedule 1 the grams data for each individual member of the category that contributed to the 5.3306 gram total. The sum of the gram quantities reported for each individual member of the category should equal the total gram quantity reported for the category on Form R for each data element (see examples below). The NA box has the same meaning on Form R Schedule 1 as it does on the Form R and should only be marked if it is marked on the Form R.

### 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 non point air emissions Stack 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 - Pentachlorodib enzofuran 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 u se 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 c opy 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 chemical s . 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. Facilitie s 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 li sting 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, p xylene and xylene (mixed isomers)). For example, if a facility processes in three separate process streams, xylene (mixed isomers ), o - xylene, and p xylene, and exceeds the conditions of the alternate threshold for each of these listed substances, the facility may combine the appropriate information on the o - xylene, p - xylene, and xylene (mixed isomers) into one Form R, but cannot combine the reports into one listing on Form A. Facilities that process o - xylene, p - xylene, and xylene (mixed isomers) in separate process streams and do not exceed the conditions of the alternate threshold for one or more of the compounds may submit a separate Form A for each of the forms of xylene meeting the alternate threshold and report on Form R for those forms that do not. Similar to reporting on the parent metals and their associated category compounds described above, facilities that separately proce ss 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 a s 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 seni or 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 certific ation 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 Le vels 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 addres s, 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 -ME web . “NA” or “None” are not acceptable entries. If you have submitted a Form A or Form R for previous reporting years, a TRI Facility Identif ication 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 s everal 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 c ode) 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 Copp er 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 alterna te 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 s eventy 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, 6 9 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 & B radstreet, 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 Manuf

acturing 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 S pecialty 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 31151 4 Dry, Condensed, and Evaporated Dairy

Product Manufacturing

### Table I. NAICS Codes

Toxics Release Inventory Reporting Form and Instructions I - 2 

## 31152 Ice Cream and Frozen Dessert Manufacturing 311520 Ice Cream and Frozen Dessert Manufacturing 

## 3116 Animal Slaughtering and Processing 3 1161 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 31 1919 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 Mayonnais e, Dressing, and Other Prepared

Sauce Manufacturing 311942 Spice and Extract Manufacturing 

## 31199 All Other Miscellaneous Food Manufacturing 311991 Perishable Prepared Food M anufacturing 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 sp onging 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 C arpet 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

Toxics Release Inventory Reporting Form and Instructions I - 4 

## 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) (cu stom 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 316 213 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 316 991 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 Manuf acturing 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

Toxics Release Inventory Reporting Form and Instructions I - 6 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 C oal 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

M anufacturing 

## 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 Cellulo sic 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

Toxics Release Inventory Reporting Form and Instructions I - 8 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

f rom Purchased Steel 

## 33122 Rolling and Drawing of Purchased Steel 331221 Rolled Steel Shape Manufacturing 331222 Steel Wire Drawing

### Table I. NAICS Codes

Toxics Release Inventory Reporting Form and Instructions I - 10 

## 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 331 51 Ferrous Metal Foundries 331511 Iron Foundries 331512 Steel Investment Foundries 331513 Steel Foundries (except Investment) 

## 33152 Nonferrous Metal Foundries 331521 Aluminum Die - Casting Foundries 331522 Nonferrous (except Aluminum) Die - Casting

Foundries 331524 Aluminum Foundries (except Die - Casting) 331525 Copper Foundries (except Die - Casting) 331528 Other Nonferrous Foundries (except Die Casting) 

## 332 Fabricated Metal Product Manufacturing 3321 Forging and Stamping 33211 Forging and Stamping 3 32111 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 B oiler 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 Fab ricated 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

Toxics Release Inventory Reporting Form and Instructions I - 12 332993 Ammunition (except Small Arms)

Manufacturing 332994 Small Arms Manufacturing 3 32995 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 L awn

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

Toxics Release Inventory Reporting Form and Instructions I - 14 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 Radi o 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

Toxics Release Inventory Reporting Form and Instructions I - 16 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 336 322 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 3 36350 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

M anufacturing 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 Vehicl e

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 33 7110 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

Toxics Release Inventory Reporting Form and Instructions I - 18 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) 21239 3 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 mainten ance 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 54171 0 Research and Development in the Physical, Engineering, and Life Sci ences 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 N AICS 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

Toxics Release Inventory Reporting Form and Instructions I - 20 4 25110 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 Chemi cal List For Reporting Year 200 9 (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 s pecific 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 N umber Qualifier Aluminum (fume or dust) 74 29 - 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 c ompounds 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 manuf actured. 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 – RY 2009

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 otherwis e 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 s ubject 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 25,00 0 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 electros tatic 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 i s 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 qualifi er 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 Sectio n 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 li sting 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 – RY 2009

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,S dimethyl ester) 75 - 07 - 0 Acetaldehyde 0.1 60 - 35 - 5 Acetamide 0.1 75 - 05 - 8 Acetonitrile 1.0 98 - 86 - 2 Acetophenone 1.0 53 - 96 - 3 2 - Acetylaminofluorene 0.1 62476 - 59 - 9 Acifluorfen, sodium salt 1.0

[5 - (2 - Chloro - 4 - (trifluoromethyl)phenoxy) - 2 - nitrobenzoic acid, sodium salt] 107 - 02 - 8 Acrolein 1.0 79 - 06 - 1 Acrylamide 0.1 79 - 10 - 7 Acrylic acid 1.0 107 - 13 - 1 Acrylonitrile 0.1 1597 2 - 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 – RY 2009

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 B utyl 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 - methoxyprimidin 2 - yl)amino]carbonyl]amino]sulfonyl] benzoate] 7782 - 50 - 5 Chlorine 1.0 10049 - 04 - 4 Chlorine dioxide 1.0 79 - 11 - 8 Chloroacetic acid 1.0 532 - 27 - 4 2 - Chloroacetophenone 1.0 4080 - 31 - 3 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 – RY 2009

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 - hydroxy N- nitroso, ammonium salt] 21725 - 46 - 2 Cyanazine 1.0 1134 - 23 - 2 Cycloate 1.0 110 - 82 - 7 Cyclohexane 1.0 108 - 93 - 0 Cyclohexanol 1.0 68359 - 37 - 5 Cyfluthrin 1.0

[3 - (2,2 - Dichloroethenyl) - 2,2 - dimethylcyclopropanecarboxylic acid, cyano(4 - fluoro - 3 -phenoxyphenyl) methyl ester] 6 8085 - 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 - 2 1 - 9 2,2 - Dichloro - 1,1,1,3,3 - 1.0

pentafluoropropane (HCFC - 225aa) 4 22 - 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 – RY 2009

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 - chloro 77 - 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 - 4 5 - 8 Dipropyl isocinchomeronate 1.0 138 - 93 - 2 Disodium 1.0

cyanodithioimidocarbonate 94 - 11 - 1 2,4 - D isopropyl ester 0.1 541 - 53 - 7 2,4 - Dithiobiuret 1.0 330 - 54 - 1 Diuron 1.0 2439 - 10 - 3 Dodine [Dodecylguanidine 1.0

monoacetate] 120 - 36 - 5 2,4 - DP 0.1 1320 - 18 - 9 2,4 - D propylene glycol 0.1

butyl ether ester 2702 - 72 - 9 2,4 - D sodium salt 0.1 106 - 89 - 8 Epichlorohydrin 0.1 13194 - 48 - 4 Ethoprop 1.0

[Phosphorodithioic acid O - ethyl S,S dipropyl ester] 110 - 80 - 5 2 - Ethoxyethanol 1.0 140 - 88 - 5 Ethyl acrylate 0.1 100 - 41 - 4 Ethylbenzene 0. 1 541 - 41 - 3 Ethyl chloroformate 1.0 759 - 94 - 4 Ethyl dipropylthiocarbamate 1.0

(EPTC) 74 - 85 - 1 Ethylene 1.0 107 - 21 - 1 Ethylene glycol 1.0 151 - 56 - 4 Ethyleneimine (Aziridine) 0.1 75 - 21 - 8 Ethylene oxide 0.1 96 - 45 - 7 Ethylene thiourea 0.1 75 - 34 - 3 Ethylidene dichlori de 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 – RY 2009

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]phosphinothioy l]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 - 5 6 - 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 – RY 2009

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) - 1H 1,2,4 - triazole - 1 -propanenitrile] 142 - 59 - 6 Nabam 1.0 300 - 76 - 5 Naled 1.0 91 - 20 - 3 Naphthalene 0.1 134 - 32 - 7 alpha- Naphthylamine 0.1 91 - 59 - 8 beta- Naphthylamine 0.1 7440 - 02 - 0 Nickel 0.1 1929 - 82 - 4 Nitrapyrin 1.0

(2 - Chloro - 6 - (trichloromethyl)pyridine) 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 - Nitros odiphenylamine 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 – RY 2009

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 5 1 - 03 - 6 Piperonyl butoxide 1.0 29232 - 93 - 7 Pirimiphos methyl 1.0

[O - (2 - (Diethylamino) - 6 - methyl - 4 - pyrimidinyl) - O,O dimethylphosphorothioate] 1336 - 36 - 3 Polychlorinated biphenyls *

(PCBs) 7758 - 01 - 2 Potassium bromate 0.1 128 - 03 - 0 Potassium dimethyldithio - 1.0

c arbamate 137 - 41 - 7 Potassium N - methyldithio - 1.0

carbamate 41198 - 08 - 7 Profenofos 1.0

[O - (4 - Bromo - 2 - chlorophenyl) - O - ethyl - S propyl phosphorothioate] 7287 - 19 - 6 Prometryn 1.0

[N,N ’ - Bis(1 - methylethyl) - 6 - methylthio 1,3,5 - 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 - thiadiazol 2 - yl] - N,N ’ - dimethylurea] 3383 - 96 - 8 Temephos 1.0 5902 - 51 - 2 Terbacil 1.0

[5 - Chloro - 3 - (1,1 - dimethylethyl) - 6 - methyl 2,4(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 – RY 2009

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 - (p chlorobenzyl)ester] 139 - 65 - 1 4,4' - Thiodianiline 0.1 59669 - 26 - 0 Thiodicarb 1.0 23564 - 06 - 9 Thiophanate ethyl 1.0

[[1,2 - Phenylenebis(iminocarbonothioyl)] biscarbamic acid diethylester] 23564 - 05 - 8 Thiophanate methyl 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 - (1H 1,2,4 - 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 - hydroxy ethyl) - , dimethyl ester] 76 - 02 - 8 Trichloroacetyl chloride 1.0 120 - 82 - 1 1,2,4 - Trichlorobenzene 1.0 71 - 55 - 6 1,1,1 - Trichloroethane (Methyl 1.0

chloroform) 79 - 00 - 5 1,1,2 - Trichloroethane 1.0 79 - 01 - 6 Trichloroethylene 0.1 75 - 69 - 4 Trichlorofluoromethane (CFC - 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- dipropyl 4 - (trifluoromethyl) - ] Deminimis CAS Number Chemical Name % Limit 26644 - 46 - 2 Triforine 1.0

[N,N ’ - [1,4 - Piperazinediylbis - (2,2,2 - trichloro ethylidene)]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 – RY 2009

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 – RY 2009

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) 8 1 - 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 - 9 3 - 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 Ethylb enzene 0.1

### Table II . EPCRA Section 313 Chemical List – RY 2009

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 10 8 - 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 – RY 2009

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 - 5 3 - 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 – RY 2009

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 - 12 3b) 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 0.1 113 4 - 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 aci d) 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 23 00 - 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 – RY 2009

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 - methyl 2,4(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 - methylthio 1,3,5 - triazine - 2,4 - diamine] 7429 - 90 - 5 Aluminum (fume or dust) 1.0 7439 - 92 - 1 Lead *

(when lead is contained in stainless steel, brass or bronze alloys the de minimis level is 0.1) 7439 - 96 - 5 Manganese 1.0 7439 - 97 - 6 Mercury * 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 trif luoride 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 - 2H isoindol - 2 - yl)methyl ester] 7697 - 37 - 2 Nitric acid 1.0 7723 - 14 - 0 Phosphorus (yellow or white) 1.0 7726 - 95 - 6 Bromine 1.0 7758 - 01 - 2 Potassium bromate 0.1 7782 - 41 - 4 Fluorine 1.0 7782 - 49 - 2 Selenium 1.0 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,S dipropyl ester] 13356 - 08 - 6 Fenbutatin oxide 1.0

(Hexakis(2 - methyl - 2 -phenylpropyl) distannoxane) 13463 - 40 - 6 Iron pentacarbonyl 1.0 13474 - 88 - 9 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 – RY 2009

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 25 321 - 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 d allethrone] 28249 - 77 - 6 Thiobencarb 1.0

[Carbamic acid, diethylthio - , S - (p chlorobenzyl)ester] 28407 - 37 - 6 C.I. Direct Blue 218 1.0 29082 - 74 - 4 Octachlorostyrene * 29232 - 93 - 7 Pirimiphos methyl 1.0

[O - (2 - (Diethylamino) - 6 - methyl - 4 - pyrimidinyl) - O,O dimethylphosphorothioate] De minimis CAS Number Chemical Name % Limit

Arranged by CAS Number 30560 - 19 - 1 Acephate 1.0

(Acetylphosphoramidothioic acid O,S dimethyl ester) 31218 - 83 - 4 Propetamphos 1.0

[3 - [(Ethylamino) methoxyphosphinothioyl]oxy] - 2 -butenoic acid, 1 - methylethyl es ter] 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 - S propyl phosphorothioate] 41766 - 75 - 0 3,3' - Dimethylbenzidine 0.1

dihydrofluoride (o Tolidinedihydrofluoride) 42874 - 03 - 3 Oxyfluorfen 1.0 43121 - 43 - 3 Triadimefon 1.0

[1 - (4 - Chlorophenoxy) - 3,3 - dimethyl - 1 - (1H 1,2,4 - triazol - 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 – RY 2009

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] 5529 0 - 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] 6 8085 - 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] 7 1751 - 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 - methoxyprimidin 2 - yl)amino]carbonyl] amino]sulfonyl]benzoate] 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] 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 - 7 9 - 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 parenthe ses. The de minimis exemption is not available for PBT chemicals, therefore an asterisk appears where a de minimis limit would otherwise appear.

### Table II . EPCRA Section 313 Chemical List – RY 2009

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 th at 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)



## O H C l 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 substan ce that contains chromium as part of that chemica l’ 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 chemica l’ s infrastructure. This category does not include copper phthalocyanine compounds that are substituted with only hydrogen, and/or chlorine, and/or brom ine. 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' - Dimethoxybenzidine 4,4' - diisocyanate 91 - 97 - 4 3,3' - Dimethyl - 4,4' -

diphenylene diisocyanate 139 - 25 - 3 3,3' - Dimethyldiphenyl

methane - 4,4' - diisocyanate 822 - 06 - 0 Hexamethylene - 1,6 -

diisocyanate 4098 - 71 - 9 Isophorone diisocyanate 75790 - 84 - 0 4 - Methyldiphenylmethane - 3,4 -

diisocyanate 5124 - 30 - 1 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 – RY 2009

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 Ethylenebisdithio carbamic 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- (OCH 2CH 2) 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)



## B rx H (10-x) Where x = 1 to 10 N575 Polybrominated Biphenyls (PBBs) (0.1) N583 Polychlorinated alkanes (C 10 to C 13) (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 C 10H 19 Cl 3 and C 13 H 16 Cl 12 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 – RY 2009

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 Dib enzo(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 infrastruc ture. N982 Zinc Compounds (1.0) Includes any unique chemical substance that contains zinc as part of that chemica l’ s infrastructure.

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# Table II I . 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 Fi ji 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 Isl and 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 S outh 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 134 23 , “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, 4.2 c. 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 facilitie s (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 medi a 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

Toxics Release Inventory Reporting Forms and Instructions A - 2 

# 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 Classifi cation 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 B een Submitted Any TRI Form R submitter may voluntarily revise their submission if they find errors after their reports have been sent to EPA. If the revision is to a hardcopy report, the facility reporter should photocopy the original form and use a blue or black pen to mark out the incorrect value and write in the corrected value. The revised report should be submitted to EPA, with an “X” in the revision block on page 1 of the Form R. If the revision is to a diskette, a new diskette should be submitted, containing the data only for the revised submission, not all the chemicals originally reported. If a federal facility receives a copy of a revision from a contractor located at the federal facility, the facility should revise the federal report, and submit the revised report to EPA and the appropriate state along with an exact copy of the contractor’s revision. The cover letter from the federal facility should indicate that its submission is a revision. 

# A.9 Who Should Sign Federal Form R Reports? Federal Form R reports should be signed by the senior federal employee on - site. If no federal employee is on site, federal Form R reports must be signed by the senior federal employee with management responsibility for the site. Federal Form R reports should be signed by a federal employee. Contractor employee signatures are not considered valid on federal reports.

### 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 rep ort. 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 92 1 Executive, Legislative, and Other General Government Support 9 21 11 Executive Offices 921 12 Legislative Bodies 92113 Public Finance Activities 9 2114 Executive and Legislative Offices Combined 92115 American Indian and Alaska Native Tribal Governments 9 2119 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 9 2311 Administration of Educational Programs 9 2312 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 Con servation 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 F or m 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 0,000,0 99 02 0,000, 100 0,000, 999 03 0,00 1,000 0,00 9,999 04 0,0 10,000 0,0 99,999 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 00 1 - 10 B 0 11 -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

Toxics Release Inventory Reporting Forms and Instructions B - 2 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 vol atilization 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 W astewater 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- aqueou s 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 M odified 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

Toxics Release Inventory Reporting Forms and Instructions B - 4 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 rep orted 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 Category Compounds 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 - Discharge s to POTWs All All Vanadium (except when contained in an alloy) All except Asbestos

### Appendix B

Toxics Release Inventory Reporting Forms and Instructions B - 6 

### 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 rep orting 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 Individually listed 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 Asbestos 1 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 Compounds 2 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 pre treatment 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

Toxics Release Inventory Reporting Forms and Instructions B - 8 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 tre atment 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 Inj ection 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 u se 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 dispos al 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 

### S ection 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 Individually listed Metal Compounds U01, U02, U03 None None None All except Asbestos 1

### Appendix B

Toxics Release Inventory Reporting Forms and Instructions B - 10 

### 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 Individually listed 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 Individually listed Metal Compounds Quantity used for energy recovery on site and off site (Sections 8 .2 and 8.3) None None None All except Asbestos 2 Quantity treated for destruction on site and off site (Sections 8.6 and 8.7) None except Barium2 None except

Barium Compounds 2 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 b oiler (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: Non Technical Data Changes (NDC), Notices of Technical Errors (NOTE), Notices of Significant Error (NOSE) , and Data Quality Alerts (DQA). FDPs identify three different types of errors: NDCs, NOTEs and NOSEs and one type of alert called Data Quality Alert (DQA). See explanation s 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

Toxics Re lease Inventory Reporting Forms and Instructions C - 2 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 identif y 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 o f 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 Proc essing 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 o f 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 Re lease 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-ME web 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 facilitie s 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 s ection 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

Toxics Re lease Inventory Reporting Forms and Instructions C - 4 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 1 st reporting deadline. 

### Section 4. Facility Identification  Questionable entries. Incorrect entries may require corrections to be made by the facility. The use of the TRI-ME web 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 Re lease 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 diisocyanate s) 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, ” “pro cessed, ” 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

Toxics Re lease Inventory Reporting Forms and Instructions C - 6 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 tre atment 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 displ ays 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-ME

web 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 co des 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 Re lease 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 processe s 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 BrokerC Disposal

– 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

Toxics Re lease Inventory Reporting Forms and Instructions C - 8 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 releas ed 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

– M2 8 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 31 3 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 Re lease 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 of f - 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

Toxics Re lease Inventory Reporting Forms and Instructions C - 10 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) 1 1. 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) 1 2 . 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. 1 3 . You did not complete Part II, Sections 5 and 6. Please provide the required information; otherwise indicate NA. 1 4 . You did not complete Part II, Section 7. Pleas e provide the required information; otherwise indicate NA. 1 5 . You did not complete Part II, Section 8. Please provide the required information; otherwise indicate NA. 

# C.5 Messages Used to Report Notices of Technical Errors (NOTEs) and Non technical Data Cha nges (NDCs) Invalid codes throughout Form R 1 6 . 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) 1 7 . 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) 1 8 . 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) 1 9 . 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 Re lease 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 mis spelled, or incorrect, or did not match the previous year submissions. If you feel our correction was made in error, please resubmit forms with correct information. (NDC) 27. In Part I, Section 4.1, you have used an invalid TRIFID or you have self

- assigned your own TRIFID or TRIFID that has been superceded. You may not generate your own TRIFID. The TRI Data Processing Center assigns this number to a facility. EPA has corrected this error and assigned you the correct TRIFID. Please note the corrected TRIFID and keep it for use in future submissions. (NDC) 28. No Public Contact name and/or telephone number was listed. Please provide the name and telephone number of your Public Contact. (NOTE) 29. No Technical C ontact 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 (GOC O) 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. Plea se 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

Toxics Re lease Inventory Reporting Forms and Instructions C - 12 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. P art 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 Re lease 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 c omplete 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. Ple ase 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 co de 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 c orrect 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

Toxics Re lease Inventory Reporting Forms and Instructions C - 14 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 c odes. 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 c olumn 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 Re lease 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 c odes 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 8 a , 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 chemicals they send to other covered users. An example would be if you sold a lacquer containing toluene to distributors who then may sell the product to other manufacturers. The distributors are not in a covered NAICS code, but because they sell the product to companies in covered NAICS codes, they must be notified so that they may pass the notice along to their customers, as required. The language of the supplier notification requirements covers mixtures or other trade name products that are sold or otherwise distributed. The “otherwise distributes ” language includes intra- company transfers and, therefore, the supplier notification requirements at 40 CFR Section 372.45 apply. 

# D.3 Supplier Notification Content The supplier notification must include the following inf ormation: 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 associ ated 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

Toxics Release Inventory Rep orting Forms and Instructions D - 2 

# D.4 How the Notification Must Be Made The required notification must be provided at least annually in writing. Acceptable forms o f 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 chemic al(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 Rep orting Forms and Instructions D - 3 Chemical or chemical category name CAS number or chemical category code Supplier

notification li mit (%) 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 dioxin like compounds if the dioxin and dioxin - like compounds are pre sent 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 li mit (%) 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

Toxics Release Inventory Rep orting Forms and Instructions D - 4 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 chemic al 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 (f or 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 Rep orting Forms and Instructions D - 5 

# D.9 Sample Notification Letter January 2, 200 9 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 chemical s 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

Toxics Release Inventory Rep orting Forms and Instructions D - 6 

# 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) Willi am 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, S uite 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; f

ax: (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.b arbara@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 - 31 40 (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 Pub lic Data Release (PDR) Brochure (EPA- 260 - R- 0 9 - 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 o ff - 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, u sers 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

Toxics Releases Inventory Forms and Instructions G - 2 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 public ation 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 fact sheets on pollution prevention from various state programs call the PPIC reference and referral service at 202 566 - 0799, or fax a request to 202 566 - 0794, or write to: U.S. EPA Pollution Prevention Information Clearinghouse (PPIC) EPA West 1200 Pennsylvania Ave. NW Room 3379 (Mail Code 7407 - T) Washington, DC 20460 - 0001 Email: ppic@epa.gov

### 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 u ses 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 134 23 , f requently 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

Toxics Release Inventory Reporting Forms and Instructions H - 2  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 provisi on, and contains a sample notification.  Toxic Chemical Release Inventory Reporting Forms and Instructions Revised 200 6 Version February 2007 (EPA 260 - C - 0 6 - 9 01)  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 199 9 (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

Toxics Release Inventory Reporting Forms and Instructions H - 4  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 Pro cessing 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 comp any) 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 numb er 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

Toxics Release Inventory Reporting Forms and Instructions 

### I - 2 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- sp ecific; 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 division s 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 - B 98 - 001)). C. Question A covered facility sells one of its establishments to a new owner. The operator of the newly sold establishment, however, does not change. The same operator operates the newly sold establishment and the rest of the facility. Although the facility makes its threshold determinations based on the activities at the entire facility (including the newly sold establishment), the facility chooses to report separately for the different establishments. What parent name should the newly sold establishment use, the parent name of the owner or the parent name of the operator (i.e., the same as the rest of the facility)? C. Answer All establishments of a covered facility must report the parent name of the facility. Therefore, in the instance described above, the newly sold establishment should use the parent name of the facility operator (i.e. , the same parent name the rest of the facility is using). (Source: Spring Training 1998). D. Question Company A purchases a facility from Company B between January 1, 2006 and June 30, 2006. For the 2005 reporting year, which company’s name and identification number should appear on the Form R or Form A submission? D. Answer In the case that a facility is purchased between January 1 and June 30, the form submitted for the previous year must reflect the name used by the facility on December 31 of that reporting year. In this example, company B’s name should appear on the form because it owned the facility for the duration of the reporting year. The TRI identification number is location - specific; thus, the identification number will stay the same even if the facility changes names, production processes, or NAICS codes. With regard to reporting, the owner or operator of the facility on the annual July 1 reporting deadline (Company A) is primarily responsible for reporting the data for the previous year’s operations at that facility. However, all prior owners and operators back to January 1 of the year covered in the report may also be held responsible if the current owner or operator does not submit a report. ( Source: Monthly C all 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 31 3?

### 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 pers on.” 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 adjac ent 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 Instruction s.