TRI

United States

Environm ental Protection

Agency

Office of Pollution

P revention and Toxics

Washington, DC 20460

EPA 745-B-00-008

May 2000

EPA Emergency Planning and Community RightTo-Know Act Section 313 Reporting Guidance

for the Textile Processing Industry
i

TABLE OF CONTENTS

Page

ACKNOWLEDGMENT ........................................................v

OVERVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vi

CHAPTER 1 - INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

1.0 PURPOSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

1.1 Background on EPCRA Section 313 and PPA Section 6607 . . . . . . . . 1-2

CHAPTER 2 - REPORTING REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

2.0 PURPOSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

2.1 Must You Report? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2

2.2 SIC Code Determination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4

2.3 Number of Employees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7

2.4 Manufacturing, Processing, and Otherwise Use of EPCRA Section 

313 Chemicals or Chemical Categories . . . . . . . . . . . . . . . . . . . . . . . . . 2-8

2.5 Activity Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10

2.6 Persistent, Bioaccumulative, and Toxic (PBT) Chemicals . . . . . . . . . 2-13

2.7 How Do You Report? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-16

2.8 Form R . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-16

2.9 Alternate Threshold and Form A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-17

2.10 Trade Secrets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-19

2.11 Recordkeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-20

CHAPTER 3 - EPCRA SECTION 313 CHEMICAL OR CHEMICAL CATEGORY 

ACTIVITY THRESHOLD DETERMINATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

3.0 PURPOSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

3.1 Step 1 - Identify Which EPCRA Section 313 Chemicals or Chemical

Categories are Manufactured (Including Imported), Processed, or

Otherwise Used . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

3.2 Step 2. Identify the Activity Category and Any Exempt Activities 

for Each EPCRA Section 313 Chemical . . . . . . . . . . . . . . . . . . . . . . . . 3-8

3.2.1 Concentration Ranges for Threshold Determination . . . . . . . . 3-12

3.2.2 Evaluation of Exemptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-13

3.2.2.1 De Minimis Exemption . . . . . . . . . . . . . . . . . . . . . . . . 3-14

3.2.2.2 Articles Exemption . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-16

3.2.2.3 Facility-Related Exemption . . . . . . . . . . . . . . . . . . . . . 3-18

Laboratory Activity Exemption . . . . . . . . . . . . . . . . . . 3-18

3.2.2.4 Activity-Related Exemptions (Otherwise Use 

Exemptions) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19

3.2.3 Additional Guidance on Threshold Calculations for Certain

Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-21
TABLE OF CONTENTS (Continued)

Page

ii

3.2.3.1 Reuse Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-21

3.2.3.2 Remediation Activities . . . . . . . . . . . . . . . . . . . . . . . . . 3-22

3.2.3.3 Recycling Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-23

3.3 Step 3. Calculate the Quantity of Each EPCRA Section 313 Chemical 

and Chemical Category and Determine Which Ones Exceed an 

Activity Threshold . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-23

CHAPTER 4 - ESTIMATING RELEASE AND OTHER WASTE MANAGEMENT

QUANTITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

4.0 PURPOSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

4.1 General Steps for Determining Release and Other Waste Management

Activity Quantities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

4.1.1 Step 1: Prepare a Process Flow Diagram . . . . . . . . . . . . . . . . . 4-3

4.1.2 Step 2: Identify EPCRA Section 313 Chemicals and Chemical

Categories and Potential Sources of Chemical Release and 

Other Waste Management Activities . . . . . . . . . . . . . . . . . . . . . 4-3

4.1.3 Step 3: Identify Release and Other Waste Management 

Activity Types . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4

4.1.4 Step 4: Determine the Most Appropriate Method(s) to Calculate

the Estimates for Release and Other Waste Management Activity

Quantities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17

4.1.4.1 Monitoring Data or Direct Measurement (code M) . . . 4-19

4.1.4.2 Mass Balance (code C) . . . . . . . . . . . . . . . . . . . . . . . . 4-20

4.1.4.3 Emission Factors (code E) . . . . . . . . . . . . . . . . . . . . . . 4-22

4.1.4.4 Engineering Calculations (code O) . . . . . . . . . . . . . . . 4-24

4.1.4.5 Estimating Release and Other Waste Management

Quantities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-26

4.2 Textile Industry and Process Description . . . . . . . . . . . . . . . . . . . . . . 4-31

4.2.1 Yarn Formation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-33

4.2.2 Fabric Formation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-36

4.2.3 Wet Processing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-41

4.2.4 Product Fabrication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-52

Appendix A TRI GUIDANCE RESOURCES

Appendix B BASIC CALCULATION TECHNIQUES

Appendix C GUIDANCE FOR REPORTING AQUEOUS AMMONIA

Appendix D TOXIC RELEASE INVENTORY: LIST OF TOXIC CHEMICALS WITHIN

THE GLYCOL ETHERS CATEGORY (excerpt)

Appendix E UNIT CONVERSION FACTORS

INDEX
iii

LIST OF TABLES

Page

2-1 SIC Codes Covered by EPCRA Section 313 Reporting . . . . . . . . . . . . . . . . . . 2-4

2-2 SIC Codes for Textile Manufacturing Facilities . . . . . . . . . . . . . . . . . . . . . . . . 2-5

2-3 EPCRA Section 313 Chemicals and Chemical Categories Commonly Encountered

in Textile Manufacturing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10

2-4 Activity Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-11

2-5 Reporting Thresholds for EPCRA Section 313 Listed PBT Chemicals . . . . . 2-14

3-1 Reporting Thresholds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8

3-2 Definitions and Examples of Manufacturing Subcategories . . . . . . . . . . . . . . 3-10

3-3 Definitions and Examples of Processing Subcategories . . . . . . . . . . . . . . . . . 3-11

3-4 Definitions and Examples of Otherwise Use Subcategories . . . . . . . . . . . . . . 3-12

3-5 EPCRA Section 313 Reporting Threshold Worksheet . . . . . . . . . . . . . . . . . . 3-26

3-6 Sample EPCRA Section 313 Reporting Threshold Worksheet . . . . . . . . . . . . 3-27

4-1 Summary of Residue Quantities From Pilot-Scale Experimental Study

(weight percent of drum capacity) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-11

4-2 Potential Data Sources for Release and Other Waste Management 

Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-19

4-3 Release and Other Waste Management Quantity Estimation Worksheet . . . . 4-27

4-4 Common EPCRA Section 313 Chemicals and Chemical Categories 

Associated with Release and Other Waste Management Activity Types 

During Fabric Formation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-39

4-5 Common EPCRA Section 313 Chemicals and Chemical Categories 

Associated with Release and Other Waste Management Activity Types 

During Textile Wet Processing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-47

4-6 Typical Dye Fixation Values . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-50
iv

LIST OF FIGURES

Page

2-1 EPCRA Section 313 Reporting Decision Diagram . . . . . . . . . . . . . . . . . . . . . . 2-3

4-1 Release and Other Waste Management Calculation Approach . . . . . . . . . . . . . 4-2

4-2 Possible Release and Other Waste Management Types for EPCRA Section 

313 Chemicals and Chemical Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5

4-3 Typical Textile Processing Flow Diagram . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-32

4-4 Typical Yarn Formation Process Flow Diagram . . . . . . . . . . . . . . . . . . . . . . . 4-34

4-5 Fabric Formation Process for Producing Flat Fabrics . . . . . . . . . . . . . . . . . . . 4-38

4-6 Wet Processing Fabric Preparation Flow Diagram . . . . . . . . . . . . . . . . . . . . . 4-42

4-7 Wet Processing Printing, Dyeing, and Finishing Flow Diagram . . . . . . . . . . . 4-43

4-8 Textile Product Fabrication Process Flow Diagram . . . . . . . . . . . . . . . . . . . . 4-52
v

ACKNOWLEDGMENT

The U.S. EPA wishes to acknowledge the valuable contributions made by the staff

and members of the American Textile Manufacturers Institute (ATMI). Without the insight

provided by those in the industry with actual experience in the fulfilling of the EPCRA

Section 313 reporting requirements we would not have been able to produce a document that we

believe will be of great assistance to those who must prepare future EPCRA Section 313 reports. 

Special thanks go to Ms. Stephanie Janczuk, Government Relations Associate, ATMI.
vi

OVERVIEW

This document supersedes the booklet entitled Title III Section 313 Release

Reporting Guidance, Estimating Chemical Releases From Textile Dyeing, dated February 1988. 

It is intended to assist establishments and facilities in the Textile Manufacturing Industry in

complying with the Emergency Planning and Community Right-To-Know Act (EPCRA)

Section 313 and Pollution Prevention Act (PPA) Section 6607 reporting requirements, the

preparation of Form R or the alternate certification statement, Form A. The EPCRA Section 313

program is commonly referred to as the Toxic Chemical Release Inventory (TRI).

The principal differences in this new document include:

& More detailed examples;

& New EPCRA Section 313 regulations and guidance developed since 1988;

& PPA Section 6607 reporting requirements;

& U.S. Environmental Protection Agency’s (EPA’s) interpretive guidance on

various issues specific to textile manufacturing; and

& EPCRA Section 313 issues regarding processes not discussed in the earlier

document.

This document is designed to be a supplement to the annual issue of the Toxic

Chemical Release Inventory Reporting Forms and Instructions, (TRI Forms and Instructions). It

is organized to provide a step-by-step guide to compliance with EPCRA Section 313, starting

with how to determine if your facility must report and ending with guidance for estimating

release and other waste management quantities.

The textile manufacturing process begins with spinning natural and man-made

fibers into yarns and threads. These are then converted (by weaving and knitting) into fabrics. 

The fabrics, and in some cases the yarns and threads used to make them, are dyed and finished. 

Fabrics may then proceed through additional processing steps designed to fabricate textile

products such as carpets, rugs, curtains, linens, apparel, and canvas.

Chapter 1 introduces EPCRA Section 313 and PPA Section 6607 reporting and

provides a brief background on Section 313 of EPCRA and Section 6607 of PPA.
vii

Chapter 2 discusses reporting requirements and begins with how to determine if

your facility must report. This determination is based on your answers to a series of four

questions:

& Is your facility’s primary Standard Industry Classification (SIC) Code on

the EPCRA Section 313 list?

& Does your facility employ ten or more full-time employees or the

equivalent?

& Does your facility manufacture, process, or otherwise use any EPCRA

Section 313 chemicals or chemical categories?

& Does your facility exceed any of the activity thresholds for an EPCRA

Section 313 chemical or chemical category?

If the answer to ANY ONE of the first three questions is “No” you are not required to submit an

EPCRA Section 313 report for any chemicals. If you answer “yes” to the first three questions

and “no” to the fourth, you are not required to submit an EPCRA Section 313 report for that

chemical or chemical category. If you answer “Yes” to ALL four questions, the next step is to

determine what kind of report you must prepare, a Form R or the alternate certification statement,

Form A. Chapter 2 provides detailed information on the requirements for each kind of report. 

Chapter 2 concludes with a discussion on how to address trade secrets and the records that you

should keep to support your reporting.

Chapter 3 discusses how to calculate the activity thresholds (manufacture,

process, and otherwise use) for the EPCRA Section 313 chemicals. Information is provided on

how to determine which EPCRA Section 313 chemicals your facility manufactures, processes, or

otherwise uses and how to calculate the quantities of each. Detailed information is also provided

on the various exemptions:

& De minimis exemption;

& Article exemption;

& Facility-related exemption; and

& Activity-related exemptions.

Chapter 3 concludes with a discussion of how to determine which EPCRA

Section 313 chemicals and chemical categories exceed a reporting threshold.
viii

Chapter 4 discusses how to estimate the release and other waste management

amounts for those EPCRA Section 313 chemicals and chemical categories for which you must

prepare a report. The first part of this chapter provides a step-by-step approach designed to

minimize the risk of overlooking an activity involving an EPCRA Section 313 chemical or

chemical category and any potential sources or types of release and other waste management

activities. This procedure consists of:

& Preparation of a detailed process flow diagram;

& Identification of EPCRA Section 313 chemicals and chemical categories

and potential sources of chemical release and other waste management

activities;

& Identification of the potential types of release and other waste

management activities from each source; and

& Determination of the most appropriate methods for estimating the

quantities of EPCRA Section 313 chemical and chemical category release

and other waste management activities.

The second part of Chapter 4 is organized to follow the steps above as they pertain

to textile manufacturing. The commonly used EPCRA Section 313 chemicals and chemical

categories, process descriptions, release and other waste management estimates, example

calculations, and common problems are presented.

This document includes examples and common errors applicable to textile

manufacturing. These examples are based on information received from representatives of the

American Textile Manufacturers Institute, questions received by the EPCRA Hotline, and

questions identified during voluntary site surveys of facilities that have filed EPCRA Section 313

reports in the past.
1-1

CHAPTER 1 - INTRODUCTION

1.0 PURPOSE

The purpose of this guidance manual is two-fold. The primary purpose is to assist

textile manufacturing facilities in complying with the reporting requirements of Section 313 of

the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) and of Section

6607 of the Pollution Prevention Act of 1990 (PPA). This manual explains the EPCRA Section

313 reporting requirements and discusses specific release and other waste management activities

encountered at many textile manufacturing facilities. Since each plant is unique, the

recommendations presented may have to be modified for your particular facility. The secondary

purpose is to provide information to other interested parties (such as management, legal

professionals, inspectors, consultants, teachers, students, and the general public) about the

processes and some of the toxic chemicals used in this industry.

This manual is intended solely for guidance and does not alter any statutory or

regulatory requirements. The document should be used in conjunction with the appropriate

statutes and regulations but does not supersede them. Accordingly, the reader should consult

other applicable documents (for example, the statute, the Code of Federal Regulations (CFR),

relevant preamble language, and the current Toxic Chemical Release Inventory Reporting Forms

and Instructions (TRI Forms and Instructions)).

This document supersedes the 1988 document entitled Title III Section 313

Release Reporting Guidance, Estimating Chemical Releases From Textile Dyeing. This new

document includes:

& More detailed examples;

& New EPCRA Section 313 regulations and guidance developed since 1988;

& PPA Section 6607 reporting requirements;

& U.S. Environmental Protection Agency’s (U.S. EPA’s) interpretive

guidance on various issues specific to textile manufacturing; and

& EPCRA Section 313 issues regarding processes not discussed in the earlier

document.
1-2

It is intended to supplement the TRI Forms and Instructions document that is updated and

published annually by U.S. EPA. It is essential that you use the current version of the TRI Forms

and Instructions to determine if (and how) you should report. Changes or modifications to

EPCRA Section 313 reporting requirements are reflected in the annual TRI Forms and

Instructions and should be reviewed before compiling information for the report.

The objectives of this manual are to:

& Reduce the level of effort expended by those facilities that prepare an

EPCRA Section 313 report; and 

& Increase the accuracy and completeness of the data being reported.

U.S. EPA cannot anticipate every potential issue or question that may apply to

your facility. Therefore, this manual attempts to address those issues most prevalent or common

for textile manufacturing. Used in conjunction with the most current TRI Forms and Instructions

and Estimating Release and Waste Treatment Efficiencies for the Toxic Chemical Release

Inventory Form (1999 version), facilities should be able to provide complete and accurate

information for EPCRA Section 313 reporting. Additional discussions on specific issues can be

found in U.S. EPA’s current edition of EPCRA Section 313, Questions and Answers (the 1998

edition is EPA 745-B-98-004), which is available on the U.S. EPA’s TRI website

(http://www.epa.gov/tri) or by contacting the EPCRA Hotline at 1-800-424-9346.

In the Washington, DC metropolitan area, call 703-412-9810.

1.1 Background on EPCRA Section 313 and PPA Section 6607

The following overview of EPCRA Section 313 and Section 6607 of the PPA,

will provide you with a basic understanding of the objectives and requirements of this program,

and will help you in completing your forms.
1-3

One of the primary goals of EPCRA is to increase the public’s knowledge of, and

access to, information on both the presence of toxic chemicals in their communities and on

releases into the environment and other waste management activities of those chemicals. 

EPCRA Section 313 requires certain designated businesses (see SIC Code discussion, Chapter 2,

Section 2.2) to submit annual reports (commonly referred to as Form R reports and Form A

reports) on over 600 EPCRA Section 313 chemicals and chemical categories. Covered facilities

report the amounts released or otherwise managed as waste. However, if a facility meets the

reporting criteria for listed toxic chemicals, the facility must report even if there are no releases

or other waste management quantities associated with these chemicals. Throughout this

document, whenever EPCRA Section 313 chemicals are discussed, the discussion includes

chemical categories as appropriate. Chemicals or chemical categories may be added or deleted

from the list. Therefore, before completing your annual report, be sure to check the most current

list included with the TRI Forms and Instructions when evaluating the chemicals and chemical

categories present at your facility. Copies of the reporting package can be requested from the

EPCRA Hotline, 1-800-424-9346.

All facilities meeting the EPCRA Section 313 reporting criteria must report the

annual release and other waste management activity quantities (routine and accidental) of

EPCRA Section 313 chemicals and chemical categories to all environmental media. A separate

report is required for each EPCRA Section 313 chemical or chemical category that is

manufactured (including imported), processed, or otherwise used above the reporting threshold. 

The reports must be submitted to U.S. EPA and State or Tribal governments, on or before July 1,

for activities in the previous calendar year. The owner/operator of the facility on July 1 is

primarily responsible for the report, even if the owner/operator did not own the facility during the

reporting year. However, property owners with no business interest in the operation of the

facility, other than a lessor interest, are exempt from reporting requirements. 

EPCRA also mandates U.S. EPA to establish and maintain a publicly available

database system consisting of the information reported under Section 313 and under Section

6607 of the PPA. This database, known as the Toxic Chemical Release Inventory (TRI)

database, can be accessed through the following sources:
1-4

& U.S. EPA Internet site, http://www.epa.gov/tri;

& Envirofacts Warehouse Internet site, http://www.epa.gov/enviro/; and

& Right-to-Know Network, http://www.rtk.net/trisearch.html.

However, information qualifying as a trade secret, in accordance with the

regulatory requirements, is protected from public release. In addition to being a resource for the

public, TRI data are also used in the research and development of regulations related to EPCRA

Section 313 chemicals and chemical categories.

To reduce the reporting burden for small businesses, U.S. EPA established an

alternate activity threshold of one million pounds manufactured, processed, or otherwise used for

facilities with total annual reportable amounts of 500 pounds or less for each EPCRA Section

313 chemical or chemical category. Provided the facility does not exceed either the reportable

amount or the alternate threshold, the facility may file a certification form (Form A) rather than a

Form R. By filing the Form A, the facility certifies that they do not exceed the reportable amount

of 500 pounds or exceed the alternate threshold of one million pounds for the respective

chemical or chemical category. 

Note that the annual reportable amount includes the quantity of EPCRA Section

313 chemical or chemical category in all production-related waste management activities, not

just releases (see the discussion in Section 2.8 for more detail). Also note that either a Form A or

a Form R, but not both, must be submitted for each EPCRA Section 313 chemical or chemical

category above any reporting threshold, even if there are zero release and other waste

management quantities.

Violation of EPCRA Section 313 reporting provisions may result in federal civil

penalties of up to $27,500 per day for each violation (61 FR 69360). State enforcement

provisions may also be applicable depending on the state’s EPCRA Section 313 reporting

regulations.

Members of the American Textile Manufacturers Institute provided input on

common problems, specific to textile manufacturing, encountered by those completing the

EPCRA Section 313 reports. U.S. EPA has combined this input with questions forwarded to the
1-5

EPCRA Hotline and those identified during voluntary site surveys of facilities that have filed

EPCRA Section 313 reports in the past. Selected issues and guidance addressing these common

problems are presented throughout this document as applicable.

The TRI Forms and Instructions and The 1994 and 1995 Toxic Release Inventory

Data Quality Report, EPA 745-R-98-002 also contains discussions of common problems in

completing the EPCRA Section 313 reports. You are encouraged to read both documents before

filling out the Form R (or Form A) for your facility.

If, after reading this manual, you still have questions about EPCRA Section 313

reporting, please contact the EPCRA Hotline at 1-800-424-9346 or refer to the U.S. EPA’s TRI

website, http://www.epa.gov/tri. Assistance is also available from the designated EPCRA

Section 313 Coordinator in the U.S. EPA regional office and the EPCRA contact in your state

(see the TRI Forms and Instructions for a current list of these contacts). Additional guidance is

also available in the resources listed in Appendix A.
2-1

CHAPTER 2 - REPORTING REQUIREMENTS

2.0 PURPOSE

The purpose of this chapter is to help you determine if you must prepare an

EPCRA Section 313 report(s) and, if so, what kind of report(s) should be prepared (Form R or

the alternate certification statement, the Form A). This chapter presents the EPCRA Section 313

reporting requirements to help you determine if these requirements apply to your facility. It also

discusses the reporting of trade secrets and the records that must be kept.

To understand the following discussion you must first understand how EPCRA

defines a facility. The term “facility” is defined as, “all buildings, equipment, structures, and

other stationary items which are located on a single site or on contiguous or adjacent sites and

which are owned or operated by the same person (or by any person who controls, who is

controlled by, or who is under common control with such person).” A facility may contain more

than one “establishment” (40 CFR 372.3). An “establishment” is defined as, “an economic unit,

generally at a single physical location, where business is conducted, or where services or

industrial operations are performed” (40 CFR 372.3). 

U.S. EPA recognizes that for business reasons it may be easier and more

appropriate for establishments at one facility to report separately. However, the combined

quantities of EPCRA Section 313 chemicals and chemical categories manufactured, processed, or

otherwise used in all establishments making up that facility must be considered for threshold

determinations. Also, the combined release and other waste management activities reported

singly for each establishment must total those for the facility as a whole. 

Note that if a facility is comprised of more than one establishment, once an

activity threshold is met by the facility, providing the facility meets the SIC Code and employee

threshold criteria, release and other waste management activities from all establishments at the

facility must be reported.
2-2

Example - Multiple Establishments

Your facility has several different establishments, all with SIC Codes covered by EPCRA Section 313. One

establishment used 7,000 pounds of toluene, an EPCRA Section 313 chemical, during the year to clean

equipment. Another establishment purchased and used 4,000 pounds of toluene during the year as a solvent to

separate a component from a mixture with recovery of toluene for reuse. Both activities constitute otherwise use

of the EPCRA Section 313 chemical (as presented in Section 2.5 and described in detail in Chapter 3) and the

total for the facility exceeded the 10,000-pound otherwise use threshold for the year. Thus, if your facility meets

the employee threshold, you must file one Form R for toluene from your facility, or two Form Rs, one from each

establishment. Please note that you may be eligible to file one Form A for the facility but you cannot file a

separate Form A for each establishment.

2.1 Must You Report?

How do you determine if your facility must prepare an EPCRA Section 313

report? Your answers to the following four questions will help you decide (illustrated by

Figure 2-1): 

1) Is the primary SIC Code for your facility included in the list covered by

EPCRA Section 313 reporting (see Section 2.2)? 

2) Does your facility have 10 or more full-time employees or the equivalent

(see Section 2.3)?

3) Does your facility manufacture (which includes importation), process, or

otherwise use EPCRA Section 313 chemicals or chemical categories (see

Section 2.4)?

4) Does your facility exceed any applicable thresholds of EPCRA Section

313 chemicals or chemical categories (for non-PBT chemicals: 25,000

pounds per year for manufacturing; 25,000 pounds per year for processing;

or 10,000 pounds per year for otherwise use - see Section 2.5; for PBT

chemicals - see Section 2.6 for applicable thresholds)?
Is Your Facility’s Prim ary SIC Code Included

on the EPCRA Section 313 List?

(See Section 2.2)

N O

YES

YES

YES

YES

YES

N O

N O

N O

N O

Does Your Facility Have 10 or More Full-Time

Employees or the Equivalent?

(See Section 2.3)

Does Your Facility Manufacture, Process, or

Otherwise Use any EPCRA Section 313

Chemicals or Chemical Categories?

(See Section 2.4)

Does Your Facility Exceed Any of the 

Thresholds for a Chemical or Chemical 

Category (after excluding quantities that are 

exempt from threshold calculations)

(See Section 2.6)

AN EPCRA SECTION 313 REPORT IS

REQUIRED FOR THIS CHEMICAL OR

CHEMICAL CATEGORY

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 lb/yr

(See Section 2.9)

FORM A FORM R

IS REQUIRED FOR THIS CHEMICAL OR

CHEMICAL CATEGORY (FOR PBT

CHEMICALS, A FORM R IS REQUIRED)

O R FORM R IS REQUIRED FOR THIS

CHEMICAL OR CHEMICAL

CATEGORY (FORM A CANNOT BE

SUBMITTED)

STOP

NO EPCRA

SECTION 313 REPORTS

REQUIRED FOR ANY

CHEMICALS OR

CHEMICAL CATEGORIES

AN EPCRA SECTION 313 REPORT IS

 NOT REQUIRED FOR THIS CHEMICAL

OR CHEMICAL CATEGORY

2-3

Figure 2-1. EPCRA Section 313 Reporting Decision Diagram
2-4

If you answered “No” to any of the first three questions, you are not required to

prepare any EPCRA Section 313 reports. If you answered “Yes” to ALL of the first three

questions, you must complete a threshold calculation for each EPCRA Section 313 chemical and

chemical category at the facility, and submit an EPCRA Section 313 report for each chemical and

chemical category exceeding the applicable threshold.

2.2 SIC Code Determination

Facilities with the SIC Codes presented in Table 2-1 are covered by the EPCRA

Section 313 reporting requirements.

Table 2-1

SIC Codes Covered by EPCRA Section 313 Reporting

SIC Code Major Groups

SIC Codes Industry Qualifiers

10 Metal Mining Except SIC Codes 1011, 1081, and 1094

12 Coal Mining Except SIC Code 1241

20 through 39 Manufacturing None

4911, 4931, and 4939 Electric and Other Services and Limited to facilities that combust coal

Combination Utilities and/or oil for the purpose of generating

electricity for distribution in commerce

4953 Refuse Systems Limited to facilities regulated under

RCRA Subtitle C

5169 Chemicals and Allied Products None

5171 Petroleum Bulk Stations and Terminals None

7389 Business Services Limited to facilities primarily engaged in

solvent recovery services on a contract or

fee basis

Table 2-2 presents a listing of each four-digit SIC Code for textile manufacturing

facilities, with brief descriptions. You should determine the SIC Code(s) for your facility, based

on the activities on site. For assistance in determining which SIC Code best suits your facility

refer to Standard Industrial Classification Manual, 1987 published by the Office of Management

and Budget.
2-5

Table 2-2

SIC Codes for Textile Manufacturing Facilities

SIC Code Description

2211 Broadwoven Fabric Mills, Cotton

2221 Broadwoven Fabric Mills, Man-Made Fiber and Silk

2231 Broadwoven Fabric Mills, Wool (including Dyeing and Finishing)

2241 Narrow Fabric and Other Smallwares Mills: Cotton, Wool, Silk, and Man-Made

Fiber

2251 Women’s Full-Length and Knee-Length Hosiery, Except Socks

2252 Hosiery, Not Elsewhere Classified

2253 Knit Outerwear Mills

2254 Knit Underwear and Nightwear Mills

2257 Weft Knit Fabric Mills

2258 Lace and Warp Knit Fabric Mills

2259 Knitting Mills, Not Elsewhere Classified

2261 Finishers of Broadwoven Fabrics, Cotton

2262 Finishers of Broadwoven Fabrics, Man-Made Fiber and Silk

2269 Finishers of Textiles, Not Elsewhere Classified

2273 Carpet and Rug Mills

2281 Yarn Spinning Mills

2282 Yarn Texturizing, Throwing, Twisting, and Winding Mills

2284 Thread Mills

2295 Coated Fabrics, not Rubberized

2296 Tire Cord and Tire Fabric Mills

2297 Nonwoven Fabric Mills

2298 Rope, Cordage, and Twine Mills

2299 Textile Goods, Not Elsewhere Classified

Note that auxiliary facilities can assume the SIC Code of another covered

establishment if the primary function is to support the covered establishment’s operations. For

the purpose of EPCRA Section 313, auxiliary facilities are defined as those that are primarily

engaged in performing support services for another covered establishment, or multiple

establishments of a covered facility, and are in a different physical location from the primary

facility. In addition, auxiliary facilities perform an integral role in the primary facility’s

activities. In general, the auxiliary facility’s basic administrative services (e.g., paperwork,
2-6

payroll, employment) are performed by the primary facility. If an auxiliary facility’s primary

function is to support/service a facility with a covered SIC Code, the auxiliary facility assumes

the covered SIC Code as its primary SIC Code and must consider the other reporting

requirements (40 CFR Section 372.22) to determine if it must comply with the EPCRA Section

313 reporting requirements. However, if the SIC Code for the primary facility is not covered by

EPCRA Section 313, then neither the primary nor the auxiliary facility is required to submit a

report.

If your facility has more than one SIC Code (i.e., several establishments with

different SIC Codes are owned or operated by the same entity and are located at your facility),

you are subject to reporting requirements if:

& All the establishments have SIC Codes covered by EPCRA Section 313;

OR

& The total value of the products shipped or services provided at

establishments with covered SIC Codes is greater than 50% of the value of

the entire facility’s products and services; OR

& Any one of the establishments with a covered SIC Code ships and/or

produces products or provides services whose value exceeds the value of

services provided, products produced, and/or shipped by every other

establishment within the facility. 

Example - Primary SIC Code

A facility has two establishments. The first establishment performs dyeing and printing operations on textile

fabrics and is in SIC Code 2269, which is a covered SIC Code. The second establishment performs textile folding

and packaging services and is in SIC Code 7389. SIC Code 7389 is not an EPCRA Section 313 covered SIC

Code. The textile product is worth $20/unit as received by the establishment in the covered SIC Code. The

facility determines the dyed or printed fabric is worth $70/unit as received by the establishment in the noncovered SIC Code. The finished product value is estimated to be $80/unit. The value added by the establishment

in the covered SIC Code ($50/unit) is more than 50% of the product value; therefore, the primary SIC Code is

2269, a covered SIC Code. Thus, the establishment is covered by EPCRA Section 313 reporting and the entire

facility is subject to reporting.

A pilot plant within a covered SIC Code is considered a covered facility and is

subject to reporting, provided it meets the employee and activity criteria (note that pilot plants are

not eligible for the laboratory exemption, which is discussed in Chapter 3). Warehouses on the
2-7

same site as facilities in a covered SIC Code, and warehouses that qualify as auxiliary facilities of

covered facilities, are also subject to reporting, provided all applicable reporting requirements are

met.

While you are currently required to determine your facility’s reporting eligibility

based on the SIC code system described above, it is important to be aware that the SIC code

system will be replaced by a new system in the future. On April 9, 1997 (62 FR 17287), the

Office of Management and Budget promulgated the North American Industrial Classification

System (NAICS). NAICS is a new economic classification system that replaces the SIC code

system as a means of classifying economic activities for economic forecasting and statistical

purposes. The transition to the new NAICS may require regulatory actions. As a result, the SIC

code system is still required to be used as the mechanism to determine your facility’s reporting

eligibility. EPA will issue notice in the Federal Register to inform you and other EPCRA

Section 313 facilities of its plans to adopt the NAICS and how facilities should make their

NAICS code determination.

2.3 Number of Employees

If your facility meets SIC Code and activity threshold criteria, you are required to

prepare an EPCRA Section 313 report if your facility has 10 or more full-time employees or the

equivalent. A full-time employee equivalent is defined as a work year of 2,000 hours. If your

facility’s employees hours total 20,000 or more hours in a calendar year, you meet the 10 or more

employee threshold criterion.

The following information should be included in your employee calculations:

& Owners;

& Operations/manufacturing staff;

& Clerical staff;

& Temporary employees;

& Sales personnel;

& Truck drivers (employed by the facility);

& Other non-manufacturing or off-site facility employees directly supporting

the facility;
2-8

& Paid vacation and sick leave; and

& Contractor employees (maintenance, construction, etc. but excluding

contracted truck drivers and minor intermittent service vendors (e.g., trash

handlers)).

In general, if an individual is employed or hired to work at the facility, all the

hours worked by that individual for the facility (including paid leave and overtime) should be

counted in determining if the 20,000-hour criterion has been met.

Example - Employee Equivalent Calculation

Your facility has six full-time employees working 2,000 hours/year. You also employ two full-time sales people

and a delivery truck driver (employed by the facility) who are assigned to the plant, each working 2,000

hours/year but predominantly on the road or from their homes. The wastewater treatment system (on site and

owned by the facility) is operated by a contractor who spends an average of two hours per day and five days per

week at the plant. Finally, you built an addition to the plant warehouse during the year, using four contractor

personnel who were on site full time for six months (working on average of 1,000 hours each). You would

calculate the number of full-time employee equivalents as follows:

& Hours for your nine full-time employees (six plant personnel, two salespeople, and one

delivery truck driver) are:

(9 employees) × (2,000 hours/year) = 18,000 hours/year;

& Hours for the wastewater treatment system operator are:

(2 hours/day) × (5 days/week) × (52 weeks/year) = 520 hours/year; and 

& Hours for the construction crew are:

(4 contractors) × (1,000 hours) = 4,000 hours/year. 

Your facility has a total of 22,520 hours for the year, which is above the 20,000 hours/year threshold; therefore,

you meet the employee criterion.

2.4 Manufacturing, Processing, and Otherwise Use of EPCRA Section 313

Chemicals or Chemical Categories

If you are in a covered SIC Code and have 10 or more full-time employee

equivalents, you must determine which EPCRA Section 313 chemicals and chemical categories

are manufactured, processed, or otherwise used at your facility. You should prepare a list which

includes all chemicals and chemical categories found in mixtures and trade name products at all

establishments at the facility. This list should then be compared to the CURRENT list of

EPCRA Section 313 chemicals and chemical categories found in the TRI Forms and Instructions

document for that reporting year (also available from the EPCRA Hotline, 1-800-424-9346). 
2-9

Once you identify the EPCRA Section 313 chemicals and chemical categories at your facility,

you must evaluate the activities involving each chemical and chemical category and determine if

any activity thresholds have been met.

The original list of chemicals and chemical categories subject to EPCRA Section

313 reporting was a combination of chemical lists from New Jersey and Maryland. Refinements

to the list have been made and changes are anticipated to continue. The list can be modified by

U.S. EPA initiatives or industry or the public can petition U.S. EPA to modify the list. When

evaluating a chemical or chemical category for addition or deletion from the list, U.S. EPA must

consider the chemical’s potential acute human health effects and chronic human health effects, or

its adverse environmental effects. U.S. EPA reviews these petitions and initiates a rulemaking to

add or delete the chemical or chemical category from the list, or publishes an explanation why it

denied the petition.

Note that chemicals and chemical categories are periodically added, delisted, or

modified. Therefore, it is imperative that you refer to the appropriate reporting year’s list. You

can refer to the U.S. EPA’s TRI website, http://www.epa.gov/tri, for updated guidance. Also,

note that a list of synonyms for EPCRA Section 313 chemicals and chemical categories can be

found in the U.S. EPA publication Common Synonyms for Chemicals Listed Under Section 313

of the Emergency Planning and Community Right-To-Know Act, (EPA 745-R-95-008). Table 2-

3 lists the EPCRA Section 313 chemicals and chemical categories most frequently reported for

textile manufacturing. This list is not intended to be all inclusive and should only be used as a

guide.
These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT 1

chemicals.

2-10

Table 2-3 

EPCRA Section 313 Chemicals and Chemical Categories Commonly

Encountered in Textile Manufacturing

(SIC Major Group 22)

Process Chemicals and Chemical Categories

Dyeing/Printing Ethylene glycol, certain glycol ethers, methanol, copper compounds, chromium

compounds

Desizing Certain glycol ethers

Sizing Methanol

Scouring Biphenyl, xylene, certain glycol ethers

Chemical Finishing Certain glycol ethers, methyl ethyl ketone, formaldehyde

Coating Operations Dichloromethane, methanol, methyl ethyl ketone, toluene

Article/Formulation Chromium compounds, copper compounds, methanol, antimony compounds

Components

Manufacturing/Processing Ethylene glycol, methanol, phenol, toluene, xylene, biphenyl

Aids

Reactants Diisocyanates, formaldehyde, methanol, phenol

2.5 Activity Categories

EPCRA Section 313 defines three activity categories for the listed chemicals and

chemical categories: manufacturing (which includes importing), processing, and otherwise use. 

The activity thresholds are 25,000 pounds per year for manufacturing, 25,000 pounds per year for

processing, and 10,000 pounds per year for otherwise use . These thresholds apply to each 1

chemical or chemical category individually. The quantity of chemicals or chemical categories

stored on site or purchased is not relevant for threshold determinations. Rather, the

determination is based solely on the annual quantity actually manufactured (including imported),

processed, or otherwise used. Therefore, EPCRA Section 313 chemicals and chemical categories

that are brought on site and stored, but are not prepared in the reporting year for distribution in

that year or subsequent years or are not otherwise used on site during the reporting year, are not

considered towards any activity threshold.
These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT 1

chemicals. 2-11

Expanded definitions with examples of each of the three activities are found in

Chapter 3, Tables 3-2, 3-3, and 3-4. The terms are briefly defined in Table 2-4.

Table 2-4

Activity Categories

Activity Threshold

Category Definition (lb/yr)

1

Manufacture To produce, prepare, import, or compound an EPCRA Section 313 chemical or 25,000

chemical category. Manufacture also applies to an EPCRA Section 313 chemical

or chemical category that is produced coincidentally during the manufacture,

processing, otherwise use, or disposal of another chemical or mixture of chemicals

as a byproduct, and an EPCRA Section 313 chemical or chemical category that

remains in that other chemical or mixture of chemicals as an impurity during the

manufacturing, processing, or otherwise use or disposal of any other chemical

substance or mixture.

Process To prepare an EPCRA Section 313 chemical or chemical category, or a mixture or 25,000

trade name product containing an EPCRA Section 313 chemical or chemical

category, for distribution in commerce. For example, the addition of an EPCRA

Section 313 chemical as a flame retardant for fabric should be reported if you

exceeded the reporting threshold. Processing includes the preparation for sale to

your customers (and transferring between facilities within your company) of a

chemical or formulation that you manufacture. For example, if you manufacture

an EPCRA Section 313 chemical or chemical category or product, package it, and

then distribute it into commerce, this chemical has been manufactured AND

processed by your facility.
Table 2-4 (Continued)

Activity Threshold

Category Definition (lb/yr)

1

2-12

Otherwise Generally, use of an EPCRA Section 313 chemical or chemical category that does 10,000

Use not fall under the manufacture or process definitions is classified as otherwise use. 

An EPCRA Section 313 chemical or chemical category that is otherwise used does

not function by being incorporated into a product that is distributed in commerce,

but may be used instead as a manufacturing or processing aid (e.g., catalyst), in

waste processing, or as a fuel (including waste fuel). 

On May 1, 1997 U.S. EPA revised the interpretation of otherwise use. The

following new otherwise use definition became effective with the 1998 reporting

year (62 FR 23834, May 1, 1997):

Otherwise use means “any use of a toxic 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 a toxic chemical does not

include disposal, stabilization (without subsequent distribution in

commerce), or treatment for destruction unless:

1) The toxic chemical that was disposed, stabilized, or treated for

destruction was received from off site for the purposes of further waste

management; OR

2) The toxic 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.” 

These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT 1

chemicals.

COMMON ERROR - Coincidental Manufacture

The coincidental manufacture of an EPCRA Section 313 chemical or chemical category, outside the primary

product process line but in direct support of the process, is frequently overlooked. For example, the coincidental

manufacture of nitrate compounds from on-site wastewater treatment of nitric acid is commonly overlooked. In

many processes, nitric acid is typically discharged, collected, and sent to an on-site treatment plant, where it is

neutralized and discharged to a POTW. Nitrate compounds are coincidentally manufactured during the

neutralization of nitric acid and are subject to the 25,000 pounds per year reporting threshold. If the threshold is

exceeded, corresponding releases should be reported as a “Discharge to POTW” in Section 6.1 and included in

Section 8.7 (“Quantity Treated Off Site”) of the Form R, and not reported under Section 6.2 “Transfers to Other

Off-Site Locations.” The quantity of nitrate compounds coincidentally manufactured can be estimated as

discussed in detail in EPA’s guidance document, Toxics Release Inventory, List of Chemicals Within the Water

Dissociable Nitrate Compounds Category and Guidance for Reporting (Revised May 1996, EPA 745-E-96-004).

Another coincidental manufacture example would be the production of metal oxides (metal compounds) during

fuel combustion (e.g., burning of coal and/or oil to generate power).
2-13

Relabeling or redistribution of an EPCRA Section 313 chemical or chemical

category where no repackaging occurs does not constitute manufacturing, processing, or

otherwise use of that chemical. This type of activity should not be included in threshold

determinations.

Also, note that the threshold determinations for the three activity categories

(manufacturing, processing, and otherwise use) are mutually exclusive. That is, you must

conduct a separate threshold determination for each activity category and if you exceed any

threshold, all release and other waste management activities of that EPCRA Section 313

chemical or chemical category at the facility must be considered for reporting. 

2.6 Persistent, Bioaccumulative, and Toxic (PBT) Chemicals

U.S. EPA promulgated the final rule for Persistent, Bioaccumulative, and Toxic

(PBT) chemicals in the October 29, 1999 Federal Register (64 FR 209). This rule applies for the

reporting year beginning January 1, 2000 (for EPCRA Section 313 reports that must be filed by

July 1, 2001).

In this rule, U.S. EPA has added seven chemicals and lowered the reporting

thresholds for 18 chemicals and chemical categories that meet the EPCRA Section 313 criteria

for persistence and bioaccumulation. The PBT chemicals and their thresholds are listed in Table

2-5.
2-14

Table 2-5

Reporting Thresholds for EPCRA Section 313 Listed PBT Chemicals

Chemical Name or Chemical Category CASRN pounds unless noted other-wise)

Section 313 Reporting Threshold (in

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 NA 0.1 grams

(manufacturing; and the processing or otherwise

use of dioxin and dioxin-like compounds if the

dioxin and dioxin-like compounds are present as

contaminants in a chemical and if they were

created during the manufacturing of that chemical)

Heptachlor 76-44-8 10

Hexachlorobenzene 118-74-1 10

Isodrin 465-73-6 10

Methoxychlor 72-43-5 100

Octachlorostyrene 29082-74-4 10

Pendimethalin 40487-42-1 100

Pentachlorobenzene 608-93-5 10

Polycyclic aromatic compounds category NA 100

Polychlorinated biphenyl (PCBs) 1336-36-3 10

Tetrabromobisphenol A 79-94-7 100

Toxaphene 8001-35-2 10

Trifluralin 1582-09-8 100

Mercury 7439-97-6 10

Mercury compounds NA 10

U.S. EPA also added two chemicals to the polycyclic aromatic compounds

(PACs) category that is listed above:

& Benzo(j,k)fluorene (fluoranthene)

& 3-methylchloanthrene

These two chemicals are not to be reported individually; rather, they should be included within

the PACs compound category.
2-15

U.S. EPA finalized two thresholds based on the chemicals’ potential to persist and

bioaccumulate in the environment. The two levels include setting Section 313 manufacture,

process, and otherwise use thresholds to 100 pounds for PBT chemicals and to 10 pounds for that

subset of PBT chemicals that are highly persistent and highly bioaccumulative. One exception is

the dioxin and dioxin-like compounds category. EPA set the threshold for the dioxin and dioxinlike compound category at 0.1 gram.

U.S. EPA eliminated the de minimis exemption for the PBT chemicals. However,

this action does not affect the applicability of the de minimis exemption to the supplier

notification requirements (40 CFR 372.45(d)(1)). U.S. EPA also excluded all PBT chemicals

from eligibility for the alternate threshold of 1 million pounds (see Section 2.9) and eliminated

range reporting of PBT chemicals and chemical categories for on-site releases and transfers offsite for further waste management.

Concurrent with the additions and lowered thresholds discussed above, U.S. EPA

added “vanadium, except when contained in an alloy” and “vanadium compounds” to the list of

toxic chemicals subject to reporting under EPCRA Section 313. The corresponding thresholds

for vanadium and vanadium compounds remain 10,000 pounds if otherwise used, 25,000 pounds

if processed, and 25,000 pounds if manufactured. Please refer to the discussion on “Qualifiers”

in Section 3.1 if vanadium is a concern at your facility.

Note that U.S. EPA is currently developing five guidance documents for

chemicals modified by the PBT rule:

& Dioxins and dioxin-like compounds;

& Mercury and mercury compounds;

& Vanadium and vanadium compounds;

& Polycyclic aromatic compounds (PACs) category; and

& Other PBT chemicals.

Please refer to this guidance if applicable to your facility.
2-16

2.7 How Do You Report?

You must submit an EPCRA Section 313 report for each EPCRA Section 313

chemical or chemical category that exceeds a threshold for manufacturing, OR processing, OR

otherwise use (providing you meet the employee and SIC Code criteria). Provided you do not

exceed certain alternate activity thresholds and total annual reportable amounts, you may prepare

a Form A (See Section 2.8) rather than a Form R. The TRI Forms and Instructions contain

detailed directions for the preparation and submittal of EPCRA Section 313 reports for each

listed chemical for the reporting year. The TRI Forms and Instructions are sent to all facilities

that submitted EPCRA Section 313 reports the preceding year. However, if you do not receive a

courtesy copy, you may request copies of the TRI Forms and Instructions from the EPCRA

Hotline (1-800-424-9346). 

2.8 Form R

Form R is the report in which the information required by EPCRA Section 313 is

reported. If you are submitting a Form R, it is essential that you use the TRI Forms and

Instructions for the appropriate reporting year. U.S. EPA encourages the electronic submittal of

the Form R, via the Automated Toxic Chemical Release Inventory Reporting Software (ATRS). 

Use of the ATRS will save preparation time in data entry and photocopying and reduce errors via

on-line validation routines and use of pick lists. The ATRS can be found on the Internet at:

& http://www.epa.gov/atrs

The ATRS is available in both DOS and Windows versions. More information can be found in

the TRI Forms and Instructions and by calling the ATRS User Support Hotline at (703) 816-

4434. 
2-17

The Form R consists of two parts:

Part I, Facility Identification Information. This part may be photocopied and reused for each Form R you submit, except for the signature, which must be original

for each submission.

Part II, Chemical Specific Information. You must complete this part separately

for each EPCRA Section 313 chemical or chemical category; it cannot be reused

year to year even if reporting has not changed. 

Submission of incomplete EPCRA Section 313 reports may result in issuance of a

Notice of Technical Error (NOTE), Notice of Significant Error (NOSE), or Notice of Noncompliance (NON). See the current TRI Forms and Instructions for more detailed information

on completing the Form R and submitting the EPCRA Section 313 report.

2.9 Alternate Threshold and Form A

U.S. EPA developed the Form A, also referred to as the “Certification Statement” 

to reduce the annual reporting burden for facilities with minimal amounts of EPCRA

Section 313 chemicals and chemical categories released and otherwise managed as waste (59 FR

61488, November 1994; applicable beginning reporting year 1994 and beyond). On Form A you

certify that you are not required to report the release and other waste management information

required by EPCRA Section 313 and PPA Section 6607. A facility must meet the following two

criteria to use a Form A:

& First, the total annual reportable amount of the EPCRA Section 313

chemical or chemical category cannot exceed 500 pounds per year. The

“reportable amount” is defined as the sum of the on-site amounts released

(including disposal), treated, recycled, and combusted for energy recovery,

combined with the sum of the amounts transferred off site for recycling,

energy recovery, treatment, and/or release (including disposal). This total

corresponds to the total of data elements 8.1 through 8.7 on the 1999

version of the Form R. 
2-18

& Second, the amount of the EPCRA Section 313 chemical or chemical

category manufactured, processed, OR otherwise used cannot exceed one

million pounds. It is important to note that the quantities for each activity

are mutually exclusive and must be evaluated independently. If the

quantity for any one of the activities exceeds 1,000,000 pounds a Form A

cannot be used.

Example - Form A Threshold

If the combined annual reportable amounts from all activities do not exceed 500 pounds, a facility that

manufactures 900,000 pounds of an EPCRA Section 313 chemical and processes 150,000 pounds of the same 

chemical is eligible to use the Form A because the facility did not exceed the one million pounds threshold for

either activity, even though the total activity usage exceeds one million pounds.

The Form A Certification Statement must be submitted for each eligible EPCRA

Section 313 chemical and chemical category. The information on the Form A will be included in

the publicly accessible TRI database; however, these data are marked to indicate that they

represent certification statements rather than Form Rs. Note that separate establishments at a

facility cannot submit separate Form As for the same chemical or chemical category; rather, only

one Form A per EPCRA Section 313 chemical or chemical category can be submitted per

facility.

 While Form A requests facility identification and chemical identification

information, no release and other waste management quantity estimations to any media are

required. You must simply certify that the total annual reportable amount did not exceed 500

pounds, and the amounts manufactured, processed, or otherwise used did not exceed one million

pounds. Once the facility has completed estimates to justify the submission of a Form A, there is

a considerable time savings in using the Form A, especially in subsequent years, providing

activities involving the chemical or chemical category did not change significantly. It is strongly

recommended that you document your initial rationale and refer to it every year to verify that you

have not modified a part of the process that would invalidate the initial rationale supporting use

of the Form A. 
2-19

Common Error - Form A Reporting

Many facilities in this industry may be eligible to submit the Alternate Certification Statement (Form A). Listed

below are some key points to remember when deciding if you should submit a Form A or Form R for an EPCRA

Section 313 chemical or chemical category:

1. The 500 lb/yr annual reportable amount criteria refers to a single EPCRA Section 313 chemical (or chemical

category) and is the sum of the on-site amounts released (including disposal), treated, recycled and

combusted for energy recovery combined with amounts transferred off-site for further waste management

activities. This total is the sum of the data elements 8.1 through 8.7 of the 1999 Form R for a single

chemical (or chemical category). 

2. The 1,000,000 lb/yr alternate threshold refers to the amount of a single EPCRA Section 313 chemical (or

chemical category) manufactured, OR the amount of a single EPCRA Section 313 chemical (or chemical

category) processed, OR the amount of a single EPCRA Section 313 chemical (or chemical category)

otherwise used. The quantities are mutually exclusive and must be evaluated independently. If the quantity

for any one of these activities exceeds 1,000,000 pounds, a Form A cannot be used.

Example: Your site otherwise uses a total of 750,000 lb/yr of chromium compounds, and

processes an additional 300,000 lb/yr of chromium compounds. Chromium compound disposal

(based on the parent metal chromium) totals 250 lb/yr to an off-site landfill, and 100 lb/yr

discharged to a POTW. No recycling or treatment of chromium compounds occur. Your site

did not exceed the 1,000,000-pound alternate threshold for processing, nor did your site exceed

the alternate threshold for otherwise use. The total annual reportable amount of 350 lb/yr falls

below 500 lb/yr. Therefore, you may complete a Form A for chromium compounds, rather than

a Form R.

When determining if you are eligible to complete a Form A, rather than a Form R, remember that each EPCRA

Section 313 chemical or chemical category should be reviewed individually. For example, you may need to

complete a Form R for Chemicals A, B, and C, however a Form A may be completed for Chemical D (assuming

the eligibility requirements are met). 

Example: Your site otherwise uses 300,000 lb/yr of methanol and 200,000 lb/yr copper

compounds. The total annual reportable amount for methanol is 10,000 lb/yr, and the total

annual reportable amount for copper compounds is 200 lb/yr. You must complete a Form R for

methanol, however you are eligible to complete a Form A for copper compounds.

If your facility consists of multiple establishments, only a single Form A can be submitted for the entire facility

(separate establishments at a facility cannot submit separate Form As for the same chemical or chemical category;

one Form A can be submitted for multiple chemicals or chemical categories). 

Example: Your site has three establishments and all otherwise use methanol. The first

establishment otherwise uses 500,000 lb/yr of methanol. The second and third establishments

each otherwise use 300,000 lb/yr of methanol. The total amount of methanol otherwise used at

the facility equals 1,100,000 lb/yr (500,000 + 300,000 + 300,000). You may not submit a Form

A for methanol. You may either submit one Form R for the entire facility, or you may submit

three Form Rs (one for each establishment) for methanol.

2.10 Trade Secrets

If you submit trade secret information, you must prepare two versions of the

substantiation form as prescribed in 40 CFR Part 350 (see 53 FR 28801, July 29, 1988) as well as
2-20

two versions of the EPCRA Section 313 report. One set of reports should be “sanitized” (i.e., it

should provide a generic name for the EPCRA Section 313 chemical or chemical category

identity). This version will be made available to the public. The second version, the

“unsanitized” version, should provide the actual identity of the EPCRA Section 313 chemical

and have the trade secret claim clearly marked in Part I, Section 2.1 of the Form R or Form A. 

The trade secrets provision only applies to the EPCRA Section 313 chemical or chemical

category identity. All other parts of the Form R or Form A must be filled out accordingly.

Individual states may have additional criteria for confidential business information

and the submittal of both sanitized and unsanitized reports for EPCRA Section 313 chemicals

and chemical categories. Facilities may jeopardize the trade secret status of an EPCRA Section

313 chemical or chemical category by submitting an unsanitized version to a state agency or

tribal government that does not require an unsanitized version.

More information on trade secret claims, including contacts for individual state’s

submission requirements, can be found in the TRI Forms and Instructions.

2.11 Recordkeeping

Complete and accurate records are absolutely essential to meaningful compliance

with EPCRA Section 313 reporting requirements. Compiling and maintaining good records will

help you to reduce the effort and cost in preparing future reports, and to document how you

arrived at the reported data in the event of U.S. EPA compliance audits. U.S. EPA requires you

to maintain records substantiating each EPCRA Section 313 report submission for a minimum of

three years. Each facility must keep copies of every EPCRA Section 313 report along with all

supporting documents, calculations, work sheets, and other forms that you used to prepare the

EPCRA Section 313 report. U.S. EPA may request this supporting documentation during a

regulatory audit.

Specifically, U.S. EPA requires the following records be maintained for a period

of three years from the date of the submission of a report (summarized from 40 CFR 372.10):
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1) A copy of each EPCRA Section 313 report that is submitted.

2) All supporting materials and documentation used to make the compliance

determination that the facility or establishment is a covered facility.

3) Documentation supporting the report submitted, including:

& Claimed allowable exemptions,

& Threshold determinations,

& Calculations for each quantity reported as being released, either on

or off site, or otherwise managed as waste,

& Activity determinations, including dates of manufacturing,

processing, or use,

& The basis of all estimates,

& Receipts or manifests associated with transfers of each EPCRA

Section 313 chemical or chemical category in waste to off-site

locations, and

& Waste treatment methods, treatment efficiencies, ranges of influent

concentrations to treatment, sequential nature of treatment steps,

and operating data to support efficiency claims.

4) For facilities submitting a Form A, all supporting materials used to make

the compliance determination that the facility or establishment is eligible

to submit a Form A, including:

& Data supporting the determination the alternate threshold applies,

& Calculations of the annual reportable amounts, 

& Receipts or manifests associated with the transfer of each EPCRA

Section 313 chemical or chemical category in waste to off-site

locations, and

& Waste treatment methods, treatment efficiencies, ranges of influent

concentrations to treatment, sequential nature of treatment steps,

and operating data to support efficiency claims.

Because EPCRA Section 313 reporting does not require additional testing or

monitoring you must determine the best readily available source of information for all estimates. 

Some facilities may have detailed monitoring data and off-site transfer records that can be used

for estimates while others may only have purchase and inventory records. Examples of records

that you should keep, if applicable, might include:

& Each EPCRA Section 313 report submitted;
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& EPCRA Section 313 Reporting Threshold Worksheets (sample worksheets

can be found in Chapter 3 of this document as well as in the TRI Forms

and Instructions);

& EPCRA Section 313 Reporting Release and Other Waste Management

Quantity Estimation Worksheets (sample worksheets can be found in

Chapter 4 of this document);

& Engineering calculations and other notes;

& Formulation sheets;

& Purchase records from suppliers;

& Inventory data;

& Material Safety Data Sheets (MSDSs);

& New Source Performance Standards (NSPS);

& National Pollutant Discharge Elimination System (NPDES)/State Pollutant

Discharge Elimination System (SPDES) permits and monitoring reports;

& EPCRA Section 312, Tier II reports;

& Monitoring records;

& Air permits;

& Flow measurement data;

& Resource Conservation Recovery Act (RCRA) hazardous waste

generator’s reports;

& Pretreatment reports filed with local governments;

& Invoices from waste management firms;

& Manufacturer’s estimates of treatment efficiencies;

& Comprehensive Environmental Response, Conservation, and Liability Act

of 1980 (CERCLA) Reportable Quantity (RQ) reports;

& RCRA manifests; and

& Process flow diagrams (including emissions, releases, and other waste

management activities).
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CHAPTER 3 - EPCRA SECTION 313 CHEMICAL OR

CHEMICAL CATEGORY ACTIVITY THRESHOLD DETERMINATIONS

3.0 PURPOSE

This chapter provides a step-by-step procedure for determining if any EPCRA

Section 313 chemicals or chemical categories exceed a reporting threshold. Threshold

determinations are essentially a three step process: 

Step 1) Identify any EPCRA Section 313 chemicals or chemical categories

you manufacture/import, process, or otherwise use.

Step 2) Identify the activity category and any exempt activities for each

EPCRA Section 313 chemical and chemical category.

Step 3) Calculate the quantity of each EPCRA Section 313 chemical and

chemical category and determine which ones exceed an activity

threshold.

3.1 Step 1 - Identify Which EPCRA Section 313 Chemicals or Chemical

Categories are Manufactured (Including Imported), Processed, or Otherwise

Used

Compile lists of all chemicals and mixtures at your facility. For facilities with

many different chemicals and mixtures it is often helpful to prepare two lists: one with the pure

(single ingredient) chemicals (including chemical compounds) and one with the mixtures and

trade name products. On the second list, under the name of each mixture/trade name product,

write the names of all chemicals in that product. Next, compare the chemicals and chemical

categories on both lists to the current EPCRA Section 313 chemicals and chemical categories list

found in the TRI Forms and Instructions (remember that chemicals and chemical categories may

be periodically added and deleted and you should use the current reporting year’s instructions). 

Highlight the EPCRA Section 313 chemicals and chemical categories that are on your lists.

Review the lists to be sure each chemical and chemical category is shown by its

correct EPCRA Section 313 name. For example, a common EPCRA Section 313 chemical

found in textile manufacturing operations is methanol. Methanol (Chemical Abstracts Service
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(CAS) Registry No. 67-56-1) has several synonyms including carbinol, methyl alcohol, methyl

hydroxide, and wood alcohol. It must be reported on Form R (or Form A), Item 1.2, by its

EPCRA Section 313 chemical name, methanol. Synonyms can be found in the U.S. EPA

document Common Synonyms for Chemicals Listed Under Section 313 of the Emergency

Planning and Community Right-to-Know Act (EPA 745-R-95-008).

While you must consider every chemical on the EPCRA Section 313 chemical

and chemical category list, you should be aware of the chemicals and chemical categories

typically used in textile manufacturing. As a guide, the most frequently reported EPCRA Section

313 chemicals and chemical categories for reporting year 1995 by textile manufacturing

facilities, SIC Major Group 22, and the processes they are typically used in, are listed in Table

2-3.

A computerized spreadsheet may be helpful in developing your facility’s chemical

and chemical category list and performing threshold calculations. The spreadsheet could show

the chemical, chemical category, or chemical mixture with corresponding component

concentrations; the yearly quantity manufactured, processed, or otherwise used; and the CAS

Registry number. The spreadsheet could also be designed to identify the total quantity by activity

category (amounts manufactured, processed, and otherwise used) for each EPCRA Section 313

chemical or chemical category in every mixture, compound, and trade name product.

An initial investment of time will be required to develop this spreadsheet;

however, the time and effort saved in threshold calculations in subsequent years will be

significant. Such a system will also reduce the potential of inadvertently overlooking EPCRA

Section 313 chemicals or chemical categories present in mixtures purchased from off-site

sources.

To develop the chemical and chemical category list and the associated activity

categories you may want to consult the following:

& Material Safety Data Sheets (MSDSs);

& Facility purchasing records;
3-3

& New Source Performance Standards (NSPS);

& Inventory records;

& Air and water discharge permits;

& Individual manufacturing/operating functions; and

& Receipts or manifests associated with the transfer of each EPCRA Section

313 chemical and chemical categories in waste to off-site locations.

The following is suggested useful information needed to prepare your EPCRA

Section 313 reports and should be included for each chemical and chemical category on your

spreadsheet: 

& The mixture name and associated EPCRA Section 313 chemical and

chemical category names;

& The associated Chemical Abstract Service (CAS) Registry numbers;

& The trade name for mixtures and compounds; 

& The throughput quantities; and

& Whether the chemical or chemical category is manufactured, processed, or

otherwise used at the facility (be sure to include quantities that are

coincidentally manufactured and imported, as appropriate). 

MSDSs provide important information for the type and composition of chemicals

and chemical categories in mixtures, and for determining whether you have purchased raw

materials that contain EPCRA Section 313 chemicals and chemical categories. As of 1989,

chemical suppliers to facilities in SIC Major Group Codes 20 through 39 are required to notify

manufacturing customers of any EPCRA Section 313 chemicals and chemical categories present

above the applicable de minimis concentration in mixtures or trade name products distributed to

facilities. The notice must be provided to the receiving facility and may be attached or

incorporated into that product’s MSDS. If no MSDS is required, the notification must be in a

letter that accompanies the first shipment of the product to your facility each year. This letter

must contain the chemical name, CAS Registry number, and the weight or volume percent (or a

range) of the EPCRA Section 313 chemical or chemical category in mixtures or trade name

products.

Carefully review the entire MSDS. Although new MSDSs must list whether

EPCRA Section 313 chemicals and chemical categories are present, the language and location of

this notification is not currently standardized. Depending on the supplier, this information could
3-4

be found in different sections of the MSDS. The most likely sections of an MSDS to provide

information on EPCRA Section 313 chemicals and chemical categories are:

& Physical properties/chemical composition section;

& Regulatory section;

& Hazardous components section;

& Labeling section; and

& Additional information section.

Also, many EPCRA Section 313 chemicals and chemical categories are present as

impurities in mixtures. These quantities must also be considered in threshold determinations

unless the concentration is below the de minimis value (see Section 3.2.2.1).

COMMON ERROR - Mixture Components

Facilities often overlook EPCRA Section 313 chemicals and chemical categories that are present in small

quantities of bulk solutions. For example, xylene is often purchased in large quantities for use as a solvent,

among other things. Most facilities correctly report for xylene; however, ethylbenzene is typically present at up to

15% in commercially available solutions of xylene. Many facilities have historically overlooked the ethylbenzene

in their bulk xylene purchases.

Several chemicals on the EPCRA Section 313 chemical list include qualifiers

related to use or form. Some chemicals are reportable ONLY if manufactured by a specified

process or classified in a specified activity category. For example, isopropyl alcohol is only

reportable if it is manufactured using the strong acid process and saccharin is reportable only if it

is manufactured. Some other chemicals are only reportable if present in certain forms. For

example, only yellow or white phosphorus is reportable, while black or red phosphorus is not

reportable.

The qualifiers and associated chemicals and chemical categories are presented

below. A detailed discussion of the qualifier criteria can be found in the TRI Forms and

Instructions. Please make special note of the discussion pertaining to vanadium and vanadium

compounds.

& Aluminum oxide (fibrous) - Aluminum oxide is only subject to threshold

determination and release and other waste management calculations when
3-5

it is handled in fibrous forms. U.S. EPA has characterized fibrous

aluminum oxide for purposes of EPCRA Section 313 reporting as a manmade fiber commonly used in high-temperature insulation applications

such as furnace linings, filtration, gaskets, joints, and seals.

& Ammonia - (includes anhydrous ammonia and aqueous ammonia from

water dissociable ammonium salts and other sources) On June 26, 1995,

U.S. EPA qualified the listing for ammonia (CAS Registry No. 7664-41-7)

and deleted ammonium sulfate (solution) (CAS Registry No. 7783-20-2)

from the EPCRA Section 313 chemical list. Both the qualification and the

deletion were effective as of reporting year 1994. The qualifier for

ammonia means that anhydrous forms of ammonia are 100% reportable

while only 10% of the total aqueous ammonia is reportable. Any

evaporation of ammonia from aqueous ammonia solutions is considered

anhydrous ammonia. This qualifier applies to both activity threshold

determinations and release and other waste management calculations. 

Note that while ammonium sulfate is no longer an EPCRA Section 313

chemical, 10% of the aqueous ammonia formed from the dissociation of

ammonium sulfate (and all other ammonium salts) is reportable, and must

be included in both activity threshold determinations and release and other

waste management calculations. Additionally, any ammonium nitrate

must also be included in the threshold determination and the nitrate

portion included in the release and other waste management calculations,

for the nitrate compounds category. U.S. EPA has published guidance on

reporting for ammonia and ammonium salts in Emergency Planning and

Community Right-to-Know, EPCRA Section 313, Guidance for Reporting

Aqueous Ammonia, EPA 745-R-95-012 (included as Appendix C).

& Asbestos (friable) - Asbestos only needs to be considered when it is

handled in the friable form. Friable refers to the physical characteristics of

being able to crumble, pulverize, or reduce to a powder with hand

pressure.

& Fume or dust - Two metals (aluminum and zinc) are qualified with “fume

or dust.” This definition excludes “wet” forms such as solutions or

slurries, but includes powder, particulate, or gaseous forms of these

metals. There is no particle size limitation for particulates. For example,

use of zinc metal as part of a final textile product is not subject to

reporting unless the zinc is in the form of a fume or dust. However, even

though elemental zinc is reportable only in the fume or dust form, all

forms of zinc compounds are reportable. Note that the entire weight of all

zinc compounds should be included in the threshold determination for zinc

compounds, while only the metal portion of metal compounds is reported

in the release and other waste management amounts. Prior to reporting

year 2000, vanadium was also qualified with “fume or dust.” As of

reporting year 2000 this qualifier has been removed for vanadium such

that all physical forms are now reportable unless the vanadium is
3-6

contained in an alloy. Please see the discussion on vanadium and

vanadium compounds below, if applicable.

& Hydrochloric acid (acid aerosols) - On July 25, 1996, U.S. EPA

promulgated a final rule delisting non-aerosol forms of hydrochloric acid

(CAS Registry No. 7647-01-0) from the EPCRA Section 313 chemical list

(effective for the 1995 reporting year). Therefore, threshold

determinations and release and other waste management estimates now

apply only to the aerosol forms. Under EPCRA Section 313, the term

aerosol covers any generation of airborne acid (including mists, vapors,

gas, or fog) without any particle size limitation. Therefore, any process

that sprays hydrochloric acid “manufactures” hydrochloric acid aerosol

and you should include this quantity in the manufacturing threshold

determination.

& Manufacturing qualifiers - Two chemicals, saccharin and isopropyl

alcohol, contain qualifiers relating to manufacture. The qualifier for

saccharin means that only manufacturers of the chemical are subject to the

reporting requirement. The qualifier for isopropyl alcohol means that only

facilities that manufacture the chemical by the strong acid process are

required to report. Facilities that only process or otherwise use these

chemicals are not required to report. Thus, a facility that uses isopropyl

alcohol as a solvent should not report for isopropyl alcohol.

& Nitrate Compounds (water dissociable; reportable only in aqueous

solution) - A nitrate compound is covered by this listing only when in

water and if water dissociable. 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 must be

considered for release and other waste management calculations. One

issue recently raised by industry is how to report nitrate compounds in

wastewater and sludge that is applied to farms as a nitrogen source (either

on site or off site). Although during such use nitrate compounds may be

taken up by plants and cycled back into the ecosystem, U.S. EPA

considers that the nitrate compounds in wastewaters/sludges to be

managed as waste. In this scenario, nitrate compounds should be reported

as being disposed to land (either on site or off site as appropriate). U.S.

EPA has published guidance for these chemicals in List of Toxic

Chemicals Within the Water Dissociable Nitrate Compounds Category

and Guidance for Reporting (EPA 745-R-96-004). 

& Phosphorus (yellow or white) - Only manufacturing, processing, or

otherwise use of phosphorus in the yellow or white chemical forms require

reporting. Black and red phosphorus are not subject to EPCRA

Section 313 reporting.
3-7

& Sulfuric acid (acid aerosols) - On June 26, 1995, U.S. EPA promulgated

a final rule delisting non-aerosol forms of sulfuric acid (CAS Registry No.

7664-93-9) from the EPCRA Section 313 chemical list (effective for the

1994 reporting year). Therefore, threshold determinations and release and

other waste management estimates now apply only to the aerosol forms. 

Under EPCRA Section 313, the term aerosol covers any generation of

airborne acid (including mists, vapors, gas, or fog) without any particle

size limitation. Therefore, any process that sprays sulfuric acid

“manufactures” sulfuric acid aerosol and you should include this quantity

in the manufacturing threshold determination. U.S. EPA has published

guidance for acid aerosols in Guidance for Reporting Sulfuric Acid, EPA

745-R-97-007.

& Vanadium and vanadium compounds - Note that prior to reporting year

2000 (effective December 31, 1999 for EPCRA Section 313 reports that

must be filed by July 1, 2001), the fume or dust qualifier also applied to

vanadium. As of December 31, 1999, U.S. EPA removed this qualifier for

vanadium for reporting year 2000 and beyond. Concurrently, U.S. EPA

exempted all physical forms of metallic vanadium that are present in

alloys. Therefore, vanadium that is present in any physical form of alloys

should not be considered for EPCRA Section 313 reporting. However, if

vanadium is separated from the alloy, all physical forms of the vanadium

are considered to be manufactured and the quantity manufactured should

be applied to the 25,000-pound manufacturing threshold. If the vanadium

is subsequently processed or otherwise used, the applicable quantity

should also be applied to the processing or otherwise use threshold(s). If a

threshold is exceeded, all quantities released or otherwise managed as

waste must be reported as appropriate.

Concurrent with this rulemaking, U.S. EPA also added vanadium

compounds to the list of toxic chemicals subject to reporting under

EPCRA Section 313. U.S. EPA specifically excluded vanadium

compounds from the fume or dust qualifier and from the alloy exemption. 

Therefore, all physical forms of vanadium compounds must be included in

threshold determinations and release and other waste management

activities estimates.

COMMON ERROR - Sulfuric and Hydrochloric Acid (Acid Aerosols)

The textile manufacturing industry uses aqueous sulfuric acid and hydrochloric acid for pH adjustment and textile

dyeing operations. Only aerosol forms of sulfuric acid and hydrochloric acid, including mists, vapors, gas, fog,

and other airborne forms of any particle size, are reportable under EPCRA Section 313. Therefore, facilities do

not need to include non-aerosol forms of either chemical toward threshold determinations and subsequent release

and other waste management calculations.
3-8

3.2 Step 2. Identify the Activity Category and Any Exempt Activities for Each

EPCRA Section 313 Chemical

The next step is to identify the activity category (or categories) and any exempt

activities for each EPCRA Section 313 chemical and chemical category on your list. Table 3-1

lists the reporting thresholds for each of the activity categories (Tables 3-2 through 3-4 provide

detailed definitions of subcategories for each activity category). Each threshold must be

individually calculated; they are mutually exclusive and are not additive.

Table 3-1

Reporting Thresholds

Activity Category Threshold1

Manufacture (including import) 25,000 pounds per year

Process 25,000 pounds per year

Otherwise Use 10,000 pounds per year

These reporting thresholds are for non-PBT chemicals. See Section 2.6 for the reporting thresholds 1

applicable to PBT chemicals.

Example -Threshold Determination

If your facility manufactures 22,000 pounds of an EPCRA Section 313 chemical or chemical category and you

also otherwise use 8,000 pounds of the same chemical or chemical category, you have not exceeded either

threshold and an EPCRA Section 313 report for that chemical or chemical category is not required. However, if

your facility manufactures 28,000 pounds per year of an EPCRA Section 313 chemical or chemical category and

otherwise uses 8,000 pounds of the same chemical or chemical category, you have exceeded the manufacturing

threshold and ALL release and other waste management quantities (except those specifically exempted) of that

chemical or chemical category must be reported on the Form R, including those from the otherwise use activity.
3-9

Example - Xylene Isomers

Textile manufacturing operations use the EPCRA Section 313 chemical xylene with the mixed isomers, CAS

Registry No. 1330-20-7, being the most frequently reported type. Ortho-, meta-, and para-xylene are each listed

on the EPCRA Section 313 chemicals list in addition to xylene (mixed isomers). The mixed isomers

classification should be used when a mixture contains any combination of two or three of the isomers. The

threshold determination for xylene should be calculated for each isomeric form individually unless the xylenes are

manufactured, processed, or otherwise used as a mixture of xylene isomers. For example, a covered facility

annually uses 8,000 pounds of para-xylene, 6,000 pounds of ortho-xylene, and 8,000 pounds of mixed isomers as

carrier solvents in three separate processing lines. All three activities of xylene are classified as otherwise used as

the carrier is intended to evaporate and not remain with the product. There are no other uses of any form of

xylene in the facility. The otherwise used activity threshold of 10,000 pounds/year has not been reached for any

of the xylenes and an EPCRA Section 313 report need not be prepared for xylene. However, should any two of

the streams mix, the facility will exceed the otherwise use threshold for mixed isomers and an EPCRA Section

313 report must be prepared for the mixed isomer form of xylene.

Each of the activity categories is divided into subcategories. 

COMMON ERROR - Threshold Determination for Recirculation

Facilities often incorrectly base threshold calculations on the amount of EPCRA Section 313 chemicals or

chemical categories in a recirculation system rather than the amount actually used in the reporting year. The

amount of the EPCRA Section 313 chemical or chemical category that is actually manufactured (including the

quantity imported), processed, or otherwise used, not the amount in storage or in the system, should be the amount

applied to the threshold determination. For example, a solvent containing an EPCRA Section 313 chemical or

chemical category is used, recirculated on site, and reused as a solvent. The amount of EPCRA Section 313

chemical or chemical category recirculated in the on-site recycling process is not considered in the threshold

determination because it is considered a “direct reuse” and is not reportable. Only the amount of new chemical

added to the system should be included in the otherwise used threshold calculation. However, if you send a

solvent containing an EPCRA Section 313 chemical or chemical category off site for distillation and subsequent

recycling, it should be reported as a transfer to an off-site location for recycling (Part II, Sections 6.2 and 8.5 of

the 1999 Form R) because the distillation is considered a waste management activity. The amount of solvent

returned to you and subsequently used in the same reporting year must be included in the threshold determination. 

If the reporting threshold is exceeded, the total quantity recycled should be reported in Section 8.4, i.e., the

amount recycled on site must be reported in Section 8.4 each time it is recycled. 

As discussed in the TRI Forms and Instructions, you are required to designate EACH category

and subcategory that applies to your facility. Detailed definitions, including descriptions of

subcategories for each activity and selected examples, are presented in Tables 3-2, 3-3, and 3-4.
3-10

Table 3-2

Definitions and Examples of Manufacturing Subcategories

Manufacturing Examples in the 

Activity Subcategory Definition Textile Industry

Produced or imported for A chemical or chemical category that is

on-site use/processing produced or imported and then further

processed or otherwise used at the same

facility.

Produced or imported for A chemical or chemical category that is

sale/distribution produced or imported specifically for sale or

distribution outside the manufacturing

facility.

Produced as a A chemical or chemical category that is Ammonia, phenol, and methanol.

byproduct produced coincidentally during the

production, processing, or otherwise use of

another chemical substance or mixture and is

separated from that substance or mixture.

Toxic chemicals produced and released as a

result of waste treatment or disposal are also

considered byproducts.

Produced as an impurity A chemical or chemical category that is

produced coincidentally as a result of the

manufacture, processing, or otherwise use of

another chemical and remains primarily in the

mixture or product with that other chemical.
3-11

Table 3-3

Definitions and Examples of Processing Subcategories

Processing Activity

Subcategory Definition Examples in the Textile Industry

Reactant A natural or synthetic chemical or chemical Formaldehyde, methanol, and

category used in chemical reactions for the phenol.

manufacture of another chemical substance

or product. Examples include feedstocks,

raw materials, intermediates, and initiators.

Formulation component A chemical or chemical category that is Antimony compounds, copper

added to a product or product mixture prior compounds, chromium compounds,

to further distribution of the product and acts and methanol

as a performance enhancer during use of the

product. Examples include additives, dyes,

reaction diluents, initiators, solvents,

inhibitors, emulsifiers, surfactants,

lubricants, flame retardants, and rheological

modifiers.

Article component A chemical or chemical category that

becomes an integral component of an article

distributed for industrial, trade, or consumer

use.

Repackaging only A chemical or chemical category that is

processed or prepared for distribution in

commerce in a different form, state, or

quantity. May include, but is not limited to,

the transfer of material from a bulk

container, such as a tank truck, to smaller

containers such as cans or bottles.
3-12

Table 3-4

Definitions and Examples of Otherwise Use Subcategories

Otherwise Use Examples in the 

Activity Subcategory Definition Textile Industry

Chemical processing aid A chemical or chemical category that is Biphenyl, methanol,

added to a reaction mixture to aid in the dichloromethane, ethylene glycol,

manufacture or synthesis of another chemical phenol, toluene, and xylene.

substance but is not intended to remain in or

become part of the product or product

mixture. Examples include process solvents,

catalysts, inhibitors, initiators, reaction

terminators, and solution buffers.

Manufacturing aid A chemical or chemical category that aids Equipment cleaning agents such as

the manufacturing process but does not ethylene glycol and methanol.

become part of the resulting product and is

not added to the reaction mixture during the

manufacture or synthesis of another chemical

substance. Examples include process

lubricants, metalworking fluids, coolants,

refrigerants, and hydraulic fluids.

Ancillary or other use A chemical or chemical category that is used

for purposes other than aiding chemical

processing or manufacturing. Examples

include cleaners, degreasers, lubricants, fuels

(including waste fuels), and chemicals used

for treating wastes.

3.2.1 Concentration Ranges for Threshold Determination

You should use the best readily available information, or where such data are not

available, reasonable estimates, for all calculations in EPCRA Section 313 reporting; however,

the exact concentration of an EPCRA Section 313 chemical or chemical category in a mixture or

trade name product may not be known. The supplier or MSDS may only list ranges, or upper or

lower bound concentrations. U.S. EPA has developed guidance on how to use information in

these situations for threshold determinations.

& If the concentration is provided as a lower and upper bound or as a range,

you should use the mid-point in your calculations for the threshold

determination. For example, the MSDS for the trade name product states

methanol is present in a concentration of not less than 20% and not more

than 40%, or it may be stated as present at a concentration between 20 to
3-13

40%. You should use the midpoint value of 30% methanol in your

threshold calculations.

& If only the lower bound concentration of the EPCRA Section 313 chemical

or chemical category is specified and the concentration of other

components are given, subtract the other component values from 100%. 

The remainder should be considered the upper bound for the EPCRA

Section 313 chemical or chemical category and you should use the given

lower bound to calculate the mid-point as discussed above. For example,

the MSDS states that a solvent contains at least 50% methyl ethyl ketone

(MEK) and 20% non-hazardous surfactants. Subtracting the

non-hazardous contents from 100% leaves 80% as the upper bound for

MEK. The mid-point between upper (80%) and lower (50%) bounds is

65%, the value you should use in your threshold calculation.

& If only the lower bound is specified and no information on other

components is given, you should assume the upper bound is 100% and

calculate the mid-point as above.

& If only the upper bound concentration is provided, you should use this

value in your threshold calculation.

Special guidance for concentration ranges that straddle the de minimis value is presented in

Section 3.2.2.1. 

3.2.2 Evaluation of Exemptions

When determining thresholds, you can exclude quantities of any EPCRA

Section 313 chemicals and chemical categories that are manufactured, processed, or otherwise

used in exempt activities. Exemptions are divided into four classes:

1. De minimis exemption;

2. Article exemption;

3. Facility-related exemption; and

4. Activity-related exemptions.

COMMON ERROR - Exempt Activities

Quantities of an EPCRA Section 313 chemical or chemical category used for exempt activities do not need to be

included in your threshold determinations or release and other waste management calculations, even if the

chemical or chemical category is used in a reportable activity elsewhere in the facility.
3-14

3.2.2.1 De Minimis Exemption

If the amount of EPCRA Section 313 chemical(s) or chemical categories present

in a mixture or trade name product processed or otherwise used is below its de minimis

concentration level, that amount is considered to be exempt from threshold determinations and

release and other waste management calculations. Note that this exemption does not apply to

manufacturing, except for importation or as an impurity as discussed below. Also note that the

de minimis exemption does not apply to the manufacturing, processing, or otherwise use of the

PBT chemicals (refer to Section 2.6). The de minimis concentration for EPCRA Section 313

chemicals and chemical categories is 1%, except for Occupational Safety and Health

Administration (OSHA)-defined carcinogens, which have a 0.1% de minimis concentration. 

Note that if a mixture contains more than one member of an EPCRA Section 313 chemical

category, the weight percent of all members must be summed. If the total meets or exceeds the

category’s de minimis level, the de minimis exemption does not apply. U.S. EPA has published

several detailed questions and answers and a directive in the current edition of EPCRA Section

313, Questions and Answers (1998 edition is EPA 745-B-98-004; see Appendix A, Directive #2)

that may be helpful if you have additional concerns about the de minimis exemption. The TRI

Forms and Instructions list each EPCRA Section 313 chemical and chemical category with the

associated de minimis value.

Once the de minimis level has been equaled or exceeded, the exemption no longer

applies to that process stream, even if the EPCRA Section 313 chemical or chemical category

later falls below the de minimis concentration. All release and other waste management activities

that occur after the de minimis concentration has been equaled or exceeded are subject to

reporting. The facility does not have to report release and other waste management activities that

took place before the de minimis concentration was equaled or exceeded.

Example - De Minimis

Your facility processes a mixture containing 1.1% nitric acid and 0.6% manganese. The de minimis exemption

would apply to manganese because the concentration is below 1%, which is the de minimis level for manganese;

however, it would not apply to nitric acid. All of the nitric acid must be included in threshold determinations and

release and other waste management calculations.
3-15

The de minimis exemption also applies to EPCRA Section 313 chemicals and

chemical categories that are coincidentally manufactured below the de minimis level only if that

chemical is manufactured as an impurity in a mixture that is subsequently distributed in

commerce. In addition, the exemption applies to EPCRA Section 313 chemicals and chemical

categories below the de minimis concentration in an imported mixture or trade name product.

For some mixtures the concentration of EPCRA Section 313 chemicals and

chemical categories may be available only as a range. U.S. EPA has developed guidance on how

to determine quantities applicable to threshold determinations and release and other waste

management calculations when this range straddles the de minimis value. In general, only the

quantity of the processed or otherwise used EPCRA Section 313 chemical or chemical category

whose concentration exceeds the de minimis must be considered. Therefore, U.S. EPA allows

facilities to estimate the quantity below the de minimis and exclude it from further consideration. 

The following examples illustrate this point.

Examples - De Minimis Concentration Ranges

Example 1:

A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1.25% manganese. Manganese is subject to a 1% de

minimis concentration exemption. The amount of mixture subject to reporting is the quantity containing manganese above the

de minimis concentration:

(8,000,000) × (0.0125 - 0.0099) ÷ (0.0125 - 0.0025)

The average concentration of manganese that is not exempt (above the de minimis) is:

(0.0125 + 0.0100) ÷ (2)

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)

In this example, 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 Example 2 below.
3-16

Example 2:

As in Example 1, manganese is present in a mixture, of which 8,000,000 pounds is processed. The MSDS states the mixture

contains 0.2% to 1.2% manganese. The amount of mixture subject to reporting (above de minimis) is:

(8,000,000) × (0.012 - 0.009) ÷ (0.012 - 0.002)

The average concentration of manganese that is not exempt (above de minimis) is:

(0.012 + 0.010) ÷ (2)

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

estimates is:

= 26,400 pounds manganese (which is above the processing threshold)

The exemption does not apply to EPCRA Section 313 chemicals and chemical

categories coincidentally manufactured as byproducts and separated from the product, nor does it

apply to EPCRA Section 313 chemicals and chemical categories coincidentally manufactured as

a result of waste management activities, from either on site or off site. (Under EPCRA Section

313, U.S. EPA does not consider waste to be a mixture.) For example, facilities may generate

nitrate compounds as byproducts. The nitrate compounds would be considered to be

coincidentally manufactured and the de minimis exemption would not apply. Thus, the amount

of nitrate compounds (water dissociable and in water) created should be counted toward the

25,000-pound manufacturing threshold.

3.2.2.2 Articles Exemption

An article is defined as a manufactured item that:

& Is formed to a specific shape or design during manufacture; 

& Has end-use functions dependent in whole or in part upon its shape or

design; and

& Does not release an EPCRA Section 313 chemical or chemical category

under normal conditions of processing or otherwise use of the item at the

facility. 
3-17

If you receive a manufactured article from another facility or you produce the

article in your facility and process or otherwise use it without changing the shape or design, and

your processing or otherwise use does not result in the release into the environment of more than

0.5 pound of the EPCRA Section 313 chemical or chemical category in a reporting year for all

like articles, then the EPCRA Section 313 chemical or chemical category in that article is exempt

from threshold determinations and release and other waste management calculations (U.S. EPA

allows a release of 0.5 pound or less to be rounded to zero; the 0.5 pound limit does not apply to

each individual article, but applies to the sum of all releases from processing or use of all like

articles). Section 313 chemicals or chemical categories used to produce an article, however, do

not qualify for the article exemption.

The shape and design can be changed somewhat during processing and otherwise

use as long as part of the item retains the original dimensions. That is, as a result of processing

or otherwise use, if an item retains its initial thickness or diameter, in whole or in part, then it

still meets the article definition. If the item's original dimensional characteristics are totally

altered during processing or otherwise use, the item would not meet the definition. As an

example, items that do not meet the definition would be items that are cold extruded, such as lead

ingots formed into wire or rods. However, cutting a manufactured item into pieces that are

recognizable as the article would not change the exemption status as long as the diameter and the

thickness of the item remain unchanged. For instance, metal wire may be bent and sheet metal

may be cut, punched, stamped, or pressed without losing the article status as long as no change is

made in the diameter of the wire or tubing or the thickness of the sheet and no releases above 0.5

pound per year occur for all like articles.

Example - Articles Exemption

A textile facility may receive fabric for further processing, such as cutting the fabric to a certain design

specification. The fabric may be trimmed by the facility without losing the article status. However, if the releases

of an EPCRA Section 313 chemical from all like fabrics exceed 0.5 pounds per year, the article exemption is

negated.

Any processing or otherwise use of an article that results in a release above 0.5

pound per year for each EPCRA Section 313 and chemical category chemical for all like articles
3-18

also negates the exemption. Cutting, grinding, melting, or other processing of a manufactured

item could result in a release of an EPCRA Section 313 chemical or chemical category during

normal conditions of use and, therefore, could negate the article exemption if the total annual

releases from all like articles exceeds 0.5 pound in a year. However, if all of the resulting waste

is recycled or reused either on site or off site, so that the release of the EPCRA Section 313

chemical or chemical category does not exceed 0.5 pound for the calendar year, then the article’s

exemption status is maintained. If the processing or otherwise use of similar manufactured items

results in a total release of less than or equal to 0.5 pound of any individual EPCRA Section 313

chemical or chemical category to any environmental media in a calendar year, U.S. EPA will

allow this quantity to be rounded to zero and the manufactured items maintain their article status. 

The 0.5-pound limit does not apply to each individual article, but applies to the sum of all

releases from processing or otherwise use of like articles for each EPCRA Section 313 chemical

or chemical category. The current edition of EPCRA Section 313 Questions and Answers (1998

edition is EPA 745-B-98-004) presents several specific question and answer discussions

pertaining to the articles exemption.

Example - Articles Exemption

If a textile article is subjected to a fabric printing process that removes a portion of an EPCRA Section 313

chemical from the surface that is not recycled or reused, this process would constitute a release and could negate

the article exemption if the total releases from all like articles is greater than 0.5 lb for the reporting year. 

3.2.2.3 Facility-Related Exemption

Laboratory Activity Exemption

EPCRA Section 313 chemicals and chemical categories that are manufactured,

processed, or otherwise used in laboratories under the supervision of a technically qualified

individual are exempted from the threshold determination (and subsequent release and other

waste management calculations). This exemption may be applicable in circumstances such as

laboratory sampling and analysis, research and development, and quality assurance and quality

control activities. It does not include pilot plant scale or specialty chemical production. It also
3-19

does not include laboratory support activities. For example, chemicals used to maintain

laboratory equipment are not eligible for the laboratory exemption.

Example - Laboratory Activity Exemption

A textile manufacturer applies various formulations of fabric coatings containing EPCRA Section 313 chemicals

to product samples for testing flame resistance. The testing occurs in the facility’s laboratory under the

supervision of a “technically qualified individual.” The EPCRA Section 313 chemicals used in this activity

would be exempt from EPCRA Section 313 reporting and should not be included in any threshold determinations

or release and other waste management calculations.

3.2.2.4 Activity-Related Exemptions (Otherwise Use Exemptions)

Some exemptions apply to the otherwise use of an EPCRA Section 313 chemical

or chemical category. The specific quantities of EPCRA Section 313 chemicals and chemical

categories used in these activities do not need to be included in facility threshold determinations

(nor the associated release and other waste management calculations). The following otherwise

use activities are considered exempt:

& EPCRA Section 313 chemicals and chemical categories used in routine

janitorial or facility grounds maintenance. Examples are bathroom

cleaners, fertilizers, and garden pesticides similar in type or concentration

to consumer products. Materials used to clean process equipment do not

meet this exemption. 

& Personal use of items. Examples are foods, drugs, cosmetics, and other

personal items including those items within a facility-operated cafeteria,

store, or infirmary. Office supplies such as correction fluid are also

exempt.

& Structural components of the facility. Exemptions apply to EPCRA

Section 313 chemicals and chemical categories present in materials used to

construct, repair, or maintain structural components of a facility. An

example common to all facilities would be the solvents and pigments used

to paint the buildings. Materials used to construct, repair, or maintain

process equipment are not exempt.
3-20

& EPCRA Section 313 chemicals and chemical categories used with

facility motor vehicles. This exemption includes the use of EPCRA

Section 313 chemicals and chemical categories for the purpose of

maintaining motor vehicles operated by the facility. Common examples

include gasoline, radiator coolant, windshield wiper fluid, brake and

transmission fluid, oils and lubricants, cleaning solutions, and solvents in

paint used to touch up the vehicle. Motor vehicles include, but may not be

limited to, cars, trucks, forklifts, locomotives, and aircraft. Note that this

exemption applies to the OTHERWISE USE of EPCRA Section 313

chemicals and chemical categories. The coincidental manufacture of

EPCRA Section 313 chemicals and chemical categories resulting from

combustion of gasoline is not exempt and should be considered toward the

manufacturing threshold.

Example - Motor Vehicle Exemption

Methanol is purchased for use as a processing aid and as a windshield washer antifreeze in company vehicles. Only the amount used as a processing aid would be used in

facility threshold calculations. Even if the facility still exceeds the otherwise use

threshold, the amount in the anti-freeze is exempt from release and other waste

management calculations.

This exemption does NOT apply to stationary equipment. The use of

lubricants and fuels for stationary process equipment (e.g., pumps and

compressors) and stationary energy sources (e.g., furnaces, boilers,

heaters), are NOT exempt.

Example - Process Equipment Chemical Use

Lubricants containing listed EPCRA Section 313 chemicals and chemical categories

used on facility vehicles, or on-site structural maintenance activities that are not integral

to the process, are exempt activities. However, lubricants used to maintain pumps and

compressors that aid facility process operations are not exempt and the amount of the

EPCRA Section 313 chemical or chemical category in the lubricant should be applied to

the otherwise use threshold.

& EPCRA Section 313 chemicals and chemical categories in certain air

or water drawn from the environment or municipal sources. Included

are an exemption for EPCRA Section 313 chemicals and chemical

categories present in process water and non-contact cooling water drawn

from the environment or a municipal source, or chemicals and chemical

categories present in air used either as compressed air or as an oxygen

source for combustion.
3-21

Example - Chemicals in Process Water

A facility uses river water for one of its processes. This water contains approximately

100 pounds of an EPCRA Section 313 chemical or chemical category. The facility

ultimately returns the water that contains the entire 100 pounds of the EPCRA Section

313 chemical or chemical category to the river. The EPCRA Section 313 chemical or

chemical category in the water can be considered exempt because the EPCRA Section

313 chemical or chemical category was present as it was drawn from the environment. 

The facility does not need to consider the EPCRA Section 313 chemical or chemical

category drawn with river water for threshold determinations or release and other waste

management calculations.

3.2.3 Additional Guidance on Threshold Calculations for Certain Activities

This section covers three specific situations in which the threshold determination

may vary from normal facility operations: reuse, remediation, and recycling activities of EPCRA

Section 313 chemicals and chemical categories.

3.2.3.1 Reuse Activities

Threshold determinations of EPCRA Section 313 chemicals and chemical

categories that are reused at the facility are based only on the amount of the EPCRA Section 313

chemical or chemical category that is added to the system 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 the EPCRA Section 313 chemical or chemical category and is not required to report (unless

the facility has additional 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 new or fresh anhydrous ammonia during the year, the facility would exceed the

otherwise use threshold, and be required to report.
3-22

Example - Threshold Determination, Recirculation

Facilities often incorrectly base threshold calculations on the amount of EPCRA Section 313 chemicals in a

recirculation system rather than the amount actually used in the reporting year. The amount of the EPCRA

Section 313 chemical that is actually manufactured (including the quantity imported), processed, or otherwise

used, not the amount in storage or in the system, should be the amount applied to the threshold determination. 

For example, a solvent containing an EPCRA Section 313 chemical is used, recirculated on site, and reused as a

solvent. The amount of EPCRA Section 313 chemical recirculated in the on-site recycling process is not

considered in the threshold determination because it is considered a “direct reuse” and is not reportable. Only the

amount of new chemical added to the system should be included in the otherwise used threshold calculation. 

However, if you send a solvent containing an EPCRA Section 313 chemical off site for distillation and subsequent

recycling, it should be reported as a transfer to an off-site location for recycling (Form R, Part II, Section 6.2 and

8.5) because the distillation is considered a waste management activity. The amount of solvent returned to you

and subsequently used in the same reporting year must be included in the threshold determination. If the

reporting threshold is exceeded, the total quantity recycled should be reported in Section 8.4; i.e., the amount

recycled must be reported in Section 8.4 each time it is recycled.

3.2.3.2 Remediation Activities

EPCRA Section 313 chemicals and chemical categories undergoing remediation

(e.g., Superfund remediation) are not being manufactured, processed, or otherwise used. 

Therefore, they are not included in the activity threshold determinations.

However, if you are conducting remediation of an EPCRA Section 313 chemical

or chemical category that is also being manufactured, processed, or otherwise used by the facility

above an activity threshold level, you must consider this activity for release and other waste

management calculations. You must report any release or other waste management quantities of

an EPCRA Section 313 chemical or chemical category due to remediation in Part II, Sections 5

through 8, accordingly, of the 1999 Form R. Those quantities would also be considered as part

of the amount for determining Form A eligibility. EPCRA Section 313 chemicals and chemical

categories used for remediation should be considered toward threshold determinations.

Excavation of material already landfilled does not constitute a release or other

waste management activity for EPCRA Section 313 reporting purposes. If an EPCRA Section

313 chemical or chemical category exceeds one of the reporting thresholds elsewhere at the

facility, all release and other waste management quantities of that chemical must be reported,

including release and other waste management quantities resulting from remediation. However,
3-23

routine activities (e.g., dredging a lagoon), even if not performed every year, are not considered

to be remedial actions and are always subject to reporting.

3.2.3.3 Recycling Activities

For on-site recycling and reuse systems where the same EPCRA Section 313

chemical or chemical category is recycled and reused multiple times, the quantity should be

counted only once (at the time it is introduced into the system) for threshold calculations. (Please

note that for reporting on-site waste management activities, the quantity of the EPCRA Section

313 chemical or chemical category should be counted every time it exits the recycling unit in

Section 8 of Form R.) EPCRA Section 313 chemicals and chemical categories recycled off site

and returned to the facility should be treated as newly purchased materials for purposes of

EPCRA Section 313 threshold determinations.

3.3 Step 3. Calculate the Quantity of Each EPCRA Section 313 Chemical and

Chemical Category and Determine Which Ones Exceed an Activity

Threshold

The final step is to determine the quantity and which EPCRA Section 313

chemicals and chemical categories exceed an activity threshold. At this point you should have:

1. Identified each EPCRA Section 313 chemical and chemical category at

your facility.

2. Determined the activity category for each EPCRA Section 313 chemical

and chemical category (manufactured, processed, or otherwise used).

Now, you must sum the amount for each EPCRA Section 313 chemical and

chemical category by activity category, subtract all exempt quantities, and compare the totals to

the applicable thresholds. Each EPCRA Section 313 chemical and chemical category exceeding

any one of the activity thresholds requires the submission of an EPCRA Section 313 report. 

Provided you meet certain criteria you may prepare a Form A rather than a Form R (see Section

2.8).
3-24

COMMON ERROR - Assuming a Threshold is Exceeded

U.S. EPA recently published a report, The 1994 and 1995 Toxic Release Inventory Data Quality Report, EPA

745-R-98-002, with the site survey results of over 100 facilities to evaluate EPCRA Section 313 reporting quality. 

One of the findings of this survey was that facilities that simply assumed that chemical activity thresholds were

exceeded were often in error. This resulted in many of these facilities filing EPCRA Section 313 reports when

thresholds were actually not exceeded. Unless the facility has strong grounds to support such an assumption, the

time spent in explicitly calculating the activity threshold is well spent.

COMMON ERROR - Zero Release and Other Waste Management Quantities

If you meet all reporting criteria and exceed any activity threshold for an EPCRA Section 313 chemical, you must

prepare a Form R OR Form A for that chemical activity, even if you have zero release and other waste

management activities. Exceeding the chemical activity threshold, not the quantity released and otherwise

managed as waste determines whether you must report. Note that if the release and other waste managed quantity

is 500 pounds or less you may be eligible to use the alternate certification statement, Form A, rather than a

Form R (see Section 2.9) for each chemical or chemical category.

COMMON ERROR - Certain Glycol Ethers

Many facilities in the textile industry otherwise use glycol ethers in various processes. Certain glycol ethers are

reportable as a chemical category for EPCRA Section 313. The definition of which glycol ethers are reportable

was modified starting with reporting year 1993 to exclude high molecular weight glycol ethers. The current

definition and listing of specific chemicals reportable under EPCRA Section 313 is presented in U.S. EPA’s Toxic

Release Inventory: List of Toxic Chemicals Within the Glycol Ethers Category, May 1995 (EPA 745-R-95-006)

and has been included in this document as Appendix D.

When performing threshold calculations, you must determine which glycol ethers your facility uses and whether

they are reportable under EPCRA Section 313.

COMMON ERROR - Threshold Determinations for Metal Compounds

Facilities are often confused regarding threshold calculations for metal compounds. The threshold determination

for metal compounds should be calculated using the total amount of the compound, not just the weight of the

parent metal. If a threshold is exceeded, the reportable quantities should be based on the amount of parent metal

only. To determine if the de minimis concentration is exceeded, the weight of the entire compound must be

applied.

For those metal compounds listed separately on the EPCRA Section 313 chemical list, do not include the amounts

of those compounds manufactured, processed, or otherwise used in threshold determinations for the metal

compound category. If a compound is listed separately, thresholds and release and other waste management

quantities should both be based on the entire compound amount. An EPCRA Section 313 report, if required,

should be submitted for this chemical individually.

To determine if an EPCRA Section 313 chemical or chemical category exceeds a

reporting threshold, you must calculate the annual activity amount of that chemical. Start with
3-25

the amount of chemical at the facility as of January 1, add any amount brought on site during the

year and the amount manufactured (including imported), and subtract the amount left in the

inventory on December 31. If necessary, adjust the total to account for exempt activities (see

Section 3.2.2 for a discussion of exemptions). You should then compare the result to the

appropriate threshold to determine if you are required to submit an EPCRA Section 313 report

for that chemical or chemical category. Keep in mind that the threshold calculations are

independent for each activity category: manufactured, processed, and otherwise used. If more

than one activity category applies, the amount associated with each category is determined

separately.

Table 3-5 presents a work sheet that may be helpful when conducting your

threshold determinations. Table 3-6 illustrates an example of how the work sheet can be used for

the following example:

Example - Threshold Worksheet

Assume your facility purchases two mixtures that contain methyl ethyl ketone in the applicable reporting year. 

You purchased 25,000 pounds of Mixture A (which is 50% methyl ethyl ketone, by weight, according to the

MSDS) and 110,000 pounds of Mixture B (which contains 20% methyl ethyl ketone, by weight). Further, you

determine that you process the entire quantity of Mixture A, while you process only half of Mixture B and

otherwise use the other half. You do not qualify for any exempt activities. 

In this example, you would have processed a total of 23,500 pounds of methyl ethyl ketone (12,500 pounds from

activities associated with Mixture A and 11,000 pounds from activities associated with Mixture B). You would

also have otherwise used a total of 11,000 pounds (all from Mixture B). Therefore, you would not have exceeded

the 25,000 pound threshold for processing; however, you would have exceeded the 10,000 pound threshold for

otherwise use and would be required to submit an EPCRA Section 313 report that includes releases and other

waste management quantities from all activities (including processing).
These activity thresholds apply to non-PBT chemicals. See Section 2.6 for activity thresholds applicable to PBT chemicals.

2

3-26

Table 3-5. EPCRA Section 313 Reporting Threshold Worksheet

Facility Name: Date Worksheet Prepar

EPCRA Section 313 Chemical or Chemical Category: Prepared By: ________

CAS Registry Number: 

Reporting Year: Amounts of the chemical manufactured, processed, or otherwise used.

Mixture Name or Other Identifier Source (lb) by Weight (lb) Manufactured Process

Information Total Weight Chemical Weight

Percent TRI Chemical

TRI

Amount of the EPCRA Section 313 C

1.2.3.4.Subtotal: (A)_________lb. (B)_______

Exempt quantity of the chemical that should be excluded.

Mixture Name as Listed Above activity) (if Applicable) Manufactured Process

Applicable Exemption (de

minimis, article, facility, Fraction or Percent Exempt

Amount of the EPCRA Section 3

Above (lb

1.2.3.4.Subtotal: (A )_________lb. (B )______

1 1

Amount subject to threshold: (A-A )_____ lb. (B-B )____

1 1 

Compare to threshold for EPCRA Section 313 reporting. Activity threshold quantities : 25,000 lb. 25,000 

2

If any one of these thresholds is exceeded, reporting is required for all activities. [Do not submit this worksheet with your EPCRA Section 313 records.]
These activity thresholds apply to non-PBT chemicals. See Section 2.6 for activity thresholds applicable to PBT chemicals.

2

3-27

Table 3-6. Sample EPCRA Section 313 Reporting Threshold Worksheet

Facility Name: ABC Textile Finishing, Inc. Date Worksheet Prepared

EPCRA Section 313 Chemical or Chemical Category: Methyl ethyl ketone Prepared By: A.B. Callo

CAS Registry Number: 78-93-3Reporting Year: 1999Amounts of the chemical manufactured, processed, or otherwise used.

Mixture Name or Other Identifier Source (lb) by Weight (lb) Manufactured Process

Information Total Weight Chemical Weight

Percent TRI Chemical

TRI

Amount of the EPCRA Section 313 C

1. Mixture A Purchasing 25,000 50% 12,500 --- 12,500 

records, MSDS

2. Mixture B Purchasing 110,000 20% 22,000 --- 11,000 

records, MSDS

3.4.Subtotal: (A) 0 lb. (B) 23,500 

Exempt quantity of the chemical that should be excluded.

Mixture Name as Listed Above activity) (if Applicable) Manufactured Process

Applicable Exemption (de

minimis, article, facility, Fraction or Percent Exempt

Amount of the EPCRA Section 3

Above (lb

1. None2.3.4.Subtotal: (A ) 0 lb. (B ) 0 l

1 1

Amount subject to threshold: (A-A ) 0 lb. (B-B ) 23,5

1 1 

Compare to threshold for EPCRA Section 313 reporting. Activity threshold quantities : 25,000 lb. 25,000 

2

If any one of these thresholds is exceeded, reporting is required for all activities. [Do not submit this worksheet with your EPCRA Section 313 records.]
4-1

CHAPTER 4 - ESTIMATING RELEASE AND OTHER WASTE

MANAGEMENT QUANTITIES

4.0 PURPOSE

This chapter is intended to guide the user in developing a systematic approach for

estimating release and other waste management quantities of EPCRA Section 313 chemicals and

chemical categories from textile manufacturing processes. Figure 4-1 diagrams a recommended

approach for estimating quantities of reportable EPCRA Section 313 chemicals or chemical

categories.

This chapter also includes common EPCRA Section 313 reporting and

compliance issues as they apply to textile manufacturers. The general discussion (Section 4.1) is

followed by a presentation of specific examples and issues (Section 4.2) as they pertain to textile

manufacturers.

4.1 General Steps for Determining Release and Other Waste Management

Activity Quantities

Release and other waste management activity quantities can be determined by

completing the following four steps described in detail in the following sections.

Step 1) Prepare a process flow diagram.

Step 2) Identify EPCRA Section 313 chemicals and chemical categories

and potential sources of chemical release and other waste

management activities.

Step 3) Identify release and other waste management activity types.

Step 4) Determine the most appropriate method(s) and calculate the

estimates for release and other waste management activity

quantities.
Identify EPCRA

Section 313 Chemicals

Prepare ProcessFlow Diagram

STEP 1:

STEP 2:

STEP 2:

STEP 3:

STEP 3:

STEP 4:

STEP 4:

Define theOperation

Review AvailableData & ChooseEstimation Method

Source 1

Fugitive

Air

Point

Air

Discharge

to

Waterbody

Underground

Injection

Land

On Site

POTW Transfer

Off Site for

Recycling

Transfer

Off Site for

Energy Recovery

Transfer

Off Site for

Treatment

Transfer

Off Site for

Disposal

On-S

Was

Treatm

Source 3

Source 2

Identify Sources of Release and Other WasteManagement Activities

Identify Releases and OtherWaste Management ActivityTypes

Calculate Estimates forReleases and Other WasteManagement ActivityQuantities

4-2

Figure 4-1. Release and Other Waste Management Calculation Approach
4-3

For EPCRA Section 313 purposes, “sources” means the streams or units that

generate the release and other waste management activity (such as process vents, container

residue, or spills) and “types” means the environmental media corresponding to elements in

Sections 5 through 8 of the 1999 Form R (for example, releases to fugitive air, releases to stack

air, discharges to receiving streams or POTWs, or releases to land).

4.1.1 Step 1: Prepare a Process Flow Diagram

Preparing a process flow diagram will help you to identify potential sources and

types of EPCRA Section 313 chemicals and chemical categories released and otherwise managed

as waste at your facility. Depending on the complexity of your facility, you may want to diagram

individual processes or operations rather than the entire facility. The diagram should show how

materials flow through the processes and identify material input, generation, and output points. 

Looking at each operation separately, you can determine where EPCRA Section 313 chemicals

and chemical categories are used and the medium to which they may be released or otherwise

managed as waste.

4.1.2 Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories

and Potential Sources of Chemical Release and Other Waste Management

Activities

Once a process flow diagram has been developed, you must determine the

potential sources and the EPCRA Section 313 chemicals and chemical categories that may be

released and otherwise managed as waste from each unit operation and process. Remember to

include upsets and routine maintenance activities. Potential sources include:

& Accidental spills and releases; & Flanges;

& Air pollution control devices (e.g., & Process discharge streams;

baghouses, electrostatic precipitators, & Process vents;

and scrubbers) & Pumps;

& Clean up and housekeeping & Recycling and energy recovery

practices; byproducts;

& Combustion byproducts. & Relief valves;

& Container residues; & Stock pile losses;

& Fittings; & Storage tanks;
4-4

& Storm water runoff; & Volatilization from process or

& Tower stacks; treatment; and

& Transfer operations; & Waste treatment discharges.

& Treatment sludge;

Next, you must identify the EPCRA Section 313 chemicals and chemical

categories that may be released or otherwise managed as waste from each source. A thorough

knowledge of the facility operations and processes is required for this determination. You should

also consider whether any of the EPCRA Section 313 chemicals or chemical categories are

coincidentally manufactured at your facility. Table 2-3 identifies EPCRA Section 313 chemicals

and chemical categories typically used in textile manufacturing. This table can be used as an aid

in identifying which chemicals and chemical categories are found in your process. The list may

not include all the EPCRA Section 313 chemicals and chemical categories your facility uses, and

it may include many chemicals that you do not use.

4.1.3 Step 3: Identify Release and Other Waste Management Activity Types

For each identified source of an EPCRA Section 313 chemical or chemical

category, you should examine all possible release and other waste management activity types. 

Figure 4-2 schematically represents the possible release and other waste management activity

types as they correspond to individual data elements of the Form R. Remember to include both

routine operations and accidents when identifying types. This diagram along with the following

descriptions can be used as a checklist to make sure all possible types of release and other waste

management activities have been considered.

a. Fugitive or Non-Point Air Emissions (Part II, Section 5.1 of Form R) -

Includes all emissions to the air that are not released through stacks, vents,

ducts, pipes, or any confined air stream. Examples include: 
Point Sources

(Part II, Sections

5.2 and 8.1)

Fugitive Em issions

(Part II, Sections 

5.1 and 8.1)

Operation Toxic C hem ical In

On-Site Recycling

(Part II, Sections 7C and 8.4)

On-Site Energy Recovery

(Part II, Sections 7B and 8.2)

On-Site Treatment

(Part II, Sections 7A and 8.6)

Transfer Off Site for Disposal

(Part II, Sections 6.2 and 8.1)

Transfer Off Site for Treatment

(Part II, Sections 6.2 and 8.7)

Transfer Off Site for Energy Recovery

(Part II, Sections 6.2 and 8.3)

Transfer Off Site for Recycling

(Part II, Sections 6.2 and 8.5)

Receiving Streams

(Part II, Sections

5.3 and 8.1)

Underground Injection

(Part II, Sections 

5.4 and 8.1)

POTW

(Part II, Sections 

6.1 and 8.1, or 8.7)

Land on site (landfill,

land treatment, 

surface im poundment)

(Part II, Sections

5.5 and 8.1)

4-5

Figure 4-2. Possible Release and Other Waste Management Types 1

for EPCRA Section 313 Chemicals and Chemical Categories

Sections refer to 1999 Form R. Quantities released to the environment as a result of remedial actions, catastrophic 1

events, or one-time events should be reported in Part II, Section 8 as Subsection 8.8.
4-6

& Equipment leaks from valves, pump seals, flanges, compressors, sampling

connections, open-ended lines, etc.;

& Releases from building ventilation systems, such as a roof fan in an open

room;

& Evaporative losses from solvent cleaning tanks, surface impoundments,

and spills; and

& Emissions from any other fugitive or non-point source.

COMMON ERROR - Reporting Fugitive Emissions

A common reporting error is failure to account for fugitive air releases during the

transfer of volatile chemicals such as toluene, chlorine, or ammonia from storage tanks

to unit operations. Sources of fugitive air releases from transfer operations include

valves and pipe flanges. To calculate breathing and working losses, SOCMI emission

factors, AP-42 emission factors and equations, and EPA’s TANKS computer program

can be used (see Section 4.1.4.3).

Note that releases from storage tanks are classified as stack air emissions.

b. Stack or Point Air Emissions (Part II, Section 5.2 of Form R) -

Includes all emissions to the air that occur through stacks, vents, ducts,

pipes, or any confined air stream, including the emissions from storage

tanks and air pollution control equipment. Note that emissions released

from general room air through a ventilation system are not considered

stack or point releases for the purpose of EPCRA Section 313 reporting

unless they are channeled through an air pollution control device. Instead,

they are considered fugitive releases. However, you should note that for

certain state reporting requirements not associated with EPCRA Section

313 reporting, some state air quality agencies consider ventilation systems

to be a stack or point source. 

c. Discharges to Receiving Streams or Water Bodies (Part II, Section 5.3

of Form R) - Includes direct wastewater discharges to a receiving stream

or surface water body. Discharges usually occur under a NPDES or

SPDES permit.

d. Underground Injection On-Site to Class I Wells (Part II, Section 5.4.1

of Form R) and to Class II through V Wells (Part II, Section 5.4.2 of

Form R) - Includes releases into an underground well at the facility. 

These wells may be monitored under an Underground Injection Control

(UIC) Program permit. RCRA Hazardous Waste Generator Reports may

be a good source of information for wastes injected into a Class I well. 

Injection rate meters may provide information for all the well classes.

e. Disposal to Land On-Site (Part II, Section 5.5 of Form R) - Includes

all releases to land on site, both planned (i.e., disposal) and unplanned

(i.e., accidental release or spill). The four predefined subcategories for
4-7

reporting quantities released to land within the boundaries of the facility

are:

(1) Landfill - The landfill may be either a RCRA permitted (Part II,

Section 5.51A) or a non-hazardous waste landfill (Part II, Section

5.51B). Both types are included if they are located on site. Leaks

from landfills in the years subsequent to the disposal of the

EPCRA Section 313 chemicals or chemical categories in the

landfill do not need to be reported as a release. 

(2) Land treatment/application farming - Land treatment is a

disposal method in which a waste containing an EPCRA

Section 313 chemical or chemical category is applied to or

incorporated into soil. Volatilization of an EPCRA Section 313

chemical or chemical category because of the disposal operation

must be included in the total fugitive air releases and should be

excluded from land treatment/application farming to avoid double

counting.

Sludge and/or aqueous solutions that contain biomass and other

organic materials are often collected and applied to farm land. 

This procedure supplies a nitrogen source for plants and supplies

metabolites for microorganisms. U.S. EPA considers this

operation to be land treatment/farming if it occurs on site. If a

facility sends this material off site for the same purpose, it is

considered to be a “transfer to an off-site location, disposal” and

should be reported under Sections 6.2 and 8.1 of the Form R.

The ultimate disposition of the chemical or chemical category after

application to the land does not change the required reporting. For

example, even if the chemical or chemical category is eventually

biodegraded by microorganisms or plants, it is not considered

recycled, reused, or treated.

(3) Surface impoundment - A surface impoundment is a natural

topographic depression, man-made excavation, or diked area

formed primarily of earthen materials that is designed to hold an

accumulation of wastes containing free liquids. Examples include:

holding, settling, storage, and elevation pits; ponds; and lagoons. 

Quantities of the toxic chemical released to surface impoundments

that are used merely as part of a wastewater treatment process

generally must not be reported in this section. However, if the

sludge from the surface impoundment contains the EPCRA

Section 313 chemical or chemical category, then the EPCRA

Section 313 chemicals or chemical categories in the sludge must be

estimated in this section unless the sludge is removed and

subjected to another waste management activity.
4-8

(4) Other disposal - Releases to land that do not fit the categories of

landfills, land treatment, or surface impoundment are classified as

other disposal. This disposal may include any spills or leaks of the

EPCRA Section 313 chemical or chemical category to land.

f. Discharges to Publicly Owned Treatment Works (POTW) (Part II,

Section 6.1 of Form R) - Includes the amount of EPCRA Section 313

chemical or chemical category in water transferred to an off-site POTW. 

Note that metals and metal compounds transferred to a POTW must also

be reported in Section 8.1.

g. Transfers to Other Off-Site Locations (Part II, Section 6.2 of Form

R) - Includes all off-site transfers containing the EPCRA Section 313

chemical or chemical category for the purposes of disposal, treatment,

energy recovery, or recycling. Off-site transfer for disposal includes

underground injection, landfill/surface impoundment, other land disposal

and transfer to a waste broker for disposal. The amount transferred off site

for disposal must also be reported in Section 8.1.

Be sure to consider metals and metal compounds that are present in

pigments used in spray coating applications. Waste containing these

pigments may be present in spent filters or other waste generated from

spray booths.

Also reported in Section 6.2 would be any residual EPCRA Section 313

chemicals or chemical categories in “empty” containers transferred off

site. U.S. EPA expects that all containers (bags, totes, drums, tank trucks,

etc.) will have a small amount of residual solids and/or liquid. On-site

cleaning of containers must be considered for EPCRA Section 313

reporting. If the cleaning occurs with a solvent (organic or aqueous), you

must report the disposition of the waste solvent as appropriate. If the

containers are sent off site for disposal or reclamation, you should report

the EPCRA Section 313 chemical or chemical category in this section.
4-9

COMMON ERROR - Shipping Container Residue

Do not overlook residual chemicals or chemical categories in containers. U.S. EPA

recently published The 1994 and 1995 Toxic Release Inventory Data Quality Report,

EPA 745-R-98-002, presenting the site survey results of over 100 facilities to evaluate

EPCRA Section 313 reporting quality. This survey found the largest source of

overlooked release and other waste management activities was from container residue. 

So-called “empty” drums may contain an inch or more of liquid after draining and

similarly “empty” bags may contain residues of dust and powder. Even though each

individual drum or bag may only contain a small amount of an EPCRA Section 313

chemical or chemical category, for facilities that receive hundreds or thousands of

drums or bags each year the annual cumulative amount of an EPCRA Section 313

chemical or chemical category can be substantial. The quantities should typically be

reported in Section 6.2. Please note that unlike RCRA, EPCRA Section 313 does not

define what constitutes an “empty” container. EPCRA Section 313 is merely trying to

account for all the quantities of toxic chemicals released and otherwise managed as

waste.

Actual data and a knowledge of the unloading methods at your facility can

be used to estimate the quantity of residual EPCRA Section 313 chemicals

or chemical categories in containers. However, U.S. EPA has developed

guidance to assist facilities if no site-specific information is available. 

Table 4-1 provides results from experimentation on residue quantities left

in drums and tanks when emptied. These results are presented as the mass

percent of the vessel capacity, and are categorized based on unloading

method, vessel material, and bulk fluid material properties such as

viscosity and surface tension. No testing was conducted for residual solids

in this study. If data or site-specific knowledge is available to estimate the

quantity of solid residual in containers, it should be considered. If no data

are available, U.S. EPA believes an estimate of 1% residual solid material

is reasonable.
4-10

Example - 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% aqueous 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.

Table 4-1 lists the residue quantity of water in a steel drum, unloaded by pumping, as approximately 2.29% of

drum capacity. 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 sent off site 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 a pumped steel drum by the total annual weight of solution

in the drums. If the density is not known, it may be appropriate to use the density of water (8.34 pounds per

gallon): 

(0.0229) × (55 gal/drum) × (1,000 drums) × (8.34 lb/gal) = 10,504 pounds solution.

The concentration of the EPCRA Section 313 chemical in the solution is 10%. 

(10,504 lb solution) × (0.10) = 1,050 pounds EPCRA Section 313 chemical.

Therefore, 1,050 pounds of the EPCRA Section 313 chemical are sent off site to the POTW, and should be

reported in Part II, Sections 6.1 and 8.7 of the 1999 Form R. Because they cannot be destroyed, metals cannot be

reported as being treated, and metals and metal portions of metal compounds should be reported in Part II,

Sections 6.1 and 8.1 of the 1999 Form R.

h. On-Site Waste Treatment (Part II, Section 7A of Form R) - Includes all

on-site waste treatment of reported EPCRA Section 313 chemicals and

chemical categories. The information reported in Section 7A focuses on

the treatment of the entire waste stream, not the specific EPCRA Section

313 chemical or chemical category. The information includes: type of

waste stream (gaseous, aqueous or non-aqueous liquid, or solid); treatment

methods or sequence; influent concentrations of the EPCRA Section 313

chemical or chemical category; treatment efficiency of each method or

sequence; and whether efficiency data are based on actual operating data. 

Metals and metal portions of metal compounds subjected to a combustion

process are not destroyed but should still be reported as going through the

treatment process, with a treatment efficiency of zero. Note that only the

metal portion of metal compounds should be reported in the Form R. The

following example illustrates how Section 7A should be completed for onsite treatment of a wastewater stream containing three EPCRA Section 313

chemicals.
4-11

Table 4-1

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

(weight percent of drum capacity)

Unloading Surfactant

Method Vessel Type Value Kerosene Water Motor Oil Solution

Material

cd e f

Pumping Steel drum Range 1.93 - 3.08 1.84 - 2.61 1.97 - 2.23 3.06

Mean 2.48 2.29 2.06 3.06

Pumping Plastic drum Range 1.69 - 4.08 2.54 - 4.67 1.70 - 3.48 Not

Mean 2.61 3.28 2.30 Available

Pouring Bung-top steel Range 0.244 - 0.472 0.266 - 0.458 0.677 - 0.787 0.485

drum Mean 0.404 0.403 0.737 0.485

Pouring Open-top steel Range 0.032 - 0.080 0.026 - 0.039 0.328 - 0.368 0.089

drum Mean 0.054 0.034 0.350 0.089

Gravity Slope-bottom Range 0.020 - 0.039 0.016 - 0.024 0.100 - 0.121 0.048

Drain steel tank Mean 0.033 0.019 0.111 0.048

Gravity Dish-bottom Range 0.031 - 0.042 0.033 - 0.034 0.133 - 0.191 0.058

Drain steel tank Mean 0.038 0.034 0.161 0.058

Gravity Dish-bottom Range 0.024 - 0.049 0.020 - 0.040 0.112 - 0.134 0.040

Drain glass-lined tank Mean 0.040 0.033 0.127 0.040

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

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

1986.

The values listed in this table should only be applied to similar vessel types, unloading methods, and bulk fluid b

materials. At viscosities greater than 200 centipoise, the residue quantities can rise dramatically and the information

on this table is not applicable.

For kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm c 2

For water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm d 2

For motor oil, viscosity = 97 centipoise, surface tension = 34.5 dynes/cm e 2

For surfactant solution viscosity = 3 centipoise, surface tension = 31.4 dynes/cm f 2
4-12

Example - 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. 

The two wastewater streams are combined and sent to an on-site wastewater treatment system before being

released to a POTW. This system consists of an oil/water separator that removes 99% of chemical A; a

neutralization tank in which the pH is adjusted to 7.5, thereby destroying 100% of the mineral acid (chemical C);

and a settling tank where 95% of the metal (chemical B) is removed from the water (and eventually land filled 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: P19 (liquid phase separation),

C11 (neutralization), P11 (settling/clarification), and N/A (to signify the end of the treatment system). Note that

Section 7A.1b is the only section of the Form R that is not chemical specific. It applies to the entire waste stream

being treated. Section 7A.1c of each Form R should show the concentration of the specific chemical in the

influent to the first step of the process (oil/water separation). For this example, assume chemicals A, B, and C are

all present at concentrations greater than 1%. Therefore, code “1” should be entered. Section 7A.1d is also

chemical specific. It applies to the efficiency of the entire system in destroying and/or removing the chemical for

which you are preparing the Form R. You should enter 99% when filing for chemical A, 95% for chemical B,

and 100% for chemical C. Finally, you should report whether the influent concentration and efficiency estimates

are based on operating data for each chemical, as appropriate.

Chemical A

7A.1a 7A.1b 1. P19 2. C11 7A.1c 7A.1d 7A.1e

 W 3. P11 4. N/A 5. 1 99 % Yes No

6. 7. 8. X 

Chemical B

7A.1a 7A.1b 1. P19 2. C11 7A.1c 7A.1d 7A.1e

 W 3. P11 4. N/A 5. 1 95 % Yes No

6. 7. 8. X 

Chemical C

7A.1a 7A.1b 1. P19 2. C11 7A.1c 7A.1d 7A.1e

 W 3. P11 4. N/A 5. 1 100 % Yes No

6. 7. 8. X 

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 Section 8.6 (quantity treated on

site). For example, when completing the Form R for chemical B you should report “0” 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 land filled off site should be reported in Sections 6.2 and 8.1. 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.
The Subsection 8.1 through 8.8 designations are for the 1999 Form R. Please refer to the current reporting year TRI *

Forms and Instructions for any changes.

4-13

i. On-Site Energy Recovery (Part II, Section 7B of Form R) - Includes all

on-site energy recovery of reported EPCRA Section 313 chemicals and

chemical categories. U.S. EPA’s view is that EPCRA Section 313

chemicals or chemical categories that do not contribute significant heat

energy during combustion processes should not be considered for energy

recovery. Therefore, only EPCRA Section 313 chemicals or chemical

categories with a significant heating value that are combusted in an energy

recovery unit such as an industrial furnace, kiln, or boiler can be reported

for energy recovery. If an EPCRA Section 313 chemical or chemical

category is incinerated on site but does not significantly contribute energy

to the process, (e.g., chlorofluorocarbons (CFCs)) it must be considered

on-site waste treatment (see 4.1.3, h. above). Metals and metal portions of

metal compounds will never be combusted for energy recovery. Note that

only the metal portion of metal compounds should be reported in the Form

R.

j. On-Site Recycling (Part II, Section 7C of Form R) - Includes all on-site

recycling methods used on EPCRA Section 313 chemicals or chemical

categories.

k. Source Reduction and Recycling Activities (Part II, Section 8 of

Form R) - Provide information about source reduction and recycling *

activities related to the EPCRA Section 313 chemical or chemical category

for which release and other waste management activities are being

reported. Section 8 uses some data collected to complete Part II, Sections

5 through 7. For this reason, Section 8 should be completed last. The

relationship between Sections 5, 6, and 8.8 to Sections 8.1, 8.3, 8.5, and

8.7 are provided in equation forms below.

(1) Quantity Released (Part II, Section 8.1 of Form R) - The

quantity reported in Section 8.1 is the quantity reported in all of

Section 5 plus the quantity of metals and metal compounds

reported as discharged off site to POTWs in Section 6.1 plus the

quantity reported as sent off site for disposal in Section 6.2 minus

the quantity reported in Section 8.8 that was released on site or sent

off site for disposal:

§8.1 = §5 + §6.1 (metals and metal compounds) + §6.2 (disposal) -

§8.8 (on-site release or off-site disposal only)

(2) Quantity Used for Energy Recovery On-Site (Part II,

Section 8.2 of Form R) - Estimate the quantity of the EPCRA

Section 313 chemical or chemical category in wastes combusted

for energy recovery on site. This estimate should be the quantity of
4-14

the chemical or chemical category combusted in the process for

which codes were reported in Section 7B. Test data from trial

burns or other monitoring data may be used to estimate the quantity

of the EPCRA Section 313 chemical or chemical category

combusted for energy recovery purposes. If monitoring data are

not available, vendor specifications regarding combustion

efficiency may be used as they relate to the EPCRA Section 313

chemical or chemical category. A quantity must be reported in

Section 8.2 when a method of on-site energy recovery is reported

in Section 7B and vice versa. 

Two conditions need to be met to report the combustion of an

EPCRA Section 313 chemical or chemical category in waste as

energy recovery: the chemical or chemical category (1) must have a

significant heating value and (2) must be combusted in an energy

recovery unit, such as a waste heat boiler, an industrial furnace, or

a kiln. If an EPCRA Section 313 chemical or chemical category

that does not have a significant heating value (except metals and

metal compounds) is combusted for energy recovery on site, it

must be considered on-site waste treatment (see 4.1.3.h). 

However, this does not apply to metals and metal compounds.

Metals and metal compounds in a waste that are combusted on site

will never be combusted for energy recovery or treated for

destruction and are therefore normally disposed. Note that “NA”

should be reported for EPCRA Section 313 chemicals and

chemical categories that do not have a significant heating value. 

This includes metals, metal portions of metal compounds,

halogens, hydrochlorofluorocarbons (HCFCs), and CFCs.

(3) Quantity Used for Energy Recovery Off-Site (Part II,

Section 8.3 of Form R) - The quantity reported in Section 8.3 is

the quantity reported in Section 6.2 for which energy recovery

codes are reported. If a quantity is reported in Section 8.8, subtract

any associated off-site transfers for energy recovery:

§8.3 = §6.2 (energy recovery) - §8.8 (off-site energy recovery)

Two conditions need to be met to report the combustion of an

EPCRA Section 313 chemical or chemical category in waste as

energy recovery: the chemical or chemical category (1) must have a

significant heating value and (2) must be combusted in an energy

recovery unit, such as a waste heat boiler, an industrial furnace, or

a kiln. If an EPCRA Section 313 chemical or chemical category

that does not have a significant heating value (except metals and

metal compounds) is sent off site for energy recovery, it must be

considered off-site waste treatment (see 4.1.3.g). However, this 
4-15

does not apply to metal and metal compounds. Metals and metal

compounds sent off site for combustion in energy recovery units

must be considered as sent off site for disposal because typically

they will ultimately be disposed. Metals and metal portions of

metal compounds will never be treated or combusted for energy

recovery. Note that only the metal portion of metal compounds

should be reported in the Form R. Also note that “NA” should be

reported for EPCRA Section 313 chemicals and chemical

categories that do not have a significant heating value. This

includes metals, metal portions of metal compounds, halogens,

HCFCs, and CFCs.

(4) Quantity Recycled On-Site (Part II, Section 8.4 of Form R) -

Estimate the quantity of the EPCRA Section 313 chemical or

chemical category recycled in wastes on site. This estimate should

be the quantity of the chemical or chemical category recycled in the

process for which codes were reported in Section 7C. A quantity

should be reported in Section 8.4 when a method of on-site

recycling is reported in Section 7C and vice versa. To estimate this

quantity, you should determine if operating data exist that indicate

a recovery efficiency and use that efficiency value combined with

throughput data to calculate an estimate. If operating data are

unavailable, available vendor specifications may be appropriate.

(5) Quantity Recycled Off-Site (Part II, Section 8.5 of Form R) -

The quantity reported in Section 8.5 must be the same as the

quantity reported in Section 6.2 for which recycling codes are

reported. If a quantity is reported in Section 8.8, subtract any

associated off-site transfers for recycling.

If the facility has knowledge about metals being recovered, this

quantity should be reported in Section 8.5.

§8.5 = §6.2 (recycling) - §8.8 (off-site recycling)

COMMON ERROR - Direct Reuse vs. Recycling

The direct reuse of an EPCRA Section 313 chemical does not need to be

included in the amount reported in Part II, Section 8 of Form R. However,

recycling of the chemical should be included.

(6) Quantity Treated On-Site (Part II, Section 8.6 of Form R) -

Waste treatment in Section 8 is limited to the destruction or

chemical conversion of the EPCRA Section 313 chemical or
4-16

chemical category in wastes. The quantities reported in Section 8.6

will be those that have undergone processes that are a subset of the

processes for which codes were reported in Section 7A, where

treatment includes physical removal from a waste stream. To

estimate the quantity treated, you should determine if operating

data exist that indicate a treatment efficiency (e.g., destruction or

chemical conversion of the EPCRA Section 313 chemical or

chemical category) and use that efficiency value combined with

throughput data to calculate an estimate. Because metals cannot be

destroyed or chemically converted into something other than the

metal or metal compound, metals cannot be reported as being

treated in Section 8.6. Note that conversion of a metal from one

oxidation state to another (e.g., Cr(VI) to Cr(III)) is not considered

treatment for Section 8.6. If operating data are unavailable,

available vendor specifications may be appropriate. Section 7A

must be completed if a quantity is entered in Section 8.6.

(7) Quantity Treated Off-Site (Part II, Section 8.7 of Form R) -

The quantity reported in Section 8.7 must be the same as the

quantity reported in Section 6.2 for which treatment codes are

reported plus quantities sent to a POTW as reported in Section 6.1

except for metals and metal compounds. If a quantity is reported in

Section 8.8, subtract the amount sent off site for treatment:

§8.7 = §6.1 (except metals and metal compounds) + §6.2

(treatment) - §8.8 (off-site treatment)

Because metals cannot be destroyed or chemically converted into

something other than the metal or metal compound, metals cannot

be reported as treated in Section 8.7. Quantities of metals reported

in Section 6.1 and 6.2 should be reported in Section 8.1 (Quantity

Released) unless the facility has knowledge that the metal is being

recovered.

(8) Quantity Released to the Environment as a Result of Remedial

Actions, Catastrophic Events, or One-Time Events Not

Associated with Production Processes (Part II, Section 8.8 of

Form R) - The purpose of this section is to separate quantities

recycled off site, used for energy recovery off site, treated off site,

or released (including disposed) that are associated with normal or

routine production from those quantities that are not. The quantity

reported in Section 8.8 is the quantity of the EPCRA Section 313

chemical or chemical category released directly into the

environment or sent off site for recycling, energy recovery,

treatment, or disposal during the reporting year because of any of

the following events:
4-17

& Remedial actions;

& Catastrophic events such as earthquakes, fires, or floods; or

& One-time events not associated with normal or routine

production processes.

The quantity reported in Section 8.8 should not be included with

quantities reported in Part II, Sections 8.1 through 8.7 of Form R,

but should be included in Part II, Sections 5 and 6 of Form R as

appropriate.

Spills that occur as a routine part of production operations and

could be reduced or eliminated by improved handling, loading, or

unloading procedures are included in the quantities reported in

Section 8.1 through 8.7 as appropriate. This includes small

drippings and spills that often occur during transfer operations and

loading/unloading operations.

On-site releases and off transfers for further waste management

from remediation of an EPCRA Section 313 chemical or chemical

category or an unpreventable accident unrelated to production

(such as a hurricane) are reportable in Section 8.8.

On-site treatment, energy recovery, or recycling of EPCRA

Section 313 chemicals or chemical categories in wastes generated

as a result of remedial actions, catastrophic events, or one-time

events not associated with production processes are not reported in

Part II, Section 8.8, nor in Sections 8.1 through 8.7 of Form R.

COMMON ERROR - Double Counting

Release and other waste management activities should not be inadvertently “double counted.” A single

wastewater discharge should not be listed as both a release to water (on site) and a discharge to POTW (off site). 

Similarly, a release to land should not be listed as both a release to land (on site) and as sent to an off-site landfill. 

Estimates of release and other waste management activities should be prepared for Sections 5 through 7 of the

Form R. For the most part, Section 8 relies on the data collected to complete these previous sections. Therefore,

Section 8 should be completed last. However, the data elements of Section 8 (8.1 through 8.7) are mutually

exclusive and care should be taken to avoid double counting.

4.1.4 Step 4: Determine the Most Appropriate Method(s) to Calculate the

Estimates for Release and Other Waste Management Activity Quantities

After you have identified all of the potential sources for release and other waste

management activity types, you must estimate the quantities of each EPCRA Section 313

chemical and chemical category released and otherwise managed as waste. U.S. EPA has
4-18

identified four basic methods that may be used to develop estimates (each method has been

assigned a code that must be included when reporting). The methods and corresponding codes

are:

& Monitoring Data or Direct Measurement (M);

& Mass Balance (C);

& Emission Factors (E); and,

& Engineering Calculations (O).

Descriptions of these techniques are provided in the U.S. EPA publication,

Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release Inventory

Forms (1999 edition). They are also briefly described below. A more detailed discussion

including examples of selected calculation techniques is presented in Appendix B. U.S. EPA

does not require you to conduct additional sampling or testing for EPCRA Section 313 reporting;

however, you are required to use the best readily available information to determine the method

that will result in the most accurate estimate. For example, it may not be appropriate to use

emission factors or engineering calculations if more accurate data, such as stack testing results,

are available. You are required to identify the primary method used for each estimation.

Many potential sources of data exist for these (and other) methods of developing

estimates. Table 4-2 presents potential data sources and the estimation methodology in which

they are most likely to be used. Based on site-specific knowledge and potential data sources

available, you should be able to determine the best method for calculating each release and other

waste management activity quantity. 

Once all potential release and other waste management activity sources, types, and

estimation methods have been determined, an estimate for each EPCRA Section 313 chemical

and chemical category can be developed corresponding to the elements on Form R.
4-19

Table 4-2

Potential Data Sources for Release and Other Waste Management

Calculations

DATA SOURCES

Monitoring Data Mass Balance

& Air permits & Air emissions inventory

& Continuous emission monitoring & Hazardous material inventory

& Effluent limitations & Hazardous waste manifests

& Hazardous waste analysis & MSDSs

& Industrial hygiene monitoring data & Pollution prevention reports

& NPDES permits & Spill event records

& Outfall monitoring data & Supply and purchasing records

& pH for acids and bases

& POTW pretreatment standards

& RCRA permit

& Stack monitoring data

& New Source Performance Standards

& Title V permit data

Emission Factors Engineering Calculations

& AP-42 chemical specific emission factors & Facility non-chemical specific emission factors.

& Facility or trade association derived chemical- & Henry’s Law

specific emission factors & Raoult’s Law

& SOCMI* or trade association non-chemical

specific emission factors

& Solubilities

& Volatilization rates

*Synthetic Organic Chemicals Manufacturing Industry

4.1.4.1 Monitoring Data or Direct Measurement (code M)

Using monitoring data or direct measurements is usually the best method for

developing chemical release and other waste management activity quantity estimates. Your

facility may be required to perform monitoring under provisions of the Clean Air Act (CAA),

Clean Water Act (CWA), RCRA, or other statutory or regulatory requirements. If so, data should

be available for developing estimates. Data may have also been collected for your facility

through an occupational health and safety assessment. If only a small amount of direct

measurement data are available or if you believe the monitoring data are not a representative

sample (for instance, results from a worst-case scenario), you must decide if another estimation

method would give a more accurate result.
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Input + Generation = Output + Consumption

Example - Monitoring Data

Data from the on-site wastewater treatment facility indicate the annual average concentration of cobalt in the

discharge is 150 mg/L. The wastewater treatment facility processed 1.5 million gallons of water. The treated

wastewater is discharged to an off-site POTW. The amount of cobalt transferred off site to the POTW (for

Section 6.1 of the Form R) is estimated as follows:

Amount of cobalt transferred

= 1,877 lb/yr (rounded to 1,900 lb/yr with two significant figures)

COMMON ERROR - Treatment Efficiencies

Vendor data on treatment efficiencies often represent ideal operating conditions. You should adjust such data to

account for downtime and process upsets during the year that would result in lower efficiencies. Remember that

efficiencies reported by vendors are often general and may not apply to specific chemicals. For example, an

incinerator or flare may be 99.99% efficient in destroying certain organic chemicals, but will have a 0% efficiency

in destroying metals. 

4.1.4.2 Mass Balance (code C)

A mass balance involves determining the amount of an EPCRA Section 313

chemical or chemical category entering and leaving an operation. The mass balance is written as

follows:

where:

& Input refers to the materials (chemicals) entering an operation. For

example, chlorine added to process water as a disinfectant would be

considered an input to the water treatment operation.

& Generation identifies those chemicals created during an operation

(manufactured, including coincidental manufacturing). For example,

when nitrogen sources are used in biological wastewater treatment
4-21

systems, nitrate compounds and additional ammonia may be coincidentally

manufactured.

& Output refers to the materials (chemicals) leaving an operation by various

avenues. Output (avenues) may include on-site release and other on-site

waste management activities; transfers off site for recycling, energy

recovery, treatment, storage, or disposal; or the amount of chemical that

leaves with the final product. In a fabric painting operation, for example,

pigments may leave the operation as part of the product (color paint on the

fabric) or in the wastewater from the dye bath or rinse.

& Consumption refers to the amount of chemical converted to another

substance during the operation (i.e., reacted). For example, in the

phosphating process, accelerators may be added to enhance reaction speed,

eliminate hydrogen production, or sludge formation control. Several

materials can be used for this purpose, including nitrite or nitrate

compounds, which would be consumed in the process.

The mass balance technique may be applied toward manufactured, processed, or

otherwise used EPCRA Section 313 chemicals and chemical categories. It is typically most

useful for otherwise used chemicals that do not become part of the final product, such as

catalysts. For large inputs and outputs, a mass balance may not be the best estimation method

because slight uncertainties in mass calculations can yield significant errors in the release and

other waste management estimates. 

Example - Mass Balance

A facility otherwise uses a volatile EPCRA Section 313 chemical as a solvent. The facility has an on-site

recycling system for the solvent and adds 20,000 pounds to the recycling system (to make up for system losses). 

The chemical is released to the air from relief vents during system filling operations and from leaks in valves and

fittings. During system maintenance, the lines are bled directly into water and the system is vented to the air. 

Monitoring data of the wastewater, including chemical concentrations and wastewater throughput, indicate that

1,200 pounds of the chemical were discharged to the wastewater. The remaining losses are assumed to be fugitive

air release and are estimated as follows:

Fugitive air releases of the EPCRA Section 313 chemical

= Amount input (lb/yr) - Amount released to wastewater (lb/yr) 

= 20,000 lb/yr - 1,200 lb/yr 

= 18,800 lb/yr 

= 19,000 lb/yr with two significant figures
4-22

COMMON ERROR - Mass Balances for Otherwise Used Chemicals

Facilities often do not account for the entire quantity of EPCRA Section 313 chemicals that are otherwise used.

Such chemicals may or may not leave the facility with the product. For those instances where the EPCRA Section

313 chemical or chemical category does not leave the facility in the product, all throughput may be lost during

processing through on-site releases to air, water, or land, or it may be shipped off site for further waste

management. Thus, the entire throughput is often reportable on Form R as release and other waste management

activities to various media. Be sure to consider the entire throughput in these circumstances and partition it as

appropriate. A mass balance may be the best starting point to estimate the release and other waste management

quantities. Commonly overlooked sources include container residue, chemicals in dust collected in baghouses

and then sent off site, heated processes (which result in stack or fugitive air emissions), and scrap material that is

landfilled.

4.1.4.3 Emission Factors (code E)

An emission factor is a representative value that attempts to relate the quantity of

a chemical or chemical category released with an associated activity. These factors are usually

expressed as the weight of chemical or chemical category released divided by a unit weight,

volume, distance, or duration of the activity releasing the chemical (e.g., pounds of chemical

released per pounds of product produced). Emission factors, commonly used to estimate air

emissions, have been developed for many different industries and activities. You should

carefully evaluate the source of the emission factor and the conditions for its use to determine if

it is applicable to the situation at your facility. If there are more than one EPA published

emission factors, you should determine which is the most appropriate for your operations and

document your rationale.

The most widely known and used source for emission factors is U.S. EPA’s

publication Compilation of Air Pollutant Emission Factors (AP-42). Volume I of AP-42

contains information on over 200 stationary source categories, including process descriptions and

potential sources of air emissions from these processes. Methodologies for estimating the

quantity of air pollutant emissions from these sources are presented as Emission Factors. For

EPCRA Section 313 purposes only CHEMICAL-SPECIFIC emission factors can be reported as

Code “E” - Emission Factor in Part II, Section 5, Column B, Basis for estimate, of the Form R. 

AP-42 contains emission factors for individual chemicals and for the chemical group Volatile

Organic Compounds (VOCs). The VOC emission factors are NOT chemical specific and when

used must be reported in Column B as Code “O” - Engineering Calculations. Each chapter in
4-23

Volume I covers a major industry or source category. Of special interest to textile manufacturing

facilities is Chapter 4: Evaporation Loss Sources, in particular Section 4.11: Textile Fabric

Printing; Chapter 6: Organic Chemical Process Industry; and Chapter 7: Liquid Storage Tanks.

AP-42 can be accessed at the following Internet site:

& http://www.epa.gov/ttn/chief/ap42.html

In an effort to provide current emissions data in an easy-to-access format, U.S.

EPA has prepared a CD-ROM entitled Air CHIEF (Air ClearingHouse for Inventories and

Emission Factors). The Air CHIEF CD-ROM is updated annually and is available from the

Government Printing Office and can be ordered from their Web site. In addition to AP-42, the

Air CHIEF CD-ROM contains the Factor Information Retrieval (FIRE) data system, a database

management system containing U.S. EPA’s recommended emission estimation factors for

criteria and hazardous air pollutants. The CD-ROM also contains installable copies of software

programs for air emission estimation models such as “TANKS” for VOC emission from storage

tanks; “WATER8” for air emissions from wastewater systems; and “CHEMDAT8” for VOC

emissions from Treatment, Storage, and Disposal Facility (TSDF) processes. Additional

information on Air CHIEF and the CD-ROM is available at:

& http://www.epa.gov/ttn/chief/airchief.html

Your facility may have developed non-chemical-specific emission factors for

fugitive or stack emissions based on stack tests for various air permits. Be sure to consider these

emission factors if appropriate. However, if such factors are used, they are considered

“engineering calculations” for the purposes of EPCRA Section 313 reporting.
4-24

Example - Emission Factors

Emission factors have been developed for air releases of fuel constituents and combustion products from boiler

operations. AP-42 lists a range of formaldehyde emission factors when No. 6 fuel oil is consumed:

0.024 to 0.061 lb formaldehyde generated/10 gal No. 6 fuel oil fired. 3

Assuming a facility met reporting requirements for formaldehyde, the facility operating a boiler using No. 6 fuel

oil could use the above emission factor to determine the amount of formaldehyde generated and subsequently

released to the air. If 1,000,000 gallons of No. 6 fuel oil is used during a reporting year, the amount of

formaldehyde generated would be between:

(0.024 lb/10 gal) × (1,000,000 gal) and (0.061 lb/10 gal) × (1,000,000 gal) 3 3

= 24 and 61 lb of formaldehyde generated

If there are no engineering controls or air pollution control devices that would destroy or remove the

formaldehyde, this quantity should be reported in Part II, Sections 5.2 and 8.1 of the 1999 Form R.

NOTE: No. 6 fuel oil contains other EPCRA Section 313 chemicals and chemical categories and EPCRA Section

313 chemicals and chemical categories may also be coincidentally manufactured during combustion. All should

be considered for EPCRA Section 313 reporting.

4.1.4.4 Engineering Calculations (code O)

Engineering calculations are assumptions and/or judgments used to estimate

quantities of EPCRA Section 313 chemicals and chemical categories released or otherwise

managed as waste. The quantities are estimated by using physical and chemical properties and

relationships (e.g., Ideal Gas law, Raoult’s law) or by modifying an emission factor to reflect the

chemical properties of the chemical in question. Engineering calculations rely on the process

parameters; you must have a thorough knowledge of your facility operations to complete these

calculations.

Engineering calculations can also include computer models. Several computer

models are available for estimating emissions from storage tanks, landfills, water and wastewater

treatment, and other processes. 
4-25

Examples - Engineering Calculations

Example 1:

Stack monitoring data are available for xylene but you are required to report for toluene. Your facility uses

toluene and xylene for the same application and the concentrations of the chemicals in the liquid feedstock are

approximately the same. You can estimate the emissions of toluene by adjusting the monitoring data of xylene by

a ratio of the vapor pressure for xylene to toluene. This example is an engineering calculation based on physical

properties and process operation information:

From facility stack monitoring data, an estimated 200 pounds of xylene are released as air emissions during the

reporting year. Toluene is also present in the air emissions, but not monitored. The stack operates at

approximately 20 C. Based on literature data, the vapor pressure at 20 C for toluene is 22 millimeters of mercury 1 1

(mmHg) and for xylene is 6 mmHg. Using a ratio of the vapor pressures, the amount of toluene released as air

emissions from the stack can be calculated:

X lb/yr toluene = 22 mmHg (vapor pressure of toluene)

200 lb/yr xylene 6 mmHg (vapor pressure of xylene)

X lb/yr toluene = (200 lb/yr xylene) (22 mmHg toluene)

 (6 mmHg xylene)

Completing the calculation, the facility determines that 730 pounds of toluene were released as stack air emissions

during the reporting year. The quantity of toluene released should be reported in Sections 5.2 and 8.1 of the 1999

Form R.

Example 2:

A coating process uses 10,000 gallons per year of a paint that is 3% xylene by volume. All of the xylene in the

paint is assumed to evaporate during the coating operation. The coating process is equipped with a fume

collection hood that captures 80% (capture efficiency) of the paint vapors. The remaining 20% of the paint

vapors are assumed to be released as fugitive air emissions. The collection hood routes the paint vapors to an

incinerator that is vented to the atmosphere and has a destruction efficiency of 99% for xylene. The specific

gravity of xylene is 0.86 and the density of water is 8.34 lb/gal. Fugitive air emissions and stack air emissions

may be estimated as follows:

1. The total amount of xylene volatilized (assumed to be the total amount of xylene in

paint) 

= (10,000 gal/yr paint) × (0.03 xylene) × (0.86 xylene specific gravity) × 

(8.34 lb/gal, density of water)

= 2,152 lb/yr xylene evaporated from coating operations

2. The amount of xylene released as fugitive air emissions

= (2,152 lb/yr) × (0.20)

= 430 lb/yr

3. The amount of xylene released as stack air emissions

= (2,152 lb/yr) × (0.80 capture efficiency) × (1.0 - 0.99 incinerated)

= 17 lb/yr

This should be reported in Sections 5.2 and 8.1 of the 1999 Form R.
4-26

Non-chemical-specific emission factors, Synthetic Organic Chemicals

Manufacturing Industry (SOCMI) emission factors, industry-determined emission factors for

processes or equipment, and site-specific emission factors also can be used, but must be

classified as “Engineering Calculations” for EPCRA Section 313 reporting.

4.1.4.5 Estimating Release and Other Waste Management Quantities

Once all sources, types, and appropriate estimation methodologies have been

identified, you can estimate the release and other waste management activity quantities of

EPCRA Section 313 chemicals or chemical categories for each element of the Form R. The

recommended approach is that you estimate amounts from all sources at your facility to each type

as identified by the elements of Form R. Table 4-3 presents a work sheet that may be helpful in

compiling this information. 

If you prepare a Form R, you must also enter on-site treatment information in

Section 7A, including the code for each treatment method used, the destruction and removal

efficiency for the EPCRA Section 313 chemical or chemical category in the treated waste stream,

and the concentration of the EPCRA Section 313 chemical or chemical category in the influent to

treatment. You should report treatment methods that do not actually destroy or remove the

chemical by entering “zero (0)” for removal efficiency. Similarly, on-site energy recovery

methods and on-site recycling methods must be reported in Sections 7B and 7C, respectively. 
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not

associated with production process.

4-27

Table 4-3

Release and Other 

Waste Management Quantity Estimation Worksheet

Facility Name: Date Worksheet Prepared: 

EPCRA Section 313 Chemical or Chemical Category: Prepared by: 

CAS Registry Number: 

Reporting Year: 

ON SITE

Release or Other Waste Management Activity Type (lb) Estimate (1999 version)

Amount Basis of Form R Element*

FUGITIVE AIR

Equipment Leaks 5.1 and 8.1 or 8.8

Process Areas 5.1 and 8.1 or 8.8

Evaporative Losses, Spills, Surface Impoundments 5.1 and 8.1 or 8.8

Total = 5.1 and 8.1 or 8.8

STACK AIR

Process Vents 5.2 and 8.1 or 8.8

Storage Tanks 5.2 and 8.1 or 8.8

Control Device Stacks 5.2 and 8.1 or 8.8

Other 5.2 and 8.1 or 8.8

Total = 5.2 and 8.1 or 8.8

RECEIVING STREAM/WATER BODY DISCHARGE

Stormwater Discharge 5.3 and 8.1 or 8.8

On-Site Treatment Plant Discharge 5.3 and 8.1 or 8.8

Total = 5.3 and 8.1 or 8.8

ON-SITE UNDERGROUND INJECTION

Underground Injection to Class I Wells 5.4 and 8.1 or 8.8

Underground Injection to Class II - V Wells 5.4 and 8.1 or 8.8

Total = 5.4 and 8.1 or 8.8
Table 4-3 (Continued)

ON SITE

Release or Other Waste Management Activity Type (lb) Estimate (1999 version)

Amount Basis of Form R Element*

*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not

associated with production process.

4-28

ON-SITE LAND

RCRA Subtitle C Landfill 5.5 and 8.1 or 8.8

Other Landfill 5.5 and 8.1 or 8.8

Land Treatment/Application Farming 5.5 and 8.1, 8.6, or 8.8

Surface Impoundment 5.5 and 8.1 or 8.8

Other Disposal 5.5 and 8.1 or 8.8

Total = 5.5 and 8.1 or 8.8

ON-SITE ENERGY RECOVERY

Industrial Kiln 8.2

Industrial Furnace 8.2

Industrial Boiler 8.2

Other Energy Recovery Methods 8.2

Total = 8.2

ON-SITE RECYCLING

Solvents/Organics Recovery 8.4

Metals Recovery 8.4

Acid Regeneration 8.4

Other Reuse or Recovery 8.4

Total = 8.4

ON-SITE TREATMENT

Air Emissions Treatment 8.6

Biological Treatment 8.6

Chemical Treatment 8.6

Incineration/Thermal Treatment 8.6

Physical Treatment 8.6

Solidification/Stabilization 8.6

Total = 8.6
Table 4-3 (Continued)

*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not

associated with production process.

4-29

OFF SITE

Release or Other Waste Management Amount Basis of Form R Element* Off-Site Location

Activity Type (lb) Estimate (1999 version) (name)

OFF-SITE DISPOSAL

Solidification/Stabilization (metals and 6.2 and 8.1 or 8.8

metal compounds only)

Amount of metal and metal compounds to 6.1 and 8.1 or 8.8

POTW

Wastewater Treatment (excluding 6.2 and 8.1 or 8.8

POTWs) metals and metal compounds

only

Underground Injection 6.2 and 8.1 or 8.8

Landfill/Surface Impoundment 6.2 and 8.1 or 8.8

Land Treatment 6.2 and 8.1 or 8.8

Other Land Disposal 6.2 and 8.1 or 8.8

Other Off-Site Management 6.2 and 8.1 or 8.8

Total = 6.2 and 8.1 or 8.8

OTHER AMOUNTS SENT OFF SITE

Amounts sent for storage 6.2 and 8.1 or 8.8

Amounts sent for unknown waste 6.2 and 8.1 or 8.8

management practice

Total = 6.2 and 8.1 or 8.8

OFF-SITE TREATMENT

Solidification/Stabilization 6.2 and 8.7 or 8.8

Incineration/Thermal Treatment 6.2 and 8.7 or 8.8

Incineration/Insignificant Fuel Value 6.2 and 8.7 or 8.8

Wastewater Treatment (to POTW 6.1 and 8.7 or 8.8

excluding metals and metal compounds)

Wastewater Treatment (excluding POTW 6.2 and 8.7 or 8.8

and metal and metal compounds)

Sent to Waste Treatment Broker 6.2 and 8.7 or 8.8

Total = 6.2 and 8.7 or 8.8
Table 4-3 (Continued)

OFF SITE

Release or Other Waste Management Amount Basis of Form R Element* Off-Site Location

Activity Type (lb) Estimate (1999 version) (name)

4-30

OFF-SITE ENERGY RECOVERY

Off-Site Energy Recovery 6.2 and 8.3 or 8.8

Sent to Energy Recovery Broker 6.2 and 8.3 or 8.8

Total = 6.2 and 8.3 or 8.8

OFF-SITE RECYCLING

Solvents/Organics Recovery 6.2 and 8.5 or 8.8

Metals Recovery 6.2 and 8.5 or 8.8

Other Reuse or Recovery 6.2 and 8.5 or 8.8

Acid Regeneration 6.2 and 8.5 or 8.8

Sent to Recycling Waste Broker 6.2 and 8.5 or 8.8

Total = 6.2 and 8.5 or 8.8

*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not

associated with production process.
4-31

4.2 Textile Industry and Process Description

The textile industry includes multiple processes and activities. Many facilities

may only perform a subset of the four major textile manufacturing operations and may use only

one raw material type. This section discusses the recommended approach for estimating

quantities of EPCRA Section 313 chemicals or chemical categories for each operation. You

should evaluate the processes at your facility and determine which operations apply. The four

textile operations discussed are: 

& Yarn Formation: preparing and spinning raw materials (natural and synthetic);

texturizing man-made filament fibers.

& Fabric Formation: warping and slashing yarn; performing weaving and knitting

operations.

& Wet Processing: preparing the fabric for dyeing and finishing; dyeing, printing,

and finishing operations.

& Product Fabrication: cutting and sewing the fabric, performing final finishing

operations.

Figure 4-3 provides a schematic view of a typical textile processing operation.
4-32

Figure 4-3. Typical Textile Processing Flow Diagram

Source: U.S. EPA, Profile of the Textile Industry, Office of Enforcement and Compliance Assurance, 1997.
4-33

The following sections present specific information on textile processes, release

and other waste management sources and types, and sample calculations for estimating release

and other waste management quantities for each of the four operations.

4.2.1 Yarn Formation

In the yarn formation process, fibers are bound using spinning operations,

grouping, and twisting. Staple fibers, natural and man-made, are prepared for spinning through a

combination of various processing steps such as blending, drawing, carding, opening, combing,

and roving. These operations are primarily mechanical; but can include some chemical activities

for the removal of impurities from the fiber and for machine maintenance. Man-made filament

fibers may be manufactured using EPCRA Section 313 chemicals and chemical categories. 

Processing of these fibers, known as texturizing, can result in the removal and subsequent release

and other waste management activities of the EPCRA Section 313 chemicals and chemical

categories from the fiber. The use of EPCRA Section 313 chemicals is not common, however,

you should review what chemicals are manufactured, processed, or otherwise used during yarn

formation.

For EPCRA Section 313 reporting, it is important to identify all release and other

waste management activity sources and types for each of the EPCRA Section 313 chemicals and

chemical categories being reported. Remember to include both routine and accidental release

and other waste management activities. 

Step 1: Prepare a Process Flow Diagram

A site-specific process flow diagram should be prepared to help identify all

potential sources and types of chemical release and other waste management activities. Figure

4-4 presents a typical yarn formation process and the possible release and other waste

management sources by unit operation. A textile facility may not employ all of these processing

steps; each facility should prepare its own diagram to reflect current unit operations.
4-34

Figure 4-4. Typical Yarn Formation Process Flow Diagram

Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and

Potential Sources of Chemical Release and Other Waste Management

Activities

EPCRA Section 313 chemicals and chemical categories are not commonly

employed during yarn formation; however, EPCRA Section 313 chemicals or chemical

categories may be processed or otherwise used during cleaning operations, or brought on site

with the material. Potential liquid sources of EPCRA Section 313 chemicals and chemical

categories include used oil, lubricants, and other machine maintenance chemicals. Solid waste

sources include excess or waste yarn that may contain EPCRA Section 313 chemicals and

chemical categories. This excess yarn is typically generated during texturizing, carding, and

spinning. 
4-35

Step 3: Identify Release and Other Waste Management Activity Types

Oils, lubricants, machine maintenance chemicals, and waste yarn and material are

typically released on site to land or sent to off-site disposal. Off-site recycling may also be

performed, but is not typical. Depending on your facility processes, you should evaluate the

disposal and other waste management activities for these sources.

Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for

Release and Other Waste Management Activity Quantities

The most typical estimation methods for yarn formation, and the textile industry

in general, are mass balances and engineering calculations. Purchasing records, along with

MSDSs can be used to determine the total amount of a chemical brought on site. Operational

data may be used to determine the quantity of the chemical processed or otherwise used in each

unit operation. Engineering assumptions and process knowledge can help to determine the

ultimate fate of the chemical(s). 

Example -Mass Balance for Machine Maintenance Chemical

A textile facility otherwise uses an EPCRA Section 313 machine maintenance chemical. The chemical is

collected and sent off site for recycling. Purchasing records show that five shipments of the chemical (5,000

pounds each) were received during the year, totaling 25,000 pounds of the chemical brought on site. Inventory

records list 3,000 pounds of the chemical on site January 1 and 2,000 pounds on site December 31. The total

amount of the chemical used during the year is calculated below:

Amount Used: 25,000 lb + 3,000 lb - 2,000 lb = 26,000 lb

Shipping records show that 24,000 pounds of the EPCRA Section 313 chemical were collected and sent off site

for recycling. Based on process knowledge, the remaining amount of the chemical was disposed on site.

Amount Disposed: 26,000 lb Used - 24,000 lb Recycled = 2,000 lb

Textile facilities may manage solid waste, such as scrap yarn, by on-site or off-site

land disposal. RCRA reports and hazardous waste manifests are potential sources of information

for concentrations of EPCRA Section 313 chemicals and chemical categories and the volume of

the waste disposed. 
4-36

4.2.2 Fabric Formation

From the spun or filament yarn, fabric is formed by knitting or weaving

operations. Yarn can be processed directly through knitting operations but typically requires

preparation for weaving operations. Preparation for weaving includes warping and slashing

(sizing). Sizing agents added to the yarn by solution or pad/dry techniques may contain EPCRA

Section 313 chemicals and chemical categories. Other chemical additives may be added to

increase yarn softness and pliability. Following drying operations, yarn may then be woven into

fabric. Like yarn formation, both knitting and weaving operations are primarily mechanical. 

Chemical activities include the addition of sizing agents and chemical additives and the use of

machine maintenance and cleaning chemicals.

Step 1: Prepare a Process Flow Diagram

A site-specific process flow diagram should be prepared to help identify all

potential sources and types of chemical release and waste management activities. Figure 4-5

shows a typical fabric formation process and the possible release and other waste management

sources by unit operation. A facility may perform only knitting or only weaving operations; each

facility should prepare its own diagram to reflect current unit operations.

Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and

Potential Sources of Chemical Release and Other Waste Management

Activities

EPCRA Section 313 chemicals and chemical categories are primarily otherwise

used during fabric formation as fabric processing agents and equipment cleaning and

maintenance chemicals. Fabric processing agents include sizing agents and performanceenhancing chemicals. Typical chemicals may include certain glycol ethers, ethylene glycol, and

methanol. These chemicals typically volatilize or are washed off during fabric formation. 

However, some may remain with the fabric throughout the fabric formation process and into the

wet processing and finishing operations.
4-37

Both fugitive and point source air emissions containing EPCRA Section 313

chemicals and chemical categories typically occur during the slashing (sizing) operation or

during fabric drying operations. This includes chemicals used as sizing agents or performanceenhancing chemicals. Dust air emissions may also be generated during fabric formation, but will

most likely be collected for disposal. 

Potential liquid sources of EPCRA Section 313 chemicals and chemical

categories include process wastewater from fabric cleaning and slashing operations; used oil,

lubricants, and other machine maintenance chemicals; and wastewater from aqueous equipment

cleaning operations. Process equipment cleaning operations do not qualify for the routine

janitorial maintenance exemption.

Solid waste is the most common release and other waste management source from

fabric formation. The primary source of solid waste is excess fabric material and scraps that may

contain EPCRA Section 313 chemicals and chemical categories not volatilized or removed

during fabric formation or chemicals brought on-site with the raw material (e.g., antimony oxide

used as a fire resistant). Another solid waste source is dust containing EPCRA Section 313

chemicals and chemical categories that is collected by air pollution control devices or by floor

sweepings. These solid wastes are usually generated during knitting or weaving operations. 

During slashing operations, residue left in sizing agent or other chemical agent containers may be

a source of EPCRA Section 313 chemicals and chemical categories.
4-38

Figure 4-5. Fabric Formation Process for Producing Flat Fabrics

Step 3: Identify Release and Other Waste Management Activity Types

Both fugitive and point source air emissions are typical EPCRA Section 313

release and other waste management types during fabric processing. Fugitive emissions are most

likely to result from slashing and drying operations when chemicals, such as methanol,

evaporate. Dusts containing EPCRA Section 313 chemicals and chemical categories may be

generated as potential fugitive emissions; however, they are typically collected (e.g., ventilation

system filters, baghouses, etc.) and otherwise managed as waste. If air from any process is

controlled through an air pollution control device, such as a scrubber, any chemical release from

the device is considered to be point source, or stack emissions. Remember that metals and metal

portions of metal compounds cannot be destroyed, but should still be reported as being sent

through the treatment process, with a treatment efficiency of zero. Section 7A and 8.6 should be

completed as appropriate (see example in Section 4.1.3(h)). Fugitive dust emissions may escape

from air pollution control devices such as a baghouse (baghouses are typically 95 to 99 percent

efficient in capturing dust particles). 

Facilities typically combine wastewater streams from operations such as

equipment cleaning, fabric cleaning, and slashing. This waste stream is then usually sent to a
4-39

POTW. A facility may also perform on-site treatment prior to discharging to a POTW or

receiving stream. 

Fabric scraps and dust containing EPCRA Section 313 chemicals and chemical

categories are typically sent off site for disposal, but your facility may have another waste

management activity for scraps. Keep in mind that dusts may be collected in floor sweepings or

in air pollution control devices, such as baghouses. Oils, lubricants, and other machine operating

aids may be sent off site for disposal, treatment, or recycling. Containers that may have residual

EPCRA Section 313 chemicals and chemical categories are often sent back to the supplier for

reuse (see Section 4.1.3 for examples pertaining to container residue).

Table 4-4 presents the most common release and other waste management activity

types and EPCRA Section 313 chemicals typical to fabric formation operations.

Table 4-4

Common EPCRA Section 313 Chemicals and Chemical Categories Associated

with Release and Other Waste Management Activity Types During Fabric

Formation

Release and Other Common EPCRA Section 313 Chemicals and

Waste Management Activity Types Chemical Categories

Fugitive Air Release Ammonia

Methanol

Point Source Air Release Ammonia

Methanol

POTW Ammonia

Ethylene glycol

Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for

Release and Other Waste Management Activity Quantities

The most typical estimation methods for fabric formation are mass balances and

engineering calculations. Information sources for mass balances include purchasing records,

MSDSs, and operational data. Using engineering assumptions and process knowledge, you can
4-40

determine whether an EPCRA Section 313 chemical or chemical category is released and

otherwise managed as waste or remains in the product. You must also determine to which media

a chemical is released and otherwise managed as waste.

Both dusts and chemical emissions may be generated during fabric formation. 

Volatile chemicals not intended to remain in the fabric will most likely evaporate during

processing or drying operations. Emission factors and engineering calculations are the most

common approaches to calculating air release and other waste management amounts. Chemicalspecific emission factors are not often available for typical textile processing operations. 

However, you can use general emission factors found in AP-42 in conjunction with engineering

calculations to estimate quantities of EPCRA Section 313 chemicals and chemical categories

emitted to air (remember that non-chemical-specific emission factors are considered to be

engineering calculations for EPCRA Section 313 reporting). 

Emission factor and engineering calculation sources include AP-42 emission

factors, facility specific emission factors, SOCMI emission factors, and worker exposure data. 

Other data sources include operating permits, monitoring data, and air pollution control device

information, such as testing data and control efficiency. Mass balances may also be used to

estimate emissions by subtracting all other known release and other waste management activity

amounts from the total amount used in the process, as shown in the following example.

Example -Mass Balance for Air Estimates

Your facility used 20,000 pounds of perchloroethylene to dry clean samples. Your dry cleaning operation area

has no air control devices. Manifests show that 5,000 pounds of spent perchloroethylene was sent off site for

disposal. You can calculate the air releases of perchloroethylene as follows:

Amount Released as Fugitive Emissions to Air = 20,000 lb used - 5,000 lb to off-site disposal

 = 15,000 lb perchloroethylene released to air 

When preparing the Form R for perchloroethylene, be sure to use the correct EPCRA Section 313 chemical name,

tetrachloroethylene. A list of common EPCRA Section 313 chemical synonyms is located in U.S. EPA’s Common

Synonyms for Chemicals Listed Under Section 313 of EPCRA. (EPA 745-R-95-008), May 1995.

Dust containing EPCRA Section 313 chemicals and chemical categories may be

collected by an air pollution control device or swept from floors as solid waste. Using

engineering calculations, the amount of an EPCRA Section 313 chemical or chemical category
4-41

present in the dust may be estimated using the chemical concentration in the fabric and the

amount of dust generated. If the amount of dust generated is unknown, a mass balance, using

purchasing and production information, may be used to estimate the quantity.

In addition to RCRA reports and hazardous waste manifests, accidental spill

records may supply information on solid waste release and other waste management activities. 

These records may include chemical concentrations and amount of waste disposed on site or

collected for other release and waste management activities.

For information on calculating wastewater release and other waste management

quantities, see Section 4.2.3 (Wet Processing), Step 4.

4.2.3 Wet Processing

Wet processing enhances appearance, durability, and serviceability of the fabric. 

Chemical agents, such as dyes, pigments, strength agents, and flame resistors are applied through

a water-intensive process. Synthetic materials may be desized and scoured prior to dyeing or

printing. After preparation for wet processing, dyeing or printing can occur, followed by rinsing,

drying, or heat setting. Printing operations typically do not use water. The final wet processing

step is mechanical and chemical finishing; these operations are used to improve appearance,

texture, and performance of the fabric.

Dye application includes various dye types and methods. Equipment commonly

used for textile dyeing includes beck, beam, jet, jig, package, pad, and vat dyeing machines. 

Dyes can be fixed to the textile chemically and/or physically. Dyes may be bonded to the fabric

or precipitated by removal of a dye solubilizing agent. Color patterns can also be added to fabric

using printing techniques such as rotary screen, direct, discharge, resist, flat screen, and roller

printing. Color can be affixed through the use of pigments, solvents, and resin binders.
4-42

Figure 4-6. Wet Processing Fabric Preparation Flow Diagram

Source: U.S. EPA, Profile of the Textile Industry, Office of Enforcement and Compliance Assurance, 1997.
Printing/Dyeing

Drying/Heat

Setting

Mechanical

Finishing

Chemical

Finishing

Fabric

To Product

Fabrication

Finishing

Chemicals

Fugitive or Stack Air

Fugitive or Stack Air

Fugitive or Stack Air

(dusts, volatile

chemicals)

(overspray, volatile

chemicals)

(container

residue,

fabric scrap)

(volatile

chemicals)

(solvents)

(solvents)

(exhausted

bath water,

rinsewater)

(cleaning water,

rinsewater)

Fugitive or Stack Air

On-Site or Off-Site Energy Recovery

On-Site or Off-Site Recycling

Fugitive or Stack Air

On-Site or Off-Site Energy Recovery

On-Site or Off-Site Recycling

Discharge to Receiving Stream

Discharge to POTW

On-Site Treatment

Off-Site Treatment

Discharge to Receiving Stream

Discharge to POTW

On-Site Treatment

Off-Site Treatment

Off-Site Disposal

Off-Site Treatment

Off-Site Recycling

Process Flow

Potential Waste Stream Sources

i:\graphics\tri\figures\textile1.cdr

4-43

Figure 4-7. Wet Processing Printing, Dyeing, and Finishing Flow Diagram

Source: U.S. EPA, Profile of the Textile Industry, Office of Enforcement and Compliance Assurance, 1997.

Step 1: Prepare a Process Flow Diagram

A site-specific process flow diagram should be prepared to help identify all

potential sources and types of chemical release and other waste management activities. Figures

4-6 and 4-7 present wet processing flow diagrams, including preparation and dyeing, printing,

and finishing steps. The typical release and other waste management sources are shown by unit

operation. The diagram shows two fabric preparation paths, one for synthetic fiber (e.g., nylon)

and one for natural fiber (e.g., cotton, cotton blends).
4-44

Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and

Potential Sources of Chemical Release and Other Waste Management

Activities

For the textile industry, wet processing operations are significant sources of

EPCRA Section 313 chemical and chemical category release and other waste management

activities. Typical chemicals include ammonia, certain glycol ethers, and methyl ethyl ketone. 

Alkaline or solvent solutions are used during scouring. Solvents, although used in the past, are

being replaced with aqueous chemicals. Bleaching agents and other chemical additives are used

during bleaching operations, however, these are usually not EPCRA Section 313 chemicals. 

Acids are used for neutralizing remaining caustic soda during mercerizing operations. During

dyeing or printing operations, chemicals such as solubilizing agents, dye carriers, salts, and fixing

agents may be employed to speed the process or enhance the process effects. Chemical activities

during finishing operations include the use of optical brighteners, softeners, and flame resistant

chemicals. 

During fabric preparation, air emissions of chemicals may be generated from

sources such as desizing, scouring, and singeing operations. Dusts containing EPCRA Section

313 chemicals and chemical categories and volatile EPCRA Section 313 chemicals and chemical

categories may be emitted from sources such as printing and dyeing operations. EPCRA Section

313 chemicals and chemical categories may volatilize during drying, heat setting, and finishing

operations. Other sources of EPCRA Section 313 chemical and chemical category air emissions

are tanks that are used to store process chemicals prior to use in the wet process and the loading

and unloading operations associated with these chemicals.

The primary liquid sources of EPCRA Section 313 chemicals and chemical

categories are spent process baths, solutions, and rinses. Process wastewater sources include

spent sizing solutions, scouring and dyeing baths, cleaning rinses, dyeing rinses, textile cleaning

water, and mercerizing operations. Chemicals typically found in textile industry wastewater

include dyes, pigments, and salts. Salts present in process wastewater may have been used as

raw materials (e.g., metal compound salts) or may be byproducts from neutralization or other

chemical reactions (e.g., nitrate compounds). Metal compounds such as copper compounds and

chromium compounds are also commonly present in process wastewater streams. Other liquid
4-45

sources include equipment cleaning wastewater, container cleaning wastewater, and used

lubricants and other machine operating aids. Cleaning solvents may become part of the

wastewater after scouring operations and equipment cleaning. Note that process equipment

cleaning operations do not qualify for the routine janitorial maintenance exemption.

Solid waste sources are similar to those found in yarn and fabric formation

operations. Potential sources include textile and fabric scrap or off-specification product

containing EPCRA Section 313 chemicals and chemical categories, dusts containing EPCRA

Section 313 chemicals and chemical categories, container residue, and machine operating aids. 

Step 3: Identify Release and Other Waste Management Activity Types

Fugitive and stack air emissions of EPCRA Section 313 chemicals and chemical

categories occur during wet processing operations. Fugitive releases may include carrier

chemicals such as formaldehyde. Fugitive emissions may result from singeing, desizing,

scouring, printing, dyeing, drying, and finishing operations when chemicals evaporate. If the air

emissions from any operation are captured by an air pollution control device, any releases from

the device are considered to be point air releases. Also, air emissions from tank vents are

classified as point air releases for EPCRA Section 313 reporting. As with fabric formation,

dusts containing EPCRA Section 313 chemicals and chemical categories may be generated as

fugitive emissions, however, the sources of these emissions are primarily the weighing and

unloading of chemicals for use in the process. These dusts may be controlled by a baghouse or

collected for disposal. Section 4.2.2 contains additional discussion on air pollution control

devices, such as baghouses. Section 7A and 8.6 should be completed as appropriate (see

example in Section 4.1.3(h)).
4-46

COMMON ERROR - Reporting Carrier Chemicals

Typically, carrier chemicals are otherwise used, and you can assume none of the chemical remains with the textile

product. Therefore, the total amount of the chemical should be accounted for through air releases, amounts

captured or destroyed in control devices, and amounts sent off site. The total amount is best determined from

purchasing records.

Another common reporting error is overestimation of the amount of chemical in waste sent off site. If testing data

is available, the quantity of waste sent off site should be based on an analysis of the waste. See Section 4.1.4.1 for

information on the use of monitoring data. The total amount of waste shipped off site must be adjusted for the

chemical concentration. Many off-site disposal facilities that receive waste will provide information on the

concentration and quantity of a chemical present in each shipment. This information is a key component of a

mass balance for estimating chemical release and other waste management quantities.

The wet processing operations generate the majority of wastewater in textile

processes. Typically, the wastewater is sent to a POTW or to another off-site location for waste

treatment. In addition, facilities may perform on-site wastewater treatment prior to discharge to a

POTW or a receiving stream.

Solid waste containing EPCRA Section 313 chemicals or chemical categories may

result in release and other waste management activity types such as disposal or recycling. 

Textile or fabric scraps, off-specification product, and dust are typically disposed of off site, but

your facility may have other waste management activities. If the solid waste contains any

EPCRA Section 313 chemicals or chemical categories, the amount sent off site or handled on site

needs to be included during release and other waste management calculations. Keep in mind that

dusts may be collected in floor sweepings or in air pollution control devices, such as baghouses. 

Oils, lubricants, and other machine operating aids may be disposed on site or sent off site for

disposal or recycling. Containers that may have residual EPCRA Section 313 chemicals or

chemical categories may be disposed, otherwise waste managed, or returned to the supplier for

reuse. Calculating container residue quantities is described in Section 4.1.3(g). If on-site waste

treatment is performed, sludges may be generated and then sent off site for disposal or other

waste management activities. 

Table 4-5 presents common release and waste management types and EPCRA

Section 313 chemicals typical to wet processing operations.
4-47

Table 4-5

Common EPCRA Section 313 Chemicals and Chemical Categories Associated

with Release and Other Waste Management Activity Types During Textile

Wet Processing

Release and Other

Waste Management Activity Types Common EPCRA Section 313 Chemicals and Chemical Categories

Fugitive Air Release Certain glycol ethers Ammonia

Formaldehyde Methanol

Point Source Air Release Ammonia Formaldehyde

Methanol Certain glycol ethers

Water Release Certain glycol ethers Formaldehyde

POTW Ammonia Certain glycol ethers

Ethylene glycol Formaldehyde

On-Site Treatment Certain glycol ethers Formaldehyde

Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for

Release and Other Waste Management Activity Quantities

 Mass balances combined with engineering calculations are the most widely used

estimation methods for textile operations. Information that may be needed for completing the

mass balance includes operational data such as batch recipes, inventory records, and production

records. This can be used to determine the quantity of the EPCRA Section 313 chemical or

chemical category that has been used on site. MSDSs contain information on EPCRA Section

313 chemicals and chemical categories contained in mixtures purchased by the facility that may

also be used for mass balances. Finally, knowledge of your facility processes and engineering

calculations may be used to determine how much of a chemical remains with the fabric. For air

emission estimates, emission factors or engineering calculations may be used. Section 4.2.2

provides additional information on air emission calculations. The example below shows how

vendor data may be used to estimate releases and other waste management activities of air

emissions.
4-48

Example - Air Pollutant Controls for Chemical Finishing

Your facility uses 30,000 pounds of an organic coating with a 15% concentration of toluene, present as a solvent,

during finishing operations. You have exceeded a threshold for toluene in other processes at your facility. In this

example, it is assumed that the solvent volatilizes completely in the dryer. The dryer vent stack leads to a

scrubber, which has a vendor-specified removal efficiency of 95 percent for volatile organic compounds. The

scrubber water is then sent directly to a POTW.

The amount of toluene emitted to the dryer vent stack is:

(30,000 lb organic coating) × (0.15) = 4,500 lb toluene

Stack Air Release:

The amount of toluene passing through the scrubber and released as stack air is:

(4,500 lb toluene) × (1 - 0.95) = 225 lb

This quantity should be reported in Part II, Section 5.2 and Part II, Section 8.1 on the RY 1999 Form R.

Discharge to POTW:

The remaining toluene is discharged with the scrubber water:

(4,500 lb toluene) × (0.95) = 4,275 lb

This quantity should be reported in Part II, Section 6.1 and Part II, Section 8.7 (Quantity Treated Off Site) as

appropriate.

Wet processing operations are water-intensive and calculating the quantity of

EPCRA Section 313 chemicals and chemical categories released and otherwise managed as

waste through process wastewater streams may be the most logical first step. Non-volatile

EPCRA Section 313 chemicals and chemical categories that are otherwise used often become

part of the process wastewater.

Your facility may have wastewater monitoring data that is more appropriate than

mass balance calculations. Data containing chemical concentrations and stream throughput is

often collected before discharges to a POTW or to a receiving stream (see Appendix B for an

example of how to use NPDES monitoring data to estimate discharges to a receiving stream).
4-49

Example - Nonvolatile Wet Processing Chemical

Your facility receives and otherwise uses a surfactant solution in 500-pound steel drums with a concentration of

10% of a nonvolatile EPCRA Section 313 chemical. The solution is pumped from the drum directly into the

process. In this example, you must determine the quantity of this chemical released and otherwise managed as

waste from this use. It is assumed that you have exceeded a threshold due to activities involving the chemical

elsewhere at your facility.

During the year, you receive and otherwise use 150 drums of the solution. The empty drums are then sent off site

to a landfill. The total amount of the EPCRA Section 313 chemical received and subsequently used is:

(500 lb) × (0.10) × (150 drums) = 7,500 lb

You have determined that none of the surfactant solution remains with the final product; rather, all that is

introduced into the process is ultimately discharged with process wastewater to a POTW. Table 4-1 lists residue

quantities that would remain in the drum after use, in weight percent of container capacity. The mean residue

quantity for a surfactant solution in a steel drum that is emptied via pumping is 3.06%. The following amounts of

the nonvolatile EPCRA Section 313 chemical should be reported:

Sent to Off-Site Land Disposal:

(7,500 lb) × (0.0306) = 230 lb

This quantity should be reported in Part II, Section 6.2 and Part II, Section 8.1 of the RY 1999 Form R.

Discharged to POTW:

(7,500 lb) × (1.0 - 0.0306) = 7,270 lb

This quantity should be reported in Part II, Section 6.1 and Part II, Section 8.7 of the RY 1999 Form R.

Textile dyeing operations use various bath constituents that may contain EPCRA

Section 313 chemicals and chemical categories. Although these chemicals are intended to

remain with the fabric, some, such as dyes, may be left in the bath process water. The amount of

dye and dye components remaining in the process water can be calculated using fixation values

as shown in the following equation.

Dye remaining in process water = Dye Input × (1 - fixation)

The fixation value can be based on facility data, manufacturer’s information, or a published

factor. An average fixation value may be appropriate to determine the annual amount of dye lost

to the process water for facilities with large volumes and variations in processes. Table 4-6 lists
4-50

some common fixation values by dye type that may be appropriate if site-specific information is

not available.

Table 4-6

Typical Dye Fixation Values

Dye Class Typical Fixation (%)

Acid 80 - 93

Basic 97 - 98

Direct 70 - 95

Disperse 80 - 92

Reactive 60 - 90

Sulfur 60 - 70

Vat 80 - 95

Source: U.S. EPA. Profile of the Textile Industry. Office of Enforcement and

Compliance, 1997.

Example - Using Engineering Calculations to Estimate Dye Chemicals in Process

Wastewater (Dye Fixation Values)

Metals in process wastewater are expected to be present from textile dyeing operations or from the use of dyeing

aids. If no monitoring data exist, the quantity can be calculated using dye fixation data. 

For example, your facility uses a chromium-complex dye with 2 weight percent chromium. From process

information, you know typically 85% of the dye becomes fixed on the fabric. If 10,000 pounds of the chromium

complex dye is used annually, the amount of chromium expected in the process water can be calculated as shown

below.

 Amount of Chromium in Process Water = (Weight of dye used) × (Weight % chromium) × (1 - fixation)

= (10,000 lb) × (0.02) × (1-0.85)

= 30 lb chromium

If you operate a continuous dyeing or printing process, include any amount of

unused dye or pigment removed and subsequently released and otherwise managed as waste from

the process in your calculations, as appropriate. Also include losses due to screen washing for

printing processes. Estimates should be based on knowledge of unused bath volume and

concentration of chemicals in the bath.
4-51

Process wastewater may be directly discharged or treated at an on-site or off-site

treatment system. If you discharge directly to a surface water, you should have a NPDES or

SPDES permit for your facility. This permit may require monitoring, may limit discharges, and

may contain other information to help you determine the amount of EPCRA Section 313

chemicals that are discharged. A calculation example using NPDES permit data has been

provided in Appendix B. Alteratively, if you indirectly discharge to a POTW, the wastewater

may require pretreatment, monitoring, sampling and testing of the treated effluent, and flow rate

measurements. This information can be used to estimate the quantities discharged in a manner

similar to that presented in the example using NPDES data.

Example - Chromium Compounds in Wastewater

Your textile processing facility otherwise uses 11,000 pounds per year of a chromium compound, specifically,

sodium dichromate (Na Cr O ) as a metal salt. 2 27

For metal compounds, such as Na Cr O , you must apply the entire weight of the compound toward the threshold 2 27

determination, therefore the otherwise used threshold (10,000 pounds per year) has been exceeded. You must

report all releases and other waste management activity amounts for the parent metal, chromium.

When calculating release and other waste management activity amounts for reporting, use only the weight of

parent metal in the compound. The weight of chromium per pound of sodium dichromate must be determined

using the following atomic weights: Cr = 52.0 Na = 23.0 O = 16.0

In this example, engineering judgement is used to assume that all the sodium dichromate is removed from the

process with the exhausted bath water. The amount of chromium in the wastewater from sodium dichromate can

then be determined as follows:

Amount of chromium in wastewater =

You must report this amount on a Form R (not on a Form A), since the reportable amount exceeds 500 lb/yr. If

the wastewater is sent to a POTW, this amount should be reported in Part II, Section 6.1 of the 1999 Form R. If

the wastewater is discharged to a receiving stream, show this amount in Part II, Section 5.3 of the Form R. 

Remember that metals sent to a POTW are not considered to be treated for destruction. Therefore, they should

also be reported in Part II, Section 8.1, Quantity Released, not in Part II, Section 8.7, Quantity Treated Off Site.
4-52

COMMON ERROR - Acids and Bases

If you use an EPCRA Section 313 mineral acid or base at your facility, but it is effectively neutralized to a pH

between 6 and 9, EPA considers the quantity in the resulting stream to be less than 0.5 pound. You should report

“zero” for the appropriate release and other waste management activity quantity. Keep in mind that the

neutralization of an acid or base may result in the coincidental manufacture of another EPCRA Section 313

chemical. For example, neutralization of nitric acid in wastewater will coincidentally manufacture water

dissociable nitrate compounds as a byproduct.

Also note any qualifiers for EPCRA Section 313 chemicals. For example, sulfuric acid and hydrochloric acid are

only reportable as aerosols; therefore, any quantity of these acids that is released or otherwise managed as waste

in solution should not be considered in the quantity reported.

4.2.4 Product Fabrication

Product fabrication includes cutting and sewing of the fabric to form the finished

product. Some mills are stand-alone facilities and receive the dyed fabric from an off-site

facility. Product fabrication mills need to determine which EPCRA Section 313 chemicals and

chemical categories may be contained in the fabric received from off site.

Step 1: Prepare a Process Flow Diagram

Figure 4-8 shows a typical product fabrication operation. A site-specific process

flow diagram should be prepared to help identify all potential sources and types of chemical

release and waste management activities. 
4-53

Figure 4-8. Textile Product Fabrication Process Flow Diagram

Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and

Potential Sources of Chemical Release and Other Waste Management

Activities

As with yarn and fabric formation, EPCRA Section 313 chemicals and chemical

categories may be present in solid textile scraps. These wastes are often generated from textile

cutting and sewing operations. EPCRA Section 313 chemicals and chemical categories may also

be used for equipment cleaning operations.

Potential liquid sources of EPCRA Section 313 chemicals and chemical

categories include wastewater from equipment cleaning operations and used oil, lubricants, and

other machine maintenance chemicals. Note that process equipment cleaning operations do not

qualify for the routine janitorial maintenance exemption. Process wastewater may included any

finishing chemical solutions used in the process.

The primary source of solid waste is excess fabric material and scraps that may

contain EPCRA Section 313 chemicals and chemical categories not volatilized or removed

during processing. Another solid waste source is collected dust containing EPCRA Section 313
4-54

chemicals or chemical categories. These solid wastes are usually generated during textile cutting

operations. 

Step 3: Identify Release and Other Waste Management Activity Types

Dusts containing EPCRA Section 313 chemicals and chemical categories may be

generated as fugitive emissions, however, the dust is not typically released, rather it is often

collected and otherwise managed as waste. 

Solid waste sources of EPCRA Section 313 chemicals and chemical categories

from product fabrication may result in release and waste management activity types such as

disposal or recycling. Fabric scraps and dust are typically disposed of off site, but your facility

may have another waste management activity for scraps. The ultimate disposition of EPCRA

Section 313 chemicals and chemical categories in the dust should be reported as appropriate. 

Any scrap materials from final product components must also be considered when determining

the amount of an EPCRA Section 313 chemical that is released and otherwise managed as waste. 

Oils, lubricants, and other machine operating aids may be disposed or sent off-site for recycling.

Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for

Release and Other Waste Management Activity Quantities

As with yarn formation (See Section 4.2.1, Step 4), the most typical estimation

methods for product fabrication are mass balances and engineering calculations. Information

sources for mass balances include purchasing records, MSDSs, and operational data. Using

engineering assumptions and process knowledge, you can determine how much of an EPCRA

Section 313 chemical or chemical category is released and otherwise managed as waste with

fabric scraps and how much becomes part of the final product. See the previous Step 4

discussions in Sections 4.2.1 through 4.2.3 for information on how to use a mass balance for

estimating the quantities of EPCRA Section 313 chemicals released and otherwise managed as

waste.
Appendix A

TRI GUIDANCE RESOURCES
A-1

Appendix A

TRI GUIDANCE RESOURCES

A.1 EPCRA Section 313 RELATED REFERENCES

40 CFR 372, Toxic Chemical Release Reporting; Community Right-to-Know; Final Rule

See 53 FR 4500, February 16, 1988.

Toxic Chemical Release Inventory Reporting Forms and Instructions for the Current Reporting

Year - See also Automated Toxic Chemical Release Inventory Reporting Software (ATRS) under

Section A.2, Internet Sites.

U.S. EPA publishes this document each year to provide current guidance for preparing the Form

R and Form A reports. This document contains the most up-to-date list of chemicals for which

reports are required. It includes a blank Form R and Form A and provides step-by-step

instructions for completing each report. It also has a list of U.S. EPA regional and state contacts

for EPCRA Section 313 reporting. The current version of this document should always be

consulted in preparing the EPCRA Section 313 report.

Common Synonyms for Chemicals Listed Under EPCRA Section 313 of the Emergency

Planning and Community Right-to-Know Act (EPA 745-R-95-008)

This glossary contains chemical names and their synonyms for substances covered by the

reporting requirements of EPCRA Section 313. The glossary was developed to aid in

determining whether a facility manufactures, processes, or uses a chemical subject to EPCRA

Section 313 reporting.

Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-toKnow Act (EPCRA) and Section 112(r) of the Clean Air Act (as amended) (EPA 740-R-95-001)

List of chemicals covered by EPCRA Sections 302 and 313, CERCLA Hazardous Substances,

and CAA 112(r). The list contains the chemical name, CAS Registry Number, and reporting

requirement(s) to which the chemical is subject. 

Data Quality Checks to Prevent Common Reporting Errors on Form R/A (EPA 745-R-98-012)

The Emergency Planning and Community Right-to-Know Act: EPCRA Section 313 Release

Reporting Requirements, August, 1995 (EPA 745/K-95-052)

This 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 U.S. 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.

EPCRA Section 313 Questions and Answers: 1998 Version, (EPA 745-B-98-004).

Executive Order 12856 - Federal Compliance with Right-to-Know Laws and Pollution

Prevention Requirements: Questions and Answers (EPA 745-R-95-011)

This document assists federal facilities in complying with Executive Order 12856. This

information has been compiled by U.S. EPA from questions received from federal facilities. This

document is intended for the exclusive use of federal facilities in complying with Sections 302,
A-2

303, 304, 311, 312, and 313 of the Emergency Planning and Community Right-to-Know Act

(EPCRA) of 1986 and the Pollution Prevention Act of 1990, as directed by the Executive Order.

Supplier Notification Requirements (EPA 560/4-91-006)

This pamphlet assists chemical suppliers who may be subject to the supplier notification

requirements under EPCRA Section 313. The pamphlet explains the supplier notification

requirements, gives examples of situations which require notification, describes the trade secret

provision, and contains a sample notification.

Toxic Chemical Release Inventory - Data Quality Checks to Prevent Common Reporting Errors

on Form R/Form A (EPA 745-R-98-012)

This is a compilation of Notices of Data Change, Significant Error, Noncompliance, or Technical

Error. It provides a listing of common errors found on the Form R reports submitted to U.S.

EPA. It also provides a discussion of the types of errors which result in each of the above

Notices as well as a list of Notice of Technical Error codes and descriptions.

Trade Secrets Rule and Form

See 53 FR 28772, July 29, 1988. This rule implements the trade secrets provision of the EPCRA

(Section 322) and includes a copy of the trade secret substantiation form.

A.2 INFORMATION SOURCES

Most of the materials included as reference in this manual are available from the following

sources:

National Center for Environmental Publications and Information (NCEPI)

P.O. Box 42419

Cincinnati, OH 45242-2419

(800) 490-9198

Fax: (513)489-8695

Internet: http://www.epa.gov/ncepihom/index.html

Emergency Planning and Community Right-to-Know (EPCRA) Information Hotline

U.S. Environmental Protection Agency

(800) 424-9346 or (703) 412-9810 (for the Washington, D.C. metropolitan area)

TDD: (800) 553-7672

Internet Sites

& TRI homepage: http://www.epa.gov/tri

This site contains information on the Toxic Release Inventory and provides links

to a variety of data and documents related to the TRI program.

& Automated Toxic Chemical Release Inventory Reporting Software (ATRS):

http://www.epa.gov/atrs

This site provides access to the automated EPCRA Section 313 reporting forms

for electronic submittal of required data to U.S. EPA.

& Air CHIEF CD-ROM
A-3

http://www.epa.gov/ttn/chief/airchief.html

This site provides information on the Air CHIEF CD-ROM, contents, ordering

information, system requirements, and sources for additional information.

& Clearinghouse for Inventories and Emission Factors (CHIEF): 

http://www.epa.gov/ttn/chief/

This site provides access to the latest information and tools for estimating

emissions of air pollutants and performing emission inventories.

& Code of Federal Regulations, 40 CFR: http://www.epa.gov/epacfr40

This site was created by U.S. EPA to expand access to Title 40 - Environmental

Protections of the Code of Federal Regulations.

& Compilation of Air Pollutant Emission Factors (AP-42):

http://www.epa.gov/ttn/chief/ap42etc.html

This site provides access to files containing guidance for estimating emissions

from specific sources and emission factors.

& Federal Register Notice: http://www.epa.gov/EPA-TRI

This site provides access to all Federal Register notices related to the TRI program

from 1994 to current.

& Material Safety Data Sheets (MSDSs):

http://msds.pdc.cornell.edu/issearch/msdssrch.htm

A key word searchable database of 325,000 MSDSs.

& TANKS: http://www.epa.gov/ttn/chief/tanks.html

This site contains information on TANKS, a DOS-based computer software

program that computes estimates of VOC emissions from fixed and floating-roof

storage tanks.

& WATER8/CHEMDAT8: http://www.epa.gov/ttn/chief/software.html#water8

WATER8 is an analytical model for estimating compound-specific air emissions

from wastewater collection and treatment systems. CHEMDAT8 is a Lotus 1-2-3

spreadsheet for estimating VOC emissions from TSDF processes.
A-4

A.3 INDUSTRY-SPECIFIC TECHNICAL GUIDANCE DOCUMENTS

In 1988 and 1990, U.S. EPA developed a group of individual guidance documents for industries

or activities in industries who primarily manufacture, process, or otherwise use EPCRA

Section 313 chemicals. See list of industries/activities below. U.S. EPA is currently revising

some of these documents and preparing additional documents. The newer versions will be

available beginning in the Fall of 1998.

Chemical Distribution Facilities, January 1999 (EPA 745-B-99-005)

Coal Mining Facilities, January 1999 (EPA 745-B-99-002)

Coincidental Manufacture/By-Products (EPA 745-B-00-014)

Electricity Generating Facilities, January 1999 (EPA 745-B-99-003)

Estimating Releases and Waste Treatment Efficiencies

Food Processors, September 1998 (EPA 745-R-98-011)

Formulation of Aqueous Solutions

Foundry Operations (EPA 745-B-00-016)

Leather Tanning and Finishing Industry, April 2000 (EPA 745-B-00-012)

Metal Working and Electroplating Operations, April 2000 (EPA 745-B-00-015)

Metal Mining Facilities, January 1999 (EPA 745-B-99-001)

Monofilament Fiber Manufacture (EPA 745-B-00-013)

Pulp, Paper, and Paperboard Production (EPA 745-B-00-010)

Petroleum Terminals and Bulk Storage Facilities, January 1999 (EPA 745-B-99-006)

Presswood & Laminated Wood Products Manufacturing 

Printing Industry, April 2000 (EPA 745-B-00-005)

RCRA Subtitle C TSD Facilities and Solvent Recovery Facilities , January 1999 (EPA 745-B-99-

004)

Rubber and Plastics Manufacturing, April 2000 (EPA 745-B-00-017)

Semiconductor Manufacture (EPA 745-R-99-007)

Smelting Operations (EPA 745-B-00-009)
A-5

Spray Application and Electrodeposition of Organic Coatings, December 1998 (EPA 745-B-99-

014)

Textile Processing Industry, April 2000 (EPA 745-B-00-008)

Welding Operations (EPA 745-B-00-011)

Wood Preserving Operations (EPA 745-B-00-007)

U.S. EPA, Office of Compliance, published a series of documents in 1995 called Sector

Notebooks. These documents provide information of general interest regarding environmental

issues associated with specific industrial sectors. The Document Control Numbers (DCN) range

from EPA/310-R-95-001 through EPA/310-R-95-018.

A.4 CHEMICAL-SPECIFIC GUIDANCE DOCUMENTS

U.S. EPA has also developed a group of guidance documents specific to individual chemicals

and chemical categories. These are presented below.

Emergency Planning and Community Right-to-Know EPCRA Section 313: Guidance for

Reporting Aqueous Ammonia, July 1995 (EPA 745-R-95-012)

Emergency Planning and Community Right-to-Know EPCRA Section 313: List of Toxic

Chemicals within the Chlorophenols Category, November 1995 (EPA 745-B-95-004)

Estimating Releases for Mineral Acid Discharges Using pH Measurements, U.S. Environmental

Protection Agency, June 1991.

Guidance for Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and other

airborne forms of any particle size), November 1997 (EPA-745-R-97-007) 

Toxic Release Inventory List of Toxic Chemicals within the Glycol Ethers Category and

Guidance for Reporting, May 1995 (EPA 745-R-95-006)

Toxic Release Inventory List of Toxic Chemicals within the Nicotine and Salts Category and

Guidance for Reporting, February 1995 (EPA 745-R-95-004)

Toxic Release Inventory List of Toxic Chemicals within the Polychlorinated Alkanes Category

and Guidance for Reporting, February 1995 (EPA 745-R-95-001)

Toxic Release Inventory List of Toxic of Chemicals within the Polycyclic Aromatic Compounds

Category, February 1995 (EPA 745-R-95-003)

Toxic Release Inventory List of Toxic Chemicals within the Strychnine and Salts Category and

Guidance for Reporting, February 1995 (EPA 745-R-95-005)

Toxic Release Inventory List of Toxic of Chemicals within the Water Dissociable Nitrate

Compounds Category and Guidance for Reporting, May, 1996 (EPA 745-R-96-004)
A-6

Toxics Release Inventory - List of Toxic Chemicals Within Ethylenebisdithiocarbamic Acid

Category, November 1994, EPA 745-B-94-003.

Toxics Release Inventory - Copper Phthalocyanine Compounds Excluded for the Reporting

Requirements Under the Copper Compounds Category on the EPCRA Section 313 List, April

1995, EPA 745-R-95-007.

Toxics Release Inventory - List of Toxic Chemicals Within Warfarin Category, November 1994,

EPA 745-B-94-004.

A.5 OTHER USEFUL REFERENCES

Burgess, W.A. Recognition of Health Hazards in Industry. Harvard School of Public Health. 

Boston, Massachusetts, John-Wiley & Sons.

CRC Handbook of Chemistry and Physics. Latest Edition, Robert C. Weast, Editor, CRC Press,

Inc., Florida.

Kirk Othmer - Encyclopedia of Chemical Technology, Latest Edition, John Wiley & Sons, New

York.

Locating and Estimating Air Emissions from Various Sources. Available from: National

Technical Information Services (NTIS), (703) 487-4650.

The Merck Index. Latest Edition, Merck & Co., Inc., New Jersey.

Perry, R.H. and C.H. Chilton, Chemical Engineer's Handbook. Latest Edition, McGraw-Hill

Book Company, New York.

Sax, N.I. and R.J. Lewis, Sr., Hawley's Condensed Chemical Dictionary. Latest Edition, Van

Nostrand Reinhold Company, New York.

U.S. EPA, Profile of the Textile Industry, Latest Edition, Office of Enforcement and Compliance

Assurance.
Appendix B

BASIC CALCULATION TECHNIQUES
B-1

Appendix B

BASIC CALCULATION TECHNIQUES

This section will provide the basic techniques needed to use specific types of data or engineering

calculations. Examples are provided for:

(1) Stack monitoring data;

(2) Industrial hygiene data;

(3) Raoult's Law;

(4) Air emission factors;

(5) RCRA hazardous waste analysis data;

(6) NPDES monitoring data.

(1) Stack Monitoring Data

The following is an example of a release calculation using monitoring data.

Example: Stack monitoring data are available for a paint booth. The measured

average concentration of toluene is 0.1 ppmv (dry gas basis). The moisture

content in the stack is typically 10%, and stack conditions are maintained at 80 Co

and atmospheric pressure. The stack gas velocity is 8 m/s. The diameter of the

stack is 0.3 m. Calculate the point air release of toluene.

Step 1. Calculate volumetric flow of stack gas stream.

Volumetric flow = (gas velocity) × [(%) × (internal stack diameter) /4)] 2

Volumetric flow = (8.0 m/s) × [(%) × (0.3 m) /4] = 0.6 m /s 2 3

Step 2. Correct for moisture content in stack gas stream. 

Stack exhausts may contain large amounts of water vapor. The concentration of

the chemical in the exhaust is often presented on a dry basis. For an accurate

release rate, correct the vent gas flow rate for the moisture content by multiplying

by the term (1 - fraction water vapor). The dry gas rate can then by multiplied by

the chemical concentration.

(Note: If the toluene concentration is on a wet gas basis, no correction is necessary

for moisture content.)
Molar volume 
 V

n 
 RTP

Molar volume 
 0.082057 L	atm

mole	K × (353 K)/(1atm)

mg

m 3 
 (concentration of chemical, ppmv) × 1

molar volume of gas × (MW)

B-2

Dry volumetric flow = (Volumetric flow) × (1-fraction water vapor)

Dry volumetric flow = (0.6 m /s) × (1-0.10) = 0.5 m /s 3 3

Step 3. Convert ppmv to mg/m .3

& ppmv is defined as one part of a chemical in 10 parts of gas (1.0 m /10 6 3 6

m ). 3

& Use the molar volume of a gas, corrected for stack temperature and

pressure conditions, calculated by the ideal gas law (PV = nRT). Note that

the molar volume of an ideal gas at 237 K and 1 atm is 22.4 L/mole.

& Molecular weight of toluene (MW) = 92.14 g/mole.

& R = the Ideal Gas Constant (0.082057 L - atm per mole-Kelvin)

To calculate the molar volume of stack gas, use the ideal gas equation.

For the example, the stack conditions are 80 C (353 K) and atmospheric pressure o

(1 atm).

= 29.0 L/mole

The conversion of ppmv to mg/m can now be calculated. 3
0.1 m 3

106 m 3

×

mole

29.0 L

× 92.14 g

mole

×

L

10	3 m 3

× 1,000 mg

1 g 
 0.3 mg/m 3

Operating time 
 8 hr

day

× 5 day

week

× 52 week

yr 
 2,080 hr/yr

Air Release 
 (0.5 m3

/s) × (0.3 mg/m3) × 3,600 s

hr

× 2,080 hr

yr

×

lb

454 g

× g

1,000 mg


 2.5 lb/yr of toluene

B-3

Using the example, the concentration of toluene is calculated as follows:

Step 4. Calculate air releases.

Air releases are calculated as follows:

Air Release=(volumetric flow, m /s) × (concentration, mg/m ) × (operating time, s/yr) 3 3

The paint booth is used 8 hours per day, 5 days per week, 52 weeks per year. 

It is important to note that this calculation assumes the measured emissions are

representative of actual emissions at all times; however, this is not always the case. Ideally, a

continuous emissions monitor provides the most representative data.

Also note that monitoring and stack data may have units that are different than

those used in the example. Modify conversion factors and constants to reflect your data when

calculating air releases.

(2) Industrial Hygiene Data

The following is an example of a release calculation using industrial hygiene data.

Example: Occupational industrial hygiene data shows that workers are exposed

to an average of 0.1 ppmv benzene (wet gas basis). The density of benzene vapor

is 0.2 lb/ft . The ventilation system exhausts 20,000 acfm of room air at 70(F. 3

The plant operates 24 hours per day, 330 days per year. 

The benzene concentration is on a wet gas basis, therefore a moisture correction

of the ventilation flow rate is not necessary. The industrial hygiene data is

collected at the same ambient conditions as the ventilation system, therefore no

adjustment for temperature or pressure needs to be performed. A conservative

estimation of benzene fugitive releases could be calculated as follows:
20,000 ft 3

min

×

60 min

hr

×

24 hr

day

× 330 day

yr

×

0.1 ft 3 benzene

106 ft 3 air

×

0.2 lb

ft 3


 190 lb/yr of benzene

B-4

Air Release = (ventilation flow rate, ft /min) × (operating time, min/yr) × 3

(concentration of chemical, ppmv) × (vapor density of chemical, lb/ft )3

Benzene releases per year would be calculated as follows:

(3) Raoult's Law

The following is an example of a release calculation using Raoult's Law. Raoult's

Law states that the partial pressure of a compound in the vapor phase over a solution may be

estimated by multiplying its mole fraction in the liquid solution by the vapor pressure of the pure

chemical.

P = X P = X P A A,L A,G T

o

where:

P( = Vapor pressure of pure liquid chemical A;

X = Mole fraction of chemical A in solution; A,L

X = Mole fraction of chemical A in the gas phase; A,G

P = Partial pressure of chemical A in the gas phase; and A

P = Total pressure. T

Example: A wash tank holds a solution containing 10% by weight of

o-xylene (A) and 90% by weight of toluene (B). The tank is vented to the atmosphere; the

process vent flow rate is estimated as 100 acfm (2.83m /min) based on a minimum fresh air 3

ventilation rate. The molecular weight of o-xylene is 106.17 g/mole and toluene is 92.14 g/mole. 

The vapor pressure of o-xylene is 10 mm of Hg (0.19 psia). The total pressure of the system is

14.7 psia (atmospheric conditions). The process tank is in service 250 days/yr. Calculate the air

release of o-xylene.

Step 1: Calculate the mole fraction of o-xylene in the liquid solution.
XA,L 


wt fraction A

MWA

wt fraction A

MWA

 wt fraction B

MWB

XA,L 


0.1

106.17

0.1

106.17  0.992.14

XA,L 
 0.09

XA,G 
 XA,LP(

PT

XA,G 
 [0.09] × 0.19 psia

14.7 psia 
 0.001

B-5

Where:

X = Mole fraction of chemical A in liquid solution; A,L

MW = Molecular weight of chemical, g/mole; and

wt fraction = Weight fraction of chemical in material.

Step 2: Calculate the mole fraction of o-xylene in the gas phase.

where:

X = Mole fraction of chemical A in gas phase; A,G

X = Mole fraction of chemical A in liquid solution; A,L

P( = Vapor pressure of pure liquid chemical A, psia; and

P = Total pressure of system, psia. T

Step 3: Calculate releases using Raoult's Law.
Emissions 
 (XA,G) × (AFR) × (t) × (MWA) × 1

MV

2.83m 3

min

× 250 day

yr

×

24 hr

day

×

60 min

hr

×

mole

22.4L

× 106.17g

mole

×

L

10	3m 3

Emissions 
 4.8 × 106 g/yr × lb

454 g 
 10,570 lb/yr of o	xylene

AE 
 (EF) × (AU) × (OT)

B-6

where:

Emissions = Air release of pollutant A, g-A/yr;

X = Mole fraction of chemical A in gas phase; A,G

AFR = Air flow rate of room, m /min; 3

t = Operating time of wash tank, min/yr;

MW = Molecular weight of chemical, g/g-mole; and

MV = Gas molar volume (22.4 L/mole at standard temperature

and pressure).

If conditions vary from standard temperature and pressure the gas molar volume

can be calculated using the ideal gas law and tank conditions as presented in

Example 1.

Emissions = (0.001) ×

= 4.8 × 10 g/yr 6

The emission of o-xylene is calculated as shown below.

Air releases for toluene can be calculated in a similar manner.

(4) Air Emission Factor

The following is an example of a release calculation using air emission factors.

Example: An industrial boiler uses 300 gallons per hour of No. 2 fuel oil. The

boiler operates 2,000 hours per year. Calculate emissions of formaldehyde using

the AP-42 emission factors.
AE 
 0.061 lb

103 gal

× 300 gal

hr

× 2,000 hr

yr 
 36.6 lb/yr of formaldehyde

5 drums

yr

× 55 gal

drum

×

9.5 lb

gal

×

5lb Cd

100lb waste 
 131 lb/yr of cadmium

B-7

where:

AE = Annual emissions of pollutant, lb/yr

EF = Emission factor of pollutant, lb/10 gallon of fuel. EF for 3

formaldehyde for an industrial boiler burning No. 2 fuel oil is

0.035 to 0.061 lb/10 gallons. 3

AU = Quantity of fuel used, gal/yr.

OT = Operating time, hr/yr.

Using an emission factor of 0.061 pounds of formaldehyde per gallon of fuel, the

air releases are calculated as follows:

(5) RCRA Waste Analysis

The following is an example of a calculation using RCRA waste analysis data.

Example: Spent paint wastes were disposed at an off-site waste treatment

facility. The quantity of paint waste shipped was five 55-gallon drums per year. 

Analysis of the waste showed 5% cadmium by weight. Estimating the density of

the paint waste to be 9.5 lb/gallon, the amount of cadmium to off-site disposal is

calculated as follows:

Amount of cadmium = (amount of paint waste disposed, gal/yr) × (concentration of cadmium, lb/lb) ×

 (density of paint waste, lb/gal)

(6) NPDES Data

The following is an example of a calculation using NPDES data.

NPDES permits require periodic monitoring of the effluent stream. In this

example, quarterly samples were taken to be analyzed for silver content. Each sample was an

hourly, flowrate-based composite taken for one day to be representative of the discharge for that

day. The total effluent volume for that day was also recorded. The following data were collected

on each sample day.
First Quarter: 10μg

L

× 1g

106 μg

×

1lb

454g

×

3.785L

gal

0.5 × 106 gal

day

0.040.050.020.005

4 lb/day 
 0.03lb/day

B-8

Yearly Quarter Discharge Flow Rate

Sample Number (10 gal/day) Total Silver (μg/L) 6

1 0.5 10

2 0.6 10

3 0.4 6

4 0.2 <3

To calculate the amount of silver in pounds discharged on each sample day, the

concentration of silver in the discharge is multiplied by the discharge flow rate for that day, as

shown below for the first quarter sample.

Amount of silver = (daily flow rate) × (silver concentration)

= 0.04 lb/day of silver

The amount of silver discharged during each of the other three monitoring events

was similarly determined to be:

0.05 lb/day; 0.02 lb/day, and 0.005 lb/day.

For the last data point the concentration of silver was reported by the laboratory to

be less than the detection limit of 3 μg/L. For this calculation the detection limit was used to

calculate the daily discharge, a conservative assumption.

The average daily discharge was calculated to be:

The plant operates 350 days/year (plant shuts down for two weeks in July).

The estimated annual discharge of silver is calculated as follows:

Annual discharge = (350 day/yr) (0.03 lb/day) = 10.5 lb of silver/yr
Appendix C

GUIDANCE FOR REPORTING AQUEOUS AMMONIA
C-1

United States Environmental Office of Pollution July 1995

Protection Agency Prevention and Toxics EPA 745-R-95-012

Washington, DC 20460

EMERGENCY PLANNING AND 

COMMUNITY RIGHT-TO-KNOW

EPCRA Section 313

Guidance for Reporting Aqueous Ammonia

EPCRA Section 313 of the Emergency Planning and Community Right-to-Know

Act of 1986 (EPCRA) requires certain facilities manufacturing, processing, or otherwise using

listed toxic chemicals to report their environmental releases of such chemicals annually. 

Beginning with the 1991 reporting year, such facilities also must report pollution prevention and

recycling data for such chemicals, pursuant to section 6607 of the Pollution Prevention Act, 42

U.S.C. 13106. When enacted, EPCRA Section 313 established an initial list of toxic chemicals

that was comprised of more than 300 chemicals and 20 chemical categories. EPCRA Section

313(d) authorizes EPA to add chemicals to or delete chemicals from the list, and sets forth

criteria for these actions.

CONTENTS

Section 1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-2

1.1 Who Must Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-2

1.2 Thresholds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-2

1.3 Chemical Sources of Aqueous Ammonia . . . . . . . . . . . . . . . . . . . . . . . C-3

1.4 De Minimis Concentrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-3

Section 2. Guidance for Reporting Aqueous Ammonia . . . . . . . . . . . . . . . . . . . . . . . . . . . C-4

2.1 Determining Threshold and Release Quantities for Ammonia . . . . . . . C-4

2.2 Chemical Sources of Aqueous Ammonia . . . . . . . . . . . . . . . . . . . . . . . C-5

2.2.1 Reporting Aqueous Ammonia Generated from Anhydrous

Ammonia 

in Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-5

2.2.2 Reporting of Ammonia Generated from the Dissociation of 

Ammonium Salts (Other Than Ammonium Nitrate) . . . . . . . . . C-6

2.2.3 Reporting of Aqueous Ammonia Generated from the Dissociation 

of Ammonium Nitrate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-7

Section 3. CAS Number and List of Some Chemical Sources of Aqueous Ammonia . . . C-10
C-2

Section 1. Introduction

On June 30, 1995 EPA finalized four actions in response to a petition received in

1989 to delete ammonium sulfate (solution) from the list of toxic chemicals subject to reporting

under EPCRA Section 313 of the Emergency Planning and Community Right-to-Know Act of

1986 (EPCRA), 42 U.S.C. 11001. The four actions taken are summarized as follows: (1)

deleted ammonium sulfate (solution) from the EPCRA Section 313 list of toxic chemicals, (2)

required that threshold and release determinations for aqueous ammonia be based on 10 percent

of the total aqueous ammonia present in aqueous solutions of ammonia, (3) modified the

ammonia listing by adding the following qualifier: 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), and (4) deleted ammonium nitrate (solution)

as a separately listed chemical on the EPCRA Section 313 list of toxic chemicals. All actions are

effective for the 1994 reporting year for reports due July 1, 1995, with the exception of the

deletion of ammonium nitrate (solution) as a separately listed chemical, which is effective for the

1995 reporting year for reports due July 1, 1996. At the time that these actions were finalized,

EPA indicated that the Agency would develop, as appropriate, interpretations and guidance that

the Agency determines are necessary to facilitate accurate reporting for aqueous ammonia. This

document constitutes such guidance for reporting under the ammonia listing.

Section 1.1 Who Must Report

A plant, factory, or other facility is subject to the provisions of EPCRA Section

313, if it meets all three of the following criteria:

& It conducts manufacturing operations (is included in Standard Industrial

Classification (SIC) codes 20 through 39); and

& It has 10 or more full-time employees (or the equivalent 20,000 hours per

year); and

& It manufactures, imports, processes, or otherwise uses any of the toxic

chemicals listed on the EPCRA Section 313 list in amounts greater than

the “threshold” quantities specified below.

Section 1.2 Thresholds

Thresholds are specified amounts of toxic chemicals used during the calendar year

that trigger reporting requirements.

If a facility manufactures or imports any of the listed toxic chemicals, the

threshold quantity will be:

& 25,000 pounds per toxic chemical or category over the calendar year.

If a facility processes any of the listed toxic chemicals, the threshold quantity will

be:

& 25,000 pounds per toxic chemical or category over the calendar year.
C-3

If a facility otherwise uses any of the listed toxic chemicals (without incorporating

it into any product or producing it at the facility), the threshold quantity is:

& 10,000 pounds per toxic chemical or category over the calendar year.

Section 1.3 Chemical Sources of Aqueous Ammonia

If a facility manufactures, processes, or otherwise uses anhydrous ammonia or

aqueous ammonia, they must report under the ammonia listing. EPA is providing a table of

Chemical Abstract Service (CAS) numbers and chemical names to aid the regulated community

in determining whether they need to report under the ammonia listing for aqueous ammonia. 

This table includes a list of water dissociable ammonium salts which, when placed in water, are a

source of aqueous ammonia. The table contains only commonly used ammonium salts and

therefore is not exhaustive. If a facility manufactures, processes, or otherwise uses aqueous

ammonia, regardless of its source, it must report under the ammonia listing, even if the source of

the aqueous ammonia is not listed in the table provided in this document.

Section 1.4 De Minimis Concentrations

The ammonia listing is subject to the one percent de minimis concentration. Thus,

solutions containing aqueous ammonia at a concentration in excess of one percent of the 10

percent reportable under this listing should be factored into threshold and release

determinations.
C-4

Section 2. Guidance for Reporting Aqueous Ammonia

Note: for the purposes of reporting under the ammonia listing for aqueous

ammonia, water dissociable ammonium salts means that the ammonium ion dissociates from its

counterion when in solution.

Section 2.1 Determining Threshold and Release Quantities for Ammonia

If a facility manufactures, processes, or otherwise uses anhydrous ammonia, the

quantity applied towards threshold determinations for the ammonia listing is the total quantity of

the anhydrous ammonia manufactured, processed, or otherwise used. The quantity reported

when calculating the amount of ammonia that is released, transferred, or otherwise managed is

the total quantity of anhydrous ammonia released or transferred.

If the facility manufactures, processes, or otherwise uses anhydrous ammonia in

quantities that exceed the appropriate threshold and subsequently dissolves some or all of the

anhydrous ammonia in water, then the following applies: 1) threshold determinations are based

on 100 percent of the anhydrous ammonia (simply 10 percent of aqueous ammonia); 2) release,

transfer, and other waste management quantities for the aqueous ammonia are calculated as 10

percent of total ammonia; 3) release, transfer, and other waste management quantities for the

anhydrous ammonia are calculated as 100 percent of the anhydrous ammonia.

If a facility manufactures, processes, or otherwise uses aqueous ammonia, the

quantity applied toward threshold determinations for the ammonia listing is 10 percent of the

total quantity of the aqueous ammonia manufactured, processed, or otherwise used. The quantity

reported when calculating the amount of ammonia that is released, transferred, or otherwise

managed is 10 percent of the total quantity of aqueous ammonia released or transferred.

If a facility dissolves a water dissociable ammonium salt in water that facility has

manufactured aqueous ammonia and 10 percent of the total aqueous ammonia manufactured

from these salts is to be included in manufacturing threshold determinations under the ammonia

listing.

If aqueous ammonia from water dissociable ammonium salts is processed or

otherwise used, then 10 percent of the total aqueous ammonia is to be included in all processing

and otherwise use threshold determinations under the ammonia listing.

Example 1: In a calendar year, a facility places 25,000 lbs of anhydrous ammonia in water for

processing and processes 25,000 lbs of aqueous ammonia from an ammonium salt. The

facility must include all of the 25,000 lbs of anhydrous ammonia in the determination of the

processing threshold, but only 10 percent (or 2,500 lbs) of the aqueous ammonia from the

ammonium salt in the processing threshold determination.

Total aqueous ammonia is the sum of the two forms of ammonia (un-ionized,

NH , and ionized, NH ) present in aqueous solutions. A precise calculation of the weight of 3 4

+
C-5

total aqueous ammonia would require determining the ratio of the two forms of ammonia present

using the pH and temperature of the solution. The weight of total aqueous ammonia can be more

easily calculated by assuming that aqueous ammonia is comprised entirely of the NH form or 4

+

the NH form. For the purpose of determining threshold and release quantities under EPCRA 3

Section 313, EPA recommends that total aqueous ammonia be calculated in terms of NH3

equivalents (i.e., for determining weights, assume total ammonia is comprised entirely of the

NH form). This method is simpler than using pH and temperature data to determine the ratio of 3

the two forms present and is consistent with the presentation of total ammonia toxicity in a

separate EPA document, Ambient Water Quality Criteria for Ammonia (EPA document #440/5-

85-001, January 1985).

Section 2.2 Chemical Sources of Aqueous Ammonia

Aqueous ammonia may be generated in solution from a variety of sources that

include the release of anhydrous ammonia to water and the dissociation of ammonium salts in

water. Water dissociable ammonium salts are not reportable in their entirety under the ammonia

listing; these salts are reportable to the extent that they dissociate in water, and only 10 percent of

the total aqueous ammonia that results when these salts dissociate is reportable. If these salts are

not placed in water, they are not reportable.

If these salts are purchased neat or as solids by a facility, then placed in water by

that facility, the facility is manufacturing aqueous ammonia.

Section 2.2.1 Reporting Aqueous Ammonia Generated from Anhydrous Ammonia in

Water

If the source of aqueous ammonia is anhydrous ammonia in water, total aqueous

ammonia (calculated in terms of NH equivalents) is equal to the quantity of anhydrous ammonia 3

manufactured, processed, or otherwise used. A hypothetical scenario demonstrating the

calculations involved in reporting aqueous ammonia generated from anhydrous ammonia in

water is given in Example 2.

Example 2: In a calendar year, a facility uses 30,000 pounds of anhydrous ammonia to

neutralize acids in a wastewater stream. The neutralized waste stream (containing aqueous

ammonia from dissociated ammonium salts) is then transferred to a POTW. The quantity to

be applied toward threshold determinations is the total quantity of anhydrous ammonia used in

the waste stream neutralization, or 30,000 pounds. The quantity of ammonia reported as

transferred is 10 percent of the total quantity of aqueous ammonia transferred, or 3,000

pounds.

Section 2.2.2 Reporting Aqueous Ammonia Generated from the Dissociation of

Ammonium Salts (Other Than Ammonium Nitrate)

If the source of aqueous ammonia is the dissociation of ammonium salts in water,

total aqueous ammonia (calculated in terms of NH equivalents) is calculated from the weight 3

percent (wt%) of the NH equivalents of the ammonium salt. The NH equivalent wt% of an 3 3

ammonium salt is calculated using the following equation:
C-6

NH equivalent wt% = (NH equivalent weight)/(MW ammonium salt) × 100 3 3

If the source of aqueous ammonia is a monovalent compound (such as ammonium chloride,

NH Cl, ammonium nitrate, NH NO , or ammonium bicarbonate (NH HCO ), the NH equivalent 4 4 3 4 3 3

weight is equal to the MW of NH (17.03 kg/kmol). If divalent compounds are involved (such as 3

ammonium carbonate, (NH ) CO ), then the NH equivalent weight is equal to the MW of NH 42 3 3 3

multiplied by two. Similarly, if trivalent compound are involved, then the NH equivalent weight 3

is equal to the MW of NH multiplied by three. 3

Example 3: 

The NH equivalent wt% of ammonium chloride is calculated as follows: 3

NH equivalent wt% = (NH equivalent weight)/(MW ammonium chloride) × 100 3 3

NH equivalent wt% = (17.03)/(53.49) × 100 3

NH equivalent wt% = 31.84% 3

The NH equivalent wt% of ammonium carbonate is calculated as follows: 3

NH equivalent wt% = 2 × (NH equivalent weight)/(MW ammonium chloride) × 100 3 3

NH equivalent wt% = 2 × (17.03)/(96.09) × 100 3

NH equivalent wt% = 35.45% 3

To aid the regulated community in reporting under the ammonia listing for

aqueous ammonia, the table of chemical sources of aqueous ammonium provided in Section 3 of

this document includes, in addition to CAS number, chemical name, and molecular weight, the

NH equivalent wt% of the commonly used, water dissociable ammonium salts listed in this 3

table.

Example 4: In a calendar year, a facility uses 100,000 pounds of ammonium chloride, NH Cl, 4

in aqueous solution which is released to wastewater streams, then transferred to a POTW. The

NH equivalent wt% of ammonium chloride is 31.84% (taken from Table 1 in Section 3 below 3

or calculated as in Example 3 above). The total quantity of aqueous ammonia present in

solution is 31.84% of the 100,000 pounds of ammonia chloride used, or 31,840 pounds. The

quantity applied towards threshold determinations for the ammonia listing is 10 percent of the

total quantity of aqueous ammonia present in solution, or 3,184 pounds. The quantity of

ammonia reported as released or transferred is 10 percent of the total quantity of aqueous

ammonia released or transferred, or 3,184 pounds.
C-7

Example 5: In a calendar year, a facility uses 500,000 pounds of ammonium carbonate,

(NH ) CO , and 400,000 pounds of ammonium bicarbonate, NH HCO , 42 3 4 3 in aqueous solution

which is released to wastewater streams, then transferred to a POTW. The NH equivalent 3

wt% of ammonium carbonate is 35.45%, and the NH equivalent wt% of ammonium 3

bicarbonate is 21.54% (taken from Table 1 in Section 3 below or calculated as in Example 3

above). The quantity of aqueous ammonia present in solution from ammonium carbonate is

35.45% of the 500,000 pounds of ammonia carbonate used, or 177,250 pounds. The quantity

of aqueous ammonia present in solution from ammonium bicarbonate is 21.54% of the

400,000 pounds of ammonia bicarbonate used or 86,160 pounds. The total quantity of

aqueous ammonia present in solution is 263,410 pounds. The quantity applied towards

threshold determinations for the ammonia listing is 10 percent of the total quantity of aqueous

ammonia present in solution, or 26,341 pounds. The quantity of ammonia reported as released

or transferred is 10 percent of the total quantity of aqueous ammonia released or transferred, or

26,341 pounds.

Section 2.2.3 Reporting Aqueous Ammonia Generated from the Dissociation of

Ammonium Nitrate

Some sources of aqueous ammonia may be reportable under other EPCRA

Section 313 category listings. Ammonium nitrate (solution) is relevant to reporting under the

ammonia listing to the extent that 10 percent of the total aqueous ammonia that results when

ammonium nitrate dissociates is reported when determining thresholds and calculating releases. 

However, under the nitrate compound category listing, ammonium nitrate (and other mixed salts

containing ammonium and nitrate) must be reported in its entirety. When reporting ammonium

nitrate under this category listing, the total nitrate compound, including both the nitrate ion

portion and the ammonium counterion, is included when determining threshold quantities. 

However, only the nitrate ion portion is included when determining the amount of ammonium

nitrate that is released, transferred, or otherwise managed in wastes. The calculations involved in

determining threshold and release quantities for reporting under the nitrate compound category

listing are described in a separate directive, List of Toxic Chemicals within the Water Dissociable

Nitrate Compounds Category and Guidance for Reporting (EPA document #745-R-95-002,

February 1995). Note: reporting ammonium nitrate under the ammonia listing and nitrate

compounds category listing is effective for the 1995 reporting year for reports due July 1, 1996.
C-8

Example 6: In a calendar year, a facility uses 1,250,000 pounds of ammonium nitrate,

NH NO , 4 3 in aqueous solution which is released to wastewater streams, then transferred to a

POTW. The NH equivalent wt% of ammonium nitrate is 21.28% (taken from Table 1 in 3

Section 3 below or calculated as in Example 3 above). The total quantity of aqueous ammonia

present in solution is 21.28% of the 1,250,000 pounds of ammonia chloride used, or 266,000

pounds. The quantity applied towards threshold determinations for the ammonia listing is 10

percent of the total quantity of aqueous ammonia present in solution, or 26,600 pounds. The

quantity of ammonia reported as released or transferred is 10 percent of the total quantity of

aqueous ammonia released or transferred, or 26,600 pounds. For determining thresholds and

calculating releases under the nitrate compound category listing, see the separate directive, List

of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance

for Reporting (EPA document #745-R-95-002, February, 1995).
C-9

Example 7: In a calendar year, a facility transfers 100,000 pounds of nitric acid (HNO ) to an 3

on-site treatment facility. The nitric acid is neutralized with anhydrous ammonia, and

treatment efficiency is 95 percent (the nitrate compound formed as a result of the treatment is

ammonium nitrate, NH NO ). The neutralized waste stream (containing aqueous ammonia 4 3

from dissociated ammonium nitrate) is then transferred to a POTW. The quantity of nitric acid

neutralized is 95 percent of 100,000 pounds or 95,000 pounds. The quantity of nitric acid

neutralized is converted first to kilograms then to kilomoles using the following equations:

Kilograms HNO neutralized = (lbs HNO neutralized) × (0.4536 kg/lb) 3 3

Kilomoles HNO neutralized = (kg HNO ) ÷ (MW of HNO in kg/kmol) 3 3 3

Substituting the appropriate values into the above equations yields:

Kilograms HNO neutralized = 95,000 lbs × 0.4536 kg/lb = 43,092 kg 3

Kilomoles HNO neutralized = 43,092 kg ÷ 63.01 kg/kmol = 683.9 kmol 3

The quantity of anhydrous ammonia used in kilomoles in the acid neutralization and the

quantity of ammonium nitrate generated in kilomoles from the neutralization are equal to the

quantity of nitric acid neutralized (683.9 kmol). The quantity of anhydrous ammonia used in

kilograms and pounds in the acid neutralization is calculated as follows:

Kilograms NH used = (kmol NH ) × (MW of NH in kg/kmol) 3 3 3

Pounds NH used = (kg NH ) × (2.205 lbs/kg) 3 3

Substituting the appropriate values into the above equation yields:

Kilograms NH used = (683.9 kmol) × (17.03 kg/kmol) = 11,647 kmol 3

Pounds NH used = (11,647 NH ) × (2,205 lbs/kg) = 25,682 pounds 3 3

The quantity reported applied towards threshold determinations for the ammonia listing is the

total quantity of anhydrous ammonia used in the acid neutralization, or 25,682 pounds. The

quantity of ammonia reported as released or transferred is 10 percent of the total quantity of

aqueous ammonia released or transferred, or 2,568 pounds. For determining thresholds and

calculating releases under the nitrate compound category listing, see the separate directive, List

of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance

for Reporting (EPA document #745-R-95-002, February 1995).
C-10

Section 3. CAS Number and List of Some Chemical Sources of Aqueous Ammonia

EPA is providing the following table of CAS numbers and chemical names to aid

the regulated community in determining whether they need to report under the ammonia listing

for aqueous ammonia. If a facility manufactures, processes, or otherwise uses, in aqueous

solution, a chemical which is listed below, they must report 10 percent of the total aqueous

ammonia that is the result of the dissociation of this chemical. However, this list is not

exhaustive. If a facility manufactures, processes, or otherwise uses, in aqueous solution, a water

dissociable ammonium compound, they must report 10 percent of the total aqueous ammonia that

is the result of the dissociation of the compound, even if the compound does not appear in the

following table.

Table C-1

Listing by CAS Number and Molecular Weight of 

Some Chemical Sources of Aqueous Ammonia

Chemical Name Weight* Wt% CAS Number

Molecular Equivalent

NH3

Ammonium acetate 77.08 22.09 631-61-8

Ammonium aluminum sulfate 237.14 7.181 7784-25-0

(Ammonium aluminum disulfate)

Ammonium antimony fluoride 252.82 13.47 32516-50-0

(Diammonium pentafluoroantimonate)

Ammonium arsenate 158.97 10.71 13462-93-6

(Ammonium arsenate, hydrogen)

(Ammonium arsenate, dihydrogen)

Ammonium arsenate 176.00 19.35 7784-44-3

(Diammonium arsenate)

(Diammonium arsenate, hydrogen)

(Diammonium arsenate, monohydrogen)

Ammonium arsenite 124.96 13.63 13462-94-7

Ammonium azide 60.06 28.35 12164-94-2

Ammonium benzenesulfonate 175.20 9.720 19402-64-3

Ammonium benzoate 139.15 12.24 1863-63-4

Ammonium bromate 145.94 11.67 13843-59-9

Ammonium bromide 97.94 17.39 12124-97-9

Ammonium cadmium chloride 236.81 7.191 18532-52-0

(Ammonium cadmium trichloride)

Ammonium carbamate 78.07 21.81 1111-78-0

Ammonium carbonate carbamate 157.13 21.68 8000-73-5

Ammonium carbonate 96.09 35.45 506-87-3

(Diammonium carbonate)
Table C-1 (Continued)

Chemical Name Weight* Wt% CAS Number

Molecular Equivalent

NH3

C-11

Ammonium carbonate, hydrogen 79.06 21.54 1066-33-7

(Ammonium bicarbonate)

Ammonium cerium nitrate 548.23 6.213 16774-21-3

(Ammonium hexanitratocerate)

(Ammonium hexanitratocerate (IV))

(Diammonium cerium hexanitrate)

Ammonium cerous nitrate 486.22 7.005 13083-04-0

(Ammonium cerous nitrate, tetrahydrate)

Ammonium chlorate 101.49 16.78 10192-29-7

Ammonium perchlorate 117.49 14.49 7790-98-9

Ammonium chloride 53.49 31.84 12125-02-9

Ammonium chromate 152.07 22.40 7788-98-9

(Ammonium chromate (VI))

(Diammonium chromate)

Ammonium chromate 252.06 13.51 7789-09-5

(Ammonium dichromate)

(Ammonium dichromate (VI))

(Ammonium bichromate)

(Diammonium dichromate)

Ammonium chromium sulfate 265.17 6.422 13548-43-1

(Ammonium chromic sulfate)

Ammonium citrate 226.19 15.06 3012-65-5

(Ammonium citrate, monohydrogen)

(Ammonium citrate, dibasic)

(Diammonium citrate)

(Diammonium citrate, hydrogen)

Ammonium citrate 243.22 21.01 3458-72-8

(Ammonium citrate, tribasic)

(Triammonium citrate)

Ammonium cobalt sulfate 289.14 11.78 13596-46-8

(Ammonium cobaltous sulfate)

Ammonium cupric chloride 241.43 14.11 15610-76-1

(Ammonium chlorocuprate (II))

(Diammonium copper tetrachloride)

(Diammonium tetrachlorocuprate)

Ammonium cyanate 60.06 28.35 22981-32-4

(Ammonium isocyanate)

Ammonium cyanide 44.06 38.65 12211-52-8

Ammonium cyanoaurate, monohydrate 319.07 5.337 14323-26-3

(Ammonium tetracyanoaurate, monohydrate)
Table C-1 (Continued)

Chemical Name Weight* Wt% CAS Number

Molecular Equivalent

NH3

C-12

Ammonium cyanoaurate 267.04 6.377 31096-40-9

(Ammonium dicyanoaurate)

Ammonium ferricyanide 266.07 19.20 14221-48-8

(Ammonium hexacyanoferrate (III))

(Triammonium hexacyanoferrate)

Ammonium ferrocyanide 284.11 23.98 14481-29-9

(Ammonium hexacyanoferrate (II))

(Tetraammonium ferrocyanide)

(Tetraammonium hexacyanoferrate)

Ammonium fluoride 37.04 45.98 12125-01-8

Ammonium fluoride 57.04 29.86 1341-49-7

(Ammonium difluoride)

(Ammonium bifluoride)

(Ammonium fluoride, hydrogen)

(Ammonium difluoride, hydrogen)

(Ammonium bifluoride, hydrogen)

Ammonium fluoroborate 104.84 16.24 13826-83-0

(Ammonium tetrafluoroborate)

Ammonium fluorogermanate (IV) 222.66 15.30 16962-47-3

(Ammonium hexafluorogermanate (IV))

(Diammonium hexafluorogermanate)

Ammonium fluorophosphate 163.00 10.45 16941-11-0

(Ammonium hexafluorophosphate)

Ammonium fluorosulfate 117.10 14.54 13446-08-7

(Ammonium fluorosulfonate)

Ammonium formate 63.06 27.01 540-69-2

Ammonium gallium sulfate 282.90 6.020 15335-98-5

Ammonium hydroxide 35.05 48.59 1336-21-6

Ammonium iodide 144.94 11.75 12027-06-4

Ammonium iridium chloride 459.05 11.13 15752-05-3

(Ammonium chloroiridate (III))

(Ammonium hexachloroiridate)

(Triammonium hexachloroiridate)

Ammonium iron sulfate 269.02 6.330 10138-04-2

(Ammonium ferric sulfate)

(Ammonium iron disulfate)

Ammonium iron sulfate 286.05 11.91 10045-89-3

(Ammonium ferrous sulfate)

(Diammonium iron disulfate)

(Diammonium ferrous disulfate)
Table C-1 (Continued)

Chemical Name Weight* Wt% CAS Number

Molecular Equivalent

NH3

C-13

Ammonium lactate 107.11 15.90 515-98-0

(Ammonium 2-hydroxypropionate)

Ammonium laurate 217.35 7.835 2437-23-2

(Ammonium dodecanoate)

Ammonium magnesium sulfate 252.50 13.49 14727-95-8

Ammonium malate 168.15 20.26 6283-27-8

Ammonium malate, hydrogen 151.12 11.27 5972-71-4

(Ammonium bimalate)

Ammonium molybdate 196.01 17.38 13106-76-8

(Diammonium molybdate)

Ammonium molybdate 1,163.8 8.780 12054-85-2

(Ammonium heptamolybdate)

(Ammonium molybdate, hydrate)

(Ammonium molybdate, tetrahydrate)

(Ammonium paramolybdate, tetrahydrate)

Ammonium nickel chloride, hexahydrate 183.09 9.301 16122-03-5

Ammonium nickel sulfate 286.88 11.87 7785-20-8

(Ammonium nickel sulfate, hexahydrate)

(Ammonium nickel disulfate, hexahydrate)

(Diammonium nickel disulfate, hexahydrate)

Ammonium nitrate 80.04 21.28 6484-52-2

Ammonium nitrate sulfate 212.18 24.08 12436-94-1

Ammonium nitrite 64.04 26.59 13446-48-5

Ammonium oleate 299.50 5.686 544-60-5

Ammonium oxalate 124.10 27.45 1113-38-8

Ammonium palladium chloride 284.31 11.98 13820-40-1

(Ammonium chloropalladate (II))

(Ammonium tetrachloropalladte (II))

(Diammonium tetrachloropalladate)

Ammonium phosphate 149.09 34.27 10124-31-9

(Ammonium orthophosphate)

Ammonium phosphate 115.03 14.80 7722-76-1

(Ammonium biphosphate)

(Ammonium phosphate, hydrogen)

(Ammonium phosphate, dihydrogen)

(Ammonium orthophosphate, dihydrogen)

(Ammonium phosphate, monobasic)
Table C-1 (Continued)

Chemical Name Weight* Wt% CAS Number

Molecular Equivalent

NH3

C-14

Ammonium phosphate 132.06 25.79 7783-28-0

(Ammonium phosphate, hydrogen)

(Ammonium orthophosphate, monohydrogen)

(Ammonium phosphate, dibasic)

(Ammonium orthophosphate, dibasic)

(Diammonium phosphate)

(Diammonium orthophosphate)

(Diammonium phosphate, hydrogen)

(Diammonium phosphate, monohydrogen)

(Diammonium orthophosphate, hydrogen)

Ammonium phosphinate 83.03 20.51 7803-65-8

(Ammonium hypophosphite)

Ammonium phosphite 99.03 17.20 13446-12-3

(Ammonium biphosphite)

(Ammonium phosphite, dihydrogen)

Ammonium picramate 216.15 7.879 1134-85-6

Ammonium propionate 91.11 18.69 17496-08-1

Ammonium rhodium chloride 369.74 13.82 15336-18-2

(Ammonium chlororhodate (III))

(Ammonium hexachlororhodate (III))

(Triammonium rhodium hexachloride)

(Triammonium hexachlororhodate)

Ammonium salicylate

(Ammonium 2-hydroxybenzoate)

155.15 10.98 528-94-9

Ammonium selenide 115.04 29.61 66455-76-3

Ammonium silicon fluoride 178.15 19.12 16919-19-0

(Ammonium fluorosilicate)

(Ammonium hexafluorosilicate)

(Diammonium silicon hexafluoride)

(Diammonium fluorosilicate)

(Diammonium hexafluorosilicate)

Ammonium stearate 301.51 5.648 1002-89-7

(Ammonium octadecanoate)

Ammonium succinate 152.15 22.39 2226-88-2

(Diammonium succinate)

Ammonium sulfamate 114.12 14.92 7773-06-0

(Ammonium amidosulfate)

(Ammonium amidosulfonate)

Ammonium sulfate 132.13 25.78 7783-20-2

(Diammonium sulfate)
Table C-1 (Continued)

Chemical Name Weight* Wt% CAS Number

Molecular Equivalent

NH3

C-15

Ammonium sulfate 115.10 14.80 7803-63-6

(Ammonium bisulfate)

(Ammonium sulfate, hydrogen)

(Ammonium sulfate, monohydrogen)

Ammonium persulfate 228.19 14.93 7727-54-0

(Ammonium peroxysulfate)

(Ammonium peroxydisulfate)

(Diammonium persulfate)

(Diammonium peroxydifulsite)

Ammonium sulfide 51.11 33.32 12124-99-1

(Ammonium bisulfide)

(Ammonium sulfide, hydrogen)

Ammonium sulfide 68.14 49.99 12135-76-1

(Ammonium monosulfide)

(Diammonium sulfide)

Ammonium sulfide 196.39 17.34 12135-77-2

(Diammonium pentasulfide)

Ammonium sulfite, monohydrate 116.13 29.33 7783-11-1

(Diammonium sulfite, monohydrate)

Ammonium sulfite 99.10 17.18 10192-30-0

(Ammonium bisulfite)

(Ammonium sulfite, hydrogen)

Ammonium tetrachloroaurate (III), hydrate 356.82 4.772 13874-04-9

Ammonium thiocarbamate 94.13 18.09 16687-42-6

Ammonium thiocarbonate 144.27 23.61 13453-08-2

(Diammonium trithiocarbonate)

Ammonium thiocyanate 76.12 22.37 1762-95-4

(Ammonium isothiocyanate)

(Ammonium sulfocyanate)

(Ammonium rhodanate)

(Rhodanid)

Ammonium dithionate 196.19 17.36 60816-52-6

Ammonium thiosulfate 148.20 22.98 7783-18-8

(Ammonium hyposulfite)

(Diammonium thiosulfate)

Ammonium tin bromide 634.19 5.371 16925-34-1

(Ammonium bromostannate (IV))

(Ammonium hexabromostannate (IV))

(Diammonium hexabromostannate)
Table C-1 (Continued)

Chemical Name Weight* Wt% CAS Number

Molecular Equivalent

NH3

C-16

Ammonium tin chloride 367.48 9.269 16960-53-5

(Ammonium chlorostannate (IV))

(Ammonium hexachlorostannate (IV))

(Diammonium tin hexachloride)

(Diammonium hexachlorostannate)

Ammonium titanium fluoride 197.95 17.21 16962-40-6

(Ammonium fluorotitanate (IV))

(Ammonium hexafluorotitanate (IV))

(Diammonium titanium hexafluoride)

(Diammonium hexafluorotitanate)

Ammonium titanium oxalate, monohydrate 276.00 12.34 10580-03-7

(Diammonium dioxalatooxotitanate, monohydrate)

Ammonium tungstate 1,779.2 5.743 12028-06-7

(Ammonium tungstate (VI))

(Ammonium paratungstate)

(Hexaammonium tungstate)

Ammonium tungstate 3,058.6 5.568 11120-25-5

(Ammonium tungstate (VI))

(Ammonium paratungstate)

(Decaammonium tungstate)

Ammonium valerate 119.16 14.29 42739-38-8

(Ammonium pentoate)

Ammonium zinc chloride 243.27 14.00 14639-97-5

(Ammonium chlorozincate)

(Ammonium tetrachlorozincate)

(Diammonium tetrachlorozincate)

*For hydrated compounds, e.g., ammonium sulfite, monohydrate, the molecular weight excludes the weight of the hydrate

portion.
Appendix D

TOXIC RELEASE INVENTORY: LIST OF TOXIC CHEMICALS WITHIN 

THE GLYCOL ETHERS CATEGORY
D-1

United States Office of Pollution May 1995

Environmental Protection Prevention and Toxics EPA 745-R-95-006

Agency Washington, DC 20460

TOXICS RELEASE INVENTORY

List of Toxic Chemicals within the Glycol Ethers

Category

Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA)

requires certain facilities manufacturing, processing, or otherwise using listed toxic chemicals to

report their environmental releases of such chemicals annually. Beginning with the 1991

reporting year, such facilities also must report pollution prevention and recycling data for such

chemicals, pursuant to section 6607 of the Pollution Prevention Act, 42 U.S.C. 13106. When

enacted, EPCRA Section 313 established an initial list of toxic chemicals that was comprised of

more than 300 chemicals and 20 chemical categories. EPCRA Section 313(d) authorizes EPA to

add chemicals to or delete chemicals from the list, and sets forth criteria for these actions.

CONTENTS

Section 1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-2

Section 2. CAS Number List of Some Chemicals within the Glycol Ethers Category . . . D-5

Section 3. CAS Number List of Some Mixtures That Contain Glycol Ethers within

the Category . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-160

Section 4. CAS Number List of Some Oligomeric or Polymeric Chemicals That

Might Contain Glycol Ether Components within the Category . . . . . . . . . . D-162
D-2

Section 1. Introduction

On June 28, 1994, EPA promulgated a final rule (published in the Federal Register July 5,

1994) modifying the definition of the glycol ethers category on the list of toxic chemicals under

Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA),

42 U.S.C. 11001 et.seq. The effect of this modification, which is described at 59 FR 34386, is

that many high molecular weight glycol ethers were excluded from the category. As described in

the final rule, this modification was made retroactive for the 1993 reporting year for reports due

July 1, 1994. This modification is also effective for all subsequent reporting years. As part of

this modification and as the result of public comment, EPA changed the category name at 40

CFR 372.65(c) from ‘glycol ethers’ to ‘certain glycol ethers.’ However, this document will refer

to the constituents of this category simply as glycol ethers. At the time of the modification, EPA

indicated that the Agency would work with the public and the regulated community to develop,

as appropriate, interpretations and guidance that the Agency determines are necessary to facilitate

accurate reporting for the modified glycol ethers category. This document constitutes such

guidance.

Who Must Report

A plant, factory, or other facility is subject to the provisions of EPCRA section 313, if it

meets all three of the following criteria:

& It conducts manufacturing operations (is included in Standard Industrial

Classification (SIC) codes 20 through 39); and

& It has 10 or more full-time employees (or the equivalent 20,000 hours per year);

and

& It manufactures, imports, processes, or otherwise uses any of the toxic chemicals

listed on the EPCRA section 313 list in amounts greater than the “threshold”

quantities specified below.

Thresholds

Thresholds are specified amounts of toxic chemicals manufactured, processed, or

otherwise used during the calendar year that trigger reporting requirements.

If a facility manufactures or imports any of the listed toxic chemicals, the threshold

quantity will be:

& 25,000 pounds per toxic chemical or category over the calendar year.

If a facility processes any of the listed toxic chemicals, the threshold quantity will be:

& 25,000 pounds per toxic chemical or category over the calendar year.

If a facility otherwise uses any of the listed toxic chemicals, the threshold quantity is:
D-3

& 10,000 pounds per toxic chemical or category over the calendar year.

EPCRA section 313 requires threshold determinations for chemical categories to be based

on the total of all chemicals in the category manufactured, processed, or otherwise used. For

example, a facility that manufactures three members of a chemical category would count the total

amount of all three chemicals manufactured towards the manufacturing threshold for that

category. When filing reports for chemical categories, the releases are determined in the same

manner as the thresholds. One report is filed for the category and all releases are reported on this

form.

Glycol Ethers Category Definition

The glycol ethers category is defined by the following formula:

R - (OCH CH ) - OR’ 2 2n

where:

n = 1, 2, or 3;

R = Alkyl C7 or less, or phenyl or alkyl substituted phenyl;

R’ = H or alkyl C7 or less, or

OR’ consisting of a carboxylic acid ester, sulfate, phosphate, nitrate, or

sulfonate.

Chemicals that meet this category definition are reportable.

EPA is providing three lists of CAS numbers and chemical names to aid the regulated

community in determining whether they need to report for the glycol ethers category. Section 2

(pages 5 to 159) lists individual chemicals that meet the definition of the EPCRA section 313

‘certain glycol ethers’ category. This list consists only of chemicals that have been assigned CAS

numbers and, thus, is not exhaustive. If a facility manufactures, processes, or otherwise uses, in

greater than threshold quantities, a glycol ether that meets the category definition, whether or not

that chemical is on the list, they must report the chemical.

Section 3 (pages 160 to 161) lists chemical mixtures which contain glycol ethers that

meet the definition of the EPCRA section 313 ‘certain glycol ethers’ category. EPA has tried to

make this list as complete as possible; however, not all mixtures that contain reportable glycol

ethers will necessarily appear on this list. If a facility manufactures, processes, or otherwise uses

a mixture which includes components, in greater than threshold quantities, that meet the

definition of the EPCRA section 313 ‘certain glycol ethers’ category, they must report the glycol

ether component(s) that meet the category definition.

Section 4 (pages 162 to 180) lists oligomeric and polymeric chemicals (for the category

formulae, R - (OCH CH ) - OR’, n is unspecified) that might contain a glycol ether component 2 2n

(n = 1, 2, or 3). EPA has tried to make this list as complete as possible; however, not all

oligomeric or polymeric chemicals that might contain glycol ethers will necessarily appear on
D-4

this list. If a facility manufactures, processes, or otherwise uses an oligomeric or polymeric

chemical that contains components, in greater than threshold quantities, that meet the definition

of the EPCRA section 313 ‘certain glycol ethers’ category, they must report the glycol ether

component(s) that meet the category definition.

Ethylene Glycol Ethers versus Propylene Glycol Ethers

The members of this category are glycol ethers derived from ethylene glycol, diethylene

glycol, and triethylene glycol. This category does not contain glycol ethers based on propylene

glycol, dipropylene glycol, or tripropylene glycol.

Individually Listed Glycol Ethers

There are two chemicals, 2-methoxyethanol (CAS number 109-86-4) and 2-ethoxyethanol

(CAS number 110-80-5) that are on the individual chemical list and CAS number lists (40 CFR

37265(a) and (b)). Threshold determinations should be made for each of these chemicals

individually and separately from the glycol ethers category.

De Minimis Concentrations

The glycol ethers category is subject to the one percent de minimis concentration. Thus,

mixtures that contain members of this category at concentrations in excess of one percent should

be factored into threshold and release determinations.
Appendix E

UNIT CONVERSION FACTORS

(From U.S. Coast Guard Commandant Instruction M.16465.12A)
E-1

CONVERSION FACTORS

To Convert To Multiply By

Length

inches millimeters 25.4

inches feet 0.0833

feet inches 12

feet meters 0.3048

feet yards 0.3333

feet miles (U.S. statute) 0.0001894

yards feet 3

yards miles (U.S. statute) 0.0005682

miles (U.S. statute) feet 5280

miles (U.S. statute) yards 1760

miles (U.S. statute) meters 1609

miles (U.S. statute) nautical miles 0.868

meters feet 3.271

meters yards 1.094

meters miles (U.S. statute) 0.0006214

nautical miles miles (U.S. statute) 1.152

Area

square inches square centimeters 6.452

square inches square feet 0.006944

square feet square inches 144

square feet square meters 0.09290

square meters square feet 10.76

square miles square yards 3,097,600

square yards square feet 9

Volume

cubic inches cubic centimeters 16.39

cubic inches cubic feet 0.0005787

cubic feet cubic inches 1728

cubic feet cubic meters 0.02832

cubic feet U.S. gallons 7.481

cubic meters cubic feet 35.31

liters quarts (U.S. liquid) 1.057

quarts (U.S. liquid) liters 0.9463

U.S. gallons barrels (petroleum) 0.02381

U.S. gallons cubic feet 0.1337

U.S. gallons Imperial gallons 0.8327

barrels (petroleum) U.S. gallons 42

Imperial gallons U.S. gallons 1.201

milliliters cubic centimeters 1
CONVERSION FACTORS (Continued)

To Convert To Multiply By

E-2

Time

seconds minutes 0.01667

seconds hours 0.0002778

seconds days 0.00001157

minutes seconds 60

minutes hours 0.01667

minutes days 0.0006944

hours seconds 3600

hours minutes 60

hours days 0.04167

Mass or Weight

pounds kilograms 0.4536

pounds short tons 0.0005

pounds long tons 0.000464

pounds metric tons 0.0004536

tons (short) pounds 2000

tons (metric) pounds 2205

tons (long) pounds 2240

kilograms pounds 2.205

tonnes (metric tons) kilograms 1000

Energy

calories Btu 0.003968

calories joules 4.187

Btu (British thermal units) calories 252.0

Btu joules 1055

joules calories 0.2388

joules Btu 0.0009479

Velocity

feet per second meters per second 0.3048

feet per second miles per hour 0.6818

feet per second knots 0.5921

meters per second feet per second 3.281

meters per second miles per hour 2.237

miles per hour meters per second 0.4470

miles per hour feet per second 1.467

knots meters per second 0.5148

knots miles per hour 1.151

knots feet per second 1.689

pounds per cubic foot grams per cubic centimeter 0.01602

grams per cubic centimeter pounds per cubic foot 62.42

grams er cubic centimeter kilograms per cubic meter 1000

kilograms per cubic meter grams per cubic centimeter 0.001
CONVERSION FACTORS (Continued)

To Convert To Multiply By

E-3

Pressure

ponds per square inch (absolute) (psia) kilonewtons per square meter (kN/m ) 6.895

psia atmospheres 0.0680

psia inches of water 27.67

psia millimeters of mercury (torr) 51.72

pounds per square inch (gauge) (psig) psia add 14.70

millimeters of mercury (torr) psia 0.01934

millimeters of mercury (torr) kN/m 0.1333

inches of water psia 0.03614

kilograms per square centimeter millimeters of mercury (torr) 735.6

inches of water kN/m 0.2491

kilograms per square centimeter atmospheres 0.9678

atmospheres kN/m 101.3

kilograms per square centimeter psia 14.22

atmospheres psia 14.70

bars kN/m 100

kilonewtons per square meter (kN/m ) psia 0.1450 2

bars atmospheres 0.9869

kilonewtons per square meter (kN/m ) atmospheres 0.009869 2

bars kilograms per square centimeter 1.020

2

2

2

2

2

Viscosity

centipoises pounds per foot per second 0.0006720

pounds per foot per second centipoises 1488

centipoises poises 0.01

centipoises Newton seconds per square meter 0.001

poises grams per centimeter per second 1

grams per centimeter per second poises 1

Newton seconds per square meter centipoises 1000

Thermal Conductivity

Btu per hour per foot per (F watts per meter-kelvin 1.731

Btu per hour per foot per (F kilocalories per hour per meter per (C 1.488

watts per meter-kelvin Btu per hour per foot per (F 0.5778

kilocalories per hour per meter per (C watts per meter-kelvin 1.163

kilocalories per hour per meter per (C Btu per hour per foot per (F 0.6720

Heat Capacity

Btu per pound per (F calories per gram per (C 1

Btu per pound per (F joules per kilogram-kelvin 4187

joules per kilogram-kelvin Btu per pound per (F 0.0002388

calories per gram per (C Btu per pound per (F 1
CONVERSION FACTORS (Continued)

To Convert To Multiply By

E-4

Concentration (in water solution)

parts per million (ppm) milligrams per liter 1

milligrams per liter ppm 1

milligrams per cubic meter grams per cubic centimeter 1×10

grams per cubic centimeter milligrams per cubic meter 1×10

grams per cubic centimeter pounds per cubic foot 62.42

pounds per cubic foot grams per cubic centimeter 0.01602

-9

9

Temperature

degrees Kelvin ((K) degrees Rankine ((R) 1.8

degrees Rankine ((R) degrees Kelvin ((K) 0.5556

degrees centigrade ((C) degrees Fahrenheit ((F) first multiply by 1.8, then add 32

degrees Fahrenheit ((F) degrees centigrade ((C) first subtract 32, then multiply by

degrees centigrade ((C) degrees Kelvin ((K) add 273.2

degrees Fahrenheit ((F) degrees Kelvin ((K) add 459.7

0.5556

Flow

cubic feet per second U.S. gallons per minute 448.9

U.S. gallons per minute cubic feet per second 0.002228

Universal Gas Constant (R)

8.314 joules per gram mole-kelvin

1.987 calories per gram mole-kelvin

1.987 Btu per pound mole per (F

10.73 psia-cubic feet per pound mole per (F

82.057 atm-cubic centimeters per gram mole-kelvin

62.361 millimeters mercury liter per gram mole-kelvin
Index-1

INDEX

The pages listed in bold text in the index correspond to the primary uses or definitions of the

associated term. Additionally, this index includes a list of primary purposes for examples and

common errors that are presented throughout the document.

Acid aerosol (sulfuric acid and hydrochloric acid) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6, 3-7

Activity

Chemical use, subcategories . . . . . . . . . . . . . . . . . . . 2-11, 2-12, 3-8, 3-10 to 3-12

Exemption (see Exemptions)

Thresholds (see Thresholds)

Air emissions

Fugitive or non-point . . 4-4, 4-6, 4-27, 4-37 to 4-39, 4-40, 4-42, 4-43, 4-45, 4-47

Stack or point source . . . . . . 4-6, 4-24, 4-27, 4-37 to 4-39, 4-43, 4-45, 4-47, 4-48

Article exemption (see Exemptions)

Automated toxic chemical release inventory software (ATRS) . . . . . . . . . . . . . . . . . . . . . . . 2-16

Byproduct (see Manufacture)

Chemical-specific

Acid aerosols . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6, 3-7

Ammonia . . . . . . . . . . . 3-5, 3-10, 3-21, 4-6, 4-21, 4-39, 4-44, 4-47, Appendix C

Ethylene glycol . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10, 3-12, 4-36, 4-39, 4-47

Formaldehyde . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10, 3-11, 4-24, 4-47

Glycol ethers . . . . . . . . . . . . . . . . . . . . 2-10, 3-24, 4-36, 4-44, 4-47, Appendix D

Hydrochloric acid . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6, 3-7

Metal compounds . . . . . . . . 2-10, 3-11, 4-12 to 4-16, 4-29, 4-38, 4-44, 4-50, 4-51

Methanol . . . . . . . . . . . . . . . 2-10, 3-1, 3-10 to 3-12, 3-20, 4-36, 4-38, 4-39, 4-47

Methyl ethyl ketone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10, 3-25, 4-44

Nitrate compounds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6, 4-21, 4-44

Phenol . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10, 3-10 to 3-12

Sulfuric acid . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-7

Toluene . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10, 3-12, 4-6, 4-25, 4-48

Chemical processing aid . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-12

Combustion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20, 4-13 to 4-15, 4-24

For energy recovery off-site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-14, 4-15

For energy recovery on-site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-13

For treatment off-site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16

For treatment on-site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10, 4-12, 4-15, 4-16

Common errors

Acids and bases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-52

Assuming a threshold is exceeded . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-24

Certain glycol ethers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-24

Coincidental manufacturing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-12

Direct reuse vs. Recycling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-15

Double counting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17

Exempt activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-13

Form A reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-19

Mass balance for otherwise used chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . 4-22
INDEX (Continued)

Index-2

Mixture components . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4

Reporting carrier chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-46

Reporting fugitive emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6

Shipping container residue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-9

Sulfuric and hydrochloric acid (acid aerosols) . . . . . . . . . . . . . . . . . . . . . . . . . . 3-7

Threshold determination for recirculation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-9

Threshold determination for metal compounds . . . . . . . . . . . . . . . . . . . . . . . . 3-24

Treatment efficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-20

Zero release and other waste management quantities . . . . . . . . . . . . . . . . . . . 3-24

Container residue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8 to 4-11, 4-37 to 4-39, 4-43, 4-45, 4-46

Example, container residue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10

De minimis (see Exemptions)

Example, de minimis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-14

Example, de minimis concentration ranges . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-15

Disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 to 4-8

Land, on-site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 to 4-8, 4-34

Land, off-site . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8, 4-34, 4-38, 4-43, 4-49, 4-53

Documentation (see Recordkeeping)

Double counting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17

Common error, double counting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17

Dyeing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6, 2-10, 4-31, 4-41, 4-43 to 4-45, 4-49, 4-50

Emission factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-18 to 4-19, 4-22 to 4-24, 4-40, B-6

Example, emission factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-24, B-6

Employee equivalent calculation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7, 2-8

Example, calculating employees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8

Energy recovery (see Combustion for energy recovery)

Engineering calculations . . . . . . . . 4-18 to 4-19, 4-24 to 4-26, 4-39, 4-40, 4-47, 4-50, 4-53, B-4

Example, engineering calculations . . . . . . . . . . . . . . . . . . . . . . . . 4-25, 4-50, 4-51

EPCRA hotline ...................................................... 1-2, 1-3, 1-5

Establishment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1, 2-5, 2-6

Example, primary SIC code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6

Example, multiple establishments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2

Examples

Air pollutant controls for chemical finishing . . . . . . . . . . . . . . . . . . . . . . . . . . 4-48

Articles exemption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-17, 3-18

Chemicals in process water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-21

Chromium compounds in wastewater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-51

Container residue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10

De minimis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-14

De minimis concentration ranges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-15

Dye Fixation Values . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-50

Emission factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-24

Employee equivalent calculation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8

Engineering calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-25

Form A threshold . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-18
INDEX (Continued)

Index-3

Laboratory activity exemption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19

Mass balance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-21

Mass balance for air estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-40

Mass balance for machine maintenance chemical . . . . . . . . . . . . . . . . . . . . . . 4-35

Monitoring data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-20

Motor vehicle exemption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20

Multiple establishments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2

Nonvolatile wet processing chemical . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-49

On-site waste treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-12

Primary SIC code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6

Process equipment exemption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20

Threshold determination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8

Threshold determination, recirculation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-22

Threshold worksheet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-25 to 3-27

Xylene isomers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-9

Exemptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-13 to 3-21

Activity-related . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19 to 3-21

Article . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-16 to 3-18

De minimis .............................................. 3-14 to 3-16

Drawn from environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20

Facility-related ............................................ 3-18, 3-19

Grounds maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19

Janitorial . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19

Laboratory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-18

Motor vehicle . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20

Personal use, example . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19

Structural components . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19

Vanadium . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-7

Fabric formation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-31, 4-36 to 4-41

Fabric preparation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-41 to 4-52

Facility

Auxiliary facility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5

Covered facility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4 to 2-7

Multi-establishment facilities (see Establishments)

Pilot plant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6, 2-7

Facility-related exemption (see Exemption)

Fixation (dye) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-49, 4-50

Form A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3, 1-4, 2-1, 2-17 to 2-19

Common error, Form A reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-19

Example Form A threshold . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-18

Form R . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3, 2-1, 2-16, 2-17, 4-4 to 4-17, 4-27 to 4-30

Glycol ethers (see Chemical specific)

Impurity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-10, 3-14

Knitting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5, 4-31, 4-32, 4-36 to 4-41

Laboratory exemption (see Exemption)
INDEX (Continued)

Index-4

Manufacture/Manufacturing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-11, 3-4, 3-6, 3-8, 3-10

Byproduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-11, 3-10, 3-16, 4-3

Coincidental manufacture . . . . . . . . . . . . . . . . . . . . . 2-11, 2-12, 3-10, 3-16, 3-19

Manufacturing subcategories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-10

Mass balance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-18 to 4-22, 4-39, 4-47, 4-54

Example, mass balance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-21, 4-40

Methods (see Reportable amount estimate methods)

Mixture . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-11, 2-12, 3-1 to 3-4, 3-11, 3-12, 3-14

Monitoring data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-18 to 4-20, 4-48, B-1, B-7

Example, monitoring data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-20

Motor vehicle exemption (see Exemption)

MSDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2 to 3-4, 3-12, 3-13

Otherwise use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-12, 3-8, 3-12

Common error, mass balance for otherwise used chemicals . . . . . . . . . . . . . . 4-22

Owner/operator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3

PBT chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-13 to 2-15

Penalties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4

Pilot plant (see Facility)

Point source (see Air emissions)

POTW . . . . . . . . . . . . 4-8, 4-12, 4-16, 4-19, 4-20, 4-29, 4-38, 4-39, 4-42, 4-43, 4-46, 4-47, 4-51

Printing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6, 2-10, 3-18, 4-31, 4-41, 4-43 to 4-45, 4-50

Process/processing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-11, 3-8, 3-11

Process equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20

Example, process equipment chemical use . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20

Process water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20

Example, chemicals in process water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-21

Processing subcategories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-11

Product fabrication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-31, 4-52-4-54

Qualifiers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4 to 3-7

Recordkeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-20 to 2-22

Recycling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-23, 4-5, 4-13, 4-15, 4-28, 4-30

Off-site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-23, 4-5, 4-15, 4-30

On-site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-23, 4-5, 4-13 to 4-15, 4-28

Release . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Chapter 4

Accidental . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16, 4-17, 4-27 to 4-30

Estimates (steps to calculate) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1, 4-17

Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3, 4-34, 4-44, 4-53

Types . . . . . 4-3 to 4-5, 4-34, 4-35, 4-38, 4-39, 4-42, 4-43, 4-45, 4-47, 4-53, 4-54

Remedial actions (remediation) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-22, 4-16, 4-17

Reportable amount . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-17, 2-19

Reportable amount estimate methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17 to 4-30

(see Emission factors)

(see Engineering calculations)

(see Mass balance)

(see Monitoring data)
INDEX (Continued)

Index-5

Reporting criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 to 2-4

Reuse . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-9, 3-21

Sources (see Release)

Standard Industrial Classification (SIC) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4 to 2-7

Primary SIC code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6

Supplier notification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-15, 3-3, 3-4

Technically qualified individual . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-18, 3-19

Thresholds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8, 3-9

Example, Form A threshold . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-18

Threshold determination . . . . . . . . . . . . . . . . . . . . . . . . . . Chapter 3, 3-23 to 3-27

Threshold worksheet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-26

Total annual reportable amount (see Reportable amount)

Trade secret . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-19, 2-20

Transfers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8, 4-9, 4-15 to 4-17

Treatment efficiency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10, 4-12, 4-20

Treatment for destruction

On-site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10, 4-12, 4-15 to 4-16, 4-28, 4-47

Off-site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16, 4-29

Types (see Release)

Waste management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Chapter 4

Waste treatment (see Treatment for destruction)

Common error, treatment efficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-20

Example, on-site waste treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-12

Wastewater discharge . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5, 4-6, 4-27, 4-47

Weaving . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-31, 4-36 to 4-41

Wet Processing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-41 to 4-52

Yarn formation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-31, 4-33 to 4-35