60 APPENDIX B

REPORTING FORM R AND FORM A CHANGE S AND ASSOCIATED

INSTRUCTION REVISIONS61

Appendix B: Reporting Form R and Form A Changes and Associated Instruction Revisions

New revisions to the Form R and Form A instructions follow. These revisions are aimed at improving the user experience by clarifying the intent of questions and reducing confusion. An overview of changes made in this version of the Form R and Form A is provided in Table B

- 1

below. Revisions to the instructions are identified in the subsequent pages using underlined text

for new text and strikeout for deleted text . Sections of the instructions that remain unchanged are

not referenced. To review the existing instructions, Toxic Chemical Release Inventory Reporting

Forms and Instruction s

– Revised 20 12 Version , visit http://www.epa.gov/tri/report/index.htm

.

Revisions to Form R and Form A

Tabl e B

- 1: Overview of Form R and Form A Revisions Please refer to specific sections in the f ollowing text for details

Form Revision Rationale Form

1 Add an optional extension to all phone numbers to allow facility representatives to provide the extension needed for a direct connection. (Part I: Section 4) The phone number provided is often the main compa ny line. Many companies have extensions for direct connection with employees.

Addition of the optional phone extension would expedite calls to facilities and help ensure the EPA can reach facilities when needed. R/A

2 Add an optional field fo r the reach code corresponding with the receiving water body for each surface water discharge. (Part II: Section 5.3) 40 CFR §372.85(b)(7) requires facilities to include on their form Rs “the name(s) of receiving stream(s) or water body to which the

chemi cal is released.” Water body name is not a unique identifier, however, and a single water body can cover a large and disparate geographic area. Therefore, in order to model the potential impact of chemical discharges on downstream and intermediate receiv ing water bodies, EPA and other regulatory agencies, researchers, and analysts

use the 14

- digit codes, called reach codes, assigned in the USGS’s National Hydrography Dataset (NHD). These reach codes identify a continuous piece of surface water with simil ar hydrologic characteristics. Once linked to the NHD by their reach code, the upstream/downstream relationships of water

- related entities such as drinking water supplies, fish habitat areas, or wild and scenic rivers can be analyzed using software tools r anging from spreadsheets to Geographic Information Systems (GIS) and the potential cumulative environmental impacts of TRI chemical can be assessed. While optional, this field would populate automatically when a user selects their receiving water body on t he map provided in the TRI

MEweb interface for this section. EPA is also looking into whether

TRI

- MEweb could pre

- populate this field in cases where the reach code is included on facilities’ discharge permits. R

3 Move the header “5.5 Disposal to land

on

- site” to precede Sections 5.4 and 5.5

on Form R so that it covers both 5.4

and 5.5. Re

- word 5.4.1 and 5.4.2 to fit

under the new header as follows: This change would clarify that releases to underground injection wells

are considered releases to land. R62

Section 5.4

- 5.5: Disposal to land on

site, Section 5.4.1: Class 1 Underground Injection Wells, Section

5.4.2 Class II

- V Underground Injection

Wells. (Part II: Section 5.4

- 5.5)

4 Provide the heading, “Production

related waste managed” for Sections

8.1

- 8.7 and re

- label Section 8.8 “Non

production

- related waste managed,” with a footnote indicating that this Section “includes quantities released to

the environment or transferred off

- site as a result of remedial actions, catastrophic events, or other one

- time

e vents not associated with production processes” (Part II: Section 8.1

- 8.8). Form R does not currently indicate that quantities reported in Sections 8.1 through 8.7 are exclusive of the amounts reported in Section 8.8. Adding the labels “Production

- related” and “Non

- production

- related” waste managed would mirror the terminology used to describe these data elements in TRI tools and the TRI National Analysis and clearly delineate which releases and transfers to report in which Sections. R

5 Add checkboxes to indicate whether the facility has provided a “Production Ratio” or an “Activity Ratio” (Part II: Section 8.9). Section 6607(b)(5) of the PPA requires facilities to submit a ratio of production in the reporting year to production in the previous year.

Whe re some variable other than production is the primary influence on waster characteristics or volumes, facilities may base this ratio on the primary influencing variable. T he existing form does not specify which type of ratio was used and thus limits the ut ility of this metric. Additionally, “production or activity ratio” is a more precise description of this Section than “production ratio or activity index” since the metric reported is a ratio regardless of whether production or some other activity variable is used. R

6 Add a new column where the facility can provide a n optional percentage range indicating the estimated annual reduction in chemical waste generation associated with a given source reduction activity (Part II: Section 8.10). This change would make it easier to report and assess the effectiveness of different types of source reduction activities and thus promote the adoption and recognition of successful pollution prevention practices. To simplify reporting, facilities would report their estimat es using one of six percentage ranges (just as treatment efficiencies are reported in ranges in Section 7). While optional, completion of this Section would be a simple way for a facility to highlight positive steps it has taken to

reduce releases of toxic chemicals to the environment. R

7 Provide optional barrier codes that facilities can use to indicate why they could not implement any source reduction activities during the reporting

year (Part II: Section 8. 11 ). Facilities are required to pick a code if they perform a new source reduction activity. However, there is currently no way for a facility to indicate why they didn’t implement a source reduction activity. While these codes would be optional, it would allow EPA to assist facilities

in overcomi ng barriers to implementing source reduction activities. R

8 Allow facility to categorize optional

free

- text information entered in Sections 8.11 and 9.1 by selecting from a list of topics provided in TRI

- MEweb (Part II: Section 8.11 and Section 9.1)

. Le tting facilities flag their free

- text entries as relevant to certain commonly

- used topics would improve TRI tools that display free

- text information, data quality efforts, and overall analytical utility of the

dataset. R63

Revision to TRI

- MEweb

Additiona lly, the EPA proposes modifying TRI

- MEweb to collect, as optional, information that

some facilities have historically provided, unsolicited, to EPA on matters related to TRI (collectively called miscellaneous TRI documents). Examples of these miscellaneous TRI documents include updates to contact and location information for the facility and reasons for non

reporting. Some of this information is useful to the Agency and could be useful to the public. Currently, the EPA receives this unsolicited information on paper.

This proposed modification would allow for an online means for the EPA to receive miscellaneous documents, reducing the cost of processing their submission aligning how EPA processes such documents with the recent requirement to submit TRI rep orting forms electronically. In other words, with this change, facilities could use TRI

- MEweb to provide details on specific categories

of information that they have been providing on a voluntary basis to the EPA throughout the existence of the program (e. g., supplemental information on updates to the facility’s name, status, location, and/or parent company; supplemental information on updates on whom to contact for technical and/or public matters; and reasons for not reporting (indicating the facility did not meet thresholds or did not report for any other appropriate reason))

. Receipt and processing of this information would not affect any reporting forms certified and submitted to the agency, but rather would allow facilities to provide an electronic mean s to submit contextual information concerning their facilities that can enhance the context of TRI data for the EPA as well as for the public

. Specific Form Revisions and Associated Instruction Revisions

PART II CHEMICAL

- SPECIFIC INFORMATION

Section 5. Quantity of the Toxic Chemical Entering Each Environmental Medium Onsite

5.3 Discharges to Receiving Streams or Water Bodies

Form Revisions: Added column for “Reach code (optional)” next to “Stream or Water Body

Name”

Instruction Revisions: See unde rlined and strikeout text which follows. In Section 5.3 you are to enter all the names of the streams or water bodies to which your facility directly discharges the EPCRA Section 313 chemical on which you are reporting. In addition, you may als o enter the 14

- digit reach code assigned to each receiving water body by the USGS’s National Hydrography Dataset (NHD). TRI

- MEweb will automatically populate the appropriate code field when you select your receiving waterbody on the map provided in the use r interface for this section. You may also be able to find the correct reach code by consulting readily available sources, such as your discharge permit. Note that reach data are not available for Alaska, Guam,

American Samoa and the Northern Mariana Islan ds, so facilities located in these areas should

leave this field blank.

EPA maps all reported discharges to reaches for purposes of its Risk Screening Environmental Indicators (RSEI) model, Discharge Monitoring Reports (DMR) Pollutant Loading Tool, and fo r64

other analyses. Identifying your stream or water body by entering a reach code in this section ensures that EPA will map your discharges to the correct reach.

Section 8. Source Reduction and Waste Management

Form and Instruction Revisions: Title chan ged from “Disposal or Other Releases, Source Reduction, and Recycling Activities” to “Source Reduction and Waste Management.” Provided heading, “Production

- related waste managed” for Sections 8.1

- 8.7. Section 8.8 re

- labeled “Non

production

- related waste ma naged,” with a footnote indicating that this Section “includes quantities released to the environment or transferred off

- site as a result of remedial actions, catastrophic events, or other one

- time events not associated with production processes.”

8.9 Pro duction Ratio or Activity Ratio

Form Revisions: Question changed to “Production Ratio or Activity Ratio (select one and enter value to right).” Checkboxes added next to “Production Ratio” and “Activi ty Ratio.”

. Instruction Revisions: See underlined an d strikeout text which follows. For Section 8.9, you must provide either a production or activity ratio or an activity index and indicate which type of ratio you reported using the checkboxes provided. The production or activity ratio or activity index all ows year

- to

- year changes in release and other waste management quantities to be viewed within the context of production.

Production Ratio vs. Activity Ratio Index

A production ratio is a ratio of reporting year production to prior year production. Calcu late a production ratio for the chemical when production levels most directly affect the quantity of the chemical managed as waste.

An activity index ratio is also a ratio of current year to prior year values, but it is used when a variable other than pr oduction is the primary influence on the quantity of the reported EPCRA Section 313 chemical managed as waste. An activity Index ratio may be applicable when the EPCRA Section 313 chemical is “otherwise used” (e.g., non

- incorporative activities such as extraction solvents, or metal degreasers).

What Variable is Used to Calculate This Ratio?

The production or activity ratio or activity index must be based on the variable(s) that most directly affect(s) the quantity of the EPCRA Section 313 chem ical generated as waste (i.e., recycled, used for energy recovery, treated, disposed or otherwise released). If an EPCRA Section 313 chemical is used in the production of refrigerators, for example, the production ratio would be

based on the number of refr igerators produced (see Example 22).

In most cases, the production or activity ratio or activity index must be based on a variable other than the quantity of the EPCRA Section 313 chemical manuf actured, processed, or otherwise used.

This is because indic es based on chemical or material usage may reflect the effect of source65

reduction activities (e.g., process improvements) rather than changes in business activity. If the reported EPCRA Section 31 3 chemical is itself the end product, however, the quantitie s of the EPCRA Section 313 chemical(s) produced in the current and prior years do provide a good basis for the production ratio. In any case, the variable used to calculate production ratio should generally be a measure of output, not a measure of input or throughput. Example 25 gives examples of production ratio or activity index variables reported by industry.

Reporting Tips:

 TRI

- MEweb includes a production or activity ratio /activity index wizard to help you calculate your ratio automatically.

 The ratio or index must be reported to the nearest tenths or hundredths place (i.e., one or two digits to the right of the decimal point) for all EPCRA 313 chemicals, including PBT chemicals. A zero is not an acceptable response unless the calculated value is less t han 1/200 th

, which can then be rounded to zero.

 If the manufacture, processing, or other use of the reported EPCRA Section 313 chemical began during the current reporting year, select NA as the production or activity ratio or activity

index . Otherwise, yo u must enter a value even if your facility did not exceed a reporting threshold for the chemical in the previous reporting year.

 The ratio or index is not to be reported as a percent change between years (i.e., for a 10 percent increase, you would report t he ratio 1.10, not 10% or 10).

 Some facilities may use the same EPCRA Section 313 chemical in more than one production process. In this case, a production or activity ratio or activity index can be estimated by weighting the production or acti vity ratio for each process based on the respective contribution of each process to the quantity of the reported EPCRA Section 313 chemical recycled, used for energy recovery, treated, or disposed of (see Example 25).

 It is important to realize that if yo ur facility reports on more than one EPCRA Section 313 chemical, the production or activity ratio or activity index may vary for different chemicals.

 Details regarding the method used to calculate the Production or Activity Ratio /Activity Index can be included in Section 9.1, “Additional Information.” This information will provide context for the production or activity ratio and may help TRI data users better understand changes in releases or other waste management quantities. In Example 22, the facility could report, “Used the number of refrigerators painted as the production variable, because our facility otherwise uses toluene to paint refrigerators” in order to provide more information in

Section 9.1.66

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

Form Revisions: Added new column (d), “Estimated Annual Reduction (Enter code(s)) (optional)”.

Instruction Revisions: See underlined and strikeout text which fol lows. If Your Facility Implemented Source Reduction Activities. If your facility implemented a new source reduction activity for the reported EPCRA Section 313 chemical during the reporting year, report the activity or activities that were implemented by s electing the most relevant activity code(s) from the drop down list in TRI

- MEweb (see W

- codes listed below).

For each “Source Reduction Activity” reported, you must also enter one or more code(s) that correspond to the internal and external method( s) or information sources you used to identify the possibility for implementing a source reduction activity at your facility. If more than three methods were used to identify the source reduction activity, enter only the three codes that

contributed most t o the decision to implement the activity.

For each “Source Reduction Activity” reported, you may also provide an estimate of the resulting

reduction in the annual amount of the chemical to be managed as waste (i.e., released, recycled, treated, or used fo r energy recovery). The estimated annual reduction can be calculated as follows:

(B

- A) × 100%

B where:

A = estimated amount of the EPCRA Section 313 chemical to be managed as waste in the year after the source reduction activity has been implemented and

B = estimated amount of the EPCRA Section 313 chemical that would have been managed as waste had the source reduction activity not been implemented.

If you choose to complete this field, the reductions associated with your pol lution prevention

efforts will be featured on EPA’s website through the Pollution Prevention Search Tool at www.epa.gov/tri/p2. The estimated annual reduction should be reported using the range codes

listed below.

Reporting Tips:

 This estimate is based on the facility’s best readily available information at the time the activity is reported and will not necessarily reflect the actual reduction once implementation of the activity is completed.

 The estimated annual reduction only accounts for the impact of t he particular source reduction activity. For example, if production is expected to double, but chemical quantities are expected to remain constant (when they also would have doubled if not for the source reduction activity), then the estimated annual reduc tion for the activity is 50%.

Estimated Annual Reduction Range Codes:67

R1 = 100% (elimination of the chemical)

R2 = greater than or equal to 50%, but less than 100%

R3 = greater than or equal to 25%, but less than 50%

R4 = greater than or equal 15%, bu t less than to 25%

R5 = greater than or equal 5%, but less than to 15%

R6 = greater than 0%, but less than 5%

8.11 If you wish to submit additional optional information on source reduction, recycling, or pollution control activities, provide it here.

Form Revisions: None.

Instruction Revisions: See underlined and strikeout text which follows. When completing this section in TRI

- MEweb, you may indicate that you have submitted information pertaining to one or more of the following topics by checking a box next to the topic to which your information pertains:

 Source Reduction

 Recycling

 Energy Recovery

 Waste Treatment

 General Environmental Management

 Methods for Identifying P2 Opportunities

 Ways P2 Was Incorporated in Original Process Design

If you do so , each topic you have selected will be included in your Section 8.11 entry, followed by the information you have provided about that topic. Using these checkboxes will facilitate searches for information about P2 and other environmentally

- friendly practic es by users of the TRI

database.

Barriers to Implementing Pollution Prevention Activities You may also provide details on any barriers your facility faces in implementing additional source reduction, recycling or pollution control activities. If you choos e to provide this information, EPA

encourages you to select one or more of the following barrier categories from the checklist provided in TRI

- MEweb and describe specifically how one of these barrier categories applies to your facility:

1. Insufficient cap ital to install new source reduction equipment or implement new source

reduction activities/initiatives.

2. Require technical information on pollution prevention techniques applicable to specific production processes.

3. Concern that product quality may decline as a result of source reduction.

4. Source reduction activities were implemented but were unsuccessful.

5. Specific regulatory/permit burdens.

6. Pollution prevention previously implemented

- additional reduction does not appear technically or economically feasible

.68

7. No known substitutes or alternative technologies.

8. Other barriers.

Each category you select in TRI

- MEweb will be included in your Section 8.11 entry, followed by the additional details you provided on that topic (if any).

9.1 Miscellaneous, Optional, an d Additional Information for Your Form R Report.

Form Revisions: None.

Instruction Revisions: See underlined and strikeout text which follows. Your facility may provide additional information pertaining to any portion of your Form R

submission in the b ox provided in the free text box provided in TRI

- MEweb or on the hard copy form (trade secret submissions only). Your submissions to Section 9.1 regarding miscellaneous, additional, optional information may provide the Agency and/or the public with useful data that helps explain why your facility submitted data in one or more data elements that might appear unusual or inconsistent with previous TRI Form R submissions or with other data supplied by your facility during this reporting year. Such additional data may help EPA reduce the need for additional data quality control as well as additional TRI

- related enforcement and compliance

efforts. Do not submit information you consider to be CBI or otherwise protected on your

Form R.

When completing this secti on in TRI

- MEweb, you may indicate that you have submitted information pertaining to one or more of the following topics by checking a box next to the topic to which your information pertains:

 Changes in Production Levels

 Calculation Methods, e.g., Emission Factors

 One

- time or Intermittent Events Impacting Reported Quantities

 Issues or Difficulties Encountered in Submitting Form



 Additional Contact Info

 Other Regulatory Requirements Related to This Chemical

 No TRI Reports Expected for This TRIFID Next Year

 No TRI Report Expected for This Chemical Next Year

If you do so, each topic you have selected will be included in your Section 8.11 entry, followed by the information you have provided about that topic (if any). Using these checkboxes will ensure

that EPA and other TRI data users understand the factors that have contributed to any apparent data quality issues. Note that if you select one of the last two topics above, it is helpful to include the reason you will not be submitting a report next year (e.g., f acility closure, move, temporary shutdown, etc.).

APPENDIX C INFORMATION SOURCES CONTAINING DATA SUBSETS, BUT NOT

COMPREHENSIVELY COMPARABLE ALTERNATIVES TO TRI DATA6 / 11 /14 69 Appendix C: Information Sources Containing Data Subsets, but not Comprehensively Compar able Alternatives to TRI Data

In this appendix, data elements available from several information sources are compared to those reported to TRI. The analysi s is broken down by the specific types of data collected under TRI. While some sources may appear to be substitutes for TRI, they do not adequately address the entire scope of TRI, even in combination. For example, a given source may:

 Not include all toxic chemicals covered by TRI,

 Be compiled less frequently than TRI, and/or

 Not be as easily accessible ( if at all) to the general public.

Table C

- 1: Relevant Information Sources
(TRI Included for Comparison)

Description Chemical Coverage Industry/Facility Coverage Reporting

Frequency Public Access

TRI DATA

EPCRA § 313 requires facilities to s ubmit reports on releases (including disposal) of particular toxic chemicals exceeding a given threshold. The reports provide information on the quantity of chemical released into the

environment and to which medium (air, land, water) the dispos al took pla ce , as well as information about waste management and

the amount of chemicals stored on

- site. TRI contains

information on releases, transfers, and pollution prevention activities for 593 individually

listed chemicals and

30 chemical categories

—

totaling

to 682 toxic

chemicals. NAICS codes

corresponding to SIC

codes 20

- 39, 10; 12; 4911, 4931, 4939; 4953; 5169; 5171; and 7389.

A facility need only report if it has 10 or more Full Time Equivalents (FTEs). Annual. EPA compiles the TRI data and

makes them avai lable through several data access tools, including the TRI Explorer and Envirofacts. Other organizations also make the data available to the public through

their own data access tools.6 / 11 /14 70 Description Chemical Coverage Industry/Facility Coverage Reporting

Frequency Public Access

AIR EMISSIONS (SECTIONS 5.1 AND 5.2) National Emissions Inventory (NE I) NEI provides estimates of anthropogenic pollutant emissions from stationary sources,

as well as area sources and mobile sources. These estimates, submitted to EPA by delegated authorities (state or county), electric utilities, and/or generated by EPA

f rom various sources, differ in estimation methodology used. 8 CAPs and 187

HAPs. No NAICS limitations. Triennial. CSV files can be downloaded from

EPA’s Web site.

Air Facility System (AFS) AFS contains compliance and permit data for stationary sources of air pollution regulated by U.S. EPA, and state and local air pollution agencies. N/A No NAICS limitations. Annual. Can be accessed on a facility

- by

facility basis through EPA data access tools, including Envirofacts

or the Enforcement and Compliance Hist ory Online (ECHO).

State Air Emissions Inventories Several states and regional agencies

maintain their own air emissions inventories. However, the amount of data as well as the types of data elements collected vary widely

from state to state. Varies wide ly (e.g.,

the California Air

Resources Board

maintains its own

list of about 400 toxic air pollutants). Varies. Varies. Most of these data are submitted to

NEI. Some data are available on

the Web on a state

- by

- state basis.

Title V Part 70 Operating Perm its
Under the 1990 Clean Air Act Amendments, facilities designated as "major sources" and facilities otherwise subject to § 112 and Title V must apply for a Title V Part 70 Operating Permit. As part of the application for a Title V permit, some facilities may have to report

emissions of air toxics. 187 HAPs. No NAICS limitations. At the time of permit application, renewal, and

modification

— permits are typically renewed every 5 years. No central repository for the

information.6 / 11 /14 71 Description Chemical Coverage Industry/Facility Coverage Reporting

Frequency Public Access

DIRECT DISCHARGES TO WATER (SE CTION 5.3) Integrated Compliance Information System

– National Pollutant Discharge Elimination System (ICIS

- NPDES)

ICIS

- NPDES is a national information management system that tracks implementation of the National Pollutant Discharge Elimination System (NPD ES) program, authorized by the Clean Water Act.

ICIS

- NPDES tracks permit issuance, permit limits, self

- monitoring data, compliance data and other data pertaining to facilities regulated under NPDES. Monitoring data for major dischargers includes only

chem icals for which a monitoring requirement has

been set in the permit

— a facility's record may not

include all pollutants actually discharged. No NAICS limitations. Major permittees

must submit Discharge Monitoring Reports (DMRs) monthly or quarterly; non

maj or permittees

must submit at least annually. Can be accessed on a facility

- by

facility basis through EPA data access tools, including Envirofacts,

and ECHO.6 / 11 /14 72 Description Chemical Coverage Industry/Facility Coverage Reporting

Frequency Public Access

UNDERGROUND INJECTION AND LAND DISPOSAL ON

- SITE (SECTIONS 5.4 AND 5.5) RCRA Biennial Reports

Sec tion 3002(a)(6) of the Resource Conservation and Recovery Act (RCRA) requires EPA to develop a program for hazardous waste generators to report the nature, quantities, and disposition of hazardous waste generated at least once every two years. In addition, section 3004(a)(2) of RCRA requires treatment, storage and disposal facilities (TSDFs) to submit a report on the wastes that they

receive from off

- site. The biennial Hazardous Waste Report (also known as the “Biennial Report”) was implemented in

1985 to c omply with these requirements. The Biennial Report form (8700

- 13A/B)

must be submitted to the authorized state agency or the EPA Regional Office by March 1st of every even

- numbered year.

The form includes information such as the facility's RCRA ID number, the name and address of the facility, the quantity of

hazardous waste sent to each TSDF in

the United States and the manner in which the waste was treated during the previous

year. Biennial Reports

contain data on

hazardous wastes as defined by RCRA

and re ported by

waste codes

– not all of which map directly to a single, unique chemical. No NAICS limitations;

however, certain waste categories are excluded (e.g., mining and agriculture). Biennial. Can be accessed on a facility

- by

facility basis through EPA d ata access tools, including Envirofacts.

Text files can be downloaded from
EPA’s Web site.

DISCHARGES TO A POTW (SECTION 6.1) RCRA Biennial Reports (BR) Biennial Reports require some reporting of discharges to POTWs. See above for more

details. See abo ve. See above. See above. See above.

ICIS

- NPDES6 / 11 /14 73 Description Chemical Coverage Industry/Facility Coverage Reporting

Frequency Public Access

ICIS

- NPDES allows for reporting of indirect discharges to water. See above for more

details. See above. See above. See above. See above.

TRANSFERS TO OTHER OFF

- SITE LOCATIONS (SECTION 6.2)

RCRA Biennial R eports (BR) Biennial Reports contain hazardous waste data from large quantity generators and TSDFs. Biennial Reports also require reporting of off

- site transfers on Form GM.

Information includes the RCRA ID of the facility to which the waste was shipped, the processes used to treat, recycle, or dispose of

the waste at the off

- site facility, the off

- site availability code, and the total quantity of waste shipped during the report year. The reports also provide data on the volume of hazardous waste shipped o ff

- site for land disposal, a release end

- point of relevance to

TRI . See above for more details. See above. See above. See above. See above.

CHEMICAL STORAGE AND INVENTORY DATA (SECTION 4.1)

EPCRA § 312 Tier I and II Reports

EPCRA § 312 requires that state s establish plans for local chemical emergency preparedness and that inventory information on hazardous chemicals be reported by

facilities to state and local authorities. Hazardous or extremely

hazardous

substances (essentially any substance that poses

a health or physical hazard). No NAICS exemptions

for facilities that are

covered under the reporting threshold requirements, but

facilities not included

under OSHA’s Hazard

Communication Standard (e.g., mines) do not have

to file. Annual. On a facility

- by

- f acility basis, by forwarding a written request.

Risk Management Plan (RMP)6 / 11 /14 74 Description Chemical Coverage Industry/Facility Coverage Reporting

Frequency Public Access

Under the authority of section 112(r) of the

Clean Air Act , the Chemical Accident

Prevention Provisions require facilities that produce, handle, process, distribute, or store certain chemicals to prepare a Risk Management Plan (RMP) and submit the RMP to EPA. These plans include

informati on about chemical amounts stored and processed at RMP facilities. Certain flammable

and toxic

substances. No NAICS limitations. At least every five years, or

within six months

of an incident. Restricted access: RMP

information may be accessed via

the Feder al Reading Rooms.

Chemical Data Reporting (CDR) Under TSCA Section 8(a), chemical

manufacturers (including importers) are required to report manufacturing

- related

information to EPA for sites that manufactured (including imported) 25,000 pounds or more o f a reportable chemical

substance any one calendar year between submission periods

. Industrial processing

and use information and commercial and

consumer use information must also be reported for these sites. CDR reporting typically covers about 7,000 to 8 ,000

chemicals in each reporting cycle. Limited to manufacturers,

including importers, of subject chemicals.

Certain manufacturers are exempt, including small manufacturers (sales <$40 million), those manufacturing a chemical

for research and development , those manufacturing chemicals as impurities, and those submitting information

under another TSCA

Section 8a rule. Every four years. Data claimed as Confidential Business Information (CBI) are not available to the public. Non

- CBI

data downloads are availa ble from
EPA’s CDR website.

POLLUTION PREVENTION DATA (SECTIONS 8.1

- 8.7; 8.10) RCRA Biennial Reports (BR) Biennial Reports contain pollution prevention information on hazardous waste from large quantity generators and TSDFs. Data are collected primarily by states, and are collated by EPA. See above for more

details. See above. See above. See above. See above.6 / 11 /14 75 Description Chemical Coverage Industry/Facility Coverage Reporting

Frequency Public Access

State Environmental Agency Databases

At least fourteen states 1 implement mandatory pollution prevention programs. Pollution prevention data coll ected under these programs varies by state, and may include both data similar to that collected by TRI (e.g., quantities of waste managed, source reduction activities, etc.) and details not found in TRI (e.g., pollution prevention plans, costs associated w ith waste management, etc.). Varies. Varies. May include TRI filers, facilities that use toxic chemicals, and generators of hazardous

waste. Varies. There is no central source for state collected pollution prevention data. Accessibility varies by state.

EMERGENCY RELEASE DATA (SECTION 8.8) National Response Center (NRC)

NRC collects real

- time information about virtually all oil and chemical spills throughout the United States to identify spills for which to coordinate emergency

response. Oils and chemic als. No source exemptions. Real

- time. Historical information about spills can be retrieved through the NRC online query system: www.nrc.uscg.mil/foia.html.

Risk Management Plan (RMP)

RMP contains a five

- year accident history for each facility with detai ls on releases of

r egulated substances from covered processes

with 1) on

- site deaths, injuries, or significant property damage ; or 2) known off

- site deaths, injuries, property damage,

e nvironmental damage, evacuations, or sheltering in place. See above fo r more details. See above. See above. See above. See above

.

1 Arizona, California, Georgia, Maine, Massachusetts, Minnesota, Mississippi, New Jer sey, New York, Oregon, Tennessee, Texas, Vermont, and Washington.6 / 11 /14 76 Description Chemical Coverage Industry/Facility Coverage Reporting

Frequency Public Access

STATE RIGHT

- TO

- KNOW PROGRAMS Several states require expanded state TRI reporting to include industries or facilities not covered by TRI or to report information beyond that required by the feder al TRI Program (e.g., Arizona, Massachusetts, and Wisconsin). Varies. O ften

identical to TRI

. Varies. May include more

industries than TRI. Annual. There is no central source for state collected data. Accessibility varies by state.6 / 11 /14 77 Appendix C Referenc es:

Abt Associates, “Comparison of Toxics Release Inventory and the Permit Compliance System,” (2005).

Abt Associates, “Comparison of Toxics Release Inventory and the National Emissions Inventory,” (2005): 6.

Arizona Department of Environmental Quality. 2014. Waste Programs Division: Pollution Prevention (P2) Program . www.azdeq.gov/environ/waste/p2/index.html

California Department of Toxic Substances Control. 2010. Pollution Prevention.

www.dtsc. ca.gov/pollutionprevention/

.

Georgia Department of Natural Resources. 2013. EPD Forms: Land Protection Branch: Hazardous Waste Managementwww.gaepd.org/Documents/epdforms_hwb.html

Great Lakes Information Network, 1996. "Regional Air Pollutant Inventory De velopment System," Information from Great Lakes Information Network Web site:

ww w.glc.org/projects/air/rapids/rapids.html ww w.glc.org

.

ICF Incorporated, 1 993. Data Gaps and Redundancies in Pollution Prevention Reporting; A Compendium of Memoranda. Prepared for U.S. EPA, Office of Prevention, Pesticides, and Toxics, Pollution Prevention Division.

Maine Department of Environmental Protection. 2013. Toxics Us e Reduction Program (TUR). www.maine.gov/dep/sustainability/tur/index.html

.

Massachusetts Executive Office of Energy and Environmental Affairs. 2014. Toxics Use

Reduction Act. www.mass.gov/eea/agencies/massdep/toxics/tur/

.

Minnesota Pollution Control Agency. 2012. Minnesota Guide to Pollution Prevention Planning. www.pca.state.mn.us/index.php/topics/preventing

- waste

- and

- pollution/assistance

- and

resources/minnesota

- guide

- to

- pollution

- prevention

- planni ng.html

.

Mississippi Department of Environmental Quality. 2007. Pollution Prevention. www.deq.state.ms.us/mdeq.n sf/page/ERC_pollution_prevention?OpenDocument

.

New Jersey Department of Environmental Protection. 2014. Office of Pollution Prevention and Community Right To Know. www.nj.gov/dep/opppc/

.

New York Deparmetn of Environmental Conservation. 2013. Hazardous W aste Reduction Plans. www.dec.ny.gov/chemical/8771.html

.

Oregon Department of Environmental Quality. 2006. Toxics Use and Hazardous Waste Reduction. www.deq.state.or.us/lq/hw/tuhwr.htm

.6 / 11 /14 78 Seitz, John S., Director OAQPS, 1995. Memorandum: "Title V Permitting for Non

- major Sources

in Recent § 112 Maximum Achievable Control Technology (MACT) Standards," May 16, 1995.

Tennessee Department of Enviro nment and Conservation. 1999. Writing a Waste Reduction Plan. www.tn.gov/environment/solid

- waste/docs/wrplan.pdf

.

Texas Commission on Environme n tal Quality. 2013. About Pollution Pr evention (P2) Planning. www.tceq.texas.gov/p2/wrpa/p2planning.html

.

U.S. EPA, 1991. 1991 Hazardous Waste Report: Instructions and Forms. EPA Form 8700

- 13A/B (5

- 80) revised 8

- 91.

U.S. EPA, 1994. "National Analysis: The Biennial RCRA Hazardous Waste Report (Based on 1991 Data)." September 1994.

U.S. EPA, 1995. "User's Guide to Federal Accidental Release Databases," Office of Solid Waste and Emergency Response, September 1995. http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=100035EX.TXT

.

U.S. EPA, 2006. "Phase III: Data Proxies for the Toxics Release Inventory (TRI)," January

2006.

U.S. EPA, 2009. "General Risk Management Progr am Guidance: Chapter 9: Risk Management Plan,” March 2009. www.epa.gov/osweroe1/docs/chem/Chap

- 09

- final.pdf

.

U.S. EPA, 2012. Air Facility System www.epa.gov/compliance/data/systems/air/afssystem.html

.

U.S. EPA, 2013a. “2011 National Emissions Inventory, version 1 Technical Support Document

November 2013

– DRAFT” www.epa.gov/ttn/chief/net/2011nei/2011_neiv1_tsd_draft.pdf

.

U.S. EPA, 2013b. “National Biennial RCRA Hazardous Waste Report: Documents and Data" www.epa.gov/osw/inforesources/data/biennialreport/

.

Vermont Department of Environmental Conservation. 2003. Pollution Prevention Planning. www.anr.state.vt.us/DEC/ead/pp ap/index.htm

.

Was hington Department of Ecology. Pollution Prevention and Planning in Washington State. www.ecy.wa.gov/programs/hwtr/p2/index.html

.

Wisconsin Emergency Management. “An Information Guide: Emerg ency Planning and Community Right

- to

- Know Act Wisconsin Statute 323.60,” http://emergencymanagement.wi.gov/EPCRA/docs/EPCRA%20BookletWHOPRS.pdf

.6 / 11 /14 79 APPENDIX D

TRI CONSU L T ATION MEETINGS6 / 11 /14 80 Appendix D: TRI Consultation Meetings

Feb ruary 7 , 2011 and February 28, 2011

T ribal consultation calls with Tribal Leaders or Designates re garding the “ T oxics Release Inventory (TRI) Reporting for Facilities Located in Indian Country an d Clarification of Additional Opportunities Available to Tribal Governments under the TRI Program” r ule

February 7, 2011

Attendees Included :

Craig T epper, Seminole Tribe Sarah Hill, Cherokee Nation Matthew Thompson, St. Regis Mohawk Tribe Dwight Peavey, EPA Region 1 Nora Lopez, EPA Region 2 Bill Reilly, EPA Region 3 Ezequiel Velez, EPA Region 4 Willie Harris, EPA Region 5 Mort Wakeland, Randy Gee, EPA Region 6 Gabriela Carvalho, EPA Region 10

Robin Gonzalez

– Acting Director, EPA Office of Information Ana lysis and Access

N ancy Wentworth

– Acting Deputy Director, EPA Office of Information Analysis and Access

Rebecca Moser

– Director, TRI Program Division

Beth Jackson

– Tribal Program Coordinator, Office of Environmental Information

Louise Camalier

– Office of Information Analysis and Access Larry Reis man

– TRI Program Division

Sarah Swenson

– TRI Program Division

Caitlin Briere

– Office of Information Analysis and Access

February 28, 2011

Attendees Included :

Vicki Kujawa

, Iowa Tribe of Oklahoma

Denise Jen sen, Winnebego Tribe of Nebraska

Melonee Montano

, Redcliff Tribe (Wisconsin) Nora Lopez, EPA R egion 2 Ezequiel Velez

, EPA R egion 4

Thelma Codina , Willie Harris

, EPA R egion 5 Randy Gee, EPA R egion 6 Barbara Conklin, EPA Region 8 Gabriela Carvalho, EPA R egio n 10 Kevin Donovan, TRI Program Division Larry Reisman

, TRI Program Division Nancy Wentworth , Acting Deputy, Office of Information Analysis and Access

Mike Petruska , Director, Environmental Analysis Division

Louise Camalier , Office of Information Analysis and Access6 / 11 /14 81 Guy Tomassoni , Environmental Analysis Division Nicky Paquette , Environmental Analysis Division

Beth Jackson

, Tribal Program Coordinator, Office of Environmental Information

Robin Gonza lez , Acting Director, Office of Information Analysis

TRI Na tional Training Conference April 2012

Attendees Included:

3M Company Alaska Department of Environmental Conservation Ark. Dept. of Environmental Quality Birmingham City Council

BP

Calvert Inc.

Center for Environmental Health Cherokee Services Group, LLC (CSG)

Clean Air Coalition of WNY Colorado Department of Public Health and Environment Commission for Environmental Cooperation

Committee on Environment and Public Works

Confederation Salish & Kootenai Tribes

Consolidated Edison of New York

Cornell Univers ity Covanta Energy CT Department of Energy and Environmental Protection DM Petroleum Operations Company Duke Energy

Environmental Council of the States

ExxonMobil Freeport

- McMoRan Copper & Gold Georgia

- Pacific LLC

Harvard Business School

Harvard Law School Holcim (US)

HRI Huxley College of the Environment Idaho Bureau of Homeland Security Indiana Dept of Environmental Management

Institute for Tribal Environmental Professionals Iowa Department of Natural Resources

Johnson & Johnson JR Simplot Company

Kansas Department of Health & Environment Kentucky Department for Environmental Protection6 / 11 /14 82 Koch Industries

K

- State Pollution Prevention Institute

Lubin School of Business Maine Emergency Management Agency Maryland Department of the Environment MI Dept of Environm ental Quality Michelin North America, Inc. Minnesota Pollution Control Agency Mississippi Department Of Environmental Quality Montana Department of Environmental Quality Morgan State University MS Dept. of Environmental Quality

NAPCA National Library of Me dicine

National Lime Association National Mining Association

National Pollution Prevention Roundtable Nebraska Department of Environmental Quality New Mexico Environment Department

NIHHS NJ Department of Environmental Protection Northeastern University

NYC Environmental Justice Alliance (NYC

- EJA)

NYS Pollution Prevention Institute Ohio Environmental Protection Agency Oklahoma Department of Environmental Quality

OMB Watch Oregon Office of State Fire Marshal

Oxbow

Penobscot Nation Pfizer, Inc.

Potomac

- Hudson Engineering, Inc. Rochester Institute of Technology SEMARNAT, Ministery of Environmental Natural Resources in Mexico City

Seneca Nation of Indians Senior Service America, Inc.

Sierra Club

Small Business Administration Staples State of Hawaii, Department of Health

State of Utah Stewardship Action Council TCEQ Tennessee State University TG Missouri Corporation The Vinyl Institute6 / 11 /14 83 Thompson Publishing Group Towson University U.S. Department of the Army U.S. Virgin Islands UMASS Lowell, Department of Community H ealth and Sustainability University of Colorado Denver University of Minnesota University of Utah University of Wisconsin Extension University of Wyoming

US Air Force Virginia Department of Environmental Quality Washington Department of Ecology Washington State Department of Ecology Waste Management

WE ACT for Environmental Justice West Liberty Foods Western Washington University

Wisconsin DNR WV Department of Environmental Protection

Yukon River Inter

- Tribal Watershed Council Yurok Tribe Environmental Prog ram Zero Waste Network

- Center For Environmental Excellence

- University of Texas at Arlington

January 22, 2013 Stakeholder Briefing on 2011 TRI National Analysis

Attendees Included :

OMB Watch National Mining Association

SBA

Earthworks

ECOS Society of Glass and Ceramic Decorated Products6 / 11 /14 84 July 29, 2013 Discussion Meeting regarding Adding Oil and Gas Extraction Industry to TRI

EPA hosted a listen session during which Petitioners discussed their Petition to Add the Oil and Gas Extraction Industry, Sta ndard Industrial Classification Code 13, to the List of Facilities Required to Report under the Toxics Release Inventory.

Attendees Included:

EPA Steve Knizner, Director, TRI Program Division ( knizner.steve@epa .gov ) Ingrid Rosencrantz, Branch Chief, TR I Regulatory Development Branch ( rosencrantz.ingrid@epa.gov ) Gilbert Mears, Staff, TRI ( mears.gilbert@epa.gov ) Cory Wa gner, Staff, TRI ( wagner.cory@epa.gov ) Chris Kaczmarek, Attorney, Office of General Counsel ( kaczmarek.chris@epa.gov ) Ben Wakefield, Attorney, Office of General Couns el ( wakefield.benjamin@epa.gov )

Non

- EPA Eric Schaeffer, Executive Director, Environmental Integrity Project ( eschaeffer@environmentalintegrity.or g ) Adam Kron, Attorney, Environmental Integrity Project ( akron@environmentalintegrity.org ) Sofia Plagakis, Policy Analyst, Center for Effective Government (formerly OMB Watch) ( splagakis@foreffectivegov.org ) Sean Moulton, Director of Open Government Policy Program , Center for Effective Government ( smoulton@foreffectivegov.org )

Diana Dascalu

- Joffe, Senior General Counsel, Chesapeake Climate Action Network ( diana@chesapeakeclimate.org ) Aaron Mintzes, Policy Advocate, Earthworks ( amintzes@earthworksa ction.org ) Matthew McFeeley, Attorney, Natural Resources Defense Council ( mmcfeeley@nrdc.org ) Craig Segall, Sierra Club, Attorney ( Craig.Segall@sierraclub.org ) Ryan Hamilton, Intern, Environmental Integrity Project Ariel Solaski, Intern, Environmental Integrity Project Caitlin Stantion, Intern, Environmental Integrity Project6 / 11 /14 85 APPENDIX E FACILITIES REQUIRED TO REPORT TO TRI (NAICS)6 / 11 /14 86 Table E

- 1 Facilities Required to Report to TRI (NAICS) (Corresponding to SIC codes 20 through 39)

Subsector

or Industry

Code

Industry

Code Exceptions and/or Limitations

311 Except 311119

- Exception is limited to facilities primarily en gaged in Custom Grain Grinding for Animal Feed

(previously classified under SIC 0723, Crop Preparation Services for Market, Except Cotton Ginning);

Except 311340

- Exception is limited to facilities primarily engaged in the retail sale of candy, nuts, pop corn and other confections not for immediate consumption made on the premises (previously classified under SIC 5441, Candy, Nut, and Confectionery Stores);

Except 311352

- Exception is limited to facilities primarily engaged in the retail sale of candy, n uts, popcorn and other confections not for immediate consumption made on the premises (previously classified under SIC 5441, Candy, Nut, and Confectionery Stores);

Except 311611

- Exception is limited to facilities primarily engaged in Custom Slaughtering for individuals (previously classified under SIC 0751, Livestock Services, Except Veterinary, Slaughtering, custom: for individuals); Except 311612

- Exception is limited to facilities primarily engaged in the cutting up and resale of purchased fresh

car casses for the trade (including boxed beef), and in the wholesale distribution of fresh, cured, and processed (but not canned) meats and lard (previously classified under SIC 5147, Meats and Meat Products);

Except 311811

- Retail Bakeries (previously cla ssified under SIC 5461, Retail Bakeries);

312 Except 312112

- Exception is limited to facilities primarily engaged in bottling mineral or spring water (previously

classified under SIC 5149, Groceries and Related Products, NEC)

Except 312230

- Exceptio n is limited to facilities primarily engaged in providing Tobacco Sheeting Services (previously classified under SIC 7389, Business Services, NEC);

313 Except 313310

- Exception is limited to facilities primarily engaged in converting broadwoven piece goo ds and

broadwoven textiles, (previously classified under SIC 5131, Piece Goods Notions, and Other Dry Goods, broadwoven

and non

- broadwoven piece good converters);, and facilities primarily engaged in converting narrow woven Textiles and narrow woven piece goods, (previously classified under SIC 5131, Piece Good Notions, and Other Dry Goods, converters, except broadwoven fabric); and facilities primarily engaged in sponging fabric for tailors and dressmakers (previously classified under SIC 7389, Business Se rvices, NEC (Sponging fabric for tailors and dressmakers));

314 Except 314120

- Exception is limited to facilities primarily engaged in making Custom drapery and in making Custom

slipcovers for retail sale (previously classified under SIC 5714, Drapery, Curtain, and Upholstery Stores);

Except 314999

- Exception is limited to facilities primarily engaged in Binding carpets and rugs for the trade, Carpet cutting and binding, and Embroidering on textile products (except apparel) for the trade (previously cl assified under SIC 7389, Business Services Not Elsewhere Classified, Embroidering of advertising on shirts and Rug binding for the trade);

315 Except 315220

- Exception is limited to custom tailors primarily engaged in making and selling men's and boys' s uits,

men’s and boys’ dress shirts, and bridal dresses or gowns or women’s, misses’ and girls’dresses, cut and sewn from purchased fabric (previously classified under SIC 5699, Miscellaneous Apparel and Accessory Stores (custom tailors))

and to custom tai lors primarily engaged in making and selling bridal dresses or gowns, or women's, misses' and girls' dresses cut and sewn from purchased fabric (except apparel contractors)(custom dressmakers) (previously classified under SIC Code 5699, Miscellaneous Appa rel and Accessory Stores);

316

321

322

323 Except 323111

- Exception is limited to facilities primarily engaged in reproducing text, drawings, plans, maps, or

other copy, by blueprinting, photocopying, mimeographing, or other methods of duplication other than printing or microfilming (i.e., instant printing) (previously classified under SIC 7334, Photocopying and Duplicating Services, (instant printing));

324

325 Except 325998

- Exception is limited to facilities primarily engaged in Aerosol can filling on a job order or contract

basis (previously classified under SIC 7389, Business Services, NEC (aerosol packaging));

326 Except 326212

- Tire Retreading, (previously classified under SIC 7534, Tire Retreading and Repair Shops

(rebuilding));

327 Except 327110

- Exception is limited to facilities primarily engaged in manufacturing and selling pottery on site

(previously classified under SIC 5719, Miscellaneous Homefurnishing Stores)6 / 11 /14 87 331

332

333

334 Except 334614

– Exception is limited to fa cilities primarily engaged in Software Reproducing (previously classified

under SIC 7372, Prepackaged Software, (reproduction of software)) and to facilities primarily engaged in mass reproducing pre

- recorded Video cassettes, and mass reproducing Video ta pe or disk (previously classified under SIC 7819, Services Allied to Motion Picture Production (reproduction of Video));

335 Except 335312

- Exception is limited to facilities primarily engaged in armature rewinding on a factory basis

(previously classifi ed under SIC 7694 (Armature Rewinding Shops (remanufacturing) );

336

337 Except 337110

- Exception is limited to facilities primarily engaged in the retail sale of household furniture and that

manufacture custom wood kitchen cabinets and counter tops ( previously classified under SIC 5712, Furniture Stores (custom wood cabinets));

Except 337121

- Exception is limited to facilities primarily engaged in the retail sale of household furniture and that manufacture custom made upholstered household furniture (previously classified under SIC 5712, Furniture Stores (upholstered, custom made furniture));

Except 337122

- Exception is limited to facilities primarily engaged in the retail sale of household furniture and that manufacture nonupholstered, household t ype, custom wood furniture (previously classified under SIC 5712, Furniture Stores (custom made wood nonupholstered household furniture except cabinets));

339 Except 339113

- Exception is limited to facilities primarily engaged in manufacturing orthopedi c devices to

prescription in a retail environment (previously classified under SIC 5999, Miscellaneous Retail Stores, NEC)

Except 339115

- Exception is limited to lens grinding facilities that are primarily engaged in the retail sale of eyeglasses and con tact lenses to prescription for individuals (previously classified under SIC 5995, Optical Goods Stores (optical laboratories grinding of lenses to prescription));

Except 339116

- Dental Laboratories (previously classified under SIC 8072, Dental Laborator ies);

111998 Limited to facilities primarily engaged in reducing maple sap to maple syrup (previously classified under SIC 2099,

Food Preparations, NEC, Reducing Maple Sap to Maple Syrup);

113310

211112 Limited to facilities that recover sulfur from n atural gas (previously classified under SIC 2819, Industrial Inorganic

chemicals, NEC (recovering sulfur from natural gas));

212324 Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating kaolin and clay

(p reviously classified under SIC 3295, Minerals and Earths, Ground or Otherwise Treated (grinding, washing, separating, etc. of minerals in SIC 1455));

212325 Limited to facilities operating without a mine or quarry and that are primarily engaged in benefi cia ting clay and

ceramic and refractory minerals (previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise Treated (grinding, washing, separating, etc. of minerals in SIC 1459));

212393 Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating chemical or

fertilizer mineral raw materials (previously classified under SIC 3295, Minerals and Earth s, Ground or Otherwise

Treat ed (grinding, washing, separating, etc. of minerals in SIC 1479)) ;

212399 Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating nonmetallic

minerals (previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise Treated (grinding, washing, separating, etc. of minerals in SIC 1499));

488390 Limited to facilities that are primarily engaged in providing routine repair and maintenance of ships and boats from

floating drydocks (previously classified under SIC 3731, Shipbuilding and Repairing (floating drydo cks not associated with a shipyard));

511110

511120

511130

511140 Except facilities that are primarily engaged in furnishing services for direct mail advertising including Address list

compilers, Address list publishers, Address list publishers and printing combined, Address list publishing , Business directory publishers, Catalog of collections publishers, Catalog of collections publishers and printing combined, Mailing list compilers, Directory compilers, and Mailing list compiling services (previo usly classified under SIC 7331, Direct Mail Advertising Services (mailing list compilers));

511191

511199

5122206 / 11 /14 88 512230 Except facilities primarily engaged in Music copyright authorizing use, Music copyright buying and licensing, and

Music publishe rs working on their own account (previously classified under SIC 8999, Services, NEC (music publishing));

519130 Limited to facilities primarily engaged in Internet newspaper publishing (previously classified under SIC 2711,

Newspapers: Publishing, or Pu blishing and Printing), Internet periodical publishing (previously classified under SIC 2721, Periodicals: Publishing, or Publishing and Printing), Internet book publishing (previously classified under SIC 2731, Books: Publishing, or Publishing and Printin g), Miscellaneous Internet publishing (previously classified under SIC 2741, Miscellaneous Publishing), Internet greeting card publishers (previously classified under SIC 2771, Greeting Cards); Except for facilities primarily engaged in web search portals.

541712 Limited to facilities that are primarily engaged in Guided missile and space vehicle engine research and development

(previously classified under SIC 3764, Guided Missile and Space Vehicle Propulsion Units and Propulsion Unit Parts),

and in Guided missile and space vehicle parts (except engines) research and development (previously classified under SIC 3769, Guided Missile and Space Vehicle Parts and Auxiliary Equipment, Not Elsewhere Classified);

811490 Limited to facilities that are primarily e ngaged in repairing and servicing pleasure and sail boats without retailing new

boats (previous ly classified under SIC 3732, Boat Building and Repairing (pleasure boat building));

Table E

- 2 Facilities Required to Report to TRI (NAICS) (Corresponding to SIC codes other than SIC codes 20 through 39)

Subsector or Industry

Code Exceptions and/or Limitations

212111

212112

212113

212221

212222

212231

212234

212299

221111 Limited to facilities that combust coal and/or oil for the purpose of ge nerating power for distribution in commerce.

221112 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce.

221113 Limited to facilities that combust coal and/or oil for the purpose of generati ng power for distribution in commerce.

221118 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce.

221121 Limited to facilities that combust coal and/or oil for the purpose of generating pow er for distribution in commerce.

221122 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce.

221330 Limited to facilities engaged in providing combinations of electric, gas, and other serv ices, not elsewhere classified

(N.E.C.)(previously classified under SIC 4939, Combination Utility Services Not Elsewhere Classified. )

424690

424710

425110 Limited to facilities previously classified in SIC 5169, Chemicals and Allied Products, Not El sewhere Classified.

425120 Limited to facilities previously classified in SIC 5169, Chemicals and Allied Products, Not Elsewhere Classified.

562112 Limited to facilities primarily engaged in solvent recovery services on a contract or fee basis (previousl y classified under

SIC 7389, Business Services, NEC);

562211 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq

.
562212 Limited to facilities regulated under the Resource Conservation and R ecovery Act, subtitle C, 42 U.S.C. 6921 et seq

.
562213 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq

.
562219 Limited to facilities regulated under the Resource Conservation and Recover y Act, subtitle C, 42 U.S.C. 6921 et seq

.
562920 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq

.