Download:
pdf |
pdfEPA 260-R-15-001
OMB Control Number: 2025-0009
December 2014
Toxic Chemical Release
Inventory Reporting Forms
and Instructions
Revised 2014 Version
Section 313
of the Emergency Planning and
Community Right-to-Know Act
(Title III of the Superfund Amendments
and Reauthorization Act of 1986)
Paperwork Reduction Act Notice: The annual public burden related to the Form R, which is approved
under OMB Control No. 2025-0009, is estimated to average 35.71 hours per response for a facility
filing a report on one chemical. The annual public burden related to the Form A, which is also
approved under OMB Control No. 2025-0009, is estimated to average 21.96 hours per response for a
facility filing a report on one chemical.
Burden means the total time, effort, or financial resources expended by persons to generate, maintain,
retain, or disclose or provide information to or for a Federal agency. This includes the time needed to
review instructions; develop, acquire, install, and utilize technology and systems for the purposes of
collecting, validating, and verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply with any previously
applicable instructions and requirements; train personnel to be able to respond to a collection of
information; search data sources; complete and review the collection of information; and transmit or
otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required
to respond to, a collection of information unless it displays a currently valid OMB control number. The
OMB control numbers for EPA’s regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.
Send comments on the Agency’s need for this information, the accuracy of the provided burden
estimates, and any suggested methods for minimizing respondent burden, including through the use of
automated collection techniques, to the Director, Collection Strategies Division, U.S. Environmental
Protection Agency (2822), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460; and to the Office of
Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, DC 20503, Attention: Desk Officer for EPA. Include the EPA ICR number and OMB
control number in any correspondence.
The completed forms should be submitted in accordance with the instructions accompanying the form,
or as specified in the corresponding regulation.
Table of Contents
Table of Contents
List of Acronyms ....................................................................................................................................i
Important Information for Reporting Year (RY) 2014........................................................................ii
New Information for RY 2014...................................................................................................ii
Other Important Information for Reporting Year 2014.............................................................. iv
TRI-MEweb RY 2014 Version .................................................................................................. v
A.
General Information ............................................................................................................... 1
A.1
Who Must Report...................................................................................................................... 1
A.2
How to Submit Forms ............................................................................................................... 2
A.3
Trade Secret Claims .................................................................................................................. 4
A.4
Recordkeeping .......................................................................................................................... 5
A.5
How to Revise, Withdraw or Cancel TRI Data........................................................................... 6
A.5.1
Revising TRI Data ..................................................................................................... 6
A.5.2
Withdrawing TRI Data............................................................................................... 7
A.5.3
Canceling a TRI Submission ...................................................................................... 7
A.6
When the TRI Report Must Be Submitted.................................................................................. 8
A.7
How to Obtain the TRI Reporting Forms ................................................................................... 9
B.
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A.. 10
B.1
Full-Time Employee Determination ........................................................................................ 10
B.2
Primary NAICS Code Determination....................................................................................... 12
B.2.a.
Auxiliary Facilities................................................................................................... 12
B.2.b.
Multi-establishment Facilities................................................................................... 12
B.2.c.
Property Owners ...................................................................................................... 13
B.3
Activity Determination............................................................................................................ 13
B.3.a.
Definitions of Manufacture, Process, and Otherwise Use .......................................... 13
B.3.b.
Persistent Bioaccumulative Toxic (PBT) Chemicals and Chemical Categories
Overview16
B.3.c.
Activity Exemptions................................................................................................. 17
B.4
Threshold Determinations ....................................................................................................... 23
B.4.a.
How to Determine if Your Facility Has Exceeded Thresholds................................... 24
B.4.b.
Threshold Determinations for On-Site Reuse Operations .......................................... 25
B.4.c.
Threshold Determinations for Ammonia................................................................... 26
B.4.d.
Threshold Determinations for Chemical Categories .................................................. 26
B.4.e
Threshold Determination for Persistent Bioaccumulative Toxic (PBT) Chemicals .... 27
B.4.f.
Mixtures and Other Trade Name Products ................................................................ 27
B.5
Release and Other Waste Management Determinations for Metals, Metal Category Compounds,
and Nitrate Compounds........................................................................................................... 28
C.
Instructions for Completing TRI Form R ............................................................................ 34
Part I. Facility Identification Information ........................................................................................... 34
Section 1. Reporting Year..................................................................................................... 34
Section 2. Trade Secret Information...................................................................................... 34
Section 3. Certification ......................................................................................................... 34
Section 4. Facility Identification ........................................................................................... 34
Section 5. Parent Company Information................................................................................ 37
Part II. Chemical Specific Information ................................................................................................ 39
Section 1. EPCRA Section 313 Chemical Identity................................................................. 39
Section 2. Mixture Component Identity ............................................................................... 40
Section 3. Activities and Uses of the EPCRA Section 313 Chemical at the Facility .............. 40
Section 4. Maximum Amount of the EPCRA Section 313 Chemical On-site at Any Time during the
Calendar Year........................................................................................................................... 43
Section 5. Quantity of the Toxic Chemical Entering Each Environmental Medium On-site .. 44
Section 6. Transfer(s) of the Toxic Chemical in Wastes to Off-Site Locations...................... 52
Toxics Release Inventory Reporting Forms and Instructions
TOC-1
Table of Contents
Section 7. On-Site Waste Treatment, Energy Recovery, and Recycling Methods................... 61
Section 8. Source Reduction and Waste Management ........................................................... 68
D.
Instructions for Completing Form R Schedule 1 (Dioxin and Dioxin-like Compounds) .... 85
D.1
What is the Form R Schedule 1?.............................................................................................. 85
D.2
Who is required to file a Form R Schedule 1? .......................................................................... 85
D.3
What information is reported on the Form R Schedule 1? ........................................................ 85
D.4
How do I report Form R Schedule 1 Data?............................................................................... 87
E.
Facility Eligibility Determination for Alternate Threshold and for Reporting on TRI Form
A Certification Statement ..................................................................................................... 88
E.1
Alternate Threshold................................................................................................................. 88
E.2
What is the Form A Certification Statement? ........................................................................... 88
E.3
What Is the Annual Reportable Amount (ARA)? ..................................................................... 88
E.4
Recordkeeping ........................................................................................................................ 89
E.5
Multi-establishment Facilities.................................................................................................. 89
E.6
Trade Secrets........................................................................................................................... 89
E.7
Metals and Metal Category Compounds .................................................................................. 89
F.
Instructions for Completing TRI Form A Certification Statement ..................................... 91
Part I. Facility Identification Information .......................................................................................... 91
Section 1. Reporting Year.................................................................................................... 91
Section 2. Trade Secret Information..................................................................................... 91
Section 3. Certification ........................................................................................................ 91
Section 4. Facility Identification .......................................................................................... 91
Section 5. Parent Company Information............................................................................... 94
Part II. Chemical Identification ........................................................................................................... 95
Section 1. Toxic Chemical Identity ...................................................................................... 95
Section 2. Mixture Component Identity ............................................................................... 95
G.
Optional Facility-Level Information..................................................................................... 97
Index ............................................................................................................................................... 98
Toxics Release Inventory Reporting Forms and Instructions
TOC-2
Table of Contents
Examples
Example 1:
Example 2:
Example 3:
Example 4:
Example 5:
Example 6:
Example 7:
Example 8:
Example 9:
Example 10:
Example 11:
Example 12:
Example 13:
Example 14:
Example 15:
Example 16:
Example 17:
Example 18:
Example 19:
Example 20:
Example 21:
Example 22:
Example 23:
Example 24:
Example 25:
Example 26:
Example 27:
Example 28:
Coincidental Manufacture............................................................................................. 14
Typical Process and Manufacture Activities ................................................................. 15
Typical Otherwise Use Activities.................................................................................. 15
Articles Exemption....................................................................................................... 18
De Minimis Applications to Process and Otherwise Use Scenarios for Non-PBT
Chemicals .................................................................................................................... 20
Concentration Ranges Straddling the De Minimis Value ............................................... 21
De Minimis Application in the Manufacture of a Toxic Chemical in a Mixture.............. 22
Coal mining extraction activities................................................................................... 23
Mixtures and Other Trade Name Products .................................................................... 29
Mixture Containing Unidentified EPCRA Section 313 Chemical .................................. 40
Manufacturing and Processing Activities of EPCRA Section 313 Chemicals ................ 43
Reporting Dioxins and Dioxin-Like Compounds .......................................................... 45
Stormwater Runoff ....................................................................................................... 52
Container Residue ........................................................................................................ 57
Reporting Metals and Metal Category Compounds that are sent Off-site ....................... 57
Calculating Releases and Other Waste Management Quantities .................................... 63
On-Site Waste Treatment ............................................................................................. 67
Reporting On-Site Energy Recovery............................................................................. 68
Reporting Future Estimates........................................................................................... 70
Avoiding Double-Counting Quantities in Sections 8.1 through 8.7................................ 72
Non-Production-Related Waste Managed (Quantity Released to the Environment or
Transferred Off-Site as a Result of Remedial Actions, Catastrophic Events, or Other OneTime Events Not Associated with Production Processes). ............................................. 74
Determining a Production Ratio.................................................................................... 76
Determining an Activity Ratio ..................................................................................... 76
“NA” is Entered Instead of a Production Ratio or Activity Ratio................................... 76
Selecting a Production or Activity Variable ................................................................ 77
Determining the Production Ratio Based on a Weighted Average ................................. 77
Source Reduction ......................................................................................................... 82
Green Chemistry .......................................................................................................... 82
Figures
Figure 1.
Figure 2.
Figure 3A.
Figure 3B.
Figure 3C.
TRI-MEweb’s Preparation, Transmission, Certification and Submission Steps ............... 2
EPCRA Section 313 Reporting Decision Diagram ........................................................ 11
EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet.................... 30
EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100 Pound
Thresholds.................................................................................................................... 31
EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10 Pound
Threshold ..................................................................................................................... 32
Toxics Release Inventory Reporting Forms and Instructions
TOC-3
Table of Contents
Figure 3D.
Figure 4.
Figure 5.
Figure 6.
Figure 7.
EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like
Compounds Chemical Category.................................................................................... 33
Reporting EPCRA Section 313 Chemicals.................................................................... 42
Hypothetical Section 6.2 Completed for Two Off-Site Locations .................................. 60
Hypothetical Section 7A............................................................................................... 64
Hypothetical Form R, Section 5.1 and Form R Schedule 1, Section 5.1......................... 86
Tables
Table I
Table II
Table III
Table IV
Table V
Table VI
NAICS Codes...............................................................................................................I-1
EPCRA Section 313 Chemicals for Reporting Year 2014 (including Toxic Chemical
Categories)................................................................................................................. II-1
State Abbreviations ................................................................................................... III-1
Federal Information Processing Standards (FIPS) Country Codes ..............................IV-1
Bureau of Indian Affairs (BIA) Tribal Codes .............................................................. V-1
Removal and Destruction Rates for POTWs ..............................................................VI-1
Appendices
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
Appendix I
Federal Facility Reporting Information ....................................................................... A-1
Reporting Codes for EPA Form R and Instructions for Reporting Metals .................... B-1
Facility Data Profiles and Common Errors in Completing Form R Reports and Form A
Certification Statements.............................................................................................. C-1
Supplier Notification Requirements ............................................................................ D-1
TRI State and Tribal Contacts......................................................................................E-1
TRI Regional Contacts ................................................................................................F-1
Other Relevant Section 313 Materials......................................................................... G-1
Guidance Documents.................................................................................................. H-1
Questions and Answers Regarding Facility Identification Information ..........................I-1
Toxics Release Inventory Reporting Forms and Instructions
TOC-4
List of Acronyms
List of Acronyms
ARA
BIA
CAS
CBI
CDX
CERCLA
CFR
D&B
DMR
DPC
DQA
EBDCs
eFDP
EPA
EPCRA
ESA
FDP
FIPS
FR
GOCO
IARC
ICR
MSDS
NA
NAICS
NDC
Annual Reportable Amount
Bureau of Indian Affairs
Chemical Abstract Services
Confidential Business Information
Central Data Exchange
Comprehensive Environmental
Response, Compensation, and Liability
Act
Code of Federal Regulations
Dun & Bradstreet
Discharge Monitoring Report
Data Processing Center
Data Quality Alert
Ethylenebisdithiocarbamic Acid, Salts
and Esters
Electronic Facility Data Profile
Environmental Protection Agency
Emergency Planning and Community
Right to Know Act
Electronic Signature Agreement
Facility Data Profile
Federal Information Processing
Standard
Federal Register
Government-Owned, ContractorOperated
International Agency for Research and
Cancer
Information Collection Request
Material Safety Data Sheets
Not Applicable
North American Industry Classification
System
Non-Technical Data Changes
NHD
NON
NOSE
NOTE
NPDES
NTP
OMB
OSHA
P2
PACs
PBBs
PBT
PCBs
POTW
PPA
RCRA
RSEI
RY
SBREFA
SIC
TDX
TRI
TRIFID
TRIPS
UIC
USC
USGS
VOCs
National Hydrography Dataset
Notice of Non-Compliance
Notice of Significant Error
Notice of Technical Errors
National Pollutant Discharge
Elimination System
National Toxicology Program
Office of Management and Budget
Occupational Safety and Health Act
Pollution Prevention
Polycyclic Aromatic Compounds
Polybrominated Biphenyls
Persistent Bioaccumulative Toxic
Polychlorinated Biphenyls
Publicly Owned Treatment Works
Pollution Prevention Act
Resource Conservation and Recovery
Act
Risk Screening Environmental
Indicators
Reporting Year
Small Business Regulatory
Enforcement Fairness Act
Standard Industrial Classification
TRI Data Exchange
Toxics Release Inventory
Toxics Release Inventory Facility
Identification Number
Toxics Release Inventory Processing
System
Underground Injection Control
United States Code
United States Geological Survey
Volatile Organic Compounds
Toxics Release Inventory Reporting Forms and Instructions
i
Important Information for Reporting Year (RY) 2014
water body by the United States Geological
Survey’s (USGS) National Hydrography
Dataset (NHD). Doing so will ensure that EPA
and other researchers map your discharges to
the correct stream reach when conducting
analyses. TRI-MEweb will automatically
populate the appropriate reach code when you
select your receiving water body on the map
provided in the user interface for this section.
Important Information for
Reporting Year (RY) 2014
New Information for RY 2014
Please note that this version of the Toxic Chemical
Release Inventory (TRI) Reporting Forms and
Instructions document supersedes previous versions.
New TRI Chemicals:
o
Nonylphenol Category
A rule was published on September 30,
2014, (79 FR 58686) adding a nonylphenol
category to the TRI list of reportable
chemicals. Facilities that manufacture,
process, or otherwise use nonylphenol
should begin collecting release information
on the chemical during 2015. Reporting
forms will be due July 1, 2016 for
nonylphenol if TRI chemical use and other
thresholds are met.
o
Beginning in RY 2014, you are required to
indicate whether the ratio you are reporting in
Section 8.9 is a production ratio or an activity
ratio. EPA has also clarified the instructions for
this Section and added new examples to help
you select the appropriate variable to use in
calculating this ratio.
O-Nitrotoluene
Facilities May Now Submit Optional FacilityLevel Information in TRI-MEweb Without
Submitting a Form R or Form A
You can now use TRI-MEweb to update
location and contact information for your
facility without having to submit a TRI
reporting
form.
Additionally,
without
submitting a TRI reporting form, you can now
use TRI-MEweb to indicate that your facility
will no longer be reporting to TRI or will not be
submitting a form for one or more specific TRIlisted chemicals for the current reporting year.
Optional Field for Reach Code of Receiving
Streams or Water Bodies
In Section 5.3, you are required to enter the
names of the streams or water bodies to which
your facility directly discharges a reportable
EPCRA Section 313 chemical. Beginning in
Reporting Year (RY) 2014, you may enter the
14-digit reach code assigned to each receiving
Estimated Annual Reduction for Source
Reduction Activities
Beginning in RY 2014, you may provide an
optional percentage range indicating the
estimated annual reduction in chemical waste
generation associated with any source reduction
activity(s) you have reported in Section 8.10. If
you choose to complete this field, the reductions
associated with your pollution prevention efforts
will be featured on EPA’s website through the
TRI Pollution Prevention Search Tool at
www.epa.gov/tri/p2.
A final rule was published on November 7,
2013 (78 FR 66848) to add o-nitrotoluene to
the list of chemicals required for TRI
reporting. Facilities are required to submit
TRI forms for RY 2014 activities, due July
1, 2015, if TRI chemical use and other
thresholds are met.
Reporting Production or Activity Ratio
Optional Checkboxes in Section 8.11 for
Barriers to Source Reduction
Beginning in RY 2014, TRI-MEweb will
provide a pick-list of categories that you may
use to report barriers your facility faces with
respect to source reduction. You may also
elaborate on how these barriers apply to your
facility by clicking the “Provide additional info”
button next to any checkbox you have selected.
This information is optional and will appear in
Section 8.11.
Checkboxes for Categorizing Optional FreeText Information in Sections 8.11 and 9.1
Beginning in RY2014, you may indicate that
you are submitting information pertaining to
one or more specific topics by selecting from a
pick-list of topics provided by TRI-MEweb in
Section 8.11 and Section 9.1. Sections 8.11 and
9.1 will be displayed as a table of comments on
different topics rather than as single textboxes.
Toxics Release Inventory Reporting Forms and Instructions
ii
Important Information for Reporting Year (RY) 2014
Use of the checkboxes will ensure that your
optional information reaches its intended
audience.
Labeling Changes
The Form R for RY 2014 includes several
labeling changes that are not associated with
any changes to reporting requirements. These
changes include the relabeling of Section 8,
“Source Reduction and Waste Management;”
the insertion of the heading, “Production-related
waste managed” for Sections 8.1-8.7; the
relabeling of Section 8.8 as “Non-productionrelated waste managed”; the placement of the
heading “Disposal to land on-site” to encompass
both Sections 5.4 and 5.5; and the use of the
term “Activity Ratio” in Section 8.9 in place of
“Activity Index.”
Pollution Prevention
In order to promote pollution prevention (P2),
EPA has increased the prominence and
accessibility of the P2 information reported in
Sections 8.10 and 8.11 of the Form R. Some
companies reporting P2 are now highlighted in
the annual TRI National Analysis report, and all
P2 entries are featured in the TRI P2 Search
tool.
P2 data is also newly accessible at the corporate
level through this tool. To learn more, visit:
http://www2.epa.gov/toxics-release-inventorytri-program/pollution-prevention-p2-and-tri.
Distributing POTW Transfer Quantities in
Section 8
Table VI contains removal and destruction rates
for toxic chemicals sent to POTWs, based on
experimental and estimated data. These
percentages are automatically pre-loaded into
TRI-MEweb to assist with Section 8
calculations, but may be overridden if the
facility has better information on the final
disposition of the chemical readily available.
Toxics Release Inventory Reporting Forms and Instructions
iii
Important Information for Reporting Year (RY) 2014
Other Important Information for
Reporting Year 2014
EPA’s Audit Policy. If you discover your facility is
or may have been in violation of Section 313 of
EPCRA (TRI Reporting), please refer to EPA’s
Policy entitled, “Incentives for Self-Policing:
Discovery, Disclosure, Correction, and Prevention of
Violations” (Audit Policy), 65 FR 19618, April 11,
2000. You may qualify for having all gravity-based
penalties waived if your facility meets all nine (9)
conditions of the Audit Policy. For more information
on EPA’s Audit Policy, see the Agency’s website:
http://www.epa.gov/compliance/incentives/auditing/
auditpolicy.html.
EPA Enforcement Response Policy for TRI
Revisions. On September 26, 1991, EPA published
a Federal Register notice on revisions to TRI
reporting forms under EPCRA Section 313 (56 FR
48795-03). Section V of the notice refers to the
Agency’s enforcement and penalties policy
regarding Form R errors:
Facilities are reminded that there is a legal obligation
to file an accurate and complete Form R report for
each chemical by July 1 each year. EPA may take
enforcement action and assess civil administrative
penalties regarding corrections to errors in Form R
reports that are not changes based on previously
unavailable information or procedures which
improve the accuracy of the data initially reported.
The kinds of errors which may result in enforcement
and in penalties include but are not limited to the
following: (1) Errors caused by not using the most
readily available information, for example, not using
monitoring data collected for compliance or other
purposes with other regulations in calculating
releases; (2) omitting a major source of emissions;
(3) a mathematical or transcription or typographical
error which seriously compromises the accuracy of
the information, and; (4) other errors which seriously
affect the utility of the data, particularly errors in
release reporting for which the facility has no records
showing the derivation of the release calculation, and
cannot provide a sufficient explanation of the report.
EPA’s Small Business Compliance Policy. If you
have 100 or fewer employees and discover that your
facility is or may have been in violation of Section
313 of EPCRA (TRI Reporting), please refer to
EPA’s Small Business Compliance Policy. EPA will
eliminate or significantly reduce penalties for small
businesses that meet the conditions of the Policy,
including voluntarily discovering violations and
promptly disclosing and correcting them. This Policy
implements Section 223 of the Small Business
Regulatory Enforcement Fairness Act (SBREFA) of
1996. For more information, see the Agency’s
website:
http://www.epa.gov/compliance/incentives/smallbusi
ness/index.html.
Parent Company Information. In past years, the
Agency found that many facilities report inaccurate
parent companies and/or Dun and Bradstreet
numbers in Sections 4 and 5 of the TRI reporting
forms. All facilities should verify the accuracy of
facility and parent company information (e.g., D&B
number, parent company name). Related questions
and answers are provided in Appendix I.
Please note that EPA pre-loads standardized parent
company names into TRI-MEweb that were
researched from the prior year submissions. This
step was taken to improve the accuracy of parent
company names as well as create a standard format
for the names themselves. For example, only capital
letters are used and all periods are eliminated from
the parent names. In addition, standardized
abbreviations are now used for common terms found
in parent names such as ‘CO for Company’ and ‘INC
for Incorporated.’ More detailed explanations and a
facility-by-facility list of standardized parent names
can be found at http://www2.epa.gov/toxics-releaseinventory-tri-program/standardized-parent-companynames-ry-2014-tri-reporting.
A. To verify the accuracy of your facility and parent
company Dun and Bradstreet number and name,
as required in Section 5 of both Form R and
Form A, go to:
https://www.dnb.com/product/dlw/form_cc4.htm
or call 1-888-814-1435 to verify your
information. Callers to the toll free phone
number should understand that the Dun and
Bradstreet support representatives will need to
verify that callers requesting the D&B numbers
are agents of the business. Dun and Bradstreet
recommends knowing basic information such as
when the business originated, officer names, and
the name, address, and phone number for the
facility.
B. Facilities reporting to TRI should also make sure
they are providing the parent company name and
Dun and Bradstreet number as of December 31st
of the current reporting year.
Toxics Release Inventory Reporting Forms and Instructions
iv
Important Information for Reporting Year (RY) 2014
TRI-MEweb RY 2014 Version
The TRI-MEweb application helps facilities fulfill
their Emergency Planning and Community Right-toKnow (EPCRA) Section 313 and Pollution
Prevention Act (PPA) Section 6607 obligations.
TRI-MEweb is an interactive, intelligent, userfriendly web-based application tool that guides
facilities through TRI reporting. Using a series of
logically
ordered
questions,
TRI-MEweb
streamlines the analysis needed to determine if a
user must complete a Form R Report or if they meet
thresholds that allow them to use the Form A
Certification Statement for a particular chemical.
The TRI-MEweb software provides guidance for
each data element on the TRI reporting Forms. TRIMEweb checks the entered data for common errors
and then prepares it for electronic transmission and
certification in the Agency’s Central Data Exchange
(CDX) (see the flow diagram of the TRI-MEweb
reporting process (Figure 1) on page 2.)
The Electronic Reporting Rule of 2014 expanded
the use of the TRI-MEweb application to allow
submission of RY 1991 –2014 data. TRI-MEweb
allows facilities to submit, revise, and withdraw TRI
reporting forms for RYs 1991 – 2014, provided the
forms do not contain trade secret information.
Facilities may no longer submit, revise, or withdraw
TRI reporting forms for reporting years prior to RY
1991.
July 1 is the TRI reporting deadline. There is a
legal obligation to file an accurate and complete
Form R report for each chemical by July 1 each
year. EPA may take enforcement action and assess
civil administrative penalties regarding corrections
to errors in Form R reports that are not changes
based on previously unavailable information or
procedures which improve the accuracy of the data
initially reported. The kinds of errors which may
result in enforcement and in penalties include but
are not limited to the following: (1) errors caused by
not using the most readily available information, for
example, not using monitoring data collected for
compliance or other purposes with other regulations
in calculating releases; (2) omitting a major source
of emissions; (3) a mathematical or transcription or
typographical error which seriously compromises
the accuracy of the information, and; (4) other errors
which seriously affect the utility of the data,
particularly errors in release reporting for which the
facility has no records showing the derivation of the
release calculation, and cannot provide a sufficient
explanation of the report.
Electronic Facility Data Profile (eFDP). Reporting
facilities may confirm and review the TRI data they
submitted to EPA by viewing their electronic
Facility Data Profile (eFDP) online by logging into
their CDX account and clicking the TRI-MEweb:
TRI Made Easy link from the MyCDX page. This
opens the “Welcome” page of the TRI-MEweb
application. On the “Welcome” page, follow the
instructions for viewing the eFDP. If the facility
Technical Contact provides an email address in the
Form R/Form A Certification Statement, they will
receive an email notifying them when their eFDP
has been updated and published for review in TRIMEweb.
TRI-MEweb User Resources
o TRI-MEweb website:
http://www2.epa.gov/toxics-release-inventorytri-program/tri-meweb-resources.
Service notifications and reference materials for
reporting are posted on this webpage.
o
TRI-MEweb online tutorials:
http://www2.epa.gov/toxics-release-inventorytri-program/tri-meweb-tutorials.
Online Tutorials that provide step-by step
instructions for using TRI-MEweb.
TRI Information Center Hotline [(800) 424-9346 select option 3] and CDX Help Desk (888) 8901995. These hotlines provide regulatory reporting
assistance and CDX/TRI-MEweb technical support
to TRI reporting facilities.
Uncertified TRI-MEweb Submissions. A facility’s
registered certifying official must electronically sign
Form R and/or Form A reports via TRI-MEweb
before the submission is complete. Uncertified TRIMEweb electronic submissions are not considered
complete according to the reporting requirements in
EPCRA Section 313. Lack of certification will
prevent the submission from being processed.
Toxics Release Inventory Reporting Forms and Instructions
v
Important Information for Reporting Year (RY) 2014
How to Begin Using the RY 2014 TRIMEweb Reporting Tool
TRI-MEweb is accessed through EPA’s Central
Data Exchange (CDX). The TRI-MEweb
application uses EPA’s CDX network to transmit
and certify electronic submissions to EPA. CDX
allows facilities to submit a paperless report and
receive instant receipt confirmation of their
submission via the Internet. In addition, facilities
that reside in a state or tribe participating in the TRI
Data Exchange (TDX) will have their RY 2005 2014 forms sent simultaneously to EPA and their
state or tribal TRI representative in electronic
format. Find which states are participating in TDX
at: http://www2.epa.gov/toxics-release-inventorytri-program/tri-data-exchange.
Getting started. In early 2015, all technical
contacts, preparers, and certifying officials from
reporting facilities that filed TRI reports in the prior
reporting year will be emailed their 6-digit alpha
numeric access key for each facility account in TRIMEweb. This unique access key is used to load any
TRI data received by EPA in the past seven
reporting years into its corresponding TRI-MEweb
facility account. If you have not received a unique
6-digit access key by February, call the CDX
helpdesk at (888) 890-1995, however the access key
is ONLY needed if you cannot access your facility
account in TRI-MEweb or if a new user wants
access to the TRI-MEweb facility account. In most
cases, you will be able to start an RY 2014
submission without needing the annual email
containing your access key. TRI-MEweb users may
also use the access key that EPA sent to facility
contacts in previous years, however, in some
exceptional cases, the key may have been changed
by EPA’s Data Processing Center.
Log in to your CDX user account to open the
TRI-MEweb application. Preparers and certifying
officials must have a CDX user account. During the
CDX registration process, both user roles will need
to add the TRI-MEweb application to their CDX
user account before preparing/certifying their TRI
forms. Web browsers must have a security setting of
TLS 1.0 enabled. Otherwise, the CDX login web
page will appear as if it is broken. For detailed
instructions for changing the security settings on
your Web browser, go to the TRI-MEweb Resource
Web page:
http://www2.epa.gov/toxics-release-inventory-triprogram/tri-meweb-resources.
If you cannot reset the password to your CDX
account or have forgotten your CDX login
name, please call the CDX Hotline (888) 8901995.
For assistance setting up a new CDX user
account, adding your TRI role, adding the TRIMEweb application to your CDX user profile,
or for information on using the TRI-MEweb
reporting tool, visit the TRI-MEweb Resources
page.
The CDX login
https://cdx.epa.gov/.
TRI-MEweb can import previous year data
into current year chemical forms. TRIMEweb can import prior year data (if RY 2013
data were provided by the facility in the
previous year) into each selected current year
TRI chemical form. Although it is optional,
importing data can accelerate data entry if the
same chemicals are reported to EPA each year.
Importing data into any forms that have been
already started in TRI-MEweb will result in the
data being overwritten by the imported data
fields.
can
be
accessed
at:
Two user roles involved in TRI reporting. There
are two user roles in the TRI reporting process: a
preparer role and a certifying official role. Figure 1
(page 2) illustrates how these two roles are
involved in the TRI reporting process.
The
“Preparer” is the person who prepares TRI forms
for submission in TRI-MEweb but is not authorized
to certify them. The “Certifying Official” is the
person of authority or legal representative at a
facility that will be certifying the data contained in
the submitted TRI Form R or Form A Certification
Statement in TRI-MEweb to EPA and their state or
tribe. Certifying officials may also prepare forms,
but the preparer cannot certify TRI forms that have
been transmitted to CDX. Both TRI roles require a
CDX user account with the TRI-MEweb
application added to the MyCDX profile. Step-bystep instructions for creating CDX user accounts
for new preparers or certifying officials can be
found on the TRI-MEweb Resources web page.
All newly designated certifying officials with CDX
accounts are required to submit an Electronic
Signature Agreement (ESA) form to EPA for
approval before certifying TRI forms submitted to
EPA and their appropriate state or tribe. (See
Section A.2 for details on ESA processing.)
Toxics Release Inventory Reporting Forms and Instructions
vi
Important Information for Reporting Year (RY) 2014
Easier certification process built into TRIMEweb. TRI-MEweb has a certification process
that allows the certifying official to certify any
reporting year TRI Form R or Form A Certification
Statement directly within TRI-MEweb. In past
years, certifying officials had to exit TRI-MEweb to
certify forms. However, certifying officials no
longer need to log out of the system to certify the
forms prepared in the TRI-MEweb application. The
certifying official simply logs in to their CDX
account, opens TRI-MEweb, and certifies TRI
forms with certifications pending.
Requirements for new certifying officials. New
certifying officials must complete the following
tasks before any pending TRI submission can be
certified. If a certifying official completed this
process in RY 2013, they will bypass the new
certifying official setup process.
1. Security requirements. A returning certifying
official responsible for an Electronic Signature
Agreement approved prior to RY 2013 or a new
certifying official in RY 2014 must comply with
new security standards by choosing and
answering 5 questions from a list of 20. One of
the answered questions will be used to verify
and authenticate the identity of the certifying
official as part of the electronic signature
process. You are also required to provide the
TRI Facility Identification (TRIFID) of your
reporting facility and electronically sign a
TRIFID Certification Agreement to obtain
access to any pending submissions. The new
certification module in TRI-MEweb captures
and stores information for all certifying
officials. Please record the answers to your
security questions because you will not be able
to edit them in TRI-MEweb or within your
CDX user account. If you forget to answer your
security question after three attempts, your
account will be locked and you will need to call
the CDX helpdesk to reset the answers to your
security questions.
2. “Real-time” Electronic Signature Agreement
(ESA) approval option for new certifying
officials. Since RY 2012, EPA provides an
alternative method for certifying officials to
process ESAs in real-time using a third-party
identity verification vendor named LexisNexis.
In the past, all new ESA applications were
required to be mailed in for approval, a process
that took about two weeks. Now all new
certifying officials will be prompted to consider
using LexisNexis to obtain their ESA approval
upon registering for a new CDX account at
https://cdx.epa.gov. ESAs approved using
LexisNexis will receive electronic notification
in seconds, or “real time”.
Another significant advantage of the real-time
method, besides obtaining immediate ESA approval,
is that the real-time approval is applicable to
multiple CDX system flows. Programs like eTSCA
and Risk Management Plan (RMP eSubmit) will be
able to share the security credentials offered by the
CDX ESA obtained under TRI. To obtain this realtime approval, the certifying official must provide
personal identity authentication information such as
name, address, etc. Please note that EPA does not
collect any personal information from our users. The
use of these third party verification and
identification widgets is common in banking
systems.
However, for those new certifying officials that do
not wish to provide personal information to a thirdparty vendor, or who fail the real-time method for
some reason, the traditional paper ESA form will
still be available. The hard copy ESA approval
process requires the printing, completion, and
mailing of an electronic signature agreement
form (see page 3 for where to send form). Please
allow adequate time for the mailing and
processing of this form, which is estimated to
take a minimum of five (5) business days.
Facilities that do not have a signed ESA, electronic
or hard copy, will not be able to certify forms in
TRI-MEweb. It is recommended that certifying
officials complete their ESA well in advance of the
reporting deadline.
Toxics Release Inventory Reporting Forms and Instructions
vii
General Information
A.
General Information
Reporting to the Toxic Chemical Release Inventory
(i.e., Toxics Release Inventory (TRI)) is required by
Section 313 of the Emergency Planning and
Community Right to Know Act (EPCRA, or Title
III of the Superfund Amendments and
Reauthorization Act of 1986), Public Law 99 499.
The information contained in the Form R constitutes
a “report,” and the submission of a report to the
appropriate authorities constitutes “reporting.”
The Pollution Prevention Act, of October, 1990
(Pub. L. 101 508), added reporting requirements to
the Form R. These requirements began with
calendar year 1991 reports and affect all facilities
required to submit a Form R under Section 313 of
EPCRA.
submissions. However, facilities submitting TRI
reports containing trade secrets will still submit their
reports to EPA on paper, not via TRI-MEweb. This
electronic reporting requirement includes late
submissions for prior reporting years, revisions, and
withdrawals.
A.1
EPCRA Section 313 requires that reports be filed by
owners and operators of facilities that meet all of the
following criteria:
The facility has 10 or more full-time employee
equivalents (i.e., a total of 20,000 hours or
greater; see 40 CFR 372.3);
The facility is included in a North American
Industry Classification System (NAICS) code
listed in Table I. NAICS codes found in Table I
correspond to the following Standard Industrial
Classification (SIC) Codes: SIC 10 (except
1011, 1081, and 1094), 12 (except 1241), 20-39,
4911 (limited to facilities that combust coal
and/or oil for the purpose of generating
electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil
for the purpose of generating electricity for
distribution in commerce), 4939 (limited to
facilities that combust coal and/or oil for the
purpose of generating electricity for distribution
in commerce), 4953 (limited to facilities
regulated under RCRA Subtitle C, 42 U.S.C.
Section 6921 et seq.), 5169, 5171, and 7389
(limited to facilities primarily engaged in
solvents recovery services on a contract or fee
basis); and
The facility manufactures (defined to include
importing), processes, or otherwise uses any
EPCRA Section 313 chemical in quantities
greater than the established threshold in the
course of a calendar year. Reporting thresholds
are listed in Section B.4.
Reporting is required to provide information to the
public on releases and other waste management of
EPCRA Section 313 chemicals in their communities
and to provide EPA with release and other waste
management information to assist the Agency in
determining the need for future regulations.
Facilities must report the quantities of routine and
accidental releases, and releases resulting from
catastrophic or other onetime events of EPCRA
Section 313 chemicals, as well as the maximum
amount of the EPCRA Section 313 chemical on-site
during the calendar year and the amount contained
in wastes managed on-site or transferred off-site.
A completed Form R or Form A must be submitted
for each EPCRA Section 313 chemical
manufactured, processed, or otherwise used at each
covered facility as described in the reporting rules in
40 Code of Federal Regulations (CFR) Part 372
(originally published February 16, 1988, in the
Federal Register and November 30, 1994, in the
Federal Register (for Form A)).
The Electronic Reporting Rule was published in the
Federal Register on August 27, 2013 (78 FR 52860)
and requires all forms to be submitted electronically.
Reports that are not submitted electronically using
TRI-MEweb will not be processed as acceptable
Who Must Report
Executive Order 13423 extends these reporting
requirements to federal facilities, regardless of their
SIC or NAICS code.
Toxics Release Inventory Reporting Forms and Instructions
1
General Information
Figure 1. TRI-MEweb’s Preparation, Transmission, Certification and Submission Steps
A.2
How to Submit Forms
Facilities must use the TRI-MEweb application to
submit non-trade secret TRI reports. TRI-MEweb is
accessible online and assists facilities reporting TRI
data by importing prior year TRI form data into
current year forms to expedite reporting, validating
reports to ensure higher data quality, and providing
instant receipt confirmation of submissions.
Some facilities prepare TRI reporting forms using
their own software. These facilities still need to load
and submit their TRI reporting forms to EPA using
TRI-MEweb via the online reporting application’s
third-party load feature. More information on the
third-party load feature can be found on the TRIMEweb webpage: http://www2.epa.gov/toxicsrelease-inventory-tri-program/tri-meweb-resources.
Facilities must submit a copy of each reporting form
sent to EPA to the state or tribe in which that facility
is located. Conveniently, TRI-MEweb will
simultaneously send a copy of each reporting form
submitted to EPA to the appropriate state or tribal
official if the state or tribe participates in the TRI
Data Exchange (TDX). (Internet submissions are
currently not available for trade secret claims). This
simultaneous submission satisfies a facility’s legal
obligation to report to EPA and the appropriate state
or tribe. States participating in TDX are shown on
this website.
http://www2.epa.gov/toxics-release-inventory-triprogram/tri-data-exchange.
Please be aware that if your facility does not reside
in a state or tribe participating in the TDX, just
transmitting TRI forms via the Internet does not
satisfy your state or tribal reporting requirements for
your facility. You must report to your state or tribe
separately and in the required format specified by
your state or tribe. However, if your state or tribe is
not in the TDX then TRI-MEweb can still be used
by the reporting facility to prepare and print the
proper paper TRI forms. A senior management
official must certify the submission by signing the
TRI forms. For non-TDX states and tribes,
completed TRI forms must be printed from TRIMEweb and mailed to the designated state or tribal
contact. Do not send forms from the TRI-MEweb
application to EPA’s Data Processing Center (DPC),
except for trade secret submissions, which still must
be sent to the DPC.
Toxics Release Inventory Reporting Forms and Instructions
2
General Information
Electronic Signature Agreement
An Electronic Signature Agreement (ESA) is a
statement that declares that the person electronically
signing a document (i.e., a reporting form)
understands the electronic signature is as legally
binding as a handwritten signature. EPA requires a
certifying official to have a signed ESA on record
before the certifying official can certify and submit
a TRI form created in TRI-MEweb. Returning
certifying officials since RY 2013 will likely have
an ESA signed on record and will only need to
navigate to the “Certify” tab in TRI-MEweb to find
any pending submission(s) that is ready to be
certified.
ESAs are created when the certifying official creates
a new CDX user account with a certifying official
role within CDX. Currently, there are two ways to
obtain an ESA approval from EPA.
Option 1 - LexisNexis real-time ESA approval.
A new certifying official may use a third-party
identity verification vendor to obtain an ESA
electronically. The certifying official will need to
voluntarily
provide
personal
identifying
information to the third-party vendor (EPA does
not collect any personal information from our
users) to authenticate his or her identity. The most
significant benefit gained from using this thirdparty identify verification is that users will no
longer need to wait up to 5 business days for EPA
to approve an ESA. If the certifying official does
not wish to provide personal information to a thirdparty vendor, he or she should submit a paper ESA
form instead well ahead of the July 1 reporting
deadline.
Option 2 - Paper ESA form. A printable ESA
form can be generated during the CDX registration
process. The ESA form must be signed and mailed
to EPA’s Data Processing Center (DPC in figure 1)
for approval before the certifying official can begin
to certify any TRI forms transmitted by the preparer
to CDX using TRI-MEweb. Hard copy ESA
approval may take up to five business days, so
please plan accordingly or consider option one,
LexisNexis. Multiple TRIFIDs can also be added to
a single hard copy ESA form. All newly assigned
TRIFIDs will be listed in the printout of the ESA
document. TRI-MEweb is updated when the ESA is
approved.
Paper ESAs can be mailed to the address below:
Attention: TRI ESA Approval Request
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 22038
TRIFID Certification Agreement. In addition to
the ESA, new certifying officials must sign a
TRIFID Certification Agreement for each facility
they represent. By signing the TRIFID Certification
Agreement, certifying officials are confirming that
they are owner/operators or senior management
officials for the reporting facility and are authorized
to certify forms for that facility. Certifying officials
must complete the TRIFID Certification Agreement
only once for each facility they represent as a
certifying official. Returning certifying officials will
be ready to certify any forms for a facility account
that has a signed TRIFID Signature Agreement. A
single CDX ESA will also allow new and returning
certifying officials to represent additional facility
accounts without the need for an ESA approval for
each facility account. All newly added facility
accounts will only require a TRIFID Signature
Agreement to be signed.
To sign the TRIFID Certification Agreement form,
users must be logged into TRI-MEweb using an
account with a certifying official role and users must
have submitted and obtained approval via CDX or a
paper ESA. Click on the “Certify” tab to access the
"Manage TRIFIDs for Certification" page, where a
list of TRIFIDs pending signature is displayed. Then
select the check box next to the facility’s TRIFID in
the "Pending Signature" table and click Sign
Agreement
button.
Review
the
TRIFID
Certification Agreement and click I Agree button.
The electronic signature widget will prompt the
certifying official to enter their CDX password,
answer a secret question, and click Sign. A
confirmation box will appear, noting the successful
signature.
ESA and TRIFID Certification Agreement
Status in TRI-MEweb. The ESA and TRIFID
Certification Agreement status of the certifying
official(s) assigned to each facility is listed under
the ESA Status column in TRI-MEweb.
A status of
No CDX ESA indicates that no
certifying officials are associated with the
facility.
A status of
Sign CDX ESA indicates that
either:
Toxics Release Inventory Reporting Forms and Instructions
3
General Information
The certifying official has not signed an
ESA. The certifying official must sign a
new CDX ESA.
o The certifying official has provided a paper
copy of ESA prior to RY 2012. The
returning
certifying
official
must
electronically sign a new CDX ESA upon
logging in to CDX for first time in RY
2014. Also note that TRIFID Certification
Agreement has also not been signed.
A status of
Sign TRIFID Signature
Agreement indicates that the certifying official
has obtain approval of the CDX ESA, but still
needs to sign the TRIFID Certification
Agreement within the TRI-MEweb application.
A status of
Active Certifying Official
Available indicates that your assigned
certifying official has received approval of the
ESA, signed the TRIFID Certification
Agreement, and is ready to certify any pending
forms transmitted by the preparer.
o
Accidental deletion of ESA in TRI-MEweb. The
TRI-MEweb application also has the capability to
manage user profiles (previously authorized
preparers or certifying officials) that have been
granted access to facility accounts. This capability
includes revoking approved ESA(s) for any
certifying official(s) that has left the facility’s
payroll or is no longer authorized to certify forms.
An ESA could also be accidently revoked by the
preparer. If this occurs, there is a 45-day grace
period to get the ESA reactivated by the CDX
helpdesk without having to send a paper form to
EPA for re-approval. An email notification is sent
to the affected certifying official by CDX when an
ESA has been revoked within TRI-MEweb.
State and Tribal Submissions.
If the facility is in a state that is not in EPA’s TRI
Data Exchange (TDX) system, then the facility must
also send a copy of the report to the state. To verify
if your state is or is not in the TDX system, go to:
http://www2.epa.gov/toxics-release-inventory-triprogram/tri-data-exchange. “State” also includes:
the District of Columbia, the Commonwealth of
Puerto Rico, Guam, American Samoa, Marshall
Islands, the U.S. Virgin Islands, the Commonwealth
of the Northern Mariana Islands, and any other
jurisdiction and Indian country. Refer to Appendix
E for the appropriate state submission addresses.
Facilities located within a tribe’s Indian country will
need to provide their three-digit Bureau of Indian
Affairs (BIA) tribal code for their Indian country
name in the “City/County/Tribe/State/ZIP code”
field on the Form R or Form A in Section 4.1. In
TRI-MEweb, these facilities should select the “My
facility is located in Indian Country” checkbox and
“Add BIA Code,” which provides a searchable list
of BIA codes and corresponding Indian country
names. BIA tribal codes are also provided in Table
V.
Hard copies of TRI forms must be mailed to the
tribe’s Chief Executive Officer because most tribal
entities are not members of TDX. If tribes have
entered into a cooperative agreement with states,
report submissions should be sent to the entity
designated in the cooperative agreement. Facilities
using TRI-MEweb to fulfill their federal and tribal
reporting requirements under EPCRA Section 313
will be able to print a hard copy of the TRI form to
mail to their Indian country’s Chief Executive
Officer.
RYs 1991 - 2004 submissions: If a facility prepares
and submits a TRI RY 1991 through RY 2004 form
using TRI-MEweb, they must print/save a copy of
their TRI form on a disk and send it to their State or
Tribal TRI coordinator, even if State or Tribal
Country is on the TRI Data Exchange (TDX)
network. TDX is not configured to simultaneously
transmit pre-RY 2005 TRI forms.
A.3
Trade Secret Claims
Starting with RY 2013, the only TRI reports EPA
will accept on paper are for trade secret
submissions. Paper submissions must be sent to
both EPA and the state or the designated official of
an Indian tribe and follow the requirements for
reporting trade secrets. If a report is not received by
both EPA and the state (or the designated official of
an Indian tribe), the submitter is considered out of
compliance and subject to enforcement action.
Facilities submitting paper forms must use the
corresponding reporting year forms. To facilitate the
completion and processing of paper forms, EPA is
providing electronically fillable reporting forms that
can be completed prior to printing for RY 2014 TRI
forms. The fillable reporting form can be found on
the TRI website: http://www2.epa.gov/toxicsrelease-inventory-tri-program/tri-reporting-formsand-instructions.
Toxics Release Inventory Reporting Forms and Instructions
4
General Information
E-mailed submissions will not be accepted.
For any EPCRA Section 313 chemical whose
identity is claimed as trade secret, two versions of
the substantiation form must be submitted to EPA as
prescribed in 40 CFR Part 350, published July 29,
1988, in the Federal Register (53 FR 28772) as well
as two versions of the EPCRA Section 313 report.
The current substantiation form is available on the
TRI website at: http://www2.epa.gov/toxics-releaseinventory-tri-program/tri-reporting-forms-andinstructions#Anchor 5. One set of reports, the
unsanitized version, must provide the actual identity
of the EPCRA Section 313 chemical. The other set
of reports, i.e., the “sanitized” version, must provide
a generic class or category for the chemical that is
structurally descriptive of the EPCRA Section 313
chemical. If EPA deems the trade secret
substantiation form valid, only the sanitized set of
forms will be made available to the public.
Further explanation of the trade secret provisions is
provided in Part I, Sections 2.1 and 2.2, and Part II,
Section 1.3, of the instructions.
In summary, a complete report to EPA for an
EPCRA Section 313 chemical claimed as a trade
secret must include all of the following:
A completed unsanitized version of Form R or
Form A report including the EPCRA Section
313 chemical identity (staple the pages
together); and
A sanitized version of a completed Form R or
Form A report in which the EPCRA Section 313
chemical identity items (Part II, Sections 1.1
and 1.2) have been left blank but in which a
generic chemical name that is structurally
descriptive has been supplied (Part II, Section
1.3) (staple the pages together); and
A completed unsanitized version of a trade
secret substantiation form (staple the pages
together); and
A sanitized version of a completed trade secret
substantiation form (staple the pages together).
Securely fasten all four reports together.
Some states or tribes also require submission of both
sanitized and unsanitized reports for EPCRA
Section 313 chemicals whose identity is claimed as
a trade secret. Others require only a sanitized
version. Facilities may jeopardize the trade secret
status of an EPCRA Section 313 chemical by
submitting an unsanitized version of the EPCRA
Section 313 report to a state agency or Indian tribe
that does not require unsanitized forms. You may
identify an individual state or tribe’s submission
requirements by contacting the appropriate state or
tribe designated EPCRA Section 313 contact (see
Appendix E).
Where to send your trade secret submission
Please send only trade secret submissions to the
P.O. Box below. Send trade secret submissions by
regular mail to:
Attention: EPCRA Substantiation Packages
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 22038
Send trade secret submissions by certified mail or
overnight mail (i.e. Fed Ex, UPS, etc.) to:
Attention: EPCRA Substantiation Packages
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
A.4
Recordkeeping
Sound recordkeeping practices are essential for
accurate and efficient TRI reporting. It is in the
facility’s interest, as well as EPA’s, to maintain
records properly. Facilities must keep a copy of
each report filed for at least three years from the
date of submission. These reports will be of use
when completing future reports.
Facilities must also maintain those documents,
calculations, worksheets, and other forms upon
which they relied to gather information for prior
reports. In the event of a problem with data elements
on a facility’s Form R or Form A report, EPA may
request documentation from the facility that
supports the information reported.
EPA may conduct data quality reviews of Form R or
Form A submissions. An essential component of
this process involves reviewing a facility’s records
for accuracy and completeness. EPA recommends
that facilities keep a record for those EPCRA
Section 313 chemicals for which they did not file
EPCRA Section 313 reports.
Toxics Release Inventory Reporting Forms and Instructions
5
General Information
EPA also recommends keeping records of all
documentation containing your CDX account
information for your preparer(s) and certifying
official(s) that use TRI-MEweb to prepare and
certify the reporting facility’s TRI Form R and/or
Form A. These CDX documents include the
Electronic Signature Agreement (ESA) and the
facility’s unique 6-digit alphanumeric access key.
database called the Toxics Release Inventory
Processing System (TRIPS), and made available to
the public through Envirofacts and TRI Explorer.
Effective January 21, 2014 facilities may only revise
TRI reporting forms submitted for RY 1991 through
the current reporting year and must do so using TRIMEweb (except for reporting forms containing trade
secrets).
Records to maintain include:
Previous years’ EPCRA Section 313 reports;
EPCRA Section 313 Reporting Threshold
Worksheets;
Engineering calculations and other notes;
Purchase records from suppliers;
Inventory data;
EPA (NPDES) permits and monitoring reports;
EPCRA Section 312 Tier II Reports;
Monitoring records;
Flowmeter data;
RCRA Hazardous Waste Generator’s Report;
Pretreatment reports filed by the facility with
the local government;
Invoices from waste management companies;
Manufacturer’s
estimates
of
treatment
efficiencies;
RCRA manifests;
Process diagrams that indicate emissions and
other releases;
Records for those EPCRA Section 313
chemicals for which they did not file EPCRA
Section 313 reports; and
CDX account information including unique 6digit access key to pre-load facility account into
TRI-MEweb and copies of the Electronic
Signature Agreement (s) submitted to EPA for
approval.
A.5
A.5.1
How to Revise, Withdraw or
Cancel TRI Data
Revising TRI Data
Facilities that filed a Form R and/or Form A
Certification Statement under EPCRA Section 313
may submit a request to revise a form that was
previously submitted, stored in EPA’s historical
Facilities may request a revision for one or more of
the following reasons:
Revision codes:
o
RR1 - New Monitoring Data
o
RR2 - New Emission Factor(s)
o
RR3 - New Chemical Concentration Data
o
RR4 - Recalculation(s)
o
RR5 - Other Reason(s)
Please note that late submissions for chemicals not
reported in a previous reporting year are not
considered revisions for that year.
Facilities are reminded that there is a legal
obligation to file an accurate and complete Form R
or Form A report for each chemical by July 1 each
year. EPA may take enforcement action and assess
civil administrative penalties regarding corrections
to errors in Form R reports that are not changes
based on previously unavailable information or
procedures which improve the accuracy of the data
initially reported. The kinds of errors which may
result in enforcement and in penalties include but
are not limited to the following: (1) Errors caused
by not using the most readily available information,
for example, not using monitoring data collected for
compliance with other regulations in calculating
releases; (2) omitting a major source of emissions;
(3) a mathematical or transcription or typographical
error which seriously compromises the accuracy of
the information, and; (4) other errors which
seriously affect the utility of the data, particularly
errors in release reporting for which the facility has
no records showing the derivation of the release
calculation, and cannot provide a sufficient
explanation of the report.
Toxics Release Inventory Reporting Forms and Instructions
6
General Information
How do I revise my submission(s)?
If you plan to revise a TRI submission, send revised
report(s) to EPA and the appropriate state or tribal
agency.
Use TRI-MEweb to submit revisions to non-trade
secret TRI submissions. EPA will only accept
revisions for RY 1991 through the current year.
If you have questions about using TRI-MEweb to
revise your Form R/A, please refer to the TRIMEweb tutorial page at:
http://www2.epa.gov/toxics-release-inventory-triprogram/tri-meweb-tutorials.
A.5.2
Withdrawing TRI Data
Facilities that filed a Form R and/or Form A
Certification Statement under EPCRA Section 313
may submit a request to withdraw a form that was
previously submitted, stored in the Toxics Release
Inventory Processing System (TRIPS), and made
available to the public through Envirofacts and TRI
Explorer.
EPA
may
periodically
review
withdrawals.
Effective January 21, 2014 facilities may only
withdraw TRI reporting forms submitted for RY
1991 through the current reporting year and must
use TRI-MEweb to do so (except for reporting
forms containing trade secrets).
Facilities may request a withdrawal for one or
several reasons, such as:
the TRI Data Exchange (TDX).
Non-TDX
state/tribal facilities need to mail in hard copy forms
to their state or tribe. Keep in mind that successfully
completed withdrawal requests permanently delete
the chemical release data that was provided by the
reporting facility and processed into TRI’s publicly
available database.
If the reporting facility needs to make a correction
to data submitted to EPA, a revision is easier to
process than withdrawing incorrect TRI forms and
resubmitting them to EPA.
Use TRI-MEweb to withdraw TRI forms from RY
1991 through the current year (except for reporting
forms containing trade secrets). Withdrawals can
only be done for TRI submissions that have been
properly transmitted, certified and processed by
EPA. If you have questions about using TRIMEweb to withdraw your Form R/A, please refer to
the TRI-MEweb tutorial page at:
http://www2.epa.gov/toxics-release-inventory-triprogram/tri-meweb-tutorials.
A.5.3
Canceling a TRI Submission
Different situations may require a TRI-MEweb user
to cancel an electronic TRI submission. For
instance, a facility’s preparer or certifying official
may determine that a draft electronic submission(s)
requires cancellation because the facility’s chemical
release did not, in fact, meet the reporting thresholds
of EPCRA Section 313.
How do I withdraw my submission(s)?
Another reason why a TRI-MEweb submission may
require cancellation is if a preparer or certifying
official has determined that a correction is needed
on a TRI form that is pending certification in CDX,
but has not yet been certified. In order to edit a TRI
form in TRI-MEweb that is pending certification to
CDX, the preparer will need to cancel the
transmitted submission with a Pending Certification
status in order to make the additional corrections in
TRI-MEweb and retransmit the original submission
or revision to CDX to be certified. EPA is
considering issuing a Notice of Non-compliance for
TRI Forms that have been transmitted to CDX but
are not certified.
If you plan to withdraw a TRI submission, send
your request to EPA using TRI-MEweb –
withdrawals on paper forms will not be accepted.
Withdrawal requests for RY 2005 - 2014 forms will
be automatically submitted to states participating in
A preparer or a certifying official cannot cancel a
TRI form submission that has already been
transmitted and certified by the certifying official. If
a chemical form has a status of Certified and Sent to
EPA in TRI-MEweb it cannot be called back to be
Withdrawal codes:
WT1 - Did not meet the reporting threshold for
manufacturing, processing, or otherwise use
WT2 - Did not meet the reporting threshold for
number of employees
WT3 - Not in a covered NAICS Code
WO1 - Other reason(s)
Toxics Release Inventory Reporting Forms and Instructions
7
General Information
edited or corrected. To change or remove data that
has already been transmitted, certified and
submitted to EPA to be processed, either revise or
withdraw the submission.
Note: ALL chemical forms that were included in the
selected submission will be canceled.
How to Cancel a TRI Submission that has not
been Certified.
If your facility decides not to complete the
certification process for any pending electronic
submission(s) transmitted to CDX by TRI-MEweb,
you should CANCEL the submission(s) using one
of the following methods:
By the Preparer: The preparer may use the TRIMEweb application to cancel any unwanted pending
submission(s). In TRI-MEweb, the preparer must
click the “Prepare” tab, choose the Reporting Year
corresponding to the unwanted submission(s) from
the “Select Year” tab, choose the appropriate
facility from the “Select Facility” tab, and select the
chemical form to be cancelled from the Select a
Form page. Next, the preparer must click the
“Review” tab. Then, the preparer must locate the
submission that includes the chemical form they
wish to cancel and select its radio button from the
Pending Submission Summary Table on the
Reporting Summary page. Next, they must click
the “Cancel” button and confirm the cancellation on
the next page. Note: ALL chemical forms that were
included in the selected submission will be
canceled.
By the Certifying Official: The certifying official
may also cancel any unwanted TRI submission(s)
pending certification. The certifying official must
log into their CDX account and click the “TRIMEweb: TRI Made Easy – Prepare/Certify
Submission” link from their MyCDX page. This
will open the “Welcome” page of the TRI-MEweb
application and then select the “Certify” tab. If
certifying official does not find the TRIFID for their
reporting facility with pending submissions listed,
they gain access to that facility account by entering
the access key on the “Enter Facility’s Access
Information” page and signing the TRIFID
Certification Agreement on the “Manage TRIFIDs
for Certification” page and clicking the “Next”
button. The electronic signature widget will pop-up
to confirm your authorized access to the facility
account. Upon successful authentication of user
identity, you may begin the cancellation process on
the “Pending Submissions” page under the
“Certify” tab. You may view the content of the
submission by clicking the “View Submission” icon
to confirm that this is the correct submission to be
cancelled. Select the “Cancel” radio button to
cancel submission and select “Next” to confirm
request. If you have questions about using TRIMEweb to cancel your Form R or Form A
Certification Statement submission, please refer to
the TRI-MEweb tutorial page at:
http://www2.epa.gov/toxics-release-inventory-triprogram/tri-meweb-tutorials.
Please note that if you are not able to certify prior to
the July 1 deadline, you will not be able to submit
on paper instead. Please ensure you execute an
electronic signature agreement (ESA) well ahead of
the July 1 deadline. If your certifying official could
not certify prior to the July 1 deadline because he or
she had not established an approved Electronic
Signature Agreement (ESA), he or she should log
into CDX once it becomes approved by EPA and
certify any pending submission(s).
If a facility could not process their ESA on time,
should their certifying official still certify
electronically after the July 1 deadline?
Yes. If a certifying officials cannot certify prior to
the July 1 deadline because they have not
established an approved ESA, they should log into
CDX once it becomes approved by EPA and certify
any pending submission(s).
A.6 When the TRI Report Must Be
Submitted
As specified in EPCRA Section 313, the report for
any calendar year must be submitted on or before
midnight on July 1 of the following year whether
using Form R or Form A. If the reporting deadline
falls on a Saturday or Sunday, EPA will accept
forms submitted on the following Monday (i.e., the
next business day).
Any voluntary revision to a report can be submitted
anytime during the calendar year for the current or
any previous reporting year. However, voluntary
revisions for the current reporting year should be
submitted by July 31 in order to be included in that
year’s TRI National Analysis.
Toxics Release Inventory Reporting Forms and Instructions
8
General Information
A.7
How to Obtain the TRI Reporting
Forms
The TRI Form R, Form R Schedule 1, Form A
Certification Statement, and related guidance
documents may be obtained from EPA’s TRI
website at:
http://www2.epa.gov/toxics-releaseinventory-tri-program. However, non-trade-secret
TRI reporting forms must be submitted to EPA using
TRI-MEweb. Paper forms are no longer processed
by EPA. Please do not send any paper forms, except
for trade secret submissions, to EPA’s Data
Processing Center.
Toxics Release Inventory Reporting Forms and Instructions
9
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
B.
How to Determine if Your
Facility Must Submit a
Form R or Is Eligible to Use
Form A
Examples:
A facility consists of 11 employees who each
worked 1,500 hours for the facility in a calendar
year. Consequently, the total number of hours
worked by all employees for the facility during
the calendar year is 16,500 hours. The number
of full-time employees for this facility is equal
to 16,500 hours divided by 2,000 hours per fulltime employee, or 8.3 full-time employees.
Therefore, even though 11 persons worked for
this facility during the calendar year, the
number of hours worked is equivalent to 8.3
full-time employees. This facility does not meet
the employee criteria and is not subject to
EPCRA Section 313 reporting.
Another facility consists of six workers and
three sales staff. The six workers each worked
2,000 hours for the facility during the calendar
year. The sales staff also each worked 2,000
hours during the calendar year although they
may have been on the road half of the year. In
addition, five contract employees were hired for
a period during which each worked 400 hours
for the facility. The total number of hours is
equal to the time worked by the workers (12,000
hours), plus the time worked by the sales staff
for the facility (6,000 hours), plus the time
worked by the contract employees (2,000
hours), or 20,000 hours. Dividing the 20,000
hours by 2,000 yields 10 full-time employees.
This facility has met the full-time employee
criteria and may be subject to reporting if the
other criteria are met.
This section will help you determine whether you
must submit an EPCRA Section 313 report (EPA
Form R or Form A Certification Statement). This
section discusses EPCRA Section 313 reporting
requirements such as the number of full-time
employees, primary NAICS code, and chemical
activity threshold quantities. The EPCRA Section
313 chemicals and chemical categories subject to
reporting are listed in Table II (also see 40 CFR
372.65). (See Figure 2 for more information.)
B.1
Full-Time Employee
Determination
The number of full-time employees is dependent
only upon the total number of hours worked by all
employees and other individuals (e.g., contractors)
for the facility during the calendar year and not the
number of persons working. Therefore, a full-time
employee, for purposes of EPCRA Section 313
reporting, is defined as 2,000 work hours per year.
When making the full-time employee determination,
the facility must consider all paid vacation and sick
leave used as hours worked by each employee. In
addition, EPA interprets the hours worked by an
employee to include paid holidays. To determine the
number of full-time employees working for your
facility, add up the hours worked by all employees
during the calendar year, including contract
employees and sales and support staff working for
the facility, and divide the total by 2,000 hours. The
result is the number of full-time employees. In other
words, if the total number of hours worked by all
employees for your facility is 20,000 hours or more,
your facility meets the ten employee threshold.
The NAICS 2012 Manual is available from the
National Technical Information Service (NTIS)
website at: http://www.ntis.gov/about/index.aspx.
Toxics Release Inventory Reporting Forms and Instructions
10
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Figure 2. EPCRA Section 313 Reporting Decision Diagram
Toxics Release Inventory Reporting Forms and Instructions
11
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
B.2
Primary NAICS Code
Determination
Beginning with 2006 EPCRA Section 313 reporting,
the TRI Program requires North American Industry
Classification System (NAICS) codes instead of
Standard Industrial Classification (SIC) codes.
Please refer to the TRI Program’s final rule titled
Community Right-to-Know; Toxic Chemical
Release Reporting Using North American Industry
Classification System (NAICS) published in the
Federal Register on June 6, 2006 (71 FR 32464).
A direct final rule was published in the Federal
Register on July 18, 2013 (78 FR 42875) to adopt
2012 NAICS codes for RY 2013 and subsequent
reporting years.
The full list of 2012 NAICS codes for facilities that
must report to TRI (including exceptions and/or
limitations) if all other threshold determinations are
met can be found in Table I and also at the TRI
website at: http://www2.epa.gov/toxics-releaseinventory-tri-program/my-facilitys-six-digit-naicscode-tri-covered-industry.
The facility should determine its own NAICS
code(s), based on its activities on-site using the
NAICS Manual and by conducting NAICS keyword
and NAICS 2 to 6-digit code searches on the Census
Bureau website at:
http://www.census.gov/eos/www/naics/.
For
purposes of EPCRA Section 313 reporting, state
assigned codes should not be used if they differ
from codes assigned using the NAICS Manual.
B.2.a.
Auxiliary Facilities
Under the Standard Industrial Classification (SIC)
system, an auxiliary facility was defined as one that
supported another covered establishment’s activities
(e.g., research and development laboratories,
warehouses, and storage facilities). An auxiliary
facility could assume the SIC code of another
covered establishment if its primary function was to
service that other covered establishment’s
operations. The North American Industry
Classification System (NAICS), that replaces the
SIC system for TRI reporting, does not recognize
the concept of auxiliary facilities and assigns
NAICS codes to all establishments based on
economic activity. In its rulemaking, “Toxic
Chemical Release Reporting Using North American
Industry Classification System,” the TRI Program
has adopted NAICS for TRI reporting and also the
NAICS treatment of former “auxiliary facilities” as
entities with their own distinct NAICS code.
B.2.b.
Multi-establishment Facilities
Your facility may include multiple establishments
that have different NAICS codes. A multiestablishment facility is a facility that consists of
two or more distinct and separate economic units. If
your facility is a multi-establishment facility,
calculate the value added of the products produced,
shipped, or services provided from each
establishment within the facility and then use the
following rule to determine if your facility meets the
NAICS code criterion:
If the total value added of the products
produced, shipped, or services provided at
establishments with covered NAICS codes is
greater than 50 percent of the value added of the
entire facility’s products and services, the entire
facility meets the NAICS code criterion.
If anyone establishment with a covered NAICS
code has a value added of services or products
shipped or produced that is greater than any
other establishment within the facility (40 CFR
Section 372.22(b)(3)) the facility also meets the
NAICS code criterion.
The value added of production or service
attributable to a particular establishment may be
isolated by subtracting the product value obtained
from other establishments within the same facility
from the total product or service value of the
facility. This procedure eliminates the potential for
“double counting” production and services in
situations where establishments are engaged in
sequential production or service activities at a single
facility.
Examples include:
A facility in coating, engraving and allied
services has two establishments. The first
establishment, a general automotive repair
service, is in NAICS code 811113 (SIC 7537),
which is not a covered NAICS code. However,
the second establishment, a metal paint shop is
in NAICS code 332812 (SIC 3479, which is a
covered NAICS code). The metal paint shop
paints the parts received from general
automotive repair service. The facility
Toxics Release Inventory Reporting Forms and Instructions
12
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
determines the product is worth $500/unit as
received from the general automotive repair
service (in non-covered NAICS code 811113)
and the value of the product is $1500/unit after
processing by the metal paint shop (in covered
NAICS code 332812). The value added by the
metal paint shop is obtained by subtracting the
value of the products from the general
automotive repair service from that of the value
of the products of the metal paint shop. (In this
example, the value added = $1,500/unit $500/unit = $1,000/unit.) The value added
($1,000/unit) by the establishment in NAICS
code 332812 is more than 50 percent of the
product value. Therefore, the facility’s primary
NAICS code is 332812, which is a covered
NAICS code.
A food processing establishment in a facility
processes crops grown at the facility in a
separate establishment. To determine the value
added of the products of each establishment the
facility could first determine the value of the
crops grown at the agricultural establishment,
and then calculate the contribution of the food
processing establishment by subtracting the crop
value from the total value of the product
shipped from the processing establishment
(value of product shipped from processing crop value = value of processing establishment).
A covered multi-establishment facility must make
EPCRA
Section
313 chemical
threshold
determinations and, if required, report all relevant
information about releases and other waste
management activities, and source reduction
activities associated with an EPCRA Section 313
chemical for the entire facility, even from
establishments that are not in covered NAICS codes.
EPA realizes, however, that certain establishments
in a multi-establishment facility can be, for all
practical purposes, separate and distinct business
units. Therefore, while threshold determinations
must be made for the entire facility, individual
establishments which compose the entire facility
may report their individual releases and other waste
management activities separately. However, the
total releases and other waste management
quantities for the entire facility must be represented
by the sum of the releases and other quantities
managed as waste reported by each of the separate
establishments.
B.2.c.
Property Owners
You are not required to report if you merely own
real estate on which a facility covered by this rule is
located; that is, you have no other business interest
in the operation of that facility (e.g., your company
owns an industrial park). The operator of that
facility, however, is subject to reporting
requirements.
B.3
B.3.a.
Activity Determination
Definitions of Manufacture,
Process, and Otherwise Use
Manufacture: The term “manufacture” means to
produce, prepare, compound, or import an EPCRA
Section 313 chemical. (See Part II, Section 3.1 of
these instructions for further clarification.)
Import is defined as causing the EPCRA Section
313 chemical to be imported into the customs
territory of the United States. If you order an
EPCRA Section 313 chemical (or a mixture
containing the chemical) from a foreign supplier,
then you have imported the chemical when that
shipment arrives at your facility directly from a
source outside of the United States. By ordering the
chemical, you have caused it to be imported, even
though you may have used an import brokerage firm
as an agent to obtain the EPCRA Section 313
chemical.
Do Not Overlook Coincidental Manufacture
The term “manufacture” also includes coincidental
production of an EPCRA Section 313 chemical
(e.g., as a byproduct or impurity) as a result of the
manufacture, processing, otherwise use or disposal
of another chemical or mixture of chemicals. In the
case of coincidental production of an impurity (i.e.,
an EPCRA Section 313 chemical that remains in the
product that is distributed in commerce), the de
minimis exemption, discussed in Section B.3.c of
these instructions, applies. The de minimis
exemption does not apply to byproducts (e.g., an
EPCRA Section 313 chemical that is separated from
a process stream and further processed or disposed
of). Certain EPCRA Section 313 chemicals may be
manufactured as a result of wastewater treatment or
other
treatment
processes.
For
example,
neutralization of wastewater containing nitric acid
can result in the coincidental manufacture of a
nitrate compound (solution), reportable as a member
of the nitrate compounds category.
Toxics Release Inventory Reporting Forms and Instructions
13
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Process: The term “process” means the preparation
of a listed EPCRA Section 313 chemical, after its
manufacture, for distribution in commerce.
Processing is usually the incorporation of an
EPCRA Section 313 chemical into a product (see
Part II, Section 3.2 of these instructions for further
clarification). However, a facility may process an
impurity that already exists in a raw material by
distributing that impurity in commerce. Processing
includes preparation of the EPCRA Section 313
chemicals in the same physical state or chemical
form as that received by your facility, or preparation
that produces a change in physical state or chemical
form. The term also applies to the processing of a
mixture or other trade name product (see Section
B.4.b of these instructions) that contains a listed
EPCRA Section 313 chemical as one component.
Otherwise Use: The term “otherwise use” means
any use of an EPCRA Section 313 chemical,
including an EPCRA Section 313 chemical
contained in a mixture or other trade name product
or waste, that is not covered by the terms
manufacture or process. Otherwise use of an
EPCRA Section 313 chemical includes disposal,
stabilization (without subsequent distribution in
commerce), or treatment for destruction if:
(1) The EPCRA Section 313 chemical that was
disposed of, stabilized, or treated for destruction
was received from off-site for the purposes of
further waste management;
Or
(2) The EPCRA Section 313 chemical that was
disposed of, stabilized, or treated for destruction
was manufactured as a result of waste management
activities on materials received from off-site for the
purposes of waste management activities.
Relabeling or redistributing of the EPCRA Section
313 chemical where no repackaging of the EPCRA
Section 313 chemical occurs does not constitute an
otherwise use or processing of the EPCRA Section
313 chemical. (See 62 FR 23846 and Part II, Section
3.3 of these instructions for further clarification).
Example 1: Coincidental Manufacture
Your company, a nitric acid manufacturer, uses aqueous ammonia in a waste treatment system
to neutralize an acidic wastewater stream containing nitric acid. The reaction of ammonia and
nitric acid produces a solution of ammonium nitrate. Ammonium nitrate (solution) is reportable
under the nitrate compounds category and is manufactured as a byproduct. If the ammonium
nitrate is produced in a quantity that exceeds the 25,000-pound manufacturing threshold, the
facility must report under the nitrate compounds category.
The aqueous ammonia is considered to be otherwise used and 10 percent of the total aqueous
ammonia would be counted towards the 10,000-pound otherwise use threshold. Reports for
releases of ammonia must also include 10 percent of the total aqueous ammonia from the
solution of ammonium nitrate (see the qualifier for the ammonia listing).
As another example, combustion of coal or other fuel in boilers/furnaces can result in the
coincidental manufacture of metal category compounds and sulfuric acid (acid aerosols),
hydrochloric acid (acid aerosols), and hydrogen fluoride.
Toxics Release Inventory Reporting Forms and Instructions
14
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Example 2: Typical Process and Manufacture Activities
Your company receives toluene, an EPCRA Section 313 chemical, from another facility, and
reacts the toluene with air to form benzoic acid, which the company distributes in commerce.
Your company processes toluene and manufactures and processes benzoic acid. Benzoic acid,
however, is not an EPCRA Section 313 chemical and thus does not trigger reporting
requirements.
Your facility combines toluene purchased from a supplier with various materials to form paint
which it then sells. Your facility processes toluene.
Your company receives a nickel compound (nickel compounds is a listed EPCRA Section 313
chemical category) as a bulk solid and performs various size-reduction operations (e.g.,
grinding) before packaging the compound in 50-pound bags, which the company sells. Your
company processes the nickel compound.
Your company receives a prepared mixture of resin and chopped fiber to be used in the injection
molding of plastic products. The resin contains a listed EPCRA Section 313 chemical that
becomes incorporated into the plastic, which the company distributes in commerce. Your
facility processes the EPCRA Section 313 chemical.
In the combustion of coal or oil, metal category compounds may be produced from either the
parent metal or a metal compound contained in the coal or oil. If a metal undergoes a change of
valence, a metal compound is considered to be manufactured. For example, during the
combustion process copper in valence state zero changes to copper in valence state +2 in a
compound such as copper (II) oxide (CuO). Furthermore, a metallic compound could be
transformed to another metallic compound without a change in valency (e.g., copper (II)
chloride (CuCl2) is transformed to copper (II) oxide (CuO)). The transformation to a new
compound by combustion without a change in valence state is also considered to be
“manufactured” for purposes of EPCRA Section 313.
Example 3: Typical Otherwise Use Activities
When your facility cleans equipment with toluene, you are otherwise using toluene. Your
facility also separates two components of a mixture by dissolving one component in toluene, and
subsequently recovers the toluene from the process for reuse or disposal. Your facility otherwise
uses toluene.
A covered facility receives a waste containing 12,000 pounds of Chemical A, a non-PBT
EPCRA Section 313 chemical, from off-site. The facility treats the waste, destroying Chemical
A and in the treatment process manufactures 10,500 pounds of Chemical B, another non-PBT
EPCRA Section 313 chemical. Chemical B is disposed of on-site. Since the waste containing
Chemical A was received from off-site for the purpose of waste management, the amount of
Chemical A must be included in the otherwise use threshold determination for Chemical A. The
otherwise use threshold for a non-PBT chemical is 10,000 pounds and since the amount of
Chemical A exceeds this threshold, all releases and other waste management activities for
Chemical A must be reported. Chemical B was manufactured in the treatment of a waste
received from off-site. The facility disposed of Chemical B on-site. Since Chemical B was
generated from waste received from off-site for treatment for destruction, disposal, or
stabilization, the disposal of Chemical B is considered to be an otherwise use. Thus, the amount
of Chemical B must be considered in the otherwise use threshold determination. Thus, the
reporting threshold for Chemical B has also been exceeded and all releases and other waste
management activities for Chemical B must be reported.
Toxics Release Inventory Reporting Forms and Instructions
15
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
B.3.b.
Persistent Bioaccumulative Toxic
(PBT) Chemicals and Chemical
Categories Overview
On October 29, 1999, EPA published a final rule (64
FR 58666) adding certain chemicals and chemical
categories to the EPCRA Section 313 list of toxic
chemicals and lowering the reporting threshold for
persistent bioaccumulative toxic (PBT) chemicals.
In addition, on January 17, 2001 EPA published a
final rule (66 FR 4500) that classified lead and lead
compounds as PBT chemicals and lowered their
reporting thresholds. The lower reporting thresholds
for lead applies to all lead except when lead is
contained in a stainless steel, brass or bronze alloy.
Dioxin and dioxin-like
compounds,
lead
compounds, mercury compounds and polycyclic
aromatic compounds (PACs) are the four PBT
chemical categories with lower reporting thresholds.
The 17 members of the dioxin and dioxin-like
compounds category and the 21 members of the
PACs category are listed in Table IIc of these
instructions. The dioxin and dioxin-like compounds
category has the qualifier, “Manufacturing; and the
processing or otherwise use of dioxin and dioxinlike compounds if the dioxin and dioxin-like
compounds are present as contaminants in a
chemical and if they were created during the
manufacturing of that chemical.”
EPA has added six individual chemicals to the
EPCRA Section 313 list of toxic chemicals that also
had their thresholds lowered:
benzo(g,h,i)perylene,
benzo(j,k)fluorene (fluoranthene),
3-methylcholanthrene,
octachlorostyrene,
pentachlorobenzene, and
tetrabromobisphenol A (TBBPA).
Benzo(j,k)fluorene and 3-methyl-cholanthrene were
added as members of the polycyclic aromatic
compounds (PACs) chemical category.
EPA lowered the reporting thresholds for PBT
chemicals to either 100 pounds, 10 pounds, or in the
case of the dioxin and dioxin-like compounds
chemical category, to 0.1 grams. The table at the
beginning of Section B.4 of these instructions lists
the applicable manufacture, process, and otherwise
use thresholds for the listed PBT chemicals.
EPA eliminated the de minimis exemption for all
PBT chemicals (except lead when contained in
stainless steel, brass or bronze alloy). However, this
action does not affect the applicability of the de
minimis exemption to the supplier notification
requirements (40 CFR Section 372.45(d) (1)). In
addition, PBT chemicals are ineligible for range
reporting for on-site releases and transfers off-site
for further waste management. This will not affect
the applicability of range reporting of the maximum
amount on-site as required by EPCRA Section
313(g).
All releases and other waste management quantities
greater than 0.1 pounds of a PBT chemical (except
the dioxin and dioxin like compounds chemical
category) should be reported at a level of precision
supported by the accuracy of the underlying data
and estimation techniques on which the estimate is
based. If a facility’s release or other waste
management estimates support reporting an amount
that is more precise than whole numbers, then the
more precise amount should be reported.
PBT chemical values of 0.1 pounds (e.g., 0.07
pounds) should either be rounded up to 0.1 pound or
reported as they are if the underlying data and
estimation techniques support that level of precision.
It is up to the facility to determine, based on the
accuracy of the underlying data and the estimation
techniques on which the estimate is based, whether
it would be appropriate to round the value to 0.1
pound, report the value as is, or round the value to
zero.
For the dioxin and dioxin-like compounds chemical
category, which has a reporting threshold of 0.1
grams, facilities need only report all release and
other waste management quantities greater than 100
micrograms (i.e., 0.0001 grams). Notwithstanding
the numeric precision used when determining
reporting eligibility thresholds, facilities should
report on the Form R to the level of accuracy that
their data supports, up to seven digits to the right of
the decimal. EPA’s reporting software and data
management systems support data precision to
seven digits to the right of the decimal. If a facility
has information on the individual members of the
dioxin and dioxin-like compounds category they
will also need to report the release and transfer
quantities of each congener (see instructions in
Section D).
Toxics Release Inventory Reporting Forms and Instructions
16
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Lead and Lead Compounds
B.3.c.
Lead and lead compounds are classified as PBT
chemicals and are subject to the lower
manufacturing, processing and otherwise use
threshold of 100 pounds. However, when lead is
contained in stainless steel, brass, or bronze alloys it
remains subject to the higher 25,000 pound
manufacturing and processing thresholds and the
10,000 pound otherwise use threshold.
Otherwise Use Exemptions. Certain otherwise uses
of listed EPCRA Section 313 chemicals are
specifically exempted:
Listed below are some important guidelines to use
when calculating threshold and release and other
waste management quantities for lead and lead
compounds:
1) quantities of lead not contained in stainless
steel, brass or bronze alloy are applied to both
the 100 pound threshold and the 25,000/10,000
pound thresholds;
2) quantities of lead that are contained in stainless
steel, brass or bronze alloys are only applied
toward the 25,000/10,000 pound thresholds;
3) a facility may take the de minimis exemption for
those quantities of lead in stainless steel, brass,
or bronze alloys that meet the de minimis
standard (e.g., manufactured as an impurity).
Accordingly, the de minimis exemption may be
considered for quantities of lead in stainless
steel, brass, or bronze alloys but it may not be
considered for lead not in stainless steel, brass,
or bronze alloys;
4) If a facility exceeds the 100-pound threshold for
lead other than in stainless steel, brass, or
bronze alloys, the facility may not apply Form
A eligibility for non-PBTs, range reporting in
Sections 5 and 6 of the Form R or the use of
whole numbers and 2 significant digits to any of
the lead they report. If a facility that exceeds the
25,000/10,000 pound threshold for lead in
stainless steel, brass, or bronze alloy without
tripping the 100-pound threshold for nonalloyed lead, the facility may consider the Form
A requirements for non-PBTs, range reporting
in Sections 5 and 6 of the Form R, and the use
of whole numbers and 2 significant digits.
Activity Exemptions
Otherwise use as a structural component of the
facility;
Otherwise use in routine janitorial or facility
grounds maintenance;
Personal uses by employees or other persons;
Otherwise use of products containing EPCRA
Section 313 chemicals for the purpose of
maintaining motor vehicles operated by the
facility; and
Otherwise use of EPCRA Section 313 chemicals
contained in intake water (used for processing
or non-contact cooling) or in intake air (used
either as compressed air or for combustion).
The exemption of an EPCRA Section 313 chemical
otherwise used 1) as a structural component of the
facility; or 2) in routine janitorial or facility grounds
maintenance; or 3) for personal use by an employee
cannot be taken for activities involving process
related equipment.
Articles Exemption. EPCRA Section 313
chemicals contained in articles that are processed or
otherwise used at a covered facility are exempt from
threshold determinations and release and other
waste management calculations. The exemption
applies when the facility receives the article from
another facility or when the facility produces the
article itself. The exemption applies only to the
quantity of EPCRA Section 313 chemical present in
the article. If the EPCRA Section 313 chemical is
manufactured (including imported), processed, or
otherwise used at the covered facility other than as
part of the article, in excess of an applicable
threshold quantity, the facility is required to report
that use of a chemical (40 CFR Section 372.38(b)).
For an EPCRA Section 313 chemical in an item to
be exempt as part of the article, the item must meet
all the following criteria in the EPCRA Section 313
article definition; that is, it must be a manufactured
item (1) which is formed to a specific shape or
design during manufacture, (2) which has end use
functions dependent in whole or in part upon its
shape or design during end use, and (3) which does
not release a toxic chemical under normal conditions
of processing or use of the item at the facility.
Toxics Release Inventory Reporting Forms and Instructions
17
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
If the processing or otherwise use of all like items
results in a total release of 0.5 pound or less of an
EPCRA Section 313 chemical in a reporting year to
any environmental medium, EPA will allow this
release to be rounded to zero, and the manufactured
items retain their article status. The 0.5 pound
threshold does not apply to each individual article,
but applies to the sum of all releases from
processing or otherwise use of all like articles. If all
the releases of like articles over a reporting year are
completely captured and recycled/reused on-site or
off-site, those items retain their article status. Any
amount that is released and is not recycled/reused
will count toward the 0.5 pound per year cut off
value.
The articles exemption applies to the normal
processing or use of articles. This exemption does
not apply to the manufacture of the article. EPCRA
Section 313 chemicals incorporated into articles
produced at a facility must be factored into
threshold determinations and release and other
waste management calculations.
Example 4: Articles Exemption
Nickel that is incorporated into a brass
doorknob is processed to manufacture the
brass doorknob, and therefore must be
counted toward threshold determinations
and release and other waste management
calculations. However, the use of the brass
doorknobs elsewhere in the facility does not
have to be counted. Disposal of the brass
doorknob after its use does not constitute a
“release;” thus, the brass doorknob remains
an article.
If an item used in the facility is fragmented,
the item is still an article if those fragments
being discarded remain identifiable as the
article (e.g., recognizable pieces of a
cylinder, pieces of wire). For instance, an
eight-foot piece of wire is cut into two fourfoot pieces of wire, without releasing any
EPCRA Section 313 chemicals. Each fourfoot piece is identifiable as a piece of wire;
therefore, the article status for these pieces
of wire remains intact.
EPCRA Section 313 chemicals received in
the form of pellets are not articles because
the pellet form is simply a convenient form
for further processing of the material.
If, in the course of processing or use, an item retains
its initial thickness or diameter, in whole or in part,
it meets the first part (i.e., it must be a manufactured
item which is formed to a specific shape or design
during manufacture) of the article definition. If the
item’s basic dimensional characteristics are totally
altered during processing or otherwise use, the item
does not meet the first part of the definition. An
example of items that do not meet the definition
would be items that are cold extruded, such as lead
ingots, which are formed into wire or rods. On the
other hand, cutting a manufactured item into pieces
that are recognizable as the article would not change
the original dimensions as long as the diameter or
the thickness of the item remained the same; the
articles exemption would continue to apply. Metal
wire may be bent and sheet metal may be cut,
punched, stamped, or pressed without losing their
article status as long as the diameter of the wire or
tubing or the thickness of the sheet is not totally
changed.
What constitutes a release of an EPCRA Section
313 chemical is important since processing or
otherwise use of articles that result in a release to
the environment (or more than 0.5 pounds) negate
the article status and precludes eligibility for the
exemption. Cutting, grinding, melting, or other
processing of manufactured items could result in a
release of an EPCRA Section 313 chemical during
normal conditions of processing or otherwise use
and therefore negate the exemption as articles.
De Minimis Exemption. The de minimis exemption
allows facilities to disregard certain minimal
concentrations of non-PBT chemicals in mixtures or
other trade name products when making threshold
determinations and release and other waste
management calculations. The de minimis
exemption does not apply to the manufacture of an
EPCRA Section 313 chemical except if that EPCRA
Section 313 chemical is manufactured as an
impurity and remains in the product distributed in
commerce, or if the EPCRA Section 313 chemical is
imported below the appropriate de minimis level.
The de minimis exemption does not apply to a
byproduct manufactured coincidentally as a result of
manufacturing, processing, otherwise use, or any
waste management activities. The de minimis
exemption does not apply to any PBT chemical
(except lead when it is contained in stainless steel,
brass or bronze alloy) or PBT chemical category. A
list of PBT chemicals may be found in Section B.4
of these instructions.
Toxics Release Inventory Reporting Forms and Instructions
18
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
When determining whether the de minimis
exemption applies to an EPCRA Section 313
chemical, the owner/operator must consider the
concentration of the non-PBT EPCRA Section 313
chemical in mixtures and other trade name products.
If the non-PBT EPCRA Section 313 chemical in a
mixture or other trade name product is manufactured
as an impurity, imported, processed, or otherwise
used and is below the appropriate de minimis
concentration level, then the quantity of the nonPBT EPCRA Section 313 chemical in that mixture
or other trade name product does not have to be
applied to threshold determinations nor included in
release or other waste management determinations.
If a non-PBT EPCRA Section 313 chemical in a
mixture or other trade name product is below the
appropriate de minimis level, all releases and other
waste management activities associated with the
EPCRA Section 313 chemical in that mixture or
other trade name product are exempt from EPCRA
Section 313 reporting. It is possible to meet an
activity (e.g., processing) threshold for an EPCRA
Section 313 chemical on a facility wide basis, but
not be required to calculate releases or other waste
management quantities associated with a particular
process because that process involves only mixtures
or other trade name products containing the nonPBT EPCRA Section 313 chemical below the de
minimis level.
EPA interprets the de minimis exemption such that
once a non-PBT EPCRA Section 313 chemical
concentration is at or above the appropriate de
minimis level in the mixture or other trade name
product threshold determinations and release and
other waste management calculations must be made,
even if that chemical later falls below the de minimis
level in the same mixture or other trade name
product. Thus, EPA considers reportable all releases
and other quantities managed as waste that occur
after the de minimis level has been met or exceeded.
If an EPCRA Section 313 chemical in a mixture or
other trade name product at or above de minimis is
brought on-site, the de minimis exemption never
applies.
De minimis levels for non-PBT EPCRA Section 313
chemicals and chemical categories are set at
concentration levels of either 1 percent or 0.1
percent; PBT chemicals and chemical categories do
not have de minimis levels with regard to this
exemption. The 0.1 percent de minimis levels are
dictated by determinations made by the National
Toxicology Program (NTP) in its Annual Report on
Carcinogens, the International Agency for Research
and Cancer (IARC) in its Monographs, or 29 CFR
part 1910, subpart Z. Therefore, once a non-PBT
chemical’s status under NTP, IARC, or 29 CFR part
1910, subpart Z indicates that the chemical is a
carcinogen or potential carcinogen, the reporting
facility may disregard levels of the chemical below
the 0.1 percent de minimis concentration provided
that the other criteria for the de minimis exemption
are met. De minimis levels for chemical categories
apply to the total concentration of all chemicals in
the category within a mixture, not the concentration
of each individual category member within the
mixture.
De Minimis Application to the Processing or
Otherwise Use of a Mixture
The de minimis exemption applies to the processing
or otherwise use of a non-PBT EPCRA Section 313
chemical in a mixture. Threshold determinations and
release and other waste management calculations
begin at the point where the chemical meets or
exceeds the de minimis level. If a non-PBT EPCRA
Section 313 chemical is present in a mixture at a
concentration below the de minimis level, this
quantity of the substance does not have to be
included for threshold determinations, release and
other waste management reporting, or supplier
notification requirements. The exemption will apply
as long as the mixture containing de minimis
amounts of a non-PBT EPCRA Section 313
chemical never equals or goes above the de minimis
limit.
Toxics Release Inventory Reporting Forms and Instructions
19
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Example 5: De Minimis Applications to Process and Otherwise Use Scenarios for Non-PBT
Chemicals
There are many cases in which the de minimis “limit” is crossed or re-crossed by non-PBT chemicals
within a process or otherwise use scenario. The following examples are meant to illustrate these complex
reporting scenarios.
Increasing Concentration To or Above De Minimis Levels During Processing for Non-PBT
Chemicals
A manufacturing facility receives toluene that contains chlorobenzene at a concentration below its de
minimis limit. Through distillation, the chlorobenzene content in process streams is increased over the de
minimis concentration of 1 percent. From the point at which the chlorobenzene concentration equals 1
percent in process streams, the amount present must be factored into threshold determinations and release
and other waste management estimates. The facility does not need to consider the amount of
chlorobenzene in the raw material when below de minimis levels, i.e., prior to distillation to 1 percent,
when making threshold determinations. The facility does not have to report emissions of chlorobenzene
from storage tanks or any other equipment associated with that specific process where the chlorobenzene
content is less than 1 percent.
Fluctuating Concentration During Processing for Non-PBT Chemicals
A manufacturer produces an ink product that contains toluene, an EPCRA Section 313 chemical, below
the de minimis level. The process used causes the percentage of toluene in the mixture to fluctuate: it rises
above the de minimis level for a time but drops below the level as the process winds down. The facility
must consider the chemical toward threshold determinations from the point at which it first equals the de
minimis limit. Once the de minimis limit has been met the exemption cannot be taken.
Concentration Ranges Straddling the De Minimis
Value
There may be instances in which the concentration
of a non-PBT chemical is given as a range
straddling the de minimis limit. Example 6
illustrates how the de minimis exemption should be
applied in such a scenario.
De Minimis Application in the Manufacture of
the Listed Chemical in a Mixture
The de minimis exemption generally does not apply
to the manufacturing of an EPCRA Section 313
chemical. However, the de minimis exemption may
apply to mixtures and other trade name products
containing non-PBT EPCRA Section 313 chemicals
that are imported into the United States. (See
Example 5)
impurities that remain in the product distributed in
commerce below the de minimis levels. The amount
remaining in the product is exempt from threshold
determinations. If the chemical is separated from the
final product, it cannot qualify for the exemption.
Any amount that is separated, or is separate, from
the product, is considered a byproduct and is subject
to threshold determinations and release and other
waste management calculations. Any amount of an
EPCRA Section 313 chemical that is manufactured
in a waste stream must be considered toward
threshold determinations and release and other
waste management calculations and accounted for
on Form R even if that chemical is manufactured
below the de minimis level.
The de minimis exemption also does not apply to
situations where a toxic chemical in waste is diluted
to below the de minimis level.
The exemption also applies to non-PBT EPCRA
Section 313 chemicals that are manufactured as
Toxics Release Inventory Reporting Forms and Instructions
20
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Example 6: Concentration Ranges Straddling the De Minimis Value
Scenario 1: A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1.25 percent
manganese. Manganese is eligible for the de minimis exemption at concentrations up to 1 percent. The
amount of mixture subject to reporting is the quantity containing manganese at or above the de minimis
concentration:
[(8,000,000) × (1.25% - 0.99%)] ÷ (1.25% - 0.25%)
The average concentration of manganese that is not exempt (above the de minimis) is:
(1.25% + 1.00%) ÷ (2)
Therefore, the amount of manganese that is subject to threshold determination and release and other waste
management estimates is:
8,000,000 1.25% 0.99% 1.25% 1.00%
23,400 pounds
1.25% 0.25%
2
= 23,400 pounds manganese (which is below the processing threshold for manganese)
In this scenario, because the facility’s information pertaining to manganese was available to two decimal
places, 0.99 was used to determine the amount below the de minimis concentrations. If the information
was available to one decimal place, 0.9 should be used, as in the scenario below.
Scenario 2: As in the previous example, manganese is present in a mixture, of which 8,000,000 pounds is
processed. The MSDS states the mixture contains 0.2 percent to 1.2 percent manganese. The amount of
mixture subject to reporting (at or above de minimis limit) is:
[(8,000,000) × (1.2% - 0.9%)] ÷ (1.2% - 0.2%)
The average concentration of manganese that is not exempt (at or above de minimis limit) is:
(1.2% + 1.0%) ÷ (2)
Therefore, the amount of manganese that is subject to threshold determinations and release and other
waste management estimates is:
8,000,000 1.2% 0.9% 1.2% 1.0%
26,400 pounds
1.2% 0.2%
2
= 26,400 pounds manganese (which is above the processing threshold for manganese)
Toxics Release Inventory Reporting Forms and Instructions
21
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Example 7: De Minimis Application in the Manufacture of a Toxic Chemical in a Mixture
Manufacture as a Product Impurity
Toluene 2,4 diisocyanate reacts with trace amounts of water to form trace quantities of 2,4diaminotoluene. The resulting product contains 99 percent toluene 2,4-diisocyanate and 0.05 percent 2,4diaminotoluene. The 2,4 diaminotoluene would not be subject to EPCRA Section 313 reporting nor would
supplier notification be required because the concentration of 2,4- diaminotoluene is below its de minimis
limit of 0.1 percent in the product.
Manufacture as a Commercial Byproduct and Impurity
Chloroform is a reaction byproduct in the production of carbon tetrachloride. It is removed by distillation
to a concentration of less than 150 ppm (0.0150 percent) remaining in the carbon tetrachloride. The
separated chloroform at 90 percent concentration is sold as a byproduct. Chloroform is subject to a 0.1
percent (1000 ppm) de minimis limit. Any amount of chloroform manufactured and separated as byproduct
must be included in threshold determinations because EPA does not interpret the de minimis exemption to
apply to the manufacture of a chemical as a byproduct. Releases of chloroform prior to and during
purification of the carbon tetrachloride must be reported. The de minimis exemption can, however, be
applied to the chloroform remaining in the carbon tetrachloride as an impurity. Because the concentration
of chloroform remaining in the carbon tetrachloride is below the de minimis limit, this quantity of
chloroform is exempt from threshold determinations, release and other waste management reporting, and
supplier notification.
Manufacture as a Waste Byproduct
A small amount of formaldehyde is manufactured as a reaction byproduct during the production of
phthalic anhydride. The formaldehyde is separated from the phthalic anhydride as a waste gas and burned,
leaving no formaldehyde in the phthalic anhydride. The amount of formaldehyde produced and removed
must be included in threshold determinations and release and other waste management estimates even if
the formaldehyde were present below the de minimis level in the process stream where it was
manufactured or in the waste stream to which it was separated because EPA does not interpret mixtures
and trade name products to includes wastes.
Laboratory Activities Exemption. EPCRA Section
313 chemicals that are manufactured, processed, or
otherwise used in a laboratory at a covered facility
under the direct supervision of a technically
qualified individual do not have to be considered for
threshold determinations and release and other
waste management calculations. However, pilot
plant scale and specialty chemical production does
not qualify for this laboratory activities exemption,
nor does the use of EPCRA Section 313 chemicals
for laboratory support activities, such as the use of
chemicals for equipment maintenance.
Coal Extraction Activities Exemption. If an
EPCRA Section 313 chemical is manufactured,
processed, or otherwise used in extraction by
facilities in NAICS codes 212111, 212112 and
212113, a person is not required to consider the
quantity of the EPCRA Section 313 chemical so
manufactured, processed, or otherwise used when
considering threshold determinations and release
and other waste management calculations (see
Example 8). Reclamation activities occurring
simultaneously with coal extraction activities (e.g.,
cast blasting) are included in the exemption.
However, otherwise use of ash, waste rock, or
fertilizer for reclamation purposes are not
considered part of extraction; non-exempt amounts
of EPCRA Section 313 chemicals contained in these
materials must be considered toward threshold
determinations and release and other waste
management calculations.
Metal Mining Overburden Exemption. If an
EPCRA Section 313 chemical that is a constituent
of overburden is processed or otherwise used by
facilities in NAICS codes 212221, 212222, 212231,
212234, and 212299, a person is not required to
Toxics Release Inventory Reporting Forms and Instructions
22
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
consider the quantity of the EPCRA Section 313
chemical so processed or otherwise used when
considering threshold determinations and release
and other waste management calculations.
For purposes of EPCRA Section 313 reporting,
overburden is the unconsolidated material that
overlies a deposit of useful material or ore. It does
not include any portion of the ore or waste rock.
Example 8: Coal mining extraction activities
Included among these are explosives for blasting
operations, solvents, lubricants, and fuels for
extraction related equipment maintenance and
use, as well as overburden and mineral deposits.
The EPCRA Section 313 chemicals contained in
these materials are exempt from threshold
determinations and release and other waste
management calculations, when manufactured,
processed or otherwise used during extraction
activities at coal mines.
B.4
Threshold Determinations
EPCRA Section 313 reporting is required if
threshold quantities are exceeded. Separate
thresholds apply to the amount of the EPCRA
Section 313 chemical that is manufactured,
processed or otherwise used.
You must submit a report for any EPCRA Section
313 chemical that is not listed as a PBT chemical
and which is manufactured or processed at your
facility in excess of the following threshold:
25,000 pounds per toxic chemical or category
over the calendar year.
You must submit a report for any EPCRA
Section 313 chemical which is not listed as a
PBT chemical and that is otherwise used at your
facility in excess of 10,000 pounds per toxic
chemical or category over the calendar year.
You must submit a report for any EPCRA Section
313 chemical that is listed as a PBT chemical and
which is manufactured, processed or otherwise used
at your facility above the designated threshold for
that chemical.
The PBT chemical names, Chemical Abstracts
Service (CAS) numbers and their reporting
thresholds are listed in the table below. See Table
IIc of these instructions for lists of individual
members of the dioxin and dioxin-like compounds
chemical category and the polycyclic aromatic
compounds (PACs) chemical category.
Toxics Release Inventory Reporting Forms and Instructions
23
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Chemical or chemical
category name
CAS number
or chemical
category
code
Threshold
(pounds,
unless noted
otherwise)
Aldrin
309-00-2
100
Benzo[g,h,i]perylene
191-24-2
10
Chlordane
57-74-9
10
Dioxin and dioxin-like
compounds
category
(manufacturing; and the
processing or otherwise
use of dioxin and dioxinlike compounds category
if the dioxin and dioxinlike
compounds
are
present as contaminants
in a chemical and if they
were created during the
manufacturing of that
chemical)
N150
0.1 gram
Heptachlor
76-44-8
10
Hexachlorobenzene
118-74-1
10
Isodrin
465-73-6
10
Lead
(this
lower
threshold does not apply
to lead when it is
contained in stainless
steel, brass or bronze
alloy)
7439-92-1
100
Lead compounds
N420
100
Mercury
7439-97-6
10
Mercury compounds
N458
10
Methoxychlor
72-43-5
100
Octachlorostyrene
29082-74-4
10
Pendimethalin
40487-42-1
100
Pentachlorobenzene
608-93-5
10
Polychlorinated
biphenyls (PCBs)
1336-36-3
10
Polycyclic aromatic
compounds category
(PACs)
N590
100
Tetrabromobisphenol A
79-94-7
100
Toxaphene
8001-35-2
10
Trifluralin
1582-09-8
100
B.4.a.
How to Determine if Your
Facility Has Exceeded
Thresholds
To determine whether your facility has exceeded an
EPCRA Section 313 reporting threshold, compare
quantities of EPCRA Section 313 chemicals that
you manufacture, process, or otherwise use to the
respective thresholds for those activities. A
worksheet is provided in Figure 3A to assist
facilities in determining whether they exceed any of
the reporting thresholds for non-PBT chemicals;
Figures 3B-D provide worksheets for PBT
chemicals. (The worksheets can be found at the end
of section B.5.) These worksheets also provide a
format for maintaining reporting facility records.
Use of these worksheets is not required and the
completed worksheet(s) should not accompany
Form R reports submitted to EPA and the state or
tribe. Additionally, EPA provides an online
threshold screening tool at:
http://www2.epa.gov/toxics-release-inventory-triprogram/tri-threshold-screening-tool.
Complete the appropriate worksheet for each
EPCRA Section 313 chemical or chemical category.
Base your threshold determination for EPCRA
Section 313 chemicals with qualifiers only on the
quantity of the EPCRA Section 313 chemical
satisfying the qualifier.
Use of the worksheets is divided into three steps:
Step 1 allows you to record the gross amount of
the EPCRA Section 313 chemical or chemical
category involved in activities throughout the
facility. Pure forms as well as the amounts of
the EPCRA Section 313 chemical or chemical
category present in mixtures or other trade name
products must be considered. The types of
activity (i.e., manufacturing, processing, or
otherwise using) for which the EPCRA Section
313 chemical is used must be identified because
separate thresholds apply to each of these
activities. A record of the information source(s)
used should be kept. Possible information
sources include purchase records, inventory
data, and calculations by a process engineer.
The data collected in Step 1 will be totaled for
each activity to identify the overall amount of
the EPCRA Section 313 chemical or chemical
category manufactured (including imported),
processed, or otherwise used.
Toxics Release Inventory Reporting Forms and Instructions
24
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Step 2 allows you to identify uses of the EPCRA
Section 313 chemical or chemical category that
were included in Step 1 but are exempt under
EPCRA Section 313. Do not include in Step 2
exempt quantities of the EPCRA Section 313
chemical not included in the calculations in Step
1. For example, if Freon contained in the
building’s air conditioners was not reported in
Step 1, you would not include the amount as
exempt in Step 2. Step 2 is intended for use
when a quantity or use of the EPCRA Section
313 chemical is exempt while other quantities
require reporting. Note the type of exemption
for future reference. Also identify, if applicable,
the fraction or percentage of the EPCRA
Section 313 chemical present that is exempt.
Add the amounts in each activity to obtain a
subtotal for exempted amounts of the EPCRA
Section 313 chemical or chemical categories at
the facility.
Step 3 involves subtracting the result of Step 2
from the results of Step 1 for each activity.
Compare this net sum to the applicable activity
threshold. If the threshold is exceeded for any of
the three activities, a facility must submit a
Form R for that EPCRA Section 313 chemical
or chemical category. Do not sum quantities of
the EPCRA Section 313 chemical that are
manufactured, processed, and otherwise used at
your facility, because each of these activities
requires a separate threshold determination. For
example, if in a calendar year you processed
20,000 pounds of a non-PBT EPCRA Section
313 chemical and you otherwise used 6,000
pounds of that same chemical, your facility has
not exceeded any applicable threshold and thus
is not required to report for that chemical.
Worksheets should be retained to document your
determination for reporting or not reporting, but
should not be submitted with the report.
You must submit a report if you exceed any
threshold for any EPCRA Section 313 chemical or
chemical category. For example, if your facility
processes 22,000 pounds of a non-PBT EPCRA
Section 313 chemical and also otherwise uses
16,000 pounds of that same chemical, it has
exceeded the otherwise use threshold (10,000
pounds for a non-PBT chemical) and your facility
must report even though it did not exceed the
process threshold (25,000 pounds for a non-PBT
chemical). In preparing your reports, you must
consider all non-exempted activities and all releases
and other waste management quantities of the
EPCRA Section 313 chemical from your facility,
not just releases and other waste management
quantities from the otherwise use activity.
Also note that threshold determinations are based
upon the actual amounts of an EPCRA Section 313
chemical manufactured, processed, or otherwise
used over the course of the calendar year. The
threshold determination may not relate to the
amount of an EPCRA Section 313 chemical brought
on-site during the calendar year. For example, if a
stockpile of 100,000 pounds of a non-PBT EPCRA
Section 313 chemical is present on-site but only
20,000 pounds of that chemical is applied to a
process, only the 20,000 pounds processed is
counted toward a threshold determination, not the
entire 100,000 pounds of the stockpile.
B.4.b.
Threshold Determinations for
On-Site Reuse Operations
Threshold determinations of EPCRA Section 313
chemicals that are reused at the facility are based
only on the amount of the EPCRA Section 313
chemical that is added during the year, not the total
volume in the system. For example, a facility
operates a refrigeration unit that contains 15,000
pounds of anhydrous ammonia at the beginning of
the year. The system is charged with 2,000 pounds
of anhydrous ammonia during the year. The facility
has therefore “otherwise used” only 2,000 pounds of
anhydrous ammonia, a non-PBT EPCRA Section
313 chemical, which is below the otherwise use
threshold for anhydrous ammonia and is not
required to report (unless there are other “otherwise
use” activities of ammonia, that when taken
together, exceed the reporting threshold). If,
however, the whole refrigeration unit was recharged
with 15,000 pounds of anhydrous ammonia during
the year, then the facility would have exceeded the
otherwise use threshold, and would be required to
report.
This does not apply to EPCRA Section 313
chemicals “recycled” or “reused” off-site and
returned to a facility. Such EPCRA Section 313
chemicals returned to a facility are treated as the
equivalent of newly purchased material for purposes
of EPCRA Section 313 threshold determinations.
Toxics Release Inventory Reporting Forms and Instructions
25
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
B.4.c.
Threshold Determinations for
Ammonia
The listing for ammonia includes the modifier
“includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium salts
and other sources; 10 percent of total aqueous
ammonia is reportable under this listing.” The
qualifier for ammonia means that anhydrous forms
of ammonia are 100 percent reportable and aqueous
forms are limited to 10 percent of total aqueous
ammonia. Therefore, when determining threshold
quantities, 100 percent of anhydrous ammonia is
included but only 10 percent of total aqueous
ammonia is included. If any ammonia evaporates
from aqueous ammonia solutions, 100 percent of the
evaporated ammonia is included in threshold
determinations.
For example, if a facility processes aqueous
ammonia, it has processed 100 percent of the
aqueous ammonia in that solution. If the ammonia
remains in solution, then 10 percent of the total
aqueous ammonia is counted towards the threshold.
If there are any evaporative losses of anhydrous
ammonia, then 100 percent of those losses must be
counted towards the processing threshold. If the
manufacturing, processing, or otherwise use
threshold for the ammonia listing is exceeded, the
facility must report 100 percent of these evaporative
losses in Sections 5 and 8 of the Form R.
B.4.d.
Threshold Determinations for
Chemical Categories
A number of chemical compound categories are
subject to reporting. See Table IIc for a listing of
these EPCRA Section 313 chemical categories.
When preparing threshold determinations for one of
these EPCRA Section 313 chemical categories, all
individual members of a category that are
manufactured, processed, or otherwise used must be
counted. Where generic names are used at a facility,
threshold determinations should be based on CAS
numbers. For example, Poly-Solv EB does not
appear among the reportable chemicals in Table IIa
or IIb but its CAS number indicates Poly-Solv EB is
a synonym for ethylene glycol mono-n-butyl ether, a
member of the certain glycol ethers chemical
category (code N230). For chemical compound
categories, threshold determinations must be made
separately for each of the three activities. Do not
include in these threshold determinations for a
category any chemicals that are also individually
listed EPCRA Section 313 chemicals (see Table IIa
or IIb). Individually listed EPCRA Section 313
chemicals are subject to their own individual
threshold determination.
Organic Compounds
For the organic compound categories, you are
required to account for the entire weight of all
compounds within a specific compound category
(e.g., glycol ethers) at the facility for BOTH the
threshold determination and release and other waste
management estimates.
Metal Category Compounds
Threshold determinations for metal category
compounds present a special case. If, for example,
your facility processes several different nickel
compounds, base your threshold determination on
the total weight of all nickel compounds processed.
However, if your facility processes both the
“parent” metal (nickel) as well as one or more
nickel compounds, you must make threshold
determinations for both nickel (CAS number 744002-0) and nickel compounds (chemical category
code N495) because they are separately listed
EPCRA Section 313 chemicals. If your facility
exceeds thresholds for both the parent metal and
compounds of that same metal, EPA allows you to
file one combined report (e.g., one report for nickel
compounds, including nickel) because the release
information you will report in connection with metal
category compounds will be the total pounds of the
metal released. If you file one combined report, you
should put the name of the metal compound
category on the Form R. In the example above, the
facility that exceeded reporting thresholds for both
the nickel and nickel compounds chemical category
could submit a single Form R for the nickel
compounds chemical category, which would contain
release and other waste management information for
both nickel and nickel compounds. Do not put both
names on the Form R.
The case of metal category compounds involving
more than one metal should be noted. Some metal
category compounds may contain more than one
listed metal. For example, lead chromate is both a
lead compound and a chromium compound. In such
cases, if applicable thresholds are exceeded, you are
required to file two separate reports, one for lead
compounds and one for chromium compounds.
Apply the total weight of the lead chromate to the
Toxics Release Inventory Reporting Forms and Instructions
26
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
threshold determinations for both lead compounds
and chromium compounds. (Note: Only the quantity
of each parent metal released or otherwise managed
as waste, not the quantity of the compound, would
be reported on the appropriate sections of both Form
Rs. See B.5.)
Nitrate
Compounds
(water
dissociable;
reportable only when in aqueous solution)
For the category nitrate compounds (water
dissociable; reportable only when in aqueous
solution), the entire weight of the nitrate compound
is counted in making threshold determinations. A
nitrate compound is covered by this listing only
when in water and only if dissociated. If no
information is available on the identity of the type
of nitrate that is manufactured, processed or
otherwise used, assume that the nitrate compound
exists as sodium nitrate.
B.4.e
Threshold Determination for
Persistent Bioaccumulative Toxic
(PBT) Chemicals
There are two separate thresholds for EPCRA
Section 313 PBT chemicals; these thresholds are set
based on the chemicals’ potential to persist and
bioaccumulate
in
the
environment.
The
manufacturing, processing and otherwise use
thresholds for PBT chemicals is 100 pounds, while
for the subset of PBTs chemicals that are highly
persistent and highly bioaccumulative, it is 10
pounds. One exception is the dioxin and dioxin-like
compounds chemical category. The threshold for
this category is 0.1 gram. The PBT chemicals, their
CAS numbers or chemical category code, and their
reporting thresholds are listed in a table in the
introductory section of B.4. See Table IIc of these
instructions for lists of individual members of the
dioxin and dioxin-like compounds chemical
category and the polycyclic aromatic compounds
(PACs) chemical category.
B.4.f.
Mixtures and Other Trade Name
Products
EPCRA Section 313 chemicals contained in
mixtures and other trade name products must be
factored into threshold determinations and release
and other waste management calculations.
year, you are required to use the best readily
available data (or reasonable estimates if such data
are not readily available) to determine whether the
toxic chemicals in a mixture meet or exceed the de
minimis concentration and, therefore, whether they
must be included in threshold determinations and
release and other waste management calculations. If
you know that a mixture or other trade name
product contains a specific EPCRA Section 313
chemical, combine the amount of the EPCRA
Section 313 chemical in the mixture or other trade
name product with other amounts of the same
EPCRA Section 313 chemical processed or
otherwise used at your facility for threshold
determinations and release and other waste
management calculations. If you know that a
mixture contains an EPCRA Section 313 chemical
but it is present below the de minimis level, you do
not have to consider the amount of the EPCRA
Section 313 chemical present in that mixture for
purposes of threshold determinations and release
and other waste management calculations. PBT
chemicals are not eligible for the de minimis
exemption except lead when it is contained in
stainless steel, brass or bronze alloy.
Observe the following guidelines in estimating
concentrations of EPCRA Section 313 chemicals in
mixtures when only limited information is available:
If you only know the upper bound
concentration, you must use it for threshold
determinations (40 CFR Section372.30(b)(ii)).
If you know the lower and upper bound
concentrations of an EPCRA Section 313
chemical in a mixture, EPA recommends you
use the midpoint of these two concentrations for
threshold determinations.
If you know only the lower bound
concentration, EPA recommends you subtract
out the percentages of any other known
components to determine a reasonable upper
bound concentration, and then determine a
midpoint.
If you have no information other than the lower
bound concentration, EPA recommends you
calculate a midpoint assuming an upper bound
concentration of 100 percent.
If your facility processed or otherwise used mixtures
or other trade name products during the calendar
Toxics Release Inventory Reporting Forms and Instructions
27
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
B.5
Release and Other Waste
Management Determinations for
Metals, Metal Category
Compounds, and Nitrate
Compounds
Metal Category Compounds
Although the complete weight of the metal category
compounds must be used in threshold
determinations for the metal compounds category,
only the weight of the metal portion of the metal
category compound must be considered for release
and other waste management determinations.
Remember that for metal category compounds that
consist of more than one metal, release and other
waste management reporting must be based on the
weight of each metal, provided that the appropriate
thresholds have been exceeded.
Metals and Metal Category Compounds
For compounds within the metal compound
categories, only the metal portion of the metal
category compound must be considered in
determining release and other waste management
quantities for the metal category compounds.
Therefore, if thresholds are separately exceeded for
both the “parent” metal and its compounds, EPA
allows you to file a combined Form R for the
“parent” metal and its category compounds. This
Form R would contain all of the release and other
waste management information for both the
“parent” metal and metal portion of the related
metal category compounds. For example, you
exceed thresholds for chromium. You also exceed
thresholds for chromium compounds. Instead of
filing two Form Rs you can file one combined Form
R. This Form R would contain information on
quantities of chromium released or otherwise
managed as waste and the quantities of the
chromium portion of the chromium compounds
released or otherwise managed as waste. When
filing one combined Form R for an EPCRA Section
313 metal and metal compound category, facilities
should identify the chemical reported as the metal
compound category name and code in Section 1 of
the Form R. Note that this does not apply to the
Form A. See Section E.7 in these instructions on the
Form A. See Appendix B for more information
about reporting the release and other waste
management of metals and metal compounds.
Nitrate
Compounds
(water
dissociable;
reportable only in aqueous solution)
Although the complete weight of the nitrate
compound must be used for threshold
determinations for the nitrate compounds category
only the nitrate portion of the compound should be
used for release and other waste management
calculations.
Toxics Release Inventory Reporting Forms and Instructions
28
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Example 9: Mixtures and Other Trade Name Products
Scenario #1: Your facility otherwise uses 12,000 pounds of an industrial solvent (Solvent X) for
equipment cleaning. The Material Safety Data Sheet (MSDS) for the solvent indicates that it contains at
least 50 percent n-hexane, an EPCRA Section 313 chemical; however, it also states that the solvent
contains 20 percent non-hazardous surfactants. This is the only n-hexane-containing mixture used at the
facility.
EPA recommends you follow these steps to determine if the quantity of the EPCRA Section 313 chemical
in Solvent X exceeds the threshold for otherwise use.
1)
Determine a reasonable maximum concentration for the EPCRA Section 313 chemical by
subtracting out the non-hazardous surfactants (i.e., 100% - 20% = 80%).
2)
Determine the midpoint between the known minimum (50%) and the reasonable maximum
calculated above (i.e., (80% + 50%)/2 = 65%).
3)
Multiply total weight of Solvent X otherwise used by 65% (0.65).
12,000 pounds × 0.65 = 7,800 pounds
4)
Because the total amount of n-hexane otherwise used at the facility was less than the 10,000-pound
otherwise use threshold, the facility is not required to file a Form R for n-hexane.
Scenario #2: Your facility otherwise used 15,000 pounds of Solvent Y to clean printed circuit boards.
The MSDS for the solvent lists only that Solvent Y contains at least 80 percent of an EPCRA Section 313
chemical that is only identified as chlorinated hydrocarbons.
EPA recommends you follow these steps to determine if the quantity of the EPCRA Section 313 chemical
in the solvent exceeds the threshold for otherwise use.
1)
Because the specific chemical is unknown, the Form R will be filed for “chlorinated hydrocarbons.”
This name will be entered into Part II, Section 2.1, “Mixture Component Identity.” (Note: Because
your supplier is claiming the EPCRA Section 313 chemical identity a trade secret, you do not have
to file substantiation forms.)
2)
The upper bound limit is assumed to be 100 percent and the lower bound limit is known to be 80
percent. Using this information, the specific concentration is estimated to be 90 percent (i.e., the
mid-point between upper and lower limits).
(100% + 80%)/2 = 90%
3)
The total weight of Solvent Y is multiplied by 90 percent (0.90) when calculating for thresholds.
15,000 × 0.90 = 13,500
4)
Because the total amount of chlorinated hydrocarbons exceeds the 10,000-pound otherwise use
threshold, you must file a Form R for this chemical.
Toxics Release Inventory Reporting Forms and Instructions
29
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Facility Name:
Date Worksheet Prepared:
EPCRA Section 313 Chemical or Chemical Category:
Prepared By:
CAS Registry Number:
Reporting Year:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
Information Source
Total Weight (lb)
Percent EPCRA Section
313 Chemical
EPCRA Section 313
Chemical Weight
by Weight
(lb)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (lb):
Manufactured
Processed
Otherwise Used
1.
2.
3.
4.
Subtotal:
(A)___________lb (B)__________lb (C)__________lb
Exempt quantity of the EPCRA Section 313 chemical or chemical category that should be excluded.
Mixture Name as Listed Above
Applicable Exemption (articles, facility,
activity)
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical Exempt from
Above (lb):
Manufactured
Processed
Otherwise Used
(A1)_____________lb
(B1)___________lb
(C1)___________lb
1.
2.
3.
4.
Subtotal:
Amount subject to threshold:
(A-A 1)_______ lb (B-B1)______ lb (C-C1)______ lb
Compare to threshold for EPCRA Section 313 reporting.
25,000 lb
25,000 lb
10,000 lb
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R or Form A; retain it for your records.
Figure 3A. EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet1
1
Note: Chemicals listed as PBT have separate thresholds (dioxin and dioxin-like compounds chemical category = 0.1 g; highly persistent, highly bioaccumulative toxic
chemicals = 10 lb; all other PBT chemicals = 100 lb). Make certain you are using the appropriate worksheet for the toxic chemical of concern.
Toxics Release Inventory Reporting Forms and Instructions
30
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Facility Name:
Date Worksheet Prepared:
EPCRA Section 313 Chemical or Chemical Category:
Prepared By:
CAS Registry Number:
Reporting Year:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
Information Source
Total Weight (lb)
Percent EPCRA Section
313 Chemical
EPCRA Section 313
Chemical Weight
by Weight
(lb)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (lb):
Manufactured
Processed
Otherwise Used
1.
2.
3.
4.
Subtotal:
(A)___________lb (B)__________lb (C)__________lb
Exempt quantity of the EPCRA Section 313 chemical or chemical category that should be excluded.
Mixture Name as Listed Above
Applicable Exemption (articles, facility,
activity) 1
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical Exempt from
Above (lb):
Manufactured
Processed
Otherwise Used
(A1)_____________lb
(B1)___________lb
(C1)___________lb
1.
2.
3.
4.
Subtotal:
Amount subject to threshold:
(A-A 1)_______ lb (B-B1)______ lb (C-C1)______ lb
Compare to threshold for EPCRA Section 313 reporting.
100 lb
100 lb
100 lb
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R or Form A; retain it for your records.
Figure 3B. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100 Pound Thresholds
1
Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
Toxics Release Inventory Reporting Forms and Instructions
31
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Facility Name:
Date Worksheet Prepared:
EPCRA Section 313 Chemical or Chemical Category:
Prepared By:
CAS Registry Number:
Reporting Year:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
Information Source
Total Weight (lb)
Percent EPCRA Section
313 Chemical
EPCRA Section 313
Chemical Weight
by Weight
(lb)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (lb):
Manufactured
Processed
Otherwise Used
1.
2.
3.
4.
Subtotal:
(A)___________lb (B)__________lb (C)__________lb
Exempt quantity of the EPCRA Section 313 chemical or chemical category that should be excluded.
Mixture Name as Listed Above
Applicable Exemption (articles, facility,
activity) 1
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical Exempt from
Above (lb):
Manufactured
Processed
Otherwise Used
(A1)_____________lb
(B1)___________lb
(C1)___________lb
1.
2.
3.
4.
Subtotal:
Amount subject to threshold:
(A-A 1)_______ lb (B-B1)______ lb (C-C1)______ lb
Compare to threshold for EPCRA Section 313 reporting.
10 lb
10 lb
10 lb
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R or Form A; retain it for your records.
Figure 3C. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10 Pound Threshold
1
Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
Toxics Release Inventory Reporting Forms and Instructions
32
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Facility Name:
Date Worksheet Prepared:
EPCRA Section 313 Chemical or Chemical Category: Dioxin and Dioxin-like Compounds
Prepared By:
CAS Registry Number:
Reporting Year:
Amounts of the EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other
Identifier
Information Source
Total Weight (g)
Percent EPCRA Section
313 Chemical
EPCRA Section 313
Chemical Weight
by Weight
(g)
Amount of the EPCRA Section 313 Chemical or
Chemical Category by Activity (g):
Manufactured
Processed
(A)___________g
(B)__________g
Otherwise Used
1.
2.
3.
4.
Subtotal:
(C)__________g
Exempt quantity of the EPCRA Section 313 chemical or chemical category that should be excluded.
Mixture Name as Listed Above
Applicable Exemption (articles, facility,
activity) 1
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical Exempt from
Above (g):
Manufactured
Processed
Otherwise Used
1.
2.
3.
4.
Subtotal:
(A1)_____________g
(B1)___________g
(C1)___________g
Amount subject to threshold:
(A-A 1)________ g (B-B1)______ g (C-C1)_______ g
Compare to threshold for EPCRA Section 313 reporting.
0.1 g
0.1 g
0.1 g
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R or Form A; retain it for your records.
Figure 3D. EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like Compounds Chemical Category
1
Note: Chemicals listed as PBT are not eligible for the de minimis exemption.
Toxics Release Inventory Reporting Forms and Instructions
33
Instructions for Completing TRI Form R
C.
Instructions for Completing
TRI Form R
The following instructions provide information on
how to enter data on a Form R (for both filers using
TRI-MEweb and trade-secret reporters using paper
forms).
TRI-MEweb collects the same facility identification
information and chemical specific information that
facilities previously submitted on the paper TRI
Form Rs. In some cases, TRI-MEweb does not
sequentially follow the Sections numerically as
listed on the Form R. As such, the TRI-MEweb
experience differs somewhat from the sequential
nature of the instructions in this document.
Facility identification information provided in Form
R Part I is entered only once per facility in TRIMEweb and is duplicated on all forms submitted,
with the exception of technical and public contact
which are collected for each form separately (See
Part I, Sections 4.3 and 4.4). For facilities that have
previously submitted TRI Forms, the facility
information remains with the facility’s profile and
needs to be updated only if facility or parent
company changes have occurred.
Chemical specific information on Form R, Part II
(including technical and public contact information)
is entered separately for each chemical reported.
Part I. Facility Identification
Information
Section 1.
Reporting Year
The reporting year is the calendar year to which the
reported information applies, not the year in which
you are submitting the report. Information for the
2014 reporting year must be submitted on or before
July 1, 2015.
Section 2.
Trade Secret Information
Trade secret submission is not supported by TRIMEweb. As such, the following sections are not to
be completed by TRI-MEweb users. These sections
reflect steps performed by trade secret filers only.
2.1
Are you claiming the EPCRA Section 313
chemical identified on Page 2 a trade
secret?
Answer this question only after you have completed
the rest of the report. The specific identity of the
EPCRA Section 313 chemical being reported in Part
II, Section 1 may be designated as a trade secret. If
you are making a trade secret claim, mark “yes” and
proceed to Section 2.2. Only check “yes” if you
manufacture, process, or otherwise use the EPCRA
Section 313 chemical whose identity is a trade
secret. (See Section A.3 of these instructions for
specific information on trade secrecy claims.) If you
checked “no,” you should submit your non-trade
secret form data electronically using TRI-MEweb.
2.2
If “yes” in 2.1, is this copy sanitized or
unsanitized?
Answer this question only after you have completed
the rest of the report. Check “sanitized” if this copy
of the report is the public version that does not
contain the EPCRA Section 313 chemical identity
but does contain a generic name that is structurally
descriptive in its place, and if you have claimed the
EPCRA Section 313 chemical identity trade secret
in Part I, Section 2.1. Otherwise, check
“unsanitized.”
Section 3.
Certification
The certification statement must be signed by a
senior official with management responsibility for
the person (or persons) completing the form. A
senior management official must certify the
accuracy and completeness of the information
reported on the form.
Electronic certification of completed forms prepared
using TRI-MEweb is performed by certifying
officials who have signed an Electronic Signature
Agreement (ESA) and TRIFID Certification
Agreement. For more information regarding
certification of forms, see Section A.2.
Section 4.
4.1
Facility Identification
Facility Name, Location, TRI Facility
Identification Number and Tribal
Country Name
Enter the full name that the facility presents to the
public and its customers in doing business (e.g., the
name that appears on invoices, signs, and other
official business documents). Do not use a nickname
for the facility (e.g., Main Street Plant) unless that is
the legal name of the facility under which it does
business. Also enter the physical street address,
Toxics Release Inventory Reporting Forms and Instructions
34
Instructions for Completing TRI Form R
mailing address, city, county, three digit BIA code,
if applicable, state, and ZIP code in the space
provided. The street address provided must be the
location where the EPCRA Section 313 chemicals
are manufactured, processed, or otherwise used.
You may not use PO Box as a facility address. If
your mailing address and street address are the
same, you should enter NA in the space for the
mailing address. If the mailing address is outside of
the US, include the FIPS country code, which may
be found in Table IV.
If your facility is not in a county, put the name of
your city, district (for example, District of
Columbia), or parish (if you are in Louisiana) in the
county block of the Form R and Form A as well as
in the county field of TRI-MEweb. “NA” or “None”
are not acceptable entries. TRI-MEweb provides a
drop-down menu for the county name, including
city districts and parish names.
If your facility is located on Indian country as
defined by 18 USC §1151 you must enter the three
digit Bureau of Indian Affairs (BIA) tribal code in
the “City/County/Tribe/State/ZIP code” field. The
BIA tribal codes are listed in Table V of the RFI.
Facilities using TRI-MEweb to complete their forms
will be asked if they are located within a tribe’s
Indian country and, upon answering “yes”, be taken
to a look-up table to determine the correct BIA
code.
If your facility is not located (overwhelming
majority of TRI facilities are not in Indian Country)
in Indian country as defined by 18 USC §1151 you
must enter only the city, county (as applicable), state
and zip code. Facilities filing a trade secret paper
form should leave a blank in the BIA field if the
facility is not located within tribal boundaries.
Facilities using TRI-MEweb to complete their forms
will be required to check a specific checkbox if they
are located within tribal lands and if they do not
check that checkbox.
Location information for a facility that has
previously submitted data to EPA.
If your facility has submitted a Form R in previous
reporting years, a TRI Facility Identification
Number (TRIFID) has already been assigned to
your facility. If you do not know your facility’s
information used in prior years submissions, contact
your Regional TRI Program representative, or
utilize Envirofacts on the Web to look up the
address, facility name, or TRIFID at:
http://www.epa.gov/enviro.
Hard copy paper Form R (trade secret submissions
only): Enter your TRIFID in Part I, Section 4.1.
TRI-MEweb: If you have previously submitted data
for your facility using TRI-MEweb, the facility
information including TRIFID remains with your
profile. If you have not submitted using TRIMEweb, then you can add your facility to your
profile using the 6-digit access key, which is emailed to all technical contacts, preparers, and
certifying officials at facilities reporting for the prior
year, or by submitting the TRIFID and technical
contact information.
Location information for a facility that has
previously submitted data to EPA, but has
changed physical location.
Hard copy paper Form R (trade secret submissions
only): If your facility has moved, do not enter your
previously assigned TRI Facility Identification
Number, enter “New Facility”. If you are filing a
separate Form R for each establishment at your
facility, you should use the same “New Facility”
field for each establishment. If you are uncertain if a
TRIFID has been assigned to your new facility
location, use Envirofacts on the Web to look up the
address or facility name at:
http://www.epa.gov/enviro.
TRI-MEweb: If your facility has moved, you will
need to request that a new TRIFID be assigned to
your facility. To request a new TRIFID, add a new
facility account to TRI-MEweb and choose to report
as a new reporting facility (option 3). TRI-MEweb
will automatically generate a new TRIFID for your
facility.
The TRIFID assigned to your new
reporting facility should be used in all future
reporting of TRI data.
Location information for a facility that has
changed ownership, but has not changed physical
location.
The TRI Facility Identification Number (TRIFID) is
established by the first Form R submitted by a
facility at a particular location. Only a change in
address warrants filing as a new facility; otherwise,
the TRI Facility Identification Number is retained
Toxics Release Inventory Reporting Forms and Instructions
35
Instructions for Completing TRI Form R
by the facility even if the facility changes name,
ownership, production processes, NAICS codes, etc.
Hard copy paper Form R (trade secret submissions
only): The TRIFID identification number will
always stay with the physical location of a facility.
If a new facility unit moves to this location it should
use this TRIFID. Establishments of a facility (for
facilities that report by part) that report separately
should use the TRIFID of the primary facility.
TRI-MEweb:
If your facility has changed
ownership during the reporting year but not its
physical location, the facility does not require a new
TRIFID. Use the TRIFID assigned to previous
owner. TRI-MEweb can be used to update facility
information due to change of ownership.
Location reporting TRI releases for the first time
to EPA.
Hard copy paper Form R (trade secret submissions
only): If you are preparing a hard copy TRI form for
the first time for your facility's location and have
never reported to TRI in previous years, you should
enter “New Facility” in the space on the hard copy
form designated for the TRI Facility Identification
number (TRIFID).
TRI-MEweb: If your facility is reporting for the
first time, upon creating your CDX account, and
adding the TRI-MEweb application, you will be
prompted to add a new facility account into TRIMEweb. TRI-MEweb will automatically generate a
new TRIFID for your facility.
The TRIFID
assigned to your new reporting facility should be
used in all future reporting of TRI data.
4.2
Full or Partial Facility Indication and
Federal Facility Designation
EPCRA Section 313 requires reports by “facilities,”
which are defined as “all buildings, equipment,
structures, and other stationary items which are
located on a single site or on contiguous or adjacent
sites and which are owned or operated by the same
person (or by any person which controls, is
controlled by, or under common control with such
person). A facility may contain more than one
establishment.”
EPCRA Section 313 defines establishment as “an
economic unit, generally at a single physical
location, where business is conducted or where
services or industrial operations are performed.”
Under Section 372.30(c) of the reporting rule, you
may submit a separate Form R for each
establishment or for groups of establishments in
your facility, provided all releases and other waste
management activities and source reduction
activities involving the EPCRA Section 313
chemical from the entire facility are reported. This
allows you the option of reporting separately on the
activities involving an EPCRA Section 313
chemical at each establishment, or group of
establishments (e.g., part of a covered facility),
rather than submitting a single Form R for that
EPCRA Section 313 chemical for the entire facility.
However, if an establishment or group of
establishments does not manufacture, process, or
otherwise use or release or otherwise manage as
waste an EPCRA Section 313 chemical, you do not
have to submit a report for that establishment or
group of establishments for that particular chemical.
(See also Section B.2.b of these instructions.)
In TRI-MEweb, facilities that wish to submit
separate Form Rs for each establishment or group of
establishments may select “Reporting by Part” with
the “Select Facility” page to set up unique
establishments within the particular facility. All
establishments reporting by part use the same
TRIFID but should provide unique facility names.
Note that facilities may not submit a Form A
Certification statement for establishments reporting
by part.
A covered facility must report all releases and other
waste management activities and source reduction
activities of an EPCRA Section 313 chemical if the
facility meets a reporting threshold for that EPCRA
Section 313 chemical. Whether submitting a report
for the entire facility or separate reports for the
establishments, the threshold determination must be
made based on the entire facility. Indicate in Section
4.2 whether your report is for the entire covered
facility as a whole or for part of a covered facility
(i.e., one or more establishments).
In TRI-MEweb, users should select the appropriate
button for: 1) federal facility (Section 4.2c), 2)
GOCO facility (Section 4.2d), or 3) neither. Federal
facilities should select only ‘federal facility’ even if
their TRI reports contain release and other waste
management information from contractors located at
the facility. Contractors at federal facilities that are
required by EPCRA Section 313 to file TRI reports
independently of the federal facility, should select
Toxics Release Inventory Reporting Forms and Instructions
36
Instructions for Completing TRI Form R
GOCO. This information is important to prevent
duplication of federal facility data. (See Appendix A
for further guidance on these instructions.)
4.3
Technical Contact
In TRI-MEweb, facilities must enter the name and
telephone number (including area code) of a
technical representative whom EPA, state, or tribal
officials may contact for clarification of the
information reported on Form R. If possible, this
number should be for the technical representative
rather than a general number for the facility. An
email address should also be entered for this person.
EPA encourages facilities to provide an email
address for the Technical Contact on their TRI
submissions because they will be able to receive
important program updates and email alerts
notifying them when their eFDP has been updated
and published for their review. If the technical
contact does not have an email address, leave the
field blank. This contact person does not have to be
the same person who prepares the report or signs the
certification statement and does not necessarily need
to be someone at the location of the reporting
facility. However, this person should be familiar
with the details of the report so that he or she can
answer questions about the information provided.
As facilities may report unique technical contacts
for each form, technical contact details are entered
in TRI-MEweb with chemical-specific data rather
than facility-identification information.
4.4
Public Contact
In TRI-MEweb, facilities must enter the name and
telephone number (including area code) of a person
who can respond to questions from the public about
the form. You should also enter an e-mail address
for this person. If the public contact does not have
an email address, leave the field blank. If you
choose to designate the same person as both the
Technical and the Public Contact, or you do not
have a Public Contact, you may enter “Same as
Section 4.3” in this space. This contact person does
not have to be the same person who prepares the
form or signs the Certification Statement and does
not necessarily need to be someone at the location
of the reporting facility. As facilities may report
unique public contacts for each form, public contact
details are entered in TRI-MEweb with chemicalspecific data rather than facility-identification
information.
4.5
North American Industry Classification
System (NAICS) Codes
Enter the appropriate six-digit North American
Industry Classification System (NAICS) Code that
is the primary NAICS Code for your facility in
Section 4.5(a). Use 2012 NAICS codes for RY 2013
and 2014 reporting and 2007 NAICS codes for RY
2006 – 2012 reporting. Enter any other applicable
NAICS for your facility in 4.5 (b)-(f), also called
“secondary NAICS codes” in TRI-MEweb. If you
do not know your NAICS code(s), consult the 2012
NAICS Manual or check the SIC to NAICS
crosswalk tables at:
http://www.census.gov.
The North American Industry Classification System
(NAICS) is the economic classification system that
replaced the 1987 SIC code system. A Federal
Register notice was published on June 6, 2006 (71
FR 32464) adopting 2007 NAICS codes for TRI
reporting. A direct final rule was published July 18,
2013 (78 FR 42875), adopting 2012 NAICS codes
for RY 2013 and subsequent years. Table I lists all
industries that are covered under EPCRA 313 and
their corresponding 2012 NAICS codes.
4.6
Dun & Bradstreet Number(s)
Enter the nine-digit number assigned by Dun &
Bradstreet (D&B) for your facility or each
establishment within your facility. These numbers
code the facility for financial purposes. This number
may be available from your facility’s treasurer or
financial officer. You can also obtain the numbers
from Dun & Bradstreet by calling 1-888-814-1435,
or by visiting this website:
https://www.dnb.com/product/dlw/form_cc4.htm. If
a facility does not subscribe to the D&B service, a
number can be obtained, toll free at 800 234-3867
(8:00 AM to 6:00 PM, EST) or on the Web at:
http://www.dnb.com. If none of your establishments
has been assigned a D&B number, you should check
“D&B Numbers Not Applicable.” If only some of
your establishments have been assigned D&B
numbers, enter those numbers in Part I, section 4.6.
Section 5.
Parent Company
Information
You must provide information on your parent
company. For TRI Reporting purposes, your parent
company is as the highest level company, located in
the United States, and that directly owns at least 50
percent of the voting stock of your company. If
Toxics Release Inventory Reporting Forms and Instructions
37
Instructions for Completing TRI Form R
there is no higher level U.S. company, select the
“No U.S. Parent Company parent (for TRI reporting
purposes)” check box. Corporate names should be
treated as parent company names for companies
with multiple facility sites. For example, the
Bestchem Corporation is not owned or controlled by
any other corporation but has sites throughout the
country whose names begin with Bestchem. In this
case, Bestchem Corporation should be listed as the
parent company. Note that a facility that is a 50:50
joint venture is its own parent company. When a
facility is owned by more than one company and
none of the facility owners directly owns at least 50
percent of its voting stock, the facility should
provide the name of the parent company of either
the facility operator or the owner with the largest
ownership interest in the facility.
5.1
Name of Parent Company
Enter the name of the corporation or other business
entity that is your highest level U.S. parent
company. If your facility has no higher level U.S.
company, select the “No U.S. Parent Company (for
TRI reporting purposes)” check box.
To improve data quality, TRI standardizes parent
company names. TRI-MEweb is preloaded with the
standardized parent company names. A full list of
parent company names for RY 2014 is available for
download at: http://www2.epa.gov/toxics-releaseinventory-tri-program/standardized-parentcompany-names-ry-2014-tri-reporting.
5.2
Parent Company’s Dun & Bradstreet
Number
Enter the D&B number for your ultimate U.S.
parent company, if applicable. The number may be
obtained from the treasurer or financial officer of
the company or by calling 1-888-814-1435, or by
visiting this website:
https://www.dnb.com/product/dlw/form_cc4.htm. If
your parent company does not have a D&B number,
you should check “Parent Company D&B Number
Not Applicable.”
Toxics Release Inventory Reporting Forms and Instructions
38
Instructions for Completing Part II of EPA Form R
Part II. Chemical Specific
Information
In Part II, you are to report on:
The EPCRA Section 313 chemical being
reported;
The general uses and activities involving the
EPCRA Section 313 chemical at your facility;
On-site releases of the EPCRA Section 313
chemical from the facility to air, water, and
land;
Quantities of the EPCRA Section 313 chemical
transferred to off-site locations;
Information for on-site and off-site disposal,
treatment, energy recovery, and recycling of the
EPCRA Section 313 chemical; and
Source reduction activities.
In TRI-MEweb, chemical specific information is
entered by initiating a blank form for a chemical or
chemical category. You may use the “Add New
Chemical Forms” search tool to look up chemical
and chemical categories by name or Chemical
Abstracts Service (CAS) number to begin a new
TRI reporting form. Alternately, you may use the
Import Data function to create and pre-populate
forms based on prior year forms submitted by the
facility. TRI-MEweb will prompt users to indicate
whether the form should be a TRI Form R or Form
A.
The TRI listed chemicals for RY 2014 are listed
both alphabetically and by CAS registry number in
Table II. Chemical categories are listed separately in
Table IIc. TRI-MEweb will not accept forms for
chemicals not listed in a particular reporting year.
For example, TRI-MEweb will not accept forms for
o-nitrotoluene prior to RY 2014 as it was first added
for RY 2014. Facilities reporting a generic name
provided by a supplier should see instructions in
Section 2.
Section 1.
1.1
EPCRA Section 313
Chemical Identity
CAS Number
Initiating a Form R for a chemical or chemical
category in TRI-MEweb automatically completes
this section.
If you are making a trade secret claim, you must
report the CAS number or category code on your
unsanitized Form R and unsanitized substantiation
form. Enter the CAS registry number exactly as it
appears in Table II of these instructions for the
chemical being reported. CAS numbers are crossreferenced with an alphabetical list of chemical
names in Table II. If you are reporting one of the
EPCRA Section 313 chemical categories (e.g.,
chromium compounds), you should enter the
applicable category code in the CAS number space.
EPCRA Section 313 chemical category codes are
listed below and can also be found in Table IIc.
Do not include the CAS number or category code on
your sanitized Form R or sanitized substantiation
form.
1.2
EPCRA Section 313 Chemical or
Chemical Category Name
Initiating a Form R for a chemical or chemical
category in TRI-MEweb automatically completes
this section.
If you are making a trade secret claim, you must
report the specific EPCRA Section 313 chemical
identity on your unsanitized Form R and unsanitized
substantiation form. Enter the name of the EPCRA
Section 313 chemical or chemical category exactly
as it appears in Table II. If the EPCRA Section 313
chemical name is followed by a synonym in
parentheses, report the chemical by the name that
directly follows the CAS number (i.e., not the
synonym). If the EPCRA Section 313 chemical
identity is actually a product trade name (e.g.,
Dicofol), the Chemical Abstracts 9th Collective
Index name is listed below it in brackets. You may
report either name in this case.
Do not list the name of a chemical that does not
appear in Table II, such as individual members of an
EPCRA Section 313 chemical category. For
example, if you use silver chloride, do not report
silver chloride with its CAS number. Report this
chemical as “silver compounds” with its category
code, N740.
Do not report the name of the EPCRA Section 313
chemical on your sanitized Form R or sanitized
substantiation form. Include a generic name that is
structurally descriptive in Part II, Section 1.3 of
your sanitized Form R report.
Toxics Release Inventory Reporting Forms and Instructions
39
Instructions for Completing Part II of EPA Form R
EPA requests that the EPCRA Section 313
chemical, chemical category, or generic name also
be placed in the box marked “Toxic Chemical,
Category, or Generic Name” in the upper right-hand
corner on all pages of Form R. While this space is
not a required data element, providing this
information will help you in preparing a complete
Form R report.
component or a maximum or average concentration
level; and
1.3
To begin a TRI Form R for a generic chemical in
TRI-MEweb, click the “create a form for a
Generic Chemical Name Provided by Supplier”
link from the “Add New Chemical Forms” search
page, then enter generic chemical name. The generic
chemical name may not be that of a listed TRI
chemical or chemical category and must be less than
70 characters in length. Facilities may also use the
Import Data tool to set up a reporting form for a
generic chemical reported in prior years.
Generic Chemical Name
Complete Section 1.3 only if you are claiming the
specific EPCRA Section 313 chemical identity of
the EPCRA Section 313 chemical as a trade secret
and have marked the trade secret block in Part I,
Section 2.1 on Page 1 of Form R. Enter a generic
chemical name that is descriptive of the chemical
structure. You should limit the generic name to 70
characters (e.g., numbers, letters, spaces,
punctuation) or less. Do not enter mixture names in
Section 1.3; see Section 2 below.
In-house plant codes and other substitute names that
are not structurally descriptive of the EPCRA
Section 313 chemical identity being withheld as a
trade secret are not acceptable as a generic name.
The generic name must appear on both sanitized and
unsanitized Form Rs, and the name must be the
same as that used on your substantiation forms.
Section 2.
Mixture Component
Identity
Complete this section only if you are reporting for
an EPCRA 313 chemical whose identity has been
withheld by the chemical supplier. You do not need
to supply trade secret substantiation forms for this
EPCRA Section 313 chemical because it is your
supplier who is claiming the chemical identity a
trade secret.
2.1
Generic Chemical Name Provided by
Supplier
Enter the generic chemical name in this section only
if the following three conditions apply:
1.) You determine that the mixture contains
an EPCRA Section 313 chemical but the only
identity you have for that chemical is a generic
name;
2.) You know either the specific
concentration of that EPCRA Section 313 chemical
3.) You multiply the concentration level by
the total annual amount of the whole mixture
processed or otherwise used and determine that you
meet the process or otherwise use threshold for that
single, generically identified mixture component.
Example 10: Mixture Containing Unidentified
EPCRA Section 313 Chemical
Your facility uses 20,000 pounds of a solvent that
your supplier has told you contains 80 percent
“chlorinated aromatic,” their generic name for a
non-PBT chemical subject to reporting under
EPCRA Section 313. You, therefore, have used
16,000 pounds of some EPCRA Section 313
chemical and that exceeds the “otherwise use”
threshold for a non-PBT chemical. You would
file a Form R and enter the name “chlorinated
aromatic” as the generic chemical name.
Section 3.
Activities and Uses of the
EPCRA Section 313
Chemical at the Facility
Indicate whether the EPCRA Section 313 chemical
is manufactured (including imported), processed, or
otherwise used at the facility and the general nature
of such activities and uses at the facility during the
calendar year (see Figure 4). You are not required to
report on Form R the quantity manufactured,
processed or otherwise used. Report activities that
take place only at your facility, not activities that
take place at other facilities involving your products.
You must check all the boxes in this section that
apply. Refer to the definitions of “manufacture,”
“process,” and “otherwise use” in Section B.3.a or
Part 40, Section 372.3 of the CFR for additional
explanations.
Toxics Release Inventory Reporting Forms and Instructions
40
Instructions for Completing Part II of EPA Form R
3.1
Manufacture the EPCRA Section 313
Chemical
a.
As a reactant — A natural or synthetic
EPCRA Section 313 chemical is used in
chemical reactions for the manufacture of
another chemical substance or of a product.
Includes but is not limited to, feedstocks, raw
materials, intermediates, and initiators.
b.
As a formulation component — An EPCRA
Section 313 chemical is added to a product (or
product mixture) prior to further distribution of
the product that acts as a performance enhancer
during use of the product. Examples of EPCRA
Section 313 chemicals used in this capacity
include, but are not limited to, additives, dyes,
reaction diluents, initiators, solvents, inhibitors,
emulsifiers, surfactants, lubricants, flame
retardants, and rheological modifiers.
c.
As an article component — An EPCRA
Section 313 chemical becomes an integral
component of an article distributed for
industrial, trade, or consumer use. One
example is the pigment components of paint
applied to a chair that is sold.
d.
Repackaging — This consists of processing or
preparation of an EPCRA Section 313
chemical (or product mixture) for distribution
in commerce in a different form, state, or
quantity. This includes, but is not limited to,
the transfer of material from a bulk container,
such as a tank truck to smaller containers such
as cans or bottles.
e.
As an impurity — The EPCRA Section 313
chemical is processed but is not separated and
remains in the mixture or other trade name
product with that/those other chemical(s).
Persons who manufacture (including import) the
EPCRA Section 313 chemical must check at least
one of the following:
a.
b.
Produce — The EPCRA Section 313
chemical is produced at the facility.
Import — The EPCRA Section 313 chemical
is imported by the facility into the Customs
Territory of the United States. (See Section
B.3.a of these instructions for further
clarification of import.)
And check at least one of the following:
c.
d.
e.
f.
For on-site use/processing — The EPCRA
Section 313 chemical is produced or imported
and then further processed or otherwise used
at the same facility. If you check this block,
generally you should also check at least one
item in Part II, Section 3.2 or 3.3.
For sale/distribution — The EPCRA Section
313 chemical is produced or imported
specifically for sale or distribution outside the
manufacturing facility.
As a byproduct — The EPCRA Section 313
chemical is produced coincidentally during
the manufacture, processing, or otherwise use
of another chemical substance or mixture and,
following its production, is separated from
that other chemical substance or mixture.
EPCRA Section 313 chemicals produced as a
result of waste management are also
considered byproducts.
As an impurity — The EPCRA Section 313
chemical is produced coincidentally as a
result of the manufacture, processing, or
otherwise use of another chemical but is not
separated and remains in the mixture or other
trade name product with that other chemical.
3.3
Persons who otherwise use the EPCRA Section 313
chemical must check at least one of the following:
a.
In summary, if you are a manufacturer of the
EPCRA Section 313 chemical, you must check (a)
and/or (b), and at least one of (c), (d), (e), and (f) in
Section 3.1.
3.2
Process the
Chemical
EPCRA
Section
313
Persons who process the EPCRA Section 313
chemical must check at least one of the following:
Otherwise Use the EPCRA Section 313
Chemical (non-incorporative activities)
As a chemical processing aid — An EPCRA
Section 313 chemical that is added to a
reaction mixture to aid in the manufacture or
synthesis of another chemical substance but is
not intended to remain in or become part of the
product or product mixture is otherwise used as
chemical processing aid. Examples of such
EPCRA Section 313 chemicals include, but are
not limited to, process solvents, catalysts,
Toxics Release Inventory Reporting Forms and Instructions
41
Instructions for Completing Part II of EPA Form R
inhibitors, initiators, reaction terminators, and
solution buffers.
b.
c.
As a manufacturing aid — An EPCRA
Section 313 chemical that aids the
manufacturing process but does not become
part of the resulting product and is not added to
the reaction mixture during the manufacture or
synthesis of another chemical substance is
otherwise used as a manufacturing aid.
Examples include, but are not limited to,
process lubricants, metalworking fluids,
coolants, refrigerants, and hydraulic fluids.
Ancillary or other use — An EPCRA Section
313 chemical that is used at a facility for
purposes other than aiding chemical processing
or manufacturing as described above is
otherwise used as an ancillary or other use.
Examples include, but are not limited to,
cleaners, degreasers, lubricants, fuels, EPCRA
Section 313 chemicals used for treating wastes,
and EPCRA Section 313 chemicals used to
treat water at the facility.
Figure 4. Reporting EPCRA Section 313 Chemicals
Toxics Release Inventory Reporting Forms and Instructions
42
Instructions for Completing Part II of EPA Form R
Section 4.
Maximum Amount of the
EPCRA Section 313 Chemical
On-site at Any Time during
the Calendar Year
For data element 4.1 of Part II, select the code (see
codes below) that indicates the maximum quantity
of the EPCRA Section 313 chemical (e.g., in storage
tanks, process vessels, on-site shipping containers,
or in wastes generated) at your facility at any time
during the calendar year. If the EPCRA Section 313
chemical was present at several locations within
your facility, use the maximum total amount present
at the entire facility at any one time. While range
reporting is not allowed for PBT chemicals
elsewhere on the Form R, range reporting for PBT
chemicals is allowed for the Maximum Amount Onsite.
Example 11: Manufacturing and Processing
Activities of EPCRA Section 313 Chemicals
In the two examples below, it is assumed that the
threshold quantities for manufacture, process, or
otherwise use (25,000 pounds, 25,000 pounds,
and 10,000 pounds, respectively for non-PBT
chemicals; 100 pounds for certain PBT
chemicals; 10 pounds for highly persistent, highly
bioaccumulative toxic chemicals; and 0.1 grams
for the PBT chemical category comprised of
dioxin and dioxin-like compounds) have been
exceeded and the reporting of EPCRA Section
313 chemicals is therefore required.
1. Your facility manufactures diazomethane. Fifty
percent is sold as a product, thus it is processed.
The remaining fifty percent is reacted with alphanaphthylamine,
forming
N-methyl-alphanaphthylamine and also producing nitrogen gas.
Your company manufactures diazomethane,
an EPCRA Section 313 chemical, both for
sale/ distribution as a commercial product
and for on-site use/processing as a feedstock
in
the
N-methyl-alpha-naphthylamine
production
process.
Because
the
diazomethane is a reactant, it is also
processed. See Figure 4 for how this
information would be reported in Part II,
Section 3 of Form R.
Your facility also processes alphanaphthylamine, as a reactant to produce Nmethyl-alpha-naphthylamine, a chemical not
on the EPCRA Section 313 list.
2. Your facility is a commercial distributor of
Missouri bituminous coal, which contains
mercury at 1.5 ppm (w:w). You should check the
box on Part II, Section 3.2.e for processing
mercury as an impurity.
Toxics Release Inventory Reporting Forms and Instructions
43
Instructions for Completing Part II of EPA Form R
Weight Range in Pounds
Range Code
01
02
03
04
05
06
07
08
09
10
11
From
0
100
1,000
10,000
100,000
1,000,000
10,000,000
50,000,000
100,000,000
500,000,000
1 billion
Section 5.
To
99
999
9,999
99,999
999,999
9,999,999
49,999,999
99,999,999
499,999,999
999,999,999
more than 1 billion
If the EPCRA Section 313 chemical present at your
facility was part of a mixture or other trade name
product, determine the maximum quantity of the
EPCRA Section 313 chemical present at the facility
by calculating the weight percent of the EPCRA
Section 313 chemical only.
Do not include the weight of the entire mixture or
other trade name product. These data may be found
in the Tier II form your facility may have prepared
under Section 312 of EPCRA. See Part 40, Section
372.30(b) of the CFR for further information on
how to calculate the weight of the EPCRA Section
313 chemical in the mixture or other trade name
product. For EPCRA Section 313 chemical
categories (e.g., nickel compounds), include all
chemical compounds in the category when
calculating the maximum amount, using the entire
weight of each compound.
Weight Range in Grams (Dioxin and Dioxin-like
Compounds)
When reporting for the dioxin and dioxin-like
compounds category use the following gram
quantity range codes:
Range Code
12
13
14
15
16
17
18
19
20
From
To
0
0.099
0.1
0.99
1.0
9.99
10
99
100
999
1,000
9,999
10,000
99,999
100,000
99,999,999
1,000,000 more than 1 million
Quantity of the Toxic
Chemical Entering Each
Environmental Medium Onsite
In Section 5, you must account for the total
aggregate on-site releases of the EPCRA Section
313 chemical to the environment from your facility
for the calendar year.
On-site releases to the environment include
emissions to the air, discharges to surface waters,
and releases to land (including underground
injection wells).
For all toxic chemicals (except the dioxin and
dioxin-like compound category), do not enter the
values in Section 5 in gallons, tons, liters, or any
measure other than pounds. You must also enter the
values as whole numbers (do not use scientific
notation). Numbers following a decimal point are
not acceptable for toxic chemicals other than those
designated as PBT chemicals. For PBT chemicals,
facilities should report release and other waste
management quantities greater than 0.1 pound
(except the dioxin and dioxin-like compounds
category), provided the accuracy and the underlying
data on which the estimate is based supports this
level of precision.
For the dioxin and dioxin-like compounds category,
facilities should report at a level of precision
supported by the accuracy of the underlying data
and the estimation techniques on which the estimate
is based. For the dioxin and dioxin like compounds
chemical category, which has a reporting threshold
of 0.1 gram, facilities need only report all release
and other waste management quantities greater than
100 micrograms (i.e., 0.0001 grams). (See Example
12) Notwithstanding the numeric precision used
when determining reporting eligibility thresholds,
facilities should report on Form R to the level of
accuracy that their data supports, up to seven digits
to the right of the decimal. EPA’s reporting software
and data management systems support data
precision up to seven digits to the right of the
decimal.
Toxics Release Inventory Reporting Forms and Instructions
44
Instructions for Completing Part II of EPA Form R
5.1
Example 12: Reporting Dioxins and DioxinLike Compounds
If the total quantity for Section 5.2 of the Form R
(i.e., stack or point air emissions) is 0.00005
grams or less, then zero can be entered. If the total
quantity is between 0.00005 and 0.0001 grams,
then 0.0001 grams can be entered or the actual
number can be entered (e.g., 0.000075).
NA vs. a Numeric Value (e.g., Zero). Generally,
NA is applicable if the waste stream that contains or
contained the EPCRA Section 313 chemical is not
directed to the relevant environmental medium, or if
leaks, spills and fugitive emissions cannot occur. If
the waste stream that contains or contained the
EPCRA Section 313 chemical is directed to the
environmental medium, or if leaks, spills or fugitive
emissions can occur, NA should not be used, even if
treatment or emission controls result in a release of
zero. If the annual aggregate release of that chemical
was equal to or less than 0.5 pound, the value
reported is zero (unless the chemical is a listed PBT
chemical).
For Section 5.1, NA generally is not applicable for
volatile organic compounds (VOCs). For Section
5.5.4, NA generally would not be applicable,
recognizing the possibility of accidental spills or
leaks of the EPCRA Section 313 chemical.
An example that illustrates the use of NA vs. a
numeric value (e.g., zero) would be nitric acid
involved in a facility’s processing activities. If the
facility neutralizes the wastes containing nitric acid
to a pH of 6 or above, then the facility reports a
release of zero for the EPCRA Section 313
chemical, not NA. Another example is when the
facility has no underground injection well, in which
case NA should be checked in Part II, Section 5.4.1
and 5.4.2 of Form R. Also, if the facility does not
landfill the acidic waste, NA should be checked in
Part II, Section 5.5.1.B of Form R.
All releases of the EPCRA Section 313 chemical to
the air must be classified as either stack or fugitive
emissions, and included in the total quantity
reported for these releases in Sections 5.1 and 5.2.
Instructions for columns A, B, and C follow the
discussions of Sections 5.1 through 5.5.
Fugitive or Non-Point Air Emissions
Report the total of all releases of the EPCRA
Section 313 chemical to the air that are not released
through stacks, vents, ducts, pipes, or any other
confined air stream. You must include (1) fugitive
equipment leaks from valves, pump seals, flanges,
compressors, sampling connections, open-ended
lines, etc.; (2) evaporative losses from surface
impoundments and spills; (3) releases from building
ventilation systems; and (4) any other fugitive or
non-point air emissions. Engineering estimates and
mass balance calculations (using purchase records,
inventories, engineering knowledge or process
specifications of the quantity of the EPCRA Section
313 chemical entering product, hazardous waste
manifests, or monitoring records) may be useful in
estimating fugitive emissions. You should check the
NA box in Section 5.1 if you do not engage in
activities that result in fugitive or non-point air
emissions of this listed toxic chemical. For VOCs,
NA generally would not be applicable.
5.2
Stack or Point Air Emissions
Report the total of all releases of the EPCRA
Section 313 chemical to the air that occur through
stacks, confined vents, ducts, pipes, or other
confined air streams. You must include storage tank
emissions. Air releases from air pollution control
equipment would generally fall in this category.
Monitoring data, engineering estimates, and mass
balance calculations may help you to complete this
section. You should check the NA box in Section
5.2 if there are no stack air activities involving the
waste stream that contains or contained the EPCRA
Section 313 chemical.
5.3
Discharges to Receiving Streams or
Water Bodies
In Section 5.3 you are to enter all the names of the
streams or water bodies to which your facility
directly discharges the EPCRA Section 313
chemical on which you are reporting. Facilities may
enter releases to as many unique receiving streams
or water bodies as needed in TRI-MEweb. In
addition, you may also enter the 14-digit reach code,
which is a unique code that identifies a continuous
piece of surface water with similar hydrologic
characteristics, assigned to each receiving water
body by the United States Geographical Society’s
(USGS) National Hydrography Dataset (NHD).
Note that reach data are not available for Alaska,
Toxics Release Inventory Reporting Forms and Instructions
45
Instructions for Completing Part II of EPA Form R
Guam, American Samoa and the Northern Mariana
Islands, 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 for
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.
In TRI-MEweb, facilities have the option of using
an interactive map interface to locate and identify
the receiving stream or water body to which the
chemical was released. TRI-MEweb will
automatically populate the appropriate reach code
field when you select your receiving water body on
the map provided in the user interface for this
section.
The name of the receiving stream or water body and
reach code may be manually entered by following
the “Can't find or identify your stream or water body
on the map?” link. In such a case, you should report
the name of the receiving stream or water body and
reach code as it appears on a discharge permit or
other appropriate documentation. If the stream is not
included in the NPDES permit or its name is not
identified in the NPDES permit, enter the name of
the off-site stream or water body by which it is
publicly known or enter the first publicly named
water body to which the receiving waters are a
tributary, if the receiving waters are unnamed. Do
not list a series of streams through which the
EPCRA Section 313 chemical flows. Be sure to
include all the receiving streams or water bodies that
receive stormwater runoff from your facility. Do not
enter names of streams to which off-site treatment
plants discharge.
You should check the NA box in Section 5.3 if there
are no discharges to receiving streams or water
bodies of the waste stream that contains or
contained the EPCRA Section 313 chemical (See
discussion of NA vs. a Numeric Value (e.g., Zero)
in the introduction of Section 5).
For each unique stream or water body, enter the
total annual amount of the EPCRA Section 313
chemical released from all discharge points at the
facility to each receiving stream or water body.
Include process outfalls such as pipes and open
trenches, releases from on-site wastewater treatment
systems, and the contribution from stormwater
runoff, if applicable (see instructions for column C
below). Do not include discharges to a POTW or
other off-site wastewater treatment facilities in this
section. These off-site transfers must be reported in
Part II, Section 6 of Form R. Wastewater analyses
and flowmeter data may provide the quantities you
will need to complete this section.
Discharges of listed acids (e.g., hydrogen fluoride,
nitric acid) may be reported as zero if the discharges
have been neutralized to pH 6 or above. If
wastewater containing a listed acid is discharged
below pH 6, then releases of the acid must be
reported. In this case, pH measurements may be
used to estimate the amount of mineral acid
released.
If you are making a trade secret claim and reporting
on hard copy, enter the receiving stream(s) and
water body or bodies in Column A. A total of three
spaces is provided on Page 2 of Form R. If you
discharge the EPCRA Section 313 chemical to more
than three streams or water bodies, you should
photocopy Page 2 of Form R as many times as
necessary and then number the boxes consecutively
for each stream or water body. At the bottom of
Page 2 you will find instructions for indicating the
total number of Page 2s that you are submitting as
part of the Form R as well as indicating the
sequence of those pages.
5.4-5.5 Disposal to Land On-site
Eight predefined subcategories for reporting
quantities released to land within the boundaries of
the facility (including underground injection) are
provided. Do not report land disposal at off-site
locations in this section. Consulting accident
histories and spill records may be useful when
preparing this section (e.g., release notification
reports required under Section 304 of EPCRA,
Section 103 of CERCLA, and accident histories
required under Section112(r)(7)(B)(ii) of the Clean
Air Act). Where relevant, you should check the NA
box in sections 5.4.1 through 5.5.3 if there are no
disposal activities for the waste stream that contains
or contained the EPCRA Section 313 chemical (See
discussion of NA vs. a Numeric Value (e.g., Zero)
in the introduction of Section 5). For 5.5.4, facilities
generally should report zero, recognizing the
potential for spills or leaks.
Toxics Release Inventory Reporting Forms and Instructions
46
Instructions for Completing Part II of EPA Form R
5.4.1 Class I Underground Injection Wells
Enter the total amount of the EPCRA Section 313
chemical that was injected into Class I wells at the
facility. Chemical analyses, injection rate meters,
and RCRA Hazardous Waste Generator Reports are
good sources for obtaining data that will be useful in
completing this section. You should check the NA
box in Section 5.4.1 if you do not inject the waste
stream that contains or contained the EPCRA
Section 313 chemical into Class I underground wells
(See discussion of NA vs. a Numeric Value (e.g.,
Zero) in the introduction of Section 5).
5.4.2 Class II-V Underground Injection Wells
Enter the total amount of the EPCRA Section 313
chemical that was injected into wells at the facility
other than Class I wells. Chemical analyses and
injection rate meters are good sources for obtaining
data that will be useful in completing this section.
You should check the NA box in Section 5.4.2 if
you do not inject the waste stream that contains or
contained the EPCRA Section 313 chemical into
Class II-V underground wells (See discussion of NA
vs. a Numeric Value (e.g., Zero) in the introduction
of Section 5).
5.5.1A RCRA Subtitle C Landfills
Enter the total amount of the EPCRA Section 313
chemical that was placed in RCRA Subtitle C
landfills. EPA has not required facilities to estimate
leaks from landfills because the amount of the
EPCRA Section 313 chemical has already been
reported as a release.
5.5.1B Other Landfills
Enter the total amount of the EPCRA Section 313
chemical that was placed in landfills other than
RCRA Subtitle C landfills. EPA has not required
facilities to estimate leaks from landfills because the
amount of the EPCRA Section 313 chemical has
already been reported as a release.
5.5.2 Land Treatment/Application Farming
Land treatment is a disposal method in which a
waste containing an EPCRA Section 313 chemical
is applied onto or incorporated into soil. While this
disposal method is considered a release to land, any
volatilization of EPCRA Section 313 chemicals into
the air occurring during the disposal operation must
not be included in this section but must be included
in the total fugitive air releases reported in Part II,
Section 5.1 of Form R.
5.5.3 Surface Impoundments
A surface impoundment is a natural topographic
depression, man-made excavation, or diked area
formed primarily of earthen materials (although
some may be lined with man-made materials), that
is designed to hold an accumulation of liquid wastes
or wastes containing free liquids. Examples of
surface impoundments are holding, settling, storage,
and elevation pits; ponds, and lagoons. If the pit,
pond, or lagoon is intended for storage or holding
without discharge, it would be considered to be a
surface impoundment used as a final disposal
method. A facility must determine, to the best of its
ability, the percentage of a volatile chemical, e.g.,
benzene, that is in waste sent to a surface
impoundment that evaporates during the reporting
year. The facility must report this as a fugitive air
emission in section 5.1. The balance should be
reported in either section 5.5.3A or 5.5.3B.
Quantities of the EPCRA Section 313 chemical
released to surface impoundments that are used
merely as part of a wastewater treatment process
generally should not be reported in this section.
However, if an impoundment accumulates sludges
containing the EPCRA Section 313 chemical, you
must include an estimate in this section unless the
sludges are removed and otherwise disposed of (in
which case they must be reported under the
appropriate section of the form). For the purposes of
this reporting, storage tanks are not considered to be
a type of disposal and are not to be reported in this
section of Form R.
5.5.3A RCRA Subtitle C Surface Impoundments
Enter the total amount of the EPCRA Section 313
chemical that was placed in RCRA Subtitle C
surface impoundments.
5.5.3B Other Surface Impoundments
Enter the total amount of the EPCRA Section 313
chemical that was placed in surface impoundments
other than RCRA Subtitle C surface impoundments.
5.5.4 Other Disposal
Includes any amount of an EPCRA Section 313
chemical released to land that does not fit the
categories of landfills, land treatment, or surface
impoundment. This other disposal would include
any spills or leaks of EPCRA Section 313 chemicals
to land. For example, 2,000 pounds of benzene leaks
from an underground pipeline into the land at a
facility. Because the pipe was only a few feet from
the surface at the erupt point, 30 percent of the
Toxics Release Inventory Reporting Forms and Instructions
47
Instructions for Completing Part II of EPA Form R
benzene evaporates into the air. The 600 pounds
released to the air would be reported as a fugitive air
release (Part II, Section 5.1) and the remaining
1,400 pounds would be reported as a release to land,
other disposal (Part II, Section 5.5.4).
0.5-pound release determination does not apply to
just a single article. It applies to the cumulative
releases from the processing or otherwise use of the
same type of article (e.g., sheet metal or plastic film)
that occurs over the course of the reporting year.
Section 5 Column A: Total Release
If you enter a range code in column A, some TRI
data tools used by the public will display the
midpoint of the range (i.e., 5, 250, or 750 lb).
Only on-site releases of the EPCRA Section 313
chemical to the environment for the calendar year
are to be reported in this section of Form R. The
total on-site releases from your facility do not
include transfers or shipments of the EPCRA
Section 313 chemical from your facility for sale or
distribution in commerce, or of wastes to other
facilities for disposal, treatment, energy recovery, or
recycling (see Part II, Section 6 of these
Instructions). Both routine releases, such as fugitive
air emissions, and accidental or non-routine
releases, such as chemical spills, must be included
in your estimate of the quantity released.
Releases of Less Than 1,000 Pounds. For total
annual releases or off-site transfers of an EPCRA
Section 313 chemical from the facility of less than
1,000 pounds, the amount may be reported either as
an estimate or by using the range codes that have
been developed (range reporting in section 5 does
not apply to PBT chemicals). Do not enter a range
code and an estimate in the same box in column A.
The reporting range codes to be used are:
Code
A
B
C
Range (pounds)
1-10
11-499
500-999
Total annual on-site releases of an EPCRA Section
313 chemical from the facility of less than 1 pound
may be reported in one of several ways. You should
round the value to the nearest pound. If the estimate
is greater than 0.5 pound, you should either enter the
range code “A” for “1-10” or enter “1” in column A.
If the release is equal to or less than 0.5 pounds, you
may round to zero and enter “0” in column A.
Note that total annual releases of 0.5 pound or less
from the processing or otherwise use of an article
maintain the article status of that item. Thus, if the
only releases you have are from processing an
article, and such releases are equal to or less than
0.5 pound per year, you are not required to submit a
report for that EPCRA Section 313 chemical. The
Releases of 1,000 Pounds or More. For releases to
any medium that amount to 1,000 pounds or more
for the year, you must provide an estimate in pounds
per year in column A.
Data Precision. Generally, estimates provided need
not be reported to more than two significant figures.
This estimate should be in whole numbers.
However, facilities should report releases and other
waste management amounts at a level of precision
supported by the accuracy of the underlying data
and the estimation techniques on which the estimate
is based. If a facility’s release or other management
calculations support reporting an amount that is
more precise than two significant digits, then the
facility should report that more precise amount.
Calculating On-Site Releases. To provide the
release information in column A, EPCRA Section
313(g) (2) requires a facility to use readily available
data (including monitoring data) collected pursuant
to other provisions of law, or, where such data are
not readily available, “reasonable estimates” of the
amounts involved. If available data (including
monitoring data) are known to be nonrepresentative, facilities must make reasonable
estimates using the best readily available
information.
Reasonable estimates of the amounts released
should be made using published emission factors,
material balance calculations, or engineering
calculations. You may not use emission factors or
calculations to estimate releases if more accurate
data are available.
No additional monitoring or measurement of the
quantities or concentrations of any EPCRA Section
313 chemical released into the environment, or of
the frequency of such releases, beyond that required
under other provisions of law or regulation or as part
of routine plant operations, is required for the
purpose of completing Form R.
Toxics Release Inventory Reporting Forms and Instructions
48
Instructions for Completing Part II of EPA Form R
You must estimate the quantity (in pounds) of the
EPCRA Section 313 chemical or chemical category
that is released annually to each environmental
medium on-site. Include only the quantity of the
EPCRA Section 313 chemical in this estimate. If the
EPCRA Section 313 chemical present at your
facility was part of a mixture or other trade name
product, calculate only the releases of the EPCRA
Section 313 chemical, not the other components of
the mixture or other trade name product. If you are
only able to estimate the releases of the mixture or
other trade name product as a whole, you should
assume that the release of the EPCRA Section 313
chemical is proportional to its concentration in the
mixture or other trade name product. See Part 40,
Section 372.30(b) of the CFR for further
information on how to calculate the concentration
and weight of the EPCRA Section 313 chemical in
the mixture or other trade name product.
exclude any contribution to mass made by the other
portion of the compound.
Section 5 Column B: Basis of Estimate
For each release and otherwise managed waste
estimate (Sections 5 & 6), you are required to
indicate the principal method used to determine the
amount of release and otherwise managed waste
reported. You should enter a letter code identifying
the method that applies to the largest portion of the
total estimated release and otherwise managed waste
quantity.
The codes are as follows:
M1
M2
If you are reporting an EPCRA Section 313
chemical category listed in Table II of these
instructions rather than a specific EPCRA Section
313 chemical, you must combine the release data for
all chemicals in the EPCRA Section 313 chemical
category (e.g., all listed members of certain glycol
ethers or all listed members of chlorophenols) and
report the aggregate amount for that EPCRA Section
313 chemical in that category separately. For
example, if your facility releases 3,000 pounds per
year of 2-chlorophenol, 4,000 pounds per year of 3chlorophenol, and 4,000 pounds per year of 4chlorophenol to air as fugitive emissions, you must
report that your facility releases 11,000 pounds per
year of chlorophenols to air as fugitive emissions in
Part II, Section 5.1.
For aqueous ammonia solutions, releases must be
reported based on 10 percent of total aqueous
ammonia. Ammonia evaporating from aqueous
ammonia solutions is considered to be anhydrous
ammonia; therefore, 100 percent of the anhydrous
ammonia should be reported if it is released to the
environment.
For dissociable nitrate compounds, release estimates
should be based on the weight of the nitrate only.
For metal category compounds (e.g., chromium
compounds), report releases of only the parent
metal. For example, a user of various inorganic
chromium salts would report the total chromium
released regardless of the chemical compound and
C
E1
E2
O
Estimate is based on continuous monitoring
data or measurements for the EPCRA Section
313 chemical.
Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA Section 313 chemical.
Estimate is based on mass balance
calculations, such as calculation of the amount
of the EPCRA Section 313 chemical in
streams entering and leaving process
equipment.
Estimate is based on published emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
Estimate is based on-site specific emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment
was fully identified through monitoring data.
For example, if 40 percent of stack emissions of the
reported EPCRA Section 313 chemical were derived
using source testing data, 30 percent by mass
balance, and 30 percent by published chemicalspecific emission factors, you should enter the code
letter “M2” for periodic or random emission
monitoring.
If the monitoring data, mass balance, or emission
factor used to estimate the release is not specific to
Toxics Release Inventory Reporting Forms and Instructions
49
Instructions for Completing Part II of EPA Form R
the EPCRA Section 313 chemical being reported,
the form should identify the estimate based on other
methods of estimation (O).
If a mass balance calculation yields the flow rate of
a waste, but the quantity of reported EPCRA Section
313 chemical in the waste is based on solubility
data, you should report “O” because engineering
calculations were used as the basis of estimate of the
quantity of the EPCRA Section 313 chemical in the
waste.
If the concentration of the EPCRA Section 313
chemical in the waste was measured by continuous
emissions monitoring equipment and the flow rate
of the waste was determined by mass balance, then
the primary basis of the estimate should be
“continuous emission monitoring” (M1). Even
though a mass balance calculation also contributed
to the estimate, “continuous emission monitoring”
should be indicated because monitoring data were
used to estimate the concentration of the chemical in
waste.
Mass balance (C) should only be indicated if it is
directly used to calculate the mass (weight) of
EPCRA Section 313 chemical released. Monitoring
data should be indicated as the basis of estimate
only if the EPCRA Section 313 chemical
concentration is measured in the waste. Monitoring
data should not be indicated, for example, if the
monitoring data relate to a concentration of the
EPCRA Section 313 chemical in other process
streams within the facility.
It is important to realize that the accuracy and
proficiency of release estimation will improve over
time. However, submitters are not required to use
new emission factors or estimation techniques to
revise previous Form R submissions.
Section 5 Column C: Percent from Stormwater
has monitoring data on the amount of the EPCRA
Section 313 chemical in stormwater runoff
(including unchanneled runoff), you must include
that quantity of the EPCRA Section 313 chemical in
your water release in column A and indicate the
percentage of the total quantity (by weight) of the
EPCRA Section 313 chemical contributed by
stormwater in column C (Section 5.3C).
If your facility has monitoring data on the EPCRA
Section 313 chemical and an estimate of flow rate,
you must use these data to determine the percent
stormwater.
If you have monitored stormwater but did not detect
the EPCRA Section 313 chemical, enter zero in
column C. If your facility has no stormwater
monitoring data for the chemical, you should check
the NA box.
If your facility does not have periodic measurements
of stormwater releases of the EPCRA Section 313
chemical, but has submitted chemical-specific
monitoring data in permit applications, then these
data must be used to calculate the percent
contribution from stormwater. One way to calculate
the flow rates from stormwater runoff is the
Rational Method. In this method, flow rates, Q, can
be estimated by multiplying the land area of the
facility, A, by the runoff coefficient, C, and then
multiplying that figure by the annual rainfall
intensity, I (i.e., Q = A × C × I). The rainfall
intensity, I, is specific to the geographical area of
the country where the facility is located, and may be
obtained from most standard engineering manuals
for hydrology. The flow rate, Q, will have
volumetric dimensions per unit time, and will have
to be converted to units of pounds per year. The
runoff coefficient represents the fraction of rainfall
that does not seep into the ground but runs off as
stormwater. The runoff coefficient is directly related
to how the land in the drainage area is used. (See
table on the next page)
This column relates only to Section 5.3 - discharges
to receiving streams or water bodies. If your facility
Toxics Release Inventory Reporting Forms and Instructions
50
Instructions for Completing Part II of EPA Form R
Description of Land Area
Business
Downtown areas
Neighborhood areas
Industrial
Light areas
Heavy areas
Industrial
Railroad yard areas
Unimproved areas
Streets
Asphaltic
Concrete
Runoff Coefficient
Description of Land Area
0.70-0.95
0.50-0.70
0.50-0.80
0.60-0.90
0.20-0.40
0.10-0.30
0.70-0.95
0.80-0.95
Runoff Coefficient
Brick
Drives and walks
Roofs
Lawns: Sandy Soil
Flat, 2 percent
Average, 2 - 7 percent
Steep, 7 percent
Lawns: Heavy Soil
Flat, 2 percent
Average, 2 - 7 percent
Steep, 7 percent
0.70-0.85
0.70-0.85
0.75-0.95
0.05-0.10
0.10-0.15
0.15-0.20
0.13-0.17
0.18-0.22
0.25-0.35
You should choose the most appropriate runoff coefficient for your site or calculate a weighted-average
coefficient, which takes into account different types of land use at your facility:
Weighted-average runoff coefficient =
(Area 1 % of total)(C1) + (Area 2 % of total)(C2) + (Area 3 % of total)(C3) + ... + (Area i % of total)(Ci)
where
Ci =
runoff coefficient for a specific land use of Area i.
Toxics Release Inventory Reporting Forms and Instructions
51
Instructions for Completing Part II of EPA Form R
Example 13: Stormwater Runoff
Your facility is located in a semi-arid region of the United States that has an annual precipitation
(including snowfall) of 12 inches of rain. (Snowfall should be converted to the equivalent inches of rain;
assume one foot of snow is equivalent to one inch of rain.) The total area covered by your facility is 42
acres (about 170,000 square meters or 1,829,520 square feet). The area of your facility is 50 percent
unimproved area, 10 percent asphaltic streets, and 40 percent concrete pavement.
The total stormwater runoff from your facility is therefore calculated as follows:
Land Use
Unimproved area
Asphaltic streets
Concrete pavement
% Total Area
50
10
40
Runoff
Coefficient
0.20
0.85
0.90
Weighted-average runoff coefficient = [(50%) × (0.20)] + [(10%) × (0.85)] × [(40%) x (0.90)] = 0.545
(Rainfall) × (land area) × (conversion factor) × (runoff coefficient) = stormwater runoff
(1 ft/year) × (1,829,520 ft2) × (7.48 gal/ft3) × (0.545) = 7,458,222 gallons/year
Total stormwater runoff = 7,458,222 gallons/year
Your stormwater monitoring data shows that the average concentration of zinc in the stormwater runoff
from your facility from a biocide containing a zinc compound is 1.4 milligrams per liter. The total amount
of zinc discharged to surface water through the plant wastewater discharge (non-stormwater) is 250
pounds per year. The total amount of zinc discharged with stormwater is:
(7,458,222 gallons stormwater) × (3.785 liters/gallon) = 28,229,370 liters stormwater
(28,229,370 liters stormwater) × (1.4 mg zinc/liter) × 103 g/mg × (1/454) lb/g = 87 lb zinc.
The total amount of zinc discharged from all sources of your facility is:
250 pounds zinc from wastewater discharged
+87 pounds zinc from stormwater runoff
337 pounds zinc total water discharged
The percentage of zinc discharge through stormwater reported in section 5.3 column C on Form R is:
(87/337) × 100% = 26%
Section 6.
Transfer(s) of the Toxic
Chemical in Wastes to OffSite Locations
You must report in this section the total annual
quantity of the EPCRA Section 313 chemical in
wastes sent to any off-site facility for the purposes
of disposal, treatment, energy recovery, or
recycling. Report the total amount of the EPCRA
Section 313 chemical transferred off-site after any
on-site waste treatment, recycling, or removal is
completed.
For all toxic chemicals (except the dioxin and
dioxin-like compounds category), do not enter the
values in Section 6 in gallons, tons, liters, or any
measure other than pounds. You must also enter the
values as whole numbers. Numbers following a
decimal point are not acceptable for toxic chemicals
other than those designated as PBT chemicals. For
PBT chemicals, facilities should report release and
other waste management quantities greater than 0.1
pound (except the dioxin and dioxin-like
compounds category) provided the accuracy and the
underlying data on which the estimate is based
supports this level of precision.
Dioxin and dioxin-like compounds category.
Facilities should report at a level of precision
supported by the accuracy of the underlying data
Toxics Release Inventory Reporting Forms and Instructions
52
Instructions for Completing Part II of EPA Form R
and the estimation techniques on which the estimate
is based. Notwithstanding the numeric precision
used when determining reporting eligibility
thresholds, facilities should report on Form R to the
level of accuracy that their data supports, up to
seven digits to the right of the decimal. TRI-MEweb
and EPA’s data management systems support data
precision to seven digits to the right of the decimal.
The smallest quantity that needs to be reported on
the Form R for the dioxin and dioxin-like
compounds category is 0.0001 grams (see Example
12).
NA vs. a Numeric Value (e.g., Zero). You must
enter a numeric value if you transfer an EPCRA
Section 313 chemical to a Publicly Owned
Treatment Works (POTW) or transfer wastes
containing that toxic chemical to other off-site
locations. If the aggregate amount transferred was
less than 0.5 pound, then you should enter zero
(unless the chemical is listed as a PBT chemical).
Also report zero for transfers of listed mineral acids
(i.e., hydrogen fluoride and nitric acid) if they have
been neutralized to a pH of 6 or above prior to
discharge to a POTW; do not check NA.
However, if you do not discharge wastewater
containing the reported EPCRA Section 313
chemical to a POTW, you should check the “Not
Applicable” box in Section 6.1. If you do not ship or
transfer wastes containing the reported EPCRA
Section 313 chemical to other off-site locations, you
should check the “Not Applicable” box in Section
6.2. In TRI-MEweb, users may enter as many
unique transfers as needed.
Instructions for Reporters Claiming Trade
Secret: Number the boxes for reporting the
information for each sequential POTW or other offsite location in Sections 6.1 and 6.2. In the upper
left hand corner of each box, the section number is
either 6.1.[ ]._.or 6.2.[ ]. This section is required
only for paper filers (trade secret submissions only);
TRI-MEweb does this task automatically for the
reporting facility.
If you report a transfer of the listed EPCRA Section
313 chemical to one or more off-site locations,
POTWs, you should number the boxes in Section
6.1 as 6.1.1, 6.1.2, etc. If you transfer the EPCRA
Section 313 chemical to more than one POTW, you
should photocopy Page 3 of Form R as many times
as necessary and then number the boxes
consecutively for each POTW (e.g., 6.1.2, 6.1.3,
etc.). At the bottom of each page 3 that is submitted,
indicate the total number of pages numbered “3”
that you are submitting as part of Form R, as well as
indicating the sequence of those pages. For
example, your facility transfers the reported EPCRA
Section 313 chemical in wastewaters to two
POTWs. You would photocopy Page 3 once,
indicate at the bottom of each Page 3 that there are a
total of two pages numbered “3” and then indicate
the first and second Page 3. The box for the first
POTW on the first Page 3 should be numbered 6.1.1
and while the box for second POTW on the second
Page 3 should be numbered 6.1.2.
If you report a transfer of the EPCRA Section 313
chemical to one or more other off-site locations, you
should number the boxes in section 6.2 as 6.2.1,
6.2.2, etc. If you transfer the EPCRA Section 313
chemical to more than two other off-site locations,
you should photocopy Page 4 of Form R as many
times as necessary and then number the boxes
consecutively for each off-site location. At the
bottom of Page 4 you will find instructions for
indicating the total number of Page 4s that you are
submitting as part of the Form R as well as
indicating the sequence of those pages. For
example, your facility transfers the reported EPCRA
Section 313 chemical to three other off-site
locations. You should photocopy page 4 once,
indicate at the bottom of Section 6.2 on each Page 4
that there are a total of two Page 4s and then
indicate the first and second Page 4. The boxes for
the two off-site locations on the first Page 4 would
be numbered 6.2.1 and 6.2.2, while the box for the
third off-site location on the second Page 4 should
be numbered 6.2.3. Please note that section 6.2
starts on Page 3 and continues on Page 4.
6.1
Discharges to Publicly Owned Treatment
Works
In Section 6.1, facilities using TRI-MEweb can
click “Add New POTW” to use a search tool to
search POTWs by location or NPDES ID. If the
receiving POTW cannot be identified using the
search, the user may enter the POTW information
manually by clicking “Enter New POTW,” and
then provide the receiving POTWs’ name and
address.
Facilities should report for each POTW to which the
facility discharges or otherwise transfers wastewater
containing the reported EPCRA Section 313
chemical. The most common transfers of this type
Toxics Release Inventory Reporting Forms and Instructions
53
Instructions for Completing Part II of EPA Form R
will be conveyances of the toxic chemical in facility
wastewater through underground sewage pipes;
however, materials may also be trucked or
transferred via some other direct methods to a
POTW.
codes that applies to the method by which the
largest percentage of the estimate was derived.
Facilities report the total quantity transferred to each
POTW and the basis of estimate for the total
quantity reported in Section 6.1.[ ]A or Section
6.1.[ ]B (for columns A and B, respectively).
M2
When you enter quantities in Section 6.1 in TRIMEweb, you will be prompted for information on
the final disposition of the off-site transfer for use in
Section 8 calculations (see instructions for Section
8). Removal and destruction rates for toxic
chemicals sent to POTW (based on experimental
and estimated data compiled by EPA) are preloaded into TRI-MEweb for this purpose but may be
overridden if you have better information on the
final disposition of the chemical readily available.
If you do not discharge wastewater containing the
reported EPCRA Section 313 chemical to a POTW,
enter NA in the box in Section 6.1. (See discussion
of NA vs. a Numeric Value (e.g., Zero) in the
introduction of Section 6).
6.1.[ ]A. Quantity Transferred to Each POTW
Enter the total amount, in pounds, of the reported
EPCRA Section 313 chemical that is contained in
the wastewaters transferred to each POTW. Do not
enter the total poundage of the wastewaters. If the
total amount transferred is less than 1,000 pounds,
you may report a range by entering the appropriate
range code (range reporting in section 6.1.[ ]_A.
does not apply to PBT chemicals). The following
reporting range codes are to be used:
M1
C
E1
E2
O
If you estimate the total quantities transferred of an
EPCRA Section 313 chemical for one POTW using
more than one calculation method, you should
report the basis of estimate that was used to
determine the largest percentage of the EPCRA
Section 313 chemical that was transferred.
6.2
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999
If you enter a range code in column A, some TRI
data tools used by the public will display the
midpoint of the range (i.e., 5, 250, or 750 lb).
6.1.[ ]B
Basis of Estimate
You must identify the basis for your estimate of the
total quantity of the reported EPCRA Section 313
chemical in the wastewater transferred to each
POTW. You should enter one of the following letter
Estimate is based on continuous monitoring
data or measurements for the EPCRA Section
313 chemical.
Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA Section 313 chemical.
Estimate is based on mass balance
calculations, such as calculation of the amount
of the EPCRA Section 313 chemical in
streams entering and leaving process
equipment.
Estimate is based on published emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
Estimate is based on-site specific emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment
was fully identified through monitoring data.
Transfers to Other Off-Site Locations
In Section 6.2, facilities using TRI-MEweb can
click “New Location” to access a form to search
off-site transfer locations by location or RCRA ID.
to which the facility ships or transfers wastes
containing the reported EPCRA Section 313
chemical for the purposes of disposal, treatment,
energy recovery, or recycling. If the receiving other
off-site location cannot be identified using the
search, the user may enter the off-site location
information clicking “Enter New Location,” and
then indicating the receiving other off-site locations’
name and address. Reporters must also indicate if
the receiving location is under the control of the
reporting facility or parent company.
Toxics Release Inventory Reporting Forms and Instructions
54
Instructions for Completing Part II of EPA Form R
In general, a RCRA ID Number (also called an EPA
Identification Number) will commonly be found on
the Uniform Hazardous Waste Manifest, which is
required by RCRA regulations for the transfer of
hazardous wastes. However, please note that an offsite transfer of a non-hazardous waste containing a
TRI chemical may be received by a facility with a
RCRA ID. If the receiving facility’s RCRA ID is
known, even if it is not associated with the waste
transfer that you are initiating, it should be provided
in Section 6.2. The purpose of the RCRA ID
number is for the identification of the off-site
transfer facility and not just to indicate a hazardous
waste transfer. If you ship or transfer wastes
containing an EPCRA Section 313 chemical and the
off-site location does not have an EPA Identification
Number, enter NA in the box for the off-site
location EPA Identification Number.
Specifically for other off-site transfers, facilities
must also report the type of disposal, treatment,
energy recovery, or recycling methods used by the
off-site location for the reported EPCRA Section
313 chemical (see Section 6.2 Column C). If
appropriate, you must report multiple activities for
each off-site location. For example, if your facility
sends a reported EPCRA Section 313 chemical in a
single waste stream to an off-site location where
some of the EPCRA Section 313 chemical is to be
recycled while the remainder of the quantity
transferred is to be treated, you must report both the
waste treatment and recycle activities, along with
the quantity associated with each activity.
If your facility transfers an EPCRA Section 313
chemical to an off-site location and that off-site
location performs more than four activities on that
chemical, multiple transfers may be listed by
clicking “+ Add Transfer.”
If you do not ship or transfer wastes containing the
EPCRA Section 313 chemical to other off-site
locations, you should check the Not Applicable box
in Section 6.2, “Transfers to Other Off-Site
Locations.”
If you ship or transfer the reported EPCRA Section
313 chemical in wastes to another country, you do
not need to report a RCRA ID for that waste. You
should check “Not Applicable” for the RCRA ID
field. Enter the location information for the nonU.S. facility including: location name, address, city,
province, country, and postal code. TRI-MEweb
provides a dropdown for selecting countries and
their Federal Information Processing Standards
(FIPS) codes. The most commonly used FIPS
country codes are listed in Table IV. To obtain a
FIPS code for a country not listed, contact the TRI
Information Center. There is nothing to enter in the
state field.
6.2a
Column A: Total Transfers
For each off-site location, enter the total amount, in
pounds (in grams for dioxin and dioxin-like
compounds), of the EPCRA Section 313 chemical
that is contained in the waste transferred to that
location. Do not enter the total quantities of the
waste. If you do not ship or transfer wastes
containing the EPCRA Section 313 chemical to
other off-site locations, you should enter NA (See
discussion of NA vs. a Numeric Value (e.g., Zero)
in the introduction of Section 6) in the box for the
off-site location’s EPA Identification Number
(defined in 40 CFR 260.10 and therefore commonly
referred to as the RCRA ID Number).
If the total amount transferred is less than 1,000
pounds, you may report a range by entering the
appropriate range code (range reporting in section
6.2 does not apply to PBT chemicals). The
following reporting range codes are to be used:
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999
Note that if you enter a range code in column A,
some TRI data tools used by the public will display
the midpoint of the range (i.e., 5, 250, or 750 lb).
Toxics Release Inventory Reporting Forms and Instructions
55
Instructions for Completing Part II of EPA Form R
Unloading
Method
Pumping
Pumping
Pouring
Pouring
Gravity
Drain
Gravity
Drain
Gravity
Drain
Summary of Residue Quantities From Pilot-Scale Experimental Studya,b
(weight percent of drum capacity)
Material
Vessel Type Value
Surfactant
Kerosenec
Waterd
Motor Oile
Solutionf
Range
1.93 - 3.08
1.84 - 2.61
1.97 - 2.23
3.06
Steel drum
Mean
2.48
2.29
2.06
3.06
Range
1.69
4.08
2.54
4.67
1.70
3.48
Not
Plastic drum
Mean
2.61
3.28
2.30
Available
Bung-top
Range
0.244 - 0.472 0.266 - 0.458 0.677 - 0.787 0.485
steel drum
Mean
0.404
0.403
0.737
0.485
Open-top
Range
0.032 - 0.080 0.026 - 0.039 0.328 - 0.368 0.089
steel drum
Mean
0.054
0.034
0.350
0.089
Slope-bottom Range
0.020 - 0.039 0.016 - 0.024 0.100 - 0.121 0.048
steel tank
Mean
0.033
0.019
0.111
0.048
Dish-bottom Range
0.031 - 0.042 0.033 - 0.034 0.133 - 0.191 0.058
steel tank
Mean
0.038
0.034
0.161
0.058
Dish-bottom Range
0.024 - 0.049 0.020 - 0.040 0.112 - 0.134 0.040
glass-lined
Mean
0.040
0.033
0.127
0.040
tank
a
From “Releases During Cleaning of Equipment.” Prepared by PEI Associates, Inc., for the U.S. Environmental Protection Agency,
Office of Pesticides and Toxic Substances, Washington DC, Contract No. 68-02-4248. June 30, 1986.
b
The values listed in this table should only be applied to similar vessel types, unloading methods, and bulk fluid materials. At
viscosities greater than 200 centipoise, the residue quantities can rise dramatically and the information on this table is not applicable.
c
For kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
d
For water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
e
For motor oil, viscosity = 94 centipoise, surface tension = 34.5 dynes/cm2
f
For surfactant solution, viscosity = 3 centipoise, surface tension = 31.4 dynes/cm2
Toxics Release Inventory Reporting Forms and Instructions
56
Instructions for Completing Part II of EPA Form R
Example 14: Container Residue
You have determined that a Form R for an EPCRA Section 313 chemical must be submitted. The facility
purchases and uses one thousand 55-gallon steel drums that contain a 10 percent solution of the chemical.
Further, it is assumed that the physical properties of the solution are similar to water. The solution is
pumped from the drums directly into a mixing vessel and the “empty” drums are triple-rinsed with water.
The rinse water is indirectly discharged to a POTW and the cleaned drums are sent to a drum reclaimer.
In this example, it can be assumed that all of the residual solution in the drums was transferred to the rinse
water. Therefore, the quantity transferred to the drum reclaimer should be reported as “zero.” The annual
quantity of residual solution that is transferred to the rinse water can be estimated by multiplying the
mean weight percent of residual solution remaining in water from pumping a steel drum (2.29 percent
from the preceding table, “Summary of Residue Quantities From Pilot-Scale Experimental Study”) by the
total annual weight of solution in the drum (density of solution multiplied by drum volume). If the density
is not known, it may be appropriate to use the density of water (8.34 pounds per gallon):
(2.29%) × (8.34 pounds/gallon) × (55 gallons/drum) × (1,000 drums) = 10,504 pounds solution
The concentration of the EPCRA Section 313 chemical in the solution is only 10%.
(10,504 pounds solution) × (10%) = 1,050 pounds
Therefore, 1,050 pounds of the chemical are transferred to the POTW.
Example 15: Reporting Metals and Metal Category Compounds that are sent Off-site
A facility manufactures a product containing elemental copper, exceeding the processing threshold for
copper. Various metal fabrication operations for the process produce a wastewater stream that contains
some residual copper and off-specification copper material. The wastewater is collected and sent directly
to a POTW. Periodic monitoring data show that 500 pounds of copper were transferred to the POTW in
the reporting year. The POTW eventually releases these chemicals to a stream. The off-specification
products (containing copper) are collected and sent off-site to a RCRA Subtitle C landfill. Sampling
analyses of the product combined with hazardous waste manifests were used to determine that 1,200
pounds of copper in the off-spec product were sent to the off-site landfill.
Therefore, the facility must report 500 pounds in Sections 6.1 and 8.1d, and 1200 pounds in Sections 6.2
(waste code M65 (RCRA Subtitle C Landfill) should be used) and 8.1d.
Note that for EPCRA Section 313 chemicals that are not metals or metal category compounds, the
quantity sent for treatment at POTWs and to other off-site treatment locations must be reported in Section
8.7 - Quantity Treated Off-site. However, if you know that some or all of the chemical is not treated for
destruction at the off-site location you must report that quantity in Section 8.1.
Toxics Release Inventory Reporting Forms and Instructions
57
Instructions for Completing Part II of EPA Form R
If you transfer the EPCRA Section 313 chemical in
wastes to an off-site facility for distinct and multiple
purposes, you must report those activities for each
off-site location, along with the quantity of the
reported EPCRA Section 313 chemical associated
with each activity. For example, your facility
transfers a total of 15,000 pounds of toluene to an
off-site location that will use 5,000 pounds for the
purposes of energy recovery, will enter 7,500
pounds into a recovery process, and will dispose of
the remaining 2,500 pounds. These quantities and
the associated activity codes must be reported
separately in Section 6.2. (See Figure 5 for a
hypothetical Section 6.2 completed for two off-site
locations, one of which receives the transfer of
15,000 pounds of toluene as detailed.) If you have
fewer than four total transfers in Section 6.2
Column A (see examples in Figure 5), an NA should
be placed in Column A of the first unused row to
indicate the termination of the sequence. If all four
rows are used, there is no need to terminate the
sequence. If there are more than four total transfers,
re-enter the name of the off-site location, address,
etc. in the next row (6.2.2) and then you should
enter NA when the sequence has terminated if there
are fewer than 8 (i.e. anytime there are fewer than 4
transfers listed in a Section 6.2 block, an NA should
be used to terminate the sequence).
Do not double or multiple count amounts transferred
off-site. For example, when a reported EPCRA
Section 313 chemical is sent to an off-site facility
for sequential activities, you should report the final
disposition of the toxic chemical.
6.2b
Column B: Basis of Estimate
You must identify the basis for your estimates of the
quantities of the reported EPCRA Section 313
chemical in waste transferred to each off-site
location. Enter one of the following letter codes that
applies to the method by which the largest
percentage of the estimate was derived.
M1
Estimate is based on continuous monitoring
data or measurements for the EPCRA Section
313 chemical.
M2
Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA Section 313 chemical.
C
Estimate is based on mass balance
calculations, such as calculation of the
amount of the EPCRA Section 313 chemical
in streams entering and leaving process
equipment.
E1
Estimate is based on published emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
E2
Estimate is based on site specific emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
O
Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying an estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment
was fully identified through monitoring data.
6.2c
Column C: Type of Waste Management:
Disposal/ Treatment/Energy
Recovery/Recycling
You should enter one of the following M codes to
identify the type of disposal, treatment, energy
recovery, or recycling methods used by the off-site
location for the reported EPCRA Section 313
chemical. You must use separate transfers and codes
for a single location when distinct quantities of the
reported EPCRA Section 313 chemical are subject
to different waste management activities, including
disposal, treatment, energy recovery, or recycling.
You must use the code that represents the ultimate
disposition of the chemical.
If the EPCRA Section 313 chemical is sent off-site
for further direct reuse (e.g., an EPCRA Section 313
chemical in used solvent that will be used as
lubricant at another facility) and does not undergo a
waste management activity (i.e., release (including
disposal), treatment, energy recovery, or recycling
(recovery)) prior to that reuse, it need not be
reported in section 6.2 or section 8.
Incineration vs. Energy Recovery
You must distinguish between incineration which is
waste treatment, and legitimate energy recovery. For
you to claim that a reported EPCRA Section 313
chemical sent off-site is used for the purposes of
energy recovery and not for treatment for
Toxics Release Inventory Reporting Forms and Instructions
58
Instructions for Completing Part II of EPA Form R
destruction, the EPCRA Section 313 chemical must
have a significant heating value and must be
combusted in an energy recovery unit such as an
industrial boiler, furnace, or kiln. In a situation
where the reported EPCRA Section 313 chemical is
in a waste that is combusted in an energy recovery
unit, but the EPCRA Section 313 chemical does not
have a significant heating value, e.g., CFCs, you
should use code M54, Incineration/Insignificant
Fuel Value, to indicate that the EPCRA Section 313
chemical was incinerated in an energy recovery unit
but did not contribute to the heating value of the
waste.
Metals and Metal Category Compounds
Metals and metal category compounds will be
managed in waste either by being released
(including disposed of) or by being recycled.
Remember that the release and other waste
management information that you report for metal
category compounds will be the total amount of the
parent metal released or recycled and NOT the
whole metal category compound. The metal has no
heat value and thus cannot be combusted for energy
recovery and cannot be treated because it cannot be
destroyed. Thus, transfers of metals and metal
category compounds for further waste management
should be reported as either a transfer for recycling
or a transfer for disposal. The applicable waste
management codes for transfers of metals and metal
category compounds for recycling are M24, metals
recovery, M93, waste broker - recycling, or M26,
other reuse/recovery. Applicable codes for transfers
for disposal include M10, M41, M62, M64, M65,
M66, M67, M73, M79, M81, M82, M90, M94, and
M99. These codes are for off-site transfers for
further waste management in which the waste
stream may be treated but the metal contained in the
waste stream is not treated and is ultimately
released. For example, M41 should be used for a
metal or metal category compound that is stabilized
in preparation for disposal.
Applicable codes for Part II, Section 6.2, column C
are:
Disposal
M10 Storage Only
M41 Solidification/Stabilization - Metals and
Metal Category Compounds only
M62 Wastewater Treatment (Excluding POTW) Metals and Metal Category Compounds only
M64 Other Landfills
M65 RCRA Subtitle C Landfills
M66 Subtitle C Surface Impoundment
M67 Other Surface Impoundments
M73 Land Treatment
M79 Other Land Disposal
M81 Underground Injection to Class I Wells
M82 Underground Injection to Class II-V Wells
M90 Other Off-Site Management
M94 Transfer to Waste Broker - Disposal
M99 Unknown
Treatment
M40 Solidification/Stabilization
M50 Incineration/Thermal Treatment
M54 Incineration/Insignificant Fuel Value
M61 Wastewater Treatment (Excluding POTW)
M69 Other Waste Treatment
M95 Transfer to Waste Broker - Waste
Treatment
Energy Recovery
M56 Energy Recovery
M92 Transfer to Waste Broker - Energy
Recovery
Recycling
M20 Solvents/Organics Recovery
M24 Metals Recovery
M26 Other Reuse or Recovery
M28 Acid Regeneration
M93 Transfer to Waste Broker - Recycling
Toxics Release Inventory Reporting Forms and Instructions
59
Instructions for Completing Part II of EPA Form R
This off-site location receives a transfer of 15,000 pounds of toluene and will combust 5,000 pounds for the
purposes of energy recovery, will enter 7,500 pounds into a recovery process, and will dispose of the
remaining 2,500 pounds.
This off-site location receives a transfer of 12,500 pounds of tetrachloroethylene (perchloroethylene) that is
part of a waste that is combusted for the purposes of energy recovery in an industrial furnace. Note that the
tetrachloroethylene should be reported using code M54 to indicate that it is combusted in an energy recovery
unit but it does not contribute to the heating value of the waste.
Figure 5. Hypothetical Section 6.2 Completed for Two Off-Site Locations
Toxics Release Inventory Reporting Forms and Instructions
60
Instructions for Completing Part II of EPA Form R
Section 7.
On-Site Waste Treatment,
Energy Recovery, and
Recycling Methods
You must report in this section the methods of waste
treatment, energy recovery, and recycling applied to
the reported EPCRA Section 313 chemical in wastes
on-site. There are three separate sections for
reporting such activities. Section 7A column c and
Section 7A column e were deleted from Form R in
2005. Section 7A column d remained on the form
until 2010. In 2011, column d was renamed column
c which is addressed below.
Section 7A:
On-Site Waste Treatment
Methods and Efficiency
Most of the chemical-specific information required
by EPCRA Section 313 that is reported on Form R
is specific to the EPCRA Section 313 chemical
rather than the waste stream containing the EPCRA
Section 313 chemical. However, EPCRA Section
313 does require that waste treatment methods
applied on-site to waste streams that contain the
EPCRA Section 313 chemical be reported. This
information is reportable regardless of whether the
facility actively applies treatment or the treatment of
the waste stream occurs passively. This information
is collected in Section 7A of Form R.
In Section 7A, you must provide the following
information if you treat waste streams containing
the reported EPCRA Section 313 chemical on-site:
(a)
(b)
(c)
The general waste stream types containing the
EPCRA Section 313 chemical being reported;
The waste treatment method(s) or sequence
used on all waste streams containing the
EPCRA Section 313 chemical; and
The efficiency of each waste treatment
method or waste treatment sequence in
destroying or removing the EPCRA Section
313 chemical.
When entering on-site treatment data in TRIMEweb, use a separate waste treatment profile in
Section 7A for each general waste stream type. Each
profile contains the general waste stream type (7A
Column a) and all waste treatment methods
associated with that stream (7A Column b). In TRIMEweb, each profile treatment stream is assigned a
name. Each waste treatment profile generated for a
facility is available to be used for other forms from
the same facility for the same reporting year. Report
only information about treatment of waste streams
at your facility, not information about off-site waste
treatment.
For each waste treatment profile, provide the
appropriate waste treatment efficiency code (7A
Column c) for that chemical.
TRI-MEweb may also simultaneously collect total
quantities treated on-site for the current reporting
year for this chemical (see Section 8.6).
If you do not perform on-site treatment of waste
streams containing the reported EPCRA Section 313
chemical, check the “Not Applicable” box for
Section 7A.
7A Column a: General Waste Stream
For each waste treatment method, indicate the type
of waste stream containing the EPCRA Section 313
chemical that is treated. Select the letter code that
corresponds to the general waste stream type:
A
Gaseous (gases, vapors, airborne particulates)
W
Wastewater (aqueous waste)
L
Liquid waste streams (non-aqueous waste)
S
Solid waste streams (including sludges and
slurries)
If a waste is a combination of water and organic
liquid and the organic content is less than 50
percent, report it as a wastewater (W). Slurries and
sludges containing water should be reported as solid
waste if they contain appreciable amounts of
dissolved solids, or solids that may settle, such that
the viscosity or density of the waste is considerably
different from that of process wastewater.
7A Column b: Waste Treatment Method(s)
Sequence
Enter the appropriate waste treatment code from the
list below for each on-site waste treatment method
used on a waste stream containing the EPCRA
Section 313 chemical, regardless of whether the
waste treatment method actually removes the
specific EPCRA Section 313 chemical being
reported. Waste treatment methods must be reported
for each type of waste stream being treated (i.e.,
gaseous waste streams, aqueous waste streams,
liquid non-aqueous waste streams, and solids).
Except for the air emission treatment codes, the
Toxics Release Inventory Reporting Forms and Instructions
61
Instructions for Completing Part II of EPA Form R
waste treatment codes are not restricted to any
medium.
Waste streams containing the EPCRA Section 313
chemical may have a single source or may be
aggregates of many sources. For example, process
water from several pieces of equipment at your
facility may be combined prior to waste treatment.
Report waste treatment methods that apply to the
aggregate waste stream, as well as waste treatment
methods that apply to individual waste streams. If
your facility treats various wastewater streams
containing the EPCRA Section 313 chemical in
different ways, the different waste treatment
methods must be listed separately.
If your facility has several pieces of equipment
performing a similar service in a waste treatment
sequence, you may combine the reporting for such
equipment. It is not necessary to enter four codes to
cover four scrubber units, for example, if all four are
treating waste streams of similar character (e.g.,
sulfuric acid mist emissions), have similar influent
concentrations, and have similar removal
efficiencies. If, however, any of these parameters
differs from one unit to the next, each scrubber
should be listed separately.
If you are using the hard copy paper form (trade
secret submissions only), and if your facility
performs more than eight sequential waste treatment
methods on a single general waste stream, continue
listing the methods in the next row and renumber
appropriately those waste treatment method code
boxes you used to continue the sequence. For
example, if the general waste stream in box 7A.1a
had nine treatment methods applied to it, the ninth
method would be indicated in the first method box
for row 7A.2a. The numeral “1” would be crossed
out, and a “9” would be inserted.
Treatment applied to any other general waste stream
types would then be listed in the next empty row. In
the scenario below, for instance, the second general
waste stream would be reported in row 7A.3a. See
Figure 6 for an example of a hypothetical section
7A.
Toxics Release Inventory Reporting Forms and Instructions
62
Instructions for Completing Part II of EPA Form R
Example 16: Calculating Releases and Other Waste Management Quantities
Your facility disposes of 14,000 pounds of lead chromate (PbCrO4.PbO) in an on-site landfill and
transfers 16,000 pounds of lead selenite (PbSeO4) to an off-site land disposal facility. You would
therefore be submitting three separate reports on the following: lead compounds, selenium compounds,
and chromium compounds. However, the quantities you would be reporting would be the pounds of
“parent” metal being released on-site or transferred off-site for further waste management. All quantities
are based on mass balance calculations (See Section 5, Column B for information on Basis of Estimate
and Section 6.2, Column C for waste management codes and information on transfers of EPCRA Section
313 chemicals in wastes). You would calculate releases of lead, chromium, and selenium by first
determining the percentage by weight of these metals in the materials you use as follows:
Lead Chromate (PbCrO4.PbO)
Lead (2 Pb atoms)
Chromium (1 Cr atom)
Molecular weight = 546.37
Atomic weight = 207.2 × 2 = 414.4
Atomic weight = 51.996
Lead chromate is therefore (percent by weight):
(414.4/546.37) = 75.85% lead and
(51.996/546.37) = 9.52% chromium.
Lead Selenite (PbSeO4)
Lead (1 Pb atom)
Selenium (1 Se atom)
Molecular weight = 350.17
Atomic weight = 207.2
Atomic weight = 78.96
Lead selenite is therefore (percent by weight):
(207.2/350.17) = 59.17% lead and
(78.96/350.17) = 22.55% selenium.
The total pounds of lead, chromium, and selenium disposed of on or off-site from your facility are as
follows:
Lead
Disposal on-site:
Transfer off-site for disposal:
0.7585 × 14,000 = 10,619 pounds from lead chromate
0.5917 × 16,000 = 9,467 pounds from lead selenite
Chromium
Disposal on-site:
0.0952 × 14,000 = 1,333 pounds from lead chromate
Selenium
Transfer off-site for disposal:
0.2255 × 16,000 = 3,608 pounds from lead selenite
Toxics Release Inventory Reporting Forms and Instructions
63
Instructions for Completing Part II of EPA Form R
Figure 6. Hypothetical Section 7A
Waste Treatment Codes
A01
A02
A03
A04
A05
A06
A07
H040
H071
H073
H075
H076
H077
H081
H082
H083
H101
H103
H111
H112
H121
H122
H123
H124
H129
Flare
Condenser
Scrubber
Absorber
Electrostatic Precipitator
Mechanical Separation
Other Air Emission Treatment
Incineration--thermal destruction other than
use as a fuel
Chemical reduction with or without
precipitation
Cyanide destruction with or without
precipitation
Chemical oxidation
Wet air oxidation
Other chemical precipitation with or without
pre-treatment
Biological treatment with or without
precipitation
Adsorption
Air or steam stripping
Sludge treatment and/or dewatering
Absorption
Stabilization or chemical fixation prior to
disposal
Macro-encapsulation prior to disposal
Neutralization
Evaporation
Settling or clarification
Phase separation
Other treatment
percentage of the EPCRA Section 313 chemical
removed from the waste stream through destruction,
biological degradation, chemical conversion, or
physical removal. The waste treatment efficiency
(expressed as a range of percent removal) represents
the percentage of the EPCRA Section 313 chemical
destroyed or removed (based on amount or mass),
not merely changes in volume or concentration of
the EPCRA Section 313 chemical in the waste
stream. The efficiency, which can reflect the overall
removal from sequential treatment methods applied
to the general waste stream, refers only to the
percent destruction, degradation, conversion, or
removal of the EPCRA Section 313 chemical from
the waste stream; it does not refer to the percent
conversion or removal of other constituents in the
waste stream. The efficiency also does not refer to
the general efficiency of the treatment method for
any waste stream. For some waste treatment
methods, the percent removal will represent removal
by several mechanisms, as in an aeration basin,
where an EPCRA Section 313 chemical may
evaporate, biodegrade, or be physically removed
from the sludge.
7A Column c: Waste Treatment Efficiency
Estimate
In the space provided, enter the range code, based
upon the codes listed below, indicating the
Toxics Release Inventory Reporting Forms and Instructions
64
Instructions for Completing Part II of EPA Form R
Percent removal can be calculated as follows:
(I - E) × 100%
I
where:
I = amount of the EPCRA Section 313 chemical in
the influent waste stream (entering the waste
treatment step or sequence) and
E = amount of the EPCRA Section 313 chemical in
the effluent waste stream (exiting the waste
treatment step or sequence).
Calculate the amount of the EPCRA Section 313
chemical in the influent waste stream by multiplying
the concentration (by weight) of the EPCRA Section
313 chemical in the waste stream by the total
amount or weight of the waste stream. In most
cases, the percent removal compares the treated
effluent to the influent for the particular type of
waste stream. For solidification of wastewater, the
waste treatment efficiency can be reported as code
E1 (greater than 99.9999 percent) if no volatile
EPCRA Section 313 chemicals were removed with
the water or evaporated into the air. Percent removal
does not apply to incineration because the waste
stream, such as wastewater or liquids, may not exist
in a comparable form after waste treatment and the
purpose of incineration as a waste treatment is to
destroy the EPCRA Section 313 chemical by
converting it to carbon dioxide and water or other
byproducts. In cases where the EPCRA Section 313
chemical is incinerated, the percent efficiency must
be based on the amount of the EPCRA Section 313
chemical destroyed or combusted, except for metals
or metal category compounds. In the cases in which
a metal or metal category compound is incinerated,
the efficiency is reported as code E6 (equal to or
greater than 0 percent, but less than or equal to 50
percent).
Similarly, an efficiency of zero must be reported for
any waste treatment method(s) that does not destroy,
chemically convert or physically remove the
EPCRA Section 313 chemical from the waste
stream.
For metal category compounds, the calculation of
the reportable concentration and waste treatment
efficiency must be based on the weight of the parent
metal, not on the weight of the metal compound.
Metals are not destroyed, only physically removed
or chemically converted from one form into another.
The waste treatment efficiency reported must
represent only physical removal of the parent metal
from the waste stream (except for incineration), not
the percent chemical conversion of the metal
compound. If a listed waste treatment method
converts but does not remove a metal (e.g.,
chromium reduction), the method must be reported
with a waste treatment efficiency of code E6 (equal
to or greater than 0 percent, but less than or equal to
50 percent.
EPCRA Section 313 chemicals that are strong
mineral acids neutralized to a pH of 6 or above are
considered treated at 100 percent efficiency.
When calculating waste treatment efficiency,
EPCRA Section 313(g)(2) requires a facility to use
readily available data (including monitoring data)
collected pursuant to other provisions of law, or,
where such data are not readily available,
“reasonable estimates” of the amounts involved.
Waste Treatment Efficiency Range Codes:
E1 =
E2 =
E3 =
E4 =
E5 =
E6 =
greater than 99.9999%
greater than 99.99%, but less than or equal
to 99.9999%
greater than 99%, but less than or equal to
99.99%
greater than 95%, but less than or equal to
99%
greater than 50%, but less than or equal to
95%
equal to or greater than 0%, but less than or
equal to 50%
Section 7B On-site Energy Recovery Processes
In Section 7B, you must indicate the on-site energy
recovery methods used on the reported EPCRA
Section 313 chemical.
EPA considers an EPCRA Section 313 chemical to
be combusted for energy recovery if the toxic
chemical has a significant heat value and is
combusted in an energy recovery device. If a
reported EPCRA Section 313 chemical is
incinerated on-site but does not contribute energy to
the process (e.g., chlorofluorocarbons), it must be
considered waste treated on-site and reported in
Section 7A. Metals and metal category compounds
cannot be combusted for energy recovery and
should NOT be reported in this section. Do not
include the combustion of fuel oils, such as fuel oil
Toxics Release Inventory Reporting Forms and Instructions
65
Instructions for Completing Part II of EPA Form R
#6, in this section. Energy recovery may take place
only in an industrial kiln, furnace, or boiler.
NA vs. a Numerical Value (e.g., Zero). If you do
not perform on-site energy recovery for a waste
stream that contains or contained the EPCRA
Section 313 chemical, check the NA box at the top
of Section 7B and enter NA in Section 8.2. If you
perform on-site energy recovery for the waste
stream that contains or contained the EPCRA
Section 313 chemical, enter the appropriate code in
Section 7B and enter the appropriate value in
Section 8.2. If this quantity is less than or equal to
0.5 pound, round to zero (unless the chemical is a
listed PBT chemical) and enter zero in 8.2. (Note:
for metals and metal compounds, you should only
report NA in Sections 7B and Section 8.2.)
In this section, use the codes below to report only
the recycling methods in place at your facility that
are applied to the EPCRA Section 313 chemical. Do
not list any off-site recycling activities. (Information
about off-site recycling must be reported in Part II,
Section 6, “Transfers of the Toxic Chemical in
Wastes to Off-site Locations.”)
NA vs. a Numerical Value (e.g., Zero). If you do
not perform on-site recycling for the reported
EPCRA Section 313 chemical, check the NA box at
the top of Section 7C and enter NA in Section 8.4. If
you perform on-site recycling for the reported
EPCRA Section 313 chemical, enter the appropriate
code in Section 7C and enter the appropriate value
in Section 8.4. If this quantity is less than or equal to
0.5 pound, round to zero (unless the chemical is a
listed PBT chemical) and enter 0 in Section 8.4.
Energy Recovery Codes
U01
U02
U03
Industrial Kiln
Industrial Furnace
Industrial Boiler
If your facility uses more than one on-site energy
recovery method for the reported EPCRA Section
313 chemical, list the methods used in descending
order (greatest to least) based on the amount of the
EPCRA Section 313 chemical entering such
methods.
TRI-MEweb will also simultaneously collect total
quantity used for energy recovery on-site for the
current reporting year for this chemical (see Section
8.2).
Section 7C On-site Recycling Processes
In Section 7C, you must report the recycling
methods used on the EPCRA Section 313 chemical.
On-Site Recycling Codes
H10 Metal recovery (by retorting, smelting, or
chemical or physical extraction
H20 Solvent recovery (including distillation,
evaporation, fractionation or extraction)
H39 Other recovery or reclamation for reuse
(including acid regeneration or other chemical
reaction process)
If your facility uses more than one on-site recycling
method for an EPCRA Section 313 chemical, enter
the codes in the space provided in descending order
(greatest to least) based on the volume of the
reported EPCRA Section 313 chemical recovered by
each process.
TRI-MEweb will also simultaneously collect total
quantity recycled on-site for the current reporting
year for this chemical (see Section 8.4).
Toxics Release Inventory Reporting Forms and Instructions
66
Instructions for Completing Part II of EPA Form R
Example 17: On-Site Waste Treatment
A process at the facility generates a wastewater stream containing an EPCRA Section 313 chemical (chemical A). A
second process generates a wastewater stream containing two EPCRA Section 313 chemicals, a metal (chemical B)
and a mineral acid (chemical C). Thresholds for all three chemicals have been exceeded and you are in the process of
completing separate Form Rs for each chemical.
These two wastewater streams are combined and sent to an on-site wastewater treatment system before being
discharged to a POTW. This system consists of an oil/water separator that removes 99 percent of chemical A; a
neutralization tank in which the pH is adjusted to 7.5, thereby destroying 100 percent of the mineral acid (chemical
C); and a settling tank where 95 percent of the metal (chemical B) is removed from the water (and eventually
landfilled off-site).
Section 7A should be completed slightly differently when you file the Form R for each of the chemicals. The table
accompanying this example shows how Section 7A should be completed for each chemical. First, on each Form R
you should identify the type of waste stream in Section 7A.1a as wastewater (aqueous waste, code W). Next, on each
Form R you should list the code for each of the treatment steps that is applied to the entire waste stream, regardless
of whether the operation affects the chemical for which you are completing the Form R (for instance, the first four
blocks of Section 7A.1b of all three Form Rs should show: H124 (phase separation), H121 (neutralization), H123
(settling or clarification), and N/A (to signify the end of the treatment system). Note that Section 7A.1b is not
chemical specific. It applies to the entire waste stream being treated. Section 7A.1c applies to the efficiency of the
entire system in destroying and/or removing the chemical for which you are preparing the Form R. You should enter
E4 when filing for chemical A, E5 for chemical B, and E1 for chemical C.
Chemical A
7A.1a
W
7A.1b
1. H124
2. H121
3. H123
4. N/A
5.
6.
7.
8.
7A.1b
1. H124
2. H121
3. H123
4. N/A
5.
6.
7.
8.
7A.1b
1. H124
2. H121
3. H123
4. N/A
5.
6.
7.
8.
7A.1c
E4
Chemical B
7A.1a
W
7A.1c
E5
Chemical C
7A.1a
W
7A.1c
E1
Note that the quantity removed and/or destroyed is not reported in Section 7 and that the efficiency reported in
Section 7A.1c refers to the amount of EPCRA Section 313 chemical destroyed and/or removed from the applicable
waste stream. The amount actually destroyed should be reported in Section 8.6 (quantity treated on-site). For
example, when completing the Form R for chemical B you should report “N/A” pounds in Section 8.6 because the
metal has been removed from the wastewater stream, but not actually destroyed. The quantity of chemical B that is
ultimately landfilled off-site should be reported in Sections 6.2 and 8.1c. However, when completing the Form R for
chemical C, you should report the entire quantity in Section 8.6 because raising the pH to 7.5 will completely destroy
the mineral acid.
Toxics Release Inventory Reporting Forms and Instructions
67
Instructions for Completing Part II of EPA Form R
Example 18: Reporting On-Site Energy Recovery
One waste stream generated by your facility contains, among other chemicals, toluene and Freon 113.
Threshold quantities are exceeded for both of these EPCRA Section 313 chemicals, and you would,
therefore, submit two separate Form R reports. This waste stream is sent to an on-site industrial furnace
that uses the heat generated in a thermal hydrocarbon cracking process at your facility. Because toluene
has a significant heat value (17,440 BTU/pound) and the energy is recovered in an industrial furnace, the
code “U02-Industrial Furnace” would be selected for the energy recovery method in Section 7B for the
Form R submitted for toluene.
However, as Freon 113 does not contribute any value for energy recovery purposes, the combustion of
Freon 113 in the industrial furnace is considered waste treatment, not energy recovery. You would report
Freon 113 as entering a waste treatment step (i.e., incineration), in Section 7A, column b. In Section 7B
the facility should report zero.
Section 8.
Source Reduction and Waste
Management
This section includes the data elements mandated by
Section 6607 of the Pollution Prevention Act of
1990 (PPA).
In Section 8, you must provide information about
source reduction activities and quantities of the
EPCRA Section 313 chemicals managed as waste.
For all appropriate questions, report only the
quantity, in pounds, (or, for the dioxin and dioxinlike compounds category, grams) of the reported
EPCRA Section 313 chemical itself. Do not include
the weight of water, soil, or other waste constituents.
When reporting on the metal category compounds,
you should report only the amount of the metal
portion of the compound as you do when estimating
release and other waste management amounts.
Sections 8.1 through 8.9 must be completed for each
EPCRA Section 313 chemical. Section 8.10 must be
completed only if a source reduction activity was
newly implemented specifically (in whole or in part)
for the reported EPCRA Section 313 chemical
during the reporting year. Section 8.11 allows you to
submit additional optional information on source
reduction, recycling, or pollution control activities
implemented for the reported EPCRA Section 313
chemical at any time at your facility.
Sections 8.1 through 8.7 require reporting of
production-related waste management quantities for
the current reporting year, the prior year, and
quantities anticipated in both the first year
immediately following the reporting year and the
second year following the reporting year (future
estimates).
Do not enter the values in Section 8 in gallons, tons,
liters, or any measure other than pounds (or, for the
dioxin and dioxin-like compounds category, grams).
For non-PBT chemicals, you must generally enter
the values as whole numbers; numbers following a
decimal point are not acceptable for non-PBT
chemicals except as noted in the instructions for
Sections 8.1c-d and 8.7. For PBT chemicals (except
the dioxin and dioxin-like compounds category),
facilities should report release and other waste
management quantities greater than 0.1 pound
provided the accuracy and the underlying data on
which the estimate is based supports this level of
precision.
For the dioxin and dioxin-like compounds category,
facilities should report at a level of precision
supported by the accuracy of the underlying data
and the estimation techniques on which the estimate
is based. However, the smallest quantity that need
be reported on the Form R for the dioxin and dioxinlike compounds category is 0.0001 grams (see
Example 12). Notwithstanding the numeric
precision used when determining reporting
eligibility thresholds, facilities should report on
Form R to the level of accuracy that their data
supports, up to seven digits to the right of the
decimal. EPA’s reporting software and data
management systems support data precision to
seven digits to the right of the decimal.
NA vs. a Numeric Value (e.g., Zero). You should
enter a numeric value in the relevant sections of
Section 8 if your facility has released, treated,
Toxics Release Inventory Reporting Forms and Instructions
68
Instructions for Completing Part II of EPA Form R
combusted for energy recovery or recycled any
quantity of an EPCRA Section 313 chemical during
the reporting year. If the aggregate quantity of that
toxic chemical was equal to or less than 0.5 pound
for a particular waste management method, you
should enter the value zero (unless the chemical is a
PBT chemical) in the relevant section. In the case
of PBTs (excluding dioxin) if the aggregate quantity
of the toxic chemical is equal to or less than 0.1
pound for a particular waste management method,
you should enter the value zero in the relevant
section. For dioxin, if the aggregate quantity is
equal to or less than .0001 grams for a particular
waste management method, you should enter the
value zero in the relevant section. For both PBTs
and dioxin, the accuracy of the underlying data on
which the estimate is based must support the
specified level of precision in order to round to zero.
However, if there has been no on-site or off-site
treatment, combustion for energy recovery, or
recycling of the waste stream containing the EPCRA
Section 313 chemical, then you should enter NA in
the relevant section. (Note: for metals and metal
category compounds, you should enter NA in
Sections 8.2, 8.3, 8.6 and 8.7, as treatment and
combustion for energy recovery generally are not
applicable waste management methods for metals
and metal compounds). For Section 8.1b, NA
generally is not applicable recognizing the potential
for spills, leaks, or fugitive emissions of the EPCRA
Section 313 chemical. You should enter NA in
Section 8.8 if there were no remedial actions,
catastrophic events such as earthquakes, fires, or
floods or one-time events not associated with
normal or routine production processes for that toxic
chemical. If there was a catastrophic event at your
facility, but you were able to prevent any releases
from occurring, then enter zero in Section 8.8.
Relationship to Other Laws
The reporting categories for quantities recycled,
used for energy recovery, treated, and disposed of
apply to completing Section 8 of Form R as well as
to the rest of Form R. These categories are to be
used only for TRI reporting. They are not intended
for use in determining, under the Resource
Conservation and Recovery Act (RCRA) Subtitle C
regulations, whether a secondary material is a waste
when recycled. These categories also do not apply to
the information that may be submitted in the
Biennial Report required under RCRA. In addition,
these categories do not imply any future redefinition
of RCRA terms and do not affect EPA’s RCRA
authority or authority under any other statute
administered by EPA.
Differences in terminology and reporting
requirements for EPCRA Section 313 chemicals
reported on Form R and for hazardous wastes
regulated under RCRA occur because EPCRA and
the PPA focus on specific chemicals, while the
RCRA regulations and the Biennial Report focus on
waste streams that may include more than one
chemical. For example, assume that a RCRA
hazardous waste containing an EPCRA Section 313
chemical is recycled to recover certain constituents
of that waste, but not the toxic chemical reported
under EPCRA Section 313. The EPCRA Section
313 chemical simply passes through the recycling
process and remains in the residual from the
recycling process, which is disposed of. While the
waste may be considered recycled under RCRA, for
TRI purposes, the EPCRA Section 313 chemical
constituent would be considered to be disposed of
(as part of the residual from the recycling process).
An EPCRA Section 313 chemical or an EPCRA
Section 313 chemical in a mixture that is a waste
under RCRA must be reported in Sections 8.1
through 8.8.
Sections 8.1 – 8.7: Production-Related Waste
Managed
Column A: Prior Year. Quantities for Sections 8.1
through 8.7 must be reported for the year
immediately preceding the reporting year in column
A. For reports due July 1, 2015 (reporting year
2014), the prior year is 2013. Information available
at the facility that may be used to estimate the prior
year’s quantities include the prior year’s Form R
submission, supporting documentation, and
recycling, energy recovery, treatment, or disposal
operating logs or invoices. When reporting prior
year estimates, facilities are not required to use
quantities reported on the previous year’s form if
better information is available. TRI-MEweb
prepopulates this column on the TRI form if the
facility reported the previous year.
Column B: Current Reporting Year. Quantities
for Sections 8.1 through 8.7 must be reported for the
current reporting year in column B.
Columns C and D: Following Year and Second
Following Year. Quantities for Sections 8.1 through
Toxics Release Inventory Reporting Forms and Instructions
69
Instructions for Completing Part II of EPA Form R
8.7 must be estimated for the following two years.
EPA expects reasonable future quantity estimates
using a logical basis. Information available at the
facility to estimate quantities of the chemical
expected during these years include (but are not
limited to) planned source reduction activities,
market projections, expected contracts, anticipated
new product lines, company growth projections, and
production capacity figures. Respondents should
take into account protections available for trade
secrets as provided in EPCRA Section 322 (42 USC
11042) for the chemical identity.
Example 19: Reporting Future Estimates
A pharmaceutical manufacturing facility uses an
EPCRA Section 313 chemical in the manufacture
of a prescription drug. During the reporting year
(2013), the company received approval from the
Food and Drug Administration to begin marketing
their product as an over-the-counter drug
beginning in 2014. This approval is publicly
known and does not constitute confidential
business information. As a result of this expanded
market, the company estimates that sales and
subsequent production of this drug will increase
their use of the reported EPCRA Section 313
chemical by 30 percent per year for the two years
following the reporting year. The facility treats
the EPCRA Section 313 chemical on-site and the
quantity treated is directly proportional to
production activity. The facility thus estimates the
total quantity of the reported EPCRA Section 313
chemical treated for the following year (2014) by
adding 30 percent to the amount in column B (the
amount for the current reporting year). The
second following year (2015) figure can be
calculated by adding an additional 30 percent to
the amount reported in column C (the amount for
the following year (2014) projection).
B (current year), TRI-MEweb will use these
equations to complete these Sections automatically.
Note on Equations. Where an equation includes a
value followed by a parenthetical, this means that
the equation is referring only to the portion of that
value described by the parenthetical. For example,
“Section 6.2 (recycling)” refers to the portion of the
value for Section 6.2 that is recycled, while
“Section 6.2 (treatment)” refers to the portion of
the value for Section 6.2 that is treated.
Section 8.1. In Section 8.1, facilities report disposal
and other releases. This includes on-site disposal
and other releases reported in Section 5 and off-site
disposal and other releases reported in Section 6, but
excludes quantities reported in Section 5 and 6 due
to remedial actions, catastrophic events, or nonproduction related one-time events (see the
discussion on Section 8.8). Note that EPCRA
Section 329(8) defines release as “any spilling,
leaking, pumping, pouring, emitting, emptying,
discharging, injecting, escaping, leaching, dumping,
or disposing into the environment (including the
abandonment of barrels, containers, and other closed
receptacles).”
Metals and metal category compounds reported in 1)
Section
6.2
as
sent
off-site
for
stabilization/solidification (M41) or wastewater
treatment (excluding POTWs) (M62) and/or 2)
Section 6.1 - discharges to POTWs, should be
reported in Section 8.1. These quantities should
NOT be reported in Section 8.7 because the metals
are not ultimately destroyed.
Beginning in the 2003 reporting year, Section 8.1
was divided into four Subsections (8.1a, 8.1b, 8.1c
and 8.1d). Please refer to the following equations
that show the relationship between Sections 5, 6,
8.8, and 8.1a through 8.1d.
Quantities Reportable in Sections 8.1 - 8.7
Section 8 of Form R uses data collected to complete
Part II, Sections 5 through 7. For this reason,
Section 8 should be completed last. The relationship
between Sections 5, 6, and 8.8 to Sections 8.1, 8.3,
8.5, and 8.7 are provided below in equation form.
EPA recommends that you use these equations to
complete Sections 8.1, 8.3, 8.5, and 8.7 for the
current year and discourages rounding. For Column
Toxics Release Inventory Reporting Forms and Instructions
70
Instructions for Completing Part II of EPA Form R
Sections 8.1a and 8.1b. Toxic chemicals disposed
of or otherwise released on-site are reported in 8.1a
or 8.1b as appropriate. Toxic chemicals sent off-site
for disposal are reported in 8.1c or 8.1d.
Section 8.1a = Section 5.4.1 + Section 5.5.1A +
Section 5.5.1B - Section 8.8 (on-site disposal to
landfills or UIC Class I Wells) 2
Section 8.1b = Section 5.1 + Section 5.2 + Section
5.3 + Section 5.4.2 + Section 5.5.2 + Section
5.5.3A + Section 5.5.3B + Section 5.5.4 - Section
8.8 (on-site disposal or other releases, other than
disposal to landfills or UIC Class I Wells) 2
Sections 8.1c and 8.1d. Toxic chemicals transferred
off-site to POTWs or other off-site locations and
then disposed of or otherwise released should be
reported in 8.1c or 8.1d as appropriate. For example,
quantities of a toxic chemical sent to a landfill, or
sent to a POTW and subsequently sent to a landfill
are reported in Section 8.1c, while quantities of a
toxic chemical sent to a surface impoundment, or
sent to a POTW and subsequently released to a
stream, are reported in Section 8.1d. Metals and
metal category compounds sent to POTWs should
be reported in one of these two sections and should
not be reported as treated for destruction in Section
8.7.
Section 8.1c = Section 6.1 (portion of transfer
that is not treated for destruction and is
ultimately disposed of in landfills or UIC Class I
Wells) + Section 6.2 (quantities associated with M
codes M64, M65 and M81) - Section 8.8 (off-site
disposal to landfills or UIC Class I Wells) 2
Section 8.1d = Section 6.1 (portion of transfer
that is not treated for destruction and is
ultimately disposed of or otherwise released,
other than disposal to landfills or UIC Class I
Wells) + Section 6.2 (quantities associated with M
codes M10, M41, M62, M66, M67, M73, M79,
M82, M90, M94, and M99) - Section 8.8 (off-site
disposal or other releases, other than disposal to
landfills or UIC Class I Wells)2
2
§ 8.8 includes quantities of toxic chemicals disposed of
or otherwise released on-site or managed as a waste offsite due to remedial actions, catastrophic events, or onetime events not associated with the production process. In
each equation, the parenthetical following “Section 8.8”
indicates which portion of § 8.8 is subtracted.
Some chemicals in addition to metals and metal
category compounds might not be treated for
destruction at a POTW. If you know that some or all
of a chemical is not treated for destruction at the
POTW, you should report that quantity in Section
8.1 (as indicated in the equations above) instead of
Section 8.7 (which is the quantity treated off-site).
In such cases, you may report using up to two
decimal places.
Removal and destruction rates for toxic chemicals
sent to POTWs, based on experimental and
estimated data, can be found in Table VI.
Sections 8.2 and 8.3. These relate to an EPCRA
Section 313 chemical or a mixture containing an
EPCRA Section 313 chemical that is used for
energy recovery on-site or is sent off-site for energy
recovery, unless it is a commercially available fuel
(e.g., fuel oil no. 6). For the purposes of reporting on
Form R, reportable on-site and off-site energy
recovery is the combustion of a waste stream
containing an EPCRA Section 313 chemical when:
(a)
The combustion unit is integrated into an
energy recovery system (i.e., industrial
furnaces, industrial kilns, and boilers); and
(b)
The EPCRA Section 313 chemical is
combustible and has a significant heating
value (e.g., 5000 BTU)
Note: Metals and metal category compounds cannot
be combusted for energy recovery. For metals and
metal category compounds, you should enter NA in
Sections 8.2 and 8.3.
Quantities used for energy recovery off-site that are
reported in Section 8.8 are excluded from Section
8.3.
Section 8.2 is not related to Sections 5 or 6
Section 8.3 = Section 6.2 (energy recovery) –
Section 8.8 (off-site energy recovery) 2
Sections 8.4 and 8.5. These relate to an EPCRA
Section 313 chemical in a waste that is recycled onsite or is sent off-site for recycling. Quantities
recycled off-site that are reported in Section 8.8 are
excluded from Section 8.5.
Section 8.4 is not related to Sections 5 or 6
Toxics Release Inventory Reporting Forms and Instructions
71
Instructions for Completing Part II of EPA Form R
Example 20: Avoiding Double-Counting
Quantities in Sections 8.1 through 8.7
5,000 pounds of an EPCRA Section 313
chemical enters a treatment operation. Three
thousand pounds of the EPCRA Section 313
chemical exits the treatment operation and then
enters a recycling operation. Five hundred
pounds of the EPCRA Section 313 chemical are
in residues from the recycling operation that is
subsequently sent off-site to a landfill for
disposal. These quantities would be reported as
follows in Section 8:
Section 8.1c: 500 pounds disposed of
Section 8.4: 2,500 pounds recycled
Section 8.6: 2,000 pounds treated (5,000 that
initially entered - 3,000 that subsequently entered
recycling)
Section 8.7 = Section 6.1 (portion of transfer that
is ultimately treated) + Section 6.2 (treatment) Section 8.8 (off-site treatment) 3
Some chemicals in addition to metals and metal
category compounds might not be treated for
destruction at a POTW. If you know that some or all
of a chemical is not treated for destruction at the
POTW, you should report that quantity in Section
8.1 instead of Section 8.7. Facilities should use their
best readily available information to determine the
final disposition of the toxic chemical sent to the
POTW, and then distribute the amount reported in
Section 6.1 among Sections 8.1c, 8.1d, and 8.7, as
appropriate. Removal and destruction rates for toxic
chemicals sent to POTWs, based on experimental
and estimated data, can be found in Table VI.
To report that 5,000 pounds were treated, 3,000
pounds were recycled, and that 500 pounds were
sent off-site for disposal would result in
over-counting the quantities of EPCRA Section
313 chemical recycled, treated, and disposed of
by 3,500 pounds.
Section 8.5 = Section 6.2 (recycling) - Section 8.8
(off-site recycling) 3
Section 8.6 and 8.7. These relate to an EPCRA
Section 313 chemical (except for most metals and
metal category compounds) or a waste containing an
EPCRA Section 313 chemical that is treated for
destruction on-site or is sent to a POTW or other
off-site location for treatment for destruction. Most
metal and category compounds are not reported in
this section because they cannot be destroyed (see
Appendix B). Quantities treated off-site that are
reported in Section 8.8 are excluded from Section
8.7.
Section 8.6 is not related to Sections 5 or 6
3
§ 8.8 includes quantities of toxic chemicals disposed of
or otherwise released on-site or managed as a waste offsite due to remedial actions, catastrophic events, or onetime events not associated with the production process. In
each equation, the parenthetical following “Section 8.8”
indicates which portion of § 8.8 is subtracted.
Toxics Release Inventory Reporting Forms and Instructions
72
Instructions for Completing Part II of EPA Form R
8.8 Non-Production-Related Waste
In Section 8.8, enter the total quantity of the EPCRA
Section 313 chemical disposed of or released
directly into the environment or sent off-site for
recycling, energy recovery, treatment, or disposal
during the reporting year due to any of the following
events:
(1)
(2)
(3)
remedial actions;
catastrophic events such as earthquakes,
fires, or floods; or
other one-time events not associated with
normal or routine production processes.
These quantities should not be included in Sections
8.1, 8.3, 8.5, or 8.7.
The purpose of this section is to separate quantities
recycled, used for energy recovery, treated, or
released (including disposals) that are associated
with normal or routine production operations from
those that are not. While all quantities released,
recycled, combusted for energy recovery, or treated
may ultimately be preventable, this section separates
the quantities that are more likely to be reduced or
eliminated by process oriented source reduction
activities from those releases that are largely
unpredictable and are less amenable to such source
reduction activities. For example, spills that occur as
a routine part of production operations and could be
reduced or eliminated by improved handling,
loading, or unloading procedures are included in the
quantities reported in Section 8.1 through 8.7 as
appropriate. A total loss of containment resulting
from a tank rupture caused by a tornado would be
included in the quantity reported in Section 8.8.
Similarly, the amount of an EPCRA Section 313
chemical cleaned up from spills resulting from
normal operations during the reporting year would
not be included in Section 8.8. However, the
quantity of the reported EPCRA Section 313
chemical disposed of from a remedial action (e.g.,
RCRA corrective action) to clean up the
environmental contamination resulting from past
practices should be reported in Section 8.8 because
they cannot currently be addressed by source
reduction methods. A remedial action for purposes
of Section 8.8 is a waste cleanup (including RCRA
and CERCLA operations) within the facility
boundary. Most remedial activities involve
collecting and treating contaminated material.
Also, releases caused by catastrophic events are to
be incorporated into the quantity reported in Section
8.8. Such releases may be caused by natural
disasters (e.g., hurricanes and earthquakes) or by
large scale accidents (e.g., fires and explosions). In
addition, releases due to other one-time events not
associated with production (e.g., terrorist bombing)
are to be included in Section 8.8. These amounts are
generally unanticipated and cannot be addressed by
routine process oriented accident prevention
techniques. By checking your documentation for
calculating estimates made for Part II, Section 5,
“Quantity of the Toxic Chemical Entering Each
Environmental Medium On-site,” you may be able
to identify disposal and release amounts from the
above sources. Emergency notifications under
CERCLA and EPCRA as well as accident histories
required under the Clean Air Act may provide
useful information. You should also check facility
incident reports and maintenance records to identify
one time or catastrophic events.
Note: While the information reported in Section 8.8
represents only remedial, catastrophic, or other onetime events not associated with production
processes, Section 5 of Form R (on-site disposal and
other releases to the environment) and Section 6
(off-site transfers for further waste management)
must include all on-site disposal and other releases
and transfers for disposal as appropriate, regardless
of whether they arise from catastrophic, remedial, or
routine process operations.
Avoid Double Counting in Sections 8.1 Through
8.8
Do not double or multiple count quantities in
Sections 8.1 through 8.8. The quantities reported in
each of those sections should be mutually exclusive.
In TRI-MEweb, any amounts that you designate as
non-production-related-waste (Section 8.8) will be
automatically excluded from production-relatedwaste (Sections 8.1-8.7).
Toxics Release Inventory Reporting Forms and Instructions
73
Instructions for Completing Part II of EPA Form R
Example 21: Non-Production-Related Waste Managed (Quantity 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).
A chemical manufacturer produces an EPCRA Section 313 chemical in a reactor that operates at low
pressure. The reactants and the EPCRA Section 313 chemical product are piped in and out of the reactor
at monitored and controlled temperatures. During normal operations, small amounts of fugitive emissions
occur from the valves and flanges in the pipelines.
Due to a malfunction in the control panel (which is state-of-the-art and undergoes routine inspection and
maintenance), the temperature and pressure in the reactor increase, the reactor ruptures, and the EPCRA
Section 313 chemical is released. Because the malfunction could not be anticipated and, therefore, could
not be reasonably addressed by specific source reduction activities, the amount released is included in
Section 8.8. In this case, much of the EPCRA Section 313 chemical is released as a liquid and pools on
the ground. It is estimated that 1,000 pounds of the EPCRA Section 313 chemical pooled on the ground
and was subsequently collected and sent off-site for treatment. In addition, it is estimated that another 200
pounds of the EPCRA Section 313 chemical vaporized directly to the air from the rupture. The total
amount reported in Section 8.8 is the 1,000 pounds that pooled on the ground (and subsequently sent offsite), plus the 200 pounds that vaporized into the air, a total of 1,200 pounds. The quantity sent off-site
must also be reported in Section 6 (but not in Section 8.7) and the quantity that vaporized must be
reported as a fugitive emission in Section 5 (but not in Section 8.1b).
8.9
Production Ratio or Activity Ratio
For Section 8.9, you must provide either a
production or activity ratio and indicate which type
of ratio you reported using the checkboxes provided.
The production or activity ratio allows year-to-year
changes in release and other waste management
quantities to be viewed within the context of
production. For example, your production ratio lets
data users know whether your releases per unit of
output have gone up or down.
What Variable is Used to Calculate The
Production or Activity Ratio?
To calculate a production or activity ratio, you must
first select the variable(s) on which the ratio will be
based. In all cases, the production or activity ratio
must be based on the variable(s) that best reflect the
output or outcome of the process(es) in which the
EPCRA Section 313 chemical is involved.
Examples of production or activity variables
selected by various industries can be found in
Example 25. Instructions for calculating a
production or activity ratio based on either a single
variable or multiple variables can be found below.
Production Ratio
A production ratio is a ratio of reporting year
production to prior year production. Calculate a
production ratio when the chemical is involved in
production processes. The equation for production
ratio is as follows:
[Production Variable] Current Year
Production Ratio =
[Production Variable] Prior Year
A production ratio may be based on production
levels for either the facility’s end product or on the
intermediate product of the process in which the
chemical is manufactured, processed, or otherwise
used. If an EPCRA Section 313 chemical is used in
the production of refrigerators, for example, the
production ratio would be based on the number of
refrigerators produced. This is shown in Example 22
and in the sample equation below:
# of refrigerators produced Current Year
Example P.R. =
# of refrigerators produced Prior Year
If the EPCRA Section 313 chemical is itself the
final product, the production ratio would be based
on the amount of the chemical manufactured.
Generally, however, the production ratio would be
based on a variable other than the quantity of the
EPCRA Section 313 chemical manufactured,
processed, or otherwise used.
Activity Ratio
Toxics Release Inventory Reporting Forms and Instructions
74
Instructions for Completing Part II of EPA Form R
An activity ratio is also a ratio of current year to
prior year values, but is reported when a chemical is
involved in an activity not directly related to
production or production levels. An activity ratio is
appropriate if a chemical is used in an auxiliary
activity such as cleaning or pollution control, for
example, and is calculated as follows:
[Activity Variable] Current Year
Activity Ratio =
[Activity Variable]
Prior Year
In all cases, the variable used to calculate an activity
ratio should represent the intended outcome of the
activity in which the chemical is used or produced,
not the inputs of throughputs for the activity. If the
EPCRA Section 313 chemical is used to clean
molds, for example, the activity ratio could be based
on the number of cleanings or the number of molds
cleaned. It would not be based on the usage of the
EPCRA Section 313 chemical or the total volume of
cleaning solution used. This is shown in Example 23
and in the sample equation below:
# of Molds Cleaned Current Year
Example A.R. =
# of Molds Cleaned Prior Year
Production or Activity Ratios Based on Multiple
Variables
In some cases, your facility may use the same
EPCRA Section 313 chemical in more than one
process. If there is no single variable that adequately
reflects the output or outcome of the process(es) in
which the reported EPCRA Section 313 chemical is
involved, a production or activity ratio can be
calculated by weighting the different production or
activity variables for the different processes in
which the chemical is involved. The procedure for
this calculation is described in Example 26.
If the reported value is based on both production and
activity variables, you would report the final value
as a “production ratio” if the production ratio(s)
were weighted more heavily than the activity
ratio(s) in the calculations (and as an “activity ratio”
if the opposite were true).
Reporting Tips:
TRI-MEweb includes a production or
activity ratio wizard to help you calculate
your ratio automatically.
The ratio must be reported to the nearest
tenths or hundredths place (i.e., one or two
digits to the right of the decimal point) for
all EPCRA 313 chemicals, including PBT
chemicals. A zero is not an acceptable
response unless the calculated value is less
than 0.005, which can 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. Otherwise, you must enter a value
even if your facility did not exceed a
reporting threshold for the chemical in the
previous reporting year.
The ratio is not to be reported as a percent
change between years (i.e., for a 10 percent
increase, you would report the ratio 1.10,
not10% or 10). A production ratio of 1
indicates no change in production from the
prior year.
It is important to realize that if your facility
reports more than one reported EPCRA
Section 313 chemical, the production or
activity ratio may vary for different
chemicals if the chemicals are used in
different processes with different outputs.
Details regarding the method used to
calculate the Production or Activity Ratio
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
uses toluene to paint refrigerators” in order
to provide more information in Section 9.1.
Toxics Release Inventory Reporting Forms and Instructions
75
Instructions for Completing Part II of EPA Form R
Example 22: Determining a Production Ratio
Your facility’s only use of toluene is as a paint carrier for a painting operation. You painted 12,000
refrigerators in the current reporting year and 10,000 refrigerators during the preceding year. The
production ratio for toluene in this case is 1.2 (12,000/10,000) because refrigerator production levels best
reflect the output of the processes in which toluene is used.
A facility manufactures inorganic pigments, including titanium dioxide. Hydrochloric acid (acid aerosols)
is produced as a waste byproduct during the production process. An appropriate production ratio for
hydrochloric acid (acid aerosols) is the annual titanium dioxide production, not the amount of byproduct
generated. If the facility produced 20,000 pounds of titanium dioxide during the reporting year and 26,000
pounds in the preceding year, the production ratio would be 0.77 (20,000/26,000).
Example 23: Determining an Activity Ratio
Your facility manufactures organic dyes in a batch process. Different colors of dyes are manufactured, and
between color changes, all equipment must be thoroughly cleaned with solvent containing glycol ethers to
reduce color carryover. During the preceding year, the facility produced 2,000 pounds of yellow dye in
January, 9,000 pounds of green dye for February through September, 2,000 pounds of red dye in
November, and another 2,000 pounds of yellow dye in December. This adds up to a total of 15,000
pounds and four color changeovers. During the reporting year, the facility produced 10,000 pounds of
green dye during the first half of the year and 10,000 pounds of red dye in the second half. If your facility
uses glycol ethers in this cleaning process only, an activity ratio of 0.5 (based on two color changeovers
for the reporting year divided by four changeovers for the preceding year) is more appropriate than a
production ratio of 1.33 (based on 20,000 pounds of dye produced in the current year divided by 15,000
pounds in the preceding year). In this case, an activity ratio is more appropriate than a production ratio
because the process in which the glycol ethers are used is not directly related to production or to
production levels.
A facility that manufactures thermoplastic composite parts for aircraft uses toluene as a wipe solvent to
clean molds. The solvent is stored in 55-gallon drums and is transferred to 1-gallon dispensers. The molds
are cleaned on an as-needed basis that is not necessarily a function of the parts production rate. Operators
cleaned 5,200 molds during the reporting year, but only cleaned 2,000 molds in the previous year. An
activity ratio of 2.6 (5,200/2,000) represents the outcome of the activities involving toluene usage in the
facility.
A facility manufactures surgical instruments and cleans the metal parts with 1,1,1-trichloromethane in a
vapor degreaser. The degreasing unit is operated in a batch mode and the metal parts are cleaned
according to an irregular schedule. The activity ratio can be based upon the total time the metal parts are
in the degreasing operation. If the degreasing unit operated 3,900 hours during the reporting year and
3,000 hours the prior year, the activity ratio is 1.3 (3,900/3,000).
Example 24: “NA” is Entered Instead of a Production Ratio or Activity Ratio
Your facility began production of semiconductor chips during this reporting year. Perchloroethylene is
used as a cleaning solvent for this operation and this is the only use of the EPCRA Section 313 chemical
in your facility. You would enter NA in Section 8.9 because you have no basis of comparison in the prior
year for the purposes of developing the activity ratio.
Toxics Release Inventory Reporting Forms and Instructions
76
Instructions for Completing Part II of EPA Form R
Example 25: Selecting a Production or Activity Variable
The table below provides examples of production or activity variables used by facilities in various
industries to calculate a production ratio or activity ratio.
Industry
Agriculture, Construction, and Mining Machinery
Manufacturing
Cement and Concrete Product Manufacturing
Clay Product and Refractory Manufacturing
Chemical and Allied Products Merchant Wholesalers
Coal Mining
Fossil Fuel Electric Power Generation
National Security and International Affairs
Nitrogenous Fertilizer Manufacturing
Plastics Product Manufacturing
Synthetic Dye and Pigment Manufacturing
Waste Treatment and Disposal
Petroleum Refineries
Sample Production / Activity Variable
Drill rigs produced
Tons of clinker produced
Tons of brick manufactured
Total gallons of glycol ethers packaged
Mine production in tons of coal
Number of megawatt-hours of electricity produced
Man-days of training per year
Ammonium thiosulfate product produced (in tons)
Pounds extruded
Number of color changeovers
Tons of waste landfilled on-site
Gallons of gasoline repackaged
Example 26: Determining the Production Ratio Based on a Weighted Average
At many facilities, a reported EPCRA Section 313 chemical is used in more than one production process.
In these cases, a production ratio or activity ratio can be estimated by weighting the production ratio for
each process based on the respective contribution of each process to the quantity of the reported EPCRA
Section 313 chemical managed as waste (recycled, used for energy recovery, treated, or disposed of).
Your facility paints bicycles with paint containing toluene. Sixteen thousand bicycles were produced in
the reporting year and 14,500 were produced in the prior year. There were no significant design
modifications that changed the total surface area to be painted for each bike. The production ratio for
bicycles is 1.1 (16,000/14,500). You estimate 12,500 pounds of toluene was managed as waste (recycled,
used for energy recovery, treated, disposed of or released) as a result of bicycle production processes.
Your facility also uses toluene as a solvent in a glue that is used to make components and add-on
equipment for the bicycles. Thirteen thousand components were manufactured in the reporting year as
compared to 15,000 during the prior year. The production ratio for the components using toluene is 0.87
(13,000/15,000). You estimate 1,000 pounds of toluene was managed as wasted as a result of components
production processes. The reported production ratio can be calculated by weighting the ratios for the
different variables based on the relative contribution each has to the total quantity of toluene managed as
waste during the reporting year (13,500 pounds). The production ratio is calculated as follows:
Production ratio = 1.1 × (12,500/13,500) + 0.87 × (1,000/13,500) = 1.08
Toxics Release Inventory Reporting Forms and Instructions
77
Instructions for Completing Part II of EPA Form R
8.10
Did Your Facility Engage in Any Newly
Implemented Source Reduction Activities for
This Chemical During the Reporting Year?
Section 8.10 must be completed if a source
reduction activity involving the reported EPCRA
Section 313 chemical was newly implemented at
your facility. An activity is considered newly
implemented if it went into effect, in whole or in
part, during this reporting year.
What Is Source Reduction?
Source reduction, as defined by the Pollution
Prevention Act, means any practice that:
Reduces the amount of any hazardous
substance, pollutant, or contaminant entering
any waste stream or otherwise released into the
environment (including fugitive emissions) prior
to recycling, energy recovery, treatment, or
disposal; and
Reduces the hazards to public health and the
environment associated with the release of such
substances, pollutants, or contaminants.
The term “source reduction” does not include any
practice that alters the physical, chemical, or
biological characteristics or the volume of a
hazardous substance, pollutant, or contaminant
through a process or activity that itself is not integral
to and necessary for the production of a product or
the providing of a service.
Source reduction activities include equipment or
technology modifications, process or procedure
modifications, reformulation or redesign of
products, substitution of raw materials, and
improvements in housekeeping, maintenance,
training, or inventory control.
How Does Source Reduction Relate to the
Quantities Reported in Sections 8.1-8.8?
Source reduction activities reduce the amount of the
reported EPCRA Section 313 chemical disposed of
or otherwise released (as reported in Section 8.1),
used for energy recovery (as reported in Sections
8.2–8.3), recycled (as reported in Sections 8.4–8.5),
or treated (as reported in Sections 8.6–8.7).
Recycling, energy recovery, and treatment are not
themselves considered source reduction activities
because these practices occur after the chemical has
entered a waste stream.
The focus of the section includes only those
activities that are applied to reduce routine or
reasonably anticipated releases or other quantities of
the reported EPCRA Section 313 chemical managed
as waste). Thus, you do not report in this section any
activities taken to reduce or eliminate the quantities
reported in Section 8.8.
Why Is Reporting on Source Reduction Activities
Important?
The Pollution Prevention Act established the
national policy “that pollution should be prevented
or reduced at the source whenever feasible...”
Reporting on source reduction activities provides
important information for assessing progress
towards this goal.
To promote pollution prevention, EPA has increased
the prominence and accessibility of the pollution
prevention information reported in Sections 8.10
and 8.11 of the Form R. For example, companies
reporting source reduction are featured in the annual
TRI National Analysis report and the popular new
TRI P2 Search tool. To learn more, visit:
http://www2.epa.gov/toxics-release-inventory-triprogram/pollution-prevention-p2-and-tri.
How Do I Report Source Reduction Activities
and Methods?
Instructions on how to report source reduction
activities (as defined above) and the methods used
to identify such activities are provided below.
TRI-MEweb
If Your Facility Implemented Source
Reduction Activities. If your facility
implemented a new source reduction activity for
the reported EPCRA Section 313 chemical
during the reporting year, report the activity or
activities that were implemented by selecting
the most relevant activity code(s) from the drop
down list in TRI-MEweb (see W-codes listed
below).
For each “Source Reduction Activity” reported,
you must also enter one or more code(s) that
correspond to the internal and external
method(s) or information sources you used to
identify the possibility for implementing a
source reduction activity at your facility. If more
than three methods were used to identify the
source reduction activity, enter only the three
Toxics Release Inventory Reporting Forms and Instructions
78
Instructions for Completing Part II of EPA Form R
codes that contributed most to the decision to
implement the activity.
For each source reduction code you enter in
TRI-MEweb, a button to the right of the entry
opens a text box that allows you to provide
additional details on that source reduction
practice. Similarly, to describe how each source
reduction practice was identified, a button to the
right of the entry opens a text box that allows
you to enter additional information on the
identification method(s) you selected. Optional
additional information about source reduction
provided via these text boxes is then added to
the next section of the Form R (Section 8.11,
Optional Pollution Prevention Information)
preceded by the W- or T-code to which it
relates.
If Your Facility Did Not Implement Source
Reduction Activities. If your facility did not
implement any new source reduction activity for
the reported EPCRA Section 313 chemical,
check the “NA” box in Section 8.10. TRIMEweb then provides a text box that you may
use to provide information on any barriers your
facility might be facing with regard to the
implementation of source reduction activities.
(This information is then added to your entry in
Section 8.11; see Section 8.11 instructions for
additional information on barriers to P2.)
Hard copy Reporting
If Your Facility Implemented Source
Reduction Activities. If using a paper form
(trade secret submissions only), source
reduction activity codes must be entered in the
first column of Sections 8.10.1 through 8.10.4.
Next, indicate any methods to identify the
reported source reduction activity using the Tcodes provided below.
If you have fewer than four source reduction
codes in Section 8.10, an NA should be placed
in the first column of the first unused row to
indicate the termination of the sequence. If all
four rows are used, there is no need to terminate
the sequence. If there are more than four source
reduction codes, photocopy Page 5 of Form R as
many times as necessary and then number the
boxes consecutively for each source reduction
activity. Enter NA when the sequence has
terminated, unless the sequence ends at 4, 8, 12,
16, etc.
If Your Facility Did Not Implement Source
Reduction Activities. If your facility did not
implement any new source reduction activity for
the reported EPCRA Section 313 chemical,
check the “NA” box in Section 8.10.
How Do I Report Estimated Annual Reduction?
For each “Source Reduction Activity” reported, you
have the option to provide an estimate of the
resulting reduction in the annual amount of the
chemical managed as waste (i.e., released, recycled,
treated, or used for 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 pollution 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
beneath the source reduction method codes.
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 the 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 reduction for the
activity is 50%.
Toxics Release Inventory Reporting Forms and Instructions
79
Instructions for Completing Part II of EPA Form R
Source Reduction Activity Codes
Source reduction activity codes are listed below. In
recent years many facilities have implemented green
chemistry and green engineering practices to
prevent pollution. In order to more closely represent
these practices, EPA has developed six new source
reduction codes. These codes are represented as:
W15; W43; W50; W56; W57; and W84 and are
provided in the list of source reductions below.
Scenarios as to when these codes should be used are
provided in Example 28.
Good Operating Practices
W13 Improved maintenance scheduling, record
keeping, or procedures
W14 Changed production schedule to minimize
equipment and feedstock changeovers
W15 Introduced
in-line
product
quality
monitoring or other process analysis system
W19 Other changes made in operating practices
Inventory Control
W21 Instituted procedures to ensure that
materials do not stay in inventory beyond
shelf-life
W22 Began to test outdated material — continue
to use if still effective
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labeling procedures
W25 Instituted clearinghouse to exchange
materials that would otherwise be discarded
W29 Other changes made in inventory control
Spill and Leak Prevention
W31 Improved storage or stacking procedures
W32 Improved procedures for loading,
unloading, and transfer operations
W33 Installed overflow alarms or automatic shutoff valves
W35 Installed vapor recovery systems
W36 Implemented inspection or monitoring
program of potential spill or leak sources
W39 Other changes made in spill and leak
prevention
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
W43 Substituted a feedstock or reagent chemical
with a different chemical
W49 Other raw material modifications made
Process Modifications
W50 Optimized reaction conditions or otherwise
increased efficiency of synthesis
W51 Instituted re-circulation within a process
W52 Modified equipment, layout, or piping
W53 Used a different process catalyst
W54 Instituted better controls on operating bulk
containers to minimize discarding of empty
containers
W55 Changed from small volume containers to
bulk containers to minimize discarding of
empty containers
W56 Reduced or eliminated use of an organic
solvent
W57 Used biotechnology in manufacturing
process
W58 Other process modifications made
Cleaning and Degreasing
W59 Modified stripping/cleaning equipment
W60 Changed to mechanical stripping/cleaning
devices (from solvents or other materials)
W61 Changed to aqueous cleaners (from solvents
or other materials)
W63 Modified containment procedures for
cleaning units
W64 Improved draining procedures
W65 Redesigned parts racks to reduce drag out
W66 Modified or installed rinse systems
W67 Improved rinse equipment design
W68 Improved rinse equipment operation
W71 Other cleaning and degreasing
modifications made
Surface Preparation and Finishing
W72 Modified spray systems or equipment
W73 Substituted coating materials used
W74 Improved application techniques
W75 Changed from spray to other system
W78 Other surface preparation and finishing
modifications made
Product Modifications
W81 Changed product specifications
W82 Modified design or composition of product
W83 Modified packaging
W84 Developed a new chemical product to
replace a previous chemical product
W89 Other product modifications made
Methods to Identify Source Reduction Activities
Toxics Release Inventory Reporting Forms and Instructions
80
Instructions for Completing Part II of EPA Form R
T01
T02
T03
T04
T05
T06
T07
T08
T09
Internal pollution prevention opportunity
audit(s)
External pollution prevention opportunity
audit(s)
Materials balance audits
Participative team management
Employee recommendation (independent of
a formal company program
Employee recommendation (under a formal
company program
State government technical assistance
program
Federal government technical assistance
program
Trade association/industry technical
assistance program
T10
T11
Vendor assistance
Other
Estimated Annual Reduction Range Codes
R1 =
R2 =
R3 =
R4 =
R5 =
R6 =
100% (elimination of the chemical)
greater than or equal to 50%, but less than
100%
greater than or equal to 25%, but less than
50%
greater than or equal 15%, but less than to
25%
greater than or equal 5%, but less than to
15%
greater than 0%, but less than 5%
Toxics Release Inventory Reporting Forms and Instructions
81
Instructions for Completing Part II of EPA Form R
Example 27: Source Reduction
A facility assembles and paints furniture. Both the glue used to assemble the furniture and the paints contain
EPCRA Section 313 chemicals. By examining the gluing process, the facility discovered that a new drum of
glue is opened at the beginning of each shift, whether the old drum is empty or not. By adding a mechanism
that prevents the drum from being changed before it is empty, the need for disposal of the glue is eliminated
at the source. As a result, this activity is considered source reduction.
The painting process at this facility generates a solvent waste that contains an EPCRA Section 313 chemical
that is collected and recovered. The recovered solvent is used to clean the painting equipment. The recycling
activity does not reduce the amount of EPCRA Section 313 chemical recycled, and therefore is not
considered a source reduction activity.
Example 28: Green Chemistry
Six codes that describe green chemistry and green engineering practices were first added to the list of source
reduction activity codes in Reporting Year 2012 These codes are listed below with a description of when to
use each to report a green chemistry or engineering activity.
W15
W43
W50
W56
W57
W84
Introduced in-line product quality monitoring or other process analysis system. Select this code if
the introduction of such a system led to a reduction in the amount of the EPCRA Section 313
chemical generated as waste.
Substituted a feedstock or reagent chemical with a different chemical. Select this code if the EPCRA
Section 313 chemical was a feedstock or reagent chemical and you replaced it (in whole or in part)
with a different chemical.
o For raw material substitutions not at the level of the individual chemical (e.g., the
substitution of natural gas for coal), select instead W42 Substituted raw materials.
o If use of a feedstock or reagent chemical was reduced or eliminated because of a change in
the final product, select instead one of the codes listed under Product Modifications.
Optimized reaction conditions or otherwise increased efficiency of synthesis. Select this code if the
amount of the EPCRA Section 313 chemical generated as waste was reduced by increasing the
overall efficiency of the synthesis.
o If efficiency of syntheses was improved by using of a different catalyst, select instead W53
Used a different process catalyst.
Reduced or eliminated use of an organic solvent. Select this code if the EPCRA Section 313
chemical was used as a solvent in the process and the process was modified such that the EPCRA
Section 313 chemical was either replaced or no longer used in as large a quantity.
Used biotechnology in manufacturing process. Select this code if the use of biotechnology in the
process reduced or eliminated the use of the TRI chemical.
Developed a new chemical product to replace previous chemical product. Select this code if the
EPCRA Section 313 chemical had been produced at the facility but was replaced it (in whole or in
part) with the production of a different chemical or chemicals.
Toxics Release Inventory Reporting Forms and Instructions
82
Instructions for Completing Part II of EPA Form R
8.11
Optional Pollution Prevention
Information
In Section 8.11, you have the opportunity to provide
more detail about activities your facility undertook
to reduce releases of the EPCRA Section 313
chemical, including source reduction, recycling,
energy recovery, treatment or other pollution
controls. EPA encourages you to provide detail in
Section 8.11, as it offers your organization the
opportunity to showcase its achievements in
preventing pollution.
If you are using TRI-MEweb to submit your report,
you can use the provided text boxes to describe your
source reduction, recycling, or pollution control
activities. If you are filing by paper (trade secret
submissions only), you may provide a description in
the box provided on the Form R.
While EPA welcomes submissions about recycling
and pollution control activities, the Agency is most
interested in collecting information about innovative
and effective source reduction activities, such as
green chemistry or green engineering practices. In
addition, the Agency wishes to encourage reporters
to provide enough detailed information about their
most effective source reduction activities to spur
other facilities to adopt similar practices, as well as
to inform the public about such activities being
implemented in their communities.
To encourage submissions with additional pollution
prevention information, EPA is increasing the
prominence and accessibility of this information.
Visit http://www2.epa.gov/toxics-release-inventorytri-program/pollution-prevention-p2-and-tri to learn
how to access this information (e.g., through the P2
Search tool) and to view examples of optional
pollution prevention information highlighted in
EPA’s annual TRI National Analysis report.
The following tips can help you provide meaningful
additional information.
Be Specific:
Which processes and products
affected?
Which technologies and materials
used?
Which release (to air, water land) or
management quantities changed?
Were there other benefits (e.g.,
product quality?)
were
were
waste
Who provided the idea or assisted with
implementation?
Why did you implement this activity?
Enter useful URLs:
For equipment manufacturers
To other information sources related to the
activity described
A tip-sheet with additional guidance and sample
entries
can
be
found
at
http://www2.epa.gov/sites/production/files/documen
ts/tri_p2_tipsheet.pdf. If you wish to provide
additional information that is not related to pollution
prevention or other environmentally friendly
practices, use Section 9.1.
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 environmentallyfriendly practices 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 choose 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:
costs,
Toxics Release Inventory Reporting Forms and Instructions
83
Instructions for Completing Part II of EPA Form R
1. Insufficient capital to install new source
reduction equipment or implement new
source reduction activities/initiatives.
2. Require technical information on pollution
prevention techniques applicable to specific
production processes.
3. Concern that product quality may decline as
a result of source reduction.
4. Source
reduction
activities
were
implemented but were unsuccessful.
5. Specific regulatory/permit burdens
6. Pollution
prevention
previously
implemented- additional reduction does not
appear technically or economically feasible.
7. 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).
EPA believes this information is valuable in giving
a full picture of the source reduction activities your
facility engages in and what barriers you face in the
implementation of source reduction activities. EPA
also believes this information may allow for an
exchange between those that have knowledge of
source reduction practices, such as the EPA P2
Program, and those that are seeking additional help.
In addition, it will better enable EPA to identify
those technological areas for which EPA can
support basic research to identify alternative
technologies that are less polluting.
9.1
Miscellaneous, Optional, and Additional
Information for Your Form R Report
Your facility may provide additional information
pertaining to any portion of your Form R
submission in the box provided 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 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:
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
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., facility
closure, move, temporary shutdown, etc.).
Toxics Release Inventory Reporting Forms and Instructions
84
Instructions for Completing Form R Schedule 1(Dioxin and Dioxin-like Compounds)
D. Instructions for Completing
Form R Schedule 1 (Dioxin and
Dioxin-like Compounds)
D.1
What is the Form R Schedule 1?
The Form R Schedule 1 is an adjunct to the Form R
that mirrors the data elements from Form R Part II
Chemical-Specific Information sections 5, 6, and 8
(current year only) and requires the reporting of the
individual grams data for each member of the dioxin
and dioxin-like compounds category present.
Facilities that file Form R reports for the dioxin and
dioxin-like compounds category are required to
determine if they have any of the information
required by the Form R Schedule 1. Facilities that
have any of the information required by Form R
Schedule 1 must submit individual member data via
the Form R Schedule 1 in addition to the Form R.
D.2
Who is required to file a Form R
Schedule 1?
Only facilities that file reports for the dioxin and
dioxin-like compounds category may be required to
file a Form R Schedule 1. Facilities that have any of
the data required by Form R Schedule 1 for the
individual members of the dioxin and dioxin-like
compounds category must submit a Form R
Schedule 1, in addition to the Form R. EPA notes
that dioxin and dioxin-like compounds are not
measured as a total quantity; the measurements are
based on the individual compounds within the
category. Emission factors for dioxin and dioxinlike compounds are also based on emission factors
for the individual compounds within the category.
EPA’s guidance document for dioxin and dioxinlike compounds (Emergency Planning And
Community Right-To-Know Act - Section 313:
Guidance for Reporting Toxic Chemicals within the
Dioxin and Dioxin-like Compounds Category, EPA745-B-00-021, December 2000) includes tables that
contain the emission factors for the individual
members of the dioxin and dioxin-like compounds
category. Since measured data and emission factor
data are based upon data for the individual members
of the dioxin and dioxin-like compounds category,
the information required by Form R Schedule 1
should be available to facilities that file Form R
reports for the dioxin and dioxin-like compounds
category.
D.3
What information is reported on
the Form R Schedule 1?
The only data reported on the Form R Schedule 1 is
the mass quantity information required in sections 5,
6, and 8 (current year only) of the Form R. All of
the other information required in sections 5, 6, and 8
of the Form R (off-site location names, stream or
water body names, etc.) would be the same so this
information is not duplicated on Form R Schedule 1.
For example, if a facility reported 5.3306 grams on
Form R Section 5.1 for fugitive or non-point air
emissions for the dioxin and dioxin-like compounds
category then the facility would report on the Form
R Schedule 1 the grams data for each individual
member of the category that contributed to the
5.3306 gram total. The sum of the gram quantities
reported for each individual member of the category
should equal the total gram quantity reported for the
category on Form R for each data element (see
examples in Figure 7). The NA box has the same
meaning on Form R Schedule 1 as it does on the
Form R and should only be marked if it is marked
on the Form R.
It is extremely important that facilities enter their
grams data for the individual members of the
category based on the order shown in the Individual
Members of the Dioxin and Dioxin-like
Compounds Category table on page 87. This
information will be used to calculate toxic
equivalency values using toxic equivalency factors
that are specific to each member of the category. As
with reporting on the Form R, facilities should
report on the Form R Schedule 1 to the level of
accuracy that their data supports, up to seven digits
to the right of the decimal. EPA’s reporting software
and data management systems support data
precision to seven digits to the right of the decimal.
Toxics Release Inventory Reporting Forms and Instructions
85
Instructions for Completing Form R Schedule 1(Dioxin and Dioxin-like Compounds)
Form R Section 5 Example
Form R Schedule 1 Section 5 Example
The Form R Schedule 1 provides boxes for recording the gram quantities for all 17 individual members of
the dioxin and dioxin-like compounds category. The boxes on the Form R Schedule 1 for each release type
are divided into 17 boxes. Each of the boxes (1-17) corresponds to the individual members of the dioxin
category as presented in Table I.
Figure 7. Hypothetical Form R, Section 5.1 and Form R Schedule 1, Section 5.1
Toxics Release Inventory Reporting Forms and Instructions
86
Instructions for Completing Form R Schedule 1(Dioxin and Dioxin-like Compounds)
Individual Members of the Dioxin and Dioxin-like Compounds Category
Box # CAS#
Chemical Name
1.
01746–01–6
2,3,7,8-Tetrachlorodibenzo- p-dioxin
2.
40321–76–4
1,2,3,7,8-Pentachlorodibenzo- p-dioxin
3.
39227–28–6
1,2,3,4,7,8-Hexachlorodibenzo- p-dioxin
4.
57653–85–7
1,2,3,6,7,8-Hexachlorodibenzo- p-dioxin
5.
19408–74–3
1,2,3,7,8,9-Hexachlorodibenzo- p-dioxin
6.
35822–46–9
1,2,3,4,6,7,8-Heptachlorodibenzo- p-dioxin
7.
03268–87–9
1,2,3,4,6,7,8,9-Octachlorodibenzo- p-dioxin
8.
51207–31–9
2,3,7,8-Tetrachlorodibenzofuran
9.
57117–41–6
1,2,3,7,8-Pentachlorodibenzofuran
10.
57117–31–4
2,3,4,7,8-Pentachlorodibenzofuran
11.
70648–26–9
1,2,3,4,7,8-Hexachlorodibenzofuran
12.
57117–44–9
1,2,3,6,7,8-Hexachlorodibenzofuran
13.
72918–21–9
1,2,3,7,8,9-Hexachlorodibenzofuran
14.
60851–34–5
2,3,4,6,7,8-Hexachlorodibenzofuran
15.
67562–39–4
1,2,3,4,6,7,8-Heptachlorodibenzofuran
16.
55673–89–7
1,2,3,4,7,8,9-Heptachlorodibenzofuran
17.
39001–02–0
1,2,3,4,6,7,8,9-Octachlorodibenzofuran
D.4
How do I report
Schedule 1 Data?
Form
R
The Electronic Reporting of Toxics Release
Inventory Data rule requires that all Dioxin and
Dioxin-like Compound data must be submitted
electronically via TRI-MEweb (except for reports
containing trade secrets, which must be submitted
on paper). For each data element in Sections 5, 6,
and 8 (current year only), TRI-MEweb has a
clickable button labeled “Schedule 1” that loads a
separate page ‘Release/Transfer Quantities by
Category Member.’ In this page, you can enter the
individual quantities for each category member.
TRI-MEweb will automatically calculate the
category total. If any releases or transfer were due to
non-production-related wastes (see Chapter 2, Part
Abbreviation
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
II, Section 8.8), enter those values on the same page.
If your facility does not have individual member
data, you can select the checkbox labeled “I would
like to enter total grams of Dioxin and Dioxin-like
Compounds” and the “Next” button to enter total
quantities.
When you have finished entering all of your data for
dioxin, use the “Validate” tab's “Data Quality
Analyses” page to view a Dioxin Toxic Equivalency
(TEQ) Calculation report. This report multiplies the
quantity for each individual category member by its
toxic equivalency factor (TEF) to determine the
total TEQ value for each section of the Form R
Schedule 1 for which data were provided.
Toxics Release Inventory Reporting Forms and Instructions
87
Facility Eligibility Determination for Alternate Threshold
and for Reporting on TRI Form A Certification Statement
E.
Facility Eligibility
Determination for Alternate
Threshold and for
Reporting on TRI Form A
Certification Statement
This section will help to determine whether you can
submit the simplified Form A Certification
Statement (hereafter referred to as Form A). The
criteria are based on the total annual reportable
amount of the listed chemical or chemical category
and the amount manufactured, processed, or
otherwise used. Note that, effective in Reporting
Year 2008, the TRI Burden Reduction Rule has
been voided by Congress. The criterion for using
Form A has returned to what they were prior to
Reporting Year 2006. The criteria are explained
below. For more information about the final rule,
see
the
TRI
homepage
at:
http://www2.epa.gov/toxics-release-inventory-triprogram/tri-laws-rulemakings-and-notices.
.
E.1
Alternate Threshold
On November 30, 1994, EPA published a final rule
(59 FR 61488) that provides qualifying facilities an
alternate threshold of 1 million pounds. Eligible
facilities wishing to take advantage of this option
may certify on a simplified two-page form referred
to as Form A Certification Statement and do not
have to use Form R. The "TRI Alternate Threshold
for Facilities with Low Annual Reportable
Amounts," provides facilities otherwise meeting
EPCRA section 313 reporting thresholds the option
of certifying on Form A provided that they do not
exceed 500 pounds for the total annual reportable
amount (defined below) for that chemical, and that
their amounts manufactured or processed or
otherwise used do not exceed one-million pounds.
As with determining section 313 reporting
thresholds, amounts manufactured, processed, or
otherwise used are to be considered independently.
This modification does not apply to forms being
submitted on or before July 1, 1995 (covering the
1994 reporting year). If you fill out a Form A for an
EPCRA section 313 chemical, do not fill out a Form
R for that same chemical.
reporting lead in stainless steel, brass or bronze
alloys) are excluded from eligibility for the alternate
threshold.
E.2
What is the Form A Certification
Statement?
The Form A, which is described as the “certification
statement” in 59 FR 61488, is intended as a means
to reduce the compliance burden associated with
EPCRA section 313. If a facility chooses to use
Form A as a substitute for Form R for any eligible
chemical, it must be submitted on an annual basis.
Facilities wishing to take advantage of this burden
reducing option may only submit Form A for
chemicals that meet the conditions described in
section E.1, Alternate Threshold, and should not
submit a Form R to the TRI Data Processing Center
for the same chemicals. The information submitted
on the Form A includes facility identification
information and the chemical or chemical category
identity. The information submitted on the Form A
will appear in the TRI data base in the same manner
that information submitted on Form R appears. An
approved Form A can be accessed via TRI-MEweb
or from the EPA TRI website.
E.3 What Is the Annual Reportable
Amount (ARA)?
For the purpose of this optional reporting
modification, the annual reportable amount (ARA)
is equal to the combined total quantities released at
the facility (including disposed of within the
facility), treated at the facility (as represented by
amounts destroyed or converted by treatment
processes), recovered at the facility as a result of
recycling operations, combusted for the purpose of
energy recovery at the facility, and amounts
transferred from the facility to off-site locations for
the purpose of recycling, energy recovery,
treatment, and/or disposal. These quantities
correspond to the sum of amounts reportable for
data elements on EPA Form R (EPA Form 9350-1;
Rev.10/09) as Part II column B of section 8, data
elements 8.1 (quantity released), 8.2 (quantity used
for energy recovery on-site), 8.3 (quantity used for
energy recovery off-site), 8.4 (quantity recycled
onsite), 8.5 (quantity recycled off-site), 8.6 (quantity
treated on-site), and 8.7 (quantity treated off-site).
However, there is an exception to the alternate
threshold rule described in the preceding paragraph.
All PBT chemicals (except certain instances of
Toxics Release Inventory Reporting Forms and Instructions
88
Facility Eligibility Determination for Alternate Threshold
and for Reporting on TRI Form A Certification Statement
E.4
Recordkeeping
Each owner or operator who determines that they
are eligible, and wishes to apply the alternate
threshold to a particular chemical, must retain
records substantiating this determination for a
period of three years from the date of the submission
of the Form A. These records must include
sufficient documentation to support calculations as
well as the calculations made by the facility that
confirm their eligibility for each chemical for which
the alternate threshold was applied.
A facility that fits within the category description,
and manufactures, processes or otherwise uses no
more than one million pounds of an EPCRA Section
313 chemical annually, and whose owner/operator
elects to take advantage of the alternate threshold, is
not considered an EPCRA Section 313 covered
facility for that chemical for the purpose of
submitting a Form R. This determination may
provide further regulatory relief from other federal
or state regulations that apply to facilities on the
basis of their EPCRA Section 313 reporting status.
A facility will need to reference other applicable
regulations to determine if their actual requirements
may be affected by this reporting modification.
E.5
Do not submit
trade secret reports electronically.
E.7
Trade Secrets
When making a trade secret claim on a Form A
submission, EPA is requiring that a facility submit a
unique Form A for each EPCRA Section 313
chemical meeting the conditions of the alternate
threshold. Facilities may assert a trade secrecy claim
for a chemical identity on the Form A as on the
Form R. Reports submitted on a per chemical basis
protect against the disclosure of trade secrets. Form
As with trade secrecy claims, like Form Rs with
similar claims, will be separately handled upon
Metals and Metal Category
Compounds
For metal category compounds, the amount applied
toward the ARA is the amount of parent metal waste
that is reported on Form R, but the thresholds apply
to the amount of metal category compounds
manufactured, processed, or otherwise used. For
Form A certification involving both listed parent
metals and associated metal compounds, the one
million pound alternate threshold must be applied
separately to the listed parent metal and the
associated
metal
compound(s).
Threshold
determinations must be made independently for
each because they are separately listed EPCRA
Section 313 chemicals.
If the threshold is exceeded for the listed parent
metal but not the associated metal category
compounds, then the releases of metal reported
on Form R for the parent metal need not include
the releases from the metal category
compounds.
If both the parent metal and the associated metal
compounds exceed the alternate threshold, then
the facility has the option of filing one Form R
for both, using the metal category compound
name and reporting total releases based on
parent metal content.
If neither the parent metal nor the associated
metal compounds exceed the alternate threshold,
then the facility must use a separate listing on
Form A for each, since the reporting thresholds
must be applied to each listed parent metal and
all compounds in the associated compound
category. EPA believes it is appropriate to make
the distinction between filing the Form R and
Form A because the Form R accounts for
amounts of metal released or otherwise
managed and Form A verifies that the alternate
threshold for each listed chemical or chemical
category has not been exceeded.
Multi-establishment Facilities
For the purposes of using Form A, the facility must
also make its determination based upon the entire
facility’s operations including all of its
establishments (see 59 FR 61488 for greater detail).
If the facility as a whole is able to take advantage of
the alternate threshold, a single Form A is required.
The eligibility to submit a Form A must be made on
a whole facility determination. Thus, all of the
information necessary to make the determination
must be assembled to the facility level.
E.6
receipt to protect against disclosure. Commingling
trade secret chemical identities with non-trade secret
chemical identities on the same submission
increases the risk of disclosure.
Toxics Release Inventory Reporting Forms and Instructions
89
Facility Eligibility Determination for Alternate Threshold
and for Reporting on TRI Form A Certification Statement
Similarly, separate listings on Form A must be
submitted for all other listed chemicals even if EPA
allows one listing on Form R to be filed for two or
more listed chemicals (e.g., o-xylene, p-xylene and
xylene (mixed isomers)). For example, if a facility
processes in three separate process streams, xylene
(mixed isomers), o-xylene, and p-xylene, and
exceeds the conditions of the alternate threshold for
each of these listed substances, the facility may
combine the appropriate information on the oxylene, p-xylene, and xylene (mixed isomers) into
one Form R, but cannot combine the reports into
one listing on Form A.
Facilities that process o-xylene, p-xylene, and
xylene (mixed isomers) in separate process streams
and do not exceed the conditions of the alternate
threshold for one or more of the compounds may
submit a separate Form A for each of the forms of
xylene meeting the alternate threshold and report on
Form R for those forms that do not. Similar to
reporting on the parent metals and their associated
category compounds described above, facilities that
separately process all types (i.e., isomers) of xylene
with individual activity levels within the conditions
of the alternate threshold should file a separate Form
A for each type of xylene.
Beginning with the 1998 reporting year, facilities
may enter as many chemicals as are eligible on a
single Form A Certification Statement.
Toxics Release Inventory Reporting Forms and Instructions
90
Instructions for Completing TRI Form A Certification Statement
F.
Instructions for Completing
TRI Form A Certification
Statement
The following instructions provide information on
how to enter data on a Form A.
Part I.
Facility Identification
Information
Section 1.
Reporting Year
The reporting year is the calendar year to which the
reported information applies, not the year in which
you are submitting the report. Information for the
2014 reporting year must be submitted on or before
July 1, 2015.
Section 2.
Trade Secret Information
Trade secret submission is not supported by TRIMEweb. As such, the following sections are not to
be completed by TRI-MEweb users. These sections
reflect steps performed by trade secret filers only.
2.1
Are you claiming the EPCRA Section 313
chemical identified on Page 3 a trade
secret?
If facilities wish to report more than one eligible
chemical on the same Form A, then they are not able
to make trade secrecy claims. Any trade secrecy
claims should be made on a separate form, and then
the process is the same as using the Form R and as
described in the following instructions.
Answer this question only after you have completed
the rest of the report. The specific identity of the
EPCRA Section 313 chemical being reported in Part
II, Section 1 may be designated as a trade secret. If
you are making a trade secret claim, mark “yes” and
proceed to Section 2.2. Only check “yes” if you
manufacture, process, or otherwise use the EPCRA
Section 313 chemical whose identity is a trade
secret. (See Section A.3 of these instructions for
specific information on trade secrecy claims.) If you
checked “no,” you should submit your non-trade
secret form data electronically using TRI-MEweb.
2.2
If “yes” in 2.1, is this copy sanitized or
unsanitized?
Answer this question only after you have completed
the rest of the report. Check “sanitized” if this copy
of the report is the public version that does not
contain the EPCRA Section 313 chemical identity
but does contain a generic name that is structurally
descriptive in its place, and if you have claimed the
EPCRA Section 313 chemical identity trade secret
in Part I, Section 2.1. Otherwise, check
“unsanitized.”
Section 3.
Certification
The Form A Certification Statement must be signed
by a senior official with management responsibility
for the person (or persons) completing the form. A
senior management official must certify the
accuracy and completeness of the information
reported on the form by signing and dating the Form
A. Unlike the certification statement contained on
Form R, the certification statement provided on the
Alternate Threshold Form A pertains to the facility’s
eligibility of having met the conditions as described
in 40 CFR Section 372.27.
Electronic certification of completed forms prepared
using TRI-MEweb is performed by certifying
officials who have signed an Electronic Signature
Agreement (ESA) and TRIFID Certification
Agreement. For more information regarding
certification of forms, see Section A.2.
Section 4.
4.1
Facility Identification
Facility Name, Location, TRI Facility
Identification Number and Tribal
Country Name
Enter the full name that the facility presents to the
public and its customers in doing business (e.g., the
name that appears on invoices, signs, and other
official business documents). Do not use a nickname
for the facility (e.g., Main Street Plant) unless that is
the legal name of the facility under which it does
business. Also enter the physical street address,
mailing address, city, county, three digit BIA code,
if applicable, state, and ZIP code in the space
provided. The street address provided must be the
location where the EPCRA Section 313 chemicals
are manufactured, processed, or otherwise used.
You may not use PO Box as a facility address. If
your mailing address and street address are the
same, you should enter NA in the space for the
mailing address. If the mailing address is outside of
the US, include the FIPS country code, which may
be found in Table IV.
If your facility is not in a county, put the name of
your city, district (for example, District of
Toxics Release Inventory Reporting Forms and Instructions
91
Instructions for Completing TRI Form A Certification Statement
Columbia), or parish (if you are in Louisiana) in the
county block of the Form R and Form A as well as
in the county field of TRI-MEweb. “NA” or “None”
are not acceptable entries. TRI-MEweb provides a
drop-down menu for the county name, including
city districts and parish names.
year, or by submitting the TRIFID and technical
contact information.
If your facility is located on Indian country as
defined by 18 USC §1151 you must enter the three
digit Bureau of Indian Affairs (BIA) tribal code in
the “City/County/Tribe/State/ZIP code” field. The
BIA tribal codes are listed in Table V of the RFI.
Facilities using TRI-MEweb to complete their forms
will be asked if they are located within a tribe’s
Indian country and, upon answering “yes”, be taken
to a look-up table to determine the correct BIA
code.
Hard copy paper Form A (trade secret submissions
only): If your facility has moved, do not enter your
previously assigned TRI Facility Identification
Number, enter “New Facility”. If you are uncertain
if a TRIFID has been assigned to your new facility
location, use Envirofacts on the Web to look up the
address or facility name at:
http://www.epa.gov/enviro.
If your facility is not located (overwhelming
majority of TRI facilities are not in Indian Country)
in Indian country as defined by 18 USC §1151 you
must enter only the city, county (as applicable), state
and zip code. Facilities filing a trade secret paper
form should leave a blank in the BIA field if the
facility is not located within tribal boundaries.
Facilities using TRI-MEweb to complete their forms
will be required to check a specific checkbox if they
are located within tribal lands and if they do not
check that checkbox.
Location information for a facility that has
previously submitted data to EPA.
If your facility has submitted a Form R or A in
previous reporting years, a TRI Facility
Identification Number (TRIFID) has already been
assigned to your facility. If you do not know your
facility’s information used in prior years
submissions, contact your Regional TRI Program
representative, or utilize Envirofacts on the Web to
look up the address, facility name, or TRIFID at:
http://www.epa.gov/enviro.
Hard copy paper Form A (trade secret submissions
only): Enter your TRIFID in Part I, Section 4.1.
TRI-MEweb: If you have previously submitted data
for your facility using TRI-MEweb, the facility
information including TRIFID remains with your
profile. If you have not submitted using TRIMEweb, then you can add your facility to your
profile using the 6-digit access key, which is emailed to all technical contacts, preparers, and
certifying officials at facilities reporting for the prior
Location information for a facility that has
previously submitted data to EPA, but has
changed physical location.
TRI-MEweb: If your facility has moved, you will
need to request that a new TRIFID be assigned to
your facility. To request a new TRIFID, add a new
facility account to TRI-MEweb and choose to report
as a new reporting facility (option 3). TRI-MEweb
will automatically generate a new TRIFID for your
facility.
The TRIFID assigned to your new
reporting facility should be used in all future
reporting of TRI data.
Location information for a facility that has
changed ownership, but has not changed physical
location.
The TRI Facility Identification Number (TRIFID) is
established by the first Form R or A submitted by a
facility at a particular location. Only a change in
address warrants filing as a new facility; otherwise,
the TRI Facility Identification Number is retained
by the facility even if the facility changes name,
ownership, production processes, NAICS codes, etc.
Hard copy paper Form A (trade secret submissions
only): The TRIFID will always stay with the
physical location of a facility. If a new facility unit
moves to this location it should use this TRIFID.
Establishments of a facility (for facilities that report
by part) that report separately should use the
TRIFID of the primary facility.
TRI-MEweb:
If your facility has changed
ownership during the reporting year but not its
physical location, the facility does not require a new
TRIFID. Use the TRIFID assigned to the previous
owner. TRI-MEweb can be used to update facility
information due to a change of ownership.
Toxics Release Inventory Reporting Forms and Instructions
92
Instructions for Completing TRI Form A Certification Statement
TRI-MEweb: If your facility is reporting for the
first time, upon creating your CDX account, and
adding the TRI-MEweb application, you will be
prompted to add a new facility account into TRIMEweb. TRI-MEweb will automatically generate a
new TRIFID for your facility.
The TRIFID
assigned to your new reporting facility should be
used in all future reporting of TRI data.
rather than a general number for the facility. An
email address should also be entered for this person.
EPA encourages facilities to provide an email
address for the Technical Contact on their TRI
submissions because they will be able to receive
important program updates and email alerts
notifying them when their eFDP has been updated
and published for their review. If the technical
contact does not have an email address, leave the
field blank. This contact person does not have to be
the same person who prepares the report or signs the
certification statement and does not necessarily need
to be someone at the location of the reporting
facility. However, this person should be familiar
with the details of the report so that he or she can
answer questions about the information provided.
As facilities may report unique technical contacts
for each form, technical contact details are entered
in TRI-MEweb with chemical-specific data rather
than facility-identification information.
4.2
4.4
Location reporting TRI releases for the first time
to EPA.
Hard copy paper Form A Certification Statement
(trade secret submissions only): If you are
preparing a hard copy TRI form for the first time for
your facility's location and have never reported to
TRI in previous years, you should enter “New
Facility” in the space on the hard copy form
designated for the TRI Facility Identification
number (TRIFID).
Federal Facility Designation
Executive Order 13423 directs federal facilities to
comply with Right-To-Know Laws and Pollution
Prevention Requirements. In TRI-MEweb, users
should select the appropriate button for: 1) federal
facility (Section 4.2c), 2) GOCO facility (Section
4.2d), or 3) neither. Federal facilities should select
only ‘federal facility’ even if their TRI reports
contain release and other waste management
information from contractors located at the facility.
Contractors at federal facilities that are required by
EPCRA Section 313 to file TRI reports
independently of the federal facility, should select
GOCO. This information is important to prevent
duplication of federal facility data. (See Appendix A
for further guidance on these instructions.)
Note that the reporting by part option is not
applicable for facilities submitting a Form A for a
TRI chemical. Unlike the Form R, the Form A does
not utilize Sections 4.2a or 4.2b which provide the
option of reporting full or partial facility information
if the facility is composed of several distinct
establishments.
4.3
Technical Contact
In TRI-MEweb, facilities must enter the name and
telephone number (including area code) of a
technical representative whom EPA, state, or tribal
officials may contact for clarification of the
information reported on Form A. If possible, this
number should be for the technical representative
Public Contact
In TRI-MEweb, facilities must enter the name and
telephone number (including area code) of a person
who can respond to questions from the public about
the form. You should also enter an e-mail address
for this person. If the public contact does not have
an email address, leave the field blank. If you
choose to designate the same person as both the
Technical and the Public Contact, or you do not
have a Public Contact, you may enter “Same as
Section 4.3” in this space. This contact person does
not have to be the same person who prepares the
form or signs the Certification Statement and does
not necessarily need to be someone at the location of
the reporting facility. As facilities may report unique
public contacts for each form, public contact details
are entered in TRI-MEweb with chemical-specific
data rather than facility-identification information.
4.5
North American Industry Classification
System (NAICS) Code
Enter the appropriate six-digit North American
Industry Classification System (NAICS) Code that
is the primary NAICS Code for your facility in
Section 4.5(a). Use 2012 NAICS codes for RY 2013
and 2014 reporting and 2007 NAICS codes for RY
2006 – 2012 reporting. Enter any other applicable
NAICS for your facility in 4.5 (b)-(f), also called
“secondary NAICS codes” in TRI-MEweb. If you
do not know your NAICS code(s), consult the 2012
NAICS Manual or check the SIC to NAICS
crosswalk tables at: http://www.census.gov.
Toxics Release Inventory Reporting Forms and Instructions
93
Instructions for Completing TRI Form A Certification Statement
The North American Industry Classification System
(NAICS) is the economic classification system that
replaced the 1987 SIC code system. A Federal
Register notice was published on June 6, 2006 (71
FR 32464) adopting 2007 NAICS codes for TRI
reporting. A direct final rule was published July 18,
2013 (78 FR 42875), adopting 2012 NAICS codes
for RY 2013 and subsequent years. Table I lists all
industries that are covered under EPCRA 313 and
their corresponding 2012 NAICS codes.
4.6
Dun & Bradstreet Number(s)
Enter the nine-digit number assigned by Dun &
Bradstreet (D&B) for your facility or each
establishment within your facility. These numbers
code the facility for financial purposes. This number
may be available from your facility’s treasurer or
financial officer. You can also obtain the numbers
from Dun & Bradstreet by calling 1-888-814-1435,
or by visiting this website:
https://www.dnb.com/product/dlw/form_cc4.htm. If
a facility does not subscribe to the D&B service, a
number can be obtained, toll free at 800 234-3867
(8:00 AM to 6:00 PM, EST) or on the Web at:
http://www.dnb.com. If none of your establishments
has been assigned a D&B number, you should check
“D&B Numbers Not Applicable.” If only some of
your establishments have been assigned D&B
numbers, enter those numbers in Part I, section 4.6.
Section 5. Parent Company
Information
You must provide information on your parent
company. For TRI Reporting purposes, your parent
company is as the highest level company, located in
the United States, and that directly owns at least 50
percent of the voting stock of your company. If
there is no higher level U.S. company, select the
“No U.S. Parent Company parent (for TRI reporting
purposes)” check box. Corporate names should be
treated as parent company names for companies
with multiple facility sites. For example, the
Bestchem Corporation is not owned or controlled by
any other corporation but has sites throughout the
country whose names begin with Bestchem. In this
case, Bestchem Corporation should be listed as the
parent company. Note that a facility that is a 50:50
joint venture is its own parent company. When a
facility is owned by more than one company and
none of the facility owners directly owns at least 50
percent of its voting stock, the facility should
provide the name of the parent company of either
the facility operator or the owner with the largest
ownership interest in the facility.
5.1
Name of Parent Company
Enter the name of the corporation or other business
entity that is your highest level U.S. parent
company. If your facility has no higher level U.S.
company, select the “No U.S. Parent Company (for
TRI reporting purposes)” check box.
To improve data quality, TRI standardizes parent
company names. TRI-MEweb is preloaded with the
standardized parent company names. A full list of
parent company names for RY 2014 is available for
download at: http://www2.epa.gov/toxics-releaseinventory-tri-program/standardized-parentcompany-names-ry-2014-tri-reporting.
5.2
Parent Company’s Dun & Bradstreet
Number
Enter the D&B number for your ultimate U.S.
parent company, if applicable. The number may be
obtained from the treasurer or financial officer of
the company or by calling 1-888-814-1435, or by
visiting this website:
https://www.dnb.com/product/dlw/form_cc4.htm. If
your parent company does not have a D&B number,
you should check “Parent Company D&B Number
Not Applicable.”
Toxics Release Inventory Reporting Forms and Instructions
94
Instructions for Completing TRI Form A Certification Statement
Part II. Chemical Identification
Reporting on the Alternate Threshold Form A
Certification Statement for metals, metal category
compounds, and mixed isomers differs somewhat
from Form R reporting. Please refer to Section E.7
for these guidelines.
Section 1.
1.1
Toxic Chemical Identity
CAS Number
Initiating a Form A for a chemical or chemical
category in TRI-MEweb automatically completes
this section.
If you are making a trade secret claim, you must
report the CAS number or category code on your
unsanitized Form A and unsanitized substantiation
form. Enter the CAS registry number exactly as it
appears in Table II of these instructions for the
chemical being reported. CAS numbers are crossreferenced with an alphabetical list of chemical
names in Table II. If you are reporting one of the
EPCRA Section 313 chemical categories (e.g.,
chromium compounds), you should enter the
applicable category code in the CAS number space.
EPCRA Section 313 chemical category codes are
listed below and can also be found in Table IIc.
Do not include the CAS number or category code
on your sanitized Form A or sanitized
substantiation form.
1.2
EPCRA Section 313 Chemical or
Chemical Category Name
Initiating a Form A for a chemical or chemical
category in TRI-MEweb automatically completes
this section.
If you are making a trade secret claim, you must
report the specific EPCRA Section 313 chemical
identity on your unsanitized Form A and
unsanitized substantiation form. Enter the name of
the EPCRA Section 313 chemical or chemical
category exactly as it appears in Table II. If the
EPCRA Section 313 chemical name is followed by
a synonym in parentheses, report the chemical by
the name that directly follows the CAS number
(i.e., not the synonym). If the EPCRA Section 313
chemical identity is actually a product trade name
(e.g., Dicofol), the Chemical Abstracts 9th
Collective Index name is listed below it in brackets.
You may report either name in this case.
Do not list the name of a chemical that does not
appear in Table II, such as individual members of
an EPCRA Section 313 chemical category. For
example, if you use silver chloride, do not report
silver chloride with its CAS number. Report this
chemical as “silver compounds” with its category
code, N740.
Do not report the name of the EPCRA Section 313
chemical on your sanitized Form A or sanitized
substantiation form. Include a generic name that is
structurally descriptive in Part II, Section 1.3 of
your sanitized Form A report.
1.3
Generic Chemical Name
Complete Section 1.3 only if you are claiming the
specific EPCRA Section 313 chemical identity of
the EPCRA Section 313 chemical as a trade secret
and have marked the trade secret block in Part I,
Section 2.1 on Page 1 of Form A. Enter a generic
chemical name that is descriptive of the chemical
structure. You should limit the generic name to 70
characters (e.g., numbers, letters, spaces,
punctuation) or less. Do not enter mixture names in
Section 1.3; see Section 2 below.
In-house plant codes and other substitute names
that are not structurally descriptive of the EPCRA
Section 313 chemical identity being withheld as a
trade secret are not acceptable as a generic name.
The generic name must appear on both sanitized
and unsanitized Form As, and the name must be
the same as that used on your substantiation forms.
Section 2.
Mixture Component
Identity
Complete this section only if you are reporting for
an EPCRA 313 chemical whose identity has been
withheld by the chemical supplier. You do not need
to supply trade secret substantiation forms for this
EPCRA Section 313 chemical because it is your
supplier who is claiming the chemical identity a
trade secret.
2.1
Generic Chemical Name Provided by
Supplier
Enter the generic chemical name in this section
only if the following three conditions apply:
1.) You determine that the mixture
contains an EPCRA Section 313 chemical but the
Toxics Release Inventory Reporting Forms and Instructions
95
Instructions for Completing TRI Form A Certification Statement
only identity you have for that chemical is a
generic name;
2.) You know either the specific
concentration of that EPCRA Section 313 chemical
component or a maximum or average concentration
level; and
3.) You multiply the concentration level by
the total annual amount of the whole mixture
processed or otherwise used and determine that you
meet the process or otherwise use threshold for that
single, generically identified mixture component.
To begin a TRI Form A for a generic chemical in
TRI-MEweb, click the “create a form for a
Generic Chemical Name Provided by Supplier”
link from the “Add New Chemical Forms” search
page, then enter generic chemical name. The
generic chemical name may not be that of a listed
TRI chemical or chemical category and must be
less than 70 characters in length. Facilities may
also use the Import Data tool to set up a reporting
form for a generic chemical reported in prior years.
Toxics Release Inventory Reporting Forms and Instructions
96
Optional Facility-Level Information
G. Optional Facility-Level
Information
Although there is no requirement to inform the
EPA of updates to a facility’s contact and location
information outside of what is required on a TRI
reporting form, each year some facilities
voluntarily elect to provide this information to the
EPA. Additionally, each reporting year some
facilities contact EPA to indicate that they will no
longer be reporting to TRI or will not be submitting
a form for one or more specific TRI-listed
chemicals.
As of January 2015, facilities can use TRI-MEweb
to provide optional facility-level information for
the following categories:
Facility name has changed
Facility technical contact has changed
Facility public contact has changed
Facility has relocated to a new physical
address
Facility merged with another location
Facility has closed
Facility was temporarily shut down
Facility did not have 10 or more full-time
employee equivalents
Facility is not in a covered NAICS sector
Facility fell below reporting threshold for
one or more chemicals due to source
reduction
Facility fell below reporting threshold for
one or more chemicals due to reason(s)
other than source reduction
Toxics Release Inventory Reporting Forms and Instructions
97
Index
Index
Ancillary or other use, 42
article component, 41
byproduct, 41
Catastrophic Events, 74
chemical processing aid, 41
Coal Extraction Activities Exemption, 22
Coincidental Manufacture, 13, 14
Container Residue, 57
De Minimis Exemption, 18
Discharges to Receiving Streams or Water
Bodies, 45, 46
Dun & Bradstreet, 37, 94
Energy Recovery, 58, 61, 65, 66, 68
EPA Identification Number, 53
EPCRA, ii, iv, 1, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15,
16, 17, 18, 19, 20, 22, 23, 24, 25, 26, 27, 28, 29,
30, 31, 32, 33, 34, 35, 36, 39, 40, 41, 42, 43, 44,
45, 46, 47, 48, 49, 50, 52, 53, 54, 55, 57, 58, 61,
62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73,
74,75, 76, 77, 78, 79, 82, 83, 89, 91, 93, 95, 96
Facility Identification, 91
Form A, 88
formulation component, 41
Full-Time Employee, 10
Import, 41
impurity, 41
Laboratory Activities Exemption, 22
Manufacture, 13, 15, 20, 22, 41
manufacturing aid, 42
Metal Category Compounds, 26
Metal Mining Overburden Exemption, 22
Mixture Component Identity, 29
Nitrate Compounds, 28
On-Site Recycling Codes, 66
Other Disposal, 47
Other Surface Impoundments, 47
Otherwise Use, 13, 14, 15, 17, 20, 41
PBT, i, 15, 16, 17, 18, 19, 20, 23, 24, 25, 27, 30,
31, 32, 33, 40, 43, 44, 45, 48, 52, 53, 54, 55, 66,
69
Process, 6, 13, 15, 20, 41
Produce, 41
Production Ratio, 76
RCRA Subtitle C landfills, 47
RCRA Subtitle C Surface Impoundments, 47
reactant, 41
Repackaging, 41
Reporting Year, 30, 31, 32, 33, 69
sale/distribution, 41
Source Reduction, 82
Stormwater Runoff, 52
Surface Impoundments, 47
Technical Contact, 37, 93
Threshold Determinations, 23
Total Transfers, 54
Trade Secret, 4, 34, 91
Underground Injection, 47, 59
Waste Treatment Codes, 64
Toxics Release Inventory Reporting Forms and Instructions
98
Table I. NAICS Codes
1.1
NAICS codes that
correspond to SIC codes 20
through 39:
311340
Nonchocolate Confectionery Manufacturing
(except facilities primarily engaged in the
retail sale of candy, nuts, popcorn and other
confections not for immediate consumption
made on the premises)
311
Food Manufacturing
311411
Frozen Fruit, Juice, and Vegetable
Manufacturing
3111
Animal Food Manufacturing
311412
Frozen Specialty Food Manufacturing
31111
Animal Food Manufacturing
31142
311111
Dog and Cat Food Manufacturing
Fruit and Vegetable Canning,
Pickling and Drying
311119
Other Animal Food Manufacturing (except
facilities primarily engaged in Custom Grain
Grinding for Animal Feed)
311421
Fruit and Vegetable Canning
311422
Specialty Canning
311423
Dried and Dehydrated Food Manufacturing
3115
Dairy Product Manufacturing
31151
Dairy Product (except
Frozen) Manufacturing
311511
Fluid Milk Manufacturing
311512
Creamery Butter Manufacturing
311513
Cheese Manufacturing
311514
Dry, Condensed, and Evaporated Dairy
Product Manufacturing
31152
Ice Cream and Frozen
Dessert Manufacturing
311520
Ice Cream and Frozen Dessert
Manufacturing
3112
Grain and Oilseed Milling
31121
Flour Milling and Malt
Manufacturing
311211
Flour Milling
311212
Rice Milling
311213
Malt Manufacturing
31122
Starch and Vegetable Fats
and Oils Manufacturing
311221
Wet Corn Milling
311224
Soybean and Other Oilseed Processing
311225
Fats and Oils Refining and Blending
31123
Breakfast Cereal Manuf.
311230
Breakfast Cereal Manufacturing
3116
3113
Sugar and Confectionery
Product Manufacturing
Animal Slaughtering and
Processing
31161
31131
Sugar Manufacturing
Animal Slaughtering and
Processing
311313
Beet Sugar Manufacturing
311611
311314
Cane Sugar Manufacturing
Animal (except Poultry) Slaughtering
(except for facilities primarily engaged in
Custom Slaughtering for individuals)
31133
Confectionery Manufacturing
from Purchased Chocolate
311612
31134
Nonchocolate Confectionery
Manufacturing
Meat Processed from Carcasses [except for
facilities primarily engaged in the cutting up
and resale of purchased fresh carcasses for
the trade (including boxed beef)]
311613
Rendering and Meat Byproduct Processing
311615
Poultry Processing
Toxics Release Inventory Reporting Forms and Instructions
I-1
Table I. NAICS Codes
3117
Seafood Product Preparation
and Packaging
31199
All Other Miscellaneous Food
Manufacturing
311710
Seafood Product Preparation and Packaging
311991
Perishable Prepared Food Manufacturing
311999
All Other Miscellaneous Food
Manufacturing
Beverage and Tobacco
Product Manufacturing
3118
Bakeries and Tortilla
Manufacturing
312
31181
Bread and Bakery Product
Manufacturing
3121
311812
Commercial Bakeries
31211
311813
Frozen Cakes, Pies, and Other Pastries
Manufacturing
Soft Drink and Ice
Manufacturing
312111
Soft Drink Manufacturing
31182
Cookie, Cracker, and Pasta
Manufacturing
311821
Cookie and Cracker Manufacturing
311824
Dry Pasta ,Dough, and Flour Mixes
Manufacturing from Purchased Flour
312112
Beverage Manufacturing
Bottled Water Manufacturing (except
facilities primarily engaged in bottling
mineral or spring water)
312113
Ice Manufacturing
31212
Breweries
312120
Breweries
31183
Tortilla Manufacturing
31213
Wineries
311830
Tortilla Manufacturing
312130
Wineries
3119
Other Food Manufacturing
31214
Distilleries
31191
Snack Food Manufacturing
312140
Distilleries
311911
Roasted Nuts and Peanut Butter
Manufacturing
3122
Tobacco Manufacturing
311919
Other Snack Food Manufacturing
31192
Coffee and Tea
Manufacturing
311920
Coffee and Tea Manufacturing
31221
Tobacco Stemming and
Redrying
312210
Tobacco Stemming and Redrying
31223 Tobacco Product
Manufacturing
31193
Flavoring Syrup and
Concentrate Manufacturing
311930
Flavoring Syrup and Concentrate
Manufacturing
31194
Seasoning and Dressing
Manufacturing
3131
Fiber, Yarn, and Thread
Mills
311941
Mayonnaise, Dressing, and Other Prepared
Sauce Manufacturing
31311
311942
Spice and Extract Manufacturing
Fiber, Yarn, and Thread
Mills
312230
313
Tobacco Manufacturing
Textile Mills
Toxics Release Inventory Reporting Forms and Instructions
I-2
Table I. NAICS Codes
313110
Fiber, Yarn, and Thread Mills
314910
Textile Bag and Canvas Mills
31499
All Other Textile Product
Mills
314994
Rope, Cordage, Twine, Tire Cord, and Tire
Fabric Mills
314999
All Other Miscellaneous Textile Product
Mills (except facilities engaged in binding
carpets and rugs for the trade, carpet cutting
and binding, and embroidering on textile
products (except apparel) for the trade)
3132
Fabric Mills
31321
Broadwoven Fabric Mills
313210
Broadwoven Fabric Mills
31322
Narrow Fabric Mills and
Schiffli Machine Embroidery
313220
Narrow Fabric Mills and Schiffli Machine
Embroidery
31323
Nonwoven Fabric Mills
315
Apparel Manufacturing
313230
Nonwoven Fabric Mills
3151
Apparel Knitting Mills
31324
Knit Fabric Mills
31511
Hosiery and Sock Mills
3132401
Knit Fabric Mills
315110
Hosiery and Sock Mills
3133
Textile and Fabric Finishing
and Fabric Coating Mills
31519
Other Apparel Knitting Mills
315190
Other Apparel Knitting Mills
3152
Cut and Sew Apparel
Manufacturing
31521
Cut and Sew Apparel
Contractors
315210
Cut and Sew Apparel Contractors
31522
Men’s and Boys’ Cut and Sew
Apparel Manufacturing
315220
Men’s and Boys’ Cut and Sew Apparel
Manufacturing (except custom tailors
primarily engaged in making and selling
men’s and boy’s suits, cut and sewn from
purchased fabric)
31524
Women’s, Girls’, and Infants’
Cut and Sew Apparel
Manufacturing
31331
313310
Textile and Fabric Finishing
Mills
Textile and Fabric Finishing Mills (except
facilities primarily engaged in converting
broadwoven piece goods and broadwoven
textiles and facilities primarily engaged in
sponging fabric for tailors and dressmakers
and facilities primarily engaged in
converting narrow woven textiles and
narrow woven piece goods)
31332
Fabric Coating Mills
313320
Fabric Coating Mills
314
Textile Product Mills
3141
Textile Furnishing Mills
31411
Carpet and Rug Mills
314110
Carpet and Rug Mills
31412
Curtain and Linen Mills
315240
314120
Curtain and Linen Mills (except facilities
primarily engaged in making custom drapery
for retail sale)
Women’s, Girls’, and Infants’ Cut and Sew
Apparel Manufacturing
31528
Other Cut and Sew Apparel
Manufacturing
3149
Other Textile Product Mills
315280
Other Cut and Sew Apparel Manufacturing
31491
Textile Bag and Canvas Mills
Toxics Release Inventory Reporting Forms and Instructions
I-3
Table I. NAICS Codes
3159
Apparel Accessories and
Other Apparel
Manufacturing
32121
Veneer, Plywood, and
Engineered Wood Product
Manufacturing
31599
Apparel Accessories and
Other Apparel
Manufacturing
321211
Hardwood Veneer and Plywood
Manufacturing
321212
Softwood Veneer and Plywood
Manufacturing
315990
Apparel Accessories and Other Apparel
Manufacturing
321213
Engineered Wood Member (except Truss)
Manufacturing
316
Leather and Allied Product
Manufacturing
321214
Truss Manufacturing
321219
Reconstituted Wood Product Manufacturing
3161
Leather and Hide Tanning
and Finishing
3219
Other Wood Product
Manufacturing
31611
Leather and Hide Tanning
and Finishing
32191
Millwork
321911
Wood Window and Door Manufacturing
316110
Leather and Hide Tanning and Finishing
321912
Cut Stock, Resawing Lumber, and Planing
3162
Footwear Manufacturing
321918
Other Millwork (including Flooring)
31621
Footwear Manufacturing
32192
316210
Footwear Manufacturing
Wood Container and Pallet
Manufacturing
3169
Other Leather and Allied
Product Manufacturing
321920
Wood Container and Pallet Manufacturing
32199
All Other Wood Product
Manufacturing
321991
Manufactured Home (Mobile Home)
Manufacturing
31699
Other Leather and Allied
Product Manufacturing
316992
Women’s Handbag and Purse Manufacturing
321992
Prefabricated Wood Building Manufacturing
316998
All Other Leather Good and Allied Product
Manufacturing
321999
All Other Miscellaneous Wood Product
Manufacturing
321
Wood Product
Manufacturing
322
Paper Manufacturing
3211
Sawmills and Wood
Preservation
3221
Pulp, Paper, and Paperboard
Mills
321113
Sawmills
32211
Pulp Mills
321114
Wood Preservation
322110
Pulp Mills
3212
Veneer, Plywood, and
Engineered Wood Product
Manufacturing
32212
Paper Mills
322121
Paper (except Newsprint) Mills
322122
Newsprint Mills
32213
Paperboard Mills
Toxics Release Inventory Reporting Forms and Instructions
I-4
Table I. NAICS Codes
322130
Paperboard Mills
3222
324
Converted Paper Product
Manufacturing
Petroleum and Coal Products
Manufacturing
3241
32221
Paperboard Container
Manufacturing
Petroleum and Coal Products
Manufacturing
32411
Petroleum Refineries
322211
Corrugated and Solid Fiber Box
Manufacturing
324110
Petroleum Refineries
322212
Folding Paperboard Box Manufacturing
32412
322219
Other Paperboard Container Manufacturing
32222
Paper Bag and Coated and
Treated Paper Manufacturing
Asphalt Paving, Roofing, and
Saturated Materials
Manufacturing
324121
Asphalt Paving Mixture and Block
Manufacturing
322220
Paper Bag and Coated and Treated Paper
Manufacturing
324122
Asphalt Shingle and Coating Materials
Manufacturing
32223
Stationery Product
Manufacturing
32419
Other Petroleum and Coal
Products Manufacturing
322230
Stationery Product Manufacturing
324191
32229
Other Converted Paper
Product Manufacturing
Petroleum Lubricating Oil and Grease
Manufacturing
324199
All Other Petroleum and Coal Products
Manufacturing
322291
Sanitary Paper Product Manufacturing
322299
All Other Converted Paper Product
Manufacturing
325
Chemical Manufacturing
3251
Basic Chemical
Manufacturing
32511
Petrochemical Manufacturing
325110
Petrochemical Manufacturing
32512
Industrial Gas Manufacturing
325120
Industrial Gas Manufacturing
32513
Synthetic Dye and Pigment
Manufacturing
325130
Synthetic Dye and Pigment Manufacturing
32518
Other Basic Inorganic
Chemical Manufacturing
325180
Other Basic Inorganic Chemical
Manufacturing
32519
Other Basic Organic
Chemical Manufacturing
323
3231
Printing and Related Support
Activities
Printing and Related Support
Activities
32311
Printing
323111
Commercial Printing (Except Screen and
Books) (except facilities primarily engaged
in reproducing text, drawings, plans, maps,
or other copy by blueprinting, photocopying,
mimeographing, or other methods of
duplication other than printing or
microfilming (i.e., instant printing)
323113
Commercial Screen Printing
323117
Books Printing
32312
Support Activities for
Printing
3231201
Support Activities for Printing
Toxics Release Inventory Reporting Forms and Instructions
I-5
Table I. NAICS Codes
325193
Ethyl Alcohol Manufacturing
325414
Biological Product (except Diagnostic)
Manufacturing
323194
Cyclic Crude, Intermediate, and Gum and
Wood Chemical Manufacturing
3255
325199
All Other Basic Organic Chemical
Manufacturing
Paint, Coating, and Adhesive
Manufacturing
3252
Resin, Synthetic Rubber, and
Artificial Synthetic Fibers and
Filaments Manufacturing
32551
Paint and Coating
Manufacturing
325510
Paint and Coating Manufacturing
32552
Adhesive Manufacturing
325520
Adhesive Manufacturing
3256
Soap, Cleaning Compound,
and Toilet Preparation
Manufacturing
32521
Resin and Synthetic Rubber
Manufacturing
325211
Plastics Material and Resin Manufacturing
325212
Synthetic Rubber Manufacturing
32522
Artificial and Synthetic Fibers
and Filaments Manufacturing
32561
325220
Artificial and Synthetic Fibers and Filaments
Manufacturing
Soap and Cleaning
Compound Manufacturing
325611
Soap and Other Detergent Manufacturing
3253
Pesticide, Fertilizer, and
Other Agricultural Chemical
Manufacturing
325612
Polish and Other Sanitation Good
Manufacturing
'325613
Surface Active Agent Manufacturing
32562
Toilet Preparation
Manufacturing
325620
Toilet Preparation Manufacturing
3259
Other Chemical Product and
Preparation Manufacturing
32591
Printing Ink Manufacturing
325910
Printing Ink Manufacturing
32592
Explosives Manufacturing
325920
Explosives Manufacturing
32599
All Other Chemical Product
and Preparation
Manufacturing
32531
Fertilizer Manufacturing
325311
Nitrogenous Fertilizer Manufacturing
325312
Phosphatic Fertilizer Manufacturing
325314
Fertilizer (Mixing Only) Manufacturing
32532
Pesticide and Other
Agricultural Chemical
Manufacturing
325320
Pesticide and Other Agricultural Chemical
Manufacturing
3254
Pharmaceutical and Medicine
Manufacturing
32541
Pharmaceutical and Medicine
Manufacturing
325991
Custom Compounding of Purchased Resins
325411
Medicinal and Botanical Manufacturing
325992
325412
Pharmaceutical Preparation Manufacturing
Photographic Film, Paper, Plate, and
Chemical
Manufacturing
325413
In-Vitro Diagnostic Substance
Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
I-6
Table I. NAICS Codes
325998
326
3261
32611
All Other Miscellaneous Chemical Product
and Preparation Manufacturing (except
facilities primarily engaged in Aerosol can
filling on a job order or contract Basis)
32619
Other Plastics Product
Manufacturing
326191
Plastics Plumbing Fixture Manufacturing
Plastics and Rubber Products
Manufacturing
326199
All Other Plastics Product Manufacturing
3262
Rubber Product
Manufacturing
32621
Tire Manufacturing
326211
Tire Manufacturing (except Retreading)
32622
Rubber and Plastics Hoses
and Belting Manufacturing
326220
Rubber and Plastics Hoses and Belting
Manufacturing
32629
Other Rubber Product
Manufacturing
326291
Rubber Product Manufacturing for
Mechanical Use
326299
All Other Rubber Product Manufacturing
327
Nonmetallic Mineral Product
Manufacturing
3271
Clay Product and Refractory
Manufacturing
32711
Pottery, Ceramics, and
Plumbing Fixture
Manufacturing
Plastics Product
Manufacturing
Plastics Packaging Materials
and Unlaminated Film and
Sheet Manufacturing
326111
Plastics Bag and Pouch Manufacturing
326112
Plastics Packaging Film and Sheet (including
Laminated) Manufacturing
326113
Unlaminated Plastics Film and Sheet (except
Packaging) Manufacturing
32612
Plastics, Pipe, Pipe Fitting,
and Unlaminated Profile
Shape Manufacturing
326121
Unlaminated Plastics Profile Shape
Manufacturing
326122
Plastics Pipe and Pipe Fitting Manufacturing
32613
Laminated Plastics Plate,
Sheet
(except Packaging), and
Shape Manufacturing
326130
Laminated Plastics Plate, Sheet (except
Packaging), and Shape Manufacturing
327110
Pottery, Ceramics, and Plumbing Fixture
Manufacturing
32614
Polystyrene Foam Product
Manufacturing
32712
326140
Polystyrene Foam Product Manufacturing
Clay Building Material and
Refractories Manufacturing
327120
32615
Urethane and Other Foam
Product (except Polystyrene)
Manufacturing
Clay Building Material and Refractories
Manufacturing
3272
Glass and Glass Product
Manufacturing
326150
Urethane and Other Foam Product (except
Polystyrene) Manufacturing
32721
32616
Plastics Bottle Manufacturing
Glass and Glass Product
Manufacturing
326160
Plastics Bottle Manufacturing
327211
Flat Glass Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
I-7
Table I. NAICS Codes
327212
Other Pressed and Blown Glass and
Glassware Manufacturing
327992
Ground or Treated Mineral and Earth
Manufacturing
327213
Glass Container Manufacturing
327993
Mineral Wool Manufacturing
327215
Glass Product Manufacturing Made of
Purchased Glass
327999
All Other Miscellaneous Nonmetallic
Mineral Product Manufacturing
3273
Cement and Concrete
Product Manufacturing
331
Primary Metal
Manufacturing
32731
Cement Manufacturing
3311
327310
Cement Manufacturing
Iron and Steel Mills and
Ferroalloy Manufacturing
32732
Ready-Mix Concrete
Manufacturing
33111
Iron and Steel Mills and
Ferroalloy Manufacturing
327320
Ready-Mix Concrete Manufacturing
331110
32733
Concrete Pipe, Brick, and
Block Manufacturing
Iron and Steel Mills and Ferroalloy
Manufacturing
3312
327331
Concrete Block and Brick Manufacturing
Steel Product Manufacturing
from Purchased Steel
327332
Concrete Pipe Manufacturing
33121
32739
Other Concrete Product
Manufacturing
Iron and Steel Pipe and Tube
Manufacturing from
Purchased Steel
331210
327390
Other Concrete Product Manufacturing
Iron and Steel Pipe and Tube Manufacturing
from Purchased Steel
3274
Lime and Gypsum Product
Manufacturing
33122
Rolling and Drawing of
Purchased Steel
32741
Lime Manufacturing
331221
Rolled Steel Shape Manufacturing
327410
Lime Manufacturing
331222
Steel Wire Drawing
32742
Gypsum Product
Manufacturing
3313
Alumina and Aluminum
Production and Processing
327420
Gypsum Product Manufacturing
33131
3279
Other Nonmetallic Mineral
Product Manufacturing
Alumina and Aluminum
Production and Processing
331313
Alumina Refining and Primary Aluminum
Production
32791
Abrasive Product
Manufacturing
331314
Secondary Smelting and Alloying of
Aluminum
327910
Abrasive Product Manufacturing
331315
32799
All Other Nonmetallic
Mineral Product
Manufacturing
Aluminum Sheet, Plate, and Foil
Manufacturing
331318
Other Aluminum Rolling, Drawing, and
Extruding
327991
Cut Stone and Stone Product Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
I-8
Table I. NAICS Codes
332114
Custom Roll Forming
332117
Powder Metallurgy Part Manufacturing
332119
Nonferrous Metal (except
Aluminum) Smelting and
Refining
Metal Crown, Closure, and Other Metal
Stamping (Except Automotive)
3322
Cutlery and Handtool
Manufacturing
331410
Nonferrous Metal (except Aluminum)
Smelting and Refining
33221
33142
Copper Rolling, Drawing,
Extruding, and Alloying
Cutlery and Handtool
Manufacturing
332215
331420
Copper Rolling, Drawing, Extruding, and
Alloying
Metal Kitchen Cookware, Utensil, Cutlery,
and Flatware (except Precious)
Manufacturing
332216
Saw Blade and Handtool Manufacturing
3323
Architectural and Structural
Metals Manufacturing
33231
Plate Work and Fabricated
Structural Product
Manufacturing
332311
Prefabricated Metal Building and
Component Manufacturing
332312
Fabricated Structural Metal Manufacturing
3314
33141
33149
Nonferrous Metal (except
Aluminum) Production and
Processing
Nonferrous Metal (except
Copper and Aluminum)
Rolling, Drawing, Extruding,
and Alloying
331491
Nonferrous Metal (except Copper and
Aluminum) Rolling, Drawing, and Extruding
331492
Secondary Smelting, Refining, and Alloying
of Nonferrous Metal (except Copper and
Aluminum)
3315
Foundries
332313
Plate Work Manufacturing
33151
Ferrous Metal Foundries
33232
331511
Iron Foundries
331512
Steel Investment Foundries
Ornamental and
Architectural Metal Products
Manufacturing
331513
Steel Foundries (except Investment)
332321
Metal Window and Door Manufacturing
33152
Nonferrous Metal Foundries
332322
Sheet Metal Work Manufacturing
332323
331523
Nonferrous Metal Die-Casting Foundries
Ornamental and Architectural Metal Work
Manufacturing
331524
Aluminum Foundries (except Die-Casting)
3324
331529
Other Nonferrous Metal Foundries (except
Die-Casting)
Boiler, Tank, and Shipping
Container Manufacturing
332
Fabricated Metal Product
Manufacturing
33241
Power Boiler and Heat
Exchanger Manufacturing
332410
Power Boiler and Heat Exchanger
Manufacturing
33242
Metal Tank (Heavy Gauge)
Manufacturing
332420
Metal Tank (Heavy Gauge) Manufacturing
3321
Forging and Stamping
33211
Forging and Stamping
332111
Iron and Steel Forging
332112
Nonferrous Forging
Toxics Release Inventory Reporting Forms and Instructions
I-9
Table I. NAICS Codes
33243
Metal Can, Box, and Other
Metal Container (Light
Gauge) Manufacturing
3329
Other Fabricated Metal
Product Manufacturing
332431
Metal Can Manufacturing
33291
Metal Valve Manufacturing
332439
Other Metal Container Manufacturing
332911
Industrial Valve Manufacturing
332912
Fluid Power Valve and Hose Fitting
Manufacturing
3325
Hardware Manufacturing
33251
Hardware Manufacturing
332913
Plumbing Fixture Fitting and Trim
Manufacturing
332510
Hardware Manufacturing
332919
3326
Spring and Wire Product
Manufacturing
Other Metal Valve and Pipe Fitting
Manufacturing
33299
33261
Spring and Wire Product
Manufacturing
All Other Fabricated Metal
Product Manufacturing
332991
Ball and Roller Bearing Manufacturing
332613
Spring Manufacturing
332992
Small Arms Ammunition Manufacturing
332618
Other Fabricated Wire Product
Manufacturing
332993
Ammunition (except Small Arms)
Manufacturing
3327
Machine Shops; Turned
Product; and Screw, Nut and
Bolt Manufacturing
332994
Small Arms, Ordnance, and Ordnance
Accessories Manufacturing
332996
Fabricated Pipe and Pipe Fitting
Manufacturing
332999
All Other Miscellaneous Fabricated Metal
Product Manufacturing
333
Machinery Manufacturing
3331
Agriculture, Construction,
and Mining Machinery
Manufacturing
33271
Machine Shops
332710
Machine Shops
33272
Turned Product and Screw,
Nut and Bolt Manufacturing
332721
Precision Turned Product Manufacturing
332722
Bolt, Nut, Screw, Rivet, and Washer
Manufacturing
33311
3328
Coating, Engraving, Heat
Treating, and Allied Activities
Agricultural Implement
Manufacturing
333111
Farm Machinery and Equipment
Manufacturing
33281
Coating, Engraving, Heat
Treating, and Allied Activities
333112
Lawn and Garden Tractor and Home Lawn
and Garden Equipment Manufacturing
332811
Metal Heat Treating
33312
332812
Metal Coating, Engraving (except Jewelry
and Silverware), and Allied Services to
Manufacturers
Construction Machinery
Manufacturing
333120
Construction Machinery Manufacturing
Electroplating, Plating, Polishing,
Anodizing, and Coloring
33313
Mining and Oil and Gas Field
Machinery Manufacturing
332813
Toxics Release Inventory Reporting Forms and Instructions
I-10
Table I. NAICS Codes
333131
Mining Machinery and Equipment
Manufacturing
333415
Oil and Gas Field Machinery and Equipment
Manufacturing
Air-Conditioning and Warm Air Heating
Equipment and Commercial and Industrial
Refrigeration Equipment Manufacturing
333132
3335
Industrial Machinery
Manufacturing
Metalworking Machinery
Manufacturing
33351
Industrial Machinery
Manufacturing
Metalworking Machinery
Manufacturing
333511
Industrial Mold Manufacturing
333241
Food Product Machinery Manufacturing
333514
333242
Semiconductor Machinery Manufacturing
Special Die and Tool, Die Set, Jig, and
Fixture Manufacturing
333243
Sawmill, Woodworking, and Paper
Machinery Manufacturing
333515
Cutting Tool and Machine Tool Accessory
Manufacturing
333244
Printing Machinery and Equipment
Manufacturing
333517
Machine Tool Manufacturing
333249
Other Industrial Machinery Manufacturing
333519
3333
Commercial and Service
Industry Machinery
Manufacturing
Rolling Mill and Other Metalworking
Machinery Manufacturing
3336
33331
Commercial and Service
Industry Machinery
Manufacturing
Engine, Turbine, and Power
Transmission Equipment
Manufacturing
33361
333316
Photographic and Photocopying Equipment
Manufacturing
Engine, Turbine, and Power
Transmission Equipment
Manufacturing
333611
333318
Other Commercial and Service Industry
Machinery Manufacturing
Turbine and Turbine Generator Set Units
Manufacturing
333612
3334
Ventilation, Heating, AirConditioning, and
Commercial Refrigeration
Speed Changer, Industrial High-Speed
Drive, and Gear Manufacturing
333613
Mechanical Power Transmission Equipment
Manufacturing
333618
Other Engine Equipment Manufacturing
3339
Other General Purpose
Machinery Manufacturing
33391
Pump and Compressor
Manufacturing
333911
Pump and Pumping Equipment
Manufacturing
333912
Air and Gas Compressor Manufacturing
333913
Measuring and Dispensing Pump
Manufacturing
3332
33324
33341
333413
333414
Equipment Manufacturing
Ventilation, Heating, AirConditioning, and
Commercial Refrigeration
Equipment Manufacturing
Industrial and Commercial Fan and Blower
and Air Purification Equipment
Manufacturing
Heating Equipment (except Warm Air
Furnaces) Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
I-11
Table I. NAICS Codes
33392
Material Handling
Equipment Manufacturing
334210
Telephone Apparatus Manufacturing
33422
Radio and Television
Broadcasting and Wireless
Communications Equipment
Manufacturing
334220
Radio and Television Broadcasting and
Wireless Communications Equipment
Manufacturing
333921
Elevator and Moving Stairway
Manufacturing
333922
Conveyor and Conveying Equipment
Manufacturing
333923
Overhead Traveling Crane, Hoist, and
Monorail System Manufacturing
333924
Industrial Truck, Tractor, Trailer, and
Stacker Machinery Manufacturing
33429
33399
All Other General Purpose
Machinery Manufacturing
Other Communications
Equipment Manufacturing
334290
Other Communications Equipment
Manufacturing
333991
Power-Driven Handtool Manufacturing
3343
333992
Welding and Soldering Equipment
Manufacturing
Audio and Video Equipment
Manufacturing
333993
Packaging Machinery Manufacturing
33431
333994
Industrial Process Furnace and Oven
Manufacturing
Audio and Video Equipment
Manufacturing
334310
Audio and Video Equipment Manufacturing
333995
Fluid Power Cylinder and Actuator
Manufacturing
3344
333996
Fluid Power Pump and Motor Manufacturing
333997
Scale and Balance Manufacturing
Semiconductor and Other
Electronic Component
Manufacturing
333999
All Other Miscellaneous General Purpose
Machinery Manufacturing
33441
334
Computer and Electronic
Product Manufacturing
Semiconductor and Other
Electronic Component
Manufacturing
334412
Bare Printed Circuit Board Manufacturing
3341
Computer and Peripheral
Equipment Manufacturing
334413
Semiconductor and Related Device
Manufacturing
334416
Capacitor, Resistor, Coil, Transformer, and
Other Inductor Manufacturing
334417
Electronic Connector Manufacturing
334418
Printed Circuit Assembly (Electronic
Assembly) Manufacturing
33411
Computer and Peripheral
Equipment Manufacturing
334111
Electronic Computer Manufacturing
334112
Computer Storage Device Manufacturing
334419
Other Electronic Component Manufacturing
334118
Computer Terminal and Other Computer
Peripheral Equipment Manufacturing
3345
3342
Communications Equipment
Manufacturing
Navigational, Measuring,
Electromedical, and Control
Instruments Manufacturing
33421
Telephone Apparatus
Manufacturing
33451
Navigational, Measuring,
Electromedical, and Control
Instruments Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
I-12
Table I. NAICS Codes
334510
Electromedical and Electrotherapeutic
Apparatus Manufacturing
33512
334511
Search, Detection, Navigation, Guidance,
Aeronautical, and Nautical System and
Instrument Manufacturing
Lighting Fixture
Manufacturing
335121
Residential Electric Lighting Fixture
Manufacturing
334512
Automatic Environmental Control
Manufacturing for Residential, Commercial,
and Appliance Use
335122
Commercial, Industrial, and Institutional
Electric Lighting Fixture Manufacturing
335129
Other Lighting Equipment Manufacturing
334513
Instruments and Related Products
Manufacturing for Measuring, Displaying,
and Controlling Industrial Process Variables
3352
Household Appliance
Manufacturing
334514
Totalizing Fluid Meter and Counting Device
Manufacturing
33521
334515
Instrument Manufacturing for Measuring and
Testing Electricity and Electrical Signals
Small Electrical Appliance
Manufacturing
335210
Small Electrical Appliance Manufacturing
33522
Major Appliance
Manufacturing
335221
Household Cooking Appliance
Manufacturing
335222
Household Refrigerator and Home Freezer
Manufacturing
335224
Household Laundry Equipment
Manufacturing
335228
Other Major Household Appliance
Manufacturing
3353
Electrical Equipment
Manufacturing
33531
Electrical Equipment
Manufacturing
335311
Power, Distribution, and Specialty
Transformer Manufacturing
335312
Motor and Generator Manufacturing (except
facilities primarily engaged in armature
rewinding on a factory basis)
335313
Switchgear and Switchboard Apparatus
Manufacturing
335314
Relay and Industrial Control Manufacturing
3359
Other Electrical Equipment
and Component
Manufacturing
33591
Battery Manufacturing
335911
Storage Battery Manufacturing
334516
Analytical Laboratory Instrument
Manufacturing
334517
Irradiation Apparatus Manufacturing
334519
Other Measuring and Controlling Device
Manufacturing
3346
Manufacturing and
Reproducing Magnetic and
Optical Media
33461
Manufacturing and
Reproducing Magnetic and
Optical Media
334613
Blank Magnetic and Optical Recording
Media Manufacturing
334614
Software and Other Prerecorded Compact
Disc, Tape and Record Reproducing (except
facilities primarily engaged in mass
reproducing pre-recorded Video Cassettes,
and mass reproducing Video tape or disk)
335
Electrical Equipment,
Appliance, and Component
Manufacturing
3351
Electric Lighting Equipment
Manufacturing
33511
Electric Lamp Bulb and Part
Manufacturing
335110
Electric Lamp Bulb and Part Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
I-13
Table I. NAICS Codes
335912
Primary Battery Manufacturing
336214
Travel Trailer and Camper Manufacturing
33592
Communication and Energy
Wire and Cable
Manufacturing
3363
Motor Vehicle Parts
Manufacturing
33631
335921
Fiber Optic Cable Manufacturing
335929
Other Communication and Energy Wire
Manufacturing
Motor Vehicle Gasoline
Engine and Engine Parts
Manufacturing
33593
Wiring Device Manufacturing
336310
Motor Vehicle Gasoline Engine and Engine
Parts Manufacturing
335931
Current-Carrying Wiring Device
Manufacturing
33632
335932
Noncurrent-Carrying Wiring Device
Manufacturing
Motor Vehicle Electrical and
Electronic Equipment
Manufacturing
33599
All Other Electrical
Equipment
and Component
Manufacturing
336320
Motor Vehicle Electrical and Electronic
Equipment Manufacturing
33633
Motor Vehicle Steering and
Suspension Components
(except Spring)
Manufacturing
335991
Carbon and Graphite Product Manufacturing
335999
All Other Miscellaneous Electrical
Equipment and Component Manufacturing
336330
Motor Vehicle Steering and Suspension
Components (except Spring) Manufacturing
336
Transportation Equipment
Manufacturing
33634
Motor Vehicle Brake System
Manufacturing
3361
Motor Vehicle Manufacturing
336340
Motor Vehicle Brake System Manufacturing
33611
Automobile and Light Duty
Motor Vehicle Manufacturing
33635
336111
Automobile Manufacturing
Motor Vehicle Transmission
and Power Train Parts
Manufacturing
336112
Light Truck and Utility Vehicle
Manufacturing
336350
Motor Vehicle Transmission and Power
Train Parts Manufacturing
33612
Heavy Duty Truck
Manufacturing
33636
Motor Vehicle Seating and
Interior Trim Manufacturing
336120
Heavy Duty Truck Manufacturing
336360
Motor Vehicle Seating and Interior Trim
Manufacturing
3362
Motor Vehicle Body and
Trailer Manufacturing
33637
Motor Vehicle Metal
Stamping
33621
Motor Vehicle Body and
Trailer Manufacturing
336370
Motor Vehicle Metal Stamping
336211
Motor Vehicle Body Manufacturing
33639
Other Motor Vehicle Parts
Manufacturing
336212
Truck Trailer Manufacturing
336390
Motor Vehicle Parts Manufacturing
336213
Motor Home Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
I-14
Table I. NAICS Codes
3364
Aerospace Product and Parts
Manufacturing
33641
Aerospace Product and Parts
Manufacturing
3371
Household and Institutional
Furniture and Kitchen
Cabinet Manufacturing
33711
Wood Kitchen Cabinet and
Countertop Manufacturing
337110
Wood Kitchen Cabinet and Countertop
Manufacturing (except facilities primarily
engaged in the retail sale of household
furniture and that manufacture custom wood
kitchen cabinets and counter tops)
336411
Aircraft Manufacturing
336412
Aircraft Engine and Engine Parts
Manufacturing
336413
Other Aircraft Parts and Auxiliary
Equipment Manufacturing
336414
Guided Missile and Space Vehicle
Manufacturing
33712
336415
Guided Missile and Space Vehicle
Propulsion Unit and Propulsion Unit Parts
Manufacturing
Household and Institutional
Furniture Manufacturing
337121
Upholstered Household Furniture
Manufacturing (except facilities primarily
engaged in the retail sale of household
furniture and that manufacture custom made
upholstered household furniture)
337122
Nonupholstered Wood Household Furniture
Manufacturing (except facilities primarily
engaged in the retail sale of household
furniture and that manufacture
nonupholstered, household type, custom
wood furniture)
337124
Metal Household Furniture Manufacturing
337125
Household Furniture (except Wood and
Metal) Manufacturing
337127
Institutional Furniture Manufacturing
3372
Office Furniture (including
Fixtures)Manufacturing
33721
Office Furniture (including
Fixtures)Manufacturing
337211
Wood Office Furniture Manufacturing
337212
Custom Architectural Woodwork and
Millwork Manufacturing
336419
Other Guided Missile and Space Vehicle
Parts and Auxiliary Equipment
Manufacturing
3365
Railroad Rolling Stock
Manufacturing
33651
Railroad Rolling Stock
Manufacturing
336510
Railroad Rolling Stock Manufacturing
3366
Ship and Boat Building
33661
Ship and Boat Building
336611
Ship Building and Repairing
336612
Boat Building
3369
Other Transportation
Equipment Manufacturing
33699
Other Transportation
Equipment Manufacturing
336991
Motorcycle, Bicycle, and Parts
Manufacturing
337214
Office Furniture (except Wood)
Manufacturing
336992
Military Armored Vehicle, Tank, and Tank
Component Manufacturing
337215
Showcase, Partition, Shelving, and Locker
Manufacturing
336999
All Other Transportation Equipment
Manufacturing
3379
337
Furniture and Related
Product Manufacturing
Other Furniture Related
Product Manufacturing
33791
Mattress Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
I-15
Table I. NAICS Codes
337910
Mattress Manufacturing
339932
33792
Blind and Shade
Manufacturing
Game, Toy, and Children’s Vehicle
Manufacturing
33994
337920
Blind and Shade Manufacturing
Office Supplies (except Paper)
Manufacturing
339
Miscellaneous Manufacturing
339940
Office Supplies (except Paper)
Manufacturing
3391
Medical Equipment and
Supplies Manufacturing
339942
Lead Pencil and Art Good Manufacturing
339943
Marking Device Manufacturing
33911
Medical Equipment and
Supplies Manufacturing
339944
Carbon Paper and Inked Ribbon
Manufacturing
339112
Surgical and Medical Instrument
Manufacturing
33995
Sign Manufacturing
339950
Sign Manufacturing
339113
Surgical Appliance and Supplies
Manufacturing (except facilities primarily
engaged in manufacturing orthopedic
devices to prescription in a retail
environment )
33999
All Other Miscellaneous
Manufacturing
339991
Gasket, Packing, and Sealing Device
Manufacturing
339114
Dental Equipment and Supplies
Manufacturing
339992
Musical Instrument Manufacturing
339115
Ophthalmic Goods Manufacturing (except
lens
grinding facilities that are primarily engaged
in the retail sale of eyeglasses and contact
lenses to prescription for individuals)
339993
Fastener, Button, Needle, and Pin
Manufacturing
339994
Broom, Brush, and Mop Manufacturing
339995
Burial Casket Manufacturing
339999
All Other Miscellaneous Manufacturing
113310
Logging
111998
All Other Miscellaneous Crop Farming
(Limited to facilities primarily engaged in
reducing maple sap to maple syrup)
211112
Natural Gas Liquid Extraction (limited to
facilities that recover sulfur from natural gas)
212324
Kaolin and Ball Clay Mining (limited to
facilities operating without a mine or quarry
and that are primarily engaged in
beneficiating kaolin and clay)
212325
Clay and Ceramic and Refractory
Minerals Mining (limited to facilities
operating without a mine or quarry and that
are primarily engaged in beneficiating clay
and ceramic and refractory minerals)
212393
Other Chemical and Fertilizer Mineral
Mining (limited to facilities operating
without a mine or quarry that are primarily
engaged in beneficiating chemical or
fertilizer mineral raw materials)
3399
Other Miscellaneous
Manufacturing
33991
Jewelry and Silverware
Manufacturing
339910
Jewelry and Silverware Manufacturing
339912
Silverware and Hollowware Manufacturing
339913
Jewelers’ Material and Lapidary Work
Manufacturing
339914
Costume Jewelry and Novelty
Manufacturing
33992
Sporting and Athletic Goods
Manufacturing
339920
Sporting and Athletic Goods Manufacturing
33993
Doll, Toy, and Game
Manufacturing
339930
Doll Toy, and Game Manufacturing
Toxics Release Inventory Reporting Forms and Instructions
I-16
Table I. NAICS Codes
212399
All Other Nonmetallic Mineral Mining
(limited to facilities operating without a mine
or quarry that are primarily engaged in
beneficiating nonmetallic minerals)
488390
Other Support Activities for Water
Transportation (limited to facilities that are
primarily engaged in providing routine repair
and maintenance of ships and boats from
floating drydocks)
511110
Newspaper Publishers
511120
Periodical Publishers
511130
Book Publishers
511140
Directory and Mailing List Publishers
(except Facilities that are primarily engaged
in furnishing services for direct mail
advertising including address list compilers,
address list publishers, address list publishers
and printing combined, address list
publishing, business directory publishers,
catalog of collections publishers, catalog of
collections publishers and printing
combined, mailing list compilers, directory
compilers, and mailing list compiling
services)
511191
Greeting Card Publishers
511199
All Other Publishers
512220
Integrated Record
Production/Distribution
512230
Music Publishers (except facilities
primarily Engaged in Music copyright
authorizing use, Music copyright buying and
licensing, and Music publishers working on
their own account)
519130
Internet Publishing and Broadcasting
and Web Search portals (limited to
facilities primarily engaged in Internet
newspaper publishing, Internet periodical
publishing, internet book publishing,
Miscellaneous Internet publishing, Internet
greeting card publishers except web search
portals
541712
Research and Development in the
Physical, Engineering, and Life Sciences
(except Biotechnology) (limited to facilities
that are primarily engaged in Guided missile
and space vehicle engine research and
development, and in Guided missile and
space vehicle parts (except engines) research
and development)
811490
Other Personal and Household Goods
Repair and Maintenance (limited to
facilities that are primarily engaged in
repairing and servicing pleasure and sail
boats without retailing new boats
(previously classified under SIC 3732,
Boat Building and Repairing (pleasure
boat building)
Toxics Release Inventory Reporting Forms and Instructions
I-17
Table II
221330
Steam and Air Conditioning Supply
Limited to facilities engaged in providing
combinations of electric, gas and other
services, not elsewhere classified (NEC)
(previously classified under SIC 4939,
Combination Utility Services Not
Elsewhere Classified.)
424690
Other Chemical and Allied Products
Merchant Wholesalers
424710
Petroleum Bulk Stations and Terminals
425110
Business to Business Electronic Markets
(limited to facilities previously classified in
5169, Chemicals and Allied Products, NEC)
425120
Wholesale Trade Agents and Brokers
(limited to facilities previously classified in
5169, Chemicals and Allied Products, NEC)
562112
Hazardous Waste Collection (limited to
facilities primarily engaged in solvent
recovery services on a contract or fee basis)
562211
Hazardous Waste Treatment and
Disposal (limited to facilities regulated
under the Resource Conservation and
Recovery Act, subtitle C, 42 U.S.C. 6921, et
seq.)
562212
Solid Waste Landfill (limited to facilities
regulated under the Resource Conservation
and Recovery Act, subtitle C, 42 U.S.C.
6921, et seq.)
(limited to facilities that combust
coal and/or oil for the purpose of
generating power for distribution
in commerce)
562213
Solid Waste Combustors and
Incinerators (Limited to facilities regulated
under the Resource Conservation and
Recovery Act, subtitle C, 42 U.S.C. 6921 et
seq.)
221111
Hydroelectric Power Generation
562219
221112
Fossil Fuel Electric Power Generation
221113
Nuclear Electric Power Generation
Other Nonhazardous Waste Treatment
and Disposal (Limited to facilities
regulated under the Resource Conservation
and Recovery Act, subtitle C, 42 U.S.C.
6921 et seq.)
221118
Other Electric Power Generation
562920
221121
Electric Bulk Power Transmission and
Control
Materials Recovery Facilities (Limited to
facilities regulated under the Resource
Conservation and Recovery Act, subtitle C,
42 U.S.C. 6921 et seq.)
221122
Electric Power Distribution
1.2
NAICS codes that correspond
to SIC codes other than 20
through 39:
212
Mining (except Oil and Gas)
2121
Coal Mining
212111
Bituminous Coal and Lignite Surface
Mining
212112
Bituminous Coal Underground Mining
212113
Anthracite Mining
2122
Metal Ore Mining
212221
Gold Ore Mining
212222
Silver Ore Mining
212231
Lead Ore and Zinc Ore Mining
212234
Copper Ore and Nickel Ore Mining
212299
All Other Metal Ore Mining
221
Utilities
22111
Electric Power Generation
Toxics Release Inventory Reporting Forms and Instructions
I-18
Table II. EPCRA Section 313 Chemical List For Reporting Year 2014
(including Toxic Chemical Categories)
Individually listed EPCRA Section 313 chemicals with CAS numbers are arranged alphabetically starting on page II-3. Following
the alphabetical list, the EPCRA Section 313 chemicals are arranged in CAS number order. Covered chemical categories follow.
Certain EPCRA Section 313 chemicals listed in Table II have parenthetic “qualifiers.” These qualifiers indicate that these EPCRA
Section 313 chemicals are subject to the section 313 reporting requirements if manufactured, processed, or otherwise used in a
specific form or when a certain activity is performed. The following chemicals are reportable only if they are manufactured,
processed, or otherwise used in the specific form(s) listed below:
Chemical/ Chemical Category
CAS Number
Qualifier
Aluminum (fume or dust)
7429-90-5
Only if it is a fume or dust form.
Aluminum oxide (fibrous forms)
1344-28-1
Only if it is a fibrous form.
Ammonia (includes anhydrous ammonia and aqueous ammonia
from water dissociable ammonium salts and other sources; 10
percent of total aqueous ammonia is reportable under this listing)
7664-41-7
Only 10% of aqueous forms. 100% of
anhydrous forms.
Asbestos (friable)
1332-21-4
Only if it is a friable form.
Hydrochloric acid (acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle size)
7647-01-0
Only if it is an aerosol form as
defined.
Nitrate compounds (water dissociable; reportable only when in
aqueous solution)
NA
Only if in aqueous solution
Phosphorus (yellow or white)
7723-14-0
7664-93-9
Only if it is a yellow or white form.
Only if it is an aerosol form as
defined.
Vanadium (except when contained in an alloy)
7440-62-2
Except if it is contained in an alloy.
Zinc (fume or dust)
7440-66-6
Only if it is in a fume or dust form.
Sulfuric acid (acid aerosols including mists, vapors, gas, fog, and
other airborne forms of any particle size)
The qualifier for the following three chemicals is based on the chemical activity rather than the form of the chemical. These
chemicals are subject to EPCRA section 313 reporting requirements only when the indicated activity is performed.
Chemical/ Chemical Category
CAS
Number
Qualifier
Dioxin and dioxin-like compounds (manufacturing; and the
processing or otherwise use of dioxin and dioxin-like compounds if
the dioxin and dioxin-like compounds are present as contaminants
in a chemical and if they were created during the manufacture of
that chemical.)
NA
Only if they are manufactured at the
facility; or are processed or otherwise
used when present as contaminants in a
chemical but only if they were created
during the manufacture of that
chemical.
Isopropyl alcohol (only persons who manufacture by the strong
acid process are subject, no supplier notification)
67-63-0
Only if it is being manufactured by the
strong acid process. Facilities that
process or otherwise use isopropyl
alcohol are not covered and should not
file a report.
Saccharin (only persons who manufacture are subject, no supplier
notification)
81-07-2
Only if it is being manufactured.
There are no supplier notification requirements for isopropyl alcohol and saccharin since the processors and users of these chemicals
are not required to report. Manufacturers of these chemicals do not need to notify their customers that these are reportable EPCRA
section 313 chemicals.
Toxics Release Inventory Reporting Forms and Instructions
II-1
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
Note: Chemicals may be added to or deleted from the list. The Emergency Planning and Community Right-to-Know Call Center
will provide up-to-date information on the status of these changes. See section B.3.c of the instructions for more information on the
de minimis % limits listed below. There are no de minimis levels for PBT chemicals since the de minimis exemption is not available
for these chemicals (an asterisk appears where a de minimis limit would otherwise appear in Table II). However, for purposes of the
supplier notification requirement only, such limits are provided in Appendix D.
Chemical Qualifiers
This table contains the list of individual EPCRA Section 313
chemicals and categories of chemicals subject to 2014 calendar
year reporting. Some of the EPCRA Section 313 chemicals
listed have parenthetic qualifiers listed next to them. An
EPCRA Section 313 chemical that is listed without a qualifier is
subject to reporting in all forms in which it is manufactured,
processed, and otherwise used.
Fume or dust. Two of the metals on the list (aluminum and
zinc) contain the qualifier “fume or dust.” Fume or dust refers to
dry forms of these metals but does not refer to “wet” forms such
as solutions or slurries. As explained in Section B.3.a of these
instructions, the term manufacture includes the generation of an
EPCRA Section 313 chemical as a byproduct or impurity. In
such cases, a facility should determine if, for example, it
generated more than 25,000 pounds of aluminum fume or dust in
the reporting year as a result of its activities. If so, the facility
must report that it manufactures “aluminum (fume or dust).”
Similarly, there may be certain technologies in which one of
these metals is processed in the form of a fume or dust to make
other EPCRA Section 313 chemicals or other products for
distribution in commerce. In reporting releases, the facility
would only report releases of the fume or dust.
EPA considers dusts to consist of solid particles generated by
any mechanical processing of materials including crushing,
grinding, rapid impact, handling, detonation, and decrepitation
of organic and inorganic materials such as rock, ore, and metal.
Dusts do not tend to flocculate, except under electrostatic forces.
EPA considers a fume to be an airborne dispersion consisting of
small solid particles created by condensation from a gaseous
state, in distinction to a gas or vapor. Fumes arise from the
heating of solids such as lead. The condensation is often
accompanied by a chemical reaction, such as oxidation. Fumes
flocculate and sometimes coalesce.
Manufacturing qualifiers. Two of the entries in the EPCRA
Section 313 chemical list contain a qualifier relating to
manufacture. For isopropyl alcohol, the qualifier is “only
persons who manufacture by the strong acid process are subject,
no supplier notification.” For saccharin, the qualifier is “only
persons who manufacture are subject, no supplier notification.”
For isopropyl alcohol, the qualifier means that only facilities
manufacturing isopropyl alcohol by the strong acid process are
required to report. In the case of saccharin, only manufacturers
of the EPCRA Section 313 chemical are subject to the reporting
requirements. A facility that only processes or otherwise uses
either of these EPCRA Section 313 chemicals is not required to
report for these EPCRA Section 313 chemicals. In both cases,
supplier notification does not apply because only manufacturers,
not users, of these two EPCRA Section 313 chemicals must
report.
Ammonia (includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium salts and other
sources; 10 percent of total aqueous ammonia is reportable
under this listing). The qualifier for ammonia means that
anhydrous forms of ammonia are 100% reportable and aqueous
forms are limited to 10% of total aqueous ammonia. Therefore
when determining threshold and releases and other waste
management quantities all anhydrous ammonia is included but
only 10% of total aqueous ammonia is included.
Any
evaporation of ammonia from aqueous ammonia solutions is
considered anhydrous ammonia and should be included in
threshold determinations and release and other waste
management calculations.
Sulfuric acid and Hydrochloric acid (acid aerosols including
mists, vapors, gas, fog, and other airborne forms of any
particle size). The qualifier for sulfuric acid and hydrochloric
acid means that the only forms of these chemicals that are
reportable are airborne forms. Aqueous solutions are not
covered by this listing but any aerosols generated from aqueous
solutions are covered.
Nitrate compounds (water dissociable; reportable only when
in aqueous solution). The qualifier for the nitrate compounds
category limits the reporting to nitrate compounds that dissociate
in water, generating nitrate ion. For the purposes of threshold
determinations the entire weight of the nitrate compound must
be included in all calculations. For the purposes of reporting
releases and other waste management quantities only the weight
of the nitrate ion should be included in the calculations of these
quantities.
Phosphorus (yellow or white). The listing for phosphorus is
qualified by the term “yellow or white.” This means that only
manufacturing, processing, or otherwise use of phosphorus in
the yellow or white chemical form triggers reporting.
Conversely, manufacturing, processing, or otherwise use of
“black” or “red” phosphorus does not trigger reporting. Supplier
notification also applies only to distribution of yellow or white
phosphorus.
Asbestos (friable). The listing for asbestos is qualified by the
term “friable,” referring to the physical characteristic of being
able to be crumbled, pulverized, or reducible to a powder with
hand pressure. Only manufacturing, processing, or otherwise
use of asbestos in the friable form triggers reporting. Supplier
notification applies only to distribution of mixtures or other trade
name products containing friable asbestos.
Toxics Release Inventory Reporting Forms and Instructions
II-2
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
Aluminum Oxide (fibrous forms). The listing for aluminum
oxide is qualified by the term “fibrous forms.” Fibrous refers to
a man-made form of aluminum oxide that is processed to
produce strands or filaments which can be cut to various lengths
depending on the application. Only manufacturing, processing,
or otherwise use of aluminum oxide in the fibrous form triggers
reporting. Supplier notification applies only to distribution of
mixtures or other trade name products containing fibrous forms
of aluminum oxide.
Notes for Sections A and B of following list of
TRI chemicals:
CAS
Number
834-12-8
117-79-3
60-09-3
92-67-1
82-28-0
81-49-2
33089-61-1
61-82-5
7664-41-7
“Color Index” indicated by “C.I.”
* There are no de minimis levels for PBT
chemicals, except for supplier notification
purposes (see Appendix D).
a.
Individually-Listed Toxic Chemicals Arranged
Alphabetically
CAS
Number
71751-41-2
30560-19-1
75-07-0
60-35-5
75-05-8
98-86-2
53-96-3
62476-59-9
107-02-8
79-06-1
79-10-7
107-13-1
15972-60-8
116-06-3
309-00-2
28057-48-9
107-18-6
107-11-9
107-05-1
7429-90-5
20859-73-8
1344-28-1
Chemical Name
Abamectin [Avermectin B1]
Acephate
(Acetylphosphoramidothioic acid
O,S-dimethyl ester)
Acetaldehyde
Acetamide
Acetonitrile
Acetophenone
2-Acetylaminofluorene
Acifluorfen, sodium salt
[5-(2-Chloro-4(trifluoromethyl)phenoxy)-2nitrobenzoic acid, sodium salt]
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Alachlor
Aldicarb
Aldrin
[1,4:5,8-Dimethanonaphthalene,
1,2,3,4,10,10-hexachloro1,4,4a,5,8,8a-hexahydro(1.alpha.,4.alpha.,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
d-trans-Allethrin
[d-trans-Chrysanthemic acid of dallethrone]
Allyl alcohol
Allylamine
Allyl chloride
Aluminum (fume or dust)
Aluminum phosphide
Aluminum oxide (fibrous forms)
De minimus
% Limit
1.0
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
0.1
1.0
0.1
1.0
1.0
*
1.0
1.0
1.0
1.0
1.0
1.0
1.0
101-05-3
62-53-3
90-04-0
104-94-9
134-29-2
120-12-7
7440-36-0
7440-38-2
1332-21-4
1912-24-9
7440-39-3
22781-23-3
1861-40-1
17804-35-2
98-87-3
55-21-0
71-43-2
92-87-5
98-07-7
191-24-2
98-88-4
94-36-0
100-44-7
7440-41-7
82657-04-3
92-52-4
3296-90-0
111-91-1
De minimus
Chemical Name
% Limit
Ametryn
1.0
(N-Ethyl-N=-(1-methylethyl)-6(methylthio)-1,3,5,-triazine-2,4diamine)
2-Aminoanthraquinone
0.1
4-Aminoazobenzene
0.1
4-Aminobiphenyl
0.1
1-Amino-2-methylanthraquinone
0.1
1-Amino-2,40.1
dibromoanthraquinone
Amitraz
1.0
Amitrole
0.1
Ammonia
1.0
(includes anhydrous ammonia and
aqueous ammonia from water
dissociable ammonium salts and
other sources; 10 percent of total
aqueous ammonia is reportable
under this listing)
Anilazine
1.0
[4,6-Dichloro-N-(2-chlorophenyl)1,3,5-triazin-2-amine]
Aniline
1.0
o-Anisidine
0.1
p-Anisidine
1.0
o-Anisidine hydrochloride
0.1
Anthracene
1.0
Antimony
1.0
Arsenic
0.1
Asbestos (friable)
0.1
Atrazine
1.0
(6-Chloro-N-ethyl-N=-(1methylethyl)-1,3,5-triazine-2,4diamine)
Barium
1.0
Bendiocarb
1.0
[2,2-Dimethyl-1,3-benzodioxol-4ol methylcarbamate]
Benfluralin
1.0
(N-Butyl-N-ethyl-2,6-dinitro-4(trifluoromethyl)benzenamine)
Benomyl
1.0
Benzal chloride
1.0
Benzamide
1.0
Benzene
0.1
Benzidine
0.1
Benzoic
trichloride
0.1
(Benzotrichloride)
Benzo(g,h,i)perylene
*
Benzoyl chloride
1.0
Benzoyl peroxide
1.0
Benzyl chloride
1.0
Beryllium
0.1
Bifenthrin
1.0
Biphenyl
1.0
2,2-bis(Bromomethyl)-1,30.1
propanediol
Bis(2-chloroethoxy) methane
1.0
Toxics Release Inventory Reporting Forms and Instructions
II-3
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
111-44-4
542-88-1
108-60-1
56-35-9
10294-34-5
7637-07-2
314-40-9
53404-19-6
7726-95-6
35691-65-7
353-59-3
75-25-2
74-83-9
75-63-8
1689-84-5
1689-99-2
357-57-3
106-99-0
141-32-2
71-36-3
78-92-2
75-65-0
106-88-7
123-72-8
7440-43-9
156-62-7
133-06-2
63-25-2
1563-66-2
75-15-0
56-23-5
463-58-1
5234-68-4
120-80-9
2439-01-2
De minimus
Chemical Name
% Limit
Bis(2-chloroethyl) ether
1.0
Bis(chloromethyl) ether
0.1
Bis(2-chloro-1-methylethyl)ether
1.0
Bis(tributyltin) oxide
1.0
Boron trichloride
1.0
Boron trifluoride
1.0
Bromacil
1.0
(5-Bromo-6-methyl-3-(1methylpropyl)-2,4(1H,3H)pyrimidinedione)
Bromacil, lithium salt
1.0
[2,4(1H,3H)-Pyrimidinedione,5bromo-6-methyl-3-(1methylpropyl), lithium salt]
Bromine
1.0
1-Bromo-1-(bromomethyl)- 1,31.0
propanedicarbonitrile
Bromochlorodifluoromethane
1.0
(Halon 1211)
Bromoform (Tribromomethane)
1.0
Bromomethane
1.0
(Methyl bromide)
Bromotrifluoromethane
1.0
(Halon 1301)
Bromoxynil
1.0
(3,5-Dibromo-4hydroxybenzonitrile)
Bromoxynil octanoate
1.0
(Octanoic acid, 2,6-dibromo-4cyanophenylester)
Brucine
1.0
1,3-Butadiene
0.1
Butyl acrylate
1.0
n-Butyl alcohol
1.0
sec-Butyl alcohol
1.0
tert-Butyl alcohol
1.0
1,2-Butylene oxide
0.1
Butyraldehyde
1.0
Cadmium
0.1
Calcium cyanamide
1.0
Captan
1.0
[1H-Isoindole-1,3(2H)-dione,
3a,4,7,7a-tetrahydro-2[(trichloromethyl)thio]-]
Carbaryl [1-Naphthalenol,
1.0
methylcarbamate]
Carbofuran
1.0
Carbon disulfide
1.0
Carbon tetrachloride
0.1
Carbonyl sulfide
1.0
Carboxin
1.0
(5,6-Dihydro-2-methyl-N- phenyl1,4-oxathiin-3-carboxamide)
Catechol
0.1
Chinomethionat
1.0
[6-Methyl-1,3-dithiolo[4,5b]quinoxalin-2-one]
CAS
Number
133-90-4
57-74-9
115-28-6
90982-32-4
7782-50-5
10049-04-4
79-11-8
532-27-4
4080-31-3
106-47-8
108-90-7
510-15-6
75-68-3
75-45-6
75-00-3
67-66-3
74-87-3
107-30-2
563-47-3
104-12-1
76-06-2
126-99-8
542-76-7
63938-10-3
354-25-6
2837-89-0
1897-45-6
95-69-2
75-88-7
75-72-9
460-35-5
5598-13-0
De minimus
Chemical Name
% Limit
Chloramben
1.0
[Benzoic acid, 3-amino-2,5dichloro-]
Chlordane
*
[4,7-Methanoindan,
1,2,4,5,6,7,8,8-octachloro2,3,3a,4,7,7a-hexahydro-]
Chlorendic acid
0.1
Chlorimuron ethyl
1.0
[Ethyl-2-[[[[(4-chloro-6methoxyprimidin-2yl)amino]carbonyl]amino]sulfonyl
] benzoate]
Chlorine
1.0
Chlorine dioxide
1.0
Chloroacetic acid
1.0
2-Chloroacetophenone
1.0
1-(3-Chloroallyl)-3,5,7-triaza-11.0
azoniaadamantane chloride
p-Chloroaniline
0.1
Chlorobenzene
1.0
Chlorobenzilate
1.0
[Benzeneacetic acid, 4-chloro.alpha.- (4-chlorophenyl)-.alpha.hydroxy-, ethyl ester]
1-Chloro-1,1-difluoroethane
1.0
(HCFC-142b)
Chlorodifluoromethane
1.0
(HCFC-22)
Chloroethane (Ethyl chloride)
1.0
Chloroform
0.1
Chloromethane (Methyl chloride)
1.0
Chloromethyl methyl ether
0.1
3-Chloro-2-methyl-1-propene
0.1
p-Chlorophenyl isocyanate
1.0
Chloropicrin
1.0
Chloroprene
0.1
3-Chloropropionitrile
1.0
Chlorotetrafluoroethane
1.0
1-Chloro-1,1,2,21.0
tetrafluoroethane (HCFC-124a)
2-Chloro-1,1,1,21.0
tetrafluoroethane (HCFC-124)
Chlorothalonil
0.1
[1,3-Benzenedicarbonitrile,
2,4,5,6-tetrachloro-]
p-Chloro-o-toluidine
0.1
2-Chloro-1,1,1- trifluoroethane
1.0
(HCFC-133a)
Chlorotrifluoromethane (CFC-13)
1.0
3-Chloro-1,1,1- trifluoropropane
1.0
(HCFC-253fb)
Chlorpyrifos methyl
1.0
[O,O-Dimethyl-O-(3,5,6-trichloro2-pyridyl)phosphorothioate]
Toxics Release Inventory Reporting Forms and Instructions
II-4
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
64902-72-3
7440-47-3
4680-78-8
6459-94-5
569-64-2
989-38-8
1937-37-7
2602-46-2
28407-37-6
16071-86-6
2832-40-8
3761-53-3
81-88-9
3118-97-6
97-56-3
842-07-9
492-80-8
128-66-5
7440-48-4
7440-50-8
8001-58-9
120-71-8
108-39-4
95-48-7
106-44-5
1319-77-3
4170-30-3
98-82-8
80-15-9
135-20-6
21725-46-2
1134-23-2
110-82-7
108-93-0
68359-37-5
68085-85-8
94-75-7
533-74-4
Chemical Name
Chlorsulfuron
[2-Chloro-N-[[(4-methoxy-6methyl-1,3,5-triazin-2yl)amino]carbonyl]
benzenesulfonamide]
Chromium
C.I. Acid Green 3
C.I. Acid Red 114
C.I. Basic Green 4
C.I. Basic Red 1
C.I. Direct Black 38
C.I. Direct Blue 6
C.I. Direct Blue 218
C.I. Direct Brown 95
C.I. Disperse Yellow 3
C.I. Food Red 5
C.I. Food Red 15
C.I. Solvent Orange 7
C.I. Solvent Yellow 3
C.I. Solvent Yellow 14
C.I. Solvent Yellow 34
(Auramine)
C.I. Vat Yellow 4
Cobalt
Copper
Creosote
p-Cresidine
m-Cresol
o-Cresol
p-Cresol
Cresol (mixed isomers)
Crotonaldehyde
Cumene
Cumene hydroperoxide
[Benzeneamine, N-hydroxy- Nnitroso, ammonium salt]
Cyanazine
Cycloate
Cyclohexane
Cyclohexanol
Cyfluthrin
[3-(2,2-Dichloroethenyl)-2,2dimethylcyclopropanecarboxylic
acid, cyano(4-fluoro-3phenoxyphenyl) methyl ester]
Cyhalothrin
[3-(2-Chloro-3,3,3-trifluoro-1propenyl)-2,2dimethylcyclopropane-carboxylic
acid cyano(3phenoxyphenyl)methyl ester]
2,4-D
[Acetic acid, (2,4dichlorophenoxy)-]
Dazomet
(Tetrahydro-3,5-dimethyl-2H1,3,5-thiadiazine-2-thione)
De minimus
% Limit
1.0
1.0
1.0
0.1
1.0
1.0
0.1
0.1
1.0
0.1
1.0
0.1
1.0
1.0
0.1
1.0
0.1
1.0
0.1
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
CAS
Number
53404-60-7
94-82-6
1929-73-3
94-80-4
2971-38-2
1163-19-5
13684-56-5
1928-43-4
53404-37-8
2303-16-4
615-05-4
39156-41-7
101-80-4
95-80-7
25376-45-8
333-41-5
334-88-3
132-64-9
96-12-8
106-93-4
124-73-2
84-74-2
1918-00-9
99-30-9
1.0
1.0
1.0
1.0
1.0
1.0
95-50-1
541-73-1
106-46-7
25321-22-6
91-94-1
612-83-9
64969-34-2
75-27-4
764-41-0
110-57-6
1649-08-7
75-71-8
0.1
107-06-2
1.0
540-59-0
1717-00-6
De minimus
Chemical Name
% Limit
Dazomet, sodium salt
1.0
[Tetrahydro-3,5-dimethyl-2H1,3,5-thiadiazine-2-thione, ion(1-),
sodium]
2,4-DB
1.0
2,4-D butoxyethyl ester
0.1
2,4-D butyl ester
0.1
2,4-D chlorocrotyl ester
0.1
Decabromodiphenyl oxide
1.0
Desmedipham
1.0
2,4-D 2-ethylhexyl ester
0.1
2,4-D 2-ethyl-4- methylpentyl
0.1
ester
Diallate
1.0
[Carbamothioic acid, bis(1methylethyl)-S-(2,3-dichloro-2propenyl) ester]
2,4-Diaminoanisole
0.1
2,4-Diaminoanisole sulfate
0.1
4,4'-Diaminodiphenyl ether
0.1
2,4-Diaminotoluene
0.1
Diaminotoluene (mixed isomers)
0.1
Diazinon
1.0
Diazomethane
1.0
Dibenzofuran
1.0
1,2-Dibromo-3- chloropropane
0.1
(DBCP)
1,2-Dibromoethane
0.1
(Ethylene dibromide)
Dibromotetrafluoroethane
1.0
(Halon 2402)
Dibutyl phthalate
1.0
Dicamba
1.0
(3,6-Dichloro-2-methoxybenzoic
acid)
Dichloran
1.0
[2,6-Dichloro-4-nitroaniline]
1,2-Dichlorobenzene
1.0
1,3-Dichlorobenzene
1.0
1,4-Dichlorobenzene
0.1
Dichlorobenzene (mixed isomers)
0.1
3,3'-Dichlorobenzidine
0.1
3,3'-Dichlorobenzidine
0.1
dihydrochloride
3,3'-Dichlorobenzidine sulfate
0.1
Dichlorobromomethane
0.1
1,4-Dichloro-2-butene
1.0
trans-1,4-Dichloro-2-butene
1.0
1,2-Dichloro-1,1- difluoroethane
1.0
(HCFC-132b)
Dichlorodifluoromethane (CFC1.0
12)
1,2-Dichloroethane (Ethylene
0.1
dichloride)
1,2-Dichloroethylene
1.0
1,1-Dichloro-1-fluoroethane
1.0
(HCFC-141b)
Toxics Release Inventory Reporting Forms and Instructions
II-5
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
75-43-4
75-09-2
127564-92-5
13474-88-9
111512-56-2
422-44-6
431-86-7
507-55-1
136013-79-1
128903-21-9
422-48-0
422-56-0
97-23-4
120-83-2
78-87-5
10061-02-6
78-88-6
542-75-6
76-14-2
34077-87-7
90454-18-5
812-04-4
354-23-4
306-83-2
62-73-7
51338-27-3
De minimus
Chemical Name
% Limit
Dichlorofluoromethane (HCFC1.0
21)
Dichloromethane (Methylene
0.1
chloride)
Dichloropentafluoropropane
1.0
1,1-Dichloro-1,2,2,3,31.0
pentafluoropropane (HCFC225cc)
1,1-Dichloro-1,2,3,3,31.0
pentafluoropropane (HCFC225eb)
1,2-Dichloro-1,1,2,3,31.0
pentafluoropropane (HCFC225bb)
1,2-Dichloro-1,1,3,3,31.0
pentafluoropropane (HCFC225da)
1,3-Dichloro-1,1,2,2,31.0
pentafluoropropane (HCFC225cb)
1,3-Dichloro-1,1,2,3,31.0
pentafluoropropane (HCFC225ea)
2,2-Dichloro-1,1,1,3,31.0
pentafluoropropane (HCFC225aa)
pentafluoropropane (HCFC1.0
225ba)
3,3-Dichloro-1,1,1,2,21.0
pentafluoropropane (HCFC225ca)
Dichlorophene
1.0
[2,2'-Methylenebis(4chlorophenol)]
2,4-Dichlorophenol
1.0
1,2-Dichloropropane
1.0
trans-1,3-Dichloropropene
0.1
2,3-Dichloropropene
1.0
1,3-Dichloropropylene
0.1
Dichlorotetrafluoroethane
1.0
(CFC-114)
Dichlorotrifluoroethane
1.0
Dichloro-1,1,2-trifluoroethane
1.0
1,1-Dichloro-1,2,2- trifluoroethane
1.0
(HCFC-123b)
1,2-Dichloro-1,1,2- trifluoroethane
1.0
(HCFC-123a)
2,2-Dichloro-1,1,1- trifluoroethane
1.0
(HCFC-123)
Dichlorvos
0.1
[Phosphoric acid, 2,2dichloroethenyl dimethyl ester]
Diclofop methyl
1.0
[2-[4-(2,4Dichlorophenoxy)phenoxy]
propanoic acid, methyl ester]
CAS
Number
115-32-2
77-73-6
1464-53-5
111-42-2
38727-55-8
117-81-7
64-67-5
35367-38-5
101-90-6
94-58-6
55290-64-7
60-51-5
119-90-4
20325-40-0
111984-09-9
124-40-3
2300-66-5
60-11-7
121-69-7
119-93-7
612-82-8
41766-75-0
79-44-7
2524-03-0
68-12-2
57-14-7
105-67-9
131-11-3
77-78-1
99-65-0
528-29-0
100-25-4
88-85-7
534-52-1
51-28-5
121-14-2
606-20-2
25321-14-6
39300-45-3
123-91-1
957-51-7
122-39-4
122-66-7
Chemical Name
Dicofol
[Benzenemethanol, 4-chloro.alpha
Dicyclopentadiene
Diepoxybutane
Diethanolamine
Diethatyl ethyl
Di(2-ethylhexyl) phthalate
(DEHP)
Diethyl sulfate
Diflubenzuron
Diglycidyl resorcinol ether
Dihydrosafrole
Dimethipin
[2,3-Dihydro-5,6-dimethyl-1,4dithiin 1,1,4,4-tetraoxide]
Dimethoate
3,3'-Dimethoxybenzidine
3,3'-Dimethoxybenzidine
dihydrochloride (o-Dianisidine
dihydrochloride)
3,3'-Dimethoxybenzidine
hydrochloride (o-Dianisidine
hydrochloride)
Dimethylamine
Dimethylamine dicamba
4-Dimethylaminoazobenzene
N,N-Dimethylaniline
3,3'-Dimethylbenzidine (oTolidine)
3,3'-Dimethylbenzidine
dihydrochloride (o-Tolidine
dihydrochloride)
3,3'-Dimethylbenzidine
dihydrofluoride (o-Tolidine
dihydrofluoride)
Dimethylcarbamyl chloride
Dimethyl chlorothiophosphate
N,N-Dimethylformamide
1,1-Dimethyl hydrazine
2,4-Dimethylphenol
Dimethyl phthalate
Dimethyl sulfate
m-Dinitrobenzene
o-Dinitrobenzene
p-Dinitrobenzene
Dinitrobutyl phenol (Dinoseb)
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Dinitrotoluene (mixed isomers)
Dinocap
1,4-Dioxane
Diphenamid
Diphenylamine
1,2-Diphenylhydrazine
(Hydrazobenzene)
Toxics Release Inventory Reporting Forms and Instructions
De minimus
% Limit
1.0
1.0
0.1
1.0
1.0
0.1
0.1
1.0
0.1
0.1
1.0
1.0
0.1
0.1
0.1
1.0
1.0
0.1
1.0
0.1
0.1
0.1
0.1
1.0
1.0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
0.1
II-6
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
2164-07-0
136-45-8
138-93-2
94-11-1
541-53-7
330-54-1
2439-10-3
120-36-5
1320-18-9
2702-72-9
106-89-8
13194-48-4
110-80-5
140-88-5
100-41-4
541-41-3
759-94-4
74-85-1
107-21-1
151-56-4
75-21-8
96-45-7
75-34-3
52-85-7
60168-88-9
13356-08-6
66441-23-4
72490-01-8
39515-41-8
55-38-9
De minimus
Chemical Name
% Limit
Dipotassium endothall
1.0
[7-Oxabicyclo(2.2.1)heptane-2,3dicarboxylic acid, dipotassium
salt]
Dipropyl isocinchomeronate
1.0
Disodium
1.0
cyanodithioimidocarbonate
2,4-D isopropyl ester
0.1
2,4-Dithiobiuret
1.0
Diuron
1.0
Dodine [Dodecylguanidine
1.0
monoacetate]
2,4-DP
0.1
2,4-D propylene glycol butyl ether
0.1
ester
2,4-D sodium salt
0.1
Epichlorohydrin
0.1
Ethoprop
1.0
[Phosphorodithioic acid O-ethyl
S,S-dipropyl ester]
2-Ethoxyethanol
1.0
Ethyl acrylate
0.1
Ethylbenzene
0.1
Ethyl chloroformate
1.0
Ethyl dipropylthiocarbamate
1.0
(EPTC)
Ethylene
1.0
Ethylene glycol
1.0
Ethyleneimine (Aziridine)
0.1
Ethylene oxide
0.1
Ethylene thiourea
0.1
Ethylidene dichloride
1.0
Famphur
1.0
Fenarimol
1.0
[.alpha.-(2-Chlorophenyl)-.alpha.(4-chlorophenyl)-5pyrimidinemethanol]
Fenbutatin oxide
1.0
(Hexakis(2-methyl-2phenylpropyl) distannoxane)
Fenoxaprop ethyl
1.0
[2-(4-((6-Chloro-2benzoxazolylen)oxy)phenoxy)prop
anoic acid, ethyl ester]
Fenoxycarb
1.0
[[2-(4Phenoxyphenoxy)ethyl]carbamic
acid ethyl ester]
Fenpropathrin
1.0
[2,2,3,3-Tetramethylcyclopropane
carboxylic acid cyano(3phenoxyphenyl)methyl ester]
Fenthion
1.0
[O,O-Dimethyl O-[3-methyl-4(methylthio)phenyl] ester,
phosphorothioic acid]
CAS
Number
51630-58-1
14484-64-1
69806-50-4
2164-17-2
7782-41-4
51-21-8
69409-94-5
133-07-3
72178-02-0
50-00-0
64-18-6
76-13-1
110-00-9
556-52-5
76-44-8
118-74-1
87-68-3
319-84-6
77-47-4
67-72-1
1335-87-1
70-30-4
680-31-9
110-54-3
51235-04-2
67485-29-4
302-01-2
10034-93-2
Chemical Name
Fenvalerate
[4-Chloro-alpha-(1-methylethyl)
benzeneacetic acid cyano (3phenoxyphenyl) methyl ester]
Ferbam
[Tris(dimethylcarbamodithioatoS,S’)iron]
Fluazifop butyl
[2-[4-[[5-(Trifluoromethyl)-2pyridinyl]oxy]phenoxy]propanoic
acid, butyl ester]
Fluometuron
[Urea, N,N-dimethyl-N=-[3(trifluoromethyl)phenyl]-]
Fluorine
Fluorouracil (5-Fluorouracil)
Fluvalinate
[N-[2-Chloro-4(trifluoromethyl)phenyl]-DLvaline(+)-cyano(3phenoxyphenyl)methyl ester]
Folpet
Fomesafen
[5-(2-Chloro-4(trifluoromethyl)phenoxy)-Nmethylsulfonyl-2-nitrobenzamide]
Formaldehyde
Formic acid
Freon 113
[Ethane, 1,1,2-trichloro-1,2,2,trifluoro-]
Furan
Glycidol
Heptachlor
[1,4,5,6,7,8,8-Heptachloro-3a,
4,7,7a-tetrahydro-4,7-methano1H-indene]
Hexachlorobenzene
Hexachloro-1,3-butadiene
alpha-Hexachlorocyclohexane
Hexachlorocyclopentadiene
Hexachloroethan
Hexachloronaphthalene
Hexachlorophene
Hexamethylphosphoramide
n-Hexane
Hexazinone
Hydramethylnon
[Tetrahydro-5,5-dimethyl-2(1H)pyrimidinone[3-[4(trifluoromethyl)phenyl]-1-[2-[4(trifluoromethyl)phenyl]ethenyl]2-propenylidene]hydrazone]
Hydrazine
Hydrazine sulfate
Toxics Release Inventory Reporting Forms and Instructions
De minimus
% Limit
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
0.1
0.1
*
*
1.0
0.1
1.0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
0.1
0.1
II-7
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
7647-01-0
74-90-8
7664-39-3
7783-06-4
123-31-9
35554-44-0
55406-53-6
13463-40-6
78-84-2
465-73-6
25311-71-1
78-79-5
67-63-0
80-05-7
120-58-1
77501-63-4
7439-92-1
58-89-9
330-55-2
554-13-2
121-75-5
108-31-6
109-77-3
12427-38-2
7439-96-5
93-65-2
149-30-4
7439-97-6
150-50-5
126-98-7
137-42-8
67-56-1
De minimus
Chemical Name
% Limit
Hydrochloric acid
1.0
(acid aerosols including mists,
vapors, gas, fog, and other
airborne forms of any particle
size)
Hydrogen cyanide
1.0
Hydrogen fluoride
1.0
Hydrogen sulfide
1.0
Hydroquinone
1.0
Imazalil
1.0
[1-[2-(2,4-Dichlorophenyl)-2-(2propenyloxy)ethyl]-1H-imidazole]
3-Iodo-2-propynyl butylcarbamate
1.0
Iron pentacarbonyl
1.0
Isobutyraldehyde
1.0
Isodrin
*
Isofenphos[2-[[Ethoxyl[(11.0
methylethyl)amino]phosphinothio
yl]oxy] benzoic acid 1methylethyl ester]
Isoprene
0.1
Isopropyl alcohol
1.0
(only persons who manufacture by
the strong acid process are subject,
no supplier notification)
4,4'-Isopropylidenediphenol
1.0
Isosafrole
1.0
[Benzoic acid, 5-[2-Chloro-41.0
(trifluoromethyl)phenoxy]-2-nitro, 2-ethoxy-1-methyl-2-oxoethyl
ester]
Lead
*
(when lead is contained in
stainless steel, brass or bronze
alloys the de minimis level is 0.1)
Lindane
0.1
[Cyclohexane, 1,2,3,4,5,6hexachloro-,
(1.alpha.,2.alpha.,3.beta.,4.alpha.,5
.alpha., 6.beta.)-]
Linuron
1.0
Lithium carbonate
1.0
Malathion
1.0
Maleic anhydride
1.0
Malononitrile
1.0
Maneb
1.0
[Carbamodithioic acid, 1,2ethanediylbis-, manganese
complex]
Manganese
1.0
Mecoprop
0.1
2-Mercaptobenzothiazole (MBT)
1.0
Mercury
*
Merphos
1.0
Methacrylonitrile
1.0
Metham sodium (Sodium
1.0
methyldithiocarbamate)
Methanol
1.0
CAS
Number
20354-26-1
2032-65-7
94-74-6
3653-48-3
72-43-5
109-86-4
96-33-3
1634-04-4
79-22-1
101-14-4
101-61-1
74-95-3
101-77-9
93-15-2
60-34-4
74-88-4
108-10-1
624-83-9
556-61-6
75-86-5
80-62-6
924-42-5
298-00-0
109-06-8
872-50-4
9006-42-2
21087-64-9
7786-34-7
90-94-8
2212-67-1
1313-27-5
76-15-3
150-68-5
505-60-2
88671-89-0
142-59-6
300-76-5
91-20-3
134-32-7
91-59-8
7440-02-0
De minimus
Chemical Name
% Limit
Methazole
1.0
[2-(3,4-Dichlorophenyl)-4-methyl1,2,4-oxadiazolidine-3,5-dione]
Methiocarb
1.0
Methoxone
0.1
((4-Chloro-2-methylphenoxy)
acetic acid) (MCPA)
Methoxone sodium salt
0.1
((4-Chloro-2-methylphenoxy)
acetate sodium salt)
Methoxychlor
*
[Benzene, 1,1'-(2,2,2trichloroethylidene)bis[4methoxy-]
2-Methoxyethanol
1.0
Methyl acrylate
1.0
Methyl tert-butyl ether
1.0
Methyl chlorocarbonate
1.0
4,4'-Methylenebis(2-chloroaniline)
0.1
(MBOCA)
4,4'-Methylenebis(N,N-dimethyl)
0.1
benzenamine
Methylene bromide
1.0
4,4'-Methylenedianiline
0.1
Methyleugenol
0.1
Methyl hydrazine
1.0
Methyl iodide
1.0
Methyl isobutyl ketone
1.0
Methyl isocyanate
1.0
Methyl isothiocyanate
1.0
[Isothiocyanatomethane]
2-Methyllactonitrile
1.0
Methyl methacrylate
1.0
N-Methylolacrylamide
1.0
Methyl parathion
1.0
2-Methylpyridine
1.0
N-Methyl-2-pyrrolidone
1.0
Metiram
1.0
Metribuzin
1.0
Mevinphos
1.0
Michler’s ketone
0.1
Molinate
1.0
(1H-Azepine-1-carbothioic acid,
hexahydro-, S-ethyl ester)
Molybdenum trioxide
1.0
(CFC-115)
1.0
Monuron
1.0
[Ethane, 1,1'-thiobis[2-chloro-]
0.1
Myclobutanil
1.0
[.alpha.-Butyl-.alpha.-(4chlorophenyl)-1H-1,2,4-triazole-1propanenitrile]
Nabam
1.0
Naled
1.0
Naphthalene
0.1
alpha-Naphthylamine
0.1
beta-Naphthylamine
0.1
Nickel
0.1
Toxics Release Inventory Reporting Forms and Instructions
II-8
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
1929-82-4
7697-37-2
139-13-9
100-01-6
91-23-6
99-59-2
98-95-3
92-93-3
1836-75-5
51-75-2
55-63-0
75-52-5
88-75-5
100-02-7
79-46-9
924-16-3
55-18-5
62-75-9
86-30-6
156-10-5
621-64-7
759-73-9
684-93-5
4549-40-0
59-89-2
16543-55-8
100-75-4
88-72-2
99-55-8
27314-13-2
2234-13-1
29082-74-4
19044-88-3
20816-12-0
301-12-2
19666-30-9
42874-03-3
10028-15-6
123-63-7
1910-42-5
Chemical Name
Nitrapyrin
(2-Chloro-6(trichloromethyl)pyridine)
Nitric acid
Nitrilotriacetic acid
p-Nitroaniline
o-Nitroanisole
5-Nitro-o-anisidine
Nitrobenzene
4-Nitrobiphenyl
Nitrofen
[Benzene, 2,4-dichloro-1-(4nitrophenoxy)-]
Nitrogen mustard
[2-Chloro-N-(2-chloroethyl)-Nmethylethanamine]
Nitroglycerin
Nitromethane
2-Nitrophenol
4-Nitrophenol
2-Nitropropane
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
p-Nitrosodiphenylamine
N-Nitrosodi-n-propylamine
N-Nitroso-N-ethylurea
N-Nitroso-N-methylurea
N-Nitrosomethylvinylamine
N-Nitrosomorpholine
N-Nitrosonornicotine
N-Nitrosopiperidine
o-Nitrotoluene
5-Nitro-o-toluidine
Norflurazon
[4-Chloro-5-(methylamino)-2-[3(trifluoromethyl)phenyl]-3(2H)pyridazinone]
Octachloronaphthalene
Octachlorostyrene
Oryzalin
[4-(Dipropylamino)-3,5dinitrobenzene sulfonamide]
Osmium tetroxide
Oxydemeton methyl
[S-(2-(Ethylsulfinyl)ethyl) O,Odimethyl ester phosphorothioic
acid]
Oxydiazon
[3-[2,4-Dichloro-5-(1methylethoxy)phenyl]- 5-(1,1dimethylethyl)-1,3,4-oxadiazol2(3H)-one]
Oxyfluorfen
Ozone
Paraldehyde
Paraquat dichloride
De minimus
% Limit
1.0
1.0
0.1
1.0
0.1
1.0
0.1
0.1
0.1
0.1
1.0
0.1
1.0
1.0
0.1
0.1
0.1
0.1
1.0
1.0
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
1.0
1.0
1.0
*
1.0
1.0
1.0
CAS
Number
56-38-2
1114-71-2
40487-42-1
608-93-5
76-01-7
87-86-5
57-33-0
79-21-0
594-42-3
52645-53-1
85-01-8
108-95-2
77-09-8
26002-80-2
95-54-5
108-45-2
106-50-3
615-28-1
624-18-0
90-43-7
57-41-0
75-44-5
7803-51-2
7723-14-0
85-44-9
1918-02-1
88-89-1
51-03-6
29232-93-7
1336-36-3
1.0
7758-01-2
128-03-0
137-41-7
1.0
1.0
1.0
1.0
41198-08-7
Chemical Name
Parathion
[Phosphorothioic acid, O,Odiethyl-O-(4-nitrophenyl)ester]
Pebulate
[Butylethylcarbamothioic acid Spropyl ester]
Pendimethalin
[N-(1-Ethylpropyl)-3,4-dimethyl2,6-dinitrobenzenamine]
Pentachlorobenzene
Pentachloroethane
Pentachlorophenol (PCP)
Pentobarbital sodium
Peracetic acid
Perchloromethyl mercaptan
Permethrin
[3-(2,2-Dichloroethenyl)-2,2dimethylcyclopropanecarboxylic
acid, (3-phenoxyphenyl) methyl
ester]
Phenanthrene
Phenol
Phenolphthalein
Phenothrin
[2,2-Dimethyl-3-(2-methyl-1propenyl)cyclopropanecarboxylic
acid (3-phenoxyphenyl)methyl
ester]
1,2-Phenylenediamine
1,3-Phenylenediamine
p-Phenylenediamine
1,2-Phenylenediamine dihydrochloride
1,4-Phenylenediamine dihydrochloride
2-Phenylphenol
Phenytoin
Phosgene
Phosphine
Phosphorus (yellow or white)
Phthalic anhydride
Picloram
Picric acid
Piperonyl butoxide
Pirimiphos methyl
[O-(2-(Diethylamino)-6-methyl-4pyrimidinyl)-O,Odimethylphosphorothioate]
Polychlorinated biphenyls
(PCBs)
Potassium bromate
Potassium dimethyldithiocarbamate
Potassium N-methyldithiocarbamate
Profenofos
[O-(4-Bromo-2-chlorophenyl)-Oethyl-S-propyl phosphorothioate]
Toxics Release Inventory Reporting Forms and Instructions
De minimus
% Limit
1.0
1.0
*
*
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
*
0.1
1.0
1.0
1.0
II-9
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
7287-19-6
23950-58-5
1918-16-7
1120-71-4
709-98-8
2312-35-8
107-19-7
31218-83-4
60207-90-1
57-57-8
123-38-6
114-26-1
115-07-1
75-55-8
75-56-9
110-86-1
91-22-5
106-51-4
82-68-8
76578-14-8
10453-86-8
81-07-2
94-59-7
7782-49-2
74051-80-2
7440-22-4
122-34-9
26628-22-8
Chemical Name
Prometryn
[N,N’-Bis(1-methylethyl)-6methylthio-1,3,5-triazine-2,4diamine]
Pronamide
Propachlor
[2-Chloro-N-(1-methylethyl)-Nphenylacetamide]
Propane sultone
[N-(3,4Dichlorophenyl)propanamide]
Propargite
Propargyl alcohol
Propetamphos
[3[(Ethylamino)methoxyphosphinot
hioyl] oxy]-2-butenoic acid, 1methylethyl ester]
Propiconazole
[1-[2-(2,4-Dichlorophenyl)-4propyl-1,3-dioxolan-2-yl]-methyl1H-1,2,4,-triazole]
beta-Propiolactone
Propionaldehyde
Propoxur
[Phenol, 2-(1-methylethoxy)-,
methylcarbamate]
Propylene (Propene)
Propyleneimine
Propylene oxide
Pyridine
Quinoline
Quinone
Quintozene
(Pentachloronitrobenzene)
Quizalofop-ethyl
[2-[4-[(6-Chloro-2quinoxalinyl)oxy]phenoxy]
propanoic acid ethyl ester]
Resmethrin
[[5-(Phenylmethyl)-3furanyl]methyl-2,2-dimethyl-3-(2methyl-1-propenyl)
cyclopropanecarboxylate]
Saccharin (only persons who
manufacture are subject, no
supplier notification)
Safrole
Selenium
Sethoxydim
[2-[1-(Ethoxyimino)butyl]-5-[2(ethylthio)propyl]-3-hydroxyl-2cyclohexen-1-one]
Silver
Simazine
Sodium azide
De minimus
% Limit
1.0
1.0
1.0
0.1
1.0
CAS
Number
1982-69-0
128-04-1
62-74-8
7632-00-0
131-52-2
132-27-4
100-42-5
96-09-3
7664-93-9
1.0
1.0
1.0
2699-79-8
35400-43-2
1.0
34014-18-1
0.1
1.0
1.0
3383-96-8
5902-51-2
1.0
0.1
0.1
1.0
1.0
1.0
1.0
79-94-7
630-20-6
79-34-5
127-18-4
1.0
354-11-0
354-14-3
1.0
1.0
961-11-5
64-75-5
116-14-3
509-14-8
7696-12-0
0.1
1.0
1.0
1.0
1.0
1.0
7440-28-0
148-79-8
62-55-5
De minimus
Chemical Name
% Limit
Sodium dicamba
1.0
[3,6-Dichloro-2-methoxybenzoic
acid, sodium salt]
Sodium dimethyldithiocarbamate
1.0
Sodium fluoroacetate
1.0
Sodium nitrite
1.0
Sodium pentachlorophenate
1.0
Sodium o-phenylphenoxide
0.1
Styrene
0.1
Styrene oxide
0.1
Sulfuric acid
1.0
(acid aerosols including mists,
vapors, gas, fog, and other
airborne forms of any particle
size)
Sulfuryl fluoride (Vikane)
1.0
Sulprofos
1.0
[O-Ethyl O-[4(methylthio)phenyl]
phosphorodithioic acid Spropylester]
Tebuthiuron
1.0
[N-[5-(1,1-Dimethylethyl)-1,3,4thiadiazol-2-yl]-N,N’dimethylurea]
Temephos
1.0
Terbacil
1.0
[5-Chloro-3-(1,1-dimethylethyl)6-methyl-2,4(1H,3H)pyrimidinedione]
Tetrabromobisphenol A
*
1,1,1,2-Tetrachloroethane
1.0
1,1,2,2-Tetrachloroethane
1.0
Tetrachloroethylene
0.1
(Perchloroethylene)
1,1,1,2-Tetrachloro-2-fluoroethane
1.0
(HCFC-121a)
1,1,2,2-Tetrachloro-1-fluoroethane
1.0
(HCFC-121)
Tetrachlorvinphos
1.0
[Phosphoric acid, 2-chloro-1(2,4,5-trichlorophenyl) ethenyl
dimethyl ester]
Tetracycline hydrochloride
1.0
Tetrafluoroethylene
0.1
Tetranitromethane
0.1
Tetramethrin
1.0
[2,2-Dimethyl-3-(2-methyl-1propenyl) cyclopropanecarboxylic
acid (1,3,4,5,6,7-hexahydro-1,3dioxo-2H-isoindol-2-yl)methyl
ester]
Thallium
1.0
Thiabendazole
1.0
[2-(4-Thiazolyl)-1Hbenzimidazole]
Thioacetamide
0.1
Toxics Release Inventory Reporting Forms and Instructions
II-10
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
28249-77-6
139-65-1
59669-26-0
23564-06-9
23564-05-8
79-19-6
62-56-6
137-26-8
1314-20-1
7550-45-0
108-88-3
584-84-9
91-08-7
26471-62-5
95-53-4
636-21-5
8001-35-2
43121-43-3
2303-17-5
68-76-8
101200-48-0
1983-10-4
2155-70-6
78-48-8
52-68-6
76-02-8
120-82-1
71-55-6
79-00-5
79-01-6
75-69-4
95-95-4
88-06-2
96-18-4
57213-69-1
121-44-8
1582-09-8
De minimus
Chemical Name
% Limit
Thiobencarb
1.0
[Carbamic acid, diethylthio-, S-(pchlorobenzyl)ester]
4,4'-Thiodianiline
0.1
Thiodicarb
1.0
Thiophanate ethyul
1.0
[[1,2Phenylenebis(iminocarbonothioyl)
] biscarbamic acid diethylester]
Thiophanate methyl
1.0
Thiosemicarbazide
1.0
Thiourea
0.1
Thiram
1.0
Thorium dioxide
1.0
Titanium tetrachloride
1.0
Toluene
1.0
Toluene-2,4-diisocyanate
0.1
Toluene-2,6-diisocyanate
0.1
Toluene diisocyanate (mixed
0.1
isomers)
o-Toluidine
0.1
o-Toluidine hydrochloride
0.1
Toxaphene
*
Triadimefon
1.0
[1-(4-Chlorophenoxy)-3,3-dimethyl-1-(1H-1,2,4- triazol-1-yl)2-butanone]
Triallate
1.0
Triaziquone
1.0
[2,5-Cyclohexadiene-1,4-dione,
2,3,5-tris(1-aziridinyl)-]
Tribenuron methyl
1.0
[2-[[[[(4-Methoxy-6-methyl-1,3,5triazin-2-yl)-methylamino]carbonyl]amino]sulfonyl] benzoic
acid methyl ester)
Tributyltin fluoride
1.0
Tributyltin methacrylate
1.0
S,S,S-Tributyltrithio- phosphate
1.0
(DEF)
Trichlorfon
1.0
[Phosphoric acid,(2,2,2-trichloro-lhydroxy-ethyl)-, dimethyl ester]
Trichloroacetyl chloride
1.0
1,2,4-Trichlorobenzene
1.0
1,1,1-Trichloroethane (Methyl
1.0
chloroform)
1,1,2-Trichloroethane
1.0
Trichloroethylene
0.1
Trichlorofluoromethane (CFC-11)
1.0
2,4,5-Trichlorophenol
1.0
2,4,6-Trichlorophenol
0.1
1,2,3-Trichloropropane
0.1
Triclopyr triethylammonium salt
1.0
Triethylamine
1.0
Trifluralin
*
[Benezeneamine, 2,6-dinitro-N,Ndipropyl-4-(trifluoromethyl)-]
CAS
Number
26644-46-2
95-63-6
2655-15-4
639-58-7
76-87-9
126-72-7
72-57-1
51-79-6
7440-62-2
50471-44-8
108-05-4
593-60-2
75-01-4
75-02-5
75-35-4
108-38-3
95-47-6
106-42-3
1330-20-7
87-62-7
7440-66-6
12122-67-7
b.
CAS
Number
50-00-0
51-03-6
51-21-8
51-28-5
51-75-2
51-79-6
52-68-6
52-85-7
53-96-3
55-18-5
55-21-0
De minimus
Chemical Name
% Limit
Triforine
1.0
[N,N’-[1,4-Piperazinediylbis(2,2,2trichloroethylidene)]bisformamide
]
1,2,4-Trimethylbenzene
1.0
2,3,5-Trimethylphenyl
1.0
methylcarbamate
Triphenyltin chloride
1.0
Triphenyltin hydroxide
1.0
Tris(2,3-dibromopropyl)
0.1
phosphate
Trypan blue
0.1
Urethane (Ethyl carbamate)
0.1
Vanadium (except when contained
1.0
in an alloy)
Vinclozolin
1.0
[3-(3,5-Dichlorophenyl)-5ethenyl-5-methyl-2,4oxazolidinedione]
Vinyl acetate
0.1
Vinyl bromide
0.1
Vinyl chloride
0.1
Vinyl fluoride
0.1
Vinylidene chloride
1.0
m-Xylene
1.0
o-Xylene
1.0
p-Xylene
1.0
Xylene (mixed isomers)
1.0
2,6-Xylidine
0.1
Zinc (fume or dust)
1.0
Zineb
1.0
[Carbamodithioic acid, 1,2ethanediyibis-, zinc complex]
Individually Listed Toxic Chemicals Arranged
by CAS Number
De minimus
Chemical Name
% Limit
Arranged by CAS Number
Formaldehyde
0.1
Piperonyl butoxide
1.0
Fluorouracil (5-Fluorouracil)
1.0
2,4-Dinitrophenol
1.0
Nitrogen mustard
0.1
[2-Chloro-N-(2-chloroethyl)-Nmethylethanamine]
Urethane (Ethyl carbamate)
0.1
Trichlorfon
1.0
[Phosphonic acid, (2,2,2-trichloro1-hydroxyethyl)-, dimethyl ester]
Famphur
1.0
2-Acetylaminofluorene
0.1
N-Nitrosodiethylamine
0.1
Benzamide
1.0
Toxics Release Inventory Reporting Forms and Instructions
II-11
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
55-38-9
55-63-0
56-23-5
56-35-9
56-38-2
57-14-7
57-33-0
57-41-0
57-57-8
57-74-9
58-89-9
59-89-2
60-09-3
60-11-7
60-34-4
60-35-5
60-51-5
61-82-5
62-53-3
62-55-5
62-56-6
62-73-7
62-74-8
62-75-9
63-25-2
64-18-6
64-67-5
64-75-5
67-56-1
67-63-0
67-66-3
67-72-1
68-12-2
68-76-8
70-30-4
71-36-3
71-43-2
De minimus
Chemical Name
% Limit
Arranged by CAS Number
Fenthion
1.0
[O,O-Dimethyl O-[3-methyl-4(methylthio)phenyl] ester,
phosphorothioic acid]
Nitroglycerin
1.0
Carbon tetrachloride
0.1
Bis(tributyltin) oxide
1.0
Parathion
1.0
[Phosphorothioic acid, O,Odiethyl-O-(4-nitrophenyl) ester]
1,1-Dimethylhydrazine
0.1
Pentobarbital sodium
1.0
Phenytoin
0.1
beta-Propiolactone
0.1
Chlordane
*
[4,7-Methanoindan,
1,2,4,5,6,7,8,8-octachloro2,3,3a,4,7,7a-hexahydro-]
[Cyclohexane, 1,2,3,4,5,60.1
hexachloro-,
(1.alpha.,2.alpha.,3.beta.,4.alpha,
5.alpha.,6.beta.)-]
N-Nitrosomorpholine
0.1
4-Aminoazobenzene
0.1
4-Dimethylaminoazobenzene
0.1
Methyl hydrazine
1.0
Acetamide
0.1
Dimethoate
1.0
Amitrole
0.1
Aniline
1.0
Thioacetamide
0.1
Thiourea
0.1
Dichlorvos
0.1
[Phosphoric acid, 2,2dichloroethenyl dimethyl ester]
Sodium fluoroacetate
1.0
N-Nitrosodimethylamine
0.1
Carbaryl
1.0
[1-Naphthalenol,
methylcarbamate]
Formic acid
1.0
Diethyl sulfate
0.1
Tetracycline hydrochloride
1.0
Methanol
1.0
Isopropyl alcohol
1.0
(only persons who manufacture by
the strong acid process are subject,
no supplier notification)
Chloroform
0.1
Hexachloroethane
0.1
N,N-Dimethylformamide
1.0
Triaziquone
1.0
[2,5-Cyclohexadiene-1,4-dione,
2,3,5-tris(1-aziridinyl)-]
Hexachlorophene
1.0
n-Butyl alcohol
1.0
Benzene
0.1
CAS
Number
71-55-6
72-43-5
72-57-1
74-83-9
74-85-1
74-87-3
74-88-4
74-90-8
74-95-3
75-00-3
75-01-4
75-02-5
75-05-8
75-07-0
75-09-2
75-15-0
75-21-8
75-25-2
75-27-4
75-34-3
75-35-4
75-43-4
75-44-5
75-45-6
75-52-5
75-55-8
75-56-9
75-63-8
75-65-0
75-68-3
75-69-4
75-71-8
75-72-9
75-86-5
75-88-7
76-01-7
76-02-8
76-06-2
76-13-1
76-14-2
76-15-3
Chemical Name
Arranged by CAS Number
1,1,1-Trichloroethane (Methyl
chloroform)
Methoxychlor
[Benzene, 1,1'-(2,2,2trichloroethylidene)bis[4methoxy-]
Trypan blue
Bromomethane (Methyl bromide)
Ethylene
Chloromethane (Methyl chloride)
Methyl iodide
Hydrogen cyanide
Methylene bromide
Chloroethane (Ethyl chloride)
Vinyl chloride
Vinyl fluoride
Acetonitrile
Acetaldehyde
Dichloromethane (Methylene
chloride)
Carbon disulfide
Ethylene oxide
Bromoform (Tribromomethane)
Dichlorobromomethane
Ethylidene dichloride
Vinylidene chloride
Dichlorofluoromethane (HCFC21)
Phosgene
Chlorodifluoromethane (HCFC22)
Nitromethane
Propyleneimine
Propylene oxide
Bromotrifluoromethane (Halon
1301)
tert-Butyl alcohol
1-Chloro-1,1-difluoroethane
(HCFC-142b)
Trichlorofluoromethane (CFC-11)
Dichlorodifluoromethane (CFC12)
Chlorotrifluoromethane (CFC-13)
2-Methyllactonitrile
2-Chloro-1,1,1-trifluoroethane
(HCFC-133a)
Pentachloroethane
Trichloroacetyl chloride
Chloropicrin
Freon 113
[Ethane, 1,1,2-trichloro-1,2,2,trifluoro-]
Dichlorotetrafluoroethane (CFC114)
Monochloropentafluoroethane
(CFC-115)
Toxics Release Inventory Reporting Forms and Instructions
De minimus
% Limit
1.0
*
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
0.1
0.1
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
II-12
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
76-44-8
76-87-9
77-09-8
77-47-4
77-73-6
77-78-1
78-48-8
78-79-5
78-84-2
78-87-5
78-88-6
78-92-2
79-00-5
79-01-6
79-06-1
79-10-7
79-11-8
79-19-6
79-21-0
79-22-1
79-34-5
79-44-7
79-46-9
79 94 7
80-05-7
80-15-9
80-62-6
81-07-2
81-49-2
81-88-9
82-28-0
82-68-8
84-74-2
85-01-8
85-44-9
86-30-6
87-62-7
87-68-3
87-86-5
88-06-2
88-72-2
88-75-5
88-85-7
88-89-1
90-04-0
90-43-7
90-94-8
91-08-7
91-20-3
Chemical Name
Arranged by CAS Number
Heptachlor
[1,4,5,6,7,8,8-Heptachloro3a,4,7,7a-tetrahydro-4,7-methano1H-indene]
Triphenyltin hydroxide
Phenolphthalein
Hexachlorocyclopentadiene
Dicyclopentadiene
Dimethyl sulfate
S,S,S-Tributyltrithiophosphate
(DEF)
Isoprene
Isobutyraldehyde
1,2-Dichloropropane
2,3-Dichloropropene
sec-Butyl alcohol
1,1,2-Trichloroethane
Trichloroethylene
Acrylamide
Acrylic acid
Chloroacetic acid
Thiosemicarbazide
Peracetic acid
Methyl chlorocarbonate
1,1,2,2-Tetrachloroethane
Dimethylcarbamyl chloride
2-Nitropropane
Tetrabromobisphenol A
4,4'-Isopropylidenediphenol
Cumene hydroperoxide
Methyl methacrylate
Saccharin (only persons who
manufacture are subject, no
supplier notification)
1-Amino-2,4dibromoanthraquinone
C.I. Food Red 15
1-Amino-2-methylanthraquinone
Quintozene
[Pentachloronitrobenzene]
Dibutyl phthalate
Phenanthrene
Phthalic anhydride
N-Nitrosodiphenylamine
2,6-Xylidine
Hexachloro-1,3-butadiene
Pentachlorophenol (PCP)
2,4,6-Trichlorophenol
o-Nitrotoluene
2-Nitrophenol
Dinitrobutyl phenol (Dinoseb)
Picric acid
o-Anisidine
2-Phenylphenol
Michler’s ketone
Toluene-2,6-diisocyanate
Naphthalene
De minimus
% Limit
*
1.0
0.1
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
*
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
0.1
0.1
1.0
1.0
1.0
0.1
1.0
0.1
0.1
0.1
CAS
Number
91-22-5
91-23-6
91-59-8
91-94-1
92-52-4
92-67-1
92-87-5
92-93-3
93-15-2
93-65-2
94-11-1
94-36-0
94-58-6
94-59-7
94-74-6
94-75-7
94-80-4
94-82-6
95-47-6
95-48-7
95-50-1
95-53-4
95-54-5
95-63-6
95-69-2
95-80-7
95-95-4
96-09-3
96-12-8
96-18-4
96-33-3
96-45-7
97-23-4
97-56-3
98-07-7
98-82-8
98-86-2
98-87-3
98-88-4
98-95-3
99-30-9
99-55-8
99-59-2
99-65-0
100-01-6
100-02-7
100-25-4
100-41-4
100-42-5
Chemical Name
Arranged by CAS Number
Quinoline
o-Nitroanisole
beta-Naphthylamine
3,3'-Dichlorobenzidine
Biphenyl
4-Aminobiphenyl
Benzidine
4-Nitrobiphenyl
Methyleugenol
Mecoprop
2,4-D isopropyl ester
Benzoyl peroxide
Dihydrosafrole
Safrole
Methoxone
((4-Chloro-2-methylphenoxy)
acetic acid) (MCPA)
2,4-D [Acetic acid, (2,4dichlorophenoxy)-]
2,4-D butyl ester
2,4-DB
o-Xylene
o-Cresol
1,2-Dichlorobenzene
o-Toluidine
1,2-Phenylenediamine
1,2,4-Trimethylbenzene
p-Chloro-o-toluidine
2,4-Diaminotoluene
2,4,5-Trichlorophenol
Styrene oxide
1,2-Dibromo-3-chloropropane
(DBCP)
1,2,3-Trichloropropane
Methyl acrylate
Ethylene thiourea
Dichlorophene
[2,2'-Methylenebis(4chlorophenol)]
C.I. Solvent Yellow 3
Benzoic trichloride
(Benzotrichloride)
Cumene
Acetophenone
Benzal chloride
Benzoyl chloride
Nitrobenzene
Dichloran [2,6-Dichloro-4nitroaniline]
5-Nitro-o-toluidine
5-Nitro-o-anisidine
m-Dinitrobenzene
p-Nitroaniline
4-Nitrophenol
p-Dinitrobenzene
Ethylbenzene
Styrene
Toxics Release Inventory Reporting Forms and Instructions
De minimus
% Limit
1.0
0.1
0.1
0.1
1.0
0.1
0.1
0.1
0.1
0.1
0.1
1.0
0.1
0.1
0.1
0.1
0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0
0.1
0.1
1.0
0.1
0.1
0.1
1.0
0.1
1.0
0.1
0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
II-13
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
100-44-7
100-75-4
101-05-3
101-14-4
101-61-1
101-77-9
101-80-4
101-90-6
104-12-1
104-94-9
105-67-9
106-42-3
106-44-5
106-46-7
106-47-8
106-50-3
106-51-4
106-88-7
106-89-8
106-93-4
106-99-0
107-02-8
107-05-1
107-06-2
107-11-9
107-13-1
107-18-6
107-19-7
107-21-1
107-30-2
108-05-4
108-10-1
108-31-6
108-38-3
108-39-4
108-45-2
108-60-1
108-88-3
108-90-7
108-93-0
108-95-2
109-06-8
109-77-3
109-86-4
110-00-9
110-54-3
110-57-6
110-80-5
110-82-7
110-86-1
111-42-2
De minimus
Chemical Name
% Limit
Arranged by CAS Number
Benzyl chloride
1.0
N-Nitrosopiperidine
0.1
Anilazine
1.0
[4,6-Dichloro-N-(2-chlorophenyl)1,3,5-triazin-2-amine]
4,4'-Methylenebis(2-chloroaniline)
0.1
(MBOCA)
4,4'-Methylenebis(N,N0.1
dimethyl)benzenamine
4,4'-Methylenedianiline
0.1
4,4'-Diaminodiphenyl ether
0.1
Diglycidyl resorcinol ether
0.1
p-Chlorophenyl isocyanate
1.0
p-Anisidine
1.0
2,4-Dimethylphenol
1.0
p-Xylene
1.0
p-Cresol
1.0
1,4-Dichlorobenzene
0.1
p-Chloroaniline
0.1
p-Phenylenediamine
1.0
Quinone
1.0
1,2-Butylene oxide
0.1
Epichlorohydrin
0.1
1,2-Dibromoethane
0.1
(Ethylene dibromide)
1,3-Butadiene
0.1
Acrolein
1.0
Allyl chloride
1.0
1,2-Dichloroethane (Ethylene
0.1
dichloride)
Allylamine
1.0
Acrylonitrile
0.1
Allyl alcohol
1.0
Propargyl alcohol
1.0
Ethylene glycol
1.0
Chloromethyl methyl ether
0.1
Vinyl acetate
0.1
Methyl isobutyl ketone
1.0
Maleic anhydride
1.0
m-Xylene
1.0
m-Cresol
1.0
1,3-Phenylenediamine
1.0
Bis(2-chloro-1-methylethyl) ether
1.0
Toluene
1.0
Chlorobenzene
1.0
Cyclohexanol
1.0
Phenol
1.0
2-Methylpyridine
1.0
Malononitrile
1.0
2-Methoxyethanol
1.0
Furan
0.1
n-Hexane
1.0
trans-1,4-Dichloro-2-butene
1.0
2-Ethoxyethanol
1.0
Cyclohexane
1.0
Pyridine
1.0
Diethanolamine
1.0
CAS
Number
111-44-4
111-91-1
114-26-1
115-07-1
115-28-6
115-32-2
116-06-3
116-14-3
117-79-3
117-81-7
118-74-1
119-90-4
119-93-7
120-12-7
120-36-5
120-58-1
120-71-8
120-80-9
120-82-1
120-83-2
121-14-2
121-44-8
121-69-7
121-75-5
122-34-9
122-39-4
122-66-7
123-31-9
123-38-6
123-63-7
123-72-8
123-91-1
124-40-3
124-73-2
126-72-7
126-98-7
126-99-8
127-18-4
128-03-0
128-04-1
128-66-5
131-11-3
131-52-2
132-27-4
132-64-9
Chemical Name
Arranged by CAS Number
Bis(2-chloroethyl) ether
Bis(2-chloroethoxy) methane
Propoxur
[Phenol, 2-(1-methylethoxy)-,
methylcarbamate]
Propylene (Propene)
Chlorendic acid
Dicofol
[Benzenemethanol, 4-chloro.alpha.-4-(chlorophenyl)-.alpha.(trichloromethyl)-]
Aldicarb
Tetrafluoroethylene
2-Aminoanthraquinone
Di(2-ethylhexyl) phthalate
Hexachlorobenzene
3,3'-Dimethoxybenzidine
3,3'-Dimethylbenzidine(oTolidine)
Anthracene
2,4-DP
Isosafrole
p-Cresidine
Catechol
1,2,4-Trichlorobenzene
2,4-Dichlorophenol
2,4-Dinitrotoluene
Triethylamine
N,N-Dimethylaniline
Malathion
Simazine
Diphenylamine
1,2-Diphenylhydrazine
(Hydrazobenzene)
Hydroquinone
Propionaldehyde
Paraldehyde
Butyraldehyde
1,4-Dioxane
Dimethylamine
Dibromotetrafluoroethane
(Halon 2402)
Tris(2,3-dibromopropyl)
phosphate
Methacrylonitrile
Chloroprene
Tetrachloroethylene
(Perchloroethylene)
Potassium
dimethyldithiocarbamate
Sodium dimethyldithiocarbamate
C.I. Vat Yellow 4
Dimethyl phthalate
Sodium pentachlorophenate
Sodium o-phenylphenoxide
Dibenzofuran
Toxics Release Inventory Reporting Forms and Instructions
De minimus
% Limit
1.0
1.0
1.0
1.0
0.1
1.0
1.0
0.1
0.1
0.1
*
0.1
0.1
1.0
0.1
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0
0.1
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
II-14
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
133-06-2
133-07-3
133-90-4
134-29-2
134-32-7
135-20-6
136-45-8
137-26-8
137-41-7
137-42-8
138-93-2
139-13-9
139-65-1
140-88-5
141-32-2
142-59-6
148-79-8
149-30-4
150-50-5
150-68-5
151-56-4
156-10-5
156-62-7
191-24-2
298-00-0
300-76-5
301-12-2
302-01-2
306-83-2
309-00-2
314-40-9
319-84-6
330-54-1
Chemical Name
Arranged by CAS Number
Captan
[1H-Isoindole-1,3(2H)-dione,
3a,4,7,7a-tetrahydro-2[(trichloromethyl)thio]-]
Folpet
Chloramben
[Benzoic acid, 3-amino-2,5dichloro-]
o-Anisidine hydrochloride
alpha-Naphthylamine
Cupferron
[Benzeneamine, N-hydroxy-Nnitroso, ammonium salt]
Dipropyl isocinchomeronate
Thiram
Potassium N-methyldithiocarbamate
Metham sodium (Sodium
methyldithiocarbamate)
Disodium cyanodithioimidocarbonate
Nitrilotriacetic acid
4,4'-Thiodianiline
Ethyl acrylate
Butyl acrylate
Nabam
Thiabendazole
[2-(4-Thiazolyl)-1Hbenzimidazole]
2-Mercaptobenzothiazole
(MBT)
Merphos
Monuron
Ethyleneimine (Aziridine)
p-Nitrosodiphenylamine
Calcium cyanamide
Benzo(g,h,i)perylene
Methyl parathion
Naled
Oxydemeton methyl
[S-(2-(Ethylsulfinyl)ethyl) O,Odimethyl ester phosphorothioic
acid]
Hydrazine
2,2-Dichloro-1,1,1-trifluoroethane
(HCFC-123)
Aldrin
[1,4:5,8-Dimethanonaphthalene,
1,2,3,4,10,10-hexachloro1,4,4a,5,8,8a-hexahydro(1.alpha.,4.alpha.,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
(5-Bromo-6-methyl-3-(1methylpropyl)-2,4(1H,3H)pyrimidinedione)
alpha-Hexachlorocyclohexane
Diuron
De minimus
% Limit
CAS
Number
1.0
330-55-2
333-41-5
334-88-3
353-59-3
1.0
1.0
354-11-0
354-14-3
0.1
0.1
0.1
354-23-4
354-25-6
1.0
1.0
1.0
357-57-3
422-44-6
1.0
422-48-0
1.0
422-56-0
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
*
1.0
1.0
1.0
0.1
1.0
*
1.0
0.1
1.0
431-86-7
460-35-5
463-58-1
465-73-6
492-80-8
505-60-2
507-55-1
509-14-8
510-15-6
528-29-0
532-27-4
533-74-4
534-52-1
540-59-0
541-41-3
541-53-7
541-73-1
542-75-6
542-76-7
542-88-1
554-13-2
556-52-5
De minimus
Chemical Name
% Limit
Arranged by CAS Number
Linuron
1.0
Diazinon
1.0
Diazomethane
1.0
Bromochlorodifluoromethane
1.0
(Halon 1211)
1,1,1,2-Tetrachloro-2-fluoroethane
1.0
(HCFC-121a)
1,1,2,2-Tetrachloro-1-fluoroethane
1.0
(HCFC-121)
1,2-Dichloro-1,1,2-trifluoroethane
1.0
(HCFC-123a)
1-Chloro-1,1,2,2-tetrafluoroethane
1.0
(HCFC-124a)
Brucine
1.0
1,2-Dichloro-1,1,2,3,31.0
pentafluoropropane (HCFC225bb)
2,3-Dichloro-1,1,1,2,31.0
pentafluoropropane (HCFC225ba)
3,3-Dichloro-1,1,1,2,21.0
pentafluoropropane (HCFC225ca)
1,2-Dichloro-1,1,3,3,31.0
pentafluoropropane (HCFC225da)
3-Chloro-1,1,1-trifluoropropane
1.0
(HCFC-253fb)
Carbonyl sulfide
1.0
Isodrin
*
C.I. Solvent Yellow 34
0.1
(Auramine)
Mustard gas
0.1
[Ethane, 1,1'-thiobis[2-chloro-]
1,3-Dichloro-1,1,2,2,31.0
pentafluoropropane (HCFC225cb)
Tetranitromethane
0.1
[Benzeneacetic acid, 4-chloro1.0
.alpha.-(4-chlorophenyl)-.alpha.hydroxy-, ethyl ester]
o-Dinitrobenzene
1.0
2-Chloroacetophenone
1.0
Dazomet
1.0
(Tetrahydro-3,5-dimethyl-2H1,3,5-thiadiazine-2-thione)
4,6-Dinitro-o-cresol
1.0
1,2-Dichloroethylene
1.0
Ethyl chloroformate
1.0
2,4-Dithiobiuret
1.0
1,3-Dichlorobenzene
1.0
1,3-Dichloropropylene
0.1
3-Chloropropionitrile
1.0
Bis(chloromethyl) ether
0.1
Lithium carbonate
1.0
Glycidol
0.1
Toxics Release Inventory Reporting Forms and Instructions
II-15
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
556-61-6
563-47-3
569-64-2
584-84-9
593-60-2
594-42-3
606-20-2
608 93 5
612-82-8
612-83-9
615-05-4
615-28-1
621-64-7
624-18-0
624-83-9
630-20-6
636-21-5
639-58-7
680-31-9
684-93-5
709-98-8
759-73-9
759-94-4
764-41-0
812-04-4
834-12-8
842-07-9
872-50-4
924-16-3
924-42-5
957-51-7
961-11-5
989-38-8
1114-71-2
1120-71-4
1134-23-2
1163-19-5
1313-27-5
1314-20-1
Chemical Name
Arranged by CAS Number
Methyl isothiocyanate
[Isothiocyanatomethane]
3-Chloro-2-methyl-1-propene
C.I. Basic Green 4
Toluene-2,4-diisocyanate
Vinyl bromide
Perchloromethyl mercaptan
2,6-Dinitrotoluene
Pentachlorobenzene
3,3'-Dimethylbenzidine
dihydrochloride (o-Tolidine
dihydrochloride)
3,3'-Dichlorobenzidine
dihydrochloride
2,4-Diaminoanisole
1,2-Phenylenediamine
dihydrochloride
N-Nitrosodi-n-propylamine
1,4-Phenylenediamine
dihydrochloride
Methyl isocyanate
1,1,1,2-Tetrachloroethane
o-Toluidine hydrochloride
Triphenyltin chloride
Hexamethylphosphoramide
N-Nitroso-N-methylurea
Propanil (N-(3,4-Dichlorophenyl)
propanamide)
N-Nitroso-N-ethylurea
Ethyl dipropylthiocarbamate
(EPTC)
1,4-Dichloro-2-butene
1,1-Dichloro-1,2,2-trifluoroethane
(HCFC-123b)
Ametryn
(N-Ethyl-N’-(1-methylethyl)-6(methylthio)-1,3,5,-triazine-2,4diamine)
C.I. Solvent Yellow 14
N-Methyl-2-pyrrolidone
N-Nitrosodi-n-butylamine
N-Methylolacrylamide
Diphenamid
Tetrachlorvinphos
[Phosphoric acid, 2-chloro-1(2,4,5trichlorophenyl)ethenyldimethyl
ester]
C.I. Basic Red 1
Pebulate
[Butylethylcarbamothioic acid Spropyl ester]
Propane sultone
Cycloate
Decabromodiphenyl oxide
Molybdenum trioxide
Thorium dioxide
De minimus
% Limit
1.0
0.1
1.0
0.1
0.1
1.0
0.1
*
0.1
CAS
Number
1319-77-3
1320-18-9
1330-20-7
1332-21-4
1335-87-1
1336-36-3
1344-28-1
1464-53-5
1563-66-2
1582-09-8
0.1
0.1
1.0
1634-04-4
1649-08-7
1689-84-5
0.1
1.0
1689-99-2
1.0
1.0
0.1
1.0
0.1
0.1
1.0
1717-00-6
1836-75-5
1861-40-1
0.1
1.0
1897-45-6
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1910-42-5
1912-24-9
1918-00-9
1918-02-1
1918-16-7
1928-43-4
1929-73-3
1929-82-4
1.0
1.0
1937-37-7
1982-69-0
0.1
1.0
1.0
1.0
1.0
1983-10-4
2032-65-7
2155-70-6
De minimus
Chemical Name
% Limit
Arranged by CAS Number
Cresol (mixed isomers)
1.0
2,4-D propylene glycol butyl ether
0.1
ester
Xylene (mixed isomers)
1.0
Asbestos (friable)
0.1
Hexachloronaphthalene
1.0
Polychlorinated biphenyls (PCBs)
*
Aluminum oxide (fibrous forms)
1.0
Diepoxybutane
0.1
Carbofuran
1.0
Trifluralin
*
[Benezeneamine, 2,6-dinitro-N,Ndipropyl-4-(trifluoromethyl)-]
Methyl tert-butyl ether
1.0
1,2-Dichloro-1,1-difluoroethane
1.0
(HCFC-132b)
Bromoxynil
1.0
(3,5-Dibromo-4hydroxybenzonitrile)
Bromoxynil octanoate
1.0
(Octanoic acid, 2,6-dibromo-4cyanophenyl ester)
1,1-Dichloro-1-fluoroethane
1.0
(HCFC-141b)
Nitrofen
0.1
[Benzene, 2,4-dichloro-1-(4nitrophenoxy)-]
Benfluralin
1.0
(N-Butyl-N-ethyl-2,6-dinitro-4(trifluoromethyl)benzenamine)
Chlorothalonil
0.1
[1,3-Benzenedicarbonitrile,
2,4,5,6-tetrachloro-]
Paraquat dichloride
1.0
Atrazine
1.0
(6-Chloro-N-ethyl-N’-(1methylethyl)-1,3,5-triazine-2,4diamine)
Dicamba
1.0
(3,6-Dichloro-2-methoxybenzoic
acid)
Picloram
1.0
Propachlor
1.0
[2-Chloro-N-(1-methylethyl)-Nphenylacetamide]
2,4-D 2-ethylhexyl ester
0.1
2,4-D butoxyethyl ester
0.1
Nitrapyrin
1.0
(2-Chloro-6(trichloromethyl)pyridine)
C.I. Direct Black 38
0.1
Sodium dicamba
1.0
[3,6-Dichloro-2-methoxybenzoic
acid, sodium salt]
Tributyltin fluoride
1.0
Methiocarb
1.0
Tributyltin methacrylate
1.0
Toxics Release Inventory Reporting Forms and Instructions
II-16
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
2164-07-0
2164-17-2
2212-67-1
2234-13-1
2300-66-5
2303-16-4
2303-17-5
2312-35-8
2439-01-2
2439-10-3
2524-03-0
2602-46-2
2655-15-4
2699-79-8
2702-72-9
2832-40-8
2837-89-0
2971-38-2
3118-97-6
3296-90-0
3383-96-8
3653-48-3
3761-53-3
4080-31-3
4170-30-3
4549-40-0
4680-78-8
5234-68-4
5598-13-0
5902-51-2
6459-94-5
De minimus
Chemical Name
% Limit
Arranged by CAS Number
Dipotassium endothall
1.0
[7-Oxabicyclo(2.2.1)heptane-2,3dicarboxylic acid, dipotassium
salt]
Fluometuron
1.0
[Urea, N,N-dimethyl-N’-[3(trifluoromethyl)phenyl]-]
Molinate
1.0
(1H-Azepine-1-carbothioic acid,
hexahydro-S-ethyl ester)
Octachloronaphthalene
1.0
Dimethylamine dicamba
1.0
Diallate
1.0
[Carbamothioic acid, bis(1methylethyl)-S-(2,3-dichloro-2propenyl) ester]
Triallate
1.0
Propargite
1.0
Chinomethionat
1.0
[6-Methyl-1,3-dithiolo[4,5b]quinoxalin-2-one]
Dodine
1.0
[Dodecylguanidine monoacetate]
Dimethyl chlorothiophosphate
1.0
C.I. Direct Blue 6
0.1
2,3,5-Trimethylphenyl methyl
1.0
carbamate
Sulfuryl fluoride (Vikane)
1.0
2,4-D sodium salt
0.1
C.I. Disperse Yellow 3
1.0
2-Chloro-1,1,1,2-tetrafluoroethane
1.0
(HCFC-124)
2,4-D Chlorocrotyl ester
0.1
C.I. Solvent Orange 7
1.0
2,2-bis(Bromomethyl)-1,30.1
propanediol
Temephos
1.0
Methoxone sodium salt
0.1
((4-Chloro-2-methylphenoxy)
acetate sodium salt)
C.I. Food Red 5
0.1
1-(3-Chloroallyl)-3,5,7-triaza-11.0
azoniaadamantane chloride
Crotonaldehyde
1.0
N-Nitrosomethylvinylamine
0.1
C.I. Acid Green 3
1.0
Carboxin
1.0
(5,6-Dihydro-2-methyl-N-phenyl1,4-oxathiin-3-carboxamide)
Chlorpyrifos methyl
1.0
[O,O-Dimethyl-O-(3,5,6-trichloro2-pyridyl)phosphorothioate]
[5-Chloro-3-(1,1-dimethylethyl)1.0
6-methyl-2,4(1H,3H)pyrimidinedione]
C.I. Acid Red 114
0.1
CAS
Number
7287-19-6
7429-90-5
7439-92-1
7439-96-5
7439-97-6
7440-02-0
7440-22-4
7440-28-0
7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-47-3
7440-48-4
7440-50-8
7440-62-2
7440-66-6
7550-45-0
7632-00-0
7637-07-2
7647-01-0
7664-39-3
7664-41-7
7664-93-9
7696-12-0
7697-37-2
7723-14-0
7726-95-6
7758-01-2
7782-41-4
De minimus
Chemical Name
% Limit
Arranged by CAS Number
Prometryn
1.0
[N,N’-Bis(1-methylethyl)-6methylthio-1,3,5-triazine-2,4diamine]
Aluminum (fume or dust)
1.0
Lead
*
(when lead is contained in
stainless steel, brass or bronze
alloys the de minimis level is 0.1)
Manganese
1.0
Mercury
*
Nickel
0.1
Silver
1.0
Thallium
1.0
Antimony
1.0
Arsenic
0.1
Barium
1.0
Beryllium
0.1
Cadmium
0.1
Chromium
1.0
Cobalt
0.1
Copper
1.0
Vanadium (except when contained
1.0
in an alloy)
Zinc (fume or dust)
1.0
Titanium tetrachloride
1.0
Sodium nitrite
1.0
Boron trifluoride
1.0
Hydrochloric acid
1.0
(acid aerosols including mists,
vapors, gas, fog, and other
airborne forms of any particle
size)
Hydrogen fluoride
1.0
Ammonia
1.0
(includes anhydrous ammonia and
aqueous ammonia from water
dissociable ammonium salts and
other sources; 10 percent of total
aqueous ammonia is reportable
under this listing)
Sulfuric acid
1.0
(acid aerosols including mists,
vapors, gas, fog, and other
airborne forms of any particle
size)
Tetramethrin
1.0
[2,2-Dimethyl-3-(2-methyl-1propenyl)cyclopropanecarboxylic
acid (1,3,4,5,6,7-hexahydro-1,3dioxo-2H-isoindol-2-yl)methyl
ester]
Nitric acid
1.0
Phosphorus (yellow or white)
1.0
Bromine
1.0
Potassium bromate
0.1
Fluorine
1.0
Toxics Release Inventory Reporting Forms and Instructions
II-17
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
7782-49-2
7782-50-5
7783-06-4
7786-34-7
7803-51-2
8001-35-2
8001-58-9
9006-42-2
10028-15-6
10034-93-2
10049-04-4
10061-02-6
10294-34-5
10453-86-8
12122-67-7
12427-38-2
13194-48-4
13356-08-6
13463-40-6
13474-88-9
13684-56-5
14484-64-1
15972-60-8
16071-86-6
16543-55-8
17804-35-2
19044-88-3
19666-30-9
20325-40-0
20354-26-1
De minimus
Chemical Name
% Limit
Arranged by CAS Number
Selenium
1.0
Chlorine
1.0
Hydrogen sulfide
1.0
Mevinphos
1.0
Phosphine
1.0
Toxaphene
*
Creosote
0.1
Metiram
1.0
Ozone
1.0
Hydrazine sulfate
0.1
Chlorine dioxide
1.0
trans-1,3-Dichloropropene
0.1
Boron trichloride
1.0
Resmethrin
1.0
[[5-(Phenylmethyl)-3furanyl]methyl-2,2-dimethyl-3-(2methyl-1-propenyl)
cyclopropanecarboxylate]]
Zineb
1.0
[Carbamodithioic acid, 1,2ethanediylbis-, zinc complex]
Maneb
1.0
[Carbamodithioic acid, 1,2ethanediylbis-, manganese
complex]
Ethoprop
1.0
[Phosphorodithioic acid O-ethyl
S,S-dipropyl ester]
Fenbutatin oxide
1.0
(Hexakis(2-methyl-2phenylpropyl) distannoxane)
Iron pentacarbonyl
1.0
1,1-Dichloro-1,2,2,3,31.0
pentafluoropropane (HCFC225cc)
Desmedipham
1.0
Ferbam
1.0
[Tris(dimethylcarbamodithioatoS,S’)iron]
Alachlor
1.0
C.I. Direct Brown 95
0.1
N-Nitrosonornicotine
0.1
Benomyl
1.0
Oryzalin
1.0
[4-(Dipropylamino)-3,5dinitrobenzenesulfonamide]
Oxydiazon
1.0
[3-[2,4-Dichloro-5-(1methylethoxy) phenyl]-5-(1,1dimethylethyl)-1,3,4-oxadiazol2(3H)-one]
3,3'-Dimethoxybenzidine
0.1
dihydrochloride (o-Dianisidine
dihydrochloride)
Methazole
1.0
[2-(3,4-Dichlorophenyl)-4-methyl1,2,4-oxadiazolidine-3,5-dione]
CAS
Number
20816-12-0
20859-73-8
21087-64-9
21725-46-2
22781-23-3
23564-05-8
23564-06-9
23950-58-5
25311-71-1
25321-14-6
25321-22-6
25376-45-8
26002-80-2
26471-62-5
26628-22-8
26644-46-2
27314-13-2
28057-48-9
28249-77-6
28407-37-6
29082 74 4
29232-93-7
30560-19-1
31218-83-4
33089-61-1
De minimus
Chemical Name
% Limit
Arranged by CAS Number
Osmium tetroxide
1.0
Aluminum phosphide
1.0
Metribuzin
1.0
Cyanazine
1.0
[2,2-Dimethyl-1,3-benzodioxol-41.0
ol methylcarbamate]
Thiophanate methyl
1.0
Thiophanate ethyl
1.0
[[1,2Phenylenebis(iminocarbonothioyl)
] biscarbamic acid diethyl ester]
Pronamide
1.0
Isofenphos
1.0
[2-[[Ethoxyl[(1-methylethyl)amino]phosphinothioyl]oxy]benzo
ic acid 1-methylethyl ester]
Dinitrotoluene (mixed isomers)
1.0
Dichlorobenzene (mixed isomers)
0.1
Diaminotoluene (mixed isomers)
0.1
Phenothrin
1.0
[2,2-Dimethyl-3-(2-methyl-1propenyl)cyclopropanecarboxylic
acid (3-phenoxyphenyl)methyl
ester]
Toluene diisocyanate
0.1
(mixed isomers)
Sodium azide
1.0
Triforine
1.0
[N,N’-[1,4-Piperazinediylbis
(2,2,2trichloroethylidene)]bisformamide
]
Norflurazon
1.0
[4-Chloro-5-(methylamino)-2-[3(trifluoromethyl)phenyl]-3(2H)pyridazinone]
d-trans-Allethrin
1.0
[d-trans-Chrysanthemic acid of dallethrone]
Thiobencarb
1.0
[Carbamic acid, diethylthio-, S-(pchlorobenzyl)ester]
C.I. Direct Blue 218
1.0
Octachlorostyrene
*
Pirimiphos methyl
1.0
[O-(2-(Diethylamino)-6-methyl-4pyrimidinyl)-O,Odimethylphosphorothioate]
Acephate
1.0
(Acetylphosphoramidothioic acid
O,S-dimethyl ester)
Propetamphos
1.0
[3-[(Ethylamino)
methoxyphosphinothioyl]oxy]-2butenoic acid, 1-methylethyl ester]
Amitraz
1.0
Toxics Release Inventory Reporting Forms and Instructions
II-18
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
34014-18-1
34077-87-7
35367-38-5
35400-43-2
35554-44-0
35691-65-7
38727-55-8
39156-41-7
39300-45-3
39515-41-8
40487-42-1
41198-08-7
41766-75-0
42874-03-3
43121-43-3
50471-44-8
51235-04-2
51338-27-3
51630-58-1
52645-53-1
De minimus
Chemical Name
% Limit
Arranged by CAS Number
Tebuthiuron
1.0
[N-[5-(1,1-Dimethylethyl)-1,3,4thiadiazol-2-yl]-N,N’dimethylurea]
Dichlorotrifluoroethane
1.0
Diflubenzuron
1.0
Sulprofos
1.0
[O-Ethyl O-[4(methylthio)phenyl]phosphorodithioic acid S-propyl
ester]
Imazalil
1.0
[1-[2-(2,4-Dichlorophenyl)-2-(2propenyloxy)ethyl]-1H-imidazole]
1-Bromo-1-(bromomethyl)-1,31.0
propanedicarbonitrile
Diethatyl ethyl
1.0
2,4-Diaminoanisole sulfate
0.1
Dinocap
1.0
Fenpropathrin
1.0
[2,2,3,3-Tetramethylcyclopropane
carboxylic acid cyano(3phenoxyphenyl)methyl ester]
Pendimethalin
*
[N-(1-Ethylpropyl)-3,4-dimethyl2,6-dinitrobenzenamine]
Profenofos
1.0
[O-(4-Bromo-2-chlorophenyl)-Oethyl-S-propyl phosphorothioate]
3,3'-Dimethylbenzidine
0.1
dihydrofluoride (oTolidinedihydrofluoride)
Oxyfluorfen
1.0
Triadimefon
1.0
[1-(4-Chlorophenoxy)-3,3dimethyl-1-(1H-1,2,4-triazol-1yl)-2-butanone]
Vinclozolin
1.0
[3-(3,5-Dichlorophenyl)-5ethenyl-5-methyl-2,4oxazolidinedione]
Hexazinone
1.0
Diclofop methyl
1.0
[2-[4-(2,4-Dichlorophenoxy)phenoxy]propanoic acid, methyl
ester]
Fenvalerate
1.0
[4-Chloro-alpha-(1-methylethyl)benzeneacetic acid cyano(3phenoxyphenyl)methyl ester]
Permethrin
1.0
[3-(2,2-Dichloroethenyl)-2,2dimethylcyclopropane carboxylic
acid, (3-phenoxyphenyl)methyl
ester]
CAS
Number
53404-19-6
53404-37-8
53404-60-7
55290-64-7
55406-53-6
57213-69-1
59669-26-0
60168-88-9
60207-90-1
62476-59-9
63938-10-3
64902-72-3
64969-34-2
66441-23-4
67485-29-4
68085-85-8
68359-37-5
De minimus
Chemical Name
% Limit
Arranged by CAS Number
Bromacil, lithium salt
1.0
[2,4(1H,3H)-Pyrimidinedione, 5bromo-6-methyl-3-(1methylpropyl), lithium salt]
2,4-D 2-ethyl-4-methylpentyl ester
0.1
Dazomet, sodium salt
1.0
[Tetrahydro-3,5-dimethyl-2H1,3,5-thiadiazine-2-thione, ion(1-),
sodium]
Dimethipin
1.0
[2,3-Dihydro-5,6-dimethyl-1,4dithiin 1,1,4,4-tetraoxide]
3-Iodo-2-propynyl butyl
1.0
carbamate
Triclopyr triethylammonium salt
1.0
Thiodicarb
1.0
[.alpha.-(2-Chlorophenyl)-.alpha.1.0
(4-chlorophenyl)-5pyrimidinemethanol]
Propiconazole
1.0
[1-[2-(2,4-Dichlorophenyl)-4propyl-1,3-dioxolan-2-yl]-methyl1H-1,2,4,-triazole]
Acifluorfen, sodium salt
1.0
[5-(2-Chloro-4(trifluoromethyl)phenoxy)-2nitrobenzoic acid, sodium salt]
Chlorotetrafluoroethane
1.0
Chlorsulfuron
1.0
[2-Chloro-N-[[(4-methoxy-6methyl-1,3,5-triazin-2-yl)amino]
carbonyl] benzenesulfonamide]
3,3'-Dichlorobenzidine sulfate
0.1
[2-(4-((6-Chloro-21.0
benzoxazolylen)oxy)phenoxy)prop
anoic acid, ethyl ester]
Hydramethylnon
1.0
[Tetrahydro-5,5-dimethyl-2(1H)pyrimidinone[3-[4(trifluoromethyl)phenyl]-1-[2-[4(trifluoromethyl)phenyl]ethenyl]2-propenylidene]hydrazone]
Cyhalothrin
1.0
[3-(2-Chloro-3,3,3-trifluoro-1propenyl)-2,2dimethylcyclopropanecarboxylic
acid cyano(3-phenoxyphenyl)
methyl ester]
Cyfluthrin
1.0
[3-(2,2-Dichloroethenyl)-2,2dimethylcyclopropanecarboxylic
acid, cyano(4-fluoro-3phenoxyphenyl) methyl ester]
Toxics Release Inventory Reporting Forms and Instructions
II-19
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
CAS
Number
69409-94-5
69806-50-4
71751-41-2
72178-02-0
72490-01-8
74051-80-2
76578-14-8
77501-63-4
82657-04-3
88671-89-0
90454-18-5
90982-32-4
101200-48-0
111512-56-2
111984-09-9
127564-92-5
De minimus
Chemical Name
% Limit
Arranged by CAS Number
Fluvalinate
1.0
[N-[2-Chloro-4(trifluoromethyl)phenyl]DLvaline(+)-cyano(3phenoxyphenyl)methyl ester]
Fluazifop butyl
1.0
[2-[4-[[5-(Trifluoromethyl)-2pyridinyl]oxy]phenoxy]propanoic
acid, butyl ester]
Abamectin [Avermectin B1]
1.0
Fomesafen
1.0
[5-(2-Chloro-4(trifluoromethyl)phenoxy)-Nmethylsulfonyl)-2nitrobenzamide]
Fenoxycarb
1.0
[[2-(4-Phenoxy
phenoxy)ethyl]carbamic acid ethyl
ester]
Sethoxydim
1.0
[2-[1-(Ethoxyimino)butyl]-5-[2(ethylthio)propyl]-3-hydroxyl-2cyclohexen-1-one]
Quizalofop-ethyl
1.0
[2-[4-[(6-Chloro-2-quinoxalinyl)
oxy]phenoxy]propanoic acid ethyl
ester]
Lactofen
1.0
[Benzoic acid, 5-[2-Chloro-4(trifluoromethyl)phenoxy]-2-nitro, 2-ethoxy-1-methyl-2-oxoethyl
ester]
Bifenthrin
1.0
Myclobutanil
1.0
[.alpha.-Butyl-.alpha.-(4chlorophenyl)-1H-1,2,4-triazole-1propanenitrile]
Dichloro-1,1,2-trifluoroethane
1.0
Chlorimuron ethyl
1.0
[Ethyl-2-[[[[(4-chloro-6methoxyprimidin-2yl)amino]carbonyl]
amino]sulfonyl]benzoate]
Tribenuron methyl
1.0
[2-[[[[(4-Methoxy-6-methyl-1,3,5triazin-2yl)methylamino]carbonyl]
amino]sulfonyl]benzoic acid
methyl ester]
1,1-Dichloro-1,2,3,3,31.0
pentafluoropropane (HCFC225eb)
3,3'-Dimethoxybenzidine
0.1
hydrochloride (o-Dianisidine
hydrochloride)
Dichloropentafluoropropane
1.0
CAS
Number
128903-21-9
136013-79-1
c.
Chemical Name
Arranged by CAS Number
2,2-Dichloro-1,1,1,3,3pentafluoropropane (HCFC225aa)
1,3-Dichloro-1,1,2,3,3pentafluoropropane (HCFC225ea)
De minimus
% Limit
1.0
1.0
Chemical Categories
Section 313 requires reporting on the EPCRA Section 313
chemical categories listed below, in addition to the specific
EPCRA Section 313 chemicals listed above.
The metal compound categories listed below, unless otherwise
specified, are defined as including any unique chemical
substance that contains the named metal (e.g., antimony, nickel,
etc.) as part of that chemical’s structure.
EPCRA Section 313 chemical categories are subject to the 1%
de minimis concentration unless the substance involved meets
the definition of an OSHA carcinogen in which case the 0.1% de
minimis concentration applies. The de minimis concentration for
each category is provided in parentheses. The de minimis
exemption is not available for PBT chemicals, therefore an
asterisk appears where a de minimis limit would otherwise
appear. However, for purposes of the supplier notification
requirement only, such limits are provided in Appendix D.
N010
Antimony Compounds (1.0)
Includes any unique chemical substance that contains
antimony as part of that chemical’s infrastructure.
N020
Arsenic Compounds (inorganic compounds: 0.1;
organic compounds: 1.0)
Includes any unique chemical substance that contains
arsenic as part of that chemical’s infrastructure.
N040
Barium Compounds (1.0)
Includes any unique chemical substance that contains
barium as part of that chemical’s infrastructure. This
category does not include:
Barium sulfate CAS Number 7727-43-7
N050
Beryllium Compounds (0.1)
Includes any unique chemical substance that
contains beryllium as part of that chemical’s
infrastructure.
N078
Cadmium Compounds (0.1)
Includes any unique chemical substance that
contains cadmium as part of that chemical’s
infrastructure.
Toxics Release Inventory Reporting Forms and Instructions
II-20
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
N084
Chlorophenols (0.1)
N120
OH
Cl x
H(5-x)
Where x = 1 to 5
N090
Chromium Compounds
(except for chromite ore mined in the Transvaal
Region of South Africa and the unreacted ore
component of the chromite ore processing residue
(COPR). COPR is the solid waste remaining after
aqueous extraction of oxidized chromite ore that has
been combined with soda ash and kiln roasted at
approximately 2,000 °F.)
(chromium VI compounds: 0.1; chromium III
compounds: 1.0)
Includes any unique chemical substance that contains
chromium as part of that chemical’s
infrastructure.
N096
Cobalt Compounds (inorganic compounds: 0.1;
organic compounds: 1.0)
Includes any unique chemical substance that contains
cobalt as part of that chemical’s infrastructure.
N100
Copper Compounds (1.0)
Includes any unique chemical substance that contains
copper as part of that chemical’s infrastructure. This
category does not include copper phthalocyanine
compounds that are substituted with only hydrogen,
and/or chlorine, and/or bromine.
N106
Cyanide Compounds (1.0)
X+CN- where X = H+ or any other group where a
formal dissociation can be made. For example KCN or
Ca(CN)2
Diisocyanates (1.0)
This category includes only those chemicals listed
below.
CAS Number Chemical Name
38661-72-2
1,3-Bis(methylisocyanate) cyclohexane
10347-54-3
1,4-Bis(methylisocyanate)cyclohexane
2556-36-7
1,4-Cyclohexane diisocyanate
134190-37-7 Diethyldiisocyanatobenzene
4128-73-8
4,4'-Diisocyanatodiphenyl ether
75790-87-3
2,4'-Diisocyanatodiphenyl sulfide
91-93-0
3,3'-Dimethoxybenzidine-4,4'diisocyanate
91-97-4
3,3'-Dimethyl-4,4'-diphenylene
diisocyanate
139-25-3
3,3'-Dimethyldiphenylmethane-4,4'diisocyanate
822-06-0
Hexamethylene-1,6-diisocyanate
4098-71-9
Isophorone diisocyanate
75790-84-0
4-Methyldiphenylmethane-3,4diisocyanate
5124-30-1
1,1-Methylenebis(4isocyanatocyclohexane)
101-68-8
Methylenebis(phenylisocyanate)
(MDI)
3173-72-6
1,5-Naphthalene diisocyanate
123-61-5
1,3-Phenylene diisocyanate
104-49-4
1,4-Phenylene diisocyanate
9016-87-9
Polymeric diphenylmethane
diisocyanate
16938-22-0
2,2,4-Trimethylhexamethylene
diisocyanate
15646-96-5
2,4,4-Trimethylhexamethylene
diisocyanate
Toxics Release Inventory Reporting Forms and Instructions
II-21
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
N150
Box
#
Dioxin and dioxin-like compounds
(Manufacturing; and the processing or otherwise
use of dioxin and dioxin-like compounds if the
dioxin and dioxin-like compounds are present as
contaminants in a chemical and if they were created
during the manufacturing of that chemical.) (*) This
category includes only those chemicals listed below.
[Note: When completing the Form R Schedule 1, enter
the data for each member of the category in the order
they are listed here (i.e., 1-17).]
CAS
Number
1 1746-01-6
2 40321-76-4
3 39227-28-6
4 57653-85-7
5 19408-74-3
6 35822-46-9
7 3268-87-9
8 51207-31-9
9 57117-41-6
10 57117-31-4
11 70648-26-9
12 57117-44-9
13 72918-21-9
14 60851-34-5
15 67562-39-4
16 55673-89-7
17 39001-02-0
N171
Chemical Name
2,3,7,8Tetrachlorodibenzo-p-dioxin
1,2,3,7,8Pentachlorodibenzo-p-dioxin
1,2,3,4,7,8Hexachlorodibenzo-p-dioxin
1,2,3,6,7,8Hexachlorodibenzo-p-dioxin
1,2,3,7,8,9Hexachlorodibenzo-p-dioxin
1,2,3,4,6,7,8Heptachlorodibenzo-p-dioxin
1,2,3,4,6,7,8,9Octachlorodibenzo-p-dioxin
2,3,7,8Tetrachlorodibenzofuran
1,2,3,7,8Pentachlorodibenzofuran
2,3,4,7,8Pentachlorodibenzofuran
1,2,3,4,7,8Hexachlorod-benzofuran
1,2,3,6,7,8Hexachlorodibenzofuran
1,2,3,7,8,9Hexachlorodibenzofuran
2,3,4,6,7,8Hexachlorodibenzofuran
1,2,3,4,6,7,8-Heptachlorodibenzofuran
1,2,3,4,7,8,9Heptachlorodibenzofuran
1,2,3,4,6,7,8,9Octachlorodibenzofuran
N230
Certain Glycol Ethers (1.0)
R - (OCH2CH2)n - OR’
where:
n = 1, 2, or 3;
R = Alkyl C7 or less; or
R = phenyl or alkyl substituted phenyl;
R’ = H or alkyl C7 or less; or
OR’ consisting of carboxylic acid ester, sulfate,
phosphate, nitrate, or sulfonate.
N420
Lead Compounds (*)
Includes any unique chemical substance that contains
lead as part of that chemical’s infrastructure.
N450
Manganese Compounds (1.0)
Includes any unique chemical substance that contains
manganese as part of that chemical’s infrastructure.
N458
Mercury Compounds (*)
Includes any unique chemical substance that contains
mercury as part of that chemical’s infrastructure.
N495
Nickel Compounds (0.1)
Includes any unique chemical substance that contains
nickel as part of that chemical’s infrastructure.
N503
Nicotine and salts (1.0)
Includes any unique chemical substance that contains
nicotine or a nicotine salt as part of that chemical’s
infrastructure.
N511
Nitrate compounds (water dissociable; reportable
only when in aqueous solution) (1.0)
N575
Polybrominated Biphenyls (PBBs) (0.1)
Brx
H (10-x)
where x = 1 to 10
Ethylenebisdithiocarbamic acid, salts and esters
EBDCs) (1.0)
Includes any unique chemical substance that contains
an EBDC or an EBDC salt as part of that chemical’s
infrastructure.
Toxics Release Inventory Reporting Forms and Instructions
II-22
Table II. EPCRA Section 313 Chemical List for Reporting Year 2014
N583
Polychlorinated alkanes (C10 to C13) (1.0, except for
those members of the category that have an average
chain length of 12 carbons and contain an average
chlorine content of 60% by weight which are subject
to the 0.1% de minimis)
Includes those chemicals defined by the following
formula:
CxH2x-y+2Cly
Where x = 10 to 13;
y = 3 to 12; and
where the average chlorine content ranges from 4070% with the limiting molecular formulas
C10H19Cl3 and C13H16Cl12
N590
N760
Thallium Compounds (1.0)
Includes any unique chemical substance that contains
thallium as part of that chemical’s infrastructure.
N770
Vanadium compounds (1.0)
Includes any unique chemical substance that contains
vanadium as part of that chemical's infrastructure.
N874
Warfarin and salts (1.0)
Includes any unique chemical substance that contains
warfarin or a warfarin salt as part of that chemical’s
infrastructure.
N982
Zinc Compounds (1.0)
Includes any unique chemical substance that contains
zinc as part of that chemical’s infrastructure.
Polycyclic aromatic compounds (PACs) (*)
This category includes the chemicals listed below.
CAS Number
56-55-3
205-99-2
205-82-3
207-08-9
206-44-0
189-55-9
218-01-9
50-32-8
226-36-8
224-42-0
53-70-3
194-59-2
5385-75-1
192-65-4
189-64-0
191-30-0
57-97-6
42397-64-8
42397-65-9
193-39-5
56-49-5
3697-24-3
7496-02-8
5522-43-0
57835-92-4
Chemical Name
Benz(a)anthracene
Benzo(b)fluoranthene
Benzo(j)fluoranthene
Benzo(k)fluoranthene
Benzo(j,k)fluorene
Benzo(r,s,t)pentaphene
Benzo(a)phenanthrene
Benzo(a)pyrene
Dibenz(a,h)acridine
Dibenz(a,j)acridine
Dibenzo(a,h)anthracene
7H-Dibenzo(c,g)carbazole
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
7,12-Dimethylbenz(a)-anthracene
1,6-Dinitropyrene
1,8-Dinitropyrene
Indeno(1,2,3-cd)pyrene
3-Methylcholanthrene
5-Methylchrysene
6-Nitrochrysene
1-Nitropyrene
4-Nitropyrene
N725
Selenium Compounds (1.0)
Includes any unique chemical substance that contains
selenium as part of that chemical’s infrastructure.
N740
Silver Compounds (1.0)
Includes any unique chemical substance that contains
silver as part of that chemical’s infrastructure.
N746
Strychnine and salts (1.0)
Includes any unique chemical substance that contains
strychnine or a strychnine salt as part of that
chemical’s infrastructure.
Toxics Release Inventory Reporting Forms and Instructions
II-23
Table III. State Abbreviations
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Marshall Islands
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
AL
AK
AS
AZ
AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL
IN
IA
KS
KY
LA
ME
MH
MD
MA
MI
MN
MS
MO
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Northern Marianas Islands
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
Toxics Release Inventory Reporting Forms and Instructions
MT
NE
NV
NH
NJ
NM
NY
NC
ND
MP
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
WI
WY
III-1
Table IV. Federal Information Processing Standards (FIPS)
Country Codes
AA
AC
AE
AF
AG
AJ
AL
AM
AN
AO
AR
AS
AT
AU
AV
AY
BA
BB
BC
BD
BE
BF
BG
BH
BK
BL
BM
BN
BO
BP
BR
BS
BT
BU
BV
BX
BY
CA
CB
CD
KE
KG
KN
KQ
KR
Aruba
Antigua and Barbuda
United Arab
Emirates
Afghanistan
Algeria
Azerbaijan
Albania
Armenia
Andorra
Angola
Argentina
Australia
Ashmore and Cartier
Islands
Austria
Anguilla
Antarctica
Bahrain
Barbados
Botswana
Bermuda
Belgium
The Bahamas
Bangladesh
Belize
Bosnia and
Herzegovina
Bolivia
Burma
Benin
Belarus
Solomon Islands
Brazil
Bassas da India
Bhutan
Bulgaria
Bouvet Island
Brunei
Burundi
Canada
Cambodia
Chad
Kenya
Kyrgyzstan
North Korea
Kingman Reef
Kiribati
CE
CF
CG
CH
CI
CJ
CK
CM
CN
CO
CR
CS
CT
CU
CV
CW
CY
DA
DJ
DO
DR
EC
EG
EI
EK
EN
ER
ES
ET
EU
EZ
FG
FI
FJ
FK
FO
FP
FR
KS
KT
KU
KZ
LA
Sri Lanka
Congo
(Brazzaville)
Congo (Kinshasa)
China
Chile
Cayman Islands
Cocos (Keeling)
Islands
Cameroon
Comoros
Colombia
Coral Sea Islands
Costa Rica
Central African
Republic
Cuba
Cape Verde
Cook Islands
Cyprus
Denmark
Djibouti
Dominica
Dominican
Republic
Ecuador
Egypt
Ireland
Equatorial Guinea
Estonia
Eritrea
El Salvador
Ethiopia
Europa Island
Czech Republic
French Guiana
Finland
Fiji
Falkland Islands
(Islas Malvinas)
Faroe Islands
French Polynesia
France
South Korea
Christmas Island
Kuwait
Kazakhstan
Laos
FS
GA
GB
GG
GH
GI
GJ
GK
GL
GM
GO
GP
GR
GT
GV
GY
GZ
HA
HK
HM
HO
HR
HU
IC
ID
IM
IN
IO
IP
IR
IS
IT
IV
IZ
JA
JE
JM
JN
JO
JU
LE
LG
LH
LI
LO
Toxics Release Inventory Reporting Forms and Instructions
French Southern and
Antarctic Lands
The Gambia
Gabon
Georgia
Ghana
Gibraltar
Grenada
Guernsey
Greenland
Germany
Glorioso Islands
Guadeloupe
Greece
Guatemala
Guinea
Guyana
Gaza Strip
Haiti
Hong Kong
Heard Island and
McDonald Islands
Honduras
Croatia
Hungary
Iceland
Indonesia
Isle of Man
India
British Indian Ocean
Territory
Clipperton Island
Iran
Israel
Italy
Cote D'Ivoire
Iraq
Japan
Jersey
Jamaica
Jan Mayen
Jordan
Juan de Nova Island
Lebanon
Latvia
Lithuania
Liberia
Slovakia
IV-1
Table IV. Federal Information Processing Standards (FIPS) Country Codes
LS
LT
LU
LY
MA
MB
MC
MD
MF
MG
MH
MI
MK
ML
MN
MO
MP
MR
MT
MU
MV
MX
MY
MZ
NC
NE
NF
NG
NH
NI
NL
NO
NP
NR
NS
NT
NU
NZ
PA
PC
PE
Liechtenstein
Lesotho
Luxembourg
Libya
Madagascar
Martinique
Macau
Moldova
Mayotte
Mongolia
Montserrat
Malawi
Macedonia
Mali
Monaco
Morocco
Mauritius
Mauritania
Malta
Oman
Maldives
Mexico
Malaysia
Mozambique
New Caledonia
Niue
Norfolk Island
Niger
Vanuatu
Nigeria
Netherlands
Norway
Nepal
Nauru
Suriname
Netherlands Antilles
Nicaragua
New Zealand
Paraguay
Pitcairn Islands
Peru
PF
PG
PK
PL
PM
PO
PP
PS
PU
QA
RE
RO
RP
RS
RW
SA
SB
SC
SE
SF
SG
SH
SI
SL
SM
SN
SO
SP
ST
SU
SV
SW
SX
SY
SZ
TD
TE
Paracel Islands
Spratly Islands
Pakistan
Poland
Panama
Portugal
Papua New Guinea
Palau
Guinea-Bissau
Qatar
Reunion
Romania
Philippines
Russia
Rwanda
Saudi Arabia
St. Pierre and
Miquelon
St. Kitts and Nevis
Seychelles
South Africa
Senegal
St. Helena
Slovenia
Sierra Leone
San Marino
Singapore
Somalia
Spain
St. Lucia
Sudan
Svalbard
Sweden
South Georgia and
South Sandwich
Islands
Syria
Switzerland
Trinidad and
Tobago
Tromelin Island
TH
TI
TK
TL
TN
TO
TP
TS
TT
TU
TV
TW
TX
TZ
UG
UK
UP
UV
UY
UZ
VC
VE
VI
VM
VT
WA
WE
WF
WI
WS
WZ
YI
YM
ZA
ZI
Toxics Release Inventory Reporting Forms and Instructions
Thailand
Tajikistan
Turks and Caicos
Islands
Tokelau
Tonga
Togo
Sao Tome and
Principe
Tunisia
East Timor
Turkey
Tuvalu
Taiwan
Turkmenistan
Tanzania
Uganda
United Kingdom
Ukraine
Burkina Faso
Uruguay
Uzbekistan
St. Vincent and the
Grenadines
Venezuela
British Virgin
Islands
Vietnam
Vatican City
Namibia
West Bank
Wallis and Futuna
Western Sahara
Western Samoa
Swaziland
Yugoslavia
Yemen
Zambia
Zimbabwe
IV-2
Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name
BIA Tribe Code
Absentee-Shawnee Tribe of Indians of Oklahoma
820
Agua Caliente Band of Cahuilla Indians of the Agua
Caliente Indian Reservation, California
584
Ak Chin Indian Community of the Maricopa (Ak
Chin) Indian Reservation, Arizona
612
Alabama-Coushatta Tribes of Texas
830
Alabama-Quassarte Tribal Town, Oklahoma
901
Alturas Indian Rancheria, California
502
Apache Tribe of Oklahoma
809
Arapahoe Tribe of the Wind River Reservation,
Wyoming
281
Aroostook Band of Micmac Indians of Maine
31
Assiniboine and Sioux Tribes of the Fort Peck
Indian Reservation, Montana
206
Augustine Band of Cahuilla Indians, California
(formerly the Augustine Band of Cahuilla Mission
Indians of the Augustine Reservation)
567
Bad River Band of the Lake Superior Tribe of
Chippewa Indians of the Bad River Reservation,
Wisconsin
430
Bay Mills Indian Community, Michigan
Indian Country Name
BIA Tribe Code
Cahto Indian Tribe of the Laytonville Rancheria,
California
524
Cahuilla Band of Mission Indians of the Cahuilla
Reservation, California
569
California Valley Miwok Tribe, California
628
Campo Band of Diegueno Mission Indians of the
Campo Indian Reservation, California
570
Capitan Grande Band of Diegueno Mission Indians
of California: Barona Group of Capitan Grande
Band of Mission Indians of the Barona Reservation,
California; Viejas (Baron Long) Group of Capitan
Grande Band of Mission Indians of the Viejas
Reservation, California
571
Catawba Indian Nation (aka Catawba Tribe of South
Carolina)
32
Cayuga Nation of New York
13
Cedarville Rancheria, California
621
Chemehuevi Indian Tribe of the Chemehuevi
Reservation, California
695
Cher-Ae Heights Indian Community of the Trinidad
Rancheria, California
566
470
Cherokee Nation, Oklahoma
905
Bear River Band of the Rohnerville Rancheria,
California
560
Cheyenne and Arapaho Tribes, Oklahoma (formerly
the Cheyenne-Arapaho Tribes of Oklahoma)
801
Berry Creek Rancheria of Maidu Indians of
California
504
Cheyenne River Sioux Tribe of the Cheyenne River
Reservation, South Dakota
340
Big Lagoon Rancheria, California
554
Chickasaw Nation, Oklahoma
906
Big Pine Band of Owens Valley Paiute Shoshone
Indians of the Big Pine Reservation, California
530
Chicken Ranch Rancheria of Me-Wuk Indians of
California
523
Big Sandy Rancheria of Mono Indians of California
506
507
Chippewa-Cree Indians of the Rocky Boy’s
Reservation, Montana
205
Big Valley Band of Pomo Indians of the Big Valley
Rancheria, California
Chitimacha Tribe of Louisiana
970
Blackfeet Tribe of the Blackfeet Indian Reservation
of Montana
201
Choctaw Nation of Oklahoma
907
Blue Lake Rancheria, California
558
Citizen Potawatomi Nation, Oklahoma
821
Bridgeport Paiute Indian Colony of California
691
Cloverdale Rancheria of Pomo Indians of California
510
Buena Vista Rancheria of Me-Wuk Indians of
California
508
Cocopah Tribe of Arizona
602
181
Burns Paiute Tribe of the Burns Paiute Indian
Colony of Oregon
144
Coeur D’Alene Tribe of the Coeur D’Alene
Reservation, Idaho
511
Cabazon Band of Mission Indians, California
568
Cold Springs Rancheria of Mono Indians of
California
Cachil DeHe Band of Wintun Indians of the Colusa
Indian Community of the Colusa Rancheria,
California
512
Colorado River Indian Tribes of the Colorado River
Indian Reservation, Arizona and California
603
Comanche Nation, Oklahoma
808
Caddo Nation of Oklahoma
806
Confederated Salish & Kootenai Tribes of the
Flathead Reservation, Montana
203
Toxics Release Inventory Reporting Form and Instructions
V-1
Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name
BIA Tribe Code
Confederated Tribes and Bands of the Yakama
Nation, Washington
124
Confederated Tribes of Siletz Indians of Oregon
(previously listed as the Confederated Tribes of the
Siletz Reservation)
142
Confederated Tribes of the Chehalis Reservation,
Washington
105
Confederated Tribes of the Colville Reservation,
Washington
101
Confederated Tribes of the Coos, Lower Umpqua
and Siuslaw Indians of Oregon
152
Confederated Tribes of the Goshute Reservation,
Nevada and Utah
Indian Country Name
BIA Tribe Code
Federated Indians of Graton Rancheria, California
622
Flandreau Santee Sioux Tribe of South Dakota
341
Forest County Potawatomi Community, Wisconsin
434
Fort Belknap Indian Community of the Fort Belknap
Reservation of Montana
204
Fort Bidwell Indian Community of the Fort Bidwell
Reservation of California
518
Fort Independence Indian Community of Paiute
Indians of the Fort Independence Reservation,
California
525
681
Fort McDermitt Paiute and Shoshone Tribes of the
Fort McDermitt Indian Reservation, Nevada and
Oregon
646
Confederated Tribes of the Grand Ronde
Community of Oregon
141
Fort McDowell Yavapai Nation, Arizona
613
Confederated Tribes of the Umatilla Reservation,
Oregon
143
Fort Mojave Indian Tribe of Arizona, California &
Nevada
604
Confederated Tribes of the Warm Springs
Reservation of Oregon
145
Fort Sill Apache Tribe of Oklahoma
803
614
Coquille Tribe of Oregon
155
Gila River Indian Community of the Gila River
Indian Reservation, Arizona
Cortina Indian Rancheria of Wintun Indians of
California
513
Grand Traverse Band of Ottawa and Chippewa
Indians, Michigan
468
Coushatta Tribe of Louisiana
971
Greenville Rancheria of Maidu Indians of California
545
Cow Creek Band of Umpqua Indians of Oregon
153
Grindstone Indian Rancheria of Wintun-Wailaki
Indians of California
519
Cowlitz Indian Tribe, Washington
132
Habematolel Pomo of Upper Lake, California
636
Coyote Valley Band of Pomo Indians of California
638
Hannahville Indian Community, Michigan
471
Crow Creek Sioux Tribe of the Crow Creek
Reservation, South Dakota
342
Havasupai Tribe of the Havasupai Reservation,
Arizona
605
Crow Tribe of Montana
202
Ho-Chunk Nation of Wisconsin
439
Death Valley Timbi-Sha Shoshone Band of
California
693
Hoh Indian Tribe of the Hoh Indian Reservation,
Washington
106
Delaware Nation, Oklahoma
807
Hoopa Valley Tribe, California
561
Delaware Tribe of Indians, Oklahoma
816
Hopi Tribe of Arizona
608
Dry Creek Rancheria of Pomo Indians of California
515
642
Hopland Band of Pomo Indians of the Hopland
Rancheria, California
521
Duckwater Shoshone Tribe of the Duckwater
Reservation, Nevada
Eastern Band of Cherokee Indians of North Carolina
1
Eastern Shawnee Tribe of Oklahoma
921
Elem Indian Colony of Pomo Indians of the Sulphur
Bank Rancheria, California
632
Elk Valley Rancheria, California
559
Ely Shoshone Tribe of Nevada
644
Enterprise Rancheria of Maidu Indians of California
517
Ewiiaapaayp Band of Kumeyaay Indians, California
573
Houlton Band of Maliseet Indians of Maine
19
Hualapai Indian Tribe of the Hualapai Indian
Reservation, Arizona
606
Iipay Nation of Santa Ysabel, California (formerly
the Santa Ysabel Band of Diegueno Mission Indians
of the Santa Ysabel Reservation)
592
Inaja Band of Diegueno Mission Indians of the Inaja
and Cosmit Reservation, California
574
Ione Band of Miwok Indians of California
529
Iowa Tribe of Kansas and Nebraska
860
Toxics Release Inventory Reporting Form and Instructions
V-2
Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name
BIA Tribe Code
Iowa Tribe of Oklahoma
822
Jackson Rancheria of Me-Wuk Indians of California
522
Jamestown S’Klallam Tribe of Washington
129
Jamul Indian Village of California
575
Jena Band of Choctaw Indians, Louisiana
34
Indian Country Name
BIA Tribe Code
Los Coyotes Band of Cahuilla and Cupeno Indians,
California (formerly the Los Coyotes Band of
Cahuilla & Cupeno Indians of the Los Coyotes
Reservation)
578
Lovelock Paiute Tribe of the Lovelock Indian
Colony, Nevada
649
Lower Brule Sioux Tribe of the Lower Brule
Reservation, South Dakota
343
Lower Elwha Tribal Community of the Lower
Elwha Reservation, Washington
125
Lower Lake Rancheria, California
625
Jicarilla Apache Nation, New Mexico
701
Kaibab Band of Paiute Indians of the Kaibab Indian
Reservation, Arizona
617
Kalispel Indian Community of the Kalispel
Reservation, Washington
103
Karuk Tribe (formerly the Karuk Tribe of
California)
555
Lower Sioux Indian Community in the State of
Minnesota
402
Kashia Band of Pomo Indians of the Stewarts Point
Rancheria, California
547
Lummi Tribe of the Lummi Reservation,
Washington
107
Kaw Nation, Oklahoma
810
Lytton Rancheria of California
509
Kewa Pueblo, New Mexico (formerly the Pueblo of
Santo Domingo)
717
Makah Indian Tribe of the Makah Indian
Reservation, Washington
108
Keweenaw Bay Indian Community, Michigan
475
527
Kialegee Tribal Town, Oklahoma
902
Manchester Band of Pomo Indians of the
Manchester-Point Arena Rancheria, California
Kickapoo Traditional Tribe of Texas
826
Manzanita Band of Diegueno Mission Indians of the
Manzanita Reservation, California
579
Kickapoo Tribe of Indians of the Kickapoo
Reservation in Kansas
861
Mashantucket Pequot Tribe of Connecticut
20
Kickapoo Tribe of Oklahoma
823
Mashpee Wampanoag Tribe, Massachusetts
35
Kiowa Indian Tribe of Oklahoma
802
Klamath Tribes, Oregon
140
Kootenai Tribe of Idaho
Match-e-be-nash-she-wish Band of Pottawatomi
Indians of Michigan
484
Mechoopda Indian Tribe of Chico Rancheria,
California
531
183
La Jolla Band of Luiseno Indians, California
(formerly the La Jolla Band of Luiseno Mission
Indians of the La Jolla Reservation)
576
Menominee Indian Tribe of Wisconsin
440
Mesa Grande Band of Diegueno Mission Indians of
the Mesa Grande Reservation, California
580
La Posta Band of Diegueno Mission Indians of the
La Posta Indian Reservation, California
577
Mescalero Apache Tribe of the Mescalero
Reservation, New Mexico
702
Lac Courte Oreilles Band of Lake Superior
Chippewa Indians of Wisconsin
431
Miami Tribe of Oklahoma
925
Lac du Flambeau Band of Lake Superior Chippewa
Indians of the Lac du Flambeau Reservation of
Wisconsin
432
Lac Vieux Desert Band of Lake Superior Chippewa
Indians, Michigan
479
Las Vegas Tribe of Paiute Indians of the Las Vegas
Indian Colony, Nevada
648
Little River Band of Ottawa Indians, Michigan
Little Traverse Bay Bands of Odawa Indians,
Michigan
Miccosukee Tribe of Indians of Florida
26
Middletown Rancheria of Pomo Indians of
California
528
Minnesota Chippewa Tribe, Minnesota (Six
component reservations: Bois Forte Band (Nett
Lake); Fond du Lac Band; Grand Portage Band;
Leech Lake Band; Mille Lacs Band; White Earth
Band)
400
482
Mississippi Band of Choctaw Indians, Mississippi
980
483
Moapa Band of Paiute Indians of the Moapa River
Indian Reservation, Nevada
650
Modoc Tribe of Oklahoma
927
Toxics Release Inventory Reporting Form and Instructions
V-3
Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name
BIA Tribe Code
Mohegan Indian Tribe of Connecticut
BIA Tribe Code
Mooretown Rancheria of Maidu Indians of
California
626
Paiute-Shoshone Tribe of the Fallon Reservation and
Colony, Nevada
583
Morongo Band of Mission Indians, California
(formerly the Morongo Band of Cahuilla Mission
Indians of the Morongo Reservation)
582
Pala Band of Luiseno Mission Indians of the Pala
Reservation, California
Pascua Yaqui Tribe of Arizona
665
Paskenta Band of Nomlaki Indians of California
533
Muckleshoot Indian Tribe of the Muckleshoot
Reservation, Washington
109
Passamaquoddy Tribe of Maine
Muscogee (Creek) Nation, Oklahoma
908
Pauma Band of Luiseno Mission Indians of the
Pauma & Yuima Reservation, California
585
Pawnee Nation of Oklahoma
812
Pechanga Band of Luiseno Mission Indians of the
Pechanga Reservation, California
586
Narragansett Indian Tribe of Rhode Island
33
Indian Country Name
27
645
14
Navajo Nation, Arizona, New Mexico & Utah
780
Nez Perce Tribe, Idaho (previously listed as Nez
Perce Tribe of Idaho)
182
Nisqually Indian Tribe of the Nisqually Reservation,
Washington
110
Peoria Tribe of Indians of Oklahoma
926
Nooksack Indian Tribe of Washington
111
Picayune Rancheria of Chukchansi Indians of
California
534
Northern Cheyenne Tribe of the Northern Cheyenne
Indian Reservation, Montana
207
Pinoleville Pomo Nation, California (formerly the
Pinoleville Rancheria of Pomo Indians of California)
535
Northfork Rancheria of Mono Indians of California
532
195
Pit River Tribe, California (includes XL Ranch, Big
Bend, Likely, Lookout, Montgomery Creek and
Roaring Creek Rancherias)
536
Northwestern Band of Shoshoni Nation of Utah
(Washakie)
Nottawaseppi Huron Band of the Potawatomi,
Michigan (formerly the Huron Potawatomi, Inc.)
481
Pokagon Band of Potawatomi Indians, Michigan and
Indiana
480
Oglala Sioux Tribe of the Pine Ridge Reservation,
South Dakota
344
Ponca Tribe of Indians of Oklahoma
813
Ponca Tribe of Nebraska
381
Ohkay Owingeh, New Mexico (formerly the Pueblo
of San Juan)
714
Port Gamble Indian Community of the Port Gamble
Reservation, Washington
113
Omaha Tribe of Nebraska
380
Potter Valley Tribe, California
537
Prairie Band of Potawatomi Nation, Kansas
862
Prairie Island Indian Community in the State of
Minnesota
403
Oneida Nation of New York
Penobscot Tribe of Maine
11
Oneida Tribe of Indians of Wisconsin
Onondaga Nation of New York
433
6
18
Osage Nation, Oklahoma (formerly the Osage Tribe)
930
Pueblo of Acoma, New Mexico
703
Otoe-Missouria Tribe of Indians, Oklahoma
811
Pueblo of Cochiti, New Mexico
704
Ottawa Tribe of Oklahoma
922
Pueblo of Isleta, New Mexico
705
Paiute Indian Tribe of Utah (Cedar Band of Paiutes,
Kanosh Band of Paiutes, Koosharem Band of
Paiutes, Indian Peaks Band of Paiutes, and Shivwits
Band of Paiutes) (formerly Paiute Indian Tribe of
Utah (Cedar City Band of Paiutes, Kanosh Band of
Paiutes, Koosharem Band of Paiutes, Indian Peaks
Band of Paiutes, and Shivwits Band of Paiutes))
692
Pueblo of Jemez, New Mexico
706
Pueblo of Laguna, New Mexico
707
Pueblo of Nambe, New Mexico
708
Pueblo of Picuris, New Mexico
709
Pueblo of Pojoaque, New Mexico
710
Paiute-Shoshone Indians of the Bishop Community
of the Bishop Colony, California
549
Pueblo of San Felipe, New Mexico
712
Pueblo of San Ildefonso, New Mexico
713
Paiute-Shoshone Indians of the Lone Pine
Community of the Lone Pine Reservation,
California
624
Pueblo of Sandia, New Mexico
711
Pueblo of Santa Ana, New Mexico
715
Toxics Release Inventory Reporting Form and Instructions
V-4
Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name
BIA Tribe Code
Pueblo of Santa Clara, New Mexico
716
Pueblo of Taos, New Mexico
Indian Country Name
BIA Tribe Code
616
718
San Carlos Apache Tribe of the San Carlos
Reservation, Arizona
Pueblo of Tesuque, New Mexico
719
San Juan Southern Paiute Tribe of Arizona
689
Pueblo of Zia, New Mexico
720
588
Puyallup Tribe of the Puyallup Reservation,
Washington
115
San Manuel Band of Mission Indians, California
(previously listed as the San Manual Band of
Serrano Mission Indians of the San Manual
Reservation)
Pyramid Lake Paiute Tribe of the Pyramid Lake
Reservation, Nevada
651
San Pasqual Band of Diegueno Mission Indians of
California
589
Quapaw Tribe of Indians, Oklahoma
920
590
Quartz Valley Indian Community of the Quartz
Valley Reservation of California
563
Santa Rosa Band of Cahuilla Indians, California
(formerly the Santa Rosa Band of Cahuilla Mission
Indians of the Santa Rosa Reservation)
Quechan Tribe of the Fort Yuma Indian Reservation,
California & Arizona
696
Santa Rosa Indian Community of the Santa Rosa
Rancheria, California
542
Quileute Tribe of the Quileute Reservation,
Washington
116
Santa Ynez Band of Chumash Mission Indians of
the Santa Ynez Reservation, California
591
Quinault Tribe of the Quinault Reservation,
Washington
117
Santee Sioux Nation, Nebraska
382
Sauk-Suiattle Indian Tribe of Washington
119
Ramona Band of Cahuilla, California (formerly the
Ramona Band or Village of Cahuilla Mission
Indians of California)
597
Sault Ste. Marie Tribe of Chippewa Indians of
Michigan
469
Red Cliff Band of Lake Superior Chippewa Indians
of Wisconsin
435
Scotts Valley Band of Pomo Indians of California
503
Seminole Nation of Oklahoma
909
Red Lake Band of Chippewa Indians, Minnesota
409
Redding Rancheria, California
538
Redwood Valley Rancheria of Pomo Indians of
California
539
Reno-Sparks Indian Colony, Nevada
653
Resighini Rancheria, California
556
Rincon Band of Luiseno Mission Indians of the
Rincon Reservation, California
587
Robinson Rancheria of Pomo Indians of California
516
Rosebud Sioux Tribe of the Rosebud Indian
Reservation, South Dakota
Seminole Tribe of Florida (Dania, Big Cypress,
Brighton, Hollywood & Tampa Reservations)
21
Seneca Nation of New York
12
Seneca-Cayuga Tribe of Oklahoma
923
Shakopee Mdewakanton Sioux Community of
Minnesota
411
Shawnee Tribe, Oklahoma
911
Sherwood Valley Rancheria of Pomo Indians of
California
629
345
Shingle Springs Band of Miwok Indians, Shingle
Springs Rancheria (Verona Tract), California
546
Round Valley Indian Tribes of the Round Valley
Reservation, California
540
Shoalwater Bay Tribe of the Shoalwater Bay Indian
Reservation, Washington
118
Sac & Fox Nation of Missouri in Kansas and
Nebraska
863
Shoshone Tribe of the Wind River Reservation,
Wyoming
282
Sac & Fox Nation, Oklahoma
824
Shoshone-Bannock Tribes of the Fort Hall
Reservation of Idaho
180
Sac & Fox Tribe of the Mississippi in Iowa
490
641
Saginaw Chippewa Indian Tribe of Michigan
472
Shoshone-Paiute Tribes of the Duck Valley
Reservation, Nevada
Sisseton-Wahpeton Oyate of the Lake Traverse
Reservation, South Dakota
347
Saint Regis Mohawk Tribe, New York (formerly the
St. Regis Band of Mohawk Indians of New York)
7
Salt River Pima-Maricopa Indian Community of the
Salt River Reservation, Arizona
615
Skokomish Indian Tribe of the Skokomish
Reservation, Washington
120
Samish Indian Tribe, Washington
133
Skull Valley Band of Goshute Indians of Utah
682
Toxics Release Inventory Reporting Form and Instructions
V-5
Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name
BIA Tribe Code
Indian Country Name
BIA Tribe Code
Smith River Rancheria, California
564
Snoqualmie Tribe, Washington
126
Turtle Mountain Band of Chippewa Indians of North
Dakota
Soboba Band of Luiseno Indians, California
593
Tuscarora Nation of New York
Sokaogon Chippewa Community, Wisconsin
437
598
Southern Ute Indian Tribe of the Southern Ute
Reservation, Colorado
750
Twenty-Nine Palms Band of Mission Indians of
California
637
Spirit Lake Tribe, North Dakota
303
United Auburn Indian Community of the Auburn
Rancheria of California
Spokane Tribe of the Spokane Reservation,
Washington
102
United Keetoowah Band of Cherokee Indians in
Oklahoma
904
Squaxin Island Tribe of the Squaxin Island
Reservation, Washington
121
Upper Sioux Community, Minnesota
401
Upper Skagit Indian Tribe of Washington
131
St. Croix Chippewa Indians of Wisconsin
436
687
Standing Rock Sioux Tribe of North & South
Dakota
302
Ute Indian Tribe of the Uintah & Ouray
Reservation, Utah
751
Stillaguamish Tribe of Washington
139
Ute Mountain Tribe of the Ute Mountain
Reservation, Colorado, New Mexico & Utah
Stockbridge Munsee Community, Wisconsin
438
Utu Utu Gwaitu Paiute Tribe of the Benton Paiute
Reservation, California
520
Summit Lake Paiute Tribe of Nevada
655
114
Walker River Paiute Tribe of the Walker River
Reservation, Nevada
656
Suquamish Indian Tribe of the Port Madison
Reservation, Washington
30
Susanville Indian Rancheria, California
550
Wampanoag Tribe of Gay Head (Aquinnah) of
Massachusetts
Swinomish Indians of the Swinomish Reservation,
Washington
122
672
Sycuan Band of the Kumeyaay Nation
594
Washoe Tribe of Nevada & California (Carson
Colony, Dresslerville Colony, Woodfords
Community, Stewart Community, & Washoe
Ranches)
Table Mountain Rancheria of California
551
607
Te-Moak Tribe of Western Shoshone Indians of
Nevada (Four constituent bands: Battle Mountain
Band; Elko Band; South Fork Band and Wells Band)
640
White Mountain Apache Tribe of the Fort Apache
Reservation, Arizona
Wichita and Affiliated Tribes (Wichita, Keechi,
Waco & Tawakonie), Oklahoma
804
Thlopthlocco Tribal Town, Oklahoma
903
Winnebago Tribe of Nebraska
383
Three Affiliated Tribes of the Fort Berthold
Reservation, North Dakota
301
Winnemucca Indian Colony of Nevada
659
Tohono O’odham Nation of Arizona
610
Wiyot Tribe, California (formerly the Table Bluff
Reservation—Wiyot Tribe)
565
Tonawanda Band of Seneca Indians of New York
8
304
9
Wyandotte Nation, Oklahoma
924
Tonkawa Tribe of Indians of Oklahoma
814
Yankton Sioux Tribe of South Dakota
346
Tonto Apache Tribe of Arizona
674
595
Yavapai-Apache Nation of the Camp Verde Indian
Reservation, Arizona
601
Torres Martinez Desert Cahuilla Indians, California
(formerly the Torres-Martinez Band of Cahuilla
Mission Indians of California)
Yavapai-Prescott Tribe of the Yavapai Reservation,
Arizona
618
Tulalip Tribes of the Tulalip Reservation,
Washington
123
Yerington Paiute Tribe of the Yerington Colony &
Campbell Ranch, Nevada
660
Tule River Indian Tribe of the Tule River
Reservation, California
553
541
Tunica-Biloxi Indian Tribe of Louisiana
336
Yocha Dehe Wintun Nation, California (formerly
the Rumsey Indian Rancheria of Wintun Indians of
California)
Tuolumne Band of Me-Wuk Indians of the
Tuolumne Rancheria of California
634
Yomba Shoshone Tribe of the Yomba Reservation,
Nevada
661
Toxics Release Inventory Reporting Form and Instructions
V-6
Table V. Bureau of Indian Affairs (BIA) Tribal Codes
Indian Country Name
BIA Tribe Code
Ysleta Del Sur Pueblo of Texas
725
Yurok Tribe of the Yurok Reservation, California
562
Zuni Tribe of the Zuni Reservation, New Mexico
721
Toxics Release Inventory Reporting Form and Instructions
V-7
Table VI. Removal and Destruction Rates for POTWs
When completing Section 8 of the Form R, facilities should use their best readily available information to determine the final
disposition of toxic chemical sent to the publicly owned treatment works (POTW) and then distribute the amount reported in Section
6.1 among Sections 8.1c, 8.1d, and 8.7, as appropriate. Table VI presents data from EPA’s Risk-Screening Environmental Indicators
(RSEI) model that can be used to assist with these calculations.
To predict the fate and transport of TRI chemicals, the RSEI model uses estimates of chemical removal efficiencies at POTWs and
of the ultimate fate of the chemical amount removed. The amount of the chemical removed is divided into the percentages removed
by (1) sorbing to sludge, (2) volatilizing into the air or (3) being biodegraded by microorganisms. Table VI assigns the portion of the
influent diverted to sludge to Section 8.1c (off-site disposal to landfills and Class I UIC wells), the portion volatilizing into the air to
Section 8.1d (other off-site releases), and the portion being biodegraded to Section 8.7 (off-site treatment). The percentage of the
influent chemical that passes through the POTW and is not removed is also assigned to Section 8.1d.
POTW removal efficiencies are a function of many factors, including the treatment technology in place at the POTW. Information
about the final disposition of chemicals at the specific POTW in question should therefore be used in place of the percentages in
Table VI if available. Additional documentation for the values presented in Table VI can be found in Technical Appendix B of the
RSEI Model Documentation, available at: http://www2.epa.gov/toxics-release-inventory-tri-program/documentation-potw-removalrates.
TRI-MEweb will use the percentages below to calculate values for Sections 8.1c, 8.1d, and 8.7 unless you replace these default
percentages with location-specific estimates of removal and destruction rates for the POTW in question. For chemicals not included
in this table, TRI-MEweb’s default assumption is that 100% of the chemical sent to the POTW is treated for destruction.
CAS
Number
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
8.1d
8.7
CAS
Number
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
8.1d
8.7
50-00-0
Formaldehyde
0
8
92
62-74-8
Sodium fluoroacetate
1
25
74
51-03-6
Piperonyl butoxide
39
3
58
63-25-2
Carbaryl
1
12
87
51-21-8
Fluorouracil
1
55
44
64-18-6
Formic acid
0
8
92
51-28-5
2,4-Dinitrophenol
1
24
75
64-67-5
Diethyl sulfate
0
5
95
51-79-6
Urethane (Ethyl carbamate)
1
55
44
64-75-5
Tetracycline hydrochloride
1
55
44
52-68-6
Trichlorfon
0
8
92
67-56-1
Methanol
0
8
92
53-96-3
2-Acetylaminofluorene
5
42
53
67-66-3
Chloroform
1
73
26
55-63-0
Nitroglycerin
1
24
75
67-72-1
Hexachloroethane
18
56
26
56-23-5
Carbon tetrachloride
2
88
10
68-12-2
N,N-Dimethylformamide
0
8
92
56-38-2
Parathion
9
2
89
70-30-4
Hexachlorophene
62
1
37
57-14-7
1,1-Dimethyl hydrazine
1
25
74
71-36-3
n-Butyl alcohol
0
8
92
57-33-0
Pentobarbital sodium
2
53
45
71-43-2
Benzene
1
23
76
57-41-0
Phenytoin
2
51
47
71-55-6
1,1,1-trichloroethane
1
95
4
57-74-9
Chlordane
61
1
38
72-43-5
Methoxychlor
45
2
53
58-89-9
Lindane
13
24
63
72-57-1
Trypan blue
1
55
44
60-09-3
4-Aminoazobenzene
8
35
57
74-83-9
Bromomethane
0
80
20
60-11-7
4-Dimethylaminoazobenzene
35
5
60
74-85-1
Ethylene
0
92
8
60-34-4
Methyl hydrazine
1
25
74
74-87-3
Chloromethane
1
59
40
60-35-5
Acetamide
0
8
92
74-88-4
Methyl iodide
1
78
21
60-51-5
Dimethoate
1
55
44
74-90-8
Hydrogen cyanide
2
98
0
61-82-5
Amitrole
1
55
44
74-95-3
Methylene bromide
1
61
38
62-53-3
Aniline
0
8
92
75-00-3
Chloroethane
1
85
14
62-55-5
Thioacetamide
1
55
44
75-01-4
Vinyl chloride
0
92
8
62-56-6
Thiourea
1
25
74
75-05-8
Acetonitrile
1
25
74
62-73-7
Dichlorvos
1
25
74
75-07-0
Acetaldehyde
0
9
91
Toxics Release Inventory Reporting Forms and Instructions
VI-1
Table VI. Removal and Destruction Rates for POTWs
CAS
Number
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
8.1d
8.7
CAS
Number
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
8.1d
8.7
75-09-2
Dichloromethane
1
44
55
79-10-7
Acrylic acid
0
8
92
75-15-0
Carbon disulfide
1
87
12
79-11-8
Chloroacetic acid
0
8
92
75-21-8
Ethylene oxide
0
9
91
79-19-6
Thiosemicarbazide
1
55
44
75-25-2
Bromoform
2
57
41
79-21-0
Peracetic acid
0
8
92
75-27-4
Dichlorobromomethane
1
68
31
79-22-1
Methyl chlorocarbonate
0
1
99
75-34-3
Ethylidene dichloride
1
78
21
79-34-5
1,1,2,2-Tetrachloroethane
2
78
20
75-35-4
Vinylidene chloride
1
91
8
79-44-7
Dimethylcarbamyl chloride
0
0
100
75-43-4
Dichlorofluoromethane
1
91
8
79-46-9
2-Nitropropane
1
26
73
75-44-5
Phosgene
0
0
100
80-05-7
4,4'-Isopropylidenediphenol
5
14
81
75-45-6
Chlorodifluoromethane
1
88
11
80-15-9
Cumene hydroperoxide
1
24
75
75-55-8
Propyleneimine
1
25
74
80-62-6
0
10
90
75-56-9
Propylene oxide
0
9
91
75-63-8
Bromotrifluoromethane
0
99
1
81-07-2
Methyl methacrylate
Saccharin (only persons who
manufacture are subject, no
supplier notification)
1
25
74
75-65-0
tert-Butyl alcohol
1
55
44
82-68-8
Quintozene
43
11
46
75-68-3
1-Chloro-1,1-difluoroethane
Trichlorofluoromethane
(CFC-11)
Dichlorodifluoromethane
(CFC-12)
Chlorotrifluoromethane
(CFC-13)
1
98
1
84-74-2
Dibutyl phthalate
29
1
70
1
98
1
85-01-8
Phenanthrene
32
6
62
85-44-9
Phthalic anhydride
0
1
99
0
99
1
86-30-6
N-Nitrosodiphenylamine
5
42
53
0
99
1
87-62-7
2,6-Xylidine
2
53
45
87-68-3
Hexachloro-1,3-butadiene
45
23
32
87-86-5
Pentachlorophenol (PCP)
54
4
42
88-06-2
2,4,6-Trichlorophenol
9
9
82
88-75-5
2-Nitrophenol
1
59
40
88-85-7
Dinitrobutyl phenol
12
54
34
75-69-4
75-71-8
75-72-9
75-86-5
0
0
100
75-88-7
2-Methyllactonitrile
2-Chloro-1,1,1trifluoroethane
0
99
1
76-01-7
Pentachloroethane
6
75
19
76-06-2
Chloropicrin
1
88
11
76-13-1
Freon 113
Dichlorotetrafluoroethane
(CFC-114)
Monochloropentafluoroethane
(CFC-115)
3
96
1
88-89-1
Picric acid
1
78
21
2
97
1
90-04-0
o-Anisidine
1
25
74
1
98
1
90-43-7
2-Phenylphenol
3
5
92
Toluene-2,6-diisocyanate
2
1
97
76-14-2
76-15-3
76-44-8
Heptachlor
50
1
49
91-08-7
76-87-9
Triphenyltin hydroxide
14
86
0
91-20-3
Naphthalene
4
6
90
77-47-4
Hexachlorocyclopentadiene
44
11
45
91-22-5
Quinoline
1
24
75
77-73-6
Dicyclopentadiene
7
84
9
91-59-8
beta-Naphthylamine
1
23
76
77-78-1
0
3
97
91-94-1
3,3'-Dichlorobenzidine
9
32
59
92-52-4
Biphenyl
10
2
88
78-48-8
Dimethyl sulfate
S,S,STributyltrithiophosphate
(DEF)
37
0
63
92-67-1
4-Aminobiphenyl
3
47
50
78-84-2
Isobutyraldehyde
0
9
91
92-87-5
Benzidine
1
25
74
78-87-5
1,2-Dichloropropane
1
70
29
93-65-2
Mecoprop
5
42
53
2,4-D isopropyl ester
8
2
90
78-88-6
2,3-Dichloropropene
1
67
32
94-11-1
78-92-2
sec-Butyl alcohol
0
8
92
94-36-0
Benzoyl peroxide
5
3
92
79-00-5
1,1,2-Trichloroethane
1
82
17
94-58-6
Dihydrosafrole
10
30
60
79-01-6
Trichloroethylene
1
93
6
94-59-7
Safrole
8
34
58
79-06-1
Acrylamide
0
8
92
94-74-6
Methoxone ((4-Chloro-2-
6
39
55
Toxics Release Inventory Reporting Forms and Instructions
VI-2
Table VI. Removal and Destruction Rates for POTWs
CAS
Number
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
methylphenoxy) acetic acid)
(MCPA)
8.1d
8.7
94-75-7
2,4-D
2
6
92
94-80-4
2,4-D butyl ester
15
1
84
95-47-6
o-Xylene
3
16
81
95-48-7
o-Cresol
0
8
92
95-50-1
1,2-Dichlorobenzene
7
47
46
95-53-4
o-Toluidine
0
94
6
95-54-5
1,2-Phenylenediamine
1
55
44
95-63-6
1,2,4-Trimethylbenzene
11
21
68
95-80-7
2,4-Diaminotoluene
1
55
44
95-95-4
2,4,5-Trichlorophenol
13
25
62
96-09-3
1
25
74
96-12-8
Styrene oxide
1,2-Dibromo-3-chloropropane
(DBCP)
4
72
24
96-18-4
1,2,3-Trichloropropane
2
56
42
96-33-3
Methyl acrylate
0
9
96-45-7
Ethylene thiourea
1
98-07-7
Benzoic trichloride
98-82-8
CAS
Number
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
8.1d
8.7
106-47-8
p-Chloroaniline
1
54
45
106-50-3
p-Phenylenediamine
1
55
44
106-51-4
Quinone
1
59
40
106-88-7
1,2-Butylene oxide
0
27
73
106-89-8
Epichlorohydrin
1
55
44
106-93-4
1,2-Dibromoethane
1
60
39
106-99-0
1,3-Butadiene
1
86
13
107-02-8
Acrolein
0
9
91
107-05-1
Allyl chloride
1
85
14
107-06-2
1,2-Dichloroethane
1
64
35
107-11-9
Allylamine
1
25
74
107-13-1
Acrylonitrile
0
9
91
107-18-6
Allyl alcohol
0
8
92
107-19-7
Propargyl alcohol
0
8
92
107-21-1
Ethylene glycol
0
8
92
91
107-30-2
Chloromethyl methyl ether
0
0
100
55
44
108-05-4
Vinyl acetate
0
11
89
0
0
100
108-10-1
Methyl isobutyl ketone
0
9
91
Cumene
7
13
80
108-31-6
Maleic anhydride
0
0
100
98-86-2
Acetophenone
0
8
92
108-38-3
m-Xylene
3
18
79
98-87-3
Benzal chloride
0
0
100
108-39-4
m-Cresol
0
8
92
98-88-4
Benzoyl chloride
0
0
100
108-45-2
55
44
Nitrobenzene
0
8
92
99-55-8
5-Nitro-o-toluidine
1
54
45
108-60-1
1,3-Phenylenediamine
Bis(2-chloro-1-methylethyl)
ether
1
98-95-3
2
53
45
99-65-0
m-Dinitrobenzene
1
54
45
108-88-3
Toluene
1
23
76
100-01-6
p-Nitroaniline
1
54
45
108-90-7
Chlorobenzene
2
39
59
100-02-7
4-Nitrophenol
0
93
7
108-93-0
Cyclohexanol
0
9
91
100-25-4
p-Dinitrobenzene
1
54
45
108-95-2
Phenol
0
8
92
100-41-4
Ethylbenzene
3
45
52
109-06-8
2-Methylpyridine
0
8
92
100-42-5
Styrene
2
13
85
109-77-3
Malononitrile
1
55
44
100-44-7
Benzyl chloride
1
27
72
109-86-4
2-Methoxyethanol
0
8
92
100-75-4
N-Nitrosopiperidine
1
55
44
110-54-3
n-Hexane
9
53
38
101-05-3
16
19
65
110-57-6
trans-1,4-Dichloro-2-butene
2
27
71
110-80-5
2-Ethoxyethanol
0
8
92
101-14-4
Anilazine
4,4'-Methylenebis(2chloroaniline) (MBOCA)
17
18
65
110-82-7
Cyclohexane
6
19
75
101-77-9
4,4'-Methylenedianiline
1
24
75
110-86-1
Pyridine
0
8
92
101-80-4
4,4'-Diaminodiphenyl ether
1
24
75
111-42-2
Diethanolamine
0
8
92
101-90-6
Diglycidyl resorcinol ether
1
25
74
111-44-4
Bis(2-chloroethyl) ether
2
78
20
105-67-9
2,4-Dimethylphenol
1
23
76
111-91-1
Bis(2-chloroethoxy) methane
1
78
21
106-42-3
p-Xylene
3
19
78
114-26-1
Propoxur
0
8
92
106-44-5
p-Cresol
0
8
92
115-07-1
Propylene (Propene)
0
91
9
106-46-7
1,4-Dichlorobenzene
7
49
44
Toxics Release Inventory Reporting Forms and Instructions
VI-3
Table VI. Removal and Destruction Rates for POTWs
CAS
Number
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
8.1d
8.7
115-32-2
Dicofol
44
2
54
116-06-3
Aldicarb
1
54
45
117-79-3
2-Aminoanthraquinone
2
52
46
117-81-7
Di(2-ethylhexyl) phthalate
38
0
62
118-74-1
Hexachlorobenzene
60
2
38
119-90-4
3,3'-Dimethoxybenzidine
1
54
45
119-93-7
3,3'-Dimethylbenzidine
1
23
76
120-12-7
Anthracene
31
8
61
120-36-5
2,4-DP
8
34
58
CAS
Number
137-41-7
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
Potassium Nmethyldithiocarbamate
0
8.1d
8.7
27
73
137-42-8
Metham sodium
0
27
73
139-13-9
Nitrilotriacetic acid
0
8
92
140-88-5
Ethyl acrylate
0
10
90
141-32-2
Butyl acrylate
1
9
90
142-59-6
Nabam
0
10
90
148-79-8
2
51
47
149-30-4
Thiabendazole
2-Mercaptobenzothiazole
(MBT)
2
52
46
Merphos
22
0
78
120-58-1
Isosafrole
7
36
57
150-50-5
120-71-8
p-Cresidine
1
54
45
151-56-4
Ethyleneimine (Aziridine)
1
55
44
120-80-9
Catechol
0
8
92
156-62-7
Calcium cyanamide
2
98
0
120-82-1
1,2,4-Trichlorobenzene
19
22
59
298-00-0
Methyl parathion
2
6
92
120-83-2
2,4-Dichlorophenol
3
5
92
300-76-5
Naled
1
25
74
0
15
85
1
98
1
121-14-2
2,4-Dinitrotoluene
1
54
45
302-01-2
121-44-8
Triethylamine
1
56
43
306-83-2
Hydrazine
2,2-Dichloro-1,1,1trifluoroethane
121-69-7
N,N-Dimethylaniline
2
53
45
309-00-2
Aldrin
62
1
37
121-75-5
Malathion
1
7
92
314-40-9
Bromacil
2
53
45
122-34-9
Simazine
2
77
21
330-54-1
Diuron
2
50
48
122-39-4
Diphenylamine
7
12
81
330-55-2
Linuron
5
41
54
122-66-7
1,2-Diphenylhydrazine
4
46
50
333-41-5
Diazinon
12
7
81
123-31-9
Hydroquinone
0
8
92
353-59-3
Bromochlorodifluoromethane
1,1,1,2-Tetrachloro-2fluoroethane (HCFC-121a)
1,1,2,2-Tetrachloro-1fluoroethane (HCFC-121)
1,2-Dichloro-1,1,2trifluoroethane
1-Chloro-1,1,2,2tetrafluoroethane
1
98
1
3
84
13
3
84
13
1
98
1
0
99
1
1
55
44
3
96
1
1
98
1
123-38-6
Propionaldehyde
0
9
91
123-63-7
Paraldehyde
1
55
44
123-72-8
Butyraldehyde
0
9
91
354-14-3
123-91-1
1,4-Dioxane
1
55
44
354-23-4
124-40-3
Dimethylamine
0
8
92
124-73-2
Dibromotetrafluoroethane
2
97
1
126-98-7
Methacrylonitrile
1
27
72
126-99-8
1
93
6
422-56-0
6
87
7
460-35-5
1
28
71
128-04-1
Chloroprene
Tetrachloroethylene
(Perchloroethylene)
Potassium
dimethyldithiocarbamate
Sodium
dimethyldithiocarbamate
1
28
71
131-11-3
Dimethyl phthalate
0
8
92
132-64-9
Dibenzofuran
18
4
78
133-06-2
Captan
1
23
76
133-07-3
Folpet
2
20
134-32-7
alpha-Naphthylamine
1
136-45-8
Dipropyl isocinchomeronate
137-26-8
Thiram
127-18-4
128-03-0
354-11-0
354-25-6
357-57-3
Brucine
3,3-Dichloro-1,1,1,2,2pentafluoropropane
3-Chloro-1,1,1trifluoropropane
463-58-1
Carbonyl sulfide
0
84
16
465-73-6
Isodrin
C.I. Solvent Yellow 34
(Auramine)
62
1
37
2
50
48
0
0
100
507-55-1
Mustard gas
1,3-Dichloro-1,1,2,2,3pentafluoropropane
3
96
1
78
510-15-6
Chlorobenzilate
39
3
58
24
75
528-29-0
o-Dinitrobenzene
1
54
45
6
3
91
533-74-4
Dazomet
0
3
97
1
24
75
534-52-1
4,6-Dinitro-o-cresol
2
53
45
492-80-8
505-60-2
Toxics Release Inventory Reporting Forms and Instructions
VI-4
Table VI. Removal and Destruction Rates for POTWs
CAS
Number
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
8.1d
8.7
540-59-0
1,2-Dichloroethylene
1
74
25
541-41-3
Ethyl chloroformate
1
43
56
541-53-7
2,4-Dithiobiuret
1
51
48
541-73-1
1,3-Dichlorobenzene
8
47
45
542-75-6
1,3-Dichloropropylene
1
44
55
542-76-7
3-Chloropropionitrile
1
55
44
542-88-1
Bis(chloromethyl) ether
0
0
100
554-13-2
Lithium carbonate
2
98
0
556-61-6
Methyl isothiocyanate
0
0
100
563-47-3
3-Chloro-2-methyl-1-propene
1
93
6
584-84-9
Toluene-2,4-diisocyanate
2
1
97
606-20-2
2
53
45
612-83-9
2,6-Dinitrotoluene
3,3'-Dichlorobenzidine
dihydrochloride
9
32
59
621-64-7
N-Nitrosodi-n-propylamine
1
54
45
624-83-9
Methyl isocyanate
0
0
100
630-20-6
1,1,1,2-Tetrachloroethane
3
82
15
636-21-5
o-Toluidine hydrochloride
1
54
45
684-93-5
N-Nitroso-N-methylurea
Propanil (N-(3,4Dichlorophenyl)propanamide)
1
55
44
4
44
1
759-94-4
N-Nitroso-N-ethylurea
Ethyl dipropylthiocarbamate
(EPTC)
764-41-0
CAS
Number
1649-08-7
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
1,2-Dichloro-1,1difluoroethane
1
8.1d
8.7
97
2
1689-84-5
Bromoxynil
6
13
81
1689-99-2
Bromoxynil octanoate
38
0
62
1717-00-6
1,1-Dichloro-1-fluoroethane
1
96
3
1861-40-1
Benfluralin
56
3
41
1897-45-6
Chlorothalonil
3
18
79
1910-42-5
Paraquat dichloride
1
55
44
1912-24-9
Atrazine
3
74
23
1918-00-9
Dicamba
1
53
46
1918-02-1
Picloram
2
90
8
1918-16-7
Propachlor
1
24
75
1928-43-4
2,4-D 2-ethylhexyl ester
22
0
78
1929-73-3
12
1
87
1929-82-4
2,4-D butoxyethyl ester
Nitrapyrin (2-Chloro-6(trichloromethyl)pyridine)
7
36
57
1982-69-0
Sodium dicamba
1
53
46
2164-07-0
Dipotassium endothall
1
24
75
2164-17-2
Fluometuron
2
52
46
2234-13-1
Octachloronaphthalene
62
1
37
52
2300-66-5
Dimethylamine dicamba
1
54
45
55
44
2303-16-4
Diallate
21
14
65
5
41
54
2303-17-5
Triallate
35
5
60
1,4-Dichloro-2-butene
1
84
15
2312-35-8
Propargite
42
44
14
834-12-8
Ametryn
4
45
51
2699-79-8
Sulfuryl fluoride
2
98
0
872-50-4
N-Methyl-2-pyrrolidone
0
8
92
2702-72-9
2
6
92
924-42-5
N-Methylolacrylamide
0
8
92
2837-89-0
2,4-D sodium salt
2-Chloro-1,1,1,2tetrafluoroethane
0
99
1
961-11-5
Tetrachlorvinphos
7
11
82
2971-38-2
2,4-D chlorocrotyl ester
16
0
84
1120-71-4
Propane sultone
1
29
70
3383-96-8
38
0
62
1163-19-5
Decabromodiphenyl oxide
62
1
37
1313-27-5
Molybdenum trioxide
2
98
0
1
25
74
1314-20-1
Thorium dioxide
90
10
0
1319-77-3
Cresol (mixed isomers)
2,4-D propylene glycol butyl
ether ester
0
8
92
4080-31-3
Temephos
Methoxone sodium salt ((4Chloro-2-methylphenoxy)
acetate sodium salt)
1-(3-Chloroallyl)-3,5,7-triaza1-azoniaadamantane chloride
1
55
44
4170-30-3
Crotonaldehyde
0
10
90
15
0
85
4549-40-0
N-Nitrosomethylvinylamine
9
51
40
5234-68-4
Carboxin
1
24
75
709-98-8
759-73-9
1320-18-9
1330-20-7
3
17
80
61
1
38
1344-28-1
Xylene (mixed isomers)
Polychlorinated biphenyls
(PCBs)
Aluminum oxide (fibrous
forms)
2
98
0
1464-53-5
Diepoxybutane
1
25
74
1563-66-2
Carbofuran
1
7
92
1582-09-8
Trifluralin
57
3
40
1634-04-4
Methyl tert-butyl ether
1
60
39
1336-36-3
3653-48-3
7287-19-6
Prometryn
11
56
33
7429-90-5
Aluminum (fume or dust)
66
34
0
7439-92-1
Lead
63
37
NA
7439-96-5
Manganese
39
61
NA
7439-97-6
Mercury
69
31
NA
7440-02-0
Nickel
38
62
NA
Toxics Release Inventory Reporting Forms and Instructions
VI-5
Table VI. Removal and Destruction Rates for POTWs
CAS
Number
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
8.1d
8.7
CAS
Number
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
8.1d
8.7
7440-22-4
Silver
66
34
NA
13684-56-5
Desmedipham
5
9
86
7440-28-0
Thallium
54
46
NA
15972-60-8
Alachlor
7
11
82
7440-36-0
Antimony
32
68
NA
17804-35-2
Benomyl
1
49
50
7440-38-2
Arsenic
49
51
NA
19044-88-3
Oryzalin
3
49
48
19666-30-9
40
3
57
1
55
44
7440-39-3
Barium
69
31
NA
7440-41-7
Beryllium
37
63
NA
7440-43-9
Cadmium
68
32
NA
20325-40-0
Oxydiazon
3,3'-Dimethoxybenzidine
dihydrochloride (oDianisidine dihydrochloride)
7440-47-3
Chromium
76
24
NA
20816-12-0
Osmium tetroxide
2
98
0
7440-48-4
Cobalt
32
68
NA
20859-73-8
Aluminum phosphide
2
98
0
7440-50-8
72
28
NA
21087-64-9
Metribuzin
1
54
45
7440-62-2
Copper
Vanadium (except when
contained in an alloy)
32
68
NA
21725-46-2
Cyanazine
2
76
22
7440-66-6
Zinc (fume or dust)
66
34
NA
22781-23-3
Bendiocarb
1
23
76
7550-45-0
Titanium tetrachloride
2
98
0
23564-05-8
Thiophanate-methyl
1
25
74
7632-00-0
Sodium nitrite
2
98
0
23950-58-5
10
30
60
7637-07-2
2
98
0
1
53
46
8
47
45
7647-01-0
Boron trifluoride
Hydrochloric acid (acid
aerosols including mists,
vapors, gas, fog, and other
airborne forms of any particle
size)
0
0
100
Pronamide
Dinitrotoluene (mixed
isomers)
Dichlorobenzene (mixed
isomers)
Diaminotoluene (mixed
isomers)
1
78
21
7664-39-3
Hydrogen fluoride
2
98
0
38
0
62
7664-41-7
0
40
60
26471-62-5
2
1
97
26628-22-8
Sodium azide
2
98
0
28249-77-6
Thiobencarb
8
35
57
7664-93-9
Ammonia
Sulfuric acid (acid aerosols
including mists, vapors, gas,
fog, and other airborne forms
of any particle size)
Phenothrin
Toluene diisocyanate (mixed
isomers)
0
0
100
30560-19-1
Acephate
1
55
44
7697-37-2
Nitric acid
0
0
100
34014-18-1
Tebuthiuron
2
77
21
7723-14-0
Phosphorus (yellow or white)
60
40
0
34077-87-7
Dichlorotrifluoroethane
1
98
1
7726-95-6
Bromine
2
98
0
35367-38-5
Diflubenzuron
13
6
81
7758-29-4
Potassium bromate
2
98
0
35554-44-0
Imazalil
15
21
64
7782-41-4
Fluorine
2
98
0
40487-42-1
Pendimethalin
47
1
52
7782-49-2
Selenium
44
56
NA
42874-03-3
Oxyfluorfen
39
3
58
7782-50-5
Chlorine
2
98
0
43121-43-3
Triadimefon
3
48
49
7803-51-2
Phosphine
2
98
0
51235-04-2
Hexazinone
19
16
65
8001-35-2
Toxaphene
62
1
37
52645-53-1
38
0
62
10028-15-6
Ozone
2
98
0
10034-93-2
Hydrazine sulfate
2
98
0
Permethrin
2,4-D 2-ethyl-4-methylpentyl
ester
10049-04-4
Chlorine dioxide
2
98
0
10061-02-6
trans-1,3-Dichloropropene
1
31
68
55406-53-6
10294-34-5
Boron trichloride
2
98
0
12122-67-7
Zineb
0
2
98
12427-38-2
Maneb
2
98
13194-48-4
Ethoprop
10
29
25321-14-6
25321-22-6
25376-45-8
26002-80-2
53404-37-8
21
0
79
1
55
44
1
23
76
57213-69-1
Dimethipin
3-Iodo-2-propynyl
butylcarbamate
Triclopyr triethylammonium
salt
1
25
74
59669-26-0
Thiodicarb
1
24
75
0
60207-90-1
Propiconazole
9
32
59
61
62476-59-9
Acifluorfen, sodium salt
12
25
63
55290-64-7
Toxics Release Inventory Reporting Forms and Instructions
VI-6
Table VI. Removal and Destruction Rates for POTWs
CAS
Number
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
8.1d
8.7
64902-72-3
Chlorsulfuron
1
54
45
67485-29-4
Hydramethylnon
53
0
47
68359-37-5
Cyfluthrin
38
0
62
71751-41-2
Abamectin
44
2
54
72178-02-0
Fomesafen
3
47
50
77501-63-4
Lactofen
31
0
69
82657-04-3
Bifenthrin
38
0
62
88671-89-0
Myclobutanil
9
32
59
90982-32-4
Chlorimuron ethyl
1
23
76
101200-48-0
Tribenuron methyl
2
22
76
127564-92-5
Dichloropentafluoropropane
3
96
N010
Antimony Compounds
32
N020
Arsenic Compounds
N040
Barium Compounds
CAS
Number
N171
% of §6.1 to §:
Chemical Name
8.1c
Arranged by CAS Number
Ethylenebisdithiocarbamic
acid, salts and esters
2
8.1d
8.7
98
0
N230
Certain Glycol Ethers
0
8
92
N420
Lead Compounds
63
37
NA
N450
Manganese Compounds
39
61
NA
N458
Mercury Compounds
69
31
NA
N495
Nickel Compounds
38
62
NA
N503
Nicotine and salts
2
98
0
N511a
0
10
90
N590
Nitrate Compounds
Polycyclic Aromatic
Compounds
92
7
1
1
N725
Selenium Compounds
44
56
NA
68
NA
N740
Silver Compounds
66
34
NA
49
51
NA
N746
Strychnine and salts
2
98
0
69
31
NA
N760
Thallium Compounds
54
46
NA
Vanadium Compounds
32
68
NA
Warfarin And Salts
3
97
0
N050
Beryllium Compounds
37
63
NA
N770
N078
Cadmium Compounds
68
32
NA
N874
N084
54
4
42
N090
Chlorophenols
Chromium Compounds
(except chromite ore mined in
the transvaal region)
76
24
NA
N096
Cobalt Compounds
32
68
NA
N100
Copper Compounds
72
28
NA
N106
Cyanide Compounds
2
98
0
N982
Zinc Compounds
66
34
NA
a
N511: Nitrate compounds (water dissociable) are reportable only
when in aqueous solution. Removal of nitrate compounds from
wastewater and/or aqueous solution therefore constitutes treatment
for destruction for TRI reporting purposes. Data source for nitrate
removal rate is US EPA. [2012]. EPIWEB- Estimation Programs
Interface Suite™ for Microsoft® Windows, v 4.11. Sewage
Treatment Plant Model (STPWIN). United States Environmental
Protection Agency, Washington, DC.
Toxics Release Inventory Reporting Forms and Instructions
VI-7
Appendix A. TRI Federal Facility Reporting
Information
Special Instructions for TRI Federal
Facility Reporting
Important: Please note that federal facilities must now
submit TRI reports electronically using TRI-MEweb.
Resources on TRI-MEweb are accessible at:
http://www2.epa.gov/toxics-release-inventory-triprogram/tri-meweb-resources.
A.1 Why Do Federal
Facilities Need to Report?
Executive Order 13423, “Strengthening Federal
Environmental
Energy,
and
Transportation
Management,” requires federal agencies to comply with
the Emergency Planning and Community Right-ToKnow Act of 1986 (EPCRA) and the Pollution
Prevention Act of 1990 (PPA). Federal facilities have
been subject to EPCRA section 313 and PPA since
reporting year 1994. TRI submissions are due to EPA on
July 1 of the year following each reporting (calendar)
year. Reporting by the federal facility does not alter the
reporting obligation of on-site contractors. Contracts
entered into after the date of this order for contractor
operation of government-owned facilities or vehicles
require the contractor to comply with the provisions of
this order with respect to such facilities or vehicles to the
same extent as the agency would be required to comply if
the agency operated facilities or vehicles.
For more information on Executive Order 13423, please
refer to the implementing instructions which can be found
on the TRI web page: http://www2.epa.gov/toxicsrelease-inventory-tri-program/tri-laws-rulemakings-andnotices
A.2 Identifying Federal
Facility Reports
Federal facility reports are identified as federal by several
indicators on the form. The facility name and parent
company name are critical indicators and must be
reported as described below. Another critical indicator is
the federal facility report box, Part I, 4.2c. Federal
facilities only should check this box to indicate that the
report is from a federal agency for a federal facility;
federal facilities should not check the GOCO box, (Part I,
Section 4.2d of the Form R). Contractors located at
federal facilities (GOCOs) should check the GOCO box
(Part I, Section 4.2d of the Form R); they should not
check the box 4.2c. Facilities should also complete the
partial or complete facility blocks (Form R page 2, block
4.2a and 4.2b) as appropriate. If you are a federal facility
reporting for the first time, you should write "new" in the
TRI Facility ID (TRIFID) box, even if a contractor has
reported for your facility in the past. The contractor will
retain the original TRIFID. You will be assigned a new
TRIFID the first time you report.
A.3 The “Double
Counting” Problem
As structured, the law and the executive order require
both regulated industries and the federal government to
report TRI data, sometimes for the same site. In order to
prevent duplicate data in the TRI database, which could
result in “double counting” data for some chemicals and
locations, EPA must be able to identify and distinguish
the GOCO reports submitted by the federal contractor
from the federal facility reports which contain data for
the same site. To accomplish this, federal facility reports
should be accompanied by either 1) exact electronic
copies of all contractor TRI reports, including when the
totals reported by the federal facility are greater than
those reported by the contractor(s), or 2) a cover letter
with a list of the facility contractors that submit TRI
reports to EPA, identifying each contractor by name, TRI
technical contact, and TRI facility name and address.
Additionally, federal facilities should check Form R, Part
I, Section 4.2c, while contractors at federal facilities
should check Form R, Part I, Section 4.2d.
A.4 How to Report Your
Facility Name
Facility name is a critical data element. It is used by EPA
to create the TRI facility ID number (TRIFID), which is a
unique number designed to identify a facility site. The
facility name and TRIFID number are used by all TRI
data users to link data from a single site across multiple
reporting years. A federal facility is assigned a new
TRIFID number when the federal report is entered into
the Toxics Release Inventory system for the first time.
This TRIFID number, generated when the first report is
entered into the Toxics Release Inventory System, will be
included in future reporting packages sent to the federal
facility, and should be used by the federal facility in all
future reports.
Federal facilities should report their facility name in
Section 4.1 as shown in the following example:
U.S. DOE Savannah River Site
It is very important that the agency name appear first,
followed by the specific plant or site name.
Toxics Release Inventory Reporting Forms and Instructions
A-1
Appendix A
Federal contractors at GOCO facilities should report their
names as shown in the following example:
U.S. DOE Savannah River Site - Westinghouse
Operations.
A.5 How to Report Your
North American Industry
Classification System
(NAICS) Code
Federal facilities should report the NAICS code which
most closely represents the activities taking place at the
site. Section A.10 lists the Public Administration NAICS
codes covering executive, legislative, judicial,
administrative and regulatory activities of the Federal
government. Government-owned and operated business
establishments are classified in major NAICS groups
according to the activity in which they are engaged. For
example, a Veterans Hospital would be classified in
Group 806 - Hospitals.
A.6 How to Report Your
“Parent Company” Name
Federal facilities should report their parent company
name on page 2 of the Form Rs (Section 5.1) by reporting
their complete Department or Agency name, as shown in
the following example:
U.S. Department of Energy
Block 5.2, Parent Company’s Dun & Bradstreet Number,
should be marked NA.
Federal contractors at GOCO facilities should not report a
federal department or agency name as their parent
company. A federal name in the parent company name
field will classify the report as federal, and the GOCO
may be identified as a non-reporter.
A.7 How to Revise Your
Data After It Has Been
Submitted
Effective January 21, 2013, facilities may only revise TRI
reporting forms submitted for Reporting Year 1991
through the current reporting year. Use TRI-MEweb to
submit revisions to non-trade secret TRI submissions.
If you have questions about using TRI-MEweb to revise
your Form R/A, please refer to the TRI-MEweb tutorial
page at:
http://www2.epa.gov/toxics-release-inventory-triprogram/tri-meweb-tutorials.
Facilities may request a revision for one or more of the
following reasons:
Revision codes:
RR1 - New Monitoring Data
RR2 - New Emission Factor(s)
RR3 - New Chemical Concentration Data
RR4 - Recalculation(s)
RR5 - Other Reason(s)
Please note that late submissions for chemicals not
reported in a previous reporting year are not considered
revisions for that year.
Facilities are reminded that there is a legal obligation to
file an accurate and complete Form R or Form A report
for each chemical by July 1 each year. EPA may take
enforcement action and assess civil administrative
penalties regarding corrections to errors in Form R
reports that are not changes based on previously
unavailable information or procedures which improve the
accuracy of the data initially reported. The kinds of errors
which may result in enforcement and in penalties include
but are not limited to the following: (1) Errors caused by
not using the most readily available information, for
example, not using monitoring data collected for
compliance with other regulations in calculating releases;
(2) omitting a major source of emissions; (3) a
mathematical or transcription or typographical error
which seriously compromises the accuracy of the
information, and; (4) other errors which seriously affect
the utility of the data, particularly errors in release
reporting for which the facility has no records showing
the derivation of the release calculation, and cannot
provide a sufficient explanation of the report.
How do I revise my submission(s)?
If you plan to revise a TRI submission, you must send
revised report(s) to EPA and the appropriate state or
tribal agency.
You must use TRI-MEweb to submit revisions to nontrade secret TRI submissions. EPA will only accept
revisions for Reporting Year 1991 through the current
year.
Toxics Release Inventory Reporting Forms and Instructions
A-2
Appendix A
A.8 Who Should Sign
Federal Form R Reports?
Federal Form R reports should be certified by the senior
federal employee on-site. If no federal employee is onsite, federal Form R reports must be certified by the
senior federal employee with management responsibility
for the site. Federal Form R reports should be certified by
a federal employee. Contractor employee certifications
are not considered valid on federal reports.
A.9 More Help is
Available!
Federal facilities may call the EPA/TRI Information
Center to ask specific questions concerning how to
submit their Form R report. For contact information, see
the “Contact Us” link on the TRI Home Page at
http://www.epa.gov/tri. Additional information may also
be found in the Federal Facilities guidance document at:
http://www2.epa.gov/toxics-release-inventory-triprogram/guidance-federal-facilities-revised-1999version.
A.10 North American
Industry Classification
System Codes 921-928
Sector 92 - Public Administration
921
Executive, Legislative, and Other
General Government Support
92111
92112
92113
92114
92115
92119
Executive Offices
Legislative Bodies
Public Finance Activities
Executive and Legislative Offices Combined
American Indian and Alaska Native Tribal
Governments
General Government, Not Elsewhere Classified
922
Justice, Public Order, and Safety
Activities
92211
92212
92213
92214
92215
92216
92219
923
Administration of Human Resource
Programs
92311
92312
92313
92314
Administration of Educational Programs
Administration of Public Health Programs
Administration of Human Resource Programs
(Except Education, Public Health, and Veterans’
Affairs Programs)
Administration of Veterans Affairs
924
Administration of Environmental
Quality Programs
92411
92412
Administration of Air and Water Resource and
Solid Waste Management Programs
Administration of Conservation Programs
925
Administration of Housing Programs,
Urban Planning, and Community
Development
92511
92512
Administration of Housing Programs
Administration of Urban Planning and
Community and Rural Development
926
Administration of Economic
Programs
92611
92612
92613
92614
92615
Administration of General Economic Programs
Regulation and Administration of Transportation
Programs
Regulation and Administration of
Communications, Electric, Gas, and Other
Utilities
Regulation of Agricultural Marketing and
Commodities
Regulation, Licensing, and Inspection of
Miscellaneous Commercial Sectors
927
Space Research and Technology
92711
Space Research and Technology
928
National Security and International
Affairs
92811
92812
National Security
International Affairs
Courts
Police Protection
Legal Counsel and Prosecution
Correctional Institutions
Parole Offices and Probation Offices
Fire Protection
Other Justice, Public Order and Safety Activities
Toxics Release Inventory Reporting Forms and Instructions
A-3
Appendix B. Reporting Codes for EPA Form R
and Instructions for Reporting Metals
B.1 Form R Part II
Revision Codes:
RR1
RR2
RR3
RR4
RR5
New Monitoring Data
New Emission Factor(s)
New Chemical Concentration Data
Recalculation(s)
Other Reason(s)
Withdrawal Codes:
WT1
WT2
WT3
WO1
Did not meet the reporting threshold for
manufacturing, processing, or otherwise use
Did not meet the reporting threshold for number
of employees
Not in a covered NAICS Code
Other reason(s)
Section 1.1.
CAS Number
EPCRA Section 313 Chemical Category
Codes
N010
N020
N040
N050
N078
N084
N090
N096
N100
N106
N120
N150
N230
N420
N450
N458
N495
N503
N511
N575
N583
N590
N725
N740
N746
N760
N770
Antimony compounds
Arsenic compounds
Barium compounds
Beryllium compounds
Cadmium compounds
Chlorophenols
Chromium compounds
Cobalt compounds
Copper compounds
Cyanide compounds
Diisocyanates
Dioxin and dioxin-like compounds
N171Ethylenebisdithiocarbamic
acid, salts and esters (EBDCs)
Certain glycol ethers
Lead compounds
Manganese compounds
Mercury compounds
Nickel compounds
Nicotine and salts
Nitrate compounds
Polybrominated biphenyls (PBBs)
Polychlorinated alkanes
Polycyclic aromatic compounds
Selenium compounds
Silver compounds
Strychnine and salts
Thallium compounds
Vanadium compounds
N874
N982
Warfarin and salts
Zinc compounds
Section 4. Maximum Amount of the
Toxic Chemical On-Site at Any Time
During the Calendar Year
Range(pounds)
Range Code
01
02
03
04
05
06
07
08
09
10
11
From
0,000,000
0,000,100
0,001,000
0,010,000
0,100,000
1,000,000
10,000,000
50,000,000
100,000,000
500,000,000
1 billion
To
0,000,099
0,000,999
0,009,999
0,099,999
0,999,999
9,999,999
49,999,999
99,999,999
499,999,999
999,999,999
more than 1 billion
Section 5. Quantity of the Non-PBT
Chemical Entering Each Environmental
Medium On-site and Section 6.
Transfers of the Toxic Chemical in
Wastes to Off-Site Locations
Total Release or Transfer
Code
A
B
C
Range (pounds)
001-10
011-499
500-999
Basis of Estimate
M1-
Estimate is based on continuous monitoring
data or measurements for the EPCRA
section 313 chemical.
M2-
Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA section 313 chemical.
C-
Estimate is based on mass balance
calculations, such as calculation of the
amount of the EPCRA section 313 chemical
in streams entering and leaving process
equipment.
Toxics Release Inventory Reporting Forms and Instructions
B-1
Appendix B
E1-
E2-
O-
Estimate is based on published emission factors,
such as those relating release quantity to
through-put or equipment type (e.g., air
emission factors).
Section 7A. On-Site Waste Treatment
Methods and Efficiency
Estimate is based on site specific emission
factors, such as those relating release quantity to
through-put or equipment type (e.g., air
emission factors).
A
Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying an estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment was
fully identified through monitoring data.
Section 6. Transfers of the Toxic Chemical
in Wastes to Off-Site Locations
Type of Waste Disposal/Treatment/Energy
Recovery/Recycling
M10
M20
M24
M26
M28
M40
M41
M50
M54
M56
M61
M62
M64
M65
M66
M67
M69
M73
M79
M81
M82
M90
M92
M93
M94
M95
M99
Storage Only
Solvents/Organics Recovery
Metals Recovery
Other Reuse or Recovery
Acid Regeneration
Solidification/Stabilization
Solidification/Stabilization-Metals and Metal
Category Compounds only
Incineration/Thermal Treatment
Incineration/Insignificant Fuel Value
Energy Recovery
Wastewater Treatment (Excluding POTW)
Wastewater Treatment (Excluding POTW) Metals and Metal Category Compounds only
Other Landfills
RCRA Subtitle C Landfills
Subtitle C Surface Impoundment
Other Surface Impoundments
Other Waste Treatment
Land Treatment
Other Land Disposal
Underground Injection to Class I Wells
Underground Injection to Class II-V Wells
Other Off-Site Management
Transfer to Waste Broker - Energy Recovery
Transfer to Waste Broker - Recycling
Transfer to Waste Broker - Disposal
Transfer to Waste Broker - Waste Treatment
Unknown
General Waste Stream
W
L
S
Gaseous (gases, vapors, airborne
particulates)
Wastewater (aqueous waste)
Liquid waste streams (non-aqueous waste)
Solid waste streams (including sludges and
slurries)
Waste Treatment Methods
Air Emissions Treatment
A01
A02
A03
A04
A05
A06
A07
Flare
Condenser
Scrubber
Absorber
Electrostatic Precipitator
Mechanical Separation
Other Air Emission Treatment
Chemical Treatment
H040
H071
H073
H075
H076
H077
Incineration--thermal destruction other than
use as a fuel
Chemical reduction with or without
precipitation
Cyanide destruction with or without
precipitation
Chemical oxidation
Wet air oxidation
Other chemical precipitation with or
without pre-treatment
Biological Treatment
H081
Biological treatment with or without
precipitation
Physical Treatment
H082
H083
H101
H103
H111
H112
H121
H122
H123
H124
H129
Adsorption
Air or steam stripping
Sludge treatment and/or dewatering
Absorption
Stabilization or chemical fixation prior to
disposal
Macro-encapsulation prior to disposal
Neutralization
Evaporation
Settling or clarification
Phase separation
Other treatment
Section 7B. On-Site Energy Recovery
Processes
U01
U02
Industrial Kiln
Industrial Furnace
Toxics Release Inventory Reporting Forms and Instructions
B-2
Appendix B
U03
Industrial Boiler
Section 7C. On-Site Recycling Processes
H10
H20
H39
Metal recovery (by retorting, smelting, or
chemical or physical extraction)
Solvent recovery (including distillation,
evaporation, fractionation or extraction)
Other recovery or reclamation for reuse
(including acid regeneration or other chemical
reaction process)
Section 8.10. Source Reduction Activity
Codes
Good Operating Practices
W13
W14
W15
W19
Improved maintenance scheduling, record
keeping, or procedures
Changed production schedule to minimize
equipment and feedstock changeovers
Introduced in-line product quality monitoring or
other process analysis system
Other changes in operating practices
Inventory Control
W21
W22
W23
W24
W25
W29
Instituted procedures to ensure that materials do
not stay in inventory beyond shelf-life
Began to test outdated material - continue to
use if still effective
Eliminated shelf-life requirements for stable
materials
Instituted better labeling procedures
Instituted clearinghouse to exchange materials
that would otherwise be discarded
Other changes in inventory control
Spill and Leak Prevention
W31
W32
W33
W35
W36
W39
Improved storage or stacking procedures
Improved procedures for loading, unloading,
and transfer operations
Installed overflow alarms or automatic shut-off
valves
Installed vapor recovery systems
Implemented inspection or monitoring program
of potential spill or leak sources
Other changes made in spill and leak prevention
Raw Material Modifications
W41
W42
W43
W49
Increased purity of raw materials
Substituted raw materials
Substituted a feedstock or reagent chemical with
a different chemical
Other raw material modifications made
Process Modifications
W50
Optimized reaction conditions or otherwise
increased efficiency of synthesis
W51
W52
W53
W54
W55
W56
W57
W58
Instituted recirculation within a process
Modified equipment, layout, or piping
Use of a different process catalyst
Instituted better controls on operating bulk
containers to minimize discarding of empty
containers
Changed from small volume containers to
bulk containers to minimize discarding of
empty containers
Reduced or eliminated use of an organic
solvent
Used biotechnology in manufacturing
process
Other process modifications
Cleaning and Degreasing
W59
W60
W61
W63
W64
W65
W66
W67
W68
W71
Modified stripping/cleaning equipment
Changed to mechanical stripping/cleaning
devices (from solvents or other materials)
Changed to aqueous cleaners (from solvents
or other materials)
Modified containment procedures for
cleaning units
Improved draining procedures
Redesigned parts racks to reduce drag out
Modified or installed rinse systems
Improved rinse equipment design
Improved rinse equipment operation
Other cleaning and degreasing
modifications
Surface Preparation and Finishing
W72
W73
W74
W75
W78
Modified spray systems or equipment
Substituted coating materials used
Improved application techniques
Changed from spray to other system
Other surface preparation and finishing
modifications
Product Modifications
W81
W82
W83
W84
W89
Changed product specifications
Modified design or composition of products
Modified packaging
Developed a new chemical product to
replace a previous chemical product
Other product modifications
Section 8.10. Methods Used to Identify
Source Reduction Activities
For each source reduction activity, enter up to three
of the following codes that correspond to the
method(s) which contributed most to the decision to
implement that activity.
T01
Internal Pollution Prevention Opportunity
Audit(s)
Toxics Release Inventory Reporting Forms and Instructions
B-3
Appendix B
T02
T03
T04
T05
T06
External Pollution Prevention Opportunity
Audit(s)
Materials Balance Audits
Participative Team Management
Employee Recommendation (independent of a
formal company program)
Employee Recommendation (under a formal
company program)
T07
T08
T09
T10
T11
State Government Technical Assistance
Program
Federal Government Technical Assistance
Program
Trade Association/Industry Technical
Assistance Program
Vendor Assistance
Other
Toxics Release Inventory Reporting Forms and Instructions
B-4
Appendix B
B.2 Reporting the Waste Management of Metals
This appendix outlines how the TRI-MEweb reporting software restricts reporting for metals when the specific data
element or waste management code is not applicable for a particular chemical. Below is a list of metals divided into
four groups along with charts that help explain where quantities of these chemicals can and cannot be reported on the
Form R using TRI-MEweb. In addition, there are charts that explain restrictions on reporting waste management codes
for the toxic chemicals in each of the four groups. This appendix only shows where reporting is restricted in TRIMEweb, it does not indicate every situation where a metal should not be reported in a specific section of the form. For
example, TRI-MEweb does not restrict the reporting of most individually-listed metal compounds as used for energy
recovery (Sections 8.2 and 8.3) even though some of these chemicals do not have a heat value greater than 5000 British
thermal units (Btu) and, thus, cannot be combusted for energy recovery. It is left to the facility to decide which of these
toxic chemicals can be used for energy recovery. If you are not using TRI-MEweb this appendix can serve as a guide to
help you understand where it is not appropriate to report certain quantities of toxic chemicals or waste management
codes on your Form R.
Parent Metals:
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Metal Compound
Categories:
Metals with Qualifiers:
Aluminum (fume or dust)
Vanadium (except when in an
alloy)
Zinc (fume or dust)
Antimony Compounds
Arsenic Compounds
Barium Compounds
Beryllium Compounds
Cadmium Compounds
Chromium Compounds
Cobalt Compounds
Copper Compounds
Lead Compounds
Manganese Compounds
Mercury Compounds
Nickel Compounds
Selenium Compounds
Silver Compounds
Thallium Compounds
Vanadium Compounds
Zinc Compounds
Individually-Listed
Metal Compounds:
Bis(tributylin) oxide
Triphenyltin hydroxide
Triphenyltin chloride
Molybdenum trioxide
Thorium dioxide
Asbestos (friable)
Aluminum oxide (fibrous
forms)
Tributyltin fluoride
Tributyltin methacrylate
Titanium tetrachloride
Boron trifluoride
Metiram
Boron trichloride
Zineb
Maneb
Fenbutatin oxide
Iron pentacarbonyl
Ferbam
C.I. Direct Brown 95
Osmium tetroxide
Aluminum phosphide
C.I. Direct Blue 218
Sections 5.3 - Discharges to Water and 6.1 - Transfers to POTWs
The following chart indicates which metals can be reported as released to water in Section 5.3 or to POTW’s in Section
6.1. Only zinc (fume or dust) and aluminum (fume or dust) are not reported in these sections because the fume or dust
form of a toxic chemical cannot exist in water.
Form R Section in
Part II
Parent Metals
Metal Category
Compounds
Metals with
Qualifiers
Individually-listed
Metal Compounds
Section 5.3 Discharges to
receiving streams or
water bodies
All
All
Vanadium (except
when contained in an
alloy)
All except Asbestos
Section 6.1Discharges to
POTWs
All
All
Vanadium (except
when contained in an
alloy)
All except Asbestos
Toxics Release Inventory Reporting Forms and Instructions
B-5
Appendix B
Section 6.2. Transfers to Other Off-Site Locations
Any toxic chemical may be reported in Section 6.2. However, TRI-MEweb will not allow certain M codes to be used
when reporting metals. The chart below indicates which M codes can be reported in Section 6.2 for the four groups of
metals. Note that all disposal M codes other than M41 and M62 can be used for all toxic chemicals. Code M24 is only
made available for the four groups of metals.
Waste Management Code for
Section 6.2
Parent
Metals
Metal Category
Compounds
Metals with
Qualifiers
Individuallylisted Metal
Compounds
M41 and M62 (disposal codes for
metals only)
All
All
Vanadium (except
when contained in an
alloy)
All except
Asbestos
M56 and M92 (energy recovery
codes)
None
None
None
All except
Asbestos1
M20 and M28 (recycling codes)
None
None
None
All
M24, M26 and M93 (recycling
codes)
All
All
All
All
M40, M50, M54, (treatment codes)
None
None
All except Vanadium
(except when
contained in an alloy)
All
M61, M69, M95 (treatment codes)
Barium2
Barium
Compounds2
Same as above
All
Section 7A. On-site Waste Treatment Methods and Efficiency
TRI-MEweb allows any toxic chemical to be reported in Section 7A, however, it limits reporting in two ways. First,
TRI-MEweb limits the treatment codes that can be reported based on the General Waste Stream Code selected. If a
TRI-MEweb user selects General Waste Stream code “A – Gaseous”, all Waste Treatment Codes are made available.
However, if a user selects from the remaining three General Waste Stream Codes (W - Wastewater, L - Liquid waste
streams, or S - Solid waste streams), the “Air Emissions Treatment” Waste Treatment Codes are not made available.
Second, the software restricts reporting for certain toxic chemicals with qualifiers. When reporting zinc (fume or dust)
or aluminum (fume or dust) TRI-MEweb will not allow the user to select General Waste Stream Codes W-Wastewater
and L-Liquid waste streams because the fume or dust form of a toxic chemical cannot exist in a liquid or water waste.
For asbestos (friable) only S - Solid or A - Gaseous can be selected. When reporting hydrochloric acid (acid aerosols)
or sulfuric acid (acid aerosols) only A - Gaseous can be selected.
Crosswalk for Section 7A, Column B. Waste Treatment Method (s) Sequence
Air Emissions Treatment (applicable to gaseous waste streams only)
(No change — same as previous codes)
A01
Flare
A02
Condenser
A03
Scrubber
A04
Absorber
A05
Electrostatic Precipitator
A06
Mechanical Separation
A07
Other Air Emission Treatment
Toxics Release Inventory Reporting Forms and Instructions
B-6
Appendix B
Biological Treatment:
Previous Codes
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
B11
Aerobic
H081
Biological treatment with or without precipitation
B21
Anaerobic
H081
Biological treatment with or without precipitation
B31
Facultative
H081
Biological treatment with or without precipitation
B99
Other Biological
Treatment
H081
Biological treatment with or without precipitation
Chemical Treatment:
Previous Codes
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
C01
Chemical Precipitation B
Lime or Sodium Hydroxide
H071
Chemical reduction with or without precipitation
C02
Chemical Precipitation B
Sulfide
H071
Chemical reduction with or without precipitation
C09
Chemical Precipitation B
Other
H077
Other chemical precipitation with or without pretreatment
C11
Neutralization
H121
Neutralization
C21
Chromium Reduction
H071
Chemical reduction with or without precipitation
C31
Complexed Metals
Treatment (other than pH
adjustment)
H129
Other treatment
C41
Cyanide Oxidation B
Alkaline Chlorination
H073
Cyanide destruction with or without precipitation
C42
Cyanide Oxidation B
Electrochemical
H073
Cyanide destruction with or without precipitation
C43
Cyanide Oxidation B Other
H073
Cyanide destruction with or without precipitation
C44
General Oxidation
(including Disinfection) B
Chlorination
H075
Chemical oxidation
C45
General Oxidation
(including Disinfection) B
Ozonation
H075
Chemical oxidation
C46
General Oxidation
(including Disinfection) B
Other
H075
Chemical oxidation
C99
Other Chemical Treatment
H129
Other treatment
Toxics Release Inventory Reporting Forms and Instructions
B-7
Appendix B
Chemical Treatment:
Previous Codes
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
Incineration/Thermal Treatment: (Note: Only report combustion for the purposes of incineration/thermal
treatment in Section 7A. If the method involves combustion for the purposes of energy recover, report as U01,
U02, or U03 in Section 7B. If the method involves combustion for the purposes of materials recovery, report as
H39 in Section 7C.)
F01
Liquid Injection
H040
Incineration B thermal destruction other than use as a
fuel
F11
Rotary Kiln with Liquid
Injection Unit
H040
Incineration B thermal destruction other than use as a
fuel
F19
Other Rotary Kiln
H040
Incineration B thermal destruction other than use as a
fuel
F31
Two Stage
H040
Incineration B thermal destruction other than use as a
fuel
F41
Fixed Hearth
H040
Incineration B thermal destruction other than use as a
fuel
F42
Multiple Hearth
H040
Incineration B thermal destruction other than use as a
fuel
F51
Fluidized Bed
H040
Incineration B thermal destruction other than use as a
fuel
F61
Infra-Red
H040
Incineration B thermal destruction other than use as a
fuel
F71
Fume/Vapor
H040
Incineration B thermal destruction other than use as a
fuel
F81
Pyrolytic destructor
H040
Incineration B thermal destruction other than use as a
fuel
F82
Wet air oxidation
H076
Wet air oxidation
F83
Thermal
Drying/Dewatering
H122
Evaporation
F99
Other Incineration/Thermal
Treatment
H040
Incineration B thermal destruction other than use as a
fuel
Physical Treatment:
Previous Codes
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
P01
Equalization
H129
Other treatment
P09
Other blending
H129
other treatment
P11
Settling/clarification
H123
Settling or clarification
P12
Filtration
H123
Settling or clarification
P13
Sludge dewatering (non-thermal)
H101
Sludge treatment and/or dewatering
P14
Air flotation
H124
Phase separation
P15
Oil skimming
H124
Phase separation
P16
Emulsion breaking B thermal
H124
Phase separation
P17
Emulsion breaking B chemical
H124
Phase separation
P18
Emulsion breaking B other
H124
Phase separation
Toxics Release Inventory Reporting Forms and Instructions
B-8
Appendix B
Physical Treatment:
Previous Codes
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
P19
Other liquid phase separation
H124
Phase separation
P21
Adsorption B Carbon
H082
Adsorption
P22
Adsorption B Ion exchange (other
than for recovery/reuse)
H082
Adsorption
P23
Adsorption B Resin
H082
Adsorption
P29
Adsorption B Other
H082
Adsorption
P31
Reverse Osmosis (other than for
recover/reuse)
H129
Other treatment
P41
Stripping B Air
H083
Air or steam stripping
P42
Stripping B Steam
H083
Air or steam stripping
P49
Stripping B Other
H083
Air or steam stripping
P51
Acid Leaching (other than for
recovery/reuse)
H129
Other treatment
P61
Solvent Extraction (other than
recovery/reuse)
H129
Other treatment
P99
Other Physical Treatment
H129
Other treatment
Solidification/Stabilization:
Previous Codes
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
G01
Cement processes
(including silicates)
H111
Stabilization or chemical fixation prior to
disposal
G09
Other Pozzolonic
Processes (including
silicates)
H111
Stabilization or chemical fixation prior to
disposal
G11
Asphaltic Techniques
H111
Stabilization or chemical fixation prior to
disposal
G20
Thermoplastic
Techniques
H111
Stabilization or chemical fixation prior to
disposal
G99
Other Solidification
Processes
H111
Stabilization or chemical fixation prior to
disposal
Section 7B. On-site Energy Recovery Processes
The chart below indicates which energy recovery codes can be reported in TRI-MEweb in Section 7B for the four
groups of metals.
Energy Recovery Code for Section
7B
U01, U02, U03
Parent
Metals
None
Metal
Category
Compounds
None
Metals with
Qualifiers
None
Toxics Release Inventory Reporting Forms and Instructions
Individuallylisted Metal
Compounds
All except
Asbestos1
B-9
Appendix B
Section 7C. On-site Recycling Processes
Any chemical can be reported in Section 7C. However, certain waste management codes should not be reported for
certain toxic chemicals. The chart below indicates which codes can be reported in Section 7C when using TRI-MEweb.
Parent
Metals
Recycling Code for Section 7C
Metal Category
Compounds
Metals with
Qualifiers
Individuallylisted Metal
Compounds
H10 (this code is for metals only)
All
All
All
All
H20
None
None
None
All
H39
All
All
All
All
Crosswalk for Section 7C. On-site Recycling Processes
Previous Codes
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
R11
Solvents/Organics Recovery
B Batch Still Distillation
H20
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
R12
Solvents/Organics Recovery
B Thin-Film Evaporation
H20
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
R13
Solvents/Organics Recovery
B Fractionation
H20
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
R14
Solvents/Organics Recovery
B Solvent Extraction
H20
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
R19
Solvents/Organics Recovery
B Other
H20
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
R21
Metals Recovery B
Electrolytic
H10
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
R22
Metals Recovery B Ion
Exchange
H10
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
R23
Metals Recovery B Acid
Leaching
H10
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
R24
Metals Recovery B Reverse
Osmosis
H10
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
R26
Metals Recovery B Solvent
Extraction
H10
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
R27
Metals Recovery B High
Temperature
H10
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Toxics Release Inventory Reporting Forms and Instructions
B-10
Appendix B
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
Previous Codes
R28
Metals Recovery B Retorting
H10
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
R29
Metals Recovery B Secondary H10
Smelting
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
R30
Metals Recovery B Other
H10
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
R40
Acid Regeneration
H39
Other recovery or reclamation for reuse (including acid
regeneration or other chemical reaction process)
R99
Other Reuse or Recovery
H39
Other recovery or reclamation for reuse (including acid
regeneration or other chemical reaction process)
Section 8. Source Reduction and Recycling Activities
The chart below indicates which metals can be reported in Sections 8.2, 8.3, 8.6 and 8.7 of the Form R when using
TRI-MEweb. Note that all toxic chemicals can be reported in Sections 8.1, 8.4, 8.5 and 8.8.
Waste Management Activity
Parent
Metals
Metal Category
Compounds
Metals with
Qualifiers
Individuallylisted Metal
Compounds
Quantity used for energy recovery
on site and off site (Sections 8.2
and 8.3)
None
None
None
All except
Asbestos2
Quantity treated for destruction on
site and off site (Sections 8.6 and
8.7)
None
except
Barium2
None except
Barium
Compounds2
All except
Vanadium
(except when
contained in an
alloy)
All
1
1
Although TRI-MEweb does not restrict reporting of most individually-listed metal compounds as transferred off site for
energy recovery, only chemicals with a heat value greater than 5000 British thermal units that are combusted in a device
that is an industrial furnace or boiler (40 CFR Section 372.3) should be reported as used for energy recovery.
2
The toxic chemical category barium compounds (N040) does not include barium sulfate. Because barium sulfate is not a
listed toxic chemical, the conversion in a waste stream of barium or barium compound to barium sulfate is considered
treatment for destruction (40 CFR Section 372.3).
Toxics Release Inventory Reporting Forms and Instructions
B-11
Appendix C. Electronic Facility Data Profiles and
Common Errors in Completing Form R Reports and
Form A Certification Statements
It is important that facilities submit required TRI chemical
submissions in a timely manner for inclusion in the TRI
national database, annual public data release (TRI National
Analysis), and other information products. All submitted
data should be complete and accurate. This appendix
provides an overview of the Electronic Facility Data Profile
(eFDP), an important document that EPA uses as a receipt
to our reporting facilities to ensure consistent, complete, and
accurate submissions. This appendix also provides specific
guidance to avoid common errors in completing Form Rs
and Form A Certification Statements, including errors in
threshold determination, misapplication of exemptions, and
activities involving a reportable chemical, any of which may
result in the erroneous non-reporting of a chemical.
Facilities must use the TRI-MEweb online reporting
application to submit non-trade secret TRI reports. TRIMEweb assists facilities to report TRI data by importing
prior year TRI form data into current year forms to expedite
reporting, validating reports to ensure higher data quality,
and providing instant receipt confirmation of submissions.
You must use TRI-MEweb to submit revisions to non-trade
secret TRI submissions. EPA will only accept revisions for
Reporting Year 1991 through the current year. If you have
questions about using TRI-MEweb to revise your Form
R/A, please refer to the TRI-MEweb tutorial page at:
http://www.epa.gov/tri/reporting_materials/tutorials/tutorial
_index.html.
Electronic Facility Data Profile (eFDP)
The eFDP report is made available via TRI-MEweb to
reporting facilities in response to any submission processed
into the EPA database. If the technical contact, preparer or
certifying official provided an email address in the Form
R/Form A, they will receive a real-time email notifying
them when their eFDP has been updated. The email will
contain information explaining how to create a CDX user
account and how to add the TRI-MEweb application.
Reporting facility officials may confirm and review their
submitted TRI data to EPA by viewing their electronic
Facility Data Profile (eFDP) on the Internet by logging into
their CDX account and clicking the TRI-MEweb: TRI Made
Easy Web link from their MyCDX page. This will open the
“Welcome” page of the TRI-MEweb application. On the
“Welcome” page, they can follow the instructions for
viewing the eFDP. It is very important to review your eFDP
report carefully. Your reporting facility may have
incorrectly entered an incorrect waste quantity in your TRIMEweb submission, or incorrectly listed the chemical
category. Reviewing the eFDP allows reporting facilities to
conduct final checks of the data submitted to EPA before it
is released to the public. If you have questions regarding
your eFDP, please send an email to [email protected]
or call 1 (888) 890-1955.
An eFDP report is comprised of the following sections:
Facility Information. This section displays all facilityspecific data, including TRI Facility Identification
(TRIFID), facility name, facility address, facility
mailing address, North American Industry
Classification System code (NAICS), and other
facility data. Errors related to facility information
will be marked in this section.
Instructions Page. This page provides instructions on
how to review and respond to the eFDP.
Chemical Report Summary. This section lists all
chemicals reported by the facility for each
reporting year covered by the eFDP. For example,
if the eFDP is responding to five original chemical
submissions for Reporting Year 2013 and revisions
to one chemical for Reporting Year 2011, a list of
all chemicals reported for both years will appear.
Errors/Alerts Identified In This Report: NonTechnical Data Changes (NDC), Notices of
Technical Errors (NOTE), Notices of Significant
Error (NOSE), and Data Quality Alerts (DQA).
eFDPs identify three different types of errors:
NDCs, NOTEs and NOSEs and one type of alert
called Data Quality Alert (DQA). See explanations
in Section B.
Error Summary Page. The Error Summary Page
provides facilities an error/alert count for each
chemical submission.
Chemical Reports.
All recently submitted and
processed Form R or Form A data (i.e., chemical
specific data) are displayed in the chemical reports
under the appropriate facility or subordinate
facility names. The eFDP report displays facsimiles
for chemical reports for submissions received
during the current calendar year and revisions or
responses to eFDPs only. For example, if a facility
originally reported five chemicals for Reporting
Year 2012, and subsequently revises only one
chemical submission, the facility will receive an
eFDP for Reporting Year 2012 with only the
revised chemical included in the Chemical Reports
section. As a result, there may be fewer chemical
reports than chemicals listed in the Chemical
Summary section. If only facility level changes
have occurred (i.e., Part I of the Form R or A), this
section is not provided.
Toxics Release Inventory Reporting Forms and Instructions
C-1
Appendix C
Data Quality Alerts. TRI provides Data Quality
Alerts (DQAs) in eFDP reports. The DQA informs
facilities of possible reporting errors by flagging
data trends that are outside the norm. For example,
if a facility reports a change in the release of a
chemical that is over 25% compared to the
previous year, a DQA will be triggered. This will
assist facilities in reporting accurate information.
C.1 Levels of Errors Identified
in eFDPs: Notice of NonTechnical Data Change (NDC),
Notice of Technical Errors
(NOTE), Notice of Significant
Errors (NOSE), Notice of
Noncompliance (NON)
eFDP Error Reporting. In addition to echoing back the
information a facility has submitted, eFDPs are used to
identify potential errors and provide Data Quality Alerts.
Errors are still possible on forms submitted through TRIMEweb and this appendix will indicate whether specific
errors can occur on paper forms or TRI-MEweb
submissions or both.
As submission information is entered into EPA’s national
database, a series of automated data quality checks are
performed. Some error messages will indicate where the
TRI Data Processing Center has made minor clerical
changes to submissions. The data quality checks are useful
to identify potential errors with certain data fields such as
TRI Facility Identification, facility name, county spelling, as
well as to perform validation checks to ensure consistency
among data elements within a given Form R or Form A.
These data quality checks, however, cannot detect whether
release, transfer, or waste management quantities were
calculated or entered accurately.
Within an eFDP report, there may be up to three different
types of errors identified.
Non-Technical Data Change (NDC)
Applies to: Paper forms only (trade secret submissions)
A Non-Technical Data Change (NDC) notifies you of
simple, clerical errors that the TRI Data Processing Center
has corrected for you. It is not necessary to respond to a
NDC. The TRI Data Processing Center will correct simple,
clerical errors that are not technical or scientific - a “nontechnical data change.” For example, if a facility
transposes CAS numbers (e.g., the submitter lists 7623-00-0
for sodium nitrite instead of 7632-00-0), the TRI Data
Processing Center will correct this clerical error and display
the correct information on the facility’s eFDP. If a facility
lists a specific glycol ethers subcategory, the TRI Data
Processing Center will replace this subcategory with the
reportable name “certain glycol ethers.” The messages used
on eFDPs to report non-technical data changes are shown at
the end of this appendix under the heading “C.5 Messages
Used to Report Notices of Technical Errors (NOTEs) and
Non-technical Data Changes (NDCs).” This type of error is
flagged for correction during data entry when using TRIMEweb and needs to be addressed by the facility before the
submission is submitted and processed by EPA. Therefore,
NDCs are not possible in a TRI-MEweb submission.
Notice of Technical Error (NOTE)
Applies to: Paper forms (trade secret submissions) and
TRI-MEweb submissions for RYs 1991 – 2004
A Notice of Technical Error (NOTE) highlights
inconsistencies or miscalculations that may distort your
facility’s information in EPA’s public data products or skew
analyses. Incomplete addresses, no technical or public
contact provided, missing or invalid NAICS codes, or the
use of range codes to report PBT chemical releases are all
examples of technical errors.
If you agree that an error exists then you should submit a
revised Form R or Form A. Depending upon when your
changes are received, there may or may not be sufficient
time to incorporate them into EPA’s database before your
report has been released to the public. Technical errors do
not prevent submissions from being entered into the data
management system, but indicate inconsistencies or
miscalculations in the submitted form. These errors can
distort public information products and skew any analyses if
not corrected. The messages used on eFDPs to report
NOTEs are shown below at the end of this appendix under
the heading “C.5 Messages Used to Report Notices of
Technical Errors (NOTEs) and Non-technical Data Changes
(NDCs).”
Notices of Significant Errors (NOSE)
Applies to: Paper forms (trade secret submissions) and
TRI-MEweb submissions
The most serious errors are classified as Notices of
Significant Errors (NOSE). The eFDP contains the Notice
of Significant Error if applicable. Significant errors prevent
submissions from being entered into the TRI Data
Processing Center data management system or do not allow
the TRI Data Processing Center to verify the authenticity of
the submission. Invalid forms, missing pages, no chemical
name or CAS number are examples of significant errors.
These types of errors can be corrected by the reporting
facility submitting a revised Form R or Form A, or the
reporting facility can provide the TRI Data Processing
Center with a brief explanation why they do not believe that
it is an error. A facility must respond to a Notice of
Significant Error within 21 days of receipt. Failure to
respond within the initial 21-day requirement may result in
the issuance of a Notice of Noncompliance (NON). A
Toxics Release Inventory Reporting Forms and Instructions
C-2
Appendix C
Notice of Noncompliance is not included in an eFDP and is
mailed separately.
Notice of Noncompliance (NON)
Applies to: Paper forms (trade secret submissions) and
TRI-MEweb submissions
The Agency will issue a Notice of Noncompliance (NON)
to a facility for failure to respond to a Notice of Significant
Error (NOSE) within the required period. A NON suggests
that a facility should take corrective action within 30 days
and respond to the Agency that corrective action has been
taken. If a facility fails to respond to the NON within the
required time period, the Agency may take further action.
Record Keeping
Facilities must keep copies, for three years, of submitted
Form R reports and Form A certification statements and all
documentation used to complete their submissions in
accordance with 40 CFR 372.10. This documentation
should include threshold determination calculations, the
basis of exemptions applied, and the estimation techniques
and data used for all quantities reported on the Form R and
Form A. Using TRI-MEweb, facilities may access
submitted chemical release data back to RY 1991. Facilities
may print this data for their records.
C.2 Common Errors in
Completing Form R Reports
and Form A Certification
Statements
The following section lists the most common errors that
reporting facilities have encountered when submitting TRI
reports to EPA. TRI-MEweb will not allow many of these
errors to be reported, except in instances where facilities are
revising forms from Reporting Years prior to RY2005.
Some of these errors are not detected nor listed on an eFDP
report. Errors that are not detectable are hard to evaluate by
EPA because they could be valid submissions and can only
be determined to be incorrect by the reporting facility.
Reporting facilities should review their reports for common
errors before submitting them to EPA.
Threshold Determinations
Calculating threshold determinations. Annual
quantities manufactured, processed, or otherwise
used for section 313 chemicals must be calculated,
not surmised. The assumption that thresholds are
exceeded commonly leads to error. This error type
is not detected nor listed on an eFDP report.
Misclassification of EPCRA section 313 chemical
activity. Failure to correctly classify an EPCRA
section 313 chemical activity may result in an
incorrect threshold determination. As a result, a
facility may fail to submit the required Form R.
This error type is not detected nor listed on an
eFDP report.
EPCRA section 313 chemical activity overlooked.
Many facilities believe that because the section 313
reporting requirement pertains to manufacturers,
only the use of EPCRA section 313 chemicals in
manufacturing processes must be examined. Any
activity involving the manufacture, process, or
otherwise use of an EPCRA section 313 chemical
or chemical category must be included in threshold
determinations. Commonly overlooked activities
include importation of chemicals, generation of
waste byproducts, processing of naturally
occurring metals and metal category compounds in
ore, manufacturing and processing intermediates,
the use of chemicals for cleaning of equipment, and
the generation of byproducts during combustion of
coal and/or oil. Facilities should take a systematic
approach to identify all chemicals and mixtures
used in production and non-production capacities,
including catalysts, well treatment chemicals, and
wastewater treatment chemicals. This error type is
not detected nor listed on an eFDP report.
Considering EPCRA section 313 chemicals in
mixtures and other trade name products.
EPCRA section 313 chemicals contained in
mixtures (including ores and stainless steel alloys)
and other trade name products must be factored
into threshold determinations and release and other
waste management determinations, provided that
the de minimis exemption cannot be taken. When
the EPCRA section 313 chemical being reported is
a component in a mixture or other trade name
product, report only the weight of the EPCRA
section 313 chemical in the mixture. Refer to
Section B.4f of this document to calculate the
weight of an EPCRA section 313 chemical in a
mixture or other trade name product. This error
type is not detected nor listed on an eFDP report.
Overlooking
manufacturing.
Coincidental
manufacturing must not be overlooked. If coal
and/or fuel oil and other raw materials that contain
EPCRA section 313 chemicals are used in
boilers/burners, there is a potential for the
coincidental manufacture of EPCRA section 313
chemicals such as sulfuric acid (acid aerosols),
hydrochloric acid (acid aerosols), hydrogen
fluoride, and metal category compounds.
Additionally, manufacturing of EPCRA section
313 chemicals during waste treatment is commonly
overlooked. For example, the treatment of nitric
acid may result in the manufacturing of a
reportable chemical (nitrate compounds). This
error type is not detected nor listed on an eFDP
report.
Toxics Release Inventory Reporting Forms and Instructions
C-3
Appendix C
Container Residue
Overlooking container residue. Container residue
must not be disregarded in release and other waste
management calculations. This error type is not
detected nor listed on an eFDP report. Even a
“RCRA empty” drum is expected to contain a
residue and it must be considered for TRI
reporting. Additionally, on-site drum rinsing and
disposal of the rinsate will result in a release and
other waste management activity. Refer to Part II,
Section 6.2 for more information regarding
container residue.
Part I. Facility Identification Information
Section 1. Reporting Year
Invalid TRI-MEweb Forms: Users must pick the
reporting year before starting to enter any chemical
release data. Users may start a blank form or choose to
import prior year data into current year forms from the
Form Summary Table on the TRI-MEweb Welcome
page after clicking on the (+) sign next to TRIFID of
the reporting facility. If the preparer transmitted,
certified and submitted a form with an incorrect
reporting year selected, a revision of this form cannot
change the reporting year field. Instead, the incorrect
reporting year form must be withdrawn and resubmitted
under the correct reporting year. This error type is not
detected nor listed on an eFDP report.
Section 2. Trade Secret Information
Applies to: Paper forms only
Incorrect completion of trade secret information.
The responses to trade secret questions in Part I
Section 2 and Part II Section 1.3 of Form R/Form
A must be consistent. If trade secrecy is indicated,
a sanitized Form R/Form A and two trade secret
substantiations (one sanitized) must be submitted
in the same package as the unsanitized trade secret
Form R/Form A. Part II Section 1.3 should be
blank if no trade secret claim is being made. Also,
if you indicate in Part I, Section 2.1 that you are
not claiming trade secret information, leave Part I,
2.2 blank. This error type is listed on an eFDP as a
NOSE.
Section 3. Certification
Applies to: TRI-MEweb submissions only
Uncertified TRI-MEweb submissions. If you are
submitting your Form R and/or Form A via TRIMEweb and CDX, you must electronically sign the
submission before it can be loaded into the TRI
database. Uncertified electronic submissions will
not be accepted and facilities will be considered
not to have filed their TRI report until it is
certified.
Section 4. Facility Identification
Questionable entries. Incorrect entries may be
corrected by the reporting facility though a
revision. The use of the TRI-MEweb software may
prevent such errors from occurring. Questionable
entries may include:
– Incorrect street address;
–
Incorrect ZIP codes;
–
Invalid County names;
–
Invalid NAICS codes;
–
Invalid Dun & Bradstreet numbers;
Note: These error types are not detected nor
listed on an eFDP report.
Part II. Chemical-Specific Information
Section 1. Toxic Chemical Identity
Applies to: Paper forms (trade secret submissions) only
Reporting chemical abstract service (CAS) registry
numbers in Section 1.1. In 1992, EPA assigned
alphanumeric category codes to the twenty
chemical categories for the purposes of reporting
the CAS number field in Section 1.1. Incorrect use
of chemical category codes have caused errors on
TRI forms requiring forms to be withdrawn and resubmitted. When completing a Form R for a
chemical category, the appropriate code for that
category must be provided in Section 1.1. The CAS
numbers are listed in Table II: “Section 313 Toxic
Chemical List,” and if needed, the category codes
are listed in Appendix B: “Reporting Codes for
EPA Form R.” Category guidance documents are
listed in the Chemical and Industry Guidance
Documents section in this document. This error
type is not detected nor listed on an eFDP report.
Invalid chemical identification in Section 1.2. The
CAS number and the chemical name reported here
must exactly match the listed official EPCRA
section 313 CAS number and EPCRA section 313
chemical name. This error type is listed on an
eFDP as a NOTE.
Applies to TRI-MEweb submissions only.
Failure to check for synonyms. Some reportable
chemicals (especially glycol ethers and toluene
diisocyanates) have many synonyms that do not
readily imply they are in the category. For
example, benzene,1,3-diisocyanatomethyl may not
be readily recognized as toluene diisocyanate
(mixed isomers). This error type is not detected nor
listed on an eFDP report.
Toxics Release Inventory Reporting Forms and Instructions
C-4
Appendix C
Generic chemical name used in Section 1.3. A
generic chemical name should only be provided if
the section 313 chemical identity is claimed as a
trade secret. Generic names should not be used if
no trade secret submissions are being claimed by a
reporting facility. This error type is listed on an
eFDP as a NOSE.
Failure to consider an EPCRA section 313 chemical
qualifier. Only EPCRA section 313 chemicals in
the form specified in the qualifier require reporting
under section 313 and should be reported on Form
R with the appropriate qualifier in parentheses. For
example, isopropyl alcohol is listed on the EPCRA
section 313 chemical list with the qualifier
manufacturing- strong acid process, no supplier
notification. Thus, the ONLY facilities that should
report this EPCRA section 313 chemical are those
that manufacture isopropyl alcohol by the strong
acid process. This error type is not detected nor
listed on an eFDP report.
Section 2. Mixture Component Identity
Applies to: TRI-MEweb submissions only
Identifying chemicals used in mixtures. Facilities
should carefully review the most recent MSDS or
supplier notification for every mixture brought onsite to identify all section 313 chemicals used
during a reporting year. Although some mixtures
may not have MSDSs, the best readily available
information should be used to determine the
presence of EPCRA section 313 chemicals in ores
and alloys. This error type is not detected nor listed
on an eFDP report.
Mixture names in Section 2.1. Mixture names are to
be entered here only if the supplier is claiming the
identity of the EPCRA Section 313 chemical a
trade secret and that is the sole identification.
Mixture names that include the name or CAS
number of one or more EPCRA Section 313
chemicals are not valid uses of the mixture name
field. This error type is not detected nor listed on
an eFDP report.
Section 3. Activities and Uses of the Toxic
Chemical at the Facility
Applies to: Paper forms (trade secret submissions) and
TRI-MEweb submissions
Reporting EPCRA section 313 chemical activity.
EPCRA section 313 chemical activity is commonly
overlooked or misclassified. Any activity involving
the manufacture, process, or otherwise use of an
EPCRA Section 313 chemical must be examined.
For example, waste treatment operations otherwise
use EPCRA Section 313 chemicals to treat waste
streams and may coincidentally manufacture an
additional EPCRA Section 313 chemical as a result
of the treatment reaction. Such activity must be
considered. Further, EPCRA Section 313 chemical
activity must be correctly classified as either
“manufactured,” “processed,” or “otherwise used.”
Section 3.1 Manufacture means to produce, prepare,
compound, or import an EPCRA Section 313
chemical.
Section 3.2 Process means the preparation of an
EPCRA Section 313 chemical after its
manufacture, which usually includes the
incorporation of the EPCRA Section 313 chemical
into the final product, for distribution in commerce.
Section 3.3 Otherwise use encompasses any use of an
EPCRA Section 313 chemical that does not fall
under the terms “manufacture” or “process,” and
includes treatment for destruction, stabilization
(without subsequent distribution in commerce),
disposal, and other use of an EPCRA Section 313
chemical, including an EPCRA Section 313
chemical contained in a mixture or other trade
name product. Otherwise use of an EPCRA
Section 313 chemical does not include disposal,
stabilization (without subsequent distribution in
commerce), or treatment for destruction unless:
1. The EPCRA Section 313 chemical that was
disposed of, stabilized, or treated for
destruction was received from off-site for the
purposes of further waste management; or
2.
For
The EPCRA Section 313 chemical that was
disposed of, stabilized, or treated for
destruction was manufactured as a result of
waste management activities on materials
received from off-site for the purposes of
further waste management activities.
example, solvents in paint applied to a
manufactured product are often misclassified as
processed, instead of otherwise used. Because the
solvents are not incorporated into the final product,
the solvent is being otherwise used, not processed.
This error type is not detected nor listed on an
eFDP report.
Section 4. Maximum Amount of the Toxic
Chemical On-site at Any Time During the
Calendar Year
Applies to: Paper forms only (trade secret submissions)
Maximum amount on-site left blank. Form has failed
to provide the appropriate code for maximum
amount on site. This error type is listed on an eFDP
as a NOSE.
Incorrect units of measure. If amounts are reported in
Toxics Release Inventory Reporting Forms and Instructions
C-5
Appendix C
units other than pounds (e.g., metric units) or with
exponential numbers, EPA may require a revision
of the Form R/Form A submitted. The exception is
for the reporting of dioxin and dioxin-like
compounds where the amounts are reported in
grams. This error type is not detected nor listed on
an eFDP report.
Section 5. Quantity of the Toxic Chemical
Entering Each Environmental Medium On-site
Applies to: Paper forms (trade secret submissions) and
TRI-MEweb submissions
Incorrectly reporting stack emissions. Fugitive
emissions from general indoor air should not be
reported as stack missions when released from a
single building vent. Additionally, stack emissions
from storage tanks, including loading, working,
and breathing losses from tanks, should not be
overlooked or reported as fugitive emissions. This
error type is not detected nor listed on an eFDP
report.
Overlooking releases to land. Section 313 chemicals
placed in stockpiles or in surface impoundments
should be reported as a “release to land” even if no
Section 313 chemicals leak from these sources.
Quantities of Section 313 chemicals land-treated
should be reported as a release to land. This error
type is not detected nor listed on an eFDP report.
Section 6. Transfers of the Toxic Chemical in
Wastes to Off-site Locations
Applies to: Paper forms (trade secret submissions) and
TRI-MEweb submissions
Reporting discharges to POTWs in Section 6.1.
When quantities of a listed mineral acid are
neutralized to a pH of 6 or greater, the quantity
reported as discharged to a POTW should be
reported as zero. It is incorrect to enter “NA” (Not
Applicable), in such a situation. This error type is
not detected nor listed on an eFDP report.
Section 7A. On-Site Waste Treatment
Methods and Efficiency
Applies to: Paper forms (trade secret submissions) and
TRI-MEweb submissions
Failure to report waste treatment methods in
Section 7A. Waste treatment methods used to treat
waste streams containing EPCRA Section 313
chemicals, and the efficiencies of these methods,
must be reported on Form R. Information must be
entered for all waste streams, even if the waste
treatment method does not affect the EPCRA
Section 313 chemical. If no waste treatment is
performed on waste streams containing the EPCRA
Section 313 chemical, the box marked Not
Applicable in Section 7A should be checked on
Form R. This error type is not detected nor listed
on an eFDP report.
Incorrect reporting of waste treatment methods in
Section 7A. The type of waste stream, waste
treatment efficiency, and waste treatment method
for each waste stream are required to be reported
on Form R using specific codes. The waste
treatment codes are listed in Appendix B:
Reporting Codes for EPA Form R. A table is also
provided in Appendix B that displays a crosswalk
between the old codes and new ones for reporting
year 2005. This error type is not detected nor listed
on an eFDP report.
Section 7B. On-Site Energy Recovery
Processes
Applies to: Paper forms (trade secret submissions) and
TRI-MEweb submissions
Reporting on-site energy recovery methods in
Section 7B. When a quantity is reported in Section
8.2 as combusted for energy recovery on-site, the
type of energy recovery system used must be
reported in Section 7B, and vice versa. This error
type is not detected nor listed on an eFDP report.
Section 7C. On-Site Recycling Processes
Reporting other off-site transfers in Section 6.2.
Any quantities reported in Sections 8.1, 8.3, 8.5,
and 8.7 as sent off-site for disposal, treatment,
energy recovery, or recycling, respectively, must
also be reported in Section 6.2 along with the
receiving location and appropriate off-site activity
code. This error type is not detected nor listed on
an eFDP report.
Applies to: Paper forms (trade secret submissions) and
TRI-MEweb submissions
Reporting on-site recycling methods in Section 7C.
When a quantity is reported in Section 8.4 as
recycled on-site, the type of recovery method must
be reported in Section 7C, and vice versa. This
error type is not detected nor listed on an eFDP
report.
Toxics Release Inventory Reporting Forms and Instructions
C-6
Appendix C
Section 8. Source Reduction and Recycling
Activities
The TRI-MEweb software offers a Section 8 Calculator.
The Section 8 Calculator will assist users in calculating their
Section 8 source reduction and recycling activity quantities.
Please note that if you use range codes to report data in
sections 5 and 6, TRI-MEweb will default to the mid-point
of the range when performing section 8 calculations.
The entries in this section must be completed, even if your
facility does not engage in source reduction or recycling
activities.
Applies to: Paper forms and TRI-MEweb submissions
Columns C and D, the future year projections
for questions 8.1 through 8.7, must be
completed. EPA expects a reasonable estimate
for the future year projections. Zero can be
used in columns C and D to indicate that the
manufacture, process, or otherwise use of the
chemical will be discontinued. In such cases,
columns C and D for Section 8.1 through 8.7
must all contain zeroes.
Paper forms: Listed on an eFDP as a NOSE.
TRI-MEweb: TRI-MEweb submissions will not be
allowed to be submitted to EPA with this error
type.
Applies to: Paper forms only (trade secret submissions)
It is incorrect to use range codes to report
quantities in Section 8. Range codes can be
used only in Sections 5 and 6 of Form R.
It is incorrect to use the same codes from
Section 4 for reporting the maximum amount
of the reported EPCRA Section 313 chemical
on-site to report quantities in Section 8.
Quantities reported in Section 8.1 through 8.7
are mutually exclusive and additive. This
means that quantities of the reported EPCRA
Section 313 chemical must not be
double-counted in Section 8.1 through 8.7.
Some double-counting errors have been due to
confusion over the differences in how on-site
treatment of an EPCRA Section 313 chemical
is reported in Section 7A as compared to
Section 8. In Section 7A, information on the
treatment of waste streams containing the
EPCRA Section 313 chemical is reported,
along with the percent efficiency in terms of
destruction or removal of the EPCRA Section
313 chemical from each waste stream. In
Section 8, only the quantity of the EPCRA
Section 313 chemical actually destroyed
through the treatment processes reported in
Section 7A is reported in Section 8.6 to avoid
double-counting within Sections 8.1 through
8.7.
Quantities reported in Section 8.1 through 8.7
must not be reported in Section 8.8 and vice
versa.
Any time a reported EPCRA Section 313
chemical is contained in a waste, and the waste
is associated with routine production-related
activities and is recycled, combusted for
energy recovery, treated, disposed of, or
otherwise released either on- or off-site, that
quantity of the EPCRA Section 313 chemical
must be included in the quantities reported in
Sections 8.1 through 8.7
All calculation errors will be listed on an eFDP as a
NOSE.
Reporting quantities in Section 8.1 Quantities of
EPCRA Section 313 chemicals that are released
(including disposed of) on-site and reported in
Section 5 of Form R must be reported in either
Section 8.1a or 8.1b.
§8.1a = § 5.4.1 + § 5.5.1A + § 5.5.1B - § 8.8
(on-site disposal to landfills or UIC Class I Wells)1
§ 8.1b = § 5.1 + § 5.2 + § 5.3 + § 5.4.2 + § 5.5.2 +
§ 5.5.3A + § 5.5.3B + §5.5.4 - § 8.8 (on-site
disposal or other releases, other than disposal to
landfills or UIC Class I Wells)1
Quantities of EPCRA Section 313 chemicals
transferred off-site for the purposes of disposal
reported in Section 6.2 using the following codes
must appear in Section 8.1c:
–
M64 Other Landfills
–
M65 RCRA Subtitle C Landfills
–
M81 Underground Injection to Class I Wells
§ 8.1c = § 6.1 (portion of transfer that is untreated
and ultimately disposed of in landfills or UIC Class
I Wells) + § 6.2 (quantities associated with M
codes M64, M65, and M81) - § 8.8 (off-site
disposal to landfills or UIC Class I Wells) 1
Metals and metal category compounds transferred
off-site to POTWs in Section 6.1 must appear in
Section 8.1c or 8.1d. To report correctly in
Sections 8.1a through d, a facility must include
quantities that are disposed of or otherwise released
to the environment either on-site or off-site,
excluding disposal or other releases due to
catastrophic events or non-production related
activities.
Quantities of EPCRA Section 313 chemicals
transferred off-site for the purposes of disposal
reported in Section 6.2 using the following codes
must appear in Section 8.1d:
–
M10 Storage Only
–
M41 Solidification/Stabilization - Metals and
Metal Category Compounds Only
Toxics Release Inventory Reporting Forms and Instructions
C-7
Appendix C
–
M62 Wastewater Treatment (excluding
POTW) - Metals and Metal Category
Compounds Only
–
M66 Subtitle C Surface Impoundment
–
M67 Other Surface Impoundments
–
M73 Land Treatment
–
M79 Other Land Disposal
–
M82 Underground Injection to Class II-V
Wells
–
M90 Other Off-Site Management
–
M94 Transfer to Waste Broker - Disposal
–
M99 Unknown.
as other one-time events not associated with
routine production practices that were combusted
for energy recovery on-site must not be included in
Section 8.8.
All calculation errors will be listed on an eFDP as a
NOSE.
Reporting quantities in Section 8.3 “Quantity used
for energy recovery off-site.” As in Section 8.2, a
quantity must not be reported in this section if the
off-site combustion of the EPCRA Section 313
chemical took place in a system that did not
recover energy (e.g., incinerator). A quantity of an
EPCRA Section 313 chemical must not be reported
as sent off-site for the purposes of energy recovery
if the EPCRA Section 313 chemical does not have
a significant heating value. Examples of EPCRA
Section 313 chemicals that do not have significant
heating values include metals and metal portions
of metal category compounds. Metals and metal
portions of metal category compounds will never
be combusted for energy recovery. Quantities must
be reported in Section 8.3 that are reported in
Section 6.2 as transferred off-site for the purposes
of combustion for energy recovery using the
following codes:
– M56 Energy Recovery
– M92 Transfer to Waste Broker - Energy
Recovery
§ 8.1d = § 6.1 (portion of transfer that is untreated
and ultimately disposed of or otherwise released,
other than disposal to landfills or UIC Class I
Wells) + § 6.2 (quantities associated with M codes
M10, M41, M62, M66, M67, M73, M79, M82,
M90, M94, and M99) - § 8.8 (off-site disposal or
other releases due to catastrophic events, other than
1
disposal to landfills or UIC Class I Wells)
All calculation errors will be listed on an eFDP as a
NOSE.
Reporting quantities in Section 8.2 “Quantity used
for energy recovery on-site.” A quantity must be
reported in Section 8.2 for the current (reporting)
year when a method of on-site energy recovery is
reported in Section 7B, and vice versa. An error
facilities make when completing Form R is to
report the methods of energy recovery used on-site
in Section 7B but not report the total quantity
associated with those methods. Another error is to
report a quantity in this section if the combustion
of the EPCRA Section 313 chemical took place in
a system that did not recover energy (e.g., an
incinerator). A quantity of the EPCRA Section 313
chemical combusted for energy recovery must not
be reported if the EPCRA Section 313 chemical
does not have a significant heating value.
Examples of EPCRA Section 313 chemicals that
do not have significant heating values include
metals, metal portions of metal category
compounds, and halons. Metals and metal portions
of metal compounds will never be treated or
combusted for energy recovery. Any quantities of
the EPCRA Section 313 chemical associated with
non-production related activities such as
catastrophic releases and remedial actions, as well
1
§8.8 includes quantities of toxic chemicals disposed of or otherwise
released on site or managed as a waste off site due to remedial actions,
catastrophic events, or one-time events not associated with the production
processes.
§ 8.3 = § 6.2 (energy recovery) - § 8.8 (off-site
energy recovery)2
All calculation errors will be listed on an eFDP as a
NOSE.
Reporting quantities in Section 8.4 “Quantity
recycled on-site.” A quantity must be reported in
Section 8.4 for the current reporting year when a
method of on-site recycling is reported in Section
7C, and vice versa. An error a facility may make
when completing Form R is to report the methods
of recycling used on-site in Section 7C but not
report the total quantity recovered using those
methods.
In addition, only the amount of the chemical that
was actually recovered is to be reported in Section
8.4. Any quantities of the EPCRA Section 313
chemical associated with non-production related
activities such as catastrophic releases and
remedial actions, as well as other one-time events
not associated with routine production practices
2
§8.8 includes quantities of toxic chemical disposed of or otherwise
released on-site or managed as waste off-site due to remedial actions,
catastrophic events, or one-time events not associated with the production
processes.
Toxics Release Inventory Reporting Forms and Instructions
C-8
Appendix C
that were recycled on-site must not be included in
Section 8.8.
not as treated in Section 8.6. Any quantities of the
EPCRA Section 313 chemical associated with
non-production related activities such as
catastrophic releases and remedial actions, as well
as other one-time events not associated with
routine production practices that were treated for
destruction on-site must not be included in Section
8.8. Metals generally will not be treated for
destruction.
All calculation errors will be listed on an eFDP as a
NOSE.
All calculation errors will be listed on an eFDP as a
NOSE.
Reporting quantities in Section 8.5. “Quantity
recycled off-site.” Quantities reported in Section
6.2 as transferred off-site for the purposes of
recycling must be included in Section 8.5 using the
following codes:
– M20 Solvents/Organic Recovery
–
M24 Metals Recovery
–
M26 Other Reuse or Recovery
–
M28 Acid Regeneration
–
M93 Transfer to Waste Broker - Recycling.
Reporting quantities in Section 8.7 “Quantity
treated off-site.” Quantities reported in Section
6.2 as transferred off-site for the purposes of
treatment must be included in Section 8.7 using the
following codes:
– M40 Solidification/Stabilization
§8.5 = §6.2 (recycling) - §8.8 (off-site recycling)2
All calculation errors will be listed on an eFDP as a
NOSE.
Reporting quantities in Section 8.6 “Quantity
treated on-site.” Quantities may not always have
to be reported in Section 8.6 when Section 7A is
completed. This is because the information
reported in Section 7A and Section 8 is different.
Information on how waste streams containing the
reported EPCRA Section 313 chemical are treated
is reported in Section 7A, while the quantity of the
EPCRA Section 313 chemical actually destroyed
as a result of on-site treatment is reported in
Section 8.6. If a quantity is reported in Section 8.6,
Section 7A must be completed but the reverse may
not be true. This may result in apparent
discrepancies between Section 7A and Section 8.
For example, a facility may treat wastewater
containing an EPCRA Section 313 chemical by
removing the EPCRA Section 313 chemical and
then disposing of it on-site. The treatment of the
wastewater would be reported in Section 7A, with
an efficiency estimate based on the amount of the
EPCRA Section 313 chemical removed from the
wastewater. Although the chemical in the waste
stream has been treated because the chemical has
been removed, the EPCRA Section 313 chemical
has not been treated because it has not been
destroyed. The facility would report only the
amount of the EPCRA Section 313 chemical
actually destroyed during treatment in Section 8.6
and the amount ultimately disposed of in Section
8.1 to avoid double-counting the same quantity in
Section 8. In cases where the EPCRA Section 313
chemical is not destroyed during a treatment
process and subsequently enters another activity,
such as disposal (e.g., metals removed from
wastewater and subsequently disposed of on-site),
the quantity of the EPCRA Section 313 chemical
would be reported as disposed of in Section 8.1,
–
M50 Incineration/Thermal Treatment
–
M54 Incineration/Insignificant Fuel Value
–
M61 Wastewater Treatment (excluding
POTW)
–
M69 Other Waste Treatment
–
M95 Transfer to Waste Broker - Waste
treatment.
Quantities of an EPCRA Section 313 chemical,
except metals and metal category compounds, sent
off-site to a POTW should also be reported in
Section 8.7. If you know, however, that a chemical
is not treated for destruction at the POTW you
should report that quantity in Section 8.1 instead of
8.7.
To report correctly EPCRA Section 313 chemicals
in Section 8.7, use the following equation.
§8.7 =§6.1 (portion of transfer that is ultimately
treated) + §6.2 (treatment) - §8.8 (off-site
treatment)3
All calculation errors will be listed on an eFDP as a
NOSE.
Reporting quantities in Section 8.8 Quantity
released to the environment as a result of
remedial actions, catastrophic events or
one-time events not associated with production
processes. The quantities that are reported in
Section 8.8 are associated with non-production
related activities such as catastrophic releases and
remedial actions, as well as one-time events not
§8.8 includes quantities of toxic chemical disposed of or otherwise
released on-site or managed as waste off-site due to remedial actions,
catastrophic events, or one-time events not associated with the production
processes.
3
Toxics Release Inventory Reporting Forms and Instructions
C-9
Appendix C
associated with routine production practices that
were disposed of or released directly to the
environment or transferred off-site for the purposes
of recycling, energy recovery, treatment or
disposal. Quantities reported in Section 8.8 must
not be reported in Section 8.1 through 8.7.
Applies to: Paper forms (trade secret submissions) and
TRI-MEweb submissions
Reporting the production ratio in Section 8.9. A
production ratio or activity index must be provided
in Section 8.9. A zero is not acceptable and NA
(Not Applicable) can be used only when the
reported EPCRA Section 313 chemical was not
manufactured, processed, or otherwise used in the
year prior to the reporting year. TRI-MEweb in RY
2012 is providing an optional worksheet to help
calculate the production ratio.
Calculating production ratio in Section 8.9. In
calculating a production ratio for otherwise used
chemicals, an activity index must be used rather
than quantities purchased or released from year to
year.
Reporting source reduction activities in Section 8.10.
It is an error to report a source reduction activity in
Section 8.10 and not report at least one method
used to identify that activity and vice versa.
All calculation errors will be listed on an eFDP as a
NOSE.
C.3 eFDP Messages Used to
Report Notices of Significant
Errors
Note:
EPA is continually trying to improve the error
checking system for TRI submissions. As a result,
a small number of the error messages in this
appendix may be changed by the time the
Reporting Year 2013 submissions are checked.
Most of these messages will remain the same. You
can look for changes to these error messages on the
TRI home page at http://www.epa.gov/tri
Applies to: Paper forms only (trade secret submissions)
1.
You have used an invalid Form R or Form A by
using either a form not applicable for the reporting
year, or a facsimile form that has not been
approved by EPA. Resubmit your data on a current
EPA approved Form R or A.
2.
Pages were missing from the form received.
Correct this by resubmitting a complete certified
form for this chemical substance.
3.
Multiple chemicals were reported in your Form R.
You must submit a separate and complete Form R
for each chemical cited.
4.
You have provided a valid CAS number and a
valid chemical name, but they do not match.
Respond by providing a valid CAS number and
matching chemical name.
5.
You have left part or all of the chemical
identification sections blank. Respond by providing
a valid CAS number and matching chemical name
or Mixture Component Identity.
6.
You reported a CAS number and chemical name
that are invalid. Respond by providing a valid CAS
number and matching chemical name.
7.
Your form indicated Trade Secret status with an
indication that this form is a Sanitized version, but
the report contains no Generic Chemical Name.
You must provide a Generic Chemical Name for
this sanitized form.
8.
You have reported Dioxin and Dioxin-like
Compounds on a Form A. Dioxin and Dioxin-like
Compounds are not eligible for the alternate
threshold. Thus, this chemical must be reported on
a Form R. Please resubmit your data on a Form R.
9.
In Part I, Section 1of the Form R or Form A
Certification Statement You did not enter a
reporting year. (Note: EPA has set the year to 2084
as a default.) You must enter a valid reporting year
for your Form R or Form A Certification
Statement. This entry cannot be left blank and NA
may not be used. (NOSE)
10. In Part I, Section 1of the Form R or Form A
Certification Statement you provided an invalid or
future reporting year. You must enter a valid
reporting year for your Form R or Form A
Certification Statement. Valid years are 1987
through 2012. This entry cannot be left blank and
NA may not be used. (NOSE)
11. You have reported a negative number(s) in Part II,
Sections 5 and/or 6 and/or 8 of your Form R.
Quantities reported in these sections must be 0 or
greater. Please respond by providing correct
release or other waste management data.
12. You did not complete Part II, Sections 5 and 6.
Please provide the required information; otherwise
indicate NA.
13. You did not complete Part II, Section 7. Please
provide the required information; otherwise
indicate NA.
14. You did not complete Part II, Section 8. Please
provide the required information; otherwise
indicate NA.
Toxics Release Inventory Reporting Forms and Instructions
C-10
Appendix C
C.4 Messages Used to Report
Notices of Technical Errors
(NOTEs) and Non-technical
Data Changes (NDCs)
Invalid codes throughout Form R
Applies to: Paper forms only (trade secret submissions)
15. You submitted an invalid code. To correct this,
consult the instructions for the proper table value
and provide a valid code value. [Specific location
on the form of the invalid code is given.] (NOTE)
16. PBT chemicals (e.g., Dioxin and Dioxin-like
Compounds,
Lead
Compounds,
Mercury
Compounds and Polycyclic Aromatic Compounds
(PACs)) are ineligible for range reporting for onsite releases and transfers off-site for further waste
management. Please provide specific release,
transfer,
and
other
waste
management
values.(NOTE)
17. For aluminum (fume or dust) or zinc (fume or
dust), the Waste Management codes M56 and M92
are unacceptable. Please provide the proper Waste
Management codes for these chemicals. (NOTE)
18. For asbestos (friable), the Waste Management
codes M56 and M92 are unacceptable. Please
provide the proper Waste Management codes for
these chemicals. (NOTE)
General Errors for both the Form R and/or
Form A
Applies to: Paper forms only (trade secret submissions)
19. You reported a negative value for a release,
transfer or other waste management quantity.
Please provide a non-negative value for the
specified part and section. (NOTE)
20. You have reported a value for a PBT chemical
beyond seven digits to the right of the decimal.
EPA’s data management systems support data
precision up to seven digits to the right of the
decimal.
EPA has truncated your numeric
submission so the number of digits to the right of
the decimal does not exceed seven. If this was
incorrect, specify the correct value, not exceeding
seven digits to the right of the decimal. (NDC)
Errors in Part I, Facility Identification
Information
Applies to: Paper forms only (trade secret submissions)
21. No selection was made in Part I, Section 2.1 and
2.2 (Trade Secret Information) and a generic
chemical name was not provided in Part II, Section
1.3. Therefore, the No box was selected in Part I,
Section 2.1. If this was incorrect, and you intended
to make a trade secret claim of the identity of the
toxic chemical, you must resubmit following the
requirements of 40 CFR Part 350 to claim trade
secret. (NDC)
22. You indicated trade secret in Part I, Section 2.1
(Trade Secret Information) but made no selection
for Part I, Section 2.2 (sanitized/unsanitized) and
did not provide a generic chemical name in Part II,
Section 1.3. EPA changed your selection in Part I,
Section 2.1 to indicate that a trade secret claim is
not being made. If this was incorrect, and you
intended to make a trade secret claim for the
identity of the toxic chemical, you must resubmit
following the requirements of 40 CFR Part 350 to
claim trade secret. (NDC)
23. You made a selection of No in Part 1, Section 2.1
(Trade Secret Information) and selected
unsanitized in Part 1, Section 2.2. In Part II,
Section 1.3 a generic name was indicated. Part II,
Section 1.3 should be completed only if trade
secret is being claimed (Part 1, Section 2.1). EPA
will move the chemical name information in Part
II, Section 1.3 to Part II, Section 1.2. If this is
incorrect and you wish to claim trade secret, you
must resubmit following the requirements of 40
CFR Part 350. (NDC)
24. In Part I, Section 4.1, you entered NA or did not
enter a county name, city name, state code, and/or
zip code. These fields may not be left blank and
NA is not an acceptable entry. You must provide
a county name, city name, state code, and/or zip
code where the facility is located. (NDC)
25. EPA has corrected the county name, city name,
state code, and/ or zip code that you identified in
Part I, Section 4.1. The county name, city name,
state code, and/ or zip code that you identified was
either misspelled, or incorrect, or did not match the
previous year submissions.
If you feel our
correction was made in error, please resubmit
forms with correct information. (NDC)
26. In Part I, Section 4.1, you have used an invalid
TRIFID or you have self-assigned your own
TRIFID or TRIFID that has been superseded. You
may not generate your own TRIFID. The TRI Data
Processing Center assigns this number to a facility.
EPA has corrected this error and assigned you the
correct TRIFID. Please note the corrected TRIFID
and keep it for use in future submissions. (NDC)
27. No Public Contact name and/or telephone number
was listed. Please provide the name and telephone
number of your Public Contact. (NOTE)
28. No Technical Contact name and/or telephone
number was listed. Please provide the name and
telephone number of your Technical Contact.
(NOTE)
29. The Federal Facility box was not checked on your
form but we believe you are a Federal Facility.
Toxics Release Inventory Reporting Forms and Instructions
C-11
Appendix C
Unless you respond that you are not a Federal
Facility, we will continue to treat you as a Federal
Facility. (NOTE)
30. A valid NAICS code was not provided. Please
provide at least one valid primary six-digit NAICS
code. (NOTE)
31. You reported an invalid state code. If the address
is in the US, please use a valid US Postal Service
state code (see Table III of the Reporting Forms
and Instructions). If the address is not in the US,
please enter a valid code in the Country Field (see
Table IV of the Reporting Forms and Instructions)
(NOTE)
32. Either Box A (An Entire Facility) or Box B (Part of
a Facility) should be checked in Part I, Section 4.2.
One of the 2 boxes must be checked, but not both.
(NOTE)
has changed the Chemical Name to use the
preferred TRI nomenclature. Please specify the
correct CAS Number and matching Chemical
Name. (NDC)
40. The CAS number you reported was changed to
match the chemical name reported, because the
CAS number you provided was not a valid TRI
Chemical. If this was incorrect, specify a valid
CAS number and matching chemical name. (NDC)
41. The chemical name you reported was changed to
match the CAS number reported, because the
chemical name you provided was not a valid TRI
Chemical. If this was incorrect, specify a valid
CAS Number and matching Chemical Name.
(NDC)
33. If applicable, check either Box C (Federal Facility)
or Box D (GOCO) in Part I, Section 4.2, but do not
check both boxes. (NOTE)
42. You reported a valid TRI CAS Number, a valid
Chemical Name, and a generic Chemical Name.
Therefore, the Generic Chemical Name was
deleted. If this was incorrect, specify the Generic
Chemical Name to be used. (NDC)
34. Dun and Bradstreet Numbers (Part I Section 4.6)
are typically 9 characters in length. Please check
the number(s) submitted. If they are incorrect,
please make the appropriate changes. If you
believe that they are correct, no further action is
necessary. (NOTE)
43. You reported a valid TRI CAS Number, a valid
Chemical Name, and a Mixture Component
Identity. Therefore, the Mixture Component
Identity was deleted. If this was incorrect, specify
the Mixture Component Identity to be used.
(NDC)
35. If this is a North American phone number, please
enter all 10 digits (i.e., include area code). If this is
for another country, please begin the phone number
with "011" as the prefix to your international
telephone number. (NOTE)
44. EPA has changed the TRI chemical category code
you reported in Part II, Section 1.1 from N151 to
N150 (the code was incorrectly listed in some
pages of the Reporting Forms and Instructions), the
correct TRI chemical category code for Dioxin and
Dioxin-like Compounds. If this is incorrect and
you are not reporting Dioxin and Dioxin-like
Compounds, please specify the correct CAS
number or chemical category code and matching
chemical name. (NDC)
36. In Part I, Section 3, you did not provide a printed
or typed name and official title of owner/operator
or senior management official. It cannot be N/A or
left blank. Please provide a name for
owner/operator or senior management official.
(NOTE)
37. In Part I, Section 5.1 you did not enter the name of
the parent company. This block cannot be left
blank. You must enter the name for the parent
company if it is a U.S. company. If it is a foreign
company then you may check the [NA] box.
(NOTE)
38. The parent company Dun and Bradstreet Number
in Part I, Section 5.2 (typically a 9-digit number)
cannot be left blank. However, if your parent
company does not have a Dun and Bradstreet
Number check the [NA] box next to Part I, Section
5.2. (NOTE)
Errors in Part II, Section 1. Toxic Chemical
Identity
Applies to: Paper forms only (trade secret submissions)
45. You have reported for isopropyl alcohol (Only
persons who manufacture by the strong acid
process are subject) (CAS number 67-63-0). If you
did not manufacture isopropyl alcohol by the
strong acid process, you have submitted this form
in error and should request that the form be
withdrawn. (NOTE)
Errors in Part II, Section 3. Activities and Uses
of Toxic Chemical at The Facility
Applies to: Paper forms only (trade secret submissions)
46. You did not indicate in Part II, Section 3 which
activity(ies) or use(s) of the EPCRA Section 313
chemical occur at your facility. Please indicate at
least one of the activity(ies) and use(s) of the
EPCRA Section 313 chemical occur at your
facility. (NOTE)
39. You have correctly identified the chemical but
have used a synonym for the chemical name. EPA
Toxics Release Inventory Reporting Forms and Instructions
C-12
Appendix C
Errors in Part II, Section 4. Maximum Amount
of the Toxic Chemical Onsite at Any Time
During the Calendar Year
Applies to: Paper forms only (trade secret submissions)
47. You did not complete Part II, Section 4.1. Please
provide a valid two digit code for the “maximum
amount of chemical on-site at any time during the
calendar year.” (NOTE)
Errors in Part II, Section 5. Quantity of the
Toxic Chemical Entering Each Environmental
Medium Onsite
Applies to: Paper forms only (trade secret submissions)
60. You did not complete Part II, Section 5.3. If you
have discharged to water, please provide the
Stream/Water Body name, the Release estimate or
range code, Basis of Estimate and % from
Stormwater; otherwise indicate “NA” (Not
Applicable). (NOTE)
61. There are missing or incomplete data for Part II,
Section 5.3. If you have discharged to water, please
provide the Stream/Water Body name, the Release
estimate or range code, Basis of Estimate and %
from Stormwater; otherwise indicate “NA” (Not
Applicable). (NOTE)
62. You did not complete Part II, Section 5. Please
provide the Release estimate or range code and
Basis of Estimate; otherwise indicate “NA” (Not
Applicable). (NOTE)
63. There are missing or incomplete data for Part II,
Section 5. Please provide the Release estimate or
range code and Basis of Estimate; otherwise
indicate “NA” (Not Applicable). (NOTE)
Errors in Part II, Section 6. Transfers of the
Toxic Chemical in Wastes To Off-Site
Locations
Applies to: Paper forms only (trade secret submissions)
64. You did not complete Part II, Section 6.1,
“discharges to POTW.” If you did not discharge
wastewater containing the Section 313 chemical to
a POTW(s), enter “NA” (Not Applicable),
otherwise please provide the Transfer amount or
range code, Basis of Estimate, POTW Name and
Location. (NOTE)
65. You reported a POTW(s) name and location but
did not provide a Transfer amount. Please provide
a Total Transfer amount or range code and Basis of
Estimate; otherwise, if there was no transfer to a
POTW of wastewater that contains or contained the
Section 313 chemical, delete the POTW location
and indicate “NA” (Not Applicable) for the POTW
transfer amount. (NOTE)
66. You reported a Total Transfer amount or range
code and Basis of Estimate in Part II Section 6.1
but did not indicate a POTW name and location in
Section 6.1.B. Please provide the POTW Name and
Location. (NOTE)
67. You provided an incomplete POTW name and
address. Please provide the name and complete
address for the POTW. (NOTE)
68. There are missing or incomplete data for Part II,
Section 6.1. Please provide the transfer amount or
range code and Basis of Estimate for Discharges to
POTWs. (NOTE)
69. You did not complete Part II, Section 6.2,
“Transfers to Other Off-site Locations.” If you did
not transfer the waste containing the Section 313
chemical to other off-site locations, enter “NA”
(Not Applicable), otherwise please provide Offsite
EPA ID, Name, Location, Transfer amount or
range code, Basis of Estimate, and type of Waste
Management code. (NOTE)
70. You reported an Off-site Transfer amount or range
code and Basis of Estimate in Part II Section 6.2
but did not indicate an Off-site name and location
in Section 6.2. Please provide the Off-site Name
and Location. (NOTE)
71. You reported an Off-site name and location but did
not provide a Transfer amount. Please provide a
Total Transfer amount or range code, Basis of
Estimate and type of Waste Management code;
otherwise, if there was no transfer to this Off-site
location, delete the Off-site name and location and
indicate “NA” (Not Applicable) in the Off-site
EPA Identification Number (RCRA ID No.) field.
(NOTE)
72. You provided both county and country data. If this
is an extra-national transfer, indicate the off-site
name, address, and Country Code; if a domestic
Offsite, provide the Off-site Name and correct
address. (NOTE)
73. You reported an Off-site name and location, but
there are missing or incomplete data for the off-site
transfer amount, basis of estimate and type of
waste management code. Please provide the Offsite Transfer amount or range code, Basis of
Estimate, and type of Waste Management code.
(NOTE)
74. You provided incomplete off-site name and
address data. For a transfer to a domestic off-site
location, you must provide a street address, city,
state, county and zip code. For a transfer to a
foreign off-site location, you must provide a street
address, city and a two character country code.
(NOTE)
75. You reported an invalid Type of Waste
Management code. For metals/metal compounds
use only disposal and certain recycling activities
Toxics Release Inventory Reporting Forms and Instructions
C-13
Appendix C
codes. Consult the Reporting Instructions for metal
and metal compounds and correct with a valid
Waste Management (i.e., “M”) code. (NOTE)
76. You reported an invalid Type of Waste
Management code. For Barium Compounds use
only disposal and certain recycling activities codes,
M61-Wastewater Treatment (Excluding POTW) or
M69-Other Waste Treatment. Consult the
Reporting Instructions for metal and metal
compounds and correct with a valid Waste
Management (i.e., “M”) code. (NOTE)
77. For non-metals codes M41 and M62 are
unacceptable. Provide the appropriate Disposal or
Other Waste Management code for this non-metal
substance. (NOTE)
78. In Part II, Section 6.2 column C you reported M
codes (M56 and/or M92) for energy recovery,
however you left Section 8.3 column B blank.
Please provide the quantity used for energy
recovery offsite in pounds/year in Section 8.3
column B. (NOTE)
79. In Part II, Section 6.2 column C you reported M
Codes (M20, M24, M26, M28, M93) for recycling,
however you left Section 8.5 column B blank.
Please provide the quantity recycled offsite in
pounds/year in Section 8.5 column B. (NOTE)
80. In Part II, Section 6.2 column C you reported M
Codes (M40, M50, M54, M61, M69, M95) for
treatment, however you left Section 8.7 column B
blank. Please provide the quantity treated offsite in
pounds/year in Section 8.7 column B. (NOTE)
Errors in Part II, Section 7. On-Site Waste
Treatment Methods and Efficiency
Applies to: Paper forms only (trade secret submissions)
81. There are no data contained in all of Part II,
Section 7A. If you do not treat wastes containing
the EPCRA Section 313 chemical at your facility,
indicate “NA;” otherwise please provide the
general waste stream code, waste treatment
methods, range of influent concentration, waste
treatment efficiency estimate and whether this is
based on operating data for all on-site waste
treatments for this chemical. (NOTE)
82. There are missing data in Part II, Section 7A.
Please provide the general waste stream code,
waste treatment methods, range of influent
concentration, waste treatment efficiency estimate
and whether this is based on operating data.
(NOTE)
84. There are no data in Part II, Section 7C. If no onsite recycling processes are used for this Section
313 chemical at your facility, indicate “NA;”
otherwise please provide at least one threecharacter on-site recycling process code. (NOTE)
Errors in Part II, Section 8. Source Reduction
and Recycling Activities
Applies to: Paper forms only (trade secret submissions)
85. There are missing data for Part II, Section 8.1-8.7.
Please provide an estimate or “NA” (Not
Applicable) in each box for section 8.1 through 8.7,
columns A, B, C, and D. You may only use “NA”
(Not Applicable) when there is no possibility a
release or transfer occurred. You may enter zero if
the release or transfer was equal to or less than half
a pound. (NOTE)
86. There are missing data in Part II, Section 8.8.
Please provide an estimate or “NA” (Not
Applicable). You may only use “NA” (Not
Applicable) when there is no possibility a release
or transfer occurred. You may enter zero if the
release or transfer was equal to or less than half a
pound. (NOTE)
87. There are no data in Part II, Section 8.9. Please
provide a production ratio, an activity index, or
“NA” (Not Applicable) if the chemical
manufacture or use began during the current
reporting year. (NOTE)
88. There are no data in Part II, Section 8.10. If your
facility did not engage in any source reduction
activity for the reported chemical, enter “NA” (Not
Applicable) and answer 8.11. Otherwise please
provide Source Reduction Activities and Methods
code(s). (NOTE)
89. There are missing data in Part II, Section 8.10.
Please provide Source Reduction Activities and
Methods code(s). (NOTE)
90. You have reported a listed metal or metal
compound category in section 8.2, 8.3, 8.6 or 8.7.
However, these chemicals cannot be treated for
destruction. Metal or metal compound category can
only be reported as disposed of or recycled. Please
report appropriately in Section 8.1, 8.4, or 8.5.
(NOTE)
91. You reported a negative value for a release,
transfer or other waste management quantity.
Please provide a non-negative value for the
specified part and section. (NOTE)
83. There are no data in Part II, Section 7B. If no onsite energy recovery processes are used for this
Section 313 chemical at your facility, indicate
“NA;” otherwise please provide at least one threecharacter on-site energy recovery process code.
(NOTE)
Toxics Release Inventory Reporting Forms and Instructions
C-14
Appendix C
Errors relating to the reconciliation of data
in Part II, Section 8 and Part II, Sections 5, 6,
and 7
Applies to: Paper forms only (trade secret submissions)
92. You did not complete Sections 8.1 through 8.7
column B or 8.8. If you report releases in Part II,
Section 5 and/or an off-site transfer in Section 6.2
and/or quantities transferred off-site to POTWs in
Section 6.1, you must report an estimate in Part II,
Sections 8.1 through 8.7 column B and/or Section
8.8. (NOTE)
93. You did not complete Sections 5, 6, or 7. If you
enter an estimate in Part II, Sections 8.1 through
8.7, column B and/or Section 8.8, you must also
report releases in Part II, Section 5 and/or off-site
transfers in Section 6.2 and/or quantities
transferred off-site to POTWs in Section 6.1 and/or
waste treatment, energy recovery, or recycling
codes in Section 7. Please provide data for Sections
5, 6, and/or 7. (NOTE)
94. You reported an estimate in Part II, Section 8.2,
column B, “Quantity Used for Energy Recovery
On-site,” but did not provide an on-site energy
recovery code in Part II, Section 7B. Please
provide an on-site energy recovery code for Part II,
Section 7B. (NOTE)
95. You reported an “On-site Energy Recovery
Process” code in Part II, Section 7B, but you did
not provide an estimate of the quantity used for
energy recovery in Part II, Section 8.2, column B.
Please provide an estimate of the quantity used for
energy recovery for Part II, Section 8.2, column B.
(NOTE)
96. You reported an estimate in Part II, Section 8.4,
column B “Quantity Recycled On-site” but did not
provide an on-site recycling code in Part II, Section
7C. Please provide an on-site recycling code for
Part II, Section 7C. (NOTE)
97. You reported one or more on-site recycling process
codes in Part II, Section 7C but did not provide an
estimate in Part II, Section 8.4, column B,
“Quantity Recycled On-site.” Please provide an
estimate of the quantity recycled for Section 8.4
column B. (NOTE)
98. You reported a value in Part II, Section 8.3 column
B, however you did not provide a corresponding
quantity with an appropriate M Code (M56
and/orM92) for energy recovery in Section 6.2
column C. Please provide the appropriate quantity
and M Codes for energy recovery in Section 6.2
column C. (NOTE)
99. You reported a value in Part II, Section 8.5 column
B, however you did not provide a corresponding
quantity with an appropriate M Code (M20, M24,
M26, M28, M93) for recycling in Section 6.2
column C. Please provide the appropriate quantity
and M Codes for recycling in Section 6.2 column
C. (NOTE)
100.You reported a value in Part II, Section 8.7 column
B, however you did not report a quantity in
Section 6.1 or a quantity with an appropriate M
Code (M40, M50, M54, M61, M69, M95) for
treatment in Section 6.2 column C. Please provide
a quantity in Section 6.1 or the appropriate quantity
and M Codes for treatment in Section 6.2 column
C. (NOTE)
101.You have reported a listed metal or metal
compound category in Part II, Section 6.1, however
you have not provided a quantity released in
section 8.1 column B. Note that in Section 8a,
metal or metal compound category can only be
reported as disposed of or recycled and not
reported as treated for energy recovery or treated
for destruction. Please provide quantity released in
pounds/year in Section 8.1 column B. (NOTE)
102.You have reported a listed metal or metal
compound category in Part II, Section 6.1, however
you have not provided quantity released in 8.1d
Column B. Note that in Section 8a, metal or metal
compound category can only be reported as
disposed of or recycled and not reported as treated
for energy recovery or treated for destruction.
Please provide quantity released in pounds/year
Section 8.1B. (NOTE)
Toxics Release Inventory Reporting Forms and Instructions
C-15
Appendix D. Supplier Notification Requirements
EPA requires some suppliers of mixtures or other trade
name products containing one or more of the EPCRA
section 313 chemicals to notify their customers. This
requirement has been in effect since January 1, 1989.
This appendix explains which suppliers must notify their
customers, who must be notified, what form the notice
must take, and when it must be sent.
D.1 Who Must Supply
Notification
You are covered by the section 313 supplier notification
requirements if you own or operate a facility which meets
all of the following criteria:
1.
Your facility is in a North American Industry
Classification System (NAICS) code that
corresponds to Standard Industrial Classification
[SIC] codes 20-39;
2.
You manufacture (including import) or process
an EPCRA section 313 chemical; and
3.
You sell or otherwise distribute a mixture or
other trade name product containing the EPCRA
section 313 chemical to either:
–
A facility in a covered NAICS code (see
Table I).
–
A person that then may sell the same
mixture or other trade name product to a
firm in a covered NAICS code (see Table
I).
Note that you may be covered by the supplier
notification rules even if you are not covered by the
section 313 release reporting requirements. For
example, even if you have fewer than 10 full-time
employees or do not manufacture or process any of the
EPCRA section 313 chemicals in sufficient quantities to
trigger the release and other waste management reporting
requirements, you may still be required to notify certain
customers.
D.2 Who Must Be Notified
Industries whose primary NAICS code does not
correspond to SIC codes 20 through 39 are not required
to initiate the distribution of notifications for EPCRA
section 313 chemicals in mixtures or other trade name
products that they send to their customers.
forward the notifications with the EPCRA section 313
chemicals they send to other covered users.
An example would be if you sold a lacquer containing
toluene to distributors who then may sell the product to
other manufacturers. The distributors are not in a
covered NAICS code, but because they sell the product to
companies in covered NAICS codes, they must be
notified so that they may pass the notice along to their
customers, as required.
The language of the supplier notification requirements
covers mixtures or other trade name products that are
sold or otherwise distributed. The “otherwise distributes”
language includes intra-company transfers and, therefore,
the supplier notification requirements at 40 CFR Section
372.45 apply.
D.3 Supplier Notification
Content
The supplier notification must include the following
information:
1.
A statement that the mixture or other trade name
product contains an EPCRA section 313
chemical or chemicals subject to the reporting
requirements of EPCRA section 313 (40 CFR
372);
2.
The name of each EPCRA section 313 chemical
and the associated Chemical Abstracts Service
(CAS) registry number of each chemical if
applicable. (CAS numbers are not used for
chemical categories, since they can represent
several individual EPCRA section 313
chemicals.); and
3.
The percentage, by weight, of each EPCRA
section 313 chemical (or all EPCRA section 313
chemicals within a listed category) contained in
the mixture or other trade name product.
For example, if a mixture contains a chemical (i.e., 12
percent zinc oxide) that is a member of a reportable
EPCRA section 313 chemical category (i.e., zinc
compounds), the notification must indicate that the
mixture contains a zinc compound at 12 percent by
weight. Supplying only the weight percent of the parent
metal (zinc) does not fulfill the requirement. The
customer must be told the weight percent of the entire
compound within an EPCRA section 313 chemical
category present in the mixture.
However, if these facilities receive notifications from
their suppliers about EPCRA section 313 chemicals in
mixtures or other trade name products, they should
Toxics Release Inventory Reporting Forms and Instructions
D-1
Appendix D
D.4 How the Notification
Must Be Made
The required notification must be provided at least
annually in writing. Acceptable forms of notice include
letters, product labeling, and product literature distributed
to customers. If you are required to prepare and
distribute a Material Safety Data Sheet (MSDS) for the
mixture under the Occupational Safety and Health Act
(OSHA) Hazard Communication Standard, your section
313 notification must be attached to the MSDS or the
MSDS must be modified to include the required
information. (A sample letter and recommended text for
inclusion in an MSDS appear at the end of this appendix.)
You must make it clear to your customers that any copies
or redistribution of the MSDS or other form of
notification must include the section 313 notice. In other
words, your customers should understand their
requirement to include the section 313 notification if they
give your MSDS to their customers.
In these cases, you must:
1.
Supply a new or revised notification within 30
days of a change in the product or the discovery
of misidentified EPCRA section 313 chemical(s)
in the mixture or incorrect percentages by
weight; and
2.
Identify in the notification the prior shipments of
the mixture or product in that calendar year to
which the new notification applies (e.g., if the
revised notification is made on August 12,
indicate which shipments were affected during
the period January 1-August 12).
D.6 When Notifications
Are Not Required
Supplier notification is not required for a “pure” EPCRA
section 313 chemical unless a trade name is used. The
identity of the EPCRA section 313 chemical will be
known based on label information.
D.5 When Notification
Must Be Provided
You are not required to make a “negative declaration.”
That is, you are not required to indicate that a product
contains no EPCRA section 313 chemicals.
You must notify each customer receiving a mixture or
other trade name product containing an EPCRA section
313 chemical with the first shipment of each calendar
year.
You may send the notice with subsequent
shipments as well, but it is required that you send it with
the first shipment each year. Once customers have been
provided with an MSDS containing the section 313
information, you may refer to the MSDS by a written
letter in subsequent years (as long as the MSDS is
current).
If your mixture or other trade name product contains one
of the EPCRA section 313 chemicals, you are not
required to notify your customers if:
If EPA adds EPCRA section 313 chemicals to the section
313 list, and your products contain the newly added
EPCRA section 313 chemicals, notify your customers
with the first shipment made during the next calendar
year following EPA’s final decision to add the chemical
to the list. For example, if EPA adds chemical ABC to
the list in September 1998, supplier notification for
chemical ABC would have begun with the first shipment
in 1999.
You must send a new or revised notice to your customers
if you:
1.
Change a mixture or other trade name product
by adding, removing, or changing the percentage
by weight of an EPCRA section 313 chemical;
or
2.
Discover that your previous notification did not
properly identify the EPCRA section 313
chemicals in the mixture or correctly indicate
the percentage by weight.
1.
Your mixture or other trade name product
contains the EPCRA section 313 chemical in
percentages by weight of less than the following
levels (These are known as de minimis levels)
–
0.1 percent if the EPCRA section 313
chemical is defined as an “OSHA
carcinogen;”
–
1 percent for other EPCRA section 313
chemicals.
De minimis levels for each EPCRA section 313 chemical
and chemical category are listed in Table II. PBT
chemicals (except lead when contained in stainless steel,
brass or bronze alloys) are not eligible for the de minimis
exemption. Therefore, de minimis levels are not provided
for these chemicals in Table II. However, for purposes of
supplier notification requirements only, such notification
is not required when the following PBT chemicals are
contained in mixtures below their respective de minimis
levels:
Toxics Release Inventory Reporting Forms and Instructions
D-2
Appendix D
Chemical or chemical
category name
CAS
number or
chemical
category
code
Supplier
notification
limit (%)
Chemical or chemical
category name
CAS
number or
chemical
category
code
Aldrin
309-00-2
1.0
Trifluralin
Benzo[g,h,i]perylene
191-24-2
1.0
Chlordane
57-74-9
0.1
*The de minimis level is 1.0 for all members except for
2,3,7,8-Tetrachlorodibenzo-p-dioxin which has a 0.1%
de minimis level.
**The de minimis level is 0.1 for inorganic lead
compounds and 1.0 for organic lead compounds
***The de minimis level is 0.1 except for
benzo(a)phenanthrene, dibenzo(a,e)fluoranthene,
benzo(j,k)fluorene, and 3-methylcholanthrene which are
subject to the 1.0% de minimis level.
Dioxin and dioxin-like
N150
compounds
(manufacturing; and the
processing or otherwise
use of dioxin and dioxinlike compounds if the
dioxin and dioxin-like
compounds are present
as contaminants in a
chemical and if they
were created during the
manufacturing of that
chemical
1.0*
Heptachlor
76-44-8
0.1
Hexachlorobenzene
118-74-1
0.1
Isodrin
465-73-6
1.0
Lead
7439-92-1
0.1
Lead compounds
N420
0.1**
Mercury
7439-97-6
1.0
Mercury compounds
N458
1.0
Methoxychlor
72-43-5
1.0
Octachlorostyrene
29082-74-4
1.0
Pendimethalin
40087-42-1
1.0
Pentachlorobenzene
608-93-5
1.0
Polychlorinated
biphenyls (PCBs)
1336-36-3
0.1
Polycyclic aromatic
compounds category
N590
0.1***
Tetrabromobisphenol A
79-94-7
1.0
Toxaphene
8001-35-2
0.1
2.
1582-09-8
Supplier
notification
limit (%)
1.0
Your mixture or other trade name product is one
of the following:
–
An article that does not release an EPCRA
section 313 chemical under normal
conditions of processing or otherwise use.
–
Foods, drugs, cosmetics, alcoholic
beverages, tobacco, or tobacco products
packaged for distribution to the general
public.
–
Any consumer product, as the term is
defined in the Consumer Product Safety
Act, packaged for distribution to the
general public. For example, if you mix
or package one-gallon cans of paint
designed for use by the general public,
notification is not required.
3.
A waste sent off site for further waste
management.
The supplier notification
requirements apply only to mixtures and trade
name products. They do not apply to wastes.
4.
You are initiating distribution of a mixture or
other trade name product containing one or more
EPCRA section 313 chemicals and your facility
is in any of the covered SIC codes added during
the 1997 industry expansion rulemaking,
including facilities whose SIC code is within
SIC major group codes 10 (except 1011, 1081,
and 1094), 12 (except 1241); industry codes
4911 (limited to facilities that combust coal
and/or oil for the purpose of generating power
for distribution in commerce), 4931 (limited to
facilities that combust coal and/or oil for the
purpose of generating power for distribution in
commerce), or 4939 (limited to facilities that
combust coal and/or oil for the purpose of
generating power for distribution in commerce);
or 4953 (limited to facilities regulated under the
Toxics Release Inventory Reporting Forms and Instructions
D-3
Appendix D
Resource Conservation and Recovery Act,
subtitle C, 42 U.S.C. Section 6921 et seq.) or
5169, or 5171, or 7389 (limited to facilities
primarily engaged in solvents recovery services
on a contract or fee basis).
D.7 Trade Secrets
Chemical suppliers may consider the chemical name or
the specific concentration of an EPCRA section 313
chemical in a mixture or other trade name product to be a
trade secret. If they consider:
1.
2.
The specific identity of an EPCRA section 313
chemical to be a trade secret, the notice must
contain a generic chemical name that is
descriptive of the structure of that EPCRA
Section
313 chemical (for example,
decabromodiphenyl oxide could be described as
a halogenated aromatic);
The specific percentage by weight of an EPCRA
section 313 chemical in the mixture or other
trade name product to be a trade secret, the
notice must contain a statement that the EPCRA
section 313 chemical is present at a
concentration that does not exceed a specified
upper bound. For example, if a mixture contains
12 percent toluene and you consider the
percentage a trade secret, the notification may
state that the mixture contains toluene at no
more than 15 percent by weight. The upper
bound value chosen must be no larger than
necessary to adequately protect the trade secret.
If you claim this information to be trade secret, you must
have documentation that provides the basis for your
claim.
D.8 Recordkeeping
Requirements
You are required to keep records of the following for
three years:
1.
Notifications sent to recipients of your mixture
or other trade name product;
2.
All supporting materials used to develop the
notice;
3.
If claiming a specific EPCRA section 313
chemical identity a trade secret, you should
record why the EPCRA section 313 chemical
identity is considered a trade secret and the
appropriateness of the generic chemical name
provided in the notification; and
4.
If claiming a specific concentration a trade
secret, you should record explanations of why a
specific concentration is considered a trade
secret and the basis for the upper bound
concentration limit.
Information retained under 40 CFR 372 must be readily
available for inspection by EPA.
Toxics Release Inventory Reporting Forms and Instructions
D-4
Appendix D
D.9 Sample Notification Letter
January 2, 2009
Mr. Edward Burke
Furniture Company of North Carolina
1000 Main Street
Anytown, North Carolina 99999
Dear Mr. Burke:
This letter is to inform you that a product that we sell to you, Furniture Lacquer KXZ-1390, contains one or more
chemicals subject to section 313 of Emergency Planning and Community Right-to-Know Act (EPCRA). We are
required to notify you of the presence of these chemicals in the product under EPCRA section 313. This law requires
certain industrial facilities to report on annual emissions and other waste management of specified EPCRA section 313
chemicals and chemical categories. Our product contains:
Toluene, Chemical Abstract Service (CAS) number 108-88-3, 20 percent, and
Zinc compounds, 15 percent.
If you are unsure whether you are subject to the reporting requirements of EPCRA section 313, or need more
information, call the EPA/TRI Information Center. For contact information, please see the TRI Home Page at
http://www.epa.gov/tri. Your other suppliers should also be notifying you about EPCRA section 313 chemicals in the
mixtures and other trade name products they sell to you.
Finally, please note that if you repackage or otherwise redistribute this product to industrial customers, a notice similar
to this one should be sent to those customers.
Sincerely,
Emma Sinclair
Sales Manager
Furniture Products
Toxics Release Inventory Reporting Forms and Instructions
D-5
Appendix D
D.10 Sample Notification on an MSDS Furniture
Products
Section 313 Supplier Notification
This product contains the following EPCRA section 313 chemicals subject to the reporting
requirements of section 313 of the Emergency Planning and Community Right-To-Know Act of
1986 (40 CFR 372):
CAS Number
Chemical Name
108-88-3
NA
Toluene
Zinc Compounds
Percent by Weight
20%
15%
This information must be included in all MSDSs that are copied and distributed for this
material.
Material Safety Data Sheet
Toxics Release Inventory Reporting Forms and Instructions
D-6
Appendix E.
TRI State and Tribal Contacts
EPCRA Section 313 requires facilities to submit reports to both EPA and their state or tribe (if located in
Indian country as defined by 18 USC §1151). For a current list of state and tribal designated Section 313
contacts, see the TRI web site at:
State TRI Contact Information:
http://www2.epa.gov/toxics-release-inventory-tri-program/tri-state-contacts
Tribal TRI Contact Information:
http://www2.epa.gov/toxics-release-inventory-tri-program/tri-tribal-contacts
Toxics Release Inventory Reporting Forms and Instructions
E-1
Appendix F. TRI Regional Contacts
Region 1 (CT, ME, MA, NH, RI, and VT)
Dwight Peavey
Office of Environmental Stewardship
USEPA Region 1 (OES05-1)
5 Post Office Square, Suite 100
Boston, MA 02109-3912
(617) 918-1829; fax: (617) 918-0829
[email protected]
Region 2 (NJ, NY, PR, and VI)
Nora Lopez
Pesticides and Toxic Substances Branch
USEPA Region 2 (MS-105)
2890 Woodbridge Avenue, Building 10
Edison, NJ 08837-3679
(732) 906-6890; fax: (732) 321-6788
[email protected]
Region 3 (DE, DC, MD, PA, VA, and WV)
William Reilly
Toxics Programs and Enforcement Branch
USEPA Region 3 (3LC61)
1650 Arch Street
Philadelphia, PA 19103-2029
(215) 814-2072; fax: (215) 814-3114
[email protected]
Region 4 (AL, FL, GA, KY, MS, NC, SC, TN)
Ezequiel Velez
Air Toxics & Monitoring Branch
Air Toxics Assessment & Implementation
Section
USEPA Region 4 (9T25)
61 Forsyth Street, S.W.
Atlanta, GA 30303-8960
(404) 562-9191; fax: (404) 562-9163
[email protected]
Region 5 (IL, IN, MI, MN, OH, and WI)
Bradley Grams
Land and Chemicals Division
USEPA Region 5 (LC-8J)
77 West Jackson Boulevard
Chicago, IL 60604
(312) 886-7747; fax: (312) 697-2527
[email protected]
Region 6 (AR, LA, NM, OK, and TX)
Morton Wakeland
Toxics Section, Multimedia Planning and
Permitting Division
USEPA Region 6 (6PD-T)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
(214) 665-8116; fax: (214) 665-6655
[email protected]
Region 7 (IA, KS, MO, and NE)
Stephen Wurtz
Toxics Release Inventory Coordinator
USEPA Region 7 (AWMD/CRIB)
11201 Renner Blvd
Lenexa, KS 66219
(913) 551-7315; fax: (913) 551-7065
[email protected]
Region 8 (CO, MT, ND, SD, UT, and WY)
Barbara Conklin
Toxics Release Inventory Program
USEPA Region 8 (8P-P3T)
1595 Wynkoop Street
Denver, CO 80202
(303) 312-6619; fax: (303) 312-6044
[email protected]
Region 9 (AS, AZ, CA, GU, HI, MH, MP,
and NV)
Russell Frazer
Toxics Release Inventory Program
USEPA Region 9 (ENF-2-1)
75 Hawthorne Street
San Francisco, CA 94105-3901
(415) 947-4220; fax: (415) 947-3583
[email protected]
Region 10 (AK, ID, OR, and WA)
Tony Davis
Inspections & Enforcement Management Unit
USEPA Region 10 (OCE-184)
1200 Sixth Avenue, Suite 900
Seattle, WA 98101-3140
(206) 553-8322; fax: (206) 553-7176
[email protected]
Toxics Release Inventory Reporting Forms and Instructions
F-1
Appendix G. Other Relevant Section 313 Materials
G.1 TRI National Analysis
Toxics Release Inventory National Analysis
EPA summarizes the latest TRI data in a report
called the TRI National Analysis. The National
Analysis is an annual report that includes
information about toxic chemical releases to the
environment, how toxic chemicals are managed at
TRI facilities (i.e. recycled, treated and burned for
energy), and how facilities are working to reduce
toxic chemicals they generate and release. The TRI
National Analysis Overview document includes
national trends and figures, while other websites
linked from the National Analysis homepage
include more localized analyses of states, certain
urban areas and watersheds. The National Analysis
homepage
can
be
accessed
at:
www.epa.gov/tri/NationalAnalysis.
To conduct your own analysis, TRI data collected
from 1987 through 2013 can be accessed using the
TRI Explorer online tool:
http://www.epa.gov/triexplorer, as well as several
other public access tools available on the TRI
website at: http://www.epa.gov/tri/tridata/index.htm.
G.2. Access to TRI Information On-line
The TRI Home Page http://www.epa.gov/tri offers
information useful to both novice and experienced
users of the Toxics Release Inventory. It provides a
description of what the TRI database is and how it
can be used; access to TRI data; TRI regulations;
and guidance documents for complying with TRI
regulations and using TRI data. You can find out
about TRI products, view or download the 2013 TRI
reports, and identify who to contact for more
information in EPA regions and state programs
across the country. From the TRI home page, you
can link to other EPA and non-EPA sites that also
allow you to search the TRI database and other
databases online.
TRI Explorer http://www.epa.gov/triexplorer is an
on-line tool that EPA has created to obtain TRI data.
It allows the user to search the TRI database using
six criteria: facility, chemical, year or industry type
(NAICS code), federal facility and geographic area
(at the county, state or national level). The tool will
generate three types of reports: (1) Release Reports
(including on- and off-site releases (i.e., off-site
releases include transfers off-site to disposal and
metals and metal compounds transferred to
POTWs)); (2) Waste Transfer Reports (including
amounts transferred off-site for further waste
management but not including transfers off-site to
disposal); and (3) Waste Quantity Reports
(including amounts recycled, burned for energy
recovery, quantities treated, and quantities released).
TOXNET http://toxnet.nlm.nih.gov the National
Library of Medicine’s (NLM) Toxicology Data
Network, provides free access to several databases,
including the TRI database, that provides a variety
of information on toxic chemicals. As with EPA’s
TRI Explorer tool, users of TOXNET can search by
chemical or other name, chemical name fragment,
or Chemical Abstracts Service Registry Number.
Also searchable are facility or parent company
name, state, city, county, or zip code. Search results
can be limited to releases greater than a specified
number of pounds, and individual releases can be
summed together to display a total amount.
Toxicity and environmental fate data for thousands
of chemicals are also available from TOXNET.
G.3 Other TRI Information
EPA’s Integrated Risk Information System
(IRIS) http://www.epa.gov/iris is an electronic
database containing information on human health
effects that may result from exposure to various
chemicals, including TRI chemicals, in the
environment. IRIS was initially developed for EPA
staff in response to a growing demand for consistent
information of chemical substances for use in risk
assessments, decision-making and regulatory
activities. The information in IRIS is intended for
those without extensive training in toxicology, but
with some knowledge of health sciences.
Consolidated List of Chemicals Subject to the
Emergency Planning and Community Right-toKnow Act and Section 112(r) of the Clean Air
Act (List of Lists), (October 2012):
http://www.epa.gov/emergencies/docs/chem/list_of_
lists.pdf
The Pollution Prevention Information
Clearinghouse (PPIC)
http://www.epa.gov/oppt/ppic/index.html PPIC was
established as part of EPA’s response to the
Pollution Prevention Act of 1990, which directed
the Agency to compile information, including a
database, on management, technical, and operational
Toxics Release Inventory Reporting Forms and Instructions
G-1
Appendix G
approaches to source reduction. PPIC provides
information to the public and industries involved in
conservation of natural resources and in reduction or
elimination of pollutants in facilities, workplaces,
and communities.
To request EPA information on pollution prevention
or obtain fact sheets on pollution prevention from
various state programs call the PPIC reference and
referral service at 202 566-0799, or fax a request to
202 566-0794, or write to:
U.S. EPA
Pollution Prevention Information Clearinghouse
(PPIC)
EPA West
1200 Pennsylvania Ave. NW
Room 3379 (Mail Code 7407-T)
Washington, DC 20460-0001
Email: [email protected]
Toxics Release Inventory Reporting Forms and Instructions
G-2
Appendix H. Guidance Documents
H.1 General Guidance
Many of the TRI guidance documents are available via the Internet http://www.epa.gov/tri.
40 CFR 372, Toxic Chemical Release Reporting; Community Right-to-Know; Final Rule
A reprint of the final EPCRA section 313 rule as it appeared in the Federal Register (FR) February 16, 1988 (53
FR 4500) (OTSFR 021688).
Common Synonyms for Chemicals Listed Under Section 313 of the Emergency Planning and Community
Right-to-Know Act
March 1995 (EPA 745R-95-008)
This glossary contains chemical names and their synonyms for substances covered by the reporting requirements
of EPCRA section 313. The glossary was developed to aid in determining whether a facility manufactures,
processes, or otherwise uses a chemical subject to EPCRA section 313 reporting.
EPCRA Section 313 Questions and Answers - Revised 1998 Version
December 1998 (EPA 745-B-98-004)
The revised 1998 EPCRA Section 313 Questions and Answers document assists regulated facilities in complying
with the reporting requirements of EPCRA section 313. This updated document presents interpretive guidance
in the form of answers to many commonly asked questions on compliance with EPCRA section 313. In
addition, this document includes comprehensive written directives to assist covered facilities in understanding
some of the more complicated regulatory issues. This updated guidance document is intended to supplement the
instructions for completing the Form R and the Alternate Threshold Certification Statement (Form A).
EPCRA Section 313 Questions and Answers - Addendum to the Revised 1998 Version
December 2004 (EPA-260-B-04-002)
As a result of Executive Order 13148, regulatory actions, and legal decisions over the past five years, some of
the Qs & As contained in the 1998 Q &A Document were updated. The 1998 Q & A Document remains valid
guidance in all other respects.
EPCRA Section 313 Questions and Answers Addendum for Federal Facilities
May 2000 (EPA 745-R-00-003)
This document is an addendum to the EPCRA section 313 Questions and Answers: Revised 1998 Version. It
provides additional assistance to federal facilities in complying with EPCRA section 313. Federal facilities,
which are subject to compliance under EPCRA through Executive Order 13423, frequently have operations that
are different from the private sector facilities subject to EPCRA. The document contains questions and answers
that address some of those differences.
EPCRA Section 313 Release and Other Waste Management Reporting Requirements
February 2001 (EPA 260/K-01-001)
The brochure alerts businesses to their reporting obligations under EPCRA section 313 and assists in
determining whether their facility is required to report. The brochure contains the EPA regional contacts, the list
of EPCRA section 313 toxic chemicals and a description of the Standard Industrial Classification (SIC) codes
subject to EPCRA section 313.
Toxic Chemical Release Reporting Using 2007 North American Industry Classification System (NAICS)
Final Rule (73 FR 32466; June 9, 2008): This final rule incorporates 2007 Office of Management and Budget
(OMB) revisions and other corrections to the NAICS codes used for TRI Reporting.
Toxic Chemical Release Reporting Using North American Industry Classification System (NAICS) Final
Rule (71 FR 32464; June 6, 2006): With this rulemaking, Toxics Release Inventory (TRI) reporting will require
North American Industry Classification System (NAICS) codes in place of Standard Industrial Classification
Toxics Release Inventory Reporting Forms and Instructions
H-1
Appendix H
(SIC) codes. North American Industry Classification System (NAICS), United States, 2002, Executive Office of
the President, Office of Management and Budget, NTIS Order Number: PB2002-101430
Persistent Bioaccumulative Toxic (PBT) Chemicals; Final Rule (64 FR 58666)
A reprint of the final rule that appeared in the Federal Register of October 29, 1999. This rule adds certain PBT
chemicals and chemical categories for reporting year 2000 and beyond under EPCRA section 313, lowers their
activity thresholds and modifies certain reporting exemptions and requirements for PBT chemicals and chemical
categories. In a separate action, as part of the October 29, 1999 rulemaking, EPA added vanadium (except when
contained in alloy) and vanadium compounds. These are not listed as PBT chemicals.
H.2 Supplier Notification Requirements
(EPA 560-4-91-006)
This pamphlet assists chemical suppliers who may be subject to the supplier notification requirements, gives examples
of situations which require notification, describes the trade secret provision, and contains a sample notification.
Toxic Chemical Release Inventory Reporting Forms and Instructions Revised 2006 Version
February 2007 (EPA 260-C-06-901)
Toxics Release Inventory: Reporting Modifications Beginning with 1995 Reporting Year
February 1995 (EPA 745-R-95-009)
Trade Secrets Rule and Substantiation Form
(53 FR 28772)
A reprint of the final rule that appeared in the Federal Register of July 29, 1988. This rule implements the trade
secrets provision of the Emergency Planning and Community Right-to-Know Act (section 322). The current
trade secret substantiation form can be accessed at http://www.epa.gov/tri/report/index.htm#forms
H.3 Chemical-Specific Guidance
EPA has developed a group of guidance documents specific to individual chemicals and chemical categories.
Emergency Planning and Community Right-to-Know Section 313: List of Toxic Chemicals within the
Chlorophenols Category
June 1999 (EPA745-B-99-013)
Toxics Release Inventory List of Toxic Chemicals within the Glycol Ethers Category and Guidance for
Reporting
December 2000 (EPA745-R-00-004)
Emergency Planning and Community Right-to-Know Act Section 313: Guidance for Reporting
Hydrochloric Acid (acid aerosols including mists, vapors, gas, fog and other airborne forms of any
particle size)
December 1999 (EPA 745-B-99-014)
Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Releases
and Other Waste Management Activities of Toxic Chemicals: Lead and Lead Compounds
November 2001 (EPA-260-B-01-027)
Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
Chemicals: Mercury and Mercury Compounds Category
August 2001 (EPA 260-B-01-004)
Toxics Release Inventory List of Toxic Chemicals within the Nicotine and Salt Category and Guidance for
Reporting
June 1999 (EPA 745-R-99-010)
Toxics Release Inventory Reporting Forms and Instructions
H-2
Appendix H
Toxics Release Inventory List of Toxic Chemicals within the Water Dissociable Nitrate Compounds
Category and Guidance for Reporting
December 2000 (EPA 745-R-00-006)
Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
Chemicals: Pesticides and Other Persistent Bioaccumulative Toxic (PBT) Chemicals
August 2001 (EPA 260-B-01-005)
Toxics Release Inventory List of Toxic Chemicals within the Polychlorinated Alkanes Category and
Guidance for Reporting
June 1999 (EPA 745-B-99-023)
Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
Chemicals: Polycyclic Aromatic Compounds Category
August 2001 (EPA 260-B-01-003)
Toxics Release Inventory List of Toxic Chemicals within the Strychnine and Salts Category and Guidance
for Reporting
June 1999 (EPA 745-R-99-011)
Emergency Planning and Community Right-to-Know Act Section 313: Guidance for Reporting Sulfuric
Acid (acid aerosols including mists, vapors, gas, fog and other airborne forms of any particle size)
March 1998 (EPA745-R-97-007)
Toxics Release Inventory List of Toxic Chemicals within Warfarin Category
June 1999 (EPA745-B-99-011)
Toxics Release Inventory List of Toxic Chemicals within Ethylenebisdithiocarbamic Acid, Salts and
Esters Category and List of Mixtures that Contain the Individually listed Chemicals Maneb, Metiram,
Nabam, and Zineb
September 2001 (EPA 260-B-01-026)
Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Aqueous
Ammonia
December 2000 (EPA 745-R-00-005)
Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
Chemicals within the Dioxin and Dioxin-like Compounds Category
December 2000 (EPA 745-B-00-021)
H.4 Industry-Specific Guidance
EPA has developed specific guidance documents for certain industries.
EPCRA Section 313: Guidance for Chemical Distribution Facilities
January 1999 (EPA 745-B-99-005)
EPCRA Section 313: Guidance for Petroleum Terminals and Bulk Storage Facilities
February 2000 (EPA 745-B-00-002)
EPCRA Section 313: Guidance for Coal Mining Facilities
February 2000 (EPA 745-B-00-003)
EPCRA Section 313: Guidance for Electricity Generating Facilities
February 2000 (EPA 745-B-00-004)
Toxics Release Inventory Reporting Forms and Instructions
H-3
Appendix H
EPCRA Section 313 Reporting Guidance for Food Processors
September 1998 (EPA 745-R-98-011)
EPCRA Section 313 Reporting Guidance for the Leather Tanning and Finishing Industry
April 2000 (EPA 745-B-00-012)
EPCRA Section 313: Guidance for Metal Mining Facilities
January1999 (EPA 745-B-99-001)
Emergency Planning and Community Right-to-Know Act Section 313 Reporting Guidance for the
Presswood and Laminated Products Industry
August 2001 (EPA 260-B-01-013)
EPCRA Section 313 Reporting Guidance for the Printing, Publishing, and Packaging Industry
May 2000 (EPA 745-B-00-005)
EPCRA Section 313: Guidance for RCRA Subtitle C TSD Facilities and Solvent Recovery Facilities
January 1999 (EPA 745-B-99-004)
EPCRA Section 313 Reporting Guidance for Rubber and Plastics Manufacturing
May 2000 (EPA 745-B-00-017)
EPCRA Section 313 Reporting Guidance for Semiconductor Manufacturing
July 1999 (EPA 745-R-99-007)
EPCRA Section 313 Reporting Guidance for the Textile Processing Industry
May 2000 (EPA 745-B-00-008)
EPCRA Section 313 Reporting Guidance for Spray Application and Electrodeposition of Organic
Coatings
December 1998 (EPA 745-R-98-014)
Toxics Release Inventory Reporting Forms and Instructions
H-4
Appendix I. Questions and Answers Regarding
Facility Identification Information
I.1 Categories
This document provides additional information about TRI
reporting procedures based on some frequently asked
questions. The questions and their answers are organized
into three groups:
Section I.2
Section I.3
Section I.4
Identifying the parent company.
Reporting after a change in name or
ownership.
Reporting for multiple sites and/or owners.
I.2 Identifying the Parent
Company
A. Question
When a facility changes ownership after a Form R has
been submitted, who is required to respond to a Notice of
Noncompliance (NON) related to the Form R? Is the
current or prior owner/operator required to respond to the
NON?
A. Answer
The current owner/operator has the primary responsibility
for responding to a NON.
However, all prior
owners/operators back to January 1 of the reporting year
may also be held responsible if the current
owner/operator does not respond to the NON in an
accurate, complete, and timely manner.
(Source: 1998 EPCRA Section 313 Questions and
Answers Document, Question #52 (EPA 745-B-98-004)).
B. Question
Who is the parent company for a 50/50 joint venture?
B. Answer
The 50/50 joint venture is its own parent company.
(Source: 1998 EPCRA Section 313 Questions and
Answers Document, Question #54 (EPA 745-B-98-004)).
C. Question
Mom and Pop Plastics is a wholly owned subsidiary of a
major chemical company which is a wholly owned
subsidiary of Big Oil Corporation, located in St. Paul,
Minnesota. Which is the parent company?
C. Answer
Big Oil Corporation is the parent company.
(Source: 1998 EPCRA Section 313 Questions and
Answers Document, Question #56 (EPA 745-B-98-004)).
I.3 Reporting After a
Change in Name or
Ownership
A. Question
The owner/operator of a covered facility is preparing
Form Rs for a facility. The facility and its parent
company both changed their names after the reporting
year. What names should be reported by the
owner/operator (for both the facility and the parent
company) on the Form Rs covering the reporting year?
A. Answer
The facility should report the names used by the facility
and parent company during that reporting year. When the
owner/operator submits Form Rs for the next reporting
year, these reports should reflect the names used by the
facility and parent company during the new reporting
year. Note that the TRI facility identification number
will not change.
(Source: 1998 EPCRA Section 313 Questions and
Answers Document, Question #614 (EPA 745-B-98004)).
B. Question
If a covered facility does not have a Dun & Bradstreet
(D&B) number but the parent corporation does, should
this number be reported?
B. Answer
Report the D&B number for the facility. If a facility does
not have a D&B number, enter “NA” in Part I, Section
4.7. The corporate D&B number should be entered in
Part I, Section 5.2 relating to parent company
information.
(Source: 1998 EPCRA Section 313 Questions and
Answers Document, Question #621 (EPA 745-B-98004)).
C. Question
In October 2009, Facility X changes ownership and is
purchased by Company Y. For the 2009 reporting year,
which facility is obligated to submit the Form R or Form
A, and whose name and what TRI identification number
should be on the form?
C. Answer
The owner or operator of the facility on the annual July 1
reporting deadline (i.e., Company Y) is primarily
responsible for reporting the data for the entire previous
Toxics Release Inventory Reporting Forms and Instructions
I-1
Appendix I
year’s operations at that facility. Any other owner or
operator of the facility before the reporting deadline may
also be held liable. The form submitted for a given
reporting year must reflect the names used by the facility
and its parent company on December 31 of that reporting
year, even if the facility changed its name or ownership at
any time during the reporting year. In this scenario,
because Facility X changed ownership before December
31 of the reporting year, Company Y’s name should
appear on the form. The TRI identification number is
location-specific; thus, the identification number will stay
the same even if the facility changes names, production
processes, or NAICS codes.
(Source: Monthly Call Center Report Question EPA530R-98---5j; October 1998).
I.4 Reporting for Multiple
Sites and/or Owners
A. Question
If two plants are separate establishments under the same
site management, must they have separate D&B
numbers?
A. Answer
They may have separate D&B numbers, especially if they
are distinctly separate business units. However, different
divisions of a company located at the same facility
usually do not have separate D&B numbers.
(Source: 1998 EPCRA Section 313 Questions and
Answers Document, Question #622 (EPA 745-B-98004)).
B. Question
An electricity generating facility (EGF) is comprised of
multiple independent owners. Each individual owner runs
his/her own separate operation, but each has a financial
interest in the operation of the entire facility. What name
should be entered as the parent company in Part I,
Section 5.1 of the Form R? Should the facility report
under one holding company name?
B. Answer
The EGF should enter in Part I, Section 5.1 of the Form R
the name of the holding or parent company, consortium,
joint venture, or other entity that owns, operates, or
controls the facility.
(Source: Question #2, Addendum to the Guidance
Documents for the Newly Added Industries (EPA 745-B98-001)).
the newly sold establishment and the rest of the facility.
Although the facility makes its threshold determinations
based on the activities at the entire facility (including the
newly sold establishment), the facility chooses to report
separately for the different establishments. What parent
name should the newly sold establishment use, the parent
name of the owner or the parent name of the operator
(i.e., the same as the rest of the facility)?
C. Answer
All establishments of a covered facility must report the
parent name of the facility. Therefore, in the instance
described above, the newly sold establishment should use
the parent name of the facility operator (i.e., the same
parent name the rest of the facility is using).
(Source: Spring Training 1998).
D. Question
Company A purchases a facility from Company B
between January 1, 2006 and June 30, 2006. For the
2005 reporting year, which company’s name and
identification number should appear on the Form R or
Form A submission?
D. Answer
In the case that a facility is purchased between January 1
and June 30, the form submitted for the previous year
must reflect the name used by the facility on December
31 of that reporting year. In this example, company B’s
name should appear on the form because it owned the
facility for the duration of the reporting year. The TRI
identification number is location-specific; thus, the
identification number will stay the same even if the
facility changes names, production processes, or NAICS
codes.
With regard to reporting, the owner or operator of the
facility on the annual July 1 reporting deadline (Company
A) is primarily responsible for reporting the data for the
previous year’s operations at that facility. However, all
prior owners and operators back to January 1 of the year
covered in the report may also be held responsible if the
current owner or operator does not submit a report.
(Source: Monthly Call Center Report Question EPA530R-98---5j; October 1998)
C. Question
A covered facility sells one of its establishments to a new
owner. The operator of the newly sold establishment,
however, does not change. The same operator operates
Toxics Release Inventory Reporting Forms and Instructions
I-2
Appendix I
E. Question
Two distinct NAICS code operations that are covered
under EPCRA Section 313 (e.g., an electricity generating
unit and a cement plant) are located on adjacent
properties and are owned by the same parent company.
The two operations are operated completely
independently of one another (e.g., separate accounting
procedures, employees, etc.). Are these two operations
considered one facility under EPCRA Section 313?
E. Answer
Yes. Under EPCRA Section 313, a facility is defined as,
“all buildings, equipment, structures, and other stationary
items which are located on a single site or on contiguous
or adjacent sites and which are owned or operated by the
same person.” Because these two operations are located
on adjacent properties and are owned by the same person
they are considered one facility for EPCRA Section 313
reporting purposes. Additional information can be found
in the 2009 Toxic Release Inventory Reporting Forms
and Instructions.
F. Question
A piece of contiguous property consists of three covered
sites with various buildings, structures and equipment.
The three sites are owned by two different companies –
Company A and Company B. All three sites operate
completely independently of each other and have separate
personnel, finances, and environmental reporting
systems. Site 1 and its buildings and structures are
owned and operated by Company A and site 3 and its
buildings and structures are owned and operated by
Company B. The middle site, site 2 and its surrounding
buildings and structures, are owned by Company A and
operated by Company B. Are all three sites and their
buildings and structures considered separate facilities
under EPCRA Section 313? Who is responsible for
reporting for each?
F. Answer
Under 40 CFR Section 372.3 a facility is defined as “all
buildings, equipment, structures, and other stationary
items which are located on a single site or on contiguous
or adjacent sites and which are owned or operated by the
same person.” Because all buildings and structures
located on sites 1 and 2 are located on contiguous
property and are owned by the same person, they are
considered one facility. Because all buildings and
structures located on sites 2 and 3 are located on
contiguous property and are operated by the same person,
they are also considered one facility. Therefore, for
purposes of determining thresholds, the toxic chemicals
manufactured, processed, and otherwise used at site 2
must be counted toward both Facility A’s and Facility
B’s threshold determinations. Because the operator is
primarily responsible for reporting, estimating and
reporting releases and other waste management
calculations for sites 2 and 3 are the primary
responsibility of Company B, and the release and other
waste management reporting for site 1 is the primary
responsibility of Company A. EPA allows the release
and other waste management reporting to be done in this
manner to avoid “double counting” releases and waste
management activities at site 2. However, provided
thresholds have been exceeded, if no reports are received
from a covered facility, determinations can be found in
the 2009 Toxic Release Inventory Reporting Forms and
Instructions.
Toxics Release Inventory Reporting Forms and Instructions
I-3
| File Type | application/pdf |
| File Title | Microsoft Word - RFI Main Document_RY2014-Final_111814.docx |
| Author | EdgarE |
| File Modified | 2014-11-20 |
| File Created | 2014-11-19 |