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pdfEPA 740-B-19-037
OMB Control Number: 2070-0212
January 2020
Toxic Chemical Release
Inventory Reporting Forms
and Instructions
Revised 2019 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:
This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C.
3501 et seq. (OMB Control No. 2070-0212). Responses to this collection of information are mandatory
(42 CFR 11023). 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 annual public
burden related to the Form R, which is approved under OMB Control No. 2070-0212 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. 2070-0212 is estimated
to average 21.96 hours per response for a facility filing a report on one chemical. 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, Regulatory Support Division, U.S. Environmental Protection Agency
(2821T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in
any correspondence. Do not send the completed form to this address.
The completed forms should be submitted in accordance with these instructions and as specified in
the corresponding regulation.
Table of Contents
Table of Contents
List of Acronyms................................................................................................................................................ i
Important Information for Reporting Year (RY) 2019 ................................................................................ii
New Information for RY 2019 ...........................................................................................................................ii
Other Important Information ..............................................................................................................................ii
A. General Information.................................................................................................................................... 1
A.1
Who Must Report................................................................................................................................. 1
A.2
How to Submit Forms .......................................................................................................................... 2
A.2.a. TRI-MEweb RY 2019 Version ................................................................................................ 3
A.2.b. How to Begin Using the RY 2019 TRI-MEweb Reporting Tool ............................................. 3
A.2.c. Electronic Signature Agreement............................................................................................... 4
A.2.d. Miscellaneous Information on TRI-MEweb and User Resources ............................................ 6
A.2.e. Confirmation of TRI Submission(s) to EPA ............................................................................ 6
A.2.f. State and Tribal Submissions ................................................................................................... 7
A.3
Trade Secret Claims ............................................................................................................................. 7
A.4
Recordkeeping ..................................................................................................................................... 7
A.5
How to Revise, Withdraw or Cancel TRI Data ................................................................................... 8
A.5.a. Revising TRI Data .................................................................................................................... 8
A.5.b. Withdrawing TRI Data ............................................................................................................. 9
A.5.c. Canceling a TRI Submission .................................................................................................... 9
A.6
When the TRI Report Must Be Submitted ......................................................................................... 10
A.7
How to Obtain the TRI Reporting Forms .......................................................................................... 11
A.8
What to Do If You Do Not Need to Submit any TRI Reports? ......................................................... 11
B.
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Certification Statement ................................................................................................................... 12
B.1
Full-Time Employee Determination .................................................................................................. 12
B.2
Primary NAICS Code Determination ................................................................................................ 14
B.2.a. Auxiliary Facilities ................................................................................................................. 14
B.2.b. Multi-establishment Facilities ................................................................................................ 14
B.2.c. Property Owners ..................................................................................................................... 16
B.2.d. Federal Facilities .................................................................................................................... 16
B.3
Activity Determination ...................................................................................................................... 16
B.3.a. Definitions of Manufacture, Process, and Otherwise Use ...................................................... 16
B.3.b. Persistent Bioaccumulative Toxic (PBT) Chemicals and Chemical Categories Overview.... 20
B.3.c. Activity Exemptions ............................................................................................................... 21
B.4
Threshold Determinations.................................................................................................................. 27
B.4.a. How to Determine if Your Facility Has Exceeded Thresholds .............................................. 28
B.4.b. Threshold Determinations for On-Site Reuse Operations ...................................................... 29
B.4.c. Threshold Determinations for Ammonia ................................................................................ 30
B.4.d. Threshold Determinations for Chemical Categories .............................................................. 30
B.4.e Threshold Determination for Persistent Bioaccumulative Toxic (PBT) Chemicals............... 31
B.4.f. Mixtures and Other Trade Name Products ............................................................................. 31
B.5
Release and Other Waste Management Determinations for Metals, Metal Category Compounds, and
Nitrate Compounds ............................................................................................................................ 32
B.6.
Facility Eligibility Determination for Alternate Threshold and for Reporting on TRI Form A
Certification Statement ...................................................................................................................... 38
B.6.a. Alternate Threshold ................................................................................................................ 38
B.6.b. What is the Form A Certification Statement? ........................................................................ 38
B.6.c. What Is the Annual Reportable Amount (ARA)? .................................................................. 38
Toxics Release Inventory Reporting Forms and Instructions
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Table of Contents
B.6.d. Recordkeeping ........................................................................................................................ 39
B.6.e. Multi-establishment Facilities ................................................................................................ 39
B.6.f. Metals and Metal Category Compounds ................................................................................ 39
Instructions for Completing TRI Forms R and A ....................................................................................... 41
C.
Part I. Facility Identification Information (Form R & A) ........................................................... 41
Section 1.
Reporting Year ...................................................................................................................... 41
Section 2.
Trade Secret Information ...................................................................................................... 41
Section 3.
Certification .......................................................................................................................... 41
Section 4.
Facility Identification ............................................................................................................ 41
4.1
Facility Name, Location, TRI Facility Identification Number and Tribal Country Name ..... 41
4.2
Full or Partial Facility Indication and Federal Facility Designation ...................................... 43
4.3
Technical Contact ................................................................................................................... 44
4.4
Public Contact ........................................................................................................................ 44
4.5
North American Industry Classification System (NAICS) Codes ......................................... 45
4.6
Dun & Bradstreet Number(s) ................................................................................................. 45
Section 5.
Parent Company Information ................................................................................................ 45
5.1
Name of Parent Company ...................................................................................................... 45
5.2
Parent Company’s Dun & Bradstreet Number ....................................................................... 45
D.
Part II. Chemical Identification Information (Form R & A)....................................................... 49
Section 1.
EPCRA Section 313 Chemical Identity (Form R & A) ....................................................... 49
1.1
CAS Number .......................................................................................................................... 49
1.2
EPCRA Section 313 Chemical or Chemical Category Name ................................................ 49
1.3
Generic Chemical Name......................................................................................................... 49
Section 2.
Mixture Component Identity (Form R & A) ......................................................................... 50
2.1
Generic Chemical Name Provided by Supplier...................................................................... 50
Section 3.
Activities and Uses of the EPCRA Section 313 Chemical at the Facility (Form R) ............ 50
3.1
Manufacture the EPCRA Section 313 Chemical.................................................................... 50
3.2
Process the EPCRA Section 313 Chemical ............................................................................ 51
3.3
Otherwise Use the EPCRA Section 313 Chemical (non-incorporative activities) ................. 52
Section 4.
Maximum Amount of the EPCRA Section 313 Chemical On-site at Any Time during the Calendar
Year (Form R) .................................................................................................................................... 54
Section 5.
Quantity of the Toxic Chemical Entering Each Environmental Medium On-site (Form R) 55
5.1
Fugitive or Non-Point Air Emissions ..................................................................................... 56
5.2
Stack or Point Air Emissions .................................................................................................. 56
5.3
Discharges to Receiving Streams or Water Bodies ................................................................ 56
5.4-5.5 Disposal to Land On-site ...................................................................................................... 57
Section 6.
Transfer(s) of the Toxic Chemical in Wastes to Off-Site Locations (Form R)..................... 63
6.1
Discharges to Publicly Owned Treatment Works .................................................................. 63
6.2
Transfers to Other Off-Site Locations .................................................................................... 65
Section 7.
On-Site Waste Treatment, Energy Recovery, and Recycling Methods (Form R) ................ 72
Section 7A: On-Site Waste Treatment Methods and Efficiency ................................................... 72
Section 7B: On-site Energy Recovery Processes .......................................................................... 76
Section 7C: On-site Recycling Processes...................................................................................... 76
Section 8.
Source Reduction and Waste Management (Form R) .......................................................... 79
8.1
On- and Off-Site Disposal and Other Releases ...................................................................... 83
Sections 8.2 and 8.3: Energy Recovery ............................................................................................. 84
Sections 8.4 and 8.5: Recycling ......................................................................................................... 84
Sections 8.6 and 8.7: Treatment ......................................................................................................... 84
8.8
Non-Production-Related Waste .............................................................................................. 85
8.9
Production Ratio or Activity Ratio ......................................................................................... 87
Toxics Release Inventory Reporting Forms and Instructions
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Table of Contents
8.10
Did Your Facility Engage in Any Newly Implemented Source Reduction Activities for This
Chemical During the Reporting Year?.................................................................................. 91
8.11 Optional Pollution Prevention Information ............................................................................ 96
Section 9.
Miscellaneous Information (Form R & A) ........................................................................... 97
9.1
Miscellaneous, Optional, and Additional Information for Your Form R Report ................... 97
9.2
Optional Pollution Prevention and Additional Information for This Toxic Chemical on Your
Form A Certification Statement ............................................................................................ 97
E.
Instructions for Completing Form R Schedule 1 (Dioxin and Dioxin-like Compounds) .......... 99
E.1
What is the Form R Schedule 1?........................................................................................................ 99
E.2
Who is required to file a Form R Schedule 1? ................................................................................... 99
E.3
What information is reported on the Form R Schedule 1? ................................................................ 99
E.4
How do I report Form R Schedule 1 Data?...................................................................................... 101
F.
Optional Facility-Level Information and Non-Reporting .......................................................... 102
Toxics Release Inventory Reporting Forms and Instructions
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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:
Example 29:
Example 30:
Example 31:
Coincidental Manufacture ...................................................................................................... 17
Typical Process and Manufacture Activities .......................................................................... 18
Typical Otherwise Use Activities ........................................................................................... 19
Articles Exemption ................................................................................................................. 22
De Minimis Applications to Process and Otherwise Use Scenarios for Non-PBT
Chemicals ............................................................................................................................... 24
Concentration Ranges Straddling the De Minimis Value ....................................................... 25
De Minimis Application in the Manufacture of a Toxic Chemical in a Mixture .................... 26
Coal mining extraction activities ............................................................................................ 27
Mixtures and Other Trade Name Products ............................................................................. 33
Reporting After a Change in Name or Ownership ................................................................. 43
Identifying the Parent Company ............................................................................................ 46
Reporting for Multiple Sites and/or Owners ......................................................................... 47
Mixture Containing Unidentified EPCRA Section 313 Chemical ......................................... 49
Manufacturing and Processing Activities of EPCRA Section 313 Chemicals ....................... 53
Reporting Dioxins and Dioxin-Like Compounds ................................................................... 55
Stormwater Runoff ................................................................................................................. 62
Container Residue .................................................................................................................. 68
Reporting Metals and Metal Category Compounds that are sent Off-site.............................. 70
Calculating Releases and Other Waste Management Quantities............................................ 74
On-Site Waste Treatment ....................................................................................................... 77
Reporting On-Site Energy Recovery ...................................................................................... 78
Reporting Future Estimates .................................................................................................... 81
Avoiding Double-Counting Quantities in Sections 8.1 through 8.7 ....................................... 85
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). ..................................................... 86
Determining a Production Ratio ............................................................................................. 89
Determining an Activity Ratio .............................................................................................. 89
“NA” is Entered Instead of a Production Ratio or Activity Ratio .......................................... 89
Selecting a Production or Activity Variable ........................................................................... 90
Determining the Production Ratio Based on a Weighted Average ........................................ 90
Source Reduction.................................................................................................................... 94
Green Chemistry..................................................................................................................... 95
Toxics Release Inventory Reporting Forms and Instructions
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Table of Contents
Figures
Figure 1.
Figure 2.
Figure 3.
Figure 4A.
Figure 4B.
Figure 4C.
Figure 4D.
Figure 5.
Figure 6.
Figure 7.
Figure 8.
Figure 9.
TRI-MEweb’s Preparation, Certification and Submission Process and Electronic Signature
Agreement Approval ................................................................................................................ 2
EPCRA Section 313 Reporting Decision Diagram ................................................................ 13
Example of a Multi-Establishment Facility ............................................................................ 15
EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet .......................... 34
EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100-Pound
Thresholds .............................................................................................................................. 35
EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10-Pound
Threshold ................................................................................................................................ 36
EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like
Compounds Chemical Category ............................................................................................. 37
Reporting EPCRA Section 313 Chemicals ............................................................................ 53
Hypothetical Section 6.2 Completed for Two Off-Site Locations ......................................... 71
Hypothetical Section 7A......................................................................................................... 73
Waste Management Hierarchy ............................................................................................... 79
Hypothetical Form R, Section 5.1 and Form R Schedule 1, Section 5.1.............................. 100
Tables
Table I
Table II
Table III
NAICS Codes ........................................................................................................................ I-1
EPCRA Section 313 Chemicals for Reporting Year 2019 (including Toxic Chemical
Categories)............................................................................................................................II-1
Removal and Destruction Rates for POTWs ...................................................................... III-1
Appendices
Appendix A
Trade Secret Submissions.................................................................................................... A-1
Toxics Release Inventory Reporting Forms and Instructions
TOC-5
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
NA
NAICS
NDC
NHD
NON
Annual Reportable Amount
Bureau of Indian Affairs
Chemical Abstracts Service
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 on
Cancer
Information Collection Request
Not Applicable
North American Industry Classification
System
Non-Technical Data Changes
National Hydrography Dataset
Notice of Non-Compliance
NOSE
NOTE
NPDES
NTP
OMB
OSHA
P2
PACs
PBBs
PBT
PCBs
POTW
PPA
RCRA
RSEI
RY
SBREFA
SDS
SIC
TDX
TRI
TRIFID
TRIPS
UIC
USC
USGS
VOCs
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
Administration
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
Safety Data Sheets
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) 2019
Important Information for
Reporting Year (RY) 2019
New Information for RY 2019
Please note that this version of the Toxic Chemical
Release Inventory (TRI) Reporting Forms and
Instructions document supersedes previous versions.
Updated
De
Minimis
Levels
for
N,N-Dimethylformamide,
2-Mercaptobenzothiazole, and Molybdenum
Trioxide Beginning with Reporting Year 2019.
The de minimis levels for N,N-dimethylformamide
(68-12-2), 2-mercaptobenzothiazole (149-30-4), and
molybdenum trioxide (1313-27-5) have been
changed from 1.0% to 0.1% since these chemicals are
now classified as Occupational Safety and Health
Administration (OSHA) carcinogens due to
assessments by the International Agency for
Research on Cancer (IARC).
In addition, to help with tracking and collecting data
for reporting year 2020, be advised that beginning
with reporting year 2020, the de minimis levels for
pyridine (110-86-1) and vinylidene chloride (75-35
4) will be changed from 1.0% to 0.1% as they will
also be classified as OSHA carcinogens due to
assessments by IARC.
Other Important Information
Certain PFAS Chemicals for 2020. Section 7321 of
the National Defense Authorization Act for Fiscal
Year 2020 (P.L. 116-92) (NDAA) added certain Perand Polyfluoroalkyl Substances (PFAS) to the TRI
list. Reporting on these chemicals is effective for
reporting year 2020 so the first reports are due by July
1, 2021, for the 2020 chemical data. A list of these
chemicals is available on the TRI-Listed Chemicals
webpage.
New TRI Chemical Category for 2019. A rule was
published on June 12, 2018 (83 FR 27291), adding a
Nonylphenol Ethoxylates (NPEs) category to the TRI
list of reportable chemicals. Reporting on the new
NPEs category is effective for reporting year 2019 so
the first reports are due by July 1, 2020, for the 2019
chemical data. The NPEs category covers the NPEs
listed below.
CASRN
7311-27-5
9016-45-9
20427-84-3
26027-38-3
26571-11-9
27176-93-8
27177-05-5
27177-08-8
27986-36-3
37205-87-1
51938-25-1
68412-54-4
127087-87-0
Chemical Name
Ethanol, 2-[2-[2-[2-(4
nonylphenoxy)ethoxy]ethoxy]ethoxy]
Poly(oxy-1,2-ethanediyl), α
(nonylphenyl)-ω-hydroxy
Ethanol, 2-[2-(4
nonylphenoxy)ethoxy]
Poly(oxy-1,2-ethanediyl), α-(4
nonylphenyl)-ω-hydroxy
3,6,9,12,15,18,21,24
Octaoxahexacosan-1-ol, 26
(nonylphenoxy)
Ethanol, 2-[2-(nonylphenoxy)ethoxy]
3,6,9,12,15,18,21-Heptaoxatricosan-1
ol, 23-(nonylphenoxy)
3,6,9,12,15,18,21,24,27
Nonaoxanonacosan-1-ol, 29
(nonylphenoxy)
Ethanol, 2-(nonylphenoxy)
Poly(oxy-1,2-ethanediyl), α
(isononylphenyl)-ω hydroxy
Poly(oxy-1,2-ethanediyl), α (2
nonylphenyl)-ω-hydroxy
Poly(oxy-1,2-ethanediyl), α
(nonylphenyl)-ω-hydroxy-, branched
Poly(oxy-1,2-ethanediyl), α-(4
nonylphenyl)-ω-hydroxy-, branched
TRI
Chemical
Category:
Hexabromocyclododecane (HBCD) Category A
rule was published on November 28th, 2016 (80 FR
85440), adding an HBCD category to the TRI list of
reportable chemicals that covers HBCD as identified
through two primary Chemical Abstracts Service
Registry Numbers (CASRNs): 1,2,5,6,9,10
hexabromocyclododecane
(3194-55-6)
and
hexabromocyclododecane (25637-99-4).
TRI Chemical: 1-Bromopropane. A rule was
published on November 23, 2015 (80 FR 72906),
adding 1-bromopropane (106-94-5) to the TRI list of
reportable chemicals.
2018 Information Collection Request (ICR) –
Updates to the TRI Reporting Forms. Below is a
summary of changes to the TRI Reporting Forms and
Instructions in the 2018 TRI ICR Renewal.
• The Bureau of Indian Affairs (BIA) code is
now a separate element on the Form R and
Form A Certification Statement.
•
A facility must now indicate if it is filing a
combined form for an elemental metal and a
Toxics Release Inventory Reporting Forms and Instructions
ii
Important Information for Reporting Year (RY) 2019
metal compound containing the same
elemental metal.
• Activities and Uses of the EPCRA Section
313 Chemical at the Facility section on the
Form R now requires a facility to indicate
more specific subcategories for certain
processing and otherwise use activities.
• “Recycling” is now an activity under
processing in Part II, Section 3.2.
• A facility may indicate that on-site disposal
includes quantities of the chemical being
managed in “waste rock piles.”
• New management codes for transfers of
waste to POTWs for Part II, Section 6.1
reporting.
• New barrier code for use when a reduction
does not appear to be technically feasible
(Part II: Section 8.11).
• Form A Certification now provides a field
for providing optional information on each
chemical listed (Part II: Section 9.2).
2017 TRI NAICS Revision. A final rule was
published in the Federal Register on December 26,
2017 (82 FR 52674), to adopt 2017 NAICS codes.
Table I lists all NAICS industries that are covered
under EPCRA 313 and their corresponding codes.
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
including P2 data at the corporate level. To learn
more, visit: https://www.epa.gov/toxics-release
inventory-tri-program/pollution-prevention-p2-and
tri
GuideME. EPA now provides TRI guidance
materials via GuideME. GuideME provides
consolidated, searchable access to TRI guidance
materials, including Questions and Answers
guidance, Reporting Forms & Instructions, Chemical
and Industry Guidance Documents, Training Slides,
and other materials. You may access these guidance
materials through your Web browser or download the
materials as PDFs.
Facilities May Submit Optional Facility Level
Information in TRI-MEweb Without Submitting
a Form R or Form A Certification Statement. You
can 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 use TRIMEweb to indicate that your facility will no longer
be reporting to TRI or will not be submitting a form
for one or more specific TRI-listed chemicals for the
current reporting year.
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), April 11, 2000 (65 FR
19618). 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:
https://www.epa.gov/compliance/epas-audit-policy.
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). 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
Toxics Release Inventory Reporting Forms and Instructions
iii
Important Information for Reporting Year (RY) 2019
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:
https://www.epa.gov/compliance/small-business
compliance.
Parent Company Information. In past years, the
Agency found that many facilities report inaccurate
parent company names 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 examples 10, 11, and 12.
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:
https://ofmpub.epa.gov/apex/guideme_ext/f?p=guid
eme:rfi-home.
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 Certification Statement, go to:
https://www.dnb.com/duns-number/lookup.html
or call 1-844-229-8664 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
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.
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 one-time events of EPCRA Section 313
chemicals, as well as the maximum amount of the
EPCRA Section 313 chemical on-site during the
calendar year and the amount contained in wastes
managed on-site or transferred off-site.
A completed Form R or Form A Certification
Statement 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 Certification Statement)).
The Electronic Reporting Rule was published in the
Federal Register on August 27, 2013 (78 FR 52860),
and requires that all forms be submitted
electronically. Reports that are not submitted
electronically using TRI-MEweb will not be
processed as acceptable 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.
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.
A.1
Who Must Report
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; 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.
In 1993, Executive Order 12856 extended these
reporting requirements to federal facilities,
regardless of their SIC or NAICS code. Subsequent
Executive Orders have not changed this requirement.
Toxics Release Inventory Reporting Forms and Instructions
1
General Information
Figure 1. TRI-MEweb’s Preparation, Certification and Submission Process and Electronic
Signature Agreement Approval
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.
TRI-MEweb via the online reporting application’s
Upload XML feature. More information on the
Upload XML feature can be found by watching this
tutorial
video:
https://www3.epa.gov/tri/tutorials/TRIT
39/index.html.
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
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
A.2
How to Submit Forms
Toxics Release Inventory Reporting Forms and Instructions
2
General Information
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 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
and tribes participating in TDX are shown on this
website:
https://www.epa.gov/toxics-release-inventory-tri
program/tri-data-exchange.
Please be aware that if your facility does not reside in
a state or tribe participating in 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 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 TRI-MEweb 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.
A.2.a. TRI-MEweb RY 2019 Version
Facilities use TRI-MEweb to fulfill their Emergency
Planning and Community Right-to-Know (EPCRA)
Section 313 and Pollution Prevention Act (PPA)
Section 6607 reporting obligations. TRI-MEweb is
an interactive, intelligent, user-friendly 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)) TRI-MEweb allows
facilities to submit, revise, and withdraw TRI
reporting forms for RYs 1991 through the current
reporting year, provided the forms do not contain
trade secret information.
A.2.b. How to Begin Using the RY 2019
TRI-MEweb Reporting Tool
TRI-MEweb is accessed through EPA’s Central
Data Exchange (CDX). The TRI-MEweb
application uses EPA’s CDX network to certify and
submit electronic submissions to EPA. CDX allows
facilities to submit a paperless report and receive
instant confirmation receipt of their submission. TRIMEweb supports most Web browsers; however,
should you encounter any problems in accessing
CDX or TRI-MEweb, consult the TRI-MEweb
Resource webpage:
https://www.epa.gov/toxics-release-inventory-tri
program/tri-meweb-resources.
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 certifies the data
contained in the submitted TRI Form R or Form A
Certification Statement in TRI-MEweb to both EPA
and their state or tribe. Certifying officials may also
prepare forms, but the preparer cannot certify TRI
forms. Both TRI roles require a CDX user account
with the TRI-MEweb application added to the
MyCDX profile. Step-by-step instructions for
creating CDX user accounts for new preparers or
certifying officials can be found on the TRI-MEweb
Resources webpage: https://www.epa.gov/toxics
release-inventory-tri-program/tri-meweb-resources.
Establishing a CDX account and getting started in
TRI-MEweb as a new preparer or certifying official.
• Access the CDX login web page at
https://cdx.epa.gov/. Click the Register with
CDX link to begin creating a new CDX user
account.
• When registering with CDX, search for
TRI-MEweb when adding a Program
Service to your account.
• Note that CDX passwords expire after 90
days. Please provide answers to the three
Toxics Release Inventory Reporting Forms and Instructions
3
General Information
security questions that you can easily
remember.
• All certifying officials must submit an
Electronic Signature Agreement (ESA)
form to EPA for approval before certifying
and submitting TRI forms. If you are
registering as a certifying official, then
please review the Electronic Signature
Agreement section below to learn how to
become authorized to certify and submit
TRI reporting forms.
• Users that already have a CDX account for
other EPA reporting programs and have
never reported to TRI before will only need
to add TRI-MEweb by clicking the
“Manage Your Program Services” link on
their MyCDX page. This will enable TRI
reporting through their CDX account.
Linking your new CDX account to an existing TRI
facility in TRI-MEweb. If your facility has
submitted a TRI reporting form for a prior reporting
year, it will already have a TRI Facility Identification
Number (TRIFID) assigned to it. You should not
create a new TRIFID for your facility if the facility
has previously submitted a TRI reporting form.
In TRI-MEweb, you can also load information about
an existing TRI facility by providing the technical
contact information and TRIFID used on a report
from the prior reporting year. Or, you can enter an
access key for your facility. In TRI-MEweb, you may
request that the facility access key be emailed to you.
Additionally, the person who previously prepared or
certified forms for your facility can use TRI-MEweb
to send the access key via email to allow a preparer
or certifying official to connect to an existing facility.
You can also contact the CDX Help Desk at (888)
890-1995 to obtain an access key.
A.2.c. 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 “Forms” tab and then to the “Pending Forms”
subtab in TRI-MEweb to find pending submission(s)
that are ready to be certified.
ESAs are created when a user creates a new CDX
account with a certifying official role. 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 identityverification vendor to obtain an ESA electronically.
(Note: the use of third-party verification and
identification widgets is common in banking
systems.) 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 third-party identity
verification is that users will no longer need to wait
up to 5 business days for EPA to approve a paper
ESA. If the certifying official does not wish to
provide personal information to a third-party vendor,
he or she should print and mail a paper ESA form to
the TRI Data Processing Center instead well ahead of
the July 1 reporting deadline.
A significant advantage of this 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 real-time
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.
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,
p.2) for approval before the certifying official can
certify any TRI forms completed by the preparer in
CDX using TRI-MEweb. Hard copy ESA approval
may take up to five business days, so please plan
accordingly or consider option one, LexisNexis.
Access to the TRI-MEweb application on the
MyCDX page is activated when the ESA is approved.
Toxics Release Inventory Reporting Forms and Instructions
4
General Information
Paper ESAs can be mailed to the address below:
Attention: TRI ESA Approval Request
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 22038
The hard copy ESA approval process requires the
printing, completion, and mailing of an electronic
signature agreement 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. Certifying officials who do not have
a signed electronic or hard copy ESA that has been
approved by the DPC will not be able to certify forms
in TRI-MEweb. It is recommended that certifying
officials complete their ESA well in advance of the
July 1 reporting deadline.
Accidental deletion of ESA in TRI-MEweb. The
TRI-MEweb application 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 TRIMEweb.
TRIFID Signature Agreement. In addition to the
ESA requirement, new certifying officials must sign
a TRIFID Signature Agreement for each facility they
represent for TRI reporting. By signing the TRIFID
Signature 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
Signature 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 for which a TRIFID Signature
Agreement was previously signed. 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. However, all newly added facility
accounts will only require a TRIFID Signature
Agreement to be signed.
A certifying official must have an approved ESA
before they can log into TRI-MEweb. Once in TRIMEweb, the certifying official should click on the
“Facility Management” tab to access the Manage
TRIFID Signature Agreements page, where a list of
TRIFIDs pending a TRIFID Signature Agreement is
displayed. Select the check box next to the facility’s
TRIFID in the “Pending Signature” table and click
the “Sign Agreement” button. If your facility
account is not visible in the “Signature Receive”
section, click the “Add Facility” button to
incorporate your missing facility account using the
access key code method. Review the TRIFID
Signature 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 the “Sign” button.
A confirmation box will appear, noting the successful
signature.
ESA and TRIFID Signature Agreement Status in
TRI-MEweb. The ESA and TRIFID Signature
Agreement status of the certifying official(s)
assigned to each facility is listed under the “Status”
column on the “Manage Users” page in TRI-MEweb.
•
•
•
•
No CDX ESA indicates that no
A status of
certifying officials have been associated with a
facility account.
A status of
Sign CDX ESA indicates that the
new certifying official has not signed an ESA.
The certifying official must sign a new CDX
ESA.
Sign TRIFID Signature
A status of
Agreement indicates that the certifying official
has obtained approval of the CDX ESA, but still
needs to sign the TRIFID Signature Agreement
within the TRI-MEweb application to a facility
account.
Active Certifying Official
A status of
Available indicates that your assigned
certifying official has received approval of the
ESA, signed the TRIFID Signature Agreement,
and is ready to certify any pending forms
completed by the preparer for a specific facility
account.
Toxics Release Inventory Reporting Forms and Instructions
5
General Information
A.2.d. Miscellaneous Information on
TRI-MEweb and User Resources
Resetting CDX Passwords. CDX passwords expire
after 90 days. You will likely need to reset your
password. Click the Forgot your password? link to
reset your password. If you do not remember the
answers you provided to the security questions you
completed when you registered with CDX then you
will need to contact the CDX Help Desk at (888) 890
1995. Once you have successfully logged into your
CDX account, you may edit the answers to your
security questions by clicking the “My Profile” tab
on the MyCDX webpage.
Import previous year data into current year
chemical forms. TRI-MEweb can import certain
data fields provided for the prior year data (if RY
2017 data were provided by the facility in the
previous year) into each selected current year TRI
chemical forms. 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 TRIMEweb will result in the data being overwritten by
the imported data fields.
Error checker software in TRI-MEweb. Once data
entry has been completed or data has been imported
into TRI forms using TRI-MEweb, you must click
the “Check for Errors” button to begin the error
checking software in TRI-MEweb.
Processing TRI forms for Certification. Once you
have check for errors using TRI-MEweb’s Error
Checking procedures and have passed with no
detectable critical errors, you can proceed to
designate a certifying official to review your
completed TRI forms who will then be able to log
into TRI-MEweb to review and digitally sign the
forms. A certifying official can cancel a form to
return it to an editable form should a correction to the
form be necessary. If no corrections are needed and
the certifying official is ready to submit the form to
EPA, the certifying official can digitally sign the
form and submit it. To sign and submit a TRI
reporting form the certifying official will need to
answer to a security question or use a SMS text
verification service to verify identity. An email from
CDX will confirm that the form has been properly
certified and submitted
Uncertified TRI-MEweb Submissions. A facility’s
registered certifying official must electronically sign
Form R and/or Form A Certification Statements via
TRI-MEweb before the submission is considered
complete.
Uncertified TRI-MEweb 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. Uncertified TRI forms do not
satisfy the requirements of the TRI Program. Failure
to adhere to the requirements of section 313 of
EPCRA and its implementing regulations could
result in an EPA enforcement action against a
facility.
TRI-MEweb User Resources
•
TRI-MEweb website:
https://www.epa.gov/toxics-release-inventory
tri-program/tri-meweb-resources.
Service notifications and reference materials for
reporting are posted on this webpage.
•
TRI-MEweb online tutorials:
https://www.epa.gov/toxics-release-inventory
tri-program/training.
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) 890-1995.
These hotlines provide regulatory reporting
assistance and CDX/TRI-MEweb technical support
to TRI reporting facilities.
A.2.e. Confirmation of TRI
Submission(s) to EPA
You can confirm that you have properly submitted
your TRI Form R and Form A Certification
Statement by the following methods:
TRI-MEweb: Confirmation of your Federal and
State/Tribal submission can be found on the
Submission History tab in the TRI-MEweb
application.
CDX Email: A CDX email is sent to the registered
email address of the certifying official, preparer and
technical contact of the reporting facility after the
form has been certified in TRI-MEweb. If you have
not received a confirmation email, verify that your
registered email address has not changed or that the
Toxics Release Inventory Reporting Forms and Instructions
6
General Information
CDX email is not being diverted to another inbox by
your junk/spam email filter.
Electronic Receipt (e-Receipt). After a form is
certified and submitted it goes through additional
data quality checks. Once the form clears these
checks, which may take several days, it enters EPA’s
TRI database. Once this happens, you will be able to
access an e-Receipt report in TRI-MEweb by
reviewing the “Submission History” tab in TRIMEweb (formerly known as electronic Facility Data
Profile or eFDP).
If the facility’s Technical Contact provides an email
address in the Form R/Form A Certification
Statement, they will also receive an email notifying
them when their e-Receipt has been published for
review in TRI-MEweb. Please Note: the technical
contact will typically receive this email following the
certification and submission of a form; however, data
quality checks performed after submittal of the form
could delay for several days the sending of this eReceipt email.
A.2.f. State and Tribal Submissions
Facilities that reside in a state or tribe participating in
the TRI Data Exchange (TDX) will have their RY
2005 - 2019 forms sent simultaneously to EPA and
their state or tribal TRI representative in electronic
format. Find which states are participating in TDX at:
https://www.epa.gov/toxics-release-inventory-tri
program/tri-data-exchange
If the facility is in a state that is not in TDX, 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: https://www.epa.gov/toxics-release
inventory-tri-program/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:
https://www.epa.gov/toxics-release-inventory-tri
program/tri-state-contacts 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 Certification
Statement 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 accessible via this webpage:
https://www.epa.gov/data-standards/tribalidentifier-data-standard.
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 transmit pre-RY
2005 TRI forms.
A.3
Trade Secret Claims
A trade secret claim may be submitted to prevent
disclosure of the identity of an EPCRA Section 313
chemical. See Appendix A for instructions on
preparing and submitting trade secret claims. Note
that trade secret submissions must be on paper and
that TRI-MEweb does not support the preparation of
trade secret TRI reporting forms.
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
Toxics Release Inventory Reporting Forms and Instructions
7
General Information
on a facility’s Form R or Form A Certification
Statement, EPA may request documentation from the
facility that supports the information reported.
EPA may conduct data quality reviews of Form R or
Form A Certification Statement 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.
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
Certification Statement. These CDX documents
include the Electronic Signature Agreement (ESA)
and the facility’s unique alphanumeric access key.
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
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 How to Revise, Withdraw or
Cancel TRI Data
A.5.a. 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
database called the Toxics Release Inventory
Processing System (TRIPS), and made available to
the public through Envirofacts and TRI Explorer.
Facilities may only revise TRI reporting forms
submitted for RY 1991 through the current reporting
year and must do so using TRI-MEweb.
Facilities may request a revision for one or more of
the following reasons:
Revision codes:
•
•
•
•
•
RR1 - New Monitoring Data
RR2 - New Emissions 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
Certification Statement 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
Toxics Release Inventory Reporting Forms and Instructions
8
General Information
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, send revised
report(s) to EPA and the appropriate state or tribal
agency.
Use TRI-MEweb to submit revisions to 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 TRI-MEweb
Tutorials at:
https://www.epa.gov/toxics-release-inventory-tri
program/electronic-submission-tri-reporting-forms.
A.5.b. 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.
Use TRI-MEweb to withdraw TRI reporting forms
submitted for RY 1991 through the current reporting
year.
Facilities may request a withdrawal for one or several
reasons, such as:
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)
How do I withdraw my submission(s)?
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 - 2019 forms will be
automatically submitted to states participating in 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 remove 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, you should revise the form
rather than withdraw and resubmit the form.
Use TRI-MEweb to withdraw TRI forms from RY
1991 through the current year. Withdrawals can only
be done for TRI submissions that have been properly
completed, certified and processed by EPA. If you
have questions about using TRI-MEweb to withdraw
your Form R/A, please refer to the TRI-MEweb
Tutorials at:
https://www.epa.gov/toxics-release-inventory-tri
program/electronic-submission-tri-reporting-forms/.
A.5.c. 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.
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. To edit a TRI form in TRIMEweb that is pending certification to CDX, the
preparer will need to cancel the submission with a
Pending Certification status in order to make the
additional corrections in TRI-MEweb and reprocess
the original submission or revision to be certified.
EPA is considering issuing a Notice of Non
compliance for TRI Forms that have been completed
but are not certified.
A preparer or a certifying official cannot cancel a TRI
form submission that has already been 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 edited or corrected. To change or
remove data that has already been 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.
Toxics Release Inventory Reporting Forms and Instructions
9
General Information
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), 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 “Forms Home” subtab under the “Forms”
tab, choose the Reporting Year corresponding to the
unwanted submission(s), expand the form summary
table by clicking the “+” sign, and select the “delete”
button for the chemical form to be cancelled from the
Forms page. Note: Only forms with a Pending
Certification status can be canceled. In addition, 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 (forms that have been assigned
a certifying official). The certifying official must log
into their CDX account and click the TRI-MEweb:
TRI Made Easy –link from their MyCDX page. This
will open the Welcome page of the TRI-MEweb
application. Then select the “Forms” tab and then the
“Pending Forms” subtab. If the certifying official
does not find the TRIFID for their reporting facility
with pending submissions listed, they can gain access
to the facility by entering the access key for the
facility listed in the Pending Authentication section
on the Manage Facilities page and signing the
TRIFID Signature Agreement on the Manage
TRIFIDs Signature Agreement 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 Forms page under the “Forms” tab.
You may view the content of the submission by
clicking the “Check for Errors” page and navigating
to the Passed Forms section to confirm that this is the
correct submission to be cancelled. Select the
“Cancel” button to cancel the submission.
A.6 When the TRI Report Must Be
Submitted
As specified in EPCRA Section 313, the Form R or
Form A Certification Statement report for any
calendar year must be submitted on or before
midnight on July 1 of the following year. 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).
Voluntary revisions to a report can be submitted
anytime during the calendar year for the current or
any prior reporting year. However, voluntary
revisions for the current reporting year must be
submitted by July 31 in order to be included in that
year’s TRI National Analysis.
Can I submit a paper form if I cannot certify
forms before the July 1 deadline? 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.
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). There is a legal obligation to file an
accurate and complete Form R or Form A
Certification Statement for each chemical by July 1
each year if TRI reporting is required, and EPA may
take enforcement action and assess civil
administrative penalties for late or inaccurate
submissions.
If a facility could not process their ESA on time,
should their certifying official still certify
electronically after the July 1 deadline? Yes. EPA
encourages facilities to have a certifying official
complete an ESA well before the July 1 deadline.
Additionally, EPA provides a real-time ESA
approval method in CDX that will allow most
certifying officials instantaneous ESA approval to
allow for ESA approval ahead of the July 1 deadline
(see A.2.c Electronic Signature Agreement above for
more details). However, if a certifying official cannot
certify prior to the July 1 deadline because they do
not have an approved ESA in place, they should log
into CDX once it becomes approved by EPA and
certify any pending forms(s). They may also call the
CDX Helpdesk for support using the real-time ESA
option. There is a legal obligation to file an accurate
and complete Form R or Form A Certification
Statement for each chemical by July 1 each year if
TRI reporting is required, and EPA may take
Toxics Release Inventory Reporting Forms and Instructions
10
General Information
enforcement action and assess civil administrative
penalties for late or inaccurate submissions.
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 GuideME
website at:
https://ofmpub.epa.gov/apex/guideme_ext/f?p=guid
eme:rfi-home.
However, non-trade-secret TRI reporting forms must
be submitted to EPA using TRI-MEweb. Except for
trade secrets, 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.
A.8 What to Do If You Do Not Need
to Submit any TRI Reports?
If a facility does not exceed an activity threshold for
a listed toxic chemical, or is not in a covered NAICS
code, or does not have 10 or more full-time employee
equivalents, it is not required to report under EPCRA
Section 313 (see Section B. How to Determine if
Your Facility Must Submit a Form R or Is Eligible
to Use Form A for more information on TRI
reporting thresholds). Further, such a facility is not
required to maintain any records associated with its
uses, releases, or other waste management activities
involving listed toxic chemicals. Such facilities, may
still want to keep records of the amounts of listed
toxic chemicals they manufacture, process, or
otherwise use in order to defend against any claim
that they failed to report.
To avoid future auditing, a facility may choose to
provide voluntary information to EPA about the
reason they are not reporting to EPA. TRI-MEweb
can also be used by a facility to indicate that it is not
reporting. Open the TRI-MEweb application. To
indicate that you are not reporting for one or more
chemicals, go to the “My TRI” page, click the
“Facility Management” tab; select the “Manage
Facilities” subtab. Click the “Take Action”
dropdown menu for the facility providing voluntary
information and then select the “Not Reporting?”
option. You can also access the page to provide
voluntary information via the “Not Reporting?”
section of TRI-MEweb’s home page.
See
Section F. Optional Facility-Level
Information and Non-Reporting for more
information on how to inform EPA that you will not
be submitting one or more reporting forms for the
current reporting year.
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.
How to Determine if Your
Facility Must Submit a
Form R or Is Eligible to Use
the Form A Certification
Statement
This section will help you determine whether you are
required to 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, and divide the
total by 2,000 hours. The result is the number of fulltime 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 tenemployee threshold.
Examples:
• A facility consists of 11 employees who
each worked 1,500 hours for the facility in a
calendar year. Consequently, the total
number of hours worked by all employees
for the facility during the calendar year is
16,500 hours. The number of full-time
employees for this facility is equal to 16,500
hours divided by 2,000 hours per full-time
employee, or 8.3 full-time employees.
Therefore, even though 11 persons worked
for this facility during the calendar year, the
number of hours worked is equivalent to 8.3
full-time employees. This facility does not
meet the employee criteria and is not
subject to EPCRA Section 313 reporting.
• Another facility consists of six workers and
three sales staff. The six workers each
worked 2,000 hours for the facility during
the calendar year. The sales staff also each
worked 2,000 hours during the calendar
year, although they may have been on the
road half of the year. In addition, five
contract employees were hired for a period
during which each worked 400 hours for the
facility. The total number of hours is equal
to the time worked by the workers (12,000
hours), plus the time worked by the sales
staff for the facility (6,000 hours), plus the
time worked by the contract employees
(2,000 hours), or 20,000 hours. Dividing the
20,000 hours by 2,000 yields 10 full-time
employees. This facility has met the fulltime employee criteria and may be subject
to reporting if the other criteria are met.
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
Figure 2. EPCRA Section 313 Reporting Decision Diagram
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
B.2 Primary NAICS Code
Determination
The facility should determine its own NAICS
code(s), based on its on-site activities 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/
or referring to the 2017 NAICS Definitions at:
https://www.census.gov/eos/www/naics/2017NAIC
S/2017_NAICS_Manual.pdf.
For purposes of EPCRA Section 313 reporting, state
assigned codes should not be used if they differ from
codes assigned in the NAICS Manual.
The full list of 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 on the TRI
website
:
https://www.epa.gov/toxics-release
inventory-tri-program/my-facilitys-six-digit-naics
code-tri-covered-industry.
The TRI Program began requiring North American
Industry Classification System (NAICS) codes
instead of Standard Industrial Classification (SIC)
codes in Reporting Year 2006. 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).
A final rule was published in the Federal Register on
December 26, 2017 (82 FR 52674), to adopt 2017
NAICS codes for RY 2017 and subsequent reporting
years.
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 the 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. The TRI
Program has adopted NAICS codes 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 an 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
(see Figure 3).
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
Multi-Establishment Facility: Three separate establishments located on contiguous/adjacent property
owned by same person(s), is one facility under EPCRA (40 CFR §§ 372.22 and 372.3)
Figure 3. Example of a Multi-Establishment Facility
The value added of production or service attributable
to an 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. The value added may be
defined as:
Equation 1
𝑣𝑣𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎 𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎
= 𝑠𝑠𝑎𝑎𝑠𝑠(𝑣𝑣𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎 𝑜𝑜𝑜𝑜 𝑝𝑝𝑝𝑝𝑜𝑜𝑎𝑎𝑎𝑎𝑝𝑝𝑝𝑝𝑠𝑠 𝑎𝑎𝑒𝑒𝑒𝑒𝑝𝑝𝑒𝑒𝑒𝑒𝑒𝑒 𝑝𝑝ℎ𝑎𝑎 𝑜𝑜𝑎𝑎𝑝𝑝𝑒𝑒𝑎𝑎𝑒𝑒𝑝𝑝𝑓𝑓)
− 𝑠𝑠𝑎𝑎𝑠𝑠(𝑣𝑣𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎 𝑜𝑜𝑜𝑜 𝑝𝑝𝑝𝑝𝑜𝑜𝑎𝑎𝑎𝑎𝑝𝑝𝑝𝑝𝑠𝑠 𝑎𝑎𝑒𝑒𝑝𝑝𝑎𝑎𝑝𝑝𝑒𝑒𝑒𝑒𝑒𝑒 𝑝𝑝ℎ𝑎𝑎 𝑜𝑜𝑎𝑎𝑝𝑝𝑒𝑒𝑎𝑎𝑒𝑒𝑝𝑝𝑓𝑓)
This procedure eliminates the potential for “double
counting” production and services in situations
where establishments are engaged in sequential
production or service activities at a single facility.
Examples include:
• A facility in coating, engraving and allied
services has two establishments. The first
establishment, a general automotive repair
service, is in NAICS code 811113 (SIC
7537), which is not a covered NAICS code.
However, the second establishment, a metal
paint shop is in NAICS code 332812 (SIC
3479, which is a covered NAICS code). The
metal paint shop paints the parts received
from general automotive repair service. The
facility determines the product is worth
$500/unit as received from the general
automotive repair service (in non-covered
NAICS code 811113) and the value of the
product is $1500/unit after processing by
the metal paint shop (in covered NAICS
code 332812). The value added by the metal
paint shop is obtained by subtracting the
value of the products from the general
automotive repair service from that of the
value of the products of the metal paint
shop. (In this example, the value added =
$1,500/unit - $500/unit = $1,000/unit.) The
value added ($1,000/unit) by the
establishment in NAICS code 332812 is
more than 50 percent of the product value.
Therefore, the facility’s primary NAICS
code is 332812, which is a covered NAICS
code.
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
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, 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. Note
that establishments report using the same TRIFID
that is used for the entire multi-establishment facility.
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.2.d. Federal Facilities
In 1993, pursuant to an Executive Order (EO), federal
facilities began complying with Section 313 of
EPCRA regardless of their primary North American
Industry Classification System (NAICS) code.
Subsequent EOs reinforced this requirement. As a
result, all federal facilities, regardless of NAICS
code, must report if they meet the employee and
chemical activity thresholds. See the Federal Facility
Reporting Information guidance document for
additional information on Federal Facility reporting
requirements.
B.3
Activity Determination
B.3.a. Definitions of Manufacture,
Process, and Otherwise Use
Manufacture: The term “manufacture” means to
produce, prepare, compound, or import an EPCRA
Section 313 chemical. (See Part II, Section 3.1 of
these instructions for further clarification.)
Import is defined as causing the EPCRA Section 313
chemical to be imported into the customs territory of
the United States. If you order an EPCRA Section
313 chemical (or a mixture containing the chemical)
from a foreign supplier, then you have imported the
chemical when that shipment arrives at your facility
directly from a source outside of the United States.
By ordering the chemical, you have caused it to be
imported, even though you may have used an import
brokerage firm as an agent to obtain the EPCRA
Section 313 chemical.
Do Not Overlook Coincidental Manufacture:
The term “manufacture” also includes coincidental
production of an EPCRA Section 313 chemical (e.g.,
as a byproduct or impurity) as a result of the
manufacture, processing, otherwise use or disposal of
another chemical or mixture of chemicals. In the case
of coincidental production of an impurity (i.e., an
EPCRA Section 313 chemical that remains in the
product that is distributed in commerce), the de
minimis exemption, discussed in Section B.3.c of
these instructions, applies. The de minimis exemption
does not apply to byproducts (e.g., an EPCRA
Section 313 chemical that is separated from a process
stream and further processed or disposed 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.
Process: The term “process” means the preparation
of a listed EPCRA Section 313 chemical, after its
manufacture, for distribution in commerce.
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
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
17
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.
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
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
19
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 dioxin-like compounds if
the dioxin and dioxin-like compounds are present as
contaminants in a chemical and if they were created
during the manufacturing of that chemical.”
EPA has added six individual chemicals to the
EPCRA Section 313 list of toxic chemicals that also
had their thresholds lowered:
•
•
•
•
•
•
benzo(g,h,i)perylene,
benzo(j,k)fluorene (fluoranthene),
3-methylcholanthrene,
octachlorostyrene,
pentachlorobenzene, and
tetrabromobisphenol A (TBBPA).
Benzo(j,k)fluorene and 3-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
20
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Lead and Lead Compounds
Lead and lead compounds are classified as PBT
chemicals and are subject to the lower
manufacturing, processing and otherwise use
threshold of 100 pounds. However, when lead is
contained in stainless steel, brass, or bronze alloys it
remains subject to the higher 25,000 pound
manufacturing and processing thresholds and the
10,000 pound otherwise use threshold.
Listed below are some important guidelines to use
when calculating 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 Certification Statement eligibility for nonPBTs, 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 non-alloyed lead, the facility may
consider the Form A requirements for nonPBTs, range reporting in Sections 5 and 6 of the
Form R, and the use of whole numbers and 2
significant digits.
• 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.
B.3.c. Activity Exemptions
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.
Otherwise Use Exemptions. Certain otherwise uses
of listed EPCRA Section 313 chemicals are
specifically exempted:
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
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
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 preclude 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
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
list of PBT chemicals may be found in Section B.4 of
these instructions.
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 nonPBT EPCRA Section 313 chemical in a mixture or
other trade name product is manufactured as an
impurity, imported, processed, or otherwise used and
is below the appropriate de minimis concentration
level, then the quantity of the non-PBT EPCRA
Section 313 chemical in that mixture or other trade
name product does not have to be applied to threshold
determinations nor included in release or other waste
management determinations. If a non-PBT EPCRA
Section 313 chemical in a mixture or other trade
name product is below the appropriate de minimis
level, all releases and other waste management
activities associated with the EPCRA Section 313
chemical in that mixture or other trade name product
are exempt from EPCRA Section 313 reporting. It is
possible to meet an activity (e.g., processing)
threshold for an EPCRA Section 313 chemical on a
facility-wide basis, but not be required to calculate
releases or other waste management quantities
associated with a particular process because that
process involves only mixtures or other trade name
products containing the non-PBT EPCRA Section
313 chemical below the de minimis level.
EPA interprets the de minimis exemption such that
once a non-PBT EPCRA Section 313 chemical
concentration is at or above the appropriate de
minimis level in the mixture or other trade name
product threshold determinations and release and
other waste management calculations must be made,
even if that chemical later falls below the de minimis
level in the same mixture or other trade name
product. Thus, EPA considers reportable all releases
and other quantities managed as waste that occur
after the de minimis level has been met or exceeded.
If an EPCRA Section 313 chemical in a mixture or
other trade name product at or above de minimis is
brought on-site, the de minimis exemption never
applies.
De minimis levels for non-PBT EPCRA Section 313
chemicals and chemical categories are set at
concentration levels of either 1 percent or 0.1 percent;
PBT chemicals and chemical categories do not have
de minimis levels with regard to this exemption. The
0.1 percent de minimis levels are dictated by
determinations made by the National Toxicology
Program (NTP) in its Annual Report on Carcinogens,
the International Agency for Research on 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 nonPBT EPCRA Section 313 chemical never equals or
goes above the de minimis limit.
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
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)
The exemption also applies to non-PBT EPCRA
Section 313 chemicals that are manufactured as
impurities that remain in the product distributed in
commerce below the de minimis levels. The 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 the
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.
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
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 SDS 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 = 26,400 pounds manganese
×
(1.2% − 0.2%)
(2)
(which is above the processing threshold for manganese)
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
Example 7: De Minimis Application in the Manufacture of a Toxic Chemical in a Mixture
Manufacture as a Product Impurity
Toluene 2,4 diisocyanate reacts with trace amounts of water to form trace quantities of 2,4-diaminotoluene.
The resulting product contains 99 percent toluene 2,4-diisocyanate and 0.05 percent 2,4-diaminotoluene.
The 2,4 diaminotoluene would not be subject to EPCRA Section 313 reporting nor would supplier
notification be required because the concentration of 2,4- diaminotoluene is below its de minimis limit of
0.1 percent in the product.
Manufacture as a Commercial Byproduct and Impurity
Chloroform is a reaction byproduct in the production of carbon tetrachloride. It is removed by distillation to
a concentration of less than 150 ppm (0.0150 percent) remaining in the carbon tetrachloride. The separated
chloroform at 90 percent concentration is sold as a byproduct. Chloroform is subject to a 0.1 percent (1000
ppm) de minimis limit. Any amount of chloroform manufactured and separated as byproduct must be
included in threshold determinations because EPA does not interpret the de minimis exemption to apply to
the manufacture of a chemical as a byproduct. Releases of chloroform prior to and during purification of the
carbon tetrachloride must be reported. The de minimis exemption can, however, be applied to the chloroform
remaining in the carbon tetrachloride as an impurity. Because the concentration of chloroform remaining in
the carbon tetrachloride is below the de minimis limit, this quantity of chloroform is exempt from threshold
determinations, release and other waste management reporting, and supplier notification.
Manufacture as a Waste Byproduct
A small amount of formaldehyde is manufactured as a reaction byproduct during the production of phthalic
anhydride. The formaldehyde is separated from the phthalic anhydride as a waste gas and burned, leaving
no formaldehyde in the phthalic anhydride. The amount of formaldehyde produced and removed must be
included in threshold determinations and release and other waste management estimates even if the
formaldehyde were present below the de minimis level in the process stream where it was manufactured or
in the waste stream to which it was separated because EPA does not interpret mixtures and trade name
products to includes wastes.
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 as
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 is 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
Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
overburden is processed or otherwise used by
facilities in NAICS codes 212221, 212222, 212230,
and 212299, a person is not required to consider the
quantity of the EPCRA Section 313 chemical as
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 in excess of 25,000 pounds
over the calendar year;
• Processed in excess of 25,000 pounds over
the calendar year; or
• Otherwise used in excess of 10,000 pounds
over the calendar year.
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 category, the polycyclic
aromatic compounds (PACs) chemical category, and
the hexabromocyclododecane category.
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
Chemical or chemical
category name
CAS
number
or
chemical
category
code
Threshold
(lb, 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 dioxin-like
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
Hexabromocyclododecane
category
N270
100
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 category
N420
100
Mercury
7439-97-6
10
Mercury compounds
category
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 4A to assist facilities
in determining whether they exceed any of the
reporting thresholds for non-PBT chemicals; Figures
4B-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:
https://www.epa.gov/toxics-release-inventory-tri
program/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
28
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 OnSite 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
29
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 qualifier
“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 term ‘anhydrous’ means ‘lacking water,’
whereas ‘aqueous’ means ‘dissolved in water.’
Anhydrous ammonia (in either the gas or compressed
liquid state) may, however, contain a small amount
of water. The presence of water in anhydrous
ammonia does not constitute aqueous ammonia
unless the amount of water present is sufficient to
dissolve the ammonia. If ammonia is not actually
dissolved in water, then the ammonia must be
considered anhydrous.
The qualifier for ammonia means that anhydrous
forms of ammonia are 100 percent reportable and
aqueous forms are limited to 10 percent of total
aqueous ammonia. Therefore, when determining
threshold quantities, 100 percent of anhydrous
ammonia is included but only 10 percent of total
aqueous ammonia is included. If any ammonia
evaporates from aqueous ammonia solutions, 100
percent of the evaporated ammonia is included in
threshold determinations.
For example, if a facility processes aqueous
ammonia, it has processed 100 percent of the aqueous
ammonia in that solution. If the ammonia remains in
solution, then 10 percent of the total aqueous
ammonia is counted towards the threshold. If there
are any evaporative losses of anhydrous ammonia,
then 100 percent of those losses must be counted
towards the processing threshold. If the
manufacturing, processing, or otherwise use
threshold for the ammonia listing is exceeded, the
facility must report 100 percent of these evaporative
losses in Sections 5 and 8 of the Form R.
B.4.d. Threshold Determinations for
Chemical Categories
A number of chemical compound categories are
subject to reporting. See Table IIc for a listing of
these EPCRA Section 313 chemical categories.
When preparing threshold determinations for one of
these EPCRA Section 313 chemical categories, all
individual members of a category that are
manufactured, processed, or otherwise used must be
counted. Where generic names are used at a facility,
threshold determinations should be based on CAS
numbers. For example, Poly-Solv EB does not appear
among the reportable chemicals in Table IIa or IIb
but its CAS number indicates Poly-Solv EB is a
synonym for ethylene glycol mono-n-butyl ether, a
member of the certain glycol ethers chemical
category (code N230). For chemical compound
categories, threshold determinations must be made
separately for each of the three activities. Do not
include in these threshold determinations for a
category any chemicals that are also individually
listed EPCRA Section 313 chemicals (see Table IIa
or IIb). Individually listed EPCRA Section 313
chemicals are subject to their own individual
threshold determination.
Organic Compounds
For the organic compound categories, you are
required to account for the entire weight of all
compounds within a specific compound category
(e.g., glycol ethers) at the facility for BOTH the
threshold determination and release and other waste
management estimates.
Metal Category Compounds
Threshold determinations for metal category
compounds present a special case. If, for example,
your facility processes several different nickel
compounds, base your threshold determination on the
total weight of all nickel compounds processed.
However, if your facility processes both the “parent”
metal (nickel) as well as one or more nickel
compounds, you must make threshold determinations
for both nickel (CAS number 7440-02-0) and nickel
compounds (chemical category code N495) because
they are separately listed EPCRA Section 313
chemicals. If your facility exceeds thresholds for
both the parent metal and compounds of that same
metal, EPA allows you to file one combined report
(e.g., one report for nickel compounds, including
nickel) because the release information you will
report in connection with metal category compounds
will be the total pounds of the metal released. If you
file one combined report, you should put the name of
the metal compound category on the Form R. In the
example above, the facility that exceeded reporting
thresholds for both the nickel and nickel compounds
chemical category could submit a single Form R for
the nickel compounds chemical category, which
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
would contain release and other waste management
information for both nickel and nickel compounds.
TRI-MEweb will prompt you to select a checkbox to
indicate whether the form contains reports for both
the parent metal and compounds of that same metal
to indicate that the form contains reporting on both
the parent metal and the metal compound (e.g., nickel
and nickel compounds).
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
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 section B.5.)
Nitrate
Compounds
(water
dissociable;
reportable only when in aqueous solution)
For the category nitrate compounds (water
dissociable; reportable only when in aqueous
solution), the entire weight of the nitrate compound
is counted in making threshold determinations. A
nitrate compound is covered by this listing only when
in water and only if dissociated. If no information is
available on the identity of the type of nitrate that is
manufactured, processed or otherwise used, assume
that the nitrate compound exists as sodium nitrate.
B.4.e Threshold Determination for
Persistent Bioaccumulative Toxic
(PBT) Chemicals
There are two separate thresholds for EPCRA
Section 313 PBT chemicals; these thresholds are set
based on the chemicals’ potential to persist and
bioaccumulate
in
the
environment.
The
manufacturing, processing and otherwise use
thresholds for PBT chemicals is 100 pounds, while
for the subset of PBTs chemicals that are highly
persistent and highly bioaccumulative, it is 10
pounds. One exception is the dioxin and dioxin-like
compounds chemical category. The threshold for this
category is 0.1 gram. The PBT chemicals, their CAS
numbers or chemical category code, and their
reporting thresholds are listed in a table in the
introductory section of B.4. See Table IIc of these
instructions for lists of individual members of the
dioxin and dioxin-like compounds chemical category
and the polycyclic aromatic compounds (PACs)
chemical category.
B.4.f. Mixtures and Other Trade Name
Products
EPCRA Section 313 chemicals contained in mixtures
and other trade name products must be factored into
threshold determinations and release and other waste
management calculations.
If your facility processed or otherwise used mixtures
or other trade name products during the calendar
year, you are required to use the best readily 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 Section 372.30(b)(ii)).
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
• 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.
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 release and other waste
management information for both the “parent” metal
and metal portion of the related metal category
compounds. For example, thresholds for chromium
and chromium compounds are both exceeded.
Instead of filing two Form Rs you can file one
combined Form R that contains 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 these instructions do not apply to the Form
A. See Section B.6.g for reporting instructions for
reporting metals and metal category compounds
using the Form A Certification Statement. See the
Form R and Form A Certification Statement
Reporting Codes and Instructions for Reporting
Metals guidance document 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
32
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 Safety Data Sheet (SDS) 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
SDS 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
33
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
1.
2.
3.
4.
(A1)_____________lb
Subtotal:
(B1)___________lb (C1)___________lb
Amount subject to threshold:
(A-A1)_______ 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. Keep this worksheet for your records.
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.
Figure 4A.
EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet
Toxics Release Inventory Reporting Forms and Instructions
34
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
1.
2.
3.
4.
Subtotal:
(A1)_____________lb
(B1)___________lb (C1)___________lb
Amount subject to threshold:
(A-A1)_______ 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. Keep this worksheet for your records.
1
Chemicals listed as PBT are not eligible for the de minimis exemption.
Figure 4B.
EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100-Pound Thresholds
Toxics Release Inventory Reporting Forms and Instructions
35
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
1.
2.
3.
4.
Subtotal:
(A1)_____________lb
(B1)___________lb (C1)___________lb
Amount subject to threshold:
(A-A1)_______ 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. Keep this worksheet for your records.
1
Chemicals listed as PBT are not eligible for the de minimis exemption.
Figure 4C.
EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10-Pound Threshold
Toxics Release Inventory Reporting Forms and Instructions
36
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
Otherwise Used
1.
2.
3.
4.
Subtotal:
(A)___________g
(B)__________g
(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-A1)________ 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. Keep this worksheet for your records.
1
Chemicals listed as PBT are not eligible for the de minimis exemption.
Figure 4D.
EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like Compounds Chemical Category
Toxics Release Inventory Reporting Forms and Instructions
37
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
B.6. Facility Eligibility Determination
for Alternate Threshold and for
Reporting on TRI Form A
Certification Statement
This section will help you 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: https://www.epa.gov/toxics-release
inventory-tri-program/tri-laws-rulemakings-and
notices.
B.6.a. Alternate Threshold
On November 30, 1994, EPA published a final rule
(59 FR 61488) that provides qualifying facilities an
alternate threshold of 1 million pounds. Eligible
facilities wishing to take advantage of this option
may certify on a simplified two-page form referred to
as Form A Certification Statement and do not have to
use Form R. The "TRI Alternate Threshold for
Facilities with Low Annual Reportable Amounts,"
provides facilities otherwise meeting EPCRA section
313 reporting thresholds the option of certifying on
Form A provided that they do not exceed 500 pounds
for the total annual reportable amount (defined
below) for that chemical, and that their amounts
manufactured or processed or otherwise used do not
exceed one-million pounds. As with determining
Section 313 reporting thresholds, amounts
manufactured, processed, or otherwise used are to be
considered independently. This modification does
not apply to forms being submitted on or before July
1, 1995 (covering the 1994 reporting year). If you fill
out a Form A for an EPCRA Section 313 chemical,
do not fill out a Form R for that same chemical.
However, there is an exception to the alternate
threshold rule described in the preceding paragraph.
All PBT chemicals (except certain instances of
reporting lead in stainless steel, brass or bronze
alloys) are excluded from eligibility for the alternate
threshold.
B.6.b. 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 B.6.a, 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 database in the same manner
that information submitted on Form R appears.
B.6.c. 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 of the
following waste management activities:
• 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 offsite 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 as Part
II column B of section 8, data elements 8.1 (quantity
released), 8.2 (quantity used for energy recovery onsite), 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).
Toxics Release Inventory Reporting Forms and Instructions
38
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
B.6.d. 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.
B.6.e. 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.
B.6.f. 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.
Similarly, separate listings on Form A must be
submitted for all other listed chemicals even if EPA
allows one listing on Form R to be filed for two or
more listed chemicals (e.g., o-xylene, p-xylene and
xylene (mixed isomers)). For example, if a facility
processes in three separate process streams, xylene
(mixed isomers), o-xylene, and p-xylene, and
exceeds the conditions of the alternate threshold for
each of these listed substances, the facility may
combine the appropriate information on the o-xylene,
p-xylene, and xylene (mixed isomers) into one Form
R, but cannot combine the reports into one listing on
Form A.
Facilities that process o-xylene, p-xylene, and xylene
(mixed isomers) in separate process streams and do
not exceed the conditions of the alternate threshold
for one or more of the compounds may submit a
separate Form A for each of the forms of xylene
meeting the alternate threshold and report on Form R
for those forms that do not. Similar to reporting on
Toxics Release Inventory Reporting Forms and Instructions
39
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
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.
Toxics Release Inventory Reporting Forms and Instructions
40
Part I. Facility Identification Information
Instructions for Completing TRI
Forms R and A
The following instructions provide information on
how to enter data on Forms R and A for non-trade
secret reporting using TRI-MEweb. Supplemental
instructions for submitting trade secret claims are
provided in Appendix A.
TRI-MEweb collects the same facility identification
information and chemical specific information that
facilities previously submitted on the paper TRI
Forms. In some cases, TRI-MEweb does not
sequentially follow the Sections numerically as listed
on the Forms. As such, the TRI-MEweb experience
differs somewhat from the sequential nature of the
instructions in this document.
Facility identification information provided in Part I
is entered only once per facility in TRI-MEweb and
is duplicated on all forms submitted, except for the
technical and public contact that 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 Part II (including
technical and public contact information) is entered
separately for each chemical reported.
C. Part I. Facility
Identification Information
(Form R & A)
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
2019 reporting year must be submitted on or before
July 1, 2020.
Section 2.
Trade Secret Information
Trade secret submission is not supported by TRIMEweb. As such, Section 2 is not to be completed by
TRI-MEweb users for non-trade secret reports. For
instructions on completing trade secret submissions,
see Appendix A of these instructions.
Section 3.
Certification
For both Form R and Form A, the certification
statement must be signed by a senior official with
management responsibility for the person (or
persons) completing the form. A senior management
official must certify the accuracy and completeness
of the information reported on the form by signing
and dating the 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 Signature Agreement
form. For more information regarding certification of
forms, see Section A.2.
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.
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.
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 Certification Statement as
well as in the county field of TRI-MEweb. “NA” or
“None” are not acceptable entries. TRI-MEweb
Toxics Release Inventory Reporting Forms and Instructions
41
Part I. Facility Identification Information
provides a dropdown menu for the county name,
including city districts and parish names.
TRIFID assigned to your new reporting facility
should be used in all future reporting of TRI data.
If your facility is located in Indian country as defined
by 18 USC §1151 you must enter the three-digit
Bureau of Indian Affairs (BIA) tribal code in the
“BIA Code” field. The BIA tribal codes are
accessible
via
this
webpage:
https://www.epa.gov/data-standards/tribal-identifier
data-standard. 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.
Facility identification information for a facility
that has changed ownership but has not changed
physical location.
The 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 TRIFID is retained by the facility even
if the facility changes name, ownership, production
processes, NAICS codes, etc.
If your facility is not located in Indian country as
defined by 18 USC §1151 (the overwhelming
majority of TRI facilities are not in Indian country),
you must enter only the city, county (as applicable),
state and ZIP code.
Facility identification 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:
https://www3.epa.gov/enviro.
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 used by the previous owner. TRI-MEweb
can be used to update facility information to reflect
the change of ownership.
Facility is submitting TRI reporting forms for the
first time
If your facility is reporting for the first time, upon
creating your CDX account, and adding the TRIMEweb application, you will be prompted to add a
new facility account into TRI-MEweb. 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.
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 TRI-MEweb, then you can
add your facility to your profile using the 6-digit
access key, which is e-mailed to all technical
contacts, preparers, and certifying officials at
facilities reporting for the prior year, or by submitting
the TRIFID and technical contact information.
Facility identification information for a facility
that has previously submitted data to EPA but has
changed physical location.
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
Toxics Release Inventory Reporting Forms and Instructions
42
Part I. Facility Identification Information
Example 10: Reporting After a Change in Name or Ownership
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?
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: the TRI Facility
identification number will not change.)
EPCRA Section 313 Questions and Answers Document 2019 Consolidation Document, Question #774
If a covered facility does not have a Dun & Bradstreet number but the parent corporation does,
should this number be reported?
Report the Dun and Bradstreet Number for the facility. If a facility does not have a Dun and Bradstreet
Number, enter ‘NA’ in Part I, Section 4.7. The corporate Dun and Bradstreet Number should be entered in
Part I, Section 5.2 relating to parent company information.
EPCRA Section 313 Questions and Answers Document 2019 Consolidation Document, Question #117
In October, Facility X changes ownership and is purchased by Company Y. For that 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?
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 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
(Monthly Call Center Report Question, EPA530-R-98-005j; October 1998). 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.
EPCRA Section 313 Questions and Answers Document 2019 Consolidation Document, Question #92
4.2
Full or Partial Facility Indication
and Federal Facility Designation
Full or Partial Facility Indication (Form R only)
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.
Toxics Release Inventory Reporting Forms and Instructions
43
Part I. Facility Identification Information
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.)
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, 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 the reporting by part option is not
applicable for facilities submitting a Form A
Certification Statement for a TRI chemical. Unlike
the Form R, the Form A Certification Statement 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.
Federal Facility Designation
Executive Orders have directed 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 the Federal
Facility Reporting Information guidance document
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 or A. 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 facilityidentification 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 TRIMEweb with chemical-specific data rather than
facility-identification information.
Toxics Release Inventory Reporting Forms and Instructions
44
Part I. 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 2017 NAICS codes for RY 2017
reporting and subsequent years. For RY 2013 – 2016
reporting, use 2012 NAICS codes; for RY 2006 –
2012 reporting, use 2007 NAICS codes. Enter any
other applicable NAICS for your facility in 4.5 (b)
(f), also called “secondary NAICS codes” in TRIMEweb. If you do not know your NAICS code(s),
consult the 2017 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. A final rule was
published in the Federal Register on December 26,
2017 (82 FR 52674), to adopt 2017 NAICS codes for
RY 2017 and subsequent years. Table I lists all
industries that are covered under EPCRA 313 and
their corresponding 2017 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 1-844-229-8664,
or
by
visiting
this
website:
https://www.dnb.com/duns-number/lookup.html
If a facility does not subscribe to the D&B service, a
number can be obtained, toll free at 844-229-8664
(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 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 (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 parent company based in the
U.S., 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 2019 is available for
download at:
https://ofmpub.epa.gov/apex/guideme_ext/f?p=guid
eme:rfi-home#downloadable.
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.
Toxics Release Inventory Reporting Forms and Instructions
45
Part I. Facility Identification Information
If your parent company does not have a D&B
number, you should check “Parent Company D&B
Number Not Applicable.”
Example 11: Identifying the Parent Company
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?
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.
EPCRA Section 313 Questions and Answers Document 2019 Consolidation Document 2019 Consolidation
Document, Question #96
Who is the parent company for a 50/50 joint venture?
The 50/50 joint venture is its own parent company.
EPCRA Section 313 Questions and Answers Document 2019 Consolidation Document, Question #99
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, MN. Which is the parent company?
Big Oil Corporation is the parent company.
EPCRA Section 313 Questions and Answers Document 2019 Consolidation Document, Question #101
Toxics Release Inventory Reporting Forms and Instructions
46
Part I. Facility Identification Information
Example 12: Reporting for Multiple Sites and/or Owners
If two plants are separate establishments under the same site management, must they have separate
Dun & Bradstreet numbers?
They may have separate Dun & Bradstreet 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 Dun &
Bradstreet numbers.
EPCRA Section 313 Questions and Answers Document 2019 Consolidation Document, Question #118
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?
The electricity generating facility 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.
EPCRA Section 313 Questions and Answers Document 2019 Consolidation Document, Question #98
A covered facility sells one of its establishments to a new owner. The operator of the newly sold
establishment, however, does not change. The same operator operates the newly sold establishment
and the rest of the facility. Although the facility makes its threshold determinations based on the
activities at the entire facility (including the newly sold establishment), the facility chooses to report
separately for the different establishments. What parent name should the newly sold establishment
use, the parent name of the owner or the parent name of the operator (i.e., the same as the rest of the
facility)?
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.)
EPCRA Section 313 Questions and Answers Document 2019 Consolidation Document, Question #102
Two distinct NAICS code operations that are covered under EPCRA section 313 (e.g., an electricity
generating facility 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?
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 (40 CFR Section 372.3). 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.
EPCRA Section 313 Questions and Answers Document 2019 Consolidation Document, Question #23
Toxics Release Inventory Reporting Forms and Instructions
47
Part I. Facility Identification Information
Example 12: Identifying the Parent Company (continued)
Company A purchases a facility from Company B between January 1 and June 30, of the same year.
For the reporting forms covering the prior year, which company’s name and identification number
should appear on the Form R or Form A submission?
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 (Monthly Call Center
Report Question, EPA530-R-98-005; October 1998). 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.
EPCRA Section 313 Questions and Answers Document 2019 Consolidation Document, Question #91
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 buildings and structures, are owned by Company A and operated by
Company B (see diagram). Are all three sites and their buildings and structures considered separate
facilities under EPCRA section 313? Who is responsible for reporting for each?
Site 1
Owned and operated by A
Site 2
Owned by A and operated by B
Site 3
Owned and operated by B
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 both the owner
and the operator are liable for penalties.
EPCRA Section 313 Questions and Answers Document 2019 Consolidation Document, Question #87
Toxics Release Inventory Reporting Forms and Instructions
48
Part II. Chemical Identification Information
D. Part II. Chemical
Identification Information
(Form R & A)
In Part II, you are to report on:
• The EPCRA Section 313 chemical being
reported;
• The type of reporting form used (i.e., Form R or
Form A Certification Statement);
• The general uses and activities involving the
EPCRA Section 313 chemical at your facility
(Form R only);
• On-site releases of the EPCRA Section 313
chemical from the facility to air, water, and land
(Form R only);
• Quantities of the EPCRA Section 313 chemical
transferred to off-site locations (Form R only);
• Information for on-site and off-site disposal,
treatment, energy recovery, and recycling of the
EPCRA Section 313 chemical (Form R only);
and
• Source reduction activities (Form R only).
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. TRIMEweb will prompt users to indicate whether the
form should be a TRI Form R or Form A.
The TRI listed chemicals for RY 2019 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 the
nonylphenol category prior to RY 2016 as it was first
added for RY 2016. Facilities reporting a generic
name provided by a supplier should see instructions
in Section 2.
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 B.6.g
for these guidelines.
Section 1.
1.1
EPCRA Section 313
Chemical Identity
(Form R & A)
CAS Number
Initiating a Form R or A for a chemical or chemical
category in TRI-MEweb automatically completes
this section.
1.2
EPCRA Section 313 Chemical or
Chemical Category Name
Initiating a Form R or A for a chemical or chemical
category in TRI-MEweb automatically completes
this section.
1.3
Generic Chemical Name
Section 1.3 is completed only for trade secret
submissions. For instructions on reporting trade
secret claims, see Appendix A.
Example 13: 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.
Toxics Release Inventory Reporting Forms and Instructions
49
Part II. Chemical Identification Information
Section 2. Mixture Component
Identity (Form R & A)
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 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 R or A for a generic chemical
in TRI-MEweb, navigate to the Forms Home page,
click the "Add Form(s)" button for the facility
reporting on a generic chemical, click the Generic
Chemical Name Provided by Supplier link on the
search window pop-up, and then enter the 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. Click
the "Begin Form" button next to the generic chemical
added to the list of forms for the facility to prepare
the TRI form.
Section 3. Activities and Uses of the
EPCRA Section 313 Chemical at
the Facility (Form R)
[Note that the remaining Part II Sections apply to the
Form R only.]
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 5). For each type of activity
performed by the facility for the reported chemical
(i.e., manufacturing, processing, or otherwise using),
specify how that chemical was used and select the
corresponding checkboxes, and provide the
corresponding use codes as appropriate for categories
that contain specific uses (e.g., processing as a
reactant provides for P codes to describe the
processing activity with more detail). 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. Starting with RY 2018, some
processing and otherwise use codes contain subactivities and sub-uses. Select all of these codes that
apply.
Note that a facility should use its best professional
judgment to characterize its activities and uses when
indicating subcategories under Processing and
Otherwise Use on the Form R. For certain industries,
some of these categories may overlap in scope. If
your industry uses any of these terms synonymously,
or discretely as two separate activities, (e.g.,
‘feedstock’ and ‘raw material’) or there is some
uncertainty as to which term is most applicable then
indicate the option(s) that best align with industry
norms.
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.
3.1
Manufacture the EPCRA Section
313 Chemical
Persons who manufacture (including import) the
EPCRA Section 313 chemical must check at least one
of the following:
Toxics Release Inventory Reporting Forms and Instructions
50
Part II. Chemical Identification Information
a.
Produce — The EPCRA Section 313
chemical is produced at the facility.
b.
Import — The EPCRA Section 313 chemical
is imported by the facility into the Customs
Territory of the United States. (See Section
B.3.a of these instructions for further
clarification of import.)
And check at least one of the following:
If the chemical is processed as a reactant, you
must indicate the applicable sub-uses:
• P101: Feedstocks
• P102: Raw materials
• P103: Intermediates
• P104: Initiators
• P199: Other
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. If the chemical is
processed as a formulation component, you
must indicate the applicable sub-uses:
• P201: Additives
• P202: Dyes
• P203: Reaction diluents
• P204: Initiators
• P205: Solvents
• P206: Inhibitors
• P207: Emulsifiers
• P208: Surfactants
• P209: Lubricants
• P210: Flame retardants
• P211: Rheological modifiers
• P299: Other
c.
For on-site use/processing — The EPCRA
Section 313 chemical is produced or imported
and then further processed or otherwise used
at the same facility. If you check this block,
generally you should also check at least one
item in Part II, Section 3.2 or 3.3.
d.
For sale/distribution — The EPCRA Section
313 chemical is produced or imported
specifically for sale or distribution outside the
manufacturing facility.
e.
As a byproduct — The EPCRA Section 313
chemical is produced coincidentally during
the manufacture, processing, or otherwise use
of another chemical substance or mixture and,
following its production, is separated from
that other chemical substance or mixture.
EPCRA Section 313 chemicals produced as a
result of waste management are also
considered byproducts.
c.
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.
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. This does not include
sending toxic chemicals off-site into commerce
for recycling, which is indicated using (f)
Recycling.
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).
f.
In summary, if you are a manufacturer of the EPCRA
Section 313 chemical, you must check (a) and/or (b),
and at least one of (c), (d), (e), and (f) in Section 3.1.
3.2
Process the EPCRA Section 313
Chemical
Persons who process the EPCRA Section 313
chemical must enter at least one of the following
processing use codes:
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.
Toxics Release Inventory Reporting Forms and Instructions
51
Part II. Chemical Identification Information
f. Recycling — 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 for purposes of recycling or
reclamation.
b.
As a manufacturing aid — An EPCRA
Section 313 chemical that aids the
manufacturing process but does not become
part of the resulting product and is not added to
the reaction mixture during the manufacture or
synthesis of another chemical substance is
otherwise used as a manufacturing aid. If the
chemical is otherwise used as a manufacturing
aid, you must indicate the applicable sub-uses:
• Z201: Process lubricants
• Z202: Metalworking fluids
• Z203: Coolants
• Z204: Refrigerants
• Z205: Hydraulic fluids
• Z299: Other
c.
Ancillary or other use — An EPCRA Section
313 chemical that is used at a facility for
purposes other than aiding chemical processing
or manufacturing as described above is
otherwise used as an ancillary or other use. If
the chemical is otherwise used as an ancillary
or other use, you must indicate the applicable
sub-uses:
• Z301: Cleaner
• Z302: Degreaser
• Z303: Lubricant
• Z304: Fuel
• Z305: Flame retardant
• Z306: Waste treatment
• Z307: Water treatment
• Z308: Construction Materials
• Z399: Other
In summary, if you are a processor of the EPCRA
Section 313 chemical, you must check (a), (b), (c),
(d), (e), or (f), and select all of the P codes for (a) or
(b) that apply.
3.3
Otherwise Use the EPCRA Section
313 Chemical (non-incorporative
activities)
Persons who otherwise use the EPCRA Section 313
chemical must enter at least one of the following
otherwise use activity codes:
a.
As a chemical processing aid — An EPCRA
Section 313 chemical that is added to a
reaction mixture to aid in the manufacture or
synthesis of another chemical substance but is
not intended to remain in or become part of the
product or product mixture is otherwise used as
chemical processing aid. If the chemical is
otherwise used as a chemical processing aid,
you must indicate the applicable sub-uses:
• Z101: Process solvents
• Z102: Catalysts
• Z103: Inhibitors
• Z104: Initiators
• Z105: Reaction terminators
• Z106: Solution buffers
• Z199: Other
In summary, if you otherwise use the EPCRA Section
313 chemical, you must check (a), (b), and/or (c), and
select all of the Z-codes for (a), (b), or (c) that apply.
Toxics Release Inventory Reporting Forms and Instructions
52
Part II. Chemical Identification Information
Figure 5. Reporting EPCRA Section 313 Chemicals
Example 14: 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 alpha-naphthylamine, forming N-methyl-alpha-naphthylamine 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 5 for how this information would be reported in Part II, Section 3 of Form
R.
Your facility also processes alpha-naphthylamine, as a reactant to produce N-methyl-alpha
naphthylamine, a chemical not on the EPCRA Section 313 list.
2. Your facility is a commercial distributor of Missouri bituminous coal, which contains mercury at 1.5 ppm
(w:w). You should check the box on Part II, Section 3.2.e for processing mercury as an impurity.
Toxics Release Inventory Reporting Forms and Instructions
53
Part II. Chemical Identification Information
Section 4. Maximum Amount of the
EPCRA Section 313 Chemical Onsite at Any Time during the
Calendar Year (Form R)
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 On-site.
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
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
0
0.1
1.0
10
100
1,000
10,000
100,000
1,000,000
Toxics Release Inventory Reporting Forms and Instructions
To
0.099
0.99
9.99
99
999
9,999
99,999
999,999
more than 1 million
54
Part II. Chemical Identification Information
Section 5. Quantity of the Toxic
Chemical Entering Each
Environmental Medium On-site
(Form R)
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 dioxinlike 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 dioxinlike compounds category), provided the accuracy and
the underlying data on which the estimate is based
supports this level of precision.
For the dioxin and dioxin-like compounds category,
facilities should report at a level of precision
supported by the accuracy of the underlying data and
the estimation techniques on which the estimate is
based. For the dioxin and dioxin like compounds
chemical category, which has a reporting threshold of
0.1 gram, facilities need only report all release and
other waste management quantities greater than 100
micrograms (i.e., 0.0001 grams). (See Example 12)
Notwithstanding the numeric precision used when
determining reporting eligibility thresholds, facilities
should report on Form R to the level of accuracy that
their data supports, up to seven digits to the right of
the decimal. EPA’s reporting software and data
management systems support data precision up to
seven digits to the right of the decimal.
Example 15: 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. (Column C only applies to
Section 5.3.)
Toxics Release Inventory Reporting Forms and Instructions
55
Part II. Chemical Identification Information
5.1
Fugitive or Non-Point Air
Emissions
Report the total of all releases of the EPCRA Section
313 chemical to the air that are not released through
stacks, vents, ducts, pipes, or any other confined air
stream. You must include (1) fugitive equipment
leaks from valves, pump seals, flanges, compressors,
sampling connections, open-ended lines, etc.; (2)
evaporative losses from surface impoundments and
spills; (3) releases from building ventilation systems;
and (4) any other fugitive or non-point air emissions.
Engineering estimates and mass balance calculations
(using purchase records, inventories, engineering
knowledge or process specifications of the quantity
of the EPCRA Section 313 chemical entering
product, hazardous waste 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 Geological Survey’s (USGS) National
Hydrography Dataset (NHD). Note that reach data
are not available for Alaska, 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, the Water Pollutant
Loading tool (formerly known as the 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 discharged. 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
Toxics Release Inventory Reporting Forms and Instructions
56
Part II. Chemical Identification Information
each receiving stream or water body. Include process
outfalls such as pipes and open trenches, releases
from on-site wastewater treatment systems, and the
contribution from stormwater runoff, if applicable
(see instructions for column C below). Do not include
discharges to a POTW or other off-site wastewater
treatment facilities in this section. These off-site
transfers must be reported in Part II, Section 6 of
Form R. Wastewater analyses and flowmeter data
may provide the quantities you will need to complete
this section.
Discharges of listed acids (e.g., hydrogen fluoride,
nitric acid) may be reported as zero if the discharges
have been neutralized to pH 6 or above. If wastewater
containing a listed acid is discharged below pH 6,
then releases of the acid must be reported. In this
case, pH measurements may be used to estimate the
amount of mineral acid released.
5.4-5.5
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 Section 112(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.
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.
Note that reporting for this section is chemicalspecific. An amount reported should reflect the
weight of the chemical, not the weight of the waste
stream in which the chemical is located.
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.
5.4.1 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
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
Toxics Release Inventory Reporting Forms and Instructions
57
Part II. Chemical Identification Information
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
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).
Section 5 Column A: Total Release
Only on-site releases of the EPCRA Section 313
chemical to the environment for the calendar year are
to be reported in this section of Form R. The total onsite 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
Reporting Range (in 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 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.
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Part II. Chemical Identification Information
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).
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 non-representative,
facilities must make reasonable estimates using the
best readily available information.
Reasonable estimates of the amounts released should
be made using published emissions factors, mass
balance calculations, or engineering calculations.
You may not use emissions factors or calculations to
estimate releases if more accurate data are available.
No additional monitoring or measurement of the
quantities or concentrations of any EPCRA Section
313 chemical released into the environment, or of the
frequency of such releases, beyond that required
under other provisions of law or regulation or as part
of routine plant operations, is required for the purpose
of completing Form R.
You must estimate the quantity (in pounds) of the
EPCRA Section 313 chemical or chemical category
that is released annually to each environmental
medium on-site. Include only the quantity of the
EPCRA Section 313 chemical in this estimate. If the
EPCRA Section 313 chemical present at your facility
was part of a mixture or other trade name product,
calculate only the releases of the EPCRA Section 313
chemical, not the other components of the mixture or
other trade name product. If you are only able to
estimate the releases of the mixture or other trade
name product as a whole, you should assume that the
release of the EPCRA Section 313 chemical is
proportional to its concentration in the mixture or
other trade name product. See Part 40, 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.
If you are reporting an EPCRA Section 313 chemical
category listed in Table II of these instructions rather
than a specific EPCRA Section 313 chemical, you
must combine the release data for all chemicals in the
EPCRA Section 313 chemical category (e.g., all
listed members of certain glycol ethers or all listed
members of chlorophenols) and report the aggregate
amount for that EPCRA Section 313 chemical in that
category separately. For example, if your facility
releases 3,000 pounds per year of 2-chlorophenol,
4,000 pounds per year of 3-chlorophenol, and 4,000
pounds per year of 4-chlorophenol to air as fugitive
emissions, you must report that your facility releases
11,000 pounds per year of chlorophenols to air as
fugitive emissions in Part II, Section 5.1.
For aqueous ammonia solutions, releases must be
reported based on 10 percent of total aqueous
ammonia. Ammonia evaporating from aqueous
ammonia solutions is considered to be anhydrous
ammonia; therefore, 100 percent of the anhydrous
ammonia should be reported if it is released to the
environment.
For dissociable nitrate compounds, release estimates
should be based on the weight of the nitrate only.
For metal category compounds (e.g., chromium
compounds), report releases of only the parent metal.
For example, a user of various inorganic chromium
salts would report the total chromium released
regardless of the chemical compound and exclude
any contribution to mass made by the other portion of
the compound.
Section 5 Column B: Basis of Estimate
For each release and otherwise managed waste
estimate (Sections 5 & 6), you are required to indicate
the principal method used to determine the amount of
release and otherwise managed waste reported. You
should enter a letter code identifying the method that
Toxics Release Inventory Reporting Forms and Instructions
59
Part II. Chemical Identification Information
applies to the largest portion of the total estimated
release and otherwise managed waste quantity.
The codes are as follows:
M1 Estimate is based on continuous monitoring
data or measurements for the EPCRA Section
313 chemical.
M2 Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA Section 313 chemical.
C
Estimate is based on mass balance
calculations, such as calculation of the amount
of the EPCRA Section 313 chemical in
streams entering and leaving process
equipment.
E1 Estimate is based on published emissions
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emissions factors). This may include
emissions factors in a trade association’s
publication or AP-42.
E2 Estimate is based on site-specific emissions
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emissions factors). This may include
emissions factors that are developed for a
specific piece of equipment and that consider
climate conditions on-site.
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 estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment
was fully identified through monitoring data.
For example, if 40 percent of stack emissions of the
reported EPCRA Section 313 chemical were derived
using source testing data, 30 percent by mass balance,
and 30 percent by published chemical-specific
emissions factors, you should enter the code letter
“M2” for periodic or random emission monitoring.
If the monitoring data, mass balance, or emissions
factor used to estimate the release is not specific to
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 emissions factors or estimation techniques to
revise previous Form R submissions.
Section 5 Column C: Percent from Stormwater
This column relates only to Section 5.3 - discharges
to receiving streams or water bodies. If your facility
has monitoring data on the amount of the EPCRA
Section 313 chemical in stormwater runoff (including
unchanneled runoff), you must include that quantity
of the EPCRA Section 313 chemical in your water
release in column A and indicate the percentage of
the total quantity (by weight) of the EPCRA Section
313 chemical contributed by stormwater in column C
(Section 5.3C).
If your facility has monitoring data on the EPCRA
Section 313 chemical and an estimate of flow rate,
you must use these data to determine the percent
stormwater.
If you have monitored stormwater but did not detect
the EPCRA Section 313 chemical, enter zero in
column C. If your facility has no stormwater
Toxics Release Inventory Reporting Forms and Instructions
60
Part II. Chemical Identification Information
monitoring data for the chemical, you should check
the NA box in TRI-MEweb (note that the Form R
does not provide a 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. 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.
Equation 2
Q=A×C×I
where:
Q=
A=
C=
I=
flow rate
land area of the facility
runoff coefficient (see Equation 3)
rainfall intensity
The runoff coefficient represents the fraction of
rainfall that does not seep into the ground but runs off
as stormwater. The runoff coefficient is directly
related to how the land in the drainage area is used.
(See table below).
Description of
Land Area
Business
Downtown areas
Runoff Coefficient
0.70-0.95
Description of
Land Area
Neighborhood areas
Industrial
Light areas
Heavy areas
Industrial
Railroad yard areas
Unimproved areas
Streets
Asphaltic
Concrete
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
Runoff Coefficient
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
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 weightedaverage coefficient, which takes into account
different types of land use at your facility:
Equation 3
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
61
Part II. Chemical Identification Information
Example 16: 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 5.5 Optional Waste Rock Piles
Information
If you manage the EPCRA Section 313 chemical in
waste rock that was disposed of on-site, you may
elect to provide additional optional information.
Waste rock refers to rock that contains insufficient
metal concentration to economically process at any
given time and is thus typically removed from the
mine to allow access to the ore-grade rock. Waste
rock does not refer to slag, tailings, or other
beneficiated rock or ore. Check the optional box if
you would like to indicate that your reported
Section 5.5 quantities include management of the
chemical in “waste rock piles.” Additionally, you
may enter the quantity of the chemical reported in
Section 5.5 that was managed in waste rock piles.
TRI-MEweb will allow for the inclusion of
optional free text that a facility may use to further
characterize its on-site management of waste rock.
Any information provided in the free-text field will
be added to Section 9.1 (Miscellaneous
Information).
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62
Part II. Chemical Identification Information
Section 6. Transfer(s) of the Toxic
Chemical in Wastes to Off-Site
Locations (Form R)
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 dioxinlike 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.
Note that reporting for this section is chemicalspecific. An amount reported should reflect the
weight of the chemical, not the weight of the waste
stream in which the chemical is located.
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. 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 “NA”
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 “NA” box in Section 6.2. In TRI-MEweb, users
may enter as many unique transfers as needed.
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 facility identifiers including
EPA Registry ID (FRS ID), NPDES ID, or RCRA 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
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.
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[ ] Column A: Quantity Transferred to this 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:
Toxics Release Inventory Reporting Forms and Instructions
63
Part II. Chemical Identification Information
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).
If you transfer the EPCRA Section 313 chemical in
wastewater to an off-site POTW for distinct and
multiple purposes, you must report those activities
for each off-site POTW, along with the quantity of
the reported EPCRA Section 313 chemical
associated with each activity. These quantities and
the associated activity codes must be reported
separately in Section 6.1. For example, if you
transferred 100 lb of the chemical to the POTW and
30 lb were released to air, 40 lb were disposed of as
sludge, and 30 lb were transformed into sludge and
then incinerated, you would provide three lines using
P codes P32, P33, and P38, respectively, with the
corresponding quantities and the basis of estimate(s).
If you do not know the ultimate disposition of
transferred quantities then please use codes P36
(Other or Unknown Disposal) and/or P37 (Other or
Unknown Treatment) along with corresponding
quantities and the basis of estimate(s). EPA provides
suggested removal and treatment rates for certain
chemicals to help you report this data element (Table
III). If you have better information on the final
disposition of the chemical readily available then use
that information instead.
If you have fewer than three total transfers in Section
6.1 Column A, an NA should be placed in Column A
of the first unused row to indicate the termination of
the sequence. If all three rows are used, there is no
need to terminate the sequence. If there are more than
three total transfers, re-enter the name of the off-site
location, address, etc. in the next row (6.1.2) and then
you should enter NA when the sequence has
terminated if there are fewer than 6 (i.e. anytime there
are fewer than 3 transfers listed in a Section 6.1
block, an NA should be used to terminate the
sequence).
If a reported EPCRA Section 313 chemical is sent to
an off-site POTW for sequential activities, you
should report the final disposition of the toxic
chemical.
6.1[ ] Column B: Basis of Estimate
You must identify the basis for your estimates of the
quantities of the reported EPCRA Section 313
chemical in the wastewater transferred to each
POTW. 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 emissions
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emissions factors). This may include
emissions factors in a trade association’s
publication or AP-42.
E2 Estimate is based on site-specific emissions
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emissions factors). This may include
emissions factors that are developed for a
specific piece of equipment and that consider
climate conditions on-site.
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 estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment
was fully identified through monitoring data.
6.1[ ] Column C: Disposal/Treatment
You should enter one of the following P codes to
identify the type of disposal or treatment methods
used by the POTW 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.
You must use the code that represents the ultimate
disposition of the chemical.
Toxics Release Inventory Reporting Forms and Instructions
64
Part II. Chemical Identification Information
Metals and Metal Category Compounds
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 and NOT the whole metal
category compound. The metal cannot be treated
because it cannot be destroyed. Thus, transfers of
metals and metal category compounds for further
waste management should be reported as a disposal.
The applicable codes for transfers of metals and
metal category compounds in wastewater to a POTW
for disposal include P30, P31, P32, P33, P34, P35,
and P36.
Applicable codes for Part II, Section 6.1, column
C are:
Disposal Codes:
P30
Discharged to Water Stream
P31
Discharged to Other Activities
P32
Released to Air
P33
Sludge to disposal
P34
Metals and metal compounds only – Sludge
to incineration
P35
Sludge to agricultural applications
P36
Other or Unknown Disposal
Treatment Codes:
P37
Other or Unknown treatment
P38
Sludge to incineration
P39
Experimental and Estimated Treatment Data
(TRI provided)
Facilities should provide the ultimate disposition of
toxic chemicals at POTWs. For example, if the toxic
chemical is:
• in the POTWs’ effluent and is discharged to
surface waters/water stream – use P30
• discharged to other activities such as
watering golf courses, agricultural land, etc.
– use P31
• released to air – use P32
• in the POTWs’ sludge and is disposed via
landfill disposal or land application – use
P33
• incinerated – use P38 (P34 for metals and
metal compounds)
• disposed via agricultural applications or
other activities – use P35
If facilities do not have specific information about the
fate of chemicals transferred to a POTW then use P36
and/or P37. If you use a treatment rate provided in
Table III then use P39. (Table III provides release and
removal and destruction rates for toxic chemicals
sent to POTWs that are based on experimental and
estimated data compiled by EPA). P39 is also used
for chemicals not included in Table III, when the
default assumption is used that 100% of the chemical
sent to the POTW is treated for destruction (except
for metals, which for which the default is that 100%
of the chemical is released). If you have better
information on the final disposition of the chemical
readily available then use that information instead.
In addition, TRI-MEweb will assist a facility in
completing this section when the facility lacks data
on the ultimate disposition of a chemical transferred
to a POTW by applying default distribution removal
and release percentages to quantities transferred to a
POTW.
6.2
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.
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
Toxics Release Inventory Reporting Forms and Instructions
65
Part II. Chemical Identification Information
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 “NA” 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. Select the non-U.S. transfer location check box
when adding a new off-site transfer site that is located
outside the borders of the United States in Section
6.2. Enter the location information for the non-U.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.
6.2[ ] 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).
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 offsite 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 6 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 6), an NA should be placed in Column A of
the first unused row to indicate the termination of the
sequence. If all three rows are used, there is no need
to terminate the sequence. If there are more than three
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 6 (i.e. anytime there
are fewer than 3 transfers listed in a Section 6.2
block, an NA should be used to terminate the
sequence).
If a reported EPCRA Section 313 chemical is sent to
an off-site facility for sequential activities, you
Toxics Release Inventory Reporting Forms and Instructions
66
Part II. Chemical Identification Information
should report the final disposition of the toxic
chemical.
Summary of Residue Quantities From Pilot-Scale Experimental Study
(weight percent of drum capacity)
Material
Unloading
Method
Vessel Type
Value
Kerosenea
Waterb
Motor Oilc
Surfactant
Solutiond
Pumping
Steel drum
Range
Mean
1.93 - 3.08
2.48
1.84 - 2.61
2.29
1.97 - 2.23
2.06
3.06
3.06
Pumping
Plastic drum
Range
Mean
1.69 - 4.08
2.61
2.54 - 4.67
3.28
1.70 - 3.48
2.30
Not Available
Pouring
Bung-top
steel drum
Range
Mean
0.244 - 0.472
0.404
0.266 - 0.458
0.403
0.677 - 0.787
0.737
0.485
0.485
Pouring
Open-top
steel drum
Range
Mean
0.032 - 0.080
0.054
0.026 - 0.039
0.034
0.328 - 0.368
0.350
0.089
0.089
Gravity Drain
Slope-bottom
steel tank
Range
Mean
0.020 - 0.039
0.033
0.016 - 0.024
0.019
0.100 - 0.121
0.111
0.048
0.048
Gravity Drain
Dish-bottom
steel tank
Range
Mean
0.031 - 0.042
0.038
0.033 - 0.034
0.034
0.133 - 0.191
0.161
0.058
0.058
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
Source: 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,
1988.
Note: 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.
a
For kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
b
For water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
c
For motor oil, viscosity = 94 centipoise, surface tension = 34.5 dynes/cm2
d
For surfactant solution, viscosity = 3 centipoise, surface tension = 31.4 dynes/cm2
Gravity Drain
Toxics Release Inventory Reporting Forms and Instructions
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Part II. Chemical Identification Information
Example 17: 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.
6.2[ ] 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
E1
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 emissions
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emissions factors). This may include
emissions factors in a trade association’s
publication or AP-42.
E2
Estimate is based on site specific emissions
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emissions 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.
6.2[ ] 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
Toxics Release Inventory Reporting Forms and Instructions
68
Part II. Chemical Identification Information
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 a
lubricant at another facility) and does not undergo a
waste management activity (i.e., release (including
disposal), treatment, energy recovery, or recycling
(recovery)) prior to that reuse, it need not be reported
in section 6.2 or section 8.
Incineration vs. Energy Recovery
You must distinguish between incineration which is
waste treatment, and legitimate energy recovery. For
you to claim that a reported EPCRA Section 313
chemical sent off-site is used for the purposes of
energy recovery and not for treatment for destruction,
the EPCRA Section 313 chemical must have a
significant heating value and must be combusted in
an energy recovery unit such as an industrial boiler,
furnace, or kiln. In a situation where the reported
EPCRA Section 313 chemical is in a waste that is
combusted in an energy recovery unit, but the
EPCRA Section 313 chemical does not have a
significant heating value, e.g., CFCs, you should use
code M54, Incineration/Insignificant Fuel Value, to
indicate that the EPCRA Section 313 chemical was
incinerated in an energy recovery unit but did not
contribute to the heating value of the waste.
Metals and Metal Category Compounds
Metals and metal category compounds will be
managed in waste either by being released (including
disposed 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 Management Method 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
69
Part II. Chemical Identification Information
Example 18: 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 8.1c.
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
70
Part II. Chemical Identification Information
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 6. Hypothetical Section 6.2 Completed for Two Off-Site Locations
Toxics Release Inventory Reporting Forms and Instructions
71
Part II. Chemical Identification Information
Section 7. On-Site Waste Treatment,
Energy Recovery, and Recycling
Methods (Form R)
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 TRI-MEweb,
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 TRI-MEweb, 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:
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
Toxics Release Inventory Reporting Forms and Instructions
72
Part II. Chemical Identification Information
emission treatment codes, the waste treatment codes
are not restricted to any medium.
different ways, the different waste treatment methods
must be listed separately.
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
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.
Figure 7. Hypothetical Section 7A
Applicable codes for Part II, Section 7A, column
B are:
Air Emissions Treatment
A01
Flare
A02
Condenser
A03
Scrubber
A04
Absorber
A05
Electrostatic Precipitator
A06
Mechanical Separation
A07
Other Air Emission Treatment
Chemical Treatment
H040 Incineration--thermal destruction other
than use as a fuel
H071 Chemical reduction with or without
precipitation
H073 Cyanide destruction with or without
precipitation
H075 Chemical oxidation
H076 Wet air oxidation
H077 Other chemical precipitation with or
without pre-treatment
Biological Treatment
H081 Biological treatment with or without
precipitation
Physical Treatment
H082 Adsorption
H083 Air or steam stripping
H101 Sludge treatment and/or dewatering
H103 Absorption
H111 Stabilization or chemical fixation prior to
disposal
H112 Macro-encapsulation prior to disposal
H121 Neutralization
H122 Evaporation
H123 Settling or clarification
H124 Phase separation
H129 Other treatment
Toxics Release Inventory Reporting Forms and Instructions
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Part II. Chemical Identification Information
Example 19: 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)
Molecular weight = 350.17
Lead (1 Pb atom)
Selenium (1 Se atom)
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
74
Part II. Chemical Identification Information
7A Column c: Waste Treatment Efficiency Estimate
In the space provided, enter the range code, based
upon the codes listed below, indicating the
percentage of the EPCRA Section 313 chemical
removed from the waste stream through destruction,
biological degradation, chemical conversion, or
physical removal. The waste treatment efficiency
(expressed as a range of percent removal) represents
the percentage of the EPCRA Section 313 chemical
destroyed or removed (based on amount or mass), not
merely changes in volume or concentration of the
EPCRA Section 313 chemical in the waste stream.
The efficiency, which can reflect the overall removal
from sequential treatment methods applied to the
general waste stream, refers only to the percent
destruction, degradation, conversion, or removal of
the EPCRA Section 313 chemical from the waste
stream; it does not refer to the percent conversion or
removal of other constituents in the waste stream.
The efficiency also does not refer to the general
efficiency of the treatment method for any waste
stream. For some waste treatment methods, the
percent removal will represent removal by several
mechanisms, as in an aeration basin, where an
EPCRA Section 313 chemical may evaporate,
biodegrade, or be physically removed from the
sludge.
Percent removal can be calculated as follows:
Equation 4
(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 = greater than 99.9999%
E2 = greater than 99.99%, but less than or equal
to 99.9999%
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75
Part II. Chemical Identification Information
E3 =
E4 =
E5 =
E6 =
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 #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 onsite 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 Section 7B
and Section 8.2.)
Energy Recovery Codes
U01
Industrial Kiln
U02
Industrial Furnace
U03
Industrial Boiler
If your facility uses more than one on-site energy
recovery method for the reported EPCRA Section
313 chemical, list the methods used in descending
order (greatest to least) based on the amount of the
EPCRA Section 313 chemical entering such
methods.
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.
In this section, use the codes below to report only the
recycling methods in place at your facility that are
applied to the EPCRA Section 313 chemical. Do not
list any off-site recycling activities. (Information
about off-site recycling must be reported in Part II,
Section 6, “Transfers of the Toxic Chemical in
Wastes to Off-site Locations.”)
NA vs. a Numerical Value (e.g., Zero). If you do
not perform on-site recycling for the reported
EPCRA Section 313 chemical, check the NA box at
the top of Section 7C and enter NA in Section 8.4. If
you perform on-site recycling for the reported
EPCRA Section 313 chemical, enter the appropriate
code in Section 7C and enter the appropriate value in
Section 8.4. If this quantity is less than or equal to 0.5
pound, round to zero (unless the chemical is a listed
PBT chemical) and enter 0 in Section 8.4.
On-Site Recycling Codes
H10 Metal recovery (by retorting, smelting, or
chemical or physical extraction)
H20 Solvent recovery (including distillation,
evaporation, fractionation or extraction)
H39 Other recovery or reclamation for reuse
(including acid regeneration or other chemical
reaction process)
If your facility uses more than one on-site recycling
method for an EPCRA Section 313 chemical, enter
the codes in the space provided in descending order
(greatest to least) based on the volume of the reported
EPCRA Section 313 chemical recovered by each
process.
TRI-MEweb will also simultaneously collect total
quantity recycled on-site for the current reporting
year for this chemical (see Section 8.4).
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76
Part II. Chemical Identification Information
Example 20: 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
Chemical B
7A.1a
W
Chemical C
7A.1a
W
7A.1b
3. H123
6.
1. H124
4. N/A
7.
2. H121
5.
8.
7A.1c
7A.1b
3. H123
6.
1. H124
4. N/A
7.
2. H121
5.
8.
7A.1c
7A.1b
3. H123
6.
1. H124
4. N/A
7.
2. H121
5.
8.
7A.1c
E4
E5
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.
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Part II. Chemical Identification Information
Example 21: 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.
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Part II. Chemical Identification Information
Section 8. Source Reduction and
Waste Management (Form R)
This section includes the data elements mandated by
Section 6607 of the Pollution Prevention Act of 1990
(PPA). The PPA calls for pollution to be prevented or
reduced at the source whenever feasible and released
to the environment only as a last resort, as shown in
Figure 8.
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. For example, you may provide
additional information on new or on-going practices.
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).
Figure 8. Waste Management Hierarchy
TRI collects information to track industry progress in
reducing waste generation and moving towards safer
waste management alternatives. Many facilities
provide descriptions of measures they have taken to
prevent pollution and reduce the amount of toxic
chemicals entering the environment. As a result, TRI
serves as a tool for identifying effective
environmental practices and highlighting pollution
prevention successes.
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 dioxin-like
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 amounts.
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 dioxin-like
compounds category is 0.0001 grams (see Example
12). Notwithstanding the numeric precision used
when determining reporting eligibility thresholds,
facilities should report on Form R to the level of
accuracy that their data supports, up to seven digits to
the right of the decimal. EPA’s reporting software
and data management systems support data precision
to seven digits to the right of the decimal.
NA vs. a Numeric Value (e.g., Zero). You should
enter a numeric value in the relevant sections of
Section 8 if your facility has released, treated,
Toxics Release Inventory Reporting Forms and Instructions
79
Part II. Chemical Identification Information
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.
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.
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
Toxics Release Inventory Reporting Forms and Instructions
80
Part II. Chemical Identification Information
Example 22: Reporting Future Estimates
A pharmaceutical manufacturing facility uses an
EPCRA Section 313 chemical in the manufacture of
a prescription drug. During the reporting year
(2019), the company received approval from the
Food and Drug Administration to begin marketing
their product as an over-the-counter drug beginning
in 2020. 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
(2020) by adding 30 percent to the amount in
column B (the amount for the current reporting
year). The second following year (2021) figure can
be calculated by adding an additional 30 percent to
the amount reported in column C (the amount for
the following year (2020) projection).
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, 2020 (reporting year 2019),
the prior year is 2018. 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. If the facility wants to change data
that was certified and submitted to EPA for the prior
year, then the prior year’s reporting form must be
revised and submitted.
Column B: Current Reporting Year. Quantities
for Sections 8.1 through 8.7 must be reported for the
current reporting year in column B.
Columns C and D: Following Year and Second
Following Year. Quantities for Sections 8.1 through
8.7 must be estimated for 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.
Quantities Reportable in Sections 8.1 - 8.7
Section 8 of Form R uses data collected from
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 summarized below in a table (Relationship
between Form R Sections 8.1-8.7 and Sections 5, 6
and 7) and explicitly described in equation form in
the text. 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 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.
Toxics Release Inventory Reporting Forms and Instructions
81
Part II. Chemical Identification Information
Relationship between Form R Sections 8.1-8.7 and Sections 5, 6 and 7
Category
Disposal and
Other Releases
Section 8 Subsection
Section 8.1a:
Total on-site disposal to Class I
Underground Injection Wells,
RCRA Subtitle C landfills, and
other landfills
Section 8.1b:
Total other on-site disposal or
other releases
Section 8.1c:
Total off-site disposal to Class I
Underground Injection Wells,
RCRA Subtitle C landfills, and
other landfills
Section 8.1d:
Total other off-site disposal or
other releases
Energy
Recovery
Recycling
Treatment
Section 8.2:
Quantity used for energy
recovery on-site
Section 8.3:
Quantity used for energy
recovery off-site
Section 8.4:
Quantity recycled on-site
Section 8.5:
Quantity recycled off-site
Section 8.6:
Quantity treated on-site
Section 8.7:
Quantity treated off-site
Corresponding Section 5, 6 or 7 Subsection
Production related on-site disposal to:
• Section 5.4.1 (on-site Class I wells)
• Section 5.5.1A (on-site RCRA Subtitle C landfills)
• Section 5.5.1B (on-site other landfills)
Production related on-site releases and disposal to:
• Section 5.1 (Fugitive emissions)
• Section 5.2 (Stack or point emissions)
• Section 5.3 (Discharges to water bodies)
• Section 5.4.2 (Class II-V wells)
• Section 5.5.2 (Land treatment)
• Section 5.5.3A (Subtitle C surface impoundments)
• Section 5.5.3B (Other surface impoundments)
• Section 5.5.4 (Other disposal)
Production related off-site transfers to:
• Section 6.1 (quantities associated with P codes P33 and
P34)
• Section 6.2 (quantities associated with M codes M64,
M65 and M81)
Production related transfers to:
• Section 6.1 (quantities associated with P codes P30, P31,
P32, P35, and P36)
• Section 6.2 (quantities associated with M codes M10,
M41, M62, M66, M67, M73, M79, M82, M90, M94, and
M99)
All quantities used for on-site energy recovery associated with
methods reported in Section 7B (on-site energy recovery
processes)
Production related off-site transfers to:
• Section 6.2 (off-site energy recovery)
All quantities recycled on-site associated with methods
reported in Section 7C (on-site recycling processes)
Production related off-site transfers to:
• Section 6.2 (recycling)
All quantities treated on-site associated with methods reported
in Section 7A (on-site waste treatment methods and efficiency)
Production related off-site transfers to:
• Section 6.1 (quantities associated with P codes P37,
P38, and P39)
• Section 6.2 (off-site treatment)
Toxics Release Inventory Reporting Forms and Instructions
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Part II. Chemical Identification Information
8.1
On- and Off-Site Disposal and
Other Releases
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 non-production
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.
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.
Equation 5
Section 8.1a (Total on-site disposal to Class I
Underground Injection Wells, RCRA Subtitle C
landfills, and other landfills) = Section 5.4.1 +
Section 5.5.1A + Section 5.5.1B – Section 8.8 (onsite disposal to landfills or UIC Class I Wells) 1
Equation 6
site disposal or other releases, other than disposal
to landfills or UIC Class I Wells) 1
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.
Equation 7
Section 8.1c (Total off-site disposal to Class I
Underground Injection Wells, RCRA Subtitle C
landfills, and other landfills) = Section 6.1
(quantities associated with P codes P33 and P34)
+ 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) 1
Equation 8
Section 8.1d (Total other off-site disposal or other
releases) = Section 6.1 (quantities associated with
P codes P30, P31, P32, P35, and P36) + 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) 1
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.
Section 8.1b (Total other on-site disposal or other
releases) = 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
Removal and destruction rates for toxic chemicals
sent to POTWs, based on experimental and estimated
data, can be found in Table III.
§ 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 one-
time events not associated with the production process. In
each equation, the parenthetical following “Section 8.8”
indicates which portion of § 8.8 is subtracted.
1
Toxics Release Inventory Reporting Forms and Instructions
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Part II. Chemical Identification Information
Sections 8.2 and 8.3: Energy Recovery
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 offsite 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 offsite 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 BTUs)
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.
Equation 9
Section 8.2 (Energy recovery on-site) = All
quantities used for on-site energy recovery
associated with methods reported in Section 7B
(on-site energy recovery processes)
Section 8.2 is not related to Sections 5 or 6.
Equation 10
Section 8.3 (Energy recovery off-site) = Section
6.2 (energy recovery) – Section 8.8 (off-site
energy recovery, not related to production) 1
Sections 8.4 and 8.5: Recycling
These relate to an EPCRA Section 313 chemical in a
waste that is recycled on-site or is sent off-site for
recycling. Quantities recycled off-site that are
reported in Section 8.8 are excluded from Section 8.5.
EPA considers the direct recirculation of a toxic
chemical within a process or between processes
without any reclamation to be “reuse” of the toxic
chemical rather than “recycling.” The direct use,
§ 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 one
time events not associated with the production process. In
1
direct further use, or direct reuse of the toxic
chemical is not "recycling" provided that there is no
reclamation of the chemical prior to that continued
use or reuse. See the Interpretations of Waste
Management Activities guidance for more
information on this topic.
Also note that if you reclaim this chemical on-site and
then reuse it, this is considered recycling for TRI
reporting purposes and you must include the quantity
of the chemical that is recycled on-site each time it is
recycled in the total quantity reported as recycled for
the year.
Equation 11
Section 8.4 (Recycling on-site) = All quantities
used for on-site recycling associated with
methods reported in Section 7C (on-site recycling
processes)
Section 8.4 is not related to Sections 5 or 6.
Equation 12
Section 8.5 (Recycling off-site) = Section 6.2
(recycling) - Section 8.8 (off-site recycling) 1
Sections 8.6 and 8.7: Treatment
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 the Form R
and Form A Certification Statement Reporting Codes
and Instructions for Reporting Metals guidance
document). Quantities treated off-site that are
reported in Section 8.8 are excluded from Section 8.7.
Equation 13
Section 8.6 (Treatment on-site) = All quantities
used for on-site treatment associated with
methods reported in Section 7A (on-site waste
treatment methods and efficiency)
Section 8.6 is not related to Sections 5 or 6.
each equation, the parenthetical following “Section 8.8”
indicates which portion of § 8.8 is subtracted.
Toxics Release Inventory Reporting Forms and Instructions
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Part II. Chemical Identification Information
Equation 14
Section 8.7 (Treatment off-site) = Section 6.1
(quantities associated with P codes P37, P38, and
P39) + Section 6.2 (treatment) – Section 8.8 (offsite treatment) 1
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 III.
Example 23: 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 offsite 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)
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.
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) remedial actions;
(2) catastrophic events such as earthquakes,
fires, or floods; or
(3) 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,
Toxics Release Inventory Reporting Forms and Instructions
85
Part II. Chemical Identification Information
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 one
time events not associated with production processes,
Section 5 of Form R (on-site disposal and other
releases to the environment) and Section 6 (off-site
transfers for further waste management) must include
all on-site disposal and other releases and transfers
for disposal as appropriate, regardless of whether
they arise from catastrophic, remedial, or routine
process operations.
Avoid Double Counting in Sections 8.1 Through
8.8
Do not double or multiple count quantities in
Sections 8.1 through 8.8. The quantities reported in
each of those sections should be mutually exclusive.
In TRI-MEweb, any amounts that you designate as
non-production-related-waste (Section 8.8) will be
automatically excluded from production-related
waste (Sections 8.1-8.7).
Example 24: 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 off-site), plus
the 200 pounds that vaporized into the air, a total of 1,200 pounds. The quantity sent off-site must also be
reported in Section 6 (but not in Section 8.7) and the quantity that vaporized must be reported as a fugitive
emission in Section 5 (but not in Section 8.1b).
Toxics Release Inventory Reporting Forms and Instructions
86
Part II. Chemical Identification Information
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:
Equation 15
Production Ratio =
[Production Variable]Current Year
[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:
Example P.R. =
#of Refrigerators ProducedCurrent Year
# of Refrigerators ProducedPrior 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
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:
Equation 16
Activity Ratio =
[Activity Variable]Current Year
Example A.R. =
# of Molds CleanedCurrent Year
[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 CleanedPrior 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.
Toxics Release Inventory Reporting Forms and Instructions
87
Part II. Chemical Identification Information
• 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,
not 10% 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.
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Part II. Chemical Identification Information
Example 25: 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
12,000
ratio for toluene in this case is 1.2 (
) because refrigerator production levels best reflect the output of
10,000
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
20,000
pounds in the preceding year, the production ratio would be 0.77 (
).
26,000
Example 26: 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
5,200
activity ratio of 2.6 (
) represents the outcome of the activities involving toluene usage in the facility.
2,000
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
3,900
the prior year, the activity ratio is 1.3 (
).
3,000
Example 27: “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
89
Part II. Chemical Identification Information
Example 28: 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
Sample Production / Activity Variable
Agriculture, Construction, and Mining Machinery
Drill rigs produced
Manufacturing
Cement and Concrete Product Manufacturing
Tons of clinker produced
Clay Product and Refractory Manufacturing
Tons of brick manufactured
Chemical and Allied Products Merchant Wholesalers Total gallons of glycol ethers packaged
Coal Mining
Mine production in tons of coal
Fossil Fuel Electric Power Generation
Number of megawatt-hours of electricity produced
National Security and International Affairs
Man-days of training per year
Nitrogenous Fertilizer Manufacturing
Ammonium thiosulfate product produced (in tons)
Plastics Product Manufacturing
Pounds extruded
Synthetic Dye and Pigment Manufacturing
Number of color changeovers
Waste Treatment and Disposal
Tons of waste landfilled on-site
Petroleum Refineries
Gallons of gasoline repackaged
Example 29: 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
+ 0.87
13,500
×
1,000
13,500
= 1.08
Toxics Release Inventory Reporting Forms and Instructions
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Part II. Chemical Identification Information
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. Some activities may be multi-faceted or multiphased and impact different facility processes or span
across multiple years. For those activities, report on
the discrete projects that went into effect entirely or
in part during the reporting year. Accordingly, in
successive reporting years, you may report on later
facets or phases of the activity.
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. Newly implemented source reduction
activities include activities that were implemented, in
whole or in part, during the reporting year (e.g.,
improved loading procedures).
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 TRI
Pollution Prevention (P2) Search Tool. To learn
more, visit: https://www.epa.gov/tri/p2.
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.
• 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 dropdown list in
TRI-MEweb (see W-codes listed below).
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91
Part II. Chemical Identification Information
For each source reduction code you enter in TRIMEweb, a text box allows you to provide
additional details on that source reduction
practice. Similarly, to describe how each source
reduction practice was identified, a text box
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.
For each source reduction code you enter in TRIMEweb, 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.
TRI-MEweb then provides you with the option of
selecting from one or more possible barriers that your
facility might be facing with regard to the
implementation of source reduction activities. A list
of barrier codes is provided below. For each code,
you also have the option to provide additional
information in a text box. (This information is then
added to your entry in Section 8.11; see Section 8.11
instructions for additional information on barriers to
P2.)
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:
Equation 17
(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 TRI
Pollution
Prevention
Search
Tool
at
https://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%.
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.
Toxics Release Inventory Reporting Forms and Instructions
92
Part II. Chemical Identification Information
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 shut
off valves
W35 Installed vapor recovery systems
W36 Implemented inspection or monitoring
program of potential spill or leak sources
W39 Other changes made in spill and leak
prevention
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
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
Toxics Release Inventory Reporting Forms and Instructions
93
Part II. Chemical Identification Information
Methods to Identify Source Reduction Activities
T01 Internal pollution prevention opportunity
audit(s)
T02 External pollution prevention opportunity
audit(s)
T03 Materials balance audits
T04 Participative team management
T05 Employee recommendation (independent of
a formal company program
T06 Employee recommendation (under a formal
company program
T07 State government technical assistance
program
T08 Federal government technical assistance
program
T09 Trade association/industry technical
assistance program
T10 Vendor assistance
T11 Other
Estimated Annual Reduction Range Codes
R1 = 100% (elimination of the chemical)
R2 = greater than or equal to 50%, but less than
100%
R3 = greater than or equal to 25%, but less than
50%
R4 = greater than or equal 15%, but less than to
25%
R5 = greater than or equal 5%, but less than to
15%
R6 = greater than 0%, but less than 5%
Example 30: Source Reduction
At a facility that manufactures and paints wood furniture various processes contain EPCRA Section 313
chemicals. Below are examples of the activities considered for reporting in Section 8.10.
A. Source Reduction initiated during the reporting year. By examining the gluing process, the facility
discovered that a new drum of glue is opened at the beginning of each shift, whether or not the old drum
is empty. By adding a mechanism that prevents the drum from being changed before it is empty, the
facility eliminated the need for disposing unused glue (W54). This activity eliminates the glue at its
source and is considered source reduction.
B. Source Reduction implemented over multiple years. With the assistance of a vendor and through a team
assessment of the processes and chemicals used, the facility identified several changes and planned for
their implementation over a three-year span. The first year the facility installed internal stop-loss valves
and leak detection to finishing processes (W33); the second year they substituted coating materials for
a table top finish from an acetone to a water based finish (W73); and the third year they modified their
in-line product quality monitoring system (W15). The activities all reduce or eliminate quantities of a
chemical entering the waste stream and released into the environment and are considered source
reduction, each reported for the year implementation commenced.
C. An activity that is NOT considered Source Reduction. The painting process at the facility generates a
solvent waste that is collected and recovered. The recovered solvent is recycled and used to clean the
painting equipment. This activity does not reduce the amount of EPCRA Section 313 chemical from
entering the waste stream, and therefore is not considered a source reduction activity.
Toxics Release Inventory Reporting Forms and Instructions
94
Part II. Chemical Identification Information
Example 31: Green Chemistry
Six codes that describe green chemistry and green engineering practices were 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
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.
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.
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.
W50
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.
If efficiency of syntheses was improved by using of a different catalyst, select instead W53 Used a different
process catalyst.
W56
W57
W84
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
95
Part II. Chemical Identification Information
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.
You can use the provided text boxes in TRI-MEweb
to describe your source reduction, recycling, or
pollution control activities.
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 https://www.epa.gov/tri/p2 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 were
affected?
• Which technologies and materials were
used?
• Which release (to air, water land) or waste
management quantities changed?
• Were there other benefits (e.g., costs,
product quality?)
• 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
https://www.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 TRIMEweb and describe specifically how one of these
barrier categories applies to your facility:
Barrier Categories
B1 Insufficient capital to install new source
reduction equipment or implement new source
reduction activities/initiatives.
B2 Require technical information on pollution
prevention techniques applicable to specific
production processes.
Toxics Release Inventory Reporting Forms and Instructions
96
Part II. Chemical Identification Information
B3
Concern that product quality may decline as a
result of source reduction.
B4 Source reduction activities were implemented
but were unsuccessful.
B5 Specific regulatory/permit burdens
B6 Pollution prevention previously implemented
additional reduction does not appear
technically or economically feasible.
B7 No known substitutes or alternative
technologies.
B8 Reduction does not appear to be technically
feasible.
B99 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.
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., Emissions
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
Section 9. Miscellaneous Information
(Form R & A)
If you do so, each topic you have selected will be
included in your Section 9.1 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.).
9.1
9.2
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. 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
Optional Pollution Prevention and
Additional Information for This
Toxic Chemical on Your Form A
Certification Statement
Your facility may provide additional information
pertaining to pollution prevention or other topics for
each Toxic Chemical or Mixture Component
included on your Form A Certification Statement
submission. Information provided in this section may
provide the Agency and/or the public with useful data
that helps explain your use of Form A Certification
Statement. For example, your facility could include
information on steps it has taken to reduce its
manufacture, processing, or other use of the
chemical. Do not submit information you consider to
be CBI or otherwise protected.
Toxics Release Inventory Reporting Forms and Instructions
97
Part II. Chemical Identification Information
TRI-MEweb allows you to categorize optional
information provided by checking a box next to the
topic to which your information pertains:
• Changes in Production Levels
• Source Reduction Activity Reduced
Activity Involving this Chemical
• One-Time or Intermittent Events Involving
this Chemical
• No TRI Report Expected for this Chemical
Next Year
If you do so, each topic you have selected will be
included in your Section 9.2 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 useful factors
related to how your facility deals with any
chemicals included on the Form A Certification
Statement. Note that if you select the last topic listed
above, it is helpful to include the reason you will not
be submitting a report next year (e.g., facility
closure, move, temporary shutdown).
Toxics Release Inventory Reporting Forms and Instructions
98
Instructions for Completing Form R Schedule 1 (Dioxin and Dioxin-like Compounds)
E.
Instructions for Completing
Form R Schedule 1 (Dioxin
and Dioxin-like
Compounds)
E.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.
E.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.
Emissions factors for dioxin and dioxin-like
compounds are also based on emissions factors for
the individual compounds within the category. EPA’s
guidance document for dioxin and dioxin-like
compounds (Emergency Planning And Community
Right-To-Know Act - Section 313: Guidance for
Reporting Toxic Chemicals within the Dioxin and
Dioxin-like Compounds Category, EPA-745-B-00
021, December 2000) includes tables that contain the
emissions factors for the individual members of the
dioxin and dioxin-like compounds category. Since
measured data and emissions 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.
E.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 9). 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 that follows Figure 9.
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
99
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 the table below.
Figure 9. Hypothetical Form R, Section 5.1 and Form R Schedule 1, Section 5.1
Toxics Release Inventory Reporting Forms and Instructions
100
Instructions for Completing Form R Schedule 1 (Dioxin and Dioxin-like Compounds)
Individual Members of the Dioxin and Dioxin-like Compounds Category
Box #
1.
CAS#
01746–01–6
Chemical Name
2,3,7,8-Tetrachlorodibenzo- p-dioxin
Abbreviation
2,3,7,8-TCDD
2.
40321–76–4
1,2,3,7,8-Pentachlorodibenzo- p-dioxin
1,2,3,7,8-PeCDD
3.
39227–28–6
1,2,3,4,7,8-Hexachlorodibenzo- p-dioxin
1,2,3,4,7,8-HxCDD
4.
57653–85–7
1,2,3,6,7,8-Hexachlorodibenzo- p-dioxin
1,2,3,6,7,8-HxCDD
5.
19408–74–3
1,2,3,7,8,9-Hexachlorodibenzo- p-dioxin
1,2,3,7,8,9-HxCDD
6.
35822–46–9
1,2,3,4,6,7,8-Heptachlorodibenzo- p-dioxin
1,2,3,4,6,7,8-HpCDD
7.
03268–87–9
1,2,3,4,6,7,8,9-Octachlorodibenzo- p-dioxin
1,2,3,4,6,7,8,9-OCDD
8.
51207–31–9
2,3,7,8-Tetrachlorodibenzofuran
2,3,7,8-TCDF
9.
57117–41–6
1,2,3,7,8-Pentachlorodibenzofuran
1,2,3,7,8-PeCDF
10.
57117–31–4
2,3,4,7,8-Pentachlorodibenzofuran
2,3,4,7,8-PeCDF
11.
70648–26–9
1,2,3,4,7,8-Hexachlorodibenzofuran
1,2,3,4,7,8-HxCDF
12.
57117–44–9
1,2,3,6,7,8-Hexachlorodibenzofuran
1,2,3,6,7,8-HxCDF
13.
72918–21–9
1,2,3,7,8,9-Hexachlorodibenzofuran
1,2,3,7,8,9-HxCDF
14.
60851–34–5
2,3,4,6,7,8-Hexachlorodibenzofuran
2,3,4,6,7,8-HxCDF
15.
67562–39–4
1,2,3,4,6,7,8-Heptachlorodibenzofuran
1,2,3,4,6,7,8-HpCDF
16.
55673–89–7
1,2,3,4,7,8,9-Heptachlorodibenzofuran
1,2,3,4,7,8,9-HpCDF
17.
39001–02–0
1,2,3,4,6,7,8,9-Octachlorodibenzofuran
1,2,3,4,6,7,8,9-OCDF
E.4 How do I report Form R
Schedule 1 Data?
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. 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 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.
Toxics Release Inventory Reporting Forms and Instructions
101
Optional Facility-Level Information and Non-Reporting
F.
Optional Facility-Level
Information and NonReporting
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.
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 exemption
• Facility fell below reporting threshold for
one or more chemicals due to reason(s)
other than source reduction or use of an
exemption
Toxics Release Inventory Reporting Forms and Instructions
102
Table I. NAICS Codes
1.1 NAICS codes that correspond to
SIC codes 20 through 39:
311
Food Manufacturing
311111
311119
Dog and Cat Food Manufacturing
Other Animal Food Manufacturing (except
facilities primarily engaged in Custom Grain
Grinding for Animal Feed)
Flour Milling
Rice Milling
Malt Manufacturing
Wet Corn Milling
Soybean and Other Oilseed Processing
Fats and Oils Refining and Blending
Breakfast Cereal Manufacturing
Beet Sugar Manufacturing
Cane Sugar Manufacturing
Chocolate and Confectionery Manufacturing
from Cacao Beans
Confectionery Manufacturing from Purchased
Chocolate
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)
Frozen Fruit, Juice, and Vegetable
Manufacturing
Frozen Specialty Food Manufacturing
Fruit and Vegetable Canning
Specialty Canning
Dried and Dehydrated Food Manufacturing
Fluid Milk Manufacturing
Creamery Butter Manufacturing
Cheese Manufacturing
Dry, Condensed, and Evaporated Dairy Product
Manufacturing
Ice Cream and Frozen Dessert Manufacturing
Animal (except Poultry) Slaughtering (except
for facilities primarily engaged in Custom
Slaughtering for individuals)
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)]
Rendering and Meat Byproduct Processing
Poultry Processing
Seafood Product Preparation and Packaging
Commercial Bakeries
311211
311212
311213
311221
311224
311225
311230
311313
311314
311351
311352
311340
311411
311412
311421
311422
311423
311511
311512
311513
311514
311520
311611
311612
311613
311615
311710
311812
311813
311821
311824
311830
311911
311919
311920
311930
311941
311942
311991
311999
Frozen Cakes, Pies, and Other Pastries
Manufacturing
Cookie and Cracker Manufacturing
Dry Pasta, Dough, and Flour Mixes
Manufacturing from Purchased Flour
Tortilla Manufacturing
Roasted Nuts and Peanut Butter Manufacturing
Other Snack Food Manufacturing
Coffee and Tea Manufacturing
Flavoring Syrup and Concentrate
Manufacturing
Mayonnaise, Dressing, and Other Prepared
Sauce Manufacturing
Spice and Extract Manufacturing
Perishable Prepared Food Manufacturing
All Other Miscellaneous Food Manufacturing
312
Beverage and Tobacco Product
Manufacturing
312111
312112
312113
312120
312130
312140
312210
312230
Soft Drink Manufacturing
Bottled Water Manufacturing (except facilities
primarily engaged in bottling mineral or spring
water)
Ice Manufacturing
Breweries
Wineries
Distilleries
Tobacco Stemming and Redrying
Tobacco Manufacturing
313
Textile Mills
313110
313210
313220
313320
Fiber, Yarn, and Thread Mills
Broadwoven Fabric Mills
Narrow Fabric Mills and Schiffli Machine
Embroidery
Nonwoven Fabric Mills
Knit Fabric 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)
Fabric Coating Mills
314
Textile Product Mills
314110
314120
Carpet and Rug Mills
Curtain and Linen Mills (except facilities
primarily engaged in making custom drapery for
retail sale)
313230
313241
313310
Toxics Release Inventory Reporting Forms and Instructions
I-1
Table I. NAICS Codes
314910
314994
314999
Textile Bag and Canvas Mills
Rope, Cordage, Twine, Tire Cord, and Tire
Fabric Mills
All Other Miscellaneous Textile Product Mills
(except facilities engaged in binding carpets and
rugs for the trade, carpet cutting and binding,
and embroidering on textile products (except
apparel) for the trade)
315
Apparel Manufacturing
315110
315190
315210
315220
Hosiery and Sock Mills
Other Apparel Knitting Mills
Cut and Sew Apparel Contractors
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)
Women’s, Girls’, and Infants’ Cut and Sew
Apparel Manufacturing
Other Cut and Sew Apparel Manufacturing
Apparel Accessories and Other Apparel
Manufacturing
315240
315280
315990
316
Leather and Allied Product
Manufacturing
316110
316210
316992
316998
Leather and Hide Tanning and Finishing
Footwear Manufacturing
Women’s Handbag and Purse Manufacturing
All Other Leather Good and Allied Product
Manufacturing
321
Wood Product Manufacturing
321113
321114
321211
321212
321213
Sawmills
Wood Preservation
Hardwood Veneer and Plywood Manufacturing
Softwood Veneer and Plywood Manufacturing
Engineered Wood Member (except Truss)
Manufacturing
Truss Manufacturing
Reconstituted Wood Product Manufacturing
Wood Window and Door Manufacturing
Cut Stock, Resawing Lumber, and Planing
Other Millwork (including Flooring)
Wood Container and Pallet Manufacturing
Manufactured Home (Mobile Home)
Manufacturing
Prefabricated Wood Building Manufacturing
All Other Miscellaneous Wood Product
Manufacturing
321214
321219
321911
321912
321918
321920
321991
321992
321999
322
Paper Manufacturing
322110
322121
Pulp Mills
Paper (except Newsprint) Mills
322122
322130
322211
322212
322219
322220
322230
322291
322299
Newsprint Mills
Paperboard Mills
Corrugated and Solid Fiber Box Manufacturing
Folding Paperboard Box Manufacturing
Other Paperboard Container Manufacturing
Paper Bag and Coated and Treated Paper
Manufacturing
Stationery Product Manufacturing
Sanitary Paper Product Manufacturing
All Other Converted Paper Product
Manufacturing
323
Printing and Related Support
Activities
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)
Commercial Screen Printing
Books Printing
Support Activities for Printing
323113
323117
323120
324
Petroleum and Coal Products
Manufacturing
324110
324121
Petroleum Refineries
Asphalt Paving Mixture and Block
Manufacturing
Asphalt Shingle and Coating Materials
Manufacturing
Petroleum Lubricating Oil and Grease
Manufacturing
All Other Petroleum and Coal Products
Manufacturing
324122
324191
324199
325
Chemical Manufacturing
325110
325120
325130
325180
325193
325194
Petrochemical Manufacturing
Industrial Gas Manufacturing
Synthetic Dye and Pigment Manufacturing
Other Basic Inorganic Chemical Manufacturing
Ethyl Alcohol Manufacturing
Cyclic Crude, Intermediate, and Gum and Wood
Chemical Manufacturing
All Other Basic Organic Chemical
Manufacturing
Plastics Material and Resin Manufacturing
Synthetic Rubber Manufacturing
Artificial and Synthetic Fibers and Filaments
Manufacturing
Nitrogenous Fertilizer Manufacturing
325199
325211
325212
325220
325311
Toxics Release Inventory Reporting Forms and Instructions
I-2
Table I. NAICS Codes
325312
325314
325320
325411
325412
325413
325414
325510
325520
325611
325612
325613
325620
325910
325920
325991
325992
325998
Phosphatic Fertilizer Manufacturing
Fertilizer (Mixing Only) Manufacturing
Pesticide and Other Agricultural Chemical
Manufacturing
Medicinal and Botanical Manufacturing
Pharmaceutical Preparation Manufacturing
In-Vitro Diagnostic Substance Manufacturing
Biological Product (except Diagnostic)
Manufacturing
Paint and Coating Manufacturing
Adhesive Manufacturing
Soap and Other Detergent Manufacturing
Polish and Other Sanitation Good
Manufacturing
Surface Active Agent Manufacturing
Toilet Preparation Manufacturing
Printing Ink Manufacturing
Explosives Manufacturing
Custom Compounding of Purchased Resins
Photographic Film, Paper, Plate, and Chemical
Manufacturing
All Other Miscellaneous Chemical Product and
Preparation Manufacturing (except facilities
primarily engaged in Aerosol can filling on a
job order or contract Basis)
326
Plastics and Rubber Products
Manufacturing
326111
326112
Plastics Bag and Pouch Manufacturing
Plastics Packaging Film and Sheet (including
Laminated) Manufacturing
Unlaminated Plastics Film and Sheet (except
Packaging) Manufacturing
Unlaminated Plastics Profile Shape
Manufacturing
Plastics Pipe and Pipe Fitting Manufacturing
Laminated Plastics Plate, Sheet (except
Packaging), and Shape Manufacturing
Polystyrene Foam Product Manufacturing
Urethane and Other Foam Product (except
Polystyrene) Manufacturing
Plastics Bottle Manufacturing
Plastics Plumbing Fixture Manufacturing
All Other Plastics Product Manufacturing
Tire Manufacturing (except Retreading)
Rubber and Plastics Hoses and Belting
Manufacturing
Rubber Product Manufacturing for Mechanical
Use
All Other Rubber Product Manufacturing
326113
326121
326122
326130
326140
326150
326160
326191
326199
326211
326220
326291
326299
327
Nonmetallic Mineral Product
Manufacturing
327110
Pottery, Ceramics, and Plumbing Fixture
Manufacturing
Clay Building Material and Refractories
Manufacturing
Flat Glass Manufacturing
Other Pressed and Blown Glass and Glassware
Manufacturing
Glass Container Manufacturing
Glass Product Manufacturing Made of
Purchased Glass
Cement Manufacturing
Ready-Mix Concrete Manufacturing
Concrete Block and Brick Manufacturing
Concrete Pipe Manufacturing
Other Concrete Product Manufacturing
Lime Manufacturing
Gypsum Product Manufacturing
Abrasive Product Manufacturing
Cut Stone and Stone Product Manufacturing
Ground or Treated Mineral and Earth
Manufacturing
Mineral Wool Manufacturing
All Other Miscellaneous Nonmetallic Mineral
Product Manufacturing
327120
327211
327212
327213
327215
327310
327320
327331
327332
327390
327410
327420
327910
327991
327992
327993
327999
331
Primary Metal Manufacturing
331110
Iron and Steel Mills and Ferroalloy
Manufacturing
Iron and Steel Pipe and Tube Manufacturing
from Purchased Steel
Rolled Steel Shape Manufacturing
Steel Wire Drawing
Alumina Refining and Primary Aluminum
Production
Secondary Smelting and Alloying of Aluminum
Aluminum Sheet, Plate, and Foil Manufacturing
Other Aluminum Rolling, Drawing, and
Extruding
Nonferrous Metal (except Aluminum) Smelting
and Refining
Copper Rolling, Drawing, Extruding, and
Alloying
Nonferrous Metal (except Copper and
Aluminum) Rolling, Drawing, and Extruding
Secondary Smelting, Refining, and Alloying of
Nonferrous Metal (except Copper and
Aluminum)
Iron Foundries
331210
331221
331222
331313
331314
331315
331318
331410
331420
331491
331492
331511
Toxics Release Inventory Reporting Forms and Instructions
I-3
Table I. NAICS Codes
331512
331513
331523
331524
331529
Steel Investment Foundries
Steel Foundries (except Investment)
Nonferrous Metal Die-Casting Foundries
Aluminum Foundries (except Die-Casting)
Other Nonferrous Metal Foundries (except DieCasting)
332
Fabricated Metal Product
Manufacturing
332111
332112
332114
332117
332119
Iron and Steel Forging
Nonferrous Forging
Custom Roll Forming
Powder Metallurgy Part Manufacturing
Metal Crown, Closure, and Other Metal
Stamping (Except Automotive)
Metal Kitchen Cookware, Utensil, Cutlery, and
Flatware (except Precious) Manufacturing
Saw Blade and Hand tool Manufacturing
Prefabricated Metal Building and Component
Manufacturing
Fabricated Structural Metal Manufacturing
Plate Work Manufacturing
Metal Window and Door Manufacturing
Sheet Metal Work Manufacturing
Ornamental and Architectural Metal Work
Manufacturing
Power Boiler and Heat Exchanger
Manufacturing
Metal Tank (Heavy Gauge) Manufacturing
Metal Can Manufacturing
Other Metal Container Manufacturing
Hardware Manufacturing
Spring Manufacturing
Other Fabricated Wire Product Manufacturing
Machine Shops
Precision Turned Product Manufacturing
Bolt, Nut, Screw, Rivet, and Washer
Manufacturing
Metal Heat Treating
Metal Coating, Engraving (except Jewelry and
Silverware), and Allied Services to
Manufacturers
Electroplating, Plating, Polishing, Anodizing,
and Coloring
Industrial Valve Manufacturing
Fluid Power Valve and Hose Fitting
Manufacturing
Plumbing Fixture Fitting and Trim
Manufacturing
332215
332216
332311
332312
332313
332321
332322
332323
332410
332420
332431
332439
332510
332613
332618
332710
332721
332722
332811
332812
332813
332911
332912
332913
332919
332991
332992
332993
332994
332996
332999
Other Metal Valve and Pipe Fitting
Manufacturing
Ball and Roller Bearing Manufacturing
Small Arms Ammunition Manufacturing
Ammunition (except Small Arms)
Manufacturing
Small Arms, Ordnance, and Ordnance
Accessories Manufacturing
Fabricated Pipe and Pipe Fitting Manufacturing
All Other Miscellaneous Fabricated Metal
Product Manufacturing
333
Machinery Manufacturing
333111
333112
Farm Machinery and Equipment Manufacturing
Lawn and Garden Tractor and Home Lawn and
Garden Equipment Manufacturing
Construction Machinery Manufacturing
Mining Machinery and Equipment
Manufacturing
Oil and Gas Field Machinery and Equipment
Manufacturing
Food Product Machinery Manufacturing
Semiconductor Machinery Manufacturing
Sawmill, Woodworking, and Paper Machinery
Manufacturing
Printing Machinery and Equipment
Manufacturing
Other Industrial Machinery Manufacturing
Optical Instrument and Lens Manufacturing
Photographic and Photocopying Equipment
Manufacturing
Other Commercial and Service Industry
Machinery Manufacturing
Industrial and Commercial Fan and Blower and
Air Purification Equipment Manufacturing
Heating Equipment (except Warm Air
Furnaces) Manufacturing
Air-Conditioning and Warm Air Heating
Equipment and Commercial and Industrial
Refrigeration Equipment Manufacturing
Industrial Mold Manufacturing
Special Die and Tool, Die Set, Jig, and Fixture
Manufacturing
Cutting Tool and Machine Tool Accessory
Manufacturing
Machine Tool Manufacturing
Rolling Mill and Other Metalworking
Machinery Manufacturing
Turbine and Turbine Generator Set Units
Manufacturing
333120
333131
333132
333241
333242
333243
333244
333249
333314
333316
333318
333413
333414
333415
333511
333514
333515
333517
333519
333611
Toxics Release Inventory Reporting Forms and Instructions
I-4
Table I. NAICS Codes
333612
333613
333618
333912
333914
333921
333922
333923
333924
333991
333992
333993
333994
333995
333996
333997
333999
Speed Changer, Industrial High-Speed Drive,
and Gear Manufacturing
Mechanical Power Transmission Equipment
Manufacturing
Other Engine Equipment Manufacturing
Air and Gas Compressor Manufacturing
Measuring, Dispensing, and Other Pumping
Equipment Manufacturing
Elevator and Moving Stairway Manufacturing
Conveyor and Conveying Equipment
Manufacturing
Overhead Traveling Crane, Hoist, and Monorail
System Manufacturing
Industrial Truck, Tractor, Trailer, and Stacker
Machinery Manufacturing
Power-Driven Handtool Manufacturing
Welding and Soldering Equipment
Manufacturing
Packaging Machinery Manufacturing
Industrial Process Furnace and Oven
Manufacturing
Fluid Power Cylinder and Actuator
Manufacturing
Fluid Power Pump and Motor Manufacturing
Scale and Balance Manufacturing
All Other Miscellaneous General Purpose
Machinery Manufacturing
334
Computer and Electronic Product
Manufacturing
334111
334112
334118
Electronic Computer Manufacturing
Computer Storage Device Manufacturing
Computer Terminal and Other Computer
Peripheral Equipment Manufacturing
Telephone Apparatus Manufacturing
Radio and Television Broadcasting and
Wireless Communications Equipment
Manufacturing
Other Communications Equipment
Manufacturing
Audio and Video Equipment Manufacturing
Bare Printed Circuit Board Manufacturing
Semiconductor and Related Device
Manufacturing
Capacitor, Resistor, Coil, Transformer, and
Other Inductor Manufacturing
Electronic Connector Manufacturing
Printed Circuit Assembly (Electronic Assembly)
Manufacturing
Other Electronic Component Manufacturing
334210
334220
334290
334310
334412
334413
334416
334417
334418
334419
334510
334511
334512
334513
334514
334515
334516
334517
334519
334613
334614
Electromedical and Electrotherapeutic
Apparatus Manufacturing
Search, Detection, Navigation, Guidance,
Aeronautical, and Nautical System and
Instrument Manufacturing
Automatic Environmental Control
Manufacturing for Residential, Commercial,
and Appliance Use
Instruments and Related Products
Manufacturing for Measuring, Displaying, and
Controlling Industrial Process Variables
Totalizing Fluid Meter and Counting Device
Manufacturing
Instrument Manufacturing for Measuring and
Testing Electricity and Electrical Signals
Analytical Laboratory Instrument
Manufacturing
Irradiation Apparatus Manufacturing
Other Measuring and Controlling Device
Manufacturing
Blank Magnetic and Optical Recording Media
Manufacturing
Software and Other Prerecorded Compact Disc,
Tape and Record Reproducing (except facilities
primarily engaged in mass reproducing prerecorded Video Cassettes, and mass reproducing
Video tape or disk)
335
Electrical Equipment, Appliance, and
Component Manufacturing
335110
335121
Electric Lamp Bulb and Part Manufacturing
Residential Electric Lighting Fixture
Manufacturing
Commercial, Industrial, and Institutional
Electric Lighting Fixture Manufacturing
Other Lighting Equipment Manufacturing
Small Electrical Appliance Manufacturing
Major Household Appliance Manufacturing
Power, Distribution, and Specialty Transformer
Manufacturing
Motor and Generator Manufacturing (except
facilities primarily engaged in armature
rewinding on a factory basis)
Switchgear and Switchboard Apparatus
Manufacturing
Relay and Industrial Control Manufacturing
Storage Battery Manufacturing
Primary Battery Manufacturing
Fiber Optic Cable Manufacturing
Other Communication and Energy Wire
Manufacturing
Current-Carrying Wiring Device Manufacturing
335122
335129
335210
335220
335311
335312
335313
335314
335911
335912
335921
335929
335931
Toxics Release Inventory Reporting Forms and Instructions
I-5
Table I. NAICS Codes
335932
335991
335999
Noncurrent-Carrying Wiring Device
Manufacturing
Carbon and Graphite Product Manufacturing
All Other Miscellaneous Electrical Equipment
and Component Manufacturing
336
Transportation Equipment
Manufacturing
336111
336112
336120
336211
336212
336213
336214
336310
Automobile Manufacturing
Light Truck and Utility Vehicle Manufacturing
Heavy Duty Truck Manufacturing
Motor Vehicle Body Manufacturing
Truck Trailer Manufacturing
Motor Home Manufacturing
Travel Trailer and Camper Manufacturing
Motor Vehicle Gasoline Engine and Engine
Parts Manufacturing
Motor Vehicle Electrical and Electronic
Equipment Manufacturing
Motor Vehicle Steering and Suspension
Components (except Spring) Manufacturing
Motor Vehicle Brake System Manufacturing
Motor Vehicle Transmission and Power Train
Parts Manufacturing
Motor Vehicle Seating and Interior Trim
Manufacturing
Motor Vehicle Metal Stamping
Motor Vehicle Parts Manufacturing
Aircraft Manufacturing
Aircraft Engine and Engine Parts
Manufacturing
Other Aircraft Parts and Auxiliary Equipment
Manufacturing
Guided Missile and Space Vehicle
Manufacturing
Guided Missile and Space Vehicle Propulsion
Unit and Propulsion Unit Parts Manufacturing
Other Guided Missile and Space Vehicle Parts
and Auxiliary Equipment Manufacturing
Railroad Rolling Stock Manufacturing
Ship Building and Repairing
Boat Building
Motorcycle, Bicycle, and Parts Manufacturing
Military Armored Vehicle, Tank, and Tank
Component Manufacturing
All Other Transportation Equipment
Manufacturing
336320
336330
336340
336350
336360
336370
336390
336411
336412
336413
336414
336415
336419
336510
336611
336612
336991
336992
336999
337
Furniture and Related Product
Manufacturing
337110
337910
337920
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)
Upholstered Household Furniture
Manufacturing (except facilities primarily
engaged in the retail sale of household furniture
and that manufacture custom made upholstered
household furniture)
Non-upholstered Wood Household Furniture
Manufacturing (except facilities primarily
engaged in the retail sale of household furniture
and that manufacture non-upholstered,
household type, custom wood furniture)
Metal Household Furniture Manufacturing
Household Furniture (except Wood and Metal)
Manufacturing
Institutional Furniture Manufacturing
Wood Office Furniture Manufacturing
Custom Architectural Woodwork and Millwork
Manufacturing
Office Furniture (except Wood) Manufacturing
Showcase, Partition, Shelving, and Locker
Manufacturing
Mattress Manufacturing
Blind and Shade Manufacturing
339
Miscellaneous Manufacturing
339112
339113
Surgical and Medical Instrument Manufacturing
Surgical Appliance and Supplies Manufacturing
(except facilities primarily engaged in
manufacturing orthopedic devices to
prescription in a retail environment)
Dental Equipment and Supplies Manufacturing
Ophthalmic Goods Manufacturing (except lens
grinding facilities that are primarily engaged in
the retail sale of eyeglasses and contact lenses to
prescription for individuals)
Jewelry and Silverware Manufacturing
Silverware and Hollowware Manufacturing
Jewelers’ Material and Lapidary Work
Manufacturing
Costume Jewelry and Novelty Manufacturing
Sporting and Athletic Goods Manufacturing
Doll Toy, and Game Manufacturing
Game, Toy, and Children’s Vehicle
Manufacturing
Office Supplies (except Paper) Manufacturing
Lead Pencil and Art Goods Manufacturing
337121
337122
337124
337125
337127
337211
337212
337214
337215
339114
339115
339910
339912
339913
339914
339920
339930
339932
339940
339942
Toxics Release Inventory Reporting Forms and Instructions
I-6
Table I. NAICS Codes
339943
339944
339950
339991
339992
339993
339994
339995
339999
113310
111998
211130
212324
212325
212393
212399
488390
511110
511120
511130
Marking Device Manufacturing
Carbon Paper and Inked Ribbon Manufacturing
Sign Manufacturing
Gasket, Packing, and Sealing Device
Manufacturing
Musical Instrument Manufacturing
Fastener, Button, Needle, and Pin
Manufacturing
Broom, Brush, and Mop Manufacturing
Burial Casket Manufacturing
All Other Miscellaneous Manufacturing
Logging
All Other Miscellaneous Crop Farming
(Limited to facilities primarily engaged in
reducing maple sap to maple syrup)
Natural Gas Extraction (limited to facilities
that recover sulfur from natural gas)
Kaolin and Ball Clay Mining (limited to
facilities operating without a mine or quarry and
that are primarily engaged in beneficiating
kaolin and clay)
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)
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)
All Other Nonmetallic Mineral Mining
(limited to facilities operating without a mine or
quarry that are primarily engaged in
beneficiating nonmetallic minerals)
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)
Newspaper Publishers
Periodical Publishers
Book Publishers
511140
511191
511199
512250
512230
519130
541713
541715
811490
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)
Greeting Card Publishers
All Other Publishers
Record Production and Distribution
Music Publishers (except facilities primarily
Engaged in Music copyright authorizing use,
Music copyright buying and licensing, and
Music publishers working on their own account)
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
Research and Development in
Nanotechnology
Research and Development in the Physical,
Engineering, and Life Sciences (except
Nanotechnology and 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)
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-7
Table I. NAICS Codes
1.2
NAICS codes that correspond to
SIC codes other than 20 through
39:
212
Mining (except Oil and Gas)
212111
212112
212113
212221
212222
212230
212299
Bituminous Coal and Lignite Surface Mining
Bituminous Coal Underground Mining
Anthracite Mining
Gold Ore Mining
Silver Ore Mining
Copper, Nickel, Lead, and Zinc Mining
All Other Metal Ore Mining
2211
Electric Utilities (limited to facilities
that combust coal and/or oil for the
purpose of generating power for
distribution in commerce)
221111
221112
221113
221118
221121
221122
221330
Hydroelectric Power Generation
Fossil Fuel Electric Power Generation
Nuclear Electric Power Generation
Other Electric Power Generation
Electric Bulk Power Transmission and Control
Electric Power Distribution
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.)
Other Chemical and Allied Products
Merchant Wholesalers
Petroleum Bulk Stations and Terminals
Business to Business Electronic Markets
(limited to facilities previously classified in
5169, Chemicals and Allied Products, NEC)
Wholesale Trade Agents and Brokers
(limited to facilities previously classified in
5169, Chemicals and Allied Products, NEC)
Hazardous Waste Collection (limited to
facilities primarily engaged in solvent recovery
services on a contract or fee basis)
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.)
Solid Waste Landfill (limited to facilities
regulated under the Resource Conservation and
Recovery Act, subtitle C, 42 U.S.C. 6921, et
seq.)
424690
424710
425110
425120
562112
562211
562212
562213
562219
562920
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.)
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.)
Materials Recovery Facilities (Limited to
facilities regulated under the Resource
Conservation and Recovery Act, subtitle C, 42
U.S.C. 6921 et seq.)
Toxics Release Inventory Reporting Forms and Instructions
I-8
Table II. EPCRA Section 313 Chemical List For Reporting Year 2019
(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.
Note: Chemicals may be added to or deleted from the list. The TRI website (https://www.epa.gov/toxics-releaseinventory-tri-program/tri-listed-chemicals) provides up-to-date information on the status of 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). Separate supplier notification requirements can be
found here: https://ofmpub.epa.gov/apex/guideme_ext/f?p=guideme:gd-title:::::title:supplier_notification.
Chemical Qualifiers
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. 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. 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
Only if it is a yellow or white form.
Sulfuric acid (acid aerosols including mists, vapors, gas, fog,
and other airborne forms of any particle size)
7664-93-9
Only if it is an aerosol form as
defined.
Vanadium (except when contained in an alloy)
7440-62-2
Except if it is contained in an alloy.
Zinc (fume or dust)
7440-66-6
Only if it is in a fume or dust form.
The qualifier for the following three chemicals is based on the chemical activity rather than the form of the
chemical. These chemicals are subject to EPCRA section 313 reporting requirements only when the indicated
activity is performed.
Toxics Release Inventory Reporting Forms and Instructions
II-1
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
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.
Supplier Notification Implications
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.
Qualifier Definitions
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 thresholds,
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
Toxics Release Inventory Reporting Forms and Instructions
II-2
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
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 aerosols generated from aqueous
solutions are.
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.
Asbestos (friable). The listing for asbestos is qualified
by the term “friable,” referring to the physical
characteristic of being able to be crumbled, pulverized,
or reducible to a powder with hand pressure. Only
manufacturing, processing, or otherwise use of
asbestos in the friable form triggers reporting. Supplier
notification applies only to distribution of mixtures or
other trade name products containing friable asbestos.
Aluminum Oxide (fibrous forms). The listing for
aluminum oxide is qualified by the term “fibrous
forms.” Fibrous refers to a man-made form of
aluminum oxide that is processed to produce strands or
filaments which can be cut to various lengths
depending on the application. Only manufacturing,
processing, or otherwise use of aluminum oxide in the
fibrous form triggers reporting. Supplier notification
applies only to distribution of mixtures or other trade
name products containing fibrous forms of aluminum
oxide.
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.
Toxics Release Inventory Reporting Forms and Instructions
II-3
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
Notes for Sections A and B of
following list of TRI chemicals:
CAS
Number
82-28-0
“Color Index” indicated by “C.I.”
* There are no de minimis levels for PBT chemicals,
except for supplier notification purposes (see:
https://www.epa.gov/toxics-release-inventory-triprogram/tri-listed-chemicals).
81-49-2
33089-61-1
61-82-5
7664-41-7
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
834-12-8
117-79-3
60-09-3
92-67-1
Chemical Name
Abamectin [Avermectin B1]
Acephate
(Acetylphosphoramidothioic
acid O,S-dimethyl ester)
Acetaldehyde
Acetamide
Acetonitrile
Acetophenone
2-Acetylaminofluorene
Acifluorfen, sodium salt [5-(2Chloro-4(trifluoromethyl)phenoxy)-2nitrobenzoic acid, sodium salt]
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Alachlor
Aldicarb
Aldrin [1,4:5,8Dimethanonaphthalene,
1,2,3,4,10,10-hexachloro1,4,4a,5,8,8a-hexahydro(1α,4α,4aβ,5α,8α,8aβ)-]
d-trans-Allethrin [d-transChrysanthemic acid of dallethrone]
Allyl alcohol
Allylamine
Allyl chloride
Aluminum (fume or dust)
Aluminum phosphide
Aluminum oxide (fibrous
forms)
Ametryn (N-Ethyl-N'-(1methylethyl)-6-(methylthio)1,3,5,-triazine-2,4-diamine)
2-Aminoanthraquinone
4-Aminoazobenzene
4-Aminobiphenyl
De
minimis
% 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
1.0
0.1
0.1
0.1
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
111-44-4
542-88-1
Chemical Name
1-Amino-2methylanthraquinone
1-Amino-2,4dibromoanthraquinone
Amitraz
Amitrole
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)
Anilazine [4,6-Dichloro-N-(2chlorophenyl)-1,3,5-triazin-2amine]
Aniline
o-Anisidine
p-Anisidine
o-Anisidine hydrochloride
Anthracene
Antimony
Arsenic
Asbestos (friable)
Atrazine (6-Chloro-N-ethylN'-(1-methylethyl)-1,3,5triazine-2,4-diamine)
Barium
Bendiocarb [2,2-Dimethyl1,3-benzodioxol-4-ol
methylcarbamate]
Benfluralin (N-Butyl-N-ethyl2,6-dinitro-4(trifluoromethyl)benzenamine
)
Benomyl
Benzal chloride
Benzamide
Benzene
Benzidine
Benzoic trichloride
(Benzotrichloride)
Benzo(g,h,i)perylene
Benzoyl chloride
Benzoyl peroxide
Benzyl chloride
Beryllium
Bifenthrin
Biphenyl
2,2-bis(Bromomethyl)-1,3propanediol
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(chloromethyl)ether
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
0.1
0.1
1.0
0.1
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
0.1
*
1.0
1.0
1.0
0.1
1.0
1.0
0.1
1.0
1.0
0.1
II-4
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
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
106-94-5
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
Chemical Name
Bis(2-chloro-1methylethyl)ether
Bis(tributyltin)oxide
Boron trichloride
Boron trifluoride
Bromacil (5-Bromo-6-methyl3-(1-methylpropyl)2,4(1H,3H)-pyrimidinedione)
Bromacil, lithium salt
[2,4(1H,3H)-Pyrimidinedione,
5-bromo-6-methyl-3-(1methylpropyl), lithium salt]
Bromine
1-Bromo-1-(bromomethyl)1,3-propanedicarbonitrile
Bromochlorodifluoromethane
(Halon 1211)
Bromoform
(Tribromomethane)
Bromomethane (Methyl
bromide)
1-Bromopropane
Bromotrifluoromethane
(Halon 1301)
Bromoxynil (3,5-Dibromo-4hydroxybenzonitrile)
Bromoxynil octanoate
(Octanoic acid, 2,6-dibromo4-cyanophenylester)
Brucine
1,3-Butadiene
Butyl acrylate
n-Butyl alcohol
sec-Butyl alcohol
tert-Butyl alcohol
1,2-Butylene oxide
Butyraldehyde
Cadmium
Calcium cyanamide
Captan [1H-Isoindole1,3(2H)-dione, 3a,4,7,7atetrahydro-2[(trichloromethyl)thio]-]
Carbaryl [1-Naphthalenol,
methylcarbamate]
Carbofuran
Carbon disulfide
Carbon tetrachloride
Carbonyl sulfide
Carboxin (5,6-Dihydro-2methyl-N-phenyl-1,4oxathiin-3-carboxamide)
Catechol
De
minimis
% Limit
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
CAS
Number
2439-01-2
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
1.0
1.0
1.0
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
1.0
0.1
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
Chemical Name
Chinomethionat [6-Methyl1,3-dithiolo[4,5-b]quinoxalin2-one]
Chloramben [Benzoic acid, 3amino-2,5-dichloro-]
Chlordane [4,7-Methanoindan,
1,2,4,5,6,7,8,8-octachloro2,3,3a,4,7,7a-hexahydro-]
Chlorendic acid
Chlorimuron ethyl [Ethyl-2[[[[(4-chloro-6methoxyprimidin-2yl)amino]carbonyl]amino]sulf
onyl]benzoate]
Chlorine
Chlorine dioxide
Chloroacetic acid
2-Chloroacetophenone
1-(3-Chloroallyl)-3,5,7-triaza1-azoniaadamantane chloride
p-Chloroaniline
Chlorobenzene
Chlorobenzilate
[Benzeneacetic acid, 4-chloroα-(4-chlorophenyl)-αhydroxy-, ethyl ester]
1-Chloro-1,1-difluoroethane
(HCFC-142b)
Chlorodifluoromethane
(HCFC-22)
Chloroethane (Ethyl chloride)
Chloroform
Chloromethane (Methyl
chloride)
Chloromethyl methyl ether
3-Chloro-2-methyl-1-propene
p-Chlorophenyl isocyanate
Chloropicrin
Chloroprene
3-Chloropropionitrile
Chlorotetrafluoroethane
1-Chloro-1,1,2,2tetrafluoroethane (HCFC124a)
2-Chloro-1,1,1,2tetrafluoroethane (HCFC-124)
Chlorothalonil [1,3Benzenedicarbonitrile,
2,4,5,6-tetrachloro-]
p-Chloro-o-toluidine
2-Chloro-1,1,1-trifluoroethane
(HCFC-133a)
Chlorotrifluoromethane (CFC13)
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
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
0.1
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
II-5
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
460-35-5
5598-13-0
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
Chemical Name
3-Chloro-1,1,1trifluoropropane (HCFC253fb)
Chlorpyrifos methyl [O,ODimethyl-O-(3,5,6-trichloro2-pyridyl)phosphorothioate]
Chlorsulfuron [2-Chloro-N[[(4-methoxy-6-methyl-1,3,5triazin-2yl)amino]carbonyl]benzenesul
fonamide]
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
Cupferron [Benzeneamine, Nhydroxy-N-nitroso,
ammonium salt]
Cyanazine
Cycloate
Cyclohexane
Cyclohexanol
Cyfluthrin [3-(2,2Dichloroethenyl)-2,2dimethylcyclopropanecarboxy
lic acid, cyano(4-fluoro-3phenoxyphenyl)methyl ester]
De
minimis
% Limit
1.0
CAS
Number
68085-85-8
1.0
1.0
94-75-7
533-74-4
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
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
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
95-50-1
541-73-1
106-46-7
25321-22-6
91-94-1
Chemical Name
Cyhalothrin [3-(2-Chloro3,3,3-trifluoro-1-propenyl)2,2dimethylcyclopropanecarboxy
lic acid cyano(3phenoxyphenyl)methyl ester]
2,4-D [Acetic acid, (2,4dichlorophenoxy)-]
Dazomet (Tetrahydro-3,5dimethyl-2H-1,3,5thiadiazine-2-thione)
Dazomet, sodium salt
[Tetrahydro-3,5-dimethyl-2H1,3,5-thiadiazine-2-thione,
ion(1-), sodium]
2,4-DB
2,4-D butoxyethyl ester
2,4-D butyl ester
2,4-D chlorocrotyl ester
Decabromodiphenyl oxide
Desmedipham
2,4-D 2-ethylhexyl ester
2,4-D 2-ethyl-4-methylpentyl
ester
Diallate [Carbamothioic acid,
bis(1-methylethyl)-S-(2,3dichloro-2-propenyl)ester]
2,4-Diaminoanisole
2,4-Diaminoanisole sulfate
4,4'-Diaminodiphenyl ether
2,4-Diaminotoluene
Diaminotoluene (mixed
isomers)
Diazinon
Diazomethane
Dibenzofuran
1,2-Dibromo-3-chloropropane
(DBCP)
1,2-Dibromoethane (Ethylene
dibromide)
Dibromotetrafluoroethane
(Halon 2402)
Dibutyl phthalate
Dicamba (3,6-Dichloro-2methoxybenzoic acid)
Dichloran [2,6-Dichloro-4nitroaniline]
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
Dichlorobenzene (mixed
isomers)
3,3'-Dichlorobenzidine
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
1.0
0.1
1.0
1.0
1.0
0.1
0.1
0.1
1.0
1.0
0.1
0.1
1.0
0.1
0.1
0.1
0.1
0.1
0.1
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
0.1
II-6
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
612-83-9
64969-34-2
75-27-4
764-41-0
110-57-6
1649-08-7
75-71-8
107-06-2
540-59-0
1717-00-6
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
Chemical Name
3,3'-Dichlorobenzidine
dihydrochloride
3,3'-Dichlorobenzidine sulfate
Dichlorobromomethane
1,4-Dichloro-2-butene
trans-1,4-Dichloro-2-butene
1,2-Dichloro-1,1difluoroethane (HCFC-132b)
Dichlorodifluoromethane
(CFC-12)
1,2-Dichloroethane (Ethylene
dichloride)
1,2-Dichloroethylene
1,1-Dichloro-1-fluoroethane
(HCFC-141b)
Dichlorofluoromethane
(HCFC-21)
Dichloromethane (Methylene
chloride)
Dichloropentafluoropropane
1,1-Dichloro-1,2,2,3,3pentafluoropropane (HCFC225cc)
1,1-Dichloro-1,2,3,3,3pentafluoropropane (HCFC225eb)
1,2-Dichloro-1,1,2,3,3pentafluoropropane (HCFC225bb)
1,2-Dichloro-1,1,3,3,3pentafluoropropane (HCFC225da)
1,3-Dichloro-1,1,2,2,3pentafluoropropane (HCFC225cb)
1,3-Dichloro-1,1,2,3,3pentafluoropropane (HCFC225ea)
2,2-Dichloro-1,1,1,3,3pentafluoropropane (HCFC225aa)
2,3-dichloro-1,1,1,2,3pentafluoropropane (HCFC225ba)
3,3-Dichloro-1,1,1,2,2pentafluoropropane (HCFC225ca)
Dichlorophene [2,2'Methylenebis(4chlorophenol)]
2,4-Dichlorophenol
1,2-Dichloropropane
trans-1,3-Dichloropropene
2,3-Dichloropropene
De
minimis
% Limit
0.1
0.1
0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
CAS
Number
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
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
1.0
1.0
60-51-5
119-90-4
20325-40-0
1.0
111984-09-9
1.0
124-40-3
2300-66-5
60-11-7
121-69-7
119-93-7
1.0
1.0
612-82-8
1.0
0.1
0.1
1.0
41766-75-0
79-44-7
Chemical Name
1,3-Dichloropropylene
Dichlorotetrafluoroethane
(CFC-114)
Dichlorotrifluoroethane
Dichloro-1,1,2-trifluoroethane
1,1-Dichloro-1,2,2trifluoroethane (HCFC-123b)
1,2-Dichloro-1,1,2trifluoroethane (HCFC-123a)
2,2-Dichloro-1,1,1trifluoroethane (HCFC-123)
Dichlorvos [Phosphoric acid,
2,2-dichloroethenyl dimethyl
ester]
Diclofop methyl [2-[4-(2,4Dichlorophenoxy)phenoxy]pr
opanoic acid, methyl ester]
Dicofol [Benzenemethanol, 4chloro-α-(4-chlorophenyl)-α(trichloromethyl)-]
Dicyclopentadiene
Diepoxybutane
Diethanolamine
Diethatyl ethyl
Di(2-ethylhexyl)phthalate
(DEHP)
Diethyl sulfate
Diflubenzuron
Diglycidyl resorcinol ether
Dihydrosafrole
Dimethipin [2,3-Dihydro-5,6dimethyl-1,4-dithiin-1,1,4,4tetraoxide]
Dimethoate
3,3'-Dimethoxybenzidine
3,3'-Dimethoxybenzidine
dihydrochloride (oDianisidine 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
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
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
II-7
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
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
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
Chemical Name
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)
Dipotassium endothall [7Oxabicyclo(2.2.1)heptane-2,3dicarboxylic acid, dipotassium
salt]
Dipropyl isocinchomeronate
Disodium
cyanodithioimidocarbonate
2,4-D isopropyl ester
2,4-Dithiobiuret
Diuron
Dodine [Dodecylguanidine
monoacetate]
2,4-DP
2,4-D propylene glycol butyl
ether ester
2,4-D sodium salt
Epichlorohydrin
Ethoprop [Phosphorodithioic
acid O-ethyl S,S-dipropyl
ester]
2-Ethoxyethanol
Ethyl acrylate
Ethylbenzene
Ethyl chloroformate
Ethyl dipropylthiocarbamate
(EPTC)
Ethylene
Ethylene glycol
Ethyleneimine (Aziridine)
Ethylene oxide
Ethylene thiourea
De
minimis
% Limit
1.0
0.1
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
CAS
Number
75-34-3
52-85-7
60168-88-9
13356-08-6
66441-23-4
72490-01-8
39515-41-8
55-38-9
1.0
51630-58-1
1.0
1.0
14484-64-1
0.1
1.0
1.0
1.0
69806-50-4
0.1
0.1
2164-17-2
0.1
0.1
1.0
7782-41-4
51-21-8
69409-94-5
1.0
0.1
0.1
1.0
1.0
133-07-3
72178-02-0
1.0
1.0
0.1
0.1
0.1
50-00-0
64-18-6
76-13-1
110-00-9
Chemical Name
Ethylidene dichloride
Famphur
Fenarimol [α-(2Chlorophenyl)-α-(4chlorophenyl)-5pyrimidinemethanol]
Fenbutatin oxide (Hexakis(2methyl-2phenylpropyl)distannoxane)
Fenoxaprop ethyl [2-(4-((6Chloro-2benzoxazolylen)oxy)phenoxy)
propanoic acid, ethyl ester]
Fenoxycarb [[2-(4Phenoxyphenoxy)ethyl]carba
mic acid ethyl ester]
Fenpropathrin [2,2,3,3Tetramethylcyclopropane
carboxylic acid cyano(3phenoxyphenyl)methyl ester]
Fenthion [O,O-Dimethyl O[3-methyl-4(methylthio)phenyl]ester,
phosphorothioic acid]
Fenvalerate [4-Chloro-α-(1methylethyl)benzeneacetic
acid cyano(3phenoxyphenyl)methyl ester]
Ferbam
[Tris(dimethylcarbamodithioat
o-S,S’)iron]
Fluazifop butyl [2-[4-[[5(Trifluoromethyl)-2pyridinyl]oxy]phenoxy]propa
noic acid, butyl ester]
Fluometuron [Urea, N,Ndimethyl-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-2nitrobenzamide]
Formaldehyde
Formic acid
Freon 113 [Ethane, 1,1,2trichloro-1,2,2,-trifluoro-]
Furan
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
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
1.0
1.0
1.0
0.1
1.0
1.0
0.1
II-8
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
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
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
Chemical Name
Glycidol
Heptachlor [1,4,5,6,7,8,8Heptachloro-3a,4,7,7atetrahydro-4,7-methano-1Hindene]
Hexachlorobenzene
Hexachloro-1,3-butadiene
alpha-Hexachlorocyclohexane
Hexachlorocyclopentadiene
Hexachloroethane
Hexachloronaphthalene
Hexachlorophene
Hexamethylphosphoramide
n-Hexane
Hexazinone
Hydramethylnon [Tetrahydro5,5-dimethyl-2(1H)pyrimidinone[3-[4(trifluoromethyl)phenyl]-1-[2[4(trifluoromethyl)phenyl]ethen
yl]-2propenylidene]hydrazone]
Hydrazine
Hydrazine sulfate
Hydrochloric acid (acid
aerosols including mists,
vapors, gas, fog, and other
airborne forms of any particle
size)
Hydrogen cyanide
Hydrogen fluoride
Hydrogen sulfide
Hydroquinone
Imazalil [1-[2-(2,4Dichlorophenyl)-2-(2propenyloxy)ethyl]-1Himidazole]
3-Iodo-2-propynyl
butylcarbamate
Iron pentacarbonyl
Isobutyraldehyde
Isodrin
Isofenphos [2-[[Ethoxyl[(1methylethyl)amino]phosphino
thioyl]oxy]benzoic acid 1methylethyl ester]
Isoprene
Isopropyl alcohol (only
persons who manufacture by
the strong acid process are
subject, no supplier
notification)
4,4'-Isopropylidenediphenol
De
minimis
% Limit
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
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
*
1.0
0.1
1.0
1.0
CAS
Number
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
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
Chemical Name
Isosafrole
Lactofen [Benzoic acid, 5-[2Chloro-4(trifluoromethyl)phenoxy]-2nitro-, 2-ethoxy-1-methyl-2oxoethyl ester]
Lead (when lead is contained
in stainless steel, brass or
bronze alloys the de minimis
level is 0.1)
Lindane [Cyclohexane,
1,2,3,4,5,6-hexachloro-,
(1α,2α,3β,4α,5α,6β)-]
Linuron
Lithium carbonate
Malathion
Maleic anhydride
Malononitrile
Maneb [Carbamodithioic acid,
1,2-ethanediylbis-, manganese
complex]
Manganese
Mecoprop
2-Mercaptobenzothiazole
(MBT)
Mercury
Merphos
Methacrylonitrile
Metham sodium (Sodium
methyldithiocarbamate)
Methanol
Methazole [2-(3,4Dichlorophenyl)-4-methyl1,2,4-oxadiazolidine-3,5dione]
Methiocarb
Methoxone ((4-Chloro-2methylphenoxy)acetic acid)
(MCPA)
Methoxone sodium salt ((4Chloro-2methylphenoxy)acetate
sodium salt)
Methoxychlor [Benzene, 1,1'(2,2,2trichloroethylidene)bis[4methoxy-]
2-Methoxyethanol
Methyl acrylate
Methyl tert-butyl ether
Methyl chlorocarbonate
4,4'-Methylenebis(2chloroaniline) (MBOCA)
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
1.0
1.0
*
0.1
1.0
1.0
0.1
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
II-9
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
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
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
Chemical Name
4,4'-Methylenebis(N,Ndimethyl)benzenamine
Methylene bromide
4,4'-Methylenedianiline
Methyleugenol
Methyl hydrazine
Methyl iodide
Methyl isobutyl ketone
Methyl isocyanate
Methyl isothiocyanate
[Isothiocyanatomethane]
2-Methyllactonitrile
Methyl methacrylate
N-Methylolacrylamide
Methyl parathion
2-Methylpyridine
N-Methyl-2-pyrrolidone
Metiram
Metribuzin
Mevinphos
Michler’s ketone
Molinate (1H-Azepine-1carbothioic acid, hexahydro-,
S-ethyl ester)
Molybdenum trioxide
Monochloropentafluoroethane
(CFC-115)
Monuron
Mustard gas [Ethane, 1,1'thiobis[2-chloro-]]
Myclobutanil [α-Butyl-α-(4chlorophenyl)-1H-1,2,4triazole-1-propanenitrile]
Nabam
Naled
Naphthalene
alpha-Naphthylamine
beta-Naphthylamine
Nickel
Nitrapyrin (2-Chloro-6(trichloromethyl)pyridine)
Nitric acid
Nitrilotriacetic acid
p-Nitroaniline
o-Nitroanisole
5-Nitro-o-anisidine
Nitrobenzene
4-Nitrobiphenyl
Nitrofen [Benzene, 2,4dichloro-1-(4-nitrophenoxy)-]
Nitrogen mustard [2-ChloroN-(2-chloroethyl)-Nmethylethanamine]
De
minimis
% Limit
0.1
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
0.1
0.1
0.1
0.1
1.0
1.0
0.1
1.0
0.1
1.0
0.1
0.1
0.1
0.1
CAS
Number
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
56-38-2
1114-71-2
40487-42-1
608-93-5
76-01-7
87-86-5
Chemical Name
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)3,5-dinitrobenzene
sulfonamide]
Osmium tetroxide
Oxydemeton methyl [S-(2(Ethylsulfinyl)ethyl) O,Odimethyl ester
phosphorothioic acid]
Oxydiazon [3-[2,4-Dichloro5-(1-methylethoxy)phenyl]-5(1,1-dimethylethyl)-1,3,4oxadiazol-2(3H)-one]
Oxyfluorfen
Ozone
Paraldehyde
Paraquat dichloride
Parathion [Phosphorothioic
acid, O,O-diethyl-O-(4nitrophenyl)ester]
Pebulate
[Butylethylcarbamothioic acid
S-propyl ester]
Pendimethalin [N-(1Ethylpropyl)-3,4-dimethyl2,6-dinitrobenzenamine]
Pentachlorobenzene
Pentachloroethane
Pentachlorophenol (PCP)
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
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
1.0
1.0
1.0
1.0
1.0
0.1
1.0
*
*
1.0
0.1
II-10
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
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
7758-01-2
128-03-0
137-41-7
41198-08-7
7287-19-6
23950-58-5
1918-16-7
1120-71-4
Chemical Name
Pentobarbital sodium
Peracetic acid
Perchloromethyl mercaptan
Permethrin [3-(2,2Dichloroethenyl)-2,2dimethylcyclopropanecarboxy
lic acid, (3phenoxyphenyl)methyl ester]
Phenanthrene
Phenol
Phenolphthalein
Phenothrin [2,2-Dimethyl-3(2-methyl-1propenyl)cyclopropanecarbox
ylic acid (3phenoxyphenyl)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 Nmethyldithiocarbamate
Profenofos [O-(4-Bromo-2chlorophenyl)-O-ethyl-Spropyl phosphorothioate]
Prometryn [N,N'-Bis(1methylethyl)-6-methylthio1,3,5-triazine-2,4-diamine]
Pronamide
Propachlor [2-Chloro-N-(1methylethyl)-Nphenylacetamide]
Propane sultone
De
minimis
% Limit
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
CAS
Number
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
*
0.1
1.0
94-59-7
7782-49-2
74051-80-2
1.0
1.0
1.0
7440-22-4
122-34-9
26628-22-8
1982-69-0
1.0
1.0
128-04-1
0.1
62-74-8
7632-00-0
Chemical Name
Propanil [N-(3,4Dichlorophenyl)propanamide]
Propargite
Propargyl alcohol
Propetamphos [3[[(Ethylamino)methoxyphosp
hinothioyl]oxy]-2-butenoic
acid, 1-methylethyl ester]
Propiconazole [1-[2-(2,4Dichlorophenyl)-4-propyl-1,3dioxolan-2-yl]methyl-1H1,2,4,-triazole]
beta-Propiolactone
Propionaldehyde
Propoxur [Phenol, 2-(1methylethoxy)-,
methylcarbamate]
Propylene (Propene)
Propyleneimine
Propylene oxide
Pyridine
Quinoline
Quinone
Quintozene
(Pentachloronitrobenzene)
Quizalofop-ethyl [2-[4-[(6Chloro-2quinoxalinyl)oxy]phenoxy]pro
panoic acid ethyl ester]
Resmethrin [[5(Phenylmethyl)-3furanyl]methyl-2,2-dimethyl3-(2-methyl-1propenyl)cyclopropanecarbox
ylate]
Saccharin (only persons who
manufacture are subject, no
supplier notification)
Safrole
Selenium
Sethoxydim [2-[1(Ethoxyimino)butyl]-5-[2(ethylthio)propyl]-3-hydroxyl2-cyclohexen-1-one]
Silver
Simazine
Sodium azide
Sodium dicamba [3,6Dichloro-2-methoxybenzoic
acid, sodium salt]
Sodium
dimethyldithiocarbamate
Sodium fluoroacetate
Sodium nitrite
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
0.1
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
1.0
II-11
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
131-52-2
132-27-4
100-42-5
96-09-3
7664-93-9
2699-79-8
35400-43-2
34014-18-1
3383-96-8
5902-51-2
79-94-7
630-20-6
79-34-5
127-18-4
354-11-0
354-14-3
961-11-5
64-75-5
116-14-3
509-14-8
7696-12-0
7440-28-0
148-79-8
62-55-5
28249-77-6
139-65-1
59669-26-0
Chemical Name
Sodium pentachlorophenate
Sodium o-phenylphenoxide
Styrene
Styrene oxide
Sulfuric acid (acid aerosols
including mists, vapors, gas,
fog, and other airborne forms
of any particle size)
Sulfuryl fluoride (Vikane)
Sulprofos [O-Ethyl O-[4(methylthio)phenyl]phosphoro
dithioic acid S-propylester]
Tebuthiuron [N-[5-(1,1Dimethylethyl)-1,3,4thiadiazol-2-yl]-N,N'dimethylurea]
Temephos
Terbacil [5-Chloro-3-(1,1dimethylethyl)-6-methyl2,4(1H,3H)-pyrimidinedione]
Tetrabromobisphenol A
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
Tetrachloroethylene
(Perchloroethylene)
1,1,1,2-Tetrachloro-2fluoroethane (HCFC-121a)
1,1,2,2-Tetrachloro-1fluoroethane (HCFC-121)
Tetrachlorvinphos
[Phosphoric acid, 2-chloro-1(2,4,5-trichlorophenyl)ethenyl
dimethyl ester]
Tetracycline hydrochloride
Tetrafluoroethylene
Tetranitromethane
Tetramethrin [2,2-Dimethyl-3(2-methyl-1propenyl)cyclopropanecarbox
ylic acid (1,3,4,5,6,7hexahydro-1,3-dioxo-2Hisoindol-2-yl)methyl ester]
Thallium
Thiabendazole [2-(4Thiazolyl)-1H-benzimidazole]
Thioacetamide
Thiobencarb [Carbamic acid,
diethylthio-, S-(pchlorobenzyl)ester]
4,4'-Thiodianiline
Thiodicarb
De
minimis
% Limit
0.1
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
*
0.1
0.1
0.1
1.0
1.0
CAS
Number
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
0.1
1.0
0.1
0.1
1.0
1983-10-4
2155-70-6
78-48-8
52-68-6
76-02-8
120-82-1
71-55-6
1.0
1.0
0.1
1.0
0.1
1.0
79-00-5
79-01-6
75-69-4
95-95-4
88-06-2
96-18-4
57213-69-1
121-44-8
Chemical Name
Thiophanate ethyl [[1,2Phenylenebis(iminocarbonothi
oyl)]biscarbamic acid
diethylester]
Thiophanate methyl
Thiosemicarbazide
Thiourea
Thiram
Thorium dioxide
Titanium tetrachloride
Toluene
Toluene-2,4-diisocyanate
Toluene-2,6-diisocyanate
Toluene diisocyanate (mixed
isomers)
o-Toluidine
o-Toluidine hydrochloride
Toxaphene
Triadimefon [1-(4Chlorophenoxy)-3,3-dimethyl1-(1H-1,2,4-triazol-1-yl)-2butanone]
Triallate
Triaziquone [2,5Cyclohexadiene-1,4-dione,
2,3,5-tris(1-aziridinyl)-]
Tribenuron methyl [Benzoic
acid, 2-[[[[(4-methoxy-6methyl-1,3,5-triazin-2yl)methylamino]carbonyl]ami
no]sulfonyl]-, methyl ester]
Tributyltin fluoride
Tributyltin methacrylate
S,S,S-Tributyltrithiophosphate
(DEF)
Trichlorfon [Phosphoric acid,
(2,2,2-trichloro-l-hydroxyethyl)-, dimethyl ester]
Trichloroacetyl chloride
1,2,4-Trichlorobenzene
1,1,1-Trichloroethane (Methyl
chloroform)
1,1,2-Trichloroethane
Trichloroethylene
Trichlorofluoromethane
(CFC-11)
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
1,2,3-Trichloropropane
Triclopyr triethylammonium
salt
Triethylamine
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
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
0.1
1.0
1.0
0.1
0.1
1.0
1.0
II-12
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
1582-09-8
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
Chemical Name
Trifluralin [Benezeneamine,
2,6-dinitro-N,N-dipropyl-4(trifluoromethyl)-]
Triforine [N,N'-[1,4Piperazinediylbis-(2,2,2trichloroethylidene)]bisforma
mide]
1,2,4-Trimethylbenzene
2,3,5-Trimethylphenyl
methylcarbamate
Triphenyltin chloride
Triphenyltin hydroxide
Tris(2,3dibromopropyl)phosphate
Trypan blue
Urethane (Ethyl carbamate)
Vanadium (except when
contained in an alloy)
Vinclozolin [3-(3,5Dichlorophenyl)-5-ethenyl-5methyl-2,4-oxazolidinedione]
Vinyl acetate
Vinyl bromide
Vinyl chloride
Vinyl fluoride
Vinylidene chloride
m-Xylene
o-Xylene
p-Xylene
Xylene (mixed isomers)
2,6-Xylidine
Zinc (fume or dust)
Zineb [Carbamodithioic acid,
1,2-ethanediyibis-, zinc
complex]
De
minimis
% Limit
*
1.0
1.0
1.0
1.0
1.0
0.1
0.1
0.1
1.0
1.0
0.1
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
b. Individually Listed Toxic Chemicals
Arranged by CAS Number
CAS
Number
50-00-0
51-03-6
51-21-8
51-28-5
51-75-2
51-79-6
Chemical Name
Formaldehyde
Piperonyl butoxide
Fluorouracil (5-Fluorouracil)
2,4-Dinitrophenol
Nitrogen mustard [2-ChloroN-(2-chloroethyl)-Nmethylethanamine]
Urethane (Ethyl carbamate)
De
minimis
% Limit
0.1
1.0
1.0
1.0
0.1
0.1
CAS
Number
52-68-6
52-85-7
53-96-3
55-18-5
55-21-0
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
Chemical Name
Trichlorfon [Phosphoric acid,
(2,2,2-trichloro-l-hydroxyethyl)-, dimethyl ester]
Famphur
2-Acetylaminofluorene
N-Nitrosodiethylamine
Benzamide
Fenthion [O,O-Dimethyl O[3-methyl-4(methylthio)phenyl]ester,
phosphorothioic acid]
Nitroglycerin
Carbon tetrachloride
Bis(tributyltin)oxide
Parathion [Phosphorothioic
acid, O,O-diethyl-O-(4nitrophenyl)ester]
1,1-Dimethyl hydrazine
Pentobarbital sodium
Phenytoin
beta-Propiolactone
Chlordane [4,7Methanoindan,
1,2,4,5,6,7,8,8-octachloro2,3,3a,4,7,7a-hexahydro-]
Lindane [Cyclohexane,
1,2,3,4,5,6-hexachloro-,
(1α,2α,3β,4α,5α,6β)-]
N-Nitrosomorpholine
4-Aminoazobenzene
4-Dimethylaminoazobenzene
Methyl hydrazine
Acetamide
Dimethoate
Amitrole
Aniline
Thioacetamide
Thiourea
Dichlorvos [Phosphoric acid,
2,2-dichloroethenyl dimethyl
ester]
Sodium fluoroacetate
N-Nitrosodimethylamine
Carbaryl [1-Naphthalenol,
methylcarbamate]
Formic acid
Diethyl sulfate
Tetracycline hydrochloride
Methanol
Isopropyl alcohol (only
persons who manufacture by
the strong acid process are
subject, no supplier
notification)
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
1.0
1.0
0.1
0.1
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
0.1
0.1
*
0.1
0.1
0.1
0.1
1.0
0.1
1.0
0.1
1.0
0.1
0.1
0.1
1.0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
II-13
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
67-66-3
67-72-1
68-12-2
68-76-8
70-30-4
71-36-3
71-43-2
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
Chemical Name
Chloroform
Hexachloroethane
N,N-Dimethylformamide
Triaziquone [2,5Cyclohexadiene-1,4-dione,
2,3,5-tris(1-aziridinyl)-]
Hexachlorophene
n-Butyl alcohol
Benzene
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
(HCFC-21)
Phosgene
Chlorodifluoromethane
(HCFC-22)
Nitromethane
Propyleneimine
Propylene oxide
Bromotrifluoromethane
(Halon 1301)
tert-Butyl alcohol
1-Chloro-1,1-difluoroethane
(HCFC-142b)
Trichlorofluoromethane
(CFC-11)
De
minimis
% Limit
0.1
0.1
0.1
1.0
1.0
1.0
0.1
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
CAS
Number
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
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
Chemical Name
Dichlorodifluoromethane
(CFC-12)
Chlorotrifluoromethane
(CFC-13)
2-Methyllactonitrile
2-Chloro-1,1,1trifluoroethane (HCFC-133a)
Pentachloroethane
Trichloroacetyl chloride
Chloropicrin
Freon 113 [Ethane, 1,1,2trichloro-1,2,2,-trifluoro-]
Dichlorotetrafluoroethane
(CFC-114)
Monochloropentafluoroethan
e (CFC-115)
Heptachlor [1,4,5,6,7,8,8Heptachloro-3a,4,7,7atetrahydro-4,7-methano-1Hindene]
Triphenyltin hydroxide
Phenolphthalein
Hexachlorocyclopentadiene
Dicyclopentadiene
Dimethyl sulfate
S,S,STributyltrithiophosphate
(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
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
1.0
1.0
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
1.0
0.1
1.0
0.1
1.0
1.0
1.0
0.1
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
0.1
II-14
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
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
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
Chemical Name
C.I. Food Red 15
1-Amino-2methylanthraquinone
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
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-2methylphenoxy)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
De
minimis
% Limit
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
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
CAS
Number
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
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
106-94-5
Chemical Name
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
Benzyl chloride
N-Nitrosopiperidine
Anilazine [4,6-Dichloro-N(2-chlorophenyl)-1,3,5triazin-2-amine]
4,4'-Methylenebis(2chloroaniline) (MBOCA)
4,4'-Methylenebis(N,Ndimethyl)benzenamine
4,4'-Methylenedianiline
4,4'-Diaminodiphenyl ether
Diglycidyl resorcinol ether
p-Chlorophenyl isocyanate
p-Anisidine
2,4-Dimethylphenol
p-Xylene
p-Cresol
1,4-Dichlorobenzene
p-Chloroaniline
p-Phenylenediamine
Quinone
1,2-Butylene oxide
Epichlorohydrin
1,2-Dibromoethane (Ethylene
dibromide)
1-Bromopropane
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
0.1
0.1
0.1
1.0
0.1
1.0
0.1
0.1
0.1
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
1.0
0.1
1.0
0.1
0.1
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
0.1
0.1
0.1
0.1
II-15
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
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
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
Chemical Name
1,3-Butadiene
Acrolein
Allyl chloride
1,2-Dichloroethane (Ethylene
dichloride)
Allylamine
Acrylonitrile
Allyl alcohol
Propargyl alcohol
Ethylene glycol
Chloromethyl methyl ether
Vinyl acetate
Methyl isobutyl ketone
Maleic anhydride
m-Xylene
m-Cresol
1,3-Phenylenediamine
Bis(2-chloro-1methylethyl)ether
Toluene
Chlorobenzene
Cyclohexanol
Phenol
2-Methylpyridine
Malononitrile
2-Methoxyethanol
Furan
n-Hexane
trans-1,4-Dichloro-2-butene
2-Ethoxyethanol
Cyclohexane
Pyridine
Diethanolamine
Bis(2-chloroethyl)ether
Bis(2-chloroethoxy)methane
Propoxur [Phenol, 2-(1methylethoxy)-,
methylcarbamate]
Propylene (Propene)
Chlorendic acid
Dicofol [Benzenemethanol, 4chloro-α-(4-chlorophenyl)-α(trichloromethyl)-]
Aldicarb
Tetrafluoroethylene
2-Aminoanthraquinone
Di(2-ethylhexyl)phthalate
(DEHP)
Hexachlorobenzene
3,3'-Dimethoxybenzidine
3,3'-Dimethylbenzidine (oTolidine)
Anthracene
De
minimis
% Limit
0.1
1.0
1.0
0.1
1.0
0.1
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
0.1
1.0
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
0.1
*
0.1
0.1
1.0
CAS
Number
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
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
Chemical Name
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(2,3dibromopropyl)phosphate
Methacrylonitrile
Chloroprene
Tetrachloroethylene
(Perchloroethylene)
Potassium
dimethyldithiocarbamate
Sodium
dimethyldithiocarbamate
C.I. Vat Yellow 4
Dimethyl phthalate
Sodium pentachlorophenate
Sodium o-phenylphenoxide
Dibenzofuran
Captan [1H-Isoindole1,3(2H)-dione, 3a,4,7,7atetrahydro-2[(trichloromethyl)thio]-]
Folpet
Chloramben [Benzoic acid, 3amino-2,5-dichloro-]
o-Anisidine hydrochloride
alpha-Naphthylamine
Cupferron [Benzeneamine, Nhydroxy-N-nitroso,
ammonium salt]
Dipropyl isocinchomeronate
Thiram
Potassium Nmethyldithiocarbamate
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
0.1
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
0.1
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
0.1
0.1
1.0
1.0
1.0
1.0
0.1
0.1
0.1
1.0
1.0
1.0
II-16
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
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
330-55-2
333-41-5
334-88-3
353-59-3
354-11-0
354-14-3
354-23-4
354-25-6
Chemical Name
Metham sodium (Sodium
methyldithiocarbamate)
Disodium
cyanodithioimidocarbonate
Nitrilotriacetic acid
4,4'-Thiodianiline
Ethyl acrylate
Butyl acrylate
Nabam
Thiabendazole [2-(4Thiazolyl)-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-1,1,1trifluoroethane (HCFC-123)
Aldrin [1,4:5,8Dimethanonaphthalene,
1,2,3,4,10,10-hexachloro1,4,4a,5,8,8a-hexahydro(1α,4α,4aβ,5α,8α,8aβ)-]
Bromacil (5-Bromo-6methyl-3-(1-methylpropyl)2,4(1H,3H)-pyrimidinedione)
alphaHexachlorocyclohexane
Diuron
Linuron
Diazinon
Diazomethane
Bromochlorodifluoromethane
(Halon 1211)
1,1,1,2-Tetrachloro-2fluoroethane (HCFC-121a)
1,1,2,2-Tetrachloro-1fluoroethane (HCFC-121)
1,2-Dichloro-1,1,2trifluoroethane (HCFC-123a)
1-Chloro-1,1,2,2tetrafluoroethane (HCFC124a)
De
minimis
% Limit
1.0
1.0
0.1
0.1
0.1
1.0
1.0
1.0
0.1
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
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
CAS
Number
357-57-3
422-44-6
422-48-0
422-56-0
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
556-61-6
563-47-3
569-64-2
584-84-9
593-60-2
594-42-3
606-20-2
608-93-5
Chemical Name
Brucine
1,2-Dichloro-1,1,2,3,3pentafluoropropane (HCFC225bb)
2,3-dichloro-1,1,1,2,3pentafluoropropane (HCFC225ba)
3,3-Dichloro-1,1,1,2,2pentafluoropropane (HCFC225ca)
1,2-Dichloro-1,1,3,3,3pentafluoropropane (HCFC225da)
3-Chloro-1,1,1trifluoropropane (HCFC253fb)
Carbonyl sulfide
Isodrin
C.I. Solvent Yellow 34
(Auramine)
Mustard gas [Ethane, 1,1'thiobis[2-chloro-]]
1,3-Dichloro-1,1,2,2,3pentafluoropropane (HCFC225cb)
Tetranitromethane
Chlorobenzilate
[Benzeneacetic acid, 4chloro-α-(4-chlorophenyl)-αhydroxy-, ethyl ester]
o-Dinitrobenzene
2-Chloroacetophenone
Dazomet (Tetrahydro-3,5dimethyl-2H-1,3,5thiadiazine-2-thione)
4,6-Dinitro-o-cresol
1,2-Dichloroethylene
Ethyl chloroformate
2,4-Dithiobiuret
1,3-Dichlorobenzene
1,3-Dichloropropylene
3-Chloropropionitrile
Bis(chloromethyl)ether
Lithium carbonate
Glycidol
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
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
1.0
1.0
1.0
1.0
1.0
1.0
1.0
*
0.1
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
0.1
1.0
0.1
1.0
0.1
0.1
1.0
0.1
*
II-17
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
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
1319-77-3
1320-18-9
1330-20-7
1332-21-4
1335-87-1
Chemical Name
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-(3,4Dichlorophenyl)propanamide
]
N-Nitroso-N-ethylurea
Ethyl dipropylthiocarbamate
(EPTC)
1,4-Dichloro-2-butene
1,1-Dichloro-1,2,2trifluoroethane (HCFC-123b)
Ametryn (N-Ethyl-N'-(1methylethyl)-6-(methylthio)1,3,5,-triazine-2,4-diamine)
C.I. Solvent Yellow 14
N-Methyl-2-pyrrolidone
N-Nitrosodi-n-butylamine
N-Methylolacrylamide
Diphenamid
Tetrachlorvinphos
[Phosphoric acid, 2-chloro-1(2,4,5-trichlorophenyl)ethenyl
dimethyl ester]
C.I. Basic Red 1
Pebulate
[Butylethylcarbamothioic
acid S-propyl ester]
Propane sultone
Cycloate
Decabromodiphenyl oxide
Molybdenum trioxide
Thorium dioxide
Cresol (mixed isomers)
2,4-D propylene glycol butyl
ether ester
Xylene (mixed isomers)
Asbestos (friable)
Hexachloronaphthalene
De
minimis
% Limit
0.1
0.1
0.1
1.0
0.1
1.0
1.0
0.1
0.1
1.0
0.1
0.1
1.0
0.1
1.0
1.0
1.0
CAS
Number
1336-36-3
1344-28-1
1464-53-5
1563-66-2
1582-09-8
1634-04-4
1649-08-7
1689-84-5
1689-99-2
1717-00-6
1836-75-5
1861-40-1
1897-45-6
1.0
1.0
1.0
0.1
1.0
1.0
0.1
1910-42-5
1912-24-9
1918-00-9
1918-02-1
1918-16-7
1.0
1.0
1928-43-4
1929-73-3
1929-82-4
0.1
1.0
1.0
0.1
1.0
1.0
0.1
1937-37-7
1982-69-0
1.0
0.1
1.0
1983-10-4
2032-65-7
2155-70-6
2164-07-0
Chemical Name
Polychlorinated biphenyls
(PCBs)
Aluminum oxide (fibrous
forms)
Diepoxybutane
Carbofuran
Trifluralin [Benezeneamine,
2,6-dinitro-N,N-dipropyl-4(trifluoromethyl)-]
Methyl tert-butyl ether
1,2-Dichloro-1,1difluoroethane (HCFC-132b)
Bromoxynil (3,5-Dibromo-4hydroxybenzonitrile)
Bromoxynil octanoate
(Octanoic acid, 2,6-dibromo4-cyanophenylester)
1,1-Dichloro-1-fluoroethane
(HCFC-141b)
Nitrofen [Benzene, 2,4dichloro-1-(4-nitrophenoxy)-]
Benfluralin (N-Butyl-N-ethyl2,6-dinitro-4(trifluoromethyl)benzenamine
)
Chlorothalonil [1,3Benzenedicarbonitrile,
2,4,5,6-tetrachloro-]
Paraquat dichloride
Atrazine (6-Chloro-N-ethylN'-(1-methylethyl)-1,3,5triazine-2,4-diamine)
Dicamba (3,6-Dichloro-2methoxybenzoic acid)
Picloram
Propachlor [2-Chloro-N-(1methylethyl)-Nphenylacetamide]
2,4-D 2-ethylhexyl ester
2,4-D butoxyethyl ester
Nitrapyrin (2-Chloro-6(trichloromethyl)pyridine)
C.I. Direct Black 38
Sodium dicamba [3,6Dichloro-2-methoxybenzoic
acid, sodium salt]
Tributyltin fluoride
Methiocarb
Tributyltin methacrylate
Dipotassium endothall [7Oxabicyclo(2.2.1)heptane2,3-dicarboxylic acid,
dipotassium salt]
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
*
1.0
0.1
1.0
*
1.0
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
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
II-18
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
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
Chemical Name
Fluometuron [Urea, N,Ndimethyl-N'-[3(trifluoromethyl)phenyl]-]
Molinate (1H-Azepine-1carbothioic acid, hexahydro-,
S-ethyl ester)
Octachloronaphthalene
Dimethylamine dicamba
Diallate [Carbamothioic acid,
bis(1-methylethyl)-S-(2,3dichloro-2-propenyl)ester]
Triallate
Propargite
Chinomethionat [6-Methyl1,3-dithiolo[4,5-b]quinoxalin2-one]
Dodine [Dodecylguanidine
monoacetate]
Dimethyl
chlorothiophosphate
C.I. Direct Blue 6
2,3,5-Trimethylphenyl
methylcarbamate
Sulfuryl fluoride (Vikane)
2,4-D sodium salt
C.I. Disperse Yellow 3
2-Chloro-1,1,1,2tetrafluoroethane (HCFC124)
2,4-D chlorocrotyl ester
C.I. Solvent Orange 7
2,2-bis(Bromomethyl)-1,3propanediol
Temephos
Methoxone sodium salt ((4Chloro-2methylphenoxy)acetate
sodium salt)
C.I. Food Red 5
1-(3-Chloroallyl)-3,5,7-triaza1-azoniaadamantane chloride
Crotonaldehyde
N-Nitrosomethylvinylamine
C.I. Acid Green 3
Carboxin (5,6-Dihydro-2methyl-N-phenyl-1,4oxathiin-3-carboxamide)
Chlorpyrifos methyl [O,ODimethyl-O-(3,5,6-trichloro2-pyridyl)phosphorothioate]
Terbacil [5-Chloro-3-(1,1dimethylethyl)-6-methyl2,4(1H,3H)-pyrimidinedione]
C.I. Acid Red 114
De
minimis
% Limit
1.0
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
1.0
1.0
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
0.1
1.0
0.1
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
7664-39-3
7664-41-7
7664-93-9
7696-12-0
1.0
1.0
0.1
7697-37-2
7723-14-0
7726-95-6
7758-01-2
Chemical Name
Prometryn [N,N'-Bis(1methylethyl)-6-methylthio1,3,5-triazine-2,4-diamine]
Aluminum (fume or dust)
Lead (when lead is contained
in stainless steel, brass or
bronze alloys the de minimis
level is 0.1)
Manganese
Mercury
Nickel
Silver
Thallium
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Vanadium (except when
contained in an alloy)
Zinc (fume or dust)
Titanium tetrachloride
Sodium nitrite
Boron trifluoride
Hydrochloric acid (acid
aerosols including mists,
vapors, gas, fog, and other
airborne forms of any particle
size)
Hydrogen fluoride
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)
Sulfuric acid (acid aerosols
including mists, vapors, gas,
fog, and other airborne forms
of any particle size)
Tetramethrin [2,2-Dimethyl3-(2-methyl-1propenyl)cyclopropanecarbox
ylic acid (1,3,4,5,6,7hexahydro-1,3-dioxo-2Hisoindol-2-yl)methyl ester]
Nitric acid
Phosphorus (yellow or white)
Bromine
Potassium bromate
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
1.0
1.0
*
1.0
*
0.1
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
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
0.1
II-19
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
7782-41-4
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
Chemical Name
Fluorine
Selenium
Chlorine
Hydrogen sulfide
Mevinphos
Phosphine
Toxaphene
Creosote
Metiram
Ozone
Hydrazine sulfate
Chlorine dioxide
trans-1,3-Dichloropropene
Boron trichloride
Resmethrin [[5(Phenylmethyl)-3furanyl]methyl-2,2-dimethyl3-(2-methyl-1propenyl)cyclopropanecarbox
ylate]
Zineb [Carbamodithioic acid,
1,2-ethanediyibis-, zinc
complex]
Maneb [Carbamodithioic
acid, 1,2-ethanediylbis-,
manganese complex]
Ethoprop [Phosphorodithioic
acid O-ethyl S,S-dipropyl
ester]
Fenbutatin oxide (Hexakis(2methyl-2phenylpropyl)distannoxane)
Iron pentacarbonyl
1,1-Dichloro-1,2,2,3,3pentafluoropropane (HCFC225cc)
Desmedipham
Ferbam
[Tris(dimethylcarbamodithioa
to-S,S’)iron]
Alachlor
C.I. Direct Brown 95
N-Nitrosonornicotine
Benomyl
Oryzalin [4-(Dipropylamino)3,5-dinitrobenzene
sulfonamide]
Oxydiazon [3-[2,4-Dichloro5-(1-methylethoxy)phenyl]-5(1,1-dimethylethyl)-1,3,4oxadiazol-2(3H)-one]
3,3'-Dimethoxybenzidine
dihydrochloride (oDianisidine dihydrochloride)
De
minimis
% Limit
1.0
1.0
1.0
1.0
1.0
1.0
*
0.1
1.0
1.0
0.1
1.0
0.1
1.0
1.0
CAS
Number
20354-26-1
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
1.0
1.0
25321-14-6
25321-22-6
25376-45-8
1.0
26002-80-2
1.0
1.0
1.0
26471-62-5
26628-22-8
26644-46-2
1.0
1.0
27314-13-2
1.0
0.1
0.1
1.0
1.0
28057-48-9
28249-77-6
1.0
28407-37-6
29082-74-4
Chemical Name
Methazole [2-(3,4Dichlorophenyl)-4-methyl1,2,4-oxadiazolidine-3,5dione]
Osmium tetroxide
Aluminum phosphide
Metribuzin
Cyanazine
Bendiocarb [2,2-Dimethyl1,3-benzodioxol-4-ol
methylcarbamate]
Thiophanate methyl
Thiophanate ethyl [[1,2Phenylenebis(iminocarbonoth
ioyl)]biscarbamic acid
diethylester]
Pronamide
Isofenphos [2-[[Ethoxyl[(1methylethyl)amino]phosphino
thioyl]oxy]benzoic acid 1methylethyl ester]
Dinitrotoluene (mixed
isomers)
Dichlorobenzene (mixed
isomers)
Diaminotoluene (mixed
isomers)
Phenothrin [2,2-Dimethyl-3(2-methyl-1propenyl)cyclopropanecarbox
ylic acid (3phenoxyphenyl)methyl ester]
Toluene diisocyanate (mixed
isomers)
Sodium azide
Triforine [N,N'-[1,4Piperazinediylbis-(2,2,2trichloroethylidene)]bisforma
mide]
Norflurazon [4-Chloro-5(methylamino)-2-[3(trifluoromethyl)phenyl]3(2H)-pyridazinone]
d-trans-Allethrin [d-transChrysanthemic acid of dallethrone]
Thiobencarb [Carbamic acid,
diethylthio-, S-(pchlorobenzyl)ester]
C.I. Direct Blue 218
Octachlorostyrene
De
minimis
% Limit
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
*
0.1
Toxics Release Inventory Reporting Forms and Instructions
II-20
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
29232-93-7
30560-19-1
31218-83-4
33089-61-1
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
Chemical Name
Pirimiphos methyl [O-(2(Diethylamino)-6-methyl-4pyrimidinyl)-O,Odimethylphosphorothioate]
Acephate
(Acetylphosphoramidothioic
acid O,S-dimethyl ester)
Propetamphos [3[[(Ethylamino)methoxyphosp
hinothioyl]oxy]-2-butenoic
acid, 1-methylethyl ester]
Amitraz
Tebuthiuron [N-[5-(1,1Dimethylethyl)-1,3,4thiadiazol-2-yl]-N,N'dimethylurea]
Dichlorotrifluoroethane
Diflubenzuron
Sulprofos [O-Ethyl O-[4(methylthio)phenyl]phosphor
odithioic acid S-propylester]
Imazalil [1-[2-(2,4Dichlorophenyl)-2-(2propenyloxy)ethyl]-1Himidazole]
1-Bromo-1-(bromomethyl)1,3-propanedicarbonitrile
Diethatyl ethyl
2,4-Diaminoanisole sulfate
Dinocap
Fenpropathrin [2,2,3,3Tetramethylcyclopropane
carboxylic acid cyano(3phenoxyphenyl)methyl ester]
Pendimethalin [N-(1Ethylpropyl)-3,4-dimethyl2,6-dinitrobenzenamine]
Profenofos [O-(4-Bromo-2chlorophenyl)-O-ethyl-Spropyl phosphorothioate]
3,3'-Dimethylbenzidine
dihydrofluoride (o-Tolidine
dihydrofluoride)
Oxyfluorfen
Triadimefon [1-(4Chlorophenoxy)-3,3dimethyl-1-(1H-1,2,4-triazol1-yl)-2-butanone]
Vinclozolin [3-(3,5Dichlorophenyl)-5-ethenyl-5methyl-2,4-oxazolidinedione]
Hexazinone
De
minimis
% Limit
1.0
1.0
CAS
Number
51338-27-3
51630-58-1
1.0
52645-53-1
1.0
1.0
53404-19-6
1.0
1.0
1.0
53404-37-8
53404-60-7
1.0
55290-64-7
1.0
1.0
0.1
1.0
1.0
*
55406-53-6
57213-69-1
59669-26-0
60168-88-9
60207-90-1
1.0
0.1
1.0
1.0
62476-59-9
63938-10-3
64902-72-3
1.0
1.0
64969-34-2
Chemical Name
Diclofop methyl [2-[4-(2,4Dichlorophenoxy)phenoxy]pr
opanoic acid, methyl ester]
Fenvalerate [4-Chloro-α-(1methylethyl)benzeneacetic
acid cyano(3phenoxyphenyl)methyl ester]
Permethrin [3-(2,2Dichloroethenyl)-2,2dimethylcyclopropanecarbox
ylic acid, (3phenoxyphenyl)methyl ester]
Bromacil, lithium salt
[2,4(1H,3H)Pyrimidinedione, 5-bromo-6methyl-3-(1-methylpropyl),
lithium salt]
2,4-D 2-ethyl-4-methylpentyl
ester
Dazomet, sodium salt
[Tetrahydro-3,5-dimethyl-2H1,3,5-thiadiazine-2-thione,
ion(1-), sodium]
Dimethipin [2,3-Dihydro-5,6dimethyl-1,4-dithiin-1,1,4,4tetraoxide]
3-Iodo-2-propynyl
butylcarbamate
Triclopyr triethylammonium
salt
Thiodicarb
Fenarimol [α-(2Chlorophenyl)-α-(4chlorophenyl)-5pyrimidinemethanol]
Propiconazole [1-[2-(2,4Dichlorophenyl)-4-propyl1,3-dioxolan-2-yl]methyl-1H1,2,4,-triazole]
Acifluorfen, sodium salt [5(2-Chloro-4(trifluoromethyl)phenoxy)-2nitrobenzoic acid, sodium
salt]
Chlorotetrafluoroethane
Chlorsulfuron [2-Chloro-N[[(4-methoxy-6-methyl-1,3,5triazin-2yl)amino]carbonyl]benzenesu
lfonamide]
3,3'-Dichlorobenzidine sulfate
Toxics Release Inventory Reporting Forms and Instructions
De
minimis
% Limit
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
1.0
1.0
0.1
II-21
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
CAS
Number
66441-23-4
67485-29-4
68085-85-8
68359-37-5
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
Chemical Name
Fenoxaprop ethyl [2-(4-((6Chloro-2benzoxazolylen)oxy)phenoxy
)propanoic acid, ethyl ester]
Hydramethylnon [Tetrahydro5,5-dimethyl-2(1H)pyrimidinone[3-[4(trifluoromethyl)phenyl]-1[2-[4(trifluoromethyl)phenyl]ethen
yl]-2propenylidene]hydrazone]
Cyhalothrin [3-(2-Chloro3,3,3-trifluoro-1-propenyl)2,2dimethylcyclopropanecarbox
ylic acid cyano(3phenoxyphenyl)methyl ester]
Cyfluthrin [3-(2,2Dichloroethenyl)-2,2dimethylcyclopropanecarbox
ylic acid, cyano(4-fluoro-3phenoxyphenyl)methyl ester]
Fluvalinate [N-[2-Chloro-4(trifluoromethyl)phenyl]-DLvaline(+)-cyano(3phenoxyphenyl)methyl ester]
Fluazifop butyl [2-[4-[[5(Trifluoromethyl)-2pyridinyl]oxy]phenoxy]propa
noic acid, butyl ester]
Abamectin [Avermectin B1]
Fomesafen [5-(2-Chloro-4(trifluoromethyl)phenoxy)-Nmethylsulfonyl-2nitrobenzamide]
Fenoxycarb [[2-(4Phenoxyphenoxy)ethyl]carba
mic acid ethyl ester]
Sethoxydim [2-[1(Ethoxyimino)butyl]-5-[2(ethylthio)propyl]-3hydroxyl-2-cyclohexen-1one]
Quizalofop-ethyl [2-[4-[(6Chloro-2quinoxalinyl)oxy]phenoxy]pr
opanoic acid ethyl ester]
Lactofen [Benzoic acid, 5-[2Chloro-4(trifluoromethyl)phenoxy]-2nitro-, 2-ethoxy-1-methyl-2oxoethyl ester]
Bifenthrin
De
minimis
% Limit
1.0
1.0
CAS
Number
88671-89-0
90454-18-5
90982-32-4
101200-48-0
1.0
111512-56-2
1.0
1.0
111984-09-9
127564-92-5
128903-21-9
136013-79-1
1.0
Chemical Name
Myclobutanil [α-Butyl-α-(4chlorophenyl)-1H-1,2,4triazole-1-propanenitrile]
Dichloro-1,1,2trifluoroethane
Chlorimuron ethyl [Ethyl-2[[[[(4-chloro-6methoxyprimidin-2yl)amino]carbonyl]amino]sulf
onyl]benzoate]
Tribenuron methyl [Benzoic
acid, 2-[[[[(4-methoxy-6methyl-1,3,5-triazin-2yl)methylamino]carbonyl]ami
no]sulfonyl]-, methyl ester]
1,1-Dichloro-1,2,3,3,3pentafluoropropane (HCFC225eb)
3,3'-Dimethoxybenzidine
hydrochloride (o-Dianisidine
hydrochloride)
Dichloropentafluoropropane
2,2-Dichloro-1,1,1,3,3pentafluoropropane (HCFC225aa)
1,3-Dichloro-1,1,2,3,3pentafluoropropane (HCFC225ea)
De
minimis
% Limit
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
1.0
1.0
Toxics Release Inventory Reporting Forms and Instructions
II-22
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
c. Chemical Categories
N084
OH
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.
Chlorophenols (0.1)
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
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-23
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
N120 Diisocyanates (1.0)
This category includes only those chemicals
listed below.
CAS
Number
N150
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
139-25-3
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
Chemical Name
1
1746-01-6
2,3,7,8-Tetrachlorodibenzo-p-dioxin
3,3'-Dimethyl-4,4'-diphenylene
diisocyanate
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
3,3'-Dimethyldiphenylmethane-4,4'diisocyanate
4
57653-85-7
1,2,3,6,7,8-Hexachlorodibenzo-p-dioxin
822-06-0
Hexamethylene-1,6-diisocyanate
5
19408-74-3
1,2,3,7,8,9-Hexachlorodibenzo-p-dioxin
6
35822-46-9
4098-71-9
Isophorone diisocyanate
1,2,3,4,6,7,8-Heptachlorodibenzo-pdioxin
75790-84-0
4-Methyldiphenylmethane-3,4diisocyanate
7
3268-87-9
1,2,3,4,6,7,8,9-Octachlorodibenzo-pdioxin
5124-30-1
1,1-Methylenebis(4isocyanatocyclohexane)
8
51207-31-9
2,3,7,8-Tetrachlorodibenzofuran
9
57117-41-6
1,2,3,7,8-Pentachlorodibenzofuran
101-68-8
Methylenebis(phenylisocyanate) (MDI)
10
57117-31-4
2,3,4,7,8-Pentachlorodibenzofuran
3173-72-6
1,5-Naphthalene diisocyanate
11
70648-26-9
1,2,3,4,7,8-Hexachlorod-benzofuran
123-61-5
1,3-Phenylene diisocyanate
12
57117-44-9
1,2,3,6,7,8-Hexachlorodibenzofuran
104-49-4
1,4-Phenylene diisocyanate
13
72918-21-9
1,2,3,7,8,9-Hexachlorodibenzofuran
9016-87-9
Polymeric diphenylmethane diisocyanate
14
60851-34-5
2,3,4,6,7,8-Hexachlorodibenzofuran
16938-22-0
2,2,4-Trimethylhexamethylene
diisocyanate
15
67562-39-4
1,2,3,4,6,7,8-Heptachlorodibenzofuran
16
55673-89-7
1,2,3,4,7,8,9-Heptachlorodibenzofuran
15646-96-5
2,4,4-Trimethylhexamethylene
diisocyanate
17
39001-02-0
1,2,3,4,6,7,8,9-Octachlorodibenzofuran
N171 Ethylenebisdithiocarbamic acid, salts and
esters EBDCs) (1.0)
Includes any unique chemical substance that
contains an EBDC or an EBDC salt as part of
that chemical’s infrastructure.
Toxics Release Inventory Reporting Forms and Instructions
II-24
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
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.
N270 Hexabromocyclododecane (*)
(This category includes only those chemicals
covered by the CAS numbers listed below)
CAS
Number
N530
CAS
Number
4-Nonylphenol
11066-49-2
Isononylphenol
25154-52-3
Nonylphenol
26543-97-5
4-Isononylphenol
84852-15-3
4-Nonylphenol, branched
90481-04-2
Nonylphenol, branched
N535
1,2,5,6,9,10-Hexabromocyclododecane
25637-99-4
Hexabromocyclododecane
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)
Chemical Name
104-40-5
Chemical Name
3194-55-6
Nonylphenol (1.0)
This category includes only those chemicals
listed below.
Nonylphenol Ethoxylates (1.0)
This category includes only those chemicals
listed below.
CAS
Number
7311-27-5
9016-45-9
20427-84-3
26027-38-3
26571-11-9
27176-93-8
27177-05-5
27177-08-8
27986-36-3
37205-87-1
51938-25-1
68412-54-4
127087-87-0
N575
Chemical Name
Ethanol, 2-[2-[2-[2-(4nonylphenoxy)ethoxy]ethoxy]ethoxy]Poly(oxy-1,2-ethanediyl), α(nonylphenyl)-ω-hydroxyEthanol, 2-[2-(4-nonylphenoxy)ethoxy]Poly(oxy-1,2-ethanediyl), α-(4nonylphenyl)-ω-hydroxy3,6,9,12,15,18,21,24-Octaoxahexacosan1-ol, 26-(nonylphenoxy)Ethanol, 2-[2-(nonylphenoxy)ethoxy]3,6,9,12,15,18,21-Heptaoxatricosan-1-ol,
23-(nonylphenoxy)3,6,9,12,15,18,21,24,27Nonaoxanonacosan-1-ol, 29(nonylphenoxy)Ethanol, 2-(nonylphenoxy)Poly(oxy-1,2-ethanediyl), α(isononylphenyl)-ω hydroxyPoly(oxy-1,2-ethanediyl), α (2nonylphenyl)-ω-hydroxyPoly(oxy-1,2-ethanediyl), α(nonylphenyl)-ω-hydroxy-, branched
Poly(oxy-1,2-ethanediyl), α-(4nonylphenyl)-ω-hydroxy-, branched
Polybrominated Biphenyls (PBBs) (0.1)
Brx
H(10-x)
where x = 1 to 10
Toxics Release Inventory Reporting Forms and Instructions
II-25
Table II. EPCRA Section 313 Chemical List for Reporting Year 2019
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 40-70% with the limiting molecular
formulas C10H19Cl3 and C13H16Cl12
N590 Polycyclic aromatic compounds (PACs) (*)
This category includes the chemicals listed
below.
CAS Number
Chemical Name
56-55-3
Benz(a)anthracene
205-99-2
Benzo(b)fluoranthene
205-82-3
Benzo(j)fluoranthene
207-08-9
Benzo(k)fluoranthene
206-44-0
Benzo(j,k)fluorene
189-55-9
Benzo(r,s,t)pentaphene
218-01-9
Benzo(a)phenanthrene
50-32-8
Benzo(a)pyrene
226-36-8
Dibenz(a,h)acridine
224-42-0
Dibenz(a,j)acridine
53-70-3
Dibenzo(a,h)anthracene
194-59-2
7H-Dibenzo(c,g)carbazole
5385-75-1
Dibenzo(a,e)fluoranthene
192-65-4
Dibenzo(a,e)pyrene
189-64-0
Dibenzo(a,h)pyrene
191-30-0
Dibenzo(a,l)pyrene
57-97-6
7,12-Dimethylbenz(a)-anthracene
42397-64-8
1,6-Dinitropyrene
CAS Number
Chemical Name
42397-65-9
1,8-Dinitropyrene
193-39-5
Indeno(1,2,3-cd)pyrene
56-49-5
3-Methylcholanthrene
3697-24-3
5-Methylchrysene
7496-02-8
6-Nitrochrysene
5522-43-0
1-Nitropyrene
57835-92-4
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.
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.
Toxics Release Inventory Reporting Forms and Instructions
II-26
Table III. Removal and Destruction Rates for POTWs
When completing Sections 6 and 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). Table III
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 III assigns the portion of the influent diverted to sludge to Section 8.1c
(Total off-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills),
the portion volatilizing into the air to Section 8.1d (Total other off-site disposal or other 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 III if available.
For chemicals not included in this table, the default assumption is that 100% of the chemical sent to the POTW is
treated for destruction (except for metals, which for which the default is that 100% of the chemical is released).
% of §6.1 to §:
CASRN
Chemical Name
8.1c
8.1d
8.7
Arranged by CAS Number
50-00-0
51-03-6
51-21-8
51-28-5
51-79-6
52-68-6
53-96-3
55-63-0
56-23-5
56-38-2
57-14-7
57-33-0
57-41-0
57-74-9
58-89-9
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
63-25-2
64-18-6
64-67-5
Formaldehyde
Piperonyl butoxide
Fluorouracil
2,4-Dinitrophenol
Urethane (Ethyl carbamate)
Trichlorfon
2-Acetylaminofluorene
Nitroglycerin
Carbon tetrachloride
Parathion
1,1-Dimethyl hydrazine
Pentobarbital sodium
Phenytoin
Chlordane
Lindane
4-Aminoazobenzene
4-Dimethylaminoazobenzene
Methyl hydrazine
Acetamide
Dimethoate
Amitrole
Aniline
Thioacetamide
Thiourea
Dichlorvos
Sodium fluoroacetate
Carbaryl
Formic acid
Diethyl sulfate
0
39
1
1
1
0
5
1
2
9
1
2
2
61
13
8
35
1
0
1
1
0
1
1
1
1
1
0
0
8
3
55
24
55
8
42
24
88
2
25
53
51
1
24
35
5
25
8
55
55
8
55
25
25
25
12
8
5
92
58
44
75
44
92
53
75
10
89
74
45
47
38
63
57
60
74
92
44
44
92
44
74
74
74
87
92
95
% of §6.1 to §:
CASRN
64-75-5
67-56-1
67-66-3
67-72-1
68-12-2
70-30-4
71-36-3
71-43-2
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
75-05-8
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
Chemical Name
Tetracycline hydrochloride
Methanol
Chloroform
Hexachloroethane
N,N-Dimethylformamide
Hexachlorophene
n-Butyl alcohol
Benzene
1,1,1-trichloroethane
Methoxychlor
Trypan blue
Bromomethane
Ethylene
Chloromethane
Methyl iodide
Hydrogen cyanide
Methylene bromide
Chloroethane
Vinyl chloride
Acetonitrile
Acetaldehyde
Dichloromethane
Carbon disulfide
Ethylene oxide
Bromoform
Dichlorobromomethane
Ethylidene dichloride
Vinylidene chloride
Dichlorofluoromethane
Phosgene
Toxics Release Inventory Reporting Forms and Instructions
8.1c
8.1d
8.7
1
0
1
18
0
62
0
1
1
45
1
0
0
1
1
2
1
1
0
1
0
1
1
0
2
1
1
1
1
0
55
8
73
56
8
1
8
23
95
2
55
80
92
59
78
98
61
85
92
25
9
44
87
9
57
68
78
91
91
0
44
92
26
26
92
37
92
76
4
53
44
20
8
40
21
0
38
14
8
74
91
55
12
91
41
31
21
8
8
100
III-1
Table III. Removal and Destruction Rates for POTWs
% of §6.1 to §:
CASRN
75-45-6
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
76-06-2
76-13-1
76-14-2
76-15-3
76-44-8
76-87-9
77-47-4
77-73-6
77-78-1
78-48-8
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
80-05-7
80-15-9
80-62-6
81-07-2
82-68-8
84-74-2
85-01-8
Chemical Name
8.1c
8.1d
8.7
Chlorodifluoromethane
Propyleneimine
Propylene oxide
Bromotrifluoromethane
tert-Butyl alcohol
1-Chloro-1,1-difluoroethane
Trichlorofluoromethane
(CFC-11)
Dichlorodifluoromethane
(CFC-12)
Chlorotrifluoromethane
(CFC-13)
2-Methyllactonitrile
2-Chloro-1,1,1trifluoroethane
Pentachloroethane
Chloropicrin
Freon 113
Dichlorotetrafluoroethane
(CFC-114)
Monochloropentafluoroethane
(CFC-115)
Heptachlor
Triphenyltin hydroxide
Hexachlorocyclopentadiene
Dicyclopentadiene
Dimethyl sulfate
S,S,STributyltrithiophosphate
(DEF)
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
4,4'-Isopropylidenediphenol
Cumene hydroperoxide
Methyl methacrylate
Saccharin (only persons who
manufacture are subject, no
supplier notification)
Quintozene
Dibutyl phthalate
Phenanthrene
1
1
0
0
1
1
1
88
25
9
99
55
98
98
11
74
91
1
44
1
1
0
99
1
0
99
1
0
0
0
99
100
1
6
1
3
2
75
88
96
97
19
11
1
1
1
98
1
50
14
44
7
0
37
1
86
11
84
3
0
49
0
45
9
97
63
0
1
1
0
1
1
0
0
0
1
0
0
2
0
1
5
1
0
1
9
70
67
8
82
93
8
8
8
55
8
1
78
0
26
14
24
10
25
91
29
32
92
17
6
92
92
92
44
92
99
20
100
73
81
75
90
74
43
29
32
11
1
6
46
70
62
% of §6.1 to §:
CASRN
85-44-9
86-30-6
87-62-7
87-68-3
87-86-5
88-06-2
88-75-5
88-85-7
88-89-1
90-04-0
90-43-7
91-08-7
91-20-3
91-22-5
91-59-8
91-94-1
92-52-4
92-67-1
92-87-5
93-65-2
94-11-1
94-36-0
94-58-6
94-59-7
94-74-6
94-75-7
94-80-4
95-47-6
95-48-7
95-50-1
95-53-4
95-54-5
95-63-6
95-80-7
95-95-4
96-09-3
96-12-8
96-18-4
96-33-3
96-45-7
98-07-7
98-82-8
98-86-2
98-87-3
98-88-4
98-95-3
99-55-8
99-65-0
100-01-6
100-02-7
Chemical Name
8.1c
8.1d
8.7
Phthalic anhydride
N-Nitrosodiphenylamine
2,6-Xylidine
Hexachloro-1,3-butadiene
Pentachlorophenol (PCP)
2,4,6-Trichlorophenol
2-Nitrophenol
Dinitrobutyl phenol
Picric acid
o-Anisidine
2-Phenylphenol
Toluene-2,6-diisocyanate
Naphthalene
Quinoline
beta-Naphthylamine
3,3'-Dichlorobenzidine
Biphenyl
4-Aminobiphenyl
Benzidine
Mecoprop
2,4-D isopropyl ester
Benzoyl peroxide
Dihydrosafrole
Safrole
Methoxone ((4-Chloro-2methylphenoxy) acetic acid)
(MCPA)
2,4-D
2,4-D butyl ester
o-Xylene
o-Cresol
1,2-Dichlorobenzene
o-Toluidine
1,2-Phenylenediamine
1,2,4-Trimethylbenzene
2,4-Diaminotoluene
2,4,5-Trichlorophenol
Styrene oxide
1,2-Dibromo-3-chloropropane
(DBCP)
1,2,3-Trichloropropane
Methyl acrylate
Ethylene thiourea
Benzoic trichloride
Cumene
Acetophenone
Benzal chloride
Benzoyl chloride
Nitrobenzene
5-Nitro-o-toluidine
m-Dinitrobenzene
p-Nitroaniline
4-Nitrophenol
0
5
2
45
54
9
1
12
1
1
3
2
4
1
1
9
10
3
1
5
8
5
10
8
6
1
42
53
23
4
9
59
54
78
25
5
1
6
24
23
32
2
47
25
42
2
3
30
34
39
99
53
45
32
42
82
40
34
21
74
92
97
90
75
76
59
88
50
74
53
90
92
60
58
55
2
15
3
0
7
0
1
11
1
13
1
4
6
1
16
8
47
94
55
21
55
25
25
72
92
84
81
92
46
6
44
68
44
62
74
24
2
0
1
0
7
0
0
0
0
1
1
1
0
56
9
55
0
13
8
0
0
8
54
54
54
93
42
91
44
100
80
92
100
100
92
45
45
45
7
Toxics Release Inventory Reporting Forms and Instructions
III-2
Table III. Removal and Destruction Rates for POTWs
% of §6.1 to §:
CASRN
100-25-4
100-41-4
100-42-5
100-44-7
100-75-4
101-05-3
101-14-4
101-77-9
101-80-4
101-90-6
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
110-54-3
110-57-6
110-80-5
110-82-7
110-86-1
111-42-2
111-44-4
Chemical Name
p-Dinitrobenzene
Ethylbenzene
Styrene
Benzyl chloride
N-Nitrosopiperidine
Anilazine
4,4'-Methylenebis(2chloroaniline) (MBOCA)
4,4'-Methylenedianiline
4,4'-Diaminodiphenyl ether
Diglycidyl resorcinol ether
2,4-Dimethylphenol
p-Xylene
p-Cresol
1,4-Dichlorobenzene
p-Chloroaniline
p-Phenylenediamine
Quinone
1,2-Butylene oxide
Epichlorohydrin
1,2-Dibromoethane
1,3-Butadiene
Acrolein
Allyl chloride
1,2-Dichloroethane
Allylamine
Acrylonitrile
Allyl alcohol
Propargyl alcohol
Ethylene glycol
Chloromethyl methyl ether
Vinyl acetate
Methyl isobutyl ketone
Maleic anhydride
m-Xylene
m-Cresol
1,3-Phenylenediamine
Bis(2-chloro-1-methylethyl)
ether
Toluene
Chlorobenzene
Cyclohexanol
Phenol
2-Methylpyridine
Malononitrile
2-Methoxyethanol
n-Hexane
trans-1,4-Dichloro-2-butene
2-Ethoxyethanol
Cyclohexane
Pyridine
Diethanolamine
Bis(2-chloroethyl) ether
8.1c
8.1d
8.7
1
3
2
1
1
16
17
54
45
13
27
55
19
18
45
52
85
72
44
65
65
1
1
1
1
3
0
7
1
1
1
0
1
1
1
0
1
1
1
0
0
0
0
0
0
0
0
3
0
1
2
24
24
25
23
19
8
49
54
55
59
27
55
60
86
9
85
64
25
9
8
8
8
0
11
9
0
18
8
55
53
75
75
74
76
78
92
44
45
44
40
73
44
39
13
91
14
35
74
91
92
92
92
100
89
91
100
79
92
44
45
1
2
0
0
0
1
0
9
2
0
6
0
0
2
23
39
9
8
8
55
8
53
27
8
19
8
8
78
76
59
91
92
92
44
92
38
71
92
75
92
92
20
% of §6.1 to §:
CASRN
111-91-1
114-26-1
115-07-1
115-32-2
116-06-3
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
126-98-7
126-99-8
127-18-4
128-03-0
128-04-1
131-11-3
132-64-9
133-06-2
133-07-3
134-32-7
136-45-8
137-26-8
137-41-7
137-42-8
139-13-9
140-88-5
141-32-2
142-59-6
Chemical Name
Bis(2-chloroethoxy) methane
Propoxur
Propylene (Propene)
Dicofol
Aldicarb
2-Aminoanthraquinone
Di(2-ethylhexyl) phthalate
Hexachlorobenzene
3,3'-Dimethoxybenzidine
3,3'-Dimethylbenzidine
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
Hydroquinone
Propionaldehyde
Paraldehyde
Butyraldehyde
1,4-Dioxane
Dimethylamine
Dibromotetrafluoroethane
Methacrylonitrile
Chloroprene
Tetrachloroethylene
(Perchloroethylene)
Potassium
dimethyldithiocarbamate
Sodium
dimethyldithiocarbamate
Dimethyl phthalate
Dibenzofuran
Captan
Folpet
alpha-Naphthylamine
Dipropyl isocinchomeronate
Thiram
Potassium Nmethyldithiocarbamate
Metham sodium
Nitrilotriacetic acid
Ethyl acrylate
Butyl acrylate
Nabam
Toxics Release Inventory Reporting Forms and Instructions
8.1c
8.1d
8.7
1
0
0
44
1
2
38
60
1
1
31
8
7
1
0
19
3
1
1
2
1
2
7
4
0
0
1
0
1
0
2
1
1
6
78
8
91
2
54
52
0
2
54
23
8
34
36
54
8
22
5
54
56
53
7
77
12
46
8
9
55
9
55
8
97
27
93
87
21
92
9
54
45
46
62
38
45
76
61
58
57
45
92
59
92
45
43
45
92
21
81
50
92
91
44
91
44
92
1
72
6
7
1
28
71
1
28
71
0
18
1
2
1
6
1
0
8
4
23
20
24
3
24
27
92
78
76
78
75
91
75
73
0
0
0
1
0
27
8
10
9
10
73
92
90
90
90
III-3
Table III. Removal and Destruction Rates for POTWs
% of §6.1 to §:
CASRN
148-79-8
149-30-4
150-50-5
151-56-4
156-62-7
298-00-0
300-76-5
302-01-2
306-83-2
309-00-2
314-40-9
330-54-1
330-55-2
333-41-5
353-59-3
354-11-0
354-14-3
354-23-4
354-25-6
357-57-3
422-56-0
460-35-5
463-58-1
465-73-6
492-80-8
505-60-2
507-55-1
510-15-6
528-29-0
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
556-61-6
563-47-3
584-84-9
606-20-2
Chemical Name
Thiabendazole
2-Mercaptobenzothiazole
(MBT)
Merphos
Ethyleneimine (Aziridine)
Calcium cyanamide
Methyl parathion
Naled
Hydrazine
2,2-Dichloro-1,1,1trifluoroethane
Aldrin
Bromacil
Diuron
Linuron
Diazinon
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
Brucine
3,3-Dichloro-1,1,1,2,2pentafluoropropane
3-Chloro-1,1,1trifluoropropane
Carbonyl sulfide
Isodrin
C.I. Solvent Yellow 34
(Auramine)
Mustard gas
1,3-Dichloro-1,1,2,2,3pentafluoropropane
Chlorobenzilate
o-Dinitrobenzene
Dazomet
4,6-Dinitro-o-cresol
1,2-Dichloroethylene
Ethyl chloroformate
2,4-Dithiobiuret
1,3-Dichlorobenzene
1,3-Dichloropropylene
3-Chloropropionitrile
Bis(chloromethyl) ether
Lithium carbonate
Methyl isothiocyanate
3-Chloro-2-methyl-1-propene
Toluene-2,4-diisocyanate
2,6-Dinitrotoluene
8.1c
8.1d
8.7
2
2
51
52
47
46
22
1
2
2
1
0
1
0
55
98
6
25
15
98
78
44
0
92
74
85
1
62
2
2
5
12
1
3
1
53
50
41
7
98
84
37
45
48
54
81
1
13
3
84
13
1
98
1
0
99
1
1
3
55
96
44
1
1
98
1
0
62
2
84
1
50
16
37
48
0
3
0
96
100
1
39
1
0
2
1
1
1
8
1
1
0
2
0
1
2
2
3
54
3
53
74
43
51
47
44
55
0
98
0
93
1
53
58
45
97
45
25
56
48
45
55
44
100
0
100
6
97
45
% of §6.1 to §:
CASRN
612-83-9
621-64-7
624-83-9
630-20-6
636-21-5
684-93-5
709-98-8
759-73-9
759-94-4
764-41-0
834-12-8
872-50-4
924-42-5
961-11-5
1120-71-4
1163-19-5
1313-27-5
1314-20-1
1319-77-3
1320-18-9
1330-20-7
1336-36-3
1344-28-1
1464-53-5
1563-66-2
1582-09-8
1634-04-4
1649-08-7
1689-84-5
1689-99-2
1717-00-6
1861-40-1
1897-45-6
1910-42-5
1912-24-9
1918-00-9
1918-02-1
1918-16-7
1928-43-4
1929-73-3
1929-82-4
1982-69-0
2164-07-0
2164-17-2
2234-13-1
2300-66-5
Chemical Name
8.1c
8.1d
8.7
3,3'-Dichlorobenzidine
dihydrochloride
N-Nitrosodi-n-propylamine
Methyl isocyanate
1,1,1,2-Tetrachloroethane
o-Toluidine hydrochloride
N-Nitroso-N-methylurea
Propanil (N-(3,4Dichlorophenyl)propanamide)
N-Nitroso-N-ethylurea
Ethyl dipropylthiocarbamate
(EPTC)
1,4-Dichloro-2-butene
Ametryn
N-Methyl-2-pyrrolidone
N-Methylolacrylamide
Tetrachlorvinphos
Propane sultone
Decabromodiphenyl oxide
Molybdenum trioxide
Thorium dioxide
Cresol (mixed isomers)
2,4-D propylene glycol butyl
ether ester
Xylene (mixed isomers)
Polychlorinated biphenyls
(PCBs)
Aluminum oxide (fibrous
forms)
Diepoxybutane
Carbofuran
Trifluralin
Methyl tert-butyl ether
1,2-Dichloro-1,1difluoroethane
Bromoxynil
Bromoxynil octanoate
1,1-Dichloro-1-fluoroethane
Benfluralin
Chlorothalonil
Paraquat dichloride
Atrazine
Dicamba
Picloram
Propachlor
2,4-D 2-ethylhexyl ester
2,4-D butoxyethyl ester
Nitrapyrin (2-Chloro-6(trichloromethyl)pyridine)
Sodium dicamba
Dipotassium endothall
Fluometuron
Octachloronaphthalene
Dimethylamine dicamba
9
32
59
1
0
3
1
1
4
54
0
82
54
55
44
45
100
15
45
44
52
1
5
55
41
44
54
1
4
0
0
7
1
62
2
90
0
15
84
45
8
8
11
29
1
98
10
8
0
15
51
92
92
82
70
37
0
0
92
85
3
61
17
1
80
38
2
98
0
1
1
57
1
1
25
7
3
60
97
74
92
40
39
2
6
38
1
56
3
1
3
1
2
1
22
12
7
13
0
96
3
18
55
74
53
90
24
0
1
36
81
62
3
41
79
44
23
46
8
75
78
87
57
1
1
2
62
1
53
24
52
1
54
46
75
46
37
45
Toxics Release Inventory Reporting Forms and Instructions
III-4
Table III. Removal and Destruction Rates for POTWs
% of §6.1 to §:
CASRN
2303-16-4
2303-17-5
2312-35-8
2699-79-8
2702-72-9
2837-89-0
2971-38-2
3383-96-8
3653-48-3
4080-31-3
4170-30-3
4549-40-0
5234-68-4
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
7697-37-2
7723-14-0
7726-95-6
7758-01-2
Chemical Name
8.1c
8.1d
8.7
Diallate
Triallate
Propargite
Sulfuryl fluoride
2,4-D sodium salt
2-Chloro-1,1,1,2tetrafluoroethane
2,4-D chlorocrotyl ester
Temephos
Methoxone sodium salt ((4Chloro-2-methylphenoxy)
acetate sodium salt)
1-(3-Chloroallyl)-3,5,7-triaza1-azoniaadamantane chloride
Crotonaldehyde
N-Nitrosomethylvinylamine
Carboxin
Prometryn
Aluminum (fume or dust)
Lead
Manganese
Mercury
Nickel
Silver
Thallium
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Vanadium (except when
contained in an alloy)
Zinc (fume or dust)
Titanium tetrachloride
Sodium nitrite
Boron trifluoride
Hydrochloric acid (acid
aerosols including mists,
vapors, gas, fog, and other
airborne forms of any particle
size)
Hydrogen fluoride
Ammonia
Sulfuric acid (acid aerosols
including mists, vapors, gas,
fog, and other airborne forms
of any particle size)
Nitric acid
Phosphorus (yellow or white)
Bromine
Potassium bromate
21
35
42
2
2
0
14
5
44
98
6
99
65
60
14
0
92
1
16
38
1
0
0
25
84
62
74
1
55
44
0
9
1
11
66
63
39
69
38
66
54
32
49
69
37
68
76
32
72
32
10
51
24
56
34
37
61
31
62
34
46
68
51
31
63
32
24
68
28
68
90
40
75
33
0
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
66
2
2
2
0
34
98
98
98
0
NA
0
0
0
100
2
0
0
98
40
0
0
60
100
0
60
2
2
0
40
98
98
100
0
0
0
% of §6.1 to §:
CASRN
7782-41-4
7782-49-2
7782-50-5
7803-51-2
8001-35-2
10028-15-6
10034-93-2
10049-04-4
10061-02-6
10294-34-5
12122-67-7
12427-38-2
13194-48-4
13684-56-5
15972-60-8
17804-35-2
19044-88-3
19666-30-9
20325-40-0
20816-12-0
20859-73-8
21087-64-9
21725-46-2
22781-23-3
23564-05-8
23950-58-5
25321-14-6
25321-22-6
25376-45-8
26002-80-2
26471-62-5
26628-22-8
28249-77-6
30560-19-1
34014-18-1
34077-87-7
35367-38-5
35554-44-0
40487-42-1
42874-03-3
43121-43-3
51235-04-2
52645-53-1
53404-37-8
55290-64-7
55406-53-6
Chemical Name
Fluorine
Selenium
Chlorine
Phosphine
Toxaphene
Ozone
Hydrazine sulfate
Chlorine dioxide
trans-1,3-Dichloropropene
Boron trichloride
Zineb
Maneb
Ethoprop
Desmedipham
Alachlor
Benomyl
Oryzalin
Oxydiazon
3,3'-Dimethoxybenzidine
dihydrochloride (oDianisidine dihydrochloride)
Osmium tetroxide
Aluminum phosphide
Metribuzin
Cyanazine
Bendiocarb
Thiophanate-methyl
Pronamide
Dinitrotoluene (mixed
isomers)
Dichlorobenzene (mixed
isomers)
Diaminotoluene (mixed
isomers)
Phenothrin
Toluene diisocyanate (mixed
isomers)
Sodium azide
Thiobencarb
Acephate
Tebuthiuron
Dichlorotrifluoroethane
Diflubenzuron
Imazalil
Pendimethalin
Oxyfluorfen
Triadimefon
Hexazinone
Permethrin
2,4-D 2-ethyl-4-methylpentyl
ester
Dimethipin
3-Iodo-2-propynyl
butylcarbamate
Toxics Release Inventory Reporting Forms and Instructions
8.1c
8.1d
8.7
2
44
2
2
62
2
2
2
1
2
0
2
10
5
7
1
3
40
1
98
56
98
98
1
98
98
98
31
98
2
98
29
9
11
49
49
3
55
0
NA
0
0
37
0
0
0
68
0
98
0
61
86
82
50
48
57
44
2
2
1
2
1
1
10
1
98
98
54
76
23
25
30
53
0
0
45
22
76
74
60
46
8
47
45
1
78
21
38
2
0
1
62
97
2
8
1
2
1
13
15
47
39
3
19
38
21
98
35
55
77
98
6
21
1
3
48
16
0
0
0
57
44
21
1
81
64
52
58
49
65
62
79
1
1
55
23
44
76
III-5
Table III. Removal and Destruction Rates for POTWs
% of §6.1 to §:
CASRN
57213-69-1
Chemical Name
Triclopyr triethylammonium
salt
59669-26-0 Thiodicarb
60207-90-1 Propiconazole
62476-59-9 Acifluorfen, sodium salt
64902-72-3 Chlorsulfuron
67485-29-4 Hydramethylnon
68359-37-5 Cyfluthrin
71751-41-2 Abamectin
72178-02-0 Fomesafen
77501-63-4 Lactofen
82657-04-3 Bifenthrin
88671-89-0 Myclobutanil
90982-32-4 Chlorimuron ethyl
101200-48-0 Tribenuron methyl
127564-92-5 Dichloropentafluoropropane
N010
Antimony Compounds
N020
Arsenic Compounds
N040
Barium Compounds
N050
Beryllium Compounds
N078
Cadmium Compounds
N084
Chlorophenols
N090
Chromium Compounds
(except chromite ore mined in
the transvaal region)
N096
Cobalt Compounds
N100
Copper Compounds
N106
Cyanide Compounds
% of §6.1 to §:
CASRN
8.1c
8.1d
8.7
1
25
74
N171
1
9
12
1
53
38
44
3
31
38
9
1
2
3
32
49
69
37
68
54
76
24
32
25
54
0
0
2
47
0
0
32
23
22
96
68
51
31
63
32
4
24
75
59
63
45
47
62
54
50
69
62
59
76
76
1
NA
NA
NA
NA
NA
42
NA
N230
N270
N420
N450
N458
N495
N503
N511a
N530
N590
32
72
2
68
28
98
NA
NA
0
N725
N740
N746
N760
N770
N874
N982
Chemical Name
Ethylenebisdithiocarbamic
acid, salts and esters
Certain Glycol Ethers
Hexabromocyclododecane
Lead Compounds
Manganese Compounds
Mercury Compounds
Nickel Compounds
Nicotine and salts
Nitrate Compounds
Nonylphenol
Polycyclic Aromatic
Compounds
Selenium Compounds
Silver Compounds
Strychnine and salts
Thallium Compounds
Vanadium Compounds
Warfarin And Salts
Zinc Compounds
8.1c
8.1d
8.7
2
98
0
0
0
63
39
69
38
2
0
60
92
8
6
37
61
31
62
98
10
2
7
92
94
NA
NA
NA
NA
0
90
38
1
44
66
2
54
32
3
66
56
34
98
46
68
97
34
NA
NA
0
NA
NA
0
NA
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.
a
Toxics Release Inventory Reporting Forms and Instructions
III-6
Appendix A. Trade Secret Submissions
A.1 Instructions for Trade Secret
Submissions
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.
Trade secret reporting must be done via hard-copy,
paper reporting.
The current substantiation form is available on the
TRI website at: https://www.epa.gov/toxics-releaseinventory-tri-program/trade-secret-reporting. 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.
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. These reporting forms can be found on the TRI
website:
https://www.epa.gov/toxics-releaseinventory-tri-program/reporting-forms-andinstructions.
E-mailed submissions will not be accepted.
Form R Reporting
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.
Form A Reporting
When making a trade secret claim on a Form A
submission, EPA is requiring that a facility submit a
unique Form A for each EPCRA section 313
chemical meeting the conditions of the alternate
threshold. Facilities may assert a trade secrecy claim
for a chemical identity on the Form A as on the Form
R. Reports submitted on a per chemical basis protect
against the disclosure of trade secrets. Form As with
trade secrecy claims, like Form Rs with similar
claims, will be separately handled upon receipt to
protect against disclosure. Commingling trade secret
chemical identities with non-trade secret chemical
identities on the same submission increases the risk of
disclosure.
All Submissions
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
Toxics Release Inventory Reporting Forms and Instructions
A-1
Appendix A
state or tribe’s submission requirements by contacting
the appropriate state or tribe designated EPCRA
section 313 contact.
whose identity is a trade secret. If you checked “no,”
you should submit your non-trade secret form data
electronically using TRI-MEweb.
Where to send your trade secret submission
If facilities wish to report more than one eligible
chemical on the same Form A, then all chemicals
included must be non-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.
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
Revising or withdrawing trade secret
submissions
Revisions and withdrawals must be performed
using paper forms.
A.2 Supplemental Form R and
Form A Instructions
The sections below are supplemental instructions to
Chapters C and D for completing hard copy forms
submitted with a trade secret submission.
Part I. Facility
Identification
Information
Section 2. Trade Secret Information
2.1 Are you claiming the EPCRA section 313
chemical identified on Page 2 a trade secret?
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
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.”
4.1 Facility Name, Location, TRI Facility
Identification Number and Tribal Country Name
Facilities filing a trade secret paper form should leave
a blank in the BIA field if the facility is not located
within tribal boundaries.
Location information for a facility that has
previously submitted data to EPA.
Enter your TRIFID in Part I, Section 4.1.
Location information for a facility that has
previously submitted data to EPA, but has
changed physical location.
If your facility has moved, do not enter your
previously assigned TRIFID, enter “New Facility”. If
you are filing a separate Form R or A 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:
https://www.epa.gov/enviro.
Location information for a facility that has
changed ownership, but has not changed
physical location.
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.
Toxics Release Inventory Reporting Forms and Instructions
A-2
Appendix A
Location reporting TRI releases for the first time to
EPA.
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).
Part II. Chemical
Identification
Information
Section 1. EPCRA Section 313 Chemical
Identity (Form R & A)
1.1 CAS Number
You must report the CAS number or category code on
your unsanitized Form R or 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
cross-referenced with an alphabetical list of chemical
names in Table II. If you are reporting one of the
EPCRA section 313 chemical categories (e.g.,
chromium compounds), you should enter the
applicable category code in the CAS number space.
EPCRA section 313 chemical category codes are
listed below and can also be found in Table IIc.
Do not include the CAS number or category code on
your sanitized Form R or A, or sanitized
substantiation form.
1.2 EPCRA Section 313 Chemical or Chemical
Category Name
You must report the specific EPCRA section 313
chemical identity on your unsanitized Form R or 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 R or A, or sanitized
substantiation form. Include a generic name that is
structurally descriptive in Part II, Section 1.3 of your
sanitized Form R or A report.
1.3 Generic Chemical Name
Section 1.3 is used only when claiming the specific
EPCRA section 313 chemical identity of the EPCRA
section 313 chemical as a trade secret.
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.
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 As, and the name must be the same as
that used on your substantiation forms.
Section 5. Quantity of the Toxic Chemical
Entering Each Environmental Medium Onsite (Form R)
5.3 Discharges to Receiving Streams or Water
Bodies
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.
Section 6. Transfer(s) of the Toxic Chemical
in Wastes to Off-Site Locations (Form R)
Number the boxes for reporting the information for
each sequential POTW or other off-site location in
Sections 6.1 and 6.2. In the upper left hand corner of
each box, the section number is either 6.1.[ ]._.or
6.2.[ ]. This section is required only for paper filers
Toxics Release Inventory Reporting Forms and Instructions
A-3
Appendix A
(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 offsite 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.
Section 7. On-Site Waste Treatment, Energy
Recovery, and Recycling Methods (Form R)
Section 7A: On-Site Waste Treatment Methods
and Efficiency
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.
Section 8. Source Reduction and Waste
Management (Form R)
8.10 Did Your Facility Engage in Any Newly
Implemented Source Reduction Activities for
This Chemical During the Reporting Year?
Instructions on how to report source reduction
activities on hard copy From R are provided below.
• If Your Facility Implemented Source
Reduction Activities. 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
T-codes 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 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.
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.
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
Toxics Release Inventory Reporting Forms and Instructions
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Appendix A
facilities to adopt similar practices, as well as to
inform the public about such activities being
implemented in their communities.
technically or economically feasible.
B7
No known substitutes or alternative
technologies.
To encourage submissions with additional pollution
prevention information, EPA is increasing the
prominence and accessibility of this information.
Visit https://www.epa.gov/tri/p2 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.
B8
Reduction does not appear to be technically
feasible.
B99
Other Barriers.
The following tips can help you provide meaningful
additional information.
Be Specific:
• Which processes and products were affected?
• Which technologies and materials were used?
• Which release (to air, water land) or waste
management quantities changed?
• Were there other benefits (e.g., costs, product
quality?)
• 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
https://www.epa.gov/sites/production/files/document
s/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.
Barrier Categories
B1
Insufficient capital to install new source
reduction equipment or implement new source
reduction activities/initiatives.
B2
Require technical information on pollution
prevention techniques applicable to specific
production processes.
B3
Concern that product quality may decline as
a result of source reduction.
B4
Source reduction activities were
implemented but were unsuccessful.
B5
Specific regulatory/permit burdens
B6
Pollution prevention previously
implemented additional reduction does not appear
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.
Section 9. Miscellaneous Information
(Form R)
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.
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.
EPA suggests you consider the following topics
should you provide optional information in the 9.1
box:
• 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
Toxics Release Inventory Reporting Forms and Instructions
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Appendix A
• No TRI Reports Expected for This TRIFID
Next Year
• No TRI Report Expected for This Chemical
Next Year
Do not submit information you consider to be CBI or
otherwise protected on your Form R.
9.2 Optional Pollution Prevention and
Additional Information for This Toxic Chemical
on Your Form A Certification Statement
Your facility may provide additional information
pertaining to pollution prevention or other topics for
each Toxic Chemical or Mixture Component
included on your Form A Certification Statement
submission. Information provided in this section may
provide the Agency and/or the public with useful data
that helps explain your use of Form A Certification
Statement. For example, your facility could include
information on steps it has taken to reduce its
manufacture, processing, or other use of the chemical.
Do not submit information you consider to be CBI or
otherwise protected.
EPA suggests you consider the following topics
should you provide optional information in the 9.2
box:
• Changes in Production Levels
• Source Reduction Activity Reduced Activity
Involving this Chemical
• One-Time or Intermittent Events Involving
this Chemical
• No TRI Report Expected for this Chemical
Next Year
Do not submit information you consider to be CBI or
otherwise protected on your Form A.
Toxics Release Inventory Reporting Forms and Instructions
A-6
| File Type | application/pdf |
| File Title | Toxic Chemical Release Inventory Reporting Forms and Instructions |
| Subject | RY2019 RFI, reporting forms and instructions, TRI manual, TRI instructions, TRI reporting instructions, TRI forms, TRI Form R, T |
| Author | US EPA |
| File Modified | 2020-07-22 |
| File Created | 2020-02-03 |