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Submission of Form R, the Toxic Chemical Release Inventory (TRl) Reporting Form, is 

 required by Section 313 of the Emergency Planning and Community Right-to-Know Act 

 (EPCRA, or Title III of the Superfijnd .Axnendments and Reauthorization Act of 1986), 

 Public Law 99-499. Reporting is required to provide the public with information on the 

 releases of listed toxic chemicals in their communities and to provide EPA with release 

 information to assist the Agency in determining the need for future regulations Facilities 

 must report the quantities of both routine and accidental releases of listed toxic chemicals, 

 as well as the maximum amount of the listed toxic chemical on-site during the calendar 

 year and the amount contained in wastes transferred otTsite 



Chemicals reported on Form R include hazardous chemicals used and hazardous chemicals 

 generated in the manufacturing process (as defined by 40 CFR 372 65) in excess of the 

 threshold planning quantities listed in 40 CFR 370 20. Form R also includes any 

 information on hazardous substances above the threshold planning quantity in storm water 

 and in wastes that are sent off-site for disposal 



A completed Form R must be submitted for each toxic chemical manufactured, processed, 

 or otherwise used at each covered facility as described in the reporting rule in 40 CFR Part 

 372 (originally published February 16, 1988, in the Federal Register) 



Section 313 of EPCRA requires that reports be filed by owners and operators of facilities 

 that meet all of the following criteria Ketchikan Pulp Company Company's Pulp Mill 

 Complex meets the submission requirements presented below: 



• The facility has 10 or more flill-time employees, and 



• The facility is included in Standard Industrial Classification (SIC) Code 261 1 

 and 



• The facility manufactures (defined to include importing), processes, or 

 otherwise uses listed toxic chemicals in quantities greater than the established 

 threshold in the course of a calendar year 



Facilities that must report under section 313 of EPCRA are required to develop reasonable 

 estimates of the amounts of listed chemicals released from the facility Additional 

 monitoring is not required by section 313, however facilities are required to consider all 

 available data, including that developed under other environmental regulations. Facilities 

 are required to document data developed and to maintain records for three years from the 

 date that the report is submitted 



Until 1995, TRI reporting was required for 368 chemicals and chemical categories. On 

 November 30, 1994, EPA promulgated final rules that added 286 chemicals and chemical 

 categories to the list of toxic chemicals for which reporting is required, and provided an 

 alternate threshold for some reporting The addition of these chemicals and chemical 

 categories almost doubled the number of toxic chemicals subject to TRI reporting. 



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