Guide for Reporting to the National Pollutant Release Inventory 2000

• Exempt Facilities
• Activities to Which the 20 000-hour Employee Threshold does not Apply
• Waste Incineration Activities
• Wood Preservation Activities
• Employee Criteria
• Schedule 1, Part 1, Substances
• Nature of Activities
• Manufacture
• Process
• Other Use
• By-products
• Other Definitions
• Facility
• Article
• Exclusions
• Calculating the 10-tonne Reporting Threshold
• NPRI Part 1 Substances Equal to or Greater than 1% Concentration
• NPRI Part 1 Substances of Less than 1% Concentration
• Example of Calculating the Reporting Threshold
• If You Are Not Required to Report
• If You Are Required to Report

In general, any person who owns or operates a facility must submit a report to the NPRI for a substance listed in Schedule 1, Part 1, of the 2000 Canada Gazette notice only if all of the following criteria are met:

• employees worked a total of 20 000 hours or more during the 2000 calendar year (equivalent to 10 full-time employees), or the facility was used for one or more of the following activities:
  • non-hazardous solid waste incineration of 100 tonnes or more of waste per year, including small combustion units, teepee burners and beehive burners
  • biomedical or hospital waste incineration of 100 tonnes or more of waste per year
  • hazardous waste incineration
  • sewage sludge incineration, or
  • wood preservation.
  
  
• the facility manufactured, processed or otherwise used 10 tonnes (10 000 kg) or more of an NPRI Part 1 substance in the 2000 calendar year, and
  
  
• the NPRI Part 1 substance was manufactured, processed or otherwise used at a concentration greater than or equal to 1% by weight, with the exception of NPRI substances considered to be by-products. The total weight of by-products must also be included in the calculation of the 10-tonne threshold for each NPRI Part 1 substance.

Figure 2 illustrates the steps to follow to determine if your facility is required to submit a report to the NPRI for a given NPRI Part 1 substance. A facility must meet all the reporting criteria before it is required to report on-site releases and transfers off site for disposal or recycling of the Part 1 substance.

Once you have determined that your facility is required to submit a report for an NPRI Part 1 substance, all on-site releases and all off-site transfers for disposal or recycling of that substance are reportable, regardless of their concentration or quantity (including "zero" releases and transfers).

The 2000 Canada Gazette notice states that the information required by the NPRI need only be reported to the Minister of the Environment if the facility owner or operator possesses the information or may reasonably be expected to have access to the information. Consequently, the NPRI does not require additional monitoring or measurement of the quantities or concentration of substances released to the environment, beyond those already required under the provisions of other laws or regulations. You are, however, required to show "due diligence" in obtaining the information required by the 2000 Canada Gazette notice.

Figure 2: Reporting Criteria for Schedule 1, Part 1 Substances

Exempt Facilities

Certain facilities, or parts thereof, are exempt from reporting to the NPRI. These exemptions apply to every substance in the NPRI. Beginning with the 2000 reporting year, a new exemption was added for the practice of dentistry. A facility, or any part thereof, is exempt from reporting if used exclusively for:

• educating or training students, such as universities, colleges and schools
  
  
• research or testing
  
  
• the maintenance and repair of transportation vehicles, such as automobiles, trucks, locomotives, ships or aircraft
  
  
• the distribution, storage or retail sale of fuels
  
  
• the wholesale or retail sale of articles or products which contain NPRI substances, provided that the substances are not released to the environment during normal use at the facility
  
  
• the retail sale of NPRI substances
  
  
• growing, harvesting or managing renewable natural resources, such as fisheries, forestry or agriculture, but not those facilities that process or otherwise use their products
  
  
• mining, but not those facilities engaged in further processing of mined materials
  
  
• drilling or operating wells to obtain oil and gas products, but not those facilities engaged in further processing of these oil and gas products, or
  
  
• the practice of dentistry.

Activities to Which the 20 000-hour Employee Threshold does not Apply

The criteria pertaining to total employee hours worked changed beginning with the 2000 calendar year. If your facility was used mainly or exclusively for one or more of the activities listed in Table 1, you must submit a report for any NPRI substance that meets its respective reporting criteria, regardless of the number of hours worked by employees.

In Table 1, NAICS codes are provided to assist in identifying facilities engaged in these activities. However, if your facility was used mainly or exclusively for any of these activities, reporting is required regardless of the NAICS code that best describes the facility. Complete descriptions of these activities are provided below.

Waste Incineration Activities

The first four activities listed in Table 1 are forms of waste incineration. Waste incineration, for the purposes of the NPRI, only includes incineration that takes place in a waste incinerator. Waste incineration does not include open burning of wastes.

A waste incinerator is a device, mechanism or structure constructed primarily to thermally treat (e.g., combust or pyrolyze) a waste for the purpose of reducing its volume, destroying a hazardous chemical present in the waste, or destroying pathogens present in the waste. This includes facilities where waste heat is recovered as a by-product from the exhaust gases from an incinerator (e.g., energy-from-waste incinerators). This also includes conical (or teepee) burners and beehive burners. This does not include industrial processes where fuel derived from waste is fired as an energy source, such as industrial boilers.

1. Non-hazardous solid waste incineration of 100 tonnes or more of waste per year, including small combustion units, teepee burners and beehive burners
   Non-hazardous solid waste means any waste, regardless of origin, which might normally be disposed of in a non-secure manner, such as at a sanitary landfill site, if not incinerated. It includes clean wood waste, i.e., waste from woodworking or forest product operations, including bark, where the wood waste has not been treated with preservative chemicals (e.g., pentachlorophenol) or decorative coatings. Non-hazardous solid waste incineration includes incineration of residential and other municipal wastes in conical (or teepee) burners, and clean wood waste in beehive burners.
   
   A facility used for the incineration of 100 tonnes or more of non-hazardous solid waste per year is required to report to the NPRI if it met the substance criteria, regardless of the number of hours worked by employees.
   
   
2. Biomedical or hospital waste incineration of 100 tonnes or more of waste per year
   Biomedical waste is defined fully in Appendix 4 of the Supplementary Guide. Biomedical or hospital waste refers to waste that is generated by:
   • human or animal health-care facilities
     
     
   • medical or veterinary research and testing establishments
     
     
   • health-care teaching establishments
     
     
   • clinical testing or research laboratories, and
     
     
   • facilities involved in the production or testing of vaccines.

   Biomedical or hospital waste includes human anatomical waste and animal waste. It also includes microbiology laboratory waste, human blood and body fluid waste, and waste sharps that have not been disinfected or decontaminated. It does not include waste from animal husbandry, or waste that is controlled in accordance with the Health of Animals Act (Canada).

   Wastes that are household in origin, or that are generated in the food production, general building maintenance and office administration activities of those facilities to which this definition applies, are not considered to be biomedical or hospital waste but rather to be non-hazardous solid waste.

   A facility used for the biomedical or hospital waste incineration of 100 tonnes or more of waste per year is required to report to the NPRI if it met the substance criteria, regardless of the number of hours worked by employees.

3. Hazardous waste incineration
   Hazardous waste is defined fully in Appendix 5 of the Supplementary Guide. Hazardous waste includes those wastes that are potentially hazardous to human health and/or the environment because of their nature and quantity, and that require special handling techniques. Hazardous waste incinerators must be licensed by the responsible jurisdiction. Hazardous waste incinerated in a mobile incinerator temporarily located at your facility must be included as part of this activity.
   
   A facility used for the incineration of hazardous waste is required to report to the NPRI if it met the substance criteria, regardless of the number of hours worked by employees or the quantities incinerated.
   
   
4. Sewage sludge incineration
   Sludge means a semi-liquid mass removed from a liquid flow of wastes. Sewage sludge means sludge from a facility treating wastewater from a sanitary sewer system.
   
   A facility used for the incineration of sewage sludge is required to report to the NPRI if it met the substance criteria, regardless of the number of hours worked by employees or the quantities incinerated.

Wood Preservation Activities

Wood Preservation (using heat or pressure treatment, or both)
A facility used for wood preservation is required to report to the NPRI for Schedule 1, Part 1, substances and mercury (and its compounds) if it met the substance criteria, regardless of the number of hours worked by employees.

Wood Preservation Using Creosote
A facility used for wood preservation must report for any of the 17 individual PAHs released on site or transferred off site from a wood-preservation process using creosote, regardless of the number of hours worked by employees. This reporting criterion is found in Schedule 2, Part 3, of the 2000 Canada Gazette notice. Refer to Chapter 4 of the Supplementary Guide for details.

Wood Preservation Using Pentachlorophenol
A facility used for wood preservation using pentachlorophenol must report for dioxins/furans and HCB, regardless of the number of hours worked by employees or the quantities of dioxins/furans and HCB released or transferred. This reporting criterion is found in Schedule 2, Part 4, of the 2000 Canada Gazette notice. Refer to Chapter 5 of the Supplementary Guide for details.

Employee Criteria

If your facility was not used for one of the activities described above, the 20 000-hour employee threshold applies. The total number of hours worked includes paid vacation and sick leave. Owners, students, part-time and contract employees are included in this calculation. This threshold depends specifically on the number of hours worked by all employees at the facility during the calendar year and not on the number of persons working. When reporting to the NPRI, 10 "full-time employees" is equivalent to 20 000 hours worked.

A facility is not required to report to the NPRI if, during the 2000 calendar year:

• the total number of hours worked by all employees was less than 20 000 hours, AND
  
  
• the facility was not used for any of the activities listed in Table 1.

Schedule 1, Part 1, Substances

Four substances were added to Schedule 1, Part 1, of the 2000 Canada Gazette notice. The substances and their Chemical Abstracts Service (CAS) registry numbers are:

Mercury (and its compounds) were moved to Schedule 2, Part 2, of the 2000 Canada Gazette notice. A facility is required to submit a report for mercury (and its compounds) if they were manufactured, processed or otherwise used, at any concentration, in a quantity of 5 kg or more. Further information on mercury and the other substances with alternate reporting thresholds is provided in the Supplementary Guide.

You must confirm that one or more of the 248 substances listed in Schedule 1, Part 1 were manufactured, processed or otherwise used at your facility. The NPRI substances are listed in alphabetical order in Appendix 1. Most of the substances have CAS numbers associated with them. The NPRI substances are listed by CAS number in Appendix 2. Substances that do not have a unique CAS number are noted with an asterisk (*).

Some groups of substances and individual substances are qualified in terms of their specific physical or chemical form, state or particle size. These qualifiers will determine whether your facility will be required to report for a given substance:

• fume or dust
  This qualifier for aluminum and vanadium refers to solids with particle diameters of 0.001 to 1 micron for fumes and 1 to approximately 100 microns for dust particles.
  
  
• fibrous forms
  This qualifier, applied to aluminum oxide, excludes the more common granular, powdered or fumed forms of alumina.
  
  
• salts
  Weak acids and bases are listed with this qualifier. Although the CAS number that appears on the NPRI list is specific to the acid or base, all salts of these listed substances must be reported as an equivalent weight of the acid or base.
  
  
• compounds
  Twelve NPRI Part 1 elements have this qualifier - antimony, arsenic, cadmium, chromium, cobalt, copper, lead, manganese, nickel, selenium, silver and zinc. The element mercury, listed in Part 2, also has this qualifier. The pure element and any substance, alloy or mixture must be reported as the equivalent weight of the element. No CAS number is provided for these substances.

  Note that tetraethyl lead and lead (and its compounds) both appear on the NPRI list. Exclude tetraethyl lead when completing a report for lead (and its compounds). Complete a separate report for tetraethyl lead. Apply the reporting criteria to each substance separately.

• friable form
  Asbestos is the general name for several fibrous minerals and products. Only asbestos that is brittle and readily crumbled should be reported.
  
  
• mixed isomers
  This qualifier is used for mixtures of isomers which have the same chemical formula but different chemical structures. The substances with this qualifier are - cresol, dinitrotoluene, n-nonylphenol, toluenediisocyanate and xylene. Substances with this qualifier are usually found as mixtures. The total quantity of all isomers must be used in calculating the 10-tonne threshold quantity. Do not apply the 10-tonne reporting threshold to each individual isomer unless the pure isomer alone is manufactured, processed, otherwise used or is an NPRI by-product.
  
  
• all isomers
  This qualifier is applied to three hydrochlorofluorocarbons: HCFC-122, HCFC-123 and HCFC-124. Each HCFC is reported as an aggregate of the individual isomers that have the same chemical formula but different chemical structures. The total quantity of all isomers must be used in calculating the 10-tonne threshold quantity.
  
  
• ionic
  This qualifier, applied to cyanides, includes the salts of hydrogen cyanide but excludes organocyanides, nitriles and organometallic cyanide compounds such as ferrocyanide. In the mining industry, ionic cyanide is equivalent to "weak acid dissociable" cyanide.
  
  
• total
  For aqueous solutions of ammonia, this means both NH₃and NH₄ ⁺ expressed as ammonia.
  
  
• yellow or white
  This qualifier is the general description for the common allotropes of elemental phosphorus.
  
  
• in solution at a pH of 6.0 or greater
  This distinguishes nitrate ion in neutral or basic solution from nitric acid (pH of less than 6.0). If nitric acid is neutralized to a pH of 6.0 or greater, you must submit a report for both nitric acid and for nitrate ion in solution. Your release or transfer of nitric acid would be "zero" and your release or transfer of nitrate ion would reflect the quantity of neutralized nitric acid reported as nitrate ion in solution at a pH of 6.0 or greater.

In most cases, consider only the substances and the CAS numbers listed. For example, "styrene" is listed with its corresponding CAS number "100-42-5". The chemical description which corresponds to this CAS number does not include "polystyrene". There are no polymers on the NPRI list, only monomers.

Material Safety Data Sheets (MSDSs) are an important source of information on the composition of purchased products. Suppliers of hazardous materials are required, as part of the Workplace Hazardous Material Information System (WHMIS), to supply MSDSs on request.

Nature of Activities

The terms "manufacture", "process" and "other use" are defined in Schedule 4 of the 2000 Canada Gazette notice. These activities are part of the reporting criteria. An NPRI Part 1 substance at a concentration equal to or greater than 1% or an NPRI Part 1 by-product at a concentration of less than 1%, are only included in the calculation of the 10-tonne reporting threshold if they had been manufactured, processed or otherwise used. An NPRI report does not have to be submitted for a substance that was never manufactured, processed or otherwise used at the facility during the reporting year.

Manufacture

The term "manufacture" means to produce, prepare or compound an NPRI substance. It also includes the incidental production of an NPRI substance as a by-product resulting from the manufacture, processing or other use of other substances.

The production of chlorine dioxide by a chemical plant is an example of manufacturing. The production of hydrochloric acid during the manufacture of chlorofluorocarbons is an example of incidental production.

Process

The term "process" means the preparation of an NPRI substance, after its manufacture, for distribution in commerce. Processing includes preparation of a substance with or without changes in physical state or chemical form. The term also applies to the processing of a mixture or formulation that contains an NPRI substance as one component, as well as the processing of "articles" (see Other Definitions).

The use of chlorine (an NPRI substance) to manufacture hypochloric acid (not an NPRI substance) is an example of processing of chlorine. The use of toluene and xylenes to blend paint solvent mixtures is an example of processing without changes in chemical form.

Other Use

The terms "other use" and "otherwise used" encompass any use of an NPRI substance at a facility that does not fall under the definitions of "manufacture" or "process". This includes the use of the substance as a chemical processing aid, manufacturing aid or some other ancillary use. The use of trichloroethylene in the maintenance of equipment used for manufacturing and processing is considered an "other use". "Other use" does not include routine janitorial or facility grounds maintenance.

By-products

In 1995, the reporting criteria for NPRI Part 1 substances were changed to include by-products in the calculation of the 10-tonne reporting threshold. The reason for this change was to identify large-volume, low-concentration releases and transfers which normally would not trigger the reporting criteria of the NPRI. This change affects facilities that release to the environment or transfer for disposal large quantities of NPRI substances, but at concentrations of less than 1%. Some examples of affected sectors include, but are not limited to, power generation, aluminum smelting, and pulp and paper production.

Normally, only NPRI Part 1 substances in concentrations equal to or greater than 1% are included in the threshold calculations. The 1% concentration limit is consistent with the reporting requirements under the WHMIS. Minor constituents (with some exceptions) are not included on MSDS. However, NPRI Part 1 by-products at less than 1% concentration by weight must be included in the calculation of the 10- tonne reporting threshold.

The NPRI applies to any person who possesses or who may reasonably be expected to have access to the types of information requested. This reasonable expectation limits the reporting liability of facilities which cannot easily determine minor amounts of NPRI substances in their feedstock or process.

To determine if an NPRI Part 1 substance is a by-product, you need to consider all elements of the by-product definition.

A "by-product" is an NPRI substance that is incidentally manufactured, processed or otherwise used at the facility at a concentration of less than 1% by weight, and is released on site to the environment or transferred off site for disposal.

The NPRI Part 1 substance is not relevant to the manufacture, process or other use of substances at the facility. It may be the product of an unwanted side-reaction or an impurity in a feedstock material. If the NPRI by-product was absent, there would be no effect on the process. As with substances reportable to the NPRI, it must have been manufactured, processed or otherwise used at the facility.

The NPRI Part 1 substance was manufactured, processed or otherwise used at a concentration of less than 1% by weight.

NPRI Part 1 substances which meet the above criteria are only considered by-products if they are released to the environment or transferred off site for disposal. Substances that are recycled or that remain in the final product are excluded from the by-product definition.

Example 1
Hydrogen fluoride is incidentally manufactured during aluminum smelting. For some large facilities, more than 10 tonnes may be released to the atmosphere at concentrations of less than 1%. The weight of the hydrogen fluoride by-product must be used in the calculation of the 10-tonne reporting threshold.

Example 2
Chromium and nickel are incidentally present in coal. During combustion, a portion of these metals is concentrated in the ash which is transferred off site for disposal and a portion of the metals is released in stack emissions. The weight of the heavy metal by-products must be included in the calculation of the 10-tonne reporting threshold.

Example 3
An NPRI Part 1 substance is present in trace amounts in a product that is repackaged for retail sale. The quantity of this substance released through spillage or through fugitive air emissions cannot be determined because the formulation of the product is proprietary or the substance concentration is not listed on the MSDS and more detailed information cannot be obtained from the supplier or manufacturer. Although this NPRI substance is considered a by-product, it is not included in the calculation of the 10-tonne reporting threshold because it is an unreasonable expectation that the facility could obtain information on the substance identity, concentration or quantity.

Other Definitions

Facility

A "facility" refers to all buildings, equipment, structures and other stationary items that are located on a single site or on contiguous or adjacent sites that are owned or operated by the same person and function as a single integrated site.

Article

An "article" is defined as a manufactured item that does not release an NPRI substance under normal conditions of processing or use. When articles such as metal sheets and bars are processed (punched, cut or sheared) and there are no releases, or the releases such as metal shearings or pieces are recycled 100% or with due care, the NPRI substances in that article need not be included in the threshold calculation. Exercising "due care" in ensuring 100% recycling means that the facility generated less than 1 kg of the NPRI substance as waste during the calendar year. Materials that are welded lose their article status since there are releases from the article during welding.

Exclusions

In calculating the quantity of an NPRI substance that is manufactured, processed or otherwise used at your facility, do not include the quantity of the substance that is:

• contained in articles that are processed or otherwise used
  
  
• contained in materials used as structural components of the facility - The exclusion of structural components of the facility from the reporting threshold is limited to buildings and other fixed structures but does not include process equipment.
  
  
• contained in materials used in routine janitorial or facility grounds maintenance - The maintenance of processing equipment is not considered "routine janitorial" or "facility grounds" maintenance. For example, if manufacturing or processing equipment is cleaned with a solvent, the amount of NPRI substance(s) contained in the solvent should be included in the threshold calculation.
  
  
• contained in materials used for personal use by employees or other persons
  
  
• used for the purpose of maintaining motor vehicles operated by the facility
  
  
• present in intake water or intake air - This refers to water used for process cooling or air used either as compressed air or for combustion.

Calculating the 10-tonne Reporting Threshold

The 10-tonne reporting threshold is based on the quantity of an NPRI Part 1 substance manufactured, processed or otherwise used at the facility at concentrations equal to or greater than 1% plus the quantity of the same NPRI Part 1 substance, at less than 1% concentration, that is considered to be a by-product which is released on site to the environment or transferred off site for disposal.

When calculating the 10-tonne reporting threshold, include the quantity of an NPRI Part 1 substance that is:

• manufactured at a concentration equal to or greater than 1%
• processed at a concentration equal to or greater than 1%
• otherwise used at a concentration equal to or greater than 1%
• a by-product, at less than 1% concentration, released on site to the environment
• a by-product, at less than 1% concentration, transferred off site for disposal.

Any NPRI substances that are recycled off site and returned to the facility should be treated as the equivalent of newly-purchased material for the purposes of NPRI threshold determinations. Since an NPRI Part 1 substance may undergo many processes in a facility, care should be taken not to double-count process streams when calculating the reporting threshold.

NPRI Part 1 Substances Equal to or Greater than 1% Concentration

The total quantity of an NPRI Part 1 substance manufactured, processed or otherwise used at concentrations greater than or equal to 1%, at any time or in any part of the facility, must be used in the calculation of the 10-tonne reporting threshold.

The quantity of a substance received by a facility at 30% concentration and then diluted to less than 1% for use, is included in the threshold calculation. The same would apply for a substance received at the facility at less than 1% and subsequently concentrated to 5%.

Facilities that blend or formulate NPRI Part 1 substances such as solvents, must include the total quantity of the substance blended or mixed in the reporting threshold calculation since blending, mixing and formulating are considered processing, which is a reportable activity.

Facilities that repackage or transfer NPRI Part 1 substances between containers need only consider the total quantity of the substance repackaged or transferred.

If only a range of concentrations is available for a substance present in a mixture, use the average of the range for threshold determinations.

NPRI Part 1 Substances of Less than 1% Concentration

The total quantity of a by-product released on site to the environment or transferred off site for disposal must be used in the calculation of the 10-tonne reporting threshold. This is the only circumstance where the quantity of an NPRI Part 1 substance at a concentration of less than 1% is used in calculating the 10-tonne reporting threshold. However, once the reporting criteria have been met, all on-site releases and off-site transfers for disposal or recycling must be reported, regardless of the substance's concentration.

The following examples illustrate application of the by-product definition:

Example 1
A facility uses a pre-polymer mixture which contains unreacted di-n-octyl phthalate monomer at a concentration of less than 1%. The monomer remains in the final product after the processing is complete. The polymer is used to make articles sold for distribution. The unreacted monomer is not released and remains in the product distributed in commerce and, therefore, is not included in calculating the 10-tonne threshold.

Example 2
Gases produced during coking of coal are recovered and used to supply heat and are therefore not considered by-products. The quantity produced at concentrations of less than 1% should not be used in the calculation of the reporting threshold.

Example 3
Many industrial processes involve separation but not all create by-products. Distillation of crude oil, for example, produces a number of secondary substances intended for distribution in commerce or further use. These are not by-products for the purpose of reporting to the NPRI.

Example 4
Metal cuttings, transferred off site for disposal, contain alloyed chromium at a concentration of less than 1%. The chromium is an essential component of the alloy, therefore it is not incidentally processed and is not considered to be a by-product. The chromium in the metal cuttings is not included in the calculation of the 10-tonne reporting threshold.

Example of Calculating the Reporting Threshold

The following example illustrates the calculation of the 10-tonne reporting threshold. This facility has several processes in which an NPRI Part 1 substance is manufactured, processed or otherwise used.

1. In the first process, NPRI substance "A" is present at 5% concentration and is included in the threshold calculation.
   
   
2. In the second process, a raw material added to the process is pure substance "A". It is also included in the threshold calculation, regardless of any subsequent dilution in the process. This also applies to a substance received at the facility at less than 1% which is subsequently concentrated to more than 1% in the process.
   
   
3. The weight of substance "A" in the raw material used in process 3 is not included in the threshold calculation because the concentration is less than 1%. Note, however, that since the facility in this example must report because it meets the 10-tonne reporting threshold, it is required to take into account and report releases and transfers from all processes including those, such as process 3, which were not used in the threshold calculations.
   
   
4. The weight of substance "A" produced and released from process 4 is included in the calculation because it is a by-product. The concentration criterion does not apply to by-products.

In this example, the facility would be required to file a report to the NPRI (assuming it also meets the 20 000-hour employee threshold) because the total amount of substance "A" manufactured, processed or otherwise used at the facility exceeds 10 tonnes for a given calendar year.

Note that the facility must submit a report even if the on-site releases or off-site transfers for disposal or recycling of substance "A" are zero.

Threshold calculations do not need to be reported to the NPRI. Their purpose is to determine the substance for which a facility is required to report on-site releases and transfers off site for disposal or recycling. Keep this information in your files.

If You Are Not Required to Report

If you have concluded that you are not required to report for your facility, either because it is an exempt facility or it does not meet all the reporting criteria, advise your regional NPRI office (listed on the inside front cover) to update our records and mailing lists. Please refer to the Supplementary Guide for the reporting criteria for mercury (and its compounds), PAHs, dioxins/furans and HCB. Both this Guide and the Supplementary Guide should be consulted by owners and operators of facilities to determine if they must report for any NPRI substances.

If You Are Required to Report

If you have concluded that you are required to report for your facility, use the electronic reporting form to complete your report. Send your report on disk and a signed Statement of Certification to your regional NPRI office (listed on the inside front cover), postmarked or courier-dated no later than June 1, 2001. If you do not have access to a computer, a paper reporting form can be provided by your regional NPRI office. Extra copies of the reporting package can also be ordered from your regional NPRI office. The reporting package is available in the following formats:

• a CD-ROM containing the Windows reporting software and guidance documents
• the Windows reporting software on 3.5" IBM-compatible diskettes
• the printed version of the Guide for Reporting to the National Pollutant Release Inventory - 2000, or
• the printed version of the Supplementary Guide for Reporting to the National Pollutant Release Inventory - Alternate Thresholds - 2000.