Toxic Chemical Release Inventory Reporting Forms and Instructions

Appendix C
1998, and subsequently revises only one chemical
submission, the facility will receive a FDP for
Reporting Year 1998 with only the revised chemical
included in the Chemical Reports section. Hence
there may be fewer chemical reports than chemicals
listed in the Chemical Summary section. If only
facility level changes have occurred (i.e., Part I of the
Form R or A), this section is not provided.
B. Levels of Errors Identified in FDPs:
Notice of Non-Technical Data Change
(NDC), Notice of Technical Errors
(NOTE), Notice of Significant Errors
(NOSE). Notice of Noncompliance (NON).
FDP Error Reporting. In addition to “echoing back” the
information a facility has submitted, FDPs are used to identify
potential errors, as well as indicate where the TRI Data
Processing Center has made minor clerical changes to
submissions. As submission information is entered into EPA’s
national database, a series of automated data quality checks are
performed. The data quality checks are useful to identify
potential errors with certain data fields such as TRI Facility
Identification, facility name, county spelling, as well as to
perform validation checks to ensure consistency among data
elements within a given Form R or Form A. These data quality
checks, however, cannot detect whether release, transfer, or
waste management quantities were calculated or entered
accurately. Within a FDP notice, there may be up to three
different types of errors identified.
First, a Non-Technical Data Change (NDC) notifies you of
simple, clerical errors that the TRI Data Processing Center has
corrected for you. It is not necessary to respond to a NDC.
The TRI Data Processing Center will correct simple, clerical
errors that are not technical or scientific — a “non-technical
data change.” For example, if a facility transposes CAS
numbers (e.g., the submitter lists 7623-00-0 for sodium nitrite
instead of 7632-00-0), the TRI Data Processing Center will
correct this clerical error and display the correct information on
the facility’s FDP. If a facility lists a specific glycol ethers
subcategory, the TRI Data Processing Center will replace this
subcategory with the reportable name “certain glycol ethers.”
The messages used on FDPs to report non-technical data
changes are shown at the end of this appendix under the
heading “E. Messages Used to Report Notices of Technical
Errors (NOTEs) and Non-technical Data Changes (NDCs).”
Second, a Notice of Technical Error (NOTE) highlights
inconsistencies or miscalculations that may distort your
facility’s information in EPA’s public data products or skew
analyses. Incomplete addresses, no technical or public contact
provided, missing or invalid SIC codes, or the use of range
codes to report PBT chemical releases are all examples of
technical errors. You should respond to NOTEs as soon as
possible. These types of errors require that the reporting
facility make corrections on its FDP (or provide the TRI Data
Processing Center with a brief explanation why they do not
believe that it is an error) or submit a revised Form R or Form
A. Depending upon when your changes are received, there
may or may not be sufficient time to incorporate them into
EPA’s database in time for public data release. Technical
errors do not prevent submissions from being entered into the
data management system, but indicate inconsistencies or
miscalculations in the submitted form. These errors can
distort public information products and skew any analyses if
not corrected. The messages used on FDPs to report NOTEs
are shown below at the end of this appendix under the heading
“E. Messages Used to Report Notices of Technical Errors
(NOTEs) and Non-technical Data Changes (NDCs).”
Third, more serious errors are classified as Notices of
Significant Errors (NOSE). The FDP contains the Notice of
Significant Error if applicable. Significant errors prevent
submissions from being entered into the TRI Data Processing
Center data management system or do not allow the TRI Data
Processing Center to verify the authenticity of the submission.
Invalid forms, missing pages, no certification signature, no
chemical name or CAS number are examples of significant
errors. These types of errors require that the reporting facility
make corrections on their FDP, submit a revised Form R or
Form A, or provide the TRI Data Processing Center with a
brief explanation why they do not believe that it is an error.
A facility must respond to a Notice of Significant Error within
21 days of receipt. Failure to respond within the initial 21 day
requirement could result in the issuance of a Notice of
Noncompliance (NON). A Notice of Noncompliance is not
included in a FDP and is mailed separately.
The Agency will issue a conditional Notice of
Noncompliance (NON) to a facility for failure to respond to
a Notice of Significant Error (NOSE) within the required
period. A NON will require a facility to take the corrective
action noted in the NOSE within 21 days and respond to the
Agency that corrective action has been taken. If a facility fails
to respond to the NON within the required time period, the
Agency may take further action.
Facilities must keep copies, for three years, of submitted Form
R reports and Form A certifications and all documentation
used to complete their submissions. This documentation
should include calculations for threshold determinations, the
basis of exemptions applied, and the estimation techniques
and data used for all quantities reported on the Form R and
Form A.
C–2 Toxics Release Inventory Reporting Forms and Instructions