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Persistent Bioaccumulative Toxic Chemicals and Toxics Release Inventory Reporting Requirements

More information from EPA on PBT chemical rules

Persistent Bioaccumulative Toxins (PBTs) are chemicals that are stable for long periods of time, and build up in the environment, particularly in food chains. Small releases of such chemicals may accumulate in the environment. The Environmental Protection Agency (EPA) finalized a rule November 26, 2010 to add sixteen chemicals, four of which are PBTs, to the Toxics Release Inventory (TRI) reporting requirements. The rule also modified certain reporting exemptions and requirements for PBT chemicals. It became effective for the Reporting Year (RY) year 2011 activity (for reports that were due July 1, 2012).

Added PBT Chemicals

The four PBT chemicals added to the TRI chemical list for RY 2011 along with their reporting thresholds are as follows:

  • 1,6-Dinitropyrene (100 pounds/yr)
  • 1,8-Dinitropyrene (100 pounds/yr)
  • 6-Nitrochrysene (100pounds/yr)
  • 4-Nitropyrene (100 pounds/yr)


The de minimus exemption for PBTs (except for purposes of supplier notification) is no longer allowed, but the vehicle exemption, laboratory exemption, facility use exemption, and article exemption are still allowed.

Other TRI PBT Requirements

No Form A and no range reporting for on-site releases and off-site transfers is allowed. Releases and waste management quantities greater than 0.1 pound are required to be reported for PBT chemicals, with the exception of dioxin and dioxin-like compounds. If any release or management of dioxin or dioxin-like compounds exceeds one hundred micrograms (0.0001 gram), it must be reported.

PBTs and Combustion

PBT chemicals that may be generated during the combustion of coal, residual fuel oil, distillate fuel oil, natural gas and wood include:

  • Vanadium
  • Mercury
  • PACs: benz(a)anthracene, chrysene and benzo(a)pyrene
  • Hexachlorobenzene

Dioxin and Dioxin-Like Compounds Category

EPA's final guidance document for dioxin and dioxin-like compounds category

There is a qualifier for these chemicals that includes 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. Sources of these chemicals are:

  • Waste incineration: municipal, medical, hazardous, tires, pulp and paper
  • Energy generation: coal, oil and/or wood combustion
  • Portland cement or cement kilns that burn hazardous waste
  • Pulp and paper mills: kraft black liquor recovery boilers, chlorine bleaching
  • Petroleum refineries: catalyst regeneration
  • Asphalt mixing plants
  • Iron and steel-making: iron ore sintering, coke production, electric arc furnaces
  • Ferrous foundries
  • Secondary smelting of aluminum, copper and lead
  • Chemical manufacturing: involving chlorinated compounds

The dioxin and dioxin-like chemical compounds category includes only the following chemicals:

  • 2,3,7,8-Tetrachlorodibenzo-p-dioxin
  • 1,2,3,7,8-Pentachlorodibenzo-p-dioxin
  • 1,2,3,4,7,8-Hexachlorodibenzo-p-dioxin
  • 1,2,3,6,7,8-Hexachlorodibenzo-p-dioxin
  • 1,2,3,7,8,9-Hexachlorodibenzo-p-dioxin
  • 1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
  • 1,2,3,4,6,7,8,9-Octachlorodibenzo-p-dioxin
  • 2,3,7,8-Tetrachlorodibenzofuran
  • 1,2,3,7,8-Pentachlorodibenzofuran
  • 2,3,4,7,8-Pentachlorodibenzofuran
  • 1,2,3,4,7,8-Hexachlorod-benzofuran
  • 1,2,3,6,7,8-Hexachlorodibenzofuran
  • 1,2,3,7,8,9-Hexachlorodibenzofuran
  • 2,3,4,6,7,8-Hexachlorodibenzofuran
  • 1,2,3,4,6,7,8-Heptachlorodibenzofuran
  • 1,2,3,4,7,8,9-Heptachlorodibenzofuran
  • 1,2,3,4,6,7,8,9-Octachlorodibenzofuran


Hexachlorobenzene is an organo-chlorine compound. It is a white crystalline solid created by the chlorination of a benzene ring. Possible sources of this compound are:

  • Magnesium production
  • Aluminum production
  • Commercial hazardous waste treatment
  • Solvent recovery facilities
  • Manufacturing of chlorinated organic compounds
  • Coal combustion

Mercury and Mercury Compounds

Possible sources of mercury and mercury compounds are:

  • Metal and coal mining
  • Pulp mills
  • Industrial and inorganic chemical facilities
  • Petroleum refineries
  • Portland cement and lime manufacturing
  • Steel works, blast furnaces and rolling mills
  • Smelting and refining of nonferrous metals
  • Fabricated metal products
  • Electric utilities
  • Commercial hazardous waste treatment
  • Petroleum bulk stations and solvent recovery facilities
  • Coal or fuel oil combustion


Octachlorostyrene is a polychlorinated styrene that is a possible byproduct of chlorine production, chlorination reactions, and metal product/finishing operations. Possible sources of Octachlorostyrene are:

  • Magnesium production
  • Aluminum production
  • Commercial hazardous waste treatment
  • Alkalies and chlorine production
  • Industrial inorganic chemicals
  • Pesticides and agricultural chemicals


Like hexachlorobenzene, pentachlorobenzene is formed by chlorination of a benzene ring. Possible sources of pentachlorobenzene are:

  • Solvent recovery services
  • Commercial hazardous waste treatment
  • Manufacturing of chemicals and allied products
  • Chemical usage of which pentachlorobenzene is a byproduct or an impurity


Pesticides include Aldrin, Chlordane, Heptachlor, Isodrin, Methoxychlor, Pendimethalin, Toxaphene, and Trifluralin which are insecticides or herbicides. Sources of these chemicals are:

  • RCRA Subtitle C Facilities
  • Pesticides and agricultural products
  • Otherwise use pesticides

Polychlorinated Biphenyls (PCBs)

PCBs are a group of 209 synthetic halogenated aromatic hydrocarbons. Transformers, electromagnets, switches, voltage regulators and capacitors may contain PCBs. Possible sources of PCBs are:

  • Electric utilities
  • Commercial hazardous waste treatment
  • Petroleum bulk stations
  • Combustion sources
  • Facilities that service or retrofill PCB containing equipment

**The article exemption can apply to PCB containing equipment that is disposed of in its entirety.

Polycyclic Aromatic Compounds (PACs)

PACs are a group of chemicals that are characterized by hydrogen and carbon arranged in two or more fused benzene rings. They are also known as polycyclic aromatic hydrocarbons (PAHs). Sources of these chemical compounds are:

  • Combustion sources
  • Electric utilities
  • Commercial hazardous waste treatment
  • Petroleum refineries
  • Petroleum bulk stations
  • Solvent recovery services

This PAC category includes only the chemicals listed below:

  • Benz(a)anthracene
  • Benzo(b)fluoranthene
  • Benzo(j)fluoranthene
  • Benzo(k)fluoranthene
  • Benzo(j,k)fluorene
  • Benzo(r,s,t)pentaphene
  • Benzo(a)phenanthrene
  • Benzo(a)pyrene
  • Dibenz(a,h)acridine
  • Dibenz(a,j)acridine
  • Dibenzo(a,h)anthracene
  • 7H-Dibenzo(c,g)carbazole
  • Dibenzo(a,e)fluoranthene
  • Dibenzo(a,e)pyrene
  • Dibenzo(a,h)pyrene
  • Dibenzo(a,l)pyrene
  • 7,12-Dimethylbenz(a)-anthracene
  • 1,6-Dinitropyrene
  • 1,8-Dinitropyrene
  • Indeno(1,2,3-cd)pyrene
  • 3-Methylcholanthrene
  • 5-Methylchrysene
  • 6-Nitrochrysene
  • 1-Nitropyrene
  • 4-Nitropyrene

Tetrabromobisphenol A (TBBPA)

Tetrabromobisphenol A (TBBPA) is a brominated flame retardant and is often used in plastics and engineering resins for printed circuit boards and computer equipment. Sources of it are:

  • Plastic materials, synthetic resins and non-volcanized elastomers
  • Chemicals and allied products
  • Custom compounding of purchased plastic resins
  • Electronic computers, computer storage devices, computer terminals
  • Printed circuit boards
  • Commercial hazardous waste treatment

Vanadium and Vanadium Compounds

Vanadium and vanadium compounds are not PBT chemicals, even though they were modified as part of the PBT rule. Vanadium is a metal used as an additive to alloys, carbon and tool steels, super-alloys, stainless steel, catalysts, ceramics, and electronic applications. Sources of vanadium are:

  • Petroleum refineries
  • Primary metal industries
  • Electric utilities
  • Combustion sources
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Virginia Department of
Environmental Quality
P.O. Box 1105
Richmond, VA 23218
(804) 698-4000

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