October,
2003
TOXIC
CHEMICAL
RELEASE
INVENTORY
TOXIC
CHEMICAL
RELEASE
REPORTING
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
OMB
CONTROL
NO.
2070­
0093
EPA
ICR
#
1363.13
October,
2003
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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3
1(
a)
Title
of
the
Information
Collection
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3
1(
b)
Short
Characterization
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3
2
NEED
FOR
AND
USE
OF
THE
COLLECTION
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4
2(
a)
Need/
Authority
for
the
Collection
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4
2(
b)
Use/
Users
of
the
Data
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6
3
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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23
3(
a)
Respondents/
SIC
Codes
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23
3(
b)
Information
Requested
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24
4
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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28
4(
a)
Agency
Activities
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28
4(
b)
Collection
Methodology
and
Management
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32
4(
c)
Small
Entity
Flexibility
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32
4(
d)
Collection
Schedule
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33
5
NONDUPLICATION,
CONSULTATIONS,
OTHER
COLLECTION
CRITERIA
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33
5(
a)
Nonduplication
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33
5(
b)
Consultations
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64
5(
c)
Effects
of
Less
Frequent
Collection
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67
5(
d)
General
Guidelines
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67
5(
e)
Confidentiality
and
Sensitive
Questions
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68
6
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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68
6(
a)
Estimating
Respondent
Burden
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68
October,
2003
6(
b)
Estimating
Respondent
Costs
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74
6(
c)
Estimating
Agency
Burden
and
Cost
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.
77
6(
d)
Bottom
Line
Burden
Hours
and
Costs
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79
6(
e)
Reasons
for
Change
in
Burden
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83
6(
f)
Burden
Statement
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.
85
ATTACHMENT
A
Toxic
Chemical
Release
Inventory
Reporting
Form
R
(
EPA
Form
#
9350­
1)
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A­
1
ATTACHMENT
B
TRI
Chemicals
Reported
to
Non­
TRI
Databases
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B­
1
ATTACHMENT
C
Emergency
Planning
and
Community
Right
to
Know
Act
of
1986,
Section
313
(
42
U.
S.
C.
A.
Section
1023)
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C­
1
ATTACHMENT
D
Pollution
Prevention
Act
(
42
U.
S.
C.
A.
Sections
13101­
13109)
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D­
1
ATTACHMENT
E
40
CFR
Part
372
Toxic
Chemical
Release
Reporting:
Community
Right­
to­
Know
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E­
1
ATTACHMENT
F
Toxic
Chemical
Release
Inventory
Reporting
Forms
and
Instructions
Revised
2001
Version
(
EPA
260­
B­
02­
001)
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F­
1
ATTACHMENT
G
Proposed
Form
R
(
OMB
No.
2070­
0093)
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G­
1
October,
2003
3
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
TITLE:
Toxic
Chemical
Release
Reporting,
Recordkeeping,
Supplier
Notification
and
Petitions
under
Section
313
of
the
Emergency
Planning
and
Community
Right­
to­
Know
Act
EPA
ICR
No.:
1363.13
OMB
Control
No.:
2070­
0093
1(
b)
Short
Characterization
This
Information
Collection
Request
(
ICR)
is
for
the
information
collection
requirements
for
toxic
chemical
release
reporting
under
section
313
of
the
Emergency
Planning
and
Community
Rightto
Know
Act
(
EPCRA)
(
42
U.
S.
C.
11001
et
seq.)
and
the
information
collection
in
section
6607
of
the
Pollution
Prevention
Act
(
PPA)
(
42
U.
S.
C.
11071
to
11079).
In
short,
EPCRA
§
313
requires
certain
owners
or
operators
of
certain
facilities
(
i.
e.,
currently
manufacturing
facilities
in
Standard
Industrial
Classification
(
SIC)
codes
20
through
39,
and
facilities
in
SIC
codes
10
(
except
1011,
1081,
and
1094),
12
(
except
1241),
4911,
4931,
4939
(
limited
to
facilities
that
combust
coal
and
/
or
oil
for
the
purpose
of
generating
power),
4953
(
limited
to
facilities
regulated
under
the
Resource
Conservation
and
Recovery
Act,
subtitle
C,
42
U.
S.
C.
section
6921
et.
seq.),
5169,
5171,
7389
(
limited
to
facilities
primarily
engaged
in
solvent
recovery
services
on
a
contract
or
fee
basis))
manufacturing,
processing,
or
otherwise
using
any
of
over
600
listed
toxic
chemicals
and
chemical
categories
(
hereafter
"
toxic
chemicals")
in
excess
of
the
applicable
threshold
quantities
to
report
on
their
environmental
releases
and
transfers
of
and
waste
management
activities
for
such
chemicals
annually.
Under
section
6607
of
the
PPA,
facilities
must
provide
information
on
the
quantities
of
the
toxic
chemicals
in
waste
streams
and
the
efforts
made
to
reduce
or
eliminate
those
quantities.

Currently,
facilities
subject
to
the
Toxics
Release
Inventory
(
TRI)
reporting
requirements
may
either
use
the
EPA
Toxic
Chemical
Release
Inventory
Form
R
(
EPA
Form
#
9350­
1),
or
the
EPA
Toxic
Chemical
Release
Inventory
Form
A
Certification
Statement
(
EPA
Form
#
9350­
2),
which
is
approved
under
OMB
Number
2070­
0143.
The
Form
R
must
be
completed
if
a
facility
manufactures,
processes,
or
otherwise
uses
any
listed
chemical
above
threshold
quantities.
For
the
Form
A
Certification
Statement,
EPA
established
an
alternate
threshold
for
those
facilities
with
low
annual
reportable
amounts
of
a
listed
toxic
chemical.
A
facility
that
meets
the
appropriate
reporting
thresholds,
but
estimates
that
the
total
annual
reportable
amount
of
the
chemical
does
not
exceed
500
pounds
per
year,
can
take
advantage
of
an
alternate
manufacture,
process,
or
otherwise
use
threshold
of
1
million
pounds
per
year
for
that
chemical,
provided
that
October,
2003
4
certain
conditions
are
met,
and
submit
the
Form
A
Certification
Statement
instead
of
the
Form
R.
Facilities
may
submit
information
on
multiple
chemicals
on
a
single
Form
A
Certification
Statement.

Pursuant
to
EPCRA
section
313
(
and
PPA
section
6607
because
of
its
linkage
to
EPCRA),
EPA's
Office
of
Environmental
Information
(
OEI)
collects,
processes,
and
makes
available
to
the
public
all
of
the
information
collected.
The
information
gathered
under
these
authorities
is
stored
in
a
database
maintained
at
EPA
and
is
available
through
the
Internet.
The
TRI
is
used
extensively
by
EPA,
other
federal,
state
and
local
government
agencies,
industry,
and
the
public.
Program
offices
within
EPA
and
other
government
agencies
have
used
the
TRI,
along
with
other
sources
of
data,
to
establish
priorities,
evaluate
potential
exposure
scenarios,
and
for
enforcement
activities.
Industries
use
TRI
data
to
identify
pollution
prevention
opportunities,
and
set
goals
for
emissions
reductions.
Environmental
and
public
interest
groups
use
TRI
data
to
make
the
public
more
aware
of
releases
of
chemicals
in
their
communities,
and
to
initiate
direct
negotiation
and
risk
reduction
with
facilities.

EPA
has
developed
EPA
Information
Quality
Guidelines
to
ensure
the
utility,
objectivity
and
integrity
of
information
that
is
disseminated
by
the
Agency.
The
information
supporting
this
ICR
is
consistent
with
all
appropriate
EPA
policies,
including
EPA's
Information
Quality
Guidelines.
In
particular,
the
EPA
Agency­
wide
Quality
System
helps
ensure
that
EPA
organizations
maximize
the
quality
of
information
disseminated
by
the
Agency.
The
Quality
System
is
documented
in
EPA
Order
5360.1
A2,
Policy
and
Program
Requirements
for
the
Mandatory
Agency­
wide
Quality
System
and
the
EPA
Quality
Manual
for
Environmental
Programs
5360
A1,
May
2000.
The
information
supporting
this
action
is
also
consistent
with
EPA's
Guide
to
Writing
Information
Collection
Requests
Under
the
Paperwork
Reduction
Act
of
1995,
revised
2/
99.
It
is
EPA's
intention
that
collection
of
information
under
this
ICR
will
result
in
information
that
will
be
collected,
maintained,
and
used
in
ways
consistent
with
both
EPA's
Information
Quality
Guidelines
and
the
OMB
Information
Quality
Guidelines.

With
TRI,
and
the
real
gains
in
understanding
it
has
produced,
communities
and
governments
know
what
listed
toxic
chemicals
many
industrial
facilities
in
their
area
release,
transfer,
or
otherwise
manage
as
waste.
In
addition,
industries
have
an
additional
tool
for
evaluating
efficiency
and
progress
on
their
pollution
prevention
goals.

OMB
last
approved
this
Information
Collection
request
on
March
10,
2003
with
an
expiration
date
of
October
31,
2003.
A
revised
draft
Form
R
is
included
in
this
ICR
as
Attachment
G.
EPA
sought
comment
on
proposed
changes
to
the
Form
R
to
collect
information
in
a
more
logical
and
easier
manner.
However,
in
light
of
extensive
comment
from
states
and
the
regulated
community
concerning
the
implementation
of
so
many
changes
at
once,
EPA
is
deferring
most
of
these
changes
for
now,
however,
some
of
the
proposed
changes
remain
in
this
version
of
the
Form
R.
For
example,
section
8.1
is
subdivided
into
four
subsections:
section
8.1.
a.
Total
onsite
disposal
to
Underground
Injection
to
Class
I
Wells,
RCRA
Subtitle
C
landfills,
and
other
landfills;
October,
2003
5
section
8.1.
b.
Total
other
onsite
disposal
or
other
releases;
section
8.1.
c.
Total
offsite
disposal
to
Underground
Injection
to
Class
I
Wells,
RCRA
Subtitle
C
landfills,
and
other
landfills;
and
section
8.1.
d.
Total
other
offsite
disposal
or
other
releases.
These
changes
as
well
as
others
are
described
in
more
detail
in
section
3(
b)
of
this
document.
The
existing
reporting
and
recordkeeping
requirements
associated
with
Form
R,
supplier
notification
and
petitions
are
discussed
in
this
ICR
(
EPA
ICR
#
1363),
which
is
separate
from
the
ICR
related
to
the
alternate
threshold
reporting
requirement
for
the
Form
A
Certification
Statement.
The
reporting
and
recordkeeping
requirements
associated
with
the
alternate
threshold
reporting
requirement
using
the
Form
A
Certification
Statement
are
contained
in
a
separate
ICR
and
are
approved
under
OMB
Control
#
2070­
0143
(
EPA
ICR
#
1704).
OMB
last
approved
the
Form
A
Certification
Statement
ICR
on
March
10,
2003
for
use
through
October
31,
2003.
Please
note
that
these
two
ICRs
are
independent
of
each
other,
such
that
the
OMB
action
taken
with
regard
to
EPA
ICR
#
1704
applies
only
to
the
alternate
reporting
requirements
and
the
Form
A
Certification
Statement.

2
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
This
information
collection
activity
is
a
statutory
requirement
pursuant
to
sections
313
of
EPCRA
(
42
U.
S.
C.
11001
et
seq.)
and
section
6607
of
the
PPA
(
42
U.
S.
C.
11071
to
11079).
According
to
EPCRA
section
313(
h),
the
data
submitted
in
the
forms
are
intended
to
"
inform
persons
about
releases
of
toxic
chemicals
to
the
environment;
to
assist
governmental
agencies,
researchers,
and
other
persons
in
the
conduct
of
research
and
data
gathering;
to
aid
in
the
development
of
appropriate
regulations,
guidelines,
and
standards;
and
for
other
similar
purposes."

Section
6602
of
the
PPA
establishes
a
national
policy
that
pollution
should
be
prevented
or
reduced
at
the
source
whenever
feasible.
To
further
this
goal,
EPA
is
to
establish
a
source
reduction
program
which,
among
other
responsibilities,
is
to
collect
and
disseminate
information.
The
information
collected
under
section
6607
is
intended
to
fulfill
that
responsibility
in
part
and
to
provide
a
basis
for
measuring
progress
in
pollution
prevention
in
certain
industrial
groups.

Annual
reporting
under
EPCRA
section
313
of
toxic
chemical
releases
and
other
waste
management
information
provides
citizens
with
a
more
complete
picture
of
the
total
disposition
of
chemicals
in
their
communities
and
helps
focus
industries'
attention
on
pollution
prevention
and
source
reduction
opportunities.
EPA
believes
that
the
public
has
a
right
to
know
about
the
disposition
of
chemicals
within
communities
and
the
management
of
such
chemicals
by
facilities
in
covered
industries
subject
to
EPCRA
section
313
reporting.

Current
TRI
reporting
has
been
successful
in
providing
communities
with
important
information
regarding
the
disposition
of
toxic
chemicals,
and
other
waste
management
information
on
toxic
chemicals
from
manufacturing
facilities
in
their
communities.
October,
2003
6
The
information
collected
under
EPCRA
section
313,
and
subsequently
distributed
through
EPA
outreach
and
awareness
programs,
is
provided
at
relatively
low
cost
compared
to
the
value
it
represents
to
the
general
public.
Through
mass
mailings
to
all
facilities
within
the
manufacturing
sector
of
the
economy,
work
with
a
wide
variety
of
trade
associations
representing
covered
industries,
local
and
national
seminars,
training
courses,
and
enforcement
activities,
EPA
has
endeavored
to
locate
all
facilities
required
to
report
under
section
313
of
EPCRA
and
inform
them
of
their
obligations.
In
addition,
EPA
has
prepared
various
tools
to
assist
facilities
in
complying
with
EPCRA.
These
materials
include
detailed
reporting
instructions,
a
questions
and
answer
document,
magnetic
media
reporting
instructions,
general
technical
guidance,
and
24
industry
and
chemical
specific
guidance
documents.
In
addition,
EPA
maintains
a
toll­
free
hotline
to
answer
regulatory
and
technical
questions
to
assist
facilities
in
preparing
TRI
reports.

Furthermore,
TRI
reporting
does
not
require
a
rigid,
one­
size
fits
all
approach
to
estimating
and
reporting
release
information.
EPA
believes
the
submitters
of
the
TRI
data
are
best
informed
to
honestly
and
accurately
report
information,
within
certain
parameters
provided
by
EPA.
The
Agency
believes
in
the
good
intent
of
the
reporters
to
use
the
most
appropriate
means
to
accurately
estimate
the
release
information.
EPA
does,
however,
also
invest
in
enforcement
and
compliance
efforts
to
insure
that
reporting
is
being
done
consistently
and
thoroughly
by
regulated
industries.

2(
b)
Use/
Users
of
the
Data
According
to
many,
the
TRI
program
is
one
of
the
most
effective
environmental
programs
ever
legislated
by
Congress
and
administered
by
EPA.
Its
success
is
due,
in
large
part,
to
the
right­
toknow
provisions
contained
in
the
legislation
itself.
By
requiring
that
the
resulting
data
be
made
publicly
available
"
by
electronic
and
other
means,"
Congress
ensured
that
citizens,
the
media,
environmental
advocates,
researchers,
the
business
community,
and
others
could
influence
and
evaluate
industry's
efforts
to
manage
toxic
emissions.
Consequently,
data
collected
under
EPCRA
section
313
and
section
6607
of
the
PPA
is
made
available
through
EPA's
Envirofacts
and
TRI
Explorer
databases.
In
addition,
the
public
may
also
obtain
TRI
information
through
OMB
Watch's
Right­
to­
Know
Network
(
RTK
NET)
at
http://
www.
rtk.
net.
RTK
NET
provide
free
public
access
to
numerous
databases,
text
files
and
conferences
on
the
environment,
housing,
and
sustainable
development.

In
addition
to
providing
information
to
the
public
via
electronic
means,
EPA
also
conducts
outreach
activities
to
make
key
groups
and
the
public
aware
of
TRI.
Journalists,
educators,
public
interest,
labor,
and
environmental
groups,
trade
associations,
and
state
governments
continue
to
be
key
targets
in
these
outreach
efforts.
In
addition,
libraries
in
communities
all
across
the
U.
S.
(
in
particular,
members
of
the
Federal
Depository
Library
Program),
are
committed
to
providing
public
access
to
TRI
data
in
a
variety
of
formats.
Educators
are
also
using
the
data
to
conduct
studies
and
courses
on
the
environment.
Labor
unions
are
using
the
TRI
data
to
improve
conditions
for
workers.
Businesses
are
using
the
data
in
many
ways
­­
as
a
October,
2003
7
basis
for
reducing
emissions,
to
cut
costs,
to
improve
operations,
and
for
a
variety
of
other
reasons.
Concerned
citizens
are
a
growing
user
group.
These
individuals,
on
their
own
and
through
organized
groups,
are
using
TRI
to
address
concerns
about
the
management
and
release
of
chemicals
in
their
communities.
Finally,
states
use
the
national
data
to
compare
chemical
management
and
releases
within
industries
and
to
set
environmental
priorities
at
the
state
level.

Because
the
value
of
TRI
increases
as
more
people
use
it,
EPA
encourages
these
organizations
to
acquaint
new
users
with
TRI,
help
people
who
already
know
about
TRI
to
better
use
and
understand
the
data,
and,
whenever
possible,
provide
feedback
on
how
to
improve
TRI
products
and
services.
The
following
are
some
examples
of
how
the
TRI
data
are
used,
both
by
EPA
and
others.
As
examples,
the
following
information
is
not
intended
to
be
all
inclusive.

Use
Within
EPA
Use
of
the
Data
by
the
Office
of
Pollution
Prevention
and
Toxics
With
the
voluntary
cooperation
of
respondent
facilities,
EPA
established
the
Industrial
Toxics
Project,
also
known
as
the
33/
50
Program.
EPA's
33/
50
Program
targeted
17
priority
TRI
chemicals
for
emissions
reductions
from
1988
reported
levels
of
33%
by
1992
and
50%
by
1995.
More
than
1300
companies
nationwide
joined
the
program
which
provided
recognition
to
participating
companies,
including
Certificates
of
Appreciation
to
all
companies
upon
enrollment,
as
well
as
Certificates
of
Environmental
Achievement
to
a
select
group
of
facilities
that
achieved
noteworthy
reductions.
Through
collaborative
partnerships
between
government,
industry
and
the
public,
the
program
met
its
goals
a
year
early
and
went
on
to
exceed
expectations
by
the
end
of
1995.
EPA
celebrated
the
program's
success
by
hosting
a
national
conference
in
September,
1996
and
explored
ways
of
building
even
more
successful
partnerships
in
the
future
with
the
use
of
the
TRI
data.

The
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
has
completed
development
of
the
Risk­
Screening
Environmental
Indicators
model
which
provides
comparative
information
regarding
the
risk­
related
potential
impacts
of
toxic
chemical
releases
on
human
health
and
the
environment.
This
multi­
media,
screening­
level
tool
considers
TRI
release
and
transfer
volumes,
toxicity,
exposure
potential,
and
the
size
of
receptor
populations.
Both
generic
and
site­
specific
exposure
characteristics
are
incorporated
into
the
Indicators
model.
The
Indicators
may
be
used
for
trends
analysis,
as
well
as
targeting
and
prioritization
of
TRI
releases
by
chemical,
release
medium,
industrial
sector,
individual
facilities,
geographic
area,
or
a
combination
of
these
and
other
variables.

OPPT's
Pollution
Prevention
Division
(
PPD)
has
used
TRI
data
as
a
screening
tool
to
prioritize
proposed
regulations
and
industrial
source
categories
to
promote
pollution
prevention
in
rulemaking.
As
a
result,
the
Pollution
Prevention
Senior
Policy
Council
identified
a
number
of
regulatory
development
efforts
that
should
consider
inclusion
of
pollution
prevention
measures.
October,
2003
8
Use
of
the
Data
by
the
Office
of
Air
and
Radiation
The
Office
of
Air
and
Radiation
(
OAR)
has
used
the
TRI
data
for
a
variety
of
tasks
related
to
the
implementation
of
the
Clean
Air
Act
(
CAA).
Section
112
of
the
CAA,
as
amended
in
1990,
requires
EPA
to
develop
Maximum
Achievable
Control
Technology
(
MACT)
standards
for
major
sources
of
189
hazardous
air
pollutants,
all
but
8
of
which
were
on
the
TRI
list
of
toxic
chemicals
prior
to
EPA's
expansion
of
the
EPCRA
section
313
list
of
toxic
chemicals.
TRI
was
used
to
estimate
the
number
of
major
sources
(
greater
than
10
tons
per
year
of
any
single
hazardous
air
pollutant
or
25
tons
per
year
of
total
toxics)
of
hazardous
air
pollutants
in
each
of
700
source
categories.
This
information
helped
to
prioritize
the
source
categories
for
regulatory
development.
In
addition,
the
impacts
of
a
potential
lower
major
source
definition
for
47
highly
toxic
compounds
were
analyzed
using
TRI
data.

TRI
was
used
to
help
identify
the
30
hazardous
air
pollutants
to
be
included
in
the
Urban
Area
Source
Program
mandated
by
Section
112(
k)
of
the
CAA.
OAR
also
has
used
TRI
to
expand
the
coverage
of
the
"
Locating
and
Estimating"
series
of
documents,
which
help
State
and
local
air
agencies
identify
potential
source
categories
of
air
toxics
in
their
communities.
Similar
data
have
been
incorporated
into
the
Crosswalk
database,
which
identifies
which
source
categories
emit
which
toxic
compounds.
OAR
is
developing
a
series
of
air
quality
indicators
to
track
progress
in
implementing
the
CAA.
Trends
in
the
TRI
data
are
envisioned
to
be
a
part
of
those
indicators.

Use
of
the
Data
in
Enforcement
Activities
Because
TRI
data
include
detailed
facility
identification
information,
as
well
as
releases
to
all
media
and
transfers
to
off­
site
locations,
the
Office
of
Enforcement
and
Compliance
Assurance
(
OECA)
has
found
that
TRI
is
particularly
well­
suited
to
multi­
media
enforcement
and
compliance
planning,
priority
setting
and
inspection
targeting.
The
OECA
and
the
Office
of
Research
and
Development
(
ORD)
are
developing
a
"
Multi­
Media
Ranking
System"
to
prioritize
sites
for
enforcement
actions
and
to
evaluate
the
effectiveness
of
environmental
laws
in
reducing
risks
from
sites.
The
system
ranks
sites
based
on
their
multi­
media
releases
of
pollutants,
their
potential
risk
to
human
health
and
the
environment,
and
the
history
of
legal
violations
by
the
facility.
The
system
combines
TRI
data
with
data
from
EPA
air
and
water
databases.

OECA
cross­
checks
data
collected
under
EPCRA
and
other
environmental
statutes
to
identify
those
facilities
or
types
of
businesses
which
reported
for
some
but
not
all
of
the
reporting
rules.
Enforcement
personnel
are
able
to
identify
additional
facilities
owned
by
the
same
corporation
or
by
the
same
parent
company
that
may
be
subject
to
liability,
by
using
TRI
data
and
the
Facility
and
Company
Tracking
System
(
FACTS).

In
addition,
OECA
uses
the
TRI
data
in
its
EPCRA
Targeting
System
(
ETS),
which
provides
local
access
to
TRI
and
FACTS
data
for
all
facilities
subject
to
EPCRA
section
313
requirements.
ETS
supports
creation
of
prioritized
inspection
targeting
lists,
generated
from
a
wide
array
of
October,
2003
9
selection
criteria,
and
daily
targeting
activities
such
as
contacts
with
facilities
and
tracking
tips
and
complaints.

OECA
also
uses
TRI
data
in
the
Integrated
Data
for
Enforcement
Analysis
(
IDEA)
System.
IDEA
provides
integrated
data
on
individual
facilities'
compliance
records
for
most
of
the
statutes
administered
by
EPA
through
access
to
approximately
ten
separate
databases,
including
the
Toxic
Release
Inventory
System
(
TRIS).
The
TRI
data
aid
OECA
in
developing
enforcement
initiatives
by
providing
a
point
of
departure
for
distinguishing
between
industrial
sectors
based
on
their
potential
for
exceeding
permits
as
indicated
by
the
amounts
of
chemicals
reported
as
managed
in
waste.

TRI
data
continue
to
be
extremely
helpful
in
identifying
pollution
prevention
projects.
Enforcement
staff
use
data
on
releases
and
transfers
to
identify
(
or
evaluate)
projects
that
will
significantly
reduce
emissions,
or
those
that
will
help
prevent
or
minimize
the
release
of
extremely
hazardous
substances
under
EPCRA
section
302.

OECA
places
a
high
priority
on
enhancing
the
use
of
TRI
data
among
Regional
field
personnel.
Guidance
has
been
provided
to
the
field
offices
on
the
resources
available
to
their
inspectors
in
identifying
non­
reporters,
late
reporters
and
data
quality
errors.
These
resources
provide
the
inspectors
with
valuable
information
extrapolated
from
the
TRI,
such
as
facility
reporting
rates,
processes,
and
releases.

Use
of
the
Data
by
the
Office
of
Solid
Waste
and
Emergency
Response
TRI
data
assist
in
priority
setting
for
waste
minimization
efforts
by
the
Office
of
Solid
Waste
and
Emergency
Response
(
OSWER).
In
combination
with
other
information
OSWER
collects
on
waste
minimization,
TRI
data
are
useful
in
analyzing
long­
term
trends
and
identifying
particular
industry
practices
that
warrant
attention
by
the
program,
serving
OSWER
pollution
prevention
goals.

With
respect
to
enforcement,
TRI
data
supplement
other
existing
data
sources
and
can
be
called
on
to
assist
in
the
development
of
OSWER
enforcement
priorities.
TRI
data
also
are
valuable
as
a
means
to
assist
in
establishing
liability
under
both
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
of
1980
(
CERCLA)
and
the
Resource
Conservation
and
Recovery
Act
of
1976
(
RCRA)
statutory
authorities.

Another
site­
specific
function
of
the
TRI
database
relates
to
its
role
in
providing
emission
information
that
can
be
used
when
developing
emission
inventories
for
the
Superfund
site
discovery
program
and
when
undertaking
Superfund
preliminary
assessments
of
sites.
In
the
reportable
quantity
(
RQ)
program,
TRI
data
could
be
used
in
analyses
to
support
future
rulemaking
under
CERCLA
(
e.
g.,
designation
of
additional
hazardous
substances).
In
addition,
states
use
TRI
data
in
conjunction
with
other
data
obtained
under
EPCRA
for
local
accident
October,
2003
10
prevention
planning.

Use
of
the
Data
by
the
Office
of
Water
The
Office
of
Water
(
OW)
is
using
the
TRI
information
to
support
the
planning
process
required
under
Section
304(
m)
of
the
Clean
Water
Act.
As
part
of
that
planning
process,
OW
is
using
the
TRI
data
as
one
way
of
evaluating
the
likelihood
of
risk
to
humans
(
i.
e.,
adverse
human
health
impacts)
resulting
from
exposure
to
pollutant
discharges
associated
with
a
source
category.

OW
has
used
TRI
data
for
identifying
candidates
for
the
National
Primary
Drinking
Water
Regulations.
Chemicals
were
identified
that
had
a
dramatic
overall
increase
(
doubling
or
more)
of
discharges
and
releases.
These
discharges
and
releases
were
considered
to
have
direct
potential
for
drinking
water
contamination
and
are
good
candidates
for
development
of
regulatory
controls.

TRI
data
were
used
as
a
screening
mechanism
for
possible
sources
of
wellhead
contamination.
Using
TRI
and
other
relevant
data
in
a
Geographic
Information
System
(
GIS),
potential
contamination
sources
have
been
identified.
These
sources
may
affect
community
ground­
water
systems
in
the
development
and
implementation
of
wellhead
protection
programs.
Regions
are
continuing
to
coordinate
ground­
water
programs
using
GIS
and
TRI
data
as
a
cross­
program
tool.

OW
has
also
used
the
TRI
data
in
the
development
of
management
plans
to
identify
the
sources
of
toxic
discharges
into
selected
estuaries
and
coastal
waters.
In
addition,
the
data
have
been
used
to
identify
sources
of
toxic
discharges
that
may
contaminate
sediments
that
are
proposed
for
ocean
dumping.

Under
the
Watershed
Protection
Approach,
the
Regions
are
using
TRI
data
along
with
other
data
in
assessing
loadings
to
their
watersheds.
They
are
identifying
multi­
media
sources
of
toxic
discharges
to
receiving
waters.

The
Office
of
Wastewater
Management
(
OWM)
used
TRI
data
to
identify
industrial
users
that
contributed
the
greatest
amount
of
toxic
pollutants
to
city
sewer
systems.
Facility
names
were
provided
to
the
Regions
for
further
evaluation.

OW
used
TRI
data
to
identify
which
pollutants
are
released
from
pesticide
manufacturing
facilities
and
the
pattern
of
releases
when
developing
effluent
limitations
guidelines
and
standards
for
an
industrial
category.
While
many
pollutants
and
industries
that
will
be
addressed
by
effluent
guidelines
are
currently
reported
in
TRI,
the
Effluent
Guidelines
Program
screens
for
a
number
of
pollutants
not
in
listed
in
the
TRI
database.

OW
used
TRI
data
and
other
water
emissions
data
in
its
National
Sediment
Contaminant
Source
Inventory,
an
evaluation
of
sources
of
sediment
contamination
in
the
U.
S.
This
project
identified
October,
2003
11
point
source
pollutant
discharges
that
may
result
in
sediment
contamination
and
analyzed
these
releases
based
on
their
potential
sediment
hazard.
Chemical
release
amounts
were
weighted
by
the
relative
toxicity
of
a
compound
to
aquatic
or
human
health,
as
well
as
relevant
fate
and
transport
factors.
The
study
identified
chemicals,
geographic
areas,
and
industrial
categories
of
greatest
concern
for
sediment
contamination.

Other
Government
Uses
Environmental
Solutions
Government
agencies
can
take
a
variety
of
actions
when
TRI
data
reveal
an
environmental
problem
in
a
specific
state
or
region.
Some
of
these
actions
involve
voluntary
incentive
programs
for
companies.
Although
these
programs
are
not
binding
commitments,
they
offer
good
publicity
for
participating
companies.
Examples
include:

Governor
Frank
O'Bannon
of
Indiana
announced
the
Indiana
Governor's
Toxics
Reduction
Challenge
in
1998.
The
challenge
pledged
to
"
support
the
state's
goal
to
reduce
toxic
chemical
releases
to
the
air
and
water
from
1995
levels:
50%
by
December
31,
2000,
in
large
urban
areas
for
carcinogens
and
persistent
bioaccumulative
toxic
chemicals;
60%
by
December
31,
2002
statewide
for
these
chemicals;
and,
50%
by
December
31,
2002,
statewide
for
all
toxic
chemicals
reported
in
the
Toxics
Release
Inventory."
The
Challenge
also
pledged
to
"
energetically
help
the
state
reach
these
goals
through
efforts
emphasizing
pollution
prevention
within
your
organization
and/
or
in
cooperation
with
other
organizations."
As
of
mid­
April
2000,
67
companies
in
Indiana
had
committed
to
the
Challenge.
A
list
of
the
companies
and
an
update
on
their
progress
is
available
on
the
Indiana
state
website:
(
http://
www.
in.
gov/
idem/).

The
P2
Program
of
the
Colorado
Department
of
Public
Health
and
the
Environment
used
TRI
data,
in
combination
with
other
data
about
hazardous
waste
and
toxic
chemical
releases
to
air
and
water,
to
identify
the
ten
industry
organizations
responsible
for
the
largest
quantities
of
hazardous
waste
generation
or
toxic
chemical
releases
in
the
state.
This
research
served
as
the
basis
for
establishing
priorities
for
P2
activities
and
for
distribution
of
technical
assistance
grants.
The
report
also
aided
in
targeting
large
companies
for
participation
in
the
"
Governor's
P2
Challenge
Program"
to
reduce
toxic
chemical
releases
and
hazardous
waste
generation.

Due
to
the
TRI
reporting
requirements
for
dioxin,
the
Delaware
Department
of
Natural
Resources
and
Environmental
Control
became
aware
of
dioxin­
tainted
waste
at
DuPont's
Edge
Moor,
DE
titanium
dioxide
(
TiO2)
plant.
Subsequently,
DuPont
agreed
to
pay
an
estimated
$
15
million
to
remediate
dioxin­
tainted
waste
at
this
facility.
DuPont
discovered
that
the
waste
sludge
was
contaminated
with
dioxin
while
the
company
was
preparing
to
comply
with
EPA's
requirement
that
dioxin
releases
be
reported
under
TRI.
In
addition,
DuPont
agreed
with
the
Delaware
Department
of
Natural
Resources
and
Environmental
Control
to
spray
a
23­
acre
stretch
along
the
Delaware
River
with
a
starch­
like
coating
to
keep
the
dioxin
from
being
stirred
up
by
the
wind
or
October,
2003
12
eroding
into
the
river.
DuPont
used
the
site
to
store
waste
sludge
from
the
Edge
Moor
plant.
The
company
will
also
close
four
sludge
lagoons
near
the
plant
and
plans
to
cut
dioxin
formation
in
half
by
2003
and
by
90
percent
by
2007.

Environmental
Targeting
Budgets
to
fund
environmental
programs
and
measures
often
do
not
increase
in
proportion
to
the
need
for
these
activities.
Environmental
targeting
initiatives,
such
as
those
listed
below,
help
governments
and
communities
prioritize
their
needs
and
ensure
that
their
resources
are
used
most
efficiently.

The
P2
Division
in
Georgia's
Department
of
Natural
Resources
used
TRI
data
to
identify
the
technical
assistance
needs
of
manufacturing
sectors
generating
chemicals
that
pose
the
greatest
risk
to
public
health
and
the
environment.
The
Division
prioritized
chemicals,
examined
manufacturing
sectors
releasing
the
highest
priority
chemicals,
and
identified
particular
subsectors
for
further
assessment.
The
Division
also
conducted
in­
depth
manufacturing
sector
assessments
to
determine
which
processes
produce
which
wastes,
what
multi­
media
waste
problems
exist,
what
P2
activities
were
being
undertaken,
and
what
additional
opportunities
might
exist.

The
Florida
Waste
Reduction
Assistance
Program
provides
assistance
in
source
reduction
and
waste
minimization
to
facilities
handling
TRI
chemicals.
The
Program
relies
on
TRI
and
other
data
to
target
facilities
for
the
Program.

EPA's
Office
of
Enforcement
and
Compliance
Assurance
(
OECA)
uses
TRI
data
within
its
Online
Tracking
Information
System
(
OTIS)
­­
a
collection
of
on­
line
search
engines
that
enables
EPA
staff,
state,
local,
and
tribal
governments,
and
federal
agencies
to
access
a
wide
range
of
data
relating
to
enforcement
and
compliance.
OTIS
is
a
web
application
that
sends
queries
to
the
Integrated
Data
for
Enforcement
Analysis
(
IDEA)
system.
Only
State
and
Federal
agencies
have
access
to
the
OTIS
data
system.
IDEA
copies
many
EPA
and
non­
EPA
databases
monthly,
and
organizes
the
information
to
facilitate
cross­
database
analysis.
OTIS
can
be
used
for
many
functions,
including
planning,
targeting,
analysis,
data
quality
review,
and
pre­
inspection
review.
OTIS
was
launched
for
internal
Agency
use
in
November
1999.
In
addition
to
performing
data
base
analysis,
OTIS
has
three
other
additional
benefits:
helps
the
Regions
and
States
to
identify
and
clean
up
data
errors;
provides
report
information
on
a
cross
media
basis,
leading
to
improved
integration
and
targeting;
provides
the
basis
for
proposed
public
access
site
for
enforcement
and
compliance
data.

OTIS
is
currently
restricted
to
registered
users
from
governmental
organizations.
As
of
March
2002,
all
states,
all
EPA
Regional
Offices,
and
another
90
local,
state
and
federal
governmental
organizations
were
registered.
Data
on
the
OTIS
site
are
from
OECA's
Integrated
Data
for
Enforcement
Analysis
(
IDEA)
system,
which
extracts
and
integrates
information
from
TRI
as
well
as
the
following
databases:
AFS
(
Clean
Air
Act
­­
AIRS
Facility
Subsystem),
PCS
(
Clean
Water
October,
2003
13
Act
­­
Permit
Compliance
System),
RCRAInfo
(
Resource
Conservation
and
Recovery
Act
Information
System),
the
Federal
Enforcement
Docket,
National
Compliance
Database
(
NCDB),
and
the
1990
U.
S.
Census.

For
the
purpose
of
targeting
exposure
screening
for
facility
employees
in
certain
geographic
areas,
the
U.
S.
Occupational
Safety
and
Health
Administration
(
OSHA)
and
local
public
health
departments
used
TRI
data
to
identify
facilities
that
release
specific
chemicals.
EPA
has
provided
OSHA
with
all
submitted
toxics
release
inventory
data
for
the
28
facilities
that
are
subject
to
the
OSHA
special
inspection
program.
These
data
provide
OSHA
inspection
teams
with
valuable
information,
such
as
a
list
of
chemicals
that
are
used
in
significant
quantities
by
each
facility.
EPA
is
also
provides
OSHA
with
information
concerning
accidental
releases.

Legislation
and
Regulations
TRI
data
often
provide
the
impetus
for
legislative
action
from
federal,
state,
and
local
governments.
For
over
a
decade,
TRI
data
has
been
used
to
influence
and
change
environmental
standards,
regulations,
and
legislation,
as
shown
below:

The
North
Carolina
Environmental
Management
Commission
set
limits
for
105
pollutants
after
a
public
interest
organization
published
a
report,
using
TRI
data,
on
unregulated
toxic
chemical
releases
to
air
in
the
state.

In
response
to
legislation
passed
in
1987
to
address
toxic
chemical
releases
to
the
air,
the
Illinois
EPA
Bureau
of
Air
used
TRI
data
to
determine
quantities
of
stack
and
fugitive
air
emissions
of
reported
substances
to
support
continued
development
of
regulatory
proposals.

Risk
Assessment
As
the
connection
between
toxic
chemicals
and
human
health
becomes
better
known,
public
health
officials
are
looking
for
ways
to
assess
the
levels
of
risk
in
their
communities.
TRI
data
have
been
a
crucial
component
in
creating
tools
to
address
these
assessments.
Examples
follow:

The
New
York
State
Department
of
Health
developed
a
risk
screening
protocol
using
TRI
air
release
data
and
toxicity
potency
data
to
produce
relative
risk
scores
and
rankings
for
facilities
and
chemicals
within
the
state.
Results
suggested
the
need
for
a
more
careful
evaluation
of
health
effects
resulting
from
large
releases
of
noncarcinogenic
compounds.

Researchers
from
EPA's
Office
of
Health
Research
published
a
study
of
national
and
regional
differences
in
county­
level
TRI
chemical
releases
to
air
according
to
the
ethnicity
or
race
and
in
conjunction
with
the
household
income
of
these
populations.
Using
the
"
Population
Emissions
Index,"
a
population­
weighted
average
release
for
each
county,
the
study
found
that
all
minority
groups
except
Native
Americans
tend
to
live
in
counties
where
levels
of
TRI
chemical
releases
to
October,
2003
14
air
are
higher.
The
data
also
suggest
that
household
incomes
tend
to
be
higher
in
counties
with
higher
TRI
chemical
releases
to
air.

The
EPA
Office
of
Pollution
Prevention
and
Toxics's
Risk­
Screening
Environmental
Indicators
Model
provides
year­
to­
year
indicators
of
the
potential
impacts
of
TRI
chemical
releases
on
human
health
and
the
environment.
The
indicators
consider
TRI
release
and
transfer
volumes,
chronic
toxicity,
exposure
potential,
and
the
size
of
receptor
populations.
Both
generic
and
sitespecific
exposure
characteristics
can
be
incorporated
in
the
model.
The
model
allows
the
targeting
and
prioritization
of
chemicals,
industries
and
geographic
areas.
Facility
scores
can
also
be
tracked
from
year
to
year
to
analyze
trends.

Quality
Assurance
and
Control
Some
states,
such
as
Massachusetts,
that
require
separate
reporting
of
toxic
chemical
releases
for
their
facilities,
find
TRI
data
to
be
a
useful
measure
of
quality
assurance
and
control.
The
Air
Pollution
Control
Program
in
the
Missouri
Department
of
Natural
Resources
also
compares
fugitive
and
stack
emissions
reported
to
the
TRI
with
toxic
chemical
release
data
reported
on
the
state's
Emissions
Inventory
Questionnaire
for
quality
control.

Other
Government
Uses
Additional
governmental
uses
of
TRI
data
can
be
found
in
agencies
not
immediately
associated
with
environmental
issues.
The
U.
S.
Internal
Revenue
Service
used
TRI
data
to
identify
companies
releasing
chlorofluorocarbons
(
CFCs)
to
enforce
a
tax
imposed
on
releases
of
CFCs
and
thus
facilitate
the
phase­
out
of
these
chemicals.

Public
Use
Each
year,
the
EPA
makes
TRI
data
available
to
the
public
on
two
Internet
sites:
TRI
Explorer
(
www.
epa.
gov/
triexplorer)
and
Envirofacts
(
www.
epa.
gov/
enviro).
The
EPA
also
provides
a
summary
of
national
and
state
data
in
the
annual
publications
Toxics
Release
Inventory:
Public
Data
Release
and
Toxics
Release
Inventory:
Public
Data
Release:
State
Fact
Sheets.
States
also
release
their
own
reports.
Community
organizations,
universities,
workers
and
labor
unions,
local
public
interest
organizations,
and
national
non­
governmental
organizations
(
NGOs)
also
conduct
analyses
and
risk
assessments
based
on
TRI
data.
Some
of
these
organizations
also
make
data
and
analyses
available
to
the
public.

Citizen
Activists
and
Community
Organizations
The
Oneida
Environmental
Resources
Board
in
Wisconsin
used
TRI
data
to
convince
leaders
of
the
Oneida
Tribe
to
organize
a
conference
on
cleaner
ways
to
manufacture
pulp
and
paper.
The
Board
used
TRI
data
to
show
that
the
pulp
and
paper
industry
was
the
largest
industrial
source
of
October,
2003
15
toxic
chemical
releases
in
Wisconsin,
despite
industry
claims
that
significant
release
reductions
in
the
past
made
further
improvements
unnecessary.
The
conference
improved
industry
awareness
of
more
environmentally
friendly
practices
and
procedures.
The
Board
also
used
TRI
data
to
alert
a
local
labor
union
about
possible
worker
health
risks.
The
union
included
requests
for
reductions
in
toxic
chemical
releases
in
its
contract
renewal
negotiations.

California's
Silicon
Valley
Toxics
Coalition
has
used
TRI
data
for
over
a
decade.
The
Silicon
Valley
Environmental
Index
(
www.
svep.
org)
shows
"
sustainability
trends"
in
Santa
Clara
County,
California.
The
Index
provides
information
about,
but
not
limited
to,
hazardous
materials
and
air
and
water
quality.
At
least
five
cities
in
Santa
Clara
County
have
referenced
or
relied
on
the
Index
as
the
basis
for
their
"
sustainable
city"
efforts
or
municipal
environmental
management
system
(
EMS)
initiatives.
Private­
sector
companies,
such
as
IBM
and
Philips
Semiconductor,
have
also
used
the
Index
in
evaluating
their
own
EMS
practices.
Several
universities
have
incorporated
the
Index
into
their
environmental
science
course
curricula.
In
addition,
several
states
(
Wisconsin,
South
Carolina,
New
Jersey)
and
countries
(
Germany
and
the
Netherlands)
have
developed
regional
environmental
indicators
studies
modeled
after
the
Index.

Wilma
Subra,
a
chemical
research
analyst
in
Louisiana,
has
been
a
vocal
citizen
leader
and
an
active
proponent
of
the
TRI
program
for
20
years,
working
to
change
regulations
and
policies
to
improve
public
health
and
the
environment
at
the
local
level.
Ms.
Subra
has
informed
residents
about
the
possible
effects
of
toxic
chemical
releases
and
has
aided
their
work
to
improve
environmental
conditions.
The
TRI
data
support
Ms.
Subra's
efforts
to
reduce
toxic
chemical
releases
from
Louisiana's
industrial
facilities.
Ms.
Subra
gathers
and
analyzes
TRI
data,
distributes
information
to
the
public,
participates
in
legal
and
regulatory
processes
against
industrial
facilities,
and
sits
on
national
and
international
advisory
committees.

National
Organizations
National
organizations
employ
TRI
data
in
many
of
the
same
ways
as
small
community
organizations,
but
on
a
larger
scale.
Such
organizations
analyze
TRI
data,
use
it
to
conduct
risk
screening
and
risk
assessment,
and
often
help
the
public
interpret
the
data.
National
organizations
often
work
with
local
public
interest
and
community
organizations
to
initiate
discussions
between
citizens
and
industry.
Some
national
organizations
also
use
TRI
data
to
help
lobby
for
changes
in
environmental
policy.
Examples
of
the
use
of
TRI
data
by
national
organizations
include
the
following:
October,
2003
16
Environmental
Defense
(
ED)
launched
its
Scorecard
website
in1998
(
http://
www.
scorecard.
org).
The
site's
"
polluter
locator"
allows
users
to
perform
a
search
by
ZIP
code
on
a
database
containing
information
on
more
than
17,000
chemical­
releasing
facilities.
The
Scorecard
also
provides
data
on
the
health
effects
and
regulatory
status
of
different
chemicals.
The
site
correlates
TRI
chemical
release
data
with
U.
S.
Census
demographic
data.
ED
is
currently
linking
TRI
data
with
toxicological
studies
to
create
a
Scorecard
tool
that
compares
the
risks
of
different
toxic
chemical
releases.
Logging
500,000
data
requests
on
its
first
day
of
operation,
the
Scorecard
website
has
drawn
significant
public
interest.

The
Right­
to­
Know
Network
(
RTKNet)
website
(
http://
www.
rtknet.
org),
launched
in
1989
by
the
nonprofit
organizations
OMB
Watch
and
the
Unison
Institute,
also
facilitates
public
access
to
TRI
data.
Users
can
search
the
TRI
data
by
ZIP
code,
city,
county,
state,
year,
or
chemical.
The
website
also
includes
links
to
additional
information
about
chemicals
and
right­
to­
know
issues.
RTKNet
estimates
that
about
a
quarter
of
a
million
searches
are
performed
on
the
site
annually.

The
former
Environmental
Information
Center
conducted
a
study
of
the
Great
Lakes
in
1997.
Scientists
used
TRI
data
to
examine
endocrine
disrupters
released
in
states
bordering
the
Great
Lakes.
The
study
ranked
the
largest
emitters
of
various
classes
of
toxic
chemicals
by
region,
and
found
the
Great
Lakes
region
to
be
the
nation's
top
emitter
of
reportable
endocrine
disrupting
chemicals.

In
September
2000,
Physicians
for
Social
Responsibility,
along
with
the
National
Environmental
Trust
and
the
Learning
Disabilities
Association
of
America,
released
the
report,
"
Polluting
Our
Future:
Chemical
Pollution
in
the
U.
S.
that
Affects
Child
Development
and
Learning"
(
www.
psr.
org/
trireport.
pdf).
This
report
used
TRI
and
other
data
to
present
national
information
about
releases
of
chemicals
that
present
potential
developmental
and
neurological
risks.
The
report
ranked
states
by
the
amount
of
releases
of
these
chemicals
and
included
information
about
counties,
industries,
and
facilities
with
the
highest
toxic
chemical
releases.

Labor
unions
also
have
used
TRI
data
to
support
demands
for
safer
working
conditions
for
employees.
Other
than
citizens
who
live
near
facilities,
employees
of
TRI
reporting
facilities
are
most
at
risk
from
toxic
chemical
releases
because
they
are
most
likely
to
come
in
regular
contact
with
these
chemicals.
Beginning
in
1990,
the
International
Union,
United
Automobile,
Aerospace
&
Agricultural
Implement
Workers
of
America
(
UAW)
began
training
employees
and
managers
of
UAW
companies
to
access,
interpret,
and
utilize
computer
databases
and
programs
in
"
critically
assessing
industrial
emergency
response
activities
at
their
facilities."
Workers
were
trained
to
download
and
interpret
environmental
compliance
data.
TRI
data
was
one
of
the
main
sources
of
information
for
the
program.
Concerning
TRI,
the
UAW
stated,
"
knowing
about
maximum
amounts
on­
site
can
help
people
prepare
for
a
`
worst­
case
scenario'.
"
It
can
help
an
emergency
response
planning
group
decide
if
there
is
enough
response
equipment
and
personnel
to
deal
with
an
emergency
involving
the
chemical(
s)
in
question."
October,
2003
17
Direct
Negotiation
Through
increasing
their
understanding
of
TRI
data,
members
of
the
public
can
begin
to
understand
potential
risks
associated
with
toxic
chemical
releases
in
their
communities
and
can
work
with
facilities
to
reduce
those
risks.
The
nation's
first
"
right­
to­
act"
law
was
enacted
in
September
1999
by
the
Passaic,
N.
J.,
Board
of
Chosen
Freeholders,
the
county's
governing
body.
The
law
"
allows
neighbors
and/
or
employees
to
petition
the
county
health
officer
for
creation
of
Neighborhood
Hazard
Prevention
Advisory
Committees
(
NHPACs)
for
specific
facilities."
Even
without
the
aid
of
this
law,
concerned
citizens
nationwide
can
take
action
in
their
own
communities.
Community
organizations
and
citizen
activists
have
used
TRI
data
to
negotiate
with
local
facilities.
Examples
of
direct
negotiation
agreements
between
citizens
and
facilities
follow:

In
the
city
of
Richmond,
California,
community
members
were
concerned
about
toxic
chemical
releases
from
several
oil
refineries
and
other
large
industrial
facilities.
The
West
County
Toxics
Coalition,
a
local
environmental
organization,
joined
with
Communities
for
a
Better
Environment,
a
statewide
environmental
organization,
to
investigate
industrial
polluters
in
Richmond.
Using
the
TRI
and
other
databases,
they
published
the
report,
Richmond
at
Risk,
that
identified
the
area's
20
largest
industrial
polluters
and
named
the
Chevron
oil
refinery
the
number
one
polluter.
The
report
served
to
initiate
discussions
among
Chevron,
the
West
County
Toxics
Coalition,
and
other
community
and
environmental
organizations.
As
a
result
of
the
meetings,
the
company
agreed
in
1994
to
close
down
older
portions
of
the
plant
and
install
P2
equipment
to
achieve
zero
net
toxic
chemical
releases
on
its
reformulated
fuel
project.

The
Calhoun
County
Resource
Watch
(
CCRW),
founded
by
a
Texas
environmental
activist
and
shrimper
named
Dianne
Wilson,
used
TRI
data
to
build
community
awareness
about
pollution
of
the
rich
shrimp
and
oyster
breeding
grounds
of
Lavaca
Bay
on
the
Gulf
of
Mexico.
Calhoun
County
was
ranked
first
in
the
nation
for
toxic
chemical
disposal
to
the
land,
based
on
the
1987
TRI
data.
Lavaca
Bay
was
designated
as
a
Superfund
site
in
1993.
CCRW
brought
suit
against
the
Aluminum
Company
of
America
(
Alcoa)
related
to
this
pollution.
In
1995,
Alcoa
signed
an
agreement
designed
to
protect
the
breeding
grounds.
Two
Alcoa
firms,
a
chemical
plant
and
a
bauxite
refinery,
committed
to
"
fund
independent
review
of
zero
discharge
options
and
to
adopt
the
technologies
where
technically,
economically,
and
environmentally
sound."
In
return,
CCRW
agreed
to
drop
its
legal
challenges
and
suspend
permit
interventions
against
the
companies.
According
to
an
Alcoa
operations
manager,
as
of
March
2000
the
company
had
made
considerable
progress
toward
the
goals
set
in
1995,
including
compliance
with
a
permit
that
sets
the
"
allowed
total
annual
maximum
mass
loading
mercury
limit"
at
30
pounds,
development
and
implementation
of
a
Best
Management
Practices
plan,
and
installation
of
an
"
evaporative
spray
and
dust
control
system"
near
the
refinery.

In
1998,
Butler
County,
PA,
warned
pregnant
women
and
infants
against
drinking
water
from
Connoquenessing
Creek
due
to
high
levels
of
nitrates
in
the
water.
In
its
report,
the
Pennsylvania
Public
Interest
Research
Group
(
PennPIRG)
used
TRI
data
to
highlight
the
significant
quantities
October,
2003
18
of
nitrate
compounds
being
released
into
the
creek.
The
report
identified
the
major
source
of
the
nitrates
as
the
AK
Steel
Corporation.
TRI
data
showed
that
the
company
had
discharged
approximately
29
million
pounds
of
nitrates
into
the
creek
in
1997
and
32
million
pounds
in
1998.
This
report
and
several
newspaper
articles
about
these
toxic
chemical
releases
prompted
the
state
to
commit
to
reduce
the
levels
of
nitrates
that
AK
Steel
is
permitted
to
release
into
the
creek.
Pennsylvania
began
developing
a
new
water
permit
to
reduce
allowable
nitrate
releases
to
a
level
90
percent
lower
than
the
previous
level.
In
June
2000,
EPA
issued
an
emergency
order
requiring
AK
Steel
to
significantly
reduce
the
nitrate
compounds
it
discharges
into
Connoquenessing
Creek.
In
addition,
AK
Steel
was
required
to
provide
and
pay
for
an
alternative
water
source
for
the
affected
public
on
any
day
that
the
local
water
plant
could
not
meet
the
federal
maximum
nitrate
contaminant
standard.

Working
with
The
Ecology
Center,
a
public
interest
organization
based
in
Ann
Arbor,
Michigan,
residents
of
the
town
of
Flat
Rock
used
TRI
data
to
obtain
a
commitment
from
Auto
Alliance
International
to
enact
an
aggressive
solvent
reduction
program.
TRI
data
showed
that
the
company's
air
releases
of
toluene
had
increased
from
100,000
pounds
in
1991
to
800,000
pounds
in
1993,
along
with
an
increase
in
noxious
odors
in
the
community.
A
former
Ecology
Center
staff
member,
Andrew
Cormai,
said,
"[
R]
esidents
who
have
put
up
with
the
smells
since
1987
suddenly
have
a
bone
to
pick
with
the
company.
The
company
is
going
to
be
saving
some
money
by
recapturing
solvents,
and
they
will
be
improving
community
air
quality."

Environmental
Justice
The
goal
of
environmental
justice
is
to
ensure
that
all
people,
regardless
of
race,
national
origin,
or
income,
are
protected
from
disproportionate
impacts
and
environmental
hazards.
"
The
concept
[
of
environmental
justice]
addresses
evidence
[
that]
in
some
parts
of
the
nation,
poor
and
minority
communities
live
closer
to
factories,
highways
and
airports
and
are
exposed
to
more
pollution
and
noise
and
generally
more
environmental
risks
than
the
population
at
large."
TRI
data
have
proved
to
be
an
important
tool
in
environmental
justice.
Communities
that
were
once
uninformed
about
the
toxic
chemical
releases
in
their
area
now
have
access
to
that
information.
Examples
of
TRI
data
use
in
environmental
justice
activities
include:

Two
areas
of
Louisiana
have
become
focal
points
for
environmental
justice
efforts:
the
Mississippi
River
corridor,
popularly
known
as
"
Cancer
Alley,"
and
the
Lake
Charles
region.
Local
groups
have
used
TRI
data
to
illustrate
the
high
toxic
chemical
release
rates
in
these
areas
compared
to
those
in
other
regions.
Several
small
communities
have
confronted
industrial
facilities
about
their
toxic
chemical
releases
and
possibly
related
health
effects.
One
illustrative
dispute
arose
in
Mossville,
Calcasieu
Parish,
Louisiana,
where
some
residents
suspected
that
poor
health
in
their
community
was
due
to
the
activities
of
17
industrial
facilities
located
within
one
half­
mile
of
the
community.
Their
concerns
prompted
numerous
public
interest
organizations
to
collaborate
on
the
report,
Breathing
Poison:
The
Toxic
Costs
of
Industries
in
Calcasieu
Parish,
Louisiana.
The
2000
report
used
TRI
data
and
information
from
the
Scorecard
website
to
convey
the
health
risks
October,
2003
19
to
which
the
community
might
be
exposed.
It
stated
the
need
for
"
pollution
reduction,
environmental
health
services,
and
a
fair
and
just
relocation
for
consenting
residents."

The
Asian
Pacific
Environmental
Network
(
APEN)
works
with
Asian
and
Pacific
Islander
communities
in
the
San
Francisco
Bay
Area,
California.
APEN
created
a
series
of
maps
that
combined
TRI
and
demographic
data,
to
show
that
many
poor
Asian
and
Pacific
Islanders
live
in
"
toxic
hot
spots."
The
maps
increased
awareness
among
community
members
about
both
their
environment
and
environmental
justice
issues.
APEN
might
add
more
environmental,
health,
and
demographic
information,
and
expand
its
mapping
work
to
other
nearby
counties.

The
Los
Angeles
chapter
of
Communities
for
a
Better
Environment
used
TRI
data
to
help
ensure
that
the
communities
it
serves
would
not
be
exposed
to
higher
environmental
risks
as
a
result
of
poverty
or
ethnicity.
In
one
project,
the
organization
combined
1996
TRI
data
with
Geographical
Information
System
(
GIS)
mapping
data
to
show
that
80
to
100
percent
of
facilities
that
release
toxic
chemicals
in
Los
Angeles
County
were
located
in
areas
where
a
large
majority
of
the
residents
were
people
of
minorities.
These
findings
led
to
the
report,
Holding
Our
Breath
 
the
Struggle
for
Environmental
Justice
in
Southeast
Los
Angeles.

Industry
Use
TRI
data
have
also
specifically
benefitted
regulated
industrial
facilities.

Cost
Reduction
A
primary
goal
of
the
International
Organization
for
Standardization
(
ISO
14000)
is
to
bring
environmental
issues
to
the
attention
of
the
highest
levels
of
corporate
management.
Leaving
decision­
making
to
environmental
managers
alone
might
not
produce
the
corporate
commitment
necessary
to
achieve
the
best
success.
TRI
data
have
been
used
as
evidence
to
convince
highlevel
management
of
the
need
for
an
EMS.
In
turn,
the
proactive
environmental
protection
afforded
by
an
EMS
can
reduce
corporate
costs.

For
some
industries,
the
creation
of
the
TRI
marked
the
first
time
that
company
managers
and
operators
could
be
made
aware
of
the
quantity
of
chemicals
being
released
from
their
facilities.
Initially,
some
companies
expressed
surprise
at
their
own
toxic
chemical
release
ratings
and
set
goals
to
improve
their
environmental
performance.
Some
companies
have
reduced
their
toxic
chemical
releases
and
increased
their
efficiency
at
the
same
time,
leading
to
an
increased
profit.
Examples
of
ways
that
industry
has
used
TRI
data
to
reduce
costs
follow:

After
reporting
toxic
chemical
releases
to
the
TRI,
Berg
Electronics
realized
that
it
was
releasing
almost
300,000
pounds
of
toxic
chemicals
into
the
environment
annually.
By
installing
a
new
cleaning
system,
the
company
reduced
its
toxic
chemical
releases
to
less
than
400
pounds
per
year.
Although
the
initial
costs
for
the
new
system
were
relatively
high
($
500,000),
the
company
October,
2003
20
was
able
to
save
approximately
$
1.2
million
a
year
by
avoiding
cleanup
and
hazardous
waste
disposal
costs.

The
Haartz
Corporation,
located
in
Acton,
Massachusetts,
makes
coated
fabrics
used
in
automobiles.
The
firm
once
used
800,000
pounds
per
year
of
methyl
ethyl
ketone
(
MEK),
a
solvent
that
can
cause
dizziness,
nausea,
or
unconsciousness
when
inhaled.
In
1987,
when
the
Haartz
Corporation
was
preparing
its
first
TRI
report,
the
company
installed
a
new
emissions
control
system
to
capture
and
recycle
MEK.
TRI
data
enabled
the
company
to
track
the
association
between
reduced
toxic
chemical
releases
and
reduced
costs.
According
to
the
Haartz
Corporation
environmental
manager,
the
company's
"
emissions
have
stayed
pretty
flat"
despite
its
"
double­
digit
sales
growth"
between
1993
and
1998.
In
addition,
reducing
its
MEK
releases
saved
the
Haartz
Corporation
an
estimated
$
200,000
annually.

International
Right­
to­
Know
The
TRI
has
served
as
the
model
for
many
countries'
Chemical
Right­
To­
Know
programs
and
laws.
Within
the
next
few
years,
more
than
30
nations
are
expected
to
have
a
TRI­
like
system,
known
internationally
as
Pollutant
Release
and
Transfer
Registers
(
PRTRs).
PRTRs
allow
the
public
to
obtain
toxic
chemical
release
data
covering
a
large
geographic
area.
Countries
can
compare
their
data
and
share
ideas
about
improving
environmental
regulations.
Examples
of
how
PRTR
information
is
being
used
include:

The
Commission
for
Environmental
Cooperation
(
CEC),
which
was
created
by
a
side­
agreement
to
the
North
American
Free
Trade
Agreement
(
NAFTA),
began
its
PRTR
work
by
preparing
a
document
that
compares
U.
S.
and
Canadian
PRTR
systems.
The
CEC
now
develops
an
annual
report,
entitled
"
Taking
Stock",
that
correlates
data
from
the
TRI
and
the
Canadian
National
Pollutant
Release
Inventory
to
give
an
overall
view
of
releases
and
transfers
of
toxic
chemicals
within
and
between
countries.
The
CEC
also
has
created
an
Internet
search
engine
that
allows
the
public
to
obtain
continental
PRTR
data.

In
2000,
the
Silicon
Valley
Toxics
Coalition
attended
an
international
conference
in
Croatia
on
public
participation
and
community
right­
to­
know.
Participants
recognized
the
fundamental
importance
of
Chemical
Right­
To­
Know
and
are
lobbying
the
United
Nations
to
promote
the
program
and
persuade
nations
to
support
the
passage
of
community
right­
to­
know
laws
modeled
after
the
TRI.

Investment
The
public's
increased
awareness
of
environmental
issues
has
made
environmental
performance
an
important
factor
in
their
investment
decisions.
Many
investment
companies
have
responded
to
October,
2003
21
this
demand
by
providing
socially
responsible
investment
options.
Examples
of
how
TRI
data
have
been
used
in
investment
decisions
include:

Green
Century
Funds,
an
investment
organization
that
specializes
in
socially
responsible
mutual
funds,
offers
two
funds
committed
to
promoting
corporate
environmental
responsibility.
The
Green
Century
Balanced
Fund
invests
in
"
performance­
driven
companies
that
are
a
part
of
the
solution
to
environmental
problems,"
as
well
as
in
environmentally
benign
companies
and
"
best
of
class"
companies
that
are
setting
standards
for
environmental
protection
in
their
industries.
The
Green
Century
Equity
Fund
screens
out
companies
with
the
worst
environmental
and
social
records.
The
funds
are
monitored
for
environmental
performance
using
TRI
data.

Vanderbilt
University's
Owen
Graduate
School
of
Management
found
a
correlation
between
a
company's
stock
value
and
its
P2
efforts,
which
were
assessed
using
TRI
data.
A
researcher
from
the
University
performed
two
separate
studies
comparing
the
progress
of
a
company's
P2
activities
as
reported
on
TRI
forms
to
a
company's
stock
market
performance.
The
study
reported
that
"
companies
that
underperform
expected
pollution
prevention
goals
are
penalized
in
the
stock
market,
and
the
stock
of
the
companies
that
engage
in
pollution
prevention
activity
tends
to
outperform
the
stock
of
companies
that
do
not
engage
in
pollution
prevention."

Using
TRI
data,
the
Investor
Responsibility
Research
Center
(
IRRC)
developed
an
Emissions
Efficiency
Index
®
that
indicates
which
companies
have
a
competitive
edge
in
environmental
performance.
The
Index
is
predicated
on
the
idea
that
greater
toxic
chemical
releases
are
associated
with
higher
risks
of
negative
publicity,
more
tort
actions,
and
higher
costs
for
pollution
control
and
waste
management.
IRRC's
constituency
uses
TRI­
based
information
to
identify
companies
with
poor
environmental
records.
Using
the
index,
investors
can
either
screen
such
companies
out
of
their
portfolios
or
purchase
shares
and
use
their
ownership
as
leverage
to
improve
environmental
performance.

Academic
Use
A
variety
of
TRI
data
applications
occur
in
academia,
in
areas
ranging
from
doctoral
theses
and
journal
publications
to
teaching
in
the
classroom.

Research
Universities
and
research
institutions
are
using
TRI
data
as
a
means
for
"
examining
environmental
policies
and
strategies,
and
clarifying
risks
associated
with
toxic
chemicals
at
the
state
and
local
level."
Students
and
faculty
in
the
academic
community
also
perform
studies
based
on
TRI
data.
Examples
of
academic
research
using
TRI
data
include:
October,
2003
22
In
February
2000,
the
journal
Drug
and
Chemical
Toxicology
published
an
article
entitled,
"
Using
GIS
to
Study
the
Health
Impact
of
Air
Emissions."
This
article
showed
how
public
health
professionals
are
able
to
use
data
(
such
as
the
TRI)
on
toxic
chemical
releases
to
air,
air
dispersion
modeling,
and
GIS
to
identify
and
define
a
potentially
exposed
population.
In
addition,
such
data
can
be
analyzed
to
estimate
the
health
risk
burden
of
that
population
and
determine
correlations
between
point­
based
health
outcome
results
and
estimated
health
risk.

In
the
Journal
of
Environmental
Economics
and
Management
in
1998
and
1999,
and
in
the
Journal
of
Economic
Surveys
in
2001,
researcher
Madhu
Khanna
published
results
of
research
that
examined
the
environmental,
economic
and
investment
effects
of
voluntary
and
mandatory
toxic
release
reporting
programs.
One
of
the
research
studies
focused
on
the
EPA's
33/
50
Program
during
its
first
three
years,
1991­
1993,
and
its
impact
on
the
U.
S.
chemical
industry.
The
paper
showed
that
Program
participation
led
to
a
statistically
significant
decline
in
toxic
releases
over
the
time
period,
a
statistically
significant
negative
impact
on
current
return
on
investment,
but
a
positive
and
statistically
significant
impact
on
the
expected
long­
run
profitability
of
firms.

At
Louisiana
State
University,
environmental
science
professor
Paul
Templet
developed
a
method,
using
TRI
data,
to
evaluate
the
comparative
effectiveness
of
pollution
control
strategies,
policies,
and
programs,
by
calculating
an
"
emissions
to
jobs
ratio."
This
ratio,
which
is
the
number
of
pounds
of
toxic
chemical
releases
per
job
in
a
given
industry
and
location,
can
be
compared
to
a
national
or
other
average.
The
comparison
is
then
used
to
assess
the
relative
toxic
air
releases
associated
with
a
certain
job.
This
ratio
was
used
to
modify
tax
exemptions
granted
to
facilities
to
encourage
and
reward
job
creation.

Professor
Mark
Stephan
used
TRI
as
the
background
for
an
academic
paper
focusing
on
the
role
of
information
disclosure
programs
in
environmental
policy.
Professor
Stephan
used
TRI
as
a
prime
example
for
the
fundamental
theories
and
concepts
that
underlie
the
empirical
work
on
the
comparison
of
basic
theories
arising
from
the
knowledge
of
economics,
psychology,
and
politics.

Researchers
R.
D.
Klassen
and
D.
C.
Whybark
studied
management
of
the
natural
environment
in
manufacturing
firms,
given
increased
public
awareness
and
scrutiny
as
a
result
of
programs
like
the
TRI.
In
one
of
their
published
studies,
it
was
found
that
an
emphasis
on
pollution
prevention
instead
of
pollution
control,
improved
delivery
performance
and
firms'competitiveness.

Classroom
Use
High
school
and
university
instructors
have
incorporated
the
TRI
into
curricula
involving
subjects
ranging
from
introductory
chemistry
to
business.

The
JSI
Center
for
Environmental
Health
Studies
developed
a
field­
based
environmental
education
curriculum
for
high
school
students
in
Chelsea,
Massachusetts,
a
low­
income
minority
October,
2003
23
community
near
Boston.
The
goal
was
to
encourage
student
participation
in
environmental
assessment
and
protection.
Students
learned
to
inventory
sources
of
contamination
in
a
local
creek
and
to
work
with
community
agencies
on
protecting
a
valuable
environmental
resource.
TRI
data
were
an
integral
part
of
the
students'
research.

Professor
Robert
Hognor
of
Florida
International
University
incorporated
TRI
data
into
his
classes
in
the
Department
of
Business
and
Society.
In
one
example,
students
used
TRI
data
as
the
basis
for
assessing
the
potential
impact
of
toxic
chemicals
in
the
Caribbean
and
then
issued
a
report
on
the
subject.

3
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
3(
a)
Respondents/
SIC
Codes
The
statute
applied
the
reporting
requirement
to
owners
and
operators
of
facilities
that
have
10
or
more
full­
time
employees,
manufacture
or
process
more
than
25,000
pounds
or
otherwise
use
more
than
10,000
pounds
of
a
listed
chemical,
and
are
in
Standard
Industrial
Classification
(
SIC)
codes
20
through
39.
The
SIC
code
determination
applies
to
all
operations
within
each
two­
digit
category,
including
all
sub­
categorizations
to
the
four­
digit
level.
In
addition,
in
May,
1997,
EPA
issued
a
final
rule
that
expanded
the
TRI
reporting
requirements
to
facilities
in
seven
industries
outside
of
the
manufacturing
sector.
A
detailed
listing
of
the
four­
digit
SIC
codes
and
categories
can
be
found
in
Table
I
of
Attachment
A
(
Toxic
Chemical
Release
Inventory
Reporting
Forms
and
Instructions).
The
following
identifies
the
SIC
codes
and
corresponding
categories
at
the
two
and
four­
digit
level:

SIC
Code
Industry
Group
10
Metal
Mining
(
except
1011,1081
and
1094)
12
Coal
Mining
(
except
1241)
20
Food
21
Tobacco
22
Textiles
23
Apparel
24
Lumber
and
Wood
25
Furniture
26
Paper
27
Printing/
Publishing
28
Chemicals
29
Petroleum
30
Rubber
and
Plastics
31
Leather
32
Stone,
Clay,
and
Glass
33
Primary
Metals
October,
2003
24
34
Fabricated
Metals
35
Machinery
(
ex.
electrical)
36
Electrical/
Electronic
Equipment
37
Transportation
Equipment
38
Instruments
39
Miscellaneous
Manufacturing
4911,
4931
or
4939
Electric
Utilities
(
limited
to
facilities
that
combust
coal
and/
or
oil
for
the
purpose
of
generating
electricity
for
distribution
in
commerce.)
4953
Commercial
Hazardous
Waste
Treatment
(
limited
to
facilities
regulated
under
RCRA
Subtitle
C,
42
U.
S.
C.
section
6921
et
seq.
5169
Chemical
Allied
Products­
Wholesale
5171
Petroleum
Bulk
Terminals
and
Plants­
Wholesale
7389
Solvent
Recovery
Services
(
limited
to
facilities
primarily
engaged
in
solvents
recovery
services
on
a
contract
or
fee
basis).

Establishments
that
are
part
of
a
multi­
establishment
facility
have
the
option
to
report
separately,
provided
that
all
of
the
releases
and
waste
management
data
from
all
of
the
establishments
in
that
facility
are
reported.

3(
b)
Information
Requested
(
i)
Data
Items
Reporting
Requirements
for
Form
R.
Form
R
consists
of
two
major
parts.
Part
I
is
for
facility
identification
information
such
as
the
name,
address,
and
other
identifying
information
including
permit
numbers.
Part
II
is
for
chemical­
specific
information,
such
as
the
identity,
uses
at
the
facility,
quantification
of
the
releases
and
other
waste
management
activities.

Changes
to
the
Form
R:
EPA
is
proposing
changes
to
Part
II
the
Form
R
based
on
feedback
received
from
stakeholders
through
various
venues
(
e.
g.,
Stakeholder
Phase
I
process,
ICR
renewal
process
in
2002,
letters,
meetings,
etc.).
Specifically,
stakeholders
have
requested
that
EPA
provide
more
clarity
in
the
organization
of
data
that
are
collected.
The
following
is
an
outline
of
the
changes
that
are
being
proposed.
A
copy
of
the
revised
Form
R
(
EPA
Form
9350­
1,
Rev.
01/
2001)
is
being
submitted
to
OMB
for
review
and
is
included
with
the
Form
R
ICR
Supporting
Statement
as
Attachment
G.
October,
2003
25
Part
I
&
II:

The
TRIFID
and
chemical
ID
will
appear
on
every
page
of
the
reporting
form.

Section
5:
Quantity
of
the
Toxic
Chemical
Entering
Each
Environmental
Media
Onsite:

The
existing
data
element,
5.5.3
Surface
Impoundment,
will
be
broken
out
into
5.5.3.
A.
RCRA
Subtitle
C
Surface
Impoundments
and
5.5.3.
B.
Other
Surface
Impoundments.

Section
6:
Transfers
of
the
Toxic
Chemical
in
Wastes
to
Off­
site
Locations:

Information
for
surface
impoundments
for
RCRA
Subtitle
C
and
other
surface
impoundments
(
as
requested
for
Section
5)
will
be
broken
down
by
deleting
the
existing
code
M63­
Surface
Impoundment,
and
replacing
it
with
codes
M66­
RCRA
Subtitle
C
Surface
Impoundment
and
M67­
Other
Surface
Impoundments.

Because
of
changes
to
Section
8.1
described
below,
the
existing
code
M71­
Underground
Injection
will
be
deleted
and
replaced
with
codes
M81­
Underground
Injection
to
Class
I
Wells
and
M82­
Underground
Injection
to
Class
II­
V
Wells.

Section
7B:
On­
site
Energy
Recovery
Processes:

The
code
U09
­
Other
Energy
Recovery
Methods
will
not
be
used.
This
element
is
no
longer
applicable
since
the
only
energy
recovery
methods
are
combustion
in
a
boiler
or
industrial
furnace.
Combustion
units
other
than
boilers
and
industrial
furnaces
are
used
for
treatment
of
the
toxic
chemical
(
except
for
metal
and
metal
compounds).

Section
8:
Source
Reduction
and
Recycling
Activities:

The
information
collected
on
releases
in
section
8.1
of
Part
II
is
broken
out
into
four
subcategories:
section
8.1.
a..
Total
on­
site
disposal
to
Underground
Injection
to
Class
I
Wells,
RCRA
Subtitle
C
landfills,
and
other
landfills;
section
8.1.
b.
Total
other
on­
site
disposal
or
other
releases;
section
8.1.
c.
Total
off­
site
disposal
to
Underground
Injection
to
Class
I
Wells,
RCRA
Subtitle
C
landfills,
and
other
landfills;
and
section
8.1.
d.
Total
other
off­
site
disposal
or
other
releases.
This
provides
a
more
complete
characterization
of
TRI
chemicals
in
waste
streams
by
distinguishing
between
releases
to
ambient
media
and
releases
to
managed
facilities
consistent
with
environmental
reporting
requirements
under
other
laws.
Therefore,
all
release
quantities
other
than
quantities
sent
to
on­
site
or
off­
site
landfills
and
Class
I
Underground
Injection
Control
wells
would
be
included
in
the
subcategories
8.1.
b
and
8.1.
d.
EPA
believes
that
this
description
more
accurately
reflects
the
intent
of
EPA's
original
proposed
breakdown
without
introducing
the
confusion
of
created
by
using
the
terms
"
contained"
and
"
uncontained."
October,
2003
26
Reporting
Requirements
for
the
Form
A
Certification
Statement.
On
November
30,
1994
(
59
FR
61488),
EPA
promulgated
the
alternative
threshold
rule
which
allows
a
facility
which
manufactures,
processes,
or
otherwise
uses
1
million
pounds
or
less
of
a
chemical
annually,
and
if
500
pounds
or
less
of
that
chemical
is
present
in
their
total
annual
reportable
amount,
then
the
alternate
threshold
reporting
option,
TRI
reporting
Form
A
Certification
Statement,
is
available
to
that
facility
for
a
specific
chemical.
An
annual
reportable
amount
is
defined
as
the
combined
total
quantities
released
at
the
facility,
treated
at
the
facility
(
as
represented
by
amounts
destroyed
or
converted
by
treatment
processes),
recovered
at
the
facility
as
a
result
of
recycle
operations,
combusted
for
the
purpose
of
energy
recovery
at
the
facility,
and
amounts
transferred
from
the
facility
to
off­
site
locations
for
the
purpose
of
recycling,
energy
recovery,
treatment,
and/
or
disposal.

The
reporting
and
recordkeeping
requirements
associated
with
the
alternate
reporting
requirement
using
the
Form
A
Certification
Statement
are
contained
in
a
separate
ICR
approved
under
OMB
Control
#
2070­
0143
(
EPA
ICR
#
1704).

Recordkeeping.
Facilities
must
keep
a
copy
of
each
Form
R
and
Form
A
Certification
Statement
submitted
for
at
least
3
years
from
the
date
of
submission.
Facilities
also
must
maintain
the
documents,
calculations,
and
other
information
used
to
prepare
the
reports.
Documents
and
records
that
facilities
keep
to
prepare
a
report
submitted
may
include,
but
are
not
limited
to:


Prior
years'
Form
Rs;


Inventory
data
and
purchase
records;


Process
diagrams
that
indicate
releases
and
waste
management
activities;


Monitoring
records;


Flowmeter
data;


Manufacturer's
estimates
of
efficiencies;


Worksheets,
engineering
calculations,
and
other
notes;


NPDES
permits
and
associated
data;


EPCRA
Section
312
Tier
II
reports;


Pretreatment
reports
when
applicable;


RCRA
manifests;


RCRA
Hazardous
Waste
Generator's
Report;
and

Invoices
from
waste
management
companies.

(
ii)
Respondent
Activities
EPA
makes
Form
R,
the
Form
A
Certification
Statement,
and
detailed
instructions
and
guidance
documents
available
to
owners
or
operators
of
facilities
subject
to
the
section
313
reporting
requirements.
In
addition,
a
toll­
free
hotline
is
available
to
handle
general
and
technical
inquiries
from
the
regulated
community.
Technical
assistance
also
is
available
through
the
EPA
Regional
offices
and
States.
The
regulated
community
is
expected
to
comply
with
the
reporting
requirements
by
completing
either
the
Form
R
or
the
Form
A
Certification
Statement
and
mailing
it
to
EPA
and
the
appropriate
state
agency.
Section
313(
g)(
2)
provides
that
a
"
facility
may
use
October,
2003
27
readily
available
data
(
including
monitoring
data)
collected
pursuant
to
other
provisions
of
law,
or
where
data
are
not
readily
available,
reasonable
estimates
of
the
amounts
involved."
Respondents
are
not
required
to
develop
new
information.
The
following
are
the
respondent
activities
and
are
briefly
summarized
below:


Compliance
Determination

Report
Completion
(
Compliance)


Substantiation
of
a
Trade
Secret
Claim

Recordkeeping/
Disclosure

Supplier
Notification

Petition
Submission
(
not
a
requirement)

Compliance
Determination.
Facilities
must
first
determine
if
they
are
required
to
submit
a
Form
R
or
are
eligible
to
submit
a
Form
A
Certification
Statement.
The
determination
is
based
on
the
SIC
code(
s)
for
the
facility,
the
number
of
full­
time
employees
or
equivalents,
and
the
quantities
of
listed
toxic
chemicals
manufactured,
processed,
or
otherwise
used
at
the
facility.
For
facilities
contemplating
using
the
Form
A
Certification
Statement,
for
each
non­
PBT
(
persistent
bioaccumulative
toxic)
chemical,
facilities
also
must
determine
the
sum
of
amounts
in
total
waste
and
determine
that
they
did
not
manufacture,
process,
or
otherwise
use
more
than
1
million
pounds
of
the
listed
toxic
chemical.
Assistance
with
compliance
determination
and
Form
R
completion
is
available
through
the
States
and
the
EPA
Headquarters
and
Regions.

Report
or
Form
Completion
(
Compliance).
Once
a
facility
has
determined
that
it
must
comply
with
the
statute,
it
must
submit
either
a
Form
R
or,
if
eligible,
a
Form
A
Certification
Statement
for
each
reportable
chemical.
The
basic
procedures
for
reporting
are
detailed
in
the
regulations
at
40
CFR
372
and
described
in
the
Reporting
Forms
and
Instructions
(
Attachment
A).

Substantiation
of
a
Trade
Secrecy
Claim.
If
a
submitter
claims
that
the
identity
of
a
chemical
is
a
trade
secret,
the
submitter
must
support
that
claim.
As
the
intent
of
the
statute
is
public
disclosure,
the
burden
is
upon
industry
to
prove
that
certain
data
must
be
withheld
from
the
public.
Information
must
be
provided
to
EPA
that
indicates
that
the
identity
has
not
been
already
revealed,
that
a
competitive
advantage
would
be
lost
if
the
identity
were
revealed,
and
that
reverse
engineering
could
not
be
performed
to
reveal
the
true
identity
of
the
substance
if
trade
secrecy
was
granted.
Trade
Secrecy
Substantiation,
including
the
burden
and
costs
to
industry,
is
discussed
in
greater
detail
in
the
ICR
for
the
Trade
Secrecy
Rule
for
EPCRA
(
EPA
ICR
#
1428,
OMB
#
2050­
0078).

Recordkeeping/
Disclosure.
Respondents
are
required
to
maintain
records
up
to
three
years.
Respondents
are
not
required
to
disclose
any
information
directly
to
the
public.

Supplier
Notification.
Suppliers
of
facilities
in
SIC
codes
20­
39
are
required
to
develop
and
distribute
a
notice
if
the
mixtures
or
trade
name
products
they
manufacture
or
process,
and
subsequently
distribute,
contain
listed
toxic
chemicals.
These
notices
are
distributed
to
companies
October,
2003
28
in
SIC
codes
20­
39
or
to
companies
that
sell
or
otherwise
distribute
the
product
to
facilities
in
SIC
codes
20­
39.

Petition
Submission.
EPA
issued
statements
of
petition
policy
and
guidance
in
the
Federal
Register
on
February
4,
1987
(
52
FR
3479)
and
on
May
23,
1991
(
56
FR
23703).
Petitioners
may
submit,
in
writing,
a
request
to
either
add
or
delete
a
chemical
to
or
from
the
section
313
list.
The
petitioner
may
include
in
this
request
evidence
that
the
chemical
either
meets
or
does
not
meet
the
criteria
established
for
inclusion
on
the
section
313
list.
Submission
of
a
petition
thus
may
involve
a
literature
search
and
compilation
and
presentation
of
the
findings
to
the
Agency.
Petition
submission
is
not
an
activity
that
is
required
of
regulated
entities,
but
the
burden
estimates
for
filing
a
petition
are
included
in
this
ICR.

4
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
4(
a)
Agency
Activities
EPA
engages
in
many
activities
to
fulfill
the
requirements
of
EPCRA.
These
activities
can
be
grouped
in
the
following
categories
which
cover
what
the
Agency
does
to
assist
the
regulated
community
with
compliance,
process
the
data,
maintain
the
database,
and
make
the
data
available.


Assistance
to
Respondents

Data
Processing
and
Quality
Control

Making
Data
Available

List
Revisions
and
Petition
Reviews

Trade
Secrecy
Reviews
Assistance
to
Respondents.
The
Agency
has
operated
a
successful
outreach
program
to
assist
businesses
in
obtaining
and
completing
both
the
Form
R
and
Form
A
Certification
Statement.
A
reporting
package
that
is
updated
annually
is
distributed
directly
to
all
TRI
respondents.
This
package
also
is
made
available
to
potential
respondents
through
EPA's
TRI
website,
Regional
office
coordinators
and
the
EPA
publications
distribution
center.
The
package
contains
reporting
forms
with
detailed
instructions
along
with
a
magnetic
media
software
package
that
allows
reporters
to
submit
their
data
on
computer
diskettes.
General
guidance
has
been
prepared
for
estimating
releases,
including
fourteen
industry­
specific
guidance
documents.

EPA
also
has
established
a
training
program
designed
to
familiarize
Regional
personnel
with
the
reporting
requirements
and
to
train
them
in
providing
technical
assistance
to
respondents.
Using
that
training,
the
Regions
have
conducted
and
continue
to
conduct
numerous
workshops
each
year
to
explain
the
reporting
requirements
to
the
regulated
community.
EPA
also
has
established
a
training
program
to
teach
EPCRA
section
313
reporting
requirements
to
private
businesses
and
consultants
that
wish
to
provide
counsel
on
section
313
compliance.
As
previously
mentioned,
October,
2003
29
EPA
operates
a
toll­
free
hotline
to
answer
general
questions
and
direct
potential
respondents
to
proper
EPA
personnel.
In
addition,
the
Agency
maintains
a
website
with
current
program­
specific
information
and
guidance
(
www.
epa.
gov/
tri).

EPA
has
also
provided
guidance
for
persons
or
organizations
interested
in
petitioning
the
agency
to
add
or
delete
chemicals
from
the
TRI
list.
In
addition
to
this
guidance,
EPA
also
convenes
prepetition
meetings
to
assist
petitioners
if
they
request
such
assistance.

Data
Processing
and
Quality
Control.
When
TRI
reports
are
submitted
on
paper,
the
information
is
keyed
into
a
database
on
a
PC­
based
local
area
network
(
LAN).
Automated
data
quality
checks
begin
at
data
entry,
including
various
edit
checks
and
the
start
of
normalization
of
some
of
the
data
fields.
At
this
point,
emphasis
is
placed
on
identifying
forms
that
are
not
completed
correctly.
If
the
problem(
s)
identified
prevent
further
processing
of
the
form,
EPA
sends
a
Notice
of
Significant
Error
to
the
respondent.
Notices
of
Technical
Error
are
sent
to
the
respondents
identifying
any
errors
and
requesting
corrections.

At
this
stage,
EPA
also
loads
data
from
those
facilities
that
have
provided
their
Form
R
submissions
on
magnetic
media.
Many
data
quality
checks
are
incorporated
into
the
magnetic
media
reporting
package.

EPA
continues
to
place
a
high
emphasis
on
data
entry
accuracy
within
the
TRI.
EPA's
internal
review
of
approximately
4%
of
the
records
showed
a
data
entry
accuracy
rate
of
over
99.9%.
This
is
up
from
97.5%
for
the
1987
reporting
year.
EPA
continues
to
conduct
the
computerized
edit
checks
at
the
point
of
data
entry,
including
a
high
percentage
of
verification
and
data
reconciliation
activities.
EPA
now
has
available
an
electronic
Facility
Data
Profile
(
FDP)
that
enables
all
reporting
facilities
to
verify
online
all
TRI
data
submitted.
EPA
continues
to
mail
hard
copy
notices
of
significant
reporting
errors
to
reporting
facilities.

Once
on
the
LAN,
the
data
are
uploaded
to
the
mainframe,
where
further
data
quality
checks
are
made.
These
operations
involve
continued
normalization
of
name
fields,
such
as
county
names,
insertion
of
missing
latitude
and
longitude
coordinates
along
with
checks
with
other
data.

Congress
requires
EPA
to
make
TRI
data
available
to
the
public
through
computer
telecommunications.
As
a
result,
EPA
has
found
it
necessary
to
undertake
a
variety
of
activities
to
make
the
data
more
usable.
This
is
due
to
the
fact
that
computer
searches
only
retrieve
data
in
exactly
the
format
requested.
Because
facilities
report
their
data
in
a
wide
variety
of
ways,
EPA
has
taken
steps
to
use
a
consistent
name
for
all
counties,
uses
a
variety
of
nomenclature
standards
for
names
within
the
database,
has
added
latitude
and
longitude
representing
the
center
of
the
zip
code
area
in
which
the
facility
is
found,
and
has
taken
other
steps
to
assist
in
the
normalization
of
the
data.
October,
2003
30
EPA
generates
a
facility
identification
number
for
newly
reporting
facilities
at
the
time
of
data
entry.
This
allows
linkage
to
all
years
of
reports
for
a
particular
facility
or
location.
The
identification
number
also
allows
easy
retrieval
of
cross­
year
data,
even
when
a
facility
is
sold
or
changes
its
name.
This
number
has
been
sent
to
all
facilities
and
they
are
required
to
use
it
on
all
future
submissions
submitted
to
the
Agency.
Use
of
the
facility
identification
number
also
facilitates
data
quality
and
cross­
year
analysis.

Under
EPCRA
section
313,
facilities
are
required
to
submit
forms
both
to
EPA
and
the
state
in
which
they
operate.
For
additional
quality
assurance
and
tracking
purposes,
EPA
provides
all
states
with
a
listing
of
facilities
that
reported
to
the
Federal
Reporting
Center
for
each
reporting
year.
This
activity
typically
results
in
the
identification
of
several
cases
where
facilities
had
not
reported
to
one
or
the
other
government.
Many
states
then
provide
copies
of
forms
to
the
EPA
where
EPA
had
not
received
copies,
and
vice­
versa.
This
activity
has
provided
a
critical
step
to
assist
EPA
in
coordinating
the
data
collection
with
the
states
and
completing
both
data
repositories.

Making
TRI
Data
Available.
Many
options
are
available
for
accessing
TRI
data.
EPA
offers
the
data
in
a
variety
of
common
computer
and
hard
copy
formats
to
ensure
that
everyone
can
easily
use
the
information.
TRI
is
available
on
diskette,
CD­
ROM,
and
on
the
Internet.
While
TRI
data
have
been
available
from
several
computer­
based
sources,
recent
system
conversions,
processing
efficiencies,
improvements
in
web­
based
access
have
created
a
need
for
a
primary
source
for
accessing
TRI
(
and
other
Agency)
data.
Therefore,
EPA
has
shifted
its
focus
to
the
Envirofacts
and
TRI
Explorer
systems
to
address
this
need.
TRI
data
will
be
updated
in
the
Envirofacts
and
TRI
Explorer
systems
at
a
more
frequent
rate
than
previously
possible
allowing
the
user
community
access
to
virtually
"
live"
TRI
data.

TRI
reports
are
also
available
from
state
government
offices
as
well
as
from
EPA.
For
each
reporting
year,
many
states
make
their
data
available
before
EPA
releases
data
from
the
national
database.
Persons
interested
in
receiving
state
specific
information
may
call
their
state
EPCRA
Coordinator
or
EPA
Regional
TRI
Coordinator
for
assistance.

List
Revisions
and
Petition
Reviews.
The
list
of
toxic
chemicals
subject
to
reporting
under
section
313
of
EPCRA
is
not
static.
The
list
can
be
modified
by
Agency­
initiated
reviews
of
chemicals
or
by
public
petition.
If
a
listing
petition
is
submitted
by
a
State
governor,
then
EPA
must
respond
within
180
days
by
either
publishing
an
explanation
of
denial
or
granting
the
petition.
If
EPA
does
not
respond
within
180
days
the
chemicals
are
automatically
added
to
the
toxic
chemical
list.
Once
a
petition
is
received,
EPA
begins
an
intensive
review
that
includes
chemistry
and
toxicity
analyses
of
the
chemical
or
chemicals.
Depending
on
the
toxicity
of
the
chemical
or
chemicals,
EPA's
review
also
may
include
exposure,
economic,
and
engineering
analyses.
If
the
chemical
meets
the
criteria
for
addition
to
the
list,
it
is
added
or
maintained
on
the
list.
If
the
criteria
are
not
met,
then
the
chemical
is
removed
from
the
list.
The
criteria
for
inclusion
on
the
list
are
stated
in
section
313(
d)(
2):
the
chemical
is
known
to
or
can
reasonably
be
October,
2003
31
anticipated
to
cause
significant
adverse
acute
human
health
effects
at
concentration
levels
that
are
reasonably
likely
to
exist
beyond
facility
site
boundaries
as
a
result
of
continuous,
or
frequently
recurring,
releases;
the
chemical
is
known
to
cause
or
can
reasonably
be
anticipated
to
cause
in
humans
cancer
or
teratogenic
effects,
or
serious
or
irreversible
reproductive
dysfunctions,
neurological
disorders,
heritable
genetic
mutations
or
other
chronic
health
effects;
or
the
chemical
is
known
to
cause
or
can
reasonably
be
anticipated
to
cause
a
significant
adverse
effect
on
the
environment
because
of
its
toxicity,
its
toxicity
and
persistence
in
the
environment,
or
its
toxicity
and
tendency
to
bioaccumulate
in
the
environment.

Since
the
list
was
first
published,
there
have
been
332
additions
(
including
6
chemical
categories)
to
and
19
deletions
or
modifications
(
including
modifications
to
two
chemical
categories)
from
it,
and
several
delisting
petitions
are
pending.
Two
hundred
ninety­
one
of
these
additions
(
including
4
chemical
categories)
are
the
result
of
Agency­
initiated
rulemakings.
Four
of
the
deletions
or
modification,
including
acetone,
sodium
hydroxide
(
solution),
sodium
sulfate
(
solution),
hydrochloric
acid
(
non­
aerosol),
and
sulfuric
acid
(
non­
aerosol),
were
high
production
volume
chemicals,
which
greatly
reduced
the
reporting
burden
on
industry.
In
general,
previous
petitions
have
been
submitted
for
single
chemicals,
however,
a
recent
increase
in
petitions
for
groups
of
chemicals
has
occurred.
EPA
may
list
the
chemicals
as
a
category
or
add
only
those
individual
chemicals
which
meet
the
section
313(
d)(
2)
criteria.
Since
inception
of
the
TRI
Program,
EPA
has
identified
several
existing
listed
chemicals
as
PBT
chemicals
as
well
as
added
new
chemicals
as
PBT
chemicals.

Trade
Secrecy
Reviews.
When
a
respondent
claims
a
chemical
identity
as
a
trade
secret,
a
substantiation
must
be
included.
Occasionally
respondents
claim
trade
secret
status
on
Form
R,
but
do
not
provide
substantiation.
In
those
cases,
EPA
must
review
the
claim
and
contact
the
respondent
to
determine
the
true
intent.
In
many
cases,
the
trade
secret
claim
was
not
intended
and
no
substantiation
is
made.
Trade
Secrecy
reviews,
including
the
costs
to
EPA,
are
discussed
in
greater
detail
in
the
ICR
for
the
Trade
Secrecy
Rule
for
EPCRA
(
EPA
#
1428,
OMB
#
2050­
0078).

4(
b)
Collection
Methodology
and
Management
EPA
continues
to
encourage
the
use
of
submissions
on
magnetic
media.
The
use
of
magnetic
media
is
intended
to
reduce
both
the
cost
and
the
time
required
to
enter,
process,
and
make
available
the
data,
although
is
may
also
reduce
the
reporting
burden
on
industry.
Submission
by
magnetic
media
also
improves
data
quality
because
of
automatic
checks
that
highlight
errors
or
omitted
data.
As
an
additional
step
in
improving
user's
ability
to
report
using
magnetic
media,
EPA
has
made
the
Form
A
Certification
Statement
available
on
magnetic
disk
and
CD­
ROM.
For
TRI
reporting,
EPA
has
made
available
an
automated
reporting
software
package
called
TRI­
ME,
that
simplifies
the
reporting
process
by
automating
calculations
and
compiling
instructions
and
guidance
in
an
electronic
format.
October,
2003
32
4(
c)
Small
Entity
Flexibility
The
statute
provides
that
facilities
with
less
than
10
full­
time
employees
(
or
equivalent)
are
not
required
to
report.
In
addition,
EPA
has
taken
several
steps
to
minimize
the
burden
for
small
businesses.
A
range
reporting
option
was
added
to
the
February
16,
1988
final
rule
(
53
FR
4500)
that
codified
the
EPCRA
section
313
reporting
requirements.
Range
reporting
was
the
preferred
option
from
the
Regulatory
Flexibility
Act
analysis
to
provide
burden
reduction
for
small
businesses.
Range
reporting
provides
an
option
for
releases
of
less
than
1,000
pounds
to
be
recorded
as
a
code
representing
one
of
three
ranges,
1
to
10
pounds,
11
to
499
pounds,
or
500
to
999
pounds,
rather
than
as
a
specific
estimate
of
the
release
amount.
The
benefit
is
not,
however,
limited
to
small
businesses.
Range
reporting
is
not
applicable
for
PBT
chemicals.

In
addition,
in
response
to
a
petition
from
the
Small
Business
Administration,
EPA
has
promulgated
the
alternate
threshold
(
November
30,
1994,
59
FR
61488)
discussed
above.
Although
any
reporting
facility
meeting
the
criteria
may
use
the
alternate
threshold,
EPA
believes
that
this
alternate
threshold
is
most
advantageous
to
small
entities.

EPA
has
also
developed
interactive,
intelligent,
user­
friendly
software
called
"
Toxics
Release
Inventory
Made
Easy
Software
(
TRI­
ME),"
that
asks
the
user
simple,
straightforward
questions
to
help
the
user
determine
if
the
facility
is
subject
to
TRI
reporting.
TRI­
ME
has
greatly
reduced
data
quality
errors
and
therefore,
reduced
the
likelihood
of
a
facility
being
in
violation
of
the
reporting
requirements,
or
having
to
subsequently
submit
corrections.
For
reporting
year
2001,
85
percent
of
the
Form
R
responses
were
received
electronically
and
37
percent
of
Form
R
responses
were
filed
using
TRI­
ME.
In
the
supporting
statement
for
the
previous
ICR
renewal,
EPA
had
predicted
a
40
percent
TRI­
ME
adoption
rate
for
reporting
year
2001.
Preliminary
results
from
reporting
year
2002
show
85
percent
of
the
Form
R
responses
were
received
electronically,
and
92
percent
of
Form
R
responses
were
filed
using
TRI­
ME
(
TRI­
ME
output
for
submission
can
be
in
paper
or
electronic
formats).

4(
d)
Collection
Schedule
Facilities
must
report
their
information
on
a
calendar
year
bases,
and
submit
the
Form
R
to
EPA
by
July
1
each
year.
On
average,
EPA
has
released
the
national
TRI
data
set
to
the
public
approximately
ten
months
after
the
annual
reporting
deadline,
i.
e.,
July
1.
In
response
to
public
concerns
about
shortening
the
time
frame
for
release
of
TRI
information,
EPA
is
instituting
tighter
deadlines
for
facilities
to
submit
revised
reports,
and
combining
a
series
of
automated
data
quality
operations.
The
Agency
expects
these
measures
will
help
it
to
meet
the
ultimate
goal
of
releasing
data
in
the
year
of
submission.
Also,
it
is
important
to
note
that
EPA's
national
database
is
just
one
avenue
of
access
to
the
TRI
information.
Each
state
also
makes
its
data
available
to
the
public,
and
most
states
are
able
to
make
their
data
available
prior
to
EPA's
release
of
the
national
database.
For
example,
nearly
half
of
the
states
release
their
state's
TRI
database
within
four
months
of
the
reporting
deadline.
October,
2003
33
5
NONDUPLICATION,
CONSULTATIONS,
OTHER
COLLECTION
CRITERIA
5(
a)
Nonduplication
The
basic
information
requested
on
the
Form
R
is
required
to
be
reported
by
law.
Other
statutes,
however,
also
require
the
reporting
of
information
about
releases
of
chemicals
to
the
environment,
creating
the
possibility
of
overlap
or
duplication
of
reporting
requirements.
EPA
anticipates
some
overlap
and
provides
that
respondents
may
use
readily
available
data
collected
pursuant
to
other
provisions
of
law
to
complete
the
section
313
reports.
However,
currently
available
non­
TRI
sources
of
information
cannot
provide
readily
accessible
release
and
transfer,
inventory,
or
pollution
prevention
data
with
the
scope,
level
of
detail,
and
chemical
coverage
as
data
currently
included
in
TRI.
October,
2003
11.
For
additional
detailed
information
on
chemical
coverage
of
TRI,
AFS,
BRS,
and
PCS,
please
refer
to
Attachments
B­
1
and
B­
2
at
the
end
of
this
document.
22.
"
Ease
of
substitution"
refers
only
to
the
potential
of
the
information
in
the
database
to
substitute
for
TRI
reporting.
It
does
not
imply
that
the
database
is
not
adequate
for
the
purposes
for
which
it
was
designed.

34
FIGURE
1
­
MAJOR
RELEASE
AND
TRANSFER
DATABASES
Data
source
Media
and
chemical
coverage1
Relevant
releases
statistics
available
Ease
of
database
substitution
for
TRI
data2
Aerometric
Information
Retrieval
System
(
AIRS),
Facility
Subsystem
(
AFS)
Contains
annual
emissions
of
six
criteria
air
pollutants
for
facilities
above
reporting
thresholds.
Also
contains
limited
information
on
toxics.
Total
annual
releases;
average
daily
releases
in
non­
attainment
areas.
Limited
toxics
data
due
to
submission
being
voluntary.

Permit
Compliance
System
(
PCS)
Contains
monthly
discharge
monitoring
data
and
flow
rates
for
major
sources
of
water
pollutants.
Contains
concentration
data;
total
annual
releases
can
be
calculated;
average
daily
releases,
maximum
"
moment"
if
continuous
monitoring.
Only
includes
chemicals
for
which
a
discharge
limit
has
been
set.
Difficult
to
link
between
PCS
parameters
and
CAS
#;
very
limited
monitoring
data
for
minor
dischargers.

Biennial
Reporting
System
(
BRS)
Contains
waste
volumes
by
RCRA
waste
code
reported
biennially.
Total
annual
off­
site
transfers
of
hazardous
waste
for
land
disposal;
total
annual
releases
to
POTW.
Many
RCRA
waste
codes
are
not
specific
to
an
individual
CAS
#.
Quantities
of
chemicals
in
waste
can
not
be
determined.
Portion
of
waste
stream
matching
each
waste
code
can
not
be
determined.

Under
RCRA,
generators,
treaters,
storers,
and
disposers
of
hazardous
waste
are
required
to
submit
reports
to
the
Biennial
Reporting
System
(
BRS)
every
two
years.
The
Biennial
Reporting
System
is
a
national
system
that
collects
data
on
the
generation,
management,
and
minimization
of
hazardous
waste.(
http://
www.
epa.
gov/
enviro/
html/
brs/
index.
html).
This
system
captures
detailed
data
on
the
generation
of
hazardous
waste
from
large
quantity
generators
and
data
on
waste
management
practices
from
treatment,
storage,
and
disposal
facilities.
The
biennial
data
October,
2003
35
provide
a
basis
for
trend
analyses.
Data
about
the
previous
year's
hazardous
waste
activities
is
reported
on
even
years
by
the
facilities
to
EPA.
EPA
then
provides
reports
on
hazardous
waste
generation
and
management
activity
that
accompany
the
data
files.
BRS
cannot
duplicate
the
information
contained
within
TRI,
as
BRS
waste
codes
do
not
necessarily
map
to
unique
chemicals,
quantities
of
specific
wastes
in
the
wastestream
cannot
be
determined,
and
reporting
is
less
frequent
than
that
of
TRI.

The
Permit
Compliance
System
(
PCS)
tracks
permit
compliance
and
enforcement
status
of
facilities
that
discharge
to
surface
waters.
The
Permit
Compliance
System
(
PCS)
(
http://
www.
epa.
gov/
enviro/
html/
pcs/)
provides
information
on
companies
which
have
been
issued
permits
to
discharge
waste
water
into
rivers.
PCS
allows
the
user
to
review
information
on
when
a
permit
was
issued
and
expires,
how
much
the
company
is
permitted
to
discharge,
and
the
actual
monitoring
data
showing
what
the
company
has
discharged.
The
Water
Discharge
Permits
Query
allows
the
user
to
retrieve
preselected
data
from
the
PCS
database
in
Envirofacts.
The
search
can
be
narrowed
by
selecting
various
options
including
facility
name,
geographic
location,
standard
industrial
classification,
and
chemicals.

PCS
data
are
not
a
suitable
substitute
for
TRI
data
due
to
the
fact
that
PCS
is
a
permit
tracking
system
and
not
a
loadings
system.
In
other
words,
PCS
typically
tracks
pollutant
concentrations,
and
not
total
releases.
This
difference
in
purpose
results
in
differences
which
are
difficult
to
resolve
in
the
amount
and
types
of
data
collected.
Furthermore,
PCS
does
not
contain
all
TRI
chemicals.

TRI
also
contains
inventory
data,
which
makes
up
a
small
portion
of
the
total
data.
The
most
likely
alternatives
for
TRI
inventory
data
are
the
Tier
I/
II
data
reported
under
EPCRA
§
312.
Under
EPCRA
§
312,
regulated
facilities
must
submit
annual
inventory
reports
of
hazardous
chemicals
stored
on
site
to
the
state.
Tier
I
requires
reporting
on
broad
categories
of
physical
hazards,
while
Tier
II
requires
chemical
specific
information
by
CAS
number.
The
information
contained
on
the
Tier
I
and
Tier
II
reports
surpasses
the
chemical
inventory
data
requested
on
TRI
Form
R
in
terms
of
the
chemicals
covered
and
level
of
detail.
However,
there
are
significant
difficulties
with
respect
to
public
access
of
Tier
I
and
Tier
II
data,
including
the
lack
of
a
national
integrated
database.

In
addition
to
release/
transfer
and
inventory
data,
TRI
also
collects
pollution
prevention
data
from
reporting
facilities.
Pollution
prevention
data
somewhat
analogous
to
data
in
TRI
can
be
found
in
BRS
(
described
above)
and
databases
administered
by
two
state
environmental
agencies.
While
BRS
provides
both
qualitative
and
quantitative
pollution
prevention
information,
it
does
not
have
the
facility
or
chemical
coverage
necessary
to
replace
TRI
pollution
prevention
reporting
requirements.
BRS
contains
data
on
generation,
transfer,
and
management
of
hazardous
wastes,
while
pollution
prevention
data
contained
in
TRI
includes
information
on
wastes
or
process
byproducts
in
all
production
phases
and
media.
In
addition,
states
have
come
to
rely
on
the
October,
2003
36
pollution
prevention
data
provided
to
them
by
TRI.
As
a
result,
no
state
program
collects
all
of
the
pollution
prevention
data
currently
available
in
TRI.

What
follows
is
a
more
detailed
discussion
of
the
several
information
sources
that
currently
provide
pollutant
release
and
transfer
data.
The
analysis
is
broken
down
by
specific
type
of
data
collected
under
TRI.

Fugitive/
Non­
Point
Air
Emissions
and
Stack/
Point
Air
Emissions
Fugitive
(
non­
point)
air
emissions
and
stack
(
point)
air
emissions
are
reported
under
Sections
5.1
and
5.2,
respectively,
of
TRI
Reporting
Form
R.
(
Fugitive
air
emissions
are
defined
as
all
releases
of
air
pollutants
to
the
air
that
are
not
released
through
stacks,
vents,
ducts,
pipes,
or
any
other
confined
air
stream.
Stack
air
emissions
are
defined
as
all
releases
of
air
pollutants
that
are
released
through
stacks,
vents,
ducts,
pipes,
or
any
other
confined
air
stream.)
In
the
paragraphs
below,
several
alternative
data
sources
are
compared
and
contrasted
to
TRI.
Key
criteria
considered
in
comparing
the
alternative
data
sources
with
TRI
include:
chemical
coverage,
industry/
facility
coverage,
release
statistics,
and
public
accessibility
to
the
data.

AIRS
Facility
Subsystem
(
AFS)

The
Aerometric
Information
Retrieval
System
(
AIRS)
is
a
computer­
based
repository
of
information
on
airborne
pollution
in
the
United
States
and
various
World
Health
Organization
(
WHO)
member
countries.
AIRS
is
comprised
of
four
major
databases
­
Air
Quality
(
AQ),
AIRS
Facility
Subsystem
(
AFS),
Area/
Mobile
Source
(
AMS),
Geo­
Common
(
GCS)
subsystems,
and
a
mapping
utility
for
all
AIRS
data
called
AIRS
Graphics
(
AG).
Each
subsystem
addresses
different,
but
connected,
aspects
of
the
Clean
Air
Act
regulatory
requirements.
AIRS
is
administered
by
EPA's
Office
of
Air
and
Radiation
(
OAR),
though
AFS
is
managed
by
OECA.

The
AIRS
Facility
Subsystem
(
AFS)
is
the
database
component
of
AIRS
which
tracks
air
emissions
from
industrial
plants.
AFS
is
a
sub­
system
of
the
Aerometric
Information
Retrieval
System
(
AIRS).
AFS
contains
compliance
and
permit
data
for
stationary
sources
regulated
by
the
U.
S.
EPA
and
state
and
local
air
pollution
agencies.
AFS
contains
emissions,
compliance,
and
enforcement
data
on
air
pollution
point
sources
regulated
by
EPA,
state
and
local
environmental
regulatory
agencies.

OAR
manages
EPA
programs
to
improve
air
quality
in
areas
where
the
current
quality
is
unacceptable
and
to
prevent
deterioration
in
areas
where
the
air
is
relatively
free
of
contamination.
To
help
accomplish
this
task,
OAR
uses
AFS
to
track
emissions
of
pollutants
that
have
been
proven
to
be
detrimental
to
public
health,
known
as
criteria
pollutants,
as
defined
in
the
national
ambient
air
quality
standards.
The
six
criteria
pollutants
which
states
must
report
to
AFS
include:
particulate
matter
less
than
10
microns
in
size
(
PM10),
carbon
monoxide
(
CO),
sulfur
dioxide
October,
2003
33.
AP­
42
Emission
Factors,
available
from
the
Factor
Information
Retrieval
(
FIRE)
System,
and
emission
factors
in
general,
are
representative
values
that
attempt
to
relate
the
quantity
of
a
pollutant
released
with
a
given
activity
associated
with
the
release
of
that
pollutant.
Emission
factors
are
typically
expressed
as
the
weight
of
pollutant
divided
by
a
unit
weight,
volume,
distance,
or
duration
of
the
activity
emitting
the
pollutant
(
EPA,
1995b).
Generally,
AP­
42
37
(
SO
2),
nitrogen
dioxide
(
NO
2),
lead
(
Pb),
and
ozone
(
reported
as
reactive
volatile
organic
compounds,
an
ozone
precursor).
States
are
required
to
report
ambient
air
quality
data
on
a
quarterly
basis,
and
point
source
data
on
a
yearly
basis,
for
the
criteria
pollutants
listed.
In
addition,
states
may
choose
to
use
the
AIRS
system
to
store
data
on
a
wide
variety
of
other
pollutants
and
related
variables.

Data
in
AFS
is
organized
into
four
logical
levels:
plant,
stack,
point,
and
segment.
The
plant
is
a
facility
represented
by
its
physical
location,
and
defined
by
property
boundaries.
A
stack
or
vent
is
where
emissions
are
introduced
into
the
atmosphere.
An
emission
point
is
a
physical
piece
of
equipment
or
a
process
that
produced
emissions.
Finally,
a
segment
is
a
component
of
a
point
process
(
such
as
fuel
combustion)
that
is
used
in
the
computation
of
emissions.
(
U.
S.
EPA,
1995a)

At
the
facility
level,
sources
with
air
emissions
greater
than
1,000
tons
per
year
(
tpy)
for
CO,
100
tpy
for
VOC,
PM­
10,
SO
x,
or
NO
x,
or
5
tpy
for
lead
must
report
actual
or
estimated
annual
emissions
data.
At
the
point
level,
such
as
a
stack
or
any
single
piece
of
equipment
or
process
where
emissions
occur,
sources
with
air
emissions
greater
than
25
tpy
for
VOC,
PM­
10,
SO
x,
or
NO
x,
250
tpy
for
CO,
and
5
tpy
for
lead
must
report
actual
or
estimated
annual
emissions
data.
AFS
data
are
utilized
by
states
to
prepare
State
Implementation
Plans
to
comply
with
regulatory
programs
and
by
EPA
as
an
input
for
the
estimation
of
total
national
emissions.
Data
for
over
100,000
point
source
facilities
are
stored
in
AFS.

Compliance
and
enforcement
data
are
updated
by
states
and
EPA
based
on
the
data
submitted
by
facilities.
Compliance
data
for
these
plants
may
be
recorded
for
the
plant
as
a
whole
or
for
a
specific
point
within
the
plant.
Emissions
estimates
are
available
for
facilities
satisfying
the
emissions
thresholds
described
above.
States
also
are
required
to
report
emissions
data
for
point
sources
which
emit
below
the
100
ton
threshold
in
areas
where
air
quality
does
not
meet
federal
standards
(
non­
attainment
areas).

Fugitive
air
emissions
data
are
not
specifically
flagged
within
AFS.
It
may
be
possible,
however,
to
generate
fugitive
emissions
estimates
for
pollutants
included
within
AFS
by
determining
all
Source
Classification
Codes
(
SCCs)
generating
fugitive
air
emissions,
and
then
totaling
emissions
(
Kleeman,
1995).
SCCs
are
eight­
character
codes
which
represent
specific
processes
or
functions
within
a
source
category.
For
example,
SCC
1­
02­
005­
01
corresponds
to
the
burning
of
distillate
oil
in
an
industrial
boiler.
SCCs
allow
proper
identification
of
processes
as
well
as
proper
calculation
of
emissions
when
applying
AP­
42
emission
factors.
3
Because
SCC
codes
are
not
October,
2003
emission
factors
are
simply
averages
of
available
emissions
rates
that
can
be
used
to
facilitate
the
estimation
of
air
emissions
and
are
sometimes
used
by
facilities
to
estimate
TRI
releases
and
transfers.
A
difficulty
with
using
emissions
factors
is
that
there
is
a
lack
of
facility­
specific
throughput
data
(
production
or
activity),
without
which
estimates
cannot
be
made.
Another
difficulty
is
that
the
factors
are
averages
and
do
not
account
for
the
variations
between
facilities.
44.
Hazardous
Air
Pollutants
(
HAPs)
are
defined
in
Section
112
of
the
Clean
Air
Act
(
CAA).
Section
112
lists
189
HAPs,
of
which
181
also
are
listed
in
TRI.

38
designed
to
distinguish
stack
level
emissions
from
fugitive
air
emissions,
such
an
effort
would
require
a
review
of
all
coded
industrial
processes
in
order
to
identify
those
generating
fugitive
emissions.

As
described
in
more
detail
in
following
sections,
AFS
data
are
not
good
substitutes
for
TRI
stack
or
fugitive
emissions
data.
Problems
include
the
lack
of
reporting
requirements
for
most
air
toxics,
and
the
lack
of
rigid
reporting
schedules.

Chemical
coverage:
States
are
required
to
report
to
EPA
annual
emissions
estimates
for
point
sources
emitting
greater
than
or
equal
to
threshold
quantities
of
the
criteria
pollutants
(
40
CFR
§
51:
321­
326):
particulate
matter
(
PM
10
&
PM
2.5),
carbon
monoxide,
sulfur
oxides,
nitrogen
oxides,
lead,
and
ozone.
Currently,
there
is
no
requirement
for
states
to
report
hazardous
air
pollutants
(
HAPs)
to
AFS,
although
some
states
with
toxics
reporting
requirements
that
exceed
federal
requirements
may
upload
their
air
toxics
information
to
AFS.
4
At
this
time,
however,
no
research
has
been
undertaken
to
determine
which
states
report
which
HAPs.
There
also
are
no
statistics
on
the
frequency
of
state
HAP
reporting,
which
facilities
report,
or
the
reporting
thresholds.

Because
data
on
toxic
releases
in
AFS
are
sparse,
emissions
can
be
estimated
(
that
is,
modeled)
using
a
technique
called
"
speciation."
Speciation
involves
multiplying
reported
emissions
of
particulate
matter
(
PM)
and
VOCs
by
fractions
representing
various
compounds,
according
to
a
profile
specific
to
the
emission
source.
SPECIATE
is
EPA's
repository
of
total
organic
compounds
(
TOC)
and
particulate
matter
(
PM)
speciated
profiles
for
a
variety
of
sources
for
use
in
source
apportionment
studies.
OAQPS's
Clearinghouse
for
Inventories
on
Emission
Factors
(
CHIEF)
website
makes
available
SPECIATE,
a
windows­
based
speciation
application
with
apportionment
factors
for
691
organic
chemicals
and
110
particulates
in
about
700
total
profiles.
However,
there
are
significant
limitations
to
the
accuracy
and
reliability
of
speciation
data.
The
speciation
profiles
contained
in
SPECIATE
were
developed
from
field
sampling,
engineering
judgements,
and
other
indirect
techniques.
The
weight
percentages
and
number
of
chemicals
in
a
given
profile
may
be
heavily
influenced
by
the
particular
analytical
and
sampling
methods
used
to
develop
the
profile.
(
U.
S.
EPA,
1996)

Another
shortcoming
of
SPECIATE
involves
the
assignment
of
profiles
for
all
SCCs
in
AIRS.
Ideally,
each
SCC
in
AIRS
would
have
a
unique
profile
to
represent
its
speciation
characteristics;
October,
2003
39
however,
there
are
far
more
SCCs
than
available
profiles.
Therefore,
those
categories
which
are
not
associated
with
original
profiles
are
assigned
profiles
based
on
engineering
judgement
(
Radian,
1993).

Industry/
facility
coverage:
Because
facilities
are
included
in
AFS
on
the
basis
of
their
emissions
levels,
there
are
no
SIC
or
industry
limitations
imposed
on
the
list
of
AFS­
covered
facilities.
In
contrast,
TRI
currently
only
requests
data
from
some,
but
not
all
SIC
codes,
thereby
excluding
many
other
industries.
It
is
important
to
note,
however,
that
emissions
thresholds
play
an
important
role
in
determining
which
facilities
are
covered.
Facilities
are
covered
under
AFS
only
if
they
release
multiple
tons
of
criteria
pollutants
annually.
Smaller
HAP
emitters
that
release
small
amounts
of
criteria
pollutants
may
therefore
be
completely
exempted
from
reporting
to
AFS.
TRI,
on
the
other
hand,
employs
thresholds
of
10,000
and
25,000
pounds
per
year,
depending
on
how
a
particular
chemical
is
used,
processed,
or
manufactured.
In
addition
to
this
use
threshold,
TRI
also
exempts
facilities
with
less
than
the
equivalent
of
ten
full
time
employees.

Release
statistics/
reporting
frequency:
EPA
requests
that
states
upload
information
to
AFS
on
an
annual
basis.
However,
because
there
are
no
defined
reporting
schedules
and
no
real
penalties
for
not
reporting,
in
practice
there
is
"
rolling
receipt"
of
information,
with
some
states
failing
to
report
for
various
reasons
in
some
years.
Although
AFS
notes
that
most
states
report
regularly,
and
some
facility­
specific
emissions
data
are
available
from
AFS
across
all
reporting
years
(
Wakefield,
1995),
the
looseness
of
the
reporting
structure
makes
comparisons
across
states,
industry,
facilities,
or
years
difficult.

Accessibility:
AFS
data
are
accessible
through
the
EPA
Mainframe
and
to
a
limited
degree,
through
AIRS
Executive,
a
self­
contained
updatable
and
downloadable
program
which
digests
and
summarizes
AIRS
data.
There
are
no
access
restrictions
for
AIRS
Executive
which
is
available
through
the
EPA
World
Wide
Web
site
(
http://
www.
epa.
gov/
airs/
aexec.
html).
The
EPA
Mainframe,
however,
is
password
protected
and
is
not
accessible
by
the
general
public.

State
Air
Emissions
Inventories
Several
states
and
regional
agencies
maintain
their
own
air
emissions
inventories,
including
the
inventory
set
up
under
California's
"
Hot
Spots"
Information
and
Assessment
Act
(
Assembly
Bill
2588),
and
the
Great
Lakes
Regional
Air
Toxics
Emissions
Inventory.
Approximately
half
the
states
have
implemented
some
kind
of
air
toxics
reporting
system
(
Pope,
1995).
However,
the
amount
of
data
as
well
as
the
types
of
data
elements
collected
varies
widely
from
state
to
state.
The
Great
Lakes
inventory
merits
special
attention
because
other
states
and
countries
(
including
Louisiana;
Texas;
Ontario,
Canada;
and
Mexico)
use
it
as
a
model
for
their
own
inventories.
A
number
of
other
states
have
active
programs
or
are
in
the
process
of
developing
them.
A
number
of
other
states
have
active
programs
or
are
in
the
process
of
developing
them.
Two
are
discussed
below
in
terms
of
their
coverage
and
accessibility
characteristics.
October,
2003
40
Chemical
coverage:
Chemicals
covered
under
state
and
regional
inventories
vary
widely
in
the
number
of
chemicals
covered,
data
elements
required,
and
reporting
thresholds
used.
While
some
inventories
collect
detailed,
facility
level
information
on
many
chemicals,
others
are
designed
only
to
track
very
specific
pollutants
for
specific
applications.

Industry/
facility
coverage:
States
often
develop
their
own
toxics
inventories
due
to
perceived
gaps
in
TRI's
industry
coverage.
For
example:

The
Great
Lakes
Regional
Air
Toxics
Emissions
Inventory
does
not
require
emissions
reporting
by
industry.
Rather,
state
agencies
will
use
best
available
emission
factors
(
FIRE)
or
sourcespecific
emission
factors
and
throughput
information
to
estimate
emissions
from
a
much
larger
catalog
of
sources
than
TRI,
including
area
sources
such
as
dry
cleaners,
asphalt
plants,
and
wood
stoves
(
Ratza,
1995).

Release
statistics/
reporting
frequency:
The
type
of
data
collected
and
data
collection
frequency
among
states
and
regions
also
varies
widely.
For
example:

Accessibility:
Because
each
state
or
region
which
maintains
a
HAPs
database
does
so
more
or
less
independently
of
the
federal
government,
there
currently
is
no
central
repository
of
this
information.
Because
the
states
and
regions
also
use
different
database
formats
and
applications
to
maintain
their
data,
building
a
multi­
state/
region
air
emissions
inventory
from
the
existing
databases
would
be
a
challenging
task.
However,
OAQPS
is
in
the
process
of
developing
a
national
toxics
inventory
database,
which
will
utilize
a
combination
of
TRI
data
and
state,
regional,
&
local
databases
(
Pope,
1995).

Another
potential
partial
solution
to
the
data
compatibility
problem,
once
it
is
fully
implemented,
is
the
Great
Lakes
Regional
Air
Toxics
Emissions
Inventory,
which
is
maintained
using
the
Regional
Air
Pollutant
Inventory
Development
System
(
RAPIDS).

As
the
principal
component
of
the
Great
Lakes
Regional
Air
Toxic
Emissions
Inventory
project,
the
Regional
Air
Pollutant
Inventory
Development
System
(
RAPIDS)
is
the
first
ever
multi­
jurisdictional
pollutant
emissions
inventory
software
that
has
been
developed.
This
software
is
an
important
product
of
the
binational
steering
committee
effort
to
design
and
implement
a
regional
inventory
containing
sources
of
toxic
air
contaminants.
RAPIDS
was
originally
tested
by
Illinois,
Indiana,
and
Wisconsin
in
their
joint
development
of
the
Southwest
Lake
Michigan
Pilot
Study.
The
focus
of
the
study
was
on
the
Commission
defined
list
of
49
toxic
pollutants,
in
addition
to
several
other
important
nontoxic
compounds.
Now,
RAPIDS
is
used
by
each
Great
Lakes
state
and
Province
of
Ontario.
The
eight
Great
Lakes
states
and
Ontario
province
working
together
through
the
Great
Lakes
Commission
are
currently
in
the
process
of
developing
a
regional
emission
inventory
for
airborne
toxic
pollutants.
This
regional
emission
inventory
is
focused
on
49
toxic
air
pollutants
which
have
been
identified
as
significant
October,
2003
41
contributors
to
the
contamination
of
the
Great
Lakes.
The
development
of
the
regional
emission
inventory
has
included
the
development
of
technical
specifications
for
a
regional
air
toxic
database
(
Phase
I);
the
development
of
an
automated
Regional
Air
Pollutant
Inventory
Development
System
(
RAPIDS),
an
emission
factor
database,
and
an
emission
inventory
protocol
for
inventorying
hazardous
air
pollutants
(
Phase
II);
and
the
full
implementation
of
the
protocol
and
emission
inventory
software
to
complete
an
eight
state
point
and
area
source
toxic
air
emission
inventory
(
Phase
III).
To
date,
this
inventory
system
has
been
developed
to
estimate
emissions
from
point
and
area
sources
only.
RAPIDS,
a
state­
of­
the­
art
client/
server
software
for
the
estimation
of
emissions
from
point
and
area
sources
is
designed
to
run
on
a
personal
computer.
Each
State
will
create
its
own
Statewide
inventory
that
will
be
uploaded
to
the
regional
RAPIDS
repository,
an
Oracle
database,
at
the
USEPA's
Great
Lakes
National
Program
Office
(
GLNPO).
RAPIDS
uses
the
Great
Lakes
State­
approved
USEPA
emission
factor
database,
the
Factor
Information
Retrieval
System
(
FIRE)
to
estimate
emissions,
and
also
accepts
source­
specific
emissions
data.
The
RAPIDS
design
has
focused
on
flexibility
and
versatility,
and
is
built
upon
an
innovative
data
model.

The
latest
release
of
RAPIDS
(
Version
2.1)
has
been
updated
to
include,
among
other
things,
the
ability
to
export
emissions
data
in
a
format
compatible
with
the
U.
S.
EPA's
National
Emissions
Inventory
(
NEI).
For
the
1999
national
inventory,
all
states
were
required
to
submit
emissions
data
in
this
format,
which
makes
RAPIDS
one
of
the
most
progressive
emissions
inventory
systems
available.
According
to
the
Great
Lakes
Commission,
RAPIDS
is
the
"
first­
ever
multistate
pollutant
emissions
estimation
software,"
and
handles
sophisticated
relational
data
management
as
well
as
emissions
estimations.

Title
V
Part
70
Operating
Permits
Under
the
1990
Clean
Air
Act
Amendments
(
CAAA),
facilities
designated
as
"
major
sources"
and
facilities
otherwise
subject
to
Section
112
and
Title
IV
must
apply
for
a
Title
V
Part
70
Operating
Permit.
Although
a
facility
can
meet
the
criteria
for
a
major
source
in
any
of
several
ways,
particularly
relevant
are
those
facilities
which
attain
major
source
status
by
emitting
10
tons
per
year
(
tpy)
or
more
of
any
HAP
or
25
tpy
total
combined
HAPs.
As
part
of
the
application
for
a
Title
V
permit,
some
facilities
may
have
to
report
emissions
of
air
toxics
(
see
discussion
on
chemical
coverage
below).
There
is
significant
overlap
between
the
189
HAPs
regulated
under
the
CAA
and
the
650+
chemicals
in
TRI.
Compared
to
TRI,
however,
the
information
provided
in
the
permit
applications
has
very
different
characteristics
in
terms
of
chemical
coverage,
completeness,
and
accessibility.

Chemical
coverage:
Title
V
requires
that
all
permit
applicants
provide
qualitative
descriptions
of
their
emissions,
including
all
criteria
pollutants
and
all
189
toxic
pollutants.
Quantitative
emissions
estimates
are
usually
required
by
the
permitting
authorities
only
when
more
information
is
needed
to
resolve
a
dispute
over
applicable
requirements,
such
as
whether
or
not
the
facility
should
be
October,
2003
42
classified
as
a
major
source.
In
the
event
that
there
is
no
dispute,
no
emissions
estimates
are
required.
In
situations
where
estimates
are
required,
facilities
are
allowed
to
use
"
available
information,"
which
includes
EPA
emission
factors
documents,
"
reasonable
engineering
projections,"
as
well
as
test
data.
EPA's
policy,
as
outlined
in
the
"
White
Paper
for
Streamlined
Development
of
Part
70
Permit
Applications,"
is
to
request
just
enough
information
to
convince
the
permitting
authorities
that
the
facility
meets
all
emissions
requirements.
According
to
the
White
Paper,
"
emissions
information
for
these
purposes
does
not
always
need
to
be
detailed
or
precise."
(
U.
S.
EPA,
1995c)
For
most
pollutants,
it
is
not
likely
that
Title
V
Part
70
emissions
data
could
substitute
for
TRI
release
reporting.

Industry/
facility
coverage:
There
are
no
SIC
or
industry
limitations
for
major
facilities.
For
non­
major
sources,
decisions
on
permit
applicability
are
made
on
a
source
category
by
source
category
basis.
Decisions
are
currently
being
made
on
Title
V
Part
70
permit
requirements
for
non­
major
sources
as
to
which
source
categories
will
be
exempted,
deferred,
or
required
to
obtain
permits
(
Seitz,
1995).
However,
as
stated
above
in
the
chemical
coverage
discussion,
actual
emissions
estimates
are
required
only
when
attempting
to
settle
a
dispute
over
facility
status
or
other
applicable
requirements.
Therefore,
the
majority
of
Title
V
permit
applicants
are
not
required
to
furnish
any
quantitative
data.
Title
V's
facility
coverage
is
likely
to
be
different
from
TRI's
facility
coverage,
due
to
the
differences
in
applicability
criteria
between
the
two
systems.
While
TRI
has
a
manufacture,
process,
or
use
threshold
for
toxic
chemicals,
Title
V
has
applicability
criteria
based
on
HAPs
emissions
(
see
above).

Release
statistics/
reporting
frequency:
Emissions
information
is
required
at
the
time
of
permit
application,
renewal,
and
modification.
Since
permits
are
typically
renewed
every
five
years,
most
facilities
will
report
their
information
every
five
years
(
Swanson,
1995).
Other
possible
situations
for
emissions
information
updates
include
new
applicable
requirements
not
requiring
permit
modifications,
and
changed
compliance
status
of
facilities.
Even
if
the
information
was
as
complete
as
TRI,
the
duration
between
reports
is
much
longer
than
the
one
year
timespan
between
TRI
reports.

Accessibility:
The
U.
S.
EPA
does
not
maintain
a
central
inventory
of
the
emissions
data
contained
in
the
permit
applications
(
Southerland,
1995).
This
information
is
kept
at
the
state
and
regional
levels,
making
it
difficult
to
access,
especially
in
comparison
to
TRI.

Summary
of
Availability
of
Fugitive/
Non­
Point
and
Stack/
Point
Air
Emissions
Data
None
of
the
data
sources
described
above
can
be
used
in
place
of
TRI
fugitive
or
stack
emissions
data.
Although
AFS
provides
good
data
on
criteria
pollutants,
only
one
criteria
pollutant
(
lead)
is
reportable
as
a
discrete
chemical
substance
on
both
AFS
and
TRI.
Further,
AFS
HAP
release
information
is
not
a
good
substitute
for
TRI
because
data
for
EPCRA
Section
313
toxic
chemicals
are
generally
unavailable,
and
speciation
cannot
reliably
generate
accurate
facility­
specific
HAP
October,
2003
43
emissions
estimates.
In
addition,
fugitive
emissions
are
not
specifically
flagged
within
AFS.
Some
state
air
emissions
inventories
such
as
California's
may
collect
air
emissions
information
that
is
as
complete
or
even
more
detailed
than
TRI.
However,
not
all
states
maintain
inventories,
and
there
are
still
many
unresolved
data
compatibility
and
accessibility
issues.
The
Great
Lakes
inventory
is
limited
in
its
geographic
coverage
as
well
as
the
number
of
chemicals
it
contains,
uses
different
data
collection
techniques
than
TRI,
and
relies
on
state­
generated
estimates
in
lieu
of
facility
reported
release
data.
Emissions
information
on
air
toxics
contained
within
Title
V
Permit
documents
also
are
not
a
substitute
for
TRI
emissions
in
terms
of
chemical
coverage,
frequency
of
reporting,
or
accessibility.

Direct
Discharges
to
Receiving
Streams
or
Water
Bodies
Form
R
requires
that
facilities
report
total
direct
discharges
to
receiving
streams
or
water
bodies.
Releases
are
reported
in
pounds
per
year
and
include
the
name
of
the
receiving
stream
or
water
body.
The
following
section
compares
and
contrasts
the
Permit
Compliance
System
(
PCS)
with
TRI
to
determine
whether
it
could
be
used
as
a
substitute
for
TRI
chemical
release
data.
In
comparing
and
contrasting
PCS
with
TRI,
several
variables
are
considered.
Key
criteria
include:
chemical
coverage,
industry
and
facility
coverage,
release
statistics,
reporting
frequency,
and
accessibility.

The
Permit
Compliance
System
(
PCS)
tracks
permit
compliance
and
enforcement
status
of
facilities
regulated
by
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
under
the
Clean
Water
Act
(
CWA)
and
is
managed
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance
(
OECA).
PCS
tracks
all
point
source
discharges
to
surface
waters,
but
does
not
include
indirect
releases
such
as
discharges
to
Publicly
Owned
Treatment
Works
(
POTWs).
Permits
are
classified
as
major
or
minor
based
on
facility
discharge
characteristics
such
as
toxic
pollutant
potential
and
flow
volume.
Facilities
are
classified
as
"
major"
based
upon
a
scoring
system
which
considers
toxic
pollutant
potential,
flow/
streamflow
volume,
conventional
pollutant
loading,
public
health
impacts,
water
quality
factors,
and
proximity
to
near
coastal
waters.

Major
dischargers
report
compliance
with
their
NPDES
permit
limits
through
Discharge
Monitoring
Reports
(
DMRs).
DMRs
are
generally
submitted
on
a
monthly
basis
to
state
and
regional
EPA,
providing
detailed
information
on
reported
measurement
values
for
those
chemicals
regulated
within
their
NPDES
permit.
Data
collected
via
DMRs
are
entered
into
PCS,
including:
concentration
and
quantity
values
for
regulated
pollutants,
and
the
type
of
permit
violation
(
if
any).
EPA
uses
PCS
to
produce
the
Quarterly
Non­
Compliance
Report
(
QNCR),
a
public
document
listing
NPDES
permit
violations.
EPA
requires
monitoring
data
only
for
those
permits
classified
as
major.
For
minor
facilities
the
database
contains
only
general
facility­
level
information.
It
is
important
to
note,
however,
that
all
NPDES
permittees
(
both
major
and
minor)
are
required
to
file
DMRs
with
their
State
or
Regional
NPDES
authorities.
Therefore,
monitoring
October,
2003
44
data
for
minor
facilities
are
available
from
the
files
of
these
permitting
authorities,
which
are
open
to
the
public.
Data
for
minor
facilities
are
not
maintained
through
the
national
database.

There
are
several
differences
between
TRI
and
PCS
stemming
primarily
from
the
divergent
purposes
of
the
two
systems.
Unlike
TRI,
PCS
is
a
permit
tracking
system
rather
than
a
toxic
pollutant
loadings
system.
The
differing
data
needs
of
these
two
types
of
systems
make
it
problematic
to
transfer
information
from
one
to
the
other.
For
example,
although
EPA
requires
the
reporting
of
PCS
data
in
mass
units
unless
it
is
impracticable
to
do
so,
the
fact
that
PCS
monitoring
data
can
be
reported
in
either
mass
units
or
as
concentrations
can
make
comparing
the
releases
of
two
facilities
a
complicated
issue.
Data
in
units
of
concentration
data
can
be
converted
to
mass
units
only
if
flow
data
also
exist.

Chemical
coverage:
A
facility's
permit
record
may
not
include
all
pollutants
actually
being
discharged
by
the
facility.
The
monitoring
data
available
through
PCS
for
major
dischargers
include
only
those
chemicals
for
which
a
monitoring
requirement
has
been
set
in
the
permit.
Federal
effluent
guidelines
exist
for
many
major
industries
and
determine
chemicals
for
which
monitoring
is
required.
However,
the
guidelines
may
not
consider
the
same
chemicals
across
industries.
Therefore,
two
facilities
in
different
industries
with
similar
chemical
releases
may
not
necessarily
both
report
the
same
set
of
chemicals
to
PCS.
Also,
for
facilities
not
covered
by
a
Federal
effluent
guideline,
and/
or
if
additional
controls
are
needed
to
ensure
compliance
with
water
quality
standards,
it
is
left
to
the
discretion
of
the
permit
writers
to
decide
which
pollutants
will
be
included
in
the
permit,
how
often
monitoring
must
occur,
and
which
parameters
and
units
of
measure
are
to
be
used.

Because
NPDES
permit
discharge
limits
are
written
in
terms
of
PCS
pollutant
parameters,
and
not
CAS
numbers,
much
of
the
data
contained
within
PCS
is
not
chemical­
specific.
An
example
of
a
non
chemical­
specific
PCS
parameter
is
parameter
00535,
Suspended
Volatile
Solids.
It
may
be
difficult
to
determine
the
mix
of
specific
chemicals
when
data
are
reported
using
non
chemicalspecific
parameters.
In
addition,
in
many
cases,
multiple
parameters
are
reported
for
the
same
chemical,
representing
different
measures
of
the
same
chemical.
For
example,
PCS
parameter
numbers
01049,
01050,
and
01051
represent
dissolved,
suspended,
and
total
lead,
respectively.
Because
there
may
be
several
parameters
for
a
single
chemical,
it
becomes
difficult
to
aggregate
their
masses.
Chemical
Abstract
Service
(
CAS)
registry
numbers
are
not
reported
for
chemical
parameters;
however,
parameters
can
sometimes
be
linked
to
a
specific
CAS
number
using
an
EPA
database
called
SUPERCAS.
SUPERCAS
is
an
edited
and
augmented
version
of
the
CAS
matching
file
contained
in
STORET,
an
EPA
water
monitoring
data
system.
All
PCS
parameters
are
contained
within
SUPERCAS,
and
although
SUPERCAS
is
not
updated
regularly,
the
addition
of
new
parameters
to
PCS
is
a
relatively
infrequent
event.

Industry/
facility
coverage:
EPA
requires
monitoring
data
only
from
those
facilities
classified
as
major
dischargers.
For
minor
facilities,
the
database
contains
only
general
facility­
level
October,
2003
45
information.
While
the
database
tracks
about
65,000
active
permits,
only
about
ten
percent
of
these
are
classified
as
major.
A
state
may
choose
to
submit
monitoring
data
for
minor
facilities
but
generally
such
data
are
unavailable.
Unlike
TRI,
PCS
does
not
restrict
reporting
requirements
to
specific
industry
groups
or
exempt
facilities
with
less
than
the
equivalent
of
ten
employees.

Release
statistics:
The
release
statistics
reported
for
PCS
parameters
depend
on
the
permit
specifications.
Often,
releases
are
reported
as
concentrations
in
parts
per
million
(
ppm)
or
milligrams
per
liter
(
mg/
L),
as
opposed
to
units
of
mass
such
as
pounds
per
year
(
lb/
yr)
or
kilograms
per
year
(
kg/
yr)
(
Rubin,
1995).
If
discharges
are
reported
in
mass
units,
a
maximum
daily
discharge
also
is
reported.
The
basis
for
these
reported
data
varies
among
facilities.
For
example,
a
facility
may
sample
its
effluent
only
once
per
month
and
still
report
a
monthly
maximum
discharge.
If
discharges
are
reported
as
concentrations,
a
minimum,
maximum,
and
average
value
may
be
reported,
although
a
significant
percentage
of
dischargers
report
only
a
maximum
concentration
(
Rubin,
1995).
In
general,
flow
rates
are
available
for
converting
concentration
units
to
units
of
mass
(
i.
e.,
kg/
year
can
be
calculated
by
multiplying
mg/
L
by
the
annual
flow
rate),
although
in
some
cases
the
flow
rates
are
not
provided.

A
complex
algorithm
is
required
to
estimate
annual
loadings
from
PCS
data.
The
algorithm
must
first
identify
facilities
reporting
quantities
in
pounds
or
kilograms,
favoring
mean
values
over
maximum
or
minimum
values.
For
facilities
with
no
loadings
data,
monthly
concentration
data
must
be
linked
and
multiplied
by
each
month's
corresponding
flow
data,
again
favoring
mean
values
over
maximum
and
minimum
values.
Additionally,
the
algorithm
must
convert
the
results
to
a
single
unit
of
measure.
PCS
facilities
report
at
least
26
different
units
of
measure
and
15
units
of
flow
(
e.
g.,
gallons,
thousands
of
gallons,
and
millions
of
gallons
in
terms
of
minutes,
hours,
days,
and
years).
This
step
is
repeated
for
each
month
and
summed
to
produce
an
annual
loadings
estimate.
If
twelve
months
of
data
are
not
available,
an
average
value
can
be
used
to
produce
an
annual
estimate.

Facility
releases
may
be
overestimated
for
several
reasons:
1)
facilities
that
release
chemicals
below
their
detection
limit
(
e.
g.,
between
0­
6
ppm)
will
sometimes
report
releases
at
the
detection
limit
(
e.
g.,
6
ppm)
in
order
to
indicate
the
likely
presence
of
a
chemical;
2)
facilities
with
episodic
releases
may
be
required
to
report
releases
at
their
peak
level
and
not
an
average
annual
quantity;
and
3)
Facilities
might
have
multiple
monitoring
points
along
the
same
outfall
route,
resulting
in
double
counting.
Such
reporting
specifications
may
be
appropriate
given
the
purpose
of
the
NPDES
permit;
however,
PCS
data
will
not
always
be
appropriate
for
estimating
annual
pollutant
loadings.

Reporting
frequency:
Discharge
Monitoring
Reports
are
generally
submitted
monthly
to
State
or
Regional
EPA;
therefore,
reporting
frequency
is
not
a
limitation
when
compared
to
TRI.
October,
2003
46
Accessibility:
PCS
data
are
accessible
through
the
EPA
Mainframe,
the
ENVIROFACTS
database,
as
well
as
RTK
NET.
The
EPA
Mainframe
is
not
accessible
to
the
general
public.

Conclusion
of
Availability
of
Data
on
Direct
Discharges
to
Water
Because
PCS
is
a
permit
tracking
system,
and
not
a
pollutant
loadings
system,
it
cannot
provide
a
suitable
substitute
for
TRI
release
data.
Within
PCS,
release
data
are
only
available
for
major
facilities,
and
are
reported
in
terms
of
PCS
parameters,
not
specific
chemicals.
These
chemical
parameters
cannot
always
be
easily
converted
into
CAS
numbers.
In
addition,
only
those
chemical
parameters
actually
specified
in
the
facility
permit
have
monitoring
requirements.
In
some
cases,
data
may
be
reported
in
units
of
concentration
rather
than
units
of
mass.
If
flow
rates
also
are
reported,
concentration
data
can
be
used
to
estimate
total
releases,
although
there
are
several
complicating
factors
in
producing
such
an
estimate.

Underground
Injection
and
Land
Disposal
On­
Site
Section
313
gives
EPA
the
authority
to
require
reporting
of
on­
site
surface
and
subsurface
(
i.
e.,
underground
injection)
releases
to
land.
On­
site
surface
releases
to
land
include
the
following
subcategories:
RCRA
subtitle
C
landfills,
other
landfills,
land
treatment/
application
farming,
RCRA
subtitle
C
surface
impoundment,
other
surface
impoundment,
and
other
disposal.
The
Biennial
Reports
(
part
of
the
RCRAInfo
database)
require
reporting
of
both
underground
injection
and
other
on­
site
releases
to
land.
The
following
analysis
compares
and
contrasts
Biennial
Reports
with
TRI
to
determine
whether
it
can
be
used
as
a
substitute
for
TRI
underground
injection
and
on­
site
releases
to
land
data.

Under
Section
3002(
a)(
6)
of
the
Resource
Conservation
and
Recovery
Act,
facilities
that
generate
an
amount
of
hazardous
waste
that
exceeds
a
defined
threshold
are
required
to
submit
biennial
reports
on
that
waste
to
EPA
(
or
to
state
agencies
that
run
RCRA
programs).
These
reports
include
information
on
the
quantity
and
nature
of
hazardous
waste,
the
disposition
of
all
hazardous
waste,
efforts
undertaken
to
reduce
volume
and
toxicity
of
waste
generated,
and
the
changes
in
volume
and
toxicity
of
waste
actually
achieved
during
the
year.
Facilities
which
treat,
store,
or
dispose
of
hazardous
wastes
must
provide
information
on
the
methods
of
treatment,
storage
or
disposal.
Data
are
reported
to
the
states
and
regions,
which
then
provide
it
to
EPA
headquarters.
Information
is
entered
into
RCRAInfo,
which
is
maintained
by
the
Office
of
Solid
Waste
and
Emergency
Response
(
OSWER).

RCRAInfo
is
EPA's
comprehensive
information
system,
providing
access
to
data
supporting
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
of
1976
and
the
Hazardous
and
Solid
Waste
Amendments
(
HSWA)
of
1984.
RCRAInfo
replaces
the
data
recording
and
reporting
abilities
of
the
Resource
Conservation
and
Recovery
Information
System
(
RCRIS)
and
the
Biennial
Reporting
System
(
BRS).

The
RCRAInfo
system
allows
tracking
of
many
types
of
information
about
the
regulated
October,
2003
47
universe
of
RCRA
hazardous
waste
handlers.
RCRAInfo
characterizes
facility
status,
regulated
activities,
and
compliance
histories
and
captures
detailed
data
on
the
generation
of
hazardous
waste
from
large
quantity
generators
and
on
waste
management
practices
from
treatment,
storage,
and
disposal
facilities.

Using
cutting­
edge
technology
and
a
simple
architecture,
RCRAInfo
provides
a
convenient
user
interface
for
the
program
staff
and
managers
of
the
EPA
and
its
State
and
Tribal
partners.
RCRAInfo
data
is
made
available
to
the
public
through
EPA's
Envirofacts
Data
Warehouse
through
monthly
extracts
or
through
the
Right
to
Know
Network.

Biennial
Reports
provide
an
overview
of
the
progress
of
the
RCRA
program
through
tracking
trends
in
hazardous
waste
generation
and
management.
Large
quantity
generators
(
LQGs)
and
treatment,
storage,
and
disposal
facilities
(
TSDFs)
are
required
to
report
every
two
years.
Large
quantity
generators
are
defined
as
facilities
that
generate
2,200
pounds
of
total
RCRA
hazardous
waste
per
month;
generate
2.2
pounds
of
RCRA
acute
hazardous
waste
a
month,
or
accumulate
this
amount
during
the
year;
or
generate
or
accumulate
more
than
220
pounds
annually
of
spill
cleanup
material
contaminated
with
RCRA
acute
hazardous
waste.
Biennial
Reports
contain
data
for
about
23,000
LQGs
and
4,000
TSDFs.

There
are
several
important
differences
between
Biennial
Reports
and
TRI.
Although
Biennial
Reports
maintain
a
large
amount
of
useful
data,
it
nevertheless
cannot
duplicate
the
information
contained
within
TRI.
Waste
codes
used
in
Biennial
Reports
do
not
necessarily
map
to
unique
chemicals,
quantities
of
specific
chemicals
in
a
wastestream
cannot
be
determined,
and
reporting
is
less
frequent
than
for
TRI.
As
detailed
below,
for
these
reasons
Biennial
Reports
are
not
a
reasonable
substitute
for
TRI.

Chemical
coverage:
Biennial
Reports
contain
data
on
hazardous
wastes
as
defined
by
RCRA.
RCRA
hazardous
waste
is
designated
as
either
"
listed
waste"
or
"
characteristic
waste".
Listed
wastes
have
been
identified
as
hazardous
as
a
result
of
EPA
investigations
of
particular
industries
or
because
EPA
has
specifically
recognized
a
commercial
chemical
waste's
toxicity.
Listed
wastes
appear
in
40
CFR
Part
261.
Characteristic
wastes
are
determined
hazardous
because
they
exhibit
one
or
more
of
the
following
"
characteristics":
ignitability,
corrosivity,
reactivity,
or
toxicity.

The
primary
difficulty
with
waste
codes
is
that
not
all
waste
codes
used
in
Biennial
Reports
reporting
map
directly
to
a
single,
unique
chemical.
For
example,
waste
code
F004
is
defined
as:

The
following
spent
non­
halogenated
solvents:
cresols,
cresylic
acid,
and
nitrobenzene;
all
spent
solvent
mixtures/
blends
containing,
before
use,
a
total
of
ten
percent
or
more
(
by
volume)
of
one
or
more
of
the
above
non­
halogenated
solvents
or
those
solvents
listed
in
F001,
F002,
and
F005;
and
still
bottoms
from
the
recovery
of
these
spent
solvents
and
spent
solvent
mixtures.
October,
2003
48
Listed
wastes
that
are
categorized
as
non­
specific
source
waste
(
the
F
wastes,
such
as
F004
defined
above),
specific
source
wastes
(
the
K
wastes),
and
three
of
the
characteristic
waste
categories
(
D001,
D002,
and
D003)
cannot
be
matched
to
a
specific
chemical.
Listed
wastes
categorized
as
commercial
chemical
products
(
the
P
and
U
wastes),
and
characteristic
wastes
meeting
the
toxicity
characteristic
(
D004­
D043)
each
may
represent
a
single,
unique
chemical,
but
they
also
may
represent
a
mixture
of
various
materials
of
which
the
identified
chemical
is
but
a
small
proportion.

Industry/
facility
coverage:
Biennial
Reports
reporting
requirements
do
not
require
that
specific
industries
or
SIC
codes
report;
however,
certain
waste
categories
are
excluded
(
40
CFR
§
§
261.4
and
261.3(
c)(
2)(
ii)).
For
example,
the
so­
called
the
Bevill
exemption
(
40
CFR
§
261.4(
b)(
7))
classifies
solid
wastes
resulting
from
the
extraction,
beneficiation,
and
processing
of
ores
and
minerals
(
including
coal,
phosphate
rock
and
overburden
from
the
mining
of
uranium
ore)
as
nonhazardous
solid
wastes
and
therefore
not
subject
to
Biennial
Reports
reporting.
Extraction
and
beneficiation
wastes,
plus
20
special
mineral
processing
wastes
(
listed
under
40
CFR
§
261.4(
b)(
7)),
fall
under
RCRA
Subtitle
D
classification.
TRI
now
requires
reporting
from
the
mining
industry.
In
addition,
emission
control
wastes,
which
are
prominent
wastes
within
the
electric
utilities
industry,
are
excluded
from
Biennial
Reports
reporting.
Electric
utilities
represent
an
industrial
group
being
considered
for
addition
to
TRI.
The
full
list
of
wastes
that
are
excluded
from
Biennial
Reports
reporting
include
the
following:

Acid
Agriculture,
Irrigation
Cement
Kiln
Dust
Chromium,
Leather
Tanning
Drilling
Fluid
Emission
Control
Waste
Fertilizer
Household
Mining
Mining,
In
situ
Mining,
Overburden
Nuclear
Petroleum­
contaminated
Media
and
Debris
Precipitation
Runoff
Pulping
Liquor
Sewage,
Domestic
Sewage,
Mixture
Wastewater,
Point
Source
Discharge
Wood,
Wood
Products
October,
2003
5
The
"
mixture
rule"
and
the
"
derived­
from"
rule
were
struck
down
by
a
1991
D.
C.
Circuit
Court
ruling,
but
at
the
court's
suggestion,
EPA
has
temporarily
reenacted
the
rules
on
an
interim
basis
while
it
develops
a
new
rule
to
consider
them.
49
Release
statistics:
While
some
of
the
waste
codes
used
in
Biennial
Reports
to
identify
waste
streams
may
refer
to
a
single,
unique
chemical
(
i.
e.,
a
specific
CAS
number),
others
do
not.
In
addition,
a
waste
stream
can
be
identified
by
multiple
waste
codes
(
e.
g.,
a
waste
stream
can
simultaneously
be
ignitable,
contain
spent
halogenated
solvents,
contain
benzene,
etc.).
At
present,
there
is
no
mechanism
to
apportion
the
waste
stream
volume
to
particular
waste
codes
where
multiple
codes
are
reported.

The
"
mixture
rule"
and
"
derived­
from"
rule
were
adopted
by
EPA
in
1980
and
affect
the
data
reported
to
Biennial
Reports.
5
The
derived­
from
rule
provides
that
wastes
derived
from
a
listed
hazardous
waste
(
such
as
the
ash
from
incineration
of
a
listed
waste)
also
are
deemed
hazardous
waste.
The
mixture
rule
provides
generally
that
any
mixture
of
listed
hazardous
and
nonhazardous
waste
are
considered
hazardous
waste
(
although
there
are
important
exceptions).
RCRA
waste
streams
are
often
a
mixture
of
one
or
more
toxic
chemicals
contained
at
various
concentrations
in
a
non­
hazardous
matrix
(
e.
g.,
railroad
gravel
or
water).
From
the
reported
data,
it
is
not
possible
to
determine
the
fraction
of
the
entire
waste
stream
that
is
composed
of
a
particular
hazardous
chemical.
While
it
is
evident
that
the
chemical
concentration
is
adequate
to
result
in
the
waste
stream
being
defined
as
hazardous
(
e.
g.,
the
chemical
concentration
exceeds
a
certain
threshold),
no
more
detailed
determination
regarding
the
quantity
of
the
hazardous
component
released
can
be
drawn.

Reporting
frequency:
LQGs
and
TSDFs
submit
Biennial
Reports
data
on
a
biennial
basis.
In
contrast,
TRI
reporting
occurs
on
an
annual
basis.

Accessibility:
Biennial
Reports
are
accessible
through
the
EPA
Mainframe,
the
ENVIROFACTS
database,
as
well
as
RTK
NET
(
See
Attachment
B­
3).
The
EPA
Mainframe
is
not
accessible
to
the
general
public.

Conclusion
on
Availability
of
Data
on
On­
Site
Releases
to
Land
Biennial
Reports
require
individual
reporting
of
underground
injections
on­
site
as
well
as
on­
site
releases
to
land,
as
does
TRI.
However,
only
half
of
the
waste
codes
used
in
Biennial
Reports
can
be
assumed
to
identify
individual
chemicals.
In
addition,
the
waste
classification
system,
including
the
"
mixture
rule"
and
"
derived­
from"
rules,
results
in
waste
quantities
being
reported
to
Biennial
Reports
that
do
not
identify
quantities
of
the
individual
chemicals.
The
quantity
reported
to
Biennial
Reports
represents
the
quantity
of
the
entire
waste
stream,
and
not
individual
chemicals.
Therefore,
Biennial
Reports
is
not
a
good
substitute
for
TRI
because
it
is
not
possible
to
reliably
estimate
the
releases
of
a
particular
toxic
chemical
to
underground
injection
on­
site
or
releases
to
land
on­
site
from
Biennial
Reports.
October,
2003
50
Discharges
to
a
POTW
Section
313
gives
EPA
the
authority
to
require
that
facilities
report
information
on
annual
discharges
to
POTWs
(
Public
Owned
Treatment
Works),
including
the
name
and
location
of
the
POTW.
Although
Biennial
Reports
requires
some
reporting
of
discharges
to
POTWs,
and
PCS
allows
for
reporting
of
indirect
discharges
to
water,
neither
system
provides
information
about
POTW
discharges
at
TRI's
level
of
detail
and
completeness.

The
RCRAInfo
system,
which
contains
data
from
the
biennial
reports
of
large
quantity
generators
(
LQGs)
and
treatment,
storage
and
disposal
facilities
(
TSDFs),
also
requires
reporting
of
some
discharges
to
POTWs.
Several
limitations
associated
with
Biennial
Reports
data,
however,
are
described
above.
In
addition,
hazardous
waste,
once
mixed
with
domestic
sewage
and
sent
to
a
POTW
for
treatment,
is
no
longer
considered
a
hazardous
waste
and
is
therefore
not
reported
to
RCRAInfo.

Section
1004(
27)
of
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
provides
that
once
hazardous
waste
is
discharged
directly
to
waters
of
the
United
States,
the
waste
is
not
subject
to
Biennial
Reports
reporting.
Hazardous
waste
must
be
reported
only
if
it
receives
on­
site
treatment
or
is
stored
in
a
RCRA
permitted
unit
prior
to
discharge.
If
it
receives
treatment
or
is
stored
in
an
exempt
unit
(
e.
g.,
tanks
or
totally
enclosed
treatment
units),
the
waste
is
reported
only
if
the
generator
qualifies
as
a
large
quantity
generator,
although
the
exempt
waste
is
not
counted
when
determining
whether
a
facility
is
a
Large
Quantity
Generator.
TRI
provides
no
exemption
for
discharges
to
POTWs
which
receive
no
prior
treatment.

Although
the
Permit
Compliance
System
(
PCS)
includes
indirect
discharge
data
elements,
PCS
does
not
require
reporting
of
indirect
discharges
(
i.
e.,
discharges
that
pass
through
a
POTW
before
entering
a
waterbody,
in
contrast
to
waste
discharged
directly
to
a
waterbody).
States
have
the
option
of
including
indirect
discharge
data,
although
very
few
require
that
this
data
be
reported
(
Rubin,
1995).

Transfers
to
Other
Off­
Site
Locations
EPCRA
Section
313
gives
EPA
the
authority
to
require
that
facilities
reporting
to
TRI
report
transfers
to
off­
site
locations,
including
the
name,
location,
and
RCRA
ID
number
of
the
off­
site
location.
The
Biennial
Reports,
which
contains
hazardous
waste
data
from
large
quantity
generators
(
LQGs)
and
treatment,
storage
and
disposal
facilities
(
TSDFs),
also
requires
reporting
of
off­
site
transfers
on
its
Form
GM.
Information
requested
by
RCRAInfo
includes
the
EPA
ID
of
the
facility
to
which
the
waste
was
shipped,
the
processes
used
to
treat,
recycle,
or
dispose
of
the
waste
at
the
off­
site
facility,
the
off­
site
availability
code,
and
the
total
quantity
of
waste
shipped
during
the
report
year
(
see
discussion
above
of
underground
injection
and
land
disposal
for
a
more
complete
description
of
Biennial
Reports).
Biennial
Reports
also
provides
data
on
the
volume
of
hazardous
waste
shipped
off­
site
for
land
disposal,
a
release
end­
point
of
relevance
to
TRI.
October,
2003
51
There
are
several
difficulties
associated
with
comparing
Biennial
Reports
data
to
TRI
data,
which
are
described
above
in
the
section
covering
on­
site
releases
to
land.

Review
of
State
Right­
to­
Know
Programs
Under
the
TRI
program,
data
is
submitted
to
both
the
U.
S.
Environmental
Protection
Agency
and
to
the
state
or
tribal
entity
in
whose
jurisdiction
the
reporting
facility
is
located.
With
the
advent
of
the
federally
mandated
TRI
reporting
requirements
and
the
influx
of
this
new
information,
states
with
release
and
transfer
reporting
requirements
of
their
own
changed
their
programs
to
minimize
program
costs
to
industry
and
government.
In
New
Jersey,
for
example,
where
TRI
overlapped
with
state
toxics
reporting
requirements
under
the
New
Jersey
Right­
To­
Know
(
RTK)
program,
the
RTK
reporting
requirements
were
removed
to
minimize
reporting
overlap.
For
more
information
on
state­
expanded
TRI
reporting,
a
detailed
discussion
is
presented
in
the
"
Status
of
State
TRI
Programs"
section
of
the
TRI
Public
Data
Release,
State
Fact
Sheets.
(
U.
S.
EPA,
1999g)
This
section
of
the
Public
Data
Release
contains
a
survey
administered
by
the
National
Conference
of
State
Legislatures
to
all
states
on
their
TRI
data
use
and
expansion
activities.

As
of
1994,
only
Arizona,
Massachusetts,
Minnesota,
and
Wisconsin
required
or
were
planning
to
require
expanded
state
TRI
reporting
to
include
non­
manufacturing
facilities
(
NCSL,
1995).
Under
the
expanded
state
requirements,
non­
manufacturing
facilities
are
required
to
file
Form
Rs
with
the
state,
but
are
not
required
to
file
with
the
federal
EPA.
In
addition,
some
states
require
facilities
to
report
release
information
beyond
that
required
by
the
federal
TRI
program.
Overall,
however,
the
additional
data
collected
by
states
are
far
less
complete
and
uniform
than
would
be
available
under
an
expanded
federal
TRI
program.
Descriptions
of
how
state
programs
differ
from
federal
TRI
requirements
are
given
below.

Massachusetts
The
Massachusetts
Toxics
Use
Reduction
Act
of
1989
(
TURA)
requires
companies
to
report
on
their
toxic
chemical
use,
while
TRI
requires
companies
to
report
their
toxic
chemical
releases.
TURA
covers
facilities
in
the
following
SIC
codes:

mining
(
SIC
codes
10­
14)
manufacturing
(
SIC
codes
20­
39),
transportation,
communications,
utilities
(
SIC
40,
44­
49),
wholesale
trade
(
SIC
50
and
51),
personal
services
(
SIC
72),
business
services
(
SIC
73),
automotive
repair,
services,
and
parking
(
SIC
75),
and
miscellaneous
repair
services
(
SIC
76).
October,
2003
52
Initially,
TURA
covered
the
same
facilities
and
chemicals
as
the
federal
TRI
program.
As
of
1995,
TURA
requirements
expanded
to
include
facilities
under
the
above
SIC
codes
which
use
chemicals
that
are
listed
as
hazardous
substances
under
§
101(
14)
and
§
102
of
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
(
CERCLA).
(
These
chemicals
are
listed
at
40
CFR
§
302.4).
Also,
substances
found
on
the
federal
Comprehensive
Environmental
Response
and
Compensation
Liability
Act
(
CERCLA)
list
are
subject
to
TURA
reporting
and
planning,
except
for
chemicals
that
are
delisted.
There
are
over
1400
chemicals
that
are
subject
to
reporting,
although
only
about
250
have
been
used
and
reported
in
Massachusetts.
Massachusetts
otherwise
uses
the
same
employee
and
manufacture/
process/
use
thresholds
and
chemical
list
as
the
federal
TRI
program
(
TURI,
1994).
Federal
facilities
are
exempt
from
TURA
reporting
Facilities
covered
under
TURA
must
file
an
annual
report
called
a
Form
S
(
similar
to
Form
R)
which
identifies
the
listed
chemicals
used
during
the
year
in
each
production
process,
the
percentage
reduction
of
toxic
by­
products
and
toxic
emissions
compared
to
a
defined
base
year,
and
the
toxic
use
reduction
techniques
used
to
reduce
the
wastes.
Data
from
the
Form
Ss
are
entered
into
the
state
Toxics
Use
Reduction
Inventory.
In
addition,
as
of
1995,
facilities
are
required
to
prepare
a
detailed
toxic
use
reduction
plan
every
two
years
(
MA
DEP,
1993).

Wisconsin
In
1996,
Wisconsin
required
mining
operations
(
SIC
codes
10
through
13)
to
file
Form
Rs
to
the
state.
In
addition,
public
agencies,
public
and
private
educational
facilities,
and
public
and
private
research
facilities
in
Wisconsin
are
subject
to
federal
TRI
reporting
requirements.
Aside
from
the
additional
SIC
codes,
Wisconsin's
Right­
To­
Know
reporting
requirements
are
identical
to
those
of
the
federal
TRI
program
(
NCSL,
1995;
BNA,
1995;
Dunst,
1995)

Conclusion
of
Availability
of
TRI­
like
Data
at
the
State
Level
Although
some
states
have
built
on
the
foundation
of
TRI
data
with
additional
state
reporting
requirements,
their
data
do
not
have
major
redundancies
with,
and
therefore
are
not
substitutes
for,
the
current
TRI
or
the
proposal
to
expand
TRI.
The
advent
of
federally
mandated
TRI
reporting
has
resulted
in
many
states
adopting
Form
R
for
their
state
reporting,
and
provided
a
strong
impetus
for
states
to
remove
redundancies
in
their
own
reporting
in
order
to
minimize
costs
to
facilities
in
their
jurisdictions.
Information
collected
by
states
above
and
beyond
federal
reporting
requirements
may
be
available
in
piecemeal
fashion.

Inventory
Data
For
each
listed
toxic
chemical,
a
regulated
facility
must
complete
data
element
4.1
of
Part
II
of
Form
R,
which
asks
for
the
"
Maximum
Amount
of
the
Toxic
Chemical
On­
Site
at
Any
Time
During
the
Calendar
Year."
Maximum
amounts
(
in
pounds)
are
reported
in
ranges
that
increase
by
powers
of
ten.
Alternative
sources
of
"
maximum
amount
on
site"
chemical
inventory
data
include
EPCRA
Section
312
Tier
I
and
II
reports.
October,
2003
6
The
Extremely
Hazardous
Substances
and
their
TPQs
are
listed
in
40
CFR
Part
355,
Appendices
A
and
B.
53
EPCRA
(
§
311­
312)
requires
that
states
establish
plans
for
local
chemical
emergency
preparedness
and
that
inventory
information
on
hazardous
chemicals
be
reported
by
facilities
to
state
and
local
authorities.
"
Hazardous
chemicals"
are
defined
under
the
Occupational
Safety
and
Hazard
Administration's
(
OSHA)
requirements
­­
essentially
any
chemical
that
poses
physical
or
health
hazards.
The
relevant
regulations
are
detailed
in
40
CFR
§
370.
Data
elements
similar
to
both
TRI
and
Tier
I/
II
reports
make
EPCRA
Tier
I/
II
the
best
candidate
for
an
alternative
source
of
TRI
"
maximum
amount
on
site"
inventory
information.

EPCRA
Section
312
outlines
a
"
two­
tier"
approach
for
annual
inventory
reporting.
All
facilities
that
store
hazardous
or
extremely
hazardous
substances
must
submit
at
least
a
Tier
I
and
often
a
Tier
II
form
as
well.
Tier
I
requires
reporting
on
broad
categories
of
physical
hazards
such
as
fire,
sudden
release
of
pressure,
and
reactivity,
as
well
as
acute
and
chronic
health
hazards.
Upon
request
by
a
Local
Emergency
Planning
Committee
(
LEPC),
State
Emergency
Response
Commission
(
SERC),
or
fire
department,
a
facility
may
be
required
to
submit
the
more
detailed
Tier
II
form
(
which
may
be
submitted
instead
of
the
Tier
I
form).
Tier
II
requires
chemical
specific
information
by
CAS
number.
For
example,
a
Tier
I
report
might
state
that
a
facility
stores
3,000
pounds
of
chemicals
that
pose
chronic
health
hazards,
while
a
Tier
II
form
for
the
same
facility
would
report
1,000
pounds
of
toluene
and
2,000
pounds
of
benzene
on­
site.
Approximately
33
states
require
regulated
facilities
to
submit
Tier
II
forms,
and
most
of
the
remaining
states
recommend
that
facilities
submit
Tier
II
forms.

A
regulated
facility
is
required
to
submit
this
information
to
each
of
the
following
groups:
LEPCs,
SERCs,
and
the
local
fire
department
with
jurisdiction
over
the
facility.
A
facility
must
submit
an
annual
report
for
every
chemical
which
requires
an
MSDS
and
which
exceeds
certain
reporting
thresholds
for
the
amount
of
chemical
stored
on
site
at
any
one
time.
The
reporting
threshold
for
chemicals
listed
under
EPCRA
§
302
as
Extremely
Hazardous
Substances
(
EHSs)
is
the
threshold
planning
quantity
(
TPQ),
or
500
pounds,
whichever
is
lower.
6
For
all
other
chemicals
with
MSDSs,
the
threshold
is
10,000
pounds.
In
general
terms,
the
inventories
contain
information
about
the
maximum
quantity
stored,
the
average
quantity
on­
site
at
any
given
time,
the
location
of
the
chemicals
at
the
facility,
and
the
number
of
days
on­
site.

Chemical
coverage:
The
chemicals
covered
under
Section
312
are
all
those
defined
as
hazardous
or
extremely
hazardous
substances
in
Section
311
(
essentially
any
substance
that
poses
a
health
or
physical
hazard).
All
of
these
substances,
for
which
facilities
must
submit
MSDSs,
are
covered
under
OSHA's
Hazard
Communication
Standard
regulations.
OSHA's
definition
of
"
hazardous
chemical"
not
only
includes
toxic
chemicals
but
also
chemicals
which
are
considered
health
hazards,
irritants,
sensitizers,
corrosive,
fire
hazards,
explosive,
as
well
as
reactive.
Consequently,
many
more
chemicals
are
included
under
OSHA's
rule
than
under
TRI.

Industry/
facility
coverage:
Facilities
that
are
required
to
submit
MSDSs
to
the
state
authorities
for
hazardous
chemicals
on
site
also
must
submit
Tier
I
and/
or
Tier
II
forms.
While
October,
2003
54
there
are
no
SIC
exemptions
for
facilities
that
are
covered
under
the
reporting
threshold
requirements,
facilities
not
included
under
OSHA's
Hazard
Communication
Standard
(
e.
g.,
mines)
do
not
have
to
file
reports.
Because
the
Section
312
thresholds
cannot
be
used
to
determine
whether
a
facility
covered
under
Section
312
also
would
be
covered
under
Section
313
(
e.
g.,
whether
a
facility
which
stores
10,000
lbs.
of
a
toxic
chemical
listed
under
TRI
also
meets
Section
313
thresholds),
the
extent
to
which
facilities
potentially
subject
to
TRI
reporting
would
be
captured
by
Section
312
is
unknown.

Release
statistics/
reporting
frequency:
Facilities
covered
under
EPCRA
Section
312
must
submit
their
Tier
I
and/
or
Tier
II
reports
containing
data
with
respect
to
the
preceding
calendar
year
to
their
respective
states
annually
on
or
before
March
1.

When
completing
a
Tier
II
form,
a
covered
facility
must
report
the
following
information:

The
chemical
name
or
the
common
name
of
the
chemical
and
the
CAS
registry
number
(
as
it
appears
on
the
MSDS);


Indication
of
whether
the
hazardous
chemical
is
an
extremely
hazardous
substance;


Indication
of
whether
the
hazardous
chemical
is
present
at
the
facility
in
its
pure
state
or
in
a
mixture,
and
whether
it
is
a
solid,
liquid,
or
gas;


The
applicable
health
and
physical
hazard
categories;


An
estimate
(
in
ranges)
of
the
maximum
amount
of
the
hazardous
chemical
present
at
the
facility
at
any
time
during
the
preceding
calendar
year
(
e.
g.,
10,000
to
99,999
pounds);


An
estimate
(
in
ranges)
of
the
average
daily
amount
of
the
hazardous
chemical
present
at
the
facility
at
any
time
during
the
preceding
calendar
year;


The
number
of
days
the
hazardous
chemical
was
found
on­
site
at
the
facility;


A
brief
description
of
the
manner
of
storage
of
the
hazardous
chemical
at
the
facility;


A
brief
description
of
the
precise
location
of
the
hazardous
chemical
at
the
facility,
and

An
indication
of
whether
the
owner
or
operator
of
the
facility
elects
to
withhold
location
information
on
a
specific
hazardous
chemical
from
disclosure
to
the
public.

Facilities
that
choose
to
withhold
from
the
public
certain
data
on
hazardous
chemicals
must
nevertheless
provide
the
information
to
the
relevant
authorities
via
the
Tier
II
Confidential
Location
Information
Sheet.
The
information
contained
on
these
sheets
is
not
made
available
to
the
public.
October,
2003
55
Accessibility:
The
general
public
may
access
Tier
I
and
Tier
II
information
on
a
facility
by
facility
basis
by
forwarding
a
written
request
to
either
the
SERC
or
the
LEPC.
Tier
II
information
on
facilities
which
do
not
meet
the
reporting
threshold
requirements
also
may
be
obtained
from
the
SERC
or
the
LEPC
if
a
"
general
need"
can
be
demonstrated
on
the
part
of
the
requester.
In
these
cases,
the
relevant
authorities
will
request
that
the
relevant
facility
or
facilities
fill
out
Tier
II
forms.

The
ability
to
access
state
EPCRA
data
at
a
higher
level
of
aggregation
depends
partly
on
the
information
technology
resources
of
the
state
authority
responsible
for
maintaining
the
data.
Approximately
one
half
of
all
the
states
have
some
type
of
computerized
database,
and
of
those,
five
states
(
Arkansas,
Maryland,
New
Jersey,
Oregon,
and
Rhode
Island)
store
full
Tier
II
data
in
a
modem­
accessible
format.
However,
because
these
databases
were
created
using
different
software
and
possess
different
database
structures,
it
is
a
considerable
challenge
to
aggregate
the
data
contained
within
them.

In
some
states
that
do
not
yet
maintain
computerized
databases
of
Tier
I
and
Tier
II
information,
the
parties
requesting
information
are
required
to
cover
the
copying
and
administrative
costs
of
the
data
retrieval.
Because
some
EPCRA
reporting
programs
are
unfunded,
fees
charged
for
this
service
range
from
low
to
substantial.
In
other
states,
the
requesting
parties
must
go
to
the
office
and
perform
the
copying
themselves
(
ICF,
1996).

Conclusion
on
the
Availability
of
Inventory
Data
Tier
I
forms
only
request
information
based
on
possible
health
and
physical
hazards,
and
do
not
ask
for
chemical­
specific
data.
The
level
of
detail
and
the
number
of
chemicals
covered
in
Tier
II
"
maximum
amount
on
site"
inventory
data
surpasses
the
chemical
inventory
data
requested
on
TRI
Form
R.
Not
all
states,
however,
require
submission
of
Tier
II
forms.
Therefore,
some
of
the
facilities
that
are
covered
under
TRI
do
not
have
to
report
as
detailed
inventory
information
under
EPCRA
Section
312.

There
also
are
significant
difficulties
with
respect
to
public
access
of
Tier
I
and
Tier
II
data.
All
information
is
reported
to
state
authorities;
there
is
no
national
integrated
database.
In
addition,
because
not
all
states
have
set
up
computerized
databases
to
manage
this
information,
extensive
data
retrieval
and
analysis
is
often
both
cumbersome
and
expensive.

Pollution
Prevention
Data
(
P2).
Form
R
requires
that
facilities
report
a
variety
of
information
that
can
be
used
for
pollution
prevention
analyses,
including
non­
quantitative
reporting
of
pollution
prevention
activities,
production
ratios,
and
chemical­
specific
amounts
of
materials
treated,
recycled,
released
(
one­
time,
and
for
the
entire
year),
and
shipped
off­
site
in
wastes.

EPA
Databases
with
Pollution
Prevention
Data
October,
2003
56
Besides
TRI,
waste
prevention
and
management
data
are
collected
at
the
federal­
level
through
RCRA
Biennial
reports.
RCRA
biennial
report
data
are
compiled
in
the
RCRAInfo
database,
as
discussed
above.
The
level
of
chemical
specificity
and
flowthrough
estimates
for
waste
prevention
and
management
information
in
RCRAInfo
and
TRI
are
not
available
in
other
federal
data
sources.

Biennial
Reports
contains
pollution
prevention
information
on
hazardous
waste
large
quantity
generators
and
treatment,
storage,
or
disposal
facilities.
Data
are
collected
primarily
by
states,
and
are
collated
by
EPA
into
the
RCRAInfo
database
system.
States
are
not
required
to
use
official
Biennial
Reports
forms
for
the
submission
of
data;
EPA
transfers
data
on
state
forms
into
the
RCRAInfo
system
as
necessary
(
ICF,
1993).

All
large
quantity
generators
must
submit
the
following
facility­
specific
information
to
RCRAInfo:


whether
any
source
reduction
or
recycling
activities
took
place
during
the
reporting
year,
and

limiting
factors
that
have
affected
source
reduction
and/
or
recycling
activities.

In
addition,
for
each
hazardous
waste
generated,
a
generator
must
specify
the
following
pollutionprevention
related
data:


RCRA
waste
code
and
hazardous
waste
quantity
generated;


efforts
to
reduce
the
volume
and
toxicity
of
wastes,
and

reductions
in
volume
and
toxicity
actually
achieved
compared
with
those
achieved
in
previous
years.

If
a
hazardous
waste
has
been
minimized
as
the
result
of
new
activities
implemented
in
the
reporting
year,
the
generator
also
must
report
the
following
pollution­
prevention
related
information:


quantity
of
waste
recycled;


source
reduction
quantity;
and

waste
minimization
activity
implemented
(
e.
g.,
waste
segregation,
inventory
control).

RCRA
Biennial
reports
provide
some
qualitative
and
quantitative
pollution
prevention
information,
but,
at
a
systems
level,
do
not
have
the
same
facility
or
chemical
coverage
as
TRI.
The
Biennial
Reports
system
is
not
a
substitute
for
TRI
pollution
prevention
data.
RCRA
Biennial
reports
only
include
hazardous
wastes;
pollution
prevention
data
contained
in
TRI
includes
information
on
wastes
or
process
by­
products
in
all
production
phases
and
media.
In
addition,
the
chemical
reporting
universe
is
different
between
the
two
systems.
The
universe
of
toxic
chemicals
regulated
under
TRI
differs
from
the
universe
of
listed
hazardous
wastes
or
chemicals
with
hazardous
waste
characteristics
regulated
by
RCRA.
October,
2003
78.
For
a
detailed
comparison
of
materials
accounting
data
elements
reported
to
TRI,
New
Jersey,
and
Massachusetts,
see
(
U.
S.
EPA,
1995d).
57
Also,
the
facility
universes
captured
by
the
two
systems
are
not
the
same.
RCRA
Biennial
reports
are
only
completed
by
RCRA
large
quantity
generators,
while
TRI
reports
are
required
by
facilities
in
manufacturing
industries
that
exceed
employee
as
well
as
chemical
manufacturing,
process,
and
use
thresholds.
The
Biennial
Reports
facility
universe
is
also
different
due
to
RCRA
waste
exclusions
and
exemptions.
For
example,
wastes
mixed
with
domestic
sewage
that
are
excluded
from
Biennial
Reports
reporting
can
be
an
indirect
water
discharge
that
may
be
covered
under
TRI
reporting.

The
pollution
prevention
reporting
in
Biennial
Reports
contains
information
on
hazardous
waste
minimization
and
recycling
efforts.
Where
this
information
does
overlap
with
TRI
pollution
prevention
reporting,
it
does
not
contain
the
same
level
of
detail.
For
example,
in
some
cases
Biennial
Reports
pollution
prevention
information
applies
to
wastestreams
consisting
of
chemical
mixtures,
while
TRI
pollution
prevention
data
are
chemical
specific.
Since
Biennial
Reports
waste
codes
are
more
general
in
nature
than
CAS
numbers,
a
facility's
waste
mixture
could
change
from
year
to
year,
and
yet
it
might
report
the
same
waste
code.
Lack
of
precision
in
reporting
of
waste
contents
also
could
result
in
a
situation
where
a
facility
reduces
the
aqueous
quantity
of
its
wastes,
and
thus
appear
to
be
preventing
pollution.
However,
by
changing
its
waste
mixture,
the
facility
might
even
increase
the
amount
of
toxic
material
entering
the
wastestream
without
modifying
its
Biennial
Reports
reporting.
That
the
exact
contents
of
a
facility's
waste
mixture
cannot
always
be
determined
may
make
it
difficult
to
extract
chemical­
specific
data
from
Biennial
Reports.

State
Environmental
Agency
Databases
Under
current
TRI
reporting
procedures,
facilities
send
copies
of
all
TRI
reports
to
both
state
and
federal
agencies.
Many
states
currently
rely
on
the
pollution
prevention
data
received
from
TRI
for
planning
and
targeting
purposes
(
U.
S.
EPA,
1993),
and
do
not
require
additional
reporting.
However,
two
states,
New
Jersey
and
Massachusetts,
have
passed
laws
to
collect
materials
accounting
pollution
prevention
data
that
exceeds
that
found
in
Section
8
of
Form
R.
Twelve
other
states
have
pollution
prevention
planning
requirements
in
place,
but
only
Massachusetts
and
New
Jersey
currently
have
mandatory
materials
accounting.
7
Massachusetts
Pollution
Prevention
Reporting:
The
Massachusetts
Toxics
Use
Reduction
Act
(
TURA)
has
required
firms
to
report
on
toxic
use
for
individual
"
production
units"
at
their
facilities
since
July
of
1991.
Facilities
submit
annual
Toxics
Use
Reports
(
Form
S)
to
the
Massachusetts
Department
of
Environmental
Protection
(
MDEP)
as
a
supplement
to
the
TRI
Form
R.
With
the
exception
of
qualitative
source
reduction
pollution
prevention
reporting
requirements
and
production
ratios,
TURA
pollution
prevention
reporting
requirements
are
additional
to
those
collected
by
TRI.

Form
S
records
information
on
the
quantity
of
the
toxic
substance
used
on
a
facility­
wide
and
production
unit
basis.
Form
S
is
divided
into
two
parts:
1)
cover
sheet
and
2)
chemical
reports.
October,
2003
58
The
cover
sheet
contains
general
facility
information,
a
certification
statement,
and
an
identification
of
production
units
at
the
facility.
Form
S
chemical
reports
must
be
filed
on
each
listed
toxic
chemical
manufactured,
processed,
or
otherwise
used
at
greater
than
10,000
pounds
per
year
(
ICF,
1993).
The
form
contains
the
following
information
on
chemical
use
and
pollution
prevention:
facility­
wide
and
production
unit
data
for
each
chemical,
year­
to­
year
reporting
changes,
and
production
unit
reports.

New
Jersey
Pollution
Prevention
Reporting:
New
Jersey
has
collected
toxic
chemical
release
and
pollution
prevention
data
longer
than
the
TRI
program
has
been
in
existence.
Since
1979,
New
Jersey
has
collected
toxic
chemical
release
and
pollution
prevention
data
through
a
variety
of
separate
programs
and
activities,
gradually
narrowing
down
the
scope
of
these
reporting
requirements
as
TRI
was
introduced
and
expanded
to
include
pollution
prevention.
In
fact,
the
results
of
an
Industrial
Survey,
which
collected
release
and
throughput
data
from
15,000
New
Jersey
facilities,
were
used
to
develop
the
list
of
SARA
Title
III
chemicals
(
U.
S.
EPA,
1995d).
For
these
reasons,
New
Jersey
data,
unlike
data
collected
in
Massachusetts,
still
overlaps
somewhat
with
data
collected
on
TRI
Form
R.
New
Jersey
pollution
prevention
data
also
contain
detailed
throughput
information
which
exceeds
that
currently
contained
in
TRI.
These
throughput
data
require
facilities
to
account
for
all
amounts
of
the
chemical
brought
or
produced
on­
site,
shipped
off­
site
in
products,
destroyed
on­
site
through
treatment,
recycled
on­
site,
and
released
to
the
environment
or
shipped
off­
site
in
wastes.

New
Jersey's
additional
reporting
requirements
apply
to
all
TRI
chemicals
and
all
facilities
covered
by
TRI
(
SIC
codes
20­
39).
Originally,
New
Jersey
required
facilities
manufacturing,
processing,
or
using
an
Environmentally
Hazardous
Substance
(
EHS)
to
report
toxic
chemical
release
information
(
U.
S.
EPA,
1995d).
The
original
EHS
list
was
comparable
to
the
list
of
chemicals
generated
by
the
Industrial
Survey
mentioned
above,
and
therefore
similar
to
the
original
SARA
Title
III
list.
The
list
of
chemicals
for
which
New
Jersey
now
collects
toxic
chemical
release
and
pollution
prevention
information
has
been
expanded
to
contain
those
in
the
national
TRI
listing.

Alternative
Sources
of
Emergency
Release
Data
TRI
Form
R
requires
that
facilities
report
the
quantity
of
TRI
listed
chemicals
released
to
the
environment
as
a
result
of
remedial
actions,
catastrophic
events,
or
one­
time
events
not
associated
with
production
processes.
Accidental
release
data
reported
to
TRI
also
are
potentially
reported
to
the
National
Response
Center
(
NRC).
However,
as
discussed
below,
the
NRC
is
a
database
of
initial
notifications,
made
during
or
immediately
after
a
release
occurs.
For
this
reason,
data
within
NRC
may
be
incomplete
or
inaccurate
and
will
not
substitute
for
TRI
emergency
release
data.

Emergency
Response
Notification
System
(
ERNS)
October,
2003
59
The
Emergency
Response
Notification
System
(
ERNS)
is
a
computer
database
containing
information
on
release
notifications
of
oil
and
hazardous
substances
that
have
occurred
throughout
the
United
States
and
have
been
reported
to
the
National
Response
Center
(
NRC)
and
or
one
of
the
10
EPA
Regions.
Initial
notifications,
which
comprise
most
of
the
information
in
ERNS,
supply
preliminary
information
on
a
release
and
are
cited
as
unverified
data.
Depending
on
the
severity
of
the
release
and
any
response
actions
taken,
the
EPA
or
Coast
Guard
On­
scene
Coordinator
(
OSC)
may
obtain
further
information
at
the
site
of
the
release
or
through
discussions
with
state
and
local
officials.
Data
has
been
collected
into
ERNS
since
1987.

ERNS
contains
many
types
of
information
on
specific
notifications
of
releases
of
oil
and
hazardous
substances,
including
the
following:
discharger
information,
date
of
release,
material
released,
cause
of
release,
damage/
injuries/
deaths,
amount
released,
source
of
release,
incident
location,
response
actions
taken,
authorities
notified,
and
environmental
medium
into
which
the
release
occurred.

ERNS
serves
as
a
mechanism
to
document
and
verify
incident­
location
information
as
initially
reported
and
is
utilized
as
a
direct
source
of
easily
accessible
data
needed
for
analyzing
releases
of
oil
and
hazardous
substances.
ERNS
information
is
used
for
guidance
and
regulatory
development,
Congressional
inquiries,
response
preparedness,
compliance
and
enforcement
support,
statistical
and
trend
analyses,
program
planning
and
management,
and
responses
to
requests
for
information
from
the
public.

ERNS
supports
the
release
notification
requirements
of
section
103(
a)
of
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
(
CERCLA),
as
amended;
section
311(
j)
of
the
Clean
Water
Act;
and
sections
300.300
and
300.405
of
the
National
Oil
and
Hazardous
Substances
Contingency
Plan,
which
begins
at
40
CFR
Part
300.

ERNS
is
a
database
of
initial
notifications,
made
during
or
immediately
after
a
release
occurs.
Because
the
data
are
reported
at
such
an
early
stage,
the
exact
details
of
the
release
are
often
unknown
and
are
therefore
not
reported.
It
is
estimated
that
two­
thirds
of
the
193
data
fields
in
ERNS
are
not
completed
for
most
release
notifications.
In
addition,
duplicate
reports
may
appear
in
the
database
because
of
follow
up
calls
that
are
not
identified
as
such
or
observers
reporting
a
release
that
has
already
been
reported.
Approximately
five
percent
of
ERNS
records
are
estimated
to
be
duplicates.
(
U.
S.
EPA,
1995e)

Integrated
Management
Information
System
(
IMIS)
October,
2003
60
IMIS
is
an
OSHA
database
that
contains
records
of
workplace
inspections
conducted
by
OSHA
industrial
hygienists.
Two
general
types
of
inspections
are
conducted
by
OSHA:
1)
Scheduled
or
planned
inspections
which
are
on­
site
enforcement
inspections
to
verify
compliance
with
OSHA
standards,
and
2)
Unplanned
inspections
which
are
investigations
of
workplace
incidents
where
there
is
one
fatality
or
three
or
more
worker
hospitalizations
(
five
or
more
worker
hospitalizations
were
required
to
trigger
an
inspection
before
1993).
Inspection
data
are
input
and
stored
within
IMIS,
providing
a
record
of
OSHA
activities
at
each
workplace
that
has
been
inspected.

OSHA
is
estimated
to
add
more
than
120,000
inspection
records
per
year,
of
which
4,000­
5,000
are
related
to
accidents.
Accident
inspections
include
a
short
description
of
the
incident,
information
regarding
each
worker
that
is
injured,
and
any
hazardous
substances
that
may
be
involved.
It
is
estimated
that
100
incidents
reported
each
year
involve
hazardous
substances.
A
four
digit
hazardous
substance
code
is
entered
into
IMIS
rather
than
a
CAS
number.
The
quantity
of
hazardous
material
released
is
not
entered.
In
addition,
it
can
not
be
assumed
that
the
reported
death
or
injury
was
a
result
of
an
accidental
release
even
in
cases
where
a
hazardous
substance
was
involved.
For
example,
if
a
maintenance
person
cleans
the
inside
of
a
storage
tank
and
is
asphyxiated
by
the
nitrogen
rich
environment,
the
death
is
not
the
result
of
an
"
accidental
release".
(
U.
S.
EPA,
1995e)

Summary
on
Availability
of
Pollution
Prevention
and
Accidental
Release
Data
The
data
systems
discussed
above
cannot
replace
TRI's
pollution
prevention
and
accidental
release
data.
Difficulties
exist
in
chemical
and
facility
coverage,
reporting
frequency,
and
the
level
of
data
detail.
Specifically,
RCRA
Biennial
reports
cannot
easily
be
used
as
a
substitute
for
TRI
pollution
prevention
data.
While
Biennial
Reports
provides
some
qualitative
and
quantitative
pollution
prevention
information,
it
does
not
have
the
same
facility
or
chemical
coverage
as
TRI.
Biennial
Reports
only
includes
hazardous
wastes,
while
TRI
pollution
prevention
data
includes
information
on
wastes
or
process
by­
products
in
all
production
phases
and
media.
Because
Biennial
Reports
collects
data
organized
by
Biennial
Reports
waste
codes,
it
also
lacks
the
chemical­
specific
detail
that
TRI
contains.
In
addition,
the
facility
and
chemical
reporting
universes
are
different
between
the
two
systems.

Overlap
of
State
pollution
prevention
data
with
that
found
in
TRI
is
minimal;
state
data
could
not
be
used
to
replace
current
TRI
pollution
prevention
reporting
requirements.
Under
current
TRI
reporting
procedures,
facilities
send
copies
of
all
TRI
reports
to
both
state
and
federal
agencies.
Many
states
have
come
to
rely
on
this
easily
available
source
of
pollution
prevention
data.
As
Massachusetts
and
New
Jersey
demonstrate,
even
those
states
that
had
taken
a
proactive
role
in
collecting
toxics
release
and
pollution
prevention
data
scaled
back
their
programs
with
the
introduction
of
mandatory
TRI
reporting.
No
state
program
collects
all
of
the
pollution
prevention
data
currently
contained
in
Form
R,
though
some
states
(
e.
g.,
New
Jersey
and
Massachusetts)
augment
TRI
pollution
prevention
data
with
requirements
additional
to
those
contained
in
Section
8
of
Form
R.
These
data,
such
as
materials
accounting
data,
are
used
at
the
October,
2003
61
state
level
for
a
variety
of
purposes,
including
benchmarking
of
facility
pollution
prevention
efforts
and
the
determination
of
toxic
material
flows
in
production
processes.

In
addition,
accidental
release
data
reported
to
ERNS
does
not
substitute
for
TRI
accidental
release
data.
ERNS
is
a
database
of
initial
notifications,
made
during
or
immediately
after
a
release
occurs.
For
this
reason,
data
within
ERNS
may
be
incomplete
or
inaccurate.

Value
Added
from
the
TRI
Reporting
System
In
addition
to
containing
data
not
available
through
other
sources,
TRI
enhances
the
usefulness
and
functionality
of
the
data
by
allowing
public
access
to
the
data,
linking
release
data
across
media
(
e.
g.,
water,
air,
land),
and
providing
definitional
consistency
for
the
units
of
measurement.
These
features
give
TRI
additional
advantages
over
any
emissions
data
system
that
might
be
assembled
from
non­
TRI
sources.

Perhaps
the
most
important
advantage
TRI
possesses
over
non­
TRI
sources
is
the
information
that
can
only
be
found
in
TRI.
As
described,
data
unique
to
TRI
include
chemical­
specific
multimedia
release
information
as
well
as
important
pollution
prevention
information.
For
example,
AFS
currently
only
tracks
a
limited
amount
of
HAP
emissions,
and
Biennial
Reports
does
not
track
hazardous
waste
treatment,
transfer,
or
disposal
at
a
chemical­
specific
level.
TRI
can
provide
this
as
well
as
other
types
of
information
not
available
elsewhere.

Because
an
important
part
of
TRI's
mission
is
to
provide
emissions
data
to
the
public,
many
different
methods
of
access
to
TRI
have
been
implemented.
Data
analysis
difficulties
aside,
access
issues
make
it
very
difficult
for
the
general
public
to
assemble
non­
TRI
data
into
a
TRI­
like
form.
Current
methods
of
accessing
TRI
include
on­
line
resources
such
as
EPA's
Envirofacts,
TRI
Explorer,
the
National
Library
of
Medicine's
TOXNET,
RTK
NET,
electronic
media
such
as
CD­
ROM,
and
printed
media.
TRI
places
all
of
the
information
in
one
location,
and
providing
many
avenues
of
access
to
that
data.

Another
major
problem
associated
with
using
non­
TRI
sources
for
TRI­
like
data
is
linking
facility
release
information
across
various
release
media.
In
the
past,
the
tool
used
to
identify
facilities
reporting
to
multiple
systems
was
the
Facility
Indexing
System
(
FINDS).
FINDS
was
a
centralized
inventory
of
facilities
monitored
or
regulated
by
EPA,
and
served
as
an
index
database
to
other
EPA
Program
Office
databases.
This
system
has
been
replaced
with
the
Facility
Registry
System
(
FRS),
a
system
developed
through
the
assistance
of
the
Facility
Registry
System.

The
above
advantages
notwithstanding,
it
is
important
to
recognize
that
these
systems
have
certain
shortcomings
with
respect
to
any
effort
to
assemble
TRI­
like
information
from
non­
TRI
sources.
For
example,
one
significant
difficulty
with
IDEA
involves
problems
with
the
FINDS
linkages
themselves.
Because
of
various
data
inconsistencies,
many
facilities
are
not
linked
to
all
of
their
permits
through
IDEA,
or
have
incorrectly
linked
permits.
TRI's
reporting
mechanism
helps
to
reduce
this
problem
within
TRI,
where
data
from
a
facility
is
reported
at
one
time
in
one
October,
2003
62
place.
In
addition,
because
IDEA
is
designed
to
primarily
provide
compliance
and
enforcement
data,
the
system
does
not
always
include
emissions
data
even
when
such
data
exists.

The
lack
of
definitional
consistency
also
can
result
in
difficulties
in
understanding
information
aggregated
across
non­
TRI
databases.
A
substantial
amount
of
effort
would
be
required
to
overcome
discrepancies
in
units
of
measure,
chemical
coverage,
reporting
thresholds,
reporting
exemptions,
and
reporting
frequencies
in
the
various
databases.
TRI
overcomes
many
of
these
problems
by
allowing
the
user
to
view
cross­
media
data
using
a
single
set
of
reporting
definitions
and
requirements.

The
different
units
and
data
aggregation
methodologies
used
by
various
non­
TRI
sources
can
lead
to
data
incompatibilities.
For
example,
because
PCS
data
are
reported
in
terms
of
PCS
parameters
(
usually
chemical
concentrations
as
opposed
to
units
of
mass),
some
fairly
involved
calculations
must
take
place
before
that
data
can
be
converted
into
TRI­
like
units.
For
Biennial
Reports,
facilities
report
their
hazardous
waste
throughput
in
terms
of
aggregated
waste
codes,
which
cannot
always
be
easily
broken
down
to
specific
chemicals.
Discrepancies
between
the
way
chemical
information
is
reported
to
the
various
non­
TRI
databases
can
make
it
difficult
or
even
impossible
to
accurately
sum
totals
of
pollutants
across
databases.
Because
all
TRI
release
and
transfer
data
are
reported
in
a
uniform
fashion,
no
such
difficulty
exists
in
TRI.

Databases
often
also
have
different
reporting
frequencies,
which
can
make
it
difficult
to
assemble
high
quality
historical
data
at
the
facility
level.
Biennial
Reports
requires
facilities
to
report
data
every
two
years,
whereas
AFS
requires
but
does
not
enforce
annual
reporting.
Because
TRI
requires
annual
reporting
from
all
covered
facilities,
TRI
effectively
overcomes
this
problem.

In
summary,
the
value
which
TRI
alone
adds
to
the
community
at
large
is
significant.
The
many
technical,
access­
related,
and
data
coverage
problems
associated
with
attempting
to
use
non­
TRI
sources
for
TRI
data
makes
impractical
the
substitution
of
these
sources
for
TRI.

5(
b)
Consultations
EPA
has
consulted
with
a
large
number
of
individuals
and
organizations
throughout
all
segments
of
the
public
in
the
development
and
continued
implementation
of
the
TRI
program.
Since
the
initial
development
of
the
program,
feedback
through
EPA's
outreach
efforts
have
been
received
from
various
organizations,
including
environmental
and
public
interest
groups,
trade
associations,
and
individual
representatives.
This
feedback
is
continually
sought
and
incorporated
in
the
ongoing
evolution
of
the
313
program.

During
the
initial
development
of
the
TRI
program,
EPA
consulted
with
a
large
number
of
individuals
and
organizations
throughout
all
segments
of
the
public
in
developing
the
rule,
form,
and
instructions.
This
consultation
has
continued
throughout
the
operation
of
the
program,
and
has
been
expanded
due
to
the
proposed
expansion
of
TRI
to
include
additional
industry
groups.
October,
2003
63
Among
the
industry­
oriented
organizations
that
are
or
have
been
involved
with
the
TRI
program
are:

American
Association
of
Exporters
and
Importers
American
Chemistry
Council
American
Chemical
Society
American
Coke
and
Coal
Chemical
Institute
American
Gas
Association
American
Iron
and
Steel
Institute
American
Petroleum
Institute
American
Pharmaceutical
American
Public
Power
Association
American
Textile
Manufacturers
Institute
American
Trucking
Association
American
Warehouse
Association
Air
Transport
Association
American
Wood
Preservers
Institute
Associated
Gas
Distributors
Association
of
Metropolitan
Sewerage
Agencies
Cement
Kiln
Recycling
Coalition
Chemical
Manufacturers
Association
Chemical
Producers
and
Distributors
Association
Chemical
Specialties
Manufacturers
Association
Chem­
Tex
Solvents
Corporation
Chlorine
Institute
Domestic
Petroleum
Council
Dry
Color
Manufacturers
Association
Edison
Electric
Institute
Electric
Power
Institute
Environmental
Industries
Association
Environmental
Technology
Council
Fertilizer
Institute
Hazardous
Material
Advisory
Council
Independent
Lubricant
Manufacturers
Association
Independent
Liquid
Terminals
Association
Independent
Petroleum
Association
of
America
International
Precious
Metals
Institute
Interstate
Mining
Compact
Commission
Interstate
Oil
and
Gas
Compact
Commission
Lead
Industries
Association
Metal
Powder
Industries
Federation
National
Agricultural
Chemicals
Association
National
Air
Transport
Association
National
Association
of
Chemical
Distributors
National
Association
of
Chemical
Recyclers
October,
2003
64
National
Association
of
Manufacturers
National
Association
of
Printing
Ink
Manufacturers,
Inc.
National
Electrical
Manufacturers
Association
National
Food
Processors
Association
National
Mining
Association
National
Rural
Electric
Cooperative
Association
National
Screw
Machine
Products
Association
National
Solid
Waste
Management
Association
Petroleum
Marketers
Association
of
America
Silver
and
Gold
Institute
Small
Business
Administration
Society
for
Mining,
Metallurgy
and
Exploration
Solid
Waste
Association
of
North
America
Steel
Service
Centers
Institute
Synthetic
Organic
Chemical
Manufacturers
Association
The
Society
of
the
Plastics
Industry,
Inc.
U.
S.
Chamber
of
Commerce
With
the
addition
of
Federal
facilities
to
TRI
in
1993
(
Executive
Order
12856),
other
Federal
agencies
such
as
the
Department
of
Defense
and
Department
of
Energy
now
play
an
active
role
in
TRI,
including
as
participants
in
Interagency
Workgroups.
In
addition
to
the
industry­
oriented
groups,
EPA
has
also
worked
with
public
interest
groups
in
the
development
of
the
TRI
program.
Environmental
and
public
interest
groups
assisted
in
the
development
of
the
Form
R,
testing
of
the
NLM
database,
and
have
provided
feedback
on
a
wide
range
of
public
access
issues.
Among
the
environmental
and
public
interest
organizations
who
have
been,
or
are,
involved
with
TRI
are:

AFL­
CIO
American
Library
Association
Environmental
Defense
Fund
Environmental
Law
Institute
INFORM
Information
Industry
Association
Mineral
Policy
Center
National
Wildlife
Association
Natural
Resources
Defense
Council
OMB
Watch
Sierra
Club
U.
S.
Public
Interest
Research
Group
Working
Group
on
Community
Right­
to­
Know
Discussions
with
all
of
the
above
groups
have
resulted
in
changes
to
the
program
that
have
had
beneficial
effects,
including
burden
reduction.
October,
2003
65
Over
the
course
of
the
past
decade,
EPA
has
used
the
regularly­
held
public
meetings
of
the
Forum
on
State
and
Tribal
Toxics
Action
(
FOSTTA),
which
represents
state
environmental
agencies,
and
the
National
Advisory
Council
on
Environmental
Policy
and
Technology
(
NACEPT),
which
includes
representatives
from
industry,
environmental
organizations,
states,
and
academia,
as
public
venues
to
consult
on
TRI
and
related
issues.
Major
issues
discussed
through
these
groups
include
the
expansion
of
TRI
to
include
both
additional
chemicals
and
facilities;
implementation
of
PPA
requirements;
redesign
of
the
Form
R;
and
development
of
the
Alternate
Reporting
Threshold
Modification.
EPA
officials
routinely
meet
with
representatives
from
industries,
states,
local
governments,
environmental
organizations,
and
community
groups
on
specific
issues
related
to
TRI,
as
the
need
for
consultation
arises.

EPA
also
makes
a
concerted
effort
to
receive
input
from
small
businesses.
Many
trade
associations
and
other
industry
organizations
with
which
EPA
has
held
discussions
include
small
businesses
as
members
or
participants.
These
groups
have
represented
the
interests
of
some
small
businesses
to
EPA,
and
have
helped
to
inform
businesses
about
TRI.
In
addition,
EPA
has
addressed
forums
such
as
the
Small
Business
Roundtable
regarding
its
initiatives,
and
has
briefed
officials
of
the
Small
Business
Administration
as
well
as
EPA's
Small
Business
Omsbudsman
and
Regional
Small
Business
Liaisons.

EPA
is
currently
undertaking
a
stakeholder
dialogue
process
for
the
TRI
program.
The
stakeholder
dialogue
has
two
phases.
Phase
1
was
completed
in
December,
2002
and
focused
on
the
program
objective
of
timely
public
release
of
quality
data.
Specifically,
EPA
sought
comment
in
the
following
areas:

I
How
to
improve
the
compliance
assistance
provided
by
the
TRI
program,
both
at
Headquarters
and
in
the
Regions,
to
aid
the
reporting
community;
II
How
to
streamline
the
collection
and
processing
of
the
90,000+
TRI
forms
that
EPA
receives
annually;
and
   
How
well
the
materials,
including
the
context,
documents
and
tools,
that
EPA
develops
for
its
annual
public
release
of
the
TRI
data
supports
their
use
and
analysis
of
the
data.

Phase
2
of
the
stakeholder
dialogue,
will
commence
in
late
fall/
early
winter
of
2003
and
will
focus
on
the
future
direction
of
the
program,
including
what
TRI
data
are
collected
and
how
they
are
characterized.
One
key
element
will
be
clarifying
the
data
elements
on
recycling
and
other
waste
management
activities
required
by
the
Pollution
Prevention
Act.
As
part
of
the
stakeholder
dialogue,
EPA
will
also
be
requesting
comment
on
a
variety
of
options
aimed
at
reducing
the
burden
associated
with
TRI
reporting.
A
final
report
summarizing
the
stakeholder
input
will
be
made
available
on
the
TRI
website
after
the
on­
line
dialogue
period
closes
and
the
ideas
and
suggestions
have
been
analyzed.

5(
c)
Effects
of
Less
Frequent
Collection
October,
2003
66
Section
313
requires
annual
reporting.
Section
313(
i)
permits
EPA
to
modify
the
reporting
frequency
by
rulemaking,
however,
EPA
must
first
notify
Congress
and
then
wait
to
initiate
the
rulemaking
to
propose
the
modification
for
at
least
12
months.
In
addition,
EPA
must
find:

(
A)
...
that
the
modification
is
consistent
with
the
provisions
of
subsection
(
h)
of
[
section
313]
based
on
­
(
i)
experience
from
previously
submitted
toxic
chemical
release
forms,
(
ii)
determinations
made
under
paragraph
(
3).]

Paragraph
(
3),
in
turn,
provides
that
EPA
must
determine
(
A)
The
extent
to
which
information
relating
to
the
proposed
modification
provided
on
the
toxic
chemical
release
forms
has
been
used
by
the
Administrator
or
other
agencies
of
the
Federal
government,
States,
local
governments,
health
professionals
and
the
public.

(
B)
The
extent
to
which
information
is
(
i)
readily
available
to
potential
users
from
other
sources,
such
as
State
reporting
programs,
and
(
ii)
provided
to
the
Administrator
under
another
Federal
law
or
through
as
State
program.

(
C)
The
extent
to
which
the
modification
would
impose
additional
and
unreasonable
burdens
on
facilities
subject
to
the
reporting
requirements
under
this
section.
However,
EPA
may
not
permit
less
frequent
reporting
unless
it
can
find
that
such
modification
is
consistent
with
the
purposes
of
the
Act,
as
determined
by
previously
submitted
Form
Rs.
Since
TRI
represents
the
best
available
database
tracking
toxic
chemical
releases
in
the
U.
S.,
changes
in
reporting
frequencies
would
have
profound
impacts
on
the
quality
and
value
of
these
data
for
purposes
of
planning
and
establishing
baselines
in
both
government
and
industry.

Less
frequent
reporting
would
also
significantly
delay
the
availability
of
the
data
to
the
public.
Form
Rs
are
required
to
be
submitted
on
or
before
July
1
following
the
year
in
which
the
reported
releases
and
transfers
occur,
and
then
national
data
are
available
from
EPA
within
a
year
after
that.
Public
access
to
the
most
current
toxic
chemical
release
data
and
other
waste
management
information
possible
could
then
be
severely
limited
if
reporting
were
to
occur
less
frequently.

5(
d)
General
Guidelines
This
ICR
adheres
to
the
guidelines
stated
in
the
1980
Paperwork
Reduction
Act,
as
amended,
OMB's
implementing
regulations,
and
all
applicable
OMB
guidance.

Although
reporting
facilities
are
required
to
identify
the
chemical
for
which
reports
are
submitted,
they
can
claim
the
chemical
identity
as
a
trade
secret.
A
generic
name
must
be
provided
as
part
of
the
information
made
available
to
the
public.
EPA
securely
stores
and
maintains
the
true
identity
of
the
chemical.
This
is
further
discussed
in
5(
e)(
i).
October,
2003
67
EPA
is
actively
encouraging
the
use
of
automated
techniques,
most
notably
PC­
based
report
generating
programs
produced
both
by
the
Agency
and
by
the
private
sector
and
other
submissions
on
magnetic
media.
EPA
recognizes
that
not
all
reporting
facilities
are
able
to
or
are
interested
in
investing
the
time
and
funds
necessary
to
employ
such
automated
techniques.
The
final
decision
on
how
to
report
is
ultimately
the
reporting
facility's.

Small
facilities
(
less
than
10
full­
time
employees
or
equivalent)
are
exempt
from
reporting
under
section
313.
An
optional
range
reporting
provision
and
an
alternate
threshold
have
been
promulgated
that
afford
burden
reduction
to
all
facilities
but
are
particularly
beneficial
to
smaller
facilities
with
small
releases
and
wastes.

5(
e)
Confidentiality
and
Sensitive
Questions
(
i)
Confidentiality
Respondents
may
designate
the
specific
chemical
identity
of
a
substance
as
a
trade
secret.
Procedures
for
submission
and
review
of
trade
secret
claims
under
section
313
are
set
forth
in
40
CFR
350.
This
rule
implements
the
general
trade
secret
provisions
of
EPCRA.
When
a
respondent
claims
the
chemical
identity
to
be
a
trade
secret,
EPA,
upon
substantiation
of
the
claim,
will
not
disclose
the
identity
of
the
chemical
to
the
public.
EPA
securely
stores
forms
with
trade
secret
information
and
allows
access
to
those
documents
only
to
persons
with
Trade
Secret
clearance.
Data
made
available
to
the
public
through
any
means
does
not
include
trade
secret
information.

(
ii)
Sensitive
Questions
This
collection
does
not
request
any
sensitive
information.

6
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
This
section
presents
the
burden
of
this
information
collection
activity
to
respondents
in
terms
of
the
time
required
for
facility
personnel
to
perform
the
activities
outlined
in
Section
3
of
this
document.
These
burden
estimates
are
based
on
previous
ICRs
and
economic
analyses,
respondent
experience
as
reflected
in
comments
to
EPA
and
other
parties,
and
information
acquired
through
site
visits
and
telephone
interviews.

The
burden
to
respondents
is
estimated
for
Form
R
requirements
(
including
compliance
determination
and
supplier
notification)
and
petitions.
Burden
estimates
are
developed
for
the
compliance
activities
and
then
multiplied
by
the
number
of
facilities
or
reports
(
as
appropriate)
to
estimate
the
total
burden
to
respondents.
The
burden
estimates
used
by
EPA
are
national
average
values.
As
with
any
average,
some
facilities
will
be
above
the
average,
and
others
will
be
below
it.
October,
2003
68
Large,
complex
facilities
may
require
more
than
the
average
time
to
comply.
However,
there
are
many
other
facilities
subject
to
the
rule
that
are
not
large
or
complex.
Therefore,
EPA
believes
that
its
burden
estimates
represent
reasonable
national
averages.

As
discussed
elsewhere
in
this
supporting
statement,
minor
modifications
to
the
design
of
Section
8.1
of
Form
R
have
been
proposed.
These
modifications
involve
less
aggregation
and
more
specificity
in
relation
to
categories
of
releases
of
TRI
chemicals
reported
in
Section
8.1
of
the
reporting
form.
New
information
is
generated
by
having
facilities
record
these
data
in
more
specific
sub­
sections
instead
of
adding
the
data
together
and
recording
the
result
in
a
more
general
reporting
classification
on
the
Form
R.
These
modifications
may
prompt
some
slight
increase
in
unit
reporting
burden
as
facilities
become
familiar
with
the
new
reporting
format,
but
the
increase
should
be
mitigated
by
the
fact
that
the
modifications
are
related
to
presentation
of
data
that
have
already
been
assembled
by
the
reporting
facility.
Note
that
the
filling
in
of
various
sub­
sections
will
be
automated
in
the
TRI­
Made
Easy
reporting
software,
which
is
already
used
by
approximately
90
percent
of
reporting
facilities.

Form
R
Requirements
The
tasks
associated
with
TRI
reporting
during
the
period
of
this
ICR
include
the
following:

Compliance
Determination:
Facilities
must
determine
whether
they
meet
the
criteria
for
Section
313
reporting.
This
task
includes
the
time
required
to
become
familiar
with
the
definitions,
exemptions,
and
threshold
requirements
under
the
TRI
program,
to
review
the
list
of
TRI
chemicals,
and
to
conduct
preliminary
threshold
determinations
to
determine
if
the
facility
is
required
to
report.

Rule
Familiarization:
Facilities
that
are
reporting
under
section
313
for
the
first
time
must
read
the
reporting
package
and
become
familiar
with
the
reporting
requirements.
This
includes
the
time
needed
to
review
instructions,
and
the
time
needed
to
train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Calculations
and
Report
Completion:
Facilities
must
gather
data
and
perform
calculations
to
provide
the
information
required
on
the
form.
This
task
includes
the
time
required
to
search
data
sources
and
the
time
to
complete
and
review
the
information.

Recordkeeping
and
Submission:
Facilities
must
maintain
recordkeeping
systems
and
mail
the
report
to
EPA
and
the
State
in
which
the
facility
the
facility
is
located.
This
task
includes
the
time
required
to
transmit
or
otherwise
disclose
the
information.

Supplier
Notification:
Certain
suppliers
of
mixtures
or
trade
name
products
containing
reportable
substances
must
annually
notify
their
customers
of
the
product's
composition,
if
the
customer
is
subject
to
Section
313
reporting.
This
task
includes
the
time
October,
2003
8
Approximately
70
percent
of
affected
facilities
file
3
or
fewer
Form
Rs.
The
most
common
number
of
reports
filed
is
1.

69
required
to
inform
customers,
either
by
letter
or
through
the
materials
safety
data
sheet
(
MSDS)
for
the
product.

The
remainder
of
this
section
discusses
the
unit
burden
hour
estimates
for
each
specific
industry
activity.
Activities
are
organized
into
two
categories:
those
performed
at
the
facility
level
and
those
that
must
be
performed
for
each
Form
R
submitted.
The
estimated
hours
required
to
complete
each
activity
are
summarized
in
Table
1
by
labor
category.
Table
2
presents
the
annual
estimated
burden
hours
according
to
type
of
facility
for
facilities
that
submit
3
Form
Rs
each.
8
This
represents
the
burden
on
a
"
typical"
facility,
although
many
facilities
file
fewer
Form
Rs
and
some
file
more.
The
total
annual
burden
to
all
facilities
is
discussed
in
Section
6(
d).
Note
that
total
annual
burden
estimate
is
based
on
unit
reporting
burdens
multiplied
by
the
total
number
of
facilities
or
forms
(
as
appropriate);
it
is
not
based
on
the
"
typical"
facility
burdens
shown
in
Table
2.
October,
2003
70
Table
1
Average
Annual
Burden
Hour
Estimate
by
Activity
Category
Activity
Management
Technical
Clerical
Total
Hours
Facility
Level
Compliance
Determination
­
all
facilities
1
3
0
4
Rule
Familiarization
­
first­
time
filers
only
12
22.5
0
34.5
Supplier
Notification
0
7
17
24
Per
Form
R
Calculations
and
Report
Completion
­
first­
time
filers
only
20.9
45.2
2.9
69.0
Calculations
and
Report
Completion
­
subsequent
year
filers
only
4.4
9.5
0.6
14.5
Recordkeeping/
Submission
­
all
filers
0
4
1
5
Table
2
Average
Annual
Burden
Hour
Estimate
per
Facility
in
Each
Subsequent
Year
Type
of
Facility
Average
Annual
Hours
Burden
Management
Technical
Clerical
Total
Hours
Compliance
Determination
Only
1
3
0
4
Compliance
Determination
and
3
Form
Rs
14.2
43.5
4.8
62.5
Compliance
Determination,
3
Form
Rs,
and
Supplier
Notification
14.2
50.5
21.8
86.5
Activities
Performed
at
the
Facility
Level
Compliance
Determination
­
A
facility
must
report
under
Section
313
if
it:
(
1)
is
within
an
SIC
code
or
industry
group
covered
by
the
TRI
program;
(
2)
has
ten
or
more
full­
time
equivalent
(
FTE)
employees;
and
(
3)
manufactures,
processes
or
otherwise
uses
any
of
the
listed
chemicals
above
the
threshold
quantities.
All
facilities
must
determine
if
they
meet
these
criteria.
Most
facilities
incur
little
burden
to
make
determinations
regarding
the
first
two
criteria.
Many
facilities
require
time
for
the
management
and
technical
staff
to
determine
the
types
of
chemicals
used
at
the
facility
and
whether
these
chemicals
are
manufactured,
processed,
or
otherwise
used
above
threshold
levels,
in
order
to
make
the
determination
under
the
third
criterion.
October,
2003
71
To
make
the
determination,
a
facility
will
typically
review
whether
it
manufactures,
processes,
or
otherwise
uses
any
of
the
chemicals
in
any
quantity,
and
then
determine
whether
it
exceeds
a
threshold
quantity.
In
many
cases,
particularly
at
facilities
that
do
not
manufacture,
process
or
otherwise
use
any
listed
chemicals,
this
first
activity
should
be
completed
within
a
relatively
short
period
of
time.
The
second
activity
may
involve
a
more
detailed
set
of
calculations.

The
average
burden
for
compliance
determination
is
estimated
to
be
4
hours
per
facility
per
year.
This
average
reflects
the
time
requirements
of
facilities
that
do
not
have
listed
chemicals
on­
site,
have
very
large
or
small
quantities
of
listed
chemicals
(
i.
e.,
are
significantly
above
or
below
the
thresholds
and
thus
do
not
require
a
significant
amount
of
time
to
make
the
determination),
or
have
not
had
significant
changes
from
the
prior
year,
as
well
as
facilities
that
have
more
complex
and
time­
consuming
compliance
determination
requirements.

Rule
Familiarization
­
If
a
facility
will
be
reporting
under
the
section
313
requirements
for
the
first
time,
facility
staff
must
review
and
comprehend
the
reporting
requirements.
At
a
minimum,
this
effort
will
involve
reading
the
instructions
to
the
Toxic
Release
Inventory
Reporting
Form
R,
however,
it
may
also
involve
consulting
EPA
guidance
documents,
attending
a
training
course,
and/
or
calling
the
EPCRA
technical
hotline.
The
cost
associated
with
rule
familiarization
occurs
only
in
the
first
year
that
a
facility
becomes
subject
to
reporting.
In
subsequent
years,
staff
are
assumed
to
be
familiar
with
the
requirements
that
apply
to
their
facility.
Thus,
the
facility
would
no
longer
bear
this
cost.
Similarly,
facilities
that
already
report
on
one
or
more
existing
TRI
chemicals
will
not
incur
a
rule
familiarization
cost.

It
is
estimated
that
facilities
reporting
under
section
313
for
the
first
time
will
need
to
make
a
onetime
expenditure
of
34.5
hours
for
rule
familiarization.
This
burden
estimate
is
comprised
of
12
hours
of
management
time
and
22.5
hours
of
technical
time.

Supplier
Notification
­
Certain
suppliers
of
mixtures
or
trade
name
products
containing
reportable
substances
must
annually
notify
their
customers
of
the
product's
composition
if
the
customer
is
subject
to
Section
313
reporting
or
sells
the
product
to
another
company
that
is
subject
to
reporting.
Facilities
may
be
subject
to
the
supplier
notification
requirements
even
if
they
are
not
covered
by
the
Section
313
reporting
requirements.
For
example,
a
facility
with
less
than
ten
fulltime
employees
or
that
does
not
meet
reporting
thresholds
may
still
be
required
to
notify
certain
customers.
Supplier
notification
is
required
so
that
customers
can
make
threshold
determinations
and
complete
reports
for
their
own
facilities.
The
notification
can
be
provided
by
a
letter
identifying
the
chemical
by
name
and
CAS
number,
and
indicating
its
percentage
by
weight
in
the
formulation.
It
can
also
be
provided
on
the
materials
safety
data
sheet
(
MSDS)
for
the
product.
On
average,
approximately
24
hours
per
facility
are
estimated
for
compliance
with
this
requirement.

Activities
Specific
to
Completing
the
Form
R
October,
2003
9
USEPA/
OEI,
Estimates
of
Burden
Hours
for
Economic
Analyses
of
the
Toxics
Release
Inventory,
June
10,
2002.
The
estimate
is
based
on
respondent
experience,
and
reflects
computerization/
automation,
increased
familiarity
with
reporting
requirements,
improved
guidance,
and
other
factors.

72
Calculations
and
Report
Completion
­
Facilities
that
determine
they
must
report
under
Section
313
will
incur
additional
burden
to
retrieve,
process,
review,
and
transcribe
information
to
complete
each
report.
Most
of
the
time
required
for
form
completion
is
to
calculate
releases,
transfers,
and
other
waste
management
practices;
relatively
little
time
is
required
to
copy
information
to
the
form.
The
facility
must
complete
one
Form
R
for
each
listed
chemical
it
is
reporting
to
TRI.

The
burden
is
estimated
to
average
14.5
hours
per
Form
R
for
on­
going,
annual
reporting.
This
estimate
is
based
on
burden
hour
data
collected
from
TRI
respondents.
9
To
complete
the
Form
R,
facilities
will
need
to
verify
and
update
data,
review
previous
calculations,
and
modify
the
information
reported
on
the
previous
year's
Form
R.
For
a
facility
completing
3
forms
in
subsequent
years,
this
results
in
an
average
estimated
burden
of
43.5
hours.
The
estimate
for
first
year
calculations
and
report
completion
is
unchanged
at
69
hours
per
Form
R.

Recordkeeping
and
Submission
­
After
a
facility
has
completed
the
form,
it
incurs
additional
burden
for
recordkeeping
and
submission
associated
with
filing
a
Form
R
report.
Recordkeeping
allows
a
facility
to
use
the
information
in
making
calculations
in
subsequent
years
and
as
documentation
in
the
event
it
receives
a
compliance
audit.
Facilities
must
maintain
records
used
to
provide
the
information
required
on
the
Form
R;
those
records
may
include
estimation
methodology
and
calculations,
engineering
reports,
inventory,
incident
and
operating
logs,
and
other
supporting
materials.
Recordkeeping
and
submission
are
estimated
to
take
an
average
of
5
hours
per
Form
R,
which
works
out
to
15
hours
for
a
facility
filing
3
Form
Rs.

Average
Burden
per
Respondent
The
estimated
burden
per
respondent
depends
on
the
type
of
respondent
and
the
number
of
reports
submitted.
For
example,
the
burden
for
facilities
that
only
perform
compliance
determination
is
estimated
to
average
4
hours
per
facility.
For
facilities
required
to
file
3
Form
Rs,
but
not
required
to
comply
with
supplier
notification,
the
burden
is
estimated
to
average
62.5
hours.
For
facilities
submitting
3
Form
Rs
that
are
also
required
to
comply
with
supplier
notification,
the
average
burden
in
the
third
year
is
estimated
at
86.5
hours
per
facility.

Petitions
The
activities
required
to
prepare
and
file
a
petition
are
listed
below.
Included
is
a
discussion
of
the
burden
associated
with
each
activity.
The
time
needed
to
complete
these
activities
is
presented
in
Table
3.
The
total
annual
burden
for
all
petitions
is
estimated
in
Section
6(
d).
October,
2003
73
Table
3
Average
Burden
Hour
Estimate
per
Petition
Activity
Average
Annual
Hours
Burden
Total
Hours
Burden
Management
Technical
Clerical
1.
Read
EPA
Policy
and
Guidance
4
0
0
4
2.
Plan
Activities
2
1
0
3
3.
Prepare
Literature
Search
2
7
0
9
4.
Conduct
Literature
Search
0
48
0
48
5.
Process,
Review,
and
Focus
Information
12
74
0
86
6.
Write
Petition
4
8
6
18
7.
Review
and
Edit
petition
4
8
2
14
8.
Submit
to
EPA
and
File
0
0
3
3
Total
Hours
per
Petition
28
146
11
185
These
estimates
assume
prior
knowledge
by
the
respondent
of
the
issues
prompting
the
listing
of
specific
chemicals.
An
additional
assumption
was
made
that
the
petitioners
had
no
inhouse
library
facilities
and,
consequently,
that
they
would
have
to
use
a
university
library
or
similar
facility.
Based
upon
the
experience
of
the
previous
reporting
years,
fewer
than
5
petitions
per
year
are
expected.
Following
are
specific
descriptions
of
the
activities
associated
with
preparing
and
filing
a
petition
for
chemical
listing
or
de­
listing.

Read
EPA
guidance
document
and
consult
with
EPA.
The
reading
and
interpretation
of
EPA
policy
and
guidance
notice
is
conducted
by
management
and
involves
four
hours
per
petition.

Plan
activities.
The
planning
activities
are
conducted
jointly
by
management
and
technical
personnel.
Three
hours
per
petition
are
required
to
complete
these
activities.

Prepare
literature
search.
This
activity
would
be
conducted
by
both
management
and
technical
personnel,
involving
about
nine
hours.

Conduct
literature
search.
The
technical
staff
member
conducts
this
activity,
which
requires
about
48
hours
per
petition.

Process,
review,
and
focus
information.
This
activity
would
be
completed
by
both
technical
and
management
personnel,
involving
a
total
of
86
hours
per
petition.

Write
petition.
This
activity
would
be
completed
by
a
combination
of
technical,
management,
and
clerical
personnel.
About
18
hours
are
required
per
petition
to
complete
the
writing.
October,
2003
10
USEPA/
OEI,
Wage
Rates
for
Economic
Analyses
of
the
Toxics
Release
Inventory
Program,
June
10,
2002.
The
wage
rates
used
in
this
supporting
statement
have
been
updated
to
June
2003
using
the
methods
described
in
this
reference.

74
Review
and
edit
petition.
A
combination
of
management,
technical,
and
clerical
personnel
would
be
involved
in
this
activity,
requiring
a
total
of
14
hours
per
petition.

Submit
petition
to
EPA
and
file.
These
activities
would
be
done
by
the
clerical
personnel,
requiring
approximately
three
hours
per
petition.

Total
respondent
burden.
The
total
burden
of
submitting
a
petition
is
estimated
to
average
185
hours.

6(
b)
Estimating
Respondent
Costs
The
cost
to
respondents
is
based
on
the
time
needed
to
complete
the
tasks
listed
in
Section
6(
a)
and
the
hourly
cost
of
labor
at
appropriate
levels
(
loaded
labor
rates).
There
are
no
specific
capital
costs
associated
directly
with
this
information
collection
activity.
There
may
be
some
small
additional
costs
for
mailing
and
supplies.
Total
annual
costs
for
all
facilities
are
discussed
in
Section
6(
d).

Form
R
Requirements
To
determine
the
per­
facility
costs
for
typical
respondents,
the
unit
burden
hour
estimates
for
compliance
activities
are
multiplied
by
fully
loaded
hourly
rates
for
the
appropriate
categories
of
labor
conducting
these
activities.
10
Loaded
hourly
rates
are
the
product
of
wages,
benefits,
and
overhead.
Hourly
wage
rates
are
divided
into
three
categories:
managerial,
technical,
and
clerical.
Average
wage
and
salary
data
for
these
categories
are
obtained
from
the
Employer
Costs
for
Employee
Compensation
(
ECEC)
report
from
the
Bureau
of
Labor
Statistics
(
BLS)
for
all
goodsproducing
private
industries.
The
additional
cost
of
benefits,
such
as
paid
leave
and
insurance,
is
also
derived
from
information
provided
in
the
ECEC
report.
Loading
factors
for
benefits
are
calculated
separately
for
managerial,
technical,
and
clerical
labor
by
dividing
the
benefits
percentage
of
total
compensation
by
the
wage
percentage
of
total
compensation.
Based
on
information
provided
by
the
chemical
industry
and
chemical
industry
trade
associations,
an
additional
loading
factor
of
17
percent
is
applied
for
general
overhead.
This
loading
factor
is
added
to
the
benefits
loading
factor,
then
applied
to
the
base
wage.
The
new
wage
rates
are
calculated
using
current
data
on
salaries
and
benefits
for
these
three
labor
categories.
The
fully
loaded
hourly
wage
rates
as
of
June
2003
are
shown
in
Table
4.
October,
2003
75
Table
4
Loaded
Hourly
Wage
Rates
by
Labor
Category
Labor
Category
Average
Hourly
Wage
Benefit
(%
wages)
Overhead
(%
wages)
Loaded
Hourly
Rate
Managerial
$
32.46
46.0%
17%
$
52.91
Technical
$
28.18
45.6%
17%
$
45.81
Clerical
$
14.99
44.9%
17%
$
24.27
Average
costs
are
summarized
by
activity
in
Table
5
and
per
facility
in
Table
6.
The
average
cost
per
facility
for
those
completing
only
compliance
determination
is
$
190.
Based
on
the
burden
hour
estimates
in
Table
1
and
the
loaded
hourly
rates
in
Table
4,
the
average
subsequent
year
cost
for
a
facility
performing
compliance
determination
and
submitting
3
Form
Rs
is
$
2,860,
while
the
cost
for
a
facility
performing
compliance
determination,
submitting
3
reports,
and
complying
with
supplier
notification
is
estimated
to
be
$
3,594.

Table
5
Average
Annual
Cost
Estimate
by
Activity
Category
Activity
Management
Technical
Clerical
Total
Cost
Facility
Level
Compliance
Determination
­
all
facilities
$
53
$
137
$
0
$
190
Rule
Familiarization
­
first­
time
filers
only
$
635
$
1,031
$
0
$
1,666
Supplier
Notification
$
0
$
321
$
413
$
734
Per
Form
R
Calculations
and
Report
Completion
­
first­
time
filers
only
$
1,106
$
2,071
$
70
$
3,247
Calculations
and
Report
Completion
­
subsequent
year
filers
$
233
$
435
$
15
$
683
Recordkeeping/
Submission
­
all
filers
$
0
$
183
$
24
$
207
Table
6
Average
Annual
Cost
Estimate
per
Facility
in
Each
Subsequent
Year
Type
of
Facility
Management
Technical
Clerical
Total
Cost
Compliance
Determination
Only
$
53
$
137
$
0
$
190
Compliance
Determination
and
3
Form
Rs
$
752
$
1,991
$
117
$
2,860
Compliance
Determination,
3
Form
Rs
and
Supplier
Notification
$
752
$
2,312
$
530
$
3,594
October,
2003
76
Petitions
The
primary
cost
to
respondents
for
developing
and
submitting
petitions
under
Section
313(
e)
will
be
the
labor
costs
associated
with
the
activities
outlined
in
Section
6(
a)
of
this
document.
These
costs
are
the
product
of
the
labor
hours
expended
to
prepare
the
average
petition,
the
wage
rates
for
the
employees
involved
in
preparing
the
petitions,
and
the
average
number
of
petitions
submitted
annually.
Based
on
the
burden
hour
estimates
in
Table
3
and
the
loaded
hourly
rates
in
Table
4,
the
cost
estimate
for
the
preparation
of
a
petition
is
presented
in
Table
7.

Table
7
Average
Cost
per
Petition
Activity
Management
Technical
Clerical
Total
1.
Read
EPA
Policy
and
Guidance
$
212
$
0
$
0
$
212
2.
Plan
Activities
$
106
$
46
$
0
$
152
3.
Prepare
Literature
Search
$
106
$
321
$
0
$
427
4.
Conduct
Literature
Search
$
0
$
2,199
$
0
$
2,199
5.
Process,
Review,
and
Focus
Information
$
635
$
3,390
$
0
$
4,025
6.
Write
Petition
$
212
$
366
$
146
$
724
7.
Review
and
Edit
petition
$
212
$
366
$
49
$
627
8.
Submit
to
EPA
and
File
$
0
$
0
$
73
$
73
Total
Cost
per
Petition
$
1,483
$
6,688
$
268
$
8,439
Based
upon
prior
years
of
implementation
of
EPCRA
Section
313,
it
is
assumed
that
fewer
than
5
petitions
will
continue
to
be
submitted
annually
(
in
recent
years,
only
1
or
2
petitions
have
been
submitted
each
year).
The
total
average
unit
cost
to
prepare
a
petition
is
estimated
to
be
$
8,439.

6(
c)
Estimating
Agency
Burden
and
Cost
This
section
estimates
the
burden
and
costs
to
EPA
to
process
Form
R
reports
based
on
information
characterizing
the
resources
used
in
previous
years.
Burden
and
costs
are
incurred
by
EPA
for
five
categories
of
activities:
data
processing,
outreach
and
training,
information
dissemination,
policy
and
petitions,
and
compliance
and
enforcement.
These
activities
are
described
in
detail
in
Table
8.
October,
2003
77
Table
8
EPA
Activities
for
Form
R
Category
Description
Data
Processing
Data
entry
 
entering
the
information
into
the
database,
microfilming
or
microfiching
the
reports,
and
filing
all
reports;

Data
quality
 
reviewing
reports
for
completeness,
errors,
and
inconsistencies;
making
inquiries
to
resolve
discrepancies;
and
reentering
corrected
data;

Magnetic
media
support
 
distributing
computer
program
for
electronic
submissions;
creation
and
updating
of
intelligent
reporting
software;

Programming
and
operating
the
EPA
mainframe
and
local
area
network;

Data
analysis
 
developing
tools
to
use
TRI
data,
analyzing
data
to
support
EPA
needs,
and
preparing
data
for
use
by
others;
and
EPCRA
Reporting
Center
fixed
costs
 
rent
and
form
storage.
Outreach
and
Training
Providing
EPCRA
technical
hotline,
technical
guidance,
industry
outreach,
and
regional,
state,
and
public
training;
and
Responding
to
requests
for
information
through
TRI
User
Support.
Information
Dissemination
Public
data
release,
Internet,
data
access
tools.

Policy
and
Petitions
Analysis
to
support
petitions,
list
revisions,
trade
secret
claims,
and
rulemakings.
Compliance
and
Enforcement
Technical
assistance,
compliance
outreach,
facility
inspections,
issuance
of
cases
and
creation
of
Supplemental
Environmental
Projects
(
SEPs).

To
estimate
EPA
burden
and
cost,
EPA
employees
(
as
measured
by
full
time
equivalents,
or
FTEs)
and
extramural
costs
are
separated
into
a
fixed
component
and
a
variable
component.
Activities
and
expenses
that
are
not
greatly
affected
by
marginal
changes
in
numbers
of
reports
are
treated
as
fixed.
These
include
rent
for
the
EPCRA
reporting
center,
development
costs
for
data
access
tools,
compliance
assistance
measures,
and
other
activities
and
expenses.
The
variable
component
is
the
amount
that
varies
depending
on
the
number
of
forms.
The
variable
component
reflects
total
extramural
data
processing
costs
divided
by
the
total
number
of
reports
processed
in
the
2000
reporting
year.
$
7.35
million
in
fixed
costs
and
31.3
FTEs
are
required
to
conduct
the
EPA
activities
described
above
plus
an
additional
$
26
in
variable
costs
for
each
form
processed.
October,
2003
11
The
Bureau
of
Census's
County
Business
Patterns
­
1997
indicates
that
there
are
191,745
facilities
with
10
or
more
employees
in
SIC
codes
20
to
39.
There
are
an
additional
10,040
facilities
in
the
seven
non­
manufacturing
industries
that
are
estimated
to
perform
compliance
determination,
for
a
total
of
201,785
facilities
performing
compliance
determination.
For
the
2001
reporting
year,
22,359
facilities
submitted
83,218
Form
Rs.
The
number
of
facilities
and
forms
has
been
rounded
up
to
the
nearest
thousand
for
this
ICR.
12
Between
RY1994
and
RY2001,
there
have
been
three
reporting
years
with
no
major
programmatic
changes.
Based
on
reporting
for
1996,
1997,
and
1999,
the
average
rate
of
facilities
that
file
using
new
TRI
Facility
IDs
is
4.7%.
These
facilities
filed
an
average
of
2%
of
the
Form
Rs.
For
the
purposes
of
this
ICR,
these
facilities
represent
"
first­
time
filers."

78
As
discussed
in
the
following
section,
approximately
84,000
Form
R
reports
are
expected
to
be
filed
per
year.
Thus,
the
total
annual
burden
to
EPA
is
estimated
to
be
$
2.16
million
in
variable
costs,
along
with
the
$
7.35
million
in
fixed
costs
and
31.3
FTEs
(
or
65,104
hours
at
$
3.2
million
in
loaded
labor
costs).
The
analysis
assumes
that
half
of
the
fixed
FTE
requirement
is
met
by
EPA
employees
at
the
general
pay
scale
grade
GS­
12,
step
5
(
at
a
loaded
salary
of
$
93,402)
and
half
by
employees
at
grade
GS­
13,
step
5
(
at
a
loaded
salary
of
$
111,070),
using
a
standard
loading
factor
of
1.6.

6(
d)
Bottom
Line
Burden
Hours
and
Costs
Estimated
Total
Annual
Burden
for
All
Respondents
This
section
presents
the
total
annual
burden
hours
for
all
respondents
including
both
those
complying
with
Section
313
and
submitting
petitions.
The
total
burden
hours
for
all
respondents
to
comply
with
Section
313
is
estimated
by
multiplying
the
unit
burden
estimate
for
each
compliance
activity
by
the
relevant
units:
facilities
or
reports.
It
is
estimated
that
201,785
facilities
must
determine
compliance
each
year,
of
which
approximately
23,000
facilities
are
expected
to
also
perform
the
report
completion
and
recordkeeping
activities
for
84,000
Form
Rs.
11
As
a
result,
178,785
facilities
are
estimated
to
complete
only
the
compliance
determination
procedure.
An
additional
23,000
facilities
are
expected
to
complete
compliance
determination,
form
completion
and
recordkeeping,
and
of
these,
3,734
facilities
are
expected
to
also
conduct
supplier
notification.
Of
the
23,000
facilities
that
file
Form
Rs,
it
is
expected
that
1,081
facilities
will
be
reporting
to
TRI
for
the
first­
time
as
they
exceed
applicable
thresholds,
and
that
these
facilities
will
file
1,680
of
the
Form
Rs.
12
Table
9
presents
the
total
annual
burden
hours
based
on
these
estimates.
October,
2003
EPA
contacted
9
TRI­
ME
users
in
2002
and
9
TRI­
ME
users
in
2003
to
obtain
estimates
of
the
burden
reduction
attributable
to
TRI­
ME.
The
burden
reduction
estimate
is
based
on
the
average
burden
reduction
reported
by
firsttime
users
of
TRI­
ME.

79
Table
9
Total
Annual
Burden
Hour
Estimate
For
Form
R
ACTIVITY
Hours
Number
of
Facilities
Number
of
Reports
Total
Burden
Compliance
Determination
­
all
facilities
4
201,785
N/
A
807,140
Rule
Familiarization
­
first­
time
filers
only
34.5
1,081
N/
A
37,295
Form
R
Completion
­
reports
from
firsttime
filers
69
N/
A
1,680
115,920
Form
R
Completion
­
reports
from
subsequent
year
filers
14.5
N/
A
82,320
1,193,640
Recordkeeping/
Submission
­
all
reports
5
N/
A
84,000
420,000
Supplier
Notification
24
3,734
N/
A
89,616
Total
2,663,611
In
an
effort
to
reduce
reporting
burden,
EPA
has
developed
intelligent
software
for
the
desktop
computer
called
TRI
 
Made
Easy
(
TRI­
ME)
to
assist
facilities
in
determining
and
completing
their
reporting
obligations.
For
reporting
year
2001,
85
percent
of
the
Form
R
responses
were
received
electronically
and
37
percent
of
Form
R
responses
were
filed
using
TRI­
ME.
In
the
supporting
statement
for
the
previous
ICR
renewal,
EPA
had
predicted
a
40
percent
TRI­
ME
adoption
rate
for
reporting
year
2001.
Preliminary
results
from
reporting
year
2002
show
85
percent
of
the
Form
R
responses
were
received
electronically,
and
92
percent
of
Form
R
responses
were
filed
using
TRI­
ME
(
TRI­
ME
output
for
submission
can
be
in
paper
or
electronic
formats).
For
the
purposes
of
this
ICR,
EPA
uses
an
estimate
of
90
percent
of
Form
Rs
being
filed
using
TRI­
ME.

Based
on
responses
from
facilities
that
tested
TRI­
ME
in
reporting
year
2000
and
facilities
that
used
TRI­
ME
in
2001,
EPA
expects
that
TRI­
ME
will
result
in
a
burden
reduction
of
15
percent
in
the
activities
of
Form
R
Completion
and
Recordkeeping/
Submission.
13
The
total
estimated
annual
burden
reduction
attributable
to
TRI­
ME
is
shown
in
Table
10.
October,
2003
80
Table
10
Annual
TRI­
ME
Burden
Reduction
for
Form
R
Hours
Saved
per
Form
Number
of
Affected
Forms
Burden
Reduction
Form
R
Completion
­
reports
from
first­
time
filers
(
11.1)
1,512
(
16,783)

Form
R
Completion
­
reports
from
subsequent
year
filers
(
2.9)
74,088
(
214,855)

Total
(
231,638)

The
annual
hours
burden
for
all
petitions
is
calculated
by
multiplying
the
per­
petition
burden
estimate
for
each
activity
by
the
expected
number
of
petitions
per
year.
A
total
of
5
petitions
are
estimated
to
be
filed
annually.
Table
11
presents
the
total
annual
hours
burden
for
all
petitions.
The
total
annual
hours
burden
for
all
petitions
submitted
is
expected
to
be
925
hours.

Table
11
Total
Annual
Burden
Hour
Estimate
For
All
Petitions
(
5
petitions
per
year)

Activity
Annual
Hours
Burden
Management
Technical
Clerical
Total
Hours
1.
Read
EPA
Policy
and
Guidance
20
0
0
20
2.
Plan
Activities
10
5
0
15
3.
Prepare
Literature
Search
10
35
0
45
4.
Conduct
Literature
Search
0
240
0
240
5.
Process,
Review,
and
Focus
Information
60
370
0
430
6.
Write
Petition
20
40
30
90
7.
Review
and
Edit
petition
20
40
10
70
8.
Submit
to
EPA
and
File
0
0
15
15
Total
Annual
Hours
Burden
140
730
55
925
Estimated
Total
Annual
Cost
for
All
Respondents
The
total
annual
reporting
cost
for
all
respondent
facilities
is
determined
by
multiplying
the
unit
cost
estimates
by
the
relevant
units
(
facilities
or
reports)
for
each
compliance
activity.
Table
12
presents
the
annual
reporting
cost
for
Form
R
before
accounting
for
TRI­
ME
burden
reduction.
October,
2003
81
Table
12
Total
Annual
Cost
Estimate
For
Form
R
ACTIVITY
Cost
Number
of
Facilities
Number
of
Reports
Total
Cost
Compliance
Determination
­
all
facilities
subject
to
EPCRA
313
$
190
201,785
N/
A
$
38,339,150
Rule
Familiarization
­
first­
time
filers
$
1,666
1,081
N/
A
$
1,800,946
Form
R
Completion
­
reports
from
first­
time
filers
$
3,247
N/
A
1,680
$
5,454,960
Form
R
Completion
­
reports
from
subsequent
year
filers
$
683
N/
A
82,320
$
56,224,560
Recordkeeping/
Submission
­
all
reports
$
207
N/
A
84,000
$
17,388,000
Supplier
Notification
$
734
3,734
N/
A
$
2,740,756
Annual
Total
$
121,948,372
As
a
result
of
the
adoption
of
TRI­
ME,
EPA
expects
a
reduction
in
total
annual
costs
attributable
to
Form
R
reporting.
Using
the
adoption
rate
and
burden
reduction
percentages
discussed
above,
EPA
predicts
reductions
in
total
annual
costs
as
shown
in
Table
13.

Table
13
Annual
TRI­
ME
Cost
Reduction
for
Form
R
Cost
Reduction
per
Form
Number
of
Affected
Forms
Cost
Reduction
Form
R
Completion
­
reports
from
first­
time
filers
($
518.10)
1,512
($
783,367)

Form
R
Completion
­
reports
from
subsequent
year
filers
($
133.50)
74,088
($
9,890,748)

Total
($
10,674,115)

The
annual
cost
for
all
petitions
is
calculated
by
multiplying
the
per­
petition
cost
for
each
activity
by
the
expected
number
of
petitions
per
year.
A
total
of
5
petitions
are
assumed
to
be
filed
annually.
The
total
annual
cost
for
all
petitions
submitted
is
shown
in
Table
14.
October,
2003
82
Table
14
Total
Annual
Cost
Estimate
for
All
Petitions
Activity
Management
Technical
Clerical
Total
Cost
1.
Read
EPA
Policy
and
Guidance
$
1,060
$
0
$
0
$
1,060
2.
Plan
Activities
$
530
$
230
$
0
$
760
3.
Prepare
Literature
Search
$
530
$
1,605
$
0
$
2,135
4.
Conduct
Literature
Search
$
0
$
10,995
$
0
$
10,995
5.
Process,
Review,
and
Focus
Information
$
3,175
$
16,950
$
0
$
20,125
6.
Write
Petition
$
1,060
$
1,830
$
730
$
3,620
7.
Review
and
Edit
petition
$
1,060
$
1,830
$
245
$
3,135
8.
Submit
to
EPA
and
File
$
0
$
0
$
365
$
365
Total
Cost
per
Petition
$
7,415
$
33,440
$
1,340
$
42,195
The
previous
tables
have
detailed
the
total
burden
and
cost
for
complying
with
Section
313
and
for
submitting
a
petition
independently.
Table
15
presents
the
total
burden
and
cost
for
both
activities,
as
well
as
for
the
reduction
in
cost
and
burden
attributable
to
TRI­
ME.

Table
15
Total
Annual
Respondent
Burden
and
Cost
Activity
Annual
Burden
Hours
Annual
Costs
(
millions
of
2003
dollars)

Form
Rs
2,663,611
$
121.95
TRI­
ME
(
231,638)
($
10.67)
Petitions
925
$
0.04
Total
2,432,898
$
111.3
6(
e)
Reasons
for
Change
in
Burden
As
a
result
of
OMB's
March
10,
2003
approval
of
the
last
ICR
renewal,
OMB's
inventory
reflects
88,117
responses
and
5,566,564
hours
for
this
information
collection.
This
ICR
supporting
statement
is
for
84,000
responses
and
2,432,898
hours.
The
reduction
in
the
estimate
of
total
burden
of
approximately
3.13
million
hours
is
the
result
of
three
adjustments.

The
first
adjustment
is
to
the
number
of
responses.
The
estimate
of
88,117
responses
in
the
existing
OMB
approval
incorporated
a
predicted
reporting
increase
from
the
economic
analysis
October,
2003
83
of
the
final
rule
to
lower
reporting
thresholds
for
lead
and
lead
compounds.
This
prediction
overestimated
actual
reporting
levels;
EPA
received
about
70
percent
of
the
additional
lead
and
lead
compound
reports
that
were
forecast.
The
number
of
responses
in
this
ICR
supporting
statement
have
been
adjusted
to
accurately
reflect
actual
reporting
levels
(
rounded
to
the
next
highest
thousand
responses).
This
adjustment
accounts
for
a
decrease
of
about
218,000
hours.

The
second
adjustment
is
to
the
unit
burden
hour
estimates
for
subsequent
year
reporting.
EPA
has
adjusted
the
estimate
of
unit
burden
hours
for
Form
R
completion
in
subsequent
years
from
47.1
hours
to
14.5
hours
based
on
responses
from
TRI
reporting
facilities.
This
adjustment
accounts
for
a
decrease
of
about
2.68
million
hours.

The
third
adjustment
relates
to
the
adoption
of
TRI­
ME,
an
automated
reporting
software
package.
EPA
has
reduced
the
burden
estimates
related
to
Form
R
Completion
and
Recordkeeping/
Submission
by
15
percent
for
the
reports
filed
using
TRI­
ME.
An
estimated
90
percent
of
reports
are
expected
to
be
filed
using
TRI­
ME
over
the
three
years
of
the
ICR.
This
adjustment
accounts
for
a
decrease
of
about
232,000
hours.

The
sum
of
these
adjustments
is
a
decrease
of
4,117
responses
and
3,133,666
burden
hours
from
the
current
approved
total.
Table
16
summarizes
the
major
program
changes
and
adjustments
that
have
been
made
over
the
last
several
years,
as
well
as
the
changes
due
to
the
adjustments
in
this
ICR
supporting
statement.
October,
2003
84
TABLE
16
Recent
Changes
in
TRI
Form
R
Burden
Activity
­
Explanation
TRI
Form
R
ICR
(
EPA
#
1363,
OMB
#
2070­
0093)

Change
Total
#
Responses
Burden
Hours
Total
Responses
Total
Burden
Hours
1997
Baseline
C
C
90,362
5,538,727
1997
Program
Change
­
Industry
Expansion:
This
rule
added
7
new
industries
to
the
list
of
industries
subject
to
TRI
reporting
beginning
in
RY98.
39,033
2,467,463
129,395
8,006,190
1999
Adjustment
­
Form
R
Correction
Worksheet:
This
adjustment
revised
the
number
of
responses
to
be
more
consistent
with
actual
reporting
levels.
However,
it
did
not
correct
for
overestimation
of
expected
reporting
from
the
Industry
Expansion
rule.
(
13,226)
(
665,666)
116,169
7,340,524
1999
Program
Change
­
PBT
Rule:
This
rule
lowered
reporting
thresholds
for
certain
PBT
chemicals,
and
added
other
PBT
chemicals
at
lower
thresholds
beginning
in
RY00.
19,990
1,485,411
136,159
8,825,935
2000
Program
Change
­
Lead
Rule:
This
rule
lowered
reporting
thresholds
for
lead
and
lead
compounds
beginning
in
RY01.
9,813
786,169
145,972
9,612,104
January
2003
Form
R
ICR
Renewal:
This
request
incorporated
accounting
adjustments
to
reflect
actual
number
of
responses.
(
57,855)
(
5,045,540)
88,117
5,566,564
October
2003
Form
R
ICR
Renewal:
This
request
reflects
actual
number
of
responses
and
incorporates
adjustments
to
estimates
of
unit
reporting
burden
based
on
facility
experience
and
TRI­
ME
reporting
software.
(
4,117)
(
3,133,666)
84,000
2,432,898
CURRENT
TOTALS
84,000
2,432,898
C
C
October,
2003
85
6(
f)
Burden
Statement
(
To
appear
on
Collection
Instrument)

The
annual
public
burden
related
to
the
Form
R,
which
is
approved
under
OMB
Control
No.
2070­
0093,
is
estimated
to
average
19.5
hours
per
response.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
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
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OEI­
2003­
0025,
which
is
available
for
public
viewing
at
the
Office
of
Environmental
Information
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Office
of
Environmental
Information
Docket
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
OEI­
2003­
0025
and
OMB
control
number
2070­
0093
in
any
correspondence.

The
completed
forms
should
be
submitted
in
accordance
with
the
instructions
accompanying
the
form,
or
as
specified
in
the
corresponding
regulation.
October,
2003
86
REFERENCES
Certain
references
cited
are
available
in
EPA
docket
#
OPPTS­
400104;
other
references
are
readily
available.

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J.
Gordon,
et
al.,
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State
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Burke,
Lauretta
M.,
1993.
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Technical
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1987
(
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1990,
September
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June
1991,
and
June
1993).

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Air
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Chikkala,
John,
1995.
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November
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1994;
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1992.
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Pat,
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(
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Environmental
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July).

Doer,
Lisa,
1995.
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Building
TRI
and
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DC:
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March).

Donaghue,
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1995.
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and
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Prevention
Partnerships
(
Washington,
DC:
U.
S.
Environmental
Protection
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Prevention
and
Toxics,
March).

Dunst,
Russ,
1995.
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Department
of
Natural
Resources.
Conversation
with
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Associates.
November
14.

Goodenow,
Dennis
California
Air
Resources
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(
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1995.
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communication
with
Abt
Associates,
August
29,
1995.

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Lakes
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1996.
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Greene,
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1995.
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(
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DC:
U.
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Environmental
Protection
Agency,
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Toxics,
March).

Hartmann,
Carolyn,
1993.
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Group,
June).

Hausman,
Rick,
1993.
"
Environmental
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Dollars
and
Change,"
Online:
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RTK
NET
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Vol.
3,
No.
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Herring,
Jeff,
OAQPS,
1995.
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August
21,
1995.

ICF
Incorporated,
1996.
Fax
transmission
from
Maravene
Edelstein
to
John
Ferris
dated
5/
8/
96,
with
table
containing
information
of
Tier
II
(
EPCRA
Section
312)
data
availability
by
state.

ICF
Incorporated,
1993.
Data
Gaps
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Redundancies
in
Pollution
Prevention
Reporting;
A
Compendium
of
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Prepared
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S.
EPA,
Office
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Prevention,
Pesticides,
and
Toxics,
Pollution
Prevention
Division.

Kleeman,
Jane,
AFS
Emissions
Coordinator,
1995
Personal
communication
with
Abt
Associates,
September
5,
1995.

Kolwey,
Neil
and
Margery
Lynch,
1994.
Pollution
Prevention
Priorities:
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Study
of
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MacLean,
Alair
and
Paul
Orum,
1992.
Progress
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Community
Right­
to­
Know
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OMB
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and
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to­
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2003
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MacLean,
Alair
and
Rich
Puchalsky,
1994.
Where
the
Wastes
Are:
Highlights
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the
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More
Than
5,000
Facilities
that
Receive
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TRI
Chemicals
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DC:
OMB
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Unison
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Massachusetts
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1994.
Toxics
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MA:
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1993.
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Overview
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McLure,
Pam,
1994.
"
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Vol.
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(
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Memorandum
from
J.
Karnes
to
Brian
Muehling
(
EPA/
OTS)
on
Updating
of
Unit
Labor
Costs
to
Reflect
Inflation
and
Industry
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28,
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National
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1995.
"
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"
Notes
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Reports
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to
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August.

Pope,
Anne,
OAQPS,
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September
6,
1995.

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Bill.
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14.

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1993.
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Speciation
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1993.

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3,
1995.

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John
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Permitting
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major
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Templet,
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in
the
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and
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1997.
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1996.

U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics.
Occupational
Compensation
Survey,
National
Summary
1996
(
1998).
U.
S.
Department
of
Labor,
Washington,
D.
C.,
March.
Bulletin
2497,
Tables
A­
1,
D­
1
and
D­
3,
1998.

U.
S.
EPA,
1991.
1991
Hazardous
Waste
Report:
Instructions
and
Forms.
EPA
Form
8700­
13A/
B
(
5­
80)
revised
8­
91.

U.
S.
EPA,
1993.
"
Proceedings:
Toxics
Release
Inventory
(
TRI)
Data
Use
Conference."
July
1993.

U.
S.
EPA,
1993b.
State
Directory:
33/
50
and
Voluntary
Pollution
Prevention
Programs,
1993.
(
Washington,
DC:
U.
S.
Environmental
Protection
Agency,
Office
of
Prevention,
Pesticides
and
Toxic
Substances,
October).

U.
S.
EPA,
1994.
"
National
Analysis:
The
Biennial
RCRA
Hazardous
Waste
Report
(
Based
on
1991
Data)."
September
1994.

U.
S.
EPA,
1995a.
Information
from
the
AIRS
AFS
Home
Page
on
the
U.
S.
EPA
World
Wide
Web
site:
(
http://
www.
epa.
gov/
docs/
airs/
afs.
html).

U.
S.
EPA,
1995b.
"
Compilation
of
Air
Pollutant
Emission
Factors:
Volume
I:
Stationary
Point
and
Area
Sources,"
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS),
January
1995.

U.
S.
EPA,
1995c.
"
White
Paper
for
Streamlined
Development
of
Part
70
Permit
Applications,"
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS),
July
10,
1995.

U.
S.
EPA,
1995d.
"
Report
to
President
Clinton:
Expansion
of
Community
Right­
to­
Know
Reporting
to
Include
Chemical
Use
Data:
Phase
III
of
the
Toxics
Release
Inventory."

U.
S.
EPA,
1995e.
"
User's
Guide
to
Federal
Accidental
Release
Databases,"
Office
of
Solid
Waste
and
Emergency
Response,
September
1995.

U.
S.
EPA,
1995f.
Information
from
the
ENVIROFACTS
database
on
the
U.
S.
EPA
World
Wide
Web
site:
(
http://
www.
epa.
gov/
enviro/
html/
ef_
home.
html).
U.
S.
EPA,
1999g.
"
1997
Toxics
Release
Inventory
Public
Data
Release:
State
Fact
Sheets,
Office
of
Pollution
Prevention
and
Toxics,
EPA
745­
F­
99­
001,
March
1995.
October,
2003
91
U.
S.
EPA
1995h.
"
An
Overview
of
the
Toxics
Release
Inventory
Data
in
the
U.
S.,"
Environmental
Assistance
Division,
Office
of
Pollution
Prevention
and
Toxics,
June,
1995.

U.
S.
EPA,
1996.
SPEC.
TXT,
document
on
CHIEF
(
Clearing
House
for
Inventories
and
Emissions
Factors)
BBS
on
the
Technology
Transfer
Network
(
TTN)
BBS.
Dialup
(
919­
541­
5742)
or
ftp
(
ttnftp.
rtpnc.
epa.
gov).

U.
S.
EPA,
1999.
"
Economic
Analysis
of
the
Final
Rule
to
Modify
Reporting
of
Persistent
Bioaccumulative
Toxic
Chemicals
Under
EPCRA
Section
313".
Economics,
Exposure
and
Technology
Division,
Office
of
Pollution
Prevention
and
Toxics.
October
1999.
Wakefield,
Mary
Jean,
AFS
Helpline
1­
800­
367­
1044,
1995.
Conversation
with
Abt
Associates.
November
28,
1995.
October,
2003
A­
1
ATTACHMENT
A
Toxic
Chemical
Release
Inventory
Reporting
Form
R
(
EPA
Form
#
9350­
1)
(
Note:
This
form
is
the
last
approved
by
OMB
and
can
be
downloaded
in
.
pdf
format
from
www.
epa.
gov/
tri/
report/
form_
r.
pdf)
October,
2003
B­
1
ATTACHMENT
B
TRI
Chemicals
Reported
to
Non­
TRI
Databases
The
first
two
tables
in
this
attachment
compare
chemical
coverage
between
TRI
and
three
mediaspecific
databases:
AFS
(
AIRS
Facility
Subsystem),
BRS
(
Biennial
Reporting
System),
and
PCS
(
Permit
Compliance
System).
These
three
databases
were
chosen
for
analysis
because
they
contain
mediaspecific
chemical
release
information.
The
third
attachment
discusses
the
accessibility
of
the
data
in
each
of
these
sources.

The
chemicals
currently
in
TRI
are
listed
in
Attachment
B­
1,
while
the
TRI
chemical
categories
are
listed
in
Attachment
B­
2.
For
each
TRI
chemical
or
category,
there
is
a
table
entry
which
contains
its
name
as
listed
in
TRI,
its
CAS
number
or
TRI­
assigned
category
number,
and
indicators
as
to
whether
or
not
that
particular
TRI
chemical
is
tracked
by
AFS,
BRS,
and/
or
PCS.
A
dot
in
the
AFS,
BRS,
or
PCS
columns
indicates
that
the
chemical
listed
at
that
row
is
either
tracked
by
that
database
or
is
speciable
using
data
from
that
database.
While
a
dot
means
that
the
particular
chemical
is
tracked
by
both
TRI
and
the
database
in
question,
it
does
not
necessarily
mean
that
a
facility
releasing
the
chemical
reports
that
specific
chemical
to
both
systems.
In
other
words,
the
same
facility
may
not
be
reporting
the
same
information
to
different
programs.
Therefore,
the
indication
that
a
chemical
is
tracked
in
both
systems
does
not
mean
the
information
contained
in
the
systems
is
equivalent.

AFS
matches
are
based
on
emissions
data
"
speciated"
from
limited
industry
profiles,
and
are
not
derived
from
directly
reported
data.
Speciated
chemical
emissions
are
estimated
using
SPECIATE
and
are
based
on
actual
reported
PM­
10
and
VOC
emissions.
Please
see
section
5(
a)
of
this
supporting
statement
for
a
description
of
SPECIATE.

Because
data
categorized
by
BRS
waste
codes
can
be
only
partially
translated
into
chemicalspecific
information,
chemicals
have
been
tagged
in
the
table
as
reporting
to
BRS
only
where
there
is
CAS­
specific
data
that
can
be
matched.
Other
wastestreams
may
contain
additional
TRI
chemicals,
but
because
their
waste
codes
are
not
CAS­
specific,
it
is
difficult
to
determine
which
chemicals
(
as
well
as
how
much
of
them)
are
actually
in
the
wastestream.

PCS
chemicals
are
tagged
in
the
table
if
at
least
one
PCS
facility
reports
the
chemical
as
part
of
its
Discharge
Monitoring
Report
(
DMR).
Therefore,
because
a
chemical
is
tagged
does
not
necessarily
mean
that
it
is
significantly
represented
in
PCS.
In
addition,
because
the
list
of
chemicals
a
facility
reports
depends
heavily
on
the
language
of
the
permit,
facilities
releasing
identical
chemicals
may
not
be
required
to
report
the
same
set
of
chemicals
to
PCS.
October,
2003
B­
2
Attachment
B­
1
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
1,1,1,2­
Tetrachloro­
2­
fluoroethane
(
HCFC­
121a)
354110
1,1,1,2­
Tetrachloroethane
630206
!

1,1,1­
Trichloroethane
71556
!
!
!

1,1,2,2­
Tetrachloro­
1­
fluoroethane
(
HCFC­
121)
354143
1,1,2,2­
Tetrachloroethane
79345
!
!

1,1,2­
Trichloroethane
79005
!
!
!

1,1­
Dichloro­
1,2,2,3,3­
pentafluoropropane
(
HCFC­
225cc)
13474889
1,1­
Dichloro­
1,2,2­
trifluoroethane
(
HCFC­
123b)
812044
1,1­
Dichloro­
1,2,3,3,3­
pentafluoropropane
(
HCFC­
225eb)
111512562
1,1­
Dichloro­
1­
fluoroethane
(
HCFC­
141b)
1717006
1,1­
Dimethyl
hydrazine
57147
!

1,2,3­
Trichloropropane
96184
1,2,4­
Trichlorobenzene
120821
!

1,2,4­
Trimethylbenzene
95636
!
!

1,2­
Butylene
oxide
106887
1,2­
Dibromo­
3­
chloropropane
96128
!

1,2­
Dibromoethane
106934
!
!
!

1,2­
Dichloro­
1,1,2,3,3­
pentafluoropropane
(
HCFC­
225bb)
422446
1,2­
Dichloro­
1,1,2­
trifluoroethane
(
HCFC­
123a)
354234
1,2­
Dichloro­
1,1,3,3,3­
pentafluoropropane
(
HCFC­
225da)
431867
1,2­
Dichloro­
1,1­
difluoroethane
(
HCFC­
132b)
1649087
1,2­
Dichlorobenzene
95501
!
!
!

1,2­
Dichloroethane
107062
!
!
!

1,2­
Dichloroethylene
540590
1,2­
Dichloropropane
78875
!
!

1,2­
Diphenylhydrazine
122667
!
!

1,2­
Phenylenediamine
95545
1,2­
Phenylenediamine
dihydrochloride
615281
1,3­
Butadiene
106990
!

1,3­
Dichloro­
1,1,2,2,3­
pentafluoropropane
(
HCFC­
225cb)
507551
1,3­
Dichloro­
1,1,2,3,3­
pentafluoropropane
(
HCFC­
225ea)
136013791
1,3­
Dichlorobenzene
541731
!
!
!

1,3­
Dichloropropylene
542756
!
!
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
3
1,3­
Phenylenediamine
108452
1,4­
Dichloro­
2­
butene
764410
!
!

1,4­
Dichlorobenzene
106467
!
!
!

1,4­
Dioxane
123911
!
!

1,4­
Phenylenediamine
dihydrochloride
624180
1­(
3­
Chloroallyl)­
3,5,7­
triaza­
1­
azoniaadamantane
chloride
4080313
1­
Amino­
2­
methylanthraquinone
82280
1­
Bromo­
1­(
bromomethyl)­
1,3­
propanedicarbonitrile
35691657
1­
Chloro­
1,1,2,2­
tetrafluoroethane
(
HCFC­
124a)
354256
1­
Chloro­
1,1­
difluoroethane
(
HCFC­
142b)
75683
2,2­
Dibromo­
3­
nitrilopropionamide
10222012
2,2­
Dichloro­
1,1,1,3,3­
pentafluoropropane
(
HCFC­
225aa)
128903219
2,2­
Dichloro­
1,1,1­
trifluoroethane
(
HCFC­
123)
306832
2,3,5­
Trimethylphenyl
methylcarbamate
2655154
2,3­
Dichloro­
1,1,1,2,3­
pentafluoropropane
(
HCFC­
225ba)
422480
2,3­
Dichloropropene
78886
2,4,5­
Trichlorophenol
95954
!

2,4,6­
Trichlorophenol
88062
!

2,4­
D
94757
!
!

2,4­
D
2­
ethyl­
4­
methylpentyl
ester
53404378
2,4­
D
2­
ethylhexyl
ester
1928434
2,4­
D
butoxyethyl
ester
1929733
2,4­
D
butyl
ester
94804
2,4­
D
chlorocrotyl
ester
2971382
2,4­
D
isopropyl
ester
94111
2,4­
D
propylene
glycol
butyl
ether
ester
1320189
2,4­
D
sodium
salt
2702729
2,4­
DB
94826
2,4­
Diaminoanisole
615054
2,4­
Diaminoanisole
sulfate
39156417
2,4­
Diaminotoluene
95807
!

2,4­
Dichlorophenol
120832
!
!

2,4­
Dimethylphenol
105679
!
!

2,4­
Dinitrophenol
51285
!
!

2,4­
Dinitrotoluene
121142
!
!

2,4­
Dithiobiuret
541537
!

2,4­
DP
(
Dichlorprop)
120365
!
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
4
2,6­
Dimethylphenol
576261
2,6­
Dinitrotoluene
606202
!
!

2,6­
Xylidine
87627
2­
Acetylaminofluorene
53963
!

2­
Aminoanthraquinone
117793
2­
Bromo­
2­
nitropropane­
1,3­
diol
(
Bronopol)
52517
2­
Chloro­
1,1,1,2­
tetrafluoroethane
(
HCFC­
124)
2837890
2­
Chloro­
1,1,1­
trifluoroethane
(
HCFC­
133a)
75887
2­
Chloroacetophenone
532274
2­
Ethoxyethanol
110805
!
!

2­
Mercaptobenzothiazole
(
MBT)
149304
2­
Methoxyethanol
109864
!

2­
Methyllactonitrile
75865
!

2­
Methylpyridine
109068
!

2­
Nitrophenol
88755
!

2­
Nitropropane
79469
!

2­
Phenylphenol
90437
!

3,3'­
Dichlorobenzidine
91941
!
!

3,3'­
Dichlorobenzidine
dihydrochloride
612839
3,3'­
Dichlorobenzidine
sulfate
64969342
3,3'­
Dimethoxybenzidene
dihydrochloride
(
o­
Dianisidine
dihyd
20325400
3,3'­
Dimethoxybenzidine
119904
!

3,3'­
Dimethoxybenzidine
hydrochloride
(
o­
Dianisidine
hydroch
111984099
3,3'­
Dimethylbenzidine
119937
!

3,3'­
Dimethylbenzidine
dihydrochloride
(
o­
Tolidine
dihydroch
612828
3,3'­
Dimethylbenzidine
dihydrofluoride
(
o­
Tolidine
dihydrofl
41766750
3,3­
Dichloro­
1,1,1,2,2­
pentafluoropropane
(
HCFC­
225ca)
422560
3,4­
Dichloropentafluoropropane
127564925
3­
Chloro­
1,1,1­
trifluoropropane
(
HCFC­
253fb)
460355
3­
Chloro­
2­
methyl­
1­
propene
563473
3­
Chloropropionitrile
542767
!

3­
Iodo­
2­
propynyl
butylcarbamate
55406536
4,4'­
Diaminodiphenyl
ether
101804
4,4'­
Isopropylidenediphenol
80057
!

4,4'­
Methylenebis(
2­
chloroaniline)
101144
!

4,4'­
Methylenebis(
N,
N­
dimethyl)
benzenamine
101611
4,4'­
Methylenedianiline
101779
!
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
5
4,4'­
Thiodianiline
139651
4,6­
Dinitro­
o­
cresol
534521
!
!

4­
Aminoazobenzene
60093
4­
Aminobiphenyl
92671
4­
Dimethylaminoazobenzene
60117
!

4­
Nitrobiphenyl
92933
4­
Nitrophenol
100027
!
!

5­
Nitro­
o­
anisidine
99592
5­
Nitro­
o­
toluidine
99558
!

Abamectin
71751412
Acephate
30560191
Acetaldehyde
75070
!
!

Acetamide
60355
Acetonitrile
75058
!
!

Acetophenone
98862
!
!

Acifluorfen
sodium
salt
62476599
Acrolein
107028
!
!
!

Acrylamide
79061
!

Acrylic
acid
79107
!
!

Acrylonitrile
107131
!
!
!

Alachlor
15972608
!

Aldicarb
116063
!
!

Aldrin
309002
!
!

Allyl
alcohol
107186
!

Allyl
chloride
107051
!

Allylamine
107119
alpha­
Hexachlorocyclohexane
319846
!

alpha­
Naphthylamine
134327
!

Aluminum
(
fume
or
dust)
7429905
!
!

Aluminum
oxide
(
fibrous
forms)
1344281
Aluminum
phosphide
20859738
!

Ametryn
834128
Amitraz
33089611
Amitrole
61825
!

Ammonia
7664417
!
!

Anilazine
101053
Aniline
62533
!
!
!
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
6
Anthracene
120127
!
!

Antimony
7440360
!
!

Arsenic
7440382
!
!

Asbestos
(
friable)
1332214
!

Atrazine
1912249
Barium
7440393
!
!

Bendiocarb
22781233
Benfluralin
1861401
Benomyl
17804352
Benzal
chloride
98873
!

Benzamide
55210
Benzene
71432
!
!
!

Benzidine
92875
!
!

Benzoic
trichloride
98077
!

Benzoyl
chloride
98884
Benzoyl
peroxide
94360
Benzyl
chloride
100447
!
!

Beryllium
7440417
!
!
!

beta­
Naphthylamine
91598
!

beta­
Propiolactone
57578
Bifenthrin
82657043
Biphenyl
92524
!

Bis(
2­
chloro­
1­
methylethyl)
ether
108601
!
!

Bis(
2­
chloroethoxy)
methane
111911
!
!

Bis(
2­
chloroethyl)
ether
111444
!
!

Bis(
chloromethyl)
ether
542881
!
!

Bis(
tributyltin)
oxide
56359
Boron
trichloride
10294345
Boron
trifluoride
7637072
Bromacil
314409
Bromacil
lithium
salt
53404196
Bromine
7726956
!

Bromochlorodifluoromethane
{
Halon
1211}
353593
Bromoform
75252
!
!

Bromomethane
74839
!
!

Bromotrifluoromethane
{
Halon
1301}
75638
Bromoxynil
1689845
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
7
Bromoxynil
octanoate
1689992
Brucine
357573
!

Butyl
acrylate
141322
!

Butyraldehyde
123728
!

C.
I.
Acid
Green
3
4680788
C.
I.
Acid
Red
114
6459945
C.
I.
Basic
Green
4
569642
C.
I.
Basic
Red
1
989388
C.
I.
Direct
Black
38
1937377
C.
I.
Direct
Blue
218
28407376
C.
I.
Direct
Blue
6
2602462
C.
I.
Direct
Brown
95
16071866
C.
I.
Disperse
Yellow
3
2832408
C.
I.
Food
Red
15
81889
C.
I.
Food
Red
5
3761533
C.
I.
Solvent
Orange
7
3118976
C.
I.
Solvent
Yellow
14
842079
C.
I.
Solvent
Yellow
3
97563
C.
I.
Solvent
Yellow
34
492808
!

C.
I.
Vat
Yellow
4
128665
Cadmium
7440439
!
!

Calcium
cyanamide
156627
Captan
133062
Carbaryl
63252
Carbofuran
1563662
!

Carbon
disulfide
75150
!
!
!

Carbon
tetrachloride
56235
!
!
!

Carbonyl
sulfide
463581
Carboxin
5234684
Catechol
120809
Chinomethionat
2439012
Chloramben
133904
Chlordane
57749
!
!

Chlorendic
acid
115286
!

Chlorimuron
ethyl
90982324
Chlorine
7782505
!
!

Chlorine
dioxide
10049044
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
8
Chloroacetic
acid
79118
Chlorobenzene
108907
!
!
!

Chlorobenzilate
510156
Chlorodifluoromethane
(
HCFC­
22)
75456
!
!

Chloroethane
75003
!
!

Chloroform
67663
!
!
!

Chloromethane
74873
!
!
!

Chloromethyl
methyl
ether
107302
!

Chloropicrin
76062
Chloroprene
126998
!

Chlorotetrafluoroethane
63938103
Chlorothalonil
1897456
!

Chlorotrifluoromethane
(
CFC­
13)
75729
!

Chlorpyrifos
methyl
5598130
Chlorsulfuron
64902723
Chromium
7440473
!
!

Cobalt
7440484
!
!

Copper
7440508
!
!

Creosote
8001589
!
!

Cresol
(
mixed
isomers)
1319773
!
!
!

Crotonaldehyde
4170303
!

Cumene
98828
!
!
!

Cumene
hydroperoxide
80159
!

Cupferron
135206
Cyanazine
21725462
Cycloate
1134232
Cyclohexane
110827
!
!
!

Cyclohexanol
108930
Cyfluthrin
68359375
Cyhalothrin
68085858
d­
trans­
Allethrin
28057489
Dazomet
533744
Dazomet
sodium
salt
53404607
Decabromodiphenyl
oxide
1163195
Desmedipham
13684565
Di(
2­
ethylhexyl)
phthalate
117817
!
!

Diallate
2303164
!
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
9
Diaminotoluene
(
mixed
isomers)
25376458
!

Diazinon
333415
!

Diazomethane
334883
Dibenzofuran
132649
Dibromotetrafluoroethane
{
Halon
2402}
124732
Dibutyl
phthalate
84742
!
!
!

Dicamba
(
3,6­
Dichloro­
2­
methyoxybenzoic
acid)
1918009
Dichloran
(
2,6­
Dichloro­
4­
nitroaniline)
99309
Dichloro­
1,1,2­
trifluoroethane
90454185
Dichlorobenzene
(
mixed
isomers)
25321226
!

Dichlorobromomethane
75274
!

Dichlorodifluoromethane
(
CFC­
12)
75718
!
!
!

Dichlorofluoromethane
(
HCFC­
21)
75434
Dichloromethane
75092
!
!
!

Dichlorophene
(
2,2'­
Methylenebis(
4­
chlorophenol)
97234
Dichlorotetrafluoroethane
(
CFC­
114)
76142
!

Dichlorotrifluoroethane
34077877
Dichlorvos
62737
Diclofop
methyl
51338273
Dicofol
115322
Dicyclopentadiene
77736
Diepoxybutane
1464535
Diethanolamine
111422
Diethatyl
ethyl
38727558
Diethyl
sulfate
64675
Diflubenzuron
35367385
Diglycidyl
resorcinol
ether
101906
Dihydrosafrole
94586
Dimethipin
55290647
Dimethoate
60515
!

Dimethyl
chlorothiophosphate
2524030
Dimethyl
phthalate
131113
!
!
!

Dimethyl
sulfate
77781
!

Dimethylamine
124403
!

Dimethylamine
dicamba
2300665
Dimethylcarbamyl
chloride
79447
!

Dimethyldichlorosilane
75785
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
10
Dinitrobutyl
phenol
(
Dinoseb)
88857
!
!

Dinitrotoluene
(
mixed
isomers)
25321146
Dinocap
39300453
Diphenamid
957517
Diphenylamine
122394
Dipotassium
endothall
2164070
Dipropyl
isocinchomeronate
136458
Disodium
cyanodithioimidocarbonate
138932
Diuron
330541
Dodine
(
Dodecylguanidine
monoacetate)
2439103
Epichlorohydrin
106898
!
!
!

Ethoprop
13194484
Ethyl
acrylate
140885
!
!

Ethyl
chloroformate
541413
Ethyl
dipropylthiocarbamate
(
EPTC)
759944
Ethylbenzene
100414
!
!

Ethylene
74851
!

Ethylene
glycol
107211
!
!

Ethylene
oxide
75218
!
!

Ethylene
thiourea
96457
!

Ethyleneimine
151564
!

Ethylidene
dichloride
75343
!
!

Famphur
52857
!

Fenarimol
60168889
Fenbutatin
oxide
13356086
Fenoxaprop
ethyl
66441234
Fenoxycarb
72490018
Fenpropathrin
39515418
Fenthion
55389
Fenvalerate
51630581
Ferbam
14484641
Fluazifop
butyl
69806504
Fluometuron
2164172
Fluorine
7782414
!
!

Fluorouracil
(
5­
Fluorouracil)
51218
Fluvalinate
69409945
Folpet
133073
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
11
Fomesafen
72178020
Formaldehyde
50000
!
!
!

Formic
acid
64186
!
!

Freon
113
76131
!
!

Heptachlor
76448
!
!

Hexachloro­
1,3­
butadiene
87683
!
!

Hexachlorobenzene
118741
!
!

Hexachlorocyclopentadiene
77474
!
!

Hexachloroethane
67721
!
!

Hexachloronaphthalene
1335871
Hexachlorophene
70304
!

Hexamethylphosphoramide
680319
!

Hexazinone
51235042
Hydramethylnon
67485294
Hydrazine
302012
!
!

Hydrazine
sulfate
10034932
Hydrochloric
acid
7647010
Hydrogen
cyanide
74908
!

Hydrogen
fluoride
7664393
!

Hydrogen
sulfide
7783064
!
!
!

Hydroquinone
123319
!

Imazalil
35554440
Iron
pentacarbonyl
13463406
Isobutyraldehyde
78842
!

Isodrin
465736
!

Isofenphos
25311711
Isopropyl
alcohol
(
manufacturing­
strong
acid
process)
67630
!
!

Isosafrole
120581
!

Lactofen
77501634
Lead
7439921
!
!

Lindane
58899
!
!

Linuron
330552
Lithium
carbonate
554132
m­
Cresol
108394
m­
Dinitrobenzene
99650
m­
Xylene
108383
!

Malathion
121755
!
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
12
Maleic
anhydride
108316
!
!

Malononitrile
109773
!

Maneb
12427382
Manganese
7439965
!
!

Mecoprop
93652
Mercury
7439976
!
!

Merphos
150505
Methacrylonitrile
126987
!

Metham
sodium
(
Sodium
methyldithiocarbamate)
137428
Methanol
67561
!
!

Methazole
20354261
Methiocarb
2032657
Methoxone
94746
Methoxone
sodium
salt
3653483
Methoxychlor
72435
!
!

Methyl
acrylate
96333
!

Methyl
chlorocarbonate
79221
!

Methyl
ethyl
ketone
78933
!
!
!

Methyl
hydrazine
60344
!

Methyl
iodide
74884
!

Methyl
isobutyl
ketone
108101
!
!
!

Methyl
isocyanate
624839
!

Methyl
isothiocyanate
556616
Methyl
mercaptan
74931
!

Methyl
methacrylate
80626
!
!
!

Methyl
parathion
298000
!

Methyl
tert­
butyl
ether
1634044
Methylene
bromide
74953
!
!

Methyltrichlorosilane
75796
Metiram
9006422
!

Metribuzin
21087649
Mevinphos
7786347
Michler's
ketone
90948
Molinate
2212671
Molybdenum
trioxide
1313275
Monochloropentafluoroethane
{
CFC­
115}
76153
!

Monuron
150685
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
13
Mustard
gas
505602
Myclobutanil
88671890
N,
N­
Dimethylaniline
121697
!

N,
N­
Dimethylformamide
68122
!

n­
Butyl
alcohol
71363
!
!

n­
Hexane
110543
!

N­
Methyl­
2­
pyrrolidone
872504
N­
Methylolacrylamide
924425
N­
Nitroso­
N­
ethylurea
759739
!

N­
Nitroso­
N­
methylurea
684935
!

N­
Nitrosodi­
n­
butylamine
924163
!

N­
Nitrosodi­
n­
propylamine
621647
!
!

N­
Nitrosodiethylamine
55185
!

N­
Nitrosodimethylamine
62759
!
!

N­
Nitrosodiphenylamine
86306
!

N­
Nitrosomethylvinylamine
4549400
N­
Nitrosomorpholine
59892
N­
Nitrosonornicotine
16543558
N­
Nitrosopiperidine
100754
Nabam
142596
Naled
300765
Naphthalene
91203
!
!
!

Nickel
7440020
!
!

Nitrapyrin
1929824
Nitric
acid
7697372
Nitrilotriacetic
acid
139139
Nitrobenzene
98953
!
!
!

Nitrofen
1836755
Nitrogen
mustard
51752
Nitroglycerin
55630
!
!

Norflurazon
27314132
Octachloronaphthalene
2234131
ortho­
Anisidine
90040
ortho­
Anisidine
hydrochloride
134292
ortho­
Cresol
95487
ortho­
Dinitrobenzene
528290
ortho­
Toluidine
95534
!
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
14
ortho­
Toluidine
hydrochloride
636215
!

ortho­
Xylene
95476
!

Oryzalin
19044883
Osmium
tetroxide
20816120
!

Oxydemeton
methyl
301122
Oxydiazon
19666309
Oxyfluorfen
42874033
Ozone
10028156
p­
Anisidine
104949
p­
Chloro­
o­
toluidine
95692
p­
Chloroaniline
106478
!

p­
Chlorophenyl
isocyanate
104121
p­
Cresidine
120718
p­
Cresol
106445
!

p­
Dinitrobenzene
100254
p­
Nitroaniline
100016
!

p­
Nitrosodiphenylamine
156105
p­
Phenylenediamine
106503
p­
Xylene
106423
!

Paraldehyde
123637
!

Paraquat
dichloride
1910425
Parathion
56382
!
!

Pebulate
1114712
Pendimethalin
40487421
Pentachloroethane
76017
!

Pentachlorophenol
87865
!

Pentobarbital
sodium
57330
Peracetic
acid
79210
Perchloromethyl
mercaptan
594423
Permethrin
52645531
Phenanthrene
85018
!
!

Phenol
108952
!
!
!

Phenothrin
26002802
Phenytoin
57410
Phosgene
75445
!

Phosphine
7803512
!

Phosphoric
acid
7664382
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
15
Phosphorus
(
yellow
or
white)
7723140
!
!

Phthalic
anhydride
85449
!
!

Picloram
1918021
Picric
acid
88891
Piperonyl
butoxide
51036
Pirimiphos
methyl
29232937
Polychlorinated
biphenyls
1336363
Potassium
bromate
7758012
Potassium
dimethyldithiocarbamate
128030
Potassium
N­
methyldithiocarbamate
137417
Profenofos
41198087
 

Prometryn
7287196
Pronamide
23950585
!

Propachlor
1918167
!

Propane
sultone
1120714
!

Propanil
709988
Propargite
2312358
Propargyl
alcohol
107197
!

Propetamphos
31218834
Propiconazole
60207901
Propionaldehyde
123386
!

Propoxur
114261
Propylene
(
Propene)
115071
!

Propylene
oxide
75569
!

Propyleneimine
75558
!

Pyridine
110861
!
!

Quinoline
91225
Quinone
106514
!

Quintozene
82688
!

Quizalofop­
ethyl
76578148
Resmethrin
10453868
S,
S,
S­
Tributyltrithiophosphate
(
DEF)
78488
Saccharin
(
manufacturing)
81072
!

Safrole
94597
sec­
Butyl
alcohol
78922
!

Selenium
7782492
!
!

Sethoxydim
74051802
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
16
Silver
7440224
!
!

Simazine
122349
Sodium
azide
26628228
!

Sodium
dicamba
1982690
Sodium
dimethyldithiocarbamate
128041
Sodium
fluoroacetate
62748
!

Sodium
nitrite
7632000
!

Sodium
o­
phenylphenoxide
132274
Sodium
pentachlorophenate
131522
Styrene
100425
!
!

Styrene
oxide
96093
Sulfuric
acid
7664939
Sulfuryl
fluoride
(
Vikane)
2699798
Sulprofos
35400432
Tebuthiuron
34014181
Temephos
3383968
Terbacil
5902512
tert­
Butyl
alcohol
75650
!

Tetrachloroethylene
127184
!
!
!

Tetrachlorvinphos
961115
Tetracycline
hydrochloride
64755
Tetramethrin
7696120
Thallium
7440280
!

Thiabendazole
148798
Thioacetamide
62555
!

Thiobencarb
28249776
Thiodicarb
59669260
Thiophanate
ethyl
23564069
Thiophanate­
methyl
23564058
Thiosemicarbazide
79196
!

Thiourea
62566
!

Thiram
137268
!

Thorium
dioxide
1314201
Titanium
tetrachloride
7550450
Toluene
108883
!
!
!

Toluene­
2,4­
diisocyanate
584849
Toluene­
2,6­
diisocyanate
91087
October,
2003
TRI
Listed
Chemicals
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Name
CAS
Number
AFS
BRS
PCS
B­
17
Toluenediisocyanate
(
mixed
isomers)
26471625
!

Toxaphene
8001352
!
!

trans­
1,3­
Dichloropropene
10061026
!

trans­
1,4­
Dichloro­
2­
butene
110576
Triadimefon
43121433
Triallate
2303175
Triaziquone
68768
Tribenuron
methyl
101200480
Tributyltin
fluoride
1983104
Tributyltin
methacrylate
2155706
Trichlorfon
52686
Trichloroacetyl
chloride
76028
Trichloroethylene
79016
!
!
!

Trichlorofluoromethane
{
CFC­
11}
75694
!
!
!

Triclopyr
triethylammonium
salt
57213691
Triethylamine
121448
Trifluralin
1582098
Triforine
26644462
Trimethylchlorosilane
75774
Triphenyltin
chloride
639587
Triphenyltin
hydroxide
76879
Tris(
2,3­
dibromopropyl)
phosphate
126727
!

Trypan
blue
72571
!

Urethane
51796
!

Vanadium
(
fume
or
dust)
7440622
!
!

Vinclozolin
50471448
Vinyl
acetate
108054
!
!

Vinyl
bromide
593602
Vinyl
chloride
75014
!
!
!

Vinylidene
chloride
75354
!
!

Xylene
(
mixed
isomers)
1330207
!
!
!

Zinc
(
fume
or
dust)
7440666
!
!

Zineb
12122677
Source:
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313
October,
2003
B­
18
Attachment
B­
2
TRI
Listed
Chemical
Categories
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Category/
Constituent
CAS
Number/
TRI
Reference
AFS
BRS
PCS
Antimony
Compounds
N010
Arsenic
Compounds
N020
Barium
Compounds
N040
Beryllium
Compounds
N050
Cadmium
Compounds
N078
Chlorophenols
N084
Chromium
Compounds
N090
Cobalt
Compounds
N096
Copper
Compounds
N100
Cyanide
Compounds
N106
Diisocyanates
N120
1,3­
Bis(
methylisocyanate)­
cyclohexane
38861722
1,4­
Bis(
methylisocyanate)­
cyclohexane
10347543
1,4­
Cyclohexane
diisocyanate
25563671
Diethyldiisocyanatobenzene
134190377
4,4'­
Diisocyanatodiphenyl
ether
41287384
2,4'­
Diisocyanatodiphenyl
sulfide
757908732
3,3'­
Dimethoxybenzidine­
4,4'­
diisocyanate
91930
3,3'­
Dimethyl­
4,4'­
diphenylene
diisocyanate
91974
3,3'­
Dimethyldiphenylmethane­
4,4'­
diisocyanate
139253
Hexamethylene­
1,6­
diisocyanate
822060
Isophorone
diisocyanate
4098719
4­
Methyldiphenylmethane­
3,4­
diisocyanate
75790840
1,1­
Methylene
bis(
4­
isocyanatocyclohexane)
5124301
Methylene
bis(
phenylisocyanate)
(
MDI)
101688
1,5­
Naphthalene
diisocyanate
3173726
1,3­
Phenylene
diisocyanate
123615
1,4­
Phenylene
diisocyanate
104494
Polymeric
diphenylmethane
diisocyanate
9016879
2,2,4­
Trimethylhexamethylene
diisocyanate
16938220
2,4,4­
Trimethylhexamethylene
diisocyanate
15646965
Ethylenebisdithiocarbamic
acid,
salts
and
esters
N171
Glycol
Ethers
N230
October,
2003
TRI
Listed
Chemical
Categories
Directly
Reporting
to
AFS,
BRS,
and/
or
PCS
Chemical
Category/
Constituent
CAS
Number/
TRI
Reference
AFS
BRS
PCS
B­
19
Lead
Compounds
N420
Manganese
Compounds
N450
Mercury
Compounds
N458
Nickel
Compounds
N495
Nicotine
and
salts
N503
Nitrate
compounds
(
water
dissociable)
N511
!

Polybrominated
Biphenyls
(
PBBs)
N575
Polychlorinated
alkanes
N583
Polycyclic
aromatic
compounds
(
following
chemicals
only)
*
N590
Benz(
a)
anthracene
56553
!
!
!

Benzo(
a)
phenanthrene
218019
!
!

Benzo(
a)
pyrene
50328
!
!
!

Benzo(
b)
fluoranthene
205992!
!

Benzo(
j)
fluoranthene
205823
Benzo(
k)
fluoranthene
207089!
!

Benzo(
rst)
pentaphene
189559
!

Dibenz(
a,
h)
acridine
226368
Dibenz(
a,
j)
acridine
224420
Dibenzo(
a,
h)
anthracene
53703
!
!

Dibenzo(
a,
e)
fluoranthene
5385751
Dibenzo(
a,
e)
pyrene
192654
Dibenzo(
a,
h)
pyrene
189640
Dibenzo(
a,
l)
pyrene
191300
7H­
Dibenzo(
c,
g)
carbazole
194592
7,12­
Dimethylbenz(
a)
anthracene
57976
!

Indeno[
1,2,3­
cd]
pyrene
193395
5­
Methylchrysene
3697243
!
!
!

1­
Nitropyrene
5522430
Selenium
Compounds
N725
Silver
Compounds
N740
Strychnine
and
salts
N746
Thallium
Compounds
N760
Warfarin
and
salts
N874
Zinc
Compounds
N982
Source:
Source:
Economic
Analysis
of
the
Final
Rule
to
Add
Certain
Industry
Groups
to
EPCRA
Section
313
October,
2003
B­
20
October,
2003
B­
21
ATTACHMENT
B­
3
Public
Access
to
EPA
Databases
This
section
describes
some
of
the
various
avenues
of
access
available
to
public
users
of
TRI
and
other
databases.
Electronic
as
well
as
conventional
information
sources
are
included
in
the
discussion.

TOXICS
RELEASE
INVENTORY
(
TRI)

EPA
has
spent
considerable
effort
and
resources
to
make
TRI
available
to
the
public.
The
various
methods
through
which
a
concerned
citizen
can
access
TRI
include:

On­
Line
Resources
Internet
access
to
TRI
data
is
available
from
the
EPA
World
Wide
Web
(
WWW)
server
at
http://
www.
epa.
gov/,
through
the
ENVIROFACTS
system
(
described
below).
The
Right­
to­
Know
Computer
Network
(
RTK
NET)
provides
free
public
access
to
TRI
as
well
as
several
other
environmental
and
governmental
databases
(
and
is
also
described
below).
The
National
Library
of
Medicine
(
NLM)
TOXNET
System
is
an
on­
line
system
offering
on­
line
searching
of
the
TRI
database.
TOXNET
was
designed
to
be
easy
to
use
by
persons
with
limited
computer
experience,
and
can
be
reached
via
either
dial­
up
or
Internet.

Electronic
media
The
TRI
CD­
ROM
contains
the
complete
national
TRI,
starting
with
the
first
inventory
in
1987.
Chemical
Fact
Sheets
(
formerly
TRI­
FACTS)
containing
reference
material
on
the
health
and
ecological
effects
of
the
regulated
substances
are
also
available
on
the
same
CD­
ROM.
Contact/
Availability:
NTIS,
Government
Printing
Office
(
GPO),
EPA
National
Service
Center
for
Environmental
Publications
(
NSCEP),
Federal
Depository
Libraries,
EPA
Regional
Offices.

The
NESE­
DB
(
National
Economics,
Social
and
Environmental
Data
Bank)
CD­
ROM
includes
the
TRI
state
data
and
the
national
public
data
file
on
CD­
ROM.
The
disc
is
produced
quarterly
by
the
Department
of
Commerce
and
provides
access
to
socio­
economic
as
well
as
environmental
statistics
and
information.
The
data
are
gathered
from
over
15
federal
agencies.
Contact/
Availability:
Department
of
Commerce,
selected
federal
depository
libraries.

Diskettes:
Requesters
can
select
diskettes
by
state
or
for
the
entire
US
in
DBASE
III
format.
Diskettes
are
accompanied
by
documentation.
Contact/
Availability:
GPO,
EPA
Internet
site.

Printed
media
TRI
Reports:
EPA
assembles
several
detailed
annual
reports
providing
summaries,
analyses,
and
comparison
of
TRI
data
by
year.
The
reports
summarize
data
on
total
releases
and
transfers
of
TRI
October,
2003
17
See
Section
5(
a)
of
this
supporting
statement
for
a
more
detailed
discussion
of
FINDS.
18.
CERCLIS,
or
the
Comprehensive
Environmental
Response
Compensation
and
Liability
Information
System,
tracks
information
collected
under
CERCLA.
CERCLIS
contains
Superfund
data
on
hazardous
waste
site
assessment
and
remediation,
including
data
on
active
sites
from
point
of
discovery
to
listing
on
the
National
Priorities
List
through
completion
of
remedial
and
response
actions.
(
U.
S.
EPA,
1995f)
19
RCRIS,
or
the
Resource
Conservation
and
Recovery
Information
System,
is
used
primarily
to
track
entities
regulated
under
RCRA
Subtitle
C
(
hazardous
waste
handlers).
RCRIS
includes
data
on
general
handler
information,
permit
or
closure
status,
compliance
with
federal
and
state
regulations,
and
cleanup
activities.
(
U.
S.
EPA,
1995f)
20
SDWIS,
or
the
Safe
Drinking
Water
Information
System
contains
information
about
public
water
systems
and
their
violations
of
EPA's
drinking
water
regulations.
These
statutes
and
accompanying
regulations
establish
maximum
contaminant
levels,
treatment
techniques,
and
monitoring
and
reporting
requirements
to
ensure
that
water
provided
to
customers
is
safe
for
human
consumption.

B­
22
chemicals;
geographic
distribution
of
TRI
releases
and
transfers;
industrial
patterns
of
releases
and
transfers;
the
interstate
and
intrastate
transport
of
wastes
and
other
kinds
of
analyses.
Contact:
EPCRA
Information
Hotline,
NSCP,
EPA
Internet
site.

OTHER
ENVIRONMENTAL
DATABASES
On­
Line
Resources
The
Environmental
Protection
Agency
(
EPA)
created
the
Envirofacts
Warehouse
(
http://
www.
epa.
gov/
enviro/
index_
java.
html)
to
provide
the
public
with
direct
access
to
the
Agency's
databases.
The
Envirofacts
Warehouse
allows
users
to
retrieve
environmental
information
from
EPA
databases
on
Air,
Chemicals,
Facility
Information,
Grants/
Funding,
Hazardous
Waste,
Spatial
Data,
Superfund,
Toxic
Releases,
and
Water
Permits
and
Drinking
Water.
Users
may
retrieve
information
from
several
databases
at
once,
or
from
one
database
at
a
time.
They
may
use
online
queries
to
retrieve
data
from
these
sources
and
create
reports,
or
generate
maps
of
environmental
information
by
selecting
from
several
mapping
applications
available
through
EPA's
Maps
On
Demand.

ENVIROFACTS
is
a
relational
database
that
integrates
data
from
several
major
EPA
program
systems,
as
well
as
the
Facility
Indexing
System
(
FINDS)
and
the
ENVIROFACTS
Master
Chemical
Integrator
(
ECMI),
which
is
a
cross
reference
index
of
chemical
data
reported
in
the
program
systems.
ENVIROFACTS
allows
the
user
to
perform
queries
that
integrate
facility
data
from
the
multiple
databases
based
on
their
FINDS
IDs.
14
ENVIROFACTS
includes
monthly­
updated
data
available
under
the
Freedom
of
Information
Act.
No
enforcement
or
budget­
sensitive
information
is
contained
in
ENVIROFACTS.
Databases
include:

AFS
BRS
PCS
CERCLIS15
TRIS
RCRIS16
SDWIS17
FINDS
ENVIROFACTS
Master
Chemical
Integrator
(
EMCI)
October,
2003
B­
23
In
addition
to
ENVIROFACTS,
The
EPA
World
Wide
Web
(
WWW)
site
provides
access
to
other
release
and
transfer
databases,
including:

AIRS
Executive:
AIRS
Executive
is
a
software
package
designed
for
easy
access
and
presentation
of
some
of
the
most
frequently
used
data
in
AIRS.
The
whole
software
package
and
the
monthly
data
updates
are
downloadable
from
the
EPA
WWW
site
(
http://
www.
epa.
gov/
airs/
aexec.
html).
However,
it
does
not
contain
the
extensive
air
pollution
data
found
in
AIRS
proper,
which
is
available
on
the
EPA
mainframe.

BRS
Hazardous
Waste
Reports
and
Data
Files:
The
BRS
data
is
contained
in
self­
extracting
zipped
flat
files
and
are
also
downloadable
from
the
EPA
WWW
site.
At
the
time
of
this
writing,
the
most
current
version
of
the
report
is
based
on
the
1997
BRS
data,
and
can
be
accessed
at
http://
www.
epa.
gov/
docs/
OSWRCRA/
hazwaste/
data/.
The
data
files
themselves
are
also
available
on
the
WWW
site,
although
expanding
a
year's
worth
of
BRS
data
requires
over
200
MB
of
disk
space.
In
addition,
a
software
package
such
as
SAS
is
necessary
for
manageable
data
manipulation.
Hard
copies
of
the
National
Biennial
RCRA
Hazardous
Waste
Report
are
also
available
from
NTIS.

The
Right­
to­
Know
Computer
Network
(
RTK
NET)
is
an
online
service
run
by
OMB
Watch
and
the
Unison
Institute.
RTK
NET
offers
free
access
to
multiple
health
and
environmental
databases,
including:

ARIP
Accidental
Release
Information
Program
BRS
Biennial
Reporting
System
DOCKET
Criminal
and
Enforcement
Dockets
FINDS
Facility
Indexing
System
PCS
Permit
Compliance
System
TRI
Toxics
Release
Inventory
CERCLIS
CERCLA
Information
System
ERNS
Emergency
Response
Notification
System
TSCATS
Toxic
Substances
Control
Act
Submissions
RCRIS
Resource
Conservation
and
Recovery
Act
Information
System
Data
within
RTK
Net
is
only
that
which
is
publicly
accessible
by
other
means.
In
other
words,
no
CBI
is
included.
Access
is
free.
RTK
NET
can
be
reached
via
dialup
or
Internet
(
www.
rtk.
net).

Resources
on
the
EPA
Mainframe
include
the
following
databases:

AFS
AIRS
Facility
Subsystem
BRS
Biennial
Reporting
System
CERCLIS
CERCLA
Information
System
DOCKET
Criminal
and
Enforcement
Dockets
October,
2003
B­
24
DUNS
Dun
and
Bradstreet
Marketing
Services
­­
Identifier
File
ERNS
Emergency
Response
Notification
System
FFIS
Federal
Facilities
Information
System
FINDS
Facility
Indexing
System
PCS
Permit
Compliance
System
RCRIS
Resource
Conservation
and
Recovery
Information
System
TRI
Toxics
Release
Inventory
Selected
data
fields
from
these
and
other
databases
are
linked
together
at
the
facility
level
through
IDEA
(
Integrated
Data
for
Enforcement
Analysis).
A
more
detailed
description
of
IDEA
can
be
found
in
Section
5(
a)
of
this
supporting
statement.

ERNS
can
also
be
reached
through
the
Department
of
Transportation's
(
DOT)
VAX
minicomputer
in
Cambridge
MA.
Online
access
is
restricted
to
EPA
and
other
authorized
federal
governmental
personnel.
EPA's
Emergency
Response
Division
in
the
Office
of
Emergency
and
Remedial
Response
provides
fact
sheets,
hard
copies,
diskettes,
or
tapes
of
requested
information.

Other
Resources
The
Freedom
of
Information
Act
(
FOIA)
is
another
mechanism
that
can
be
utilized
by
the
public
to
request
information
from
EPA.
A
FOIA
is
a
written
request
for
records
held
or
believed
to
be
held
by
EPA
where
a
record
is
defined
as
any
existing
document,
memorandum,
report,
photograph,
sound
or
magnetic
recording,
computer
tape,
drawing,
or
other
medium
in
which
information
has
been
preserved.
FOIAs
are
usually
utilized
when
there
are
not
other
direct
methods,
such
as
hotlines
or
clearinghouses,
available
through
which
the
public
can
request
the
information.
EPA
will
release
the
requested
information
unless
it
falls
under
one
of
the
following
nine
exemptions:

Matters
of
national
defense
or
foreign
policy.
Internal
Agency
rules.
Information
exempted
by
other
statutes.
Trade
secrets,
commercial,
or
financial
information­­
Confidential
Business
Information
(
CBI).
Privileged
inter­
or
intra­
Agency
memoranda.
Personal
privacy.
Records
or
information
compiled
for
law
enforcement
purposes.
Records
of
financial
institutions.
Geographical
or
geophysical
information
and
data
concerning
wells.

FOIA
authorizes
EPA
to
charge
requesters
the
direct
cost
for
any
searching,
reviewing,
and
duplication
required
to
respond
to
the
request
if
these
costs
exceed
$
25.00.

The
National
Technical
Information
Service
(
NTIS),
a
component
of
the
Department
of
Commerce,
is
used
extensively
by
many
EPA
system
managers
to
make
information
available
to
the
public.
NTIS,
by
law,
is
self­
supporting
and
sells
its
products
and
services
to
users
on
a
cost­
recovery
basis.
NTIS
reproduces
and
sells
the
material
created
by
EPA
which
includes
publications,
diskettes,
CD
ROMs,
October,
2003
B­
25
magnetic
tapes,
and
video
tapes.
To
search
online
for
environmental
reports,
NTIS's
Bibliographic
Database
is
offered
through
various
commercial
services.
In
addition,
NTIS
publishes
a
twice
monthly
subscription,
the
NTIS
Alert
on
Environmental
Pollution
&
Control.
This
subscription
provides
summaries
of
newly
issued
environmental
reports
and
studies
released
by
Government
agencies.
NTIS
offers
several
EPA
databases
on
computer
tape
and
CD­
ROM.
Some
of
the
databases
are
text
only,
requiring
the
user
to
provide
their
own
search
and
retrieval
software.

Available
databases
include:

CERCLIS
CERCLA
Information
System
(
text
only)
ERNS
Emergency
Response
Notification
System
(
text
only)
FINDS
Facility
Indexing
System
(
text
only)
ISI
Information
Systems
Inventory
(
an
inventory
of
inventories)
IRIS
Integrated
Risk
Information
System
PCS
Permit
Compliance
System
RCRIS
ExtractsRCRA
Information
System
TRI
Toxics
Release
Inventory
(
CD­
ROM)
TSCA
Inventory
Toxic
Substances
Control
Act
Chemical
Substances
Inventory
October,
2003
ATTACHMENT
C
Emergency
Planning
and
Community
Right
to
Know
Act
of
1986,
Section
313
(
42
U.
S.
C.
A.
Section
1023)
October,
2003
C­
1
EMERGENCY
PLANNING
AND
COMMUNITY
RIGHT­
TO­
KNOW
ACT
SECTION
313
UNITED
STATES
CODE
TITLE
42
­
THE
PUBLIC
HEALTH
AND
WELFARE
CHAPTER
116
­
EMERGENCY
PLANNING
AND
COMMUNITY
RIGHT­
TO­
KNOW
SUBCHAPTER
I
­
EMERGENCY
PLANNING
AND
NOTIFICATION
§
11023.
Toxic
chemical
release
forms
(
a)
Basic
requirement
The
owner
or
operator
of
a
facility
subject
to
the
requirements
of
this
section
shall
complete
a
toxic
chemical
release
form
as
published
under
subsection
(
g)
of
this
section
for
each
toxic
chemical
listed
under
subsection
(
c)
of
this
section
that
was
manufactured,
processed,
or
otherwise
used
in
quantities
exceeding
the
toxic
chemical
threshold
quantity
established
by
subsection
(
f)
of
this
section
during
the
preceding
calendar
year
at
such
facility.
Such
form
shall
be
submitted
to
the
Administrator
and
to
an
official
or
officials
of
the
State
designated
by
the
Governor
on
or
before
July
1,
1988,
and
annually
thereafter
on
July
1
and
shall
contain
data
reflecting
releases
during
the
preceding
calendar
year.

(
b)
Covered
owners
and
operators
of
facilities
(
1)
In
general
(
A)
The
requirements
of
this
section
shall
apply
to
owners
and
operators
of
facilities
that
have
10
or
more
full­
time
employees
and
that
are
in
Standard
Industrial
Classification
Codes
20
through
39
(
as
in
effect
on
July
1,
1985)
and
that
manufactured,
processed,
or
otherwise
used
a
toxic
chemical
listed
under
subsection
(
c)
of
this
section
in
excess
of
the
quantity
of
that
toxic
chemical
established
under
subsection
(
f)
of
this
section
during
the
calendar
year
for
which
a
release
form
is
required
under
this
section.
(
B)
The
Administrator
may
add
or
delete
Standard
Industrial
Classification
Codes
for
purposes
of
subparagraph
(
A),
but
only
to
the
extent
necessary
to
provide
that
each
Standard
Industrial
Code
to
which
this
section
applies
is
relevant
to
the
purposes
of
this
section.
(
C)
For
purposes
of
this
section
­
(
i)
The
term
"
manufacture"
means
to
produce,
prepare,
import,
or
compound
a
toxic
chemical.
(
ii)
The
term
"
process"
means
the
preparation
of
a
toxic
chemical,
after
its
manufacture,
for
distribution
in
commerce
­
(
I)
in
the
same
form
or
physical
state
as,
or
in
a
different
form
or
physical
state
from,
that
in
which
it
was
received
by
the
person
so
preparing
such
chemical,
or
(
II)
as
part
of
an
article
containing
the
toxic
chemical.
October,
2003
C­
2
(
2)
Discretionary
application
to
additional
facilities
The
Administrator,
on
his
own
motion
or
at
the
request
of
a
Governor
of
a
State
(
with
regard
to
facilities
located
in
that
State),
may
apply
the
requirements
of
this
section
to
the
owners
and
operators
of
any
particular
facility
that
manufactures,
processes,
or
otherwise
uses
a
toxic
chemical
listed
under
subsection
(
c)
of
this
section
if
the
Administrator
determines
that
such
action
is
warranted
on
the
basis
of
toxicity
of
the
toxic
chemical,
proximity
to
other
facilities
that
release
the
toxic
chemical
or
to
population
centers,
the
history
of
releases
of
such
chemical
at
such
facility,
or
such
other
factors
as
the
Administrator
deems
appropriate.

(
c)
Toxic
chemicals
covered
The
toxic
chemicals
subject
to
the
requirements
of
this
section
are
those
chemicals
on
the
list
in
Committee
Print
Number
99­
169
of
the
Senate
Committee
on
Environment
and
Public
Works,
titled
"
Toxic
Chemicals
Subject
to
Section
313
of
the
Emergency
Planning
and
Community
Right­
To­
Know
Act
of
1986"
(
42
U.
S.
C.
11023)
(
including
any
revised
version
of
the
list
as
may
be
made
pursuant
to
subsection
(
d)
or
(
e)
of
this
section).

(
d)
Revisions
by
Administrator
(
1)
In
general
The
Administrator
may
by
rule
add
or
delete
a
chemical
from
the
list
described
in
subsection
(
c)
of
this
section
at
any
time.

(
2)
Additions
A
chemical
may
be
added
if
the
Administrator
determines,
in
his
judgment,
that
there
is
sufficient
evidence
to
establish
any
one
of
the
following:
(
A)
The
chemical
is
known
to
cause
or
can
reasonably
be
anticipated
to
cause
significant
adverse
acute
human
health
effects
at
concentration
levels
that
are
reasonably
likely
to
exist
beyond
facility
site
boundaries
as
a
result
of
continuous,
or
frequently
recurring,
releases.
(
B)
The
chemical
is
known
to
cause
or
can
reasonably
be
anticipated
to
cause
in
humans
­
(
i)
cancer
or
teratogenic
effects,
or
(
ii)
serious
or
irreversible
­
(
I)
reproductive
dysfunctions,
(
II)
neurological
disorders,
(
III)
heritable
genetic
mutations,
or
(
IV)
other
chronic
health
effects.
(
C)
The
chemical
is
known
to
cause
or
can
reasonably
be
anticipated
to
cause,
because
of
­
(
i)
its
toxicity,
October,
2003
C­
3
(
ii)
its
toxicity
and
persistence
in
the
environment,
or
(
iii)
its
toxicity
and
tendency
to
bioaccumulate
in
the
environment,
a
significant
adverse
effect
on
the
environment
of
sufficient
seriousness,
in
the
judgment
of
the
Administrator,
to
warrant
reporting
under
this
section.
The
number
of
chemicals
included
on
the
list
described
in
subsection
C
of
this
section
on
the
basis
of
the
preceding
sentence
may
constitute
in
the
aggregate
no
more
than
25
percent
of
the
total
number
of
chemicals
on
the
list.
A
determination
under
this
paragraph
shall
be
based
on
generally
accepted
scientific
principles
or
laboratory
tests,
or
appropriately
designed
and
conducted
epidemiological
or
other
population
studies,
available
to
the
Administrator.

(
3)
Deletions
A
chemical
may
be
deleted
if
the
Administrator
determines
there
is
not
sufficient
evidence
to
establish
any
of
the
criteria
described
in
paragraph
(
2).

(
4)
Effective
date
Any
revision
made
on
or
after
January
1
and
before
December
1
of
any
calendar
year
shall
take
effect
beginning
with
the
next
calendar
year.
Any
revision
made
on
or
after
December
1
of
any
calendar
year
and
before
January
1
of
the
next
calender
year
shall
take
effect
beginning
with
the
calendar
year
following
such
next
calendar
year.

(
e)
Petitions
(
1)
In
general
Any
person
may
petition
the
Administrator
to
add
or
delete
a
chemical
from
the
list
described
in
subsection
(
c)
of
this
section
on
the
basis
of
the
criteria
in
subparagraph
(
A)
or
(
B)
of
subsection
(
d)(
2)
of
this
section.
Within
180
days
after
receipt
of
a
petition,
the
Administrator
shall
take
one
of
the
following
actions:
(
A)
Initiate
a
rulemaking
to
add
or
delete
the
chemical
to
the
list,
in
accordance
with
subsection
(
d)(
2)
or
(
d)(
3)
of
this
section.
(
B)
Publish
an
explanation
of
why
the
petition
is
denied.

(
2)
Governor
petitions
A
State
Governor
may
petition
the
Administrator
to
add
or
delete
a
chemical
from
the
list
described
in
subsection
(
c)
of
this
section
on
the
basis
of
the
criteria
in
subparagraph
(
A),
(
B),
or
(
c)
of
subsection
(
d)(
2)
of
this
section.
In
the
case
of
such
a
petition
from
a
State
Governor
to
delete
a
chemical,
the
petition
shall
be
treated
in
the
same
manner
as
a
petition
received
under
paragraph
(
1)
to
delete
a
chemical.
In
the
case
of
such
a
October,
2003
C­
4
petition
from
a
State
Governor
to
add
a
chemical,
the
chemical
will
be
added
to
the
list
within
180
days
after
receipt
of
the
petition,
unless
the
Administrator
­
(
A)
initiates
a
rulemaking
to
add
the
chemical
to
the
list,
in
accordance
with
subsection
(
d)(
2)
of
this
section,
or
(
B)
publishes
an
explanation
of
why
the
Administrator
believes
the
petition
does
not
meet
the
requirements
of
subsection
(
d)(
2)
of
this
section
for
adding
a
chemical
to
the
list.

(
f)
Threshold
for
reporting
(
1)
Toxic
chemical
threshold
amount
The
threshold
amounts
for
purposes
of
reporting
toxic
chemicals
under
this
section
are
as
follows:
(
A)
With
respect
to
a
toxic
chemical
used
at
a
facility,
10,000
pounds
of
the
toxic
chemical
per
year.
(
B)
With
respect
to
a
toxic
chemical
manufactured
or
processed
at
a
facility
­
(
i)
For
the
toxic
chemical
release
form
required
to
be
submitted
under
this
section
on
or
before
July
1,
1988,
75,000
pounds
of
the
toxic
chemical
per
year.
(
ii)
For
the
form
required
to
be
submitted
on
or
before
July
1,
1989,
50,000
pounds
of
the
toxic
chemical
per
year.
(
iii)
For
the
form
required
to
be
submitted
on
or
before
July
1,
1990,
and
for
each
form
thereafter,
25,000
pounds
of
the
toxic
chemical
per
year.

(
2)
Revisions
The
Administrator
may
establish
a
threshold
amount
for
a
toxic
chemical
different
from
the
amount
established
by
paragraph
(
1).
Such
revised
threshold
shall
obtain
reporting
on
a
substantial
majority
of
total
releases
of
the
chemical
at
all
facilities
subject
to
the
requirements
of
this
section.
The
amounts
established
under
this
paragraph
may,
at
the
Administrator's
discretion,
be
based
on
classes
of
chemicals
or
categories
of
facilities.

(
g)
Form
(
1)
Information
required
Not
later
than
June
1,
1987,
the
Administrator
shall
publish
a
uniform
toxic
chemical
release
form
for
facilities
covered
by
this
section.
If
the
Administrator
does
not
publish
such
a
form,
owners
and
operators
of
facilities
subject
to
the
requirements
of
this
section
shall
provide
the
information
required
under
this
subsection
by
letter
postmarked
on
or
before
the
date
on
which
the
form
is
due.
Such
form
shall
­
(
A)
provide
for
the
name
and
location
of,
and
principal
business
activities
at,
the
facility;
October,
2003
C­
5
(
B)
include
an
appropriate
certification,
signed
by
a
senior
official
with
management
responsibility
for
the
person
or
persons
completing
the
report,
regarding
the
accuracy
and
completeness
of
the
report;
and
(
C)
provide
for
submission
of
each
of
the
following
items
of
information
for
each
listed
toxic
chemical
known
to
be
present
at
the
facility:
(
i)
Whether
the
toxic
chemical
at
the
facility
is
manufactured,
processed,
or
otherwise
used,
and
the
general
category
or
categories
of
use
of
the
chemical.
(
ii)
An
estimate
of
the
maximum
amounts
(
in
ranges)
of
the
toxic
chemical
present
at
the
facility
at
any
time
during
the
preceding
calendar
year.
(
iii)
For
each
waste
stream,
the
waste
treatment
or
disposal
methods
employed,
and
an
estimate
of
the
treatment
efficiency
typically
achieved
by
such
methods
for
that
waste
stream.
(
iv)
The
annual
quantity
of
the
toxic
chemical
entering
each
environmental
medium.

(
2)
Use
of
available
data
In
order
to
provide
the
information
required
under
this
section,
the
owner
or
operator
of
a
facility
may
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.
Nothing
in
this
section
requires
the
monitoring
or
measurement
of
the
quantities,
concentration,
or
frequency
of
any
toxic
chemical
released
into
the
environment
beyond
that
monitoring
and
measurement
required
under
other
provisions
of
law
or
regulation.
In
order
to
assure
consistency,
the
Administrator
shall
require
that
data
be
expressed
in
common
units.

(
h)
Use
of
release
form
The
release
forms
required
under
this
section
are
intended
to
provide
information
to
the
Federal,
State,
and
local
governments
and
the
public,
including
citizens
of
communities
surrounding
covered
facilities.
The
release
form
shall
be
available,
consistent
with
section
11044(
a)
of
this
title,
to
inform
persons
about
releases
of
toxic
chemicals
to
the
environment;
to
assist
governmental
agencies,
researchers,
and
other
persons
in
the
conduct
of
research
and
data
gathering;
to
aid
in
the
development
of
appropriate
regulations,
guidelines,
and
standards;
and
for
other
similar
purposes.

(
i)
Modifications
in
reporting
frequency
(
1)
In
general
The
Administrator
may
modify
the
frequency
of
submitting
a
report
under
this
section,
but
the
Administrator
may
not
modify
the
frequency
to
be
any
October,
2003
C­
6
more
often
than
annually.
A
modification
may
apply,
either
nationally
or
in
a
specific
geographic
area,
to
the
following:
(
A)
All
toxic
chemical
release
forms
required
under
this
section.
(
B)
A
class
of
toxic
chemicals
or
a
category
of
facilities.
(
C)
A
specific
toxic
chemical.
(
D)
A
specific
facility.

(
2)
Requirements
A
modification
may
be
made
under
paragraph
(
1)
only
if
the
Administrator
­
(
A)
makes
a
finding
that
the
modification
is
consistent
with
the
provisions
of
subsection
(
h)
of
this
section,
based
on
­
(
i)
experience
from
previously
submitted
toxic
chemical
release
forms,
and
(
ii)
determinations
made
under
paragraph
(
3),
and
(
B)
the
finding
is
made
by
a
rulemaking
in
accordance
with
section
553
of
title
5.

(
3)
Determinations
The
Administrator
shall
make
the
following
determinations
with
respect
to
a
proposed
modification
before
making
a
modification
under
paragraph
(
1):

(
A)
The
extent
to
which
information
relating
to
the
proposed
modification
provided
on
the
toxic
chemical
release
forms
has
been
used
by
the
Administrator
or
other
agencies
of
the
Federal
Government,
States,
local
governments,
health
professionals,
and
the
public.
(
B)
The
extent
to
which
the
information
is
(
i)
readily
available
to
potential
users
from
other
sources,
such
as
State
reporting
programs,
and
(
ii)
provided
to
the
Administrator
under
another
Federal
law
or
through
a
State
program.
(
C)
The
extent
to
which
the
modification
would
impose
additional
and
unreasonable
burdens
on
facilities
subject
to
the
reporting
requirements
under
this
section.

(
4)
5­
year
review
Any
modification
made
under
this
subsection
shall
be
reviewed
at
least
once
every
5
years.
Such
review
shall
examine
the
modification
and
ensure
that
the
requirements
of
paragraphs
(
2)
and
(
3)
still
justify
continuation
of
the
modification.
Any
change
to
a
modification
reviewed
under
this
paragraph
shall
be
made
in
accordance
with
this
subsection.

(
5)
Notification
to
Congress
The
Administrator
shall
notify
Congress
of
an
intention
to
initiate
a
rulemaking
for
a
modification
under
this
subsection.
After
such
October,
2003
C­
7
notification,
the
Administrator
shall
delay
initiation
of
the
rulemaking
for
at
least
12
months,
but
no
more
than
24
months,
after
the
date
of
such
notification.

(
6)
Judicial
review
In
any
judicial
review
of
a
rulemaking
which
establishes
a
modification
under
this
subsection,
a
court
may
hold
unlawful
and
set
aside
agency
action,
findings,
and
conclusions
found
to
be
unsupported
by
substantial
evidence.

(
7)
Applicability
A
modification
under
this
subsection
may
apply
to
a
calendar
year
or
other
reporting
period
beginning
no
earlier
than
January
1,
1993.

(
8)
Effective
date
Any
modification
made
on
or
after
January
1
and
before
December
1
of
any
calendar
year
shall
take
effect
beginning
with
the
next
calendar
year.
Any
modification
made
on
or
after
December
1
of
any
calendar
year
and
before
January
1
of
the
next
calendar
year
shall
take
effect
beginning
with
the
calendar
year
following
such
next
calendar
year.

(
j)
EPA
management
of
data
The
Administrator
shall
establish
and
maintain
in
a
computer
data
base
a
national
toxic
chemical
inventory
based
on
data
submitted
to
the
Administrator
under
this
section.
The
Administrator
shall
make
these
data
accessible
by
computer
telecommunication
and
other
means
to
any
person
on
a
cost
reimbursable
basis.

(
k)
Report
Not
later
than
June
30,
1991,
the
Comptroller
General,
in
consultation
with
the
Administrator
and
appropriate
officials
in
the
States,
shall
submit
to
the
Congress
a
report
including
each
of
the
following:
(
1)
A
description
of
the
steps
taken
by
the
Administrator
and
the
States
to
implement
the
requirements
of
this
section,
including
steps
taken
to
make
information
collected
under
this
section
available
to
and
accessible
by
the
public.
(
2)
A
description
of
the
extent
to
which
the
information
collected
under
this
section
has
been
used
by
the
Environmental
Protection
Agency,
other
Federal
agencies,
the
States,
and
the
public,
and
the
purposes
for
which
the
information
has
been
used.
(
3)
An
identification
and
evaluation
of
options
for
modifications
to
the
requirements
of
this
section
for
the
purpose
of
making
information
collected
under
this
section
more
useful.
October,
2003
C­
8
(
l)
Mass
balance
study
(
1)
In
general
The
Administrator
shall
arrange
for
a
mass
balance
study
to
be
carried
out
by
the
National
Academy
of
Sciences
using
mass
balance
information
collected
by
the
Administrator
under
paragraph
(
3).
The
Administrator
shall
submit
to
Congress
a
report
on
such
study
no
later
than
5
years
after
October
17,
1986.

(
2)
Purposes
The
purposes
of
the
study
are
as
follows:
(
A)
To
assess
the
value
of
mass
balance
analysis
in
determining
the
accuracy
of
information
on
toxic
chemical
releases.
(
B)
To
assess
the
value
of
obtaining
mass
balance
information,
or
portions
thereof,
to
determine
the
waste
reduction
efficiency
of
different
facilities,
or
categories
of
facilities,
including
the
effectiveness
of
toxic
chemical
regulations
promulgated
under
laws
other
than
this
chapter.
(
C)
To
assess
the
utility
of
such
information
for
evaluating
toxic
chemical
management
practices
at
facilities,
or
categories
of
facilities,
covered
by
this
section.
(
D)
To
determine
the
implications
of
mass
balance
information
collection
on
a
national
scale
similar
to
the
mass
balance
information
collection
carried
out
by
the
Administrator
under
paragraph
(
3),
including
implications
of
the
use
of
such
collection
as
part
of
a
national
annual
quantity
toxic
chemical
release
program.

(
3)
Information
collection
(
A)
The
Administrator
shall
acquire
available
mass
balance
information
from
States
which
currently
conduct
(
or
during
the
5
years
after
October
17,
1986
initiate)
a
mass
balance­
oriented
annual
quantity
toxic
chemical
release
program.
If
information
from
such
States
provides
an
inadequate
representation
of
industry
classes
and
categories
to
carry
out
the
purposes
of
the
study,
the
Administrator
also
may
acquire
mass
balance
information
necessary
for
the
study
from
a
representative
number
of
facilities
in
other
States.
(
B)
Any
information
acquired
under
this
section
shall
be
available
to
the
public,
except
that
upon
a
showing
satisfactory
to
the
Administrator
by
any
person
that
the
information
(
or
a
particular
part
thereof)
to
which
the
Administrator
or
any
officer,
employee,
or
representative
has
access
under
this
section
if
made
public
would
divulge
information
entitled
to
protection
under
section
1905
of
title
18,
such
information
or
part
shall
be
considered
confidential
in
accordance
with
the
purposes
of
that
section,
except
that
such
information
or
part
may
be
disclosed
to
other
officers,
employees,
or
authorized
representatives
of
the
United
States
concerned
with
carrying
out
this
section.
October,
2003
C­
9
(
C)
The
Administrator
may
promulgate
regulations
prescribing
procedures
for
collecting
mass
balance
information
under
this
paragraph.
(
D)
For
purposes
of
collecting
mass
balance
information
under
subparagraph
(
A),
the
Administrator
may
require
the
submission
of
information
by
a
State
or
facility.

(
4)
Mass
balance
definition
For
purposes
of
this
subsection,
the
term
"
mass
balance"
means
an
accumulation
of
the
annual
quantities
of
chemicals
transported
to
a
facility,
produced
at
a
facility,
consumed
at
a
facility,
used
at
a
facility,
accumulated
at
a
facility,
released
from
a
facility,
and
transported
from
a
facility
as
a
waste
or
as
a
commercial
product
or
byproduct
or
component
of
a
commercial
product
or
byproduct.
October,
2003
ATTACHMENT
D
Pollution
Prevention
Act
(
42
U.
S.
C.
A.
Sections
13101­
13109)
October,
2003
D­
2
POLLUTION
PREVENTION
ACT
SECTION
6607
UNITED
STATES
CODE
TITLE
42
­
THE
PUBLIC
HEALTH
AND
WELFARE
CHAPTER
133
­
POLLUTION
PREVENTION
§
13106.
Source
reduction
and
recycling
data
collection
(
a)
Reporting
requirements
Each
owner
or
operator
of
a
facility
required
to
file
an
annual
toxic
chemical
release
form
under
section
11023
of
this
title
for
any
toxic
chemical
shall
include
with
each
such
annual
filing
a
toxic
chemical
source
reduction
and
recycling
report
for
the
preceding
calendar
year.
The
toxic
chemical
source
reduction
and
recycling
report
shall
cover
each
toxic
chemical
required
to
be
reported
in
the
annual
toxic
chemical
release
form
filed
by
the
owner
or
operator
under
section
11023(
c)
of
this
title.
This
section
shall
take
effect
with
the
annual
report
filed
under
section
11023
of
this
title
for
the
first
full
calendar
year
beginning
after
November
5,
1990.

(
b)
Items
included
in
report
The
toxic
chemical
source
reduction
and
recycling
report
required
under
subsection
(
a)
of
this
section
shall
set
forth
each
of
the
following
on
a
facility­
by­
facility
basis
for
each
toxic
chemical:

.
(
1)
The
quantity
of
the
chemical
entering
any
waste
stream
(
or
otherwise
released
into
the
environment)
prior
to
recycling,
treatment,
or
disposal
during
the
calendar
year
for
which
the
report
is
filed
and
the
percentage
change
from
the
previous
year.
The
quantity
reported
shall
not
include
any
amount
reported
under
paragraph
(
7).
When
actual
measurements
of
the
quantity
of
a
toxic
chemical
entering
the
waste
streams
are
not
readily
available,
reasonable
estimates
should
be
made
based
on
best
engineering
judgment
(
2)
The
amount
of
the
chemical
from
the
facility
which
is
recycled
(
at
the
facility
or
elsewhere)
during
such
calendar
year,
the
percentage
change
from
the
previous
year,
and
the
process
of
recycling
used.
(
3)
The
source
reduction
practices
used
with
respect
to
that
chemical
during
such
year
at
the
facility.
Such
practices
shall
be
reported
in
accordance
with
the
following
categories
unless
the
Administrator
finds
other
categories
to
be
more
appropriate.
(
A)
Equipment,
technology,
process,
or
procedure
modifications.
(
B)
Reformulation
or
redesign
of
products.
(
C)
Substitution
of
raw
materials.
(
D)
Improvement
in
management,
training,
inventory
control,
materials
handling,
or
other
general
operational
phases
of
industrial
facilities.
(
4)
The
amount
expected
to
be
reported
under
paragraph
(
1)
and
(
2)
for
the
two
calendar
years
immediately
following
the
calendar
year
for
which
the
report
is
filed.
October,
2003
D­
3
Such
amount
shall
be
expressed
as
a
percentage
change
from
the
amount
reported
in
paragraphs
(
1)
and
(
2).
(
5)
A
ratio
of
production
in
the
reporting
year
to
production
in
the
previous
year.
The
ratio
should
be
calculated
to
most
closely
reflect
all
activities
involving
the
toxic
chemical.
In
specific
industrial
classifications
subject
to
this
section,
where
a
feedstock
or
some
variable
other
than
production
is
the
primary
influence
on
waste
characteristics
or
volumes,
the
report
may
provide
an
index
based
on
that
primary
variable
for
each
toxic
chemical.
The
Administrator
is
encouraged
to
develop
production
indexes
to
accommodate
individual
industries
for
use
on
a
voluntary
basis.
(
6)
The
techniques
which
were
used
to
identify
source
reduction
opportunities.
Techniques
listed
should
include,
but
are
not
limited
to,
employee
recommendations,
external
and
internal
audits,
participative
team
management,
and
material
balance
audits.
Each
type
of
source
reduction
listed
under
paragraph
(
3)
should
be
associated
with
the
techniques
or
multiples
of
techniques
used
to
identify
the
source
reduction
technique.
(
7)
The
amount
of
any
toxic
chemical
released
into
the
environment
which
resulted
from
a
catastrophic
event,
remedial
action,
or
other
one­
time
event,
and
is
not
associated
with
production
processes
during
the
reporting
year.
(
8)
The
amount
of
the
chemical
from
the
facility
which
is
treated
(
at
the
facility
or
elsewhere)
during
such
calendar
year
and
the
percentage
change
from
the
previous
year.
For
the
first
year
of
reporting
under
this
subsection,
comparison
with
the
previous
year
is
required
only
to
the
extent
such
information
is
available.

(
c)
SARA
provisions
The
provisions
of
sections
11042,
11045(
c),
and
11046
of
this
title
shall
apply
to
the
reporting
requirements
of
this
section
in
the
same
manner
as
to
the
reports
required
under
section
11023
of
this
title.
The
Administrator
may
modify
the
form
required
for
purposes
of
reporting
information
under
section
11023
of
this
title
to
the
extent
he
deems
necessary
to
include
the
additional
information
required
under
this
section.

(
d)
Additional
optional
information
Any
person
filing
a
report
under
this
section
for
any
year
may
include
with
the
report
additional
information
regarding
source
reduction,
recycling,
and
other
pollution
control
techniques
in
earlier
years.

(
e)
Availability
of
data
Subject
to
section
11042
of
this
title,
the
Administrator
shall
make
data
collected
under
this
section
publicly
available
in
the
same
manner
as
the
data
collected
under
section
11023
of
this
title.
October,
2003
ATTACHMENT
E
40
CFR
Part
372
Toxic
Chemical
Release
Reporting:
Community
Right­
to­
Know
October,
2003
E­
1
TITLE
40­­
PROTECTION
OF
ENVIRONMENT
CHAPTER
I­­
ENVIRONMENTAL
PROTECTION
AGENCY
PART
372­­
TOXIC
CHEMICAL
RELEASE
REPORTING:
COMMUNITY
RIGHT­
TO­
KNOW
Subpart
A­­
General
Provisions
Sec.
372.10
Recordkeeping.

(
d)
Each
owner
or
operator
who
determines
that
the
owner
operator
may
apply
the
alternate
threshold
as
specified
under
Sec.
372.27(
a)
must
retain
the
following
records
for
a
period
of
3
years
from
the
date
of
the
submission
of
the
certification
statement
as
required
under
Sec.
372.27(
b):
(
1)
A
copy
of
each
certification
statement
submitted
by
the
person
under
Sec.
372.27(
b).
(
2)
All
supporting
materials
and
documentation
used
by
the
person
to
make
the
compliance
determination
that
the
facility
or
establishment
is
eligible
to
apply
the
alternate
threshold
as
specified
in
Sec.
372.27.
(
3)
Documentation
supporting
the
certification
statement
submitted
under
Sec.
372.27(
b)
including:
(
i)
Data
supporting
the
determination
of
whether
the
alternate
threshold
specified
under
Sec.
372.27(
a)
applies
for
each
toxic
chemical.
(
ii)
Documentation
supporting
the
calculation
of
annual
reportable
amount,
as
defined
in
Sec.
372.27(
a),
for
each
toxic
chemical,
including
documentation
supporting
the
calculations
and
the
calculations
of
each
data
element
combined
for
the
annual
reportable
amount.
(
iii)
Receipts
or
manifests
associated
with
the
transfer
of
each
chemical
in
waste
to
off­
site
locations.
October,
2003
E­
1
Subpart
B­­
Reporting
Requirements
Sec.
372.27
Alternate
threshold
and
certification.

(
a)
With
respect
to
the
manufacture,
process,
or
otherwise
use
of
a
toxic
chemical,
the
owner
or
operator
of
a
facility
may
apply
an
alternate
threshold
of
1
million
pounds
per
year
to
that
chemical
if
the
owner
or
operator
calculates
that
the
facility
would
have
an
annual
reportable
amount
of
that
toxic
chemical
not
exceeding
500
pounds
for
the
combined
total
quantities
released
at
the
facility,
disposed
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
recycle
operations,
combusted
for
the
purpose
of
energy
recovery
at
the
facility,
and
amounts
transferred
from
the
facility
to
off­
site
locations
for
the
purpose
of
recycle,
energy
recovery,
treatment,
and/
or
disposal.
These
volumes
correspond
to
the
sum
of
amounts
reportable
for
data
elements
on
EPA
Form
R
(
EPA
Form
9350­
1;
Rev.
12/
4/
93)
as
Part
II
column
B
or
sections
8.1
(
quantity
released),
8.2
(
quantity
used
for
energy
recovery
on­
site),
8.3
(
quantity
used
for
energy
recovery
off­
site),
8.4
(
quantity
recycled
on­
site),
8.5
(
quantity
recycled
off­
site),
8.6
(
quantity
treated
on­
site),
and
8.7
(
quantity
treated
off­
site).

(
b)
If
an
owner
or
operator
of
a
facility
determines
that
the
owner
or
operator
may
apply
the
alternate
reporting
threshold
specified
in
paragraph
(
a)
of
this
section
for
a
specific
toxic
chemical,
the
owner
or
operator
is
not
required
to
submit
a
report
for
that
chemical
under
Sec.
372.30,
but
must
submit
a
certification
statement
that
contains
the
information
required
in
Sec.
372.95.
The
owner
or
operator
of
the
facility
must
also
keep
records
as
specified
in
Sec.
372.10(
d).

(
c)
Threshold
determination
provisions
of
Sec.
372.25
and
exemptions
pertaining
to
threshold
determinations
in
Sec.
372.38
are
applicable
to
the
determination
of
whether
the
alternate
threshold
has
been
met.

(
d)
Each
certification
statement
under
this
section
for
activities
involving
a
toxic
chemical
that
occurred
during
a
calendar
year
at
a
facility
must
be
submitted
to
EPA
and
to
the
State
in
which
the
facility
is
located
on
or
before
July
1
of
the
next
year.
October,
2003
E­
1
Subpart
E­­
Forms
and
Instructions
Sec.
372.95
Alternate
threshold
certification
and
instructions.

(
a)
Availability
of
the
alternate
threshold
certification
statement
and
instructions.
Availability
of
the
alternate
threshold
certification
statement
and
instructions
is
the
same
as
provided
in
Sec.
372.85(
a)
for
availability
of
the
reporting
form
and
instructions.

(
b)
Alternate
threshold
certification
statement
elements.
The
following
information
must
be
reported
on
an
alternate
threshold
certification
statement
pursuant
to
Sec.
372.27(
b):
(
1)
Reporting
year.
(
2)
An
indication
of
whether
the
chemical
identified
is
being
claimed
as
trade
secret.
(
3)
Chemical
name
and
CAS
number
(
if
applicable)
of
the
chemical,
or
the
category
name.
(
4)
Signature
of
a
senior
management
official
certifying
the
following:
pursuant
to
40
CFR
372.27,
  
I
hereby
certify
that
to
the
best
of
my
knowledge
and
belief
for
the
toxic
chemical
listed
in
this
statement,
the
annual
reportable
amount,
as
defined
in
40
CFR
372.27(
a),
did
not
exceed
500
pounds
for
this
reporting
year
and
that
the
chemical
was
manufactured,
or
processed,
or
otherwise
used
in
an
amount
not
exceeding
1
million
pounds
during
this
reporting
year.''
(
5)
Date
signed.
(
6)
Facility
name
and
address.
(
7)
Mailing
address
of
the
facility
if
different
than
paragraph
(
b)(
6)
of
this
section.
(
8)
Toxic
chemical
release
inventory
facility
identification
number
if
known.
(
9)
Name
and
telephone
number
of
a
technical
contact.
(
10)
The
four­
digit
SIC
codes
for
the
facility
or
establishments
in
the
facility.
(
11)
Latitude
and
longitude
coordinates
for
the
facility.
(
12)
Dun
and
Bradstreet
Number
of
the
facility.
(
13)
EPA
Identification
Number(
s)
(
RCRA)
I.
D.
Number(
s)
of
the
facility.
(
14)
Facility
NPDES
Permit
Number(
s).
(
15)
Underground
Injection
Well
Code
(
UIC)
I.
D.
Number(
s)
of
the
facility.
(
16)
Name
of
the
facility's
parent
company.
(
17)
Parent
company's
Dun
and
Bradstreet
Number.
October,
2003
F­
1
ATTACHMENT
F
Toxic
Chemical
Release
Inventory
Reporting
Forms
and
Instructions
Revised
2001
Version
(
EPA
260­
B­
02­
001)

(
Note:
This
document
is
available
only
electronically
on
the
TRI
website
at
http://
www.
epa.
gov/
tri/
report/
index.
htm#
updates,
)
October,
2003
G­
1
ATTACHMENT
G
Proposed
Form
R
(
OMB
2070­
0093)
