TOXIC
CHEMICAL
RELEASE
INVENTORY
TOXIC
CHEMICAL
RELEASE
REPORTING
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
OMB
CONTROL
NO.
2070­
0093
EPA
ICR
#
1363.14
October,
2005
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION...................................................
2
1(
a)
Title
of
the
Information
Collection.................................................................................................
2
1(
b)
Short
Characterization......................................................................................................................
2
2
NEED
FOR
AND
USE
OF
THE
COLLECTION.............................................................................
5
2(
a)
Need/
Authority
for
the
Collection..................................................................................................
5
2(
b)
Use/
Users
of
the
Data
........................................................................................................................
6
3
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED.........................................
29
3(
a)
Respondents/
SIC
Codes
.................................................................................................................
29
4
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT...................................................
30
4(
a)
Agency
Activities
.............................................................................................................................
30
4(
b)
Collection
Methodology
and
Management.................................................................................
34
4(
c)
Small
Entity
Flexibility....................................................................................................................
34
4(
d)
Collection
Schedule.........................................................................................................................
35
5
NONDUPLICATION,
CONSULTATIONS,
OTHER
COLLECTION
CRITERIA...............
35
5(
a)
Nonduplication...................................................................................................................................
35
5(
b)
Consultations
....................................................................................................................................
66
5(
c)
Effects
of
Less
Frequent
Collection
.............................................................................................
70
5(
d)
General
Guidelines...........................................................................................................................
70
5(
e)
Confidentiality
and
Sensitive
Questions........................................................................................
71
6
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
....................................
71
6(
a)
Estimating
Respondent
Burden
......................................................................................................
71
6(
b)
Estimating
Respondent
Costs
..........................................................................................................
78
6(
c)
Estimating
Agency
Burden
and
Cost..............................................................................................
81
6(
d)
Bottom
Line
Burden
Hours
and
Costs...........................................................................................
82
6(
e)
Reasons
for
Change
in
Burden.........................................................................................................
86
6(
f)
Burden
Statement................................................................................................................................
88
October,
2005
2
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.:
1363.14
OMB
Control
No.:

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
Resources
Conservation
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
0093.
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
certain
conditions
are
met,
and
submit
the
Form
A
Certification
Statement
instead
of
the
Form
R.
October,
2005
4
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
October
31,
2003
with
an
expiration
date
of
January
31,
2006.
October,
2005
5
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.

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
October,
2005
6
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
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.
October,
2005
7
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
(
RSEI)
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.

OPPT
uses
TRI
data
to
track
environmental
progress
towards
annual
performance
goals
as
part
of
GPRA.
Specifically,
OPPT
is
using
RSEI
data
to
set
risk­
based
and
pollution
prevention
performance
goals.
For
example,
for
FY05,
OPPT
set
a
goal
of
12%
reduction
from
2001
in
the
production­
adjusted
risk­
based
score
of
releases
and
transfers
of
toxic
chemicals.
Pollution
prevention
goals
were
also
determined
based
on
TRI
releases;
for
example,
one
goal
for
FY04
was
a
32%
reduction
in
TRI
reported
releases
at
Federal
Facilities.

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,
October,
2005
8
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.

OAR's
National
Emission
Inventory
(
NEI)
database
contains
information
about
sources
that
emit
criteria
air
pollutants
and
their
precursors,
and
hazardous
air
pollutants.
Several
sources,
including
TRI,
are
used
to
compile
information
on
annual
air
pollutant
emissions
from
point,
nonpoint,
and
mobile
sources.
Data
from
the
NEI
are
used
for
air
dispersion
modeling,
regional
strategy
development,
regulation
setting,
air
toxics
risk
assessment,
and
tracking
trends
in
emissions
over
time.
More
information
about
the
NEI
database
and
its
sources
can
be
found
on
EPA's
AirData
web
site,
at
http://
www.
epa.
gov/
air/
data/
neidb.
html.

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.
The
Office
of
Regulatory
Enforcement
(
ORE)
within
OECA
has
also
used
TRI
data
in
their
National
Enforcement
Screening
Strategy.
Various
data
were
incorporated
including
measures
for
risk
associated
with
TRI
releases.
This
strategy
screened
for
large
companies
with
compliance
issues
with
a
presence
across
EPA
Regions
that
could
potentially
be
targeted
for
enforcement.

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.
October,
2005
9
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
in
conjunction
with
company
tracking
systems.

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
over
a
dozen
separate
databases,
including
the
Toxic
Release
Inventory
System
(
TRIS).
In
the
near
future,
RSEI
will
also
be
included
in
IDEA
to
provide
metrics
for
risk
and
hazard
associated
with
TRI
data.
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.
OECA
provides
web
access
to
databases
in
IDEA
through
their
Online
Tracking
Information
System
(
OTIS).
OTIS
is
open
to
a
host
of
federal
and
state
users
who
can
use
the
data
for
targeting,
cross­
media
comparisons,
and
tracking
enforcement
targets.
Users
include
state
environmental
agencies,
state
attorney
general
offices,
other
state
agencies,
local
governments,
and
Federal
government
departments
and
agencies
(
including
the
military).

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.
A
recent
OECA
initiative,
conducted
in
conjunction
with
the
Regions,
used
TRI
data
to
target
facilities
that
submitted
late
reports
to
TRI
for
enforcement.

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).
Many
of
the
30
priority
chemicals
OSWER
has
identified
as
a
focus
for
its
waste
minimization
efforts
are
reported
to
TRI.
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.

OSWER
also
uses
TRI
data
to
target
facilities
for
recruitment
to
voluntary
waste
minimization
programs.
Facilities
are
selected
from
TRI
by
Region
based
on
their
releases
of
priority
chemicals.
Each
Region
then
determines
particular
facilities
that
may
be
candidates
for
waste
reduction
opportunities
or
for
participation
in
the
National
Partnership
for
Environmental
October,
2005
10
Priorities
(
NPEP),
a
voluntary
program
managed
under
OSWER.
There
are
about
40
participating
facilities
that
make
commitments
to
reduce
wastes
and
releases
of
their
hazardous
chemicals.

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.
TRI
data
are
also
used
in
OSWER's
RCRA
annual
reports.
They
incorporate
TRI
data
on
releases
and
the
nature
and
scope
of
recycling,
for
example,
of
metal
recycling
or
solvent
recycling.

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
prevention
planning.
In
conducting
facility
inspections,
TRI
data
are
used
to
provide
a
multimedia
look
at
what
chemicals
are
being
released.
Inspectors
use
this
information
to
look
for
discrepancies.

Similar
to
other
offices,
OSWER
uses
TRI
data
to
track
progress
being
made
toward
EPA
goals
under
GPRA
to
reduce
the
quantity
of
priority
chemicals
contained
in
regulated
hazardous
wastes.
Specifically,
TRI
data
are
used
in
an
annual
Trends
Report
that
discusses
the
progress
being
made
toward
meeting
two
GPRA
goals:
1)
a
2008
GPRA
goal
to
reduce
priority
chemicals
in
regulated
hazardous
wastes
by
10
percent,
using
a
2001
baseline,
and
2)
a
2005
GPRA
goal
to
reduce
priority
chemicals
in
hazardous
waste
by
50
percent,
using
a
1991
baseline.
The
Trends
Report
shows
trends
concerning
the
generation
and
management
of
the
priority
chemicals
by
National,
EPA
Region,
State,
and
industry
sector
levels.
For
example,
TRI
data
indicated
that
facilities
generating
a
priority
chemical
in
both
1991
and
2001,
achieved
a
53%
reduction
in
the
amount
of
priority
chemicals
they
generated
as
RCRA
hazardous
waste
between
these
years,
surpassing
the
GPRA
goal
of
50%
reduction.
TRI
data
show
a
declining
trend
overall
in
the
quantity
of
the
priority
chemicals,
although
there
have
been
some
increases
year
to
year.
The
most
recent
version
of
the
Trends
Report,
for
1991
to
2001,
can
be
seen
at:
www.
epa.
gov/
epaoswer/
hazwaste/
minimize/
trends.
htm
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.
October,
2005
11
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.

TRI
data
serves
as
an
input
to
watershed
analysis
software
maintained
by
OW.
BASINS
(
Better
Assessment
Science
Integrating
point
and
Nonpoint
Sources)
is
a
multipurpose
environmental
analysis
system
designed
for
use
by
regional,
state,
and
local
agencies
in
performing
watershed
and
water
quality­
based
studies.
The
software
allows
a
user
to
analyze
water
quality
for
a
selected
stream
site
or
throughout
an
entire
watershed.
Different
point
and
nonpoint
source
data
are
modeled,
including
the
locations
of
TRI
facilities.
The
BASINS
software
system
includes
map
layers
showing
the
locations
and
toxic
releases
of
TRI
reporting
facilities
throughout
the
U.
S.

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
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
October,
2005
12
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.

OW
is
charged
with
reviewing
and
revising
the
effluent
limitations
guidelines
established
under
the
CWA.
Guidelines
have
been
established
for
55
major
industrial
categories.
OW
identifies
changes
to
guidelines
for
existing
industrial
categories,
plus
new
industrial
categories,
if
they
pose
a
large
risk
from
toxic
discharges.
As
part
of
the
review
process
in
2003
and
2004,
OW
looked
at
water
releases
reported
in
TRI
to
help
them
identify
industries
with
greater
risk
for
potential
revision
or
implementation
of
effluent
limitations.
Some
industries
initially
identified
include
organic
and
inorganic
chemicals;
nonferrous
metals
manufacturing;
petroleum
refining;
petroleum
storage;
and
timber
and
pulp
processing.
TRI
data
were
then
also
used
to
determine
which
industries
could
achieve
effluent
reductions
through
a
voluntary
program
rather
than
new
regulation.
Use
of
TRI
data
was
helpful
in
identifying
which
industrial
sectors'
releases
were
mostly
attributed
to
a
small
percentage
of
facilities
as
the
releases
for
the
sector
could
potentially
be
reduced
if
the
largest
releasers
participated
in
voluntary
pollutant
reduction
programs.

Use
of
the
Data
by
the
Office
of
Policy,
Economics,
and
Innovation
The
Office
of
Policy,
Economics,
and
Innovation
(
OPEI)
launched
the
Sector
Strategies
program
in
2003
as
an
industry­
EPA
partnership
to
promote
improved
environmental
performance.
TRI
data
were
used
to
measure
environmental
performance
trends
for
participating
industry
sectors,
for
the
first
annual
report
released
in
2004.
TRI
data
will
continue
to
be
used
to
measure
environmental
trends
in
subsequent
annual
reports.
In
future
years
the
program
may
also
include
RSEI
data
for
each
industry
sector
to
incorporate
measures
of
exposure
and
risk
or
specific
groups
of
chemicals
released/
managed
may
be
used
to
measure
environmental
performance
trends.

OPEI's
Performance
Track
program
rewards
facilities
that
go
beyond
environmental
compliance
and
make
voluntary
commitments
to
improve
performance.
Rewards
include
reduced
regulatory
burden.
The
program
used
an
analysis
of
TRI
data
conducted
by
the
Office
of
Water
in
developing
water­
related
regulatory
incentives
for
its
members.
In
the
process
of
developing
new
effluent
guidelines
for
selected
industrial
sectors,
OW
evaluated
industrial
sectors'
TRI
data
to
determine
sectors
where
a
small
percentage
of
facilities
were
responsible
for
the
majority
of
risk
related
to
water
discharges.
If
these
facilities
could
participate
in
a
voluntary
environmental
program,
the
sector
as
a
whole
may
not
require
new
effluent
guidelines.
For
sectors
identified
by
OW,
Performance
Track
determined
the
top
releasers
and
evaluated
if
they
would
be
eligible
for
this
voluntary
program.
If
deemed
eligible,
current
Performance
Track
facilities
in
these
sectors
would
also
benefit
because
they
would
not
be
subject
to
increased
regulation.
However,
the
analysis
indicated
that
many
of
the
top
releasers
in
those
sectors
would
probably
not
be
eligible
due
to
their
level
of
compliance
with
environmental
requirements.

Use
of
the
Data
by
the
National
Center
for
Environmental
Economics
October,
2005
13
The
National
Center
for
Environmental
Economics
(
NCEE)
assists
EPA
Program
Offices,
Agency
economists,
and
regulatory
policy
makers
with
economic
analyses.
NCEE
also
conducts
research
projects
analyzing
the
relationship
between
economic
factors,
environmental
health,
and
pollution
control.
Some
examples
of
their
research
work
that
have
used
TRI
data
include:

The
Trade
Environmental
Assessment
Model
(
TEAM),
created
by
NCEE,
is
a
multimedia
model
that
allows
a
user
to
simulate
changes
in
environmental
emissions
resulting
from
changes
in
industrial
activity.
The
model
incorporates
economic
data
in
addition
to
multi­
media
pollutant
release
data.
TRI
data
on
indirect
dischargers
are
used
as
one
component
of
modeling
releases
to
water.
The
model's
output
measures
the
change
in
chemical
emissions,
by
industry
category,
county,
or
chemical.

TRI
data
were
utilized
in
a
project
examining
compliance
with
air
pollution
regulations
at
U.
S.
pulp
and
paper
mills.
Several
plant­
level
characteristics
were
tested
for
their
relationship
to
air
regulation
compliance,
including
emissions
to
other
media,
which
was
measured
in
part
with
TRI
data.
The
study
hypothesized
that
higher
emissions
to
various
media
may
be
one
factor
related
to
lower
compliance
with
air
pollution
regulations.
Results
indicated
that
TRI
air
and
water
discharges
(
relative
to
a
facility's
shipments)
tended
not
to
be
correlated
with
air
regulation
compliance.
Although
low
correlation
was
found
with
environmental
emissions,
other
plant
and
firm
level
characteristics
are
being
evaluated,
such
as
facility
shipments,
age,
profitability,
and
compliance
with
other
regulations.

Economists
at
NCEE
have
used
TRI
data
in
ongoing
environmental
justice
analyses.
In
a
study
of
communities
in
Texas,
TRI
locational
data
were
used
to
examine
relationships
between
various
socioeconomic
factors
and
siting
of
facilities.
A
related
study
used
TRI
emissions
information
to
determine
if
there
is
a
disproportionate
burden
of
risk
in
different
communities.
The
project
incorporates
data
on
pounds
released
in
addition
to
toxicity
weights
for
the
chemicals
released
to
look
at
the
risk
factor.

Program
evaluation
is
another
topic
where
NCEE
has
used
TRI
data.
To
assess
the
effectiveness
of
voluntary
programs,
NCEE
is
evaluating
the
effect
of
one
such
program,
the
National
Metal
Finishing
Strategic
Goals
Program.
The
program
set
emissions
reductions
goals
to
be
met
by
2001,
near
the
programs'
end.
Some
of
these
goals
can
be
measured
using
TRI,
for
example,
one
goal
of
the
program
was
to
reduce
metals
air
emissions
from
a
1992
baseline.
TRI
data
will
be
used
to
assess
the
amount
of
reduction
achieved
by
participating
facilities
and
to
determine
what
role
the
voluntary
program
played
in
the
reduction
in
comparison
to
other
factors,
by
looking
at
reductions
in
similar
non­
participating
facilities.
October,
2005
14
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/).
In
addition,
the
Indiana
Department
of
Environmental
Management
frequently
uses
TRI
data
to
work
with
industries
and
suggest
ways
to
reduce
waste
at
the
source,
use
less
toxic
alternatives,
and
identify
opportunities
to
recycle
and
reuse
materials.

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
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.
October,
2005
15
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
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
a
public
access
site
for
enforcement
and
compliance
data.

OTIS
is
currently
restricted
to
registered
users
from
governmental
organizations.
In
2004,
about
340
local,
state,
and
federal
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
Act
­­
Permit
Compliance
System),
RCRAInfo
(
Resource
Conservation
and
Recovery
Act
Information
System),
ICIS
(
Integrated
Compliance
Information
System),
National
Compliance
Database
(
NCDB),
and
the
2000
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
October,
2005
16
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
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
(
RSEI)
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
October,
2005
17
targeting
and
prioritization
of
chemicals,
industries
and
geographic
areas.
Facility
scores
can
also
be
tracked
from
year
to
year
to
analyze
trends.

TRI
is
offered
as
1
of
9
toxicology
and
hazardous
chemical­
related
databases
accessible
through
the
National
Library
of
Medicine's
TOXNET
Web
site.
TRI
data
can
be
searched
by
chemical,
year,
facility
name,
geographic
location,
type
and
amount
of
releases.
Results
display
facilityspecific
information,
including
facility
releases
and
management.
Other
databases
offered
include:
Hazardous
Substances
Data
Bank
(
HSDB),
Integrated
Risk
Information
System
(
IRIS),
International
Toxicity
Estimates
for
Risk
(
ITER),
Chemical
Carcinogenesis
Research
Information
(
CCRIS),
and
Genetic
Toxicology
(
GENE­
TOX),
as
well
as
literature
databases
for
toxicityrelated
research
articles.
TOXNET
users
cited
preparation
of
risk
assessment,
improved
understanding
of
environmental/
occupational
health
concerns,
and
use
in
regulatory
activities
as
some
of
the
top
uses
of
their
searches.
The
TRI
TOXNET
search
web
site
is
available
at:
http://
toxnet.
nlm.
nih.
gov/
cgi­
bin/
sis/
htmlgen?
TRI.

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.
October,
2005
18
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
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.

Citizens'
Environmental
Coalition
(
CEC)
(
http://
cectoxic.
home.
igc.
org/)
is
a
statewide
grassroots
organization
of
110
groups
and
14,000
individual
members
working
to
eliminate
pollution
in
New
York
State.
They
also
seek
to
empower
and
educate
the
public
about
environmental
problems,
and
promote
corporate
accountability.
CEC
uses
TRI
as
a
means
to
"
empower,
educate
and
assist
people
concerned
about
environmental
problems."
They
maintain
a
sister
web
site
(
http://
www.
ecothreatny.
org/)
with
an
interactive
mapping
tool
for
New
York
that
allows
for
selection
of
different
environmental
concerns,
including
TRI
sites,
other
air
pollution
sources,
water
pollution
sources,
and
Superfund
sites.
It
is
possible
to
zoom
in
on
a
particular
community
and
also
obtain
information
on
specific
locations.

Ohio
Citizen
Action
(
http://
www.
ohiocitizen.
org/)
is
Ohio's
largest
environmental
organization.
They
use
and
promote
toxic
chemical
right­
to­
know
laws
as
a
means
for
negotiating
"
good
October,
2005
19
neighbor
agreements"
with
industrial
facilities
in
Ohio.
For
example,
the
group's
non­
profit
arm,
Ohio
Citizen
Action
Education
Fund,
examined
TRI
data
for
Sunoco's
Toledo
Refinery
in
Ohio
to
check
the
company's
statement
to
the
community
regarding
its
annual
environmental
releases.
The
group
found
that
the
company's
statement
was
based
on
its
reporting
to
TRI
rather
than
its
total
chemical
releases,
as
reported
to
the
City
of
Toledo.

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:

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.
In
2003,
Scorecard
received
approximately
3
million
queries
related
to
TRI
data.

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
over
100,000
TRI
searches
were
performed
in
2003
which
is
about
50%
of
the
total
database
searches
on
RTK
NET
for
the
year.

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
October,
2005
20
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."

The
Safe
Hometowns
Initiative
is
a
group
of
organizations
and
individuals
concerned
about
the
threat
to
public
safety
posed
by
hazardous
chemicals
in
American
communities.
They
formed
shortly
after
September
11th
to
encourage
government
and
industry
to
protect
communities
by
putting
prevention
first
rather
than
restricting
environmental
information.
They
advocate
using
TRI
data
in
their
Safe
Hometowns
Guide
(
http://
www.
safehometowns.
org/
download.
html)
to
help
communities
identify
vulnerable
facilities,
organize
assessments
of
hazardous
materials
used
at
facilities,
and
make
recommendations
on
safer
material
and
process
alternatives.

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
October,
2005
21
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
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
October,
2005
22
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
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.
October,
2005
23
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
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.

Performance
Measurement
Industry
uses
TRI
data
to
identify
pollution
prevention
opportunities,
set
goals
for
toxic
chemical
release
reductions,
and
demonstrate
its
commitment
to
and
progress
in
reducing
emissions.
At
least
one
industry
initiative
­­
the
American
Chemistry
Council's
(
ACC)
Responsible
Care
October,
2005
24
Program
plans
to
use
TRI
data
as
a
performance
measure
to
demonstrate
participating
companies'
environmental
progress.
In
2004,
there
were
226
companies
participating
in
the
Responsible
Care
Program
that
will
report
their
TRI
releases
as
a
performance
metric.
Of
the
226
responsible
care
companies,
33
are
in
the
top
50
(
66%)
chemical
companies
based
on
sales
in
2002
and
will
use
their
TRI
releases,
in
part,
as
a
measure
of
their
performance.

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
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
October,
2005
25
Green
Century
Equity
Fund
screens
out
companies
with
the
worst
environmental
and
social
records.
The
funds
are
monitored
for
environmental
performance
using
TRI
data.

KLD
Research
and
Analytics
screens
companies
and
investments
for
inclusion
in
Domini
Social
Investments'
"
Domini
400
Social
Index."
Environmental
performance
is
one
aspect
of
their
selection
criteria
including
an
evaluation
of
the
largest
emitters
as
reported
in
TRI
for
each
state.
Other
environmental
selection
measures
include
compliance
with
EPA
regulations,
a
company's
liability
for
hazardous
waste
sites,
and
involvement
in
pollution
prevention
programs,
among
other
factors.

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.

Before
making
an
investment
in
property,
The
National
Association
of
Realtors
suggests
that
homebuyers
check
information
reported
through
TRI.
On
their
web
site,
Realtor
Magazine
Online
recommends
that
homebuyers
and
realtors
evaluate
an
area's
environmental
safety
by
checking
the
pollutant
release
data
provided
at
Environmental
Defense's
Scorecard
web
site.

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
October,
2005
26
level."
Students
and
faculty
in
the
academic
community
also
perform
studies
based
on
TRI
data.
Examples
of
academic
research
using
TRI
data
include:

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
in
research
focusing
on
the
role
of
information
disclosure
programs
in
environmental
policy.
One
of
his
research
projects,
conducted
with
Michael
Kraft
and
Troy
Abel,
utilized
TRI
data
to
examine
correlations
between
measures
of
emissions
as
reported
in
TRI
and
state
measures
of
policy,
political
environment,
and
economic
resources.
The
authors
found
that
the
ratio
of
facilities
reducing
toxic
releases
to
facilities
increasing
them
was
correlated
with
political
factors
at
the
state
level
such
as
membership
in
conservation
groups.
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.

Andrew
King
and
Michael
Lenox
of
New
York
University's
Stern
School
of
Business
tested
the
relationship
between
"
lean
production"
and
environmental
performance.
TRI
data
were
employed
as
one
measure
of
production,
with
lower
inventories
representing
leaner
production.
The
study
found
that
lean
production
was
correlated
to
measures
of
waste
reduction
and
pollution
reduction.
October,
2005
27
Michael
Ash
of
the
University
of
Massachusetts
and
T.
Robert
Fetter
of
Science
Applications
International
Corporation
used
TRI
data
in
an
environmental
justice
analysis
for
the
contiguous
United
States.
They
incorporate
measures
of
risk
faced
by
different
economic
and
racial
groups
by
using
RSEI,
which
combines
TRI
data
on
releases
with
information
on
transport
and
toxicity
for
each
chemical.
Their
analysis
also
controls
for
regional
variations
in
pollution,
allowing
them
to
identify
exposure
differences
both
within
cities
and
between
cities.
They
found
a
consistent
relationship
between
income
and
pollution
exposure,
and
determined
that
certain
racial
groups
live
both
in
more
polluted
cities,
and
in
more
polluted
neighborhoods
within
cities,
while
others
live
in
less
polluted
cities,
but
in
more
polluted
areas
within
cities.

Linda
Bui,
an
economics
researcher
at
Brandeis
University,
has
used
TRI
data
in
her
work
on
the
effect
of
public
disclosure
laws
such
as
TRI.
One
such
study,
published
in
The
Review
of
Economics
and
Statistics
in
2003,
evaluated
the
relationship
between
TRI
releases
and
housing
prices
and
other
political
economy
variables.
In
another
study,
Bui
examined
firm­
level
response
of
petroleum
refineries
to
public
disclosure
of
their
toxic
chemicals
through
TRI.
TRI
releases
to
air
and
water
were
evaluated
in
relation
to
firm
expenditure
on
abatement
technology
for
other
non­
hazardous
chemicals
discharged.
In
addition,
Bui
looked
at
whether
state
pollution
prevention
policies
and
TRI­
type
programs
helped
to
explain
differences
in
TRI
releases
at
the
refineries
across
states
as
a
measure
of
effectiveness
of
public
disclosure
policies.
Researchers
from
Harvard
University,
Robert
Stavins,
Lori
Snyder,
and
Nolan
Miller,
also
evaluated
firm­
level
response
to
TRI.
Their
study
examines
the
effect
of
TRI
and
other
regulatory
programs
on
technology
adoption
in
the
chlorine
manufacturing
industry,
particularly
of
adoption
of
membrane
cell
technology.
The
authors
are
also
studying
the
effect
of
state­
level
pollution
prevention
regulations
with
some
similarity
to
TRI.

Lori
Snyder
also
conducted
research
assessing
the
validity
of
TRI
data
in
light
of
the
potential
"
truncation
bias"
that
may
be
caused
by
TRI's
reporting
thresholds.
She
estimates
the
magnitude
of
releases
for
Massachusetts
that
may
not
be
reported
to
TRI
because
of
facilities
which
dropped
below
the
reporting
threshold
for
particular
chemicals.
Massachusetts's
Toxic
Use
Reduction
Act
(
TURA)
provides
comparison
data
for
Massachusetts
facilities,
because
it
has
lower
thresholds
and
it
also
asks
facilities
why
they
may
have
stopped
reporting
for
a
chemical
they
previously
reported.
She
found
that
truncation
bias
could
be
significant
at
least
for
releases
in
Massachusetts,
and
based
on
her
results,
she
provides
guidance
for
policy
analysts
in
using
TRI
data
to
measure
program
effectiveness.

Research
conducted
at
North
Carolina
State
University,
in
conjunction
with
the
Pew
Research
Center
for
the
People
and
the
Press
and
with
funding
from
EPA,
assessed
the
extent
to
which
people
are
aware
of
TRI
data
and
the
impact
of
this
information.
To
measure
the
extent
of
public
awareness
of
TRI
information
and
people's
approach
to
environmental
information,
a
telephone
survey
was
carried
out
of
600
people
in
two
cities.
The
authors
also
conducted
more
in­
depth
focus
groups
and
interviews
with
respondents
who
were
familiar
with
TRI
to
ascertain
the
level
of
October,
2005
28
their
knowledge
and
the
level
of
their
support
for
environmental
information
dissemination
as
a
form
of
environmental
protection.

As
an
extension
of
measuring
program
effectiveness,
Wade
E.
Martin
of
California
State
University
proposed
a
study
to
evaluate
the
economic
benefit
of
TRI
information.
He
proposed
to
study
two
main
user
groups,
attorneys
and
citizen
activist
groups,
to
determine
their
"
willingness
to
pay"
for
the
data
available
through
TRI.
The
project
would
entail
surveying
a
random
sample
of
both
user
groups,
and
asking
questions
about
their
use
of
TRI
data
and
its
role
in
their
work.
The
end
result
would
be
an
economic
valuation
for
the
TRI
data,
and
the
cost
to
these
users
of
not
having
the
data
available
in
its
current
format.

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
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.

TRI
data
are
integrated
into
many
lesson
plans
or
activity
guides
for
K­
12
teachers
and
students.
The
National
Science
Teacher's
Association
published
a
resource
guide
for
high
school
teachers
on
using
environmental
data,
specifically
TRI,
to
integrate
science
in
an
everyday
context.
The
resource
kit
was
designed
with
the
help
of
EPA
and
helps
students
to
conduct
research
into
environmental
issues
in
their
own
communities.
Delaware's
Department
of
Natural
Resources
designed
a
set
of
lessons
for
a
high
school
and
middle
school
air
quality
education
program.
This
program,
which
incorporates
TRI
data,
includes
a
lesson
on
air
quality
impact
associated
with
industrial
sources.
Students
use
the
data
to
locate
facilities
in
their
area
that
have
air
emissions.
They
are
also
able
to
identify
the
types
and
quantity
of
facility
emissions.
They
can
compare
businesses
that
report
to
TRI
between
counties
and
explore
the
health
hazards
posed
by
the
reported
emissions.

A
2001
workshop
sponsored
by
the
University
of
Arizona
explored
how
to
integrate
toxicology
with
high
school
curriculum.
How
to
obtain
data
from
the
TRI
and
what
the
data
mean
were
included
in
the
activities
for
middle
and
high
school
teachers
to
help
them
use
it
with
their
students.

Private
groups
also
have
incorporate
TRI
data
into
environmental
education
programs.
Aquatic
Research
Interactive,
Inc,
which
conducts
distance
learning
programs
online,
offers
a
program
on
accessing
TRI
data.
"
Diving
into
Toxic
Releases
Inventory"
reviews
how
students,
educators,
and
October,
2005
29
community
members
can
access
toxic
release
data
from
the
EPA.
The
program
demonstrates
how
to
use
EPA's
TRI
Explorer
Web
site,
including
how
to
use
the
different
search
features;
generate
reports;
and
interpret
the
results.

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
34
Fabricated
Metals
October,
2005
30
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.

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
October,
2005
31
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,
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
October,
2005
32
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.

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.

Ensuring
the
accuracy
of
the
on­
site
release
and
off­
site
transfer
estimates
is
an
on­
going
effort,
and
includes
comparison
across
reporting
years
as
well
as
use
of
data
and
evaluations
based
on
facility
site
visits.
EPA
conducted
a
data
quality
site
survey
of
104
facilities
for
reporting
years
1994
and
1995:
25
facilities
in
SIC
code
25
(
furniture
manufacturing)
for
1994;
19
facilities
in
SIC
code
281
(
inorganic
chemical
manufacturing)
for
1994;
17
facilities
in
SIC
code
285
(
paint
manufacturing)
for
1994;
23
facilities
in
SIC
code
30
(
rubber
and
plastics
manufacturing)
for
1994;
10
facilities
in
SIC
code
26
(
pulp
and
paper
manufacturing)
for
1995;
and
10
facilities
in
SIC
code
286
(
organic
chemical
manufacturing)
for
1995.
Following
are
some
of
the
major
findings
of
the
site
survey:
1)
Facility
and
site
surveyor
release
estimates
were
in
good
agreement,
calculated
to
be
within
±
3%.
2)
Facilities
primarily
used
purchasing
records
to
make
threshold
determinations.
3)
Facilities
in
chemical
manufacturing
used
production
data
more
frequently
to
make
threshold
determinations.
4)
Facilities
in
chemical
manufacturing
were
more
likely
to
assume
thresholds
were
exceeded
and
because
of
that
they
had
the
highest
error
rate,
primarily
for
reporting
chemicals
that
did
not
exceed
thresholds.
5)
Container
residue
was
the
most
commonly
overlooked
release
source.

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,
October,
2005
33
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
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.
October,
2005
34
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.

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,
it
is
thought
that
this
alternate
threshold
will
be
most
advantageous
to
small
entities.

EPA
conducted
a
TRI
Stakeholder
Dialogue
between
November
2002
and
February
2004
to
explore
burden
reduction
opportunities.
During
this
dialogue,
improvements
to
the
TRI
reporting
process
were
identified
and
a
number
of
burden
reduction
options
associated
with
TRI
reporting
were
explored.
After
reviewing
these
improvements
and
reporting
options,
EPA
has
promulgated
a
TRI
Reporting
Forms
Modification
Rule
(
July
12,
2005,
70
FR
39931)
that
simplifies
a
number
of
TRI
reporting
requirements;
removes
some
data
elements
from
the
Form
R
and
Form
A
that
October,
2005
35
can
be
obtained
from
other
EPA
information
collection
databases,
or
are
rarely
used,
and
updates
the
regulations
to
provide
corrected
contact
information
and
descriptions
of
the
Forms
R
and
A
data
elements.
The
benefit
is
not,
however,
limited
to
small
businesses.

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.
In
the
last
five
years
TRIME
usage
has
increased.
Note
that
73
percent
of
responses
were
received
electronically
for
the
1999
reporting
year.
And
by
reporting
year
2003
93%
of
responses
were
received.

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.

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.

The
TRI
contains
information
on
releases,
transfers,
inventories,
and
pollution
prevention
activities
for
approximately
650
toxic
chemicals
and
chemical
categories.
Although
there
are
no
national
databases
that
are
comparable
to
the
whole
of
TRI,
several
data
sources
exist
which
contain
media­
specific
data
on
releases
and
transfers.
In
theory,
information
from
these
databases
October,
2005
36
could
be
combined
to
form
an
analog
of
release
and
transfer
data
contained
in
TRI.
However,
this
undertaking
is
extremely
difficult
at
best,
and
may
be
impossible
given
the
currently
available
data
sources
(
see
Figure
1
below).
Difficulties
replicating
TRI
data
using
these
alternative
sources
include
differences
in
chemical
coverage,
facility
coverage,
reporting
frequencies,
and
perhaps
most
importantly,
the
integration
of
data
from
various
sources
at
a
facility
level.

For
example,
the
AIRS
Facility
Subsystem
(
AFS)
contains
emissions,
compliance,
and
enforcement
data
on
air
pollution
point
sources
emitting
any
of
the
so­
called
criteria
pollutants
at
levels
above
defined
thresholds.
The
Air
Quality
System
(
AQS)
technical
area
is
designed
primarily
for
AQS
users
(
state,
tribal
and
local
agency
management,
EPA
Regional
Offices,
consultants,
and
environmental
groups.)
It
provides
information
about
the
use
of
the
AQS
application,
software
downloads,
file
formats,
background
project
information,
and
events
of
special
interest
to
personnel
working
with
data
for
the
AQS.
AQS
was
formerly
a
subsystem
of
the
Aerometric
Information
Retrieval
System
(
AIRS).
AIRS
also
included
the
AIRS
Facility
Subsystem
(
AFS).
AFS
is
now
operated
and
maintained
by
the
EPA's
Office
of
Enforcement
and
Compliance
Assurance
(
OECA).

The
Air
Facility
Subsystem
(
AFS)
contains
compliance
and
permit
data
for
stationary
sources
regulated
by
the
U.
S.
EPA
and
state
and
local
air
pollution
agencies.
AFS
is
used
by
some
state
and
local
government
agencies
to
track
permit
data.
For
further
information
regarding
the
air
permitting
program,
visit
EPA's
Air
Permits
page.
This
information
is
used
by
the
states
to
prepare
State
Implementation
Plans
(
SIPs)
and
to
track
the
compliance
status
of
point
sources
with
various
regulatory
programs
under
the
Clean
Air
Act.
Tracking
of
emissions
inventories
has
been
moved
to
the
National
Emissions
Inventory
(
NEI)
database.
This
site
is
designed
to
keep
users
of
the
system
appraised
of
new
developments.
AFS
was
once
a
part
of
AIRS,
hence
the
historical
utilization
of
that
term
may
be
incorporated
within
referenced
documentation.

AFS
data
are
not
a
good
substitute
for
TRI
air
emissions
data
because
of
the
lack
of
reporting
requirements
for
most
air
toxics
and
the
lack
of
rigid
reporting
schedules,
and
because
there
is
no
requirement
for
states
to
report
emissions
of
Hazardous
Air
Pollutants
(
HAPs)
to
AFS.
A
number
of
states
and
regional
agencies
do
maintain
their
own
air
emissions
inventories,
including
California,
and
the
Great
Lakes
states.
In
these
states,
difficulties
replicating
TRI
data
include
variations
in
the
types
of
data
collected,
and
the
fact
that
only
some
states
maintain
these
types
of
inventories.
October,
2005
37
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
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
1.
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.

2.
"
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.
October,
2005
38
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.
You
can
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
you
to
retrieve
preselected
data
from
the
PCS
database
in
Envirofacts.
You
can
narrow
your
search
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
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.
October,
2005
39
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).

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
(
SO2),
nitrogen
dioxide
(
NO2),
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
October,
2005
40
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,
SOx,
or
NOx,
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,
SOx,
or
NOx,
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
designed
to
distinguish
stack
level
emissions
from
fugitive
air
emissions,
such
an
effort
would
3.
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
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.
October,
2005
41
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
(
PM10
&
PM2.5),
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;
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
judgment
(
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
4.
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.
October,
2005
42
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
general
thresholds
of
25,000
pounds
per
year
for
manufacture
and
processing
of
a
chemical
and
10,000
pounds
per
year
for
otherwise
use
of
a
chemical.
These
thresholds
are
not
tied
to
emissions
quantities.
In
addition
to
this
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.

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.
October,
2005
43
Industry/
facility
coverage:
States
often
develop
their
own
toxics
inventories
due
to
perceived
gaps
in
TRI's
industry
coverage.

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
principle
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
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
October,
2005
44
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
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
October,
2005
45
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
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
October,
2005
46
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
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
but
allows
reporting
in
concentration
if
it
is
impracticable
to
do
so,
the
fact
that
PCS
monitoring
data
can
be
reported
in
either
mass
units
or
as
October,
2005
47
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,
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
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
limit
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
October,
2005
48
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.

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.
October,
2005
49
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
that
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
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
October,
2005
50
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.

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
Report
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
October,
2005
51
(
including
coal,
phosphate
rock
and
overburden
from
the
mining
of
uranium
ore)
as
nonhazardous
solid
wastes
and
therefore
not
subject
to
reporting
a
Biennial
Report.
5
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
Report
requirement.
Electric
utilities
represent
an
industrial
group
being
considered
for
addition
to
TRI.
The
full
list
of
wastes
that
are
excluded
from
Biennial
Reports
include
the
following:

5.
As
defined
under
§
261.4(
b)(
7),
the
beneficiation
of
ores
and
minerals
includes
but
is
not
limited
to
activities
such
as
the
following:
crushing,
grinding,

washing,
sizing,
drying,
solvent
extraction,
and
magnetic
separation.
For
a
complete
list
refer
to
§
261.4(
b)(
7).
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
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.
October,
2005
52
The
"
mixture
rule"
and
"
derived­
from"
rule
were
adopted
by
EPA
in
1980
and
affect
the
data
reported
to
Biennial
Reports.
6
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
are
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.

Discharges
to
a
POTW
Section
313
of
EPCRA
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
require
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.

6.
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.
October,
2005
53
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
or
indirectly
to
surface
waters,
the
waste
is
not
subject
to
Biennial
Report
requirements.
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
contain
hazardous
waste
data
from
large
quantity
generators
(
LQGs)
and
treatment,
storage
and
disposal
facilities
(
TSDFs),
also
require
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
provide
data
on
the
volume
of
hazardous
waste
shipped
off­
site
for
land
disposal,
a
release
end­
point
of
relevance
to
TRI.

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.
October,
2005
54
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:
October,
2005
55
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).

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
October,
2005
56
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.

Section
311
and
312
of
EPCRA
require
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
section
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
section
302
as
Extremely
Hazardous
Substances
(
EHSs)
is
the
threshold
planning
quantity
(
TPQ),
or
500
pounds,
whichever
is
lower.
7
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.

7
The
Extremely
Hazardous
Substances
and
their
TPQs
are
listed
in
40
CFR
Part
355,
Appendices
A
and
B.
October,
2005
57
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
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;
October,
2005
58

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.

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.
October,
2005
59
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
(
onetime
and
for
the
entire
year),
and
shipped
off­
site
in
wastes.

EPA
Databases
with
Pollution
Prevention
Data
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
below.
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
pollution­
prevention
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.
October,
2005
60
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.

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
Report
requirements
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
Report
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
Report.
That
the
exact
contents
of
a
facility's
waste
mixture
cannot
always
be
determined
may
make
it
difficult
to
extract
chemicalspecific
data
from
Biennial
Reports.

State
Environmental
Agency
Databases
As
required
by
section
313
(
a)
of
EPCRA,
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
October,
2005
61
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.
8
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.
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.

8.
For
a
detailed
comparison
of
materials
accounting
data
elements
reported
to
TRI,
New
Jersey,
and
Massachusetts,
see
(
U.
S.
EPA,
1995d).
October,
2005
62
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.
October,
2005
63
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)

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
October,
2005
64
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)

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
include
hazardous
wastes,
while
TRI
pollution
prevention
data
includes
information
on
wastes
or
process
by­
products
in
all
production
phases
and
media.
Because
Biennial
Reports
collect
data
organized
by
Biennial
Reports
waste
codes,
they
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.
As
required
by
section
313
(
a)
of
EPCRA,
facilities
send
copies
of
all
TRI
reports
to
both
state
and
federal
October,
2005
65
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
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
do
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
TRIlike
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.

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.
October,
2005
66
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
require
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.
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
October,
2005
67
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
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
October,
2005
68
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
that
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
which
have
had
beneficial
effects,
including
burden
reduction.

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
October,
2005
69
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
has
conducted
a
series
of
Stakeholder
meetings
over
time,
with
the
most
recent
being
in
October
of
2004
to
address
issues
concerning
reporting
requirements
and
possible
changes
to
the
Form
R.
Specific
issues
discussed
at
these
meetings
included
ways
of
improving
the
TRI
program,
ways
of
reducing
the
burden
of
TRI
reporting,
and
possible
improvements
to
the
TRI
reporting
form.
These
meetings
have
resulted
in
a
series
of
separate
rulemakings
to
address
burden
that
are
currently
under
development.
October,
2005
70
5(
c)
Effects
of
Less
Frequent
Collection
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.
October,
2005
71
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).

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,
October,
2005
72
respondent
experience
as
reflected
in
comments
to
EPA
and
other
parties,
best
professional
judgement
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.
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.

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

°
Compliance
Determination:
Facility
staff
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:
Facility
staff
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:
Facility
staff
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:
Facility
staff
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
required
to
inform
customers,
either
by
letter
or
through
the
materials
safety
data
sheet
(
MSDS)
for
the
product.

This
ICR
reflects
one
change
from
the
last
TRI
Form
R
ICR.
Due
to
the
TRI
Reporting
Forms
Modification
Rule,
both
first
and
subsequent
form
completion
time
is
slightly
reduced.
Previously,
EPA
estimated
that
form
completion
would
require
69
hours
in
the
first
year
for
October,
2005
73
PBT
and
Non­
PBT
chemicals.
In
subsequent
years,
form
completion
would
require
47.1
hours
for
PBT
chemicals
and
25.2
hours
for
Non­
PBT
chemicals.
Currently,
EPA
estimates
that
form
completion
will
require
66.8
hours
for
PBT
chemicals
and
67.6
hours
for
Non­
PBT
chemicals
in
the
first
year
and
46.3
hours
for
PBT
chemicals
and
24.6
hours
for
Non­
PBT
chemicals
in
subsequent
years.

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.
9
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
the
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.

Table
1
Average
Annual
Burden
Hour
Estimate
by
Activity
Category
Activity
Management
Technical
Clerical
Total
Hours
Compliance
Determination
­
all
facilities
1
3
0
4
Rule
Familiarization
­
first­
time
filers
12
22.5
0
34.5
Facility
Level
Supplier
Notification
0
7
17
24
Calculations
and
Report
Completion
­
first­
time
filers
­
PBTs
20.3
43.9
2.7
66.8
Calculations
and
Report
Completion
­
first­
time
filers
­
Non­
PBTs
20.5
44.4
2.8
67.6
Calculations
and
Report
Completion
­
subsequent
year
filers
­
PBTs
14.1
30.4
1.9
46.3
Calculations
and
Report
Completion
­
subsequent
year
filers
­
Non­
PBTs
7.5
16.1
1.0
24.6
Per
Form
R
Recordkeeping/
Submission
­
all
filers
0
4
1
5
9.
Approximately
70
percent
of
affected
facilities
file
3
or
fewer
Form
Rs
in
reporting
year
2002.
The
most
common
number
of
reports
filed
is
1.
October,
2005
74
Table
2
Average
Annual
Burden
Hour
Estimate
per
Facility
in
Each
Subsequent
Year
Average
Annual
Hours
Burden
Type
of
Facility
Management
Technical
Clerical
Total
Hours
Compliance
Determination
Only
1
3
0
4
Compliance
Determination
and
3
PBT
Form
Rs
43.3
106.1
8.6
157.9
Compliance
Determination
and
3
Non­
PBT
Form
Rs
23.6
63.2
6.1
92.9
Compliance
Determination,
3
PBT
Form
Rs,
and
Supplier
Notification
43.3
113.1
25.6
181.9
Compliance
Determination,
3
Non­
PBT
Form
Rs,
and
Supplier
Notification
23.6
70.2
23.1
116.9
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.

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.
October,
2005
75
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
one­
time
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
full­
time
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
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
46.3
hours
per
PBT
Form
R
and
24.6
hours
per
Non­
PBT
Form
R
for
on­
going,
annual
reporting.
This
estimate
is
based
on
the
most
recent
estimate
of
reporting
burden
negotiated
by
EPA
and
OMB.
10
It
has
also
been
adjusted
downward
to
reflect
burden
savings
associated
with
the
recently
promulgated
TRI
Reporting
Forms
Modification
Rule.
To
complete
the
Form
R,
facilities
will
need
to
verify
and
update
data,
review
previous
10
USEPA/
OEI,
Terms
of
Clearance
for
TRI
ICR
Renewal,
January
20,
2004.
Memo
from
Cody
Rice
OPPT/
EETD/
EPAB
to
Amy
Newman
OEI/
OIAA/
EAD/
ASB.
October,
2005
76
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
138.9
hours
per
PBT
Form
R
and
73.8
hours
per
Non­
PBT
Form
R.
The
estimate
for
first
year
calculations
and
report
completion
is
66.8
hours
per
Form
R
for
a
PBT
chemical
and
67.6
hours
per
Form
R
for
a
Non­
PBT
chemical.

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
be
157.9
hours
if
all
3
reports
are
for
PBT
chemicals
and
92.9
hours
if
all
3
reports
are
for
Non­
PBT
chemicals.
For
facilities
submitting
3
Form
Rs
that
are
also
required
to
comply
with
supplier
notification,
the
average
burden
is
estimated
at
181.9
and
116.9
hours
per
facility
for
PBT
chemicals
and
Non­
PBT
chemicals,
respectively.

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,
2005
77
Table
3
Average
Burden
Hour
Estimate
per
Petition
Average
Annual
Hours
Burden
Activity
Management
Technical
Clerical
Total
Hours
Burden
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.
October,
2005
78
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.
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.
11
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
goods­
producing,
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
2004
hourly
wage
rates
are
shown
in
Table
4.

11
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
2004
dollars.
October,
2005
79
Table
4
Loaded
Hourly
Wage
Rates
by
Labor
Category
2004
Labor
Category
Average
Hourly
Wage
Benefit
(%
wages)
Overhead
(%
wages)
Loaded
Hourly
Rate
Managerial
$
33.61
40.85%
17%
$
53.05
Technical
$
28.52
40.06%
17%
$
44.79
Clerical
$
14.70
43.68%
17%
$
23.62
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
$
187.
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
PBT
forms
is
$
7,251.
The
average
subsequent
year
cost
for
a
facility
submitting
3
Non­
PBT
forms
is
$
4,229.
For
facilities
that
must
also
comply
with
supplier
notification,
the
average
subsequent
year
cost
increases
to
$
7,966
for
PBT
reports
and
$
4,944
for
Non­
PBT
reports.

Table
5
Average
Annual
Cost
Estimate
by
Activity
Category
Activity
Management
Technical
Clerical
Total
Cost
Compliance
Determination
­
all
facilities
$
53
$
134
$
0
$
187
Rule
Familiarization
­
first­
time
filers
$
637
$
1,008
$
0
$
1,644
Facility
Level
Supplier
Notification
$
0
$
314
$
402
$
715
Calculations
and
Report
Completion
­
firsttime
filers
­
PBTs
$
1,076
$
1,965
$
63
$
3,104
Calculations
and
Report
Completion
­
firsttime
filers­
Non­
PBTs
$
1,088
$
1,986
$
66
$
3,140
Calculations
and
Report
Completion
­
subsequent
year
filers
­
PBTs
$
748
$
1,360
$
44
$
2,152
Calculations
and
Report
Completion
­
subsequent
year
filers
­
Non­
PBTs
$
400
$
720
$
24
$
1,144
Per
Form
R
Recordkeeping/
Submission
­
all
filers
$
0
$
179
$
24
$
203
October,
2005
80
Table
6
Average
Annual
Cost
Estimate
per
Facility
in
Each
Subsequent
Year
Type
of
Facility
Management
Technical
Clerical
Total
Cost
Compliance
Determination
Only
$
53
$
134
$
0
$
187
Compliance
Determination
and
3
Form
Rs
­
PBTs
$
2,297
$
4,752
$
202
$
7,251
Compliance
Determination
and
3
Form
Rs
­
Non­
PBTs
$
1,254
$
2,832
$
143
$
4,229
Compliance
Determination,
3
Form
Rs
and
Supplier
Notification
­
PBTs
$
2,297
$
5,066
$
604
$
7,966
Compliance
Determination,
3
Form
Rs
and
Supplier
Notification
­
Non­
PBTs
$
1,254
$
3,145
$
545
$
4,944
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
Cost
1.
Read
EPA
Policy
and
Guidance
$
212
$
0
$
0
$
212
2.
Plan
Activities
$
106
$
45
$
0
$
151
3.
Prepare
Literature
Search
$
106
$
314
$
0
$
420
4.
Conduct
Literature
Search
$
0
$
2,150
$
0
$
2,150
5.
Process,
Review,
and
Focus
Information
$
637
$
3,314
$
0
$
3,951
6.
Write
Petition
$
212
$
358
$
142
$
712
7.
Review
and
Edit
petition
$
212
$
358
$
47
$
618
8.
Submit
to
EPA
and
File
$
0
$
0
$
71
$
71
Total
Cost
per
Petition
$
1,485
$
6,539
$
260
$
8,285
October,
2005
81
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
$
8,285.

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.

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).
October,
2005
82
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
2003
reporting
year.
$
0.8
million
in
fixed
costs
and
26.3
FTEs
are
required
to
conduct
the
EPA
activities
described
above
plus
an
additional
$
35
in
variable
costs
for
each
form
processed.

As
discussed
in
the
following
section,
approximately
82,000
Form
R
reports
are
expected
to
be
filed
per
year.
Thus,
the
total
annual
burden
to
EPA
is
estimated
to
be
$
2.88
million
in
variable
costs,
along
with
the
$
0.8
million
in
fixed
costs
and
26.3
FTEs
(
or
55,000
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
$
99,776)
and
half
by
employees
at
grade
GS­
13,
step
5
(
at
a
loaded
salary
of
$
118,651),
using
a
loading
factor
of
1.4
that
includes
wages
and
benefits
but
not
overhead
which
is
included
in
the
fixed
costs
portion
of
the
Agency
burden
estimate.

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
22,000
facilities
are
expected
to
also
perform
the
report
completion
and
recordkeeping
activities
for
82,000
Form
Rs.
12
As
a
result,
179,785
facilities
are
estimated
to
complete
only
the
compliance
determination
procedure.
An
additional
22,000
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
22,000
facilities
that
file
Form
Rs,
it
is
expected
that
1,031
facilities
will
be
reporting
to
TRI
for
the
first­
time
as
they
exceed
applicable
thresholds,
and
that
these
12
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
2002
reporting
year,
21,941
facilities
submitted
81,429
Form
Rs.
The
number
of
facilities
and
forms
has
been
rounded
up
to
the
nearest
thousand
for
this
ICR.
October,
2005
83
facilities
will
file
1,629
of
the
Form
Rs.
13
Table
9
presents
the
total
annual
burden
hours
based
on
these
estimates.

Table
9
Total
Annual
Burden
Hour
Estimate
For
Form
R
Activity
Hours
Number
of
Facilities
Number
of
Reports
Total
Burden
Compliance
Determination
­
all
facilities
subject
to
EPCRA
313
4
201,785
N/
A
807,140
Rule
Familiarization
­
first­
time
filers
only
34.5
1,031
N/
A
35,570
Form
R
Completion
­
reports
from
first­
time
filers
­
PBTs
66.8
N/
A
311
20,779
Form
R
Completion
­
reports
from
first­
time
filers
­
Non­
PBTs
67.6
N/
A
1,318
89,144
Form
R
Completion
­
reports
from
subsequent
year
filers
­
PBTs
46.3
N/
A
15,232
705,477
Form
R
Completion
­
reports
from
subsequent
year
filers
­
Non­
PBTs
24.6
N/
A
64,568
1,590,794
Recordkeeping/
Submission
­
all
reports
5
N/
A
81,429
407,145
Supplier
Notification
24
3,734
N/
A
89,616
Total
3,745,665
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
10
presents
the
total
annual
hours
burden
for
all
petitions.
The
total
annual
hours
burden
for
all
petitions
submitted
is
expected
to
be
925
hours.

13
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."
October,
2005
84
Table
10
Total
Annual
Burden
Hour
Estimate
For
All
Petitions
(
5
petitions
per
year)

Annual
Hours
Burden
Activity
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
11
presents
the
annual
reporting
cost
for
Form
R.
October,
2005
85
Table
11
Total
Annual
Cost
Estimate
For
Form
R
(
2004
dollars)

Activity
Cost
Number
of
Facilities
Number
of
Reports
Total
Cost
Compliance
Determination
­
all
facilities
subject
to
EPCRA
313
$
187.42
201,785
N/
A
$
37,818,545
Rule
Familiarization
­
first­
time
filers
$
1,644.38
1,031
N/
A
$
1,695,351
Form
R
Completion
­
reports
from
firsttime
filers
­
PBTs
$
3,103.82
N/
A
311
$
965,102
Form
R
Completion
­
reports
from
firsttime
filers
­
Non­
PBTs
$
3,139.76
N/
A
1,318
$
4,138,389
Form
R
Completion
­
reports
from
subsequent
year
filers
­
PBTs
$
2,151.72
N/
A
15,232
$
32,775,139
Form
R
Completion
­
reports
from
subsequent
year
filers
­
Non­
PBTs
$
1,144.29
N/
A
64,568
$
73,884,580
Recordkeeping/
Submission
­
all
reports
$
202.78
N/
A
81,429
$
16,512,173
Supplier
Notification
$
715.07
3,734
N/
A
$
2,670,071
Annual
Total
$
170,459,349
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
12.
October,
2005
86
Table
12
Total
Annual
Cost
Estimate
for
All
Petitions
(
2004
dollars)

Activity
Management
Technical
Clerical
Total
Cost
1.
Read
EPA
Policy
and
Guidance
$
1,061
$
0
$
0
$
1,061
2.
Plan
Activities
$
531
$
224
$
0
$
754
3.
Prepare
Literature
Search
$
531
$
1,568
$
0
$
2,098
4.
Conduct
Literature
Search
$
0
$
10,750
$
0
$
10,750
5.
Process,
Review,
and
Focus
Information
$
3,183
$
16,572
$
0
$
19,755
6.
Write
Petition
$
1,061
$
1,792
$
709
$
3,561
7.
Review
and
Edit
petition
$
1,061
$
1,792
$
236
$
3,089
8.
Submit
to
EPA
and
File
$
0
$
0
$
354
$
354
Total
Cost
per
Petition
$
7,427
$
32,697
$
1,299
$
41,423
The
previous
tables
have
detailed
the
total
burden
and
cost
for
complying
with
Section
313
and
for
submitting
a
petition
independently.
Table
13
presents
the
total
burden
and
cost
for
both
activities.

Table
13
Total
Annual
Respondent
Burden
and
Cost
Activity
Annual
Burden
Hours
Annual
Costs
(
millions
of
2004
dollars)

Form
Rs
3,745,665
$
170.46
Petitions
925
$
0.04
Total
3,746,590
$
170.50
6(
e)
Reasons
for
Change
in
Burden
As
a
result
of
OMB's
October,
2003
approval
of
the
last
ICR
renewal,
OMB's
inventory
reflects
84,000
responses
and
3,888,752
hours
for
this
information
collection.
This
ICR
supporting
statement
is
for
82,000
responses
and
3,746,590
hours.
The
reduction
in
the
estimate
of
total
burden
of
approximately
142
thousand
hours
is
due
to
1)
the
fact
that
approximately
2,000
fewer
forms
were
filed
in
RY2002
than
in
RY2001
and
2)
Form
R
has
been
modified
to
eliminate
certain
data
elements
and
to
simplify
others.
Table
14
summarizes
the
major
program
changes
and
adjustments
that
have
been
made
over
the
last
several
years.
October,
2005
87
TABLE
14
Recent
Changes
in
TRI
Form
R
Burden
TRI
Form
R
ICR
(
EPA
#
1363,
OMB
#
2070­
0093)

Change
Total
Activity
­
Explanation
#
Responses
Burden
Hours
Total
Responses
Total
Burden
Hours
1997
Baseline
 
 
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)
(
4,045,540)
88,117
5,566,564
October
2003
Form
R
ICR
Renewal:
This
request
reflects
actual
number
of
responses
and
accounts
for
a
lower
subsequent
year
reporting
burden
for
non­

PBT
chemicals.
(
4,117)
(
1,677,812)
84,000
3,888,752
May
2005
Form
R
ICR
Renewal:
This
request
reflects
actual
number
of
responses.
(
2,000)
(
91,413)
82,000
3,797,339
2005
Program
Change
­
TRI
Reporting
Forms
Modification
Rule:
This
rule
eliminates
certain
data
elements
and
simplifies
others
beginning
in
RY2005.
 
(
50,749)
82,000
3,746,590
CURRENT
TOTALS
 
 
82,000
3,746,590
October,
2005
88
6(
f)
Burden
Statement
(
To
appear
on
Collection
Instrument)

The
annual
public
burden
related
to
the
Form
R
for
form
completion
and
recordkeeping,
which
is
approved
under
OMB
Control
No.
2070­
0093,
is
estimated
to
average
51.3
hours
per
response
for
PBT
chemicals
and
29.6
for
Non
PBT
chemicals.
There
is
additional
burden
associated
with
rule
familiarization,
compliance
determination
and
supplier
notification
as
described
in
Table
9.

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
025,
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
025
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,
2005
89
REFERENCES
Certain
references
cited
are
available
in
EPA
docket
#
OPPTS­
400104;
other
references
are
readily
available.

Arbuckle,
J.
Gordon,
et
al.,
1993.
Environmental
Law
Handbook,
Twelfth
Edition.
Government
Institutes,
Inc.,
Rockland
MD.

Bureau
of
National
Affairs,
1995.
"
State
Pollution
Prevention
Laws
&
Programs
and
Document
Submissions
Chart."

Burke,
Lauretta
M.,
1993.
Environmental
Equity
in
Los
Angeles
(
Santa
Barbara:
University
of
California
Center
for
Geographic
Information
and
Analysis,
July).

California
Air
Resources
Board,
Technical
Support
Division,
1993.
Emissions
Inventory
Criteria
and
Guidelines
Regulation
Pursuant
to
the
Air
Toxics
"
Hot
Spots"
Information
and
Assessment
Act
of
1987
(
as
amended
June
1990,
September
1990,
June
1991,
and
June
1993).

California
Air
Resources
Board,
undated.
"
Overview
of
the
Air
Toxics
`
Hot
Spots'
Information
and
Assessment
Act."

Chikkala,
John,
1995.
Minnesota
Department
of
Public
Safety
Emergency
Response
Commission.
Conversation
with
Abt
Associates.
November
13.

Chines,
Peter
(
1994).
Investor
Responsibility
Research
Center,
Inc.
Letter
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Samuel
Sasnett,
U.
S.
Environmental
Protection
Agency,
Office
of
Pollution
Prevention
and
Toxics,
April
21,
1994;
and
attachment,
"
How
to
Read
IRRC's
Corporate
Environmental
Profiles,"
pp.
18­
19.

Citizens
Fund,
1993.
Poisons
in
Our
Neighborhoods:
Toxic
Pollution
in
the
United
States
(
Washington,
DC:
Citizens
Fund,
November).

Citizens
Fund,
1992.
Manufacturing
Pollution
(
Washington,
DC:
Citizens
Fund,
August).

Cummens,
Pat,
1993.
Untitled
presentation,
in
Proceedings:
Toxics
Release
Inventory
(
TRI)
Data
Use
Conference
(
Washington,
DC:
U.
S.
Environmental
Protection
Agency,
Office
of
Pollution
Prevention
and
Toxics,
July).

Doer,
Lisa,
1995.
"
How
TRI
Can
Drive
Pollution
Prevention,"
in
Proceedings:
Toxics
Release
Inventory
(
TRI)
Data
Use
Conference:
Building
TRI
and
Pollution
Prevention
Partnerships
(
Washington,
DC:
U.
S.
Environmental
Protection
Agency,
Office
of
Pollution
Prevention
and
Toxics,
March).
October,
2005
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Donaghue,
Bob,
1995.
"
Prioritizing
Pollution
Prevention
Assistance
Needs
Using
the
1992
Toxic
Release
Inventory,"
in
Proceedings:
Toxics
Release
Inventory
(
TRI)
Data
Use
Conference:
Building
TRI
and
Pollution
Prevention
Partnerships
(
Washington,
DC:
U.
S.
Environmental
Protection
Agency,
Office
of
Pollution
Prevention
and
Toxics,
March).

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

Goodenow,
Dennis
California
Air
Resources
Board
(
CARB),
1995.
Personal
communication
with
Abt
Associates,
August
29,
1995.

Great
Lakes
Information
Network,
1996.
"
Regional
Air
Pollutant
Inventory
Development
System,"
Information
from
Great
Lakes
Information
Network
World
Wide
Web
site:
http://
www.
glc.
org/
projects/
air/
rapids/
rapids.
html
http://
www.
glc.
org
Greene,
Terry,
1995.
"
JSI
Community
Outreach
Project,"
in
Proceedings:
Toxics
Release
Inventory
(
TRI)
Data
Use
Conference:
Building
TRI
and
Pollution
Prevention
Partnerships
(
Washington,
DC:
U.
S.
Environmental
Protection
Agency,
Office
of
Pollution
Prevention
and
Toxics,
March).

Hartmann,
Carolyn,
1993.
Troubled
Waters:
Major
Sources
of
Toxic
Water
Pollution
(
Washington,
DC:
U.
S.
Public
Interest
Research
Group,
June).

Hausman,
Rick,
1993.
"
Environmental
Investing:
Dollars
and
Change,"
Online:
The
RTK
NET
Newsletter,
Vol.
3,
No.
2
(
Fall).

Herring,
Jeff,
OAQPS,
1995.
Personal
communication
with
Abt
Associates,
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
and
Redundancies
in
Pollution
Prevention
Reporting;
A
Compendium
of
Memoranda.
Prepared
for
U.
S.
EPA,
Office
of
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:
A
Study
of
Priorities
for
Pollution
Prevention
Activities
in
Colorado
(
Colorado
Pollution
Prevention
Advisory
Board,
May).
October,
2005
91
MacLean,
Alair
and
Paul
Orum,
1992.
Progress
Report:
Community
Right­
to­
Know
(
Washington,
DC:
OMB
Watch
and
Working
Group
on
Community
Right­
to­
Know,
July).

MacLean,
Alair
and
Rich
Puchalsky,
1994.
Where
the
Wastes
Are:
Highlights
from
the
Records
of
the
More
Than
5,000
Facilities
that
Receive
Transfers
of
TRI
Chemicals
(
Washington,
DC:
OMB
Watch
and
Unison
Institute,
April).

Massachusetts
Toxics
Use
Reduction
Institute,
1994.
Toxics
Use
Reduction:
Fact
Sheet
1.
Lowell,
MA:
University
of
Massachusetts
Lowell.
February.

Massachusetts
Department
of
Environmental
Protection,
1993.
An
Overview
of
the
Toxics
Use
Reduction
Act.
Prepared
by
Manik
Roy.
February.

McLure,
Pam,
1994.
"
Georgia
on
My
Mind",
Online:
The
RTK
NET
Newsletter,
Vol.
4,
No.
1
(
Summer).

Memorandum
from
J.
Karnes
to
Brian
Muehling
(
EPA/
OTS)
on
Updating
of
Unit
Labor
Costs
to
Reflect
Inflation
and
Industry
Comments
for
CAIR,
Centaur
Associates
Inc.
May
28,
1987.

National
Conference
of
State
Legislatures
(
NCSL),
1995.
"
1995
State
TRI
Program
Assessment."

"
Notes
from
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