1
Toxics
Release
Inventory
TRI
Reporting
Forms
Modifications:

Burden
Reduction
Rule
Shelley
Fudge
TRI
Program
Division
202­
566­
0674
Fudge.
Shelley@
epa.
gov
2
Reporting
Forms
Modifications
Rule
°
Primary
goal:
Proposing
changes
to
Form
R
and
Form
A
in
order
to
streamline
TRI
reporting,

wherever
possible,
to
reduce
burden
on
reporters
(&
EPA)
while
maintaining
utility
of
the
data
°
Options
derived
from
public
comments
and
program
considerations
°
Timeline:

 
Proposed
rule
anticipated
release:
December
2004
3
Four
types
of
options
1.
Facility
information
to
remove
from
Form
R
and
Form
A,
and
instead,
obtain
from
EPA's
on­
line
data
systems
2.
Items
to
remove
from
Form
R
collection
and
TRI
publications
entirely
3.
Sections
to
modify
of
Form
R
4.
Clarify
Form
A
applicability
4
Facility
information
to
remove
from
Part
I
of
Form
R
and
Form
A,
and
instead,

obtain
from
Facility
Registry
System
(
FRS)

°
Lat/
long
(
Sec.
4.6)

°
RCRA
ID
#
(
Sec.
4.8)

°
NPDES
permit
#
(
Sec.
4.9)

°
UIC
well
code
#
(
Sec.
4.10)
5
In
detail:

Remove
Lat/
long
(
Sec.
4.6)

°
Proposed
Action:

 
Remove
Lat/
Long
data
field
from
Form
R,
and
instead
pull
Lat/
Long
data
from
EPA's
Facility
Registry
System
(
FRS).

°
Justification:

 
Part
of
EPA's
overall
effort
to
centralize
data
collection
and
dissemination.
FRS
has
been
designated
as
EPA's
authoritative,
centralized
source
of
Lat/
Long
data.
6
In
detail:

Remove
RCRA,
NPDES
and
UIC
Program
ID
Numbers
°
Proposed
Action:

 
Remove
these
data
fields
from
Form
R,
and
instead
pull
the
data
from
EPA's
Facility
Registry
System
(
FRS).

°
Justification:

 
Provide
burden
reduction
and
avoid
duplication
of
effort.

 
FRS
has
been
designated
as
EPA's
authoritative,

centralized
source
of
such
facility
information.
7
Items
to
remove
from
Form
R,
Part
II
collection
and
TRI
publications
entirely
°
Remove
"%
from
Stormwater"
(
5.3C)

°
Remove
two
columns
from
"
On­
site
Waste
Treatment
Methods
and
Efficiency"
(
7A):

 
"
Range
of
influent
concentration"
(
7A.
1c)

 
"
Based
on
Operating
Data?"
(
7A.
1e)

°
Remove
optional
additional
information
checkbox
(
Sec.
8.11)
8
In
detail:

Remove
"%
From
Stormwater"
(
5.3C)

°
Proposed
Action:

 
Remove
"%
from
Stormwater"
for
each
"
Stream
or
Water
Body
Name"
under
"
Qty
of
the
toxic
chemical
entering
each
environmental
medium
Onsite"
(
Sec.

5.3C)

°
Justification:

 
Reduce
burden
and
simplify
Sec.
5
of
Form
R.

 
Unnecessary
to
continue
collecting
this
data
since
this
section
doesn't
appear
to
be
widely
used.
9
In
detail:

Remove
7A.
1c
and
7A.
1e
in
"
On­
site
Waste
Treatment
Methods
and
Efficiency"

°
Proposed
Action:

 
Remove
"
Range
of
influent
concentration"
(
7A.
1c),
and
"
Based
on
operating
data?"
(
7A.
1e)

°
Justification:

 
Reduce
burden
and
simplify
Sec.
7
of
Form
R.

 
Unnecessary
to
continue
collecting
this
data
since
these
sections
don't
appear
to
be
widely
used.
10
In
detail:

Remove
optional
additional
information
checkbox
(
Sec.
8.11)

°
Proposed
Action:

 
Remove
Sec.
8.11
yes/
no
question:
"
Is
additional
info
on
source
reduction,
recycling,
or
pollution
control
activities
included
with
this
report?"
from
Form
R.

 
Continue
to
provide
facilities
the
opportunity
to
submit
this
information
and
make
it
available
through
one
of
EPA's
on­
line
systems
(
e.
g.,
e­
DOCKET
or
Envirofacts)

 
Include
instructions
on
how
to
do
this
in
reporting
forms
&

instructions
booklet.

°
Justification:

 
Streamline
Form
R
 
it
is
unnecessary
to
collect
yes/
no
response.

 
Increase
public
access
to
this
additional
information
 
thereby
promoting
source
reduction
activities
of
TRI
facilities
11
Sections
to
modify
of
Form
R
°
Decrease
number
of
codes
in
"
On­
Site
Waste
Treatment
Method(
s)
Sequence"
(
7A.
1b)

°
Replace
specific
%
amount
with
range
codes
in
"
Waste
Treatment
Efficiency
Estimate"
(
7A.
1d)
with
range
codes
°
Simplify
"
On­
site
Energy
Recovery
Processes"
(
7B)
 
use
yes/
no
checkbox
°
Decrease
number
of
codes
in
"
On­
site
Recycling
Processes"

(
7C)
12
In
detail:

"
On­
site
Waste
Treatment
Method(
s)

Sequence"
(
Sec.
7A.
1b
)

°
Proposed
Action:

 
Reduce
existing
64
codes
with
6
treatment
"
M"
codes
from
Form
R,
Sec.
6.2.

°
Justification:

 
While
EPCRA
requires
the
reporting
of
waste
treatment
or
disposal
methods
used
for
each
waste
stream
(
7A.
1b),

EPA
does
not
believe
that
this
data
is
widely
used.

 
7A.
1b
codes
aren't
in
TRI
Explorer
(
in
Envirofacts)

 
Reduce
burden,
increase
uniformity
of
codes
13
In
detail:

"
Waste
Treatment
Efficiency
Estimate"

(
Sec.
7A.
1d)

°
Proposed
Action:

 
Allow
facilities
to
report
a
range
amount
instead
of
the
specific
current
percentage
amount
currently
required.

°
Justification:

 
While
EPCRA
requires
the
reporting
of
an
estimate
of
the
treatment
efficiency
achieved
by
the
methods
reported
in
7A.
1b,
EPA
this
information
doesn't
appear
to
be
widely
used.

 
Reduce
burden,
increase
uniformity
of
codes.
14
In
detail:

"
On­
site
Energy
Recovery
Processes"

(
Sec.
7B)

°
Proposed
Action:

 
Remove
the
three
existing
"
U"
codes;
instead,
provide
"
yes/
no"
checkbox
for
those
who
do
on­
site
energy
recovery.

°
Justification:

 
Reduce
burden,
simplify
and
increase
uniformity
of
codes.
15
In
detail:

"
On­
site
Recycling
Processes"
(
Sec.
7C)

°
Proposed
Action:

 
Replace
the
16
existing
recycling
codes
with
the
four
recycling
"
M"
codes
already
used
in
Sec.
6.2.

°
Justification:

 
Reduce
burden,
simplify
and
increase
uniformity
of
codes.
16
Clarify
Form
A
applicability
°
Proposed
Action:

 
Clarify
EPA
policy
regarding
use
of
Form
A
Certification
Statement
°
Justification:

 
Address
comments
from
facilities
concerned
about
Form
A
eligibility
17
Next
Steps
°
The
many
options
described
here
are
still
being
fleshed
out
with
other
EPA
offices.

°
Our
current
burden
savings
analysis
is
thus
based
on
the
rule's
overall
cost
and
burden
savings.

°
Once
we
know
which
options
will
be
included
in
the
proposal,
we
can
complete
our
burden
savings
analysis.
18
Burden
Reduction
Analytical
Results
°
Preliminary
estimates
for
cost
savings
from
the
proposal
are
up
to
$
5.6
million.

°
Preliminary
estimates
for
total
burden
savings
are
up
to
124,000
hours.
