5­
1
CHAPTER
FIVE
BENEFITS
In
enacting
the
Emergency
Planning
and
Community
Right­
to­
Know
Act
(
EPCRA)
of
1986
and
the
Pollution
Prevention
Act
(
PPA)
of
1990,
Congress
recognized
the
significant
benefits
of
providing
information
on
the
presence,
releases,
and
waste
management
of
toxic
chemicals.
The
Toxic
Release
Inventory
(
TRI)
has
proven
to
be
one
of
the
most
powerful
forces
in
empowering
the
federal
government,
state
and
local
governments,
industry,
environmental
groups
and
the
general
public
to
fully
participate
in
an
informed
dialogue
about
the
environmental
impacts
of
toxic
chemicals
in
the
United
States.
TRI's
publicly
available
database
provides
quantitative
information
on
toxic
chemical
releases
and
other
waste
management
activities.
With
the
collection
of
this
information
starting
in
1987
came
the
ability
for
the
public,
government,
and
the
regulated
community
to
understand
the
magnitude
of
chemical
releases
in
the
United
States,
and
to
assess
the
need
to
reduce
the
releases
and
transfers
of
toxic
chemicals.
TRI
enables
all
interested
parties
to
establish
credible
baselines,
to
set
realistic
goals
for
environmental
progress,
and
to
measure
progress
in
meeting
these
goals
over
time.
As
such,
the
TRI
system
has
become
a
neutral
yardstick
by
which
progress
can
be
measured
by
all
stakeholders.

EPA
believes
that
the
changes
proposed
in
this
rulemaking
will
enhance
the
efficiency
and
effectiveness
of
the
TRI
program
while
continuing
to
provide
communities
with
the
same
high
level
of
significant
chemical
release
and
other
waste
management
information.
Certain
data,
however,
will
be
lost
under
the
proposed
rule
and
thus
negative
benefits
will
accrue
to
society.
Alternately,
on
the
cost
side,
industry
will
realize
a
cost
savings
due
to
reduced
reporting
burden.
The
likely
impact
of
modifying
the
13
data
elements
are
discussed
below:

Removal
of
Longitude/
Latitude
Reporting
Requirement
(
Part
I,
section
4.6)

EPA
believes
that
the
locational
data
available
in
FRS
will
provide
sufficient
latitude/
longitude
data
for
TRI
reporting
facilities.
Locational
information
will
be
readily
available
for
any
and
all
TRI
reports
and
applications,
such
as
TRI
Explorer,
Form
R
retrievals
from
Envirofacts.
TRI
data
and
facility
identification
data
including
locational
information
will
be
seamlessly
joined
for
access
all
data
users.
EPA
will
do
this
by
databasing
the
information
and
the
use
of
web
services.

Eliminating
the
latitude/
longitude
reporting
requirement
and
relying
on
other
geo­
spatial
means
to
supply
TRI
reporting
facilities'
locational
data
not
only
reduces
Form
R
and
Form
A
reporting
burden
for
TRI
reporters,
it
is
in
line
with
the
Agency's
goal
to
"
collect
once
and
use
many."
EPA
believes
that
this
approach
allows
the
Agency
to
provide
better
documented
data
that
will
be
more
consistently
collected,
quality
assured,
and
managed
than
the
current
practice.
5­
2
Removal
of
Reporting
Requirements
for
EPA
Program
Identity
Numbers
(
Part
I,
Sections
4.8,
4.9
and
4.10)

FRS
integrates
into
a
single
record
all
program
identification
and
permit
information
numbers,
including
those
for
the
RCRA,
NPDES
and
Underground
Injection
programs.
These
identification
numbers
will
still
be
available
in
FRS
and
can
be
accessed
at
anytime
through
the
EnviroFacts
Web
site:
www.
epa.
gov/
enviro/
frs.
Thus,
EPA
believes
it
is
possible
to
eliminate
the
reporting
requirements
on
Form
R
and
Form
A
for
Agency
program
identification
numbers
without
sacrificing
data
quality.

Removal
of
Reporting
Requirement
for
Determining
the
Percentage
of
the
Total
Quantity
of
Toxic
Chemicals
Contributed
by
Stormwater
(
Part
II,
Section
5.3
Column
C)

Removal
of
this
data
element
will
result
in
the
loss
of
information
on
the
percentage
of
the
total
quantity
of
listed
chemicals
that
are
contributed
by
stormwater.
Only
facilities
with
monitoring
data
on
the
amount
of
EPCRA
section
313
chemicals
that
are
released
to
stormwater
runoff
currently
report
this
information.

EPA
is
not
aware
of
anyone
who
uses
the
information
reported
in
this
data
element
and,
therefore,
believes
it
is
unnecessary
to
continue
collecting
the
information.
In
this
proposed
rulemaking,
however,
the
Agency
is
seeking
comment
on
whether
anyone
uses
this
information,
and
if
so,
why
and
how
it
is
used.

Modifications
to
the
Reporting
Requirement
for
On­
Site
Waste
Treatment
Methods
and
Efficiency
(
Part
II,
Section
7)

The
Agency
has
not
been
able
to
verify
that
information
regarding
facilities'
on­
site
waste
treatment,
energy
recovery
and
recycling
of
EPCRA
section
313
chemicals
is
routinely
used.
This
information
is
therefore
thought
to
be
of
little
utility
to
TRI
stakeholders.
The
Agency
believes
that
simplifying
this
section
will
result
in
reduced
reporting
burden
for
those
facilities
required
to
complete
this
portion
of
the
form.
Specific
modifications
are
as
follows:

Section
7A
On­
Site
Waste
Treatment
Methods
and
Efficiency:
Columns
a,
c
and
e
By
removing
columns
a,
c,
and
e,
information
on
the
general
waste
stream
type
for
each
waste
stream
treated
by
the
facility,
the
concentration
range
of
the
listed
chemical
as
it
enters
the
treatment
step,
and
an
indication
as
to
whether
the
waste
treatment
efficiency
reported
is
based
on
actual
operating
data
would
be
lost.

Section
7A
On­
Site
Waste
Treatment
Methods
and
Efficiency:
Column
b
The
existing
64
waste
management
codes
available
for
this
data
element
will
be
replaced
with
five
of
the
waste
management
codes
(
i.
e.,
M
codes)
used
for
reporting
in
Part
II,
section
6.2
of
the
Form
R
where
facilities
report
quantities
of
toxic
chemicals
transferred
to
off
site
locations.
EPA
believes
that
decreasing
the
number
codes
available
will
reduce
reporting
burden
for
two
5­
3
reasons.
First,
facilities
will
have
fewer
codes
to
consider
when
reporting
in
this
section.
Second,
the
codes
will
be
used
in
two
sections
of
the
form.
As
a
result,
facilities
will
no
longer
need
to
familiarize
themselves
with
two
different
sets
of
waste
management
codes
when
reporting
in
both
Part
II,
sections
6.2
and
7A.

Section
7A
On­
Site
Waste
Treatment
Methods
and
Efficiency:
Column
d
The
proposed
modification
of
this
data
element
would
shift
the
reported
data
from
an
actual
percentage
of
the
EPCRA
section
313
chemical
removed
from
the
waste
stream
to
a
waste
treatment
efficiency
range.
If
the
ranges
are
defined
narrowly,
little
information
is
lost
(
i.
e.,
the
range
closely
approximates
the
actual
percentage.)

Section
7B
On­
site
Energy
Recovery
Processes
The
proposed
modification
of
this
data
element
will
result
in
the
loss
of
information
specifying
the
type
of
on­
site
energy
recovery
device
used
to
combust
the
toxic
chemical;
specifically,
Industrial
Kiln,
Industrial
Furnace,
or
Industrial
Boiler.
Instead,
facilities
will
simply
indicate
whether
or
not
they
perform
energy
recovery
on
site.

Section
7C
On­
Site
Recycling
Processes
The
existing
16
recycling
codes
available
for
this
data
element
will
be
replaced
with
all
but
one
of
the
recycling
codes
used
in
Part
II,
section
6.2
of
the
Form
R.
Similar
to
the
proposed
modification
7A.
1b,
decreasing
the
number
codes
available
should
reduce
reporting
burden
for
two
reasons.
First,
facilities
will
have
fewer
codes
to
consider
when
reporting
in
this
section.
Second,
the
codes
will
be
used
in
two
sections
of
the
form.
As
a
result,
facilities
will
no
longer
need
to
familiarize
themselves
with
two
different
sets
of
waste
management
codes
when
reporting
in
both
Part
II,
sections
6.2
and
7C.

Removal
of
Reporting
Data
Field
for
Optional
Submission
of
Additional
Information
(
Part
II,
Section
8.11)

Although
an
indication
of
whether
or
not
additional
information
on
source
reduction,
recycling,
or
pollution
control
activities
at
the
facility
is
attached
to
Form
R
will
be
eliminated,
the
actual
information
will
not
be
lost.
EPA
will
provide
a
way
for
facilities
to
submit
this
information
electronically.
In
addition,
EPA
plans
to
make
this
information
available
on
EPA's
public
access
Web
site.
