2­
1
CHAPTER
TWO
METHODOLOGY
For
the
final
rule,
EPA
must
estimate
the
burden
and
cost
savings,
as
well
as
other
impacts
associated
with
the
burden
reduction
options
considered
in
Phase
1.
This
chapter
presents
the
methodologies
used
to
estimate:
1)
the
unit
time
facilities
would
save
under
Phase
1,
2)
the
unit
cost
savings
experienced
by
TRI
reporters,
and
3)
the
impacts
to
small
entities.
Total
reporting
burden
and
cost
savings
are
presented
in
Chapter
Three.
The
impacts
of
the
final
rule
are
discussed
in
Chapter
Four.

2.1
ESTIMATION
OF
UNIT
BURDEN
SAVINGS
The
final
Phase
1
rule
will
reduce
reporting
burden
by
removing
or
modifying
10
existing
Form
R
data
elements,
of
which
4
are
also
Form
A
elements.
To
estimate
the
burden
savings,
EPA
considered
the
time
saved
for
each
data
element.
Currently
approved
OMB
form
completion
estimates,
however,
reflect
the
total
time
required
by
facilities
to
complete
the
full
Form
R,
not
the
time
required
to
complete
the
individual
data
elements
that
make
up
the
form.
The
OMB­
approved
reporting
estimates
are
presented
in
Table
2­
1.

TABLE
2­
1
OMB­
APPROVED
TIME
ESTIMATES
FOR
FORM
R
CALCULATIONS/
FORM
COMPLETION
Activity
Management
Technical
Clerical
Total
Hours
First
year
Calculations
and
report
completion
­
non­
PBT
chemicals
11.32
24.11
1.62
37.04
Calculations
and
report
completion
­
PBT
chemicals
20.90
45.20
2.90
69.00
Subsequent
years
Calculations
and
report
completion
­
non­
PBT
chemicals
7.70
16.40
1.10
25.20
Calculations
and
report
completion
­
PBT
chemicals
14.30
30.80
2.00
47.10
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
row.
Source:
Rice,
Cody
Memo:
Terms
of
Clearance
for
TRI
ICR
Renewal.
Jan
20,
2004.
An
OMB­
approved
estimate
for
first
time
non­
PBT
filers
does
not
exist;
however,
the
RIA
for
the
original
Section
313
rulemaking
estimated
the
time
required
to
complete
a
report
in
the
first
year
to
be
147%
of
the
time
required
in
subsequent
years.
This
factor
was
applied
to
the
OMB­
approved
subsequent
year
non­
PBT
report
completion
times
to
calculate
the
first
year
non­
PBT
completion
times.
(
U.
S.
EPA
Regulatory
Impact
Analysis
in
Support
of
Final
Rulemaking
under
Section
313
of
Title
III
of
the
Superfund
Amendments
and
Reauthorization
Act
of
1986
(
1988).
2­
2
To
develop
data
element
specific
burden
estimates,
EPA
developed,
using
best
engineering
judgement,
what
it
believes
are
realistic
modeled
estimates
of
the
time
required
to
fill
out
each
data
element
on
the
Form
R.
These
modeled
estimates
are
based
on
the
activities
TRI
reporters
undertake
at
a
typical
facility
to
complete
each
data
element,
and
are
broken
into
time
estimates
for
technical,
managerial,
and
clerical
staff.
The
derivation
of
these
data
element
specific
burden
estimates
can
be
found
in
a
memo
from
Hilary
Eustace,
David
Cooper,
and
Susan
Day
of
Abt
Associates
Inc.
to
Paul
Borst,
US
EPA
entitled
TRI
Reporting
Burden
Estimates
(
July
16,
2004).
In
the
data
element
specific
reporting
burden
derivation,
modeled
data
element
burden
estimates
are
scaled­
up
to
the
current
OMB­
approved
burden
estimates
for
completing
the
full
Form
R.
Several
sets
of
burden
estimates
were
prepared,
including
times
for
both
electronic
and
paper
form
preparation
for
every
category
outlined
below:

°
Modeled
Burden
Estimates
for
Every
Form
R
Data
Element:
Modeled
burden
estimates
were
prepared
for
every
data
element
on
the
Form
R
based
on
best
engineering
judgement
for
both
management
and
technical
time.
Under
the
modeled
scenario,
which
assumes
electronic
reporting,
no
clerical
time
is
required
for
form
completion.
Separate
modeled
burden
estimates
were
prepared
for
PBT
and
non­
PBT
chemicals.
°
Modeled
Burden
Estimates
for
Total
Form
R
Completion:
The
modeled
data
element
burden
estimates
were
weighted
by
the
incidence
rate,
which
is
the
percentage
of
all
forms
containing
information
other
than
"
NA"
for
the
data
element,
in
order
to
reflect
the
fact
that
not
all
data
elements
will
be
completed
on
all
forms.
The
incidence
rate
was
calculated
using
the
frozen
RY
2002
TRI
data.
This
analysis
was
conducted
separately
for
PBT
and
non­
PBT
chemicals.
°
Scaled
Burden
Estimates
for
Every
Form
R
Data
Element
for
PBT
Chemicals:
The
current
OMB­
approved
time
estimate
for
calculations
and
form
completion
for
a
PBT
chemical
assumes
that
all
data
elements
are
completed;
therefore,
the
non­
incidence
weighted
modeled
burden
estimates
were
scaled­
up
to
the
current
OMB­
approved
time
estimate
for
form
completion
for
a
PBT
chemical.
EPA
recognizes
that
the
time
required
to
type
information
into
some
data
elements
on
Form
R
can
be
considered
"
static"
(
i.
e.,
the
data
element
only
requires
typing
or
a
quick
information
lookup)
and
unrelated
to
the
relative
degree
of
difficulty
in
determining
the
information
to
be
entered
into
the
field.
As
an
example,
the
time
required
to
record
the
company
name
is
dependent
only
on
the
time
required
to
type,
and
possibly
a
quick
information
lookup.
Scaling
such
data
elements
up
to
the
OMB­
approved
total
time
estimate
could
result
in
a
significant
over
estimate
of
the
actual
time
required.
For
this
reason,
data
elements
that
are
deemed
to
be
"
static"
were
not
scaled
to
the
OMB­
approved
time.
To
preserve
the
total
OMB­
approved
form
completion
time
during
scaling,
the
total
time
for
all
static
data
elements
was
subtracted
from
the
total
OMB­
approved
time,
and
the
non­
static
data
elements
were
then
scaled
to
the
remaining
OMB­
approved
time.
The
PBT
scaling
factor
for
technical
staff
is
calculated
by
dividing
the
total
OMB­
approved
time
for
PBT
chemicals
(
see
Table
2­
1)
less
the
total
modeled
time
for
all
static
elements,
by
the
total
modeled
time
for
PBT
2­
3
chemicals
less
the
total
modeled
time
for
all
static
elements,
as
follows:

(
OMB­
approved
time
­
total
static
time)/(
total
modeled
time
­
total
static
time)

The
total
modeled
PBT
technical
staff
burdens
for
static
and
non­
static
data
elements
are
taken
from
the
TRI
Reporting
Burden
Estimates
memo.
Separate
scaling
factors
are
computed
for
first
year
and
subsequent
year
reporting:

First
Year
Scaling
Factor:
(
,
.
.
)
/
(
,
.
.
)
.
2
712
00
86
25
1
770
32
86
25
156
 
 
=
Subsequent
Year
Scaling
Factor:
(
,
.
.
)
/
(
,
.
.
)
.
1848
00
2525
1
270
34
2525
146
 
 
=

The
following
bullets
describe
how
scaled
burden
estimates
were
derived
for
management,
technical,
and
clerical
staff
for
PBT
chemicals.

°
Management
 
This
analysis
assumes
that
the
time
required
for
management
to
review
a
completed
Form
R
data
element
is
proportional
to
the
technical
time
required
to
complete
that
data
element.
The
Phase
1
management
burden
estimate
for
PBT
chemicals,
therefore,
is
calculated
by
multiplying
the
scaled
technical
burden
for
that
data
element
by
the
ratio
of
the
total
OMB
management
burden
for
PBT
chemicals
to
the
total
OMB
technical
burden
for
PBT
chemicals
(
20.90
hr/
45.20
hr
=
0.46
first
year,
14.30
hr/
30.80
hr
=
0.46
subsequent
years).
This
method
preserves
OMB's
ratio
of
management
to
technical,
and
avoids
the
potentially
extreme
and
unrealistic
ratios
that
would
result
if
modeled
management
times
were
scaled
the
same
way
technical
times
were
scaled.
°
Technical
 
The
modeled
estimates
for
technical
burden,
except
those
determined
to
be
"
static"
(
see
above),
were
scaled
up
to
the
OMB­
approved
estimates
using
the
above
first
and
subsequent
year
scaling
factors.
°
Clerical
 
The
main
difference
between
electronic
and
paper
submission
for
Form
R
reporting
burden
is
the
clerical
time
needed
for
typing.
To
generate
a
paper
copy,
clerical
staff
would
take
the
information
prepared
by
the
technical
staff
and
type
it
onto
a
paper
copy
of
the
Form
R.
The
modeled
estimates
for
clerical
time
were
assumed
to
be
zero
because
it
was
assumed
that
technical
staff
complete
all
submissions
using
the
TRI­
ME
software.
The
Phase
1
burden
estimates,
however,
conservatively
assume
that
all
submissions
are
done
via
paper.
Unlike
management
and
technical
times,
the
clerical
time
for
paper
submissions
is
assumed
to
be
unrelated
to
the
relative
degree
of
difficulty
in
determining
the
information
to
be
entered
into
the
field.
For
this
reason,
clerical
time
was
not
determined
by
scaling
from
the
modeled
estimates
generated
for
technical
time.
Also,
while
it
may
not
take
the
exact
same
amount
of
time
to
line
up
a
paper
form
and
type
each
data
element,
there
is
no
reasonable
way
to
estimate
what
the
modeled
time
would
be
to
type
each
data
element.
Equally
distributing
the
OMB
estimate
for
clerical
time
across
each
data
element
was
determined
to
be
the
best
method.
The
PBT
clerical
burdens,
therefore,
are
calculated
as
the
total
OMB­
approved
clerical
time
for
PBT
chemicals,
divided
by
the
total
number
of
Form
R
data
elements
(
2.90
hr*
60(
min/
hr)/
148
data
elements
=
1.18
min
per
data
element
first
year,
2.00
2­
4
hr*
60(
min/
hr)/
148
data
elements
=
0.81
min
per
data
element
subsequent
years).
°
Scaled
Burden
Estimates
for
Every
Form
R
Data
Element
for
non­
PBT
Chemicals:
The
incidence
weighted
modeled
burden
estimates
for
non­
PBT
chemicals
were
scaled­
up
to
the
current
OMB­
approved
time
estimate
for
form
completion
for
a
Form
R
for
a
non­
PBT
chemical.
Data
elements
that
are
deemed
to
be
"
static"
(
see
discussion
above)
were
not
scaled
to
the
OMB­
approved
time.
To
preserve
the
total
OMB­
approved
time,
the
total
time
for
all
static
data
elements
was
subtracted
from
the
total
OMB­
approved
time,
and
the
non­
static
data
elements
were
then
scaled
to
the
remaining
OMB­
approved
time.
The
scaling
factor
for
the
technical
burden
is
calculated
by
dividing
the
total
OMBapproved
time
for
non­
PBT
chemicals
(
see
Table
2­
1)
less
the
total
modeled
time
for
all
static
elements,
by
the
total
modeled
time
for
non­
PBT
chemicals
less
the
total
modeled
time
for
all
static
elements,
as
follows:

(
OMB­
approved
time
 
total
static
time)/(
total
modeled
time
 
total
static
time)

The
total
modeled
non­
PBT
technical
staff
burdens
for
static
and
non­
static
data
elements
are
taken
from
the
TRI
Reporting
Burden
Estimates
memo
referenced
above.
Separate
scaling
factors
are
computed
for
first
year
and
subsequent
year
reporting:

First
Year
Scaling
Factor:
(
,
.
.
)
/
(
.
.
)
.
1
446
48
59
00
629
49
59
00
2
43
 
 
=
Subsequent
Year
Scaling
Factor:
(
.
.
)/(
.
.
)
.
984
00
1597
422
76
1597
2
38
 
 
=

The
following
bullets
describe
how
scaled
burden
estimates
were
derived
for
management,
technical,
and
clerical
staff,
for
non­
PBT
chemicals.

°
Management
 
The
Phase
1
management
burden
estimate
for
an
individual
data
element
is
calculated
by
multiplying
the
scaled
technical
time
for
that
data
element
by
the
ratio
of
the
total
OMB
non­
PBT
management
time
to
the
total
OMB
non­
PBT
technical
time
(
11.32
hr/
24.11
hr
=
0.47
first
year,
7.70
hr/
16.40
hr
=
0.47
subsequent
years).
°
Technical
 
The
modeled
estimates
for
technical
burden,
except
those
determined
to
be
"
static"
(
see
above)
were
scaled­
up
to
the
OMB­
approved
estimates,
using
the
first
and
subsequent
year
scaling
factors
described
above.
°
Clerical
 
Clerical
burden
times
were
calculated
as
the
total
OMB­
approved
clerical
time
for
non­
PBT
chemicals,
divided
by
the
total
number
of
Form
R
data
elements
(
1.62
hr*
60(
min/
hr)/
148
data
elements
=
0.66
min
per
data
element
first
year,
1.10
hr*
60(
min/
hr)/
148
data
elements
=
0.45
min
per
data
element
subsequent
years).

For
this
analysis
of
the
final
Phase
1
rule,
EPA
uses
the
scaled
data
element
specific
burden
estimates
to
estimate
the
burden
savings
associated
with
the
removal
or
modification
of
the
10
data
elements
covered
in
the
final
rule
(
see
Table
2­
2).
Burden
estimates
are
broken
out
for
PBT
and
non­
PBT
chemical
reports
to
reflect
the
OMB­
approved
estimates.
As
a
conservative
estimate,
all
facilities
are
assumed
to
file
via
a
paper
form.
2­
5
TABLE
2­
2
PHASE
1
REPORTING
REQUIREMENT
CHANGES
Change
Form
R
Section
remove
Part
I,
Section
4.6,
Latitude/
Longitude
(
Form
R
and
A)

remove
Part
I,
Section
4.8,
RCRA
ID
number
(
Form
R
and
A)

remove
Part
I,
Section
4.9,
NPDES
ID
number
(
Form
R
and
A)

remove
Part
I,
Section
4.10,
UIC
ID
number
(
Form
R
and
A)

modify
Part
II,
Section
7A.
1b,
Waste
Treatment
Method(
s)

remove
Part
II,
Section
7A.
1c,
Range
of
Influent
Concentration
modify
Part
II,
Section
7A.
1d,
Waste
Treatment
Efficiency
Estimate
remove
Part
II,
Section
7A.
1e,
Based
on
Operating
Data?

modify
Part
II,
Section
7C,
On­
Site
Recycling
remove
Part
II,
Section
8.11,
Is
additional
information
on
source
reduction,
recycling,
or
pollution
control
activities
included
with
this
report?

2.1.1
Phase
1
Unit
Burden
Data
Element
Estimates
This
section
presents
the
derivation
of
the
change
in
reporting
burden
associated
with
the
10
data
elements
addressed
in
Phase
1.
For
each
data
element,
the
modeled
reporting
burden
for
a
Form
R
is
first
presented
followed
by
a
discussion
of
how
the
scaled
reporting
burden
for
a
Form
R
is
derived.
First
and
subsequent
year
burden
estimates
(
in
minutes)
are
presented
for
management,
technical,
and
clerical
staff
in
parentheses
at
the
end
of
each
section.
The
first
four
data
elements,
Sections
4.6,
4.8,
4.9,
and
4.10,
would
also
apply
to
Form
A.
Burden
estimates
are
based
on
the
OMB­
approved
time
for
completing
paper
submissions.
The
total
change
in
burden
associated
with
all
10
data
elements
is
presented
in
Chapter
Three.

Section
4.6:
Latitude/
Longitude
Under
the
final
rule,
Section
4.6
would
be
removed
from
Form
R.
Therefore,
the
entire
reporting
burden
associated
with
this
data
element
would
be
saved.

Modeled
Reporting
Burden
Estimates
Management
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R
(
0.50
min
first
year,
0.50
min
subsequent
years).

Technical
The
modeled
burden
estimates
for
technical
staff
assume
that
staff
will
go
to
the
TRI
facility
siting
tool,
available
on
the
EPA
Web
site
(
http://
www.
epa.
gov/
tri/
report/
siting_
tool/
index.
html),
and
2­
6
type
in
their
facility
address.
The
tool
will
then
report
back
the
latitude
and
longitude.
The
technical
staff
will
then
record
this
information
in
Part
I,
Section
4.6
of
the
Form
R
(
4.5
min
first
year,
1.5
min
subsequent
years).

Clerical
The
modeled
burden
estimates
for
clerical
time
are
assumed
to
be
zero
because
it
is
assumed
that
all
forms
are
completed
by
technical
staff
using
the
TRI­
ME
software.

Scaled
Reporting
Burden
Estimates
PBT
Chemicals
Management
Scaled
management
burden
estimates
are
generated
by
multiplying
the
technical
reporting
burden
for
Section
4.6
(
see
below)
by
the
PBT
management
scaling
ratio
(
4.50
min*
0.46
=
2.08
min
first
year,
1.50
min*
0.46
=
0.70
min
subsequent
years).

Technical
The
OMB­
approved
PBT
burden
estimates
assume
that
all
facilities
fill
out
all
Form
R
data
elements;
therefore,
the
Section
4.6
reporting
burden
estimate
is
not
incidence
weighted
for
PBT
chemicals.
All
Form
R
filers
are
required
to
fill
out
Section
4.6,
and
the
time
required
for
technical
staff
to
look
up
and
type
the
latitude
and
longitude
coordinates
is
assumed
to
be
"
static."
The
burden
estimate
for
technical
staff,
therefore,
is
not
scaled
to
the
OMB­
approved
estimate
(
4.5
min
first
year,
1.5
min
subsequent
years).

Clerical
Clerical
times
are
estimated
by
dividing
the
currently
approved
OMB
clerical
burden
for
a
PBT
chemical
submission
by
the
total
number
of
data
elements
on
the
Form
R
(
2.90
hr
*
60(
min/
hr)/
148
data
elements
=
1.18
min
per
data
element
first
year,
2.00
hr*
60(
min/
yr)/
148
data
elements
=
0.81
min
per
data
element
subsequent
years).
Since
the
degrees,
minutes,
and
seconds
have
to
be
entered
separately
for
both
the
latitude
and
the
longitude,
the
time
for
typing
is
multiplied
by
six
(
7.05
min
first
year,
4.86
min
subsequent
years).

TABLE
2­
3
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
REMOVING
PART
I,
SECTION
4.6
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
2.08
0.70
Technical
4.50
1.50
Clerical
7.05
4.86
Total
13.63
7.06
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.
2­
7
Non­
PBT
Chemicals
Management
Scaled
management
burden
estimates
are
generated
by
multiplying
the
technical
reporting
burden
for
Section
4.6
(
see
below)
by
the
non­
PBT
management
scaling
ratio
(
4.50
min*
0.47
=
2.11
min
first
year,
1.50
min*
0.47
=
0.70
min
subsequent
years).

Technical
The
Section
4.6
incidence
rate
for
non­
PBT
chemicals
is
100%
because
Section
4.6
is
assumed
to
be
a
required
field
that
is
filled
out
by
all
facilities.
The
scaling
factor
is
not
applied
to
the
Section
4.6
incidence
weighted
reporting
burden
because
the
time
required
for
technical
staff
to
obtain
the
latitude
and
longitude
is
assumed
to
be
"
static"
(
4.5
min
first
year,
1.5
min
subsequent
years).

Clerical
The
clerical
time
needed
for
typing
is
derived
by
dividing
the
OMB­
approved
total
clerical
burden
for
non­
PBT
chemicals
by
the
total
number
of
data
elements
on
the
Form
R,
(
1.62
hr*
60(
min/
hr)/
148
data
elements
=
0.66
min
per
data
element
first
year,
1.10
hr*
60(
min/
hr)/
148
data
elements
=
0.45
min
per
data
element
subsequent
years).
Since
the
degrees,
minutes,
and
seconds
have
to
be
entered
separately
for
both
the
latitude
and
the
longitude,
the
time
for
typing
is
multiplied
by
six
(
3.93
min
first
year,
2.68
min
subsequent
years).

TABLE
2­
4
NON­
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
REMOVING
PART
I,
SECTION
4.6
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
2.11
0.70
Technical
4.50
1.50
Clerical
3.93
2.68
Total
10.55
4.88
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Section
4.8:
RCRA
ID
Number
Under
the
final
rule,
Section
4.8
would
be
removed
from
the
Form
R.
Therefore,
the
entire
reporting
burden
associated
with
this
data
element
would
be
saved.

Modeled
Reporting
Burden
Estimates
Management
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R
(
0.08
min
first
year,
0.08
min
subsequent
years).

Technical
Unless
hazardous
waste
manifests
are
stored
with
the
technical
staff
preparing
the
report,
they
will
need
to
obtain
this
information
from
elsewhere
in
the
company
by
making
a
phone
call,
checking
2­
8
files,
or
making
an
in­
person
information
request.
For
the
purposes
of
this
estimate,
it
is
assumed
that
technical
staff
will
need
to
obtain
this
information
from
elsewhere.
Once
obtained,
technical
staff
will
record
this
information
in
Part
I,
Section
4.8
of
the
Form
R
(
10.00
min
first
year,
0.25
min
subsequent
years).

Clerical
The
modeled
burden
estimates
for
clerical
time
are
assumed
to
be
zero
because
it
is
assumed
that
all
forms
are
completed
by
technical
staff
using
the
TRI­
ME
software.

Scaled
Reporting
Burden
Estimates
PBT
Chemicals
Management
Scaled
management
burden
estimates
are
generated
by
multiplying
the
technical
reporting
burden
for
Section
4.8
(
see
below)
by
the
PBT
management
scaling
ratio
(
10.00
min*
0.46
=
4.62
min
first
year,
0.25
min*
0.46
=
0.12
min
subsequent
years).

Technical
The
OMB­
approved
PBT
burden
estimates
assume
that
all
facilities
fill
out
all
Form
R
data
elements;
therefore,
the
Section
4.8
reporting
burden
estimate
is
not
incidence
weighted
for
PBT
chemicals.
The
time
required
for
technical
staff
to
obtain
the
RCRA
ID
is
assumed
to
be
"
static."
The
burden
estimate
for
technical
staff,
therefore,
is
not
scaled
to
the
OMB­
approved
estimate
(
10.00
min
first
year,
0.25
min
subsequent
years).

Clerical
Clerical
times
are
estimated
by
dividing
the
currently
approved
OMB
clerical
burden
for
a
PBT
chemical
submission
(
see
Table
2­
1)
by
the
total
number
of
data
elements
on
the
Form
R
(
2.90
hr*
60(
min/
hr)/
148
data
elements
=
1.18
min
per
data
element
first
year,
2.00
hr*
60(
min/
hr)/
148
=
0.81
min
per
data
element
subsequent
years).

TABLE
2­
5
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
REMOVING
PART
I,
SECTION
4.8
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
4.62
0.12
Technical
10.00
0.25
Clerical
1.18
0.81
Total
15.80
1.18
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.
2­
9
Non­
PBT
Chemicals
Management
Scaled
management
burden
estimates
are
generated
by
multiplying
the
technical
reporting
burden
for
Section
4.8
(
see
below)
by
the
non­
PBT
management
scaling
ratio
(
8.05
min*
0.47
=
3.78
min
first
year,
0.20
min*
0.47
=
0.09
min
subsequent
years).

Technical
The
Section
4.8
incidence
rate
for
non­
PBT
chemicals
is
80.47%
in
RY2002.
The
scaling
factor
is
not
applied
to
the
Section
4.8
incidence
weighted
reporting
burden
because
the
time
required
for
technical
staff
to
obtain
the
RCRA
ID
is
assumed
to
be
"
static"
(
10.00
min*
0.80
=
8.05
min
first
year,
0.25
min*
0.80
=
0.20
min
subsequent
years).

Clerical
The
clerical
time
needed
for
typing
is
derived
by
dividing
the
OMB­
approved
total
clerical
burden
for
non­
PBT
chemicals
(
see
Table
2­
1)
by
the
total
number
of
data
elements
on
the
Form
R
(
1.62
hr*
60(
min/
hr)/
148
data
elements
=
0.66
min
per
data
element
first
year,
1.10
hr*
60(
min/
hr)/
148
data
elements
=
0.45
min
per
data
element
subsequent
years).

TABLE
2­
6
NON­
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
REMOVING
PART
I,
SECTION
4.8
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
3.78
0.09
Technical
8.05
0.20
Clerical
0.66
0.45
Total
12.48
0.74
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Section
4.9:
NPDES
ID
Under
the
final
rule,
Section
4.9
would
be
removed
from
the
Form
R.
Therefore,
the
entire
reporting
burden
associated
with
this
data
element
would
be
saved.

Modeled
Reporting
Burden
Estimates
Management
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R
(
0.08
min
first
year,
0.08
min
subsequent
years).

Technical
Unless
NPDES
permit
documents
are
stored
with
the
technical
staff
preparing
the
report,
they
will
need
to
obtain
this
information
from
elsewhere
in
the
company
by
making
a
phone
call,
checking
files,
or
making
an
in­
person
information
request.
For
the
purposes
of
this
estimate,
it
is
assumed
that
technical
staff
will
need
to
obtain
this
information
from
elsewhere.
Once
obtained,
2­
10
technical
staff
will
record
this
information
in
Part
I,
Section
4.9
of
the
Form
R
(
10.0
min
first
year,
0.25
min
subsequent
years).

Clerical
The
modeled
burden
estimates
for
clerical
time
are
assumed
to
be
zero
because
it
is
assumed
that
all
forms
are
completed
by
technical
staff
using
the
TRI­
ME
software.

Scaled
Reporting
Burden
and
Cost
Estimates
PBT
Chemicals
Management
Scaled
management
burden
estimates
are
generated
by
multiplying
the
technical
reporting
burden
for
Section
4.9
(
see
below)
by
the
PBT
management
scaling
ratio
(
10.00
min*
0.46
=
4.62
min
first
year,
0.25
min*
0.46
=
0.12
min
subsequent
years).

Technical
The
OMB­
approved
PBT
burden
estimates
assume
that
all
facilities
fill
out
all
Form
R
data
elements;
therefore,
the
Section
4.9
reporting
burden
estimate
is
not
incidence
weighted
for
PBT
chemicals.
The
time
required
for
technical
staff
to
obtain
the
NPDES
ID
is
assumed
to
be
"
static."
The
burden
estimate
for
technical
staff,
therefore,
is
not
scaled
to
the
OMB­
approved
estimate
(
10.00
min
first
year,
0.25
min
subsequent
years).

Clerical
Clerical
times
are
estimated
by
dividing
the
currently
approved
OMB
clerical
burden
for
a
PBT
chemical
submission
(
see
Table
2­
1)
by
the
total
number
of
data
elements
on
the
Form
R
(
2.90
hr*
60(
min/
hr)/
148
data
elements
=
1.18
min
per
data
element
first
year,
2.00
hr*
60(
min/
hr)/
148
data
elements
=
0.81
min
per
data
element
subsequent
years).

TABLE
2­
7
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
REMOVING
PART
I,
SECTION
4.9
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
4.62
0.12
Technical
10.00
0.25
Clerical
1.18
0.81
Total
15.80
1.18
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Non­
PBT
Chemicals
Management
Scaled
management
burden
estimates
are
generated
by
multiplying
the
technical
reporting
burden
for
Section
4.9
(
see
below)
by
the
non­
PBT
management
scaling
ratio
(
4.60
min*
0.47
=
2.16
min
2­
11
first
year,
0.11
min*
0.47
=
0.05
min
subsequent
years).

Technical
The
Section
4.9
incidence
rate
for
non­
PBT
chemicals
is
45.97%
in
RY2002.
The
scaling
factor
is
not
applied
to
the
Section
4.9
incidence
weighted
reporting
burden
because
the
time
required
for
technical
staff
to
obtain
the
RCRA
ID
is
assumed
to
be
"
static"
(
10.00
min*
0.46
=
4.60
min
first
year,
0.25
min*
0.46
=
0.11
min
subsequent
years).

Clerical
The
clerical
time
needed
for
typing
is
derived
by
dividing
the
OMB­
approved
total
clerical
burden
for
non­
PBT
chemicals
(
see
Table
2­
1)
by
the
total
number
of
data
elements
on
the
Form
R
(
1.62
hr*
60(
min/
hr)/
148
=
0.66
min
first
year,
1.10
hr*
60(
min/
hr)/
148
=
0.45
min
subsequent
years).

TABLE
2­
8
NON­
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
REMOVING
PART
I,
SECTION
4.9
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
2.16
0.05
Technical
4.60
0.11
Clerical
0.66
0.45
Total
7.41
0.61
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Section
4.10:
Underground
Injection
Well
Code
ID
Under
the
final
rule,
Section
4.10
would
be
removed
from
the
Form
R.
Therefore,
the
entire
reporting
burden
associated
with
this
data
element
would
be
saved.

Modeled
Reporting
Burden
Estimates
Management
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R
(
0.08
min
first
year,
0.08
min
subsequent
years).

Technical
Unless
UIC
permit
documents
are
stored
with
the
technical
staff
preparing
the
report,
they
will
need
to
obtain
this
information
from
elsewhere
in
the
company
by
making
a
phone
call,
checking
files,
or
making
an
in­
person
information
request.
For
the
purposes
of
this
estimate,
it
is
assumed
that
technical
staff
will
need
to
obtain
this
information
from
elsewhere.
Once
obtained,
technical
staff
will
record
this
information
in
Part
I,
Section
4.10
of
the
Form
R
(
10.0
min
first
year,
0.25
min
subsequent
years).

Clerical
The
modeled
burden
estimates
for
clerical
time
are
assumed
to
be
zero
because
it
is
assumed
that
all
forms
are
completed
by
technical
staff
using
the
TRI­
ME
software.
2­
12
Scaled
Reporting
Burden
and
Cost
Estimates
PBT
Chemicals
Management
Scaled
management
burden
estimates
are
generated
by
multiplying
the
technical
reporting
burden
for
Section
4.9
(
see
below)
by
the
PBT
management
scaling
ratio
(
10.00
min*
0.46
=
4.62
min
first
year,
0.25
min*
0.46
=
0.12
min
subsequent
years).

Technical
The
OMB­
approved
PBT
burden
estimates
assume
that
all
facilities
fill
out
all
Form
R
data
elements;
therefore,
the
Section
4.10
reporting
burden
estimate
is
not
incidence
weighted
for
PBT
chemicals.
The
time
required
for
technical
staff
to
obtain
the
UIC
ID
is
assumed
to
be
"
static."
The
burden
estimate
for
technical
staff,
therefore,
is
not
scaled
to
the
OMB­
approved
estimate
(
10.00
min
first
year,
0.25
min
subsequent
years).

Clerical
Clerical
times
are
estimated
by
dividing
the
currently
approved
OMB
clerical
burden
for
a
PBT
chemical
submission
(
see
Table
2­
1)
by
the
total
number
of
data
elements
on
the
Form
R
(
2.90
hr*
60(
min/
hr)/
148
data
elements
=
1.18
min
per
data
element
first
year,
2.00
hr*
60(
min/
hr)/
148
data
elements
=
0.81
min
per
data
element
subsequent
years).

TABLE
2­
9
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
REMOVING
PART
I,
SECTION
4.10
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
4.62
0.12
Technical
10.00
0.25
Clerical
1.18
0.81
Total
15.80
1.18
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Non­
PBT
Chemicals
Management
Scaled
management
burden
estimates
are
generated
by
multiplying
the
technical
reporting
burden
for
Section
4.10
(
see
below)
by
the
non­
PBT
management
scaling
ratio
(
0.06
min*
0.47
=
0.03
min
first
year,
0.00
min*
0.47
=
0.00
min
subsequent
years).

Technical
The
Section
4.10
incidence
rate
for
non­
PBT
chemicals
is
0.59%
in
RY2002.
The
scaling
factor
is
not
applied
to
the
Section
4.10
incidence
weighted
reporting
burden
because
the
time
required
for
technical
staff
to
obtain
the
RCRA
ID
is
assumed
to
be
"
static"
(
10.00
min*
0.0059
=
0.06
min
first
year,
0.25
min*
0.0059
=
0.001
min
subsequent
years).
2­
13
Clerical
The
clerical
time
needed
for
typing
is
derived
by
dividing
the
OMB­
approved
total
clerical
burden
for
non­
PBT
chemicals
(
see
Table
2­
1)
by
the
total
number
of
data
elements
on
the
Form
R
(
1.62
hr*
60(
min/
hr)/
148
data
elements
=
0.66
min
per
data
element
first
year,
1.10
hr*
60(
min/
hr)/
148
data
elements
=
0.45
min
per
data
element
subsequent
years).

TABLE
2­
10
NON­
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
REMOVING
PART
I,
SECTION
4.10
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.03
0.00
Technical
0.06
0.00
Clerical
0.66
0.45
Total
0.74
0.45
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Section
7A.
b:
Range
of
Influent
Concentration
Under
the
final
rule,
column
b
of
Section
7A
would
be
simplified
by
reducing
the
number
of
codes
available
for
reporting.
Therefore,
the
reporting
burden
associated
with
this
data
element
would
be
reduced
but
not
eliminated.

Modeled
Reporting
Burden
Estimates
Management
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R
(
1.00
min
first
year,
0.83
min
subsequent
years).

Technical
Section
7A
requires
technical
staff
to
review
process
diagrams,
review
air
or
NPDES
permits,
or
talk
to
the
operations
staff
to
identify
any
on­
site
waste
treatment
activities.
Column
b
of
Section
7A
requires
technical
staff
to
identify
all
of
the
treatment
steps
a
waste
stream
passes
through
and
the
order
of
occurrence,
locate
the
appropriate
treatment
codes
representing
the
treatment
activity
in
the
TRI
Reporting
Forms
and
Instructions,
and
then
report
them
in
the
actual
order
of
occurrence
in
Part
II,
Section
7A.
1b
of
the
Form
R
(
20
min
first
year,
5
min
subsequent
years).

An
analysis
of
RY
2002
TRI
data
indicates
that
there
is
an
average
of
approximately
two
waste
streams
listed
under
on­
site
treatment
in
Section
7A
for
both
PBT
and
non­
PBT
chemicals.
Only
incremental
additional
time
would
be
needed
to
identify
waste
treatment
activity
steps
for
the
second
waste
stream
and
then
report
them
in
the
actual
order
of
occurrence
in
Part
II,
Section
7A.
2b
of
the
Form
R
because
document
review
and
discussions
with
operations
staff
were
already
conducted
to
identify
steps
for
the
first
waste
stream
(
5
min
first
year,
2
min
subsequent
years).

Under
the
final
rule,
the
64
codes
that
can
currently
be
reported
in
column
b
will
be
replaced
with
18
hazardous
waste
treatment
codes
(
H040­
129)
currently
used
in
EPA's
biennial
Hazardous
2­
14
Waste
Report
and
the
7
air
emissions
treatment
codes
from
the
original
list
of
waste
treatment
codes
for
Section
7A
column
b.
EPA
believes
that
decreasing
the
number
of
available
codes
will
reduce
reporting
burden
for
two
reasons:
First,
facilities
will
have
fewer
codes
to
consider
when
reporting
in
this
section.
Second,
under
this
option,
the
same
codes
will
be
adopted
for
both
the
RCRA
hazardous
waste
and
TRI
reporting
programs.

The
estimated
modeled
burden
for
filling
out
column
b
using
the
new
set
of
codes,
assuming
an
average
of
approximately
two
waste
streams
per
Form
R,
is
23.00
minutes
(
18
min
for
Section
7A.
1b
+
5
min
for
Section
7A.
2b)
the
first
year,
and
5.00
minutes
(
3
min
for
Section
7A.
1b
+
2
min
for
Section
7A.
2b)
in
subsequent
years.
The
modeled
burden
savings
associated
with
this
modification
is
the
difference
between
the
total
modeled
time
estimate
and
the
reduced
modeled
time
estimate
(
25.00
min
 
23.00
min
=
2.00
min
first
year,
7.00
min
 
5.00
min
=
2.00
min
subsequent
years).

Clerical
The
modeled
burden
estimates
for
clerical
time
are
assumed
to
be
zero
because
it
is
assumed
that
all
forms
are
completed
by
technical
staff
using
the
TRI­
ME
software.

Scaled
Reporting
Burden
Estimates
PBT
Chemicals
Management
Scaled
management
burden
is
calculated
by
multiplying
the
scaled
technical
reporting
burden
savings
for
Section
7A
(
see
below)
by
the
PBT
management
scaling
ratio
(
3.12
min*
0.46
=
1.44
min
first
year,
2.93
min*
0.46
=
1.36
min
subsequent
years).

Technical
The
OMB­
approved
PBT
burden
estimates
assume
that
all
facilities
fill
out
all
Form
R
data
elements;
therefore,
the
Section
7A.
b
reporting
burden
estimate
is
not
incidence
weighted
for
PBT
chemicals.
The
scaled
burden
savings
are
calculated
as
the
difference
between
the
scaled
reporting
burden
before
the
Phase
1
modification
and
the
scaled
reporting
burden
after
the
modification.
The
PBT
scaling
factors
(
first
year,
1.56;
subsequent
years,
1.46)
prior
to
the
Phase
1
modifications
are
presented
in
Section
2.1.

The
pre­
Phase
1
scaled
reporting
burden
is
the
product
of
the
modeled
burden
and
the
scaling
factor
for
PBT
chemicals
(
25.00
min*
1.56
=
39.98
min
first
year,
7.00
min*
1.46
=
10.25
min
subsequent
years).
The
post­
Phase
1
scaled
reporting
burden
is
the
product
of
the
modeled
burden
and
the
scaling
factor
for
PBT
chemicals
(
23.00
min*
1.56
=
35.86
min
first
year,
5.00
min*
1.46
=
7.32
min
subsequent
years).
The
scaled
reporting
burden
savings
for
technical
staff
is
calculated
as
the
difference
between
the
pre­
Phase
1
and
the
post­
Phase
1
scaled
reporting
burdens
(
38.98
min
 
35.86
min
=
3.12
min
first
year,
10.25
min
 
7.32
min
=
2.93
min
subsequent
years).

Clerical
2­
15
The
time
savings
for
clerical
staff
is
assumed
to
be
zero
because
column
b
is
being
modified
and
not
removed.

TABLE
2­
11
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
MODIFYING
PART
II,
SECTION
7A
COLUMN
B
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
1.44
1.36
Technical
3.12
2.93
Clerical
0.00
0.00
Total
4.56
4.29
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Non­
PBT
Chemicals
Management
Scaled
management
burden
savings
are
generated
by
multiplying
the
scaled
technical
reporting
burden
savings
(
see
below)
by
the
non­
PBT
management
scaling
ratio
(
2.36
min*
0.47
=
1.11
min
first
year,
2.31
min*
0.47
=
1.08
min
subsequent
years).

Technical
The
Section
7A.
b
incidence
rate
for
non­
PBT
chemicals
is
48.52%
in
RY2002.
The
scaled
burden
savings
are
calculated
as
the
difference
between
the
scaled
reporting
burden
before
the
Phase
1
modification
and
the
scaled
reporting
burden
after
the
Phase
1
modification.
The
non­
PBT
scaling
factors
(
first
year,
2.43;
subsequent
years,
2.38)
prior
to
the
Phase
1
modifications
are
presented
in
Section
2.1.

The
pre­
Phase
1
scaled
reporting
burden
is
the
product
of
the
incidence
weighted
modeled
burden
and
the
pre­
Phase
1
scaling
factor
for
non­
PBT
chemicals
(
25.00
min*
0.49*
2.43
=
29.50
min
first
year,
7.00
min*
0.49*
2.38
=
8.08
min
subsequent
years).
The
post­
Phase
1
scaled
reporting
burden
is
the
product
of
the
incidence
weighted
modeled
burden
and
the
post­
Phase
1
scaling
factor
for
non­
PBT
chemicals
(
23.00
min*
0.49*
2.43
=
27.14
min
first
year,
5.00
min*
0.49*
2.38
=
5.77
min
subsequent
years).
The
scaled
reporting
burden
savings
for
technical
staff
is
calculated
as
the
difference
between
the
pre­
Phase
1
and
the
post­
Phase
1
scaled
reporting
burdens
(
29.50
min
 
27.14
min
=
2.36
min
first
year,
8.08
min
 
5.77
min
=
2.31
min
subsequent
years).

Clerical
The
time
savings
for
clerical
staff
is
assumed
to
be
zero
because
column
b
is
being
modified
and
not
removed.

TABLE
2­
12
NON­
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
MODIFYING
PART
II,
SECTION
7A
COLUMN
B
2­
16
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
1.11
1.08
Technical
2.36
2.31
Clerical
0.00
0.00
Total
3.47
3.39
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Section
7A.
c:
Range
of
Influent
Concentration
Under
the
final
rule,
column
c
of
Section
7A
would
be
removed
from
the
Form
R.
Therefore,
the
entire
reporting
burden
associated
with
this
data
element
would
be
saved.
Note,
however,
that
most
of
the
steps
(
and
associated
time)
required
to
determine
influent
concentration
will
still
need
to
be
conducted
as
part
of
estimating
the
waste
treatment
efficiency
in
Section
7a.
d.
As
a
result,
burden
savings
in
Section
7A.
c
will
lead
to
an
increase
in
reporting
burden
in
Section
7A.
d
(
see
Section
7A.
d
for
more
discussion).

Modeled
Reporting
Burden
Estimates
Management
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R
(
2.00
min
first
year,
0.83
min
subsequent
years).

Technical
Section
7A
requires
technical
staff
to
review
process
diagrams,
review
air
or
NPDES
permits,
or
talk
to
the
operations
staff
to
identify
any
on­
site
waste
treatment
activities.
Column
c
of
Section
7A
requires
technical
staff
to
indicate
the
range
of
concentration
of
the
chemical
in
the
waste
stream
as
it
typically
enters
the
waste
treatment
step
or
sequence.
Staff
will
locate
and
review
monitoring
data
or
talk
with
operations
staff
to
determine
the
range
of
influent
concentration
(
30.00
min
first
year,
15.00
min
subsequent
years).

An
analysis
of
RY
2002
TRI
data
indicates
that
there
is
an
average
of
approximately
two
waste
streams
listed
under
on­
site
treatment
in
Section
7A
for
both
PBT
and
non­
PBT
chemicals.
Determining
the
range
of
the
influent
concentration
for
the
second
waste
stream
would
require
the
same
effort
as
for
the
first
waste
stream
because
technical
staff
would
be
reviewing
a
different
set
of
information,
such
as
different
laboratory
reports.
Therefore,
the
following
additional
time
is
needed
in
Part
II,
Section
7A.
2c
for
the
second
waste
stream
(
30.00min/
15.00min).

The
estimated
modeled
burden
for
filling
out
column
c,
assuming
an
average
of
approximately
two
waste
streams
per
Form
R,
is
60.00
minutes
(
30
min
for
Section
7A.
1c
+
30
min
for
Section
7A.
2c)
the
first
year,
and
30.00
minutes
(
15
min
for
Section
7A.
1c
+
15
min
for
Section
7A.
2c)
in
subsequent
years.

Clerical
The
modeled
burden
estimates
for
clerical
time
are
assumed
to
be
zero
because
it
is
assumed
that
all
forms
are
completed
by
technical
staff
using
the
TRI­
ME
software.
2­
17
Scaled
Reporting
Burden
and
Cost
Estimates
PBT
Chemicals
Management
Scaled
management
burden
estimates
are
generated
by
multiplying
the
technical
reporting
burden
for
Section
7A.
c
(
see
below)
by
the
PBT
management
scaling
ratio
(
93.55
min*
0.46
=
43.26
min
first
year,
43.92
min*
0.46
=
20.39
min
subsequent
years).

Technical
The
OMB­
approved
PBT
burden
estimates
assume
that
all
facilities
fill
out
all
Form
R
data
elements;
therefore,
the
Section
7A.
c
reporting
burden
estimate
is
not
incidence
weighted
for
PBT
chemicals.
The
scaled
reporting
burden
estimate
is
the
product
of
the
modeled
technical
burden
estimate
an
the
scaling
factor
between
the
total
OMB
time
and
the
total
modeled
time
for
PBT
chemicals
(
60
min*
1.56
=
93.55
min
first
year,
30
min*
1.46
=
43.92
min
subsequent
years).

Clerical
Clerical
times
are
estimated
by
dividing
the
currently
approved
OMB
clerical
burden
for
a
PBT
chemical
submission
(
see
Table
2­
1)
by
the
total
number
of
data
elements
on
the
Form
R
(
2.90
hr*
60(
min/
hr)/
148
data
elements
=
1.18
min
per
data
element
first
year,
2.00
hr*
60(
min/
hr)/
148
data
elements
=
0.81
min
per
data
element
subsequent
years).

TABLE
2­
13
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
REMOVING
PART
II,
SECTION
7A
COLUMN
C
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
43.26
20.39
Technical
93.55
43.92
Clerical
1.18
0.81
Total
137.98
65.12
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Non­
PBT
Chemicals
Management
Scaled
management
burden
estimates
are
generated
by
multiplying
the
technical
reporting
burden
for
Section
7A.
c
(
see
below)
by
the
non­
PBT
management
scaling
ratio
(
70.80
min*
0.47
=
33.24
min
first
year,
34.64
min*
0.47
=
16.26
min
subsequent
years).
2­
18
Technical
The
Section
7A.
c
incidence
rate
for
non­
PBT
chemicals
is
48.52%
in
RY2002.
The
scaled
reporting
burden
estimate
is
the
product
of
the
incidence
weighted
modeled
technical
burden
estimate
and
the
scaling
factor
between
the
total
OMB
time
and
the
total
modeled
time
for
non­
PBT
chemicals
(
60
min*
0.49*
2.43
=
70.80
min
first
year,
30
min*
0.49*
2.38
=
34.64
min
subsequent
years).

Clerical
The
clerical
time
needed
for
typing
is
derived
by
dividing
the
OMB­
approved
total
clerical
burden
for
non­
PBT
chemicals
(
see
Table
2­
1)
by
the
total
number
of
data
elements
on
the
Form
R
(
1.62
hr*
60(
min/
hr)/
148
data
elements
=
0.66
min
per
data
element
first
year,
1.10
hr*
60(
min/
hr)/
148
data
elements
=
0.45
min
per
data
element
subsequent
years).

TABLE
2­
14
NON­
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
REMOVING
PART
II,
SECTION
7A
COLUMN
C
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
33.24
16.26
Technical
70.80
34.64
Clerical
0.66
0.45
Total
104.70
51.35
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Section
7A.
d:
Range
of
Influent
Concentration
Under
the
final
rule,
the
waste
treatment
efficiency
would
be
reported
in
column
d
as
range
codes
rather
than
exact
percentage
estimates.
Facilities
using
analytical
data
(
i.
e.,
pre­
and
posttreatment
concentrations
as
determined
by
laboratory
analysis
or
monitoring)
to
estimate
the
waste
treatment
efficiency
will
still
need
to
conduct
the
same
calculations
with
this
data
to
determine
a
range
as
would
be
conducted
to
determine
an
exact
efficiency
percentage.
For
facilities
not
using
analytical
data
to
make
this
estimate,
the
time
needed
to
make
the
estimate
through
other
methods
such
as
talking
with
operations
staff,
or
reviewing
treatment
equipment
manuals,
may
be
slightly
reduced
with
range
reporting,
but
will
not
be
significantly
reduced.

Also,
as
mentioned
in
Section
7A.
c
above,
the
Phase
1
rule
includes
elimination
of
column
c,
range
of
influent
concentration.
This
influent
concentration
information
is
needed
to
make
the
waste
treatment
efficiency
estimate
for
column
d.
Because
the
final
Phase
1
rule
will
eliminate
column
c,
activities
conducted
to
determine
influent
concentration,
and
the
associated
burden,
would
be
conducted
in
support
of
column
d.
For
facilities
with
available
monitoring
data,
location
and
review
of
these
data
would
be
needed
both
to
determine
the
range
of
influent
concentration,
and
also
to
determine
the
waste
treatment
efficiency.
Since
use
of
monitoring
data
to
determine
the
treatment
efficiency
percentage
will
yield
a
point
result,
there
will
be
no
burden
savings
associated
with
use
of
range
codes
in
Section
7A.
d.
1
Note
that
a
general
burden
estimate
was
made
here
across
all
waste
stream
types,
all
sectors,
and
all
chemicals
for
a
typical
TRI
reporting
facility.
It
is
expected
that
there
could
be
significant
variation
in
associated
burden
with
reporting
these
on­
site
waste
treatment
data
elements
with
these
differing
factors.

2­
19
For
facilities
employing
estimation
methods
other
than
use
of
monitoring
data,
it
may
be
necessary
to
have
some
understanding
of
the
influent
concentration
in
order
to
determine
the
waste
treatment
efficiency.
Therefore,
some,
but
not
all,
of
the
burden
associated
with
7A.
c
is
shifted
to
7A.
d
when
7A.
c
is
eliminated.
In
addition,
however,
use
of
range
codes
for
7A.
d
will
require
less
precise
reporting,
and
there
will
be
some
associated
reduction
in
burden
for
this
data
element.

To
account
for
the
fact
that
some
facilities
may
use
monitoring
data
to
estimate
waste
treatment
efficiency
and
others
may
not,
a
weighted
average
reporting
burden
associated
with
the
modification
to
Section
7A.
d
is
estimated.

Modeled
Reporting
Burden
Estimates
Management
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R
(
1.00
min
first
year,
0.83
min
subsequent
years).

Technical
Section
7A
requires
technical
staff
to
review
process
diagrams,
review
air
or
NPDES
permits,
or
talk
to
the
operations
staff
to
identify
any
on­
site
waste
treatment
activities.
Column
d
of
Section
7A
requires
technical
staff
to
enter
the
percentage
of
the
chemical
removed
from
the
waste
stream
through
destruction,
biological
degradation,
chemical
conversion,
or
physical
removal
in
Part
II,
Section
7A.
1d
of
the
Form
R
(
15
min
first
year,
5
min
subsequent
years).

An
analysis
of
RY
2002
TRI
data
indicates
that
there
is
an
average
of
approximately
two
waste
streams
listed
under
on­
site
treatment
in
Section
7A
for
both
PBT
and
non­
PBT
chemicals.
Determining
the
treatment
efficiency
for
the
second
waste
stream
would
require
the
same
time
effort
as
for
the
first
waste
stream
because
technical
staff
would
be
reviewing
a
different
set
of
information,
such
as
different
equipment
manuals.
Therefore,
the
following
additional
time
is
needed
in
Part
II,
Section
7A.
2d
for
the
second
waste
stream
(
15.00min/
5.00min).

As
mentioned
above,
the
change
in
reporting
burden
for
Section
7A.
d
depends
on
whether
or
not
the
facility
uses
monitoring
data
to
estimated
waste
treatment
efficiency.
Under
the
final
rule,
some
or
all
of
the
burden
saved
by
not
reporting
Section
7A.
c
is
shifted
to
Section
7A.
d.
Best
professional
judgement
indicates
that
facilities
using
monitoring
data
would
need
to
spend
all
of
the
time
they
would
have
spent
calculating
the
influent
concentration
(
30
minutes
in
the
first
year
and
15
minutes
in
the
subsequent
years)
when
filling
out
Section
7A.
1d.
Best
professional
judgement
also
indicates
that
facilities
using
methods
other
than
monitoring
data
would
only
need
to
spend
an
additional
10
minutes
in
the
first
year
and
5
minutes
in
subsequent
years
when
filling
out
Section
7A.
1d.
1
Further,
any
burden
savings
attributable
to
use
of
range
codes
for
this
data
element
are
offset
by
the
shifted
burden
of
activities
previously
conducted
under
7A1.
c.
2
The
percentages
do
not
include
forms
that
left
Section
7A.
e
blank.

2­
20
EPA
used
the
data
reported
in
section
7A.
e
(
based
on
operating
data)
to
calculate
the
percentage
of
forms
that
use
monitoring
data
to
calculate
the
data
in
Section
7A.
d.
Based
on
data
from
RY
2001,
2002,
and
2003,
34%
of
forms
use
monitoring
data
while
the
remaining
66%
of
forms
use
methods
other
than
monitoring
data.
2
The
weighted
treatment
efficiency
burden
is
calculated
as
the
sum
of
the
burden
to
calculate
the
treatment
efficiency
and
the
weighted
burden
to
calculate
influent
concentration.
In
the
first
year,
the
weighted
reporting
burden
to
calculate
influent
concentration
for
facilities
that
use
monitoring
data
is
the
product
of
the
modeled
burden
and
the
percentage
of
facilities
that
use
monitoring
data
(
30
min*
2
waste
streams*
0.34
=
20.54
min).
Likewise,
the
reporting
burden
for
facilities
that
use
methods
other
than
monitoring
data
is
the
product
of
the
modeled
burden
and
the
percentage
of
facilities
that
do
not
use
monitoring
data
(
10
min*
2
waste
streams*
0.66
=
13.15
min).
The
weighted
burden
in
the
first
year
is
calculated
as
the
sum
of
the
burden
to
calculate
the
treatment
efficiency
and
the
weighted
burden
to
calculate
influent
concentration
(
30
min
+
20.54
min
+
13.15
min
=
63.69
min).

In
subsequent
years,
the
weighted
reporting
burden
to
calculate
influent
concentration
for
facilities
that
use
monitoring
data
is
the
product
of
the
modeled
burden
and
the
percentage
of
facilities
that
use
monitoring
data
(
15
min*
2
waste
streams*
0.34
=
10.27
min).
Likewise,
the
reporting
burden
for
facilities
that
use
methods
other
than
monitoring
data
is
the
product
of
the
modeled
burden
and
the
percentage
of
facilities
that
do
not
use
monitoring
data
(
5
min*
2
waste
streams*
0.66
=
6.58
min).
The
weighted
burden
in
subsequent
years
is
calculated
as
the
sum
of
the
burden
to
calculate
the
treatment
efficiency
and
the
weighted
burden
to
calculate
influent
concentration
(
10
min
+
10.27
min
+
6.58
min
=
26.85
min).

The
estimated
burden
for
filling
out
Section
7A.
d
if
Section
7A.
c
is
eliminated
is
63.69
minutes
in
the
first
year,
and
26.85
minutes
in
subsequent
years.
The
modeled
burden
savings
associated
with
this
modification
is
the
difference
between
the
total
modeled
time
estimate
and
the
modified
modeled
time
estimate
(
30.00
min
 
63.39
min
=
­
33.39
min
first
year,
10.00
min
 
26.85
min
=
­
16.85
min
subsequent
years).

Clerical
The
modeled
burden
estimates
for
clerical
time
are
assumed
to
be
zero
because
it
is
assumed
that
all
forms
are
completed
by
technical
staff
using
the
TRI­
ME
software.

Scaled
Reporting
Burden
Estimates
PBT
Chemicals
Management
Scaled
management
burden
is
calculated
by
multiplying
the
scaled
technical
reporting
burden
savings
for
Section
7A.
d
(
see
below)
by
the
PBT
management
scaling
ratio
(­
52.54
min*
0.46
=
­
24.29
min
first
year,
­
24.66
min*
0.46
=
­
11.45
min
subsequent
years).
2­
21
Technical
The
OMB­
approved
PBT
burden
estimates
assume
that
all
facilities
fill
out
all
Form
R
data
elements;
therefore,
the
Section
7A.
d
reporting
burden
estimate
is
not
incidence
weighted
for
PBT
chemicals.
The
scaled
burden
savings
are
calculated
as
the
difference
between
the
scaled
reporting
burden
before
the
Phase
1
modification
and
the
scaled
reporting
burden
after
the
Phase
1
modification.
The
PBT
scaling
factors
(
first
year,
1.56;
subsequent
years,
1.46)
prior
to
the
Phase
1
modifications
are
presented
in
Section
2.1.

The
pre­
Phase
1
scaled
reporting
burden
is
the
product
of
the
modeled
burden
and
the
scaling
factor
for
PBT
chemicals
(
30
min*
1.56
=
46.78
min
first
year,
10
min*
1.46
=
14.64
min
subsequent
years).
The
post­
Phase
1
scaled
reporting
burden
is
the
product
of
the
modeled
burden
and
the
scaling
factor
for
PBT
chemicals
(
63.69
min*
1.56
=
99.31
min
first
year,
26.85
min*
1.46
=
39.30
min
subsequent
years).
The
scaled
reporting
burden
savings
for
technical
staff
is
calculated
as
the
difference
between
the
pre­
Phase
1
and
the
post­
Phase
1
scaled
reporting
burdens
(
46.78
min
 
99.31
min
=
­
52.54
min
first
year,
14.64
min
 
39.30
min
=
­
24.66
min
subsequent
years).

Clerical
The
time
savings
for
clerical
staff
is
assumed
to
be
zero
because
column
d
is
being
modified
and
not
removed.

TABLE
2­
15
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
MODIFYING
PART
II,
SECTION
7A
COLUMN
D
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
(
24.29)
(
11.45)

Technical
(
52.54)
(
24.66)

Clerical
0.00
0.00
Total
(
76.83)
(
36.11)

Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Non­
PBT
Chemicals
Management
Scaled
management
burden
savings
are
generated
by
multiplying
the
scaled
technical
reporting
burden
savings
(
see
below)
by
the
non­
PBT
management
scaling
ratio
(­
39.76
min*
0.47
=
­
18.67
min
first
year,
­
19.45
min*
0.47
=
­
9.13
min
subsequent
years).

Technical
The
Section
7A.
d
incidence
rate
for
non­
PBT
chemicals
is
48.52%
in
RY2002.
The
scaled
burden
savings
are
calculated
as
the
difference
between
the
scaled
reporting
burden
before
the
Phase
1
modification
and
the
scaled
reporting
burden
after
the
Phase
1
modification.
The
non­
PBT
scaling
factors
(
first
year,
2.43;
subsequent
years,
2.38)
prior
to
the
Phase
1
modifications
are
presented
in
Section
2.1.
2­
22
The
pre­
Phase
1
scaled
reporting
burden
is
the
product
of
the
incidence
weighted
modeled
burden
and
the
scaling
factor
for
non­
PBT
chemicals
(
30
min*
0.49*
2.43
=
35.40
min
first
year,
10
min*
0.49*
2.38
=
11.55
min
subsequent
years).
The
post­
Phase
1
scaled
reporting
burden
is
the
product
of
the
incidence
weighted
modeled
burden
and
the
scaling
factor
for
non­
PBT
chemicals(
63.69
min*
0.49*
2.43
=
75.16
min
first
year,
26.85
min*
0.49*
2.38
=
31.00
min
subsequent
years).
The
scaled
reporting
burden
savings
for
technical
staff
is
calculated
as
the
difference
between
the
pre­
Phase
1
and
the
post­
Phase
1
scaled
reporting
burdens
(
35.40
min
 
75.16
min
=
­
39.76
min
first
year,
11.55
min
 
31.00
min
=
­
19.45
min
subsequent
years).

Clerical
The
time
savings
for
clerical
staff
is
assumed
to
be
zero
because
column
d
is
being
modified
and
not
removed.

TABLE
2­
16
NON­
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
MODIFYING
PART
II,
SECTION
7A
COLUMN
D
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
(
18.67)
(
9.13)

Technical
(
39.76)
(
19.45)

Clerical
0.00
0.00
Total
(
58.43)
(
28.59)

Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Section
7A.
e:
Range
of
Influent
Concentration
Under
the
final
rule,
column
e
of
Section
7A
would
be
removed
from
the
Form
R.
Therefore,
the
entire
reporting
burden
associated
with
this
data
element
would
be
saved.

Modeled
Reporting
Burden
Estimates
Management
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R
(
0.08
min
first
year,
0.08
min
subsequent
years).

Technical
Section
7A
requires
technical
staff
to
review
process
diagrams,
review
air
or
NPDES
permits,
or
talk
to
the
operations
staff
to
identify
any
on­
site
waste
treatment
activities.
Section
7A.
1e
requires
technical
staff
to
report
whether
the
waste
treatment
efficiency
estimate
was
calculated
using
monitoring
data
by
checking
yes
or
no
in
Part
II,
Section
7A.
1e
of
the
Form
R
(
0.08
min
first
year,
0.08
min
subsequent
years).

An
analysis
of
RY
2002
TRI
data
indicates
that
there
is
an
average
of
approximately
two
waste
streams
listed
under
on­
site
treatment
in
Section
7A
for
both
PBT
and
non­
PBT
chemicals.
Reporting
whether
the
waste
treatment
efficiency
estimate
for
the
second
waste
stream
was
calculated
using
monitoring
data
would
require
the
same
time
effort
as
for
the
first
waste
stream.
2­
23
Therefore,
the
total
time
needed
in
Part
II,
Section
7A.
2e
is
doubled
(
0.17
min
first
year,
0.17
min
subsequent
years).

Clerical
The
modeled
burden
estimates
for
clerical
time
are
assumed
to
be
zero
because
it
is
assumed
that
all
forms
are
completed
by
technical
staff
using
the
TRI­
ME
software.

Scaled
Reporting
Burden
Estimates
PBT
Chemicals
Management
Scaled
management
burden
estimates
are
generated
by
multiplying
the
scaled
technical
reporting
burden
(
see
below)
by
the
PBT
management
scaling
ratio
(
0.17
min*
0.46
=
0.08
min
first
year,
0.17
min*
0.46
=
0.08
min
subsequent
years).

Technical
The
OMB­
approved
PBT
burden
estimates
assume
that
all
facilities
fill
out
all
Form
R
data
elements;
therefore,
the
Section
7A.
e
reporting
burden
estimate
is
not
incidence
weighted
for
PBT
chemicals.
The
time
required
for
technical
staff
to
fill
out
Section
7A.
e
is
assumed
to
be
"
static".
The
burden
estimate
for
technical
staff,
therefore,
is
not
scaled
to
the
total
OMB­
approved
time
(
0.17
min
first
year,
0.17
min
subsequent
years).

Clerical
Clerical
times
are
estimated
by
dividing
the
currently
approved
OMB
clerical
burden
for
a
PBT
chemical
submission
(
see
Table
2­
1)
by
the
total
number
of
data
elements
on
the
Form
R
(
2.90
hr*
60(
min/
hr)/
148
data
elements
=
1.18
min
per
data
element
first
year,
2.00
hr*
60(
min/
hr)/
148
data
elements
=
0.81
min
per
data
element
subsequent
years).

TABLE
2­
17
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
REMOVING
PART
II,
SECTION
7A
COLUMN
E
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.17
0.17
Clerical
1.18
0.81
Total
1.42
1.05
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.
2­
24
Non­
PBT
Chemicals
Management
Scaled
management
burden
estimates
are
generated
by
multiplying
the
scaled
technical
reporting
burden
(
see
below)
by
the
non­
PBT
management
scaling
factor
(
0.08
min*
0.47
=
0.04
min
first
year,
0.08
min*
0.47
=
0.04
min
subsequent
years).

Technical
The
Section
7A.
e
incidence
rate
for
non­
PBT
chemicals
is
48.52%
in
RY2002.
The
time
required
for
technical
staff
to
fill
out
Section
7A.
e
is
assumed
to
be
"
static".
The
burden
estimate
for
technical
staff,
therefore,
is
not
scaled
to
the
total
OMB­
approved
time
(
0.17
min*
0.49
=
0.08
min
first
year,
0.17
min*
0.49
=
0.08
min
subsequent
years).

Clerical
The
clerical
time
needed
for
typing
is
derived
by
dividing
the
OMB­
approved
total
clerical
burden
for
non­
PBT
chemicals
(
see
Table
2­
1)
by
the
total
number
of
data
elements
on
the
Form
R
(
1.62
hr*
60(
min/
hr)/
148
data
elements
=
0.66
min
per
data
elements
first
year,
1.10
hr*
60(
min/
hr)/
148
data
elements
=
0.45
min
per
data
element
subsequent
years).

TABLE
2­
18
NON­
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
REMOVING
PART
II,
SECTION
7ACOLUMN
E
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.04
0.04
Technical
0.08
0.08
Clerical
0.66
0.45
Total
0.77
0.56
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.
2­
25
Section
7C:
On­
Site
Recycling
Under
the
final
rule,
Section
7C
would
be
simplified
by
reducing
the
number
of
codes
available
for
reporting.
Therefore,
the
reporting
burden
associated
with
this
data
element
would
be
reduced
but
not
eliminated.

Modeled
Reporting
Burden
Estimates
Management
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R
(
1.00
min
first
year,
0.83
min
subsequent
years).

Technical
It
is
assumed
that
technical
staff
either
review
process
flow
diagrams
or
talk
to
operations
staff
in
order
to
identify
any
on­
site
recycling
activities.
For
each
waste
stream
that
is
undergoing
treatment
for
on­
site
recycling,
technical
staff
locate
the
appropriate
code
for
the
activity
in
the
TRI
Reporting
Forms
and
Instructions.
The
codes
are
reported
in
descending
order
by
quantity
of
waste
recycled
in
Part
II,
Section
7C
of
the
Form
R
(
38.00
min
first
year,
27.00
min
subsequent
years)

Under
the
final
rule,
the
16
codes
that
can
currently
be
reported
in
Section
7C
would
be
replaced
with
three
reclamation
and
recovery
management
codes
used
in
EPA's
biennial
Hazardous
Waste
Report.
EPA
believes
that
decreasing
the
number
of
codes
available
will
reduce
reporting
burden
for
two
reasons:
First,
facilities
will
have
fewer
codes
to
consider
when
reporting
in
this
section.
Second,
under
this
option,
the
same
codes
will
be
adopted
for
both
the
RCRA
hazardous
waste
and
TRI
reporting
programs.

The
estimated
burden
for
filling
out
Section
7C
using
the
new
set
of
codes
is
37.00
minutes
the
first
year,
and
26.00
minutes
in
subsequent
years.
The
modeled
burden
savings
associated
with
this
modification
is
the
difference
between
the
total
modeled
time
estimate
and
the
reduced
modeled
time
estimate
(
38.00
min
 
37.00
min
=
1.00
min
first
year,
27.00
min
 
26.00
min
=
1.00
min
subsequent
years).

Clerical
The
modeled
burden
estimates
for
clerical
time
are
assumed
to
be
zero
because
it
is
assumed
that
all
forms
are
completed
by
technical
staff
using
the
TRI­
ME
software.

Scaled
Reporting
Burden
Estimates
PBT
Chemicals
Management
Scaled
management
burden
is
calculated
by
multiplying
the
scaled
technical
reporting
burden
savings
(
see
below)
by
the
PBT
management
scaling
ratio
(
1.56
min*
0.46
=
0.72
min
first
year,
1.46
min*
0.46
=
0.68
min
subsequent
years).
2­
26
Technical
The
OMB­
approved
PBT
burden
estimates
assume
that
all
facilities
fill
out
all
Form
R
data
elements;
therefore,
the
Section
7C
reporting
burden
estimate
is
not
incidence
weighted
for
PBT
chemicals.

The
scaled
burden
savings
are
calculated
as
the
difference
between
the
scaled
reporting
burden
before
the
Phase
1
modification
and
the
scaled
reporting
burden
after
the
Phase
1
modification.
The
PBT
scaling
factors
(
first
year,
1.56;
subsequent
years,
1.46)
prior
to
the
Phase
1
modifications
are
presented
in
Section
2.1.
The
pre­
Phase
1
scaled
reporting
burden
is
the
product
of
the
modeled
burden
and
the
scaling
factor
for
PBT
chemicals
(
38.00
min*
1.56
=
59.25
min
first
year,
27.00
min*
1.46
=
39.53
min
subsequent
years).

The
post­
Phase
1
scaled
reporting
burden
is
the
product
of
the
modeled
burden
and
the
scaling
factor
for
PBT
chemicals
(
37.00
min*
1.56
=
57.69
min
first
year,
26.00
min*
1.46
=
38.06
min
subsequent
years).
The
scaled
reporting
burden
savings
for
technical
staff
is
calculated
as
the
difference
between
the
pre­
Phase
1
and
the
post­
Phase
1
scaled
reporting
burdens
(
59.25
min
 
57.69
min
=
1.56
min
first
year,
39.53
min
 
38.06
min
=
1.46
min
subsequent
years).

Clerical
The
time
savings
for
clerical
staff
is
assumed
to
be
zero
because
Section
7C
is
being
modified
and
not
removed.

TABLE
2­
19
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
MODIFYING
PART
II,
SECTION
7C
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.72
0.68
Technical
1.56
1.46
Clerical
0.00
0.00
Total
2.28
2.14
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Non­
PBT
Chemicals
Management
Scaled
management
burden
savings
are
generated
by
multiplying
the
scaled
technical
reporting
burden
savings
(
see
below)
by
the
non­
PBT
management
scaling
ratio
(
0.24
min*
0.47
=
0.11
min
first
year,
0.23
min*
0.47
=
0.11
min
subsequent
years).

Technical
The
Section
7C
incidence
rate
for
non­
PBT
chemicals
is
9.82%
in
RY2002.
The
scaled
burden
savings
are
calculated
as
the
difference
between
the
scaled
reporting
burden
before
the
Phase
1
modification
and
the
scaled
reporting
burden
after
the
Phase
1
modification.
The
non­
PBT
scaling
factors
(
first
year,
2.43;
subsequent
years,
2.38)
prior
to
the
Phase
1
modifications
are
2­
27
presented
in
Section
2.1.
The
pre­
Phase
1
scaled
reporting
burden
is
the
product
of
the
incidence
weighted
modeled
burden
and
the
scaling
factor
for
non­
PBT
chemicals
(
38.00
min*
0.098*
2.43
=
9.08
min
first
year,
27.00
min*
0.098*
2.38
=
6.31
min
subsequent
years).

The
post­
Phase
1
scaled
reporting
burden
is
the
product
of
the
incidence
weighted
modeled
burden
and
the
scaling
factor
for
non­
PBT
chemicals
(
37.00
min*
0.098*
2.43
=
8.84
min
first
year,
26.00
min*
0.098*
2.38
=
6.08
min
subsequent
years).
The
scaled
reporting
burden
savings
for
technical
staff
is
calculated
as
the
difference
between
the
pre­
Phase
1
and
the
post­
Phase
1
scaled
reporting
burdens
(
9.08
min
 
8.84
min
=
0.24
min
first
year,
6.31min
 
6.08
min
=
0.23
min
subsequent
years).

Clerical
The
time
savings
for
clerical
staff
is
assumed
to
be
zero
because
Section
7C
is
being
modified
and
not
removed.

TABLE
2­
20
NON­
PBT
REPORTING
BURDEN
SAVINGS
ASSOCIATED
WITH
MODIFYING
PART
II,
SECTION
7C
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.11
0.11
Technical
0.24
0.23
Clerical
0.00
0.00
Total
0.35
0.34
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Section
8.11:
Is
Additional
Information
on
Source
Reduction,
Recycling
or
Pollution
Control
Activities
Included
with
this
Report?
Under
the
final
rule,
Section
8.11
would
be
removed
from
the
Form
R;
however,
provision
of
additional
information
on
source
reduction,
recycling,
or
pollution
control
activities
is
optional.
For
the
purposes
of
this
analysis,
therefore,
there
is
no
management,
technical,
nor
clerical
burden
savings
attributed
to
the
elimination
of
this
element
of
the
Form
R.

2.1.2
Summary
of
Unit
Burden
Savings
Table
2­
21
summarizes
the
unit
burden
savings
associated
with
the
final
Phase
1
rule.
2­
28
TABLE
2­
21
SUMMARY
OF
UNIT
BURDEN
SAVINGS
ASSOCIATED
WITH
THE
PHASE
1
RULE
First
year
savings
per
form
(
min)
Subsequent
year
savings
per
form
(
min)
Management
Technical
Clerical
Total
Management
Technical
Clerical
Total
Part
I,
Section
4.6,
Latitude/
Longitude
(
Form
R
and
A)

PBT
2.08
4.50
7.05
13.63
0.70
1.50
4.86
7.06
Non­
PBT
2.11
4.50
3.93
10.55
0.70
1.50
2.68
4.88
Part
I,
Section
4.8,
RCRA
ID
number
(
Form
R
and
A)

PBT
4.62
10.00
1.18
15.80
0.12
0.25
0.81
1.18
Non­
PBT
3.78
8.05
0.66
12.48
0.09
0.20
0.45
0.74
Part
I,
Section
4.9,
NPDES
ID
number
(
Form
R
and
A)

PBT
4.62
10.00
1.18
15.80
0.12
0.25
0.81
1.18
Non­
PBT
2.16
4.60
0.66
7.41
0.05
0.11
0.45
0.61
Part
I,
Section
4.10,
UIC
ID
number
(
Form
R
and
A)

PBT
4.62
10.00
1.18
15.80
0.12
0.25
0.81
1.18
Non­
PBT
0.03
0.06
0.66
0.74
0.00
0.00
0.45
0.45
Part
II,
Section
7A.
1b,
Waste
Treatment
Method(
s)

PBT
1.44
3.12
0.00
4.56
1.36
2.93
0.00
4.29
Non­
PBT
1.11
2.36
0.00
3.47
1.08
2.31
0.00
3.39
Part
II,
Section
7A.
1c,
Range
of
Influent
Concentration
PBT
43.26
93.55
1.18
137.98
20.39
43.92
0.81
65.12
Non­
PBT
33.24
70.80
0.66
104.70
16.26
34.64
0.45
51.35
Part
II,
Section
7A.
1d,
Waste
Treatment
Efficiency
Estimate
PBT
(
24.29)
(
52.54)
0.00
(
76.83)
(
11.45)
(
24.66)
0.00
(
36.11)

Non­
PBT
(
18.67)
(
39.76)
0.00
(
58.43)
(
9.13)
(
19.45)
0.00
(
28.59)

Part
II,
Section
7A.
1e,
Based
on
Operating
Data?

PBT
0.08
0.17
1.18
1.42
0.08
0.17
0.81
1.05
Non­
PBT
0.04
0.08
0.66
0.77
0.04
0.08
0.45
0.56
Part
II,
Section
7C,
On­
Site
Recycling
PBT
0.72
1.56
0.00
2.28
0.68
1.46
0.00
2.14
Non­
PBT
0.11
0.24
0.00
0.35
0.11
0.23
0.00
0.34
Part
II,
Section
8.11,
Is
additional
information
on
source
reduction,
recycling,
or
pollution
control
activities
included
with
this
report?

PBT
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Non­
PBT
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Total
Unit
Burden
Savings
Associated
with
the
Phase
1
Rule
(
Form
A)

Non­
PBT
8.08
17.20
5.90
31.18
0.85
1.82
4.01
6.68
Total
Unit
Burden
Savings
Associated
with
the
Phase
1
Rule
(
Form
R)
PBT
37.16
80.36
12.93
130.45
12.10
26.06
8.92
47.08
Non­
PBT
23.91
50.92
7.21
82.04
9.22
19.63
4.91
33.75
3
Employer
Costs
for
Employee
Compensation,
Private
industry
workers,
Goods­
producing
industries,
white­
collar
occupations,
as
published
by
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics.
The
December
2004
values
for
these
series
are
listed
in
Table
11
of
the
Employer
Costs
for
Employee
Compensation
Summary,
released
March
16,
2005.

4
U.
S.
Environmental
Protection
Agency,
EPA
Air
Pollution
Control
Cost
Manual,
Sixth
Edition,
EPA­
452­
02­
001,
January
2002,
pg.
2­
34.

2­
29
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.

Total
burden
savings
are
presented
in
Chapter
Three.

2.2
ESTIMATION
OF
UNIT
COST
SAVINGS
To
estimate
the
unit
cost
savings
associated
with
the
final
rule,
the
typical
number
of
hours
of
managerial,
technical,
and
clerical
labor
saved
due
to
the
modification
or
elimination
of
each
data
element
is
combined
with
typical
labor
rates.
The
unit
cost
savings
associated
with
each
data
element
is
calculated
for
the
first
year
of
compliance,
when
some
learning
must
take
place;
and
for
subsequent
years,
when
less
time
is
needed
because
facilities
are
more
familiar
with
the
tasks.

Each
cost
savings
estimate
is
made
up
of
two
components:
the
unit
time
estimates
(
i.
e.,
number
of
labor
hours
saved
by
each
type
of
personnel),
and
the
hourly
wage
rates
associated
with
each
level
of
personnel.
Hourly
wage
rates
are
divided
into
three
categories:
managerial,
technical,
and
clerical.
Updated
2004
hourly
wage
rates,
including
fringe
benefits
and
overhead,
were
developed
by
EPA
for
each
of
these
categories.
Average
wage
data
for
these
categories
was
taken
from
the
Employer
Costs
for
Employee
Compensation
(
ECEC)
report
from
the
Bureau
of
Labor
Statistics
(
BLS)
for
all
goods­
producing,
private
industries.
3
The
managerial
labor
rate
is
defined
as
the
average
hourly
wages
and
salaries
for
the
"
Management,
business,
and
financial"
occupational
category.
The
technical
labor
rate
is
defined
as
the
average
hourly
wages
and
salaries
for
the
"
Professional
and
related"
occupational
category.
The
clerical
labor
rate
is
defined
as
the
average
hourly
wages
and
salaries
for
the
"
Office
and
administrative
support"
occupational
category.

The
additional
cost
of
benefits,
such
as
paid
leave
and
insurance,
is
also
derived
from
the
ECEC
data.
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
(
e.
g.,
0.29/
0.71
=
0.4085).

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
(
e.
g.,
$
33.61/
hr
x
[
1
+
(
0.4085
+
0.17)]
=
$
53.05/
hr).
The
total
loading
for
indirect
costs
is
within
the
range
of
50
to
70
percent
suggested
in
EPA
guidance.
4
The
results
of
this
method
are
shown
in
Table
2­
22.
2­
30
TABLE
2­
22
DERIVATION
OF
LOADED
HOURLY
RATES
FOR
TRI
FORM
COMPLETION
Labor
Category
2004
Average
Wages
2004
Benefits
and
Overhead
Loading
Factor
2004
Loaded
Hourly
Rate
Managerial
$
33.61
1.578
$
53.05
Technical
$
28.52
1.571
$
44.79
Clerical
$
14.70
1.607
$
23.62
Unit
cost
savings
associated
with
each
data
element
are
presented
below
in
Table
2­
23.
2­
31
TABLE
2­
23
SUMMARY
OF
UNIT
COST
SAVINGS
ASSOCIATED
WITH
THE
PHASE
1
RULE
First
year
savings
per
form
(
2004
Dollars)
Subsequent
year
savings
per
form
(
2004
Dollars)
Management
Technical
Clerical
Total1
Management
Technical
Clerical
Total1
Part
I,
Section
4.6,
Latitude/
Longitude
(
Form
R
and
A)
PBT
$
1.84
$
3.36
$
2.78
$
7.98
$
0.60
$
1.08
$
1.87
$
3.55
Non­
PBT
$
1.87
$
3.36
$
1.55
$
6.78
$
0.62
$
1.12
$
1.05
$
2.80
Part
I,
Section
4.8,
RCRA
ID
number
(
Form
R
and
A)
PBT
$
4.09
$
7.47
$
0.46
$
12.02
$
0.10
$
0.19
$
0.32
$
0.61
Non­
PBT
$
3.34
$
6.01
$
0.26
$
9.61
$
0.08
$
0.15
$
0.18
$
0.41
Part
I,
Section
4.9,
NPDES
ID
number
(
Form
R
and
A)
PBT
$
4.09
$
7.47
$
0.46
$
12.02
$
0.10
$
0.19
$
0.32
$
0.61
Non­
PBT
$
1.91
$
3.43
$
0.26
$
5.60
$
0.05
$
0.09
$
0.18
$
0.31
Part
I,
Section
4.10,
UIC
ID
number
(
Form
R
and
A)
PBT
$
4.09
$
7.47
$
0.46
$
12.02
$
0.10
$
0.19
$
0.32
$
0.61
Non­
PBT
$
0.02
$
0.04
$
0.26
$
0.33
$
0.00
$
0.00
$
0.18
$
0.18
Part
II,
Section
7A.
1b,
Waste
Treatment
Method(
s)
PBT
$
1.27
$
2.33
$
0.00
$
3.60
$
1.20
$
2.19
$
0.00
$
3.39
Non­
PBT
$
0.98
$
1.76
$
0.00
$
2.74
$
0.96
$
1.72
$
0.00
$
2.68
Part
II,
Section
7A.
1c,
Range
of
Influent
Concentration
PBT
$
38.25
$
69.84
$
0.46
$
108.54
$
18.03
$
32.79
$
0.32
$
51.13
Non­
PBT
$
29.39
$
52.85
$
0.26
$
82.50
$
14.38
$
25.86
$
0.18
$
40.41
Part
II,
Section
7A.
1d,
Waste
Treatment
Efficiency
Estimate
PBT
($
21.48)
($
39.22)
$
0.00
($
60.70)
($
10.12)
($
18.41)
$
0.00
($
28.54)

Non­
PBT
($
16.51)
($
29.68)
$
0.00
($
46.19)
($
8.08)
($
14.52)
$
0.00
($
22.60)
Part
II,
Section
7A.
1e,
Based
on
Operating
Data?
PBT
$
0.07
$
0.12
$
0.46
$
0.66
$
0.07
$
0.12
$
0.32
$
0.51
Non­
PBT
$
0.03
$
0.06
$
0.26
$
0.35
$
0.03
$
0.06
$
0.18
$
0.27
Part
II,
Section
7C,
On­
Site
Recycling
PBT
$
0.64
$
1.16
$
0.00
$
1.80
$
0.60
$
1.09
$
0.00
$
1.69
Non­
PBT
$
0.10
$
0.18
$
0.00
$
0.28
$
0.10
$
0.17
$
0.00
$
0.27
Part
II,
Section
8.11,
Is
additional
information
on
source
reduction,
recycling,
or
pollution
control
activities
included
with
this
report?
PBT
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Non­
PBT
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Unit
Cost
Savings
Associated
with
the
Phase
1
Rule
(
Form
A)
Non­
PBT
$
7.14
$
12.84
$
2.32
$
22.31
$
0.75
$
1.36
$
1.58
$
3.69
Total
Unit
Cost
Savings
Associated
with
the
Phase
1
Rule
(
Form
R)
PBT
$
32.85
$
59.99
$
5.09
$
97.93
$
10.70
$
19.46
$
3.51
$
33.67
Non­
PBT
$
21.14
$
38.01
$
2.84
$
61.99
$
8.15
$
14.65
$
1.93
$
24.73
Note:
Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
column.
1
Cost
per
chemical
report,
based
on
loaded
hourly
wage
rates
of
$
51.66,
$
43.13,
and
$
23.05
for
managerial,
technical,
and
clerical
labor,
respectively.
5
Available
at
http://
www.
census.
gov/
epcd/
ec97sic/
E97SUSB.
HTM/.

6
Value
of
shipments
are
reported
by
Census
instead
of
revenues
for
the
manufacturing
and
mining
industries.

7
Available
at
http://
www.
bls.
gov/
ppi/.

8
Available
at
http://
www.
bls.
gov/
ppi/
ppistonagg.
htm.

2­
32
Total
cost
savings
are
presented
in
Chapter
Three.

2.3
ESTIMATION
OF
IMPACTS
Because
the
final
rule
creates
cost
savings
rather
than
imposing
costs
on
the
regulated
universe,
a
SBREFA
analysis
is
not
required.
However,
to
characterize
the
impacts
of
Phase
1
on
TRI
filers,
EPA
calculated
average
annual
revenues
for
the
three
largest
TRI
industries
(
in
terms
of
reported
releases)
and
compared
them
to
the
estimated
cost
savings
per
form.
The
estimated
cost
savings
per
form
is
calculated
for
the
first
year
of
compliance,
when
some
learning
must
take
place;
and
for
subsequent
years,
when
less
time
is
needed
because
facilities
are
more
familiar
with
the
tasks.

The
impact
savings
calculation
was
made
for
three
industries
with
the
highest
releases:
Metal
Mining
(
SIC
10),
Chemicals
and
Allied
Products
(
SIC
28),
and
Primary
Metal
Industries
(
SIC
33).
EPA
used
the
1997
Economic
Census
data
which
are
the
latest
available
data
to
calculate
average
annual
revenues
in
those
industries.
5
Average
annual
revenues
by
industry
in
1997
were
calculated
by
dividing
total
value
of
shipments
by
total
number
of
establishments
for
each
2­
digit
SIC
code.
6
EPA
had
to
inflate
the
average
revenues
calculated
based
on
the
1997
Census
data
to
2004
dollars
to
compare
them
to
the
estimated
cost
savings
per
form.
The
revenues
were
inflated
from
1997
dollars
to
2004
dollars
using
the
Bureau
of
Labor
Statistics'
(
BLS)
Producer
Price
Index
(
PPI)
by
industry.
7
Since
PPI
data
is
not
available
for
2004
by
SIC
Code,
EPA
used
the
BLS
concordance
between
SIC
Codes
and
NAICS
Codes
to
determine
which
indices
should
be
used
(
see
Table
2­
24
below).
8
TABLE
2­
24
CONCORDANCE
BETWEEN
SIC
CODE
AND
NAICS
CODE
PRODUCER
PRICE
INDEX
DATA
SIC
Code
SIC
Code
Description
NAICS
Code
NAICS
Code
Description
10
Metal
Mining
2122
Metal
Ore
Mining
28
Chemicals
and
Allied
Products
325
Chemical
Manufacturing
33
Primary
Metal
Industries
331
Primary
Metal
Manufacturing
2­
33
The
results
of
the
comparison
of
average
cost
savings
to
average
revenues
for
the
three
industries
are
presented
in
Chapter
Four.
