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
included
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
final
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
10
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
and
Form
R
or
A
retrievals
from
Envirofacts.
TRI
data
and
facility
identification
data
including
locational
information
will
be
seamlessly
joined
for
access
by
all
data
users.

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
all
program
identification
and
permit
information
numbers
into
a
single
record,
including
those
for
the
RCRA,
NPDES
and
Underground
Injection
programs.
EPA
believes
that
FRS
contains
accurate
and
authoritative
facility
identification
records
that
are
subject
to
rigorous
verification
and
data
management
quality
assurance
procedures.
FRS
records
are
continuously
reviewed
and
enhanced
by
a
Regional
Data
Steward
network
and
active
State
partners.
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.

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:
Column
b
The
existing
64
waste
management
codes
available
for
this
data
element
will
be
replaced
with18
hazardous
waste
treatment
codes
(
H040­
129)
currently
used
in
EPA's
biennial
Hazardous
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
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
providing
consistency
between
two
EPA
reporting
systems
regarding
waste
treatment
methods
data.

Section
7A
On­
Site
Waste
Treatment
Methods
and
Efficiency:
Columns
c
and
e
By
removing
columns
c
and
e,
information
on
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
d
The
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.
As
the
ranges
are
defined
narrowly,
little
information
is
lost
(
i.
e.,
the
range
closely
approximates
the
actual
percentage.)
5­
3
Section
7C
On­
Site
Recycling
Processes
The
existing
16
recycling
codes
available
for
this
data
element
will
be
replaced
with
three
reclamation
and
recovery
management
codes
used
in
EPA's
biennial
Hazardous
Waste
Report.
Similar
to
the
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,
under
this
option,
the
same
codes
will
be
adopted
for
both
the
RCRA
hazardous
waste
and
TRI
reporting
programs.

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.
