Memorandum
From:
Carey
A.
Johnston,
P.
E.
USEPA/
OW/
OST
ph:
(
202)
566
1014
johnston.
carey@
epa.
gov
To:
Toxics
Release
Inventory
Reporting
Forms
Modification
Rule
Dockets
EPA
Docket
Numbers:
TRI­
2004­
0001
&
TRI­
2002­
0001
Thru:
Lynn
Zipf,
OW
Workgroup
Chair
Date:
June
9,
2005
Re:
Impact
of
Release
Inventory
Reporting
Forms
Modification
Rule
on
the
Effluent
Guidelines
Planning
Process
Under
Section
304(
b),
the
Clean
Water
Act
directs
EPA
to
develop
national
technology
based
regulations
placing
limits
on
the
pollutants
that
are
discharged
by
categories
of
industry
to
surface
waters
(
termed
"
effluent
guidelines")
or
to
sewage
treatment
plants
(
termed
"
pretreatment
standards").
Pretreatment
standards
ensure
that
pollutants
do
not
pass
through
or
interfere
with
the
safe
and
effective
operation
of
these
treatment
plants.
The
Act
also
directs
EPA
to
develop
national
technology
based
regulations
(
termed
"
new
source
performance
standards")
for
new
industrial
facilities.

Under
Section
304(
m),
the
Clean
Water
Act
also
requires
EPA
to
publish
a
biennial
plan
establishing
a
schedule
for
the
annual
review
and
revision
of
existing
effluent
guidelines
and
identify
industries
discharging
more
than
trivial
amounts
of
toxic
or
"
non­
conventional"
pollutants,
such
as
nutrients,
for
which
the
Agency
has
not
yet
promulgated
effluent
guidelines.
EPA
must
establish
a
schedule
for
completing
effluent
guidelines
for
these
`
newly
identified'
industries
within
three
years.

Integral
to
EPA's
review
of
existing
effluent
guidelines
and
the
development
of
the
biennial
plan
is
the
use
of
TRI
data.
EPA
compiles
data
taken
from
TRI,
the
adjusted
releases
from
publicly
owned
treatment
works
(
POTWs)
to
surface
waters
(
in
pounds),
the
associated
toxicity
of
the
pollutants
discharged
and
the
relationship
between
SIC
codes
and
effluent
guidelines
point
source
category
into
a
database.
EPA
used
this
database
for
priority
setting
in
its
annual
review
and
development
of
the
2004
Plan.

EPA's
Office
of
Water
reviewed
the
January
10,
2005
(
70
FR
1674)
and
March
7,
2005
(
70
FR
10919)
Federal
Register
notices
regarding
changes
to
TRI
reporting
requirements.
The
attached
table
summarizes
how
these
changes
will
affect
304(
m)
planning
and
304(
b)
review.
Proposed
Change
Projected
Effect
Removal
of
latitude/
longitude
reporting
requirement
Removal
of
permit
identification
information
reporting
requirement
We
do
not
anticipate
much
of
an
impact
as
we
will
use
the
FRS
database
to
pull
in
this
information.

Removal
of
Stormwater
Percentage
Reporting
Requirement
We
use
this
field
to
determine
the
percentage
of
toxic
chemical
release
that
is
from
stormwater.
This
data
field
is
often
left
blank.
Without
this
data
element,
we
will
not
have
a
way
to
preliminarily
identify
which
discharges
are
primarily
from
stormwater.
In
general,
we
call
facilities
(
in
the
case
of
large
discharges)
or
use
it
for
analysis
of
general
trends
in
an
industry
(
e.
g.,
wood
preserving).
Modifications
to
the
Reporting
Requirements
for
On­
Site
Waste
Treatment
Methods
and
Efficiency
We
use
this
field
to
determine
how
facilities
treat
their
wastewater.
This
data
field
is
often
left
blank.
Without
this
data
element,
we
will
not
have
a
way
to
preliminarily
identify
trends
in
wastewater
treatment
in
place.
Removal
of
Reporting
Data
Field
for
Optional
Submission
of
Additional
Information
No
effect.

Form
R
Technical
Modifications
(
where
to
find
form
and
some
form
language)
No
effect.

Dioxin
Reporting
Change:
1)
report
a
single
number
for
grams
TM­
17
and
another
for
grams
TEQ
(
no
congenerspecific
2)
report
g
TM­
17
for
all
17
congeners
and
g
TEQ
summed
for
compound
category,
and
3)
report
g
TM­
17
for
all
17
congeners
and
g
TEQ
for
all
congeners.
Any
of
the
three
proposed
changes
will
simplify
our
analysis,
because
dioxin
data
would
be
available
in
g
TM­
17
and
g­
TEQ.
The
data
would
likely
be
available
electronically
in
a
separate
table
and
this
would
simply
our
analyses.
Option
3
gives
the
most
information
on
individual
congeners.
