2­
1
September
19,
2005
CHAPTER
TWO
METHODOLOGY
For
the
proposed
Phase
2
burden
reduction
rule,
EPA
must
estimate
the
burden
and
cost
savings,
as
well
as
other
impacts
associated
with
the
options
considered.
This
chapter
presents
the
methodologies
used
to
estimate:
1)
the
unit
time
and
cost
savings
experienced
by
TRI
reporters
as
a
result
of
the
proposed
rule,
2)
the
number
of
facilities
and
forms
that
would
be
able
to
take
advantage
of
each
option
separately
and
combined,
and
3)
the
impacts
on
small
entities.
Total
reporting
burden
and
cost
savings
are
presented
in
Chapter
Three.
The
benefits
of
the
proposed
rule
are
discussed
in
Chapter
Four.
The
impacts
of
the
proposed
rule
on
reporting
are
discussed
in
Chapter
5
As
explained
in
more
detail
in
Chapter
One,
EPA
is
proposing
two
options
that
it
believes
may
reduce
reporting
burden
for
TRI
facilities.
The
New
Eligibility
for
Form
A:
PBT
Chemicals
Option
allows
a
facility
reporting
on
PBT
chemicals
(
except
for
dioxin
and
dioxin­
like
compounds)
with
no
disposal
or
other
releases
to
use
Form
A,
provided
they
meet
the
1,000,000
pound
alternate
reporting
threshold
and
have
no
more
than
500
pounds
in
Sections
8.2
through
8.8
and
do
not
include
any
releases
or
disposal
in
their
Section
8.8
quantities.
The
Expanded
Eligibility
for
Form
A:
Non­
PBT
Chemicals
Option
extends
the
existing
Form
A
eligibility
criteria
and
allows
a
facility
reporting
on
Non­
PBT
chemicals
with
an
annual
reportable
amount
(
sections
8.1
 
8.7)
of
5,000
lbs
or
less
to
use
Form
A,
provided
they
meet
the
1,000,000
pound
alternate
reporting
threshold.

Some
facilities
may
qualify
for
both
options,
however,
for
different
chemicals.
Although
these
options
could
be
proposed
separately,
EPA
is
combining
the
options
in
the
proposed
rule.

Industry
burden
and
cost
savings
were
calculated
using
the
following
four­
step
procedure:

Step
1:
Estimate
the
typical
total
number
of
hours
of
managerial,
technical,
and
clerical
labor
needed
to
complete
each
task
for
each
type
of
form.

Step
2:
Calculate
the
hours
saved
by
each
labor
category
for
each
task
due
to
filing
a
less
burdensome
form.
Based
on
typical
labor
rates,
calculate
the
average
unit
savings
in
the
first
year
of
compliance
as
staff
becomes
familiar
with
the
regulations
and
in
subsequent
years,
when
less
time
is
needed
because
staff
is
more
familiar
with
the
regulations.

Step
3:
Estimate
the
universe
of
affected
forms
and
facilities
that
would
qualify
for
each
of
the
burden
reduction
options.

Step
4:
For
each
task,
multiply
the
unit
savings
by
the
number
of
facilities
and/
or
forms,
and
then
sum
the
results
to
calculate
the
total
industry
savings.
2­
2
September
19,
2005
2.1
UNIT
BURDEN
SAVINGS
ESTIMATES
The
proposed
rule
will
result
in
burden
savings
by
reducing
reporting
requirements
for
forms
that
meet
certain
criteria.
The
tasks
associated
with
TRI
reporting
under
the
proposed
rule
include:


Report
Completion:
Facilities
must
gather
data
and
perform
calculations
to
provide
the
information
required
on
Form
R
or
Form
A.


Mailing
and
Recordkeeping:
Facilities
must
maintain
recordkeeping
systems
and
mail
their
reports
to
EPA
and
the
State.

To
estimate
the
burden
savings,
EPA
calculated
the
unit
burden
savings
as
the
difference
between
the
facility's
current
activity
(
i.
e.,
filing
a
Form
R)
and
the
post­
regulation
activity
(
i.
e.,
filing
a
Form
A).

2.1.1
Form
R
and
Form
A
Unit
Burden
Estimates
The
current
burden
estimates
for
form
completion
estimates,
which
are
approved
by
the
Office
of
Management
and
Budget
(
OMB),
reflect
the
total
time
required
by
facilities
to
complete
either
a
Form
R
or
a
Form
A.
The
OMB­
approved
reporting
burden
estimates
are
presented
in
Table
2­
1.
The
estimate
of
total
burden
savings
due
to
the
proposed
rule
is
developed
by
combining
the
estimated
unit
burden
savings
under
each
option
with
the
number
of
potentially
affected
forms
under
each
option.
Unit
burden
savings
are
calculated
by
subtracting
the
unit
reporting
burden
associated
with
filling
out
a
Form
A
from
the
unit
reporting
burden
associated
with
filing
a
Form
R.
In
the
analysis
associated
with
the
New
Eligibility
for
Form
A:
PBT
Chemicals
Option,
Form
A
calculations
and
report
completion
burden
is
assumed
to
be
17.6
hours
for
non­
PBT
chemicals
and
31.6
hours
for
PBT
chemicals.
The
17.6
hours
is
based
on
the
current
OMB
approved
burden
estimate.
Since
there
is
no
approved
estimate
for
using
Form
A
for
PBT
chemicals,
the
17.6
hours
was
adjusted
proportionately
to
the
difference
between
the
OMB
approved
burden
estimates
for
Form
R
calculations
and
report
completion
for
non­
PBT
chemical
and
PBT
chemicals
(
i.
e.,
25.2
hours
and
47.1
hours
respectively).
This
resulted
in
a
64%
adjustment
of
the
current
17.6
hours
for
Form
A
for
non­
PBT
chemicals
to
31.6
hours
for
Form
A
for
PBT
chemicals.

2.1.2
Hourly
Labor
Rate
Estimate
Each
cost
savings
estimate
has
two
components:
the
unit
time
savings
estimates
(
i.
e.,
number
of
labor
hours
saved
by
each
type
of
personnel),
and
the
hourly
wage
rate
of
each
level
of
personnel.
There
are
three
categories
of
hourly
wage
rates:
managerial,
technical,
and
clerical.
EPA
developed
updated
2004
hourly
wage
rates,
including
fringe
benefits
and
overhead,
for
each
of
these
categories.
Average
wage
data
for
these
categories
were
taken
from
the
Employer
Costs
for
Employee
Compensation
(
ECEC)
report
by
the
Bureau
of
Labor
Statistics
(
BLS)
for
all
goods­
producing,
private
industries.
3
The
managerial
labor
rate
is
defined
as
the
average
hourly
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.
2­
3
September
19,
2005
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
2.

4
U.
S.
Environmental
Protection
Agency,
EPA
Air
Pollution
Control
Cost
Manual,
Sixth
Edition,
EPA­
452­
02­
001,
January
2002,
pg.
2­
34.
2­
4
September
19,
2005
TABLE
2­
1
OMB­
APPROVED
FORM
R
AND
FORM
A
UNIT
BURDEN
ESTIMATES
Unit
Time
Estimates
(
hours)
(
per
form)

Activity
Managerial
Technical
Clerical
Total
Time
Form
R
Subsequent
Years
Calculations
and
Report
Completion
­
PBT
Chemicals
14.3
30.8
2
47.1
Calculations
and
Report
Completion
­
Non­
PBT
Chemicals
7.7
16.4
1.1
25.2
Recordkeeping/
Submission
0
4
1
5
Form
A
Subsequent
Years
Calculations
and
Report
Completion
­
PBT
Chemicals
11.2
18.9
1.5
31.6
Recordkeeping/
Submission
 
PBT
Chemicals
0
2.4
0.6
3
Calculations
and
Report
Completion
 
Non­
PBT
Chemicals
6.05
10.7
0.85
17.6
Recordkeeping/
Submission
 
Non­
PBT
Chemicals
0
2.4
0.6
3
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.

EPA,
2000
Form
A
Information
Collection
Request.
2­
5
September
19,
2005
TABLE
2­
2
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
Source:
Employer
Costs
for
Employee
Compensation
(
ECEC)
report
by
the
Bureau
of
Labor
Statistics
(
BLS).

Total
cost
savings
are
presented
in
Chapter
Three.

2.1.3
Summary
of
Unit
Burden
Savings
As
discussed
in
Section
2.1,
the
unit
burden
savings
are
calculated
as
the
difference
between
the
facility's
current
activity
(
i.
e.,
filing
a
Form
R)
and
the
post­
regulation
activity
(
i.
e.,
filing
a
Form
A).
Because
facilities
are
already
familiar
with
Form
A,
there
will
be
no
difference
between
the
average
burden
they
incur
in
the
first
year
of
the
proposed
rule
and
all
subsequent
years
of
the
rule.
Furthermore,
since
these
facilities
are
already
reporting
to
TRI,
they
are
not
expected
to
incur
any
rule
familiarization
burden.
The
unit
burden
savings
in
the
two
options
differs
because
the
Form
R
and
Form
A
form
completion
estimates
are
higher
for
PBT
chemicals
than
Non­
PBT
chemicals.
Table
2­
3
summarizes
the
unit
burden
savings
associated
with
the
proposed
options.

TABLE
2­
3
UNIT
BURDEN
AND
COST
SAVINGS
FOR
ACTIVITIES
PERFORMED
BY
INDUSTRY
Unit
Time
Estimates
(
hours)
(
per
form)
Activity
Managerial
Technical
Clerical
Total
Unit
Cost
(
2004
Dollars)

Average
Annual
Burden
and
Cost
Savings
in
the
First
and
Subsequent
Years
Form
Completion
 
Non­
PBT
Chemicals
1.7
5.7
0.3
7.6
$
348.74
Form
Completion
 
PBT
Chemicals
3.1
11.9
0.5
15.5
$
709.27
Recordkeeping/
Mailing
0.0
1.6
0.4
2.0
$
81.11
Note:
Because
facilities
are
already
familiar
with
Form
A,
there
is
no
rule
familiarization
cost.

Due
to
rounding,
the
total
may
not
equal
the
sum
of
the
row.

2.2
ESTIMATES
OF
FORMS
AND
FACILITIES
BY
OPTION
Because
the
proposed
rule
primarily
affects
facilities
that
are
already
reporting
to
TRI,
it
was
possible
to
query
the
most
current
frozen
TRI
data
(
RY2002
at
the
time
of
this
analysis)
to
determine
the
number
of
forms
and
facilities
meeting
the
eligibility
criteria
for
the
two
proposed
2­
6
September
19,
2005
options.
6
For
the
New
Eligibility
for
Form
A:
PBT
Chemicals
Option,
EPA
estimated
that
2,703
forms
filed
by
2,064
facilities
would
qualify
for
this
option.
7
For
the
Expanded
Eligibility
for
Form
A:
Non­
PBT
Chemicals
Option,
EPA
estimated
that
12,201
forms
filed
by
6,461
facilities
would
qualify
for
this
option.

Table
2­
4
summarizes
the
number
of
affected
facilities
and
forms
when
the
options
are
analyzed
separately
and
combined.

TABLE
2­
4:
UNIVERSE
OF
AFFECTED
FACILITIES
AND
FORMS
BY
OPTION
New
Eligibility
for
Form
A:
PBT
Chemicals
Option
Expanded
Eligibility
for
Form
A:
Non­
PBT
Chemicals
Optiona
Combined
Options
Total
Number
of
Affected
Facilities
2,064
6,461
7,958
Total
Number
of
Affected
Forms
2,703
12,201
14,904
a
The
number
of
affected
non­
PBT
forms
in
this
analysis
does
not
include
the
non­
PBT
forms
that
are
currently
likely
eligible
for
Form
A
based
on
an
ARA
of
less
than
or
equal
to
500
pounds.

Note:
In
this
analysis,
all
TRI
data
are
summed
at
the
facility­
chemical
level.

Source:
Frozen
RY2002
TRI
data.

Total
burden
savings
are
presented
in
Chapter
Three.

2.3
ESTIMATION
OF
IMPACTS
OF
THE
PROPOSED
RULE
ON
REPORTING
To
evaluate
the
impacts
of
the
proposed
rule
on
reporting,
EPA
looked
at
both
the
total
release
pounds
and
total
production
related
waste
pounds
on
a
chemical
by
chemical
basis
that
would
not
be
reported
if
Form
As
were
substituted
for
Form
Rs
for
chemical
submissions.
The
EPA
also
conducted
an
analysis
of
zip
codes
affected
by
new
and
expanded
Form
A
eligibility.

6
Note
that
there
may
be
new
facilities
filing
to
TRI
for
the
first
time
that
may
experience
burden
reduction
due
to
the
proposed
rule.
Without
information
on
their
reportable
chemicals
and
amounts,
however,
it
is
not
possible
to
determine
the
option
for
which
they
would
qualify
and
they
are
thus
not
accounted
for
in
this
analysis.

7
Any
positive
values
reported
in
Section
8.8
are
assumed
to
be
a
release
or
disposal
quantity
if
a
positive
value
was
also
reported
in
Section
5,
Section
6.1
when
the
chemical
is
a
metal,
Section
6.2
for
disposal
M
codes,
or
Section
6.2
for
M40
(
Solidification/
Stabilization)
and
M61
(
Wastewater
treatment
(
Excluding
POTW))
when
the
chemical
is
a
metal.
