
1
M
E
M
O
R
A
N
D
U
M
TO:
Paul
Borst,
USEPA
FROM:
Hilary
Eustace,
David
Cooper,
Susan
Day
DATE:
July
16,
2004
RE:
TRI
Reporting
Burden
Estimates
1.
INTRODUCTION
EPA
currently
relies
on
previously
developed
OMB
approved
TRI
reporting
burden
estimates
that
reflect
the
total
time
required
by
facilities
to
complete
activities
such
as
rule
familiarization,
compliance
determination,
form
completion,
record
keeping/
mailing,
and
supplier
notification.
While
form
completion
reporting
burden
estimates
have
been
prepared
for
completion
of
the
full
Form
R,
the
total
time
is
not
broken
down
by
the
individual
data
elements
that
make
up
the
form.
Data
element
specific
burden
estimates
would
allow
for
informed
assessments
and
comparisons
of
proposed
TRI
burden
reduction
methods
as
well
as
any
future
proposed
Form
R
modifications.
In
this
memo,
burden
estimates
are
derived
for
every
data
element
on
the
Form
R
based
on
the
activities
TRI
reporters
undertake
to
complete
each
data
element
as
well
as
the
time
estimates
for
technical,
managerial,
and
clerical
staff
at
a
typical
facility
to
conduct
these
activities.
During
the
last
TRI
ICR
renewal,
EPA
referenced
industry
data
suggesting
that
TRI
reporting
burden
is
lower
than
previously
estimated.
While
the
newly
negotiated
burden
estimates
were
revised
downward
for
non­
PBT
chemicals,
they
were
not
lowered
by
as
much
as
EPA
proposed.
Furthermore,
PBT
chemical
reporting
burden
was
not
lowered
at
all.
The
OMB
approved
reporting
estimates
are
presented
in
Table
1.
The
data
element
specific
burden
estimates
presented
in
this
memo
are
estimated
first
to
reflect
the
time
it
actually
takes
the
typical
facility
to
fill
out
each
data
element.
This
burden
is
referred
to
as
the
"
realistic
burden."
Second,
the
data
element
specific
realistic
burden
estimates
are
scaled
up
so
that
summing
them
yields
the
OMB
approved
burden
estimate
of
form
completion.
Several
sets
of
burden
estimates
were
prepared,
including
times
for
both
electronic
and
paper
form
preparation
for
every
category
outlined
below:
Abt
Associates
Inc.
Draft
07/
16/
04
2
°
Realistic
Burden
Estimates
for
Every
Form
R
Data
Element:
Realistic
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
realistic
scenario,
no
clerical
time
is
spent
on
form
completion.
Separate
realistic
burden
estimates
were
prepared
for
non­
PBT
and
PBT
chemicals.
°
Realistic
Burden
Estimates
for
Total
Form
R
Completion:
The
realistic
data
element
burden
estimates
were
weighted
by
the
incidence
rate,
which
is
the
total
percentage
of
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
non­
PBT
and
PBT
chemicals.
°
Scaled
Burden
Estimates
for
Every
Form
R
Data
Element
for
non­
PBT
Chemicals:
The
realistic
burden
estimates
generated
for
every
data
element
for
non­
PBT
chemicals
were
scaled
up
to
meet
the
current
OMB­
approved
time
estimate
for
calculations
and
form
completion
for
a
Form
R
for
a
non­
PBT
chemical.
°
Scaled
Burden
Estimates
for
Every
Form
R
Data
Element
for
PBT
Chemicals:
The
realistic
burden
estimates
generated
for
every
data
element
for
PBT
chemicals
were
scaled
up
to
meet
the
current
OMB­
approved
time
estimate
for
calculations
and
form
completion
for
a
Form
R
for
a
PBT
chemical.
Since
the
current
OMB­
approved
time
estimate
for
calculations
and
form
completion
for
a
PBT
chemical
assumes
that
all
data
elements
are
completed,
these
scaled
data
element
time
estimates
were
not
multiplied
by
the
incidence
rate
for
PBT
chemicals.
Abt
Associates
Inc.
Draft
07/
16/
04
3
TABLE
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
11.3
24.1
1.6
37.0
Calculations
and
report
completion
­
PBT
chemicals
20.9
45.2
2.9
69.0
Subsequent
years
Calculations
and
report
completion
­
non­
PBT
chemicals
7.7
16.4
1.1
25.2
Calculations
and
report
completion
­
PBT
chemicals
14.3
30.8
2.0
47.1
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).

Realistic
estimates,
based
on
best
engineering
judgment,
are
presented
in
Section
2;
Section
3
presents
the
realistic
estimate
scaled
to
the
OMB
approved
Form
R
completion
times.
Within
each
section,
PBT
and
non­
PBT
reporting
burden
is
examined
separately
due
to
differences
in
methodology.
The
PBT
and
non­
PBT
chemical
sub­
sections
are
further
divided
into
electronic
and
paper
methodology
and
results
sub­
sections.

2.
REALISTIC
REPORTING
BURDEN
ESTIMATES
2.1.
A.
Methodology
for
Electronic
Submission
The
basis
for
all
of
the
burden
estimates
presented
in
this
memo
start
with
a
realistic
burden
estimate
for
a
typical
facility
to
prepare
a
Form
R
in
the
first
year
and
all
subsequent
reporting
years.
To
generate
this
realistic
burden
estimate,
the
method
described
below
was
utilized.
First,
the
steps
required
for
completion
of
each
data
element
(
field)
on
the
Form
R
were
identified.
Best
engineering
judgement
was
used
to
estimate
the
time
to
complete
each
step
based
on
a
reasonable
and
likely
scenario
for
conducting
the
needed
steps
a
typical
facility.
Best
engineering
judgement
was
provided
by
a
team
of
three
staff
with
nearly
40
years
of
combined
experience
working
with
facilities
on
environmental
issues.
These
staff
have
worked
with
hundreds
of
facilities
on
TRI
Abt
Associates
Inc.
Draft
07/
16/
04
4
reporting
and
other
environmental
requirements
by
conducting
inspections
and
providing
technical
assistance
to
hundreds
of
facilities,
serving
as
TRI
trainers,
conducting
technical
review
on
hundreds
of
TRI
data
withdrawal
requests,
conducting
hundreds
of
TRI
data
quality
calls,
working
for
two
of
the
Massachusetts
Toxics
Use
Reduction
Act
agencies,
and
working
as
environmental
staff
at
large
manufacturing
facilities.)
Next,
the
total
time
to
complete
each
data
element
was
estimated
by
summing
together
the
labor
hours
required
to
complete
the
set
of
steps
necessary
for
each
data
element.

Best
and
worst­
case
scenarios
of
activities
were
considered
when
estimating
the
time
required
to
complete
each
step.
The
time
estimates
presented
here
reflect
the
most
typical/
likely
scenario.
For
example,
scenarios
to
identify
average
discharge
water
flow
rate
range
from
transcribing
dozens
of
hand­
written
entries
from
manual
meter
observation
to
simply
pulling
this
piece
of
data
from
a
fully­
automated
system.
The
likely
scenario
selected
is
that
the
typical
facility
will
have
at
least
partial
automation
on
data
capture
from
their
flow
meter,
but
technical
staff
will
likely
have
to
pull
multiple
pieces
of
information,
interpret
this
information,
and
perform
a
few
calculations.
Several
Form
R
data
elements
will
require
the
same
or
similar
activities.
To
ensure
consistency,
times
were
standardized
for
these
activities.
These
standard
times
are
presented
in
Table
2.

For
Form
R
data
elements
requiring
a
quantitative
estimate
of
release
or
other
waste
management
quantities,
the
steps
a
facility
would
take
to
fill
in
the
data
elements
were
derived
based
on
the
most
common
basis
of
estimate
code
reported
for
that
field
in
the
RY
2002
TRI
data.
The
basis
of
estimate
code
analysis
is
presented
in
Table
3.
For
example,
monitoring
data
was
the
most
common
basis
of
estimate
code
for
off­
site
transfers
to
POTWs;
therefore,
the
steps
required
to
make
engineering
calculations
based
on
monitoring
data
were
used
as
the
basis
for
the
time
estimate
for
this
data
element.
In
actuality,
each
facility
would
use
their
best
available
data
for
completing
each
field.
As
a
final
check,
estimated
times
for
data
elements
were
compared
with
one
another
based
on
expected
relative
degree
of
difficulty.

The
total
realistic
form
completion
burden
was
calculated
by
combining
the
time
required
to
complete
each
data
element
with
the
percent
of
times
individual
data
elements
are
typically
completed.
As
mentioned
above,
this
adjustment
was
made
by
weighting
the
data
element
specific
burden
by
the
incidence
rate
for
that
element.
For
example,
if
a
stack
air
release
quantity
(
either
"
0"
or
an
actual
quantity)
was
reported
on
50%
of
all
non­
PBT
Form
Rs,
the
time
estimated
to
complete
Part
II,
Section
5.2
of
the
Form
R
was
multiplied
by
50%.
For
data
elements
that
are
required,
it
was
assumed
that
100%
of
forms
had
the
data
element
filled
out.
The
final
reporting
burden
is
a
realistic
estimate
of
the
total
form
completion
time
based
on
engineering
judgement.
A
separate
analysis
was
done
for
non­
PBT
and
PBT
chemicals.

As
mentioned
above,
these
burden
estimates
are
based
on
the
TRI
reporting
experiences
of
a
typical
facility.
It
was,
therefore,
necessary
to
make
the
following
assumptions
about
a
typical
facility:

°
The
facility
is
reasonably
modern
and
well­
organized.
Abt
Associates
Inc.
Draft
07/
16/
04
5
°
The
facility
has
internet
access
with
reasonable
connection
speed.

°
Through
rule
familiarization,
the
technical
staff
are
aware
that
written
EPA
TRI
guidance
is
available
through
the
website.

°
Unless
otherwise
noted,
the
set
of
activities
listed
for
a
release
estimate
need
only
be
conducted
once.

°
Unless
otherwise
noted,
there
is
no
difference
in
completing
a
data
element
for
non­
PBT
versus
PBT
chemicals.
(
Additional
discussion
on
PBTs
versus
non­
PBTs
is
provided
below).

°
Technical
staff
retain
copies
of
the
previous
year's
reports
in
a
readily
available
format.
Therefore,
static
information
available
from
the
previous
year's
reports,
such
as
RCRA
I.
D.,
is
assumed
to
require
only
typing
time
in
subsequent
years.

°
For
subsequent
year
reports,
technical
staff
will
be
able
to
locate,
review,
and
interpret
information
needed
to
prepare
release
and
other
waste
management
estimates
more
quickly
since
they
have
already
gone
through
the
process.

°
For
subsequent
year
reports,
it
is
assumed
that
there
are
no
significant
changes
to
facility
operations
or
waste
management
practices.

°
Technical
staff
preparing
the
report
will
concurrently
type
this
information
into
TRI­
ME
and
will
not
require
clerical
assistance
in
entering
information
into
TRI­
ME.

°
On
the
paper
form
estimates
of
reporting
burden,
clerical
time
consists
entirely
of
typing
hard
copy
Form
Rs;
no
other
activities
are
undertaken.
For
example,
technical
staff
conduct
all
of
the
needed
research
for
preparing
the
form.

Since
more
than
80%
of
Form
Rs
were
filed
electronically
in
RY
2002,
it
is
assumed
for
the
realistic
burden
estimate
that
technical
staff
prepare
the
electronic
form;
therefore,
no
clerical
burden
is
estimated.
Also,
in
the
realistic
burden
estimate,
management
review
time
is
based
on
the
maximum
perceived
level
of
management
involvement
at
reporting
facilities
and
is
lower
than
previous
OMB
approved
management
burden
estimates.
In
the
following
sections,
data
elements
are
presented
as
they
appear
on
the
Form
R.
Reporting
burden
estimates
are
presented
after
each
step
for
first
year/
subsequent
years
in
minutes.
If
a
step
will
take
less
time
or
does
not
need
to
be
repeated
in
subsequent
years,
this
will
be
reflected
in
the
allotted
time
(
i.
e.,
a
lower
time
or
"
0"
will
be
given
for
subsequent
years).

As
mentioned
above,
the
calculations/
form
completion
burden
for
non­
PBT
chemicals
was
recently
revised
from
47.1
hours
to
25.2
hours
for
non­
PBT
chemicals
(
Memo
from
Cody
Rice
to
Abt
Associates
Inc.
Draft
07/
16/
04
6
Amy
Newman:
Terms
of
Clearance
for
TRI
ICR
Renewal.
Jan
20,
2004).
Reporting
burden
associated
with
PBT
chemicals
was
not
revised
due
to
trade
association
comments
suggesting
that
because
range
reporting
and
the
de
minimis
exemption
cannot
be
used
for
PBT
chemicals,
form
completion
takes
longer
for
a
PBT
chemical
than
a
non­
PBT
chemical.
While
there
may
be
overall
differences
in
TRI
reporting
burden
between
PBT
and
non­
PBT
forms,
this
difference
is
largely
due
to
compliance
determination
activities,
not
form
completion.

Specifically,
the
de
minimis
exemption
is
not
allowed
for
PBT
chemicals.
Therefore,
compliance
determination
may
take
longer
for
PBT
chemicals,
as
additional
mixtures
may
need
to
be
assessed
for
threshold
quantity.
It
does
not
appear,
however,
that
the
lack
of
the
de
minimis
exemption
will
increase
the
burden
associated
with
making
release
estimates
due
to
a
need
to
assess
additional
waste
streams.
An
analysis
of
the
RY
2002
TRI
data
indicated
that
the
average
number
of
reported
"
M"
codes
for
off­
site
transfers
was
slightly
lower
for
PBTs
than
for
non­
PBTs
(
2.55
versus
2.64,
respectively).
Assuming
that
different
waste
streams
are
indicated
by
different
waste
management
methods,
as
indicated
by
the
"
M"
code,
it
appears
that
there
were
slightly
fewer
differing
waste
streams
for
PBT
chemicals
than
for
non­
PBT
chemicals.

Also,
not
being
able
to
use
range
reporting
does
not
actually
increase
the
reporting
burden
for
PBT
filers.
Range
reporting
is
allowed
for
non­
PBT
chemicals
in
Part
II,
Sections
5
and
6
of
the
Form
R
(
on­
site
releases
and
off­
site
transfers
of
wastes),
but
is
not
allowed
in
Part
II,
Section
8
of
the
Form
R.
All
release
and
other
waste
management
quantities
from
Sections
5
and
6
are
also
recorded
in
Section
8
of
the
Form
R,
therefore,
actual
estimates
(
versus
range
estimates)
for
Sections
5
and
6
must
be
made
to
complete
Section
8.
As
a
result,
no
fewer
calculations
are
necessary
to
complete
a
Form
R
for
non­
PBTs
versus
PBTs
due
to
range
reporting.
In
addition,
range
reporting
is
only
allowed
for
releases
less
than
1,000
pounds,
and
calculations
are
needed
to
determine
which
range
is
applicable.

As
shown
below,
using
best
engineering
judgment,
there
does
not
appear
to
be
a
significant
difference
between
calculations/
form
completion
activities
and
burden
for
PBT
versus
non­
PBT
chemicals.
In
fact,
it
is
estimated
that
the
calculations/
form
completion
time
for
PBT
chemicals
is
slightly
lower,
primarily
due
to
the
fact
that
more
EPA­
published
quantitative
guidance
is
available
for
PBT
chemicals,
such
as
emission
factors.
Analysis
of
RY
2002
TRI
data
shows
the
following:

°
The
most
commonly
reported
basis
of
estimate
codes
were
nearly
identical
for
PBTs
versus
non­
PBTs.

°
The
percent
of
data
elements
filled
out
by
RY
2002
filers
was
nearly
the
same
for
PBT
and
non­
PBT
forms,
with
the
difference
being
the
percent
was
slightly
lower
for
PBTs.

°
For
data
elements
where
multiple
occurrences
were
reported
(
e.
g.,
off­
site
transfer
locations,
number
of
"
M"
codes
for
off­
site
transfers,
number
of
reported
on­
site
treatment
waste
streams),
the
incidence
rates
were
nearly
identical
for
PBT
and
non­
PBT
Abt
Associates
Inc.
Draft
07/
16/
04
7
forms.

The
derivation
of
the
data
element
specific
burden
estimates
is
presented
below.
Only
one
complete
set
of
steps
reflecting
expected
activities
for
both
PBT
and
non­
PBT
chemicals
is
provided
for
each
data
element
(
with
a
few
minor
exceptions)
as
there
are
no
significant
differences
in
form
completion
activities.
Minor
differences
expected
between
non­
PBT
and
PBT
chemicals
are
noted
in
the
individual
data
element
discussions
where
they
occur.

Data
Element
Specific
Reporting
Burden
Form
R,
Part
I.
Facility
Identification
Information
Section
1:
Reporting
Year
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

Technical
staff
will
have
knowledge
of
this
information
and
will
report
it
in
Part
I,
Section
1
of
the
Form
R.
(
0.25
min/
0.25
min)

Reporting
Burden
Associated
with
Part
I,
Section
1
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.25
0.25
Total
0.33
0.33
Section
2:
Trade
Secret
Information
2.1
Are
you
claiming
the
toxic
chemical
identified
on
page
2
trade
secret?
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

Technical
staff
will
have
knowledge
of
this
information
and
will
check
yes
or
no
in
Part
I,
Section
2.1
of
the
Form
R.
(
0.08
min/
0.08
min)
Abt
Associates
Inc.
Draft
07/
16/
04
8
Reporting
Burden
Associated
with
Part
I,
Section
2.1
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.08
0.08
Total
0.16
0.16
2.2
Is
this
copy
sanitized
or
unsanitized?

Facilities
must
meet
rigorous
standards
as
outlined
in
40
CFR
350
in
order
to
claim
trade
secret
status;
therefore,
it
is
assumed
a
typical
facility
will
check
"
no"
in
Part
I,
Section
2.1
of
the
Form
R,
and
subsequently
Part
I,
Section
2.2
of
the
Form
R
will
be
left
blank.

Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

Technical
staff
will
have
knowledge
of
this
information
and
will
check
yes
or
no
in
Part
I,
Section
2.2
of
the
Form
R.
(
0.08
min/
0.08
min)

Reporting
Burden
Associated
with
Part
I,
Section
2.2
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.08
0.08
Total
0.16
0.16
Section
3:
Certification
In
RY
2002,
more
than
80%
of
Form
R
reports
were
filed
via
diskette
or
CDX
submission.
Electronic
signature
occurs
as
part
of
the
CDX
submission
process
and
with
diskette
submission
a
separate
signed
letter
is
sent.
Burden
for
this
effort
is
allocated
under
"
Record
keeping/
Mailing"
and
therefore
is
not
included
in
the
"
Calculations/
Form
Completion"
burden
estimate
outlined
in
this
report.
Thus,
no
management,
technical,
nor
clerical
burden
associated
with
this
element
of
the
Form
R
will
be
allocated
for
this
analysis.

Section
4.1:
Facility
Identification
(
Name,
Address)

Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.67
min/
0.67
min)

Technical
staff
will
have
knowledge
of
this
information
and
will
report
it
in
Part
I,
Section
4.1
of
the
Form
R.
(
2.0
min/
0
min)
Abt
Associates
Inc.
Draft
07/
16/
04
9
Reporting
Burden
Associated
with
Part
I,
Section
4.1
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.67
0.67
Technical
2.00
0.00
Total
2.67
0.67
Section
4.2:
Reporting
by
Part
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

4.2a
or
4.2b
Technical
staff
will
have
knowledge
of
this
information,
and
will
check
off
if
this
Form
R
is
for
an
entire
facility
or
part
of
a
facility
in
Part
I,
Section
4.2a
or
4.2b,
respectively,
of
the
Form
R.
(
0.08
min/
0.08
min)

Reporting
Burden
Associated
with
Part
I,
Section
4.2a
or
4.2b
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.08
0.08
Total
0.16
0.16
4.2c
or
4.2d
This
section
is
only
filled
out
if
the
Form
R
is
from
a
federal
facility
or
a
government­
owned,
contractor­
operated
(
GOCO)
entity
conducting
work
on
behalf
of
the
federal
government.
Since
fewer
than
5%
of
Form
Rs
are
filled
out
by
these
facilities,
this
section
will
typically
be
left
blank.

Technical
staff
will
have
knowledge
of
this
information,
and
will
check
off
if
this
Form
R
is
for
a
federal
facility
or
a
GOCO
in
Part
I,
Section
4.2c
or
4.2d,
respectively,
of
the
Form
R.
No
time
is
included
for
this
step
because
it
is
filled
out
less
than
5%
of
the
time.

Section
4.3:
Technical
Contact
Information
(
Name,
Address,
E­
mail,
Telephone)

Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.25
min/
0.25
min)

Technical
staff
will
have
knowledge
of
this
information
and
will
report
it
in
Part
I,
Section
4.3
of
the
Form
R.
(
0.75
min/
0
min)
Abt
Associates
Inc.
Draft
07/
16/
04
10
Reporting
Burden
Associated
with
Part
I,
Section
4.3
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.25
0.25
Technical
0.75
0.00
Total
1.00
0.25
Section
4.4:
Public
Contact
Information
(
Name,
Telephone)

Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.17
min/
0.17
min)

Technical
staff
will
have
knowledge
of
this
information
and
will
report
it
in
Part
I,
Section
4.4
of
the
Form
R.
(
0.50
min/
0
min)

Reporting
Burden
Associated
with
Part
I,
Section
4.4
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.17
0.17
Technical
0.50
0.00
Total
0.67
0.17
Section
4.5:
SIC
Code(
s)

Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

As
an
integral
part
of
compliance
determination,
a
facility
will
have
determined
which
SIC
codes
apply
to
the
facility.
Technical
staff
simply
record
this
information
in
Part
I,
Section
4.5
of
the
Form
R.
(
0.25
min/
0
min)

Reporting
Burden
Associated
with
Part
I,
Section
4.5
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.25
0.00
Total
0.33
0.08
Abt
Associates
Inc.
Draft
07/
16/
04
11
Section
4.6:
Latitude/
Longitude
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.50
min/
0.50
min)

Technical
staff
will
go
to
the
TRI
facility
siting
tool
available
on
the
EPA
Web
site
and
type
in
their
facility
address.
The
tool
will
then
report
back
the
latitude
and
longitude.
The
technical
staff
will
record
this
information
in
Part
I,
Section
4.6
of
the
Form
R.
(
4.5
min/
0
min)

Reporting
Burden
Associated
with
Part
I,
Section
4.6
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.50
0.50
Technical
4.50
0.00
Total
5.00
0.50
Section
4.7:
Dun
&
Bradstreet
Number
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

Technical
staff
will
obtain
this
information
from
elsewhere
in
the
company
by
making
a
phone
call,
checking
files,
or
making
an
in­
person
information
request.
Once
obtained,
technical
staff
will
record
this
information
in
Part
I,
Section
4.7
of
the
Form
R.
(
10.0
min/
0
min)

Reporting
Burden
Associated
with
Part
I,
Section
4.7
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
10.00
0.00
Total
10.08
0.08
Section
4.8:
EPA
Identification
Number
(
RCRA
ID)

Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

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
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
Abt
Associates
Inc.
Draft
07/
16/
04
12
obtained,
technical
staff
will
record
this
information
in
Part
I,
Section
4.8
of
the
Form
R.
(
10.0
min/
0
min)

Reporting
Burden
Associated
with
Part
I,
Section
4.8
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
10.00
0.00
Total
10.08
0.08
Section
4.9:
Facility
NPDES
Permit
Number
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

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,
technical
staff
will
record
this
information
in
Part
I,
Section
4.9
of
the
Form
R.
(
10.0
min/
0
min)

Reporting
Burden
Associated
with
Part
I,
Section
4.9
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
10.00
0.00
Total
10.08
0.08
Section
4.10:
Underground
Injection
Well
Code
(
UIC
I.
D.)

Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

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.
Once
obtained,
technical
staff
will
record
this
information
in
Part
I,
Section
4.10
of
the
Form
R.
(
10.0
min/
0
min)
Abt
Associates
Inc.
Draft
07/
16/
04
13
Reporting
Burden
Associated
with
Part
I,
Section
4.10
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
10.00
0.00
Total
10.08
0.08
Section
5.1:
Name
of
Parent
Company
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

Technical
staff
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.
Once
obtained,
technical
staff
will
record
this
information
in
Part
I,
Section
5.1
of
the
Form
R.
(
10.0
min/
0
min)

Reporting
Burden
Associated
with
Part
I,
Section
5.1
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
10.00
0.00
Total
10.08
0.08
Section
5.2:
Parent
Company's
Dun
&
Bradstreet
Number
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

Technical
staff
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.
Once
obtained,
technical
staff
will
record
this
information
in
Part
I,
Section
5.2
of
the
Form
R.
(
10.0
min/
0
min)

Reporting
Burden
Associated
with
Part
I,
Section
5.2
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
10.00
0.00
Total
10.08
0.08
Abt
Associates
Inc.
Draft
07/
16/
04
14
Form
R,
Part
II.
Chemical­
Specific
Information
Section
1.1:
CAS
Number
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

Technical
staff
will
have
the
CAS
Number
readily
available
from
activities
conducted
during
compliance
determination,
such
as
review
of
Material
Safety
Data
Sheets
(
MSDSs)
or
review
of
the
EPCRA
Section
313
chemical
list,
and
report
it
in
Part
II,
Section
1.1
of
the
Form
R.
(
0.25
min/
0
min)

Reporting
Burden
Associated
with
Part
II,
Section
1.1
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.25
0.00
Total
0.33
0.08
Section
1.2:
Toxic
Chemical
or
Chemical
Category
Name
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

Technical
staff
will
have
the
chemical
name
readily
available
from
activities
conducted
during
compliance
determination,
such
as
review
of
Material
Safety
Data
Sheets
(
MSDSs)
or
review
of
the
EPCRA
Section
313
chemical
list,
and
report
it
in
Part
II,
Section
1.2
of
the
Form
R.
(
0.25
min/
0
min)

Reporting
Burden
Associated
with
Part
II,
Section
1.2
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.25
0.00
Total
0.33
0.08
Section
1.3:
Generic
Chemical
Name
Facilities
must
meet
rigorous
standards
as
outlined
in
40
CFR
350
in
order
to
claim
trade
secret
status;
therefore,
this
section
of
the
Form
R
is
not
typically
used.
If
a
facility
meets
the
standard
for
trade
secret
status,
this
section
of
the
Form
R
is
completed
instead
of
Part
II,
Sections
1.1
and
1.2.
If
this
section
is
used,
management
burden
includes
proofreading
this
section
as
part
of
an
Abt
Associates
Inc.
Draft
07/
16/
04
15
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

Technical
staff
would
create
a
generic,
structurally
descriptive
chemical
name
and
report
it
in
Part
II,
Section
1.3
of
the
Form
R.
(
0.50
min/
0
min)

Reporting
Burden
Associated
with
Part
II,
Section
1.3
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.50
0.00
Total
0.58
0.08
Section
1.4:
Distribution
of
Each
Member
of
the
Dioxin
and
Dioxin­
Like
Compounds
Category
This
section
of
the
Form
R
is
left
blank
unless
the
chemical
is
dioxin
and
dioxin­
like
compounds.
Therefore,
for
Form
Rs
for
all
other
chemicals
there
is
no
management,
technical,
nor
clerical
burden
associated
with
this
element.
If
the
Form
R
is
for
dioxin
and
dioxin­
like
compounds,
management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

Technical
staff
would
most
likely
obtain
the
distribution
of
each
member
of
the
dioxin
and
dioxinlike
compounds
category
for
the
appropriate
activity
from
EPA's
document
"
EPCRA
Section
313
Guidance
for
Reporting
Toxic
Chemicals
Within
the
Dioxin
and
Dioxin­
like
Compounds
Category"
and
report
it
in
Part
II,
Section
1.4
of
the
Form
R.
(
5
min/
2
min)

Reporting
Burden
Associated
with
Part
II,
Section
1.4
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
5.00
2.00
Total
5.08
2.08
Section
2.1:
Generic
Chemical
Name
Provided
by
Supplier
This
section
of
the
Form
R
is
only
completed
if
the
facility's
chemical
supplier
meets
the
standard
for
trade
secret
status
and
is
therefore
not
typically
used.
If
the
material
supplied
meets
the
standard
for
trade
secret
status,
this
section
of
the
Form
R
is
completed
instead
of
Part
II,
Sections
1.1
and
1.2.
If
this
section
is
used,
management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

Technical
staff
would
have
the
generic
chemical
name
provided
by
the
supplier
readily
available
Abt
Associates
Inc.
Draft
07/
16/
04
16
from
activities
conducted
during
compliance
determination,
such
as
review
of
Material
Safety
Data
Sheets
(
MSDSs),
and
report
it
in
Part
II,
Section
2.1
of
the
Form
R.
(
0.25
min/
0
min)

Reporting
Burden
Associated
with
Part
II,
Section
2.1
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.25
0.00
Total
0.33
0.08
Section
3.1:
Manufacture
the
Toxic
Chemical
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

As
an
integral
part
of
compliance
determination,
the
facility
becomes
familiar
with
the
EPCRA
Section
313
threshold
activities
that
the
chemical
was
involved
in
during
the
reporting
year.
Therefore,
technical
staff
simply
check
off
the
relevant
descriptions
of
manufacturing
activities
for
the
chemical
presented
in
Part
II,
Section
3.1
of
the
Form
R.
(
0.08
min/
0
min)

Reporting
Burden
Associated
with
Part
II,
Section
3.1
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.08
0.00
Total
0.16
0.08
Section
3.2:
Process
the
Toxic
Chemical
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

As
an
integral
part
of
compliance
determination,
the
facility
becomes
familiar
with
the
EPCRA
Section
313
threshold
activities
that
the
chemical
was
involved
in
during
the
reporting
year.
Therefore,
technical
staff
simply
check
off
the
relevant
descriptions
of
processing
activities
for
the
chemical
presented
in
Part
II,
Section
3.2
of
the
Form
R.
(
0.08
min/
0
min)
Abt
Associates
Inc.
Draft
07/
16/
04
17
Reporting
Burden
Associated
with
Part
II,
Section
3.2
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.08
0.00
Total
0.16
0.08
Section
3.3:
Otherwise
Use
the
Toxic
Chemical
Management
burden
includes
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.08
min/
0.08
min)

As
an
integral
part
of
compliance
determination,
the
facility
becomes
familiar
with
the
EPCRA
Section
313
threshold
activities
that
the
chemical
was
involved
in
during
the
reporting
year.
Therefore,
technical
staff
simply
check
off
the
relevant
descriptions
of
otherwise
use
activities
for
the
chemical
presented
in
Part
II,
Section
3.3
of
the
Form
R.
(
0.08
min/
0
min)

Reporting
Burden
Associated
with
Part
II,
Section
3.3
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.08
0.08
Technical
0.08
0.00
Total
0.16
0.08
Section
4.1:
Maximum
Amount
of
the
Toxic
Chemical
On­
Site
at
any
Time
During
the
Calendar
Year
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
1.08
min/
0.91
min)

The
maximum
amount
of
toxic
chemical
on­
site
at
any
point
during
the
year
is
reported
as
a
range
code,
with
each
range
representing
one
order
of
magnitude.
To
determine
the
range
estimate
for
the
maximum
amount
of
the
toxic
chemical
in
storage,
in
process,
and
in
on­
site
wastes
at
any
one
point
during
the
year,
it
is
assumed
the
technical
staff
performs
the
steps
outlined
below.
The
estimate
is
needed
to
identify
a
quantity
within
a
very
broad
range,
not
to
identify
a
more
exact
quantity.
For
this
reason,
steps
outlined
here
will
take
less
time
than
when
conducted
for
a
data
element
requiring
a
more
precise
estimate.

°
Determine
the
maximum
quantity
of
the
toxic
chemical
in
storage
at
any
point
during
the
calendar
year
by
either
reviewing
inventory
records
or
talking
with
operations
staff.
(
9.00
min/
9.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
18
°
Determine
the
maximum
quantity
of
the
toxic
chemical
in
process
at
any
point
during
the
calendar
year
by
either
reviewing
operations
records
or
talking
with
operations
staff.
(
9.00
min/
9.00
min)

°
Determine
the
maximum
quantity
of
the
toxic
chemical
in
on­
site
wastes
at
any
point
during
the
calendar
year
by
either
reviewing
waste
records,
such
as
hazardous
waste
manifests,
or
talking
with
operations
staff.
(
9.00
min/
9.00
min)

°
Sum
together
the
storage,
process,
and
waste
quantities
to
calculate
the
maximum
amount
of
the
toxic
chemical
on­
site
at
any
one
point
during
the
year.
(
3.00
min/
3.00
min)

°
Locate
the
appropriate
2­
digit
code
from
the
TRI
Reporting
Forms
and
Instructions
and
report
it
in
Part
II,
Section
4.1
of
the
Form
R.
(
0.25
min/
0.25
min)

Reporting
Burden
Associated
with
Part
II,
Section
4.1
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
1.08
0.91
Technical
30.25
30.25
Total
31.33
31.16
Section
5.1:
Fugitive
or
Non­
Point
Air
Emissions
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
3.08
min/
2.58
min)

The
most
commonly
reported
basis
of
estimate
code
for
fugitive
air
releases
for
both
non­
PBT
and
PBT
chemicals
is
"
O,"
other
approaches.
It
is
assumed
the
most
typical
approach
would
involve
an
estimate
based
on
use
of
physical
and
chemical
properties
and
process
operating
conditions.
To
estimate
fugitive
or
non­
point
air
emissions,
technical
staff
would
perform
the
following
steps:

°
Identify
all
fugitive
release
points
for
the
chemical
through
review
of
air
permits,
discussions
with
operations
staff,
review
of
process
flow
diagrams,
or
a
visual
inspection
of
operations.
(
30.00
min/
5.00
min)

°
Identify
physical
and
chemical
property
data
for
the
chemical,
including
volatility,
boiling
point,
etc.
(
5.00
min/
5.00
min)

°
Identify
relevant
process
operating
conditions,
such
as
temperature,
turbulence,
etc.,
(
45.00
min/
30.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
19
°
Determine
material
usage
quantity
through
a
review
of
inventory
records,
purchase
records,
operation
records,
or
discussions
with
operations
staff.
(
30.00
min/
30.00
min)

°
Locate
and
review
guidance
from
EPA,
trade
associations,
or
other
sources,
or
air
permit
information
that
provides
quantitative
assistance
for
estimating
fugitive
loss
(
e.
g.,
EPA's
Protocol
for
Equipment
Leak
Emission
Estimates,
air
permit
assumption
of
1%
loss
of
volatiles
due
to
transfers
in
an
otherwise
closed
system).
(
60.00
min/
30.00
min)

°
Make
the
best
estimate
of
fugitive
or
non­
point
air
emissions
based
upon
the
physical
and
chemical
properties
and
process
operating
conditions
and
report
the
value
in
Part
II,
Section
5.1
of
the
Form
R.
(
25.00
min/
15.00
min)

°
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
5.1.
B
of
the
Form
R.
(
0.25
min/
0.25
min)

Reporting
Burden
Associated
with
Part
II,
Section
5.1
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
3.08
2.58
Technical
195.25
115.08
Total
198.33
117.66
Section
5.2:
Stack
or
Point
Air
Emissions
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
3.08
min/
1.75
min)

The
most
commonly
reported
basis
of
estimate
code
for
stack
air
releases
for
non­
PBT
chemicals
is
"
O,"
other
approaches.
It
is
assumed
the
most
typical
approach
uses
non­
published
emission
factors.
The
most
commonly
reported
basis
of
estimate
code
for
stack
air
releases
for
PBT
chemicals
is
"
E,"
published
emission
factors.
Using
these
emission
factors,
technical
staff
would
perform
the
following
steps:

°
Identify
all
of
the
stack
release
points
for
the
chemical.
The
process
for
identifying
these
releases
requires
technical
staff
to
perform
any
or
all
of
the
following
steps:
review
air
permits
or
process
flow
diagrams,
consult
with
operational/
environmental
staff,
or
conduct
a
visual
inspection
of
the
facility.
(
30.00
min/
5.00
min)

°
For
each
stack
air
release,
locate
the
most
applicable
emission
factor.
For
PBT
chemicals,
EPA­
published
emission
factors
are
obtained
from
numerous
EPA
sources,
including
a
chemical
or
industry
specific
guidance,
AP­
42,
or
the
technology
transfer
network
(
for
Abt
Associates
Inc.
Draft
07/
16/
04
20
TANKS
program).
(
10/
9
minutes)
For
non­
PBT
chemicals,
emission
factors
are
obtained
from
sources
such
as
trade
associations
and
university
research.
(
30.00
min/
15.00
min)

°
Determine
the
annual
quantity
of
input
material
by
reviewing
purchase
records,
inventory
records,
and/
or
operational
records.
(
30.00
min/
30.00
min)

°
Multiply
this
material
usage
quantity
by
the
emission
factor
to
determine
the
amount
of
material
released
from
each
point
during
the
year.
If
needed,
convert
the
amount
of
material
released
to
pounds
(
or
grams
for
dioxins)
by
applying
the
appropriate
conversion
factor.
(
6.00
min/
6.00
min)

It
is
assumed
that
there
will
be
an
average
of
two
unique
types
of
stack
releases
for
each
chemical
at
a
typical
facility
(
i.
e.,
two
different
emission
factors
would
be
applied).
There
are
economies
of
scale
in
quantifying
the
second
release
type
due
to
concurrent
activities,
such
as
searching
the
same
sources
to
locate
emission
and
conversion
factors
(
4.00
min/
4.00
min)
and
reviewing
the
same
sources
to
determine
the
annual
quantity
of
input
material.
Technical
staff
would
perform
the
following
steps:

°
Multiply
this
material
usage
quantity
by
the
emission
factor
to
determine
the
amount
of
material
released
from
each
point
during
the
year.
If
needed,
convert
the
amount
of
material
released
to
pounds
(
or
grams
for
dioxins)
by
applying
the
appropriate
conversion
factor.
(
5.00
min/
5.00
min)

°
Sum
all
of
the
quantified
stack
air
releases
for
the
given
chemical
to
quantify
the
total
stack
or
point
air
emissions
(
lb/
yr)
and
report
the
value
in
Part
II,
Section
5.2
of
the
Form
R.
(
1.00
min/
1.00
min)

°
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
5.2.
B
of
the
Form
R.
(
0.25
min/
0.25
min)

Reporting
Burden
Associated
with
Part
II,
Section
5.2
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
3.08
1.75
Technical
106.25
66.25
Total
109.33
68.00
Section
5.3:
Discharges
to
Receiving
Streams
or
Water
Bodies
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
3.33
min/
2.83
min)
Abt
Associates
Inc.
Draft
07/
16/
04
21
The
most
commonly
reported
basis
of
estimate
code
for
discharges
to
receiving
streams
or
water
bodies
is
"
M,"
use
of
monitoring
data,
for
both
non­
PBTs
and
PBTs.
To
estimate
discharges
to
receiving
streams
or
water
bodies,
technical
staff
would
perform
the
following
steps:

Release
Quantity
from
Process
Water
1.
Locate
and
review
the
facility's
monitoring
results
for
process
water
outfall(
s)
to
determine
the
chemical
concentration
for
each
monitoring
point.
(
35.00
min/
25.00
min)

2.
Obtain
flow
rate
data
from
the
NPDES
permit
or
a
flow
meter.
If
neither
is
available,
estimate
the
volume
of
wastewater
generated
by
reviewing
water
usage
data.
The
estimated
flow
is
calculated
by
dividing
the
volume
of
wastewater
by
the
usage
time
(
e.
g.,
days).
(
15.00
min/
10.00
min)

3.
Identify
the
number
of
discharge
days
by
talking
with
operations
staff.
(
15.00
min/
15.00
min)

4.
Multiply
the
identified
chemical
concentration
(
for
one
monitoring
data
point)
by
the
daily
water
flow
rate
to
calculate
the
daily
release
for
this
point.
Repeat
this
step
for
all
monitoring
points,
averaging
the
results
together
to
calculate
the
average
daily
release.
Multiply
the
average
daily
release
by
the
number
of
release
days
to
calculate
the
total
annual
release
quantity.
Apply
any
needed
conversion
factors
to
get
the
result
in
pounds.
(
10.00
min/
10.00
min)

Release
Quantity
from
Storm
Water
5.
Locate
and
review
the
facility's
monitoring
results
from
storm
water
outfall(
s)
to
determine
the
chemical
concentration
for
each
monitoring
point,
and
average
them
together.
Apply
needed
conversion
factors
to
obtain
the
total
annual
release
from
storm
water
in
pounds.
(
45.00
min/
35.00
min)

6.
Locate
the
annual
rainfall
for
the
facility's
area,
assuming
12
inches
of
snow
is
equivalent
to
1
inch
of
rain.
(
4.00
min/
3.00
min)

7.
Estimate
the
percent
of
land
at
the
facility
covered
by
asphalt,
concrete,
and
unimproved
vegetation/
soil.
Technical
staff
generate
a
weighted­
average
runoff
coefficient
by
multiplying
the
percent
of
land
area
by
the
runoff
coefficient
for
that
land
type.
(
30.00
min/
5.00
min)

8.
Multiply
the
total
annual
rainfall
by
the
weighted­
average
runoff
coefficient,
the
total
area
of
the
facility,
and
the
conversion
factor
for
gallons
per
cubic
foot
to
calculate
the
total
annual
storm
water
runoff
in
gallons.
(
5.00
min/
5.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
22
9.
Multiply
the
total
volume
(
gallons)
of
storm
water
by
the
chemical
concentration
to
calculate
the
total
mass
(
pounds)
of
the
chemical
contained
in
the
annual
storm
water
runoff.
If
needed,
apply
a
conversion
factor.
(
4.00
min/
4.00
min)

Total
Release
Quantity
10.
Sum
together
the
annual
release
quantity
from
process
water
with
the
annual
release
quantity
from
storm
water
to
obtain
the
total
annual
release
quantity
to
water.
Report
the
total
release
(
lb/
yr)
in
Part
II,
Section
5.3.1.
A
of
the
Form
R
as
the
total
releases
to
a
water
body
for
a
specific
chemical.
(
2.00
min/
2.00
min)

Basis
of
Estimate
11.
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
a
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
5.3.1.
B
of
the
Form
R.
(
0.25
min/
0.25
min)

Percent
from
Stormwater
12.
Divide
the
quantity
of
the
chemical
contained
in
the
storm
water
by
the
total
quantity
of
the
chemical
released
to
water
in
order
to
calculate
the
percent
of
the
chemical
released
from
storm
water.
Report
this
percentage
in
Part
II,
Section
5.3.1.
C
of
the
Form
R.
(
2.00
min/
2.00
min)

Note:
Many
facilities
will
not
need
to
assess
storm
water
in
order
to
calculate
release
to
water
as
many
TRI
chemicals
will
not
typically
be
found
in
storm
water
run­
off,
but
will
instead
only
be
found
in
process
water.
In
order
to
reasonably
estimate
how
much
time
should
be
allocated
to
a
typical
facility
for
assessing
storm
water,
a
data
analysis
was
conducted
on
the
RY
2002
TRI
data.
First,
all
form
Rs
for
which
5.3A
had
a
value
of
greater
than
or
equal
to
zero
were
identified.
Second,
within
that
set,
the
percentage
of
these
forms
that
had
a
value
of
greater
than
zero
in
5.3C
were
identified.
This
analysis
was
conducted
separately
for
non­
PBTs
and
for
PBTs,
with
identified
values
of
39.3%
and
44.4%,
respectively.
The
total
estimated
burden
for
identifying
annual
release
quantity
from
storm
water
(
steps
5
through
9
above)
was
then
multiplied
by
39.3%
for
non­
PBTs
and
by
44.4%
for
PBTs.
This
calculation
is
shown
below:

Total
percent
from
storm
water
burden
multiplied
by
incidence
rate
for
a
value
greater
than
zero
in
5.3.
C
when
there
was
a
value
of
greater
than
or
equal
to
zero
in
5.3.
A:
non­
PBTs:
(
88.00
min/
52.00
min)
x
39.3%
incidence
=
(
34.58/
20.44)
PBTs:
(
88.00
min/
52.00
min)
x
44.4%
incidence
=
(
39.07/
23.09)

This
incidence­
weighted
value
was
added
with
the
total
estimated
burden
for
identifying
the
annual
release
quantity
from
process
water
to
obtain
the
total
calculation
time
estimate
for
5.3.
A.
The
table
below
reflects
the
incidence­
weighted
value
for
storm
water
assessment.
Abt
Associates
Inc.
Draft
07/
16/
04
23
Reporting
Burden
Associated
with
Part
II,
Section
5.3
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Non­
PBT
PBT
Non­
PBT
PBT
Management
3.33
3.33
2.83
2.83
Technical
113.83
118.32
84.69
87.34
Total
117.16
121.65
87.52
90.17
Section
5.4.1:
Underground
Injection
On­
Site
to
Class
I
Wells
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
2.08
min/
1.75
min)

The
most
commonly
reported
basis
of
estimate
code
for
releases
to
underground
injection
Class
I
wells
is
"
M,"
use
of
monitoring
data
for
both
non­
PBT
and
PBT
chemicals.
To
estimate
quantities
injected
underground
or
on­
site
to
Class
I
wells,
the
technical
staff
would
perform
the
following
steps:

13.
Locate
and
review
monitoring
data
for
the
facility,
and
then,
for
each
monitoring
event,
identify
the
concentration
of
the
specific
chemical
in
the
waste
stream.
The
chemical
concentrations
from
all
monitoring
events
are
then
averaged.
(
35.00
min/
25.00
min)

14.
Either
talk
to
operations
staff,
review
production
records
and
estimate
waste
generation,
review
well
operations
records,
or
review
well
permit
data/
required
injection
well
reports
to
determine
the
total
quantity
of
waste
disposed
via
Class
I
wells
for
the
reporting
year.
(
30.00
min/
30.00
min)

15.
Multiply
the
total
quantity
of
waste
disposed
via
Class
I
wells
by
the
average
concentration
of
the
specific
chemical
in
the
waste
stream
to
calculate
the
total
pounds
of
the
chemical
released
to
Class
I
wells
during
the
reporting
year.
If
needed,
apply
a
conversion
factor.
Report
the
value
(
lb/
yr)
in
Part
II,
Section
5.4.1.
A
of
the
Form
R.
(
8.00
min/
8.00
min)

16.
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
5.4.1.
B
of
the
Form
R.
(
0.25
min/
0.25
min)

Reporting
Burden
Associated
with
Part
II,
Section
5.4.1
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
2.08
1.75
Abt
Associates
Inc.
Draft
07/
16/
04
24
Technical
73.25
63.25
Total
75.33
65.00
Section
5.4.2:
Underground
Injection
On­
Site
to
Class
II­
V
Wells
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
2.08
min/
1.75
min)

The
most
commonly
reported
basis
of
estimate
code
for
releases
to
underground
injection
Class
II­
V
wells
is
"
M,"
use
of
monitoring
data
for
both
non­
PBT
and
PBT
chemicals.
To
estimate
quantities
injected
underground
or
on­
site
to
Class
II­
V
wells,
the
technical
staff
would
perform
the
following
steps:

17.
Locate
and
review
monitoring
data
for
the
facility.
Then,
for
each
monitoring
point,
identify
the
concentration
of
the
specific
chemical
in
the
waste
stream.
The
chemical
concentrations
from
all
monitoring
data
points
(
events)
are
then
averaged.
(
35.00
min/
25.00
min)

18.
Either
talk
to
the
operations
staff,
review
production
records
and
estimate
waste
generation,
review
well
operations
records,
or
review
well
permit
data/
required
injection
well
reports
to
determine
the
total
quantity
of
waste
disposed
via
Class
II­
V
wells
for
the
reporting
year.
(
30.00
min/
30.00
min)

19.
Multiply
the
total
quantity
of
waste
disposed
via
Class
II­
V
wells
by
the
average
concentration
of
the
specific
chemical
in
the
waste
stream
to
calculate
the
total
pounds
of
the
chemical
released
to
Class
II­
V
wells
during
the
reporting
year,.
If
needed,
apply
a
conversion
factor.
Report
the
value
(
lb/
yr)
in
Part
II,
Section
5.4.2.
A
of
the
Form
R.
(
8.00
min/
8.00
min)

20.
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
5.4.2.
B
of
the
Form
R.
(
0.25
min/
0.25
min)

Reporting
Burden
Associated
with
Part
II,
Section
5.4.2
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
2.08
1.75
Technical
73.25
63.25
Total
75.33
65.00
Section
5.5.1A:
On­
site
Land
Disposal
via
RCRA
Subtitle
C
Landfills
Abt
Associates
Inc.
Draft
07/
16/
04
25
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
3.08
min/
1.75
min)

The
most
commonly
reported
basis
of
estimate
code
for
releases
to
RCRA
landfills
is
"
O,"
other
approaches,
for
both
non­
PBT
and
PBT
chemicals.
It
is
assumed
technical
staff
would
track
the
generation
and
on­
site
disposal
of
these
wastes
as
follows:

21.
Identify
all
waste
streams
containing
the
chemical
of
interest
disposed
of
in
RCRA
landfills.
(
30.00
min/
5.00
min)

22.
Review
RCRA
records
(
manifests
and
biennial
reports)
to
determine
the
total
quantity
of
waste
disposed
of
in
RCRA
landfills
for
the
reporting
year;
or
talk
to
operations
staff,
review
production
records
and
estimate
waste
generation,
or
review
on­
site
disposal
tracking
records.
(
30.00
min/
30.00
min)

23.
Review
RCRA
waste
characterization
data,
talk
to
operations
staff,
review
any
non­
RCRA
waste
characterization
information,
or
review
production/
activity
Standard
Operating
Procedures
(
SOPs)
and
process
flow
diagrams
to
determine
the
concentration
of
a
specific
chemical
disposed
of
in
a
RCRA
landfill.
(
30.00
min/
25.00
min)

24.
Multiply
the
total
quantity
of
waste
disposed
of
in
RCRA
landfills
by
the
average
concentration
of
the
specific
chemical
in
the
waste
stream
to
calculate
the
total
pounds
of
the
chemical
disposed
of
in
RCRA
landfills
during
the
reporting
year,.
If
needed,
apply
a
conversion
factor.
Report
the
value
(
lb/
yr)
in
Part
II,
Section
5.5.1A.
A
of
the
Form
R.
(
6.00
min/
6.00
min)
25.
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
5.5.1A.
B
of
the
Form
R.
(
0.25
min/
0.25
min)

Reporting
Burden
Associated
with
Part
II,
Section
5.5.1A
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
3.08
1.75
Technical
96.25
66.25
Total
99.33
68.00
Section
5.5.1B:
On­
site
Land
Disposal
via
Other
Landfills
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
3.08
min/
1.75
min)
Abt
Associates
Inc.
Draft
07/
16/
04
26
The
most
commonly
reported
basis
of
estimate
code
for
releases
to
on­
site
non­
RCRA
landfills
is
"
O,"
other
approaches,
for
both
non­
PBT
and
PBT
chemicals.
It
is
assumed
the
technical
staff
would
track
the
generation
and
on­
site
disposal
of
these
wastes
as
follows:

26.
Identify
all
waste
streams
containing
the
chemical
of
interest
disposed
of
in
on­
site
non­
RCRA
landfills.
(
30.00
min/
5.00
min)

27.
Talk
to
operations
staff,
review
production
records
and
estimate
waste
generation,
or
review
on­
site
disposal
tracking
records
to
determine
the
total
quantity
of
waste
disposed
of
in
non­
RCRA
landfills
for
the
reporting
year.
(
30.00
min/
30.00
min)

28.
Talk
to
operations
staff,
review
any
waste
characterization
information,
or
review
production/
activity
SOPs
and
process
flow
diagrams
to
determine
the
concentration
of
a
specific
chemical
disposed
of
in
non­
RCRA
landfills.
(
30.00
min/
25.00
min)

29.
Multiply
the
total
quantity
of
waste
disposed
via
non­
RCRA
landfills
by
the
average
concentration
of
the
specific
chemical
in
the
waste
stream
to
calculate
the
total
pounds
of
the
chemical
disposed
of
in
non­
RCRA
landfills
during
the
reporting
year.
If
needed,
apply
a
conversion
factor.
Report
the
value
(
lb/
yr)
in
Part
II,
Section
5.5.1B.
A
of
the
Form
R.
(
6.00
min/
6.00
min)

30.
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
5.5.1B.
B
of
the
Form
R.
(
0.25
min/
0.25
min)
Abt
Associates
Inc.
Draft
07/
16/
04
27
Reporting
Burden
Associated
with
Part
II,
Section
5.5.1B
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
3.08
1.75
Technical
96.25
66.25
Total
99.33
68.00
Section
5.5.2:
On­
Site
Land
Disposal
via
Land
Treatment/
Application
Farming
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
2.08
min/
1.75
min
for
non­
PBT
filers;
3.08
min/
1.75
min
for
PBT
filers)

The
most
commonly
reported
basis
of
estimate
code
for
releases
via
land
treatment
is
"
M,"
use
of
monitoring
data,
for
non­
PBT
chemicals.
To
estimate
the
quantity
going
to
on­
site
land
disposal
via
land
treatment/
application
farming
for
non­
PBT
chemicals,
the
technical
staff
would
perform
the
following
steps:

31.
Locate
monitoring
data
and
determine
the
chemical
concentration
in
the
waste
stream
for
each
monitoring
point.
Then
calculate
an
average
chemical
concentrations
across
all
monitoring
data
points
(
events).
(
35.00
min/
25.00
min)

32.
Talk
to
operations
staff,
review
production
records,
and
estimate
waste
generation,
or
review
on­
site
disposal
tracking
records
(
i.
e.,
the
number
of
land
applications
multiplied
by
the
average
load
size)
to
determine
the
total
quantity
of
waste
disposed
via
land
treatment/
application
farming
for
the
reporting
year.
(
30.00
min/
30.00
min)

33.
Multiply
the
total
quantity
of
waste
disposed
via
land
treatment
by
the
average
concentration
of
the
specific
chemical
in
the
waste
stream
to
calculate
the
total
pounds
of
the
chemical
disposed
of
on­
site
for
land
treatment/
application
farming
during
the
reporting
year.
If
needed,
apply
a
conversion
factor.
Report
the
value
(
lb/
yr)
in
Part
II,
Section
5.5.2.
A
of
the
Form
R.
(
8
min/
8
min)

34.
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
5.5.2.
B
of
the
Form
R.
(
0.25
min/
0.25
min)

The
most
commonly
reported
basis
of
estimate
code
for
releases
via
land
treatment
is
"
O,"
other
approaches,
for
PBT
chemicals.
To
estimate
the
quantity
going
to
on­
site
land
disposal
via
land
treatment/
application
farming
for
PBT
chemicals,
the
technical
staff
would
perform
the
following
steps:

°
Identify
all
waste
streams
disposed
of
via
land
treatment
that
contain
the
chemical
of
Abt
Associates
Inc.
Draft
07/
16/
04
28
interest.
(
30.00
min/
5.00
min)

°
Determining
the
total
quantity
of
waste
disposed
of
via
land
treatment
for
the
reporting
year
requires
the
technical
staff
to
either
talk
to
operations
staff,
review
production
records
and
estimate
waste
generation,
or
review
on­
site
disposal
tracking
records.
(
30.00
min/
30.00
min)

°
Talk
to
operations
staff,
review
any
waste
characterization
information,
or
review
production/
activity
SOPs
and
process
flow
diagrams
to
generate
chemical
concentration
estimates
of
a
specific
chemical
disposed
of
via
land
treatment.
(
30.00
min/
25.00
min)

°
Multiply
the
total
quantity
of
waste
disposed
via
land
treatment
by
the
average
concentration
of
the
specific
chemical
in
the
waste
stream
to
calculate
the
total
pounds
of
the
chemical
disposed
of
via
land
treatment
during
the
reporting
year.
If
needed,
apply
a
conversion
factor.
Report
the
value
(
lb/
yr)
in
Part
II,
Section
5.5.2.
A
of
the
Form
R.
(
6.00
min/
6.00
min)

°
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
5.5.2.
B
of
the
Form
R.
(
0.25
min/
0.25
min)

Reporting
Burden
Associated
with
Part
II,
Section
5.5.2
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Non­
PBT
PBT
Non­
PBT
PBT
Management
2.08
3.08
1.75
1.75
Technical
73.25
96.25
63.25
66.25
Total
75.33
99.33
65.00
68.00
Section
5.5.3A:
RCRA
Subtitle
C
Surface
Impoundments
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
3.08
min/
1.75
min)

The
most
commonly
reported
basis
of
estimate
code
for
releases
via
RCRA
surface
impoundments
is
"
C,"
mass
balance,
for
both
non­
PBT
and
PBT
chemicals.
To
estimate
TRI
chemical
quantities
sent
to
RCRA
landfills,
technical
staff
would
track
the
loss
of
this
chemical
using
a
mass
balance
approach
as
follows:

°
Identify
all
waste
streams
disposed
of
via
RCRA
Subtitle
C
surface
impoundments
that
contain
the
chemical
of
interest.
(
30.00
min/
5.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
29
°
Determine
the
total
annual
chemical
usage
quantity
through
a
review
of
production
records,
a
review
of
inventory
records,
or
conversations
with
operations
staff.
(
30.00
min/
30.00
min)

°
Estimate
the
quantity
of
the
chemical
that
goes
out
with
the
product
through
a
review
of
product
QA/
QC
data
or
product
specifications,
or
conversations
with
operations
staff.
(
30.00
min/
25.00
min)

°
Subtract
the
quantity
of
the
chemical
in
the
product
from
the
total
chemical
usage
quantity
to
determine
the
total
waste
quantity
via
mass
balance.
If
the
total
waste
quantity
is
not
disposed
of
via
RCRA
surface
impoundment,
the
total
waste
quantity
is
multiplied
by
the
percentage
of
waste
going
to
RCRA
surface
impoundments.
If
needed,
apply
a
conversion
factor.
Report
the
value
(
lb/
yr)
in
Part
II,
Section
5.5.3A.
A
of
the
Form
R.
(
6.00
min/
6.00
min)

°
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
5.5.3A.
B
of
the
Form
R.
(
0.25
min/
0.25
min)

Reporting
Burden
Associated
with
Part
II,
Section
5.5.3A
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
3.08
1.75
Technical
96.25
66.25
Total
99.33
68.00
Section
5.5.3B:
Other
Surface
Impoundments
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
3.08
min/
1.75
min)

The
most
commonly
reported
basis
of
estimate
code
for
releases
via
other
surface
impoundments
is
"
C,"
mass
balance,
for
both
non­
PBT
and
PBT
chemicals.
To
estimate
TRI
chemical
quantities
sent
to
other
surface
impoundments,
technical
staff
would
track
the
loss
of
this
chemical
using
a
mass
balance
approach
as
follows:

°
Identify
all
waste
streams
disposed
of
via
other
surface
impoundments
that
contain
the
chemical
of
interest
through
a
review
of
process
flow
diagrams,
conversations
with
operations
staff,
or
a
visual
inspection
of
the
process
area.
(
30.00
min/
5.00
min)

°
Determine
the
total
annual
chemical
usage
quantity
through
a
review
of
production
records,
a
review
of
inventory
records,
or
conversations
with
operations
staff.
(
30.00
Abt
Associates
Inc.
Draft
07/
16/
04
30
min/
30.00
min)

°
Estimate
the
quantity
of
chemical
that
goes
out
with
the
product
through
a
review
of
product
QA/
QC
data
or
product
specifications,
or
conversations
with
operations
staff.
(
30.00
min/
25.00
min)

°
Subtract
the
quantity
of
the
chemical
in
the
product
from
the
total
chemical
usage
quantity
to
determine
the
total
waste
quantity
via
mass
balance.
If
the
total
waste
quantity
is
not
disposed
of
via
non­
RCRA
surface
impoundment,
the
total
waste
quantity
is
multiplied
by
the
percentage
of
waste
going
to
non­
RCRA
surface
impoundments.
If
needed,
apply
a
conversion
factor.
Report
the
value
(
lb/
yr)
in
Part
II,
Section
5.5.3B.
A
of
the
Form
R.
(
6.00
min/
6.00
min)

°
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
5.5.3B.
B
of
the
Form
R.
(
0.25
min/
0.25
min)

Reporting
Burden
Associated
with
Part
II,
Section
5.5.3B
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
3.08
1.75
Technical
96.25
66.25
Total
99.33
68.00
Section
5.5.4:
Other
On­
Site
Land
Disposal
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
1.08
min/
0.91
min)

Other
on­
site
land
disposal
can
include
intentional
storage
of
wastes
on
land
(
other
than
in
landfills,
surface
impounds
or
via
land
treatment/
application
farming),
or
unplanned
releases
to
land
from
spills
and
accidents.
Best
engineering
judgement
indicates
that
reporting
in
this
category
is
primarily
due
to
unplanned
releases
from
spills
and
accidents.
While
time
estimates
are
provided
for
both
scenarios,
the
time
allotted
to
this
data
element
for
the
overall
Form
R
realistic
burden
estimate
is
from
the
unplanned
release
scenario
only.

The
most
commonly
reported
basis
of
estimate
code
for
other
on­
site
land
disposal
is
"
O,"
other
approaches,
for
both
non­
PBT
and
PBT
chemicals.
It
is
assumed
that
the
approach
used
by
technical
staff
would
be
to
track
the
generation
and
on­
site
disposal
of
these
wastes
as
follows:
Abt
Associates
Inc.
Draft
07/
16/
04
31
For
planned
other
on­
site
disposal
to
land:

°
Identify
all
waste
streams
disposed
of
via
other
land
disposal
that
contain
the
chemical
of
interest.
(
30.00
min/
5.00
min)

°
Talk
to
operations
staff,
review
production
records
and
estimate
waste
generation,
or
review
on­
site
disposal
tracking
records
to
determine
the
total
quantity
of
waste
disposed
of
via
other
land
disposal
for
the
reporting
year.
(
30.00
min/
30.00
min)

°
Talk
to
operations
staff,
review
any
waste
characterization
information,
or
review
production/
activity
SOPs
and
process
flow
diagrams
to
generate
chemical
concentration
estimates
of
a
specific
chemical
disposed
of
via
other
land
disposal.
(
30.00
min/
25.00
min)

°
For
planned
releases,
multiply
the
total
quantity
of
waste
disposed
via
surface
impoundment
by
the
average
concentration
of
the
specific
chemical
in
the
waste
stream
to
calculate
the
total
release
pounds
of
the
chemical
disposed
of
via
other
land
disposal
during
the
reporting
year.
If
needed,
apply
a
conversion
factor.
(
6.00
min/
6.00
min)

For
unplanned
other
on­
site
disposal
to
land:

°
For
unplanned
releases,
determine
the
total
quantity
of
the
chemical
released
to
land
during
unplanned
events,
such
as
spills
and
accidents,
by
either
reviewing
spill
reports,
contacting
spill
responders,
or
conducting
a
mass
balance
estimate
based
upon
the
quantity
of
materials
in
storage
tanks
before
and
after
the
event.
Report
the
value
(
lb/
yr)
in
Part
II,
Section
5.5.4.
A
of
the
Form
R.
(
35.00
min/
35.00
min)

°
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
5.5.4.
B
of
the
Form
R.
(
0.25
min/
0.25
min)

Best
engineering
judgment
indicates
that
most
reporting
in
this
section
will
come
from
unplanned
(
accidental)
releases.
As
such,
the
following
table
only
provides
time
estimates
relevant
to
the
reporting
of
these
releases.

Reporting
Burden
Associated
with
Part
II,
Section
5.5.4
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
1.08
0.91
Technical
35.25
35.25
Total
36.33
36.16
Abt
Associates
Inc.
Draft
07/
16/
04
32
Section
6.1:
Discharges
to
Publicly
Owned
Treatment
Works
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
3.58
min/
2.25
min)

The
most
commonly
reported
basis
of
estimate
code
for
discharges
to
POTWs
is
"
M,"
use
of
monitoring
data,
for
both
non­
PBTs
and
PBTs.
To
estimate
the
total
quantity
of
a
TRI
chemical
discharged
to
a
POTW,
technical
staff
would
perform
the
following
steps:

°
Locate
and
review
monitoring
data
in
order
to
identify
the
necessary
chemical
concentration
information.
The
monitoring
data
could
be
obtained
by
either
reviewing
internal
files
or
speaking
directly
with
the
pre­
treatment
coordinator
at
the
POTW.
(
35.00
min/
25.00
min)

°
Review
flow
meter
data
to
locate
flow
rate
data.
If
flow
meter
data
are
not
available,
technical
staff
estimate
the
quantity
of
wastewater
generated
by
reviewing
water
usage
data.
This
quantity
is
then
divided
by
usage
time
(
e.
g.,
days)
in
order
to
calculate
the
estimated
flow.
Alternatively,
technical
staff
might
request
flow
rate
data
directly
from
the
POTW.
(
15.00
min/
10.00
min)

°
Talk
with
operations
staff
or
contact
the
POTW
to
determine
the
number
of
days
wastewater
was
sent
to
the
POTW.
(
15.00
min/
15.00
min)

°
Multiply
the
identified
chemical
concentration
(
for
one
monitoring
data
point)
by
the
daily
water
flow
rate
to
calculate
the
total
mass
of
the
chemical
transferred
to
the
POTW
on
a
daily
basis.
If
needed,
locate
a
conversion
factor
in
order
to
report
the
final
result
in
units
of
pounds
per
day.
Repeat
the
above
steps
for
every
monitoring
result,
then
average
together
all
of
the
results.
Multiply
the
pound
per
day
release
value
by
the
total
number
of
discharge
days
per
year
to
calculate
the
total
annual
transfers
to
POTWs
in
pounds.
Report
the
value
(
lb/
yr)
in
Part
II,
Section
6.1.
A.
1
of
the
Form
R.
(
8.00
min/
8.00
min)

°
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Part
II,
Section
6.1.
A.
2
of
the
Form
R.
(
0.25
min/
0.25
min)

An
analysis
of
the
RY
2002
showed
that
an
average
of
one
POTW
per
Form
R
was
listed
for
both
non­
PBT
and
PBT
chemicals.
For
subsequent
year
reporting,
it
is
assumed
the
facility
will
be
using
the
same
POTW.

°
Technical
staff
will
have
the
POTW
name
and
location
information
readily
available
from
document
review
conducted
for
the
release
estimate.
Technical
staff
will
report
this
information
in
Part
II,
Section
6.1.
B.
1
of
the
Form
R.
(
1.50
min/
0
min)
Abt
Associates
Inc.
Draft
07/
16/
04
33
Reporting
Burden
Associated
with
Part
II,
Section
6.1
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
3.58
2.25
Technical
74.75
58.25
Total
78.33
60.50
Section
6.2:
Transfers
to
Other
Off­
Site
Locations
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
4.83
min/
3.42
min)

The
most
commonly
reported
basis
of
estimate
code
for
transfers
to
other
off­
site
locations
is
"
O,"
other
approaches,
for
both
non­
PBT
and
PBT
chemicals.
It
is
assumed
that
the
approach
used
by
technical
staff
would
be
to
track
the
off­
site
transfer
of
these
wastes
primarily
using
waste
characterization
and
waste
transfer
documentation
as
outlined
below:

°
Identify
all
off­
site
transfers
of
unique
waste
streams
containing
the
chemical
of
interest.
(
30.00
min/
5.00
min)

°
For
the
first
unique
waste
stream,
determine
the
concentration
of
the
chemical
in
the
stream
by
either
reviewing
waste
characterization
profiles,
contacting
the
facility's
hazardous
waste
shipper
to
obtain
their
waste
characterization
information,
or
conducting
a
mass
balance
evaluation.
(
30.00
min/
30.00
min)

°
Determine
the
total
quantity
of
the
first
unique
waste
stream
that
the
facility
ships
off­
site
during
the
reporting
year
by
reviewing
hazardous
waste
manifests,
invoices
from
waste
vendors,
or
talking
to
operations
staff.
(
30.00
min/
30.00
min)

°
For
the
first
waste
stream,
multiply
the
chemical
concentration
by
the
total
quantity
of
waste
shipped
off­
site
to
calculate
the
total
quantity
of
the
chemical
shipped
off­
site
for
the
year.
If
needed,
multiply
by
a
conversion
factor
to
obtain
a
final
result
in
pounds.
(
6.00
min/
6.00
min)

An
analysis
of
RY
2002
TRI
data
indicates
that
there
was
an
average
of
approximately
two
offsite
transfer
locations
and
an
average
of
approximately
two
reported
"
M"
codes.
Therefore,
it
is
assumed
that
on
average,
two
unique
waste
streams
are
being
transferred
off­
site.
There
are
economies
of
scale
in
estimating
the
quantity
of
the
TRI
chemical
in
the
second
waste
stream
due
to
the
concurrent
activities
of
reviewing
the
same
sources
to
determine
the
chemical
concentration
in
the
waste
and
to
estimate
the
annual
quantity
of
waste
transferred
off­
site.
To
estimate
the
additional
time
needed
to
quantify
the
off­
site
transfer
of
the
second
waste
stream
technical
staff
would
perform
the
following:
Abt
Associates
Inc.
Draft
07/
16/
04
34
°
For
the
second
waste
stream,
determine
the
concentration
of
the
chemical
in
the
stream
by
either
reviewing
waste
characterization
profiles,
contacting
the
facility's
hazardous
waste
shipper
to
obtain
their
waste
characterization
information,
or
conducting
a
mass
balance
evaluation.
Determine
the
total
quantity
of
each
unique
waste
stream
that
the
facility
ships
off­
site
during
the
reporting
year.
(
5.00
min/
5.00
min)

°
For
the
second
waste
stream,
multiply
the
chemical
concentration
by
the
total
quantity
of
waste
shipped
off­
site
to
calculate
the
total
quantity
of
the
chemical
shipped
off­
site
for
the
year.
If
needed,
multiply
by
a
conversion
factor
to
obtain
a
final
result
in
pounds.
Calculate
the
total
quantity
of
the
chemical
shipped
off­
site
for
all
waste
streams
by
summing
together
the
annual
quantity
of
the
chemical
shipped
off­
site
in
each
waste
stream.
Report
this
result
(
lb/
yr)
in
Part
II,
Section
6.2.
A
of
the
Form
R.
(
6.00
min/
6.00
min)

For
both
waste
streams,
technical
staff
would
perform
the
following
steps:

°
Report
whether
the
release
estimate
was
based
on
monitoring
data,
mass
balance,
published
emission
factor,
or
other
engineering
calculations
by
recording
the
code
M,
C,
E,
or
O,
respectively,
in
Section
6.2.
B
of
the
Form
R.
(
0.25
min/
0.25
min)

°
Report
the
type
of
waste
treatment/
disposal/
recycling/
energy
recovery
code
by
recording
the
appropriate
M­
code
in
Section
6.2.
C
of
the
Form
R.
(
0.25
min/
0.25
min)

As
indicated
above,
an
analysis
of
RY
2002
TRI
data
showed
that
for
off­
site
transfers,
there
was
an
average
of
approximately
two
off­
site
transfer
locations.
For
subsequent
year
reporting,
it
is
assumed
the
facility
will
not
necessarily
use
the
same
off­
site
transfer
locations.
Due
to
the
competitive
nature
of
the
hazardous
waste
removal
industry,
market
fluctuations,
the
search
for
better
pricing,
and
the
fact
that
facilities
can
readily
change
vendors
(
unlike
piping
changes
needed
to
use
a
different
POTW,
for
example),
it
is
possible
that
facilities
may
be
using
different
off­
site
transfer
locations
from
year­
to­
year.
For
this
reason,
it
is
not
assumed
that
only
one
off­
site
transfer
facility
name
and
location
will
be
pre­
populated
from
loading
last
year's
forms,
and
typing
time
is
allotted
to
enter
the
second
off­
site
transfer
name
and
location
information.

°
Technical
staff
will
have
the
off­
site
transfer
name
and
location
information
readily
available
from
document
review
conducted
for
the
release
estimate
and
will
report
this
information
in
Part
II,
Section
6.2.1
and
6.2.2
of
the
Form
R.
(
4.17
min/
2.08
min)
Abt
Associates
Inc.
Draft
07/
16/
04
35
Reporting
Burden
Associated
with
Part
II,
Section
6.2
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
4.83
3.42
Technical
112.17
84.58
Total
117.00
88.00
Section
7A:
On­
Site
Waste
Treatment
Methods
and
Efficiency
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
5.17
min/
3.50min)

To
complete
Section
7A,
technical
staff
perform
the
following
steps:

°
Review
process
diagrams,
review
air
or
NPDES
permits,
or
talk
to
the
operations
staff
to
identify
any
on­
site
waste
treatment
activities.
For
the
first
waste
stream,
technical
staff
perform
the
following
steps:

°
Identify
the
type
of
waste
stream
(
gaseous,
wastewater,
liquid
waste,
or
solid
waste)
and
report
the
appropriate
code
in
Part
II,
Section
7A.
1a.
(
10.00
min/
5.00
min)

°
Identify
all
of
the
treatment
steps
this
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
report
them
in
the
actual
order
of
occurrence
in
Part
II,
Section
7A.
1b
of
the
Form
R..
(
20.00
min/
5.00
min)

°
Locate
and
review
monitoring
data,
or
talk
with
operations
staff
to
determine
the
range
of
influent
concentration.
Report
the
appropriate
range
code
for
this
concentration
in
Part
II,
Section
7A.
1.
c
of
the
Form
R.
(
30.00
min/
15.00
min)

°
Technical
staff
apply
one
of
the
approaches
listed
below
to
quantify
the
treatment
efficiency:

°
Review
equipment
manuals
for
manufacturer
reported
efficiencies.

°
Use
pre­
and
post­
treatment
analytical
data
to
calculate
treatment
efficiency
by
subtracting
the
post­
treatment
chemical
concentration
from
the
pre­
treatment
chemical
concentration
and
then
divide
the
result
by
the
pre­
treatment
chemical
concentration.

°
Technical
staff
can
also
obtain
the
information
by
talking
to
operations
staff.
Abt
Associates
Inc.
Draft
07/
16/
04
36
°
Report
the
treatment
efficiency
in
Part
II,
Section
7A.
1.
d
of
the
Form
R
(
15.00
min/
5.00
min).

°
Report
whether
the
efficiency
was
calculated
using
monitoring
data
by
checking
yes
or
no
in
Part
II,
Section
7A.
1e
of
the
Form
R.
(
0.08
min/
0.08
min)

An
analysis
of
RY
2002
TRI
data
indicates
that
there
was
an
average
of
approximately
two
waste
streams
listed
under
on­
site
treatment
in
Section
7A.
The
additional
steps
technical
staff
would
take
in
identifying
and
reporting
on­
site
treatment
activities
are
outlined
below.
There
are
some
economies
of
scale
in
identifying
on­
site
treatment
activities
for
the
second
waste
stream
as
a
full
facility
operations
review
was
conducted
as
part
of
identifying
if
there
are
any
waste
streams
undergoing
on­
site
treatment.

°
No
additional
time
would
be
needed
to
identify
types
of
waste
streams
undergoing
on­
site
treatment
as
the
necessary
review
was
already
conducted
to
identify
the
first
waste
stream.
Therefore,
no
additional
time
is
needed
in
Part
II,
Section
7A.
2a
for
the
second
waste
stream
(
0.00min/
0.00min).

°
Only
incremental
additional
time
would
be
needed
to
identify
waste
treatment
activity
steps
for
the
second
waste
stream
as
document
review
and
discussions
with
operations
staff
were
already
conducted
to
identify
steps
for
the
first
waste
stream.
Therefore,
the
following
additional
time
is
needed
in
Part
II,
Section
7A.
2b
for
the
second
waste
stream
(
5.00min/
2.00min).

°
Determining
the
range
of
the
influent
concentration
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
laboratory
reports.
Therefore,
the
following
additional
time
is
needed
in
Part
II,
Section
7A.
2c
for
the
second
waste
stream
(
30.00min/
15.00min).

°
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).

°
Report
whether
the
efficiency
for
the
second
waste
stream
was
calculated
using
monitoring
data
by
checking
yes
or
no
in
Part
II,
Section
7A.
2e
of
the
Form
R,.
(
0.08
min/
0.08
min)
Abt
Associates
Inc.
Draft
07/
16/
04
37
Reporting
Burden
Associated
with
Part
II,
Section
7A
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
5.17
3.50
Technical
125.16
52.16
Total
130.33
55.66
Section
7B:
On­
Site
Energy
Recovery
Processes
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
1.0
min/
0.83
min)

It
is
assumed
that
technical
staff
either
review
process
flow
diagrams
or
talk
to
operations
staff
in
order
to
identify
any
on­
site
energy
recovery
activities.
For
each
waste
stream
that
is
undergoing
treatment
for
on­
site
energy
recovery,
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
energy
recycled
in
Part
II,
Section
7B
of
the
Form
R.
(
32.00
min/
24.00
min)

Reporting
Burden
Associated
with
Part
II,
Section
7B
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
1.00
0.83
Technical
32.00
24.00
Total
33.00
24.83
Section
7C:
On­
Site
Recycling
Processes
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
1.0
min/
0.83
min)

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/
27.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
38
Reporting
Burden
Associated
with
Part
II,
Section
7C
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
1.00
0.83
Technical
38.00
27.00
Total
39.00
27.83
Section
8.1a:
Total
On­
Site
Disposal
to
Class
I
Underground
Injection
Wells,
RCRA
Subtitle
C
Landfills,
and
Other
Landfills
Management
burden
includes
an
assessment
of
whether
quantities
previously
calculated
for
Sections
5
and
6
have
been
recorded
in
the
correct
subsection
of
Section
8
as
well
as
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.50
min/
0.50
min)

Four
columns
must
be
completed
in
this
section,
requiring
technical
staff
to
perform
the
following
steps:

°
Column
A:
Record
"
NA"
in
Part
II,
Section
8.1a,
Column
A
of
the
Form
R
if
the
facility
is
a
first
time
filer.
For
subsequent
reporting
years,
locate
the
release
estimate
from
the
"
Column
B,
Current
Reporting
Year"
column
from
the
previous
year's
form
and
record
this
quantity
in
Part
II,
Section
8.1a,
Column
A
of
the
Form
R.
(
0.25
min/
0.25
min)

°
Column
B:
Sum
together
the
quantities
calculated
in
Part
II,
Sections
5.4.1,
5.5.1A,
and
5.5.1B
and
then
subtract
any
on­
site
release
or
disposal
quantities
due
to
catastrophic
events.
Report
the
total
quantity
disposed
of
on­
site
via
Class
I
Underground
Injection
Wells,
RCRA
Subtitle
C
landfills,
and
other
landfills
in
Part
II,
Section
8.1a,
Column
B
of
the
Form
R.
(
5.00
min/
5.00
min)

°
Column
C:
Make
the
best
projection
for
the
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.1a,
Column
C
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
for
how
much
this
will
reduce
the
release
quantity
for
the
following
year.
(
1.00
min/
1.00
min)

°
Column
D:
Make
the
best
projection
for
the
second
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.1a,
Column
D
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
second
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
of
how
much
this
will
reduce
the
release
quantity
for
the
second
following
year.
(
1.00
min/
1.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
39
Reporting
Burden
Associated
with
Part
II,
Section
8.1a
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.50
0.50
Technical
7.25
7.25
Total
7.75
7.75
Section
8.1b:
Total
Other
On­
Site
Disposal
or
Other
Releases
Management
burden
includes
an
assessment
of
whether
quantities
previously
calculated
for
Sections
5
and
6
have
been
recorded
in
the
correct
subsection
of
Section
8
as
well
as
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.50
min/
0.50
min)

Four
columns
must
be
completed
in
this
section,
requiring
technical
staff
to
perform
the
following
steps:

°
Column
A:
Record
"
NA"
in
Part
II,
Section
8.1b,
Column
A
of
the
Form
R
if
the
facility
is
a
first
time
filer.
For
subsequent
reporting
years,
locate
the
release
estimate
from
the
"
Column
B,
Current
Reporting
Year"
column
from
the
previous
year's
form
and
record
this
quantity
in
Part
II,
Section
8.1b,
Column
A
of
the
Form
R.
(
0.25
min/
0.25
min)

°
Column
B:
Sum
together
the
quantities
calculated
in
Part
II,
Sections
5.1,
5.2,
5.3,
5.4.2,
5.5.2,
5.5.3A,
5.5.3B,
and
5.5.4
and
then
subtract
any
on­
site
release
or
disposal
quantities
due
to
catastrophic
events.
Report
the
total
quantity
disposed
of
on­
site
via
other
disposal
or
other
releases
in
Part
II,
Section
8.1b,
Column
B
of
the
Form
R.
(
5.00
min/
5.00
min)

°
Column
C:
Make
the
best
projection
for
the
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.1b,
Column
C
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
for
how
much
this
will
reduce
the
release
quantity
for
the
following
year.
(
1.00
min/
1.00
min)

°
Column
D:
Make
the
best
projection
for
the
second
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.1b,
Column
D
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
second
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
of
how
much
this
will
reduce
the
release
quantity
for
the
second
following
year.
(
1.00
min/
1.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
40
Reporting
Burden
Associated
with
Part
II,
Section
8.1b
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.5
0.50
Technical
7.25
7.25
Total
7.75
7.75
Section
8.1c:
Total
Off­
Site
Disposal
to
Class
I
Underground
Injection
Wells,
RCRA
Subtitle
C
Landfills,
and
Other
Landfills
Management
burden
includes
an
assessment
of
whether
quantities
previously
calculated
for
Sections
5
and
6
have
been
recorded
in
the
correct
subsection
of
Section
8
as
well
as
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.50
min/
0.50
min)

Four
columns
must
be
completed
in
this
section,
requiring
technical
staff
to
perform
the
following
steps:

°
Column
A:
Record
"
NA"
in
Part
II,
Section
8.1c,
Column
A
of
the
Form
R
if
the
facility
is
a
first
time
filer.
For
subsequent
reporting
years,
locate
the
release
estimate
from
the
"
Column
B,
Current
Reporting
Year"
column
from
the
previous
year's
form
and
record
this
quantity
in
Part
II,
Section
8.1c,
Column
A
of
the
Form
R.
(
0.25
min/
0.25
min)

°
Column
B:
Sum
together
the
quantities
calculated
in
Part
II,
Sections
6.1
(
portion
of
transfer
that
is
untreated
and
ultimately
disposed
of
in
UIC
Class
I
Wells,
RCRA
Subtitle
C
landfills
and
other
landfills)
and
6.2
(
quantities
associated
with
M
codes
M64,
M65,
and
M81)
and
then
subtract
any
off­
site
disposal
quantities
due
to
catastrophic
events.
Report
the
total
quantity
disposed
of
off­
site
via
Class
I
Underground
Injection
Wells,
RCRA
Subtitle
C
landfills,
and
other
landfills
in
Part
II,
Section
8.1c,
Column
B
of
the
Form
R.
(
5.00
min/
5.00
min)

°
Column
C:
Make
the
best
projection
for
the
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.1c,
Column
C
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
for
how
much
this
will
reduce
the
release
quantity
for
the
following
year.
(
1.00
min/
1.00
min)

°
Column
D:
Make
the
best
projection
for
the
second
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.1c,
Column
D
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
second
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
of
how
much
this
will
reduce
the
release
quantity
for
the
second
following
year.
(
1.00
min/
1.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
41
Reporting
Burden
Associated
with
Part
II,
Section
8.1c
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.5
0.50
Technical
7.25
7.25
Total
7.75
7.75
Section
8.1d:
Total
Other
Off­
Site
Disposal
or
Other
Releases
Management
burden
includes
an
assessment
of
whether
quantities
previously
calculated
for
Sections
5
and
6
have
been
recorded
in
the
correct
subsection
of
Section
8
as
well
as
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.50
min/
0.50
min)

Four
columns
must
be
completed
in
this
section,
requiring
technical
staff
to
perform
the
following
steps:

°
Column
A:
Record
"
NA"
in
Part
II,
Section
8.1d,
Column
A
of
the
Form
R
if
the
facility
is
a
first
time
filer.
For
subsequent
reporting
years,
locate
the
release
estimate
from
the
"
Column
B,
Current
Reporting
Year"
column
from
the
previous
year's
form
and
record
this
quantity
in
Part
II,
Section
8.1d,
Column
A
of
the
Form
R.
(
0.25
min/
0.25
min)

°
Column
B:
Sum
together
the
quantities
calculated
in
Part
II,
Sections
6.1
(
portion
of
transfer
that
is
untreated
and
ultimately
disposed
of
in
UIC
Class
II­
V
Wells,
and
land
disposal
other
than
to
landfills)
and
6.2
(
quantities
associated
with
M
codes
M10,
M41,
M62,
M66,
M67,
M73,
M79,
M82,
M90,
M94,
and
M99)
and
then
subtract
any
off­
site
disposal
quantities
due
to
catastrophic
events.
Report
the
total
quantity
disposed
of
offsite
via
other
disposal
or
other
releases
in
Part
II,
Section
8.1d,
Column
B
of
the
Form
R.
(
5.00
min/
5.00
min)

°
Column
C:
Make
the
best
projection
for
the
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.1d,
Column
C
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
for
how
much
this
will
reduce
the
release
quantity
for
the
following
year.
(
1.00
min/
1.00
min)

°
Column
D:
Make
the
best
projection
for
the
second
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.1d,
Column
D
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
second
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
of
how
much
this
will
reduce
the
release
quantity
for
the
second
following
year.
(
1.00
min/
1.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
42
Reporting
Burden
Associated
with
Part
II,
Section
8.1d
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.50
0.50
Technical
7.25
7.25
Total
7.75
7.75
Section
8.2:
Quantity
Used
for
Energy
Recovery
On­
Site
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
1.25
min/
1.08
min)

Four
columns
must
be
completed
in
this
section,
requiring
technical
staff
to
perform
the
following
steps:

°
Column
A:
Record
"
NA"
in
Part
II,
Section
8.2,
Column
A
of
the
Form
R
if
the
facility
is
a
first
time
filer.
For
subsequent
reporting
years,
locate
the
release
estimate
from
the
"
Column
B,
Current
Reporting
Year"
column
from
the
previous
year's
form
and
record
this
quantity
in
Part
II,
Section
8.2,
Column
A
of
the
Form
R.
(
0.25
min/
0.25
min)

°
Column
B:
To
estimate
the
quantity
of
the
chemical
used
annually
for
actual
energy
recovery
on­
site,
refer
to
the
recovery
processes
reported
in
Section
7B
and
either
review
operations
records
or
speak
with
operations
staff.
Report
the
total
quantity
used
for
energy
recovery
on­
site
in
Part
II,
Section
8.2,
Column
B
of
the
Form
R.
(
30.00
min/
30.00
min)

°
Column
C:
Make
the
best
projection
for
the
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.2,
Column
C
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
for
how
much
this
will
reduce
the
release
quantity
for
the
following
year.
(
1.00
min/
1.00
min)

°
Column
D:
Make
the
best
projection
for
the
second
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.2,
Column
D
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
second
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
of
how
much
this
will
reduce
the
release
quantity
for
the
second
following
year.
(
1.00
min/
1.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
43
Reporting
Burden
Associated
with
Part
II,
Section
8.2
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
1.25
1.08
Technical
32.25
32.25
Total
33.50
33.33
Section
8.3:
Quantity
Used
for
Energy
Recovery
Off­
Site
Management
burden
includes
an
assessment
of
whether
quantities
previously
calculated
for
Sections
5
and
6
have
been
recorded
in
the
correct
subsection
of
Section
8
as
well
as
proofreading
of
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.50
min/
0.50
min)

Four
columns
must
be
completed
in
this
section,
requiring
technical
staff
to
perform
the
following
steps:

°
Column
A:
Record
"
NA"
in
Part
II,
Section
8.3,
Column
A
of
the
Form
R
if
the
facility
is
a
first
time
filer.
For
subsequent
reporting
years,
locate
the
release
estimate
from
the
"
Column
B,
Current
Reporting
Year"
column
from
the
previous
year's
form
and
record
this
quantity
in
Part
II,
Section
8.3,
Column
A
of
the
Form
R.
(
0.25
min/
0.25
min)

°
Column
B:
To
estimate
the
quantity
of
the
chemical
used
annually
for
energy
recovery
off­
site,
subtract
Section
8.8
(
off­
site
energy
recovery
due
to
catastrophic
events)
from
Section
6.2
(
quantities
associated
with
energy
recovery)
and
report
the
value
in
Part
II,
Section
8.3,
Column
B
of
the
Form
R.
(
5.00
min/
5.00
min)

°
Column
C:
Make
the
best
projection
for
the
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.3,
Column
C
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
for
how
much
this
will
reduce
the
release
quantity
for
the
following
year.
(
1.00
min/
1.00
min)

°
Column
D:
Make
the
best
projection
for
the
second
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.3,
Column
D
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
second
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
of
how
much
this
will
reduce
the
release
quantity
for
the
second
following
year.
(
1.00
min/
1.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
44
Reporting
Burden
Associated
with
Part
II,
Section
8.3
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.5
0.50
Technical
7.25
7.25
Total
7.75
7.75
Section
8.4:
Quantity
Recycled
On­
Site
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
1.25
min/
1.08
min)

Four
columns
must
be
completed
in
this
section,
requiring
technical
staff
to
perform
the
following
steps:

°
Column
A:
Record
"
NA"
in
Part
II,
Section
8.4,
Column
A
of
the
Form
R
if
the
facility
is
a
first
time
filer.
For
subsequent
reporting
years,
locate
the
release
estimate
from
the
"
Column
B,
Current
Reporting
Year"
column
from
the
previous
year's
form
and
record
this
quantity
in
Part
II,
Section
8.4,
Column
A
of
the
Form
R.
(
0.25
min/
0.25
min)

°
Column
B:
Estimate
the
quantity
of
the
chemical
actually
recycled
on­
site
annually
by
reviewing
the
information
identified
for
Section
7C
and
either
review
operations
records
or
speak
with
operations
staff.
Report
the
total
quantity
recycled
on­
site
in
Part
II,
Section
8.4,
Column
B
of
the
Form
R.
(
30.00
min/
30.00
min)

°
Column
C:
Make
the
best
projection
for
the
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.4,
Column
C
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
for
how
much
this
will
reduce
the
release
quantity
for
the
following
year.
(
1.00
min/
1.00
min)

°
Column
D:
Make
the
best
projection
for
the
second
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.4,
Column
D
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
second
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
of
how
much
this
will
reduce
the
release
quantity
for
the
second
following
year.
(
1.00
min/
1.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
45
Reporting
Burden
Associated
with
Part
II,
Section
8.4
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
1.25
1.08
Technical
32.25
32.25
Total
33.50
33.33
Section
8.5:
Quantity
Recycled
Off­
Site
Management
burden
includes
an
assessment
of
whether
quantities
previously
calculated
for
Sections
5
and
6
have
been
recorded
in
the
correct
subsection
of
Section
8
as
well
as
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.50
min/
0.50
min)

Four
columns
must
be
completed
in
this
section,
requiring
technical
staff
to
perform
the
following
steps:

°
Column
A:
Record
"
NA"
in
Part
II,
Section
8.5,
Column
A
of
the
Form
R
if
the
facility
is
a
first
time
filer.
For
subsequent
reporting
years,
locate
the
release
estimate
from
the
"
Column
B,
Current
Reporting
Year"
column
from
the
previous
year's
form
and
record
this
quantity
in
Part
II,
Section
8.5,
Column
A
of
the
Form
R.
(
0.25
min/
0.25
min)

°
Column
B:
To
estimate
the
quantity
of
the
chemical
recycled
annually
off­
site,
subtract
Section
8.8
(
off­
site
recycling
due
to
catastrophic
events)
from
Section
6.2
(
quantities
associated
with
recycling)
and
report
the
value
in
Part
II,
Section
8.5,
Column
B
of
the
Form
R.
(
5.00
min/
5.00
min)

°
Column
C:
Make
the
best
projection
for
the
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.5,
Column
C
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
for
how
much
this
will
reduce
the
release
quantity
for
the
following
year.
(
1.00
min/
1.00
min)

°
Column
D:
Make
the
best
projection
for
the
second
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.5,
Column
D
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
second
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
of
how
much
this
will
reduce
the
release
quantity
for
the
second
following
year.
(
1.00
min/
1.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
46
Reporting
Burden
Associated
with
Part
II,
Section
8.5
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.5
0.50
Technical
7.25
7.25
Total
7.75
7.75
Section
8.6:
Quantity
Treated
On­
Site
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
estimate.
In
some
cases
it
also
includes
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
1.25
min/
1.08
min)

Four
columns
must
be
completed
in
this
section,
requiring
technical
staff
to
perform
the
following
steps:

°
Column
A:
Record
"
NA"
in
Part
II,
Section
8.6,
Column
A
of
the
Form
R
if
the
facility
is
a
first
time
filer.
For
subsequent
reporting
years,
locate
the
release
estimate
from
the
"
Column
B,
Current
Reporting
Year"
column
from
the
previous
year's
form
and
record
this
quantity
in
Part
II,
Section
8.6,
Column
A
of
the
Form
R.
(
0.25
min/
0.25
min)

°
Column
B:
Estimate
the
quantity
of
the
chemical
actually
treated
on­
site
annually
by
reviewing
the
information
identified
for
Section
7A
and
either
review
operations
records
or
speak
with
operations
staff.
The
total
quantity
treated
on­
site
is
reported
in
Part
II,
Section
8.6,
Column
B
of
the
Form
R.
(
30.00
min/
30.00
min)

°
Column
C:
Make
the
best
projection
for
the
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.6,
Column
C
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
for
how
much
this
will
reduce
the
release
quantity
for
the
following
year.
(
1.00
min/
1.00
min)

°
Column
D:
Make
the
best
projection
for
the
second
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.6,
Column
D
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
second
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
of
how
much
this
will
reduce
the
release
quantity
for
the
second
following
year.
(
1.00
min/
1.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
47
Reporting
Burden
Associated
with
Part
II,
Section
8.6
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
1.25
1.08
Technical
32.25
32.25
Total
33.50
33.33
Section
8.7:
Quantity
Treated
Off­
Site
Management
burden
includes
an
assessment
of
whether
quantities
previously
calculated
for
Sections
5
and
6
have
been
recorded
in
the
correct
subsection
of
Section
8
as
well
as
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.50
min/
0.50
min)

Four
columns
must
be
completed
in
this
section,
requiring
technical
staff
to
perform
the
following
steps:

°
Column
A:
Record
"
NA"
in
Part
II,
Section
8.7,
Column
A
of
the
Form
R
if
the
facility
is
a
first
time
filer.
For
subsequent
reporting
years,
locate
the
release
estimate
from
the
"
Column
B,
Current
Reporting
Year"
column
from
the
previous
year's
form
and
record
this
quantity
in
Part
II,
Section
8.7,
Column
A
of
the
Form
R.
(
0.25
min/
0.25
min)

°
Column
B:
To
estimate
the
quantity
of
the
chemical
treated
off­
site,
sum
together
the
quantities
from
Section
6.1
(
excluding
most
metal/
metal
category
compounds)
and
Section
6.2
(
the
quantities
associated
with
treatment)
and
then
subtract
any
portion
of
Section
8.8
associated
with
off­
site
treatment
due
to
catastrophic
events.
Report
the
total
quantity
treated
off­
site
in
Part
II,
Section
8.7,
Column
B
of
the
Form
R.
(
5.00
min/
5.00
min)

°
Column
C:
Make
the
best
projection
for
the
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.7,
Column
C
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
for
how
much
this
will
reduce
the
release
quantity
for
the
following
year.
(
1.00
min/
1.00
min)

°
Column
D:
Make
the
best
projection
for
the
second
following
year's
release
quantity
and
record
it
in
Part
II,
Section
8.7,
Column
D
of
the
Form
R.
If
no
source
reduction
activities
are
planned,
multiply
the
current
year
release
estimate
by
the
expected
percentage
change
in
production
for
the
second
following
year.
If
source
reduction
activities
are
planned,
make
the
best
estimate
of
how
much
this
will
reduce
the
release
quantity
for
the
second
following
year.
(
1.00
min/
1.00
min)
Abt
Associates
Inc.
Draft
07/
16/
04
48
Reporting
Burden
Associated
with
Part
II,
Section
8.7
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.50
0.50
Technical
7.25
7.25
Total
7.75
7.75
Section
8.8:
Quantity
released
to
the
Environment
as
a
Result
of
Remedial
Actions,
Catastrophic
Events,
or
One­
Time
Events
not
Associated
with
Production
Processes
Management
burden
includes
an
assessment
of
whether
quantities
previously
calculated
for
Sections
5
and
6
have
been
recorded
in
the
correct
subsection
of
Section
8
as
well
as
proofreading
this
section
as
part
of
an
overall
review
of
the
Form
R.
(
0.25
min/
0.25
min)

Technical
staff
sum
together
the
relevant
quantities
already
estimated
and
record
them
in
Part
II,
Section
8.8,
Column
B
of
the
Form
R.
(
5.00
min/
5.00
min)

Reporting
Burden
Associated
with
Part
II,
Section
8.8
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.25
0.25
Technical
5.00
5.00
Total
5.25
5.25
Section
8.9:
Production
Ratio
or
Activity
Index
Management
burden
includes
review
of
data,
methods,
and
assumptions
used
to
develop
the
production
ratio;
and
in
some
cases,
data
quality
activities
such
as
comparing
the
values
with
previous
years.
(
0.83
min/
0.83
min)

Technical
staff
would
perform
the
following
steps
to
calculate
the
production
ratio
or
activity
index:

°
Determine
the
annual
production
or
activity
level
for
the
reporting
year
by
either
reviewing
production
records
or
maintenance
logs,
or
talking
with
the
operations
staff.
(
30.00
min/
30.00
min)

°
Determine
the
annual
production
or
activity
level
for
the
previous
year
by
reviewing
maintenance
records
or
talking
with
operations
staff.
(
5.00
min/
5.00
min)

°
Divide
the
current
year's
production
or
activity
level
by
the
prior
year's
production
or
activity
level.
Alternatively,
review
the
waste
minimization
section
of
the
RCRA
report.
Abt
Associates
Inc.
Draft
07/
16/
04
49
Report
the
production
ratio
or
activity
index
in
Part
II,
Section
8.9
of
the
Form
R.
(
1.00
min/
1.00
min)

For
facilities
reporting
for
the
first
year,
a
production
ratio
is
required
if
the
facility
manufactured,
processed
or
otherwise
used
the
TRI
chemical
in
the
previous
year,
even
if
no
thresholds
were
exceeded.
While
some
first
year
reports
will
be
for
completely
new
operations,
others
will
be
for
facilities
that
have
exceeded
threshold
for
the
first
time.
For
this
reason,
it
was
assumed
that
calculation
of
the
production
ratio
would
be
required
for
first
year
reports.

Reporting
Burden
Associated
with
Part
II,
Section
8.9
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0.83
0.83
Technical
36.00
36.00
Total
36.83
36.83
Section
8.10:
Did
Your
Facility
Engage
in
any
Source
Reduction
Activities?

Management
burden
includes
review
of
data
and
methods
used
to
identify
source
reduction
activities.
(
1.08
min/
0.92
min)

To
identify
whether
or
not
any
source
reduction
activities
were
implemented,
technical
staff
either
review
SOPs;
review
any
process,
equipment,
or
material
input
changes;
review
the
waste
minimization
section
of
the
RCRA
report;
or
talk
with
operations
staff.
If
source
reduction
activities
were
implemented,
technical
staff
locate
the
source
reduction
codes
in
the
Reporting
Forms
and
Instructions
and
enter
the
codes
in
Section
8.10.1
of
the
Form
R.
Technical
staff
enter
the
appropriate
codes
for
Methods
to
Identify
Activity
in
Section
8.10.1.
a.
(
35.25
min/
35.25
min)

Reporting
Burden
Associated
with
Part
II,
Section
8.10
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
1.08
0.92
Technical
35.25
35.25
Total
36.33
36.17
Section
8.11:
Is
Additional
Information
on
Source
Reduction,
Recycling
or
Pollution
Control
Activities
Included
with
this
Report?

Provision
of
additional
information
on
source
reduction,
recycling,
or
pollution
control
activities
is
optional;
therefore,
there
is
no
management,
technical,
nor
clerical
burden
associated
with
this
element
of
the
Form
R.
Abt
Associates
Inc.
Draft
07/
16/
04
50
Reporting
Burden
Associated
with
Part
II,
Section
8.11
Personnel
Type
First
Year
Burden
(
minutes)
Subsequent
Year
Burden
(
minutes)

Management
0
0.00
Technical
0
0.00
Total
0.00
0.00
2.1.
B.
Results
for
Electronic
Submission
Table
4
summarizes
the
total
reporting
burden
associated
with
electronic
submissions
of
PBT
and
non­
PBT
forms.
Tables
5
and
6
present
the
realistic
and
incidence
weighted
reporting
burden
for
every
data
element
on
the
Form
R
for
first
year
electronic
submissions
of
PBT
and
non­
PBT
reports.
Tables
7
and
8
present
the
realistic
and
incidence
weighted
reporting
burden
for
every
data
element
on
the
Form
R
for
subsequent
year
electronic
submissions
of
PBT
and
non­
PBT
reports.

TABLE
4
TOTAL
REPORTING
BURDEN
FOR
ELECTRONIC
SUBMISSIONS
Estimated
realistic
time
per
form
(
hr)
Incidence
weighted
time
per
form
(
hr)

Management
Technical
Total
Management
Technical
Total
First
year
PBT
0.99
29.51
30.50
0.34
9.20
9.54
Non­
PBT
0.98
29.38
30.36
0.37
10.49
10.86
Subsequent
years
PBT
0.77
20.98
21.75
0.29
6.17
6.46
Non­
PBT
0.77
20.97
21.74
0.32
6.89
7.21
2.1.
C.
Methodology
for
Paper
Submission
The
only
difference
between
electronic
and
paper
submissions
for
first
year
and
subsequent
year
Form
R
reporting
burden
is
clerical
time.
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.
Therefore,
for
both
PBT
and
non­
PBT
chemicals,
clerical
times
were
estimated
by
dividing
the
currently
approved
OMB
clerical
times
(
Table
1)
by
the
total
number
of
fields
on
the
Form
R.
While
it
may
not
take
the
exact
same
amount
of
time
to
line
up
each
data
element
for
typing,
there
is
no
reasonable
way
to
estimate
this,
so
giving
equal
time
to
each
element
was
determined
to
be
the
best
method.
The
clerical
time
allotted
to
each
element
was
then
added
to
the
estimate
for
the
electronic
form
(
including
management
and
technical
time)
for
that
element
to
generate
time
estimates
for
every
data
element
for
PBT
and
non­
PBT
first
and
subsequent
year
reporting
via
a
paper
Form
R.
Abt
Associates
Inc.
Draft
07/
16/
04
51
2.1.
D.
Results
for
Paper
Submission
Table
9
summarizes
the
total
reporting
burden
for
paper
submission
of
PBT
and
non­
PBT
forms.
Tables
10
and
11
present
the
realistic
and
incidence
weighted
reporting
burden
for
every
data
element
on
the
Form
R
for
first
year
paper
submissions
of
PBT
and
non­
PBT
reports.
Tables
12
and
13
present
the
realistic
and
incidence
weighted
reporting
burden
for
every
data
element
on
the
Form
R
for
subsequent
year
paper
submissions
of
PBT
and
non­
PBT
reports.

TABLE
9
TOTAL
REPORTING
BURDEN
FOR
PAPER
SUBMISSIONS
Estimated
realistic
time
per
form
(
hr)
Incidence
weighted
time
per
form
(
hr)

Management
Technical
Clerical
Total
Management
Technical
Clerical
Total
First
year
PBT
1.01
29.51
2.90
33.42
0.35
9.20
1.59
11.14
Non­
PBT
0.99
29.38
1.62
31.99
0.38
10.49
0.93
11.80
Subsequent
years
PBT
0.78
21.17
2.00
23.95
0.30
6.33
1.10
7.73
Non­
PBT
0.78
21.17
1.10
23.05
0.33
7.05
0.63
8.01
3.
SCALED
REPORTING
BURDEN
ESTIMATES
3.1
Scaled
Estimate
for
PBT
Chemicals
In
this
section,
the
realistic
technical
reporting
burden
estimates
developed
for
PBT
chemicals
are
used
in
combination
with
the
currently­
approved
OMB
form
completion
reporting
burden
estimates
to
generate
burden
estimates
for
each
data
element
consistent
with
the
OMB
total.
Four
individual
reporting
burden
scenarios
are
scaled
up:
first
year
electronic,
subsequent
year
electronic,
first
year
paper,
and
subsequent
year
paper.
The
incidence
weighted
values
are
not
used
for
PBT
chemicals
because
the
OMB
burden
estimate
assumes
all
Form
R
fields
are
filled
out
by
all
reporters.

3.1.
A.
Methodology
for
Scaled
PBT
Chemical
Electronic
Submissions
The
OMB­
approved
form
completion
burden
estimates
for
PBT
first
and
subsequent
year
technical
burden
are
45.2
and
30.8
hours,
respectively.
The
following
procedure
was
used
to
scale
the
realistic
electronic
PBT
data
element
burden
estimates
to
these
OMB­
approved
burden
estimates.
Reporting
burden
is
estimated
for
both
first
and
subsequent
years.
Abt
Associates
Inc.
Draft
07/
16/
04
52
°
Technical
reporting
burden
for
data
elements
requiring
only
typing
or
typing
plus
a
quick
information
look­
up
(
such
as
locating
the
facility's
D&
B
number)
was
estimated
(
86.25
min,
13.42
min).
The
times
for
these
steps
were
assumed
static
and,
therefore,
were
not
scaled
up.

°
Total
static
time
was
subtracted
from
both
the
OMB
approved
technical
burden
(
2712.0
min,
1848.0
min)
and
the
total
realistic
technical
burden
(
1770.32
min,
1258.51
min)
to
estimate
the
total
OMB
(
2625.75
min,
1834.58
min)
and
realistic
(
1684.07
min,
1245.09
min)
times
for
those
Form
R
data
elements
that
require
more
complex
information
gathering
and
calculations.

°
The
OMB
approved
technical
burden
for
nonstatic
data
elements
was
divided
by
the
PBT
realistic
burden
for
nonstatic
data
elements
(
i.
e.,
2625.75/
1770.32;
1834.58/
1258.71)
to
calculate
a
scaling
factor
(
1.56,
1.47).
(
Note
that
the
PBT
realistic
estimates
used
here
were
not
incidence­
weighted,
as
the
OMB
assumption
for
the
current
estimate
for
PBT
chemicals
is
that
all
data
elements
are
completed).

°
The
scaling
factor
was
applied
to
all
of
the
nonstatic
realistic
data
element
burden
estimates.

°
Realistic
management
burden
estimates
were
generated
by
multiplying
the
scaled
up
realistic
technical
burdens
by
the
20.9/
45.2
or
14.3/
30.8
hr
ratio
of
management
to
technical
burden
in
the
current
OMB­
approved
burden
estimate
for
first
and
subsequent
year
reporting
for
PBT
chemicals,
respectively.

°
Scaled
up
management
and
technical
times
were
added
together
for
each
data
element
to
estimate
a
total
time
for
that
data
element.

3.1.
B.
Results
for
PBT
Chemical
Electronic
Submissions
Table
14
presents
scaled
management
and
technical
burden
estimates
for
completing
each
data
element
of
the
Form
R
for
first
and
subsequent
year
electronic
submissions
of
PBT
reports.

3.1.
C.
Methodology
for
PBT
Chemical
Paper
Submissions
The
only
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
time
required
to
type
information
into
one
data
element
on
the
Form
R
was
considered
to
be
static
and
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
realistic
estimates
generated
for
technical
time.
Instead,
clerical
times
were
estimated
by
dividing
the
currently
approved
OMB
clerical
burden
(
Table
1)
for
PBT
chemical
submission
by
the
total
number
of
data
elements
on
the
Form
R.
1An
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).

Abt
Associates
Inc.
Draft
07/
16/
04
53
While
it
may
not
take
the
exact
same
amount
of
time
to
line
up
each
data
element
for
typing,
there
is
no
reasonable
way
to
estimate
this,
so
giving
equal
time
to
each
element
was
determined
to
be
the
best
method.
The
clerical
time
allotted
to
each
element
was
then
added
to
the
estimate
for
the
electronic
form
(
including
management
and
technical
time)
for
that
element
to
generate
scaled
time
estimates
for
every
data
element
for
PBT
first
and
subsequent
year
reporting
via
a
paper
Form
R.

3.1.
D.
Results
for
PBT
Chemical
Paper
Submission
Table
15
presents
scaled
management,
technical,
and
clerical
burden
estimates
for
completing
each
data
element
of
the
Form
R
for
first
and
subsequent
year
submissions
of
paper
PBT
chemical
reports.

3.2
Scaled
Estimate
for
non­
PBT
Chemicals
In
this
section,
the
realistic
technical
reporting
burden
estimates
developed
for
non­
PBT
chemicals
are
used
in
combination
with
the
currently­
approved
OMB
form
completion
reporting
burden
estimates
to
generate
burden
estimates
for
each
data
element
consistent
with
the
OMB
total.
Four
individual
reporting
burden
scenarios
are
scaled
up:
first
year
electronic,
subsequent
year
electronic,
first
year
paper,
and
subsequent
year
paper.
The
incidence
weighted
values
are
used
for
non­
PBT
chemicals
because
the
OMB
burden
estimates
for
non­
PBT
chemicals
are
based
on
actual
reporting
burden
data
from
facilities.

3.2.
A.
Methodology
for
non­
PBT
Chemical
Electronic
Submissions
The
OMB­
approved
form
completion
burden
estimate
for
non­
PBT
subsequent
year
technical
burden
is
16.4
hours.
A
first­
year
estimate
for
non­
PBT
technical
burden
of
24.1
hours
was
estimated
by
multiplying
the
subsequent
year
estimate
by
147
percent.
1
The
following
procedure
was
used
to
scale
the
realistic
electronic
non­
PBT
burden
estimates
to
these
OMB­
approved
burden
estimates.
Reporting
burden
is
estimated
for
both
first
and
subsequent
years.

°
Technical
reporting
burden
for
data
elements
requiring
only
typing
or
typing
plus
a
quick
information
look­
up
(
such
as
locating
the
facility's
D&
B
number)
was
estimated
(
59.0
min,
6.4min).
The
times
for
these
steps
were
assumed
static
and,
therefore,
were
not
scaled
up.

°
Total
static
time
was
subtracted
from
both
the
OMB
approved
technical
burden
(
1446.48
Abt
Associates
Inc.
Draft
07/
16/
04
54
min,
984.0
min)
and
the
total
incidence­
weighted
realistic
technical
burden
(
629.49
min,
413.18
min)
to
estimate
the
total
OMB
(
1387.48
min,
977.60
min)
and
realistic
(
570.49
min,
406.79
min)
times
for
those
Form
R
data
elements
that
require
more
complex
information
gathering
and
calculations.

°
The
OMB
approved
technical
burden
for
nonstatic
data
elements
was
divided
by
the
non­
PBT
realistic
burden
for
nonstatic
data
elements
(
i.
e.,
1387.48/
570.49;
977.60/
406.79)
to
calculate
a
scaling
factor
(
2.43,
2.40).

°
The
scaling
factor
was
applied
to
all
of
the
nonstatic
realistic
data
element
burden
estimates.

°
Realistic
management
burdens
were
generated
by
multiplying
the
scaled
up
realistic
technical
burdens
by
the
11.3/
24.1
or
7.7/
16.4
hr
ratio
of
management
to
technical
burden
in
the
current
OMB­
approved
burden
estimate
for
first
and
subsequent
non­
PBT
chemicals,
respectively.

°
Scaled
up
management
and
technical
times
were
added
together
for
each
data
element
to
estimate
a
total
time
for
that
data
element.

3.2.
B.
Results
for
non­
PBT
Chemical
Electronic
Submissions
Table
16
presents
scaled
management
and
technical
burden
estimates
for
completing
each
field
of
the
Form
R
for
first
and
subsequent
year
electronic
submissions
of
non­
PBT
reports.

3.2.
C.
Methodology
for
non­
PBT
Chemical
Paper
Submissions
The
only
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
time
required
to
type
information
into
one
data
element
on
the
Form
R
was
considered
to
be
static
and
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
realistic
estimates
generated
for
technical
time.
Instead,
clerical
times
were
estimated
by
dividing
the
currently
approved
OMB
clerical
burden
(
Table
1)
for
non­
PBT
chemicals
by
the
total
number
of
fields
on
the
Form
R.

While
it
may
not
take
the
exact
same
amount
of
time
to
line
up
each
data
element
for
typing,
there
is
no
reasonable
way
to
estimate
this,
so
giving
equal
time
to
each
element
was
determined
to
be
the
best
method.
The
clerical
time
allotted
to
each
element
was
then
added
to
the
estimate
for
the
electronic
form
(
including
management
and
technical
time)
for
that
element
to
generate
time
estimates
for
every
data
element
for
non­
PBT
first
and
subsequent
year
reporting
via
a
paper
Form
R.
Abt
Associates
Inc.
Draft
07/
16/
04
55
3.2.
D.
Results
for
non­
PBT
Chemical
Paper
Submissions
Table
17
presents
realistic
management,
technical,
and
clerical
burden
estimates
for
completing
each
data
element
of
the
Form
R
for
first
and
subsequent
year
paper
submissions
of
non­
PBT
reports.
