Overview
of
Data
Used
In
Analyzing
the
Expansion
of
Form
A
for
Non­
PBT
Chemicals,
Toxics
Release
Inventory
Burden
Reduction
Proposed
Rule
This
overview
provides
context
for
the
data
below
used
to
support
the
TRI
Burden
Reduction
Proposed
Rule.
EPA
used
these
data
to
evaluate
the
impacts
of
the
proposed
option
to
expand
Form
A
eligibility
for
non­
PBT
chemicals
within
the
bounds
of
the
Agency's
statutory
authority
under
the
section
313
of
the
Emergency
Planning
and
Community
Right
to
Know
Act.
42
U.
S.
C.
11023.
Specifically,
these
data
show,
that
under
this
proposed
option,
a
substantial
majority
of
total
releases
would
still
be
obtained
with
expanded
Form
A
eligibility.

The
data
below
were
also
used
in
completion
of
the
economic
analysis
for
this
proposal
as
required
by
Executive
Order
12866.
The
data
are
used
differently
to
fulfill
the
Agency's
statutory
obligations
under
EPCRA
and
to
complete
requirements
under
the
E.
O.
12866.
The
different
analysis
pertains
to
the
difference
between
two
classes
of
regulated
entities:
1)
those
are
potentially
eligible
to
use
Form
A
but
elect
not
to
and
2)
those
that
are
both
eligible
and
elect
to
use
Form
A.
For
purposes
of
understanding
the
Agency's
statutory
obligations
under
EPCRA,
EPA
looks
at
the
entire
universe
of
facilities
eligible
to
use
Form
A
regardless
of
whether
they
choose
to
use
the
shorter
form.
For
purposes
of
completing
E.
O.
12866,
only
facilities
that
actually
choose
to
use
Form
A
are
considered
in
calculating
the
burden
and
cost
(
or
in
the
case
of
this
rule,
burden
savings
and
cost
savings).

There
are
several
reasons
why
a
facility
that
would
otherwise
qualify
for
Form
A
(
i.
e.,
the
annual
reportable
amount
reported
in
Section
8.1
through
8.7
for
the
chemical
being
reported
is
less
than
500
lbs)
is
not
electing
to
do
so.
It
is
possible
that
the
regulated
entity's
manufacturing,
processing
or
other
use
of
the
chemical
at
their
facility
exceeds
the
1
million
lb.
threshold
also
necessary
for
Form
A.
In
this
case,
the
entity
would
not
have
a
legal
right
to
use
Form
A.
Or
a
facility
might
elect
to
use
Form
R
in
lieu
of
Form
A
in
order
to
show
the
community
it
is
located
in
its
source
reduction
efforts.
A
facility
may
elect
to
use
Form
R
if
it
is
uncertain
about
its
Form
A
eligibility
or
if
it
is
unaware
of
its
Form
A
eligibility.
EPA
cannot
determine
from
evaluating
a
Form
R's
annual
reportable
amount
(
for
non­
PBT
chemicals)
which,
if
any,
of
these
reasons
that
a
facility
may
chose
to
forego
using
Form
A.

The
Agency
is
therefore
assuming
conservatively
that
all
Form
Rs
which
have
annual
reportable
amounts
less
than
500
lbs
for
non­
PBT
chemicals
have
the
legal
right
to
use
Form
A,
even
though
this
may
not
always
be
the
case.
The
data
below
include
non­
PBT
chemicals
reported
which
may
have
a
legal
right
to
use
Form
A
but
choose
not
do
so.
These
data
are
reproduced
in
Appendix
A
of
the
Economic
Analysis
of
the
TRI
Burden
Reduction
Proposed
Rule
containing
only
non­
PBT
chemicals
with
annual
reportable
amounts
between
500
and
5000
lbs.
