Table
1:
Estimated
Impacts
of
Option
4
Allowing
Form
A
Reporting
for
Non­
PBT
Chemicals
at
Different
ARA
Thresholds
(
based
on
RY
2002
data)

Form
A
ARA
Threshold
Level:

500
lbs*
1,000
lbs
2,000
lbs
5,000
lbs
Release
(
8.1)
pounds
not
reported
on
Form
R
961,737
2,497,939
5,634,536
15,126,117
Percentage
of
total
release
pounds
0.02%
0.06%
0.13%
0.34%

Production­
related
waste
(
8.1
thru
8.7)
pounds
not
reported
on
Form
R
1,300,392
3,633,327
8,949,478
26,669,591
Percentage
of
total
production­
related
waste
pounds
0.01%
0.01%
0.04%
0.11%

Number
of
Form
Rs
converting
to
Form
As
10,268
13,452
17,106
22,469
Facilities
with
all
Form
Rs
converting
to
Form
As
1,727
2,288
3,036
4,284
Zip
codes
with
all
Form
Rs
converting
to
Form
As
418
550
735
1,083
Zip
codes
with
at
least
one
Form
R
converting
to
Form
A
3,343
3,938
4,493
5,227
Zip
codes
with
at
least
one
facility
converting
all
Form
Rs
to
Form
As
1,461
1,862
2,355
3,057
Annual
cost
savings
($
million)
$
4.4
$
5.8
$
7.4
$
9.7
*
Only
includes
Form
Rs
filed
in
RY
2002
that
were
likely
eligible
for
the
alternate
reporting
threshold
based
on
their
ARA.

Table
2:
Estimated
Burden
and
Cost
Savings
Associated
with
Option
4
Allowing
Form
A
Reporting
for
Non­
PBT
Chemicals
at
Different
ARA
Thresholds
(
based
on
RY
2002
data)

Form
A
ARA
Threshold
Level:

500
lbs*
1,000
lbs
2,000
lbs
5,000
lbs
Number
of
Affected
Facilities
5,079
6,388
7,614
9,364
Number
of
Affected
Forms
10,268
13,452
17,106
22,469
Average
Annual
Burden
Hour
Savings
(
first
and
subsequent
years)

Form
Completion
­
non­
PBT
chemicals
78,037
102,235
130,006
170,764
Recordkeeping/
Mailing
20,536
26,904
34,212
44,938
Total
98,573
129,139
164,218
215,702
Average
Annual
Burden
Cost
Savings
(
first
and
subsequent
years)

Form
Completion
­
non­
PBT
chemicals
$
3,580,867
$
4,691,257
$
5,965,555
$
7,835,850
Recordkeeping/
Mailing
$
832,858
$
1,091,119
$
1,387,502
$
1,822,506
Total
$
4,413,725
$
5,782,376
$
7,353,057
$
9,658,356
*
Only
includes
Form
Rs
filed
in
RY
2002
that
were
likely
eligible
for
the
alternate
reporting
threshold
based
on
their
ARA.
