September,
2005
Memo
to
Docket
on
Calculation
Burden
for
Facilities
Ultimately
Acquiring
Form
A
Status
As
part
of
the
development
of
the
Phase
2
burden
reduction
rule,
it
was
desired
to
obtain
comment
on
a
new
engineering
estimate
based
approach
for
determining
TRI
burden
(
see
"
TRI
Reporting
Burden
Estimates"
July
16,2004
from
Eustice,
Cooper,
and
Day
also
contained
in
the
docket).
That
report
developed
estimates
for
the
calculation
and
completion
of
one
Form
R
and
was
subjected
to
a
full
peer
review.

An
analogous
document
was
not
developed
for
Form
A,
but
could
be
estimated
by
using
the
basic
building
block
methodology
of
the
document.
In
order
to
provide
a
fair
comparison
between
burden
reduction
potential
estimated
using
the
OMB
approved
burden
estimates
and
those
estimated
by
the
new
methodology,
it
was
necessary
to
prepare
such
an
estimate.
Analysis
focused
exclusively
on
subsequent
year
reporters
because
they
were
the
overwhelming
benefactors
of
the
proposal
and
only
a
rough
number
was
necessary
to
perform
this
sort
of
generalized
comparison.

Basic
Assumptions
­
Document
assumes
same
unit
times
for
individual
elements,
regardless
of
whether
the
chemical
of
concern
is
a
PBT
or
non­
PBT.
The
rationale
was
articulated
in
the
document
and
is
not
questioned
here.
Times
are
taken
from
Table
7
and
Table
8
of
that
document.

­
The
principal
beneficiaries
of
both
proposals
will
be
relatively
simple
with
respect
to
the
chemical
of
concern.
That
is,
it
is
assumed
that
complex
facilities
with
many
waste
streams
will
be
unlikely
to
have
total
waste
management
weights
under
the
appropriate
cut­
offs.

­
Because
these
are
subsequent
year
reporters,
they
will
generally
know
whether
they
manufacture,
process
or
use
a
chemical
in
excess
of
the
alternate
threshold.

­
For
PBTs,
it
is
known
that
the
majority
of
beneficiaries
would
be
lead
reporters.
Further,
it
is
known
that
the
beneficiaries
must
have
zero
releases
and
are
almost
exclusively
transferring
lead
off­
site
for
recovery.
Under
these
conditions,
there
will
be
no
additional
contributors
to
TPRW.
It
will
be
assumed,
therefore,
that
Section
6.2
burden
estimates
constitute
the
best
estimate
of
time
required
to
determine
the
ability
to
meet
the
PBT
annual
reportable
amount
threshold.
It
is
worthwhile
to
note
that
three
PBTs
make
up
98%
of
all
potential
proposal
beneficiaries.
The
second
largest
category
is
PAC
reporters.
They
almost
exclusively
burn
the
PACs
in
incinerators
or
as
part
of
energy
recovery.
The
burden
associated
with
estimating
the
amount
of
PACs
in
these
streams
is
less
than
that
associated
with
off­
site
transfer
(
implying
an
overestimate
of
burden),
but
will
be
ignored
for
the
purposes
of
this
exercise.
The
third
category
of
PBTs
is
mercury
that
is
also
being
sent
off­
site
for
recovery.

­
It
will
be
assumed
that
the
form
completion
time
can
be
taken
for
Form
A
reporting
elements
from
Table
7
and
8,
as
appropriate.

PBT
Form
A
Eligible
Respondent
Under
Section
6.2
it
is
assumed
that
the
typical
reporter
will
have
two
waste
streams
to
evaluate.
The
methodology
of
the
document
provides
an
80%
economy
of
scale
to
the
evaluation
of
the
second
stream.
For
the
purposes
of
this
analysis,
the
last
three
steps
in
this
section
relate
to
completing
the
Form
R
and
can
be
omitted.
It
also
seems
appropriate
to
halve
the
management
review
time,
given
the
simplicity
of
computations
involved.
The
technical
staff
calculation
time
of
six
minutes
per
waste
stream
seems
excessive,
but
will
not
be
questioned.
Making
these
adjustments
leaves
83.7
minutes
for
computation.
Add
to
this
the
2
minutes
required
for
Form
A
completion
and
the
estimate
of
burden
for
this
source
would
be
85.7
minutes,
or
1.4
hours.

Non­
PBT
Form
A
Eligible
Respondent
These
respondents
could
actually
have
a
release
as
part
of
the
ARA.
However,
as
stated
earlier,
it
seems
highly
unlikely
that
they
would
have
a
myriad
of
release
points
and
management/
disposal
practices
or
they
would
be
unlikely
to
be
beneath
the
threshold.
As
a
first
step
in
evaluating
these
sources,
it
was
decided
to
look
at
the
computational
burden
for
each
of
the
releases
in
Section
5.1
through
Section
6.2.
The
average
computation
time
for
these
thirteen
entries
is
approximately
70
minutes.
Without
further
information,
it
is
impossible
to
determine
an
appropriate
weighting
factor
for
a
second
waste
stream.
However,
it
is
worthwhile
to
note
that
the
average
value
is
considerably
less
than
that
obtained
for
PBTs.
Given
the
assumptions
of
the
document,
it
would
be
concluded
that
70
minutes
is
an
appropriate
calculation
time.
However,
if
one
assumes
only
a
50%
economy
of
scale
for
a
second
waste
stream,
the
calculation
time
would
be
105
minutes.
The
average
of
these
two
values
is
1.4
hours
as
well.
Therefore,
it
was
decided
to
use
1.4
hours
as
the
engineering
based
estimate
for
both
purposes.
