  SEQ CHAPTER \h \r 1 

TOXICS RELEASE INVENTORY

ALTERNATE THRESHOLD FOR LOW ANNUAL REPORTABLE AMOUNTS;

TRI FORM A TOXIC CHEMICAL RELEASE REPORTING

INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT

OMB CONTROL NO.  2070-0143

EPA ICR # 1704.09

December 10, 2007

 TOC \f 

1	IDENTIFICATION OF THE INFORMATION COLLECTION	3

1(a) Title and Number of the Information Collection	3

1(b) Short Characterization/Abstract	3

2	NEED FOR AND USE OF THE COLLECTION	6

2(a) Need/Authority for the Collection	6

2(b) Practical Utility/Users of the Data	7

3	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA	8

3(a) Non-Duplication	8

3(b) Public Notice Required Prior to ICR Submission to OMB 	8

3(c) Consultations 	8

3(d) Effects of Less Frequent Collection	9

3(e) General Guidelines	9

3(f) Confidentiality	10

3(g) Sensitive Questions	10

4	THE RESPONDENTS AND THE INFORMATION REQUESTED	10

4(a) Respondents/NAICS Codes	10

4(b) Information Requested	11

5	THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION METHODOLOGY,
AND INFORMATION MANAGEMENT	16

 5(a) Agency Activities	16

 5(b) Collection Methodology and Management	20

 5(c) Small Entity Flexibility	21

 5(d) Collection Schedule	21

6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION	22

6(a) Estimating Respondent Burden	23

6(b) Respondent Costs	27

6(c) Estimating Agency Burden and Cost	31

6(d) Estimating the Respondent Universe and Total Burden and Costs	33

6(e) Bottom Line Burden Hours and Costs	36

6(f) Reasons for Change in Burden	37

6(g) Burden Statement	38

 

APPENDICES

Appendix A: Blank Form A

Appendix B: Reporting Form Instructions Associated with Form Changes



1	IDENTIFICATION OF THE INFORMATION COLLECTION REQUEST

Title and Number of the Information Collection

Title:	Alternate Threshold for Low Annual Reportable Amounts; Toxic
Chemical Release Reporting

EPA ICR No.  	1704.08

OMB Control No.	2070-0143

Short Characterization/Abstract

This Information Collection Request (ICR) is for the information
collection requirements for toxic chemical release reporting under §313
of the Emergency Planning and Community Right-to-Know Act (EPCRA) (42
U.S.C. 11001 et seq.) and the information collection requirements in
§6607 of the Pollution Prevention Act (PPA) (42 U.S.C. 11071 to 11079).
In short, EPCRA §313 requires certain owners or operators of certain
facilities in covered industries that manufacture, process, or otherwise
use any of nearly 650 listed toxic chemicals and chemical categories
(hereafter "toxic chemicals") in excess of the applicable threshold
quantities to report their environmental releases and transfers of and
waste management activities for such chemicals annually. Under §6607 of
the PPA, facilities must provide information on the quantities of the
toxic chemicals in waste streams and the efforts made to reduce or
eliminate those quantities. 

Currently, facilities subject to the TRI reporting requirements may use
either the EPA Toxics Release Inventory Form R (EPA Form #9350-1), or,
if they meet lower threshold requirements, the EPA Toxics Release
Inventory Form A Certification Statement (EPA Form #9350-2), which is
approved under Office of Management and Budget (OMB) Number 2070-0143
(see the Form A ICR Supporting Statement for more information on these
reporting requirements). With Form R, one chemical is reported per form;
with Form A, multiple chemicals may be reported per form. 

Facilities with low quantities of listed toxic chemicals in waste may
certify that they do not exceed an annual reportable amount (ARA) on
Form A. Detailed release and waste management information need not be
reported.  Previously, a facility that met the EPCRA §313 reporting
thresholds, but estimated that their estimated total ARA of the listed
toxic chemical did not exceed 500 pounds per year, could take advantage
of the alternate manufacture, process or otherwise-use thresholds of 1
million pounds per year for that listed toxic chemical, provided that
the facility met certain other conditions. Due to the TRI Burden
Reduction Rule promulgated December 22, 2006, Form A eligibility is
expanded to allow, for the first time, limited use of Form A for
persistent, bioaccumulative, toxic (PBT) chemicals. (71 FR 76932,
December 22, 2006). The new eligibility criteria for Form A reporting
are as follows: 

New Eligibility for Form A: PBT Chemicals -- allows a facility reporting
on PBT chemicals, except dioxin and dioxin-like compounds, with zero
disposal or other releases to use Form A, provided they meet the
1,000,000 pound alternate reporting threshold and have 500 pounds or
less of total other waste-management quantities. (Sections 8.2 – 8.8)

Expanded Eligibility for Form A: Non-PBT Chemicals -- allows a facility
reporting on Non-PBT chemicals with an ARA (Sections 8.1 – 8.8) of
5,000 lbs or less and 2,000 lbs or less of disposal or other releases to
use Form A, provided they meet the 1,000,000 pound alternate reporting
threshold. 

Each qualifying facility that chooses to apply this alternate
manufacture, process or otherwise-use threshold must file a Form A
Certification Statement certifying that they met the condition of the
alternate threshold for one or more chemicals, in lieu of completing a
Form R for each listed chemical for which the facility exceeded
statutory thresholds. The Form A Certification Statement is submitted to
both the EPCRA reporting center and the designated state recipient in
the same manner that the Form R is submitted. The Form A Certification
Statement provides a signed statement that the sum of the amount of the
listed toxic chemical or chemicals in releases or wastes did not exceed
the appropriate PBT or Non-PBT release and waste thresholds for the
reporting year, and that the chemical(s) was manufactured, processed, or
otherwise-used in an amount not exceeding 1 million pounds during this
reporting year. A single Form A Certification Statement may contain as
many listed toxic chemicals as meet the conditions of the alternate
threshold.

EPA is proposing changes to the Form R and Form A Certification
Statement to standardize responses and enhance the utility of the data.
More specifically, the changes to the forms and TRI Reporting Forms and
Instructions (RFI) described below allow facilities to provide more
detailed information on how they estimate their data, facilitate
efficient contact with the appropriate facility personnel, and improve
understanding of the reasons behind form revisions or withdrawals. The
changes are presented below:

1)	Provide more specific "basis of estimate" codes (Form R only).
Facilities may currently select among four codes to indicate how they
calculate their release quantities: the use of monitoring data (code M),
mass balance calculations (C), emission factors (E), and other
approaches (O). The modification in the RFI to provide more specific
codes will allow reporting facilities to provide more detailed
information. Collecting this detailed information—more specific
“basis of estimate” data—will help the TRI Program determine which
methods are most often used and/or appropriate for use by particular
industries for certain chemicals, as well as when new TRI guidance may
be needed. Therefore, EPA will provide a more extensive list of codes
for "basis of estimate" in the RFI, including (M1) and (M2) for
continuous and periodic/random monitoring, respectively; and (E1) and
(E2) for published and site-specific emission factors, respectively.
(Note: codes (C) and (O) remain unchanged). Via these codes, facilities
will indicate the principal method used to determine the quantities
reported to TRI. 

2)	Enhance Public Contact information (Form R and/or Form A, as noted
below). These changes provide efficiency gains for the Agency and the
reporting facilities. Adding a "Public Contact" field to the Form A will
provide the name of a person who can respond to questions from the
public about the Form A Certification Statement in the same way that a
person currently responds for Form R submissions. In addition, providing
an e-mail address for the public contact on both Form R and Form A will
make it easier to contact and follow-up with the Public Contact if
necessary. 

3)	Add boxes for entering revision codes (Form R and A). The TRI Program
currently receives many form revisions each year, but does not
systematically collect information on the reasons for the revisions. The
new revision codes will allow both the public and the TRI Program staff
to better understand why a facility resubmitted a form. In addition, by
analyzing the reasons for revisions, the TRI Program may be better able
to address recurring reporting issues or problems that facilities may be
facing, ultimately reducing errors and saving time for both the Agency
and the reporting facilities. Therefore, facilities will now report up
to two codes (listed and defined in the RFIs) indicating the main
reason(s) that a form is being revised.

4)	Provide a field for withdrawing a form; and add boxes for entering
withdrawal codes (Form R and A). Currently, a facility that wishes to
withdraw a previously submitted form must submit its request, including
the rationale, as a hard copy memorandum to the TRI Data Processing
Center via regular mail, certified mail, or overnight delivery. Adding a
"Withdrawal" field and associated code boxes for reasons for withdrawal
to Form R and Form A will (1) streamline the withdrawal process for
facilities, (2) make it easier for EPA to automate the withdrawal
process, and (3) improve the Agency’s ability to analyze the reasons
for withdrawals.

EPA has developed EPA Information Quality Guidelines to ensure the
utility, objectivity, and integrity of information that is disseminated
by the Agency. The information supporting this ICR is consistent with
all appropriate EPA policies, including EPA's Information Quality
Guidelines. In particular, the EPA Agency-wide quality system helps
ensure that EPA organizations maximize the quality of information
disseminated by the Agency. The quality system is documented in EPA
Order 5360.1 A2, Policy and Program Requirements for the Mandatory
Agency-wide Quality System and the EPA Quality Manual for Environmental
Programs 5360 A1, May 2000. The information supporting this action is
also consistent with EPA's Guide to Writing Information Collection
Requests Under the Paperwork Reduction Act of 1995, revised November
2005. It is EPA's intention that collection of information under this
ICR will result in information that will be collected, maintained, and
used in ways consistent with both EPA's Information Quality Guidelines
and the OMB Information Quality Guidelines. 

OMB last approved this ICR on March 3, 2006, with an expiration date of
January 31, 2008.  The approved ICR reflected a reporting burden of
259,192 hours and $12 million for Form A respondents. In this ICR
Renewal, the effect of the TRI Burden Reduction Rule is expected to
sustain the reduced overall burden due to increased Form A eligibility
(i.e., number of Form Rs decreased and number of Form As increased,
yielding a net burden decrease) with total responses, burden and cost of
Form A reporting projected at 10,235 responses, 515,284 hours, and
$25.99 million. Further, the TRI Program is proposing to add certain
data elements to both reporting forms.  The addition of these data
elements is estimated to increase the total reporting burden and cost
for Form A reporting to 515,901 hours and $26.01 million.  

For a facility certifying for a single listed toxic chemical via a Form
A Certification Statement, the burden is estimated to average 20.52
hours for a Non-PBT chemical and 35.89 hours for a PBT chemical under
EPCRA §313 (all estimates incorporate proposed changes). (This estimate
includes the time required for calculations, Form A Certification
Statement completion, and record keeping.) By comparison, the average
time using Form R (including calculations, form completion, and record
keeping) is estimated to average 29.66 hours per form for a single
listed Non-PBT chemical and 51.34 hours for a single listed PBT chemical
(all estimates incorporate proposed changes). Thus, for a facility
filing a Form A Certification Statement instead of Form R for a single
listed chemical, the alternate threshold yields an average savings of
9.1 hours for a Non-PBT chemical and 15.4 hours for a PBT chemical. 

2	NEED FOR AND USE OF THE COLLECTION

 2(a) Need/Authority for the Collection

Section 313 of EPCRA, 42 U.S.C. 11023, requires certain facilities that
manufacture, process, or otherwise use listed toxic chemicals in excess
of the applicable threshold quantities to report their environmental
releases of such chemicals annually either on Form R or Form A.
Beginning with the 1991 reporting year, such facilities also began
reporting source reduction and recycling data for listed chemicals,
pursuant to §6607 of the Pollution Prevention Act, 42 U.S.C. 13106. 

Each covered facility must report on each listed chemical manufactured,
processed or otherwise used in excess of the reporting thresholds
established in EPCRA §313(f)(1). EPA has authority to revise these
threshold amounts pursuant to EPCRA §313(f)(2); however, such revised
threshold amounts must obtain reports on a substantial majority of total
releases of the chemical at all facilities subject to EPCRA §313. A
revised threshold may be based on classes of chemicals or categories of
facilities.

EPA established an alternate threshold under EPCRA §313(f)(2) for a
category of facilities with low amounts of a listed toxic chemical in
wastes.  A facility that chooses to apply the alternate threshold must
submit an EPA Toxics Release Inventory Form A Certification Statement
(EPA Form #9350-2). EPA’s regulations implementing TRI reporting are
codified at 40 CFR part 372.

The information collected on the Form A Certification Statement is
necessary to fulfill EPA’s responsibilities under EPCRA §313(f)(2). A
Form A Certification Statement addresses the statutory mandates and the
public's right-to-know while allowing regulatory relief for facilities
with lower volumes of chemicals in wastes. A Form A Certification
Statement provides appropriate information:

indicating the location of facilities manufacturing, processing or
otherwise using these chemicals,

demonstrating that the chemicals are being manufactured, processed or
otherwise used at current reporting thresholds, and 

confirming that the sum of amounts of the chemical in releases and waste
did not exceed the appropriate PBT or Non-PBT release and waste annual
reportable amounts for that reporting year. 

The requirement to submit a Form A Certification Statement fosters
continued attention to chemical management practices and provides a
locational tool vital to any compliance program or other interested
party. It is necessary to receive some type of specific indication that
a facility is taking advantage of the alternate threshold annually to
assist in any compliance monitoring and enforcement efforts.

2(b) Practical Utility/Users of the Data

According to many, the TRI Program is one of the most effective
environmental programs ever legislated by Congress and administered by
EPA. Its success is due, in large part, to the right-toknow provisions
contained in the legislation itself. By requiring that the resulting
data be made publicly available "by electronic and other means,"
Congress ensured that citizens, the media, environmental advocates,
researchers, the business community, and others could influence and
evaluate industry's efforts to manage toxic emissions. Consequently,
data collected under EPCRA §313 and §6607 of the PPA are made
available through EPA's Envirofacts and TRI Explorer databases. In
addition, the public may also obtain TRI information through other
sources such as OMB Watch's Right-to-Know Network (RTK NET) at  
HYPERLINK http://www.rtk.net.RTK  http://www.rtk.net. RTK  NET provides
free public access to numerous databases, text files, and conferences on
the environment, housing, and sustainable development.

In addition to providing information to the public via electronic means,
EPA also conducts outreach activities to make key groups and the public
aware of TRI. Journalists; educators; public interest, labor, and
environmental groups; trade associations; and state governments continue
to be key targets in these outreach efforts. In addition, libraries in
communities all across the United States (in particular, members of the
Federal Depository Library Program) are committed to providing public
access to TRI data in a variety of formats. Educators are using the data
to conduct studies and courses on the environment. Labor unions are
using the TRI data to improve conditions for workers. Businesses are
using the data in many ways—as a basis for reducing emissions, to cut
costs, to improve operations, and for a variety of other reasons.
Concerned citizens are a growing user group. These individuals, on their
own and through organized groups, are using TRI to address concerns
about the management and release of chemicals in their communities.
Finally, states use the national data to compare chemical management and
releases within industries and to set environmental priorities at the
state level.

Because the value of TRI increases the more it is used, EPA encourages
current users to acquaint new users with TRI; help people who already
know about TRI to better use and understand the data; and, whenever
possible, to provide feedback on ways to improve TRI products and
services. The ICR Supporting Statement for Form R provides specific
examples of some of the actual uses of TRI data.

The Form A Certification Statement provides information that a Section
313-listed chemical is being manufactured, processed or otherwise-used
at or above threshold levels specified in 40 CFR parts 372.25 and
372.28. Through the use of the Form A Certification Statement, the
individuals and groups described above will continue to have knowledge
that the sum of the amounts in releases and waste for a particular
facility do not exceed amounts specified in 40 CFR 372.27 for the
chemical for which the alternate threshold was applied.

3	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 	CRITERIA

Non-Duplication

The information requested by the Form A Certification Statement reflects
a subset of information requested by Form R. To the extent that the Form
A reporting option is used by a portion of the TRI reporting community,
corresponding data that would have been provide in a Form R will not be
reported. Information comparing TRI reporting to information available
under other statutes is available in the ICR Supporting Statement for
Form R.

3(b) Public Notice Required Prior to ICR Submission to OMB

EPA is planning to submit a request to renew existing approved ICRs for
both Form Rs and As to OMB. Both ICRs are scheduled to expire on January
31, 2008. Before submitting the ICRs to OMB for review and approval, EPA
is soliciting comments on specific aspects of the proposed information
collections. A Federal Register Notice will be published to announce
this renewal request.

3(c) Consultations

EPA has consulted with a large number of individuals and organizations
throughout all segments of the public in the development and continued
implementation of the TRI Program. EPA has received feedback from
various organizations, including environmental and public interest
groups, trade associations, and individual representatives, through its
outreach efforts in venues such as:

Stakeholder meetings and online dialogues to discuss issues such as
options for reporting burden reduction

The TRI National Meeting held every year and open to the public every
other year. 

EPA continually seeks this feedback and incorporates it into the ongoing
evolution of the TRI Program.  Lists of organizations with which EPA has
consulted in the past few years can be found in Appendix E of the Form R
ICR Supporting Statement.  

3(d) Effects of Less Frequent Collection

EPCRA §313 requires annual reporting on either Form R or Form A.
Section 313(i) permits EPA to modify the reporting frequency by
rulemaking; however, EPA must first notify Congress and then delay the
initiation of such a rulemaking for at least 12 months, but no more than
24 months, from the date of the notification. In addition, EPA must
find:

...that the modification is consistent with the provisions of subsection
(h) of [EPCRA §313] based on -

	(i)	experience from previously submitted toxic chemical release forms,

	(ii)	determinations made under paragraph (3).

Paragraph (3), in turn, provides that EPA must determine:

The extent to which information relating to the proposed modification
provided on the toxic chemical release forms has been used by the
Administrator or other agencies of the federal government, states, local
governments, health professionals and the public.

The extent to which information is (i) readily available to potential
users from other sources, such as state reporting programs, and (ii)
provided to the Administrator under another federal law or through a
state program.

The extent to which the modification would impose additional and
unreasonable burdens on facilities subject to the reporting requirements
under this section.

Since TRI represents the best available multi-media database for
tracking toxic chemical releases in the United States, a change in the
reporting frequency to less than once a year could have a significant
impact on the availability of timely toxic chemical data and affect data
users, particularly at the community level.  Public access to the most
current toxic chemical release data and other waste management
information would become more difficult.

3(e) General Guidelines

This ICR adheres to the guidelines stated in the 1995 Paperwork
Reduction Act, as amended, OMB's implementing regulations, and all
applicable OMB guidance.

Although reporting facilities are required to identify the chemical for
which reports are submitted, they can claim the chemical identity as a
trade secret. A generic name must be provided as part of the information
made available to the public. EPA securely stores and maintains the true
identity of the chemical (see also Section 3(f)).  

EPA continues to encourage submission through the Internet via EPA’s
Central Data Exchange (CDX) by using the Toxics Release Inventory Made
Easy (TRI-ME) reporting software. In preparing submissions within the
TRI-ME reporting software and submitting them via the Internet, both the
cost and the time required to enter and process the data are reduced.
Also, for facilities using the TRI-ME reporting software, quality checks
are streamlined, allowing EPA to release the data to the public sooner.
All these benefits apply to reporters using the technology, regardless
of whether they submit via Form R or Form A.

Small facilities (less than 10 full-time employees or equivalent) are
exempt from reporting under EPCRA §313. Two particular provisions that
apply to TRI reporters universally: 1) the optional range reporting
provision and 2) an alternate threshold allowing increased Form A
eligibility are particularly beneficial to non-exempt smaller facilities
with small releases and wastes.

3(f) Confidentiality

Respondents may designate the specific chemical identity of a substance
as a trade secret according to EPCRA §322. Procedures for submission
and review of trade secret claims under EPCRA §313 are set forth in 40
CFR 350. When a facility claims the chemical identity to be a trade
secret and properly substantiates the claim, EPA will not disclose the
identity of the chemical to the public. EPA securely stores forms with
trade secret information and allows access to those documents only to
persons with Trade Secret clearance. Data made available to the public
through any means do not include trade secret information.

3(g) Sensitive Questions

This collection does not request any sensitive information.

4	THE RESPONDENTS AND THE INFORMATION REQUESTED 

4(a) Respondents/NAICS Codes

The reporting requirements found in EPCRA §313 apply to owners and
operators of facilities that have 10 or more full-time employees,
manufacture or process more than 25,000 pounds or otherwise use more
than 10,000 pounds of a listed chemical, and are in the manufacturing
sector or in any of seven additional industry sectors added to the TRI
Program by EPA in 1997.  Historically, these sectors were identified by
their Standard Industrial Classification (SIC) codes.  Beginning with
Reporting Year (RY) 2006, the TRI Program has converted from SIC codes
to NAICS codes (71 FR 32464, June 6, 2006). The full list of NAICS codes
for facilities that must report to TRI (including exemptions and/or
limitations) if all other threshold determinations are met can be found
in Appendix F of the ICR Supporting Statement for Form R.  A detailed
listing of the six-digit NAICS codes and categories can be found in
Table I of the Toxics Release Inventory Reporting Forms and
Instructions. 

Recently there have been changes to the eligibility for Form A
reporting. Previously, under the final PBT (Persistent Bioaccumulative
Toxic Chemicals) Rule, published October 29, 1999, specified PBT
chemicals were excluded from eligibility for alternate threshold
reporting (i.e., the Form A Certification Statement cannot be used to
report PBT chemicals). The recent TRI Burden Reduction Rule, however,
allows the use of the alternate reporting threshold for PBTs (except
dioxin and dioxin-like compounds) under certain conditions for the first
time. Note below that these new thresholds that apply to PBT chemicals
for alternative reporting are lower than the corresponding thresholds
for Non-PBT chemicals.

The Form A Certification Statement can be submitted by those facilities
that would otherwise be required to submit a Form R but determine that
they are eligible to apply the alternate threshold based on the
quantities of disposal and other releases and waste management that they
report.  Therefore, the alternate threshold does not affect facilities
that are not already part of the TRI regulated community.

4(b) Information Requested 

Data Items

The following information must be reported on a Form A Certification
Statement pursuant to 40 CFR part 372 (see Appendix A for a blank Form
A):

1) Reporting year.

2) An indication of whether the chemical identified is being claimed as
trade secret.

3) Chemical name or names and CAS number(s) (if applicable) of the
chemical(s), or the category(ies) or the generic chemical name(s).

4) Signature of a senior management official certifying one of the
following, as applicable, pursuant to 40 CFR part 372.27: 

(Non-PBT)

	 ‘‘I hereby certify that to the best of my knowledge and belief for
the toxic chemical(s) listed in this statement, for this reporting year,
the annual reportable amount for each chemical, as

defined in 40 CFR 372.27(a)(1), did not exceed 5,000 pounds, which
included no more than 2,000 pounds of total disposal or other releases
to the environment, and that the chemical was manufactured, or
processed, or otherwise used in an amount not exceeding 1 million pounds
during this reporting year;” or

(PBT)	

‘I hereby certify that to the best of my knowledge and belief for the
toxic chemical(s) of special concern listed in this statement, there
were zero disposals or other releases to the  environment (including
disposals or other releases that resulted from catastrophic events) for
this reporting year, the ‘‘Annual Reportable Amount of a Chemical of
Special Concern’’ for each such

chemical, as defined in 40 CFR 372.27(a)(2), did not exceed 500 pounds
for this reporting year, and that the chemical was manufactured, or
processed, or otherwise used in an amount not exceeding 1 million pounds
during this reporting year.’’

5) Date signed.

6) Facility name and address.

7) Mailing address of the facility if different than (6).

8) Toxic chemical release inventory facility identification number if
known. 

9) Name and telephone number of a Technical Contact.

10) The six-digit NAICS codes for the facility or establishments in the
facility. 

11) Dun and Bradstreet Number of the facility.

12) Name of the facility's Parent Company.

13) Parent Company's Dun and Bradstreet Number.

These 13 elements are a subset of the information collected on Form R. 

Beyond element 3, which allows for multiple chemicals to be reported on
a single Form A Certification Statement, the only element unique to the
Form A Certification Statement is element 4. Element 4 of the Form A
Certification Statement corresponds to the certification statement on
Form R and represents a signed statement by a facility owner/operator or
senior management official. Unlike Form R, the signed statement on the
Form A Certification Statement certifies that, for PBT chemicals, 1)
disposal or other releases equaled zero, 2) total other waste management
quantities equaled 500 pounds or less, and 3) that the amounts
manufactured, or processed, or otherwise used did not exceed 1 million
pounds for that year. For Non-PBT chemicals, the Form A Certification
Statement certifies 1) that disposal or other releases are less than or
equal to 2,000 pounds, 2) total other waste management quantities
equaled 5,000 pounds or less, and 3) that the amounts manufactured, or
processed, or otherwise used did not exceed 1 million pounds for that
year.

Justification for Form A Elements

Element 4 relates to the conditions being met in order to claim
eligibility for the submission of a Form A Certification Statement. This
element is essential in meeting the statutorily mandated requirement of
continuing to capture a substantial majority of releases for each listed


EPCRA §313 chemical.

Elements 6 through 13 are requested for identification purposes. Of
these, elements 6 through 9 are necessary to determine which facility is
claiming the alternate threshold along with the information needed to
contact the claimant. Elements 11 through 13 are requested in order to
cross-reference the facility with other reporting systems. These data
elements are essential for enforcement purposes and have proven to be
useful for cross-program multimedia investigations.

Overall, the Form A Certification Statement provides appropriate
information:

indicating the location of facilities manufacturing, processing or
otherwise using these chemicals,

demonstrating that the chemicals are being manufactured, processed or
otherwise used at current reporting thresholds, and 

confirming that the sum of amounts of the chemical in releases and waste
did not exceed the appropriate PBT or Non-PBT release and waste annual
reportable amounts for that reporting year. 

The requirement to submit a Form A Certification Statement fosters
continued attention to chemical management practices and provides a
locational tool vital to any compliance program or other interested
party.

	Additional Data Elements

As mentioned above, EPA is proposing changes to the Form R and Form A
Certification Statement to standardize responses and enhance the utility
of the data. More specifically, the changes to the forms and TRI
Reporting Forms and Instructions (RFI) described below will allow
facilities to provide more detailed information on how they estimate
their data, facilitate efficient contact with the appropriate facility
personnel, and improve understanding of the reasons behind form
revisions or withdrawals. The changes are presented below:

1)	Provide more specific "basis of estimate" codes (Form R only).
Facilities may currently select among four codes to indicate how they
calculate their release quantities: the use of monitoring data (code M),
mass balance calculations (C), emission factors (E), and other
approaches (O). The modification in the RFI to provide more specific
codes will allow reporting facilities to provide more detailed
information Collecting this detailed information—more specific
“basis of estimate” data—will help the TRI Program determine which
methods are most often used and/or appropriate for use by particular
industries for certain chemicals, as well as when new TRI guidance may
be needed. Therefore, EPA will provide a more extensive list of codes
for "basis of estimate" in the RFI, including (M1)and (M2) for
continuous and periodic/random monitoring, respectively; and (E1) and
(E2) for published and site-specific emission factors, respectively.
(Note: codes (C) and (O) remain unchanged). Via these codes, facilities
will indicate the principal method used to determine the quantities
reported to TRI. 

2)	Enhance the Public Contact information (Form R and/or Form A, as
noted below). These changes provide efficiency gains for the Agency and
the reporting facilities. Adding a "Public Contact" field to the Form A
will provide the name of a person who can respond to questions from the
public about the Form A Certification Statement in the same way that a
person currently responds for Form R submissions. In addition, providing
an e-mail address for the public contact on both Form R and Form A will
make it easier to contact and follow-up with the Public Contact if
necessary. 

3)	Add boxes for entering revision codes (Form R and A). The TRI Program
currently receives many form revisions each year, but does not
systematically collect information on the reasons for the revisions. The
new revision codes will allow both the public and the TRI Program staff
to better understand why a facility resubmitted a form. In addition, by
analyzing the reasons for revisions, the TRI Program may be better able
to address recurring reporting issues or problems that facilities may be
facing, ultimately reducing errors and saving time for both the Agency
and the reporting facilities. Therefore, facilities will now report up
to two codes (listed and defined in the RFI) indicating the main
reason(s) that a form is being revised.

4)	Provide a field for withdrawing a form; add boxes for entering
withdrawal codes (Form R and A). Currently, a facility that wishes to
withdraw a previously submitted form must submit its request, including
the rationale, as a hard copy memorandum to the TRI Data Processing
Center via regular mail, certified mail, or overnight delivery. Adding a
"Withdrawal" field and associated code boxes for reasons for withdrawal
to Form R and Form A will (1) streamline the withdrawal process for
facilities, (2) make it easier for EPA to automate the withdrawal
process and (3) improve the Agency’s ability to analyze the reasons
for withdrawals.

As is the case for Form R, for Form A facilities must maintain records
used to report the information required on the form according to 40 CFR
§372.10. Those records may include estimation methodology and
calculations; engineering reports; inventory, incident, and operating
logs; and other supporting materials. Facilities must keep a copy of
each report filed for at least three years.

 (ii)	Respondent Activities 

As is the case for Form R, the regulated community eligible to file Form
A is expected to comply with the reporting requirements. Facilities
eligible for the alternate reporting threshold complete the Form A
Certification Statement and submit it to EPA and the appropriate state
agency. EPCRA §313(g)(2) provides that a "facility may use readily
available data (including monitoring data) collected pursuant to other
provisions of law, or where data are not readily available, reasonable
estimates of the amounts involved." Respondents are not required to
develop new information.

The same level of assistance provided to Form R respondents is available
to facilities applying the alternate threshold and completing the Form A
Certification Statement. Instructions, guidance documents, and a
toll-free hotline are available to address general and technical
inquiries from the regulated community. 

The following steps will be completed by a facility using the alternate
threshold and thus filing a Form A:

Compliance Determination

Calculations (Compliance)

Completion of Form (Disclosure)

Substantiation of a Trade Secret Claim (not performed by all
respondents) 

Record keeping

Supplier Notification (not performed by all respondents)

Petition Submission (not a requirement)

Compliance Determination. Facilities must determine if they meet the
criteria for EPCRA §313 reporting, if they are eligible to apply the
alternate threshold, and/or if they are required to provide supplier
notification. This determination is based on the NAICS code(s) for the
facility, the number of full-time employees or equivalents, the
chemicals manufactured, processed or otherwise used at the facility, the
quantity of those chemicals and the quantity of releases and other waste
management.

Calculations (Compliance). Facilities must calculate disposal and other
releases quantities as well as the annual reportable amount for a
chemical in order to determine if the facility is eligible to apply the
alternate threshold for that chemical.  Disposal and other releases are
calculated as the combined total of total on-site disposal to Class I
Underground Injection Wells, RCRA Subtitle C landfills, and other
landfills; total other on-site disposal or other releases; total
off-site disposal to Class I Underground Injection Wells, RCRA Subtitle
C landfills, and other landfills; and total other off-site disposal or
other releases.  The annual reportable amount is calculated as the
combined total of the amounts released at the facility (including
disposal), treated at the facility (as represented by amounts destroyed
or converted by treatment processes), recovered at the facility as a
result of recycling operations, combusted for the purpose of energy
recovery at the facility, transferred from the facility to off-site
locations for the purpose of recycling, energy recovery, treatment, or
disposal, and generated as non-production related waste. In addition,
the facility must also determine that it did not manufacture, process,
or otherwise use more than 1 million pounds of the listed chemical.

Completion of Form (Disclosure). Each facility taking advantage of the
alternate threshold must complete the Form A Certification Statement.

Substantiation of a Trade Secrecy Claim. Facilities claiming a trade
secret for the chemical identity should refer to documentation
requirements discussed in the Trade Secrecy ICR for EPCRA (EPA #1428,
OMB #2050-0078).

Record keeping. Each facility taking advantage of the alternate
threshold is required to maintain records for a period of three years
from the date of the submission of the Form A Certification Statement
and to make the records available upon request. These records provide
substantiation that an appropriate threshold determination was made and
that the sum of amounts in releases and total waste did not exceed the
appropriate threshold for that chemical for that reporting year. This
documentation is necessary for any compliance effort attempting to
verify claims made by a facility using the alternate threshold.
Facilities must maintain a copy of each Form A Certification Statement
and Form R submitted, as well as the documents, calculations, and other
information they collected for developing the reports submitted.

Supplier Notification. No additional supplier notification requirements
are associated with the Form A Certification Statement.

Petition Submission. No additional procedures relating to petition
submissions are required by the Form A Certification Statement.

5	THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION METHODOLOGY,
AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA engages in many activities to fulfill the requirements of EPCRA.
These activities can be grouped in the following categories that cover
what the Agency does to assist the regulated community with compliance,
to process the data, to maintain the database, and to make the data
available:

Assistance to Reporters

Electronic Reporting

Paper-Based Reporting

Data Processing and Quality Control

Database Organization

Links to State Reporting

Making Data Available

List Revisions and Petition Reviews

Trade Secrecy Reviews

Assistance to Reporters. The Agency operates a successful outreach
program to assist businesses in obtaining and completing both the Form R
and Form A Certification Statement. A CD-ROM containing an annually
updated reporting package is distributed directly to all TRI respondents
who reported in the prior year. EPA also makes this package available to
potential reporters through its TRI Web site and TRI Regional office
coordinators. The package contains an electronic copy of the reporting
forms and detailed instructions along with a reporting software
application that allows reporters to submit their data over the Internet
or on computer diskettes. General guidance has been prepared for
estimating releases, including 14 industry-specific guidance documents.

EPA operates a training program to familiarize EPA Regional personnel
with the reporting requirements and to train them in providing technical
assistance to respondents. Using that training, the EPA Regions conduct
numerous workshops each year to explain the reporting requirements to
the regulated community. EPA also conducts a training program on EPCRA
§313 reporting requirements to train private businesses and consultants
that wish to provide advice on EPCRA §313 compliance. Also, EPA
operates a toll-free hotline to answer general questions and direct
potential respondents to proper EPA personnel. A second hotline is
available to answer questions about the electronic reporting software
and the procedure for submitting and certifying data to EPA over the
Internet. In addition, the Agency maintains a Web site with current
program-specific information and guidance ( HYPERLINK
"http://www.epa.gov/tri" http://www.epa.gov/tri ).

Electronic Reporting. Ninety-seven percent of all TRI Form Rs and Form
As are prepared and submitted using the Toxics Release Inventory Made
Easy (TRI-ME) reporting software. TRI-ME is a software application that
TRI facilities can use for entering and validating their data.
Historically, this software has been desktop-based and distributed via
posting on the TRI Web site and mailing directly to facilities (via
CD-ROM) each year. Beginning in RY2007, a new version of TRI-ME—TRI-ME
web, will be fully launched with the intent to eventually replace TRI-Me
desktop. 

Given that this ICR covers the transition period between reporting by
TRI-ME desktop and TRI-MEweb, both methods are discussed here.
Capabilities in TRI-ME desktop that will be replaced or incorporated
into TRI-MEweb include:

Facilities can key or upload their data into TRI-ME. TRI-ME provides
reporting guidance to help facilities determine if they need to report
for specific chemicals and to assist them in the actual reporting.
TRI-ME also provides facilities with extensive data validation checking
through point-of-entry edit checks as well as a cumulative, mandatory
batch test prior to submission. The cumulative batch test provides users
with descriptive messages and links back to the form where potential
errors exist.

After entering their data into the TRI-ME application and validating
them, facilities have two options for submitting their data to EPA.
First, facilities can send their TRI data to EPA and certify them
electronically via EPA’s Central Data Exchange (CDX). Second, they can
save the data to a diskette, print and sign a certification letter, and
mail both items to TRI’s EPCRA Data Processing Center. 

Data submitted to TRI via the CDX are automatically forwarded to the TRI
EPCRA Data Processing Center (DPC) and loaded into the TRI Processing
System (TRIPS) database. The TRIPS database is located at EPA’s
National Computer Center in Research Triangle Park, NC. For diskette
submissions, the data are received at the DPC, cataloged, scanned for
viruses and loaded into the TRIPS database. 

Through the TRI State Data Exchange Network, facilities are able to
submit their data via CDX once to both EPA and the participating state
government. Upon submission to CDX, a copy of the data is simultaneously
sent to EPA’s TRIPS database and to the appropriate state via the TRI
State Data Exchange Network. This reporting option allows facilities to
fulfill their legal obligation to report to the federal and state
entities through a single submission of data to CDX. 

In 2007 (RY 2006), the TRI Program piloted a Web version of the TRI-ME
software that   also increases the original functionality of the TRI-ME
desktop application in several areas. Full implementation of TRI-MEweb
is planned for 2008 (RY2007).  Similar to the existing desktop version,
the TRI-MEweb application allows online submission and certification of
the data. But additional enhancements include: 

Preloaded Forms and Central Data Storage. The TRI-MEweb application
allows users to preload their forms with prior year data stored in an
EPA-maintained database. In addition, the application will store
work-in-progress data via the same online database, so that users will
no longer have to manage the data themselves (i.e., they will not have
to save the information on their hard drive).

Quick Lists. The TRI-MEweb application will contain enhancements,
including a redesigned questionnaire and “quick lists” that
streamline reporting tasks. Similar to tax reporting software, from
which TRI-MEweb was modeled, “quick lists” allow users to narrow
their data entry to only the pertinent areas. 

Data Quality Checks. The Web version introduces new semantic checks of
data quality that compare a facility’s data to prior year submissions;
EPA registry data; and ultimately, data from industry and similarly
sized facilities. Unlike in TRI-ME desktop, these comparisons will occur
online in real time, allowing the user to review all data for possible
quality concerns and make corrections at the same time. 

On-Line Revisions. The application will allow true online revision of
data by facilities. Through this feature, facilities will be able to
access previously submitted forms, and revise and recertify them in one
quick and easy step. 

Paper-Based Reporting. Facilities can also submit data to TRI on paper
forms. When facilities submit TRI reports on paper, the information is
keyed into the TRIPS database on a PC-based wide area network (WAN).
Automated data quality checks begin at data entry; these include various
edit checks and the start of standardization of some of the data fields.
At this point, the emphasis is on identifying forms that are not
completed correctly. If the problem(s) identified prevent further
processing of the form, EPA sends a Notice of Significant Error (NOSE)
to the respondent.

Unlike with paper submissions, the mandatory data validation routines in
the TRI-ME reporting application will not allow the submission of forms
that are not completed correctly. This protection applies to the data
entry fields in the form but cannot, of course, apply to the signature
field in cases when the reporter does not sign the Certification
Statement for forms submitted on diskette. 

Data Processing and Quality Control. Once the reported data have entered
the TRIPS database, all the validation checks that were initially run
via the TRI-ME application are repeated. For paper submissions, these
checks are performed for the first time. Forms that fail these tests
receive error notices known as Notices of Technical Error (NOTE). A NOTE
points out possible data validity errors that are not technical in
nature but are also not egregious enough to prevent the form from being
disseminated (see NOSE above). In addition, a set of data quality checks
that compare the incoming data with prior years data and various data
thresholds are performed on the data for the first time. Further
standardization of facility identification information continues. 

Upon the completion of the data validation and quality checks, Facility
Data Profile (FDP) reports are generated and made available for facility
review on the FTP Web site. The reports contain an echoing back of the
data and all validation (NOTE errors) and data quality messages that
were generated after the data were loaded into the database. Facilities
receive an e-mail alerting them when a report becomes available and
asking them to access the password-protected site and review the report.
After review, facilities can revise their data by submitting a certified
replacement form via the TRI-ME software or on paper. 

Database Organization. EPCRA §313(j) requires EPA to make TRI data
available to the public through computer telecommunications and other
means. EPA has found it beneficial to undertake a variety of activities
to make the data more usable, given that computer searches only retrieve
data in exactly the format requested. Because facilities report their
data in a wide variety of ways, EPA has taken steps to use consistent
names for counties, use a variety of nomenclature standards for names
within the database, and assist in the standardization of the response
data.

EPA generates a facility identification number for newly reporting
facilities at the time of data entry. This allows linkage to all years
of reports for a particular facility or location. The identification
number also allows easy retrieval of cross-year data, even when a
facility is sold or changes its name. This number has been sent to all
facilities, and they are required to use it on all future submissions to
the Agency. Use of the facility identification number also facilitates
data quality reviews and cross-year analysis.

Links to State Reporting. Under EPCRA §313, facilities are required to
submit forms both to EPA and the state in which they operate. For
additional quality assurance and tracking purposes, EPA provides all
states with a listing of facilities that reported to the Data Processing
Center for each reporting year. This reconciliation activity typically
results in the identification of several cases where facilities did not
report to both. Many states then provide lists of forms to EPA when EPA
has not received copies, and vice versa. Both the state and EPA then
contact the facilities from which they are missing forms and request
submission. This activity has provided a critical step to assist EPA in
coordinating the data collection with the states and completing both
data repositories.

In 2003, EPA implemented the TRI State Data Exchange Network, which
enabled facilities to simultaneously submit their data to EPA and their
respective state governments. This new reporting option allowed
facilities to fulfill their legal obligation to report to the federal
and state entities through the sole submission of data through CDX. To
utilize the TRI State Data Exchange Network, facilities have to (1) use
the TRI-ME desktop application, (2) submit their data over the Internet
to EPA’s CDX, and (3) be located in a participating state. At the same
time a transmission is sent to EPA’s TRIPS database, CDX sends the
data on to participating states via the TRI State Data Exchange Network.
The TRI State Data Exchange Network is a standards-based data network
that allows the transfer of data between states and EPA. This capability
will be sustained in the new TRI-MEweb application. 

In 2006, EPA introduced a new flow to the TRI State Data Exchange
Network by which data submitted via diskette and paper to the TRI Data
Processing Center are also forwarded to participating states. This
second stage of the network flow does not remove the obligation to
report to both EPA and the reporter’s state government because of
necessary intervening steps such as data entry. However, it eliminates
the need for dual data entry systems, allowing participating states to
discontinue their data entry systems. In addition, these states no
longer need to perform the annual form reconciliation with EPA, since
they are obtaining the exact same flow of data that EPA receives from
facilities. 

Making TRI Data Available. Many options are available for accessing TRI
data. For example, the annual TRI Public Data Release (PDR) includes an
overview of the most recently reported TRI data, information on trends,
and downloadable data files of all TRI reports submitted for the
reporting year. The TRI data for RY 2005 were released on March 22,
2007, which was earlier than ever before. The RY 2005 PDR includes key
findings, links to the data, and a link to TRI Explorer, one of EPA's
electronic tools for TRI data analysis.

The TRI Program has also developed the electronic Facility Data Release
(e-FDR) in response to public requests to make the TRI data available as
soon as possible after the data are received by EPA. The e-FDR is a
facility-level, form-by-form release of the TRI data, which provides an
early look at individual facility data, but which does not include the
in-depth analyses (e.g., national trend analyses) that are provided in
the PDR several months later. The first e-FDR, for RY 2003, was released
in November 2004; the second e-FDR, for RY 2004, was released in
November 2005; and the latest e-FDR, for RY 2005, was released in
September 2006. 

EPA has also developed database tools that can be used to access the
data. One such tool, TRI Explorer, allows users to search the TRI data
by ZIP code, county, and state, as well as view data at the national
level. Combined with hazard and exposure information, it serves as a
valuable tool for identifying potential chemical hazards in communities.

Using EPA’s Envirofacts, users can determine which facilities
in designated areas have reported toxic releases, including air
emissions, surface water discharges, releases to land, underground
injections, and transfers to off-site locations. Envirofacts allows the
user to query and view data for each TRI Form R submitted by a facility.

Finally, the TRI Data Mart is a new tool that is to be released in 2007
to provide a single point of enhanced access to TRI data and analytical
tools, just some of which are currently available through TRI Explorer
or Envirofacts. The TRI Data Mart will provide greater analytical
capabilities and be able to respond to a variety of customized data
queries. 

Trade Secrecy Reviews. Respondents claiming a chemical identity as a
trade secret must include substantiation. Each year TRI receives
reporting forms with the trade secret box checked but no accompanying
substantiation form. In these cases, EPA treats the trade secret claim
as a mistake, and notifies the submitter. In many of these cases, the
trade secret claim was not intended and no substantiation is necessary.
In other cases, however, EPA receives completed trade secret claims. For
more information on trade secrecy reviews, including the costs to EPA,
see the ICR for the Trade Secrecy Rule for EPCRA (EPA #1428, OMB
#2050-0078).

5(b) Collection Methodology and Management

EPA continues to encourage Form R and A submissions through the Internet
via EPA’s CDX and the interactive, intelligent, user-friendly TRI-ME
software. This software asks the user simple, straightforward questions
to help the user determine if the facility is subject to TRI reporting.
TRI-ME has greatly reduced data quality errors and has therefore reduced
the likelihood of a facility being in violation of the reporting
requirements, or having to subsequently submit revisions. In the last
five years TRI-ME usage has increased. Ninety-seven percent (66 percent
CDX and 31 percent diskette) of submissions were received electronically
for RY 2005. 

Beginning in RY2007, the TRI Program will fully implement TRI-MEweb, an
innovative online application with all the functionality of TRI-ME
desktop plus major enhancements. This online tool will have significant
new features to further help reduce reporting burden, improve data
quality, and reduce errors. 

5(c) Small Entity Flexibility  

EPCRA §313 (b)(1)(A) provides that facilities with fewer than 10
full-time employees (or the equivalent) are not required to report. In
addition, the application of the alternate threshold and therefore use
of the Form A is advantageous to those entities that might be classified
as small under other definitions. The range established by the release
and waste thresholds (in alternate threshold reporting) may apply
proportionally higher to smaller entities, thereby resulting in greater
regulatory relief for these smaller facilities. EPA considered a number
of different annual reportable amount levels when it originally
promulgated this rule. Originally, the 500 pound level was chosen
because it appeared to best balance burden reduction with the need for
data and information. It is also consistent with the requirements of
EPCRA §313. However, the Agency has promulgated a new rule—the TRI
Burden Reduction Rule (December 2006)—that increases the annual
reportable amount for Non-PBT chemicals from 500 lbs to 5000 lbs,
providing that disposal and other releases do not exceed 2,000 pounds.
In addition, under this rule, PBT chemicals can be reported on Form A
for the first time ever as long as disposal and other releases equals
zero and the annual reportable amount does not exceed 500 pounds.  

Through the development of the Form A Certification Statement (in
conjunction with the petition process, electronic reporting, efforts to
review the original list of TRI chemicals to determine whether any of
those chemicals do not meet the listing criteria, and other mechanisms),
EPA has reduced, to the extent practicable and appropriate at this time,
the burden on facilities providing the information collected under EPCRA
§313. EPA continues to work with affected parties to identify
opportunities for further burden reduction.

5(d) Collection Schedule

Facilities must report their information on a calendar-year basis, and
submit Form Rs or Form As to EPA by July 1 each year. On average, EPA
has released the national TRI data set to the public approximately 10
months after the annual reporting deadline. In response to public
requests to shorten the time frame for release of TRI information, EPA
is encouraging facilities to submit revised reports sooner, and
streamlining data quality operations. The Agency expects these measures
will help it to meet the ultimate goal of releasing data in the year of
submission. Also, it is important to note that EPA's national database
is just one avenue of access to the TRI information. Each state also
makes its data available to the public, and most states are able to make
their data available prior to EPA's release of the national data. For
example, nearly half of the states release their TRI data within four
months of the TRI reporting deadline.

6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION  

This information collection activity imposes burden and cost on those
facilities that are eligible to use the alternate reporting threshold as
implemented in Form A use under the EPCRA §313 reporting requirements. 
It also imposes costs on EPA to process and make available the data
collected and stored in the Toxics Release Inventory.  The following
sections present the derivation of Form A respondent burden and cost as
well as Agency burden and cost. For TRI reporters, estimates of average
Form A reporting burden per respondent are presented.  These unit burden
estimates are then combined with appropriate wage rates to develop unit
costs. Total Form A respondent burden and costs are estimated by
combining the universe of reporting forms and facilities with estimates
of unit burden and cost. This universe of reporting forms and facilities
is based on reporting in RY2005, adjusted to account for the predicted
impacts of the TRI Burden Reduction rule and proposed changes.  When
estimating reporter burden, the submission medium is assumed to be 100
percent paper, reflecting the most conservative case. The combined total
number of forms and facilities (i.e., respondents) is hereafter referred
to as the ICR Universe. The Form R burden and cost associated with the
new data elements and revised instructions are presented separately in
alternate tables and then accounted for in the bottom-line burden and
cost estimates (highlighted). 

OMB last approved this ICR request on March 3, 2006, with an expiration
date of January 31, 2008. The approved ICR reflected a reporting burden
of 259,192 hours and $12 million for Form A respondents.  In this ICR
Renewal, the effect of the TRI Burden Reduction Rule is expected to
sustain the reduced overall burden due to increased From A eligibility
(i.e., number of Form Rs decreased and number of Form As increased,
yielding a net burden decrease) with total responses, burden, and cost
of Form A reporting projected at 10,235 responses, 515,284 hours, and
$25.99 million. Further, the TRI Program is proposing to add certain
data elements to both reporting forms.  The addition of these data
elements is estimated to increase total reporting burden and cost for
Form A reporting to 515,901 hours and $26.01 million, respectfully.  

For Agency burden, estimates of fixed costs associated with rent for the
EPCRA Reporting Center, development costs for data access tools,
compliance assistance measures, and other activities and expenses are
presented. Variable costs, dependent on the number of Form As processed,
are also calculated.  In Agency burden estimates, the FY2005
distribution of submission media (paper, diskette, CDX online) is
assumed to be the same over the course of the ICR period. 

	6(a) Estimating Respondent Burden

This section presents the burden of this information collection activity
on respondents in terms of the time required for facility personnel to
perform the steps outlined in Section 4 of this document. These burden
estimates are based on previous ICRs and economic analyses, respondent
experience as reflected in comments to EPA and other parties, and
information acquired through site visits and telephone interviews.

One factor to note is that reporter burden has been impacted over time
by technology advances. For example, in 2003, EPA implemented the TRI
State Data Exchange Network, which enabled facilities in participating
states to submit their data simultaneously via CDX to EPA and to their
state government. This new reporting option allowed facilities to
fulfill their legal obligation to report to the federal and state
entities through the sole submission of data to EPA via CDX. In
addition, EPA has developed the interactive, intelligent, user-friendly
TRI-ME software. This software asks the user simple, straightforward
questions to help the user determine if the facility is subject to TRI
reporting. TRI-ME has greatly reduced data quality errors and has
therefore reduced the likelihood of a facility being in violation of the
reporting requirements, or having to subsequently submit corrections.
Additionally,   SEQ CHAPTER \h \r 1 EPA expects that TRI-ME has resulted
in a burden reduction in the activities of Form R completion and
recordkeeping/submission. As a conservative estimate of reporting
burden, however, reporter burden savings associated with technology
advances, including TRI-ME and concurrent federal and state reporting
are not reflected in this ICR.

Form A Respondent Requirements

The burden to respondents is estimated for Form A Certification
Statement requirements. Burden estimates are developed for the
compliance activities and then multiplied by the number of facilities or
reports (as appropriate) to estimate the total burden to respondents.
The burden estimates used by EPA are national average values. As with
any average, some facilities will be above the average, and others will
be below it. Large, complex facilities may require more than the average
time to comply. However, there are many other facilities subject to the
rule that are not large or complex. Therefore, EPA believes that its
burden estimates represent reasonable national averages. The activities
associated with the alternate threshold reporting include report
calculations and certification, form completion, and recordkeeping and
submission. Specifically:

Rule Familiarization: Facilities that are reporting under EPCRA §313
for the first time must read the reporting package and become familiar
with the reporting requirements. This activity includes the time needed
to review instructions, and the time needed to train personnel to be
able to respond to a collection of information.

Calculations/Certification: Facilities must gather data and perform
calculations to determine eligibility for the alternate threshold. This
activity includes the time to search data sources, and the time to
complete and review the information.

Form Completion: Facilities must complete the form. Facilities use a
single Form A Certification Statement to submit certifications for all
chemicals that are eligible for the alternate threshold.

Recordkeeping/Submission: Facilities must maintain recordkeeping systems
and submit the completed Form A Certification Statement to EPA and their
state.

Each of these activities is described in more detail below.

Rule Familiarization.  If a facility will be reporting under the EPCRA
§313 requirements for the first time, facility staff must review and
comprehend the reporting requirements as well as EPA procedures for
submitting, revising, and withdrawing forms. At a minimum, this effort
will involve reading the reporting instructions. However, it may also
involve consulting EPA guidance documents, attending a training course,
and/or calling the EPCRA technical hotline. The cost associated with
rule familiarization occurs only in the first year that a facility
becomes subject to reporting. In subsequent years, facility staff are
assumed to be familiar with the requirements that apply to their
facility. Thus, the facility would no longer bear this cost. Similarly,
facilities that already report on one or more existing TRI chemicals
will not incur a rule familiarization cost.

Calculations/Certification. To certify that a listed toxic chemical
qualifies for the alternate threshold, a facility must estimate its
disposal and other releases, its annual reportable amount, and the
amount manufactured, processed, or otherwise used. If a facility's
annual reportable amount for a Non-PBT chemical is 5,000 pounds or less
and its disposal or other releases do not exceed 2,000 pounds, the
facility is eligible to apply the alternate threshold of 1 million
pounds manufactured, processed or otherwise used. If a facility's annual
reportable amount for a PBT chemical is 500 pounds or less and its
disposal or other releases are zero, the facility is eligible to apply
the alternate threshold of 1 million pounds manufactured, processed or
otherwise used.

Form A Certification Statement Completion. If a facility is eligible and
chooses to apply the alternate threshold, it must complete the Form A
Certification Statement. The facility completes one Form A Certification
Statement that contains certifications for all the listed toxic
chemicals to which it is applying the alternate threshold.

The new data elements proposed for Form A by EPA will add minimal burden
to the form as follows:

Field for “Public Contact” including email address (affects Form A
only)  - The facility will enter the name, telephone number (including
area code), and e-mail address of the public contact.  In the first
year, this data element is estimated to take 0.2 minutes of management
time, 0.5 minutes of technical time, and 1.3 minutes of clerical time to
complete.  In subsequent years, it is estimated to take 0.2 minutes of
management time, 0.5 minutes of technical time, and 0.9 minutes of
clerical time to complete.

Code boxes indicating that the form is a revision or withdrawal as well
as the reason for revision or withdrawal (affects Form A and Form R).
For a revision or withdrawal, the facility will indicate with up to two
codes the reason(s) for revision or withdrawal in the code box. Given
that revision and withdrawal procedures are considered to be part of
Rule Familiarization, these procedural changes, which apply to a subset
of the ICR Universe, are negligible and assumed to be zero.

Recordkeeping/Submission. After a facility has certified a listed toxic
chemical as eligible for the alternate threshold, it incurs additional
labor costs for recordkeeping and submission. Recordkeeping allows a
facility to use the information in making calculations in subsequent
years, and as documentation in the event it receives a compliance audit.
Facilities may maintain such records as estimation methodology and
calculations, engineering reports, inventory, incident and operating
logs, and any other supporting materials needed to document eligibility
for the alternate threshold. Facilities must transmit Form A
Certification Statements to EPA and State authorities.

Form A Respondent Burden

The calculations needed to determine eligibility for the Form A
Certification Statement are a subset of the calculations necessary to
complete Form R. Thus, the time required to calculate the annual
reportable amount was estimated in previous ICRs by aggregating EPA’s
estimates of the time required to calculate each of the sections of Form
R that are relevant to determining the annual reportable amount. 

Since the last Form A ICR, this ICR incorporates two substantive
changes.  First, due to the TRI Burden Reduction Rule promulgated
December 22, 2006, the expanded Form A eligibility will result in an
increase in the number of Form As filed and therefore an increase in
Form A reporting burden.  The unit burdens (PBT and Non-PBT) associated
with filling out Form A, however, remain unchanged.  The change in the
number of Form As filed is discussed in section 6(d). Second, EPA is
proposing to add data elements and revise instructions for Form R and A
that would that improve the consistency and granularity of TRI data via
details of standardized responses. The addition of data elements will
slightly increase the unit burden associated with filling out Form A but
should not affect the number of Form As submitted. Note that the tables
below are often presented in (a) and (b) versions to reflect the base
case (incorporating the TRI Burden Reduction Rule) and then the proposed
changes. Reporting burden estimates by activity and labor category are
shown in Table 1a. The incremental burden associated with the new data
elements is shown in Table 1b.

Table 1a

Reporter Average Annual Burden Hour Estimates for Form A

  SEQ CHAPTER \h \r 1 Activity	Management	Technical	Clerical	Total Hours

First-year activities





Rule Familiarization - first-time filers	12	22.5	0	34.5

Calculations/ Certification - first-time Non-PBT filers	16.3	26	2.2	44.5

Calculations/ Certification - first-time PBT filers	16.1	25.7	2.2	44

Form A Completion - first-time filers	0.02	1.5	0.05	1.6

Recordkeeping/Submission	0	2.4	0.6	3

Total Non-PBT	28.3	52.4	2.9	83.6

Total PBT	28.1	52.1	2.9	83.1

Subsequent year activities





Calculations/ Certification - subsequent year Non-PBT filers	5.95	9.5
0.75	16.2

Calculations/ Certification - subsequent year PBT filers	11.2	19	1.4
31.6

Form A Completion - subsequent year filers	0.09	1.2	0.03	1.3

Recordkeeping/Submission	0	2.4	0.6	3

Total Non-PBT	6.04	13.1	1.38	20.5

Total PBT	11.29	22.6	2.03	35.9

Source: Economic Analysis of the Toxics Releases Inventory Burden
Reduction Rule, September 2006.



Table 1b

Reporter Incremental Annual Burden Increase Estimates for Form A

  SEQ CHAPTER \h \r 1 Activity	Management	Technical	Clerical	Total
Minutes	Total Hours

First-year activities





	Form A Completion - first-time filers (Non-PBT and PBT)

	Include field for Public Contact information	0.2	0.5	1.3	2.05	0.034

Include code boxes on form to indicate reason(s) for revision or
withdrawal, if a form is being resubmitted	0.0	0.0	0.0	0.0	0.00

Total	0.2	0.5	1.3	2.05	0.034

Subsequent year activities





	Form A Completion - subsequent year filers (Non-PBT and PBT)

	Include field for Public Contact information	0.2	0.5	0.9	1.6	0.027

Include code boxes on form to indicate reason(s) for revision or
withdrawal, if a form is being resubmitted	0.0	0.0	0.0	0.0	0.00

Total	0.2	0.5	0.9	1.6	0.027

Note that the derivation of reporting burden estimates associated with
the new data elements and revised reporting instructions follows the
methodology used in the Economic Analysis for the TRI Reporting Forms
Modification Rule, July 2005. 



6(b) Estimating Respondent Costs

The cost to respondents is based on the time needed to complete the
activities listed in Section 6(a) and the hourly cost of labor at
appropriate levels (loaded labor rates). There are no specific capital
and operation and maintenance costs associated directly with this
information collection activity. There may be some small additional
costs for mailing and supplies. Total annual costs for all facilities
are discussed in Section 6(d).

	(i) Estimating Labor Costs

Respondent costs are related to the number of chemical certifications
reported on the Form A Certification Statements and the loaded hourly
rates of the personnel who complete the reporting activities. For the
first year, the total reporting burden is estimated to average 83.61
hours  for a facility submitting a single certification statement for a
Non-PBT chemical and 83.08 hours  for a facility submitting a single
certification statement for a PBT chemical under EPCRA §313 (all
estimates incorporate proposed changes). (This estimate includes the
time required for rule familiarization, calculations/certification, Form
A Certification Statement completion, and recordkeeping/submission.) For
subsequent reporting years, the total reporting burden is estimated to
average 20.52 hours for a facility submitting a single certification
statement for a Non-PBT chemical and 35.89 hours for a facility
submitting a PBT chemical under EPCRA §313 (all estimates incorporate
proposed changes). These estimates include the time required for
calculations/certification, Form A Certification Statement completion,
and recordkeeping/submission. By comparison, the average time required
for calculations, form completion, and recordkeeping/submission for Form
R is estimated to average between 29.66 hours per form for a Non-PBT
chemical and 51.34 hours per form for a PBT chemical in subsequent
reporting years (all estimates incorporate proposed changes). Thus, for
a facility filing a Form A Certification Statement for a single
chemical, the alternate threshold yields an average savings of 9.1 hours
for a Non-PBT chemical and 15.4 hours for a PBT chemical in subsequent
reporting years. 

For a facility that certifies multiple chemicals on a Form A
Certification Statement, the burden per reported chemical is reduced. On
average 2.2 chemicals were reported to EPA using Form A Certification
Statements for RY2005. About 50 percent of the facilities using the Form
A Certification Statement reported on one chemical, another 18 percent
reported on two chemicals, 16 percent on three chemicals, and the
remaining 16 percent of facilities reported on 4 or more chemicals. The
typical per facility burden and cost for certifying one to three
chemicals is shown in Tables 2a and 2b before and after the addition of
the new data elements. The loaded hourly rates used in Tables 2a and 2b
correspond with the loaded hourly rates for the relevant labor
categories in the Form R ICR Supporting Statement.

Table 2a

Reporter Annual Burden and Cost per Facility (Assuming 1, 2, or 3
Chemicals)   SEQ CHAPTER \h \r 1 

Activity	Number of Chemicals Reported on 

Each Form A

	1 Chemical	2 Chemicals	3 Chemicals

	hours	cost	hours	cost	hours	cost

First-year filers







Rule Familiarization - first-time filers	34.5	$1,805	34.5	$1,805	34.5
$1,805

Calculations/ Certification - first-time Non-PBT filers	44.5	$2,280	89
$4,560	133.5	$6,840

Calculations/ Certification - first-time PBT filers	44	$2,253	88	$4,506
132	$6,759

Form A Completion - first-time filers	1.6	$77	1.6	$77	1.6	$77

Recordkeeping/Submission	3	$134	6	$268	9	$402

Total per Facility - Non-PBT	83.6	$4,296	131.1	$6,710	178.6	$9,124

Total per Facility – PBTs	83.0	$4,269	130	$6,656	177	$9,043

Average per Chemical – Non-PBT	83.6	$4,296	65.5	$3,355	59.5	$3,041

Average per Chemical – PBT	83.0	$4,269	65	$3,328	59	$3,014

Subsequent year filers







Calculations/ Certification - subsequent year Non-PBT filers	16.2	$831
32.4	$1,662	48.6	$2,493

Calculations/ Certification - subsequent year PBT filers	31.6	$1,620
63.2	$3,240	95	$4,860

Form A Completion - subsequent year filers	1.3	$64	1.3	$64	1.3	$64

Recordkeeping/Submission	3	$134	6	$268	9	$402

Total per Facility – Non-PBT	20.5	$1,029	39.7	$1,994	58.9	$2,959

Total per Facility –PBT	35.9	$1,818	70.4	$3,572	105	$5,326

Average per Chemical – Non-PBT	20.5	$1,029	19.8	$997	19.6	$986

Average per Chemical – PBT	35.9	$1,818	35.2	$1,786	35	$1,775



Table 2b

Reporter Annual Burden and Cost per Facility (Assuming 1, 2, or 3
Chemicals),

Including New Data Elements   SEQ CHAPTER \h \r 1 

Activity	Number of Chemicals Reported on 

Each Form A

	1 Chemical	2 Chemicals	3 Chemicals

	hours	cost	hours	cost	hours	cost

First-year filers







Rule Familiarization - first-time filers	34.5	$1,805	34.5	$1,805	34.5
$1,805

Calculations/ Certification - first-time Non-PBT filers	44.5	$2,280	89
$4,560	133.5	$6,840

Calculations/ Certification - first-time PBT filers	44.0	$2,253	87.932
$4,505	131.9	$6,758

Form A Completion - first-time filers	1.6	$79	1.6	$79	1.6	$79

Recordkeeping/Submission	3	$134	6	$269	9	$403

Total per Facility - Non-PBT	83.6	$4,298	131.1	$6,712	178.6	$9,127

Total per Facility – PBTs	83.1	$4,271	130.0	$6,658	177.0	$9,045

Average per Chemical – Non-PBT	83.6	$4,298	65.6	$3,356	59.5	$3,042

Average per Chemical – PBT	83.1	$4,271	65.0	$3,329	59.0	$3,015

Subsequent year filers







Calculations/ Certification - subsequent year Non-PBT filers	16.2	$831
32.4	$1,663	48.6	$2,494

Calculations/ Certification - subsequent year PBT filers	31.6	$1,620
63.2	$3,240	94.7	$4,860

Form A Completion - subsequent year filers	1.3	$65	1.3	$65	1.3	$65

Recordkeeping/Submission	3	$134	6	$269	9	$403

Total per Facility – Non-PBT	20.5	$1,031	39.7	$1,996	58.9	$2,962

Total per Facility –PBT	35.9	$1,819	70.5	$3,574	105.1	$5,328

Average per Chemical – Non-PBT	20.5	$1,031	19.9	$998	19.6	$987

Average per Chemical – PBT	35.9	$1,819	35.2	$1,787	35.0	$1,776

Note that the derivation of reporting burden and cost estimates
associated with the new data elements and revised reporting instructions
follows the methodology used in the Economic Analysis for the TRI
Reporting Forms Modification Rule, July 2005. 



6(c) Estimating Agency Burden and Cost

This section estimates the burden and costs to EPA to process Form R
reports based on information characterizing the resources used in
previous years. EPA incurs burden and costs for five categories of
activities: data processing, outreach and training, information
dissemination, policy and petitions, and compliance and enforcement.
These activities are described in detail in Table 3.

Table 3

EPA Activities for TRI Reporting Forms

Category	Description

Data Processing	Data entry – entering the information into the
database, microfilming or microfiching the reports, and filing all
reports;

Data quality – reviewing reports for completeness, errors, and
inconsistencies; making inquiries to resolve discrepancies; and
reentering corrected data;

Magnetic media support – distributing the computer program for
electronic submissions; creating and updating intelligent reporting
software;

Programming and operating the EPA mainframe and local area network;

Data analysis – developing tools to use TRI data, analyzing data to
support EPA needs, and preparing data for use by others; and

EPCRA Reporting Center fixed costs – rent and form storage.

Outreach and Training	Providing EPCRA technical hotline, technical
guidance, industry outreach, and regional, state, and public training;
and

Responding to requests for information through TRI User Support.

Information Dissemination	Public Data Release, Internet, data access
tools.

Policy and Petitions	Analysis to support petitions, list revisions,
trade secret claims, and rulemakings.

Compliance and Enforcement	Technical assistance, compliance outreach,
facility inspections, issuance of cases, and creation of Supplemental
Environmental Projects (SEPs).



The estimate of EPA burden and costs is separated into a fixed component
and a variable component; EPA staff commitments (as measured by FTEs)
are reported in total. Activities and expenses that are not greatly
affected by marginal changes in report quantities are reported as fixed
costs. These activities and expenses include rent for the EPCRA
Reporting Center, development costs for data access tools, compliance
assistance measures, and other activities and expenses listed above. The
variable component is the amount that varies depending on the number of
forms. The variable unit costs are estimated as total data processing
costs divided by the total number of reports processed in RY 2005. Table
4 details the costs associated with the activities of Table 3 in total
and for each Form R and Form A. 

Table 4

Agency Burden and Cost* 

Category	Annual Cost

(million)	Form R

(million)	Form A

(million)

Data Processing (Fixed Cost)

Forms Processing (Variable Cost)	    $ 4.25 

    $ 0.45 	    $ 3.70 

    $ 0.39 	    $ 0.55 

    $ 0.06 

Outreach and Training	    $ 1.10 	    $ 0.96 	    $ 0.14 

Information Dissemination 	    $ 0.81 	    $ 0.70 	    $ 0.11 

Policy and Petitions	    $ 1.08 	    $ 0.94 	    $ 0.14 

Compliance and Enforcement	    $ 0.37 	    $ 0.32 	    $ 0.05 

Totals	   $ 8.06 	    $ 7.01 	    $ 1.05 

*This estimate includes all Agency activities related to all TRI work,
reflecting a 50 FTE effort with 13 FTEs from Regional office support.
The portion of FTEs attributed to Form R activities is approximately 87%
of the total, or 44 FTEs.

Note that total costs are allocated to Form Rs and As in same proportion
as the number of Form Rs and Form As in the ICR Universe (66,751 Form
Rs; 10,255 Form As). See the explanation of these counts in Section
6(d).



Table 5 summarizes the fixed and variable costs associated with
reporting under the EPCRA §313 requirements by form type and by
submission media.

Table 5

Agency Data Processing Costs

	Form R	Form A

	Paper 	CDX 	Diskette 	Paper 	CDX 	Diskette 

Variable

Cost Per Form	$24.79	$6.26	$3.01	$18.42	$6.26	$3.01

Fixed Costs	$3.7 million	$.55 million

Average Cost per Form	$61.25	$59.63



As discussed in the following section, approximately 10,235 Form A
Certification Statements are expected to be filed per year incorporating
projected effects of the TRI Burden Reduction Rule. Thus, the total
annual burden to EPA associated with Form As is estimated to be $0.99
million in fixed costs, $0.06 million in variable costs, and 6 FTEs (or
56,160 hours at $0.7 million in loaded labor costs).  These costs
reflect the burden to conduct the EPA activities described above plus an
additional (variable) cost for each form processed depending on the
submission media. The analysis assumes that, on average, the fixed FTE
requirement is met by EPA employees at the general pay scale for grade
GS-12, step 8 (at a loaded salary of $115,289) using a loading factor of
1.4 that includes wages and benefits but not overhead which is included
in the fixed costs portion of the Agency burden estimate.

6(d) Estimating the Respondent Universe and Total Burden and Costs

Total respondent burden is related to the number of chemical
certifications reported on the Form A Certification Statements and the
number of facilities that file Form A Certification Statements. Table 6
shows the assumed universe of TRI reporters and forms for both the Form
R and Form A ICRs and the effect of changes in Form A eligibility. This
universe is based on reporting in RY2005, adjusted to account for the
impact that TRI Burden Reduction rule is expected to have on Form A
reporting. Due to the TRI Burden Reduction Rule, 6,620 facilities are
expected to make Form A Certification Statements for an additional
11,832 chemicals.  For the purposes of bottom line burden hours and
costs in this ICR Supporting Statement, EPA is summing current Form A
reporting, based on RY2005, and expected increases in Form A reporting,
post the TRI Burden Reduction Rule. This sum yields 10,235 facilities
filing Form A Certification Statements for 22,561 chemicals. Since the
number of Form A Certification Statements that will be filed after the
TRI Burden Reduction Rule is unknown, the estimated number of facilities
filing Form As is used as a proxy for the number of Form A Certification
Statements in the ICR Universe.

It is estimated that approximately 11,780 Form Rs will be replaced by
Form As, assuming all who are eligible for the simplified Form A take
advantage of it. Additionally, a very small number of Form
As—47—will no longer be eligible to be filed as a Form A and will be
replaced by Form Rs due to the new definition of the Annual Reportable
Amount.  These estimates (including newly eligible Form As) are strictly
projections for what is expected in RY2007 given the anticipated effects
of the TRI Burden Reduction Rule and assuming reporter characteristics
are roughly the same in RY2007 as they were in RY2005. See Table 6 for
additional details.

Table 6

ICR Universe of TRI Facilities and Forms

	Form R	Form A

	Number of Chemicals (Same as Number of Forms)	Number of Chemicals
(Note: Average of 2.2 Chemicals per Form)

RY2005 TRI Universe

  Number of Facilities	21,154	4,713

  Number of PBT Chemicals	15,645	221

Number of Non-PBT     Chemicals	62,891	10,754

Newly Eligible for Form A

Number of Facilities	6,620

Number of PBT Chemicals	2,375

Number of Non-PBT Chemicals	9,457

Newly Ineligible for Form A

Number of Facilities	35

Number of Non-PBT Chemicals	47

RY 2008 ICR Universe

Number of Facilities	19,441	10,235

Number of PBT Chemicals	13,270	2,397

Number of Non-PBT Chemicals	53,481	20,164

RY 2008 ICR Universe of Forms

Form R = 78,536-11,832 +47 = 66,751

Form A4 = [(10776+11,832)/2.2]-[47/1.1]=10,235

Notes: 

1. In RY2005 the TRI Burden Reduction Rule was not in place (i.e., no
eligibility for reporting PBTs on Form A) but Form As were incorrectly
filed for 22 PBT chemicals. 

2. The number of facilities cannot simply be added or subtracted across
columns or down rows due to the fact that any given facility may be
filing both Form Rs and a Form A; also note that the categories of
chemicals reported on each form are not mutually exclusive, with overlap
of those switching (by chemical) from Form R to A and vice versa. 3)
These projections assume that the number of facilities filing Form A is
an adequate proxy for the number of Form A Certifications.

4.  To count the number of Form As, the number of chemicals has to be
divided by the number of chemicals per form. For the main group of Form
R chemicals being moved to reports on Form A, the average count of
chemicals per Form A is 2.2; for the small group of chemicals that are
no longer eligible for Form A and moved to Form R, the average count of
chemicals per form is 1.1.



Total respondent burden and cost for the Form A Certification Statement
is shown in Tables 7a and 7b for the current Form A and for the new data
elements, respectively.

Table 7a

Total Annual Respondent Burden and Cost

Activity	Hours	Number of Facilities	Number of Chemicals	Total Burden

Rule Familiarization - First-year filers	34.5	334	N/A	11,523 

Calculations/Certification - First-year Non-PBT filers	44.5	N/A	729
32,441 

Calculations/Certification - First-year PBT filers	43.966	N/A	11	484 

Form A Completion - First-year filers	1.6	334	N/A	528 

Calculations/Certification - Subsequent year Non-PBT filers	16.2	N/A
19,457	315,210 

Calculations/Certification - Subsequent year PBT filers	31.58	N/A	2,364
74,655 

Form A Completion - Subsequent year filers	1.3	9,901	N/A	12,758 

Recordkeeping/Submission - All filers	3.0	N/A	22,561	67,684 

Total Burden



515,284  

Activity	Cost	Number of Facilities	Number of Chemicals	Total Cost

Rule Familiarization - First-year filers	$1,805 	334	N/A	$602,974 

Calculations/Certification - First-year Non-PBT filers	$2,280 	N/A	729
$1,662,095 

Calculations/Certification - First-year PBT filers	$2,253 	N/A	11
$24,779 

Form A Completion - First-year filers	$77 	334	N/A	$25,863 

Calculations/Certification - Subsequent year Non-PBT filers	$831 	N/A
19,457	$16,176,831 

Calculations/Certification - Subsequent year PBT filers	$1,620 	N/A
2,364	$3,829,931 

Form A Completion - Subsequent year filers	$64 	9,901	N/A	$632,763 

Recordkeeping/Submission - All filers	$134 	N/A	22,561	$3,029,820 

Total Cost



$25,985,056



	

Table 7b

Total Incremental Annual Respondent Burden and Cost Increase 

Activity	Minutes	Number of Chemicals	Total Burden (Hours)

Form A Completion - First-year filers



	Include field for Public Contact information	2.0	740	25 

Include code boxes on form to indicate reason(s) for revision or
withdrawal, if a form is being resubmitted	0.0	740	0 

Form A Completion - Subsequent year filers	 	 	 

Include field for Public Contact information	1.6	21,821	592 

Include code boxes on form to indicate reason(s) for revision or
withdrawal, if a form is being resubmitted	0.0	21,821	0 

Total Burden

	617 

Activity	Cost	Number of Chemicals	Total Cost

Form A Completion - First-year filers



	Include field for Public Contact information	$1.18 	740	$874 

Include code boxes on form to indicate reason(s) for revision or
withdrawal, if a form is being resubmitted	$0.00 	740	$0 

Form A Completion - Subsequent year filers	 	 	 

Include field for Public Contact information	$1.01 	21,821	$21,990 

Include code boxes on form to indicate reason(s) for revision or
withdrawal, if a form is being resubmitted	$0.00 	21,821	$0 

Total Cost

	$22,864 

Note that the derivation of reporting burden estimates associated with
the new data elements and revised reporting instructions follows the
methodology used in the Economic Analysis for the TRI Reporting Forms
Modification Rule, July 2005. 

6(e) Bottom-Line Burden and Cost Tables

This section presents the total burden and cost incurred by TRI
reporters that use the alternate reporting threshold under EPCRA §313
and by EPA to process Form As annually.

Respondent Tally

Table 8 presents the total annual reporting burden and cost associated
with Form A.

Table 8

Total Annual Form A Reporting Burden and Cost

	Number of Respondents	Number of Responses	Number of Chemicals for Which
Certifications Statements are Submitted	Annual Burden Hours	Annual Costs

(2006 dollars)

Current Form A	10,235	10,235	22,561	515,284	$25,985,056

New Data Elements and Instructions	10,235	

10,235	

22,561	617	$22,864

Total

515,901	$26,007,920

Notes: 

1. The basis for these estimates is derived from RY2005 TRI reporting.

2. In comparison to the last ICR and last OMB Action, the estimates in
this table reflect a net baseline shift of -213 responses, and -23,404
hours, plus a calculation correction of -6,333 to a previously reported
overstated “Number of Responses.”



The Agency Tally

The total annual burden to EPA associated with Form As is estimated to
be $0.99 million in fixed costs, $0.06 million in variable costs, and 6
FTEs (or 56,160 hours at $0.7 million in loaded labor costs). These
costs reflect the burden to conduct the EPA activities described above
plus an additional (variable) cost for each form processed depending on
the submission media.

Variations in the Annual Bottom Line

Significant variation in the annual respondent reporting/recordkeeping
burden and cost is not expected over the course of the clearance period.

6(f) Reasons for Change in Burden

OMB last approved this Information Collection request on March 3, 2006,
with an expiration date of January 31, 2008. The approved ICR reflected
a Form A respondent reporting burden of 259,192 hours and $12 million.
This previous ICR period was 2006-2007. By the end of 2006, the TRI
Burden Reduction Rule was promulgated and the inventory was recalculated
at 10,227 responses and 509,761 hours (no cost reported) due to shifts
from Form R to Form A.

In this ICR Renewal, the effect of the TRI Burden Reduction Rule is
expected to sustain the reduced overall burden due to increased Form A
eligibility (i.e., number of Form Rs decreased and number of Form As
increased) with total respondent burden and cost of Form A reporting
projected at 10,235 responses, 515,284 hours and $25.99 million.
Further, the TRI program is proposing to add certain data elements to
both reporting forms.  The addition of these data elements is estimated
to increase the total reporting burden and cost for Form A reporting to
515,901 hours and $26.01 million.  

The burden estimated in this supporting statement differs from the last
ICR as a result of increases in the number of chemicals for which
facilities will now be able to file Form A Certification Statements due
to the TRI Reporting Burden Reduction Rule. The number of chemicals for
which Form A Certification Statements will be filed is estimated to
increase from approximately 12,000 chemicals in RY2002 to approximately
22,600 chemicals. The addition of one data element is expected to result
in a minor increase in reporting burden of 617 hours.

Refer to the Form R ICR Supporting Statement, Figure 1 and Table 18 for
extended background information on the chronology of both TRI rulemaking
and ICR Renewal.

6(g) Burden Statement (To appear on Collection Instrument)

The annual public burden for calculations, report completion,
recordkeeping and submission, which is approved under OMB Control No.
2070-0143, is estimated to average 20.52 hours for a facility that
certifies one Non-PBT chemical per Form A Certification Statement and
35.89 hours for a facility that certifies one PBT chemical per Form A
Certification Statement (all estimates incorporate proposed changes). 
Responding to this information collection requires 1) determining
whether a listed toxic chemical is eligible for certification under the
alternate threshold, and 2) completing the Form A Certification
Statement. The burden of determining eligibility for certification and
associated recordkeeping is estimated to average 19.2 hours (not
impacted by changes) for each Non-PBT chemical that is certified and
34.6 hours (not impacted by changes) for each PBT chemical that is
certified. The burden of completing the Form A Certification Statement
is estimated to average 1.32 hours (estimates incorporates proposed
changes), regardless of the number or type (Non-PBT or PBT) of chemicals
being certified. The total burden per response is the combination of
these two, and will vary depending on the number of listed toxic
chemicals being certified.

Burden is defined as the total time, effort, or financial resources
expended by persons to generate, maintain, retain, or disclose or
provide information to or for a Federal agency. This burden includes the
time needed to review instructions; develop, acquire, install, and
utilize technology and systems for the purposes of collecting,
validating, and verifying information, processing and maintaining
information, and disclosing and providing information; adjust the
existing ways to comply with any previously applicable instructions and
requirements; train personnel to be able to respond to a collection of
information; search data sources; complete and review the collection of
information; and transmit or otherwise disclose the information. 

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB control number. The OMB control numbers for EPA's regulations
are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-TRI-2007-0355, which is available for online viewing at
www.regulations.gov, or in-person viewing at the Office of Environmental
Information Docket in the EPA Docket Center (EPA/DC), EPA West, Room
3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket
Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday
through Friday, excluding legal holidays. The telephone number for the
Reading Room is (202) 566-1744, and the telephone number for the Office
of Environmental Information Docket is (202) 566-1752. The
www.regulations.gov site can be used to submit or view public comments,
access the index listing of the contents of the public docket, and
access those documents in the public docket that are available
electronically. When in the system, select “search,” then key in the
Docket ID Number identified above. Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk
Officer for EPA. Please include the EPA Docket ID No.
EPA-HQ-TRI-2007-0355 and OMB Control No. 2070-0143 in any
correspondence.

The completed form should be submitted in accordance with the
instructions accompanying the form.

 

APPENDIX A 

BLANK FORM A

APPENDIX B

REPORTING FORM INSTRUCTIONS 

ASSOCIATED WITH FORM CHANGES



Appendix B: Reporting Form Instructions Associated with Form Changes

This appendix presents the instructions that will accompany the proposed
form revisions and additions by data element.

PART 1 FACILITY IDENTIFICATION INFORMATION

4.4 Public Contact 

Enter the name and telephone number (including area code) of a person
who can respond to questions from the public about the form. You should
also enter an e-mail address for this person. If you choose to designate
the same person as both the Technical and the Public Contact, or you do
not have a Public Contact, you may enter “Same as Section 4.3” in
this space. This contact person does not have to be the same person who
prepares the form or signs the Certification Statement and does not
necessarily need to be someone at the location of the reporting
facility. 

PART II CHEMICAL-SPECIFIC INFORMATION 

Basis of Estimate Instructions (Applies to Form R only)

 tc \l3 "Section 5 Column B: Basis of Estimate 

For each release and otherwise managed waste estimate (Sections 5 & 6),
you are required to indicate the principal method used to determine the
amount of release and otherwise managed waste reported. You should enter
a letter code identifying the method that applies to the largest portion
of the total estimated release and otherwise managed waste quantity.

The codes are as follows:

M1 – Continuous emission monitoring

M2 – Periodic or random emission monitoring

C – Mass balance calculations

E1 – Published emission factor

E2 – Site-specific emission factor

O – Other methods of estimation

For example, if 40 percent of stack emissions of the reported EPCRA  XE
"EPCRA"   §313 chemical were derived using source testing data, 30
percent by mass balance, and 30 percent by published chemical-specific
emission factors, you should enter the code letter “M2” for periodic
or random emission monitoring.

If the monitoring data, mass balance, or emission factor used to
estimate the release is not specific to the EPCRA  XE "EPCRA"   §313
chemical being reported, the form should identify the estimate as based
on other methods of estimation (O).

If a mass balance calculation yields the flow rate of a waste, but the
quantity of reported EPCRA  XE "EPCRA"   §313 chemical in the waste is
based on solubility data, you should report “O” because engineering
calculations were used as the basis of estimate of the quantity of the
EPCRA  XE "EPCRA"   §313 chemical in the waste.

If the concentration of the EPCRA  XE "EPCRA"   §313 chemical in the
waste was measured by continuous emissions monitoring equipment and the
flow rate of the waste was determined by mass balance, then the primary
basis of the estimate should be “continuous emission monitoring”
(M1). Even though a mass balance calculation also contributed to the
estimate, “continuous emission monitoring” should be indicated
because monitoring data were used to estimate the concentration of the
chemical in waste.

Mass balance (C) should only be indicated if it is directly used to
calculate the mass (weight) of EPCRA  XE "EPCRA"   §313 chemical
released. Monitoring data should be indicated as the basis of estimate
only if the EPCRA  XE "EPCRA"   §313 chemical concentration is measured
in the waste.  Monitoring data should not be indicated, for example, if
the monitoring data relate to a concentration of the EPCRA  XE "EPCRA"  
§313 chemical in other process streams within the facility.

It is important to realize that the accuracy and proficiency of release
estimation will improve over time. However, submitters are not required
to use new emission factors or estimation techniques to revise previous
Form R submissions.

Submitting a Request to Revise TRI Data 

Facilities that filed a Form R and/or Form A Certification Statement
under EPCRA § 313 may submit a request to revise a form that was
previously submitted, stored in the Toxics Release Inventory Processing
System (TRIPS), and made available to the public through Envirofacts and
TRI Explorer.  Facilities may request a revision for one or more of the
following reasons:

•	New Monitoring Data (RR1)

•	New Emission Factor(s) (RR2)

•	New Chemical Concentration Data (RR3)

•	Recalculation(s) (RR4)

•	Other Reason(s) (RR5)

The revision code(s) should be entered in the “Revision” box on the
first page of the reporting form.  You may enter up to two revision
codes on the form. 

Please note that late submissions for chemicals not reported in a
previous reporting year are not considered revisions for that year.

How do I revise my submission(s)?

If you have determined that your facility wishes to revise a TRI
submission, you must send your request to EPA and the appropriate State
agency.  For submitting a revision to EPA, please use one of the
following methods:

1.  TRI-MEweb.  The preferred method for revising TRI forms from
Reporting Year 2005 through the current year is to use TRI-MEweb.  For
more information regarding access to TRI-MEweb, please visit   HYPERLINK
"http://www.epa.gov/tri"  http://www.epa.gov/tri .  TRI-MEweb provides
several advantages compared to hard-copy reporting, such as
pre-populating the form with the previous year’s data, allowing
reporters to electronically sign and submit the form over the Internet,
providing automated data quality checks, and electronically confirming
EPA’s receipt of a submitted form.  If you have questions about
accessing TRI-MEweb, please contact the CDX Hotline at epacdx@csc.com or
call toll-free at 1-888-890-1995.

2.  TRI-ME via CDX.  The preferred method for revising TRI forms from
Reporting Year 2002 through Reporting Year 2004 is to use the TRI
Made-Easy (TRI-ME) software and submit the report via CDX and the
Internet.  You can download the TRI-ME software at   HYPERLINK
"http://www.epa.gov/tri"  http://www.epa.gov/tri .  If revising a report
from a particular reporting year, you must use the TRI-ME software for
that same reporting year.  For example, if you are revising a form for
Reporting Year 2003, you must use the Reporting Year 2003 version of
TRI-ME, which is available at   HYPERLINK "http://www.epa.gov/tri" 
http://www.epa.gov/tri .  If you have questions about using the TRI-ME
software and submitting a report through CDX, please contact the CDX
Hotline at epacdx@csc.com or call toll-free at 1-888-890-1995. 

3.  TRI-ME  XE "TRI-ME"   via Diskette.  If you do not have Internet
access and you wish to revise a form for Reporting Year 2005 or a prior
year, EPA encourages you to use the TRI-ME software and to submit your
revised report by diskette to one of the addresses below.  All diskette
submissions must be accompanied by a signed Certification Statement.  If
you do not have the TRI-ME software for the reporting year  XE
"Reporting Year"   that you need, please contact EPA at 301-429-5005.  

Send diskette or hard copy revision requests by regular mail to the
following address:

TRI Data Processing Center

P.O. Box 1513

Lanham, MD 20703-1513

Attention: TRI Revision Request

Send diskette or hard copy revision requests by certified mail or
overnight mail to the following address:

TRI Data Processing Center

c/o Computer Sciences Corporation

Suite 150

8400 Corporate Drive

Landover, MD 20785-2294	

Attention: TRI Revision Request

Phone:  301-429-5005

4.  Hard Copy Form.  EPA strongly discourages paper submissions due to
the increased possibility of data entry errors; however, if necessary,
you may revise a previously submitted hard-copy form by using either 1)
a photocopy of the original or 2) a blank form.  

Photocopy of Original Submission.  You may submit a photocopy of your
original submission (from your file) with the corrections made in blue
ink.  Please re-sign and re-date the certification statement on Page 1. 
For RY 2007 revisions and beyond, please enter the appropriate revision
code(s).  For RY 2006 and prior years, please enter an “X” in the
space marked “Enter ‘X’ here if this is a revision,” on page 1
of the form.

Blank Form.  Hard copy submissions may be submitted using the form
applicable for that particular reporting year or the most recent form
available.  You can request prior year reporting forms at
tridocs@epa.gov.  For RY 2007 revisions and beyond, please enter in the
appropriate revision code(s).  For RY 2006 and prior years, please enter
an “X” in the space marked “Enter ‘X’ here if this is a
revision,” on page 1 of the form.

See 3. above for mailing instructions for diskette and hard copy
revision requests. 

Submitting a Request to Withdraw  XE "Withdraw"   TRI Data

Facilities that filed a Form R and/or Form A Certification Statement
under EPCRA §313 may submit a request to withdraw a form that was
previously submitted, stored in the Toxics Release Inventory Processing
System (TRIPS), and made available to the public through Envirofacts and
TRI Explorer.  EPA may periodically review withdrawals. 

Facilities may request a withdrawal for one or several reasons, such as:

•	Did not meet the reporting threshold for manufacturing, processing,
or otherwise use (WT1)

•	Did not meet the reporting threshold for number of employees (WT2) 

•	Not in a covered NAICS Code (WT3) 

•	Other reason(s) (WO1)

The withdrawal code(s) should be entered in the “Withdrawal” box on
the first page of the reporting form.  You may enter up to two
withdrawal codes on the form.

How do I withdraw my submission(s)?

If you have determined that your facility wishes to withdraw a TRI
submission, you must send your request to EPA and the appropriate State
agency.  For submitting a withdrawal to EPA, please use one of the
following methods:

1.    TRI-MEweb. The preferred method for requesting a withdrawal of a
previously submitted TRI form from Reporting Year 2005 through the
current year is TRI-MEweb.  For more information regarding access to
TRI-MEweb, please visit   HYPERLINK "http://www.epa.gov/tri" 
http://www.epa.gov/tri  or contact the CDX Hotline at epacdx@csc.com or
call toll-free at 1-888-890-1995.

2. TRI-ME via CDX.  For the RY 2007 version of the software only,
withdrawals may be submitted electronically using the TRI-ME  software
and submitting the report via CDX and the Internet.  You can download
the TRI-ME software at   HYPERLINK "http://www.epa.gov/tri" 
http://www.epa.gov/tri .  If you have questions about submitting via
CDX, please contact the CDX Hotline at epacdx@csc.com or call toll-free
at 1-888-890-1995.

3. TRI-ME via Diskette.  For the RY 2007 version of the software only,
withdrawals can be submitted via diskette to one of the addresses below.
 Withdrawals submitted on diskette using the prior versions of the
TRI-ME software will not be accepted.  

Send diskette or hard copy withdrawal requests by regular mail to the
following address:

TRI Data Processing Center

P.O. Box 1513

Lanham, MD 20703-1513

Attention: TRI Withdrawal Request

Send diskette or hard copy withdrawal requests by certified mail or
overnight mail to the following address:

TRI Data Processing Center

c/o Computer Sciences Corporation

Suite 150

8400 Corporate Drive

Landover, MD 20785-2294

Attention: TRI Withdrawal Request

Phone:  301-429-5005

4.   Hard Copy Form.  All other withdrawal requests may be submitted by
hard copy as follows:

Reporting Year 2007 Forward.  You may submit a photocopy of your
original submission (from your file).  Using blue ink, re-sign and
re-date the certification statement on Page 1 and enter the appropriate
withdrawal code(s) in the space provided on page 1 of the form.\

Reporting Year 2006 and Prior Years.  Please submit a photocopy of the
form you wish to withdraw (from your file), and attach – as a cover
page – page 1 of the current year’s reporting form, which includes a
field for the withdrawal codes.  Using blue ink, please sign and date
the certification statement and enter the appropriate withdrawal code(s)
in the space provided on page 1 of the current year’s form.  

See 3. above for mailing instructions for diskette and hard copy
withdrawal requests. 

 Certain sectors are subject to TRI reporting. For a complete listing of
the North American Industry Classification System (NAICS) codes subject
to TRI reporting see Appendix F of this ICR Supporting Statement. These
NAICS codes correspond to the Standard Industrial Classification (SIC)
codes included in the statutory requirement pursuant to EPCRA §313 (42
U.S.C. 11001 et seq.) and PPA §6607 (42 U.S.C. 11071 to 11079).

 Refer to Appendix A of this Supporting Statement for a blank Form A;
refer to Appendix A of the Form R Supporting Statement for a blank Form
R. For the full set of instructions and Forms, refer to
http://www.epa.gov/tri/report/#forms.

 For specific details, refer to Appendix A: Blank Form A, and Appendix
B: Reporting Form Instructions Associated with Form Changes.

 The Office of Management and Budget publishes these guidelines in
accordance with the Guidelines for Ensuring and Maximizing the Quality,
Objectivity, Utility, and Integrity of Information Disseminated by
Federal Agencies (Government-wide Guidelines) published in interim final
form by OMB in the Federal Register in Volume 66, No. 189 at 49718 on
September 28, 2001, and updated in final form in Volume 2, No. 67 at
8452 on February 22, 2002.

  For a complete chronology of TRI rulemaking and ICR Renewals along
with resultant impact on Form R reporting burden, see Figure 1 and Table
18 of the Form R ICR Supporting Statement.

 The previous ICR period was 2006-2007. By the end of 2006, the TRI
Burden Reduction Rule was promulgated and the inventory was recalculated
at 3,344,292 hours  (no cost reported) due to shifts from Form R
reporting to Form A (decrease of Form R burden of 402,298 hours--see
Economic Analysis of the TRI Burden Reduction Rule, December 2006).
Please note that the recalculation of burden was estimated by
subtracting projected changes from the previous ICR inventory. This
calculation differs from the approach taken in the current ICR renewal
economic analyses. In the 2006 calculation, the base number of the
previous inventory was derived under different conditions (RY2002,
93,380 total forms) than the increments (RY2005, 89,312 total forms). In
this ICR renewal (and Form R/A Supporting Statements), FY2005 data are
used for baseline and increment estimates.  

 To access TRI Reporting Forms and Instructions, see
http://www.epa.gov/tri/report/#forms.

 A copy of the Form A Certification Statement is attached in Appendix A.
 To access TRI Reporting Forms and Instructions, see
http://www.epa.gov/tri/report/#forms.

 For specific details, refer to Appendix A: Blank Form R, and Appendix
B: Reporting Form Instructions Associated with Form Changes.

 Reporting instructions associated with the new data elements are
presented in Appendix B.

 TRI-MEweb is slated to become the sole reporting software for TRI
electronic reporting in 2009 or 2010, when the desktop version of TRI-ME
will be discontinued.

 Prior to the TRI Burden Reduction Rule, the Annual Reportable Amount
was defined as the sum of quantities reported in Form R sections
8.1-8.7; with implementation of TRI Burden Reduction Rule, the Annual
Reportable Amount was redefined to include the sum of quantities in
sections 8.1-8.8.  As a result, some facilities previously filing Form
As are expected to have to report on Form R instead.

 The methodology used in this ICR to estimate the number of forms and
facilities that would be affected by the TRI Burden Reduction Rule is
the same as the methodology used in the Economic Analysis (EA) of the
TRI Burden Reduction Rule.  Due to the difference in reporting years
used in each analysis (RY2004 in the EA and RY2005 in the ICR), however,
the estimated number of forms and facilities affected by the TRI Burden
Reduction Rule differs slightly between analyses.

 For a complete chronology of Rule changes and ICR Renewals along with
resultant impact on Form R reporting burden, see Table18 of the Form R
ICR.

 The previous ICR period was 2006-2007. By the end of 2006, the TRI
Burden Reduction Rule was promulgated, and the inventory was
recalculated at 3,344,292 hours (no cost reported) due to shifts from
Form R to Form A reporting (decrease of Form R burden of 402,298
hours—see the Economic Analysis of the TRI Burden Reduction Rule,
December 2006). Please note that the recalculation of burden was
estimated by subtracting projected changes from the previous ICR
inventory. This calculation differs from the approach taken in the
current ICR Renewal’s economic analyses. In the 2006 calculation, the
base number of the previous inventory was derived under different
conditions (RY 2002, 93,380 total forms) than the increments (RY2005,
89,312 total forms). In this ICR Renewal (and Form R/A Supporting
Statements), RY 2005 data are used for baseline and increment estimates.

 Facilities must also determine whether they are within a covered NAICS
code; have the equivalent of 10 or more full-time employees; and
manufacture, process or use any of the listed toxic chemicals above the
threshold quantity. The time required for compliance determination at
all facilities in covered NAICS codes with 10 or more employees is
already accounted for in the Form R ICR (see Form R ICR Supporting
Statement).

 Estimates here apply to Form A only; Form R already has a field for
Public Contact that is being modified to include email address. For Form
R, the burden associated with the corresponding change—adding an email
address— is assumed to be negligible.

 Employer Costs for Employee Compensation, Private industry workers,
Goods-producing industries, white-collar occupations, as published by
the U.S. Department of Labor, Bureau of Labor Statistics. The September
2006 values for these series are listed in Table 11 of the Employer
Costs for Employee Compensation Summary.

 Note that, in a limited number of cases, the TRI Burden Reduction rule
may require some facilities currently filing Form As to switch back to
Form Rs (see next section and next footnote).

 Prior to the TRI Burden Reduction Rule, the Annual Reportable Amount
was defined as the sum of quantities reported in Form R Sections
8.1-8.7; with implementation of the TRI Burden Reduction Rule, the
Annual Reportable Amount was redefined to include the sum of quantities
in Sections 8.1-8.8.   Based on RY2005 TRI data, it is estimated that 35
facilities currently filing Form As on 47 chemicals would lose Form A
eligibility.  

 Originally recalculated and reported on the OMB Action at 16,781
responses and 538,688 hours; estimates in text are corrected to
incorporate a baseline shift and an overstated erroneous estimate of the
“Number of Responses.” The revised numbers for this last OMB Action
in text are based on a consistent base and increment (RY2004) as are the
final estimates for this ICR Universe in Table 8 (RY2005). By
comparison, the previous recalculation was estimated by adding projected
changes (derived from RY2004 with 89,645 total forms A and R) to the
previous ICR inventory (based on RY2002 with 93,380 total forms A and
R),without accounting for baseline shifts related to decreases in Form A
reporting overall since RY2002.  

										August 2005

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December 2007

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October 2005

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December 2007

