# Revising TRI Burden to Ratio-Based Methodology

Information Collection Re quest Renewal (ICR) 2 nd 

## FR Notice

April 28, 2011

TRI Regulatory De velopment Branch TRI Program Division
Office of Information Analysis and Access
Office of Environm ental Informationii Authors

EPA Laura B. Nielsen, Ph.D.
Kara Koehrn Andrew Prugar Zachary Scott
Esmeralda Stuk

Abt Associates Inc. Susan Day
Svetlana Semenova
Rebecca Finkiii Table of Contents

Abstract iv Acknowledgment v Introduction 1
Overview 1 TRI Program Burden Estimate Requirements and Uses 4 Background Research: Relevant History and Methodology Comparisons 5 Ratio-Based Burden Methodology, Methods, and Models 9
Benefits 12

Appendix A. Methodology Overview a nd Guide to Methods Technical Appendices (B-E) A-1 to A-18 Appendix B. Steady State Total Burden Calculation B-1 to B-26 Appendix C. Form Element Estimation C-1 to C-16 Appendix D. First-Time Filer Estimation D-1 to D-4 Appendix E. Cost Conversion E-1 to E-6 Appendix F. Program Staff Tool F-1 to F-8 Appendix G. Abt Associates E ngineering Studies G-1 to G-64 Appendix H. Peer Review Information H-1 to H-4iv Abstract

The TRI Program Division is proposing to revise the TRI burden methodology to a Ratio-Based Burden Methodology (RBBM) to boost efficien cy and sharpen transparency. Through simplifications, internal consis tency, and better access, EPA staff and the general public will obtain faster, more reliable, and more understandable burden estimates for a variety of uses. The TRI Program Division envisions implementing this methodology in the 2012 ICR Renewal. Thereafter, the methodology will also be employed in economic analyses associated with TRI rulemakings.

RBBM simplifies calculations and imposes intern al consistency while maintaining the overall total Program burden estimate as a starting point. The revised structure consists of four ratio models plus one base number, the Nominal Form R unit burden . The ratio models characterize key relationships of TRI burden estimation. For example, the A/R model, a ratio of Form A (single-chemical) to Form R burden, ensures inte rnal consistency betwee n Form A and Form R
burden estimates. The Nominal Form R unit burden provides a comprehensive unit burden of 35.7 hours per Form R and consequently also supports focused discussions about burden estimate accuracy.

TRI’s burden estimates comply with Paperw ork Reduction Act (PRA) requirements for providing burden estimates, “to the extent practi cable,” while reflecting a reasonable sense of average conditions and an appropr iate level of specificity. The activities included in burden
estimates are the same in RBBM as under the previous methodology. For activities associated with filing TRI Form R/Form A chemical reports , burden estimates include: rule familiarization, compliance determination, calculations and Form completion, and recordkeeping and
submission. For activities unrelated to Form reporting, burden estim ates include: supplier notification, non-reporter complian ce determination, and petitions.

As a result of RBBM’s simplicity, internal consistency, and accessibility, the TRI Program Division anticipates that staff will need to spe nd less time and effort developing TRI information collection burden information. In addition, ease of re-creating estimates supports administrative consistency, while improved access to calcu lations affords greater transparency.v Acknowledgment

The authors thank the following colleagues who pr ovided a fresh perspective in their informal reviews of portions, or of the entire draft, at various stages of document development.

Rachel Alford Daniel Bushman, Ph.D.
Louise Camalier
Constance Downs Olga Faktorovich Thomas Forbes, Ph.D. Gregory Nielsen Barry Nussbaum, D.Sc. Cody Rice Denice Shaw, Ph.D.
Daniel Teitelbaumvi THIS PAGE INTENTIONAL LY LEFT BLANKRevising TRI Burden to Ratio-Based Methodology

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1 Introduction

The purpose of this document is to provide technical explanation and documentation for the Ratio-Based Burden Methodology (RBBM), as current ly proposed for use in the Toxics Release Inventory (TRI) Program. In addition, EPA explains how RBBM will be able to provide improvements in efficiency, administrative cons istency, and transparenc y. EPA begins with an overview of the methodology, followed by backgr ound information, and research comparing burden estimate methodologies. EPA then explains the RBBM approach, including quantitative details of its constituent methods, such as the Steady State Total Burden Calculation (page 10). Lastly, EPA presents the benefits of using RBBM. Appendices A-E supplement the main body of the report. More specifically, EPA provide s an overview of the methodology in Appendix A, followed by technical appendices for each of the constituent methods: Steady State Total Burden Calculation, Form Element Estimation, First- Time Filer Estimation, and Cost Conversion (Appendices B-E, respectively).

Additional appendices F-H are provided as refe rence material. Appendix F depicts the Program Staff Tool, a Microsoft Excel spreadsheet which is designed to provide a user-friendly interface for generating burden estimates. Appendix G provid es the Abt Associates Engineering Studies, which provide previously develope d detailed data element-specific burden estimates used as the building blocks for RBBM’s ratio models. Appendi x H summarizes the May 2010 peer review of
an earlier draft of this document. Also useful for reference are: 1) the Form R and Form A ICR Supporting Statements 1 from the 2008 TRI ICR, and 2) th e Form R and Form A ICR Supporting
Statement 2 for the ICR slated in 2012, which illust rate the existing and revised methodologies, respectively. The latter item is being published concurrently with this document (originally and with this revised version).

Overview

Ratio-Based Burden Methodology (RBBM) simplifi es calculations, establishes internal consistency, and sharpens transparency wh ile retaining the components of the existing methodology and maintaining the overall total Progr am burden estimate as a starting point. EPA initiated this methodolog y revision due to its experience w ith Information Collection Request (ICR) renewals and rulemaking economic analyses (EAs) that were particularly complex and/or performed under tight time constraints. In less fo rmal settings, additional ideas for characterizing burden emerged from staff experiences while ge nerating burden estimates. Consequently, EPA sought improvements on the current approach, as guided by two key questions: 1) What is the simplest and easiest way to calculate burden? an d 2) How can EPA best provide clearly defined
and consistent estimates?

The current methodology for estimating burden hours a nd cost is based on a system of 96 factors organized into four categories as shown in Fi gure 1. There are 96 total factors because for each of the four categories—persistent bioaccumulativ e and toxic (PBT) first year, PBT subsequent

1 Toxics Release Inventory (TRI) Form R Toxic Chemical Release Reporting Informa tion Collection Request Supporting Statement. EPA ICR #1363.15. March 02, 2008. and Toxics Release Inventory (TRI) Alternate Threshold For Low Annual Reportable Amounts; TRI Form A Toxic Chemical Release Reporting Information Collection Request Supporting Statement. EPA ICR # 1704.09. March 2, 2008. Docket #EPA-HQ-TRI2007-0355.

2 Toxics Release Inventory (TRI) Form R and Form A Toxic Chemic al Release Reporting Informati on Collection Request Supporting Sta tement. EPA ICR#1363.21. OMB Control No. 2025-0009. Date Forthcoming. Do cket # EPA-HQ-OEI-2010-0835; hereafter referred to as TRI 2012 ICR Supporting Statement.Revising TRI Burden to Ratio-Based Methodology

year, nonPBT first year, nonPBT subsequent year —there are 12 factors (t wo for each facilitylevel and form-level, estimated across three labor categories—manage rial, technical and clerical). Taking those 12 factors across four cat egories and two Forms (R and A) yields this
total of 96 factors. For each category’s set of factors, such as Form R non-PBT subsequent year unit burdens, a relevant subpopulation TRI chemical count must be provided – for example, the number of subsequent year non-PBT Form R chemi cals. The factors in Figur e 1 are referred to as OMB-approved, as these unit burdens are official ly approved by the Office of Management and Budget (OMB) for use in estimating TR I Program burden as of March 27, 2008.

Figure 1 Current Methodology Complexity: Numerous Burden Factors and Chemical Counts

In developing RBBM, EPA decided to restructure th is system for several r easons: 1) calculations could be greatly simplified via algebraic reduc tion, 2) relationships between interrelated categories could be specified via ratio models to remove potential internal inconsistencies, 3) multiple scales could be unified to pr event certain accounting errors caused by doublecounting (i.e., facility-level conve rted to form-level factors). 3

Table 1 provides a structural comparison between the existing methodology and RBBM as applied to Form R burden. 4 Note that RBBM consolidates PB T factors and first-year factors within the base “Form R unit burden” to yield one unit burden instead of multiple unit burdens. Moreover, this single unit burden is comprehensiv e and thus incorporates all activities (e.g. rule familiarization, form completion, etc.) which co ntribute to the burden of Form R reporting.

3 Under the existing methodology, the double-counting potential exists due to the facility-level unit burdens in two situations 1 ) via the structure by which Form A and Form R reporting is estimated separately with both estimates counting facility burden 2) the rulemaking con text in which additional reports are added from facilities that already handle facility level burden re gardless of the changes imposed by the rule. Both these sources of error are prevented in RBBM.

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2 4 The same comparison applies for Form A, but is omitted for ease of presentation.Revising TRI Burden to Ratio-Based Methodology

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3 Therefore, in addition to requiring fewer unit burdens (with fewer subpop ulations to track), RBBM’s comprehensive unit burden permits th e estimation of total burden by simply multiplying just one unit burden by the total numbe r of chemicals. In this case, total “Form R burden” can be estimated by “Form R unit burden” multiplied by the “number of Form R
chemicals.”

Table 1: Burden Methodology Calculation Factors and Unit Burdens – Form R

Current Burden via Existing Methodology Steady State Burden via RBBM Estimate Description: Su m the numerous products of factors multiplied by chemical counts or facilities (depending on the scale of the factor). Estimate Description: multiply the comprehensive unit burden by total
number of chemicals.

Estimation Factors Per (chemical) form-level:

• hrs per PBT, subsequent year,

• hrs per PBT, first year

• hrs per non-PBT, subsequent year

• hrs per non-PBT, first year

per facility-level:

• hrs for PBT and non-PBT, subsequent year

• hrs for PBT and non-PBT, first year Estimation Factor

Per (chemical) form-level:

• hrs per chemical*

Reported Unit Burdens (do not include related facility-level burden) Î 29.66 hrs per Form R non-PBT (subsequent year) Î 53.34 hrs per Form R PBT (subsequent year) Reported Unit Burden

Î 35.7 hrs per Form R

* Incorporates all the same considerations as the ex isting methodology. Simplifications are detailed in the Ratio-Based Burden Methodology, Methods and Models Section (p.9). See also Appendix B.

Focusing on RBBM information in Table 1 to present the total burden estimate, Figure 2 provides the Steady State Total Burden Calculation, RBBM’s primary method. Steady State
Total Burden is the estimate of the ongoing TRI Program burden, as updated by rulemakings’ permanent impacts, but absent any first-time filer impacts. Note that the only inputs required for
this estimate are the total counts of Form R and Form A chemicals. Next, EPA describes the key
factors within RBBM’s re formulated structure.

The Nominal Form R unit burden is the unit burden for Form R. As a component of RBBM, it provides the base number for the entire met hodology. For the transition to RBBM, its value is back-calculated in order to maintain the established baseline’s total burden. In practice, the
Nominal Form R unit burden provides the primary focal point for assessing and maintaining RBBM’s accuracy.

Form A unit burden is defined as Nominal Form R unit burden multiplied by A/R , a model of the ratio of Form A single-chemical burden 5 to Form R burden. The value for A/R is derived by assessing the Form R burden for activities si milarly required to complete a Form A. A/R

5 Although Form A permits multiple chemical reports on the same fo rm (on average 2.31 chemicals per Form A), for purposes of met hods development and modeling, EPA works with ch emical counts, referring to “Form R chemical s” and “Form A chemicals.” Note that for Form R reporting, there is only one chemical per Form.Revising TRI Burden to Ratio-Based Methodology

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4 specifies the relationship betw een Form A and Form R burden. 6 The examples in Table 1 and Figure 2 illustrate that RBBM incorporates the same components of the existing methodology, but offers a much simpler formulation. Furthermore, the use of ratio models such as A/R ensures internal consistency within the new structure. Figure 2 Ratio-Based Burden Methodology Two Unit Burdens; Two Chemical Counts; One Wage Rate

Steady State Total Burden Calculation

1) Steady State Total Burden = Form R Burden + Form A Burden + Non-Form Burden

Where: Form R Burden = (# Form R Chemicals) * (Nominal Form R Unit Burden) Form A Burden = (# Form A Chemicals) * (A/R) * (Nominal Form R Unit Burden)
Non-Form Burden = (Supplier Notification) + (Non-Reporter Compliance Determination) + (Petitions)

And: A/R, Ratio of Form A Burden to Form R Burden = 0.615 Nominal Form R Unit Burden = 35.7 hours per Form R Chemical Form A Unit Burden (derived) = 22.0 hours per Form A Chemical

2) Steady State Total Cost = Steady State Total Burden * (WAWR)

And: WAWR, Weighted Average Wage Rate = $49.62/hour †

† Based on June 2010 wage data. Wage data: http://www.bls.gov/ncs/ect/#tables

TRI Burden Estimate Requirements and Uses

Under the Emergency Planning and Community Ri ght to Know Act (EPCRA), the TRI Program, as authorized under Section 313, requires reporti ng facilities to submit data annually on use and management of toxic chemicals. As part of EPA’s responsibilities to the public under the Paperwork Reduction Act (PRA), EPA must regularly satisfy requirements that permit information collection from members of the genera l public, including industry participants in the TRI reporting community. One of these requirem ents is to ensure that each information collection exercise “...informs the person receivi ng the collection of information of—...(III) an estimate, to the extent practicable , of the burden of the collection.” 7 Burden estimates encompass “...the total time, effort, or financial resources expended by persons to generate, maintain, retain, disclose, or provide information to or for a federal agency.” These estimates should consider
time needed to: 8

6 The bases for A/R include detailed burden estimates by task, making the A/R model verifiable and readily subj ect to validation. See Appendix B for development and Appendix G for de tailed burden estimates by task.

7 US National Archives and Records Administration, Paperwork Reduction Act of 1995, Accessed 23 Mar 2010 < http://www.archives.gov/federal-regist er/laws/paperwork-reduction/3506.html >

8 See EPA. 1999. ICR Handbook: EPA’s Guide to Writing Information Collection Requests Under the Pa perwork Reduction Act of 1995.
Accessed 2 Feb 2010 < http://www.epa.gov/wed/page s/opportunities/icrhndbk.pdf >Revising TRI Burden to Ratio-Based Methodology

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5 • Review instructions;

• Develop, acquire, install, utilize tech nology and systems, for the purpose of collecting, validating and verifying in formation, 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 res pond to a collection of information;

• Search data sources;

• Complete and review the collection of information; and

• Transmit or otherwise disclose the information.

For the TRI Program, these consid erations translate to factors that reflect industry efforts associated with form burden—rule familiarization, compliance determination, calculations and form completion, recordkeeping, and non-form burden—supplier no tification, non-reporter compliance determination, and petitions.

The TRI Program uses burden estimates in the cont ext of three main types of Program activities: ICR renewal, rulemaking economic analyses, and in formal informational gathering. At the time of the ICR renewal, which is performed every three years, EPA’s TRI Program must update the
burden estimates that OMB has on record for th e current burden associated with TRI reporting. The Supporting Statement for the ICR renewal provides estimates of the program’s ongoing burden—or steady state total burden— in labor hours, and cost in current dollars. These estimates
are obtained based on actual conditions as measured in the most recent TRI reports. 9

In the context of a rulemaking, the economic analysis provides burden estimates in order to predict the impact of the polic y change(s) under cons ideration. Upon policy implementation, this estimated incremental change in burden is added or subtracted from the current burden estimate that OMB has on record. If the rulemaking incr eases the number of reporters or otherwise imposes reporter start-up burden, the economic analys is also provides estimates of first-time filer burden incurred during the first ye ar of a policy change. Note th at economic analysis estimates, both steady state and first-time filer, are base d on models—not actual conditions. If there are differences between the economic analysis pr edictions and the actu al conditions, these differences are implicitly reconciled at the ne xt ICR renewal as the ICR is based on actual reporting of Form R and Form A chemicals. 10

Background Research: Relevant Hist ory and Methodology Comparisons

The information in this section provides backgr ound in preparation for presenting more detail
about RBBM in the next section. The methodol ogy history explains how the TRI Program

9 Estimates based on actual conditions contra st to estimates based on mode l projections. Note that in the event that the TRI pro gram implements policy changes due to a rulemaking finalized in the course of th e year of the ICR renewal proj ect, the ICR renewal burden estim ates are updated using more current info rmation and/or models.

10 For example, when new policy permits decr eases in reporting that are not fully utili zed, the economic analysis may predict a r eduction in reporting, while the ICR measures the actual reporting at levels higher than originally modeled/anticipated.Revising TRI Burden to Ratio-Based Methodology

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6 burden methodology has evolved. Methodology comparisons show that EPA’s existing and revised methodologies fit within the range of currently accepted practices. 11

Methodology History

Under the existing methodology, EPA calculates total industry burden estimates using a methodology established at the TRI Program inception that has since been periodically reviewed and approved by OMB during ICR renewals. For ex ample, as the program underwent changes in reporting—such as implementing the shorter Form A—the methodology underwent reviews and occasional revisions. Beyond minor adjustments to include additional form elements, the biggest
revision occurred in the 2004 ICR Renewal when ch anges to the system of unit burden factors were adopted.

As preparation prior to the 2004 ICR renewal, EP A staff questioned the magnitude of estimates and related unit burdens which had not been up dated since the beginning of the TRI program, given the fact that the program had implemen ted technological adva nces designed to ease reporter burden. 12 Based on numerous evidentiary sources , EPA proposed a systematic revision to the methodology. After the public comment peri od and OMB review, partial revisions were implemented which lowered total burden estimates by 49%, 13 and also resulted in: 14

• Reducing the amount of Form R Non-PBT unit burden, while holding PBT unit burden constant, thereby unintentionally imposing a distinction in which PBT burden is 1.73 of non-PBT burden (i.e., 73% higher). This change occurred as an offshoot of the revision process, rather than as a deliberate specification.

• Maintaining the ratio of Form A unit burden to Form R unit burden at .64 as previously
determined. 15

Subsequently, during the Phase I Burden Re duction Rule, EPA proposed to revise the methodology using a basis developed in Abt Asso ciates Engineering St udies. The July 2004 document and methodology was peer-reviewed w ith results posted in the public docket (Proposed Rule EPA HQ-TRI-2005-0073). The me thod was neither finalized nor formally adopted into TRI burde n estimation practice.

By the time of the 2008 ICR revision, TRI staff and management recognized sources of potential internal inconsistency that, at a minimum, led to confusion and/or inefficiency. For example, the
ratio of .64 for Form A to Form R burden was not readily verifiable. A dditionally, the effective
ratio of 1.73 for PBT to non-PBT burden was not di rectly specified, and therefore could not be verified. Lastly, procedures for revising/adding form elements occasionally used a set of
estimates which were not reconciled to the whol e (form) unit burden, and therefore could not be

11 Per analysis in Table 2. Sources: EPA -TRI Program Staff (June 2009); IRS – Office of Research, Taxpayer Analysis and Modeling Group (June 2009).

12 An electronic version of the Reporting Forms and Instructions was initially implemented in desk-top software ( TRI-ME CD) and later upgraded to Web-based technology ( TRI-MEweb ).

13 Total TRI Program burden estimate was decreased from 6.03 mil lion to 2.61 million hours based on Notices of OMB Action (called Paperwork Reduction Submissions) for Form R ICR and Form A ICR. Submitte d October 27, 2003; Approved Janua ry 9, 2004. Per the 2004 ICR Supporting Statement, 85.95 % of the (57%) total reduction was associated with adjustment of “unit burden for Form R completion in subsequent years from 47.1 to 14.5 hours,” yielding a 49% decrease in total burden associated with the me thodology change. See Appendix B for full
breakdown of the 2004 ICR renewal 57% decrease.

14 For context and details, see: Rice, Cody. 2004. Terms of Clear ance for TRI ICR Renewal. Regul ations.gov. Accessed 23 Dec 2010

< http://www.regulations.gov/#!docume ntDetail;D=EPA-HQ-OEI-2004-0006-0004 >

15 See Appendix B for additional detail a nd references to supporting material.Revising TRI Burden to Ratio-Based Methodology

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7 applied consistently across Form R and Form A. As a result of these issues, EPA staff had limited ability to manage questions about the origin and validity of burden estimates. From these observations, EPA concluded that a revised methodology should requir e internally consistent and
verifiable unit burdens.

Methodology Comparisons

In the process of seeking guidance for RBBM’s design, EPA staff reviewed a range of approaches to burden estimation in government in formation collections, all of which conform to PRA requirements. Table 2 depi cts methodology features from se veral high volume collections, including TRI. In this discussion, the term “ca libration” refers to a method by which estimates are compared to, and reconciled with, an actua l measurement of the quantity that they are designed to estimate. 16 The IRS 1120 (U.S. Corporation Income Tax Return) and IRS 1040 (U.S. Individual Income Tax Return) collections empl oy a lower and higher level of accuracy in their methodologies, respectively, when compared to TRI. EPA’s TRI burden methodologies (both the existing and the algebraically equivalent RBBM) fall in between, with high specificity but no calibration via representative sampling. 17 Across the columns of Table 2, the differences in approaches address different applications and correspondingl y require different types of
maintenance.

With the IRS examples, additional specificity accompanies higher precision because the more complex 1040 burden estimation employs calibration using a representative sample. In contrast, TRI burden estimates are derived from best pr ofessional judgment without this type of calibration. Generally, the TRI-t ype of methodology develops cal culations drawing from an appropriate amount of specificity and some sense of average values. Overall, calibrated estimates are more accurate than uncalibrated estimates; bu t highly specified estimates are not necessarily more precise (and hence not necessarily more ac curate) than less specified estimates. In the
context of TRI’s uncalibrated es timates, increasing specificity (i.e., adding variables) adds complexity without necessarily increasing preci sion. EPA concludes that neither TRI’s existing nor revised methodologies require additional specifi city. EPA also considered enhancing the TRI methodology with calibration via a representative survey but did not wish to impose additional burden on the TRI reporting commun ity. TRI’s approach is appropr iate and complies with PRA requirements for providing burden estimates, “to the extent practicable ” while reflecting a reasonable sense of average conditions a nd an appropriate level of specificity. 18

In summary, the internal consis tencies identified during the 2 008 ICR Renewal, and the insight above regarding appropriate complexity la y the groundwork for RBBM’s design. A simpler
formulation is derived with ratio models ensu ring internal consistency across Forms R and Forms A, as well as from form elements to whole forms.

16 This definition contrasts with the one us ed in scientific circles that discuss measurement techniques, where accuracy has two components: nonbias and precision. In such contexts, calibration is assured using a high precision “standard.” Outside this context (as in RBB M), estimates achieve accuracy by approximating the average conditions a nd incorporating an appropria te level of specificity.

17 Note as a matter of context that the TRI Program’s methodology is the Agency’s most complex (per Rick Westlund, OEI Office of Information Collection 1/13/2010).

18 RBBM allows for future enhancements. As the single base number, the Nominal Form R burden may be adjusted to reflect updates identified
via calibration or other sources.Revising TRI Burden to Ratio-Based Methodology4/28/118Table 2: Burden Estimation Methodology Features from Example Government Information CollectionsSources: EPA—TRI Program Staff (June 2009); IRS— Officeof Research (June 2009)IRS 1120Corporate (ADL)Uncalibrated/Low SpecificityTRI CurrentForm R and Form AUncalibrated/High SpecificityTRI Proposed (RBBM)Form R and Form AUncalibrated/SimplifiedSpecificity(Equivalent to TRI Current)IRS 1040Individual (ITBM)Calibrated/High SpecificityDescriptionBurden depends on:•the number of lines on theform instructions•the number of fields•the number of attachments•the number of line itemscompletedBurden depends on:•Unit burdens for Form A and Form R (PBT,non-PBT) set by informed decisions basedon best professional judgment and input viaPublic Comment•Estimates of Incremental increases to formburden based on Abt Associates Engineeringestimates and case-by-case evaluationsBurden depends on:•Internally consistent and verifiable unitburdens for Form A and Form R. Unitburdens reflect the number of elements andrelated calculations. Nominal Form R unitburden set by informed decisions based onbest professional judgment and input viaPublic Comment.•Estimates of incremental increases to formburden utilize internal consistent system ofstandardized form element estimatesMicrosimulation Model:•Burden is modeled as afunction of taxpayercharacteristics•The model is applied to arepresentative sample of taxreturns and the resultingburden estimates extrapolatedto the population as a wholeMethodsDevelopmentModel burden based onreadily observable variablesIdentify element-level processes; assignvalues for associated activitiesRestructure to simplify and to ensureinternal consistency. Retain previouslyidentified processes; utilize Abt AssociatesEngineering estimates of element-levelburden on a relative basis (in ratio models).Identify element-levelprocesses; calibrate viarepresentative survey•Model relationships between populationsubsets as ratios•Survey individuals’completion time of completelow level processes•Maintain same baseline burden as astarting point.•Model burden based ontaxpayer characteristics•Generalize model results topopulationAssumptionsFew, strong assumptionsSeveral, unverifiable assumptionsFew, measurable assumptionsMany, validated assumptionsUpdates/SurveyRequirementsBased on survey data for onepopulation extended to otherpopulationsNot based on survey dataNot basedon survey data (capability existsfor future upgrade)Model calibrated with 2008survey data, update plannedfor 2011.Updates as there are changesto formsUpdates as there are changes to forms;otherwise, wholesale adjustments are nonsytematicUpdates as there are changes to forms;otherwise wholesale adjustmentsstreamlined and internally consistentModel inputs updated yearlyStrengthsEasy to updateSatisfies PRA requirements•Easy to update•Accuracy (calibration)•Increased understanding•Increased understanding•Robust•Robust•Simple and transparent•Explicitly considerspreparation method (self ortax-preparer)Revising TRI Burden to Ratio-Based Methodology

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9 Ratio-Based Burden Methodology, Methods, and Models

The revised methodology simplifies a set of multiple, large matrices to four ratio models plus
one base number for Form R unit burden. This simplification converts the system to a new structure, as depicted in the equation below.

Burden Hours = fct [(Nominal Form R Un it Burden), (A/R), (PBT/non-PBT), (FTF f )]
and

Cost = (Burden Hours)*WAWR

Where: fct Means “a function of”
Nominal Form R Unit Burden= Single base number for the entire methodology; provides the focal point for assessing and maintaining estimate

accuracy A/R = Ratio of burden for single-ch emical Form A to Form R

PBT/non-PBT = Ratio of burden for PBT chemical to non-PBT chemical

FTF f = (First-Time Filer Factor) Ratio of burden for first-time (f irst year) filers to steady state (subsequent year) filers

WAWR = (Weighted Average Wage Rate) Cost conversion factor in cu rrent $ per hour; incorporates fixed proportions of Manageri al, Technical, and Clerical labor categories.

Specifications Within a New Structure

The summary equation above applies to the entire system of methods and relevant models. In this methodology’s final formulation, and as described below, RBBM accomplishes the following design objectives:

• Internal consistency maintained via ratio models

o Steady state burden— A/R

, PBT/non-PBT

o First-time filer burden factor— FTF f

o Standardized Form Element Burdens, as comprehensive estimates that are consistent from element to Form, as well as across Form R and Form A

• Algebraic and substantive simplifications, includ ing: 1) neglect the e ffects of first-time filers in steady state burden estimates 19 2) set the PBT/non-PBT model equal to one 20

• Unified scales across activity-specific unit burdens – i.e., facility-level factors were rescaled to (per chemical) form-level factors for both Form A and Form R

• One-step conversion from hours to current dollars, using WAWR

• Overall total Program burden estimate maintained as a starting point

19 The incremental contribution for first-time fili ng burden produces a very slight increase to the Steady State Total Burden estimate, as reflected in the calculated effect of modeling error on the Steady State Total Burden estimate at -.04%. See Appendix B.

20 Specified as a ratio model, but set to the default value for th e ratio equal to one, due to the lack of verifiable alternative . See Appendix B for qualitative evidence considered (public comments and engineering studies).Revising TRI Burden to Ratio-Based Methodology

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10 Table 3 presents the decision rules used to direct simplifications and ensure internal consistency. See Appendices A-E for further de tail. Regarding the ratio models, EPA used estimates for form subtasks from the Abt Associates Engineering Studies as building bloc ks, particularly for A/R
and FTF f (See Appendix G for these studies). For example, the value for A/R is derived by assessing the Form R burden for activities si milarly required to complete a Form A.

Table 3: Methodology Deve lopment Decision Rules
Rule Description Models
1 Derive Form A numbers from Fo rm R numbers using estimates of burden by activity A/R

2 Use Form R basis where additional complexity for Form A basis is
unmerited FTF f , WAWR

3 Make simplifying assumptions where they are mathematically justified A/R Model regarding First-Time Filers,
WAWR
4 Make simplifying assumptions wher e a distinction is not backed up by quantitative and/or statistical eviden ce (especially when the need for evidence is expressed by stakeholders) A/R Model regarding
PBT/non-PBT

5 When scaling to Nominal Form R unit burden, scale up elements equally, in proportion to their contributions to the total Standardized Form
Element Burdens
6* Back-calculate the Form R unit burden in order to maintain the
established baseline’s total burden Nominal Form R unit
burden * Preserving the existing methodology’s to tal burden estimate is important because TRI burden estimates are primarily used to track changes from year to year against an established ba seline. EPA defines the methodology transition point as the time of the last ICR approval with conditions specified by 2008 I CR renewal projections. At that point in time, the Program burden totals calculated under existing and revised methodologies are identical. See Appendix B for detailed calculations of
Nominal Form R unit burden

.

The RBBM Models and Equations

Figure 4 depicts the entire system of equations for the RBBM. The values for key factors are:

• Nominal Form R unit burden is 35.7 hrs per Form R

• A/R is .615 hr/hr ; PBT/non-PBT is 1.0 hr/hr

• FTF f is 2.1 hr/hr

• WAWR (June 2010) is $49.62/hr. See also Appendix C for Standardized Form Elem ent Burdens and related procedures for updates
to the Nominal Form R unit burden , under RBBM.

Figure 4 RBBM System and Constituent Methods

Steady State Total Burden Calculation Steady State Total Burden
= Form R Burden + Form A Burden + Non-Form Burden
= Nominal Form R Unit Burden*# Form R Chemicals + [Nominal Form R Unit Bu rden* (A/R)*(# Form A Chemic als )] + Non-Form BurdenRevising TRI Burden to Ratio-Based Methodology

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11 Form Element Estimation
Nominal Form R unit burden
new = Nominal Form R unit burden old + Form change burden

First-Time Filer Estimation
First-Time Filer Burden

= FTF f * (Relevant Ste ady State Burden)

= FTF f *[(Nominal Form R Unit Burd en* # New Form R Chemicals)] + [(A/R) * Nominal Form R Unit Burden * # New Form A Chemicals]

Cost Conversion Steady State Total Cost = (Steady State Total Burden)*WAWR

Ratio Models: Stability and Internal Consistency

Beyond imposing internal consistency and preventi ng related inconsistencies from developing in the future, ratio models are inherently more (roughly) stable and th erefore more robust to changes than their component variables. For example, for A/R (the ratio of Form A burden to Form R burden) the value of the actual ratio (.6 15) remains stable over the course of typical Program changes. This ratio remains stable beca use the actual changes to Form R and Form A impose similarly small incremental burden change s to both the numerator and the denominator of the ratio, thus causing the ratio itself to remain roughly constant. 21 In contrast, the Nominal
Form R unit burden requires routine updating because typica l changes to the Form R increase or decrease actual reportin g burden per Form R. Last, the ratio m odels are useful standalone metrics because they quantify key relationships between two elements. For example, A/R is .615, reflecting the burden of a Form A as 61.5% of the burden of a Form R, and implying that filing a Form A instead of a Form R yields a 38.5% burden reduction per chemical.

Nominal Form R Unit Burden: Comprehensive Focus and High Utility

The Nominal Form R unit burden provides a number of functions . As already stated, it is the base number for the entire methodology, providing a single focal point for discussions about methodology accuracy. This contrasts with the existing methodology in which numerous factors and variables are maintained and the suggestion to add more variables (e. g., staff turnover) arises frequently. Instead, RBBM supports focused discu ssions about whether 35.7 hours per Form R is the correct base number. Second, revisions are straightforward. In rulemaking and ICR revision, Form R changes are estimated and applied to the Nominal Form R unit burden . Other changes in the system are automatically propagated via the ratio models (to Form A and for first-time filers). Similarly, when EPA receives information indicating that overall bu rden estimates are either too high or too low, the Nominal Form R unit burden is the single primary point of adjustment.

As a clarification on RBBM’s desi gn, note that Decision Rules 4 ( PBT/non-PBT=1) and 6 (backcalculated Nominal Form R unit burden ) both impact the definition for nominal Form burden, as
well as the resultant overall structure of RB BM. In choosing to leave the value of the PBT/non-

21 Note that in the even t that the Form R and/or Form A undergo extrem e revisions that alter the relationship between A/R burden, then A/R would require updating.Revising TRI Burden to Ratio-Based Methodology

4 /28/11

12 PBT ratio at the default value of one, the back-calculated base number ( Nominal Form R unit
burden ) remains a single focal point for consider ing overall average conditions for Form R burden per chemical. 22 This single focal point is afforded by the simplicity of the overall Steady
State Total Burden Calculation that also does not required a PBT/non-PBT model and tracking of related separate subpopulations. Moreove r, given that th e back-calculated Nominal Form R unit
burden preserves the existing totals as a starting point (Decision Rule 6), RBBM carries forward certain prior assumptions from the existing methodology without explicitly modeling them. In particular, note that the higher PBT repor ting burden is incorporated into the Nominal Form R
unit burden’s starting value of 35.7 hours/Form R, which is elevated above the value that would
have been otherwise obtained—at about 30 hour s/form—had only non-PBT burden been used to
determine Nominal Form R unit burden

. 23

In opting for simplicity over specific ity via the RBBM approach (even if PBT/non-PBT burden were quantified), EPA retains the sophisticati on of a single unit burden for Form R reporting with Form A reporting burden closely linked. The Nominal Form R unit burden reflects overall “average” conditions, without the need to add variables. In short, any effect that EPA needs to consider is incorporated into the average conditions of the Nominal Form R unit burden

.

In the event that the overall PBT/non-PBT relation ship is determined, EPA could restructure to a more complex total burden calculation, 24 or keep the simpler formulation by updating the
Nominal Form R unit burden (single base number) on a prorated basis. Regardless, EPA would
then be able to estimate burden differences a ssociated with PBT chemical reporting, as needed.

EPA supports this value of 35.7 hours per Form R as a reasonable approximation of the actual unit burden, based on years of review and scrutiny to which the current total burden estimate has been subjected. The unit burden of 35.7 hours, in the context of a new system of ratio models, is the culmination of prior accuracy assessments (see methodology history). Therefore, this basis is legitimized for ultimately setting the magnitude of the Program total burden at this time.

Benefits

With the simplified and internally consistent calc ulations plus a user-fri endly interface via the Program Staff Tool (shown in Appendix F) , EPA expects RBBM to streamline burden estimation. In addition to saving time, RBBM enhances administrative consistency with shorter, more straightforward procedures that are readil y replicated and consistently communicated. Last, RBBM increases transparency because burden info rmation is available in a more accessible, compact, and comprehensive format that is easier to use. As a result, EPA staff and the general public will obtain an increased understanding of the key drivers of burden estimation for a variety of purposes, including those encountered in the cont ext of public policy changes. Therefore, EPA recommends the adoption of RBBM for the TRI Program, beginning with the
2012 ICR renewal.

22 Moreover, RBBM’s total burden calculation does not have the comple xity of tracking separate subpopulations for Form R PBT and non-PBT chemical reports.

23 For the transition, the previous methodology’s inclusion of a higher PBT unit burden for 20% of chemical reports is rolled up into the new back-calculated unit burden. Similar logic applies to fi rst-time filer effects, though the impact is negligible.

24 Requires the inclusion of the PBT/non-PBT ratio and separate chemical counts fo r Form R PBT and non-PBT subpopulations.Appendix A

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A-1 Methodology Overview and Guide to Met hods Technical Appendices (B – E)

This appendix presents an overview of the revised methodology, Ratio-Based Burden Methodology (RBBM) as a guide to the other mo re detailed Appendices B-E. As such, this appendix does not provide back-up evidence or ju stify assumptions; that information is covered
in the relevant detailed appendices:

• Appendix B – Steady State Total Burden Calculation

• Appendix C – Form Element Estimation

• Appendix D – First-Time Filer Estimation

• Appendix E – Cost Conversion

The methodology revision project that culminated as RBBM started in May 2009, with technical document writing initiated in March 2010. The dr aft technical document was submitted for peer review on May 1, 2010. The peer reviewers endors ed the methodology as credible and effective (See Appendix H for summary). As a result, EPA left all of RBBM’s design and major procedures in tact. EPA then revised th e technical document, addressing specific questions/critiques of the met hodology and implementing editorial suggestions from peer reviewers and other sources. Throughout the proj ect, EPA employed interdisciplinary teams for methodology development, document development, and document revisions.

RBBM development was guided by the methodol ogy priorities of simplicity, internal consistency, and transitional ba seline continuity and was more precisely specified by broadly applicable decision rules. These rules are presen ted on page 10 in the main report and discussed herein. The methodology revision entail s restructuring a set of large ma trices to a system of four ratio models plus one base number ( Nominal Form R unit burden , derivation to follow). Additionally, Standardized Form Element Burdens replace ca se-by-case engineering estimates for use in updating unit burden to reflect Form ch anges, such as burden associated with adding a
new element.

There are two major classes of burden estimates in TRI applications: steady state burden and
first-time filer burden. Steady State Total Burden is the estimate of the ongoing TRI Program burden, as updated by rulemakings’ permanent impact s, but absent any first-time filer impacts.
These are the burden estimates that OMB has on r ecord that are re-estimated in full at ICR renewal time. Similarly, when an economic analysis (EA) is conducted in association with a rulemaking, the ongoing incremental change in bu rden is added or subtracted from the Steady
State Total Burden , constituting a sustained steady state change in burden. In a related application, the Form Element Estim ate provides revisions to unit burden due to changes in Form R/Form A filing requirements which can occur eith er in the ICR renewal or in a rulemaking.

In contrast to steady state, first-time filer bur den (previously termed fi rst-year year burden)
accounts for the elevated level of effort that reporters incur during a start-up year. In RBBM, first-time filer burden is estimated using a ratio model that reflects the increased burden over and above relevant steady state burden. Given this st ructure, EPA first deri ves models supporting the Steady State Total Burden estimate, including the restruct uring and related Form Element Estimation. Thereafter, First-Time Filer Estim ation is presented. Last, Cost Conversion is presented, as this method is applicable to all burd en estimates.Appendix A

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A-2 Steady State Burden

The Steady State Total Burden Ca lculation consists of Form bur den and non-Form burden. In the next sections, EPA derives the portions of the restructured system pertaining to Form burden.
This first set of derivations de monstrates that the proposed appr oach is a greatly simplified algebraic equivalent to the ex isting method. The next section provides the derivation for the A/R model that is central to the new structure. Af ter that, EPA presents a revised and slightly
modified calculation for non-Form burden that addresses TRI burden not directly captured by filling out a Form R or A. EPA then provides the procedure for back-calculating the base number, Nominal Form R unit burden . Finally, EPA presents an overview of the related Form
Element Estimation.

Restructuring the System

The existing method for estimating Form burden consis ts of an extensive syst em of matrices that can be collapsed and further simplified. The matrix notation for Form R burden hours is:

Eqn. A-1: Form R Burden hours = [F] chem. category, activity, YR, labor category * [N] forms

Eqn. A-2: Form R Cost = [F] chem. category, activity, YR, labor category * [N] forms * [$] labor category

Where:

chem category = PBT or Non-PBT activity = Rule familiarization, comp liance determination, form completion, recordkeeping and submission YR= First year or subsequent year labor category = Management, t echnical, or clerical labor

And where:

[F] chem category, activity,

YR, labor category 18x3 matrix of reporting activ ity factors with subsets depending on whether the Form is for a PBT or non-PBT chemical, and a first year or s ubsequent year filing...with three
columns for the three labor cate gories (managerial, technical, clerical) [N] forms 1x18 vector of TRI chemical counts according to the categories specified in matrix F [$] labor category 3x1 vector of current dollar wa ge rate ($/hr) for managerial, technical, and clerical labor

Note that a parallel set of matrices exis t for Form A burden estimation in the existing methodology. However, as the new methodology de rives Form A-relate d burden exclusively from Form R, the derivation that foll ows need only pertain to Form R.

The detailed list of OMB-approved unit burdens as of March 27, 2008 fo r reporting activities (hereafter known as factors) for Form R non-PB T and PBT chemicals are presented in Tables A-Appendix A

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A-3 1 and A-2, respectively. An alternative set of f actors for non-PBT only, as developed in the Abt Associates Engineering Studies (f or source reference, see Appendix G) and derived by EPA, are presented in Table A-3 for Form R and Form A. Table A-4 provides the slightly reformulated version of Table A-3’s factors, incorporating RBBM conversion of facilit y-level unit burdens to (per chemical) form-level. The totals in Table A-4 apply directly to building RBBM ratio models (used later in Eqns. A-4, A-9, and A-10). For th e purposes of deriving the system simplification, however, Tables A-1 and A-2 may be combined to populate the comprehensive matrices below.
Note that these tables’ factors are a mixture of facility-level and fo rm-level constants.

Table A-1: OMB-Approved Burden, Non-PBTForm R (non-PBT) Managerial Technical Clerical Totalfirst year Facility Rule Familiarization 12 22.5 0 34.5

Compliance Determination 4 12 0 16

Form R Calculations and Form Completion 20.5 44.4 2.8 67.66

Recordkeeping 0 4 1 5

Managerial Technical Clerical Totalsubsequent Facility Rule Familiarization 0 0 0 0

Compliance Determination 1 3 0 4

Form R Calculations and Form Completion 7.55 16.08 1.03 24.66

Recordkeeping 0 4 1 5

Table A-2: OMB-Approved Burden, PBTForm R (PBT) Managerial Technical Clerical Totalfirst year Facility Rule Familiarization 12 22.5 0 34.5

Compliance Determination 4 12 0 16

Form R Calculations and Form Completion 20.28 43.87 2.70 66.86

Recordkeeping 0 4 1 5

Managerial Technical Clerical Totalsubsequent Facility Rule Familiarization 0 0 0 0

Compliance Determination 1 3 0 4

Form R Calculations and Form Completion 14.10 30.37 1.86 46.34

Recordkeeping 0 4 1 5Appendix A

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A-4 Table A-3: Abt Associates Engineering Study Factors, Non-PBT with Derived Form AForm R (non-PBT) Managerial Technical Clerical Total Derived Form A Total*first year Facility Rule Familiarization 1 22.5 0 23.5 23.5

Compliance Determination 1 13.7 0 14.7 14.7

Form R Calculations and Form Completion 0.37 10.49 0 10.86 3.39

Recordkeeping 0 4 1 5 5

Managerial Technical Clerical Total Derived Form A

Total*subsequent Facility Rule Familiarization 0 0 0 0 0

Compliance Determination 0.25 1 0 1.25 1.25

Form R Calculations and Form Completion 0.32 6.89 0.0 7.20 2.30

Recordkeeping 0 4 1 5 5 * Form A burden estimates are derived from Form R by summing the burden associated with Form R data elements for which a reporter would make calculations to determine their Form R elig ibility as well as the data elements they actually report on For m A.

Table A-4: Ratio-Based Burden Methodolo gy “Building Blocks” for Ratio Models

Abt Associates Factors, Mixed Scales Ratio-Based Burden Methodology Unit Burdens, Consistent per Chemical Scale

Form R Derived Form A* Ratio Model Bases Form R Derived Form A*Form R (non-PBT )first year Facility Rule Familiarization 23.5 23.5 R, A Chemical ** 6.07 6.90
Compliance Determination 14.7 14.7 3.80 4.31

Form R Calculations and Form Completion 10.86 4.27 R, A Chemical 10.86 4.27
Recordkeeping 5 5 5 5

Form Burden Per Chemical Total N/A N/A 25.73 20.48subsequent Facility Rule Familiarization 0 0 R, A Chemical ** 0 0

Compliance Determination 1.25 1.25 0.32 0.37

Form R Calculations and Form Completion 7.2 2.34 R, A Chemical 7.2 2.34

Recordkeeping 5 5 5 5

Form Burden Per Chemical Total N/A N/A 12.52 7.71

*Form A burden estimates are derived from Form R by summing the burden associated with Form R data elements for which a reporte r would make calculations to determine their Form R eligibility as well as the data elements they actually report on Form A. ** Facility-level factors converted to form (per chemical) level factors via equivalent chemicals per facility for R (3.87) and A (3.41). See Appendix B Supplement for derivations In prac tice Form R reports contain one chemical per report and Form A allows multiple chemicals (2.3 on average).Appendix A

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A-5 Starting with the F * N matrix product (represent ed by Eqn. A-1), with F being an array of factors (burden per form or facility), and N a vector of variables (form or facility counts), EPA simplifies by collapsing the entire set of factors to one constant and reducing vector N to one variable—total Form R chemical counts. However, in order to make th is simplification, EPA
must convert the factors to the same unit of analysis (per chemical form-level) by dividing facility-level factors by the applicable average number of Form R chemicals per facility, Rcpf
e. 1 Expanding the matrix notation and standardiz ing the factors’ units, F * N becomes F ′ * N.

Matrix System F ′ * N

F NPBT,fYR,RF,m Rcpf

e F NPBT,fYR,RF,t Rcpf

e F NPBT,fYR,RF,c Rcpf

e N NPBT,fYR

F NPBT,fYR,CD,m Rcpf

e F NPBT,fYR,CD,t Rcpf

e F NPBT,fYR,CD,c Rcpf

e N NPBT, fYR

F NPBT,fYR,CFC,m F NPBT,fYR,CFC,t F NPBT,fYR,CFC,c N NPBT,fYR

F NPBT,fYR,REC,m F NPBT,fYR,REC,t F NPBT,fYR,REC,c N NPBT,fYR

F NPBT,sYR,RF,m Rcpf

e F NPBT,sYR,RF,t Rcpf

e F NPBT,sYR,RF,c Rcpf

e N NPBT,sYR

F NPBT,sYR,CD,m Rcpf

e F NPBT,sYR,CD,t Rcpf

e F NPBT,sYR,CD,c Rcpf

e N NPBT, sYR

F NPBT,sYR,CFC,m F NPBT,sYR,CFC,t F NPBT,sYR,CFC,c N NPBT,sYR

F NPBT,sYR,REC,m F NPBT,sYR,REC,t F NPBT,sYR,REC,c N NPBT,sYR

F PBT,fYR,RF,m

Rcpf

e F PBT,fYR,RF,t Rcpf

e F PBT,fYR,RF,c Rcpf

e * N NPBT,fYR

F PBT,fYR,CD,m

Rcpf

e F PBT,fYR,CD,t Rcpf

e F PBT,fYR,CD,c Rcpf

e N PBT, fYR

F PBT,fYR,CFC,m F PBT,fYR,CFC,t F PBT,fYR,CFC,c N PBT,fYR

F PBT,fYR,REC,m F PBT,fYR,REC,t F PBT,fYR,REC,c N PBT,fYR

F PBT,sYR,RF,m

Rcpf

e F PBT,sYR,RF,t Rcpf

e F PBT,sYR,RF,c Rcpf

e N PBT,sYR

F PBT,sYR,CD,m

Rcpf

e F PBT,sYR,CD,t Rcpf

e F PBT,sYR,CD,c Rcpf

e N PBT, sYR

F PBT,sYR,CFC,m F PBT,sYR,CFC,t F PBT,sYR,CFC,c N PBT,sYR

F PBT,sYR,REC,m F PBT,sYR,REC,t F PBT,sYR,REC,c N PBT,sYR

Figure A-1: Sample Defini tion of Matrix Term



### F PBT,fYR,RF,m

Where: PBT = Chemical category is PBT fo rm. (Other possibility is non-PBT) fYR= Year is first year of filing. (Other possibility is subsequent year of filing) RF = Activity is rule familiarization. (Oth er possibilities are compliance determination, calculations and form completion, an d recordkeeping and submission) m= Labor category is managerial. (Other possibilities are technical and clerical)

1 Although this appears to be a straightforward conversion, in practice it was not. EPA derived “equivalent chemical per facility,” for Form R and Form A, based on distribu tions of Form R and Form A chemicals within and across facilities, on average. See Appendix B Supplement for details.Appendix A

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A-6 To help clarify terms, Figure A-1 defines the term s for an example variable in the matrix. The
value of each variable is contained in Tabl es A-1, A-2 (existing methodology), and A-3, A-4 (revised methodology).

Assuming that the first-time filer effect is negligible and asserting the model that PBT/non-PBT burden=1 (i.e., on average no quantifiable differe nce between burden for filing a PBT chemical report versus a non-PBT), the matrix factors redu ce to a simple sum. Correspondingly, the matrix product reduces to the unit burden (hours per Form R chemical) times the total number of Form
R chemicals.

F ′′ * N ′ (with matrix N reduced to the constant N R for total number of Forms)

Matrix System F ′′ * N ′

F NPBT,sYR,RF,m fpR

e F NPBT,sYR,RF,t Rcpf

e F NPBT,sYR,RF,c Rcpf

e N R

F NPBT,sYR,CD,m fpR

e F NPBT,sYR,CD,t Rcpf

e F NPBT,sYR,CD,c Rcpf

e e * N R

F NPBT,sYR,CFC,m F NPBT,sYR,CFC,t F NPBT,sYR,CFC,c N R

F NPBT,sYR,REC,m F NPBT,sYR,REC,t F NPBT,sYR,REC,c N R

﴾ R N =s Form R Burden Hour 2 :3-A .nqE F ′′ i,j ﴿ = N R C R 

## ∑∑

== 4

1 4

1 ji Where:

C R = Sum of all factors in the matrix, re flecting the unit burden per Form R chemical

Intuitively, one would state this equation as follows: “the total Form R burden hours estimate is the product of the Form R unit bur den times the number of chemicals filed by Form R where the unit burden consists of four contributing activities: rule familiarization, compliance determination, calculations and form comp letion, and recordkeeping and submission.”

Ensuring Internal Consistency Using Ra tio Models and Engineering Estimates

If EPA were to make simplifications such as “Form R burden hours = N R C R ” and go no further, EPA would greatly reduce the co mputational and reporting complexity for TRI program burden calculations. However, this alone would not addr ess one of the key concerns that led it to develop a new method: internal consistency. Consistency across Forms R and A is desired, as well as consistency in computing estimates of the first-time filing burden that affect new entrants to the reporting community as a result of policy change. Ratio models of A/R and first year burden/subsequent year burden (newly termed “first-time filer factor ( FTF f )”) characterize the relationships between these estimates, regardless of the magnitude of the values used in the composite Form unit burdens. As seen by comparing Table A-1 and A-3, the OMB-approved numbers are higher than the Abt Asso ciates Engineering Studies numbers. 3 These differences in absolute magnitude are not relevant to RBBM de velopment of ratio models for the purpose of

2 This equation uses standard matrix notation where i refers to the row of the matrix and j refers to the column.

3 Differences are due to differences in origin: EPA OM B-approved estimates were defined at program inception (with periodic revisions), while Abt Associates’ Engineering Study estimates were generated more than a decade after program inception.Appendix A

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A-7 providing internal consistency. Sp ecifically, the Abt Associates Engineering estimates are used on a relative basis only, for building ratio mode ls. Moreover, EPA concludes that the Abt Associates Engineering estimates are appropriate for RBBM’s ratio models because they most reliably quantify the relative burdens of vari ous tasks making them useful for quantifying relationships between key variab les. As an added benefit, EPA’s use of the Abt Associates Engineering estimates provides a means by which A/R and other models may be verified. 4 At another level, the Abt Associates Engineering estimates inform updates to the Nominal Form R unit burden which are internally consistent w ith the Form unit burden, based on Standardized Form Element Burdens (see more information late r in this appendix and also in Appendix C).

Several models were specified using the Abt Associates Engineering Studies Form R non-PBT estimates presented in Table A-4. For clarific ation purposes, Table A-5 presents unit burden components as a percent of total Form R unit burden. This format provides information about activity-based components of unit burden on a percentage basis, regardless of the value of Form
R Nominal unit burden

.

Table A-5: Ratio-Based Burden Methodology Components

, Standardized to Form R Basis
Ratio-Based Burden Methodology Unit Burdens , Consistent per Chemical Scale

100%=Form R Unit Burden

Ratio Model Bases Form R % Derived Form A* %Nominal Form R(non-PBT )Subsequent year(Steady State) Facility Burden Apportioned to Form R Activity

R, A Chemical 0 0 Rule Familiarization

Compliance Determination 2.58 2.93

Form R Calculations and Form Completion R, A Chemical 57.49 18.64

Recordkeeping 39.93 39.93

Form Burden Per Chemical Total Percentage of Form R Unit Burden 100.00 61.50

*Form A burden estimates are derived from Form R by summing th e burden associated with Form R data elements for which a reporte r would make calculations to determine their Form R eligibility as well as the data elements they actually report on Form A.

In the A/R ratio model, EPA ensures that Form A un it burden is related to Form R unit burden
via the subset of tasks and data elements from Form R that ar e similarly required to complete Form A. Using the values in Table A-4, and the relevant elements of Matrix System F ′′ * N ′ , the
A/R ratio model is computed at .615 as follows:

4 See also discussions in Appendix B regarding benefits of ratio models and strengths/weaknesses of Abt Associates Engineering Studies.Appendix A

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A-8 Eqn. A-4: A/R = (Sum of Form A Factors (as deri ved from Form R) / Sum of Form R Factors)

= ((F NPBT,sYR,RF,T +F NPBT,sYR,CD,T )/Acpf
e )+F NPBT,sYR,CFC*,T +F NPBT,sYR,REC,T

-------------------------------------------------------------------------------------------------------------- -------------------- ((F NPBT,sYR,RF,T +F NPBT,sYR,CD,T )/Rcpf
e )+F NPBT,sYR,CFC,T +F NPBT,sYR,REC,T

Notes
1 Facility level factors are converted to Form level factors using Acpf
e and Rcpf
e 2 T subscript refers to managerial plus technical plus clerical labor
3 Acpf

e refers to Equivalent Form A Chemicals per Facility (see Appendix B Supplement)
4 Rcpf

e refers to Equivalent Form R Chemicals per Facility (see Appendix B Supplement)
5 CFC* refers to the Form A factor, as derived from Form R factor components; these burdens include Form A eligibility determination with half of Form R’ s Section 5 and 6 work plus all the tasks associated
with Form R elements th at also occupy Form A

The A/R value of .615 has the following interpretation: “the burden of a Form A as 61.5% of the burden of a Form R, implying that filing a Form A instead of a Form R yields a 38.5% burden reduction per chemical.”

Transitioning to the New System

The final system of models calc ulates total burden as follows:

Eqn. A-5: Steady State Total Burden = Form R bu rden + Form A burden + Non-Form burden

Where:

• Form R Burden = (# Form R Chemicals) * (Nominal Form R Unit Burden)

• Form A Burden = (# Form A Chemicals) * (A/R) * (Nominal Form R Unit Burden)

• Non-Form Burden = (Supplier Notification) + (Non-Reporter Compliance Determination) + Petitions
And:
A/R = Ratio model of single-chemical Form A unit burden to Form R unit
burden 5

Nominal Form
R unit burden = Single base number for the entire methodology; provides the focal point for assessing and maintaining estimate accuracy

To establish the starting point for RBBM that would provide a seamless transition to the new methodology, EPA estimated the nominal Form unit burden that would not produce a change in
the Steady State Total Burden estimate. The back calculation yields a Nominal Form R unit
burden of 35.7 hours/Form R: 6

5 For purposes modeling, EPA refers to “Form R chemicals” and “Form A chemicals” in order to provide a consistent metric across form types. In practice Form R re ports contain one chemical pe r report and Form A allows multiple chemicals (2.3 on average).

6 EPA defines the methodology revision’s transition point as the time of the last ICR approval with conditions specified by 2008 ICR renewal projections. In the actual calculation EPA corrects for previous double-counting of facility level burden among facilities filing both As and Rs in the last ICR renewal, shifting the baseline downward slightly by 5460 hours (removes .13% overstatement). Non-Form Burden amounts are: Supplier Notification—Appendix A

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A-9 Eqn. A-6: Nominal Form R Unit Burden = (Total Burden – Non-Form burden)/[# Form R Chemicals + ((A/R)* # Form A Chemicals) ]

Form Element Estimation

Form Element Estimation provides a standardiz ed and reproducible method for estimating updates to unit burden associated with form ch anges, replacing the cas e-by-case engineering approach used in the existing method. The mode l consists of Standardized Form Element Burdens, organized by “type” of element. The generalized format for using this method is:

Egn. A-7: Nominal Form R unit burden
new = Nominal Form R unit burden old + Form change burden
Where:

Form change
burden = estimate based on conditions of the form change, utilizing Standardized
Form Element Burdens

Form element estimation is applicable any ti me changes to the reporting Form R, and by association, corresponding elements of the Form A, are involved. Changes to the reporting form can occur at ICR renewal and during ru lemakings. Such changes impact the Nominal Form R
unit burden . This method differs from the rest of RBBM’s burden estimation methods because its specifications are tied to the magnitude of the Nominal Form R unit burden

.

Figure A-2 at the end of this Appendix depicts the Standardized Form Element Burdens, as mapped onto an RY 2009 Form R. See Appendix C for further details including a list of Standardized Form Element Burdens by type of element, as well as related procedures for updating the Nominal Form R unit burden.

First-Time Filer Estimation

First-time filer burden, referred to as first year burden in the existi ng methodology, historically has two applications. First-time filer burden is estimated as part of the total Program burden
estimate in ICR renewals to account for the portion of the reporting community with new
entrants. The estimate of first-time filers is ma de by determining the number of facilities newly reporting to TRI in the year the ICR is updated. The number of new TRI reporters serves as an approximation for the number of new filers ex pected in any reporting year during the period covered by the ICR renewal. In the revised RBBM formulation, the impact of additional firsttime reporter burden is neglected in the (newly termed) Steady State Total Burden Calculation.

In rulemakings, first-time filer bur den is estimated to account for th e start-up effect of a policy or regulatory change to the TRI reporting requirement s—for example, when a new sector is added to the reporting community. In th is example, during the year that to policy change is first implemented, the new reporters incur start-up burd en which then reduces to steady state burden

89,616 hours; Non-Reporters Compliance Determination—734,976 hours; and Petitions—925 hours (see Appendix B for further explanation)Appendix A

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A-10 in the next year. In the case of EAs, the first-time filer burden includes both the burden to facilities reporting to TRI for the first-time as well as the burden to existing filers in the first year of a policy or regulatory change. Under RBBM, EA s still typically report both steady state and
first-time filer incremental burdens/costs associat ed with the new policy or regulation. For these estimates, only Form burden is relevant. 7 Given the overarching estimation method (Eqn. A-11), the first-time filer factor ( FTF f ) is derived below.

Eqn. A-8 First-Time Filer Burden = FTF f * Relevant Steady State Total Burden

Similar to the A/R model, the FTF model provides a consistent ba sis to estimate the first year burden relative to steady state burden for both Form R and Form A. It is developed using the
ratio of Form R factors for the first year to Form R factors fo r subsequent years. Using the
values in Table A-4 and the relevant factors from Matrix System F ′ * N, the first-time filer factor

, FTF f , for RBBM is computed at 2.1 as follows:

Eqn. A-9: FTF f = ((F NPBT,fYR,RF,T +F NPBT,fYR,CD,T )/Rcpf
e )+F NPBT,fYR,CFC,T +F NPBT,fYR,REC,T

------------------------------------------------------------------------------------------------------------------------------ ((F NPBT,sYR,RF,T +F NPBT,sYR,CD,T )/Rcpf
e )+F NPBT,sYR,CFC,T +F NPBT,sYR,REC,T Notes
1 Facility level factors are converted to Form level factors.
2 T subscript refers to managerial plus technical plus clerical labor.
3 Rcpf

e refers to Equivalent Form R Chemicals per Facility (see Appendix B Supplement).

The FTF f of 2.1 has the following interpretation: “f or any comparison of first-time filer to ongoing filer burden, the elevated startup effort is roughly twice the normal ongoing burden.”

Cost Conversion

The Cost Conversion method invol ves developing a universal WAWR that incorporates fixed proportions of Managerial, Techni cal and Clerical labor categor ies at values of .03, .89. and .08 respectively and can be applied to Form R burden, Form A burden and Steady State Total
Burdens . Similar to the burden estimate in Eqn A-3, for the cost estimate, the matrix calculation is reduced to the following weighted average unit cost per Form times the number of Forms: 8

N R *(F ′′ * $)

Matrix System N R *(F ′′ * $)
N R * F NPBT,sYR,RF,m Rcpf

e F NPBT,sYR,RF,t Rcpf

e F NPBT,sYR,RF,c Rcpf

e * $/hr managerial $/hr
technical $/hr
clerical

F NPBT,sYR,CD,m Rcpf

e F NPBT,sYR,CD,t Rcpf

e F NPBT,sYR,CD,c Rcpf

e F NPBT,sYR,CFC,m F NPBT,sYR,CFC,t F NPBT,sYR,CFC,c

F NPBT,sYR,REC,m F NPBT,sYR,REC,t F NPBT,sYR,REC,c

7 EA’s report incremental burden associated with proposed changes; since non-Form burden components are constant, they do not vary with changes in forms, yielding a zero effect in this context.

8 The existing method has been modified for ease of presentati on. In practice, no devisor is used but rather, facility burden is multiplied by the number of facilities and form burden is multiplied by the number of forms. Total facility and form burden are then summed to equal total burden reported by Form R.Appendix A

4/28/11
A-11 

## ( 

## ∑∑

== 4

1 4

1 ji R N = (( stsoC R mroF : 10 -A .nqE F ′′ i,j ﴿ * $ j ) ﴿

Rearranging this equation to a Weighted Average Wage Rate ( WAWR in current $/hr) from which hours can be readily converted to cost (for Form R relate d burden) yields:

Eqn. A- 11: Form R Costs = Form R Burden * WAWR

Generalizing to the overall equation:

Eqn. A-12: Steady State Total Cost = Steady State Total Burden * WAWR

Intuitively, one would state this equation as follows: “the total steady state cost estimate is the product of total burden times the weighted average $/hr labor rate.” The current WAWR (June 2010) 9 of $49.62/hour has the following interpretation: “f or every hour of incremental burden increased or decreased, the associated cost, on average, is $49.69 per hour.” W AWR provides a universal conversion factor for all TRI key burde n estimates, including Form R burden, Form A burden, and Steady State Total Burden.

Methodology Decision Rules Summary

This appendix presented the c onceptual bases for the new RBB M, including the generalized steps by which the existing methodology’s system was restructured and simplified. In the process of restructuring and simplifying, certain key development decision rules (summarized in main report, p. 10) were established, including:

• Rule 1: Derive Form A burden from Form R burden using estimates of burden by activity —This decision rule, used in the A/R model, ensures transparency and internal consistency by using the subset of tasks from Form R reporting that similarly apply to Form A reporting.

• Rule 2: Use Form R basis where additional co mplexity for Form A basis is unmerited— This decision rule, used in the FTF f and WAWR models, provides universal models across Form A, Form R, and total burdens.

• Rule 3: Make simplifying assumptions where they are mathematically justified—This
decision rule is used in the A/R model in the context of the decision to exclude first-time filer effects from models from the Steady Stat e Burden Calculation. The rule is also used in applying the WAWR universally across Form R, Form A, and total burden estimates.

• Rule 4: Make simplifying assumptions wh ere a distinction is not backed up by quantitative and/or statistical evidence (e specially when the need for evidence is expressed by stakeholders)—This decision rule was used to set the value of the ratio
model for PBT/non-PBT burden equal to one.

• Rule 5: When scaling from form element estimates to Nominal Form R unit burden , scale elements equally, in proportion to their contri butions to the total—This decision rule was used in developing Standardized Form Element Burdens.

9 Wage data source: http://www.bls.gov/ncs/ect/#tablesAppendix A

4/28/11
A-12 • Rule 6: Back-calculate the Form R unit burden in order to maintain the established baseline’s total burden—This decision rule was used to set the starting value for Nominal
Form unit burden

.

Appendices B-E present method development, incl uding detailed analyses used to formulate and refine distinct pieces of th e overall methodology. These appendi ces, organized by each of the constituent methods, comprehensively detail m odels and computationa l procedures of the methodology. Additionally, key analytical decisions are discussed with assumptions validated using empirical evidence where possible.Appendix A

4/28/11
A-13 Figure A-2: Standardized Data Element Time Estimates Scaled to 35.7 Hours

Form Approved OMB Number: 2070-0093 (IMPORTANT: Type or print; read instructions be fore completing form) Approval Expires: 03/31/2011 Page 1 of 5 

# EPA

United States Environmental Protection Agency 

### FORM R

Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986, also Known as Title III of the Superfund
Amendments and Reauthorization Act TRI Facility ID Number

Toxic Chemical, Category or Generic Name

WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing
Center
P. O. Box 1513 2. APPROPRIATE STATE OFFICE (See instruction in Appendix E)

This section only applies if you are revising or withdrawing a previous ly submitted form,
otherwise leave bank. Revision (enter up to two codes(s)) Withdrawal (enter up to two code(s))

IMPORTANT: See instructions to determine when “Not Applicable (NA)” boxes should be checked.

PART 1. FACILITY IDEN TIFICATION INFORMATION

SECTION 1. REPORTING YEAR 0.006 hours

SECTION 2. TRADE SECRET INFORMATION

2.1 Are you claiming the toxic chemical identified on page 2 trade secret?
0.006 hours

2.2 Is this copy Sanitized
Unsanitized Answer only if “YES” in 2.1
0.006 hours Yes (Answer question 2.2; Attach substantiation forms) No (Do not answer question 2.2; Go to Section 3)

SECTION 3. CERTIFICATION (Impor tant: Read and sign after completing all form sections.) I hereby certify that I have reviewed the attached documents a nd that, to the best of my knowle dge and belief, the submitted in formation is true and complete and that the amounts and values in this report are accura te based on reasonable estimates using data available to the preparers of this report.
Name and official title of owner/operator or seni or management official: Signature: Date Signed:

NA NA

SECTION 4. FACILITY IDENTIFICATION

4.1 TRI Facility ID Number 0.002 hours Facility or Establishment Name
0.002 hours Facility or Establishment Name or Ma iling Address (If different from street address) 0.002 hours

Street 0.002 hours Mailing Address 0.002 hours

City/County/State/Zip Code 0.002 hours City/County/State/Zip Code 0.002 hours Country (Non-US) 0.002 hours

4.2 This report contains in formation for: 0.006 hours

(Important: Check c or d if applicable) a. an entire facility b. Part of a facility c. a Federal facility d. GOCO

4.3 Technical Contact Name 0.002 hours Telephone Number (include area code)
0.002 hours Email Address 0.002 hours

4.4 Public Contact Name 0.002 hours Telephone Number (include area code)
0.002 hours Email Address 0.002 hours

4.5 N AICS Code(s) Primary

b. c. d. e. f. a. 0.002 hours

4.6 Dun & Bradstreet
N umber (s) (9 digits) a. 0.002 hours

b.

SECTION 5. PARENT COMPANY INFORMATION

5.1 N ame of Parent Company NA 0.002 hours

5.2 Parent Company’s Dun & Bradstreet Number NA 0.002 hours

EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete.Appendix A

4/28/11
A-14 Form Approved OMB Number: 2070-0093 (IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 03/31/2011 Page 2 of 5



### FORM R

PART II. TOXIC CHEMICAL RELE ASE INVENTORY REPORTING FORM TRI Facility ID Number

Toxic Chemical, Category or
Generic Name

SECTION 1. TOXIC CHEMICAL IDENTITY (Important: DO NOT complete this section if you completed Section 2 below.)

1.1 CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical

0.002 hours
1.2 Toxic Chemical or Chemical Category Na me (Important: Enter only one name exactly as it appears on the Section 313 list.)

0.002 hours

Generic Chemical Name ( Im p ortant: Com p lete onl y if Part 1, Section 2.1 is checked “ y es”. Generic Name must be structurall y descri p tive. ) 1.3 0.002 hours

SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.) Generic Chemical Name Provided by Supplier (Important: Maximu m of 70 characters, including num bers, letters, spaces and punctu ation.)
2.1 0.002 hours

SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY (Important: Check all that apply.)

3.1 Manufacture the toxic chemical:
0.002 hours 3.2 Process the toxic chemical:
0.002 hours 3.3 Otherwise use the toxic chemical:
0.002 hours

a. Produce b. Import

a. As a reactant

b. As a formulation component

c. As an article component

c. Repackaging

c. As an impurity a. As a chemical processing aid

b. As a manufacturing aid

c. Ancillary or other use If produce or import

c. For on-site use/processing

d. For sale/distribution

e. As a byproduct

f. As an impurity

SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEM ICAL ON SITEATANY TIME DURING THE CALENDAR YEAR
4.1 0.944 hours (Enter two digit code from instruction package.)

SECTION 5. QUANTITY OF THE TO XIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE

A. Total Release (pounds/year*)

(Enter a range code** or estimate) B. Basis of Estimate (enter code) C. % From Stormwater

5.1 Fugitive or non-point
air emissions NA
0.005 hours 3.264 hours 0.010 hours

5.2 Stack or point
air emissions NA

0.005 hours 1.879 hours 0.010 hours

5.3 Discharges to receiving streams or water bodies (enter one name per box)
Stream or Water Body Name

5.3.1 0.008 hours 1.881 hours 0.010 hours 0.416 hours

5.3.2

5.3.3

If additional pages of Part II, Section 5.3 are attached, indicate the total number of pages in this box, and indicate the Part II, Section 5.3 page number in this box. (example: 1,2,3, etc.)

EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obs olete. *For Dioxin or Di oxin-like compounds, report in grams/year. ** Range Codes: A= 1-10 pounds; B= 11-499 pounds; C= 500-999 pounds.Appendix A

Form Approved OMB Number: 2070-0093 (IMPORTANT: Type or print; read instructions befo re completing form) Approval Expires: 03/31/2011 Page 3 of 5



### FORM R
PART II. CHEMICAL - SPECIFIC INFORMATION (CONTINUED) TRI Facility ID Number

Toxic Chemical, Category or Generic Name

SECTION 5. QUANTITY OF THE TO XIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ON SITE (continued)

NA A. Total Release (pounds/year*) (enter range code ** or estimate ) B. Basis of Estimate (enter code)

5.4.1 Underground Injection onsite to Class I
Wells 0.005 hours 1.881 hours 0.010 hours

5.4.2 Underground Injection onsite
to Class II-V Wells 0.005 hours 1.881 hours 0.010 hours

5.5 Disposal to land onsite

5.5.1A RCRA Subtitle C landfills 0.005 hours 1.810 hours 0.010 hours

5.5.1B Other landfills 0.005 hours 1.810 hours 0.010 hours

5.5.2 Land treatment/application farming 0.005 hours 1.881 hours 0.010 hours

5.5.3A RCRA Subtitle C surface impoundments 0.005 hours 1.810 hours 0.010 hours

5.5.3B Other surface impoundments 0.005 hours 1.810 hours 0.010 hours

5.5.4 Other disposal 0.005 hours 1.810 hours 0.010 hours

SECTION 6. TRANSFERS OF THE TOXIC CHEM ICAL IN WASTES TO OFF-SITE LOCATIONS

6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1.A Total Quantity Transferred to POTWs and Basis of Estimate

6.1.A.1Total Transfers (pounds/year*) (enter range code ** or estimate) 6.1.A.2 Basis of Estimate (enter code)

1.881 hours 0.010 hours

POTW Name 6.1.B______ 0.008 hours

POTW Address 0.008 hours

City 0.008 hours State 0.008 hours County 0.008 hours Zip 0.008 hours

POTW Name 6.1.B______

POTW Address

City State County Zip If additional pages of Part II, Section 6.1 are attached, indicate the total number of pages

in this box and indicate the Part II, Section 6.1 page number in this box (example: 1,2,3, etc.)

SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS

6.2.______ Off-Site EPA Identification Number (RCRA ID No.) 0.008 hours

Off-Site Location Name 0.008 hours

Off-Site Address 0.008 hours

City 0.008 hours State 0.008 hours County 0.008 hours Zip 0.008 hours Country (Non-US) 0.008
hours

Is location under cont rol of reporting facility or parent company? Yes No 0.008 hours EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete. * For Dioxin or Dioxin-like com pounds, report in grams/year ** Range Codes: A=1-10 pounds: B=1-499 pounds; C=500 - 999 pounds.

4/28/11
A-15Appendix A

4/28/11
A-16 Form Approved OMB Number: 2070-0093 (IMPORTANT: Type or print; read instructions befo re completing form) Approval Expires: 03/31/2011 Page 4 of 5



### FORM R

PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED) TRI Facility ID Number

Toxic Chemical, Category or
Generic Name

SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (CONTINUED)

A. Total Transfers (pounds/year*) (enter range code**or estimate) B. Basis of Estimate (enter code) C. Type of Waste Treatment/Disposal/ Recycling/Energy Recovery (enter code)

1. 1.810 hours 1. 0.010 hours 1.M 0.010 hours

2. 2. 2 . M

3. 3. 3 . M

4. 4. 4 . M

6.2______ Off-Site EPA Identification Number (RCRA ID No.)

Off-Site Location Name

Off-Site Address

City State County Zip Country ( Non-US )

Is location under contro l of reporting facility or parent company? Yes No

A. Total Transfers (pounds/year*) (enter range code**or estimate) B. Basis of Estimate (enter code) C. Type of Waste Treatment/Disposal/ Recycling/Energy Recovery (enter code)

1. 1. 1 . M
2. 2. 2.M

3. 3. 3.M
4. 4. 4.M
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY

Not Applicable (NA)

0.005 hours Check here if no on-site wast e treatment is applied to any waste stream containing the toxic chemical or chemical category

a. General

Waste Stream [enter code] b. Waste Treatment Method(s) Sequence [enter 3- or 4- character code(s)] d. Waste Treatment Efficiency [enter 2 character code]

7A.1a 7A.1 1 2 7A.1d

0.162 hours 3 4 0.648 hours 5 0.416 hours 6 7 8
7A.2a 7A.2 1 2 7A.2d

3 4 5

6 7 8
7A.3a 7A.3 1 2 7A.3d

3 4 5

6 7 8
7A.4a 7A.4 1 2 7A.4d

3 4 5

6 7 8
7A.5a 7A.5 1 2 7A.5d

3 4 5

6 7 8

If additional pages of Part II, Section 6.2/7A are attached, indicate the total number of pages in this box

.

and indicate the Part II, Section 6.2/7 page number in this box: (example: 1,2,3,etc.) EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete. *For Dioxin or Dioxin-like com pounds, report in grams/year **Range Codes: A=1 - 10 pounds; B=11 - 499 pounds C= 500-999 pounds.Appendix A

4/28/11
A-17 Form Approved OMB Number: 2070-0093 (IMPORTANT: Type or print; read instructions befo re completing form) Approval Expires: 03/31/2011 Page 5 of 5



### FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED) TRI Facility ID Number

Toxic Chemical, Category or Generic Name

SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES

Not Applicable (NA) – 0.005 hours Check here if no on-site energy recovery is applied to any waste stream containing the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character code(s)] 0.648 hours

1 2 3

SECTION 7C. ON-SITE RECYCLING PROCESSES

Not Applicable (NA) – 0.005 hours Check here if no on-site energy recovery is applied to any waste stream containing the toxic chemical or chemical category.
Recycling Methods [enter 3-character code (s)] 0.648 hours

1 2 3

SECTION 8. SOURCE REDUCTION AND RECYLING ACT IVITIES

Column A
Prior Year (pounds/year*) Column B Current Reporting Year (pounds/year*) Column C Following Year (pounds/year*) Column D Second Following Year (pounds/year*)

8.1

8.1a Total on-site disposal to Class I Underground InjectionWells, RCRA Subtitle C landfills, and other landfills 0.009 hours 0.146 hours 0.030 hours 0.030 hours

8.1b Total other on-site disposal or other
releases 0.009 hours 0.146 hours 0.030 hours 0.030 hours

8.1c Total off-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills 0.009 hours 0.146 hours 0.030 hours 0.030 hours

8.1d Total other off-site disposal or other
releases 0.009 hours 0.146 hours 0.030 hours 0.030 hours

8.2 Quantity used for energy recovery onsite 0.009 hours 0.856 hours 0.030 hours 0.030 hours

8.3 Quantity used for energy recovery offsite 0.009 hours 0.146 hours 0.030 hours 0.030 hours

8.4 Quantity recycled
onsite 0.009 hours 0.856 hours 0.030 hours 0.030 hours

8.5 Quantity recycled offsite 0.009 hours 0.146 hours 0.030 hours 0.030 hours

8.6 Quantity treated onsite 0.009 hours 0.856 hours 0.030 hours 0.030 hours

8.7 Quantity treated offsite 0.009 hours 0.146 hours 0.030 hours 0.030 hours

8.8 Quantity released to the envi ronment as a result of remedi al actions, catastrophic events,
or one-time events not associated with production processes (pounds/year)* 0.146 hours

8.9 Production ratio or activity index 0.944 hours

8.10 Did your facility engage in any source reduction activities for this chemical during the reporting year? If not, enter “NA” in Secti on 8.10.1 and answer Section 8.11.

Source Reduction Activities [enter code(s)] Methods to Identify Activity (enter codes)

8.10.1 0.648 hours a. 0.010 hours b. c.

8.10.2 a. b. c.
8.10.3 a. b. c.

8.10.4 a. b. c.

8.11 If you wish to submit additional optional information on source reduction, recycling, or pollution control activities, check “Yes.” Yes

0.000 hours EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete. *For Dioxin or Dioxin-like com pounds, report in grams/year *Range Codes: A=1 - 10 pounds; B=11 - 499 pounds C= 500-999 poundAppendix A

4/28/11
A-18Appendix B

4/28/11
B-1 Steady State Total Burden Calculation

This appendix presents and justifies the pr imary method of Ratio-B ased Burden Methodology (RBBM)—the Steady State Total Burden Calcula tion, including details of its development.

As stated earlier, Steady State Total Burden is the estimate of the ongoing TRI Program burden, as updated by rulemakings’ permanent impacts, but absent any first-time filer impacts. Recall from (Eqn. A- 5) of Appendix A: 1

, 2

, 3

Steady State Total Burden = Form R bur den + Form A burden + Non-Form burden

Where:

• Form R Burden = (# Form R chemicals) * (Nominal Form R unit burden)

• Form A Burden = (# Form A chemicals) * (A/R) * (Nominal Form R unit burden)

• Non-Form Burden = (Supplier Notification) + (Non-Reporter Compliance Determination) + Petitions
And:

A/R = Ratio model of single-chemical Form A unit burden to Form R unit
burden
Nominal Form
R Unit
Burden = Single base number for the entire methodology; provides the focal point for assessing and maintaining estimate accuracy

The components of this method include Form burden ( A/R model and Nominal Form R unit
burden ) and non-Form burden (petitions, supplier notification, and non-reporter compliance determination). An important note about this method is the way its components support the overarching methodology priorities of simplicity, internal consis tency, and transitional baseline continuity. The A/R model ensures internal consistency between Form R and Form A unit burdens, and ultimately between total burdens for Form R and Form A chemicals. The Nominal
Form R unit burden is computed with two purposes in mind: to provide a seamless transition from old to new methodology and to serve as the one point for adjustments and updates.

The first section of this appendi x presents the existing system’s relevant characteristics and explains why the new structure was chosen. This section is followed by a series of discussions on method development for several models. These di scussions include, as part of the relevant A/R model specifications, the substantive simplifications including: 1) neglect the effects of first-time filers in steady state burden esti mates, and 2) set the value of PBT/non-PBT model equal to one.

1 This model also applies to estimates of incremental burden associated with a proposed policy or regulatory change. In that case, the number of forms in the equation would represent the incremental number of forms associated with the proposed change.

2 Note that the method’s formulation incorporates simplifica tions: a) Neglect the effect of first-time filers in the steady state, and b) set the ratio model for PBT to non-PBT burden equal to one.

3 For purposes of modeling, EPA refers to “Form R Chemicals” and “Form A Chemicals” in order to provide a consistent metric across form types. In practice Form R re ports contain one chemical pe r report and Form A allows multiple chemicals (2.3 on average).Appendix B

4/28/11
B-2 Additionally, the details fo r specifying non-Form burden and for back calculating Nominal Form
R unit burden are provided.

This appendix does not address burden estimation a ssociated with new Form elements, or related procedures for updating Nominal Form R unit Burden , as these topics are covered as a separate method in Appendix C. Similarly, as first-time file rs are not included in RBBM’s formulation of the Steady State Total Burden Calculation; that estimation, for calculating first-time effects in rulemakings, is covered as a se parate method in Appendix D.

Changes to an Existing System: Adding Simplicity and Internal Consistency

Two aspects of the existing methodology focused RBBM’s design. It was overly complex and it lacked internal consistency (see discussion in th is document’s main report). In order to provide internal consistency, EPA redesigned the Steady State Burden Calculation to incorporate ratio models (discussed in next secti on). In order to simplify, EPA de veloped the Steady State Burden Calculation which requires a minimum number of variables (discussed further here).

The overarching simplification in RBBM is to al gebraically reduce a complex matrix system, as described in Appendix A. As an essential step in that simplification, EPA re-scaled facility-level factors to (per chemical) form -level factors. EPA derived Equivalent Form R/A Chemicals per Facility based on the distributions of Form R and Fo rm A chemicals within and across facilities (see Appendix B Supplement – Distribution Analys is for details). In addition to providing simplification, the re-scaled factors prevent double-counti ng facility-level burden.

Under the existing methodology, double-counting potenti al occurs in two variants. First, when
total Form A and Form R burdens are estima ted, both estimates count the burden for those facilities filing both A and R chemicals. Second, wh en a new chemical is reported by a facility, the incremental burden associated with the new chemical report does not discount for the fact that the facility may already be filing other chem ical forms. With RBBM, facility-level burden is apportioned across (per chemical) form-level unit burdens, so that facil ity-level burden is now accounted for on a “by chemicals” basis, with e ach chemical’s burden only counted once each.

As a secondary benefit of uniformly scaled fact ors, the RBBM form-level estimates are “fully loaded” to incorporate all asp ects of TRI reporting. For this reason, the resultant unit burdens (Form R and the related Form A single-chemical ) are comprehensive, preventing the need to track multiple unit burdens for form and facility. Similarly, the Standardized Form Element
Burdens contain incremental elemental estimates th at similarly incorporate all associated burden (discussed in Appendix C).

As another essential step in the overarching si mplification of algebrai c reduction, EPA imposed substantive simplifications to the Steady State Total Burden Calculation by: 1) neglecting the effects of first-time filers in steady state burden estimates, and 2) setting the PBT/non-PBT model’s ratio value equal to one. The first simplif ication is justified mathematically, as treating
the relevant 3% of TRI chemical reports as steady state filers instead of first-time filers decreasesAppendix B

4/28/11
B-3 the total steady state burden by .04%. 4 The second simplification is justified due to the absence
of an evidence-based verifiable alte rnative (see discu ssion section on the PBT/non-PBT model).

These simplifications, as adjustments to the overall burden calculation, improve the methodology in two ways. First, they keep the equation simp le. Had these simplifications not been made, the Calculation would have required tracking subpopulations of PBT ch emical filers and first-time filers, making the method more complex. As it now stands, only two input variables are required—number of Form R chemicals and number of Form A chemicals. A second benefit from these simplifications is the sophistication of a single unit burden for Nominal Form R unit
burden with Form A reporting burden clos ely linked (see further discussion in Justification:
Back-Calculated Nominal Unit Burden ).

Moving from Implicit to Explicit Ratios

Table B-1 provides the unit burdens and effectiv e ratios embedded in the existing system. As described in the main report, the A/R is .64 acr oss PBT and non-PBT chemicals. Similarly, the
ratio for PBT/non-PBT is 1.73 across Form R and Form A chemicals.

Table B-1: Summary of Form-Based Un it Burdens from Existing Methodology Subsequent Year Burden Hours per Single Chemical Form* A/R=.64; PBT/non-PBT=1.73

Non-PBT PBT
Form R 29.66 51.34
Form A (single chemical)** 20.52 35.89 (no longer valid as PBTs may not be reported on Form A) *excludes facility-level burden for compliance determination **single chemical Form A is used in unit burden comparisons, although mul tiple chemicals may be reported on Form A (about 2.3 on average) Source: Toxics Release Inventory TRI Form R Toxic Chemical Release Reportin g Information Collection Request Supporting Statement OMB Control Number 2070-0093 EPA ICR #1363.15. December 10, 2007.

In the case of A/R , the current ratio of .64 for Form A to R burden 5 is very close to RBBM’s value of .615. However, with the Form A to Form R burden very different from the ratio of form pages of .25, the ratio value needed to be more readily verifiable. Upon inspection, EPA concluded that the reason for the apparently hi gh ratio is due to labor-i ntensive calculations required to determine Form A eligibility that ar e made regardless of final decision on Form type. Using RBBM, the detailed estimates of the Abt Asso ciates Engineering Studi es substantiate this finding with A/R burden estimated at .615. RBBM estimates Form A burden based on detailed

4 Based on 2008 ICR (RY 2007) chemical counts and models, see Findings under A/R Model in this Appendix.

5 For details and context for the A/R value of .64, see: Rice, Cody. 2004. Terms of Clearance for TRI ICR Renewal. Regulations.gov. Accessed 23 Dec 2010 < http://www.regulations.gov/#!do cumentDetail;D=EPA-HQ-OEI-2004-
0006-0004 >Additional references include: 1) the Regulatory Im pact Analysis of the EP CRA Section 313 Alternate Threshold Final Rule, Regulatory Impacts Branch, Economics, Exposure and Technology Division, Office of Pollution Prevention and Toxics, US Environmental Protection Agency, November 18, 1994 and 2) memo from Cody Rice (USEPA/OEI) to Amy Newman (USEPA/OEI) re: Terms of Clearance for TRI ICR Renewal, January 20, 2004. Sources used to derive the .64 figure included 1) the original TRI Regulato ry Impact Analysis, 2) the Pollution Prevention Act EA for the proposed rule from 1991, and 3) the 1/20/2004 Terms of Clearance Memo.Appendix B

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B-4 analysis of common tasks be tween Form A and Form R. 6 The RBBM approach to the A/R model ensures internal consistency and provides verifiable unit burdens, thereby increasing transparency.

Regarding the ratio of PBT/non-PBT burden, the ex isting system’s ratio uni ntentionally resulted from discussions aimed at lowering totals with the decision to make a downward adjustment to non-PBT unit burden, while holdi ng PBT unit burden constant. 7 Under these circumstances, the
resultant ratio of 1.73 occurred as an offshoot of th e revision process, rather than as a deliberate specification. This value of 1.73 is very different than the “null” assumption of 1.0, leaving the basis vulnerable to questions such as: Given th e rationale that PBT chemical reporters incur greater burden because they cannot use the de minimis exemption, how much greater should the
ratio be? How should the ratio be determined? Is there sufficient eviden ce to support the 73% difference? Ideally, quantitativ e evidence obtained via representative sampling would provide information on overall average conditions for TRI reporters. Regarding RBBM’s PBT/non-PBT ratio model, EPA sought to specify a ratio va lue in a manner that would produce internally
consistent and verifiable unit burdens. 8

Justification: Ratio Models with Engineered Building Blocks

As the name implies, ratio models are central to RBBM’s design. As often as possible, EPA
formulates ratio models in order to characte rize key relationships around which it wants to ensure internal consistency. In this appendix, EPA uses A/R and PBT/non-PBT models; see also Standardized Form Element Burdens, FTF, and WAWR models. The ratio structure has a number of advantages:

• Ratios, as a type of measure, possess an absolute zero requiring less maintenance than measures of the components separately.

• Ratio models themselves have intrinsic value, providing useful standa lone metrics as they quantify key relationships between two elements.

• Ratio models are inherently more stable and therefore more robust to changes than their component variables.

Moreover, RBBM’s ratio models pr ovide assurances that unit burde ns are internally consistent
and verifiable because:

• Ratio models specify internal relationships.

• The bases for the ratio models ( A/R, FTF, WAWR ) are quantitatively derived.

6 Note that the burden required to de termine eligibility to use Form A (as described here) is not the same as the burden required to determine whether or not the Section 313 reporting requirements apply to a facility in general. Form A eligibility is based on whether, on a per chemical basis, a facility has less than 500 lbs of total annual reportable amount and that amounts ma nufactured, processed or otherwise us ed do not exceed one million lbs.

7 For details, Rice, Cody. 2004. Terms of Clearance for TRI ICR Renewal. Regulations.gov. Accessed 23 Dec 2010

< http://www.regulations.gov/#!docume ntDetail;D=EPA-HQ-OEI-2004-0006-0004 >.

8 Ultimately, in RBBM the PBT/non-Pbt value is specified as one. Note, how ever, that the higher PBT reporting burden from the existing methodology is incorporated into RBBM’s Nominal Form R unit burden’s starting value of
35.7 hours/Form R. See discussion in Justification: Back-Calculated Nominal Unit Burden section.Appendix B

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B-5 Regarding the robustness, RBBM’s ratio models are robust due to the inherent stability of relationships that they characterize, as well as stability of related assumptions. For example, in the technology advances by whic h reporting shifted from primarily paper to electronic submission, the relationship between Form A burden and Form R burden remained largely unchanged and of the same ratio, while the magnit ude of total reporting burden was estimated to
decrease. This ratio remains stab le because the changes to Form R and Form A impose similarly small incremental burden changes to both the nume rator and the denominator of the ratio, thus causing the ratio itself to remain roughly constant. Note, however, that in the event that the Form R and/or Form A undergo extreme revisions that alter the relationship between A/R burden, then
the A/R model would require updating.

EPA developed RBBM’s ratio models based on ex isting work and best available information.
Detailed burden estimates from the Abt Asso ciates Engineering Studies are employed as computational components of RBBM ratio models (see Appendix G for these studies). In these studies, Abt Associates provided expertise for each study using a team of three staff with nearly 40 years of combined experience working with f acilities on environmental issues. These staff
members had worked with hundreds of faciliti es on TRI reporting and other environmental requirements. They had conducted inspections and provided technical assist ance, served as TRI trainers, conducted technical re view on hundreds of TRI data w ithdrawal requests, conducted hundreds of TRI data quality calls, worked for two of the Massachusetts Toxics Use Reduction Act agencies, and worked as environmental staff at large manufacturing faci lities. In short, the authors have a thorough understanding of what is required in reporti ng, especially with regard to
the relative burden associated w ith each task in relation to ot hers. The authors’ knowledge base was tapped to evaluate burden consistently acr oss reporting activities a nd develop a systematic
set of burden estimates.

The Abt Associates Engineering Studies themse lves provide estimates of burden by activity, with the “calculation and Form completion” activity broken down to element-by-element
estimates. This means that for each element of a Form R, the authors evaluated the
calculations/tasks involved and estimated burden. Moreover, with in the Form R, the authors assessed how frequently a response was provided for each element, and adjusted the element burden by incidence weights. 9

Given the strengths of internal validity and inte rnal consistency, the Abt Associates Engineering Estimates are used as building blocks for ratio models in RBBM. Additionally, since these estimates were derived after the TRI program underwent numerous technology advances, EPA concludes that, on a relative basi s, these estimates reflect updated and more current conditions than those made at TRI program inception. EPA recognizes that the information from the Abt Associates Engineering Studies drew from a non-representative sa mple of TRI reporters 10 , and consequently uses the estimates to develop ratio models of relative re lationships but not for absolute measures (e.g. Form R compliance de termination). Additiona lly, use of the Abt Engineering estimates provides a means by which A/R and other models may be verified. For

9 The incidence rate was calculated using the frozen RY 2002 TRI data. All but one method of the RBBM use this version of unit burdens (in models A/R, FTF, WAWR ). The exception is the set of Form Element Burden Estimates, for reasons described in Appendix C.

10 Note that this weakness does not pose problems in the context of designing ratio models reflecting relative relationships; it is more problematic when revising absolute values for unit burdens.Appendix B

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B-6 justifications of the values assigned to the specif ic ratios see detailed sections on the ratio models themselves in this and other appendices.

Justification: Back-Calculated Nominal Unit Burden

RBBM’s base unit burden, Nominal Form R unit burden is a base number for the entire methodology. Due to the simplifications descri bed above, it provides a comprehensive single focal point for discussions about methodology accur acy. For routine adjustments, such as Form R revisions, estimates for increases or decreases in burden associated with the particular form changes are applied to the Nominal Form R unit burden , with related changes automatically propagated through the RBBM system via ratio m odels (e.g., to Form A, and for first-time filers). As an additional RBBM feature, with the ratio models addressing key internal relationships, Nominal Form R unit burden reflects overall average c onditions for all remaining unspecified effects, removing the need to revise the methodology by adding variables. 11

EPA considered the question: How should the value of the base unit burden be set? From the Abt Associates Engineering Studies, one could as k, why not just sum up the Form R element-byelement estimates to set the value for the Fo rm R unit burden of 7.06 hour s? Instead, RBBM sets the base unit burden based on the back-calculated number—35.7 hours per Form R—that preserves the same total burden, assuming consta nt levels of Form R and Form A chemical

counts.

In managing the transition to RBBM, EPA placed priority on ensuring transitional baseline continuity. This requirement preserves the baseline of total burden at its existing level, with RBBM estimates starting at the point from which pr ior estimates left off. Note that EPA defines the methodology revision’s transition point as the time of the last ICR approval. 12 Thereafter updates are to be made according to RBBM , either via wholesale changes to the Nominal Form
R unit burden , or by making incremental changes to it using Standardized Form Element Burdens. Given the simplified Steady St ate Total Burden Ca lculation, with the A/R key relationship modeled and the total burden fixed, the only variable le ft unspecified is the base unit
burden. The resultant back-calculated value is 35.7 hours, and the variable is termed Nominal
Form R unit burden

.

EPA refers to the back-calculated number as the Nominal Form R unit burden because it is a base number without exact derivation from rigor ous modeling. Mathematically, it represents the Form R, non-PBT, subsequent year unit burden. In practice it serves as a proxy for overall average conditions for all Form R’s (with Form A burden closely linked at 61.5% of that unit burden). As noted above in the previous discussions on overarc hing simplifications, this unit burden incorporates facility-level burdens, compre hensively reflecting all as pects of relevant TRI reporting. 13

11 In this Appendix, the discussion has mainly focused on the PBT/non-PBT and first-time filer effects because they were part of the previous methodology. The broader argument stated here applies to other unmodeled effects, such as ongoing staff turnover.

12 Based on 2007 projections, see TRI 2008 ICR Supporting Statement.

13 Note also that Standardized Burden Elemen t Burdens (See Appendix C), used to update the Nominal Form R unit
burden in the event of form changes, are also comprehensive (i .e.,“fully loaded”) and internally consistent with the
base unit burden.Appendix B

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B-7 As a reflection of overall average Form R unit burden, RBBM’s Nominal Form R unit burden carries forward certain prior assumptions fr om the existing methodology without explicitly modeling them. In particular, no te that the higher PBT reporting burden for 20% of Form Rs is incorporated into the Nominal Form R unit burden’s starting value of 35.7 hours/Form R, which
is elevated above the value th at would have been otherwise obtained—at about 30 hours/form— had only non-PBT burden been used to determine Nominal Form R unit burden

. 14

EPA supports this value of 35.7 hours per Form R as a reasonable approximation of the actual unit burden, based on years of review and scrutiny to which the current total burden estimate has been subjected. The unit burden of 35.7 hours, in the context of a new system of ratio models, is the culmination of prior accuracy assessments, including a 49% decrease to the baseline in the
2004 ICR Renewal. 15 Therefore, this basis is legitimized for ultimately setting the magnitude of the Program total burden at this time.

Method Development

In this section, EPA describes the development wo rk and model-specific justifications for the key components for the Steady State Total Burden Calculation. The section covers models for
Form Burden and constants for non-Form Burde n. The back-calculated unit burden is presented last, because it is specified last.

PBT/Non-PBT Model

The PBT/non-PBT model specifie s unit burden for PBT chemical s with respect to non-PBT chemicals. In this methodology, the value of this ratio is set equal to one:

Ratio of Form R PBT Unit Burden to Form
R non-PBT Unit Burden [=] Hours per PBT Form R Hours per non-PBT Form R

Unlike most analytical decisions in the revised methodology, the decision to set the PBT/nonPBT equal to one is based on the lack of evidence . It is an assertion of a null hypothesis out of concern that the existing system’s specification of 1.73 is unverifiable and could produce internal
inconsistencies. EPA concludes that in the ev ent that a reasonable person asks: Why would a PBT chemical require 73% more burden, on av erage than a non-PBT chemical? EPA should

14 Note from Table B-1 that form-level burden is 29.66 hours per Form R chemical. Adding facility level burdens totaling 4 hours per facility, and given that each reportin g facility manages about 4 Form R chemicals, yields the rough estimate of 30 hours per non-PBT Form R chemical.

15 As an overall 57% downward adjustment, the TRI Program burden estimate was decreased from 6.03 million to 2.61 million hours according to Notices of OMB Action (called Paperwork Re duction Submissions) for Form R ICR and Form A ICR. Submitted October 27, 2003. Approved January 9, 2004. Based on the TRI 2004 ICR Supporting Statements, there were four sources (with relative contributions): 1) reducing non-PBT subsequent year burden from 47.1 to 14.5 hours (85.95%), 2) correcting the previous ICR due to Lead Rule implementation (6.37%), 3) changes to actual reporting from previous ICR (.24%) and 3) a one-time adjustment for TRI-ME (7.44%). This yields a 49%
decrease in total burden associ ated with the methodology change from the first source.Appendix B

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B-8 have a concrete, evidence-based response. In the absence of such quantitative evidence, the fallback position was chosen.

This question has been extensively debated. On one side, public comments from industry express
concern about additional burden due to a dditional demands related to PBT reporting requirements. One the other side, Abt Associates Engineering Studies fi nd no substantial bases for differences. Table B-3 provides the arguments on both sides. Regardless of credibility on either side, both of which are compelling, neither position offers strong evidence of the most likely average relationship representative of the TRI reporting population. EPA concludes that the ratio of PBT to non-PBT reporting burden ca nnot be determined analytically using the readily available information.

As an important qualifier, even thou gh the ratio value for the model for PBT/non-PBT is set equal to one, the overall Steady State Burden Calc ulation carries forward the elevated level of burden related to the prior assumptions of higher PBT unit burden from the existing methodology while not explicitly modeling th e effect (see discussion earlier, under Justification:
Back-Calculated Nominal Unit Burden ).

Table B-3: PBT Chemical Reporting Bu rden relative to non-PBT Chemicals Industry Comments Abt Associates Engineering Studies
SUMMARY Special conditions of PBT reporting, including

no de minimis exception and no range reporting create higher burden for PBT reporting. SUMMARYActivities required for reporting PBT and nonPBT chemicals are similar enough that the
same unit burden hour estimate should be used.

PBT reporting requires additional research, inquiries of suppliers not required to provide
notification of de minimis levels of PBT chemicals, additional calculations for compliance determinations, additional calculations for Form R completion and recordkeeping (extra burden associated with obtaining and managing the relevant data). 1) It does not appear, however, that the lack of the
de minimis exemption will increase the burden associated with making release estimates due to a
need to assess additional waste streams. 2) Also, not being able to use range reporting does not actually increase the reporting burden for PBT filers. Even though range reporting is allowed for non-PBT chemicals in Part II, Sections 5 and 6 of the Form R, it is not allowed for same data elements in Part II, Section 8. As a result, no fewer calculations are necessary to complete a Form R for
non-PBTs versus PBTs due to range reporting. Requires facilities to report PBT chemicals to a precision level of .1 lbs for lead or .0001 grams for dioxins; large number of facilities reporting one pound or less; median lead release for all reporters is one pound.*

*Lead and Lead Compounds Form R reports constitute abou t 55% of PBT chemical reports (and PBTs constitute about 20% of total TRI chemical reports)—measured by average percentages in period between 2004-2007 in
Frozen TRI data for RY 2007Appendix B

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B-9 Sources: 1) Industry comments drawn from comment documents in docket #OEI-2003-0025 for EPA ICR No. 1363.12 and EPA ICR 1363.13;in docket # OEI-2004-0006 for EPA ICR 1363.14; and from docket # TRI-2007-0355, EPA
ICR 1363.15 Abt Associates Engineering Studies (provided in Appendix G) based on development of Realistic Burden Estimates for Total Form R Completion (also see description of these models in this Appendix’s “Justification: Ratio Models with Engineered Building Blocks”).This analysis was conducted separately for non-PBT and PBT chemicals

In conclusion, EPA recommends the value for the PBT/non-PBT model of 1.0 hr/hr.

A/R Model

Given the decision to set PBT/non-PBT equal to one, the next ques tion to address in developing the Steady State Total Burden Calculation is: how to set the A/R ratio value? The A/R model specifies the unit burden for Form A as a functio n of its components common to Form R, defined by:

Ratio of Form A Unit Burden to Form R
Unit Burden [=] Hours per Single-Chemical Form A Hours per Form R

Computed using the factor matrices for Fo rm R and Form A (as derived from Form R) 16 presented in Appendix A:

A/R = ( [A factors from F ′′ i,j ] / ( [F ′′ i,j ] ﴿ 

## ∑∑

== 3

1 4

1 ji 

## ∑∑

== 3

1 4

1 ji

In A/R model building, EPA ensures internal co nsistency between Form A and Form R. When specifying the set of Form R activities similarly a pplicable to Form A, the factor for calculations and form completion is based on the burden invo lved in Form A eligibility determination (including half of Form R’s Section 5 and 6 work ) plus all the tasks associated with Form R elements that also occupy Form A. This level of detail was provided via the rigor of the Abt Associates Engineering Studies. See Appendi x A’s Table A-4 for calculation results for A/R components, according to Form R and Form A. Al so see Table A-5 for a comparison of relative
contributions from the various activities across Forms.

The design of this model re quired the following steps: 17

1. Rescale facility-level factors to form-level factors.
2. Reduce the factor matrices to sums for each Form A and Form R.
3. Compute the ratio of Form A to Form R burden.
4. Verify simplifying assumptions.

16 Where i denotes the row and j

denotes the column from the Matrix F ′′ in Appendix A.

17 See Appendix A for an overview of the derivations and page 10 of the main report for an overview of the decision
rules.Appendix B

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B-10 5. Assess model robustness to shif ts in distributions of Fo rm R and Form A chemicals
within and across facilities.

The key analytical decisions for developing this model include:

1. Deriving Equivalent Form R/A Chemicals per Facility for use in rescaling facility-level factors to (per chemical) form-level factors (covered in Appendix B Supplement).
2. Determining how to translate the burden estimates for Form elements in Form R to corresponding estimates for Form A.
3. Where possible, confirming simplifying assumptions.

Testing the A/R Model

Table B-4 presents the results of the tests that support EPA’s anal ytical decisions to incorporate distributional effects in rescaling, to neglect the effect of first-tim e filers, and to employ the most rigorous version of Abt Associates’ estimates (incidence weighted engineering estimates).

Column (1) shows the reference case, whic h is the most complex model without any simplifications. The reference case has the following attributes:

• Incorporates first-time filer effects

• Uses the most rigorous version of the Ab t Associates Engineering Studies’ estimates (incidence-weighted “Realistic” estimates)

• Rescales using Equivalent Form R/A Chemicals per Facility.

Each model run as shown in Columns (2) throug h (4) removes complexities one at a time to support the recommended model in Column (5) which accepts only one simplification—to neglect first-time filers. 18 Additionally, Column (6) provides a robustness test that shows how much modeling error would be in curred if circumstances changed to a dramatically different
distribution of Form Rs/Form As within and across facilities. 19

18 EPA expected negligible first-time filer effects on the steady state burden because first-time filers account for
2.87% of the total chemicals filed and 6.16 % of facilitie s (average percentages in period between 2004-2007 per Frozen TRI data for RY 2007 based on RY 2005).

19 EPA used distributions from TRI Phase II burden redu ction conditions (see details in Appendix B Supplement).Appendix B

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B-11 Table B-4: A/R Model Development Results and Analysis

Test Run Description (1) REFERENCE

no simplifications (2) Same as

(1) but without first-time filer adjustment (3) Same as (1) but without incidence
rate adjustments (4) Same as (1) but without distribution specificity* (5) RECOMMENDED realistic estimates with incidence rate adjustments** (6)
Robustness Test - alternate distribution
***

Model Form R unit Burden (hrs/Form R) 12.66 12.52 27.24 12.67 12.52 12.53

Model Form A unit burden (hrs/single chem Form A) 7.76 7.67 13.16 7.95 7.71 7.67

A/R 0.613 0.612 0.483 0.628 0.615 0.612 A/R % difference from Reference (Model Error) -0.12 -21.22 2.41 0.39 0.50 * Does not account for potential doubl e-counting of facility level burden among facilities reporting both Rs and As. ** Current A, R, A+R distributions , no first-time filer adjustments *** Phase 2 Burden Reduction Rule

Findings

The recommended formulation of the A/R model with a value of .615 hr /hr, is robust to changes in model assumptions as well as changes in actual c onditions, as simulated, yielding differences
between A/R conditions and the A/R model under 0.5 %. Moreover, si milar results are shown for
the Nominal Form R unit burden in Table B-5—with a co rresponding difference of 1%.

Regarding the practical need for distributiona l considerations, given the relatively small
difference for A/R at 2.41%, 20 EPA considered making the additional simplification. However, with the conversion factors ( Equivalent Form R/A Chemicals per Facility

— Rcpf
e. Acpf
e ) fundamental to RBBM overall, and integral to the development of several models (A/R, FTF f , WAWR) , EPA examined the robustness of the conver sion factors themselves. Table B-5 presents
the result that even in the face of dramatic shifts in distribution, Equivalent Form R/A Chemicals per Facility are reasonably robust, within about 10%.

Taking a more comprehensive view, EPA calculates th e effects of 1) neglec ting first-time filers and 2) the alternate distribution on the Steady State Total Burden estimate. Regarding the assumption to neglect the effect of first-time file r in the steady state, EPA calculates the effect of modeling error on the Steady State Total Burden estimate at -.04% . Re garding the test for an alternate distribution, EPA calculates the associat ed error of encountering different conditions while using RBBM original models whic h results in an error of -.55% for Steady State Total
Burden.

20 The percent difference is calculated by taking the difference between the reference A/R model without distributional specificity and the reference A/R model di vided by the reference A/R model [((0.628-0.613)/0.613) *100 =2.41% ]. Note that figures have been rounded.Appendix B

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B-12 Table B-5: Nominal Form R Unit Burd en and Equivalent Forms per Facility

Test Run Description (1) REFERENCE

no simplifications (2) Same as (1) but without first-time filer

adjustment (3) Same as (1) but without incidence
rate adjustments (4) Same as (1) but without distribution specificity* (5) RECOMMENDED realistic estimates

with incidence rate adjustments** (6)
Robustness
test - alternate distribution***

A/R 0.613 0.612 0.483 0.628 0.615 0.612
A/R % difference from Reference (Model Error) -0.12 -21.22 2.41 0.39 0.50

Back Calculated Nominal Form R Unit Burden 35.75 35.75 37.15 35.59 35.72 35.99
Nominal Form R Unit Burden % difference from Reference (Model Error) 0.02 3.92 -0.43 -0.07 -0.77

Equivalent Form R chemical/facility 3.869 3.869 3.869 3.733 3.869 3.817 chemical/Form R % difference from Reference -3.53 0.00 -1.35

Equivalent Form A chemical/facility 3.407 3.407 3.407 2.302 3.407 3.777 chemical/Form A % difference from Reference -32.43 0.00 10.86

* Does not account for potential doubl e-counting of facility level burden among facilities reporting both Rs and As.

** Current A, R, A+R distributions , no first-time filer adjustments
*** Phase 2 Burden Reduction Rule

Non-Form Burden

The non-Form burden portion of the Steady State Burden Calculati on contains three components: petitions, supplier notification, and non-reporter compliance determ ination. Each component and the new method’s simplifying assumptions are presented below. 21

Burden associated with supplier notification applies to suppliers with customers subject to EPCRA §313 reporting. These supp liers do not necessarily complete TRI reports/Forms themselves. On an annual basis, 3,734 facilitie s are assumed to spend 24 hours each for a total of 89,616 hours. This estimate is currently not regularly updated. It was reviewed in terms of providing an adequate level of burden for the task and viewed as sufficiently high. Moving
forward with the same basis of numbers of facilities and hours per task—and supporting
transitional baseline conti nuity—a constant value of 89,616 hours is estimated.

21 For more detailed information regarding the existing me thod for non-form burden estimates, see TRI 2008 ICR Supporting Statement.Appendix B

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B-13 Burden associated with non-reporter compliance de termination comes from facilities outside of the TRI reporting community that ha ve to determine whether they n eed to file a Form R or Form A. On an annual basis, 183,744 facilities 22 are assumed to spend four hours each for a total of 734,976 hours. In this method, all facilities in NA ICS-code-eligible sector s (with ten or more employees) are assumed to incur compliance determination burden. Wh en reviewing this assumption, EPA concluded that it produces a high ly overstated estimate because only those facilities close to the cusp of TRI reporting thre sholds for manufacture, process and otherwise use, need to check their reporti ng eligibility regularly. In sum, the burden estimate was reviewed in terms of providing an adequate level of burden for the task and viewed as sufficiently high. For the sake of simplicity in s upport of transitional base line continuity, this basis of numbers of facilities and hours per task will be frozen a nd the new methodology estimates the current value

as a constant— 734,976 hours

.

Burden associated with petitions for the TRI program includes activ ities to research, prepare and file a petition with EPA. In the existing met hod, five petitions per year are assumed at 185 hours per petition, totaling 925 hours. This estimate is currently not regul arly updated. It was reviewed in terms of providing an adequate level of burden for the task and viewed as sufficiently high. Moving forward with the same basis of number s of petitions and hours per petition, as well as supporting transitional baseline c ontinuity, a constant value of 925 hours is estimated.

In comparison to the Form burden estimates, wh ich vary with the number and types of Forms that are being filed, the non-Form burden estima tes remain constant in the Steady State Total Burden Calculation. Moreover, as these estimate s are sufficiently large, and in one case highly overstated, they do not require a ny regular maintenance or further updates. The sum of non-Form
burden is constant at 825,517 hours

.

Nominal Form R Unit Burden

Given overarching simplifications and RBBM’s obj ective of transitional baseline continuity,
Nominal Form R is back-calcula ted via the following equation: 23

Eqn. B-1: Nominal Form R Unit Burden = (Total Burden – non-Form burden)/[(# Fo rm R chemicals)+((A/R)*#Form A chemicals)]

EPA defines the methodology revision’s transition point as the time of the last ICR approval with conditions specified by 2008 ICR renewal proj ections. This calculati on produces a value of 35.7 hours per Form R chemical for the Nominal Form R unit burden . As shown in Table B-5,

22 The estimate for the number of facilities that are doing compliance determination but not reporting to TRI is determined by subtracting reporters from the total number of facilities with ten or more employees in TRI-subject NAICS codes. To compute the number of reporting facilities, EPA divides the current number of Form R reports from the latest ICR by the average number of Form s per facility—66,751/3.7. Although non-Form burden has historically been reported with the estimate for Form R burd en in its ICR Supporting Statement, this is only done by convention, as it reflects total non-Form burden for the TRI program.

23 In the actual calculation EPA corrects for double-counting of facility level burden among facilities filing both As and Rs in the last ICR renewal, shifting the baseline down ward slightly (administrative correction due to calculation error). The double-count was caused by estimating facility-l evel burden twice for facilities that file both Forms R and A. In the revised methodology the conversion factors for equivalent chemicals per facility used to rescale facility unit burdens prevent double-counting.Appendix B

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B-14 the Nominal Form R unit burden is robust to changes in model a ssumptions as well as changes in conditions, showing diff erences under 1%.

In April 2010, EPA tested the effectiveness of the back-calculated Nominal Form R unit burden in providing transitional baseli ne continuity. In a spot-check comparison between RBBM Steady State Total Burden and the TRI Program on-reco rd burden numbers, results were within 2%. 24

Summary: Steady State Total Burden Method

Computation

Eqn. B-2: Steady State Total Burden = Form R burden + Form A burden + non-Form burden

= (Nominal Form R unit burden*# Form R chemicals) +(Form R unit burden*(A/R)*#Form A chemicals) + non-Form burden

= 35.7 *# Form R chemicals + [ 35.7 * .615 * # Form A chemicals] + 825,517

Where:

A/R= Ratio model of single-chemical Form A unit burden to Form R unit
burden
Nominal
Form R unit
Burden= Single base number for the entire methodology; provides the focal point for assessing and maintaining estimate accuracy.

Assumptions

The following assumptions apply for the maintenance and update recommendations that follow: 1) Simplifying substantive assumptions remain va lid. First-time filers in the steady state have a negligible effect; PBT/non-PBT burden =1 due to lack of a ve rifiable alternative. 2) The Nominal Form R unit burden of 35.7 hours remains a reasonable estimate of unit burden with Form R non-PBT remaining the most frequent type submission. 3) Relationships between reporting activities in the Abt Associates Engineering Studies which are drawn from a subpopulation, as meas ured by best professional judgment of Abt Associates’ engineers, are reasonably reflect ive of the true relationships in the total reporting population overall. 4) The distribution for Form As/Form Rs within and across facilities stays within the range of distributions in this study (see values for Equivalent R/A Chemicals per Facility in Appendix B Supplement).

24 As of June 2010, the sum of burden hours “on record” was 3.87 million hours, based on Notices of OMB Action, Form R ICR and Form A ICR March 27, 2009. The corresponding RBBM estimate is 3.93 million hours which is within 2%. Note that this RBBM estimate does not include updates to the Form R unit burden to account for the slight additional burden associated with dioxin repor ting (see estimate in the TRI 2012 ICR Renewal Supporting Statement).Appendix B

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B-15 Maintenance and Update Recommendations

EPA evaluated maintenance needs for A/R, Nominal Form R unit burden, and Equivalent Form R/A Chemicals per Facility . None of the models require updating on a routine basis. The A/R model and the back-calculated Nominal Form R unit burden values are robust to extreme changes in (per chemical) Form/facility distribu tions and model assumptions, with differences of less than 1%. However, EPA notes that the A/R formulation is dependent on the conversion
factors used to rescale facility-level unit burdens to (per chemical) form level. Regarding the conversion factors, EPA does not anticipate ex treme changes in their values under status quo operations (and even so, results here are within a 10% modeling error). However, in the event that the program adds industry sector(s), the (p er chemical) form/facility distribution could shift due to the addition of large chem ical counts of different distri butions than the distributions
considered here.

As a practical matter, given that the requireme nts for ICR renewal repo rting provide periodic
recalculation of the Equivalent Form R/A Chemicals per Facility , these numbers can be routinely
checked to be sure that this basis for the A/R model (and others— FTF f and WAWR ) remains
valid. EPA recommends this routine check.Appendix B

4/28/11
B-16 Supplement– Distributional Analysis Equivalent Form R Chemicals per Facility and Equivalent Form A Chemicals per Facility

This supplement describes how and why the conversion factors, Equivalent Form R/A Chemicals per Facility ( / ) were developed. The factors are us ed to re-scale facility-level unit burdens to (per chemical) form level unit burdens. This supplement describes: e Rcpf

e Acpf

• Why the scaling fact ors are needed;

• Formulas used to calculate the factors;

• Derivation of the formulas;

• Distributions for Forms R and A re porting under two scenarios; and

• Values for these factors unde r the two scenarios.

The derivations below provide a divisor for each fac ility-level unit burden that apportions facility
level burden to form level burden. Based on the di stributions of Form As and Form Rs within and across facilities, facility-level burden asso ciated with Form R chemicals is apportioned equally across Form R chemicals and facility-level burden associated with Form A chemicals is apportioned equally across Form A ch emicals. As a result of the de rivations herein, these values, as used for scaling facility-level factors to ch emical level factors are (used in matrices of Appendix A and Table A-4) are: Equivalent Form R Chemicals per Facility, = 3.87

e Rcpf
Equivalent Form A Chemicals per Facility, = 3.42

e Acpf

Equivalent Form R Chemicals per Facility ( ) and Equivalent Form A Chemicals per
Facility ( ) e Rcpf

e Acpf

Facilities reporting to TRI incur facility-level burden, such as compliance determination. This facility-level burden is incu rred once per reportin g cycle, regardless of how many forms a facility files. Facility-l evel burden must be converted to a pe r chemical measure unit burden to be incorporated into the chemical-level ratio model. The conversion entails breaking down and apportioning the facility-level burden by chemical and it depends on the number and form-type
of chemicals filed at the aver age facility. Since EPA tracks burden differently for A and R reporting, the apportionment must be calculated separately for Form R and Form A reporting,
with consideration of the combined Form distributions at facilities.

At the form level, R and A chemicals are repor ted differently, with Fo rm Rs containing one chemical per form and Form As containing one or multiple chemicals on the same form. In actual reporting, a given facility may report any combination of Form types (Rs only, As only, or Rs and As together).

For purposes of methods development and modeli ng, EPA refers to Form R chemicals and Form
A chemicals as the number of chemicals for which each form type is submitted. This metric puts both types of reporting on the same basis, avoidi ng the awkward conversion to put Form As on a per chemical basis, dividing by the average number of chemicals per form. In TRI programAppendix B

4/28/11
B-17 operations, the average number of chemicals per Form A is used to scale chemical counts to form counts, as required to report to OMB the numbe r of responses. It is al so intuitively helpful to know how many chemicals, on average, are re ported via Form A. This conversion—based on
raw counts of chemicals and facilities—is different than the conversion described herein for purposes of re-scaling facility-level unit burde ns to per R/A chemical bases (here termed Equivalent Form R/A Chemicals per Facility).

Since, Form Rs and Form As are considered sepa rately in the model, two measures of facilitylevel burden per chemical are needed:

Facility-level burden per Form R chemical, in hrs/Form R chemical Bprc Facility-level burden per Form A chemical, in hrs/Form A chemical Bpac

Equivalent Form R/A Chemicals per Facility are used to allocate facility-level burden to chemical-level burden. For example, chemical-l evel unit burden (e.g., compliance determination per Form R chemical) for Form Rs can be calcula ted by dividing facility-level burden associated with Form R chemicals by Equivalent Form R Chemicals per Facility . Similarly, chemical-level burden for Form As can be calculated by dividing facility-level burden associated with Form A chemicals by Equivalent Form A Chemicals per Facility.

Equivalent Form R Chemicals per Facility

e Rcpf
Equivalent Form A Chemicals per Facility

e Acpf

These scaling factors are used instead of average forms per facility to adjust reporting burden in a manner that prevents the potenti al double-counting of f acility-level burden for that can occur
when a facilities that files both Form Rs and Form As. There are three types of f acilities that report to TRI (see Figure B-1):

• Facilities reporting only Form As (A Only),

• Facilities reporting bo th Form As and Form Rs (R+A), and

• Facilities reporti ng only Form Rs (R Only).

Figure B-1: Facility Types

If average forms per facility is used to allocate facility-level burden to chemical-level burden, R+A facilities are double-counted (Figure B-2). Using Equivalent Form R/A Chemicals perAppendix B

4/28/11
B-18 Facility to apportion facility-level burden across forms removes this double-counting; these
measures account for the distribution of Form As and Rs within and across facilities.

Figure B-2: Double-Counting usin g Average Forms per Facility

Calculation of and using and Bprc Bpac

e Rcpf

e Acpf

EPA calculates and using a measure of nominal fac ility-level burden per facility

and and . EPA calculates and from the distributions of Form R and Form A reporting among facility types. Speci fic measures used include counts of Form R chemicals and Form A chemicals reported and counts of facilities repor ting Form Rs and As. Bprc

e Apcf Bpac

e Rpcf

e Rpcf

e Apcf

The formulas and are as follows: Bprc

e Rcpf

e OVERALL Rcpf Bff Bprc = , where

ARR RONLY RTOT f f rc

e Rcpf

+ + = η

ARAR AR

acrc rc
R
+ + +

+ = η = Nominal facility-level burden per facility overa ll, for all TRI filers OVERALL Bff

= Number of R+A facilities

AR f

+ = Number of R Only facilities

RONLY f

= Number of Form A chemicals re ported to TRI by R+A facilities AR ac + = Number of Form R chemicals re ported to TRI by R+A facilities

AR rc + = Number of Form R chemicals reported to TRI (by R+A and R Only facilities)

RTOT rc

The formulas and are as follows: Bpac

e Apcf

e OVERALL Acpf Bff Bpac = , where

ARA AONLY ATOT f f ac

e Acpf

+ + = η

ARAR AR

acrc ac A ++ +
+ = η = Nominal facility-level burden per facility overa ll, for all TRI filers OVERALL Bff

= Number of R+A facilities

AR f

+ = Number of A Only facilities

AONLY f

= Number of Form A chemicals re ported to TRI by R+A facilities AR ac + = Number of Form R chemicals re ported to TRI by R+A facilities

AR rc +Appendix B

4/28/11
B-19 = Number of Form A chemicals reported to TRI (by R+A and A Only facilities) ATOT ac

Derivation of Formulas for
, , , and Bprc Bpac

e Rcpf

e Acpf

Together, facility-level burden per Form R chemical ( ) and facility-level burden per Form A chemical ( ) must account for facility-level burden from all three facility types (Table B6). Bprc Bpac

Total facility-level burden associated with Form R chemicals from R Only

facilities RONLY Bf

Total facility-level burden associated with Form A chemicals from A Only

facilities AONLY Bf

Total facility-level burden associated with Form A and R chemicals from R+A

facilities AR Bf

+

Total facility-level burden associated with Form R chemicals and Form A

chemicals from all facilities OVERALL Bf

Table B-6: Facility-level Unit Burden Facility Type Form Type Facility-Level Burden
A Only Form A AONLY Bf

OVERALL Bf A+R Form A

AR Bf

+ Form R

R Only Form R RONLY Bf

All facility-level burden from R Only facilities is apportioned to Form R chemicals. Similarly, all facility-level burden from A Only facilities is apportioned to Form A chemicals. To avoid double-counting, facility-level burden from R+A f acilities is split betwee n Form R chemicals and Form A chemicals (Table B-7).

Total facility-level burden associated w ith Form A chemicals from all facilities reporting Form As ATOT Bf

Total facility-level burden associated w ith Form R chemicals from all facilities reporting Form Rs RTOT BfAppendix B

4/28/11
B-20 Table B-7: Apportionment of Facility-level Unit Burden to Rs and As Facility Type Form Type Facility-Level Burden
A Only Form A AONLY Bf

ATOT Bf

OVERALL Bf A+R Form A

AR Bf

+ Form R

RTOT Bf R Only Form R RONLY Bf

The total facility-level burden for A+R facilities can be apportioned amongst form types using the fraction of forms reported by A+R facilities that are Form Rs and Form As (Figure B-3, Table B-8). This method assumes the magnitude of total facility-level burden for each form type is distributed evenly with the number of fo rms in each type reported by A+R facilities.

R η Fraction of the A+R facility-level burden that is associated with Form R chemicals; used to apportion total facili ty-level burden from A+R facilities to total facility-level burde n for Form R chemicals

A η Fraction of the A+R facility-level burden that is associated with Form A chemicals; used to apportion total facili ty-level burden from A+R facilities to total facility-level burden for Form A chemicals
Number of Form R chemi cals reported by A+R facilities AR rc + Number of Form A chemi cals reported by A+R facilities AR ac +

Eqn. 1

ARAR AR

acrc rc
R
+ + +

+ = η

Eqn. 2

ARAR AR

acrc ac
A
+ + +

+ = η

Note that 1 =+ RA η η . Combining Eqn. 1 and Eqn. 2:

Eqn. 3 1 = = + =+

+ + + +

+ + +

+ + +

+ +

+ + ARAR ARAR

ARAR AR

ARAR AR

acrc acrc

acrc ac

acrc rc
RA ηη

Figure B-3: Fraction of Forms Reported By R+A Facilities
that are Form Rs And Form AsAppendix B

4/28/11
B-21 Table B-8: Apportionment of Facility-lev el Unit Burden from R+A Facilities Facility Type Form Type Facility-Level Burden
A Only Form A AONLY Bf

ATOT Bf

OVERALL Bf A+R Form A

AR Bf

+ ARA Bf

+ ⋅ η

Form R ARR Bf

+ ⋅ η

RTOT Bf R Only Form R RONLY Bf

Apportioning all facility-level burd en from R Only facilities to Form R chemicals, all facilitylevel burden from A Only facilities to Form A ch emicals, and splitting facility-level burden from
R+A facilities between Form R chemicals and Form A chemicals involves the following:

Eqn. 4 RONLY ARR RTOT BfBf Bf +⋅= + η Eqn. 5 AONLY ARA ATOT BfBf Bf +⋅= + η

The total facility-level burden for all TRI filers can be apportioned amongs t facility types using the fraction of TRI reporters in each facility type (Figure B-4). This method assumes the fraction of total facility-level burden incurr ed by each facility type is equal to the fraction of facilities in each type.

Number of faciliti es reporting to TRI OVERALL f
Number of R Only facilities

RONLY f
Number of A Only facilities

AONLY f

Number of R+A facilities

AR f

+ Fraction of TRI reporters (faci lities) reporting only Form Rs,

RONLY x Fraction of TRI reporters (faci lities) reporting only Form As

AONLY x Fraction of TRI reporters (facili ties) reporting Form Rs and As

AR x +

Eqn. 6

OVERALL RONLY

OVERALL RONLY Bf Bf f f

RONLY x == Eqn. 7

OVERALL AONLY

OVERALL AONLY Bf Bf f f

AONLY x == Eqn. 8

OVERALL AR

OVERALL

AR Bf Bf f f

AR x + + == +

Combining Eqn. 4, Eqn. 6, and Eqn. 8:

Eqn. 9 OVERALL ARR OVERALL RONLY RTOT Bfx BfxBf

+ + = η

Combining Eqn. 5, Eqn. 7, and Eqn. 8:

Eqn. 10 OVERALL ARA OVERALL AONLY ATOT Bfx BfxBf

+ + = ηAppendix B

4/28/11
B-22 Figure B-4: The Fraction of To tal Facility-Level Burden Incurred by Each Facility Type

The total facility-level burden for all TRI filers divided by the total number of TRI filers equals the facility-level burden per facility for all TRI filers.

Facility-level burden per facility overall, for all TRI filers OVERALL Bff

Eqn. 11 OVERALL f Bf Bff

OVERALL OVERALL =

Combining Eqn. 9 and Eqn. 11:

Eqn. 12 OVERALL OVERALL ARR OVERALL OVERALL RONLY RTOT fBffx fBffxBf

⋅ +

⋅ = + η

Combining Eqn. 10 and Eqn. 11:

Eqn. 13 OVERALL OVERALL ARA OVERALL OVERALL AONLY ATOT fBffx fBffxBf

⋅ +

⋅ = + η

Total facility-level burden can be converted to facility-level burden per chemical by dividing by
number of chemicals:

Eqn. 14 RTOT RTOT

rc Bf Bprc =

Eqn. 15 ATOT ATOT

ac Bf Bpac =

Combining Eqn. 12 and Eqn. 14:

Eqn. 16

RTOT OVERALL OVERALL ARR OVERALL OVERALL RONLY

rc f Bffx f Bffx Bprc ⋅ +⋅ + = η

Simplifying Eqn. 16:

Eqn. 17 OVERALL rc f f Bff Bprc

RTOT ARR RONLY

⋅ = + + ηAppendix B

4/28/11
B-23 In Eqn. 17, ARR RONLY ff

+ + η represents the equivalent number of facilities associated with Form R reporting. Equivalent Form R Chemicals per Facility equals the number of Form R chemicals reported divided by this number of facilities.

Eqn. 18

ARR RONLY RTOT ff rc

e Rcpf

+ + = η

Combining Eqn. 17 and Eqn. 18:

Eqn. 19

e OVERALL Rcpf Bff Bprc =

Combining Eqn. 13 and Eqn. 15:

Eqn. 20

ATOT OVERALL OVERALL ARA OVERALL OVERALL AONLY

ac f Bffx f Bffx Bpac ⋅ +⋅ + = η

Simplifying Eqn. 20:

Eqn. 21 OVERALL ac f f Bff Bpac

ATOT ARA AONLY + +

= η

In Eqn. 21, ARA AONLY ff

+ + η represents the equivale nt number of facilities associated with Form A reporting. Equivalent Form A Chemicals per Facility equals the number of Form A chemicals reported divided by this number of facilities.

Eqn. 22

ARA AONLY ATOT f f ac

e Acpf

+ + = η

Combining Eqn. 23 and Eqn. 24:

Eqn. 23

e OVERALL Acpf Bff Bpac =

Calculation of
, , , and Under Current Operations Bprc Bpac

e Rcpf

e Acpf

Bprc and can be calculated using the distribution of forms and faciliti es among facility types under current operations as projected in the 2008 ICR renewal. This distribution is presented in Table B-9. BpacAppendix B

4/28/11
B-24 Table B-9: Form and Facility Distributio ns Under Current Operations - No Burden
Reduction

Reporter Type Unique
Facilities Count of Chemicals Average Number of
Chemicals
R A Total R A Total A Only 2,307 0 4,831 4,831 N/A 2.09 2.09 R Only 18,748 67,772 0 67,772 3.61 N/A 3.61
Both R and A 2,406 10,764 5,945 16,709 4.47 2.47 6.94
Total/Overall 23,461 78,536 10,776 89,312 3.73 2.30 3.81
Note: Raw form counts were used to match th e 2008 ICR. Chemicals are not rolled up at the facility-chemical level. Source: TRI 2005 Public Data Release, RY 2005

Under current TRI operations,

• Nominal Facility-level burden=1.25 for non-PBT, subsequent year (compliance determination only)

• Equivalent Form R Chemicals per Facility = 3.87

• Equivalent Form A Chemicals per Facility = 3.41

• Facility-level burden per Form R chemical = 0.32

• Facility-level burden per Form A chemical = 0.37 (Table B-10 and Table B-11)

Table B-10: Variables, Formulas,
and Values Used to Calculate Facility-level Burden per Form R Chemical Under Current Operations
Variable/Formula Value

RTOT rc 78,536

AR rc + 10,764

AR ac + 5,945

RONLY f 18,748

AR f

+ 2,406

OVERALL Bff 1.25

ARAR AR

acrc rc
R
+ + +

+ = η 0.64

ARR RONLY RTOT f f rc

e Rcpf

+ + = η 3.87

e OVERALL Rcpf Bff Bprc = 0.32 Table B-11: Variables, Formulas,
and Values Used to Calculate Facility-level Burden per Form A Chemical Under Current Operations
Variable/Formula Value

ATOT ac 10,776

AR rc + 10,764

AR ac + 5,945

AONLY f 2,307

AR f

+ 2,406

OVERALL Bff 1.25

ARAR AR

acrc ac A ++ +
+ = η 0.36

ARA AONLY ATOT f f ac

e Acpf

+ + = η 3.41

e OVERALL Acpf Bff Bpac = 0.37Appendix B

4/28/11
B-25 Calculation of
, , , and Under Alternate Operations Bprc Bpac

e Rpcf

e Apcf

Bprc and were also calculated under an alternativ e scenario, using the distribution of Form

R/ Form A within and across facilities during phase II burd en reduction conditions. This alternative distribution is presented in Table B-12. Bpac

Table B-12: Form and Facility Dist ributions Under Alternate Conditions

Reporter Type Unique
Facilities Count of Chemicals Average Number of
Chemicals
R A Total R A Total A Only 4,020 0 8,096 8,096 N/A 2.01 2.01 R Only 13,226 35,196 0 35,196 2.66 N/A 2.66
Both R and
A 6,215 31,555 14,465 46,020 5.08 2.33 7.40

Total/Overa
ll 23,461 66,751 22,561 89,312 3.80 2.21 3.81

Note: Raw form counts were used to match the 2008 ICR. Chemicals were not rolled up at the facility-chemical level. Source: TRI 2005 Public Data Release, RY 2005

Under alternate conditions,

• Nominal Facility-level burden=1.25 for non-PBT, subsequent year (compliance determination only)

• Equivalent Form R Chemicals per Facility = 3.82

• Equivalent Form A Chemicals per Facility = 3.78

• Facility-level burden per Form R chemical = 0.33

• Facility-level burden per Form A chemical = 0.33 (Table B-13 and Table B-14)Appendix B

4/28/11
B-26 Table B-13: Variables, Formulas,
and Values Used to Calculate Facility-level Burden per Form R
Chemical Under Alternate
Conditions
Variable/Formula Value Table B-14: Variables, Formulas, and Values Used to Calculate Facility-level Burden per Form A Chemical Under
Alternate Conditions

Variable/Formula Value

ATOT ac 22,561

AR rc + 31,555

AR ac + 14,465

AONLY f 4,020

AR f

+ 6,215

OVERALL Bff 1.25

ARAR AR

acrc ac A ++ +
+ = η 0.31

ARA AONLY ATOT f f ac

e Acpf

+ + = η 3.78

e OVERALL Acpf Bff Bpac = 0.33 RTOT rc 66,751

AR rc + 31,555

AR ac + 14,465

RONLY f 13,226

AR f

+ 6,215

OVERALL Bff 1.25

ARAR AR

acrc rc
R
+ + +

+ = η 0.69

ARR RONLY RTOT f f rc

e Rcpf

+ + = η 3.82

e OVERALL Rcpf Bff Bprc = 0.33Appendix C

4/28/11 C-1 Form Element Estimation

This appendix presents the Form Element Estimation method of the Ratio-Based Burden Methodology (RBBM), including the models of Standardized Form Element Burdens. The method provides a standardized set of form elem ent burdens for use when estimating changes to the Form R, as applied to the Nominal Form R unit burden

. 1

This method is different from the other me thods of RBBM in the way it implements the methodology priorities of simplicity, internal co nsistency, and estimate baseline continuity.
Unlike the A/R

, FTF and WAWR , this method’s models are cl osely tied to the methodology’s base number, Nominal Form R unit burden . If estimates obtained by this method are not
considered in context of the unit burden used for reference, they may indu ce artificial baseline shifts, or at a minimum, produce internal inconsistencies, as burden estimates due to form changes do not adequately reflec t their proportionate contributi on to the total form unit burden. The means by which this method main tains internal c onsistency with Nominal Form R unit
burden is by ensuring that the form elements of the Form R sum to the value (or close to the value of) the Nominal Form R unit burden. Therefore, in the event that the Nominal Form R unit
burden undergoes a wholesale update or large cha nge its value, the entire Form Element
Estimation method must be revised so that Stan dardized Form Element Burdens proportionately add up to the value of the new Nominal Form R unit burden

.

For simplicity, this method standardizes the Abt Associates Engineering Studies estimates to develop Standardized Form Element Burdens. St andardization is achieved by organizing similar form elements into standard categories, and then using average burdens. For internal consistency
between Standardized Form Element Burdens and the Nominal Form R unit burden , the elements
are scaled so that the sum of all element estimates is equal to the Nominal Form R unit burden of
35.7. Like the Nominal Form R unit burden , each form element estimate is fully loaded, incorporating facility-lev el burden. This approach is consiste nt with Decision Rule #5 on page 10 in the main report. 2 With respect to tran sitional and ongoing baseline continuity, the method ensures that the changes in unit burden are estimated in a manner that induces changes to the
baseline commensurate with inte nded changes in the form.

Form Element Estimation Method

Method Development

The method provides a way to quickly estimate an incremental burden associated with a form change. The equation below represents the method for estimating the total burden after accounting for the new data elements.

Nominal Form R unit burden
new = Nominal Form R unit burden old + Form change burden

1 Changes that affect Form R may or may not affect Form A. In this methodology, when changes to Form R affect Form A, they are theoretically captured when the Form R unit burden is multiplied by the A/R model. The A/R model is not updated in conjunction with form changes, as it is sufficiently robust.

2 This scaling differs from scaling used in Abt Associates Engineering Studies (see references in Appendix G). In the Engineering Studies, when scaling from “realistic” to “scaled” estimates, elements were not scaled up proportionately. Some elements were considered “un-scalab le.” This decision altered the relative proportions of each element, compromising internal consistency and considered inappropriate for RBBM.Appendix C

4/28/11 C-2 The form change burden could be a positive or negative number, depending on the nature of the form elements that are added to, or removed from , Form R. In order to implement this feature, EPA first developed a classification system of es timates related to the current form and then scaled the standardized elements so they sum to the Nominal Form R unit burden . Key analytical decisions included 1) defining the categories of th e classification system that best represent the form elements, and 2) specifying the scaling syst em that works best for this method’s objectives as well as overall methodology objectives. The deve lopment steps are described below. Due to the very long nature of the tables, they are a ll presented at the end of this Appendix with the exception of Table C-5, which is brief and th erefore included in the body of the Appendix.

Identifying Standardized Categories

As mentioned above, EPA develope d a classification system of es timates related to the existing Form R and then grouped data elements into standardized burden cate gories. This section
describes how the classification system was organized. Table C-1 provides the list of estimates
from the TRI RY 2002 Form R from the Abt Asso ciates Engineering Studies (see Appendix G). 3 From this list, EPA defined categories and co mputed means and variance for each category.

This method groups elements into corresponding categories to which new data elements may belong. Data elements were grouped into categories using the following criteria:

1. The information collected by the data element: release value, facility location information, chemical identif ication information; and
2. The type of work required to fill out the data element: locating and reviewing monitoring data, conducting a short informa tion look-up, or typing a simple code.

Initially, data elements were grouped into cate gories with other elem ents that required the collection of similar information. However, in some cases these ini tial categories had high variability in estimated engineering burden. EP A reduced this variability by refining the categories by type of work required. Data elem ents collecting estimates of source reduction and recycling activity in the current year, for exampl e, were initially grouped together yet varied considerably in burden. This group was then sp lit into two groups: one for quantities derived
from relevant Section 5 and 6 data elements and the other for source reduction and recycling
estimates with no relevant Section 5 and 6 data elements. The final list of data elements in their respective categories is included in Table C-2.

The estimates are called raw estimates for the pu rpose of this study, as they did not contain incidence weights, which were based on response frequencies by data elem ent. EPA discussed the merits and disadvantages of using the Abt A ssociates Engineering Studies fully engineered numbers, as were used in A/R, FTF and WAWR . However, for the needs of this method, they
were not considered the most appropriate estimates. Given the setting in which EPA estimates form changes, often the incidence rate for a new element is unknown, providing no basis for an average or general assumption. Also, given th e objective of Standardized Form Element Burdens, raw data element estimates provided cons istent information for data elements that are

3 Although the information drew from a non-representative sample of reporters, the study’s design insured a high level of internal consistency due to its internal validity. See Appendix B for a complete discussion of the strengths and weaknesses of Abt Associates Engin eering Studies as they apply to RBBM.Appendix C

4/28/11 C-3 theoretically the same without re spect to reporter behavior. Similarly, knowing in advance that the method will require scaled estimates used to update the Nominal Form R unit burden, then it is desirable to have similar data elements posse ss the same standardized value. As a result of these considerations, EPA decided to use the ra w estimates without incidence weighting for the pre-scaling basis of the method. Th is decision provides internal consistency from data elements
to Form and across Form R and Form A.

Scaling Options

EPA considered whether or not it was necessary to scale the standardized categories to the
Nominal Form R unit burden to ensure consistency between the Form Element Estimation
Method and the Nominal Form R unit burden . The following four opti ons were considered:

• Option 1 – No scaling, use raw es timates (no incidence weighting)

• Option 2 – No scaling, use incide nce weighted raw estimates

• Option 3 – Scale raw estimates (no inciden ce weighting) to Nominal Form R burden (35.7 hours).

• Option 4 4 – Scale raw estimates (no incidence weighting) to Calculation and Form Completion portion of Nomina l Form R burden (20.4 hours)

EPA then ranked the first three options base d on internal consistency, parsimony, intuitive calculations, temporal consistency, ICR renewal im plications and EA imp lications (see Table C4). With the highest rank, Option 3 was selected as the best appr oach. The main reasons for this
decision are as follows:
1. Scaling the raw estimate category so that the Form R totals 35.7 hours provides consistency because 35.7 hours is the value of the Nominal Form R unit burden . As
with the Nominal Form R unit burden , the Standardized Form Element Burdens reflect “fully loaded” estimates of all act ivities associated with Form R completion (facility-level and per chemical form-level).
2. At face value, this scaling produces relatively intuitive calculations given expectations that that the sum of categor y means should equal the total burden per
Form R.

Tables C-2 and C-3 present a general profile for each category of the Standardized Form Element Burdens, including the number of data elements corresponding to each category, the mean, and the standard deviation for each catego ry with burden estimates raw and scaled to 35.7 hours, respectively.

Findings

The Form Element Estimation method is designed to provide a struct ured and reproducible method for estimating burden associated with Form changes. When new form elements are added to Form R, EPA staff will be able to use Table C-3 or Figure A-2 st andardized burdens to determine what change in burden (in hours) is associated with the form changes.

Additionally, with experience, EP A has discovered that form ch anges do not always manifest
themselves within the confines of this method’s framework for “add or subtract a form element.”

4 Note that Option 4 was considered at a later date and theref ore, was not ranked.Appendix C

4/28/11 C-4 In fact, changes are often so minuscule that EP A estimates them to have a negligible impact on form-related burden. Table C-5 provides a list of changes of this nature.

Table C-5: Form Changes for Which A dditional Burden is not Estimated Form Change Circumstance of Inestimable Burden Code or Check Box (could include: indication of activity or reason, yes/no, NA, etc.) Where burden associated with data gathering and recordi ng is negligible and frequency of reporting the data element is low. Or if response is already implied in existing data element (e.g. addition of NA box)
Clarification of existi ng required data fields including reorganization Where clarification on reporting form is made but no new information is required Addition of optional open-ended question No burden by convention

Method Summary

Computation

To illustrate how a revised Nominal Form R unit burden is calculated when new data elements are added to Form R, assume that EPA is addi ng a new data element to capture an additional EPA identification number such as the Facility Re gistry System (FRS) ID. If the analyst is familiar with the specific existing data element or group of existing data elements to which the new data element is similar, he/she can refe r to the relevant categorical burden in the
Standardized Form Element Burdens listed in Table C-3 and in the Program Staff Tool. Alternately, the analyst can look up a similar el ement’s standardized burden, as depicted in Figure A-2. Table C-3 shows the time estimate for Facility Identification Information Codes .0023 hours. The sample calculation of the new Nominal Form R unit burden is as follows:

Eqn. C-1: Form R Unit Burden when New Form Elements are Added

Nominal Form R unit burden
new = Nominal Form R unit burden old + Form change burden

Nominal Form R unit burden
new = 35.7 hours + .0023 hours =35.7023 hours

Assumptions

When a new form element is added to Form R an d the incremental burden associated with the
form element is selected from one of the categories, the follo wing three assumptions are made:

1) The corresponding category is representative of the new data element. For this assumption to hold true, reporter activity re presenting the new data element should be similar to the activities comprising that general category. 2) The incidence weight for the new data elemen t need not be considered in this method. 3) The Nominal Form R unit burden —as the calculated sum of form element burdens—
remains close to the value used to scale the system of form elements (35.7 hours) because burden associated with form changes are sm all relative to the overall form burden.Appendix C

4/28/11 C-5 Maintenance and Update Recommendations

This method does not require periodic updates. The decision on whether an update is necessary should be made according to the following recommendation:

• For ICR renewals and EAs accompanying major rulemakings: review the form element categories to ensure proper form element classification. Compare the scaling
basis of 35.7 to the curre nt value assigned to Nominal Form R unit burden

.

• For minor EAs and other minor analyses: no update is required.

In the event that the Nominal Form R unit burden undergoes a wholesale update or large change in its value, the entire Form Element Estima tion method must be revised to assure that Standardized Form Element Burdens proporti onately add up to the value of the new Nominal
Form R unit burden

.

Table C-1: List of Categories and Corresponding Form Elements

Category Form Part Sub Section Data Element

Certification PART I. Facility Identification Information 3: Certification Name and official title

Signature

Date signed

Chemical Identification Information PART II. Toxic Chemical Release Inventory Reporting Form 1.1: CAS Number Section 1.1: CAS number

1.2: Toxic Chemical or Chemical Category Name Section 1.2: Toxic chemical or chemical category name

1.3: Generic Chemical Name Section 1.3: Generic chemical

name
2.1: Generic Chemical Name Provided by Supplier Section 2.1: Generic chemical name provided by supplier

Code or Checkbox for Readily Available Info PART II. Toxic Chemical Release Inventory Reporting Form 5.1: Fugitive or non-point air emissions B. Basis of estimate

5.2: Stack or point air emissions B. Basis of estimate

5.4.1: Underground injection onsite to Class I wells B. Basis of estimate

5.4.2: Underground injection onsite to Class II-V wells B. Basis of estimate

5.5.1A: RCRA Subtitle C landfills B. Basis of estimate

5.5.1B: Other landfills B. Basis of estimate

5.5.2: Land treatment/application farming B. Basis of estimate

5.5.3A: RCRA Subtitle C surface impoundments B. Basis of estimateAppendix C

4/28/11 C-6 5.5.3B: Other surface impoundments B. Basis of estimate

5.5.4: Other disposal B. Basis of estimate

6.1.A: Total quantity transferred to POTWs and basis of estimate 6.1.A.2: Basis of estimate

7A.1e: Based on operating data? 7A.1e: Based on operating data? 5.3: Discharges to receiving streams or water bodies B. Basis of estimate

6.2: Transfers to other off-site locations B: Basis of estimate

6.2: Transfers to other off-site locations C: Type of waste treatment/ disposal/recycling/energy

recovery 8.10: Did your facility engage in any source reduction activities? Methods to identify activity

Description of M/P/OU at Facility PART II. Toxic Chemical Release Inventory Reporting Form 3.1: Manufacture the toxic chemical Section 3.1: Manufacture the
toxic chemical

3.2: Process the toxic chemical Section 3.2: Process the toxic chemical

3.3: Otherwise use the toxic
chemical Section 3.3: Otherwise use
the toxic chemical

Description of Treatment or Pollution Prevention Activity PART II. Toxic Chemical Release Inventory Reporting Form 7B: On-site energy recovery

processes Energy recovery methods

7C: On-site recycling processes Recycling Methods

7A: On-site waste treatment methods and efficiency 7A.1b: Waste treatment method(s) sequence 8.10: Did your facility engage in any source reduction activities? Source reduction activities

Description of Waste Stream at Facility PART II. Toxic Chemical Release Inventory Reporting Form 7A: On-site waste treatment methods and efficiency 7A.1a: General waste stream (enter code)

Facility Identification Information - Codes PART 1. Facility Identification Information 4.5 Section 4.5 NAICS Code(s) (6 digits)

4.6 Section 4.6: Dunn and Bradstreet Number(s) (9 digits)

5.2: Parent company's Dun & Bradstreet number Section 5.2: Parent company's Dun & Bradstreet number

4.8: EPA identification number (RCRA I.D. No.) Section 4.8: EPA identification number (RCRA I.D. No.) 4.9: Facility NPDES permit number(s) Section 4.9: Facility NPDES permit number(s)

4.10: Underground injection well code (UIC) I.D. number(s) Section 4.10: Underground injection well code (UIC) I.D. number(s)

4.1 TRI facility ID numberAppendix C

4/28/11 C-7 Facility Identification Information - Geographic PART 1. Facility Identification Information 4.6: Latitude Degrees

Minutes

Seconds

Degrees

Minutes

Seconds

Facility Identification Information - Name and Contact PART 1. Facility Identification Information 4.1 Facility or establishment name

Street

City/county/state/zip code

Facility or establishment name or mailing address (if different from street address)

Mailing address

City/state/zip code

Country (non-US)

4.3 Technical contact name

Telephone number

Email address

4.4 Public contact name

Telephone number

5.1: Name of parent company Section 5.1: Name of parent

company

Form Type PART 1. Facility Identification Information 1: Reporting Year Secti on 1: Reporting Year

2.1: Are you claiming the toxic chemical identified on page 2 trade secret? Section 2.1: Are you claiming the toxic chemical identified on page 2 trade secret? 2.2: Is this copy sanitized or unsanitized? Section 2.2: Is this copy sanitized or unsanitized?

4.2: This report contains information for (check a or b; check c or d if applicable) Section 4.2: This report contains information for (check a or b; check c or d if applicable)Appendix C

4/28/11 C-8 Future Year Projection PART II. Toxic Chemical Release Inventory Reporting Form 8.1a: Total on-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills Column C: Following year

Column D: Second following
year

8.1b: Total other on-site disposal or other releases Column C: Following year

Column D: Second following
year

8.1c: Total off-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills Column C: Following year

Column D: Second following
year

8.1d: Total other off-site disposal or other releases Column C: Following year

Column D: Second following
year

8.2: Quantity used for energy recovery on-site Column C: Following year

Column D: Second following
year

8.3: Quantity used for energy recovery off-site Column C: Following year

Column D: Second following
year

8.4: Quantity recycled on-site Column C: Following year

Column D: Second following
year

8.5 Quantity recycled offsite Column C: Following year

Column D: Second following
year

8.7: Quantity treated off-site Column C: Following year

Column D: Second following
year

8.6: Quantity treated on-site Column C: Following year

Column D: Second following
year

Measure of Activity at Facility PART II. Toxic Chemical Release Inventory Reporting Form 8.9: Production ratio or activity index Section 8.9: Production ratio or activity index

4.1 Section 4.1: Determine maximum quantity on-siteAppendix C

4/28/11 C-9 Measure of Waste/Discharge Stream PART II. Toxic Chemical Release Inventory Reporting Form 7A.1c: Range of influent concentration 7A.1c: Range of influent concentration 5.3: Discharges to receiving streams or water bodies C. % from stormwater

7A: On-site waste treatment methods and efficiency 7A.1d: Waste treatment efficiency estimate

NA PART II. Toxic Chemical Release Inventory Reporting Form 5.1: Fugitive or non-point air emissions NA

5.2: Stack or point air emissions NA

5.4.1: Underground injection onsite to Class I wells NA

5.4.2: Underground injection onsite to Class II-V wells NA

5.5.1A: RCRA Subtitle C landfills NA

5.5.1B: Other landfills NA

5.5.2: Land treatment/application farming NA

5.5.3A: RCRA Subtitle C surface impoundments NA

5.5.3B: Other surface impoundments NA

5.5.4: Other disposal NA

7A: On-site waste treatment methods and efficiency NA

7B: On-site energy recovery

processes NA

7C: On-site recycling processes NA

5.3: Discharges to receiving streams or water bodies NA

Optional Data Element PART II. Toxic Chemical Release Inventory Reporting Form 8.11: If you wish to submit additional optional information on source reduction, recycling, or pollution control activities, check “Yes.” Section 8.11: If you wish to submit additional optional information on source reduction, recycling, or pollution control activities, check “Yes.”

Quantity Derived from Relevant Section 5 and 6 Data Elements PART II. Toxic Chemical Release Inventory Reporting Form 8.1a: Total on-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills Column B: Current reporting

year

8.1b: Total other on-site disposal or other releases Column B: Current reporting

year 8.1c: Total off-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills Column B: Current reporting
year

8.1d: Total other off-site disposal or other releases Column B: Current reporting

yearAppendix C

4/28/11 C-10 8.3: Quantity used for energy recovery off-site Column B: Current reporting

year

8.5 Quantity recycled offsite Column B: Current reporting
year

8.7: Quantity treated off-site Column B: Current reporting

year 8.8: Quantity released to the environment as a result of remedial actions, catastrophic events, or one-time events not associated with production
processes Section 8.8: Quantity
released to the environment as a result of remedial actions,catastrophic events, or onetime events not associated with production processes

Receiving Facility/Site Identification Information PART II. Toxic Chemical Release Inventory Reporting Form 5.3: Discharges to receiving streams or water bodies 5.3.1: Stream or water body

name

6.1.B: POTW POTW name

POTW address

City

State

County

Zip

6.2: Transfers to other off-site locations Off-site EPA identification number (RCRA ID No.)

Off-site location name

Off-site address

City

State

County

Zip

Country (non-US)

Is location under control of reporting facility or parent company?
Release Quantity Estimated Using Emissions Factors PART II. Toxic Chemical Release Inventory Reporting Form 5.2: Stack or point air emissions A. Total release

Release Quantity PART II. Toxic Chemical Release Inventory Reporting 5.5.1A: RCRA Subtitle C landfills A. Total releaseAppendix C

4/28/11 C-11 Estimated Using Facility Records Form 5.5.1B: Other landfills A. Total release

5.5.3A: RCRA Subtitle C surface impoundments A. Total release

5.5.3B: Other surface impoundments A. Total release

5.5.4: Other disposal A. Total release

6.2: Transfers to other off-site locations A: Total transfers

5.4.1: Underground injection onsite to Class I wells A. Total release

5.4.2: Underground injection onsite to Class II-V wells A. Total release

5.5.2: Land treatment/application farming A. Total release

6.1.A: Total quantity transferred to POTWs and basis of estimate 6.1.A.1: Total transfers

5.3: Discharges to receiving streams or water bodies A. Total release

Release Quantity Estimated Using Physical and Chemical Properties of Chemical and
Process Operating Conditions PART II. Toxic Chemical Release Inventory Reporting Form 5.1: Fugitive or non-point air emissions A. Total release

SRR with No
Relevant Section 5 and 6
Data Elements Current Year PART II. Toxic Chemical Release Inventory Reporting Form 8.2: Quantity used for energy recovery on-site Column B: Current reporting
year

8.4: Quantity recycled on-site Column B: Current reporting
year

8.6: Quantity treated on-site Column B: Current reporting
year

Value Reported in Prior Year PART II. Toxic Chemical Release Inventory Reporting Form 8.1a: Total on-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills Column A: Prior year

8.1b: Total other on-site disposal or other releases Column A: Prior year

8.1c: Total off-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills Column A: Prior year

8.1d: Total other off-site disposal or other releases Column A: Prior yearAppendix C

4/28/11 C-12 8.2: Quantity used for energy recovery on-site Column A: Prior year

8.3: Quantity used for energy recovery off-site Column A: Prior year

8.4: Quantity recycled on-site Column A: Prior year

8.5 Quantity recycled offsite Column A: Prior year

8.6: Quantity treated on-site Column A: Prior year

8.7: Quantity treated off-site Column A: Prior yearAppendix C

4/28/11 C-13 Table C-2: Standardized Form Element Bu rden Categories (Raw Estimate Means and Standard Deviations)

Category Number of Data Elements Time (Hours)

Mean St Dev
Certification 3 NA NA
Chemical Identification Information 4 0.0014 0.0000 Code or Checkbox for Readily Available Info 15 0.0057 0.0005 Description of M/P/OU at Facility 3 0.0014 0.0000 Description of Treatment or Pollution Prevention Activity 4 0.3889 0.2102

Description of Waste Stream at Facility 1 0.0972 NV Facility Identification Information - Codes 4 0.0014 0.0000 Facility Identification Information - Name and Contact 14 0.0014 0.0000

Form Type 4 0.0035 0.0014 Future Year Projection 20 0.0181 0.0000 Measure of Activity at Facility 2 0.5667 0.0668 Measure of Waste/Discharge Stream 2 0.2494 0.2997

NA 13 0.0028 0.0000 Optional Data Element 1 0.0000 NV Quantity Derived from Relevant Section 5 and 6 Data Elements 8 0.0875 0.0000

Receiving Facility/Site Identification Information 16 0.0046 0.0027 Release Quantity Estimated Using Emissions Factors 1 1.1278 NV

Release Quantity Estimate d Using Facility Records 6 1.0861 0.2645 Release Quantity Estimated Using Monitored Values 5 1.1287 0.1644 Release Quantity Estimated Using Physical and Chemical Properties of Chemical and Process Operating Conditions 1 1.9583 NV

SRR with No Relevant Section 5 and 6 Data Elements Current Year 3 0.5139 0.0000

Value Reported in Prior Year 10 0.0056 0.0000
NV indicates a value could not be calculated becaus e there is only one data element in the category or because total raw time is zero.Appendix C

4/28/11 C-14 Table C-3: Standardized Form Element Burden Categories (Means and Standard
Deviations Based on Raw Burden Estimates Scaled to 35.7 Hours)

Category Number of Data Elements Time (Hours)

Mean St Dev
Certification 3 NA NA
Chemical Identification Information 4 0.0023 0.0000 Code or Checkbox for Readily Available Info 15 0.0096 0.0008 Description of M/P/OU at Facility 3 0.0023 0.0000 Description of Treatment or Pollution Prevention Activity 4 0.6481 0.3502

Description of Waste Stream at Facility 1 0.1620 NV Facility Identification Information - Codes 4 0.0023 0.0000 Facility Identification Information - Name and Contact 14 0.0023 0.0000

Form Type 4 0.0058 0.0023 Future Year Projection 20 0.0301 0.0000 Measure of Activity at Facility 2 0.9444 0.1113 Measure of Waste/Discharge Stream 2 0.4157 0.4995

NA 13 0.0046 0.0000 Optional Data Element 1 0.0000 NV Quantity Derived from Relevant Section 5 and 6 Data Elements 8 0.1458 0.0000

Receiving Facility/Site Identification Information 16 0.0077 0.0044 Release Quantity Estimated Using Emissions Factors 1 1.8795 NV

Release Quantity Estimate d Using Facility Records 6 1.8100 0.4408 Release Quantity Estimated Using Monitored Values 5 1.8810 0.2740 Release Quantity Estimated Using Physical and Chemical Properties of Chemical and Process Operating Conditions 1 3.2636 NV

SRR with No Relevant Section 5 and 6 Data Elements Current Year 3 0.8564 0.0000

Value Reported in Prior Year 10 0.0093 0.0000
NV indicates a value could not be calculated becaus e there is only one data element in the category or because total raw time is zero.Appendix C

4/28/11 C-15 Table C-4: Example Evaluation of Options for Scaling, by Category Option 1: Raw Estimates/No Incidence Weighting (Sum of data elements= 21.43 hours) Option 2: Incidence Weighting Included (Sum of data elements= 7.06 hours) Option 3: Scaled to Equal Nominal Form R for

Raw or Incidence Weighted (Sum = 35.7 hours) Option 4: Scaled to Equal Nominal Form R

Proportion of Calculations and Form Completion (Sum = 20.4 hours)
Rank (1-3) Comments Rank (1-3) Comments Rank (1-3) Comments Rank (1-3) Comments

Internal Consistency 2 More consistent with old method (compared to incidence weighted estimates.) 3 1 More consistent with the new method moving forward. NA Equally consistent as Option3, but

more consistent with total form unit burden

Parsimony 1 Easiest to generate using existing engineering burden estimates. 3 Requires information on how often data elements are filled out in a given year. Will have year to year variation. 2 Simply scaling from base. NA Simply scaling from base.

Intuitive Calculations 2 Based on real world experience with form. 1 Reflects the reality that not all facilities fill out all data elements. 3 Modeled estimate. NA requires explanation, given expectation that elements should add to total Form burden

Temporal Consistency 2 3 Requires information on how often data elements are filled out in a given year. Will have year to year variation. 1 More consistent with the new method moving forward. NA More consistent with the new method moving forward.

ICR Renewal Implications 3 Would be adding raw engineering estimate to back calculated nominal. Different bases. 2 1 Consistent with reporting burden for entire form (nominal form burden.) NA Consistent with reporting burden for appropriate portion of entire form (nominal form burden.)

EA Implications 1 Need to show nonincidence weighted burden in EA. 3 2 Can scale both raw
and incidence weighted. NA Can scale both
raw and incidence weighted.

Overall Rank 1.83 2.5 1.66 NAAppendix C

4/28/11 C-16Appendix D

4/28/11

D-1 First-Time Filer Estimation

This appendix presents the First-Time File r Estimation method of the Ratio-Based Burden Methodology (RBBM). As explained in Appendix A, first-time filer burden accounts for the elevated level of effort that reporters incur dur ing a start-up year. The existing method estimates
first-time filer burden in two instances. For ICR re newals, first-time filer burden is estimated as part of total Program burden to account for new en trants to the reporting community in any given reporting year. In RBBM terms, this estimate has a small effect on the Steady State Total Burden Calculation. Second, first-time filer burden is used in economic analyses (EAs) supporting rulemakings to evaluate the star t-up effect of a policy or regula tory change to the TRI reporting requirements, for example, when a new sector is added to the reporting community. As noted in Appendix A, however, in the Ratio-Based Burden Methodology (RBBM), fi rst-time filer burden now applies to calculating EA st art-up burden only, as it was show n to be negligible in the overall Steady State Total Burden Calculation. First-Time Filer Estimation, as presented in Appendix A, is envisioned as working in conj unction with estimates of steady state burden as
follows:

First-Time Filer Burden = FTF f * Relevant Steady State Total Burden

Model Development for ICR Renewal Burden

As stated in Appendix B, neglec ting the impact of first-time filing in the steady state estimate is justified mathematically because treating the relevant 3% of TRI chemical reports as steady state
filers instead of first-time filers decreases the Steady State Total Burden estimate by .04%, based on 2008 ICR Renewal conditions. Therefore, with respect to ICR renewal burden estimates and the Steady State Burden Calculation, EPA has c oncluded that incorpor ating first-time filer burden has a negligible infl uence (see Appendix B).

Model Development for Economic Analysis Burden

In the context of EA work, EPA must estimate the incremental steady state and first-time impacts that a policy or regulatory change would ha ve on TRI reporting. Depending on the proposed change, it may have significant first-time imp acts when new reporters enter the TRI reporting universe or when existing reporte rs complying with a new aspect of TRI reporting are getting up to speed with the new policies or requirements. Therefore, when estimating the incremental impacts associated with a policy change or rulemaking, first-time filer burden must be estimated.
It should be noted that first-time f iler burden is a transient effect th at will decrease to steady state burden levels in the second year.

First-Time Filer Model

Under the existing methodology, first-time burden is estimated using the same method as that used for steady state burden, i.e., using the two co mplex matrices and a separate count for firsttime filers. As described in Appendix A, the Steady State Total Burden Calculation simplifies these calculations using ratio models and unit bu rdens from Abt Associates Engineering Studies. Using the same development process, EPA provide s internal consistency between estimates for first-time and steady state reporting, as de fined by the First-Time Filer factor, FTF f ):Appendix D

4/28/11

D-2 Ratio of First-Time Burden to Steady State Burden [=] _ First-Time Hours__ Steady State Hours

Computed using the factor matrices for Form R presented in Appendix A: 1

FTF f = ( [first year factors from F ′′ i,j

] / ( [subsequent year factors from F ′′ i,j ] ﴿ 

## ∑∑

== 3

1 4

1 ji 

## ∑∑

== 3

1 4

1 ji

The FTF f is developed using the ratio of the burden associated with first-time Form R reporting
activities to the burden associated with stea dy state Form R reporting activities. See Appendix A’s Eqn A-9 and Table A-4 for the model’s specific calculation.

Findings

The recommended value for the First-Time Filer Factor, FTF f , is 2.1 hr/hr, based on Form R
factors. EPA estimated the FTF f separately for Form R and Form A using several model assumptions and distribution conditions similar to the design for A/R tests described in Appendix B. Following Decision Rule #2 on page 10 of the main report, the Form R basis is used to apply for all instances in which first-time filing is estimated, given that the additional complexity of incorporating the Form A basis is unmerited. Table D-1 supports this decision as the difference in estimates based on Form R (FTF R ) versus those based on Form A (FTF A ) do not differ substantially.

1 Where i denotes the row and j denotes the column from the Matrix F ′′ in Appendix A.Appendix D

4/28/11

D-3 Table D-1: Estimation of First-Time Filer Factor for Form R and Form A

Test Run Description (1) REFERENCE

no simplifications (2) Same as (1), but

without Firsttime filer adjustment (3) Same as (1), but without incidence rate adjustments (4) Same as (1), but without distribution specificity* (5) RECOMMENDED -realistic estimates with incidence rate adjustments** (6) Robustness Test - alternate distribution***

Model Form R unit burden (hrs/Form R)

12.66 12.52 27.24 12.67 12.52 12.53 Model Form A unit burden (hrs/single -chemical Form A)

7.76 7.67 13.16 7.95 7.71 7.67

FTF R 2.05 2.05 1.67 2.08 2.05 2.06

FTF R % difference from Reference 0.00 -18.66 1.31 0.00 0.49

FTF A 2.66 2.51 2.14 3.28 2.66* 2.53

A/R 0.613 0.612 0.483 0.628 0.615 0.612

A/R % difference from Reference -0.12 -21.22 2.41 0.39 0.50

* Does not account for potential double counting of facility le vel burden among facilities reporting both Form Rs and Form As.

** Current A, R, A+R distributions, no first-ti me filer adjustments. Based on the same condi tions as for column 5 in Tables B-3 an d B-4. See Eqn
A-12 for FTF derivation.

*** Phase 2 Burden Reduction Rule.
Note: FTF A is only 23% higher than FTF R . According to Decision Rule # 2 in the main repor t Form R basis is used when complexity of Form A basis is unmerited.

Method Summary

Computation For first-time incremental burden: As noted above, first-time file r burden is only addressed in
the context of calculatin g EA start-up burden. Specifically, in any EA supporting a regulatory or policy change, there will be costs incurred only in the first year of the change, in addition to the sustained steady state costs associated with the change. Take, for example, the recent TRI rulemaking adding 16 chemicals to the list of reportable chemicals. To estimate first-time filer burden, the analyst will combine information on th e unit burden associated with the filing of forms for the new chemicals, the number of new chemicals and the FTF f . Note that in this rulemaking, reporters are not expect ed to file Form As for any of the new chemicals. The analyst would estimate first-time filer burden for the additional 186 Form Rs that are expected to be filed
as follows:

Eqn D-2: Total first-time filer burden associated with the rule adding 16 chemicals to TRI =

= FTF f *(Form R Relevant Steady State Burden for New Chemicals + Form A Relevant Steady State Burden for New Chemicals)Appendix D

4/28/11

D-4 = FTF f * (Nominal Form R unit burden* # New Form R chemicals + [(A/R) * Nominal Form R unit burden] * # New Form A chemicals) = 2.1*(35.7*186 + [.615*35.7]* 0)

= 13,944 hours

This first-time filer burden estimate will be repo rted in the EA along with steady state burden as
an estimate of the total burden associated w ith TRI reporting created by the proposed regulatory or policy change.

Assumptions

Use of the FTF model for estimating first-time filer bur den relies on the following assumptions:

• First-time and steady state burden as curre ntly identified in the Abt Associates Engineering Studies estimates for Form R is a reasonable reflection of the amount of time it takes to complete reporting activities for the first-time relative to the steady state for TRI reporting.

• The relationship between first-time and stea dy state burden does not vary between the steady state and policy/regulator y change scenarios or acro ss policy/regulatory change
scenarios.

• Relationships between reporting activities in th e Abt Associates Engineering Studies that are drawn from a subpopulation ar e reasonably reflectiv e of the true relationships in the total reporting population, as measured by the best professional judgment of Abt Associates’ engineers.

Maintenance and Update Recommendations

The FTF model/method requires no maintenance. However, EPA notes that the FTF formulation is dependent on the conversion factors used to rescale facility-level unit burdens to (per chemical) form level. As shown in Appendix B, even in the face of dramatic shifts in distribution, Equivalent Form R/A Chemicals per Facility are reasonably r obust, within about 10%. However, in the event that the program adds industry sector(s), the (per chemical) form/facility distribution could shif t due to the addition of large ch emical counts of substantially different distributions of (per chemical) form t ype and/or number of ch emicals per facility.

As a practical matter, given the requirements for ICR renewal reporting, periodic recalculations
of the Equivalent Form R/A Chemicals per Facility will be regularly available and can be
checked to be sure that this basis for the FTF f model (and others— A/R and WAWR ) is still valid.
EPA recommends this routine check.Appendix E

4/28/11
E-1 Cost Conversion

This appendix presents the Cost Conversi on method of Ratio-Based Burden Methodology (RBBM), including the weight ed average wage rate ( WAWR ). WAWR provides and alternative to separately computing wages for the three labor categories, Managerial, Technical and Clerical, with each ICR renewal or rulemaking and in stead specifies one up-front Cost Conversion incorporating all three la bor categories. As presented in Appe ndix A, this method is envisioned as working primarily in conjunction with es timates of steady state burden as follows:

Eqn. E-1: Steady State Total Cost = (S teady State Total Burden)*WAWR

It should be noted that this method is the only method in the Ratio-Based Burden Methodology (RBBM) that calibrates with upda tes to actual economic conditions , given the availability of quarterly current wage data from the Bureau of Labor Statistics (BLS). It should also be noted
that this method uses information from the Abt A ssociates Engineering Studi es to set the relative proportions of each labor category reflecting cu rrent technology conditions. As with other similarly developed models ( A/R, FTE ), updates may be required in the event that large changes in the distributions of form counts/types acr oss facilities affect the conversion factors ( Equivalent Form R/A Chemicals per Facility ). Unlike these other models, which have no impact on
transitional baseline continui ty, the WAWR under RBBM induces a slight one-time decrease (5%) to the baseline for the to tal cost estimate, while not a ffecting the relevant burden hour
estimate.

Weighted Average Wage Rate (WAWR) Models

The WAWR ratio model determines costs associat ed with burden hour estimates, as defined by:

WAWR (Weighted Average Wage Rate): Average loaded cost for a mix of managerial, technical and clerical labor per hour of TRI reporter burden [=] Current $/Hour

This model uses one wage rate that reflects an average estimate for all labor categories as opposed to three different wage rates. The weighted hourly wage ra te is developed by combining the relative contribution of each labo r category to total burden with current hourly

wages.

Procedure

As an example, to compute the steady state costs for Form R : 1

1 Form R burden only is used for initial illustrations, with verification of assumptions that the same bases apply to Form A and steady state total costs. See key analytical d ecisions in this Appendix. For additional details on Form R/A burden, and Steady State Total Burden calculations, see Appendix B.Appendix E

4/28/11
E-2 Eqn. E-2: Form R Cost = Form R Burden Hours* WAWR

The WAWR for year YR is calculated as follows:

Eqn. E-3: WAWR YR = (p
m * $/hr m,YR ) + (p t * $/hr t,YR ) + (p
c * $/hr c,YR )

Where

WAWR YR = WAWR in current dollars for year YR

p m , p t , p c = proportions of the reporting burden for each labor category, managerial, technical and clerical.

$/hr m,YR , $/hr t,YR, $/hr c,YR = The wage rates for manage rial, technical and clerical labor for year YR, in current $/hour.

For Form R, as in Form A, and the Total Cost calculation, the proportions are consta nt, providing fixed weights to the weighted average calculation:

Eqn. E-4: WAWR YR = (.03 * $/hr m,YR ) + (.89 * $/hr t,YR ) + (.08 * $/hr c,YR )

In this method, the burden is calculat ed in total and then multiplied by WAWR . Note that each labor category wage rate mu st be obtained for the quart er and year of interest.

Method Development

The key analytical decisions fo r developing this method include:

1. Specifying the set of fixed weights that re present the proportion of the reporting burden for each labor category: two options were c onsidered: 1) weights developed using the unit burden estimates from the existing met hodology, or 1) weights developed using the Abt Associates Engineering Studies. The fi xed weights for Managerial, Technical and Clerical labor categories are 0.03, 0.89 and 0.08, based on the Abt Associates Engineering Studies, and 0.25, 0.68 and 0.07, based on the existing methodology, respectively. Both sets of weights were de rived using Form R burden as a basis (see Decision Rule #2 on page 10 of the main report).

2. Determining if one WAWR can be used to convert From R, Form A, and total burdens to
costs. This determination involved ve rifying the assumption that a Form A WAWR is not substantially different from a Form R WAWR in order to be able to use a standardized
form WAWR for calculating required for Form R. It also involved verifying that the same
WAWR could be applied to total burden to obtain total cost.

3. Recommending an update frequency.

Analyses to support these decisions are presented in order. The fi rst set of analytical decisions specifies the basis for the proposed fixed wei ghts for proportions of each labor category. Should EPA use existing methodology’s proportions or thos e implied by the Abt Associates engineering estimates? Although RBBM has fully justified using the Abt Asso ciates Engineering Study unitAppendix E

4/28/11
E-3 burdens in ratio models (see Appendix B), in th is particular method, the practice will induce a slight (5%) one-time baselin e shift of $2.65/hour, from $52.27/hour (using the existing methodology) to $49.62/hour using RBBM. For many of the same reasons that the revised methodology uses the Abt Associates Engineering Studies unit burdens for A/R and FTF, they are preferred for WAWR as well. Advantages include internal consistency and the fact that these estimates were made in 2004, reflecting tec hnology advances since program inception. EPA concludes that the slight one-time baseline shift for cost is acceptable, given the relative merits of using the same building bl ocks used throughout RBBM.

Consequently, the WAWRs used for RBBM have a modified form ulation from that of the existing method because the RBBM fixed weights are derive d using Abt Engineering Studies.. Recall that the OMB-approved implied weights are 0.25, 0.6 8, and 0.07 and that RBBM weights are 0.03, 0.89, and 0.08 (see Appendix A, Table A-4 for a breakdown by activity). The resultant RBBM weights as they apply to Form R repor ting are presented in Table E-1 below.

Table E-1 Subsequent Year Reporting Burden – Per Form R Chemical Activity Management Technical Clerical
Rule Familiarization 0 0 0 Compliance Determination 0.069* 0.275* 0* Calculations and Form Completion 0.320 6.890 0.0 Recordkeeping 0.000 4.000 1
Total Form level burden 0.389 11.165 1 Weights 0.03 0.89 0.08 *Facility-level factors converted to form (per chemical)-level factors via Equivalent Form R Chemicals per Facility (3.87) See Eqn A-10 and Tables A-3 and A-4. Source: Table A-3, Abt Associates Engineering Studies (see Appendix B and references in Appendix G)

The second set of analytical decision s verifies that the derived Form R WAWR weights may be used for Form R burden, Form A burden, and total burden.

An analysis similar to the one presented in Table E-1 was conducted based on Form A, as derived from Form R, for reporting activities re sulting in management, technical, and clerical weights of 0.03, 0.84 and 0.13, compared to Form R proportions of 0.03, 0.89 and 0.08, respectively. EPA concluded that Form A weight s are similar enough to Form R weights to allow use of the Form R weights when computing Form A costs.

To assess WAWR’s applicability to total burden, EPA then analyzed the effect of using the Form
R WAWR to calculate total TRI re porting costs. EPA found that using the Form R based WAWR yields total cost estimates that are less than 0.2% higher than a to tal cost calculation that uses separate Form R and Form A WAWRs. Additio nally, differences incurred by incorporating nonform burden are negligible. 2

2 This finding is based on an analysis of the per form co mparable proportion of burden attributable to management, technical, and clerical under the following two scenarios: Total reporting burden (including non-form activities such as supplier notification and petitions) and form-related re porting burden only. In scenario one: total reporting burden, the weights are as follows: 24 management, .66 technical, and .09 clerical. In scenario two: form-relatedAppendix E

4/28/11
E-4 Given the findings from these two anal yses, EPA concludes that the Form R WAWR is equally applicable to Form R, Form A, and Steady St ate Total Cost estimates, using the weights for Form R for each labor rate category. To com pute WAWR, the cost of each activity by labor category is developed by combining the burde n in hours with hourly wage rates for the appropriate labor category. An example ca lculation is presented in Table E-2.

Table E-2 Derivation of Weighted Average Wage Rate ($/hour), June 2010 Managerial Technical Clerical
Total Loaded Rate $62.29 $51.37 $25.24 Weights 0.03 (3%) 0.89 (89%) 0.08 (8%) Average Wage (weighted) $49.62*

Source: http://www.b ls.gov/news.release/ecec.t11.htm Note: For comparison, the Form A weighted average wage is $48.30. * Individual numbers may not result in the total due to rounding.

The weighted average loaded hourly wage rate across the three labor categories was $49.62 in June 2010. This weighted average rate is applied to the total number of hours needed to complete Form R and Form A (Nominal Form R and Fo rm A unit burden where Form A unit burden is derived from Form R unit burden using the A/R m odel) to estimate the unit cost per form. The cost per form is then applied to the total TRI to tal burden to estimate the total TRI reporting cost.

The third analytical decision involves recommending the frequency of updating the method. Since the information on wage rates is publishe d quarterly by the Bureau of Labor Statistics (BLS), updates to the WAWR should be made accordingly.

Findings

The RBBM-consistent basis using Abt Associates engineering estimates are preferred for weighting labor categories within WAWR , for the same reason they are the basis for A/R and
FTF. They provide benefits of internal consistency and reflect more current conditions with technology advances.

Method Summary

Computation

To update the WAWR for an ICR renewal or a major rulemaking, the following steps are
involved:

reporting burden only, the weights are as follows: 25 management, .68 technical, and .07 clerical. Both calculations
use 2008 ICR renewal estimates.Appendix E

4/28/11
E-5 1. Obtain employer cost current wage rates for total and salary compensation 3 from BLS for three labor categories: Manageri al, Technical and Clerical labor. 4 Adjust each upward to account for non-wage compen sation: 17% overhead, 43.4% benefits.
2. Compute the weighted average wage rate, using the fixed weights reflecting burden hours (0.03, 0.89 and 0.08) 5 to calculate the current WAWR 2010 (e.g., $49.62/hour for June 2010).

The following equation presents the estim ation of total burden when updating the WAWR for an ICR renewal or a major rulemaking using curren t wages from BLS (see Eqn B-2 for reference regarding Steady State Total Burden ).

Eqn. E-5:

Steady State Total Cost = Ste ady State Total Burden * WAWR 2010

Steady State Total Cost = (Nominal Form R Unit Burden*# Form R Chemicals + [Nominal Form R Unit Burden*(A/R) *# Form A Chemicals] + Non-Form Burden)*WAWR 2010

Total Cost = (35.7*# Form R Chemicals + [35.7*.615*# Form A Chemicals] + 825,517)*
WAWR 2010

Where WAWR 2010 is calculated using Eqn. E-4 and the latest 2010 wage rates from BLS:

WAWR 2010 = (.03 * $/hr m,2010 ) + (.89 * $/hr t,2010 ) + (.08 * $/hr c,2010 )

Assumption

Wage rate proportions in WAWR of .03 for mana gerial labor, .89 for tech nical labor, and .08 for
clerical labor are reasonable estimates of actua l conditions, on average, for the overall reporting community.

Maintenance and Update Recommendations

Update WAWR in every burden estimate for which new information from BLS is available (quarterly updates). The fixed weights of WAWR require no maintenance. However, EPA notes that the values of these weights are dependent on the conversion fa ctors used to re scale facilitylevel unit burdens to (per chemical) form level. As shown in Appendix B, even in the face of dramatic shifts in distribution, Equivalent Form R/A Chemicals per Facility , within about 10%. However, in the event that the program adds industry sector(s), the (per chemical) form/facility

3 Note that benefits may be calculated as the difference between total and salary compensation on a quarterly basis (e.g., WAWR benefits are 43.4% of compensation for June 2010).

4 Corresponding BLS titles: Managerial = Management, business, and financial; Technical = Professional and related; Clerical = Office and administrative support.

5 See calculation components and results in Table E-1.Appendix E

4/28/11
E-6 distribution could shift due to th e addition of large chemical c ounts of substantially different distributions of (per chemical ) form type and/or number of chemicals per facility.

As a practical matter, given the requirements for ICR renewal reporting, periodic recalculations
of the Equivalent Form R/A Chemicals per Facility will be regularly available and can be
checked to be sure that this ba sis for the fixed weights of the WAWR model (and others— A/R
and FTF f ) are still valid. EPA recommends this routine check.Appendix F

Program Staff Tool

4/28/11 F-1Appendix F4/28/11F-2DIRECTIONS:The pink fields are userinput cells. Your final estimates will be displayed inthe dark green cells on this page. To see calculations and variables used in theinterface, including models and accounting parameters, refer to the “Reference Information” tab. If you need to change or add form elements, refer toinstructions and data under the “Form Element Estimates” tab.DEFINITIONS:Steady State Burden (SS) -estimate of ongoing Program burden, including permanent impacts from rulemakings, but absent first-time filer burdenFirst Time Filer Burden (FTF) -estimate to account for start-up burden incurred during the first year of a policy changeWeighted Average Wage Rate (WAWR) -consolidated wage rate that incorporates relevant proportions of managerial, technical, and clerical laborForm R and Form A unit burdens- comprehensive unit burdens that incorporate all aspects of per chemical form-related burden, including: rule familiarization,compliance determination, calculations andform completion, and recordkeeping and submissionSection 1: UNIT BURDEN1. If you are adding form elements for this analysis, estimatethe burden of these new elements using the procedure in the "Form Element Estimates" tab. Thenenter the sum of these estimates into the "Additional Burden perForm" user input cell. Note that for added form elements thatonly affect a subset of forms, wedo not discount based on incidence rate.2. If you do not have additional form elements for this analysis, make sure the number in the "Additional Burden per Form" cell is 0.Note: The newly calculated Form R Unit Burden will be used to calculate both total Form R and total Form A burden.Section 2: CHEMICAL COUNTSComplete this section according to whether you are estimating the full model (ICR) or incremental model (EA).In the case of an ICR, enter the number ofchemicals reported by Form A and Form R, or in the case of an EA, enter the change in the number of chemicalsreported by Form A and Form R in the "Incremental Change" input cells in Section 2.Section 3: STEADY STATE BURDEN ESTIMATESThis section displays the final estimates in the dark green cells. For an ICR use the "Final Totals" and for an EA use the "Final Incremental Change."Section 4: FIRST YEAR ADDITIONAL BURDEN DUE TO FIRST-TIME FILERS (FTF)For EAs that initiate policy change that in turn causes a startup burden for first-time filers (FTF), enter the number of additional Form R and Form A chemicalsin this section to determine this burden due to FTFs.Appendix F4/28/11F-3KeyModels (see reference tab)User inputsCalculated numbersFinal estimatesIntermediate CalculationsHelpful hintsUSER INPUTS AND MODELSESTIMATESSection 1:UNIT BURDENStarting PointAdditionalBurden perFormNew Form R Burden TotalForm R unit burden (hours per form)35.7+0=35.7Form A unit burden (hours per single-chemicalform)22.0+0=22.0Form A unit burden = (A/R) * Form R unitburdenSection 2: CHEMICAL COUNTSNumber of ChemicalsStarting PointIncrementalChangeChemicals TotalNumber chemicals reported on Form R81,382+0 =81,382Number of chemicals reported on Form A9,284+0 =9,284Note: Form A is units of chemicals rather thanresponsesAppendix F4/28/11F-4Section 3: STEADY STATE BURDEN ESTIMATESHours of Form BurdenStarting PointIncrementalChangeNew Burden HoursTotalTotal Form R Burden (hrs)2,905,337+0=2,905,337Total Form A Burden (hrs)203,835+0=203,835Total Non-form Burden (hrs)825,517825,517Note: Incremental change numbers insection 3 include new forms and anychanges in form unit burden.Totals and Cost ConversionFinalIncrementalChangeFinal TotalsWAWR (current $/hr)49.62Total Burden (hrs)03,934,689Total Cost (dollars)(Total Burden in hrs) * (June 2010 $WAWR) =$0$195,231,097Section 4: FIRST YEAR ADDITIONAL BURDEN DUE TO FIRSTTIME FILERS (FTF)IncrementalChange# of chemicals reported on Form R forFTFs0# of chemicals reported on Form A forFTFs0FTF Form R Burden (hrs)Form R Unit Burden * FTF # Form R Chemicals *FTF Factor =0FTF Form A Burden (hrs)Form A Unit Burden * FTF # Form A Chemicals *FTF Factor =0FTF Total Burden (hrs)0FTF Total Cost (dollars)(FTF Burden in hrs) * (June 2010 $ WAWR)=$0Appendix F4/28/11F-5Reference Equations and Model ValuesEquations used in Estimator:Total Burden = Form R Burden + Form A Burden + NonForm BurdenWhere:Form R Burden = (# Form R chemicals) * (Nominal Form R Unit Burden)Form A Burden = (# Form A chemicals) * (A/R) * (Nominal Form R Unit Burden)NonForm Burden = (Petitions) + (Supplier Notification) + (Non-Reporters’ Burden)Total Cost = Total Burden * (WAWR)Where:WAWR is the weighted average wage rate in current dollars/hrFirst Time Filer Burden = (FTFf* relevant steady state burden)Where:FTFf= the first time filer factorrelevant steady state burden = [(# new Form R chemicals *Nominal Form R unit burden)] + [(# new Form A chemicals * NominalForm R unitburden * (A/R))]Appendix F4/28/11F-6Table 1. Values used in EstimatorUpdate FrequencyLast UpdatedNameValueUnitsDescriptionMODEL PARAMETERSAccording to TolerancesMay 2010A/R Model=0.615hrs/hrsA ratio of burdens for single-chemical Form Ato Form R.None by ScheduleMay 2010Petitions=925hrsNon-form burden, assumes 5 petitions per year185 hours per petition.None by ScheduleMay 2010SupplierNotification=89,616hrsNon-form burden, can apply to any facility butbasis is 24 hours per reporting facility as of2008 ICR.None by ScheduleMay 2010Non-ReporterComplianceDetermination=734,976hrsNon-Form burden, assumes 4 hourscompliance determination to all in NAICS withover 10 employees as of 2008 ICR.According to TolerancesMay 2010First Time FilerFactor (FTFf)=2.1hrs/hrsA ratio of the first-time filer burden to steadystate burden.WAWRQuarterlyJune 2010WeightedAverage WageRate (WAWR)=$49.62$/hrDollars per hour ratio that incorporatesmanagerial, technical, and clerical labor rates.Note: to update the WAWR, refer to theguidance below.REFERENCE INFORMATIONAs Form Changes areImplemented in Rulemakingsand ICRs (note: verifyRulemaking estimates at ICR)Feb 2011Nominal Form RUnit Burden=35.7hrsCurrent Base number for Form R burden, giventhe form elements approved at most recentaction (ICR or Rulemaking).At Every ICRFeb 2011Form RChemicals perFacility=3.68chems/facilityBased on number of chemicals per facility.At Every ICRFeb 2011Form AChemicals perForm=2.31chems/Form ABased on number of chemicals per form, whichis assumed to be number of chemicals perfacility.Guidance to Update the WAWR:The WAWR is a dollar per hour ratio that is based on the managerial, technical, and clerical labor rates from the EmployerCost for Employee Compensation Economic update publishedquarterlyby the BLS.To update the WAWR with the latest data from BLS, enter the most recently published values for Total Compensation andWages and Salaries in the table titled Employer Cost for Employee Compensation under the appropriate date. TheBenefits column will automatically calculate the Benefit amount for each labortype. The table titled WAWR will thengenerate the new WAWR and present it under the appropriate date.To use the new WAWR in the Estimator tab, update the referenceformulas for $/hr and date in cells F30 and C30 to link tothe new WAWR and date. (For example, when updating toa September 2010 WAWR, cell F30 would be linked to F60and cell C30 would be linked to F56.)Appendix F4/28/11F-7Table 2. WAWR CalculationWAWRDateDecember 2009March 2010June 2010September 2010Managerial$61.42$62.32$62.29Technical$50.51$51.17$51.37Clerical$24.99$25.22$25.24WAWR$48.81$49.44$49.62EMPLOYER COST FOR EMPLOYEE COMPENSATIONDateDecember 2009March 2010June 2010CompensationComponentTotalCompensationWagesandSalariesBenefitsTotalCompensationWagesandSalariesBenefitsTotalCompensationWagesandSalariesBenefitsManagerial$54.91$38.30$16.61$55.73$38.75$16.98$55.69$38.84$16.85Technical$45.04$32.16$12.88$45.63$32.59$13.04$45.81$32.73$13.08Clerical$22.33$15.65$6.68$22.55$15.73$6.82$22.56$15.75$6.81Note: Corresponding BLS titles: Managerial = Management, business,and financial; Technical = Professional and related; Clerical = Office and administrativesupport. Total Compensation and Wages and Salaries data is taken directly from ECEC, while Benefits data is derived from the ECEC data.Source: Employer Cost for Employee Compensation, Table 9.BLS. <http://www.bls.gov/news.release/ecec.t11.htm>September 2010TotalCompensationWagesandSalariesBenefitsOVERHEAD17%LABOR BURDEN WEIGHTSManagerial0.03Technical0.89Clerical0.08Appendix F4/28/11F-8FORM REPAFORM RTRI Facility ID NumberUnited StatesSection 313 of the Emergency Planning and Community Right-to-Know Act of 1986, also Knownas Title III of the Superfund Amendments andReauthorization ActEnvironmentalProtection AgencyToxic Chemical, Category or Generic NameWHERE TO SEND COMPLETED FORMS:1. TRI Data Processing Center2. APPROPRIATE STATE OFFICEP. O. Box 1513(See instruction in Appendix E)Lanham, MD 20703-151This section only applies if you arerevising or withdrawing a previouslysubmitted form, otherwise leave bank.Revision (enter up to two codes(s))Withdrawal (enter up to two code(s))IMPORTANT: See instructions to determine when “Not Applicable (NA)” boxes should be checked.PART 1. FACILITY IDENTIFICATION INFORMATIONNOTE:For further details of this form image see Appendix A, Figure A-2.Appendix G

4/28/11 G-1 Abt Associates Engineering Studies

1) TRI Reporting Burden Estimates, Memo from Hilary Eustace, David Cooper, Susan Day, Abt Associates to Paul Borst, EPA, July 16, 2004 2) Modified TRI Reporting Burden Estimates for Rule Familiarization, Compliance Determination, and Form Completion from Susan Day, Abt Associates to Laura Nielsen, EPA, December 2, 2010

NOTICE Abt Associates Engineering Estimates in Ratio-Based Burden Methodology (RBBM) As explained in Methodology History , the Abt Associates engineer ing estimates were proposed in 2004, but neither finalized nor formally adopted into TRI burden estimation practice. In this methodology revision and in the formulation of RBBM, EPA uses the estimates for a different purpose than originally intended. Instead of using Abt Associates engineering estimates as a basis for absolute values (i.e., the Nominal Form R unit burden ), RBBM uses the estimates to construct ratio models of key relationships (e.g., A/R ), thereby only relying on the relative values
of the estimates and not absolute values.Appendix G

4/28/11 G-2 M E M O R A N D U M

TO: Paul Borst, U.S. EPA

FROM: Hilary Eustace, David Cooper, Susan Day

DATE: July 16, 2004

RE: TRI Reporting Burden Estimates

1. I NTRODUCTION

EPA currently relies on previously develope d OMB approved TRI reporting burden estimates that reflect the total time require d by facilities to complete activit ies such as rule familiarization, compliance determination, form completion, reco rd keeping/mailing, and supplier notification. While form completion reporting burden estimates ha ve been prepared for completion of the full Form R, the total time is not broken down by the i ndividual data elements that make up the form. Data element specific burden estimates would allow for informed assessments and comparisons of proposed TRI burden reduction methods as well as any future proposed Form R modifications. In this memo, burden estimates ar e derived for every data element on the Form R based on the activities TRI reporters undertake to co mplete each data element as well as the time estimates for technical, manage rial, and clerical staff at a typical facility to conduct these activities. During the last TRI ICR renewal, EP A referenced industry data suggesting that TRI reporting burden is lower than previously estimated. While the newly negotiated burden
estimates were revised downward for non-PBT chem icals, they were not lowered by as much as EPA proposed. Furthermore, PBT chemical repor ting burden was not lowered at all. The OMB approved reporting estimates are presented in Table 1. The data element specific burden estimates presented in this memo are estimated firs t to reflect the time it actually takes the typical facility to fill out each data element. This burde n is referred to as the “r ealistic burden.” Second, the data element specific realistic burden estimates are scaled up so that summing them yields the OMB approved burden estimate of form comple tion. Several sets of burden estimates were prepared, including times for both electronic an d paper form preparation for every category
outlined below:Appendix G

4/28/11 G-3 • Realistic Burden Estimates for Every Form R Data Element: Realistic burden estimates were prepared for every data elem ent on the Form R based on best engineering judgment for both management and technical time. Under the re alistic scenario, no clerical time is spent on form completion. Separate realistic burden estimates were prepared for non-PBT and PBT chemicals.

• Realistic Burden Estimates fo r Total Form R Completion: The realistic data element burden estimates were weighted by the incidence rate, which is the total percentage of forms containing information other than “NA” fo r the data element, in order to reflect the fact that not all data elements will be completed on all forms. The incidence rate was calculated using the frozen RY 2002 TRI data. This analysis was conducted separately
for non-PBT and PBT chemicals.

• Scaled Burden Estimates for Every Form R Data Element for non-PBT Chemicals : The realistic burden estimates generated fo r every data element for non-PBT chemicals were scaled up to meet the current OMB- approved time estimate for calculations and form completion for a Form R for a non-PBT chemical.

• Scaled Burden Estimates for Every Form R Data Element for PBT Chemicals : The realistic burden estimates generated for every data element for PBT chemicals were scaled up to meet the current OMB-approved time estimate for calculations and form completion for a Form R for a PBT chemical. Since the current OMB-approved time estimate for calculations and form completion for a PBT chemical assumes that all data elements are completed, these scaled data element time estimates were not multiplied by
the incidence rate for PBT chemicals.Appendix G

4/28/11 G-4 TABLE 1
OMB-APPROVED TIME ES TIMATES FOR FORM R
CALCULATIONS/FORM COMPLETION

Activity Management Technical Clerical Total Hours

First year
Calculations and report completion -
non-PBT chemicals 11.3 24.1 1.6 37.0

Calculations and report completion -
PBT chemicals 20.9 45.2 2.9 69.0

Subsequent years

Calculations and report completion -
non-PBT chemicals 7.7 16.4 1.1 25.2

Calculations and report completion -
PBT chemicals 14.3 30.8 2.0 47.1

Source: Rice, Cody Memo: Terms of Clear ance for TRI ICR Renewal. Jan 20, 2004. An OMB-approved estimate for first time non-PBT f ilers does not exist; however, the RIA for the original Section 313 rulemaking estimated the time required to complete a report in the first year to be 147% of the time required in subseque nt years. This factor was applied to the OMB approved subsequent year non-PBT report completi on times to calculate the first year non-PBT completion times. (U.S. EPA Regulatory Imp act Analysis in Support of Final Rulemaking
under Section 313 of Title III of the Superfund Amendments a nd Reauthorization Act of 1986 (1988).

Realistic estimates, based on best engineering judgment, are pres ented in Section 2; Section 3 presents the realistic estimate scaled to th e OMB approved Form R completion times. Within each section, PBT and non-PBT reporting burden is examined separately due to differences in methodology. The PBT and non-PBT chemical sub-s ections are further di vided into electronic and paper methodology and resu lts sub-sections.

2. R EALISTIC R EPORTING B URDEN E STIMATES

2.1.A. Methodology for Electronic Submission

The basis for all of the burden estimates presen ted in this memo start with a realistic burden estimate for a typical facility to prepare a Form R in the first year and all subsequent reporting years. To generate this realistic burden estima te, the method described below was utilized. First, the steps required for completion of each data element (field) on the Form R were identified. Best engineering judgment was used to estimate the time to complete each step based on aAppendix G

4/28/11 G-5 reasonable and likely scenario for conducting th e needed steps a typical facility. Best engineering judgment was provided by a team of th ree staff with nearly 40 years of combined experience working with facilities on environmen tal issues. These staff have worked with hundreds of facilities on TRI reporting and othe r environmental requirements by conducting inspections and providing technical assistance to hundreds of facili ties, serving as TRI trainers, conducting technical review on hundreds of TRI data withdrawal requests, conducting hundreds of TRI data quality calls, working for two of the Massachusetts Toxics Use Reduction Act agencies, and working as environmental staff at large manufacturing facilities.) Next, the total time to complete each data element was estimated by summing together the labor hours required to complete the set of steps necessary for each data element.

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

For Form R data elements requiring a quantitative estimate of release or other waste management quantities, the steps a facility w ould take to fill in the data elements were derived based on the most common basis of estimate code reported for that field in the RY 2002 TRI data. The basis of estimate code analysis is presented in Table 3 (refer to Excel spreadsheet). For example, monitoring data was the most common basis of es timate code for off-site transfers to POTWs; therefore, the steps required to make engineer ing calculations based on monitoring data were
used as the basis for the time estimate for this data element. In actualit y, each facility would use
their best available data for co mpleting each field. As a final check, estimated times for data elements were compared with one another ba sed on expected relative degree of difficulty.

The total realistic form completion burden wa s calculated by combining the time required to complete each data element with the percent of times individual data elements are typically completed. As mentioned above, this adjustme nt was made by weighting the data element specific burden by the incidence rate for that el ement. For example, if a stack air release quantity (either “0" or an actual quantity) was reported on 50% of all non-PBT Form Rs, the time estimated to complete Part II, Section 5.2 of the Form R was multiplied by 50%. For data elements that are required, it was assumed that 1 00% of forms had the data element filled out. The final reporting burden is a realistic estimate of the total form completion time based on engineering judgment. A separate analys is was done for non-PBT and PBT chemicals.Appendix G

4/28/11 G-6 As mentioned above, these burden estimates are based on the TRI reporting experiences of a typical facility. It was, therefor e, necessary to make the follo wing assumptions about a typical facility:

• The facility is reasonably modern and well-organized.

• The facility has internet access with reasonable connection speed.

• Through rule familiarization, the technical sta ff are aware that written EPA TRI guidance is available through the website.

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

• Unless otherwise noted, there is no differen ce in completing a data element for non-PBT versus PBT chemicals. (Additional discus sion on PBTs versus non-PBTs is provided below).

• Technical staff retain copies of the previous year’s reports in a read ily available format. Therefore, static information available from the previous ye ar’s reports, such as RCRA I.D., is assumed to require only t yping time in subsequent years.

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

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

• Technical staff preparing the report will concur rently type this information into TRI-ME and will not require clerical assistance in entering information into TRI-ME.

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

Since more than 80% of Form Rs were filed electronically in RY 2002, it is assumed for the
realistic burden estimate that t echnical staff prepare the electroni c form; therefore, no clerical burden is estimated. Also, in the realistic burde n estimate, management review time is based on the maximum perceived level of management invol vement at reporting facilities and is lower than previous OMB approved management burden estimates. In the following sections, data elements are presented as they appear on the Fo rm R. Reporting burden estimates are presented after each step for first year/subsequent years in minutes. If a step will take less time or does notAppendix G

4/28/11 G-7 need to be repeated in subsequent years, this will be reflected in the allotted time (i.e., a lower time or “0" will be given for subsequent years).

As mentioned above, the calculations/form co mpletion burden for non-PBT chemicals was recently revised from 47.1 hours to 25.2 hours for non-PBT chemicals (Memo from Cody Rice to Amy Newman: Terms of Clearance for TRI ICR Renewal. Jan 20, 2004). Reporting burden
associated with PBT chemicals was not revise d due to trade associa tion comments suggesting that because range reporting and the de minimis exemption cannot be used for PBT chemicals, form completion takes longer for a PBT chemical than a non-PBT chemical. While there may be overall differences in TRI reporting burden betw een PBT and non-PBT forms, this difference is largely due to compliance determinati on activities, not form completion.

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

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

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

• The most commonly reported basis of estimat e codes were nearly identical for PBTs
versus non-PBTs.Appendix G

4/28/11 G-8 • The percent of data elements filled out by RY 2002 filers was nearly the same for PBT and non-PBT forms, with the difference being the percent was sligh tly lower for PBTs.

• For data elements where multiple occurren ces were reported (e.g., off-site transfer locations, number of “M” codes for off-s ite transfers, number of reported on-site treatment waste streams), the incidence rates were nearly identical for PBT and non-PBT
forms.

The derivation of the data element specific bur den estimates is presented below. Only one complete set of steps reflecting expected ac tivities for both PBT and non-PBT chemicals is provided for each data element (with a few mi nor exceptions) as there are no significant differences in form completion activities. Mi nor differences expect ed between non-PBT and
PBT chemicals are noted in the individual data element discussions where they occur.

Data Element Specific Reporting Burden

Form R, Part I. Facility Identification Information

Section 1: Reporting Year

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

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

Reporting Burden Associated with Part I, Section 1
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 0.25 0.25

Total 0.33 0.33

Section 2: Trade Secret Information

2.1 Are you claiming the toxic chemical identified on page 2 trade secret? Management burden includes proofread ing this section as part of an overall review of the Form R. (0.08 min/0.08 min)

Technical staff will have knowledge of this info rmation and will check yes or no in Part I, Section 2.1 of the Form R. (0.08 min/0.08 min)Appendix G

4/28/11 G-9 Reporting Burden Associated with Part I, Section 2.1
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 0.08 0.08

Total 0.16 0.16

2.2 Is this copy sanitized or unsanitized?

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

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

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

Reporting Burden Associated with Part I, Section 2.2
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 0.08 0.08

Total 0.16 0.16

Section 3: Certification

In RY 2002, more than 80% of Form R reports were filed via diskette or CDX submission. Electronic signature occurs as part of the CDX submission process and with diskette submission a separate signed letter is sent. Burden for this effort is allocated under “Record keeping/Mailing” and therefore is not included in the “Calcu lations/Form Completion” burden estimate outlined in this report. Thus, no management, technical, nor clerical burden associated
with this element of the Form R w ill be allocated for this analysis.

Section 4.1: Facility Identi fication (Name, Address)

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

Technical staff will have knowledge of this informa tion and will report it in Part I, Section 4.1 of the Form R. (2.0 min/0 min)Appendix G

4/28/11 G-10 Reporting Burden Associated with Part I, Section 4.1
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.67 0.67

Technical 2.00 0.00

Total 2.67 0.67

Section 4.2: Reporting by Part

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

4.2a or 4.2b

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

Reporting Burden Associated with Part I, Section 4.2a or 4.2b
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 0.08 0.08

Total 0.16 0.16

4.2c or 4.2d

This section is only filled out if the Form R is from a federal facility or a government-owned, contractor-operated (GOCO) entity conducting work on behalf of the federal government. Since fewer than 5% of Form Rs are filled out by thes e facilities, this section will typically be left
blank.

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

Section 4.3: Technical Contact Informatio n (Name, Address, E-mail, Telephone)

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

4/28/11 G-11 Technical staff will have knowledge of this informa tion and will report it in Part I, Section 4.3 of the Form R. (0.75 min/ 0 min)

Reporting Burden Associated with Part I, Section 4.3
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.25 0.25

Technical 0.75 0.00

Total 1.00 0.25

Section 4.4: Public Contact Information (Name, Telephone)

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

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

Reporting Burden Associated with Part I, Section 4.4
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.17 0.17

Technical 0.50 0.00

Total 0.67 0.17

Section 4.5: SIC Code(s)

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

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

Reporting Burden Associated with Part I, Section 4.5
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 0.25 0.00

Total 0.33 0.08Appendix G

4/28/11 G-12 Section 4.6: Latitude/Longitude

Management burden includes proofread ing this section as part of an overall review of the Form R. (0.50 min/0.50 min)

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

Reporting Burden Associated with Part I, Section 4.6
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.50 0.50

Technical 4.50 0.00

Total 5.00 0.50

Section 4.7: Dun & Bradstreet Number

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

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

Reporting Burden Associated with Part I, Section 4.7
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 10.00 0.00

Total 10.08 0.08

Section 4.8: EPA Identification Number (RCRA ID)

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

Unless hazardous waste manifests are stored with the technical staff preparing the report, they
will need to obtain this information from el sewhere in the company by making a phone call, checking files, or making an in-person informati on request. For the purposes of this estimate, it
is assumed that technical staff will need to obtain this information from elsewhere. OnceAppendix G

4/28/11 G-13 obtained, technical staff will record this informa tion in Part I, Section 4.8 of the Form R. (10.0 min/0 min)

Reporting Burden Associated with Part I, Section 4.8
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 10.00 0.00

Total 10.08 0.08

Section 4.9: Facility NPDES Permit Number

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

Unless NPDES permit documents are stored with th e technical staff preparing the report, they
will need to obtain this information from el sewhere in the company by making a phone call, checking files, or making an in-person informati on request. For the purposes of this estimate, it
is assumed that technical staff will need to obtain this information from elsewhere. Once obtained, technical staff will record this inform ation in Part I, Section 4.9 of the Form R. (10.0 min/0 min)

Reporting Burden Associated with Part I, Section 4.9
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 10.00 0.00

Total 10.08 0.08

Section 4.10: Underground Injection Well Code (UIC I.D.)

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

Unless UIC permit documents are stored with the t echnical staff preparing the report, they will
need to obtain this information from elsewher e in the company by making a phone call, checking files, or making an in-person information reque st. For the purposes of this estimate, it is assumed that technical staff will need to obtain this information from elsewhere. Once obtained,
technical staff will record this informati on in Part I, Section 4.10 of the Form R. (10.0 min/0 min)

.Appendix G

4/28/11 G-14 Reporting Burden Associated with Part I, Section 4.10
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 10.00 0.00

Total 10.08 0.08

Section 5.1: Name of Parent Company

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

Technical staff will need to obtain this informa tion from elsewhere in the company by making a phone call, checking files, or making an in-perso n information request. Once obtained, technical staff will record this information in Part I, Section 5.1 of the Form R. (10.0 min/0 min)

Reporting Burden Associated with Part I, Section 5.1
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 10.00 0.00

Total 10.08 0.08

Section 5.2: Parent Company’s Dun & Bradstreet Number

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

Technical staff will need to obtain this informa tion from elsewhere in the company by making a phone call, checking files, or making an in-perso n information request. Once obtained, technical staff will record this information in Part I, Section 5.2 of the Form R. (10.0 min/0 min)

Reporting Burden Associated with Part I, Section 5.2
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 10.00 0.00

Total 10.08 0.08Appendix G

4/28/11 G-15 Form R, Part II. Chemical-Specific Information
Section 1.1: CAS Number

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

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

Reporting Burden Associated with Part II, Section 1.1
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 0.25 0.00

Total 0.33 0.08

Section 1.2: Toxic Chemical or Chemical Category Name

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

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

Reporting Burden Associated with Part II, Section 1.2
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 0.25 0.00

Total 0.33 0.08

Section 1.3: Generic Chemical Name

Facilities must meet rigorous standards as outlined in 40 CFR 350 in order to claim trade secret status; therefore, this section of the Form R is not typically used. If a facility meets the standard for trade secret status, this section of the Form R is completed instead of Part II, Sections 1.1 and 1.2. If this section is used, ma nagement burden includes proofreadi ng this section as part of an
overall review of the Fo rm R. (0.08 min/0.08 min)Appendix G

4/28/11 G-16 Technical staff would create a generic, structural ly descriptive chemical name and report it in Part II, Section 1.3 of the Form R. (0.50 min/0 min)

Reporting Burden Associated with Part II, Section 1.3
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 0.50 0.00

Total 0.58 0.08

Section 1.4: Distribution of Each Member of the Dioxin and Di oxin-Like Compounds Category

This section of the Form R is left blank unless the chemical is dioxin and dioxin-like compounds. Therefore, for Form Rs for all other chemicals there is no management, technical, nor clerical
burden associated with this element. If th e Form R is for dioxin and dioxin-like compounds, management burden includes proofreading this secti on as part of an overall review of the Form R. (0.08 min/0.08 min)

Technical staff would most likel y obtain the distribution of ea ch member of the dioxin and dioxin-like compounds category fo r the appropriate activity fro m EPA’s document “EPCRA Section 313 Guidance for Reporting Toxic Chem icals Within the Dioxin and Dioxin-like Compounds Category” and report it in Part II, Section 1.4 of th e Form R. (5 min/2 min)

Reporting Burden Associated with Part II, Section 1.4
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 5.00 2.00

Total 5.08 2.08

Section 2.1: Generic Chemical Name Provided by Supplier

This section of the Form R is only completed if the facility’s chemical supplier meets the
standard for trade secret status and is therefore not typically used. If th e material supplied meets the standard for trade secret status, this section of the Form R is completed instead of Part II,
Sections 1.1 and 1.2. If this section is use d, management burden includes proofreading this section as part of an overall review of the Form R. (0.08 min/ 0.08 min)Appendix G

4/28/11 G-17 Technical staff would have the generic chemical name provided by the su pplier readily available from activities conducted during compliance determin ation, such as review of Material Safety Data Sheets (MSDSs), and report it in Part II , Section 2.1 of the Form R. (0.25 min/0 min)

Reporting Burden Associated with Part II, Section 2.1
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 0.25 0.00

Total 0.33 0.08

Section 3.1: Manufacture the Toxic Chemical

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

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

Reporting Burden Associated with Part II, Section 3.1
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 0.08 0.00

Total 0.16 0.08

Section 3.2: Process the Toxic Chemical

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

As an integral part of compliance determinati on, the facility becomes familiar with the EPCRA
Section 313 threshold activities that the chemi cal was involved in duri ng the reporting year. Therefore, technical staff simply check off the re levant descriptions of processing activities for the chemical presented in Part II, Sect ion 3.2 of the Form R. (0.08 min/0 min)Appendix G

4/28/11 G-18 Reporting Burden Associated with Part II, Section 3.2
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 0.08 0.00

Total 0.16 0.08

Section 3.3: Otherwise Use the Toxic Chemical

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

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

Reporting Burden Associated with Part II, Section 3.3
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.08 0.08

Technical 0.08 0.00

Total 0.16 0.08

Section 4.1: Maximum Amount of the Toxic Chemical On-Site at any Time During the
Calendar Year

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (1.08 min/ 0.91 min)

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

• Determine the maximum quantity of the toxic chemical in storage at any point during the calendar year by either reviewi ng inventory records or talking with operations staff. (9.00 min/9.00 min)Appendix G

4/28/11 G-19 • Determine the maximum quantity of the toxic chemical in process at any point during the calendar year by either review ing operations records or ta lking with operations staff. (9.00 min/9.00 min)

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

• Sum together the storage, process, and wast e quantities to calculate the maximum amount
of the toxic chemical on-si te at any one point during the year. (3.00 min/3.00 min)

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

Reporting Burden Associated with Part II, Section 4.1
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 1.08 0.91

Technical 30.25 30.25

Total 31.33 31.16

Section 5.1: Fugitive or Non-Point Air Emissions

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (3.08 min/2.58 min)

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

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

• Identify physical and chemical property da ta for the chemical, including volatility, boiling point, etc. (5.00 min/5.00 min)

• Identify relevant process operating conditions, such as temperature, turbulence, etc., (45.00 min/30.00 min)Appendix G

4/28/11 G-20 • Determine material usage quantity through a review of inventory records, purchase records, operation records, or discussions with operations staff. (30.00 min/30.00 min)

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

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

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

Reporting Burden Associated with Part II, Section 5.1
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 3.08 2.58

Technical 195.25 115.08

Total 198.33 117.66

Section 5.2: Stack or Point Air Emissions

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (3.08 min/1.75 min)

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

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

• For each stack air release, lo cate the most applicable emission factor. For PBT chemicals, EPA-published emission factors ar e obtained from numerous EPA sources, including a chemical or industry specific guidance, AP-42, or the technology transferAppendix G

4/28/11 G-21 network (for TANKS program). (10/9 minutes) For non-PBT chemicals, emission
factors are obtained from sources such as trade associations a nd university research. (30.00 min/15.00 min)

• Determine the annual quantity of input materi al by reviewing purchas e records, inventory records, and/or operational records. (30.00 min/30.00 min)

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

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

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

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

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

Reporting Burden Associated with Part II, Section 5.2
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 3.08 1.75

Technical 106.25 66.25

Total 109.33 68.00Appendix G

4/28/11 G-22 Section 5.3: Discharges to Receiving Streams or Water Bodies

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (3.33 min/2.83 min)

The most commonly reported basis of estimate code for discharges to receiving streams or water bodies is “M,” use of monitoring data, for both non-PBTs and PBTs. To estimate discharges to receiving streams or water bodies, technica l staff would perform the following steps:

Release Quantity from Process Water

1. Locate and review the facility’s monitori ng results for process water outfall(s) to determine the chemical concentration for each monitoring point. (35.00 min/25.00 min)

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

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

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

Release Quantity from Storm Water

5. Locate and review the facility’s monitori ng results from storm water outfall(s) to
determine the chemical concentration fo r each monitoring point, and average them together. Apply needed conversion factors to obtain the total annual release from storm water in pounds. (45.00 min/35.00 min)

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

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

4/28/11 G-23 8. Multiply the total annual rainfall by the wei ghted-average runoff coefficient, the total area of the facility, and the c onversion factor for gallons per cubic foot to calculate the
total annual storm water runoff in gallons. (5.00 min/5.00 min)

9. Multiply the total volume (gallons) of stor m water by the chemical concentration to calculate the total mass (pounds) of the chem ical contained in the annual storm water runoff. If needed, apply a conve rsion factor. (4.00 min/4.00 min)

Total Release Quantity

10. Sum together the annual release quantity from process water with the annual release quantity from storm water to obtain the total an nual release quantity to water. Report the total release (lb/y r) in Part II, Section 5.3.1.A of the Fo rm R as the tota l releases to a water body for a specific ch emical. (2.00 min/2.00 min)

Basis of Estimate

11. Report whether the release estimate was ba sed on monitoring data, mass balance, a published emission factor, or ot her engineering calculations by recording the code M, C, E, or O, respectively, in Section 5.3. 1.B of the Form R. (0.25 min/0.25 min)

Percent from Stormwater

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

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

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

4/28/11 G-24 This incidence-weighted value was added with the total estimated burden for identifying the annual release quantity from process water to obta in the total calculation ti me estimate for 5.3.A.
The table below reflects the incidence-wei ghted value for storm water assessment.

Reporting Burden Associated with Part II, Section 5.3

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Non-PBT PBT Non-PBT PBT
Management 3.33 3.33 2.83 2.83

Technical 113.83 118.32 84.69 87.34

Total 117.16 121.65 87.52 90.17

Section 5.4.1: Underground Inject ion On-Site to Class I Wells

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (2.08 min/1.75 min)

The most commonly reported basis of estimate code for releases to underg round injection Class I wells is “M,” use of monitoring data for bot h non-PBT and PBT chemicals. To estimate quantities injected underground or on -site to Class I wells, the t echnical staff would perform the following steps:

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

2. Either talk to operations st aff, review production records and estimate waste generation, review well operations records, or review well permit data/r equired injection well reports to determine the total quantity of waste disp osed via Class I wells for the reporting year. (30.00 min/30.00 min)

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

4. Report whether the release estimate was based on monitoring data, mass balance, published emission factor, or ot her engineering calculations by recording the code M, C, E, or O, respectively, in Section 5.4. 1.B of the Form R. (0.25 min/0.25 min)Appendix G

4/28/11 G-25 Reporting Burden Associated with Part II, Section 5.4.1
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 2.08 1.75

Technical 73.25 63.25

Total 75.33 65.00

Section 5.4.2: Underground Inject ion On-Site to Class II-V Wells

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (2.08 min/1.75 min)

The most commonly reported basis of estimate c ode for releases to underground injection Class II-V wells is “M,” use of monitoring data for both non-PBT and PBT chemicals. To estimate quantities injected underground or on-site to Cla ss II-V wells, the techni cal staff would perform the following steps:

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

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

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

4. Report whether the release estimate was based on monitoring data, mass balance, published emission factor, or ot her engineering calculations by recording the code M, C, E, or O, respectively, in Section 5.4. 2.B of the Form R. (0.25 min/0.25 min)Appendix G

4/28/11 G-26 Reporting Burden Associated with Part II, Section 5.4.2
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 2.08 1.75

Technical 73.25 63.25

Total 75.33 65.00

Section 5.5.1A: On-site Land Disp osal via RCRA Subtitle C Landfills

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (3.08 min/1.75 min)

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

1. Identify all waste streams containing the ch emical of interest disposed of in RCRA landfills. (30.00 min/5.00 min)

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

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

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

4/28/11 G-27 Reporting Burden Associated with Part II, Section 5.5.1A
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 3.08 1.75

Technical 96.25 66.25

Total 99.33 68.00

Section 5.5.1B: On-site Land Disposal via Other Landfills Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (3.08 min/1.75 min)

The most commonly reported basis of estimate code for releases to on-si te non-RCRA landfills is “O,” other approaches, for both non-PBT and PBT ch emicals. It is assumed the technical staff would track the generation and on-site di sposal of these wastes as follows:

1. Identify all waste streams containing the chemi cal of interest dispos ed of in on-site nonRCRA landfills. (30.00 min/5.00 min)

2. Talk to operations staff, review producti on records and estimate waste generation, or review on-site disposal tracki ng records to determine the tota l quantity of waste disposed of in non-RCRA landfills for the reporting year. (30.00 min/30.00 min)

3. Talk to operations staff, review any wast e characterization information, or review production/activity SOPs and process flow diag rams to determine the concentration of a specific chemical disposed of in non-RCRA landfills. (30.00 min/25.00 min)

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

5. Report whether the release estimate was based on monitoring data, mass balance, published emission factor, or ot her engineering calculations by recording the code M, C, E, or O, respectively, in Section 5.5.1B.B of the Form R. (0.25 min/0.25 min)Appendix G

4/28/11 G-28 Reporting Burden Associated with Part II, Section 5.5.1B
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 3.08 1.75

Technical 96.25 66.25

Total 99.33 68.00

Section 5.5.2: On-Site Land Disposal via Land Treatment/Application Farming

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (2.08 min/1.75 min for non-PB T filers; 3.08 min/1.75 min for PBT filers)

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

1. Locate monitoring data and determine the chemi cal concentration in the waste stream for each monitoring point. Then calculate an av erage chemical concentrations across all monitoring data points (event s). (35.00 min/ 25.00 min)

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

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

4. Report whether the release estimate was based on monitoring data, mass balance, published emission factor, or ot her engineering calculations by recording the code M, C, E, or O, respectively, in Section 5.5. 2.B of the Form R. (0.25 min/0.25 min)

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

4/28/11 G-29 • Identify all waste streams disposed of via land treatment that contain the chemical of interest. (30.00 min/5.00 min)

• Determining the total quantity of waste disp osed of via land treatme nt for the reporting year requires the technical staff to either talk to operations staff, review production records and estimate waste generation, or revi ew on-site disposal tracking records. (30.00 min/30.00 min)

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

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

• Report whether the release estimate was based on monitoring data, mass balance, published emission factor, or ot her engineering calculations by recording the code M, C, E, or O, respectively, in Section 5.5. 2.B of the Form R. (0.25 min/0.25 min)

Reporting Burden Associated with Part II, Section 5.5.2

Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)

Non-PBT PBT Non-PBT PBT
Management 2.08 3.08 1.75 1.75

Technical 73.25 96.25 63.25 66.25

Total 75.33 99.33 65.00 68.00

Section 5.5.3A: RCRA Subtitle C Surface Impoundments

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (3.08 min/1.75 min)

The most commonly reported basis of estimate code for releases via RCRA surface impoundments is “C,” mass balance, for both non- PBT and PBT chemicals. To estimate TRI chemical quantities sent to RCRA landfills, technical staff would tr ack the loss of this chemical

sing a mass balance approach as follows: u

• Identify all waste streams disposed of via RCRA Subtitle C surface impoundments that contain the chemical of interest. (30.00 min/5.00 min)Appendix G

4/28/11 G-30 • Determine the total annual chemical us age quantity through a review of production records, a review of invent ory records, or conversations with operations staff. (30.00 min/30.00 min)

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

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

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

Reporting Burden Associated with Part II, Section 5.5.3A
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 3.08 1.75

Technical 96.25 66.25

Total 99.33 68.00

Section 5.5.3B: Other Surface Impoundments

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (3.08 min/1.75 min)

The most commonly reported basis of estimate code for releases via other surface impoundments is “C,” mass balance, for both non-PBT and PBT chemicals. To estimate TRI chemical quantities sent to other surface impoundments, technical staff would track the loss of this

hemical using a mass balance approach as follows: c

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

4/28/11 G-31 • Determine the total annual chemical us age quantity through a review of production records, a review of invent ory records, or conversations with operations staff. (30.00 min/30.00 min)

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

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

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

Reporting Burden Associated with Part II, Section 5.5.3B
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 3.08 1.75

Technical 96.25 66.25

Total 99.33 68.00

Section 5.5.4: Other On-Site Land Disposal

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (1.08 min/0.91 min)

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

The most commonly reported basis of estimate code for other on-site land di sposal is “O,” other approaches, for both non-PBT and PBT chemicals. It is assumed that the approach used by
technical staff would be to track the generation and on-site dispos al of these wastes as follows:Appendix G

4/28/11 G-32 For planned other on-site disposal to land:

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

• Talk to operations staff, review producti on records and estimate waste generation, or review on-site disposal tracki ng records to determine the tota l quantity of waste disposed of via other land disposal for th e reporting year. (30.00 min/30.00 min)

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

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

For unplanned other on-site disposal to land:

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

• Report whether the release estimate was based on monitoring data, mass balance, published emission factor, or ot her engineering calculations by recording the code M, C, E, or O, respectively, in Section 5.5. 4.B of the Form R. (0.25 min/0.25 min)

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

Reporting Burden Associated with Part II, Section 5.5.4
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 1.08 0.91

Technical 35.25 35.25

Total 36.33 36.16Appendix G

4/28/11 G-33 Section 6.1: Discharges to P ublicly Owned Treatment Works

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (3.58 min/2.25 min)

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

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

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

• Talk with operations staff or contact the POTW to determine the number of days

wastewater was sent to the POTW. (15.00 min/15.00 min)

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

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

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

• Technical staff will have the POTW name and location information readily available
from document review conducted for the release estimate. Technical staff will report this information in Part II, Section 6.1.B.1 of the Form R. (1.50 min/0 min)Appendix G

4/28/11 G-34 Reporting Burden Associated with Part II, Section 6.1
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 3.58 2.25

Technical 74.75 58.25

Total 78.33 60.50

Section 6.2: Transfers to Other Off-Site Locations

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (4.83 min/3.42 min)

The most commonly reported basis of estimate code for transfers to other off-site locations is “O,” other approaches, for both non-PBT and PBT ch emicals. It is assumed that the approach used by technical staff would be to track the off-site transfer of these wastes primarily using

aste characterization and waste transfer documentation as outlined below: w

• Identify all off-site transfers of unique wast e streams containing the chemical of interest. (30.00 min/ 5.00 min)

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

• Determine the total quantity of the first uni que waste stream that the facility ships offsite during the reporting year by reviewing hazardous waste manifests, invoices from waste vendors, or talking to ope rations staff. (30.00 min/30.00 min)

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

An analysis of RY 2002 TRI data indicates that there was an average of approximately two offsite transfer locations and an average of approxima tely two reported “M” codes. Therefore, it is assumed that on average, two unique waste stream s are being transferred off-site. There are economies of scale in estimating the quantity of th e TRI chemical in the second waste stream due to the concurrent activities of reviewing th e same sources to determine the chemical
concentration in the waste and to estimate the a nnual quantity of waste transferred off-site. To estimate the additional time needed to quantify th e off-site transfer of the second waste stream technical staff would perform the following:Appendix G

4/28/11 G-35 • For the second waste stream, determine the conc entration of the chemical in the stream by either reviewing waste characterization profiles, contacting the facility’s hazardous waste shipper to obtain their waste charac terization information, or conducting a mass balance evaluation. Determine the total quant ity of each unique waste stream that the facility ships off-site during the reporting year. (5.00 min/5.00 min)

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

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

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

• Report the type of waste treatment/disposal/r ecycling/energy recovery code by recording the appropriate M-code in Section 6. 2.C of the Form R. (0.25 min/0.25 min)

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

• Technical staff will have the off-site transfer name and location information readily available from document review conducted for the release estimate and will report this information in Part II, Section 6.2.1 a nd 6.2.2 of the Form R. (4.17 min/2.08 min)Appendix G

4/28/11 G-36 Reporting Burden Associated with Part II, Section 6.2
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 4.83 3.42

Technical 112.17 84.58

Total 117.00 88.00

Section 7A: On-Site Waste Trea tment Methods and Efficiency

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (5.17 min/3.50min)

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

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

• Identify the type of waste stream (gas eous, wastewater, liquid waste, or solid waste) and report the appropr iate code in Part II, Section 7A.1a. (10.00 min/5.00 min)

• Identify all of the treatm ent steps this waste stream passes through and the order
of occurrence. Locate the a ppropriate treatment codes representing the treatment activity in the TRI Reporting Forms and Instructions and report them in the actual order of occurrence in Part II, Sectio n 7A.1b of the Form R. (20.00 min/5.00 min)

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

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

• Review equipment manuals for manu facturer reported efficiencies.

• Use pre- and post-treatment analytical da ta to calculate treatment efficiency by subtracting the post-treatment chemical concentration from the pre-treatment
chemical concentration and then divide the result by the pre-treatment chemical
concentration.

• T echnical staff can also obtain the info rmation by talking to operations staff.Appendix G

4/28/11 G-37 • Report the treatment efficiency in Part II, Section 7A.1.d of the Form R (15.00 min/5.00 min).

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

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

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

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

• Determining the range of the influent con centration for the second waste stream would require the same time effort as for the first waste stream because technical staff would be reviewing a different set of info rmation, such as different labo ratory reports. Therefore, the following additional time is needed in Part II, Section 7A.2c for the second waste stream (30.00min/15.00min).

• Determining the treatment efficiency for the second waste stream w ould require the same
time effort as for the first waste stream b ecause technical staff would be reviewing a different set of information, such as diffe rent equipment manuals. Therefore, the following additional time is needed in Part II, Section 7A.2d for th e second waste stream (15.00min/5.00min).

• Report whether the efficiency for the s econd waste stream was calculated using monitoring data by checking yes or no in Part II, Section 7A.2e of the Form R,. (0.08 min/0.08 min)Appendix G

4/28/11 G-38 Reporting Burden Associated with Part II, Section 7A
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 5.17 3.50

Technical 125.16 52.16

Total 130.33 55.66

Section 7B: On-Site Energy Recovery Processes

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (1.0 min/0.83 min)

It is assumed that technical staff either review pr ocess flow diagrams or talk to operations staff in order to identify any on-s ite energy recovery activiti es. For each waste stream that is undergoing treatment for on-site energy recovery, technical st aff locate the appropriate code for the activity in the TRI Reporting Forms and Instructions. The codes are reported in descending order by quantity of energy recycled in Part II, S ection 7B of the Form R. (32.00 min/24.00 min)

Reporting Burden Associated with Part II, Section 7B
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 1.00 0.83

Technical 32.00 24.00

Total 33.00 24.83

Section 7C: On-Site Recycling Processes

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (1.0 min/0.83 min)

It is assumed that technical staff either review pr ocess flow diagrams or talk to operations staff in order to identify any on-site r ecycling activities. For each wa ste stream that is undergoing treatment for on-site recycling, t echnical staff locate the appropriate code for the activity in the TRI Reporting Forms and Instructions. The code s are reported in descending order by quantity of waste recycled in Part II, Secti on 7C of the Form R. (38.00 min/27.00 min)Appendix G

4/28/11 G-39 Reporting Burden Associated with Part II, Section 7C
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 1.00 0.83

Technical 38.00 27.00

Total 39.00 27.83

Section 8.1a: Total On-Site Disposal to Class I Underground Injection Wells, RCRA Subtitle C Landfills, and Other Landfills

Management burden includes an assessment of wh ether quantities previo usly calculated for
Sections 5 and 6 have been r ecorded in the correct subsec tion of Section 8 as well as proofreading this section as pa rt of an overall review of th e Form R. (0.50 min/0.50 min)

Four columns must be completed in this se ction, requiring technical staff to perform the

ollowing steps: f

• Column A: Record "NA" in Part II, Section 8.1a, Column A of the Fo rm R if the facility is a first time filer. For subsequent reporting years, locate the rele ase estimate from the "Column B, Current Reporting Year" column from the previous year’s form and record this quantity in Part II, S ection 8.1a, Column A of th e Form R. (0.25 min/0.25 min)

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

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

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

Reporting Burden Associated with Part II, Section 8.1aAppendix G

4/28/11 G-40 Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.50 0.50

Technical 7.25 7.25

Total 7.75 7.75

Section 8.1b: Total Other On-S ite Disposal or Other Releases

Management burden includes an assessment of wh ether quantities previo usly calculated for
Sections 5 and 6 have been r ecorded in the correct subsec tion of Section 8 as well as proofreading this section as pa rt of an overall review of th e Form R. (0.50 min/0.50 min)

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

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

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

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

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

4/28/11 G-41 Reporting Burden Associated with Part II, Section 8.1b
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.5 0.50

Technical 7.25 7.25

Total 7.75 7.75

Section 8.1c: Total Off-Site Disposal to Class I Underground Injection Wells, RCRA Subtitle C Landfills, and Other Landfills

Management burden includes an assessment of wh ether quantities previo usly calculated for
Sections 5 and 6 have been r ecorded in the correct subsec tion of Section 8 as well as proofreading this section as pa rt of an overall review of the Form R. (0.50 min/0.50 min)

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

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

• Column B: Sum together the quantities calcula ted in Part II, Sec tions 6.1 (portion of transfer that is untreated and ultimately di sposed of in UIC Class I Wells, RCRA Subtitle C landfills and other landfills) and 6.2 (quant ities associated with M codes M64, M65, and M81) and then subtract any off-site dis posal quantities due to catastrophic events. Report the total quantity disposed of off-s ite via Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills in Part II, Section 8.1c, Column B of the Form R. (5.00 min/5.00 min)

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

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

4/28/11 G-42 Reporting Burden Associated with Part II, Section 8.1c
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.5 0.50

Technical 7.25 7.25

Total 7.75 7.75

Section 8.1d: Total Other Off-Si te Disposal or Other Releases

Management burden includes an assessment of wh ether quantities previo usly calculated for
Sections 5 and 6 have been r ecorded in the correct subsec tion of Section 8 as well as proofreading this section as pa rt of an overall review of the Form R. (0.50 min/0.50 min)

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

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

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

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

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

4/28/11 G-43 Reporting Burden Associated with Part II, Section 8.1d
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.50 0.50

Technical 7.25 7.25

Total 7.75 7.75

Section 8.2: Quantity Used for Energy Recovery On-Site

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (1.25 min/1.08 min)

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

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

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

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

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

4/28/11 G-44 Reporting Burden Associated with Part II, Section 8.2
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 1.25 1.08

Technical 32.25 32.25

Total 33.50 33.33

Section 8.3: Quantity Used for Energy Recovery Off-Site

Management burden includes an assessment of wh ether quantities previo usly calculated for
Sections 5 and 6 have been r ecorded in the correct subsec tion of Section 8 as well as proofreading of this section as part of an overall review of the Fo rm R. (0.50 min/0.50 min)

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

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

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

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

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

4/28/11 G-45 Reporting Burden Associated with Part II, Section 8.3
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.5 0.50

Technical 7.25 7.25

Total 7.75 7.75

Section 8.4: Quantity Recycled On-Site

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (1.25 min/1.08 min)

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

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

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

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

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

4/28/11 G-46 Reporting Burden Associated with Part II, Section 8.4
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 1.25 1.08

Technical 32.25 32.25

Total 33.50 33.33

Section 8.5: Quantity Recycled Off-Site

Management burden includes an assessment of wh ether quantities previo usly calculated for
Sections 5 and 6 have been r ecorded in the correct subsec tion of Section 8 as well as proofreading this section as pa rt of an overall review of the Form R. (0.50 min/0.50 min)

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

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

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

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

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

4/28/11 G-47 Reporting Burden Associated with Part II, Section 8.5
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.5 0.50

Technical 7.25 7.25

Total 7.75 7.75

Section 8.6: Quantity Treated On-Site

Management burden includes review of data, me thods, and assumptions used to develop the estimate. In some cases it also includes data qual ity activities such as comparing the values with previous years. (1.25 min/1.08 min)

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

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

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

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

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

4/28/11 G-48 Reporting Burden Associated with Part II, Section 8.6
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 1.25 1.08

Technical 32.25 32.25

Total 33.50 33.33

Section 8.7: Quantity Treated Off-Site

Management burden includes an assessment of wh ether quantities previo usly calculated for
Sections 5 and 6 have been r ecorded in the correct subsec tion of Section 8 as well as proofreading this section as pa rt of an overall review of th e Form R. (0.50 min/0.50 min)

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

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

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

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

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

4/28/11 G-49 Reporting Burden Associated with Part II, Section 8.7
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.50 0.50

Technical 7.25 7.25

Total 7.75 7.75

Section 8.8: Quantity released to the Envi ronment as a Result of Remedial Actions, Catastrophic Events, or One-Time Events no t Associated with Production Processes

Management burden includes an assessment of wh ether quantities previo usly calculated for
Sections 5 and 6 have been r ecorded in the correct subsec tion of Section 8 as well as proofreading this section as pa rt of an overall review of th e Form R. (0.25 min/0.25 min)

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

Reporting Burden Associated with Part II, Section 8.8
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.25 0.25

Technical 5.00 5.00

Total 5.25 5.25

Section 8.9: Production Ratio or Activity Index

Management burden includes review of data, me thods, and assumptions used to develop the production ratio; and in some cases, data quality ac tivities such as comparing the values with previous years. (0.83 min/0.83 min)

Technical staff would perform the following step s to calculate the produc tion ratio or activity
index:

• Determine the annual production or activity le vel for the reporting year by either reviewing production records or maintenance l ogs, or talking with the operations staff. (30.00 min/30.00 min)

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

• Divide the current year’s pr oduction or activity level by th e prior year’s production or activity level. Alternatively, review the wa ste minimization section of the RCRA report.Appendix G

4/28/11 G-50 Report the production ratio or activity index in Part II, Section 8.9 of the Form R. (1.00 min/1.00 min)

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

Reporting Burden Associated with Part II, Section 8.9
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0.83 0.83

Technical 36.00 36.00

Total 36.83 36.83

Section 8.10: Did Your Facility Engage in any Source Reduction Activities?

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

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

Reporting Burden Associated with Part II, Section 8.10
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 1.08 0.92

Technical 35.25 35.25

Total 36.33 36.17Appendix G

4/28/11 G-51 Section 8.11: Is Additional Information on Source Reduction, Recycling or Pollution Control Activities Included with this Report?

Provision of additional informa tion on source reduction, recycling, or pollution control activities is optional; therefore, there is no management, tec hnical, nor clerical burden associated with this
element of the Form R.

Reporting Burden Associated with Part II, Section 8.11
Personnel Type First Year Burden (minutes) Subsequent Year Burden (minutes)
Management 0 0.00

Technical 0 0.00

Total 0.00 0.00

2.1.B. Results for Electronic Submission

Table 4 summarizes the total reporting burden as sociated with electroni c submissions of PBT and non-PBT forms. Tables 5 and 6 (refer to Ex cel spreadsheet) pres ent the realistic and incidence weighted reporting burden for every data element on the Form R for first year
electronic submissions of PBT a nd non-PBT reports. Tables 7 and 8 (refer to Excel spreadsheet) present the realistic and incide nce weighted reporting burden for every data element on the Form R for subsequent year electronic subm issions of PBT and non-PBT reports.

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

Management Technical Total Management Technical Total
First year

PBT 0.99 29.51 30.50 0.34 9.20 9.54

N on-PBT 0.98 29.38 30.36 0.37 10.49 10.86
Subsequent years

PBT 0.77 20.98 21.75 0.29 6.17 6.46

N on-PBT 0.77 20.97 21.74 0.32 6.89 7.21

2.1.C. Methodology for Paper Submission

The only difference between electronic and paper submissions for first year and subsequent year Form R reporting burden is clerical time. To generate a pape r copy, clerical staff would take the information prepared by the technical staff and type it onto a paper c opy of the Form R. Therefore, for both PBT and non-PBT chemicals, clerical times were estimated by dividing theAppendix G

4/28/11 G-52 currently approved OMB clerical times (Table 1) by the total number of fields on the Form R. While it may not take the exact same amount of time to line up each data element for typing, there is no reasonable way to estimate this, so gi ving equal time to each element was determined
to be the best method. The clerical time allotted to each element was then added to the estimate for the electronic form (including management and technical time) for that element to generate time estimates for every data element for PBT and non-PBT first and subs equent year reporting via a paper Form R.

2.1.D. Results for Paper Submission

Table 9 summarizes the total reporting burden fo r paper submission of PBT and non-PBT forms. Tables 10 and 11 (refer to Excel spreadsheet) pr esent the realistic and incidence weighted reporting burden for every data element on the Fo rm R for first year paper submissions of PBT and non-PBT reports. Tables 12 and 13 (refer to Excel spreadsheet) present the realistic and incidence weighted reporting burd en for every data element on the Form R for subsequent year paper submissions of PBT and non-PBT reports.

TABLE 9
TOTAL REPORTING BURDEN FOR PAPER SUBMISSIONS
Estimated realistic time per form (hr) Incidence weighted time per form (hr)
Management Technical Clerical Total Management Technical Clerical Total
First year

PBT 1.01 29.51 2.90 33.42 0.35 9.20 1.59 11.14

N onPBT 0.99 29.38 1.62 31.99 0.38 10.49 0.93 11.80

Subsequent years

PBT 0.78 21.17 2.00 23.95 0.30 6.33 1.10 7.73

N onPBT 0.78 21.17 1.10 23.05 0.33 7.05 0.63 8.01

3. S CALED R EPORTING B URDEN E STIMATES

3.1 Scaled Estimate for PBT Chemicals

In this section, the realistic technical reporti ng burden estimates developed for PBT chemicals are used in combination with the currently -approved OMB form co mpletion reporting burden estimates to generate burden estimates for each da ta element consistent with the OMB total. Four individual reporting burden scenarios are scaled up: first year electronic, subsequent year electronic, first year paper, and subsequent year paper. The incidence weighted values are notAppendix G

4/28/11 G-53 used for PBT chemicals because the OMB burden es timate assumes all Form R fields are filled out by all reporters.

3.1.A. Methodology for Scaled PBT Chemical Electronic Submissions

The OMB-approved form completion burden esti mates for PBT first and subsequent year
technical burden are 45.2 and 30.8 hours, respectively. The following procedure was used to scale the realistic electronic PBT data element burden estimates to these OMB-approved burden estimates. Reporting burden is estimated for both first and subsequent years.

• Technical reporting burden for da ta elements requiring only typing or typing plus a quick information look-up (such as locating the f acility’s D&B number) was estimated (86.25 min, 13.42 min). The times for these steps were assumed static and, therefore, were not scaled up.

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

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

• The scaling factor was applie d to all of the nonstatic re alistic data element burden
estimates.

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

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

4/28/11 G-54 3.1.B. Results for PBT Chemical Electronic Submissions

Table 14 (refer to Excel spreadsheet) presents sc aled management and technical burden estimates for completing each data element of the Form R for first and subsequent year electronic submissions of PBT reports.

3.1.C. Methodology for PBT Chemical Paper Submissions

The only difference between electronic and paper submission for Form R reporting burden is the clerical time needed for typing. To generate a paper copy, clerical staff would take the information prepared by the technical staff and t ype it onto a paper copy of the Form R. The time required to type information into one data element on the Form R was considered to be
static and unrelated to the rela tive degree of difficulty in dete rmining the information to be entered into the field. For this reason, cleric al time was not determined by scaling from the realistic estimates generated for technical time. Instead, clerical times were estimated by dividing the currently approved OM B clerical burden (Table 1) for PBT chemical submission by
the total number of data elements on the Form R.

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

3.1.D. Results for PBT Chemical Paper Submission

Table 15 (refer to Excel spreadsheet) presents sc aled management, technical, and clerical burden estimates for completing each data element of the Form R for first and subsequent year submissions of paper PBT chemical reports.

3.2 Scaled Estimate fo r non-PBT Chemicals

In this section, the realisti c technical reporting burden es timates developed for non-PBT
chemicals are used in combination with the currently-approved OMB form completion reporting burden estimates to generate burden estimates for each data element consistent with the OMB total. Four individual reporting bu rden scenarios are scaled up: fi rst year electroni c, subsequent year electronic, first year paper, and subsequent year paper. Th e incidence weighted values are
used for non-PBT chemicals because the OMB burden estimates for non-PBT chemicals are based on actual reporting bur den data from facilities.Appendix G

4/28/11 G-55 nt years. 3.2.A. Methodology for non-PBT Chem ical Electronic Submissions

The OMB-approved form completion burden esti mate for non-PBT subsequent year technical burden is 16.4 hours. A first-year estimate for non-PBT technical burden of 24.1 hours was estimated by multiplying the subsequent year estimate by 147 percent. 1 The following procedure was used to scale th e realistic electronic non-PBT burden estimates to these OMBapproved burden estimates. Reporting burden is estimated for both first and subseque

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

• Total static time was subtracted from bot h the OMB approved technical burden (1446.48 min, 984.0 min) and the total incidence-weig hted realistic technical burden (629.49 min, 413.18 min) to estimate the total OMB (1387.48 min, 977.60 min) and realistic (570.49 min, 406.79 min) times for those Form R data elements that require more complex information gathering and calculations.

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

• The scaling factor was applie d to all of the nonstatic re alistic data element burden
estimates.

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

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

1 An OMB-approved estimate for first time non-PBT filers does not exist; however, the RIA for the original Section 313 rulemaking estimated the time re quired to complete a report in the first year to be 147% of the time required in subsequent years. This factor was applied to the OMB approved subsequent year non-PBT report completion times to calculate th e first year non-PBT completion times. (U.S. EPA Regulatory Impact Analysis in Support of Final Rulemaking under Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 (1988).Appendix G

4/28/11 G-56 3.2.B. Results for non-PBT Chemical Electronic Submissions

Table 16 (refer to Excel spreadsheet) presents sc aled management and technical burden estimates for completing each field of the Form R for first and subsequent year electronic submissions of non-PBT reports.

3.2.C. Methodology for non-PBT Chemical Paper Submissions

The only difference between electronic and paper submission for Form R reporting burden is the clerical time needed for typing. To generate a paper copy, clerical staff would take the information prepared by the technical staff and t ype it onto a paper copy of the Form R. The time required to type information into one data element on the Form R was considered to be
static and unrelated to the rela tive degree of difficulty in dete rmining the information to be entered into the field. For this reason, cleric al time was not determined by scaling from the realistic estimates generated for technical time. Instead, clerical times were estimated by dividing the currently approved OMB clerical burden (Table 1) for non-PBT chemicals by the
total number of fields on the Form R.

While it may not take the exact same amount of time to line up each data element for typing, there is no reasonable way to estimate this, so gi ving equal time to each element was determined
to be the best method. The clerical time allotted to each element was then added to the estimate for the electronic form (including management and technical time) for that element to generate time estimates for every data element for non-PB T first and subsequent year reporting via a paper Form R.

3.2.D. Results for non-PBT Chemical Paper Submissions

Table 17 (refer to Excel spreadsheet) presents realistic management, technical, and clerical burden estimates for completing each data element of the Form R for first and subsequent year paper submissions of non-PBT reports.Appendix G

4/28/11 G-57 

# memorandum

To: Laura Nielsen, U.S. EPA

From: Susan Day

Date: December 2, 2010

Subject: Modified TRI Reporting Burden Estimates for Rule Familiarization and Compliance Determination

________________________________________________________________________

1. INTRODUCTION

EPA currently relies on previously develope d OMB approved TRI reporting burden estimates that reflect the total time require d by facilities to complete activit ies such as rule familiarization, compliance determination, form completion, reco rd keeping/mailing, and supplier notification. In an earlier analysis (2004), Abt Associates Inc. developed new burden estimates for form completion, broken down by the individual data elements that make up the Form R. 1 In that assessment, a list of activities a facility typically conducts to complete each data element was developed. Next, best professiona l judgment was used to estimate the time needed to complete each activity. Finally, these times were summed together. The total form completion time developed through that assessment was referred to as the “realistic burden.” This memo summarizes the application of the same met hodology to rule familiarization and compliance determination in an analysis completed in 2005. “Realistic burden” estimates for each are presented below.

In order to develop standardized estimates that ar e meaningful across the ra nge of facility types, sizes, and sectors reporting to TRI, the realistic burden is set to re flect activities at a typical TRIreporting facility. Assumptions about th e typical facility are outlined below.

1 TRI Reporting Burden Estimates, Memo from Hilary Eust ace, David Cooper, Susan Day, Abt Associates to Paul Borst, EPA, July 16, 2004. Docket # EPA-HQ-TRI-2005-0073-0012.Appendix G

4/28/11 G-58 The typical facility:

• is mid-sized (somewhere between a small, si ngle activity shop and a very large, very complex operation).

• is representative of all sectors covered under TRI.

• is reasonably modern and well-organized.

• has internet access with reasonable connection speed.

• has technical staff with sufficient expertise to readily understand the chemical and industrial concepts necessary for TRI program comprehension.

• will not be right at threshold for employees or chemicals, but will be well above or well below threshold. Therefore, once these determina tions are made, they will not need to be reassessed every year.

• conducts quantitative threshold assessments for 6 chemicals, and files TRI reports for 3 of these. Each chemical is typically in volved in only one threshold activity.

2. COMPLIANCE DETERMINATION

2.1 Realistic Burden – First Year

To make a compliance determination the typical facility will need to conduct facility level activities such as NAICS code and employee asse ssment and a chemical list determination. In addition, chemical-specific thresh old quantity determinations must be made. The activities a typical facility would conduct in making their compliance de termination and associated burden estimates are presented in this section.

2.1.1 Facility Level Activities

NAICS Code Assessment To conduct the NAICS code assessment, (i.e., is the facility in an EP CRA section 313-covered NAICS code?) technical staff will call accountin g or other corporate department for this
information (10.00 min/0.17 hour).

Employee Threshold Assessment To conduct the employee threshold assessment, (i .e., does the facility exceed the EPCRA section 313 20,000 hour employee threshold?) technical staff will determine the whole set of full- and part-time employees, temps, contractors (excepti ng drivers and janitorial contractors), and offsite corporate support by checking with payr oll and other management, supervisory, or accounting staff as necessary (30.00 min/0.5 hour).

Next, technical staff will calculate the total hours worked by this group during the full calendar year or up until a clear determination is made th at the facility is above or below the 20,000 hour threshold by summing together quantities on ti mesheets or accounting system totals (30.00 min/ 0.5 hour).Appendix G

4/28/11 G-59 Chemical List Determination
To determine which TRI chemicals ar e present, technical staff will:

• Compare all materials (includi ng mixtures, alloys, and fuels) used/manufactured at the facility to the EPCRA section 313 (TR I) list. This task will involve:

o Gathering all MSDSs, or other batch inf o, product specs, certificates of analysis, labeling information, etc (60.00 mins/1.0 hour).

o Reviewing the “Regulatory Information” section of the MSDS. Where an MSDS is not available, technical staff will co mpare available supplier data on chemical constituents with the TRI chemical list (90.00 min/1.5 hours).

o For PBT chemicals, technical staff will a ssess if there are likely PBT chemicals present at below de minimis in mixtures used by the fac ility. This step is needed
since the de minimis exemption is allowed for supplier notification, but is not
allowed for PBT chemicals for threshold determination or release reporting (60.00 min/1.0 hour).

Table 1: Facility-Level Comp liance Determination Burden

NAICS Code Assessment 0.17 technical hours
Employee Threshold Assessment 1.0 technical hours

Chemical List Determination 3.5 technical hours

Total 4.67 technical hours

2.1.2 Chemical-Specific Activities

As mentioned above, the typical facility will conduct quantitative threshold assessments for six chemicals. For each TRI chemical, technical staff will review all manufacture/uses of the chemical at the facility to determine if they fa ll under the definition of ma nufacture, process, or otherwise use. This task will involve talking w ith operations staff, facility chemists, reviewing process flow diagrams, conducting facility walkthrough and reviewi ng standard operating procedures (30.00 min/0.5 hours).

For each TRI chemical manufactured, processe d, or otherwise used, technical staff will determine the total annual quantity of the chemical for each threshold activity. This activity will include determining the percentage of the TRI chem ical in a mixture, alloy, or fuel. The method to calculate threshold quantity for process OR otherwise use is:

• Determine the material usage quantity within each applicable thresh old activity through a review of inventory records, purchase records, operation r ecords, or discussions with operations staff (30.00 mins/0.5 hour s). This task may require a determination of the total material usage quantity through i nventory or purchase records, followed by dividing this total
into the different threshold activities through operations re cords or discussions with operations staff. For the purposes of this analys is, however, it is assumed that each chemical typically falls within only one threshold activity.

• If the material used is a mixture, determine the chemical concentration in the mixture throughAppendix G

4/28/11 G-60 a review of the MSDS, batch analysis, or other supplier information (30.00 min/0.5 hours).

• Multiply total material usage quantity by chemical concentration to determine total annual chemical usage quantity (2.00 min/0.03 hours).

The total time required to calcu late a threshold quantity for pr ocess or otherwise use is 62.00
min/1.0 hour.

For intentional manufacture, technical staff will determine the annual quantity manufactured through production records (30.00 min/0.5 hours).

The method used to calculate the threshold quantity for coincidental manufacture is to determine the annual quantity for combustion products a nd reaction by-products or impurities as follows:

• Combustion products : Technical staff will determine the annual quantity manufactured through use of emission factors by:

o Locating the most applicable emission factor. Numerous EPA sources are available such as AP-42 TRI chemical sp ecific and industry specific guidance.
Non-EPA sources include uni versity research and tr ade associations (30.00 min/0.5 hours).

o Determining the annual quantity of input material by reviewing purchase records, inventory records, and/or opera tional records (30.00 min/0.5 hours).

o Multiplying this material usage quantity by the emission factor to determine the
amount of material released from each point during the year and, if necessary, converting the amount of material releas ed to pounds (or grams for dioxins) by applying the appropriate convers ion factor (6.00 min/0.1 hours).

o Finding the average pollution control effici ency for the emission factor from the AP-42 listing or emission factor source, or identifying if the emission factor was generated from uncontrolled sources. Usi ng this pollution control efficiency, technical staff will extrapolate the to tal quantity generated from the quantity emitted (10.00 min/0.17 hours).

o The total time required to calculate a threshold quantity in coincidental
manufacture is 76.00 min/1.27 hours.

• Reaction by-products or impurities: Technical staff will identify the quantity of chemical coincidentally manufactured through discussion s with facility chemists, production records, operations staff, chemistry literature, or EPA TRI guidance documents (45.00 min/0.75 hours).

Once annual threshold quantities have been calc ulated, technical staff will compare the annual threshold quantities for each chemical with th e TRI regulatory threshold limits by entering the threshold quantity in TRI-MEweb for each chemical. TRI-MEweb will indicate for which chemicals TRI regulatory thresholds ha ve been exceeded (0.25 min/0.0 hours).Appendix G

4/28/11 G-61 Average Realistic Chemical- Specific Threshold Assessment It is assumed in this analysis that a chemical is typically only involved in one threshold activity at a facility. However, this activity may be a processing, an ot herwise use, or a manufacturing activity. As outlined above, the total time to cal culate the threshold quantity for a chemical involved in a processing activity or an otherwise use is 62.00 minutes or 1.0 hour. There are three different scenarios for calculating the th reshold quantity for a ch emical involved in a manufacturing activity depending on whether th e chemical is intentionally manufactured, a product of combustion, or a reaction by-produc t or impurity (0.5 hours, 1.27 hours, or 0.75 hours, respectively). The average burden of these three methods is 0.8 hours. Since estimates
for intentional manufacture and coincidental ma nufacture of combustion products or reaction byproducts and impurities may not occur with equal fr equency, this average has been rounded up to 1.0 hour. In addition, manufacturing, processing, or otherwise use activities may not occur at the same frequency. Therefore, a more accurate estima te is made if estimates for all three activities are rounded up to the most burdensome. The resulting burden estimates are summarized in
Table 2.

Table 2: Average Chemical-Specific Threshold Assessment Burden Otherwise Use chemical specific threshold quantitative assessment 1.0 technical hour
Processing chemical specific threshold quantitative assessment 1.0 technical hour
Manufacturing chemical specific threshold quantitative assessment 1.0 technical hour
Average burden for quantitative asse ssment of different threshold
activities 1.0 technical hour

Total Realistic Chemical-Specific Threshold Assessment Burden To make a compliance determination, a facility must 1) determine the appropriate threshold activity for each chemical; 2) determine the quantity of chemical used in the threshold activity, and 3) compare the quantity of chemical being used in a threshold activity to TRI regulatory reporting thresholds. As outlined above, it wi ll take a facility 30.0 minutes or 0.5 hours to determine in which threshold activity the chemical is used. On average, 1.0 hour will be required to determine the quantity of chemical be ing used in a threshold activity. Finally, it will take a facility 0.25 minutes or 0.0 ho urs to enter this quantity into TRI-MEweb for comparison with TRI regulatory reporting th resholds. A summation of burden estimates associated with these three activities is presented in Table 3.

Table 3: Total Realistic Chemical-Specific Threshold Assessment Burden

Determine which threshold activit y is occurring 0.5 technical hours
Average quantitative assessment burden 1.0 technical hour
Enter threshold quantity in TRI-MEweb 0.0 technical hours

Total Per Chemical Burden 1.5 technical hoursAppendix G

4/28/11 G-62 2.1.3 Total Realistic First Year Compliance Determination Burden

Total realistic first year compliance determination burden is estimated by summing the facility level compliance determination burdens and th e chemical-specific compliance determination burden across the six chemicals for which a typi cal facility will need to conduct threshold assessments. The estimated total realistic first year compliance determination burden is presented in Table 4.

Table 4: Total Realistic First-Yea r Compliance Determination Burden Facility level burden 4.67 technical hours

6 chemicals x 1.5 hour / chemical 9.0 technical hours

Total 13.67 technical hours

2.2 Realistic Burden – Subsequent Year

In subsequent years it is assumed that NAICS c ode and employee threshold determinations will typically not need to be reassessed, thus no burde n will be incurred. It is also assumed that no new activities are required relativ e to quantitative threshold assessments. Some time is, however, required to review facility activ ities and ensure that no signifi cant changes have occurred.

2.2.1 Facility Level Activities

At the facility level, technical staff will assess facili ty activities and products/mixtures used to determine if there are significant process and/or chemical use changes at the facility requiring modified or new quantitative threshold assessments. As part of this assessment, they will talk to production staff, review operations record s, and review MSDSs (60.00 min/1.0 hour).

Subsequent year burden estimates for complian ce determination activitie s are summarized in
Table 5.

Table 5: Total Realistic Subsequent Year Compliance Determination Burden With No Staff or Process Changes

NAICS Assessment 0.0 technical hours
Employee Threshold 0.0 technical hours
Facility level review of opera tions to determine that there were no significant chemical use and/or process changes 1.0 technical hour

Total 1.0 technical hourAppendix G

4/28/11 G-63 2.3 Summary of Compliance Dete rmination Burden Estimates

Table 6 summarizes the realistic burden estima tes developed in this analysis. Realistic management burden estimates are based on best professional judgment of what is actually occurring at a typical TRI-reporting facility. No clerical burden is provided as it is assumed that a typical facility will be using TRI-MEweb , and that technical staff will conduct the data entry
into TRI-MEweb as part of their efforts.

Table 6: Compliance Determination Unit Burden Hour Estimates
Management Technical Clerical Total Hours

Realistic Estimate – 1 st year 1 13.67 0 14.67
Realistic Estimate – subs year 0.25 1 0 1.25

Current OMB Estimate – 1 st year 4 12 0 16
Current OMB Estimate – subs year 1 3 0 4

3. RULE FAMILIARIZATION

3.1 Realistic Burden Estimate - First Year

To familiarize themselves with the TRI reporting requirements, the typical facility will need to review TRI program content both generally and as applicable to their facility by:

• Reading the Reporting Forms and Inst ructions booklet (600 min/10 hours).

• Reviewing all or selected por tions of relevant EPA TRI guidance documents including:

o Q & A document (120 min/2 hours)

o Industry-specific guidance (if it exists) or most closely applicable (90 min /1.5 hour)

o Electricity Generating Facilities Guidan ce (for fuels use) (30 min/0.5 hours)

o Chemical Specific Guidance(s) (120min/2 hours)

• Attending a training session ( 360 min/6-hour live session or bot h halves of a web-based training).

• Contacting the EPCRA hotline or other informa tion resource for clarifications/facilityspecific determinations (30 min/0.5 hours).

Summing across these activities, the total realis tic first year rule familiarization burden is estimated at 1,350 min/22.5 hours.

3.2 Realistic Burden - Subsequent Year

It is assumed that no rule familiarization will occur in subsequent years. Even with a process change, technical staff will use existing knowledge of the TRI program to determine how TRIAppendix G

4/28/11 G-64 applies to this process change. Table 7 summarizes rule familiarization burden estimates for the first and subsequent years.

Table 7: Rule Familiarization Unit Burden Hour Estimates
Management Technical Clerical Total Hours

Realistic Estimate – 1 st year 1 22.5 0 23.5
Realistic Estimate – subs year 0 0 0 0

Current OMB Estimate – 1 st year 12 22.5 0 34.5
Current OMB Estimate – subs year 0 0 0 0Appendix H

4/28/11

H -1 Peer Review Summary Statem ent with EPA Responses

This technical document underwent peer review to assess the integrity and value of the revised methodology, Ratio-Based Burden Methodology ( RBBM). The reviewers represented academia, industry, and non-profit sect ors with expertise in industrial engineering, social science/public policy, and mathematical methodology (see Table H-1 below). Overall the reviewers were positive, concluding that the methodology changes:

• Are reasonable, appropri ate, and well-supported

• Achieve efficiency, administrative constancy, and transparency

Table H-1: Peer Reviewers Represent a Ra nge of Disciplines and Perspectives

Reviewer Name Organization Sector Representing Jeffrey Burke, BA Executive Director, National
Pollution Prevention
Roundtable (in addition to twenty-plus years experience
as Senior Environmental Scientist with US EPA Region 3) Non-profit/Government

Mark Cohen, PhD Economics Vice President for Research,
Resources for the Future Social Science/Public Policy

Mark Stephan, PhD, Politics,
Associate Professor Associate Professor, Washington State University Social Science/Public Policy, Mathematical Methodology Michael Walls, MBA, JD VP, Regulatory and Technical Affairs, American Chemistry
Council Social Science/Public Policy

Joelie Zak, BS, BA Executive VP of Scientific
Control Laboratories Engineering/Science

Reviewers were asked for overall impressions and assessments of 1) goal attainment, 2) validity and consistent application of methodology decision rules/assumptions, and 3) model maintenance requirements. Beyond these assess ments, EPA requested comments on the merits and methods of survey calibration.

On goal attainment , reviewers generally agreed that the stated goals of simplification, improved internal consistency, and improved transparen cy are met (with only one disagreeing about transparency). Additional perceived benefits included: 1) increased access to burden estimates and 2) better understanding of uncertainti es associated with TRI burden estimates.

Regarding decision rules and assumptions , reviewers consistently agr eed with the internal logic
and conclusions of the Ratio-Based Burden Methodology. However, two noteworthy exceptions
in which one or more reviewers raised concerns : 1) setting the value of for PBT/non-PBT burden equal to one, and 2) holdi ng non-Form burden constant.Appendix H

4/28/11

H -2 In response to EPA’s solicitation for input on survey calibration as a future enhancement, three
out of five reviewers recomm ended this type of enhancement (including one non-industry reviewer). More information is pr ovided in EPA’s response below.

Based on the peer review endorsement, EPA c oncluded that the methodology is sound without need of design changes or major procedural adjustments. Regarding document quality, the body of the report is considered well-written w ith Appendices receiving mixed reviews (although considered very thorough). EPA has revi sed the document, addressing specific questions/critiques of the met hodology and implementing editorial suggestions from peer
reviewers and other sources.

SELECTED REVIEWER COMMENTS AND EPA RESPONSES

While reviewer comments were generally positiv e, EPA believes that responses and additional explanations on several issues ar e justified to ensure that EPA’ s position is clear and to avoid potential misunderstandings.

1. Accuracy Questions Remain on Burden Hours

Review Comments: Although it is beneficial to simplify calculations, there is still a need to validate the burden estimates to be sure they ar e representative of re porter experiences. For example, one reviewer stated, “The measure of the new methodology’s estimate should not be a simple comparison to the estimates gene rated under the prior methodology—the new methodology should return significant improveme nts in the (absolute) estimation of TRI
burden.”

EPA Response : EPA acknowledges that some reviewers (here and in public comment venues) question the credibility of the syst em of factors used to character ize reporting activities, as well as values assigned to those factors. EPA belie ves these bases, as implemented in both the existing and revised methodologies, comply with PRA requirements that burden estimates be provided, “to the extent practicab le.” TRI burden estimates reflec t a reasonable sense of the average conditions and an appropr iate level of specificity. Further, EPA emphasizes that the purpose of TRI burden estimates—and its burden accounting system in general—is to track changes from year to year agai nst an established baseline.

2. PBT Burden—Modeling versus Accounting

Review Comments: Some reviewers are concerned by the methodology’s simplification that sets PBT/non-PBT burden equal to one, due to lack of evidence to quantify an average value representative of the overall re porter population. One reviewer a sserts, “ ...in real life reporting, there is currently extra burden placed on specific PBT chemical TRI filings that does not seem to be accounted for in the existing or new model.” Another states, “ACC does not agree with the conclusion that reporting for PBT and non-PBT s ubstances are similar enough to allow the same unit-burden-hour estimate. PBT reporting as a whol e takes more time than non PBTs, largely due to the de minimis exception not ap plicable to non-PBT substances.”Appendix H

4/28/11

H -3 EPA Response : There are two parts to this response. First and foremost, EPA recognizes the need to distinguish between PBT and non-PBT burden by including a speci fic ratio model for that purpose. At this time, howev er, EPA is unable to specify the va lue of the ratio in the context of RBBM which requires verifiable and in ternally consistent unit burdens. Without substantiating evidence for this type of model a ssertion (see Decision Rules in main report) EPA has decided to implement a default ratio equa l to one, while providing a placeholder for later
revision in the event that additional informati on becomes available. Second, though the value of the ratio is left unspecified, this methodology re vision carries forward ce rtain prior assumptions
so that the net effect of PBT re porting is incorporated in overall totals. Specifically, the previous calculation’s effects of a higher PBT unit burden for 20% of chemicals are rolled up into the new unit burden ( Nominal Form R unit burden ). In back-calculating this base number of 35.7 hours per Form R, the unit burden reflects overall aver age conditions, and is elevated above the value that would have been otherwise obtained—at about 30 hours/form—had only non-PBT burden
been used to determine Nominal Form R unit burden . An important note on RBBM and its benefits: the simplified comprehensive Nominal Form R unit burden plus the A/R model (which links to Form A unit burden) provides a focal point for burden-estimate discussions, reducing confusion associated with keeping up with a dditional unit burdens and chemical counts from multiple subpopulations.

3. Survey Calibration Enhancement

Review Comments: Three out of five reviewers recomm end enhancement via some form of survey calibration. Of these thr ee, the two industry reviewers ma ke their recommendations based on 1) concerns that the burden estimates are ge nerally too low and 2) the need to measure a distinction between PBT and non-PBT reporting burden. The third supporter does not see the need, but admits that pressure from any part y would merit survey calibration. One of the nonsupporters does not recommend surv ey calibration for this applica tion, but stresses that EPA is not correctly focused on the purpos e of survey calibration. This re viewer states that the purpose of survey calibrated burden estimates is to de termine if data elements should be dropped or altered (i.e., consider cost of the in formation compared to its value).

EPA Response: EPA appreciates the thoughtfulness and thoroughness of the reviewers’ comments on survey calibration. At this time, and as stated above, EPA believes the current bases comply with PRA requirements for reasonabl e estimates. In addition to increased Agency effort, EPA is concerned about imposing additional burden on the reporting community to participate in a survey designed for the purposes of calibrating burden estimates.

4. DIOXIN (and Form R Schedule 1) Burden Not Included

Review Comment: The revised methodology does not address Dioxin reporting (implemented in 2007) and the burden contribu tions from Form R Schedule 1.

EPA Response: At the time of the calculations for the revised methodology, conditions are those of the 2008 ICR. As such, the Form R Schedule 1 requirement was not in place. Subsequently, the addition of Form R Schedul e 1 reporting is estimated in the Supporting Statement of the 2012 ICR Renewal, using the techniques of RBBM’s Form Element EstimationAppendix H

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H -4 (in Appendix C). Note, however, that the impact of Schedule 1 burden on total Form R burden is very small (.00516 hours overall per Form R).

5. Weighted Average Wage Rate (WAWR) of $51 Seems Low

Review Comment: According to one reviewer “In genera l the weighted average wage rate of $51 seems low given the engineering and manageri al expertise required. We are aware that in similar (and admittedly less complicated) analyses conducted in other areas, the 90th percentile would be used and adjusted upward by 40 percent to get to a more accurate representation of non-wage compensation. In addition, with electron ic data entry and submittal, there may well not be any appreciable clerical involvement with TR I reporting. The use of the clerical wage level also results in an average wa ge rate that is too low.”

EPA Response : The WAWR is based on statistics gene rated by the US Department of Labor Bureau of Labor Statistics (B LS) and includes non-wage compen sation. As shown in the table below, EPA uses the average wage rate a nd adjusts upward by 60.40% (in this June 2010 example) to incorporate non-wage compensatio n. EPA’s WAWR method weights each category of management, technical, and clerical labor according to th e proportional contribution (.03, .89, and .08 respectively) as defined in Appendix E based on the Abt A ssociates Engineering Studies. The value of $51 reflects these analytical decisions for September 2009 conditions using a method whereby wage rates are updated to curren t dollars using the empl oyment cost index (no longer used in RBBM). Applying the current version of RBBM and June 2010 conditions, the result of $49.62/hr is obtained. Further detail is provided in the table below.

Table H-2: Derivation of the Weig hted Average Wage Rate (WAWR) (June 2010) Wage Type (Burden Proportion) Managerial (.03) Technical (.89) Clerical (.08) WAWR Composite

Occupational Type Management, business,
and financial Professional and
related Office and
administrative support WAWR $/hr

Wages and Salaries $38.84 $32.73 $15.75

Total benefits $16.85 $13.08 $6.81

Overhead $6.60 $5.56 $2.68

Total Loaded Rate $62.29 $51.37 $25.24

WAWR Contribution 1.87 45.72 2.02 49.62 Based on June 2010 wage data. http://www.bls.gov/ncs/ect/#tables

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