TOXICS RELEASE INVENTORY 

TRI FORM R AND FORM A 

TOXIC CHEMICAL RELEASE REPORTING 

INFORMATION COLLECTION REQUEST 

SUPPORTING STATEMENT 

OMB CONTROL NO. 2025-0009 

EPA ICR #1363.21 

February 8, 2010 

1 IDENTIFICATION OF THE INFORMATION COLLECTION ...............................................3 

1(a) Title of the Information Collection .......................................................................................3 

1(b) Short Characterization/Abstract ............................................................................................3 

2 NEED FOR AND USE OF THE COLLECTION ......................................................................5 

2(a) Need/Authority for the Collection ........................................................................................5 

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

3 NONDUPLICATION, CONSULTATIONS, OTHER COLLECTION CRITERIA ...................8 

3(a) Nonduplication .......................................................................................................................8 

3(b) Public Notice Required Prior to ICR Submission to OMB .................................................13 

3(c) Consultations ........................................................................................................................13 

3(d) Effects of Less Frequent Collection ......................................................................................13 

3(e) General Guidelines ...................................................................................................................14 

3(f) Confidentiality ......................................................................................................................14 

3(g) Sensitive Questions ..............................................................................................................15 

4 THE RESPONDENTS AND THE INFORMATION REQUESTED .......................................15 

4(a) Respondents/NAICS Codes ..................................................................................................15 

4(b) Information Requested .........................................................................................................15 

5 THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT ................................................19 

5(a) Agency Activities .................................................................................................................19 

5(b) Collection Methodology and Management ...........................................................................22 

5(c) Small Entity Flexibility .........................................................................................................22 

5(d) Collection Schedule ..............................................................................................................23 

6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION ...................................23 

6(a) Estimating Respondent Burden ............................................................................................25 

6(b) Estimating Respondent Costs ..............................................................................................35 

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6(c) Estimating Agency Burden and Cost ...................................................................................37 

6(d) Estimating the Respondent Universe and Total Burden and Costs ........................................38 

6(e) Bottom Line Burden Hours and Cost Tables ........................................................................40 

6(f) Reasons for Change in Burden .............................................................................................42 

6(g) Burden Statement ................................................................................................................45 

APPENDICES 

Appendix A: Blank Form R, Form A, and Form R Schedule 1 

Appendix B: Reporting Form Instructions Associated with Form Changes 

Appendix C: Information Sources Containing Data Subsets, but not Comprehensively Comparable 

Alternatives to TRI 

Appendix D: TRI Consultation Meetings 

Appendix E: Facilities Required to Report to TRI (NAICS) 
 

 

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1 IDENTIFICATION OF THE INFORMATION COLLECTION 

1(a) Title of the Information Collection 

TITLE: Toxics Release Inventory (TRI) Form R and Form A Toxic 

Chemical Release Reporting, Recordkeeping, Supplier 

Notification and Petitions under Section 313 of the Emergency 

Planning and Community Right-to-Know Act 

EPA ICR No.: 1363.23 

OMB Control No.: 2025-0009 

1(b) Short Characterization/Abstract 

This Information Collection Request (ICR) is for the information collection requirements 

associated with EPA’s Toxics Release Inventory (TRI) Program. Pursuant to section 313 of 

EPCRA, certain facilities that manufacture, process, or otherwise use specified toxic chemicals in 

amounts above reporting threshold levels must submit annually to EPA and to designated State 

officials toxic chemical release forms containing information specified by EPA. 42 U.S.C. 11023. 

In addition, pursuant to section 6607 of the Pollution Prevention Act (PPA), facilities reporting 

under section 313 of EPCRA must also report pollution prevention and waste management data, 

including recycling information, for such chemicals. 42 U.S.C. 13106. These reports are compiled 

and stored in EPA’s database known as the Toxics Release Inventory (TRI), and the TRI data are 

made readily available to the public.1

 

Currently, facilities subject to the TRI reporting requirements may use either the EPA Toxics 

Release Inventory Form R (EPA Form #9350-1), or, if they meet alternate threshold requirements, 

the EPA Toxics Release Inventory Form A Certification Statement2 (or simply referred to as 

“Form A” - EPA Form #9350-2). With Form R, one chemical is reported per form; with Form A, 

multiple chemicals may be reported per form.3

 

In the past, EPA has issued separate ICRs: 1) EPA ICR No. 1363.21, OMB Control No. 2025-

0009 (TRI Form R) and 2) EPA ICR No. 1704.13, OMB Control No. 2025-0010 for Form R and 

for Form A reporting, respectively. In this ICR Renewal, EPA is transitioning from issuing two 

separate ICRs to issuing a single ICR—EPA ICR No. 1363.21, OMB Control No. 2025-0009 that 

encompasses both Form R and Form A. Additionally, in this Renewal, EPA is proposing revisions 

1

 Certain sectors are subject to TRI reporting. For a complete listing of the North American Industry Classification 

System (NAICS) codes subject to TRI reporting see Appendix E of this ICR Supporting Statement. 

2

 The Form A submission requires a Certification Statement confirming that the sum of amounts of the chemical in 

releases and waste does not exceed the appropriate Non-PBT release and waste annual reportable amounts for that 

reporting year (see Form A in Appendix A for Statement details). 

3

 Refer to Appendix A of this Supporting Statement for a blank Form R and Form A. For the full set of instructions 

and Forms, refer to http://www.epa.gov/tri/report/#forms. 
 

 

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to the Form R and Form A to standardize responses and enhance data utility. More specifically, the 

proposed changes to the forms and TRI Reporting Forms and Instructions (RFI) are:4

 Remove the NA box from Parent Company field (Form R/A- Part I: Sec. 5, 5.1) 

 Disaggregate the “Total Transfers” field and add fields to identify the chemical discharge 

quantities to specific publicly owned treatment works (POTWs) (Form R- Part II: Sec. 6.1) 

 Form R- Part II: Sec. 8.10, 8.10.1-4) 

 Section 8 Enhancements: 

o Change instructional statement on form to include “newly implemented and/or 

ongoing" source reduction activities (Form R- Part II: Sec. 8.10) 

o Add an “NA” box to match associated text revisions(Form R- Part II: Sec. 8.10) 

o Add a field to allow separate reporting for both new and ongoing source reduction 

activities (Form R- Part II: Sec. 8.10, 8.10.1-4) 

o Remove Yes box and enlarge the text section for the question on optional pollution 

prevention information (Form R- Part II: Sec. 8.11) 

 Add an new question to capture miscellaneous and optional information regarding the 

submission (Form R- Part II: Sec.9, 9.1) 

 Add NA boxes to improve consistency in the form (Form R/Form R Schedule 1- Sec. 5.3, 

6.1, 6.2) 

Pursuant to EPCRA §313 (and PPA §6607 because of its linkage to EPCRA), EPA's Office of 

Environmental Information (OEI) collects, processes, and makes available to the public all of the 

information collected. The information gathered under these authorities is stored in a database 

maintained at EPA and is available through the Internet. EPA; other federal, state, and local 

government agencies; industry; and the public use TRI extensively. Program offices within EPA 

and other government agencies have used TRI, along with other sources of data, to establish 

priorities, evaluate potential exposure scenarios, and conduct enforcement activities. Industries use 

TRI data to identify pollution prevention opportunities and set goals for emissions reductions. 

Environmental and public interest groups use TRI data to make the public more aware of releases 

of chemicals in their communities, as well as to initiate direct negotiation and risk reduction with 

facilities. 

EPA has developed EPA Information Quality Guidelines to ensure the utility, objectivity, and 

integrity of information that is disseminated by the Agency. The information supporting this ICR 

is consistent with all appropriate EPA policies, including EPA's Information Quality Guidelines. 

In particular, the EPA Agency-wide quality system helps ensure that EPA organizations maximize 

the quality of information disseminated by the Agency. The quality system is documented in EPA 

Order 5360.1 A2, Policy and Program Requirements for the Mandatory Agency-wide Quality 

System and the EPA CIO Policy 2106.0 US Environmental Policy: Quality Policy Oct 2008. 

An updated Procedure for Quality Policy was published in October 2008.5

 The information 

supporting this action is also consistent with EPA's Guide to Writing Information Collection 

Requests Under the Paperwork Reduction Act of 1995, revised November 2005. It is EPA's 

4

 For additional details, refer to Appendix A: Blank Form R, Form R Schedule 1, and Form A, and Appendix B:

Reporting Form Instructions Associated with Form Changes. 

5

 US Environmental Protection Agency. Procedure for Quality Policy. CIO 2106-P-0.10. October 20, 2008. 
 

 

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intention that collection of information under this ICR will result in information that will be 

collected, maintained, and used in ways consistent with both EPA's Information Quality 

Guidelines and the OMB Information Quality Guidelines.6

The TRI data are unique in providing a multi-media (air, water, and land) picture of toxic 

chemical releases, transfers, and other waste management activities by covered facilities on a 

yearly basis. With a centralized database and electronic data access tools, TRI provides a wide 

range of capabilities for a variety of users. Communities and governments can access the 

identities and quantities of listed toxic chemicals that many industrial facilities in their area 

release, transfer, or otherwise manage as waste. In addition, industries can use TRI as a tool for 

evaluating efficiency and progress on their pollution prevention goals. 

OMB last approved ICRs for Form R and Form A separately on March 2, 2008, with an 

expiration date of July 31, 2011. The ICRs approved at that time reflected a total program 

reporting burden projection of 76,986 responses, 3.72 million hours and $186 million for Form R 

and Form A respondents. In this ICR Renewal, the effect of the interim changes via rulemakings 

(see Figure 2 on p. 43 for TRI Rulemaking and ICR Chronology), as well as other changes in 

conditions that have gradually shifted the number of Form R and/or Form A chemical reports 

downward are incorporated. EPA projects total responses, burden, and cost of Form R and Form 

A reporting at 73,727 responses, 3.52 million hours and $174.5 million. Further, the TRI 

program is proposing to revise data elements and instructions for the reporting forms. The 

revised data elements and instructions are estimated to have a negligible impact on form burden. 

The time required to complete all activities associated with Form R completion (rule 

familiarization, reporter compliance determination, calculations, form completion, and 

recordkeeping) is estimated to average 35.70516 hours per Form R (including all proposed form 

changes). By comparison, this same burden is estimated to average 21.95867 hours for facilities 

submitting a Form A for a single listed chemical (all estimates incorporate proposed changes). 

Thus, for a facility filing a Form A instead of Form R for a single listed chemical, according to 

EPA’s TRI burden methodology, the alternate threshold yields an average savings of 13.7 hours 

per chemical. 

2 NEED FOR AND USE OF THE COLLECTION 

 2(a) Need/Authority for the Collection 

This information collection activity is a statutory requirement pursuant to EPCRA §313 

(42 U.S.C. 11001 et seq.) and PPA §6607 (42 U.S.C. 11071 to 11079). According to EPCRA 

§313(h), the data submitted in the forms are intended to "inform persons about releases of toxic 

chemicals to the environment; to assist governmental agencies, researchers, and other persons in 

6

 The Office of Management and Budget publishes these guidelines in accordance with the Guidelines for Ensuring 

and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies 

(Government-wide Guidelines) published in interim final form by OMB in the Federal Register in Volume 66, No. 

189 at 49718 on September 28, 2001, and updated in final form in Volume 2, No. 67 at 8452 on February 22, 2002. 
 

 

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the conduct of research and data gathering; to aid in the development of appropriate regulations, 

guidelines, and standards; and for other similar purposes." 

Section 6602 of the PPA establishes a national policy that pollution should be prevented or 

reduced at the source whenever feasible. To further this goal, EPA is to establish a source 

reduction program that collects and disseminates information, among other responsibilities. The 

information collected under §6607 is intended to fulfill that responsibility in part and to provide a 

basis for measuring progress in pollution prevention in certain industrial groups. 

EPA’s regulations implementing TRI reporting are codified at 40 CFR part 372. Each covered 

facility must report on each listed chemical manufactured, processed or otherwise used in excess 

of the reporting thresholds established in EPCRA §313(f)(1). EPA established an alternate 

threshold7

 under EPCRA §313(f)(2) for a category of facilities with low amounts of a listed toxic 

chemical in wastes. 

A facility that chooses to apply the alternate threshold submits an EPA Toxics Release Inventory 

Form A instead of a Form R. Note that a Form A may contain multiple chemicals. The information 

collected on the Form R, or alternatively on the shorter Form A, fulfills EPA’s responsibilities 

under EPCRA §313(f)(2). Regarding Form A, although both forms address the statutory mandates 

and the public's right-to-know, Form A allows regulatory relief for facilities with lower amounts of 

listed toxic chemicals in wastes. Table 1 summarizes the information collected by form. 

Table 1 

Form R and Form A Information Collection 

Information Collected Form R Form A 

Location of facilities manufacturing, processing or otherwise using these chemicals √ √

Demonstrations that the chemicals are being manufactured, processed or otherwise 

used at current reporting thresholds √ √

Certification that the sum of amounts of the chemical in releases and waste did not 

exceed the appropriate Non-PBT or PBT (lead in stainless steel, brass, or bronze alloy) 

release and waste annual reportable amounts for that reporting year 

√

Accounting of quantities of chemicals entering environmental mediums on site √

Disclosure of chemical transfers to offsite locations √

Description of onsite waste treatment, energy recovery, and recycling processes √

Accounting of other disposal, source reduction and recycling activities √

Additional optional information on source reduction, recycling and pollution control 

activities √

The requirement for Form A submission fosters continued attention to chemical management 

practices and provides important facility identification information. With a Form A, EPA and the 

 

7 EPA has authority to revise the threshold amounts pursuant to EPCRA §313(f)(2) provided that revised threshold 

amounts still result in reporting on a substantial majority of total releases of the chemical at all facilities subject to 

EPCRA §313. A revised threshold may be based on classes of chemicals or categories of facilities.
 

 

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general public receive a specific indication annually that a facility has a certain chemical; 

however, with the facility able to use the alternate threshold, reporting is less extensive. 

 2(b) Practical Utility/Users of the Data 

The overall goal of the Toxics Release Inventory Program is to provide communities with 

information about toxic chemical releases and other waste management activities and to support 

informed decision making at all levels by industry, government, non-governmental organizations, 

and the public.8

 The Program’s success is due, in large part, to the right-to-know provisions 

contained in the legislation. By requiring that the resulting data be made publicly available "by 

electronic and other means," Congress ensured that the general public, the media, environmental 

advocates, researchers, the business community, and others could evaluate and influence industry's 

efforts to manage toxic emissions. Consequently, data collected under EPCRA §313 and PPA 

§6607 are made available through access tools such as EPA's Envirofacts, TRI Explorer, 

TRI.NET, and the web-enabled mobile myRTK. TRI now provides the TRI Preliminary Dataset 

within weeks after the annual July 1st TRI reporting deadline. The release consists of 

downloadable files on the TRI Web site (with links from Data.gov), as well as updated online data 

access tools (Envirofacts and TRI Explorer). The annual TRI National Analysis and the final 

dataset used for that analysis are generally made available within six months after the reporting 

deadline. 

In addition to providing information to the public via electronic means, EPA also conducts 

outreach activities to make key groups and the public aware of TRI. Libraries in communities all 

across the United States (in particular, members of the Federal Depository Library Program) are 

committed to providing public access to TRI data. TRI data are used by environmental agencies, 

industry, and the public. EPA program offices use TRI data, along with other data, to help 

establish programmatic priorities, evaluate potential hazards to human health and the natural 

environment, and undertake appropriate regulatory and/or enforcement activities. Environmental 

and public interest groups use the data to better understand toxic chemical releases at the 

community level and to work with industry, government agencies, and others to promote 

reductions in toxic chemical releases. Industrial facilities use the TRI data to evaluate the 

efficiency of their production processes and to help track and communicate their progress in 

achieving pollution prevention goals. States use the TRI data to compare toxic chemical releases 

and other waste management approaches within specific industries and to set environmental 

priorities at the state level. EPA encourages TRI data users to provide feedback on ways to 

improve TRI products and services. 

8

 U.S. EPA Toxics Release Inventory Program. http://www.epa.gov/tri/ 
 

 

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3 NONDUPLICATION, CONSULTATIONS, OTHER COLLECTION CRITERIA 

3(a) Nonduplication 

The basic information requested on Form R/Form A is required to be reported by law. Other 

statutes, however, also necessitate the reporting of information about releases of chemicals to the 

environment, as well as transfers, treatment, and source reduction and recycling activities, creating 

the possibility of overlap or duplication of reporting requirements. EPA anticipates some overlap 

and acknowledges that respondents may use readily available data collected pursuant to other 

provisions of law to complete the EPCRA §313 reports. However, information required by these 

other statutes may not provide readily accessible multi-media release and transfer, inventory, or 

pollution prevention data with the same scope, level of detail, chemical coverage, and frequency of 

collection as data currently included in TRI. 

TRI contains information on releases, transfers, inventories, and pollution prevention activities for 

593 individually listed chemicals and 30 chemical categories—with total number of chemicals and 

chemical categories at 682. The recent rule adding 16 National Toxicology Program (NTP) 

chemicals (effective RY 2011)9 increases the number of individually listed chemicals by 12 (from 

581) and adds 4 chemicals to the Polycyclic Aromatic Compounds (PAC) category. EPA is not 

aware of national databases that are comparable to the whole of TRI; however, several existing 

data sources contain media-specific data on releases and transfers. In theory, information from 

these databases could be combined to form an analog of release and transfer data contained in TRI. 

However, in practice, given the currently available data sources (see Table 2 in next section and 

Appendix C), this substitution is extremely unlikely. For example, there are differences in 

chemical coverage and facility coverage, as well as differences in the level of public access, 

reporting frequencies, and the integration of data from various sources at the facility level. The 

following sections describe other sources of chemical releases and transfers, chemical inventory, 

and pollution prevention data. 

Chemical Release and Transfer Data 

Table 2 presents a summary of major databases containing release and transfer data that are 

discussed in this section. Appendix C provides a comprehensive list of relevant data sources. 

9

Addition of National Toxicology Program Carcinogens; Community Right-to-Know Toxic Chemical Release 

Reporting Final Rule. 40 CFR Part 372. EPA Docket ID Number EPA-HQ-TRI-2010-0006. Federal Register Vol. 75 

No. 227. November 26, 1010. 
 

 

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Table 2

Major Release and Transfer Databases 

Data Source Media and Chemical 

Coverage 

Relevant Release 

Statistics Available 

Ease of Database 

Substitution for TRI Dataa 

National 

Emissions 

Inventory (NEI) 

Contains annual emissions 

of 6 criteria air pollutants 

(CAPs) and 189 hazardous 

air pollutants (HAPs) for 

facilities above reporting 

thresholds. 

Total annual releases. Includes air releases only. Data

are updated only every 3 years. 

Coverage of TRI chemicals is 

limited. 

Permit 

Compliance 

System (PCS) 

Contains monthly discharge 

monitoring data for selected 

water pollutants and flow 

rates for major sources. 

Concentration data; 

total annual releases 

(can be calculated); 

average daily releases, 

maximum “moment” if 

continuous monitoring.

Includes only chemicals for 

which a discharge limit has 

been set. Difficult to link 

between PCS parameters and a 

Chemical Abstract Service 

(CAS) number. Very limited 

monitoring data for minor 

dischargers. 

Biennial 

Reporting System 

(BRS) 

Contains waste volumes by 

Resource Conservation and 

Recovery Act (RCRA) 

waste code reported 

biennially. 

Total annual off-site 

transfers of hazardous 

waste for land disposal; 

total annual releases to 

publicly owned 

treatment works 

(POTWs). 

Many RCRA waste codes are 

not specific to an individual 

CAS number. Quantities of 

chemicals in waste cannot be 

determined. Portion of waste 

stream matching each waste 

code cannot be determined. 

a “Ease of substitution” refers only to the potential of the information in the database to substitute for TRI 

reporting. It does not imply that the database is not adequate for the purposes for which it was designed.

Air Releases 

The 1990 amendments to the Clean Air Act require EPA to monitor and regulate the emissions of 

criteria air pollutants (CAPs) and hazardous air pollutants (HAPs). EPA is required to identify the 

sources of these pollutants, quantify the sources by category, develop regulations, and then assess 

public health and environmental impacts. To facilitate this process, two emissions inventories were 

created: the National Toxics Inventory (NTI) for HAPs and the National Emission Trends (NET) 

for CAPs. These two databases were combined in 1999 to form the National Emissions Inventory 

(NEI) database. 

NEI is EPA's compilation of estimates of air pollutants discharged on an annual basis and their 

sources. NEI data are organized into four main categories: point sources (stationary), nonpoint 

sources (stationary), on-road sources (mobile), and non-road sources (mobile). The compilation 

includes emissions estimates submitted by state, local and tribal air pollution control agencies, 

estimates calculated by EPA, and emissions obtained from other sources. It may include multiple 

emissions values for each pollutant. From the NEI, EPA creates the General Purpose Release, the 

publicly available emissions inventory that contains a single emission value for each pollutant at a 
 

 

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given source. EPA uses the NEI to track emissions trends over time, develop regional pollutant 

reduction strategies, set and analyze regulations, perform air toxics risk assessments including 

inhalation risks and multi-pathway exposure, model air pollutant dispersion and deposition, and 

measure environmental performance as required by the Government Performance and Results Act. 

Since 1996, EPA has compiled the NEI every three years. For 2008, the NEI business process was 

reengineered to shorten the period between the inventory year in which data were collected and 

publication. The most recent inventory is the 2005 NEI, which was published in 2008. 

There are a number of differences in the scope of NEI and TRI data, including the type and 

number of pollutants measured, the industrial sectors included in the inventory, and the type of 

information collected (e.g.. which environmental media releases are measured and what other 

release or management-specific information is collected). TRI includes 593 individually listed 

chemicals and 30 chemical categories—with the total number of chemicals and chemical categories 

at 682. The recent rule adding 16 NTP chemicals (effective RY 2011) increases the number of 

individually listed chemicals by 12 (from 581) and adds 4 chemicals to the PAC category. To be 

included in TRI, a chemical must be known or reasonably anticipated to cause acute or chronic 

health effects or significant adverse environmental effects. NEI covers 5 Criteria Air Pollutants 

(CAPs) and 189 Hazardous Air Pollutants (HAPs), 183 of which are also covered by TRI. Among 

industrial sources of chemical releases, only manufacturing facilities, federal facilities, and seven 

sectors added to the TRI Program in 1998 (metal mining, coal mining, fossil-fuel fired electric 

utilities, chemical wholesale distributors, petroleum terminals, and hazardous waste treatment and 

solvent recovery) are required to report chemical releases to TRI. The NEI, which covers all 

sources of CAP and HAP emissions, includes a number of sectors that are not included in TRI. For 

example, the agriculture, oil extraction and construction sectors are all included in NEI, but not 

TRI. In addition to point-source emissions estimates from industrial facilities, NEI includes 

county-level emissions estimates for area, mobile and other sources. 

The sources included in TRI and NEI are further limited by various reporting thresholds. In 

addition to the sector criteria, a facility must report to TRI only if it has 10 or more full-time 

employee equivalents and manufactures, processes or otherwise uses any TRI-listed chemical in 

quantities greater than the established threshold. The most common reporting threshold quantities 

are 25,000 pounds for manufacturing and processing and 10,000 pounds for otherwise use. PBT 

chemicals have lower thresholds for reporting to TRI. For HAPs, under NEI, a facility must be 

included in the point source inventory if it has the potential to emit 10 or more tons per year of one 

HAP or 25 tons per year or more of any combination of HAPs. Information captured by TRI 

differs from that captured by NEI on a number of counts. TRI includes multimedia data about 

chemical releases. Unlike NEI, TRI includes data about activities such as surface water 

discharges, underground injection, and landfill disposal of toxic chemicals. It also includes source 

reduction and waste management data, which can be used to assess pollution prevention trends on 

a facility basis. NEI focuses entirely on air emissions, but provides much more detailed emission 

source-specific data about releases, such as process descriptions, throughput and stack height. The 

different information captured by the data systems largely reflects the different goals behind the 

development of the inventories. TRI’s main purpose is to provide the public with information 
 

 

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about potential chemical hazards, whereas NEI was developed to produce data that would support 

modeling and risk assessment needs. 

Water Discharges 

The Permit Compliance System (PCS) tracks the permit compliance and enforcement status of 

facilities that discharge to surface waters (http://www.epa.gov/enviro/html/pcs). For entities 

permitted to discharge wastewater into navigable waters, PCS contains information on permit 

issuance and expiration dates, quantities the company is permitted to discharge, and the actual 

monitoring data showing what the company has discharged. PCS data are not directly 

comparable to TRI data because PCS is a permit tracking system and not a loadings system. 

Thus, PCS typically contains data on monthly monitoring of pollutant concentrations and flow, 

and not total releases. Since monitoring required by the National Pollutant Discharge 

Elimination System (NPDES) covers only selected chemicals in the wastewater, PCS contains 

data on a very limited number of the TRI chemicals. PCS has been modernized to the Integrated 

Compliance Information System (ICIS) as ICIS-NPDES. 

Waste Disposal 

Under the Resource Conservation and Recovery Act (RCRA), large quantity generators and 

treatment storage and disposal facilities are required to submit information on the generation, 

management, and final disposition of RCRA-defined hazardous wastes. Every two years, filers 

must report the following information about each waste generated or managed in the preceding 

year: constituent waste codes; amounts generated; on- and off-site treatment, storage, and 

management; wastes received; and off-site shipment recipients. Facilities submit these biennial 

Hazardous Waste Reports to the state or EPA Regional office. The biennial reports (BR) include 

one year’s data (e.g., 2009 Biennial Report reflects data on waste management during 2009) and 

are stored centrally in EPA’s RCRAInfo system where they are available approximately two years 

after the covered year (http://www.epa.gov/epaoswer/hazwaste/data/biennialreport/index.htm). 

Biennial Reporting System (BRS) data do not duplicate the information contained within TRI, as: 

(1) hazardous waste codes do not necessarily map to unique chemicals; (2) quantities of specific 

chemicals in the waste stream cannot be determined; (3) reporting occurs every other year, as 

opposed to annually for TRI; and (4) data are not available to the public until two years after 

reporting. 

Chemical Inventory Data 

TRI also contains inventory data, which make up a small portion of the total data. The most likely 

alternatives for TRI inventory data are the Tier I/II data reported under EPCRA §312. Under 

EPCRA §312, regulated facilities must submit annual inventory reports of hazardous chemicals 

stored on-site to the state. Tier I requires reporting on broad categories of physical hazards, while 

Tier II requires chemical-specific information by CAS number. The information contained in the 

Tier I and Tier II reports surpasses the chemical inventory data requested on TRI Form R in terms 

of the chemicals covered and level of detail. However, there are significant difficulties associated 
 

 

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with public access of Tier I and Tier II data, including the lack of a nationally integrated database 

and restrictions on public access due to security concerns. 

Under §112(r) of the Clean Air Act, facilities with processes that use or store more than a specified 

amount of certain flammable and toxic substances are required to develop and implement a risk 

management program and submit to EPA a summary of their program—called a Risk 

Management Plan (RMP). These plans include the amounts (in pounds) of each substance that are 

processed or used, hazard assessments of the potential effects of hypothetical accident scenarios, a 

five-year history of accidental releases involving regulated substances at the facility, and 

information about the facility’s accident prevention and emergency response programs. Facilities 

with processes that use or store more than a threshold amount (500–20,000 pounds) of a listed 

chemical must file an RMP and update their filing at specified times, including following a 

significant accidental release. TRI data do not duplicate RMP data as: (1) RMP covers 54 of the 

TRI chemical and chemical compound categories,10 (2) some RMP data are considered to be 

confidential business information (CBI) and are therefore not publically available; and (3) 

reporting occurs every five years, as opposed to annually for TRI.11

Pollution Prevention Data 

In addition to release/transfer and inventory data, TRI also collects pollution prevention data from 

reporting facilities. Pollution prevention data somewhat analogous to data in TRI can be found in 

the Biennial Hazardous Waste Reports (described above) and in databases for two states 

administered by their state environmental agencies. While BR data provide qualitative and 

quantitative pollution prevention information, facility and/or chemical coverage is not directly 

comparable to data required for TRI reporting. BR contains data on generation, transfer, and 

management of hazardous wastes; TRI reporting requires data on toxic chemicals in waste streams 

or process by-products (all production phases and media). Furthermore, no other federal (or state) 

program collects all of the pollution prevention data currently required by TRI. 

In Appendix C, data elements available from several information sources are compared to those 

reported to TRI. The analysis is broken down by the specific types of data collected under TRI. 

While Appendix C displays sources that might appear to be substitutes for TRI, they do not 

adequately address the entire scope of TRI, even in combination. For example, a given source 

may: 

 not include all toxic chemicals covered by TRI, 

 be compiled less frequently than TRI, and/or 

 not be as easily accessible (if at all) to the general public. 

10 http://www.epa.gov/osweroe1/docs/chem/list_of_lists_05_07_10.xls 

11 http://www.epa.gov/oem/docs/chem/Chap-09-final.pdf 
 

 

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

EPA is planning to submit one combined request to renew existing approved ICRs for both 

Form R and Form A to OMB. Both ICRs are scheduled to expire on July 31, 2011. Before 

submitting the combined ICR to OMB for review and approval, EPA is soliciting comments 

on specific aspects of the proposed information collection. A Federal Register Notice is being 

published to announce this renewal request and the availability of this Supporting Statement 

for review by the public. 

3(c) Consultations 

EPA has consulted with a large number of individuals and organizations throughout all segments 

of the public in the development and continued implementation of the TRI Program. EPA has 

received feedback from environmental and public interest groups, trade associations, educational 

institutions, individual representatives, and others through its outreach efforts in venues such as: 

 meetings with stakeholders to provide TRI program updates and obtain input on 

rulemakings; 

 on-line dialogues to discuss issues such as options for reporting burden reduction; 

 Webinars to provide training on various topics, including expanding the use of TRI for 

environmental justice; and 

 the TRI National Training Conference, held every 18 months. 

For more specific information on meetings and organizations consulted, see Appendix D. EPA 

continually seeks this feedback and incorporates it into the ongoing evolution of the TRI Program. 

3(d) Effects of Less Frequent Collection 

Section 313 requires annual reporting. Section 313(i) permits EPA to modify the reporting 

frequency by rulemaking; however, EPA must first notify Congress and then delay the 

initiation of such a rulemaking for at least 12 months, but no more than 24 months, from the 

date of the notification. In addition, EPA must find: that the modification is consistent with the 

provisions of subsection (h) of [§313] based on - 

(i) experience from previously submitted toxic chemical release forms 

(ii) determinations made under paragraph (3). 

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

(A)The extent to which information relating to the proposed modification provided on 

the toxic chemical release forms has been used by the Administrator or other 

agencies of the federal government, states, local governments, health professionals 

and the public. 
 

 

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(B) The extent to which information is (i) readily available to potential users from other 

sources, such as state reporting programs, and (ii) provided to the Administrator under 

another federal law or through a state program. 

(C) The extent to which the modification would impose additional and unreasonable 

burdens on facilities subject to the reporting requirements under this section. 

Since TRI represents the best available multi-media database for tracking toxic chemical releases 

in the United States, a change in the reporting frequency to less than once a year could have a 

significant impact on the availability of timely toxic chemical data and affect data users, 

particularly at the community level. Additionally, public access to the most current toxic chemical 

release data and other waste management information would become more difficult. 

3(e) General Guidelines 

This ICR adheres to the guidelines stated in the 1995 Paperwork Reduction Act, as amended, 

OMB's implementing regulations, and all applicable OMB guidance. 

Although reporting facilities are required to identify the chemical for which reports are 

submitted, they can claim the chemical identity as a trade secret. In such circumstances, a 

generic name is provided as part of the information made available to the public. EPA 

securely stores and maintains the true identity of the chemical (see also Section 3(f)). 

EPA continues to encourage the electronic submission of TRI Form R/Form A through the 

Internet via EPA’s Central Data Exchange (CDX) by using the Toxics Release Inventory Made 

Easy Web (TRI-MEweb) reporting software. TRI-MEweb helps facilities prepare high-quality 

reports more easily than they could using paper reporting forms due to a number of technology 

advances, including built-in data quality checks. 

Small facilities (with fewer than 10 full-time employees or the equivalent) are exempt from 

reporting under EPCRA §313. Two particular provisions that apply to TRI reporters universally: 

1) the optional range reporting provision 12 and 2) an alternate threshold allowing Form A 

eligibility, are particularly beneficial to non-exempt smaller facilities with small releases and 

wastes. 

3(f) Confidentiality 

Respondents may designate the specific chemical identity of a substance as a trade secret 

according to EPCRA §322. Procedures for submission and review of trade secret claims under 

EPCRA §313 are set forth in 40 CFR 350. When a facility claims the chemical identity to be a 

12 Range reporting provides an option for releases of less than 1,000 pounds to be recorded as a code representing 

one of three ranges (1 to 10 pounds, 11 to 499 pounds, or 500 to 999 pounds) rather than as a specific estimate of 

the release amount. Range reporting is not permitted on Form Rs for PBT chemicals. For further discussion, see 

Section 5(c). 
 

 

ICR 1st FR Notice 2/08/11 

 

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trade secret and properly substantiates the claim, EPA will not disclose the identity of the 

chemical to the public. EPA securely stores forms with trade secret information and allows 

access to those documents only to persons with Trade Secret clearance. Data made available to 

the public through any means do not include trade secret information. 

3(g) Sensitive Questions

This collection does not request any sensitive information. 

4 THE RESPONDENTS AND THE INFORMATION REQUESTED 

 4(a) Respondents/NAICS Codes 

The reporting requirements found in EPCRA §313 apply to owners and operators of facilities that 

have 10 or more full-time employees, manufacture or process more than 25,000 pounds or 

otherwise use more than 10,000 pounds of a listed chemical, and are in the manufacturing sector or 

in any of seven additional industry sectors added to the TRI Program by EPA in 1997 or are Federal 

facilities (regardless of industrial sector). Historically the TRI-covered industrial sectors were 

identified by their Standard Industrial Classification (SIC) codes. Beginning with Reporting Year 

(RY) 2006, the TRI Program converted from SIC codes to North American Industry Classification 

System (NAICS) codes (71 FR 32464, June 6, 2006). The full list of NAICS codes for facilities that 

must report to TRI (including exemptions and/or limitations), if all other threshold determinations 

are met, can be found in Appendix E. 

4(b) Information Requested 

(i) Data Items, Including Recordkeeping Requirements 

A copy of the proposed Form R, Form R Schedule 1 and Form A are included in Appendix A. For 

instruction revisions associated with the proposed form revisions, see Appendix B. To access 

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

Form R 

Facilities reporting to TRI report releases and other waste management of listed chemicals on 

Form R. The required data items, which are summarized below, are specified in 40 CFR §372.85. 

Form R is divided into two sections. In Part I, respondents report facility identification 

information including: facility identification number; facility name and address; NAICS code; 

facility Dun and Bradstreet (D&B) number; parent company name; parent company D&B number; 

name, email address, and phone of the technical contact; and name, email address, and phone of 

the public contact. In Part II, respondents report: 

 Toxic chemical identity, 

 Mixture component identity, 

 Activities and uses of the toxic chemical at the facility, 
 

 

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 Maximum amount of the toxic chemical on site at any time during the calendar year, 

 Quantity of the toxic chemical entering each environmental medium on-site, 

 Transfers of the toxic chemical in wastes to off-site locations, 

 On-site waste treatment methods and efficiency, and 

 Source reduction and recycling activities. 

On Form R Schedule 1, facilities reporting on dioxin and dioxin-like compounds report the 

individual grams data for each member of the dioxin and dioxin-like compounds category present. 

Form R Schedule 1 is a four-page form that mirrors the data elements from Form R Part II 

Chemical-Specific Information sections 5, 6, and 8 (current year only). 

Form A 

Form A is also divided into two sections. Part I solicits the same information as Part I of Form R 

(see list above) but requires a different certification statement which represents a signed 

statement by a facility owner/operator or senior management official. In contrast to Form R 

where reduced threshold eligibility is not an issue, the Form A’s signed statement certifies that 

the annual reportable amount as defined by 40 CFR 372.27(a) did not exceed 500 pounds for the 

reporting year, and that the amounts manufactured, or processed, or otherwise used did not 

exceed 1 million pounds for that year. In most instances, PBT chemicals may not be reported 

using Form A.13 In Part II, a facility may report multiple chemicals on a single Form A. 

Specifically Form A solicits: 

 Toxic chemical identity, 

 Mixture component identity, 

In addition to annual reporting requirements, facilities must maintain records used to provide the 

information required on the form according to 40 CFR §372.10. Those records may include 

estimation methodology and calculations; engineering reports; inventory, incident, and operating 

logs; and other supporting materials. Facilities must keep a copy of each report filed for at least 

three years. 

Proposed Form Revisions 

As mentioned above, EPA is proposing revisions to the Form R and Form A that standardize 

responses and enhance data utility. More specifically, the revisions to the forms and TRI Reporting 

Forms and Instructions (RFI) and rationale for the revisions are presented in Table 3. 

13 The exception is lead in stainless steel, brass, or bronze alloys, which are not excluded from Form A 

eligibility.
 

 

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Table 3 

Proposed Form Revisions

Form Revision Rationale Form 

1 Remove the NA box from the 

Parent Company field (Part I: Sec. 

5,.5.1) 

The NA box is currently used to indicate a foreign 

parent company. Removing this box and requiring 

facilities to report the highest level U.S. parent 

company will facilitate analysis of the TRI data at 

the parent company level. 

R/A 

2 Disaggregate the “Total Transfers” 

field and add fields to identify 

chemical discharge quantities to 

specific publicly owned treatment 

works (POTWs) Part II: Sec 6.1) 

The existing form collects a single “Total Transfer” 

quantity for transfers to all POTWs. Providing 

separate fields for the transfer quantity to each 

POTW will facilitate analysis of the releases to 

specific watersheds. 

R 

3 Section 8 Enhancements 

° Change instructional statement on 

form to include “newly 

implemented and/or ongoing” 

source reduction activities (Part 

II: Sec. 8.10). 

° Add an “NA” box to match 

associated text revisions (Part II: 

Sec. 8.10) 

° Add a field to allow separate 

reporting for both new and 

ongoing source reduction 

activities (Part II: Sec. 8.10, 

8.10.1-4). 

° Remove the “Yes” box and 

enlarge the text section for 

question on optional Pollution 

Prevention information (Form R 

Section 8.11). 

The existing form requests information on “any 

source reduction activities for this chemical during 

the reporting year;” but the Reporting Forms and 

Instructions request information on “newly 

implemented” source reduction activities. This 

change on the form and in the instructions will 

remove this difference, allowing facilities to 

distinguish between new and ongoing source 

reduction activities. It also provides a larger text 

box (8.11) where facilities can provide optional 

information on source reduction, recycling, or 

pollution control activities. 

R 

4 Add a new question to capture 

miscellaneous and optional 

information regarding the 

submission (Part II: Sec..9.1). 

This new text box allows facilities to provide 

optional, miscellaneous information that may be 

helpful to EPA and/or the public in using or 

interpreting their data (e.g., facility closures, 

explanations for changes in release quantities, etc.). 

R 

5 Add NA boxes (Part II: Sec 5.3, 

6.1, 6.2) 

Add NA boxes were appropriate to improve 

consistency within the form. 

R 

(including R 

Schedule 1) 

 
 

 

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(ii) Respondent Activities 

Facilities engage in a number of activities to comply with the EPCRA §313 reporting 

requirements. These activities can be divided into two distinct groups: Form Activities, 

consisting of rule familiarization, compliance determination, calculations and form completion, 

and recordkeeping and submission; and Non-Form Activities, consisting of supplier notification, 

non-reporter compliance determination, and petitions. 

Form Activities 

 Rule Familiarization: Staff of a facility that is reporting under EPCRA §313 for the first 

time must read the reporting package and become familiar with the reporting requirements. 

This includes the time needed to review instructions, and the time needed to train personnel to 

respond to a collection of information. 

 Compliance Determination: At reporting facilities staff must make the determination that 

the facility meets the criteria for EPCRA §313 reporting. This activity includes the time 

required to become familiar with the definitions, exemptions, and threshold requirements 

under the TRI Program, to review the list of TRI chemicals, and to conduct preliminary 

threshold determinations to determine if the facility is required to report. 

 Calculations and Form Completion: Facility staff must gather data and perform 

calculations to provide the information required on the form. This activity includes the time 

required to search data sources and the time to complete and review the information. 

 Recordkeeping and Submission: Facility staff must maintain recordkeeping systems and 

submit the report to EPA and the state in which the facility is located. This activity includes 

the time required to transmit or otherwise disclose the information. 

Non-Form Activities 

 Supplier Notification: Certain suppliers of mixtures or trade name products containing 

reportable substances must annually notify their customers of the product's composition, if the 

customer is subject to EPCRA §313 reporting. This activity includes the time required to 

inform customers, either by letter or through the materials safety data sheet (MSDS) for the 

product. 

 Non-Reporter Compliance Determination: In any given reporting year, a group of eligible 

facilities will complete compliance determination but will not file a Form R or Form A. The 

activity is the same as is presented above under Form Activities; however, given that 

compliance determination applies to all other facilities in NAICS-code-eligible sectors (with 

ten or more employees)—including those that ultimately do not report to TRI—the later 

category is accounted for in this separate activity. 
 

 

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 Petitions: Any person may petition the EPA to add or delete a chemical from the TRI toxic 

chemical list. EPA evaluates the toxicity of the chemical against the listing criteria 

established by Congress and makes a determination whether to grant or deny the petition 

request. If the petition is granted, EPA will propose a rule to either add or delete the 

chemical and after reviewing the public comments will issue a final rule. If the petition is 

not granted, EPA issues a notice explaining why the petition was denied. The activities 

required to prepare and file a petition are listed below. 

 Read EPA policy and guidance documents and consult with EPA; 

 Plan activities; 

 Prepare literature search; 

 Conduct literature search; 

 Process, review, and focus information; 

 Write petition; 

 Review and edit petition; and 

 Submit petition to EPA and file. 

EPA provides the reporting community with instructions, guidance documents, training materials, 

and toll-free hotlines to assist them in completing and submitting their reporting forms to EPA. 

5 THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT 

5(a) Agency Activities 

EPA engages in many activities to fulfill the purpose and requirements of EPCRA. These activities 

can be grouped in the following categories that cover what the Agency does to assist the regulated 

community with compliance, to process the data, to maintain the database, and to make the data 

available: 

 Assistance to Reporters 

 Electronic Reporting 

 Paper-Based Reporting 

 Data Processing and Quality Control 

 Database Organization 

 Links to State Reporting 

 Making Data Available 

 List Revisions and Petition Reviews 

 Trade Secrecy Reviews 

Assistance to Reporters. The Agency operates an outreach program to assist reporters with 

activities related to Form R/Form A completion. EPA provides TRI reporting assistance with a 

variety of online tools and guidance, including TRI Reporting Forms and Instructions and TRIMEweb (TRI Made Easy) reporting software. TRI-MEweb is a web-based software application 

that TRI facilities can use for entering, validating and submitting their data. The TRI Program 
 

 

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also provides both basic and advanced downloadable TRI training slides plus online audio 

training modules on the TRI Web site. 

EPA operates two toll-free hotlines to answer general questions and questions pertaining to 

electronic reporting and data certification over the internet. In addition, the Agency maintains a 

Web site with current program-specific information and guidance (http://www.epa.gov/tri). 

General guidance has been prepared for estimating releases, including 14 industry-specific 

guidance documents. Additionally, EPA provides guidance and assistance for persons or 

organizations regarding petitions to add or delete chemicals from the TRI list. 

Electronic Reporting. As observed in 2010 for reporting year (RY) 2009, ninety-seven percent 

of all TRI Form Rs and Form As were prepared and submitted electronically using TRIMEweb. 14,15 Capabilities in TRI-MEweb include: 

 Easy Upload and Validation Checks. Facilities can key or upload their data into TRIMEweb. TRI-MEweb also provides facilities with extensive data validation checking 

through point-of-entry edit checks as well as a cumulative, mandatory validation checks 

prior to submission. 

 Submittal to the Central Data Exchange. After entering their data into the TRIMEweb application and validating them, facilities can submit their data via EPA’s 

Central Data Exchange (CDX) for certification. 

 Automatic Data Transmittal. Once a TRI submission has been certified by a facility’s 

certifying official, CDX automatically forwards it to the TRI EPCRA Data Processing 

Center (DPC) where it is loaded into the TRI Processing System (TRIPS) database. The 

TRIPS database is located at EPA’s National Computer Center in Research Triangle 

Park, NC. 

 State Government Data Submittal. Through the TRI State Data Exchange Network, 

facilities are able to submit the data via CDX and have the data transmitted to both EPA 

and the participating state government. This reporting option allows facilities to fulfill 

their legal obligation to report to both EPA and the appropriate State through a single 

transmission of data to CDX. 

 Preloaded Forms and Central Data Storage. The TRI-MEweb application allows 

users to preload their forms with prior year data stored in an EPA-maintained database. 

This database is currently separate from the TRIPS database which is used to store 

certified TRI submissions. 

 

14 Based on TRI 2009 baseline dataset from EPA 9/16/2010. This dataset does not include revision submissions or 

withdrawals. 

15 Prior to TRI-MEweb, TRI reporting software had been desktop-based, distributed via the TRI Web site and mailed 

directly to facilities (via CD-ROM) each year. In RY 2007, TRI-MEweb, the new Web version of TRI-ME, was fully 

launched. The TRI-Me desktop software was retired from service in RY 2009. 
 

 

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 Quick Lists. TRI-MEweb provides “quick lists” that allow users to narrow their data 

entry to only the pertinent areas. 

 Data Quality Checks. TRI-MEweb contains a number of data quality checks including 

internal consistency and semantic checks that compare a facility’s data to prior year 

submissions. 

 On-Line Revisions and Withdrawals. The application allows online revision and 

withdrawal of data by facilities. Through this feature, facilities are able to access 

previously submitted forms, and revise or withdraw as needed. 

 Automated Section 8 Calculator. TRI-MEweb automatically calculates Section 8 Column 

B (current year) estimates based on data entered in other form sections. Users may tailor 

the calculation's inputs, but cannot enter their own calculated values. This approach is 

intended to reduce the frequent mathematical errors in Section 8 and simplify the reporting 

process. 

 TRI Assistance Library. An online TRI Assistance Library is available to help facility 

reporters complete their TRI submissions. 

Paper-Based Reporting. Facilities can also submit data to TRI on paper forms. When facilities 

submit TRI reports on paper, the information is keyed into the TRIPS database. Automated data 

quality checks begin at data entry. At this point, the emphasis is on identifying forms that are 

not completed correctly and cannot be processed further because of fundamental errors (e.g. no 

chemical specified). 

Data Processing and Quality Control. Once the reported data have entered the TRIPS 

database, some validation checks that were initially run via the TRI-MEweb application are 

repeated. For paper submissions, these checks are performed for the first time. In addition, a set 

of data quality checks that compare the incoming data with prior years data and various data 

threshold checks are performed on the data for the first time. 

Upon the completion of the data validation and quality checks, Facility Data Profile (FDP) 

reports are generated and made available for facility review on the FTP Web site. The reports 

contain an echoing back of the data and all validation and data quality messages. Facilities are 

notified by e-mail when a report becomes available. After review, facilities can revise their 

data by submitting a certified replacement form via the TRI-MEweb application or on paper. 

Database Organization. EPCRA §313(j) requires EPA to make TRI data available to the public 

through computer telecommunications and other means. EPA ensures that each facility has a 

unique identifier—the TRI facility ID (TRIFID). EPA generates a TRIFID for newly reporting 

facilities at the time of data entry. The identification number allows easy retrieval of cross-year 

data, even when a facility is sold or changes its name. Facilities are notified of their TRIFID and 

required to use it consistently over time. 

Links to State Reporting. Under EPCRA §313, facilities are required to submit forms to both 

EPA and the state agency in which they operate. For coordination, tracking, and quality 
 

 

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assurance purposes, EPA and the state agencies reconcile their submissions at the end of the 

reporting cycle. 

In 2004, EPA implemented the TRI State Data Exchange Network, which enables facilities to 

simultaneously submit their data to EPA and the State in which they are located. This reporting 

option allows facilities to fulfill their legal obligation to report to EPA and the State through the 

sole submission of data through CDX. 

Making TRI Data Available. Many options are available for accessing TRI data—ranging from 

data files to refined analyses. The annual TRI National Analysis (previously known as the Public 

Data Release) is an overview of the most recently reported TRI data. It includes key findings, indepth analyses, and information on trends. Three on-line data access tools: TRI-Explorer, 

Envirofacts and TRI.NET, make TRI data available to the public for further analysis. TRI.NET 

can also be used to view and analyze TRI data using geospatial capabilities and allows users to 

combine TRI data with other related data for further analysis. All three of these tools are updated 

periodically throughout the year to provide access to the most current data. 

The TRI Program historically did not release the latest year of TRI reported data until the release 

of the TRI National Analysis. However, starting in 2009, EPA began releasing the most recent 

year of TRI data within weeks after the July 1st reporting deadline. The TRI preliminary dataset is 

made available in downloadable data files, as well as via TRI Explorer and Envirofacts. 

List Revisions and Petition Reviews. The list of toxic chemicals subject to reporting under 

EPCRA §313 is subject to change. Regulatory additions or subtractions of chemicals from the 

list of TRI-covered chemicals can be initiated by EPA independently or in response to a petition. 

Trade Secrecy Reviews. Facilities claiming a chemical identity as a trade secret must substantiate 

the claim by completing the Trade Secret Substantiation Form available from the TRI Web site 

(www.epa.gov/tri) under "TRI Reporting Materials." For more information on trade secrecy 

reviews, including the costs to EPA, see the ICR for the Trade Secrecy Rule for EPCRA (EPA 

#1428, OMB #2050-0078). 

5(b) Collection Methodology and Management 

EPA continues to encourage Form R and Form A submissions through the Internet via EPA’s 

CDX and the TRI-MEweb application. For RY 2009, over 94 ninety-seven percent of all TRI 

submissions were prepared using TRI-MEweb and submitted electronically to EPA via CDX. 

5(c) Small Entity Flexibility 

Under EPCRA §313 (b)(1)(A), facilities with fewer than 10 full-time employees (or the 

equivalent) are not required to report. In addition, EPA has taken several steps to minimize the 

burden for covered small businesses. A range reporting option was added to the Final Rule (53 

FR 4500, February 16, 1988) that codified the EPCRA §313 reporting requirements. Range 
 

 

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reporting was the preferred option from the Regulatory Flexibility Act analysis to provide 

burden reduction for small businesses. Range reporting provides an option for releases of less than 

1,000 pounds to be recorded as a code representing one of three ranges (1 to 10 pounds, 11 to 

499 pounds, or 500 to 999 pounds) rather than as a specific estimate of the release amount. The 

benefit is not, however, limited to small businesses. Note that range reporting is not permitted 

on Form Rs for PBT chemicals. 

In response to a petition from the Small Business Administration, EPA promulgated the alternate 

threshold (59 FR 61488, November 30, 1994), manifested in Form A reporting, as discussed in 

Section 1(b). Although any reporting facility meeting the criteria may use the alternate threshold, 

this alternate threshold may be particularly advantageous to small entities. 

5(d) Collection Schedule 

Facilities must report their information on a calendar-year basis, and submit Form Rs or Form As 

to EPA by July 1 of the following year. In response to public requests to shorten the time frame 

for release of TRI information, TRI began a modernization effort in 2007 that included transition 

to TRI-MEweb from desktop software, and a number of streamlining initiatives. One of the 

resultant improvements was the Preliminary Data Release which provides TRI database 

information as quickly as possible after the reporting deadline. In 2009, EPA released toxic 

chemical data to the public in mid-August, less than two months after the July 1st reporting 

deadline. In 2010, EPA released data less than one month after the reporting deadline in the TRI 

preliminary dataset with downloadable data files and access via TRI Explorer and Envirofacts. 

6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

This information collection activity imposes burden and cost on certain facilities affected by 

EPCRA §313 reporting requirements. It also imposes costs on EPA to process and make available 

the data collected and stored in the Toxics Release Inventory. The following sections present the 

derivation of Form R and Form A respondent burden and cost as well as Agency burden and cost. 

For TRI reporters, estimates of average Form R and Form A reporting burden per respondent are 

presented. These form unit burden estimates are then combined with an appropriate wage rate to 

develop unit costs. Total Form R and Form A respondent burden and costs are estimated by 

combining the universe of reporting forms with estimates of unit burden and cost. This universe of 

reporting forms is based on reporting in RY 2009 plus updates to reflect changes during the year 

of the ICR project—in this case, the modeled number of chemicals and facilities estimated to 

report under the Addition of National Toxicology Program Carcinogens rule, published on 

November 26, 2010. The combined total number of forms and facilities (i.e., respondents) is 

hereafter referred to as the ICR Universe. The methodology used to estimate reporting burden in 

this ICR Renewal—Ratio-Based Burden Methodology (RBBM)16 —is a restructured and 

16 Revising TRI Burden to Ratio-Based Methodology, TRI Regulatory Development Branch, TRI Program Division, 

Office of Information Analysis and Access, Office of Environmental Information, January 2011, EPA Docket ID 

Number EPA-HQ-OEI-2010-0835; hereafter referred to as RBBM Reference Document (Docket #EPA-HQ-OEI2010-0835), EPA, 2011. 
 

 

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simplified formulation of the previously employed methodology.17 When estimating reporter 

burden using RBBM, the Nominal Form R unit burden (35.7 hours) is the base number and Form 

A unit burden is set at 61.5% of that value. These unit burdens reflect burden associated with form 

activities including rule familiarization, compliance determination, calculations and form 

completion, and recordkeeping. In addition to Form R and Form A burden, total TRI program 

burden is captured by adding non-form burden associated with supplier notification, non-reporter 

compliance determination, and petitions to form burden. 

OMB approved separate Form R and Form A ICRs on March 2, 2008. The current expiration date 

for both forms is July 31, 2011. The OMB approved burden numbers at that time were 3,217,280 

hours for Form R and 515,901 hours for Form A, totaling 3.73 million hours. Several changes in 

the burden estimates have been approved by OMB since the OMB approvals of the ICRs on March 

2, 2008.18 On March 20, 2009, OMB approved the merging of the ICR for TRI detailed reporting 

on dioxin and dioxin-like compounds (OMB 2025-007, ICR 2086.02), into the TRI Form R ICR 

(currently OMB Control Number 2025-0009), increasing burden by 899 hours. Then on March 

27, 2009, OMB approved changes in the number of responses and the burden hours for Form R 

and Form A to reflect the passage of Section 425 of the Omnibus Appropriations Act of 2009, 

which rescinded the December 2006 Toxics Release Inventory Burden Reduction Rule.19 As a 

result, the OMB-approved numbers for Form R were increased by 140,565 hours and for Form A 

burden were decreased by 318,418 yielding a net increase of 458,983 hours. Most recently, on 

November 26, 2010, the Addition of National Toxicology Program Carcinogens rule was 

published in the Federal Register. This rule is estimated to increase the number of reporting 

facilities by 74 and the number of Form Rs submitted by 186 with an associated burden increase of 

6,641 hours. 

Meanwhile, over the past several years, there has been a slight decrease in the number of facilities 

reporting to TRI. Based on the latest data for RY 2009 with updates to reflect the estimated 

additional reporting resulting from the Addition of National Toxicology Program Carcinogens 

rule, EPA now estimates the total number of combined Form R and Form A responses to be 

73,727, the associated total annual burden hours to be 3.52 million and the annual cost to be 

$174.5 million (see Section 6(b) for breakdown by Form R, Form A, and non-Form contributions). 

These estimates incorporate the proposed revisions to Form R/Form A which have been estimated 

to have a negligible impact on form burden. 

For Agency burden, estimates of costs for RFI and Compliance Assistance; TRI Reporting 

Software and Related Data Collection/Exchange IT Infrastructure, and Data Processing are 

presented. In Agency form processing cost estimates, the RY 2009 distribution of submission 

17 As opposed to a system several large matrices containing mixed scales, this structure is four ratio models plus a base 

number for Nominal Form R unit burden. For mathematical derivations, See Ibid. 

18 For a complete chronology of rule changes and ICR renewals along with resultant impact on Form R reporting 

burden, see Figure 2 and Table 18. 

19 The 2009 Omnibus Appropriations Act revised Form A eligibility, reverting back to criteria in place prior to the 

2006 Phase II Burden Reduction rule. This effect shifts about 3% of reported chemicals from Form A to Form R, as 

estimated based on RY 2007 TRI frozen data. 
 

 

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media (paper versus TRI-MEweb submissions) is assumed to be the same over the course of the 

next ICR period. 

6(a) Estimating Respondent Burden 

This section presents the burden of this information collection activity to Form R and Form A 

respondents in terms of the time required for facility personnel to perform the activities outlined 

in Section 3 of this document. In the past, these burden estimates were based on previous ICRs 

and economic analyses, respondent experience as reflected in comments to EPA and other 

parties, best professional judgment, and information acquired through site visits and telephone 

interviews. For this ICR, EPA implemented a revision to the existing methodology, called 

Ratio-Based Burden Methodology (RBBM), to estimate TRI respondent burden for both Form 

R and Form A reporting.20

Ratio-Based Burden Methodology simplifies calculations, imposes internal consistency, and 

sharpens transparency while retaining the components of the existing methodology and 

maintaining its overall total burden estimate as a starting point.21 Additionally, by virtue of 

RBBM’s structure, the methodology prevents accounting errors.22 For activities associated with 

filing TRI chemical reports, RBBM burden estimates include rule familiarization, compliance 

determination, calculations and form completion, and recordkeeping. Similarly, for activities 

unrelated to form reporting (non-form burden) RBBM estimates include supplier notification, nonreporter compliance determination, and petitions. 

Figure 1 presents the equations of RBBM’s primary method: Steady State Total Burden 

Calculation. With RBBM’s calculation of form burden, the only variables/inputs required are total 

counts for Form R Chemicals and Form A Chemicals. The factors/constants of the equations 

include: 

1) Nominal Form R unit burden, in units of burden hours per Form R Chemical and 2) A/R,23 a 

model for the ratio of Form A (single-chemical)24 to Form R burden. 

As shown in Figure 1, Nominal Form R unit burden is multiplied by the number of Form R 

Chemicals to estimate the total Form R burden. Similarly, Form A unit burden (formulated as the 

product of A/R and Nominal Form R unit burden) is multiplied by the number of Form A 

20 For references on methodology development, see RBBM Reference Document (Docket #EPA-HQ-OEI-2010-

0835), EPA, 2011. 

21At the time of transition (the start of the 2008 ICR) the comparison between totals is exact. Later, in an interim spotcheck (April 2010), totals were within 2%. 

22 The simplicity of RBBM reduces accounting errors in general; but more specifically, the structure prevents errors 

related to double-counting. See discussion in RBBM Reference Document (Docket #EPA-HQ-OEI-2010-0835), EPA, 

2011. 

23 In A/R, Form A unit burden is derived using the activities associated with the subset of elements from Form R that a 

reporter would complete in order to determine TRI reporting eligibility and file a Form A, ensuring internal 

consistency. For further details, see RBBM Reference Document (Docket #EPA-HQ-OEI-2010-0835), EPA, 2010.

24 Although Form A permits multiple chemical reports on the same form (on average 2.31 Chemicals per Form A), for 

purposes of methods development and modeling, EPA works with chemical counts, referring to “Form R Chemicals” 

and “Form A Chemicals.” 
 

 

ICR 1st FR Notice 2/08/11 

 

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Chemicals to estimate total Form A burden. For cross-reference to the activities associated with 

form reporting, Table 4 shows the percent contribution of each Form R activity (and related Form 

A activity) to total burden. 

Figure 1 

Ratio-Based Burden Methodology a 

Two Burden Factors; 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/hrb

a For a complete description of the Ratio-Based Burden Methodology, see “Revising TRI Burden to Ratio-Based 

Methodology” (RBBM Reference Document -Docket #EPA-HQ-OEI-2010-0835, EPA, 2011). 

RBBM incorporates a number of simplifications.25 First, burden factors associated with activities 

incurred at the facility level (e.g., compliance determination) have been rescaled as form-level 

factors, providing a uniform scale for all relevant factors. Second, first year filing is no longer 

included in the Steady State Total Burden due to negligible impact. Third, it is no longer necessary 

to account for burden by chemical type (PBT versus non-PBT). Last, burden need not be estimated 

using three separate labor categories (management, technical, clerical) because with RBBM a 

weighted average wage rate (WAWR) is applied to the overall burden hours to estimate cost. 

25 For verification of assumptions related to these simplifications, see RBBM Reference Document (Docket #EPAHQ-OEI-2010-0835), EPA, 2011. 
 

 

ICR 1st FR Notice 2/08/11 

 

27

Table 4: Ratio-Based Burden Methodology Components 

Ratio-Based Burden Methodology 

Unit Burdensa

100%=Form R Unit Burden

Ratio Model 

Bases 

Form R 

% 

Derived 

Form Ab

% 

Activity 

Rule Familiarization 0 0

Facility 

Burden 

Apportioned 

to Form R Compliance 

Determination 

R/A Chemical 

2.58 2.93

 

 

 

Calculations and Form 

Completion 57.49 18.64

Nominal Form R

(non-PBT ) 

Subsequent year 

(Steady State)

Form R 

Recordkeeping 

R/A Chemical 

39.93 39.93

Form Burden Per 

Chemical Total 

Percentage of Form R 

Unit Burden 100.00 61.50

a Consistent “per chemical” scale. 

b 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 eligibility as well as the 

data elements they actually report on Form A (basis of Form A and Form R as of 2008 ICR Renewal).

The burden estimates used by EPA are considered to be national average values. As with any 

average, some facilities will be above the average, and others will be below it. Large, complex 

facilities may require more than the average time to comply; however, many other facilities 

subject to the rule are not large or complex. Overall, EPA considers the TRI Program burden 

estimates to be reasonably representative of national averages. 

Form R and Form A Respondent Requirements 

As noted in Section 4(b)ii above, facilities engage in a number of activities to comply with the 

EPCRA §313 reporting requirements. These activities can be divided into two distinct groups: 

Form Activities, consisting of rule familiarization, compliance determination, calculations and 

form completion, and recordkeeping and submission; and Non-Form Activities consisting of 

supplier notification, non-reporter compliance determination, and petitions. A detailed 

description of these activities is presented in Section 4(b)(ii).
 

 

ICR 1st FR Notice 2/08/11 

 

28

Form Activities 

 Rule Familiarization 

 Compliance Determination 

 Calculations and Form Completion 

 Recordkeeping and Submission 

Non-Form Activities 

 Supplier Notification 

 Non-Reporter Compliance Determination 

 Petitions 

Note that for burden unrelated to reporting on a Form R or A, the RBBM simplifies 

calculations by holding all of these values at a constant level, as estimated in the 2008 ICR 

Renewal.26

Updating Form R and Form A Unit Burden 

As noted above, this ICR Renewal uses the RBBM to estimate total TRI Program burden. 

However, the RBBM’s initial basis uses TRI reporting conditions as captured at the beginning 

of the 2008 ICR Renewal. Since that time, new dioxin reporting requirements—which affect 

Form R unit burden—have taken effect under EPCRA section 313, and according to RBBM 

necessitate a revision to the estimate for Form R unit burden. Therefore, the additional burden 

created by the dioxin requirements must be accounted for in the beginning of the 2012 ICR 

Renewal, and in this Supporting Statement’s analysis. Using RBBM and RY 2009 TRI data as 

bases, 27, 28 as shown below, the unit reporting burden in this ICR Renewal reflects the updated 

Form R and Form A unit reporting burdens. 

 

26 RBBM Reference Document (Docket #EPA-HQ-OEI-2010-0835), EPA, 2011. 

27 Using the RBBM, additional burden associated with form changes are readily estimated. Specifically, the method 

provides a standardized set of form element burdens for use when estimating additions to the Form R (from which 

Form A burden is calculated, as explained above). For a more detailed description of form element estimation using 

the new method, see Appendix C of RBBM Reference Document (Docket #EPA-HQ-OEI-2010-0835), EPA, 2011. 28 Information from the EA associated with the rule was also consulted. Analysis of the Estimated Burden and Cost of 

Form R Schedule 1 for Dioxin and Dioxin-like Compounds; Toxic Equivalency Reporting; Community Right to Know 

Toxic Chemical Release Reporting (May 10, 2007). 
 

 

ICR 1st FR Notice 2/08/11 

 

29

Since the last ICR Renewal, other substantive changes occurred via rulemakings. Due to the 

2009 Omnibus Appropriations Act which reversed the TRI Burden Reduction Rule, the total 

number of Form Rs filed by facilities was expected to increase and the number of Form As filed 

by facilities was expected to decrease. Most recently, on November 26, 2010, the Addition of 

National Toxicology Program Carcinogens rule was published in the Federal Register. This rule 

is estimated to increase the number of reporting facilities by 74 and the number of Form Rs 

submitted by 186. The relative unit burdens associated with filling out Form R and Form A, 

however, remain unchanged. The anticipated change in the number of Form Rs and Form As 

filed is discussed in Section 6(d). 

Additionally, EPA is proposing to revise data elements and revise instructions for Form Rs and 

Form As that would improve the consistency and utility of TRI data. However, the revision of 

data elements and certain instructions is estimated to have no measurable impact on Form R and 

Form A burden. 

The following discussion explains how the unit burden is affected by changes from rulemakings 

since the last ICR and how it will be negligibly affected if the proposed form revisions are 

finalized (analysis is based on RY 2009 data with updates to reflect the estimated additional 

reporting resulting from the Addition of National Toxicology Program Carcinogens rule). 

Dioxin Reporting Requirements 

On May 10, 2007, the Toxics Release Inventory Program issued a final rule expanding reporting 

requirements for the dioxin and dioxin-like compounds category. There are 17 distinct members of 

this chemical category listed under TRI. The final rule removes the requirement to report the 

single distribution of compound to the dioxin category and further requires that, in addition to the 

total grams released for the entire category, facilities must report the quantity for each individual 

member on a new Form R Schedule 1. EPA uses the individual mass quantity data to calculate 

toxic equivalency (TEQ) values that are made available to the public along with the mass data. 

To account for the additional reporting burden created by the dioxin rule, the standardized form 

element burdens developed in the RBBM are used to estimate additional burden to dioxin 

reporters (specifically those reporters that provide a congener distribution, which is estimated to 

occur on 94% of dioxin forms). This additional unit burden is then weighted to reflect the 

percent of dioxin reports in the total universe of TRI reports (1.6%) and added to steady state 

Form R unit burden. 

For facilities at which data on the distribution of dioxin and each dioxin-like compound are 

available, the following activities were previously estimated as requirements for reporting this 

information on Form R: 

 Calculate the quantity of dioxin and each dioxin-like compound released and/or 

transferred off-site to each environmental medium and managed as waste using 
 

 

ICR 1st FR Notice 2/08/11 

 

30

 

monitoring data, facility-specific emission factors, or facility-specific EPA default 

emission factors; 

 Sum across chemicals in the category to calculate total reportable releases and other 

waste management quantities of dioxin and dioxin-like compounds; 

 Calculate or estimate the distribution of total releases across the 17 chemicals listed 

in the dioxin and dioxin-like compounds category; and 

 Record the distribution of releases on the existing Form R as the percentage of total 

releases in the form of each of the 17 chemicals listed in the dioxin and dioxin-like 

compounds category. 

Regardless of whether a facility reports the distribution of each member of the dioxin and dioxinlike compounds category in Part II, Section 1.4 of the existing Form R, each facility was required 

to report the total grams of dioxin and dioxin-like compounds released to each environmental 

medium, transferred off-site, or managed as waste in Sections 5, 6, 7, and 8. Therefore, the 

additional time required to report the quantity for each individual member on Form R Schedule 1 

is small given that quantities have already been calculated. 

In the RBBM, the standardized form element burden category "Quantity Derived from Relevant 

Section 5 and 6 Data Elements" provides an estimate for filling in a data element where 

calculations have occurred as a part of an existing data element. EPA estimates 0.25 minutes of 

management time and 5.00 minutes of technical time will be required to fill out a subsection on 

Form R Schedule 1. As stated in the Dioxin Economic Analysis, dioxin reporters fill out an 

average of 4 subsections on Form R.29 Therefore, total incremental burden is estimated to be 21 

minutes or .35 hours per Form R Schedule 1 (i.e., per dioxin respondent). 

As not all TRI reporters fill out Form R Schedule 1, this additional burden is weighted by the 

percent of total reporters that fill out dioxin reports and then added to steady state Form R unit 

burden (35.7 hrs). The calculation is presented below. Note that all form counts are based on 

RY 2009 data. 

(Eq.1) 

 =

35.70516 = .35hrs ((1,094×.94)/69,690) + 35.7 

29 Analysis of the Estimated Burden and Cost of Form R Schedule 1 for Dioxin and Dioxin-like Compounds; Toxic 

Equivalency Reporting; Community Right to Know Toxic Chemical Release Reporting. May 10, 2007. 

Additional Form R Schedule 1 Unit Burden × ((Total # of Dioxin 

Form Rs × Percent of Dioxin Form Rs Reporting 

Congener Distribution) /Total Number of Form Rs) +

Steady State Form R Unit Burden 

= Adjusted Steady 

State Form R 

Unit Burden 
 

 

ICR 1st FR Notice 2/08/11 

 

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Addition of National Toxicology Program Carcinogens 

On November 26, 2010, the Toxics Release Inventory Program issued the Addition of National 

Toxicology Program Carcinogens rule adding 16 chemicals, identified as carcinogens by the 

National Toxicology Program (NTP), to the list of reportable TRI chemicals. These 16 chemicals 

meet the EPCRA Section 313(d)(2)(B) criteria for listing because they are reasonably anticipated 

to be a human carcinogen by the NTP in its Report on Carcinogens (ROC) document. Further, 

EPA estimates that facilities currently manufacture, process or otherwise use these chemicals 

above TRI thresholds and therefore would file TRI reports. All chemical reports are assumed to 

be filed as Form R reports. Therefore, the total number of additional TRI reports expected due to 

the rule is 186 Form Rs, and the number of new facilities reporting to TRI is 74. 

Revised Data Elements 

EPA is proposing several revisions to Form R and Form A. As mentioned above, these revisions 

will contribute to the standardization of responses and enhancement of data utility. Specifically, 

EPA is proposing: 

 to remove the NA box in section 5.1 of Form R and Form A and revise the instructions. 

The NA box is currently used to indicate a foreign parent company. At the margin, 

removing “NA” as a possible response does not constitute enough change to estimate 

additional burden. Rather, the change serves to clarify the existing forms. Removing this 

box and requiring facilities to report the highest level U.S. parent company will facilitate 

analysis of the TRI data at the parent company level. 

 to disaggregate “total transfers” fields in Form R, Section 6.1 and provide space to identify 

chemical discharge quantities to specific publicly owned treatment works (POTWs). The 

existing form collects a single “Total Transfer” quantity for transfers to all POTWs. 

Providing separate fields for the transfer quantity to each POTW will facilitate analysis of 

the releases to specific watersheds. This change is estimated to impose no additional 

burden as no additional data are to be calculated by the reporter. Note that the total release 

data, which are made up of the individual discharge data, were already requested on the 

existing form. As an additional, but not pivotal consideration, more than 99% of forms 

submitted to TRI in RY 2008 only listed a single POTW, thus the total release that would 

have been reported on the existing form would also be reported to satisfy this form 

change.30 

 to revise the instructional statement for element 8.10 on the form to include “newly 

implemented and/or ongoing" pollution prevention activities, while adding an “NA” box to 

match associated text revisions; plus add a field for elements 8.10.1-8.10.4 to allow 

separate reporting for both new and ongoing source reduction activities. Additionally, 

EPA is proposing to remove the “Yes” box and enlarge the text section for the question on 

optional pollution prevention information (element 8.11.) As important context, the 

existing instructional statement for 8.10 requests information on “any source reduction 

activities for this chemical during the reporting year;” but the Reporting Forms and 

30 TRI 2008 PDR, RY 2008 via TRI.NET 
 

 

ICR 1st FR Notice 2/08/11 

 

32

Instructions request information on “newly implemented” source reduction activities. With 

this revision, both documents request information on newly implemented and existing 

activities. This change would clarify reporting facilities’ requirement to report both new 

and ongoing source reduction activities where the existing form and instructions are 

inconsistent. However, with this change no measureable burden increase is identified 

because the change in form instructions only serves to clarify the form’s intent. In the 

existing form, the instructions asked for “any source reduction activities” to be listed, 

which included both new and ongoing activities. The new form instructions provide a 

clarification stating that the listed source reduction activities can be “newly implemented 

and/or ongoing” therefore, no additional information is requested from the reporter, 

implying that no additional burden is incurred. 

 to add an additional question—Form R Section 9.1, to allow facilities to provide optional, 

miscellaneous information that may be helpful to EPA and/or the public in using or 

interpreting their data (e.g., facility closures, explanations for changes in release quantities, 

etc.). Because this is an optional, and an open-ended question, by convention, no regulatory 

burden is imposed on facilities with its addition. 

 to add NA boxes in three sections 5.3, 6.1, 6.2 of Form R and Form R Schedule 1, and an 

NA box in Section 8.10 of Form R. At the margin, including these NA boxes does not 

constitute enough change to the forms to increase the estimate of the burden. Rather, the 

NA boxes serve to clarify the existing forms and standardize responses. 

The changes proposed, along with their contributions to the forms and estimated additional 

burden are presented in Table 5. 

Table 5 

Additional Unit Reporting Burden Associated with New Data Elements 

Section Number Form Change 

Estimated 

Burden 

(minutes) 

Form R, Form A – 

Part I: Section 5.1 Remove NA box 0.00 

Form R – Part II: 

Section 6.1, 6.1A, 

6.1B 

Disaggregate “total” fields and add fields to identify 

chemical discharge volumes for specific publicly 

owned treatment works (POTWs) 

0.00 

Form R – Part II: 

Section 8.10 

Change instructional statement on form to include 

“newly implemented and/or ongoing" pollution 

prevention activities

0.00 

Form R – Part II: 

Section 8.10 Add an “NA” box to match associated text revisions 

0.00 

Form R – Part II: 

Section 8.10.1-8.10.4 

Add a field to allow separate reporting for both new 

and ongoing source reduction activities 

0.00 

Form R – Part II: 

Section 8.11 

Remove Yes box and enlarge the text box for question 

on P2 optional information 0.00 
 

 

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Section Number Form Change 

Estimated 

Burden 

(minutes) 

Form R – Part II: 

Section 9.1 

Add question capturing miscellaneous and optional 

information regarding the submission 0.00 

Form R, Schedule 1 – 

Part II: Section 5.3 Add NA box 0.00 

Form R, Schedule 1 – 

Part II: Section 6.1 Add NA box 0.00 

Form R, Schedule 1 – 

Part II: Section 6.2 Add NA box 0.00 

Table 6 presents the average annual burden hour estimates by form type. 

Table 6 

Reporter Average Annual Burden Hour Estimate by Form Type 

Form Type Unit Burden Hours Per Form 

Form R (Including Form R Schedule 1) 35.70516 

Form A 21.95867 

Notes: 

1) Unit burdens include burden for all activities associated with filing a form, whether incurred at the 

facility-level or form-level including compliance determination, rule familiarization, calculations and 

report completion, and recordkeeping and submission. 

2) Form A unit burden is set at 61.5% of Form R unit burden. 

3) Burden per form does not include non-form burden (supplier notification, petitions, and non-reporter 

compliance determination).

Any given facility may file only Form Rs, only Form As, or a combination of Form Rs and 

Form As. Table 7 provides more details on the distribution of reporting by form type among 

facilities. Note also that for a given Form A filing, the average number of chemicals reported 

is 2.31. Overall, an average of 3.77 chemicals (Rs and As) are reported per facility with 11.3% 

of all chemicals filed via Form As. 
 

 

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Table 7 

Form per Facility Distributions 

(Current Operations RY 2009 with Updates for Additional Reporting on 

16 National Toxicology Program Chemicals)

Count of Chemicals Average Number of 

Chemicals/Facility 

Form Per 

Facility 

Distributions 

- Current 

Operations 

RY 2009 

Reporter 

Type 

Unique 

Facilities R A Total R A Total 

A Only 1,878 0 3,914 3,914 N/A 2.08 2.08 

R Only 17,020 61,708 0 61,708 3.63 N/A 3.63 

Both R and A 1,973 8,168 4,980 13,148 4.14 2.52 6.66 

Total/Overall 20,870 69,876 8,894 78,770 3.68 2.31 3.77 

Notes: 

1) Calculations are based on RY 2009 raw single-chemical form counts (chemicals not rolled up at the 

Facility-chemical level) with updates to reflect estimated additional reporting due to the Addition of 

National Toxicology Program Carcinogens rule. 

2) Approximately 71 percent of affected facilities filed three or fewer Form Rs in RY 2009. The most 

common number of reports filed is one. 

3) Approximately 67 percent of affected facilities filed two or fewer Form As in RY 2009. The most 

common number of reports filed is one. 

Source: TRI 2009 baseline dataset from EPA 9/16/2010 with updates to reflect estimated additional 

reporting from the Economic Analysis of the Addition of National Toxicology Program Carcinogens 

Rule. 

Table 8 presents the annual estimated burden hours for the overall average conditions. These 

estimates represent the burden on a "typical" facility as defined by the facility filing the 

average number of chemicals (as represented by overall averages). As shown in Table 7, there 

are a variety of patterns for Form R/Form A Chemical filings by facility. The total annual 

burden to all facilities is discussed in Section 6(d). 
 

 

ICR 1st FR Notice 2/08/11 

 

35

Table 8 

Form R and Form A Reporter Typical Annual Burden Hours 

Based on Average Conditions per Facility in Steady State Burden Calculation 

Form Type Annual Average Facility 

Burden Hours 

Form R (Including Form R Schedule 1) Contribution 

[35.70516 hrs per chemical × 3.68 chemicals per 

facility × (.887) proportion of chemicals] 116.547 

Form A Contribution 

[21.95867 hours per chemical × 2.31 chemicals per 

facility × (.113) proportion of chemicals] 5.732 

Overall Average 122.279 

 

 6(b) Estimating Respondent Costs 

The steady state total cost to respondents is based on the time needed to complete the activities 

listed in Section 6(a) and the weighted average wage rate (WAWR) which is the average loaded 

cost for a mix of managerial, technical, and clerical labor (in proportions of .03, .89, and .08, 

respectively) per hour of TRI reporter burden31. There are no specific capital and operation and 

maintenance costs associated directly with this information collection activity. There may be 

some small additional costs for mailing and supplies. Total annual costs for all facilities are 

discussed in Section 6(d). 

(i) Estimating Labor Costs 

Labor burden is estimated for three separate labor categories (management, technical, and clerical) 

across multiple activities; it is necessary to obtain wage rates for each labor category in order to 

estimate labor costs and compute WAWR, as shown in Table 9. 

 

31 For the derivation and justification of the WAWR, see RBBM Reference Document (Docket #EPA-HQ-OEI-2010-

0835), EPA, 2011. 
 

 

ICR 1st FR Notice 2/08/11 

 

36

Table 9 

Derivation of the Weighted 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.

Average respondent costs are summarized in Table 10 for Form R and Form A. 

Table 10 

Form R and Form A Reporter Typical Annual Cost Estimate 

Based on Average Conditions per Facility in Steady State Burden Calculation 

Form Type Annual Average Facility Cost 

Form R (Including Form R Schedule 1) Contribution 

[(35.70516 hrs. per chemical × 3.68 chemicals per facility 

×.887 proportion of chemicals) × $49.62]

$5,783.08 

Form A Contribution 

[(21.95867 hours per chemical × 2.31 chemicals per facility 

× .113 proportion of chemicals) × $49.62] 

$284.42 

Overall Average $6,067.50 

Notes: 

1. Based on RY 2009 TRI reporting as of September 30, 2010 with updates to reflect estimated additional 

reporting due to the Addition of National Toxicology Program Carcinogens Rule published November 26, 

2010. 

2. Burden per form does not include non-form burden of supplier notification, petitions, and nonreporter compliance determination.

Note that non-form burden is assumed to be a constant at 825,517 hours with an associated cost of 

$40,962,154. The components of this burden are: 

 Petitions – 925 hours 

 Supplier Notification – 89,616 hours 

 Non Reporters’ Compliance Determination – 734,976 hours 

The total cost associated with non-form burden is estimated by multiplying this constant by the 

WAWR (see Section 6(d) for total respondent cost associated with the TRI Program). 
 

 

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37

6(c) Estimating Agency Burden and Cost 

This section estimates the burden and costs to EPA to process Form R and Form A reports based 

on information characterizing the resources used in previous years. EPA incurs burden and costs 

for three categories of activities: RFI and Compliance Assistance; TRI Reporting Software and 

Related Data Collection and Exchange; and Data Processing. These activities are outlined in 

detail in Table 11. 

Table 11 

EPA Activities for Collecting, Processing, and Managing TRI Data 

Category Description 

Reporting Forms 

and Instructions 

(RFI) and 

Compliance 

Assistance 

 Revising the TRI Reporting Forms and Instructions (RFI) 

 Updating the online TRI Training Modules 

 Providing technical and regulatory support hotlines 

 Providing online Frequently Asked Questions and Answers 

TRI Reporting 

Software and 

Related Data 

Collection and 

Exchange 

 Revising the TRI-MEweb reporting software 

 Pre-populating TRI-MEweb with facility information from the 

previous year 

 Providing support for facilities to submit and certify their TRI 

reports using TRI-MEweb and the Central Data Exchange 

 Supporting simultaneous reporting to EPA and the States for 

facilities that are located in states that participate in the TRI State 

Data Exchange 

 Related infrastructure investments and program management for 

TRI-MEweb and the TRI State Data Exchange 

Data Processing 

 Processing the submitted data 

 Conducting data quality checks 

 Entering data from paper forms into the TRI Processing System 

(TRIPS) 

 Disseminating data files for use in TRI-related applications 

 Related infrastructure investments and program management for 

TRIPS 

The estimate of EPA burden specific to RFI and Compliance Assistance, TRI Reporting 

Software and Related Data Collection and Exchange, and Data Processing are presented in 

Table 12 in terms of Agency costs and number of FTEs. 
 

 

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38

Table 12 

Agency Costs and FTEs to Support the Collection, 

Processing, and Management of TRI Data a 

Description Non-FTE Cost FTEb 

RFI and Compliance Assistance $ 320,000 1.4 

TRI Reporting Software and Related Data 

Collection/Exchange IT Infrastructure $ 1,279,803 2.1 

Data Processing $ 3,030,968 2.0 

 Total $ 4,630,771 5.5 a

Based on FY 2010 budget.

b

 Based on actual headcounts. 

The estimated Data Processing costs include fixed costs (overhead) and variable costs, which 

depend on the number and type of form submissions. The cost of processing TRI forms is 

approximately $25.75 per chemical for paper submissions and $3.12 per chemical for TRIMEweb submissions.32 Total Agency cost for items, as shown in Table 12, is $4,630,771. 

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

Estimated Total Annual Burden for All Respondents

This section presents the total annual burden hours for all respondents, incorporating both 

form and non-form burden (see detailed bases in Section 6(a)). The total burden hours for all 

respondents under this ICR are estimated using the Steady State Total Burden method as 

depicted in Figure 1. Form R burden and Form A burden are calculated using unit burdens and 

single-chemical form counts; non-Form burden is a constant. The sum of these three burden 

components equals steady state total burden. Table 13 shows the assumed universe of TRI 

facilities and forms for both Form Rs and Form As for this ICR Renewal. 

 

32 Personal communication with Peggy Bagnoli. TRI Information and Outreach Branch. July 8, 2010. The baseline 

data used to calculate distribution percentage of submissions is based on chemical counts from RY 2009. 
 

 

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39

Table 13 

ICR Universe of TRI Facilities and Forms 

(Based on RY 2009 Baseline TRI data With Updates for Additional Reporting of 16 

National Toxicology Program Chemicals) 

Form R Form A 

Number of Chemicals 

(Same as Number of 

Forms) 

Number of Chemicals 

(Note: Average of 2.31 

Chemicals per Form) 

RY 2009 TRI Universe 

Number of Facilities 18,993 3,851 

Number of PBT Chemicals 14,115 22 

Number of Non-PBT Chemicals 55,761 8,872 

Number of Total Chemicals 69,876 8,894 

Notes: 

1. 22 Form As were filed in 2009 for lead, likely associated with lead in stainless steel, brass or 

bronze alloys which are not excluded from Form A eligibility. 

2. The total unique number of facilities reporting in RY 2009 was 20,797 which is not the sum of 

Form R and Form A facilities above, as some facilities file on both Form Rs and Form As (see Table 

7). Average number of Form R Chemicals per facility is 3.68; Average number of Form A Chemicals 

per form (and per facility) is 2.31. The overall average number of chemicals per facility is 3.77. 

3. To count the number of Form As, the number of Form A Chemicals has to be divided by the 

number of Form A Chemicals per form (2.31). Therefore, the number of Form As is estimated to be 

3,851 ((8,872+22)/2.31). Note that “burden per Form A chemical” is the key unit for tracking burden 

associated with a Form A, and that the conversion to number of Form As (i.e, number of Form A 

responses) is done to satisfy certain burden accounting and reporting requirements..4. Universe 

includes the modeled number of chemicals and facilities estimated to report under the Addition of 

National Toxicology Program Carcinogens Rule published on November 26, 2010. It is estimated 

that under the NTP rule, 74 facilities will be added to the regulated community and an additional 186 

Non-PBT chemical Form Rs will be submitted.

Table 14 presents the total annual burden hours estimates for both Form R and Form A. 

Table 14 

Total Annual Burden Hour Estimate 

Form Type

Unit Burden 

Hours 

Per Form

Number of 

Responses 

Number of Form 

R or A Chemicals

Steady State Total 

Burden

Form R (Including Form 

R Schedule 1) 35.70516 69,876 69,876 2,494,934 

Form A 21.95867 3,851 8,894 195,300 

Non-Form (constant) 825,517 

Total 3,515,751 
 

 

ICR 1st FR Notice 2/08/11 

 

40

Estimated Total Annual Cost for All Respondents

The total annual reporting cost for all respondent facilities is determined by multiplying the 

WAWR by the steady state total burden. Table 15 presents the total annual reporting cost for 

Form R and Form A. 

Table 15 

Total Annual Cost Estimate 

(June 2010 dollars) 

Form Type WAWR Steady State Total 

Burden (Hours)

Steady State 

Total Cost 

(June $2010)

Form R (Includes Form R 

Schedule 1) $49.62 2,494,934 $123,798,625 

Form A $49.62 195,300 $9,690,786 

Non-Form (constant) $49.62 825,517 $40,962,154 

Total 3,515,751 $174,451,565 

Note: WAWR based on June 2010 wage data, http://www.bls.gov/ncs/ect/#tables.

 6(e) Bottom-Line Burden Hours and Cost Tables 

This section presents the total burden and cost to the regulated industry to comply with the 

information collection requirements under EPCRA §313 and under PPA §6607, as well as the 

cost to EPA to process Form R and Form As annually. 

 (i) Respondent Tally 

Table 16 presents the total burden and cost for complying with EPCRA §313 for current and new 

reporting requirements. 
 

 

ICR 1st FR Notice 2/08/11 

 

41

Table 16 

Total Annual Burden and Cost 

Activity 

Number of 

Facilities 

(Respondents) 

Number of 

Responses 

Annual Burden 

Hours 

Annual Costs 

(June 2010 

dollars) 

Existing Form Rs 

(Includes Form R 

Schedule 1) 18,993 69,876 2,494,934 $123,798,625 

Existing Form As 3,851 3,851 195,300 $9,690,786 

Non-Form (constant) 825,517 $40,962,154 

Subtotal 20,871a 73,727c 3,515,751 $174,451,565 

New Form R Data 

Elements and 

Instructions b 18,993 69,876 0.00 $0.00 

New Form A Data 

Elements and 

Instructions b 3,851 3,851 0.00 $0.00 

Grand Total $174,451,565 a The total number of facilities reporting is not equal to the sum of Form R and Form A respondents as some facilities 

may file both Form Rs and Form As. 

b The basis for these estimates is derived from RY 2009 TRI reporting with updates to reflect the estimated impacts of 

the Addition of National Toxicology Program Carcinogens Rule, published November 26, 2010. 

c

 The average number of responses per respondents is 3.53.

(ii) The Agency Tally 

The total annual program burden to EPA is estimated to be $4.63 million, and 5.5 FTEs. These 

costs reflect the burden to conduct the EPA activities described above. 

(iii) Variations in the Annual Bottom Line 

Significant variation in the annual respondent reporting/recordkeeping burden and cost is not 

expected over the course of the ICR approval period. 
 

 

ICR 1st FR Notice 2/08/11 

 

42

6(f) Reasons for Change in Burden 

Several changes in the burden estimates have been approved by OMB since the OMB approvals of 

the ICRs on March 2, 2008. On March 20, 2009, OMB approved the merging of the ICR for TRI 

detailed reporting on dioxin and dioxin-like compounds (OMB 2025-007, ICR 2086.02), into the 

TRI Form R ICR (currently OMB Control Number 2025-0009), increasing burden by 899 hours. 

Then on March 27, 2009, OMB approved changes in the number of responses and the burden 

hours for Form R and Form A to reflect the passage of Section 425 of the Omnibus Appropriations 

Act of 2009, which rescinded the December 2006 Toxics Release Inventory Burden Reduction 

Rule. As a result, the OMB-approved numbers for Form R were increased by 140,565 hours and 

for Form A burden were decreased by 318,418 yielding a net increase of 458,983 hours. 

Most recently, on November 26, 2010, the Addition of National Toxicology Program Carcinogens 

Rule was published in the Federal Register. This rule is estimated to increase the number of 

reporting facilities by 74 and the number of Form Rs submitted by 186 with an associated burden 

increase of 6,641 hours. 

Over the past several years, there has been a slight decrease in the number of facilities reporting 

to TRI. Based on the latest data for RY 2009 with updates to reflect the estimated burden due to 

the additional 16 chemicals associated with the Addition of National Toxicology Program 

Carcinogens rule, EPA now estimates the total number of combined Form R and Form A 

responses to be 73,727, the associated total annual burden hours to be 3,515,751, and the annual 

cost to be $174,451,565. Further, the TRI program is proposing to revise data elements and 

instructions for the reporting forms. The revised data elements and instructions are estimated to 

have a negligible impact on form burden. 

Since the ICR approval on March 2, 2008, the reduction in the estimate of total burden of 224,071 

hours (exclusive of the additional 16 National Toxicology Program Carcinogens for which no 

reports have yet been received) is primarily due to the filing of approximately 10,728 fewer forms 

in RY 2009 than was projected in the 2008 ICR Renewal (based on RY 2005 data). Refer to 

Figure 2 and Table 17 for background information on the chronology of both TRI rulemakings and 

ICR renewals which outlines changes that have occurred due to rulemaking.
ICR 1st FR Notice 

43

Figure 2 

TRI Rulemaking and ICR Chronology 
ICR 1st FR Notice 

44

Table 17 

Recent Changes in TRI Form R Burden 

TRI Form R ICR (EPA # 13

Change 

Activity – Explanation

# Responses Burden Hours 

R

1997 Baseline — — RY 1997 Program Change – Industry Expansion Rule: This rule added 7 new industries to the list of industries subject to TRI reporting beginning in RY1998. 39,033 2,467,463 1999 Adjustment – Form R Correction Worksheet: This adjustment revised the number of responses to be more consistent with actual reporting levels. However, it did not correct for overestimation of expected reporting from the Industry Expansion Rule. 

(13,226) (665,666) 

RY 1999 Program Change – PBT Rule: This rule lowered reporting thresholds for certain PBT Chemicals, and added other PBT Chemicals at lower thresholds beginning in RY 2000. 19,990 1,485,411 RY 2000 Program Change – Lead Rule: This rule lowered reporting thresholds for lead and lead compounds beginning in RY 2001. 9,813 786,169 January 2003 Form R ICR Renewal: This request incorporated accounting adjustments to reflect actual number of responses. (57,855) (4,045,540) October 2003 Form R ICR Renewal: This request reflected actual number of responses and accounted for a lower subsequent year reporting burden for non-PBT Chemicals. (4,117) (1,677,812) May 2005 Form R ICR Renewal: This request reflected actual number of responses. (2,000) (91,413) RY 2005 Program Change – TRI Reporting Forms Modification Rule: This rule 

eliminated certain data elements and simplified others beginning in RY 2005. — (50,749) 

RY 2006 Program Change – TRI Burden Reduction Rule: This rule expanded non-PBT Chemical eligibility for Form A and, for the first time, allowed limited use of Form A for PBT Chemicals. 

(15,100) (505,117) 

RY 2008 New Data Elements and Revised Instructions: The proposed additions and revisions improve and enhance the data as well as standardize the information collected. (149) (24,193) RY 2008 Form R ICR Renewal — — RY 2010 New Data Element and Revised Instructions 0.00 RY 2011 Form R ICR UNIVERSE PROJECTION 3,125 (722,346) Notes: 
ICR 1st FR Notice 2/08/11 

45

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

The annual public burden for form calculations such as, rule familiarization, compliance 

determination, calculations and form completion, and recordkeeping, which is approved under 

OMB Control No. 2025-0009, is estimated to average 35.70516 hours per response for a facility 

filing a Form R and 21.95867 hours for a facility filing a Form A for one chemical. There is 

additional non-form burden associated with non-reporter compliance determination, petitions 

and supplier notification. 

Burden is defined as the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology 

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the 

collection of information; and transmit or otherwise disclose the information. 

An agency may not conduct or sponsor, and a person is not required to respond to, a collection 

of information unless it displays a currently valid OMB control number. The OMB control 

numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. 

To comment on the Agency's need for this information, the accuracy of the provided burden 

estimates, and any suggested methods for minimizing respondent burden, including the use of 

automated collection techniques, EPA has established a public docket for this ICR under Docket 

ID No. EPA-HQ-TRI-2010-0835, which is available for online viewing at 

www.regulations.gov, or in-person viewing at the Office of Environmental Information Docket 

in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW., 

Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 

p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading 

Room is (202) 566-1744, and the telephone number for the Office of Environmental Information 

Docket is (202) 566-1752. The www.regulations.gov site can be used to submit or view public 

comments, access the index listing of the contents of the public docket, and access those 

documents in the public docket that are available electronically. When in the system, select 

“search,” then key in the Docket ID Number identified above. Also, you can send comments to 

the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th 

Street, NW., Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA 

Docket ID No. EPA-HQ-TRI-2010-0835 and OMB Control No. 2025-0009 in any 

correspondence. 

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

form. 
ICR 1st FR Notice 2/08/11 

46

REFERENCES 

Certain references cited are available in EPA Docket Identification Number EPA-HQ-TRI2010-0835; other references are readily available. 

Arbuckle, J. Gordon, et al., 1993. Environmental Law Handbook, Twelfth Edition. Government 

Institutes, Inc., Rockland MD. 

U.S. Department of Labor, Bureau of Labor Statistics. Employer Costs for Employee 

Compensation. U.S. Department of Labor, Washington, D.C. June 2010. 

U.S. EPA, 1986. Emergency Planning and Community Right-to-Know Act of 1986, §313 (42 

U.S.C.A. §1023. http://www.epa.gov/tri/lawsandregs/index.htm.

U.S. EPA, 1990. Pollution Prevention Act (42 U.S.C.A. §13101-13109. U.S. EPA 

http://www.epa.gov/tri/lawsandregs/index.htm.

U.S. EPA, 2007. Analysis of the Estimated Burden and Cost of Form R Schedule 1 for Dioxin and 

Dioxin-like Compounds; Toxic Equivalency Reporting; Community Right to Know Toxic 

Chemical Release Reporting (May 10, 2007). 

U.S. EPA, 2008. Procedure for Quality Policy. CIO 2106-P-0.10. October 20, 2008. 

U.S. EPA, 2011. Revising TRI Burden to Ratio-Based Methodology; TRI Regulatory 

Development Branch, TRI Program Division, Office of Information Analysis and Access, 

Office of Environmental Information (February 1, 2011). 

U.S. EPA. 40 CFR Part 372 Toxic Chemical Release Reporting: Community Right-to-Know. 

http://www.epa.gov/tri/lawsandregs/index.htm#cfr

Addition of National Toxicology Program Carcinogens; Community Right-to-Know Toxic 

Chemical Release Reporting Final Rule. 40 CFR Part 372. EPA Docket ID Number EPA-HQTRI-2010-0006. Federal Register Vol. 75 No. 227. November 26, 1010. 
ICR 1st FR Notice 2/08/11 

47

APPENDIX A 

BLANK FORMS 

FORM A 

FORM R 

FORM R SCHEDULE 1 
Form Approved OMB Number: 2025-0009 

(IMPORTANT: Read instructions before completing form; type or use fill-and-print form) Approval Expires: 07/31/2011 Page ___ of ___ 

TOXICS RELEASE INVENTORY 

FORM A 

WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center 2. APPROPRIATE STATE OFFICE OR TRI Facility ID Number 

 P. O. Box 10163 (See instructions in Appendix E) 

 Fairfax, VA 22038 

Revision (Enter up to two code(s)) Withdrawal (Enter up to two code(s)) This section only applies if you are revising or withdrawing a 

previously submitted form, otherwise leave blank. 

 

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

PART I. FACILITY IDENTIFICATION INFORMATION 

SECTION 1. REPORTING YEAR _____________ 

SECTION 2. TRADE SECRET INFORMATION 

Are you claiming the toxic chemical identified on page 2 as a trade secret? 

2.1 Yes (Answer question 2.2; 

attach substantiation forms) 

No (Do not answer 2.2; 

 go to Section 3) 

2.2 Is this copy Sanitized Unsanitized 

(Answer only if “Yes” in 2.1) 

SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.) 

I hereby certify that to the best of my knowledge and belief, for each toxic chemical listed in this statement, the annual reportable amount as defined in 40 CFR372.27 

(a), did not exceed 500 pounds for this reporting year and that the chemical was manufactured, processed, or otherwise used in an amount not exceeding 1 million 

pounds during this reporting year. 

Name and official title of owner/operator or senior management official: Signature: Date Signed 

SECTION 4. FACILITY IDENTIFICATION 

Facility or Establishment Name TRI Facility ID Number 

Physical Street Address Mailing Address (if different from physical street address) 

City/County/State/ZIP Code City/County/State/ZIP Code Country (Non-US) 

4.1 

4.2 This report contains information for: (Important: Check c or d if applicable) c. A Federal facility d. GOCO 

Technical Contact Name Telephone Number (include area code) 

4.3 

Email Address 

4.4 Public Contact Name Telephone Number (include area code) 

Email Address 

Primary

4.5 NAICS Code(s) (6 digits) 

a. b. c. d. e. f. 

a. 4.6 Dun & Bradstreet 

Number(s) (9 digits) b. 

SECTION 5. PARENT COMPANY INFORMATION 

5.1 Name of Parent Company 

 

5.2 Parent Company’s Dun & Bradstreet Number NA 

EPA Form 9350 -2 (Rev. 12/2010) - Previous editions are obsolete. 
Form Approved OMB Number: 2025-0009 

(IMPORTANT: Read instructions before completing form; type or use fill-and-print form) Approval Expires: 07/31/2011 Page ___ of ___ 

EPA FORM A TRI Facility ID Number 

PART II. CHEMICAL IDENTIFICATION 

Do not use this form for reporting PBT chemicals, including Dioxin and Dioxin-like Compounds* 

SECTION 1. TOXIC CHEMICAL IDENTITY Report ___ of ___ 

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

1.1 

Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.) 

1.2 

Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked “Yes”. Generic Name must be structurally descriptive.) 

1.3 

SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above) 

Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.) 

2.1 

SECTION 1. TOXIC CHEMICAL IDENTITY Report ___ of ___ 

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

1.1 

Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.) 

1.2 

Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked “Yes”. Generic Name must be structurally descriptive.) 

1.3 

SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above) 

Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.) 

2.1 

SECTION 1. TOXIC CHEMICAL IDENTITY Report ___ of ___ 

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

1.1 

Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.) 

1.2 

Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked “Yes”. Generic Name must be structurally descriptive.) 

1.3 

SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above) 

Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.) 

2.1 

SECTION 1. TOXIC CHEMICAL IDENTITY Report ___ of ___ 

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

1.1 

Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.) 

1.2 

Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked “Yes”. Generic Name must be structurally descriptive.) 

1.3 

SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above) 

Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.) 

2.1 

*See the TRI Reporting Forms and Instructions manual for the list of PBT Chemicals (including Dioxin and Dioxin-like Compounds)

EPA Form 9350 -2 (Rev. 12/2010xx) - Previous editions are obsolete. (Make additional copies of this page, if needed) 
Form Approved OMB Number: 2025-0009 

(IMPORTANT: Read instructions before completing form; type or use fill-and-print form) Approval Expires: 07/31/2011 Page 1 of 6 

TRI Facility ID Number 

Toxic Chemical, Category, or Generic Name 

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 

WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center 

 P. O. Box 10163 

 Fairfax, VA 22038 

2. APPROPRIATE STATE OFFICE 

 (See instructions in Appendix E) 

This section only applies if you are 

revising or withdrawing a 

previously submitted form, 

otherwise leave blank. 

Revision (Enter up to two code(s)) Withdrawal (Enter up to two code(s))

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

PART I. FACILITY IDENTIFICATION INFORMATION 

SECTION 1. REPORTING YEAR ________ 

SECTION 2. TRADE SECRET INFORMATION

Are you claiming the toxic chemical identified on page 2 as a trade secret? 

2.1 Yes (Answer question 2.2; 

attach substantiation forms) 

No (Do not answer 2.2; 

go to Section 3) 

2.2 Is this copy Sanitized Unsanitized

(Answer only if “Yes” in 2.1) 

SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.) 

I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted information is true and complete and 

that the amounts and values in this report are accurate based on reasonable estimates using data available to the preparers of this report.

Name and official title of owner/operator or senior management official: Signature: Date: 

SECTION 4. FACILITY IDENTIFICATION

Facility or Establishment Name TRI Facility ID Number 

Physical Street Address Mailing Address (if different from physical street address) 

City/County/State/ZIP Code City/County/State/ZIP Code Country (Non-US) 

4.1 

4.2 This report contains information for: (Important: 

Check a or b; check c or d if applicable) 

a. An entire 

facility 

b. Part of a 

facility 

c. A federal 

facility 

d. GOCO 

Telephone Number (include area code) Technical Contact Name 

4.3 

Email Address 

Telephone Number (include area code) Public Contact Name 

4.4 

Email Address 

Primary 4.5 NAICS Code(s) 

(6 digits) a. b. c. d. e. f. 

4.6 Dun & Bradstreet a. 

Number(s) (9 digits) b. 

SECTION 5. Parent Company Information

5.1 Name of Parent Company 

5.2 Parent Company’s Dun & Bradstreet 

Number 

NA 

EPA form 9350 -1 (Rev. 12/2010) – Previous editions are obsolete. 
Form Approved OMB Number: 2025-0009 

(IMPORTANT: Read instructions before completing form; type or use fill-and-print form) Approval Expires: 07/31/2011 Page 2 of 6 

TRI Facility ID Number 

FORM R

Part II. CHEMICAL-SPECIFIC INFORMATION Toxic Chemical, Category, or Generic Name 

SECTION 1. TOXIC CHEMICAL IDENTITY (Important: DO NOT complete this section if you are reporting a mixture in 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 category.) 

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

1.3 Generic Chemical Name (Important: Complete only if Part I, Section 2.1 is checked “Yes”. Generic Name must be structurally descriptive.) 

SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1.)

2.1 Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.) 

SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY 

 (Important: Check all that apply.) 

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

 a.  Produce b.  Import 

 If Produce or Import 

 c.  For on-site use/processing 

 d.  For sale/distribution 

 e.  As a by-product 

 f.  As an impurity 

a.  As a reactant 

b.  As a formulation component 

c.  As an article component 

d.  Repackaging 

d.  As an impurity 

a.  As a chemical processing aid 

b.  As a manufacturing aid 

c.  Ancillary or other use 

SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON SITE AT ANY TIME DURING THE 

CALENDAR YEAR 

4.1 (Enter two digit code from instruction package.) 

SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ON SITE 

A. Total Release (pounds/year*) 

 (Enter a range code** or estimate)

B. Basis of Estimate

 (Enter code) 

C. Percent from Stormwater 

5.1 Fugitive or non-point 

air emissions NA 

5.2 Stack or point 

emissions NA 

5.3 Discharges to receiving 

streams or water bodies 

(Enter one name per 

box) 

NA 

 Stream or Water Body Name 

5.3.1 

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. 12/2010) – Previous editions are obsolete. *For Dioxin or Dioxin-like compounds, report in grams/year. 

**Range Codes: A= 1-10 pounds; B= 11-499 pounds; C= 500-999 pounds. 
Form Approved OMB Number: 2025-0009 

(IMPORTANT: Read instructions before completing form; type or use fill-and-print form) Approval Expires: 07/31/2011 Page 3 of 6 

TRI Facility ID Number 

FORM R

 Toxic Chemical, Category, or Generic Name Part II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)

SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ON SITE 

(continued) 

NA 

A. Total Release (pounds/year*) (Enter a range 

 code** or estimate) 

B. Basis of Estimate

 (Enter code) 

5.4.1 Underground Injection on-site 

to Class I Wells 

5.4.2 Underground Injection on-site 

to Class II-V Wells 

5.5 Disposal to land on-site 

5.5.1A RCRA Subtitle C landfills 

5.5.1B Other landfills 

5.5.2 Land treatment/application 

farming 

5.5.3A RCRA Subtitle C surface 

impoundments 

5.5.3B Other surface impoundments 

5.5.4 Other disposal 

SECTION 6. TRANSFER(S) OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS 

6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs) NA 

6.1._ POTW Name

POWT Address 

City County State ZIP 

A. Quantity Transferred to this POTW 

 (pounds/year*) (Enter range code**or estimate) 

 B. Basis of Estimate 

 (Enter code) 

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 NA 

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

Off-Site Location Name: 

Off-Site Address: 

City County State ZIP Country (non-US)

Is this location under control of reporting facility or parent company?  Yes  No 

EPA form 9350 -1 (Rev. 12/2010) – Previous editions are obsolete. *For Dioxin or Dioxin-like compounds, report in grams/year. 

**Range Codes: A= 1-10 pounds; B= 11-499 pounds; C= 500-999 pounds. 
Form Approved OMB Number: 2025-0009 

(IMPORTANT: Read instructions before completing form; type or use fill-and-print form) Approval Expires: 07/31/2011 Page 4 of 6 

TRI Facility ID Number 

FORM R

Part II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED) Toxic Chemical, Category, or Generic Name 

SECTION 6.2. TRANSFERS TO OTHER OFF-SITE LOCATION (CONTINUED) 

A. Total Transfer (pounds/year*) 

 (Enter a 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 

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

Off-Site Location Name: 

Off-Site Address: 

City County State ZIP Country (non-US)

Is location under control of reporting facility or parent company? Yes  No 

A. Total Transfer (pounds/year*) 

 (Enter a 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) - Check here if no on-site waste treatment method 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.b 1 2 7A.1c 

3 4 5 

6 7 8 

7A.2a 7A.2.b 1 2 7A.2c 

3 4 5 

6 7 8 

7A.3a 7A.3.b 1 2 7A.3c 

3 4 5 

6 7 8 

7A.4a 7A.4.b 1 2 7A.4c 

3 4 5 

6 7 8 

7A.5a 7A.5.b 1 2 7A.5c 

3 4 5 

6 7 8 

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.) 

EPA form 9350 -1 (Rev. 12/2010) – Previous editions are obsolete. *For Dioxin or Dioxin-like compounds, report in grams/year. 

**Range Codes: A= 1-10 pounds; B= 11-499 pounds; C= 500-999 pounds. 
Form Approved OMB Number: 2025-0009 

(IMPORTANT: Read instructions before completing form; type or use fill-and-print form) Approval Expires: 07/31/2011 Page 5 of 6 

TRI Facility ID Number 

FORM R

Part II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED) Toxic Chemical, Category, or Generic Name 

SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES 

 NA 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)) 

1 2 3 

SECTION 7C. ON-SITE RECYLING PROCESSES 

 NA Check here if no on-site recycling is applied to any waste stream containing the toxic chemical or chemical category. 

Recycling Methods (Enter 3-character code(s)) 

1. 2. 3. 

SECTION 8. DISPOSAL OR OTHER RELEASES, SOURCE REDUCTION, AND RECYCLING ACTIVITIES 

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 

8.1.a Total on-site disposal to Class I Underground Injection Wells, 

RCRA Subtitle C landfills, and other landfills 

8.1.b Total other on-site disposal or other releases 

8.1.c Total off-site disposal to Class I Underground Injection Wells, 

RCRA Subtitle C landfills, and other landfills 

8.1.d Total other off-site disposal or other releases 

8.2 Quantity used for energy recovery on-site 

8.3 Quantity used for energy recovery off-site 

8.4 Quantity recycled on-site 

8.5 Quantity recycled off-site 

8.6 Quantity treated on-site 

8.7 Quantity treated off-site 

8.8 Quantity released to the environment as a result of remedial 

actions, catastrophic events, or one-time events not associated 

with production processes (pounds/year*) 

8.9 Production ratio or activity index 

8.10 Did your facility engage in any source reduction activities (newly implemented and/or ongoing) for this chemical during the reporting year? 

If so, complete the following section; if not, check NA. NA 

Source Reduction 

Activities (Enter 

code(s)) 

Is Activity New? 

(Yes/No) 

Methods of Identify Activity (Enter codes) 

8.10.1 a. b. c. 

8.10.2 a. b. c. 

8.10.3 a. b. c. 

8.10.4 a. b. c. 

EPA form 9350 -1 (Rev. 12/2010) – Previous editions are obsolete. *For Dioxin or Dioxin-like compounds, report in grams/year. 

**Range Codes: A= 1-10 pounds; B= 11-499 pounds; C= 500-999 pounds.
Form Approved OMB Number: 2025-0009 

(IMPORTANT: Type or print; read instructions before completing form) Approval Expires: 07/31/2011 Page 6 of 6 

TRI Facility ID Number 

FORM R

Part II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED) Toxic Chemical, Category, or Generic Name 

SECTION 8.11. DISPOSAL OF OTHER RELEASES, SOURCED REDUCTION, AND RECYCLING ACTIVITIES 

8.11 If you wish to submit additional optional information on source reduction, recycling, or pollution control activities, provide it here. 

SECTION 9. MISCELLANEOUS INFORMATION 

9.1 If you wish to submit any miscellaneous, additional, or optional information regarding your Form R submission, provide it here.

EPA form 9350 -1 (Rev. 12/2010) – Previous editions are obsolete. *For Dioxin or Dioxin-like compounds, report in grams/year.

**Range Codes: A= 1-10 pounds; B= 11-499 pounds; C= 500-999 pounds. 
EPA Form 9350-3

(IMPORTANT: Read instructions before completing form; type or use fill-and-print form)

Form Approved OMB Number: 2025-0007 

Approval Expires: 07/31/2011 Page 1 of 4

United States

Environmental Protection 

Agency

FORM R Schedule 1 TRI Facility ID Number

PART II. CHEMICAL-SPECIFIC INFORMATION (continued)

SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM ON-SITE

5.1 NA 5.2 NA 5.3 Discharges to receiving streams or water bodies

(Enter data for one stream or water body per box)

 NA 

Fugitive or nonpoint air emissionsStack or point

air emissions

5.3.1 5.3.2 5.3.3

D. Mass (grams) of each compound in the category (1-17)

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

If additional pages of Section 5.3 are attached, indicate the total number of pages in this box 

and indicate the Section 5.3 page number in this box (Example: 1, 2, 3, etc.)
EPA Form 9350-3

(IMPORTANT: Read instructions before completing form; type or use fill-and-print form)

Form Approved OMB Number: 2025-0007 

Approval Expires: 07/31/2011 Page 2 of 4

FORM R Schedule 1 TRI Facility ID Number

PART II. CHEMICAL-SPECIFIC INFORMATION (continued)

SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM ON-SITE

Underground Injection 5.5 Disposal to land o-nsite

5.4.1 NA 5.4.2 NA 5.5.1.A NA 5.5.1.B NA 5.5.2 NA 5.5.3A NA 5.5.3B NA 5.5.4 NA

Underground 

Injection on-site 

to Class I Wells

Underground 

Injection on-site 

to Class II-V 

Wells

RCRA Subtitle C 

landfills

Other landfills Land treatment/ 

application farming

RCRA Subtitle C 

surface 

impoundments

Other surface 

impoundments

Other disposal

C. Mass (grams) of each compound in the category (1-17)

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17
EPA Form 9350-3

(IMPORTANT: Read instructions before completing form; type or use fill-and-print form)

Form Approved OMB Number: 2025-0007 

Approval Expires: 07/31/2011 Page 3 of 4

FORM R Schedule 1

PART II. CHEMICAL-SPECIFIC INFORMATION (continued)

TRI Facility ID Number

SECTION 6. TRANSFERS OF DIOXIN AND DIOXIN-LIKE COMPOUNDS IN WASTES TO OFF-SITE LOCATIONS

6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs) NA 

6.1.A.3 Mass (grams) of Each Compound in the Category (1-17)

1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 16 17

6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS NA 

6.2.__ D. Mass (grams) of each compound in the category (1-17)

1. 1 2 3 4 5 6 7 8

9 10 11 12 13 14 15 16 17

2. 1 2 3 4 5 6 7 8

9 10 11 12 13 14 15 16 17

3. 1 2 3 4 5 6 7 8

9 10 11 12 13 14 15 16 17

4. 1 2 3 4 5 6 7 8

9 10 11 12 13 14 15 16 17

6.2.__ D. Mass (grams) of each compound in the category (1-17)

1. 1 2 3 4 5 6 7 8

9 10 11 12 13 14 15 16 17

2. 1 2 3 4 5 6 7 8

9 10 11 12 13 14 15 16 17

3. 1 2 3 4 5 6 7 8

9 10 11 12 13 14 15 16 17

4. 1 2 3 4 5 6 7 8

9 10 11 12 13 14 15 16 17

If additional pages of Section 6.2 are attached, indicate the total number of pages in this box 

and indicate the Section 6.2 page number in this box (Example: 1, 2, 3, etc.)
EPA Form 9350-3

(IMPORTANT: Read instructions before completing form; type or use fill-and-print form)

Form Approved OMB Number: 2025-0007 

Approval Expires: 07/31/2011 Page 4 of 4

FORM R Schedule 1

PART II. CHEMICAL-SPECIFIC INFORMATION (continued)

TRI Facility ID Number

SECTION 8. DISPOSAL OR OTHER RELEASES, SOURCE REDUCTION, AND RECYCLING ACTIVITIES FOR DIOXIN AND DIOXIN-LIKE COMPOUNDS 

(current year only)

8.1a 8.1b 8.1c 8.1d 8.2 8.3 8.4 8.5 8.6 8.7 8.8

Total on-site 

disposal to 

Class 1 

Underground 

Injection Wells,

RCRA Subtitle

C landfills, and

other landfills

Total other 

on-site disposal

or other 

releases

Total off-site 

disposal to 

Class 1 

Underground 

Injection Wells,

RCRA Subtitle

C landfills, and

other landfills

Total other 

off-site disposal

or other 

releases

Quantity used 

for energy 

recovery 

on-site

Quantity used 

for energy 

recovery 

off-site 

Quantity 

recycled 

on-site

Quantity 

recycled 

off-site

Quantity 

treated 

on-site

Quantity 

treated 

off-site 

Quantity released to

the environment as a

result of remedial 

actions, catastrophic

events, or one-time

events not associated

with production 

processes

Column f. Mass (grams) of each compound in the category (1-17)

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17
ICR 1st FR Notice 

60
ICR 1st FR Notice 2/08/11 

61

APPENDIX B 

REPORTING FORM INSTRUCTIONS 

ASSOCIATED WITH FORM CHANGES 
ICR 1st FR Notice 2/08/11 

62

Appendix B: Reporting Form R Changes and Associated Instruction Revisions 

Last updated: 11/15/2010 

New revisions to the Form R instructions follow. These revisions are aimed at improving the user 

experience by clarifying the intent of questions and reducing confusion. An overview of changes 

made in this version of the Form R itself are listed below. Revisions to the instructions are 

identified in the subsequent pages using underlined text. Sections of the instructions which remain 

unchanged are not referenced. To review existing instructions, Toxic Chemical Release Inventory 

Reporting Forms and Instructions – Revised 2009 Version, visit 

http://www.epa.gov/tri/report/index.htm. 

Revisions to Form R 

Table B-1: Overview of Form R Revisions 

Please refer to specific sections in the following text for details 

Form Revision Rationale Form 

1 Remove the NA box from the 

Parent Company field (Part I: 

Sec. 5,.5.1) 

The NA box is currently used to indicate a 

foreign parent company. Removing this box 

and requiring facilities to report the highest 

level U.S. parent company will facilitate 

analysis of the TRI data at the parent 

company level. 

R/A 

2 Disaggregate the “Total 

Transfers” field and add fields 

to identify chemical discharge 

quantities to specific publicly 

owned treatment works 

(POTWs) Part II: Sec 6.1) 

The existing form collects a single “Total 

Transfer” quantity for transfers to all POTWs. 

Providing separate fields for the transfer 

quantity to each POTW will facilitate analysis 

of the releases to specific watersheds. 

R 

3 Section 8 Enhancements 

° Change instructional 

statement on form to include 

“newly implemented and/or 

ongoing” source reduction 

activities (Part II: Sec. 8.10). 

° Add an “NA” box to match 

associated text revisions (Part 

II: Sec. 8.10) 

° Add a field to allow separate 

reporting for both new and 

ongoing source reduction 

activities (Part II: Sec. 8.10, 

8.10.1-4). 

° Remove the “Yes” box and 

enlarge the text section for 

The existing form requests information on 

“any source reduction activities for this 

chemical during the reporting year;” but the 

Reporting Forms and Instructions request 

information on “newly implemented” source 

reduction activities. This change on the form 

and in the instructions will remove this 

difference, allowing facilities to distinguish 

between new and ongoing source reduction 

activities. It also provides a larger text box 

(8.11) where facilities can provide optional 

information on source reduction, recycling, or 

pollution control activities. 

R 
ICR 1st FR Notice 2/08/11 

63

question on optional Pollution 

Prevention information (Form R 

Section 8.11). 

4 Add a new question to capture 

miscellaneous and optional 

information regarding the 

submission (Part II: Sec..9.1). 

This new text box allows facilities to provide 

optional, miscellaneous information that may 

be helpful to EPA and/or the public in using 

or interpreting their data (e.g., facility 

closures, explanations for changes in release 

quantities, etc.). 

R 

5 Add NA boxes (Part II: Sec 

5.3, 6.1, 6.2) 

Add NA boxes were appropriate to improve 

consistency within the form. 

R (including 

R Schedule 1)

Specific Form and Instruction Revisions 

PART 1 FACILITY IDENTIFICATION INFORMATION

Section 5. Parent Company Information 

Form Revisions: Removed NA option for name of parent company (see also below) 

Instruction Revisions: See underlined text which follows. 

You must provide information on your parent company. For purposes of the Form R, a parent 

company is defined as the highest level company, located in the United States, which directly 

owns at least 50 percent of the voting stock of your company. If your facility is owned by a foreign 

entity, enter NA in this space provide the highest level parent company based in the United States 

even if that is your own facility. Do not enter NA. Corporate names should be treated as parent 

company names for companies with multiple facility sites. For example, the Bestchem Corporation 

is not owned or controlled by any other corporation but has sites throughout the country whose 

names begin with Bestchem. In this case, Bestchem Corporation should be listed as the parent 

company. Note that a facility that is a 50:50 joint venture is its own parent company. When a 

facility is owned by more than one company and none of the facility owners directly owns at least 

50 percent of its voting stock, the facility should provide the name of the parent company of either 

the facility operator or the owner with the largest ownership interest in the facility. If neither the 

operator nor this owner has a parent company, then the NA box should be checked.

5.1 Name of Parent Company 

Form Revisions: Removed NA option for name of parent company 

Instruction Revisions: See underlined text which follows. 

Enter the name of the corporation or other business entity that is your ultimate U.S. parent 

company. If your facility has no parent company, you should check the NA box higher level U.S. 

parent company, you should enter the name of your facility in the Parent Company box.
ICR 1st FR Notice 2/08/11 

64

PART II CHEMICAL-SPECIFIC INFORMATION 

Section 5. Quantity of the Toxic Chemical Entering Each Environmental Medium Onsite 

5.3 Discharges to Receiving Streams or Water Bodies 

Form Revisions: Added NA box as a response to the question, “Discharges to receiving streams or 

water bodies (enter one name per box)” 

Instruction Revisions: See underlined text which follows and note addition of blank underscored 

spaces for inclusion of appropriate numbers which are bracketed 

In Section 5.3 you are to enter all the names of the streams or water bodies to which your facility 

directly discharges the EPCRA Section 313 chemical on which you are reporting. A total of three 

spaces is provided on Page 2 of Form R. Enter the name of each receiving stream or surface water 

body to which the EPCRA Section 313 chemical being reported is directly discharged. Report the 

name of the receiving stream or water body as it appears on the NPDES permit for the facility. If 

the stream is not included in the NPDES permit or its name is not identified in the NPDES permit, 

either 1) enter the name of the off-site stream or water body by which it is publicly known or 2) if 

the receiving waters are unnamed, enter the first publicly named water body to which the receiving 

waters are a tributary. Do not list a series of streams through which the EPCRA Section 313 

chemical flows. Be sure to include all the receiving streams or water bodies that receive 

stormwater runoff from your facility. Do not enter names of streams to which off-site treatment 

plants discharge. You should check the NA box in Section 5.3.[ ]_ if there are no discharges to 

receiving streams or water bodies of the waste stream that contains or contained the EPCRA 

Section 313 chemical (See discussion of NA vs. a Numeric Value (e.g., Zero) in the introduction 

of Section 5). 

Section 6. Transfer(s) of the Toxic Chemical in Wastes to Off-Site Locations 

Form Revision: Disaggregate the “Total Transfers” field and add fields to identify chemical 

discharge quantities to specific POTW(s)(see also below) 

Instruction Revisions: 

 Title for Section 6. revised from “Transfers of the Toxic Chemical in Wastes to Off-Site 

Locations” to “Transfer(s) of the Toxic Chemical in Wastes to Off-Site Locations” 

 In Sub-Sections titled “NA vs. a Numeric Value (e.g., Zero)” and “Important,” there are 

minor changes noted below such as changes to the section numbers followed by an 

underscore. 

NA vs. a Numeric Value (e.g., Zero). You must enter a numeric value if you transfer an EPCRA 

Section 313 chemical to a POTW or transfer wastes containing that toxic chemical to other off-site 

locations. If the aggregate amount transferred was less than 0.5 pound, then you should enter zero 
ICR 1st FR Notice 2/08/11 

65

(unless the chemical is listed as a PBT chemical). Also report zero for transfers of listed mineral 

acids (i.e., hydrogen fluoride and nitric acid), if they have been neutralized to a pH of 6 or above 

prior to discharge to a POTW; do not check NA. 

However, if you do not discharge wastewater containing the reported EPCRA Section 313 

chemical to a POTW, you should check enter NA in the box in Section 6.1. If you do not ship or 

transfer wastes containing the reported EPCRA Section 313 chemical to other offsite locations, 

you should check enter NA in the box in Section 6.2. 

Important: You must number the boxes for reporting the information for each POTW or other 

off-site location in Sections 6.1 and 6.2. In the upper left hand corner of each box, the section 

number is either 6.1.[_] or 6.2.[_]. If you are reporting multiple POTWs or multiple other off-site 

locations, and you are submitting a hard-copy report, note instructions below to photocopy form 

pages.

If you report a transfer of the EPCRA Section 313 chemical to one or more other off-site locations, 

you should number the boxes in section 6.1. as 6.1.1, etc. If you transfer the EPCRA Section 313 

chemical to more than two one POTWs, you should photocopy Page 3 of Form R as many times as 

necessary and then number the boxes consecutively for each POTW (e.g. 6.1.2, 6.1.3, etc.). At the 

bottom of Part II Section 6.1 of the Form R you will find instructions indicating each page 3 that is 

submitted, indicate the total number of pages numbered “3” that you are submitting as part of 

Form R and indicate the sequence of those pages. For example, your facility transfers the reported 

EPCRA Section 313 chemical in wastewaters to two three POTWs. You would photocopy Page 3 

once, indicate at the bottom of each Page 3 that there are a total of two pages numbered “3” and 

then indicate the first and second Page 3. The boxes for the first two POTWs on the first Page 3 

should be numbered 6.1.1 6.1.B.1 and 6.1.B.2, while the box for second third POTW on the 

second Page 3 should be numbered 6.1.2. 6.1.B.3.

If you report a transfer of the EPCRA Section 313 chemical to one or more other off-site locations, 

you should number the boxes in section 6.2 as 6.2.1, 6.2.2, etc. If you transfer the EPCRA Section 

313 chemical to more than two other off-site locations, you should photocopy Page 4 of Form R as 

many times as necessary and then number the boxes consecutively for each off-site location. At 

the bottom of Page 4 you will find instructions for indicating the total number of Page 4s that you 

are submitting as part of the Form R as well as indicating the sequence of those pages. For 

example, your facility transfers the reported EPCRA Section 313 chemical to three other off-site 

locations. You should photocopy page 4 once, indicate at the bottom of Section 6.2 on each Page 4 

that there are a total of two Page 4s and then indicate the first and second Page 4. The boxes for 

the two off-site locations on the first Page 4 would be numbered 6.2.1 and 6.2.2, while the box for 

the third off-site location on the second Page 4 should be numbered 6.2.3. Please note section 6.2 

starts on Page 3 and continues on Page 4.

6.1 Discharges to Publicly Owned Treatment Works 

Form Revisions: Disaggregate the “Total Transfers” field and add fields to identify chemical 

discharge quantities to specific POTW(s); Also an “NA” box has been added to 6.1 
ICR 1st FR Notice 2/08/11 

66

“DISCHARGE(S) TO PUBLICALLY OWNED TREATMENT WORK(S) (POTWs)” In addition, 

the numbering under 6.1 has changed from 6.1.1 to 6.1.__. 

Instruction Revisions: See underlined text which follows. 

In Section 6.1.[_] you should enter the name and address for each POTW to which your facility 

discharges or otherwise transfers wastewater containing the reported EPCRA Section 313 

chemical. The most common transfers of this type will be conveyances of the toxic chemical in 

facility wastewater through underground sewage pipes; however, materials may also be trucked or 

transferred via some other direct methods to a POTW. In Section 6.1.[_]A or Section 6.1.[_]B (for 

columns A and B, respectively) estimate the quantity of the reported EPCRA Section 313 

chemical transferred to each POTW and the basis upon which the estimate was made, respectively. 

If you do not discharge wastewater containing the reported EPCRA Section 313 chemical to a 

POTW, enter NA in the box in Section 6.1. (See discussion of NA vs. a Numeric Value (e.g., 

Zero) in the introduction of Section 6). 

Instruction Revisions: 

 Section Titled “Total Transfers” has been renamed “Quantity Transferred to this POTW” 

 See underlined text which follows for additional changes. 

6.1.[_]A Quantity Transferred to this POTW 

Enter the total amount, in pounds, of the reported EPCRA Section 313 chemical that is contained 

in the wastewaters transferred to each all POTWs. Do not enter the total poundage of the 

wastewaters. If the amount transferred is less than 1,000 pounds, you may report a range by 

entering the appropriate range code (range reporting in section 6.1.__.A. does not apply to PBT 

chemicals). The following reporting range codes are to be used: 

Code Reporting Range (in pounds) 

A 1-10 

B 11-499 

C 500-999 

6.1.[_]B Basis of Estimate 

You must identify the basis for your estimate of the total quantity of the reported EPCRA Section 

313 chemical in the wastewater transferred to each POTW. You should enter one of the following 

letter codes that applies to the method by which the largest percentage of the estimate was derived. 

M1 Estimate is based on continuous monitoring data or measurements for the EPCRA Section 

313 chemical. 

M2 Estimate is based on periodic or random monitoring data or measurements for the EPCRA 

Section 313 chemical. 
ICR 1st FR Notice 2/08/11 

67

C Estimate is based on mass balance calculations, such as calculation of the amount of the 

EPCRA Section 313 chemical in streams entering and leaving process equipment. 

E1 Estimate is based on published emission factors, such as those relating release quantity to 

through-put or equipment type (e.g., air emission factors). 

E2 Estimate is based on-site specific emission factors, such as those relating release quantity 

to through-put or equipment type (e.g., air emission factors). 

O Estimate is based on other approaches such as engineering calculations (e.g., estimating 

volatilization using published mathematical formulas) or best engineering judgment. This 

would include applying an estimated removal efficiency to a waste stream, even if the 

composition of the stream before treatment was fully identified through monitoring data. 

6.2 Transfers to Other Off-Site Locations 

Form Revisions: An “NA” box has been added to 6.2

Section 8. Disposal or Other Releases, Source Reduction, and Recycling Activities 

Form Revisions: Section 8 enhancements (see also below) 

Form and Instruction Revisions: Title changed from “Source Reduction and Recycling Activities” 

to “Disposal or Other Releases, Source Reduction, and Recycling Activities” 

8.10 Did your facility engage in any source reduction activities (newly implemented and/or 

ongoing) for this chemical during the reporting year? If so, complete the following 

section; if not, check NA. 

Form Revisions: Section 8 enhancements (see also below) 

 Question changed from “Did your facility engage in any source reduction activities for this 

chemical during the reporting year?. If not enter NA” in Section 8.10.1 and answer Section 

8.11.” to “Did your facility engage in any source reduction activities (newly implemented 

and/or ongoing) for this chemical during the reporting year? If so, complete the following 

section, if not, check NA.” 

 An “NA” box has been included to match associated text revisions (above) in 8.10. 

 A column asking “Is activity new? (Yes/No)” has been included. 

Instruction Revisions: See underlined text which follows

Section 8.10 must be completed if a source reduction activity was newly implemented specificly 

(in whole or in part) your facility is currently implementing any source reduction activities (in 

whole or in part) for the reported EPCRA Section 313 chemical during the reporting year. If your 
ICR 1st FR Notice 2/08/11 

68

facility did not engage in any source reduction activity for the reported EPCRA Section 313 

chemical, enter check the NA box in Section 8.10. If your facility engaged in any source reduction 

activity for the reported EPCRA Section 313 chemical during the reporting year, report the activity 

or activities that were implemented in 8.10.1 through 8.10.4. Source reduction activity codes must 

be entered in the first column. See more detailed information about these codes in the reporting 

instructions section below titled, “Source Reduction Activities.” Include both activities which 

were newly implemented during the reporting year, as well as those that are ongoing activities 

from the previous reporting year. An activity is considered newly implemented if it went into 

effect during this reporting year. All reported source reduction activities should only include those 

which are currently implemented. 

Section 8.11 If you wish to submit additional optional information on source reduction, 

recycling, or pollution control activities, provide it here. 

 

Form Revisions: Section 8 enhancements 

 Removed the “Yes” box and enlarged the text box for the question on optional Pollution 

Prevention information; question has changed from “If you wish to submit additional 

optional information on source reduction, recycling, or pollution control activities, check 

“Yes” to “If you wish to submit additional optional information on source reduction, 

recycling, or pollution control activities, provide it here.” 

Instruction Revisions: 

 Section Heading has changed from “Is Additional Optional Information on Source 

Reduction, Recycling, or Pollution Control Activities Included with this Report?” to 

“Disposal of other releases, source reduction, and recycling activities.” 

 Text regarding mailing instructions as been removed and substituted with the following. 

Check “Yes” for this data element. If you wish to submit any additional optional information on 

source reduction, recycling, or pollution control activities you have implemented in the reporting 

year or in prior years for the reported EPCRA Section 313 chemical, you may provide a 

description in the box supplied on Form R. If you are using TRI-MEweb to submit your report, 

you can use the pull-down text box feature to describe your source reduction, recycling, or 

pollution control activities. You may submit such additional information in hard-copy in addition 

to, or instead of, the information supplied in TRI-MEweb text box feature. If you wish to submit 

by regular mail, please use the following address:

TRI Reporting Center

P.O. Box 10163

Fairfax, VA 22038

To submit hard-copy information for section 8.11 by certified or overnight mail, use the following 

address:

CGI Federal, Inc.
ICR 1st FR Notice 2/08/11 

69

c/o EPA Reporting Center

12601 Fair Lakes Circle

Fairfax, VA 22033

All information submitted in hard-copy must include the name, address, and TRIFD number for 

the facility submitting the information.

If there is a contact person at the facility other than the technical or public contact provided in Part 

I, Section 4, the summary page should include that person’s name and telephone number for 

individuals who wish to obtain further information about those activities. Also submit a copy of 

this additional information to the appropriate state agency as part of the Form R submittal to that 

agency.

While EPA welcomes submissions about recycling and pollution control activities, the Agency is 

most interested in collecting information about innovative and effective source reduction activities. 

In addition, the Agency wishes to encourage reporters to provide enough detailed information 

about their most effective source reduction activities to spur other facilities to adopt similar 

practices, as well as to inform the public about such activities being implemented in their 

communities.

Section 9. Miscellaneous Information 

9.1 Miscellaneous, Optional, and Additional Information for your Form R Report 

Form Revisions: Added new question. “If you wish to submit any miscellaneous, additional, 

optional information regarding your Form R submission, provide it here.” 

Instruction Revisions: The following instructions have been added for this new question. 

Your facility may provide additional information pertaining to any portion of your Form R 

submissions in the box provided on the hard-copy form, or in the drop-down text box provided in 

TRI-MEweb. Your submissions to Section 9.1 regarding miscellaneous, additional, optional 

information may provide the Agency and/or the public with useful data that helps explain why 

your facility submitted data in one or more data elements that might appear unusual or inconsistent 

with previous TRI Form R submissions or with other data supplied by your facility during this 

reporting year. Examples include relatively large changes in quantities reported, production levels 

and/or facility closings. Such additional data may help EPA reduce the need for additional data 

quality control, as well as additional TRI-related enforcement and compliance efforts. 

 
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APPENDIX C 

INFORMATION SOURCES CONTAINING DATA SUBSETS, BUT NOT 

COMPREHENSIVELY COMPARABLE ALTERNATIVES TO TRI DATA 
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Appendix C 

Information Sources Containing Data Subsets, but not Comprehensively Comparable Alternatives 

(TRI Included for Comparison) 

Description Chemical Coverage Industry/Facility Coverage Reporting Frequency 

TRI DATA EPCRA §313 requires facilities to submit 

reports on disposal and releases of particular toxic chemicals exceeding a given threshold. The reports provide information on the quantity of chemical released into the environment, to which medium (air, land, water) the chemical was disposed, as well as information about waste management and the amount of chemicals stored on-site. 

TRI contains information on releases, transfers, and pollution prevention activities for 593 individually listed chemicals and 30 chemical categories—totaling to 682 toxic chemicals. Of these chemicals, 183 are classified as hazardous air pollutants (HAPs). 

NAICS codes corresponding to SIC codes 20-39, as well as 10; 12; 4911, 4931, and 4939; 4953; 5169; 5171; and 7389. A facility need only report if it has 10 more Full Time Equivalents(FTEs) 

Annual EPA co

makes several the TRI Other odata avtheir ow

AIR EMISSIONS (SECTIONS 5.1 AND 5.2) National Emissions Inventory (NEI) NEI provides estimates of man-made pollutant emissions from stationary sources, as well as area sources and mobile sources. These estimates, submitted to EPA by delegated authorities (state or county), electric utilities, and/or generated by EPA 

6 CAPs and 189 HAPs 

No NAICS limitations Triennial MS Ac

downlo
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Description Chemical Coverage Industry/Facility Coverage Reporting Frequency 

from various sources, differ in the methodology used. Air Facility System (AFS)AFS contains compliance and permit data for stationary sources of air pollution regulated by U.S. EPA, and state and local air pollution agencies. 

N/A No NAICS limitations Annual Can be 

access EnforceHistory on a fac

State Air Emissions Inventories Several states and regional agencies maintain their own air emissions inventories. However, the amount of data as well as the types of data elements collected vary widely from state to state. 

Varies widely (e.g., the California Air Resources Board maintains its own list of approx. 400 toxic air pollutants) 

Varies, but states often develop their own toxics inventories due to their specific needs. 

Varies Most o

NEI, anWeb on 

Title V Part 70 Operating Permits Under the 1990 Clean Air Act Amendments, facilities designated as "major sources" and facilities otherwise subject to §112 and Title 

V must apply for a Title V Part 70 Operating Permit. As part of the application for a Title V permit, some facilities may have to report emissions of air toxics. 

189 HAPs No NAICS limitations At the time of 

permit application, renewal, and modification—permits are typically renewed every 5 years 

No ceninforma

DIRECT DISCHARGES TO WATER (SECTION 5.3) Permit Compliance System (PCS)PCS is a national information management system that tracks implementation of the National Pollutant Discharge Elimination System (NPDES) program, authorized by the Clean Water Act. PCS tracks permit issuance, permit limits, self-monitoring data, 

Monitoring data for major dischargers includes only chemicals for which a monitoring requirement has 

No NAICS limitations Major permittees 

must submit Discharge Monitoring Reports (DMRs) monthly or 

Can be access or the IInformon a fac
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Description Chemical Coverage Industry/Facility Coverage Reporting Frequency 

compliance data and other data pertaining to facilities regulated under NPDES. PCS has been modernized to the Integrated Compliance Information System (ICIS) as 

ICIS-NPDES. 

been set in the permit—a facility's record may not include all pollutants actually discharged 

quarterly; nonmajor permittees must submit at least annually 

UNDERGROUND INJECTION AND LAND DISPOSAL ON-SITE (SECTIONS 5.4 AND 5.5)RCRA Biennial ReportsSection 3002(a)(6) of the Resource Conservation and Recovery Act (RCRA) requires EPA to develop a program for hazardous waste generators to report the nature, quantities, and disposition of hazardous waste generated at least once every two years. In addition, section 3004(a)(2) of RCRA requires treatment, storage and disposal facilities (TSDFs) to submit a report on the wastes that they receive from off-site. The biennial Hazardous Waste Report (also known as the “Biennial Report”) was implemented in 1985 to comply with these requirements. The Biennial Report form (8700-13A/B) must be submitted to the authorized state agency or the EPA Regional Office by March 1st of every even-numbered year. The form includes information such as the facility's RCRA ID number, the name and address of the facility, the quantity of hazardous waste sent to each TSDF in the United States and the manner in which the waste was treated during the previous 

year.

Biennial Reports contain data on hazardous wastes as defined by RCRA and reported by waste codes – not all of which map directly to a single, unique chemical. 

No NAICS limitations; however, certain waste categories are excluded (e.g., mining and agriculture) 

Biennial Can be 

access RCRAIbasis. 
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Description Chemical Coverage Industry/Facility Coverage Reporting Frequency 

DISCHARGES TO A POTW (SECTION 6.1)RCRA Biennial Reports (BR)Biennial Reports require some reporting of discharges to POTWs. (See above for more details.) 

See above See above See above See abo

Permit Compliance System (PCS)PCS allows for reporting of indirect discharges to water. (See above for more details.) 

See above See above See above See abo

TRANSFERS TO OTHER OFF-SITE LOCATIONS (SECTION 6.2)RCRA Biennial Reports (BR)Biennial Reports contain hazardous waste data from large quantity generators and TSDFs. Biennial Reports also require reporting of off-site transfers on Form GM. Information includes the RCFA ID of the facility to which the waste was shipped, the processes used to treat, recycle, or dispose of the waste at the off-site facility, the off-site availability code, and the total quantity of waste shipped during the report year. The reports also provide data on the volume of hazardous waste shipped off-site for land disposal, a release end-point of relevance to TRI. (See above for more details.) 

See above See above See above See abo

CHEMICAL STORAGE AND INVENTORY DATA (SECTION 4.1)EPCRA §312 Tier I and II ReportsEPCRA §312 requires that states establish 

plans for local chemical emergency preparedness and that inventory information on hazardous chemicals be reported by 

Hazardous or extremely hazardous substances 

No NAICS exemptions for facilities that are covered under the reporting threshold 

Annual On a fa

forward
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Description Chemical Coverage Industry/Facility Coverage Reporting Frequency 

facilities to state and local authorities. (essentially any 

substance that poses a health or physical hazard) 

requirements, but facilities not included under OSHA’s Hazard Communication Statndard (e.g., mines) do not have to file 

Risk Management Plan (RMP)Under the authority of section 112(r) of the Clean Air Act, the Chemical Accident Prevention Provisions require facilities that 

produce, handle, process, distribute, or store 

certain chemicals to develop a Risk Management Program, prepare a Risk Management Plan (RMP), and submit the RMP to EPA. Covered facilities were initially required to comply with the rule in 1999, and the rule has been amended on several occasions since then, most recently in 2004. These plans include information about chemical amounts stored or processed at RMP facilities. 

Certain flammable and toxic substances 

No NAICS limitations At least every 

five years, or within six months of an incident 

Restricinformathe Fed

POLLUTION PREVENTION DATA (SECTIONS 8.1-8.7)RCRA Biennial Reports (BR)Biennial Reports contain pollution prevention information on hazardous waste from large quantity generators and TSDFs. Data are collected primarily by states, and are collated by EPA. (See above for more details.) 

See above See above See above See abo

State Environmental Agency DatabasesAt least two states, New Jersey and Massachusetts, have passed laws to collect pollution prevention data on materials 

Include more industries 

than TRI 

Annual At this 

source prevent
ICR 1st FR Notice 

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Description Chemical Coverage Industry/Facility Coverage Reporting Frequency 

accounting that exceed that found in Section 8 of Form R. Several other states may also require certain TRI filers (based on chemical thresholds and industry sector) to submit annual P2 plans with their TRI reports. 

may mpublic. 

EMERGENCY RELEASE DATA (SECTION 8.8)National Response Center (NRC)NRC collects real-time information about virtually all oil and chemical spills throughout the United States to identify spills for which to coordinate emergency response. 

Oils and chemicals No source exemptions Real-time Histori

can be online qHttp://w

STATE RIGHT-TO-KNOW PROGRAMS Several states require expanded state TRI reporting to include industries/facilities not covered by TRI or to report release information beyond that required by the federal TRI Program (e.g., Arizona, Massachusetts, Minnesota, and Wisconsin). 

Varies by state, but often identical to TRI 

Varies, but may include more industries than TRI 

Annual No cen

informaby state
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Appendix C References:

Abt Associates, “Comparison of Toxics Release Inventory and the Permit Compliance System,” 

(2005). 

Abt Associates, “Comparison of Toxics Release Inventory and the National Emissions 

Inventory,” (2005): 6. 

Arizona Department of Environmental Quality. Waste Programs Division: Pollution Prevention: 

Toxic Release Inventory. http://www.azdeq.gov/environ/waste/p2/tri.html

Great Lakes Information Network, 1996. "Regional Air Pollutant Inventory Development 

System," Information from Great Lakes Information Network Web site: 

http://www.glc.org/projects/air/rapids/rapids.html http://www.glc.org. 

ICF Incorporated, 1993. Data Gaps and Redundancies in Pollution Prevention Reporting; A

Compendium of Memoranda. Prepared for U.S. EPA, Office of Prevention, Pesticides, and 

Toxics, Pollution Prevention Division. 

Massachusetts Toxics Use Reduction Institute, 1994. Toxics Use Reduction: Fact Sheet 1. 

Lowell, MA: University of Massachusetts Lowell. February. 

Massachusetts Department of Environmental Protection, 1993. An Overview of the Toxics Use 

Reduction Act. Prepared by Manik Roy. February. 

Massachusetts Department of Environmental Protection. Toxics and Hazards: Toxics Use 

Reduction Act. http://www.mass.gov/dep/toxics/toxicsus.htm

Minnesota Pollution Control Agency. Chemicals in Communities: Public Data and Evaluation. 

http://www.pca.state.mn.us/index.php/topics/preventing-waste-and-pollution/p2-pollutionprevention/reducing-toxicity/chemicals-in-communities.html

Seitz, John S., Director OAQPS, 1995. Memorandum: "Title V Permitting for Non-major Sources 

in Recent §112 Maximum Achievable Control Technology (MACT) Standards," May 16, 1995. 

U.S. EPA, 1991. 1991 Hazardous Waste Report: Instructions and Forms. EPA Form 8700-

13A/B (5-80) revised 8-91. 

U.S. EPA, 1994. "National Analysis: The Biennial RCRA Hazardous Waste Report (Based on 

1991 Data)." September 1994. 

U.S. EPA, 1995a. Information from the AIRS AFS Home Page: 

http://www.epa.gov/docs/airs/afs.html).
ICR 1st FR Notice 2/08/11 

79

U.S. EPA, 1995e. "User's Guide to Federal Accidental Release Databases," Office of Solid 

Waste and Emergency Response, September 1995. 

U.S. EPA, 2002. RMP National Database overview, October 2002. 

http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/RMPoverview.htm. 

U.S. EPA, 2003. “National Analysis: The National Biennial RCRA Hazardous Waste Report 

(Based On 2003 Data)" http://www.epa.gov/epaoswer/hazwaste/data/br03/. 

U.S. EPA, 2006. "Phase III: Data Proxies for the Toxics Release Inventory (TRI)," January 

2006. 

Wisconsin Department of Natural Resources. Toxics Release Inventory (SARA Form R) 

Reporting. http://dnr.wi.gov/air/emission/crs/crs_help_tri.htm
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APPENDIX D 

TRI CONSULTATION MEETINGS 
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Appendix D: TRI Consultation Meetings 

TRI National Training Conference 

March 2009 

Attendees Included: 

Kentucky Department of Environmental Protection 

Kansas Department of Health & Environment 

North Carolina Crime Control and Public Safety 

Maine Emergency Management Agency 

New Mexico Department of Homeland Security and Emergency Management 

Commission for Environmental Cooperation 

National Library of Medicine 

Small Business Administration (SBA) 

Chevron 

Lockheed Martin 

Potomac-Hudson Engineering, Inc. 

IW Financial 

Grassroots Connection 

U.S. DOE 

University of Colorado – Denver 

OMB Watch 

December 10, 2009 

Stakeholder Briefing on 2008 TRI National Analysis 

Attendees: 

OMB Watch 

American Iron & Steel Institute 

ACCI 

IPC 

National Mining Association 

American Petroleum Institute 

SBA 

February 16, 2010 

Industry Perspectives on Improving the TRI Database 

Attendees: 

Nucor Corp 

SSAB 
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United States Steel Corporation 

American Iron & Steel Institute 

Heritage Environmental 

SBA 

March 23, 2010 

Metal Mining Rulemaking – Stakeholder Meeting 

Attendees Included: 

Earthworks 

Pew Environmental Group 

OMB Watch 

June 23, 2010 

Conference Call on TRI, Metal Mining, and Environmental Justice 

Participants Included: 

OMB Watch 

Western Organization of Resource Councils 

Earthworks 

Great Basin Resource Watch 

October 2009, June 2010 

Online Metal Mining Stakeholder Discussion Forum 

Commenters Included: 

OMB Watch 

Idaho Conservation League 

Texas A&M University 

Southeast Alaska Conservation Council 

Earthworks 

Center for Science in Public Participation 

Rock Creek Alliance 
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APPENDIX E 

FACILITIES REQUIRED TO REPORT TO TRI (NAICS) 
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Table E-1 

Facilities Required to Report to TRI (NAICS) 

(Corresponding to SIC codes 20 through 39)

Subsector 

or Industry 

Code 

Exceptions and/or Limitations 

113310 

221330 Limited to facilities engaged in providing combinations of electric, gas, and other services not classified elsewhere 

(NEC) (previously classified under SIC 4939, Combination Utility Services Not Elsewhere Classified); 

311 Except 311119 - Exception is limited to facilities primarily engaged in Custom Grain Grinding for Animal Feed 

(previously classified under SIC 0723, Crop Preparation Services for Market, Except Cotton Ginning); 

Except 311330 - Exception is limited to facilities primarily engaged in the retail sale of candy, nuts, popcorn and other 

confections not for immediate consumption made on the premises (previously classified under SIC 5441, Candy, Nut, 

and Confectionery Stores); 

Except 311340 - Exception is limited to facilities primarily engaged in the retail sale of candy, nuts, popcorn and other 

confections not for immediate consumption made on the premises (previously classified under SIC 5441, Candy, Nut, 

and Confectionery Stores); 

Except 311811 - Retail Bakeries (previously classified under SIC 5461, Retail Bakeries); 

Except 311611 - Exception is limited to facilities primarily engaged in Custom Slaughtering for individuals (previously 

classified under SIC 0751, Livestock Services, Except Veterinary, Slaughtering, custom: for individuals); 

Except 311612 - Exception is limited to facilities primarily engaged in the cutting up and resale of purchased fresh 

carcasses for the trade (including boxed beef) (previously classified under SIC 5147, Meats and Meat Products); 

312 Except 312112 - Exception is limited to facilities primarily engaged in bottling mineral or spirit water (previously 

classified under SIC 5149, Groceries and Related Products, NEC); 

Except 312229 - Exception is limited to facilities primarily engaged in providing Tobacco Sheeting Services 

(previously classified under SIC 7389, Business Services, NEC); 

313 Except 313311 - Exception is limited to facilities primarily engaged in converting broad woven piece goods and broad 

woven textiles (previously classified under SIC 5131, Piece Goods Notions, and Other Dry Goods, broad woven and 

non-broad woven piece good converters), and facilities primarily engaged in sponging fabric for tailors and 

dressmakers (previously classified under SIC 7389, Business Services, NEC (Sponging fabric for tailors and 

dressmakers)); 

Except 313312 - Exception is limited to facilities primarily engaged in converting narrow woven textiles, and narrow 

woven piece goods (previously classified under SIC 5131, Piece Goods Notions, and Other Dry Goods, converters, 

except broad woven fabric); 

314 Except 314121 - Exception is limited to facilities primarily engaged in making custom drapery for retail sale 

(previously classified under SIC 5714, Drapery, Curtain, and Upholstery Stores); 

Except 314129 - Exception is limited to facilities primarily engaged in making custom slipcovers for retail sale 

(previously classified under SIC 5714, Drapery, Curtain, and Upholstery Stores); 

Except 314999 - Exception is limited to facilities primarily engaged in binding carpets and rugs for the trade, carpet 

cutting and binding, and embroidering on textile products (except apparel) for the trade (previously classified under 

SIC 7389, Business Services Not Elsewhere Classified, Embroidering of advertising on shirts and Rug binding for the 

trade); 

315 Except 315222 - Exception is limited to custom tailors primarily engaged in making and selling men's and boys' suits, 

cut and sewn from purchased fabric (previously classified under SIC 5699, Miscellaneous Apparel and Accessory 

Stores (custom tailors)); 

Except 315223 - Exception is limited to custom tailors primarily engaged in making and selling men's and boys' dress 

shirts, cut and sewn from purchased fabric (previously classified under SIC 5699, Miscellaneous Apparel and 

Accessory Stores (custom tailors)); 

Except 315233 - Exception is limited to custom tailors primarily engaged in making and selling bridal dresses or 

gowns, or women's, misses' and girls' dresses cut and sewn from purchased fabric (except apparel contractors) (custom 

dressmakers) (previously classified under SIC Code 5699, Miscellaneous Apparel and Accessory Stores); 

316 

321 
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322 

323 Except 323114 - Exception is limited to facilities primarily engaged in reproducing text, drawings, plans, maps, or 

other copy, by blueprinting, photocopying, mimeographing, or other methods of duplication other than printing or 

microfilming (i.e., instant printing) (previously classified under SIC 7334, Photocopying and Duplicating Services 

(instant printing)); 

324 

325 Except 325998 - Exception is limited to facilities primarily engaged in aerosol can filling on a job order or contract 

basis (previously classified under SIC 7389, Business Services, NEC (aerosol packaging)); 

326 Except 326212 - Tire Retreading (previously classified under SIC 7534, Tire Retreading and Repair Shops 

(rebuilding)); 

327 Except 327112 - Exception is limited to facilities primarily engaged in manufacturing and selling pottery on site 

(previously classified under SIC 5719, Miscellaneous Homefurnishing Stores); 

331 

332 

333 

334 Except 334611 - Exception is limited to software reproducing (previously classified under SIC 7372, Prepackaged 

Software, (reproduction of software)); 

Except 334612 - Exception is limited to facilities primarily engaged in mass reproducing pre-recorded Video cassettes, 

and mass reproducing Video tape or disk (previously classified under SIC 7819, Services Allied to Motion Picture 

Production (reproduction of Video)); 

335 Except 335312 - Exception is limited to facilities primarily engaged in armature rewinding on a factory basis 

(previously classified under SIC 7694 (Armature Rewinding Shops (remanufacturing)); 

336 

337 Except 337110 - Exception is limited to facilities primarily engaged in the retail sale of household furniture and 

facilities that manufacture custom wood kitchen cabinets and counter tops (previously classified under SIC 5712, 

Furniture Stores (custom wood cabinets)); 

Except 337121 - Exception is limited to facilities primarily engaged in the retail sale of household furniture and 

facilities that manufacture custom made upholstered household furniture (previously classified under SIC 5712, 

Furniture Stores (upholstered, custom made furniture)); 

Except 337122 - Exception is limited to facilities primarily engaged in the retail sale of household furniture and 

facilities that manufacture nonupholstered, household type, custom wood furniture (previously classified under SIC 

5712, Furniture Stores (custom made wood nonupholstered household furniture except cabinets)); 

339 Except 339113 – Exception is limited to facilities primarily engaged in manufacturing orthopedic devices to 

prescription in a retail environment (previously classified under SIC 5999 Miscellaneous retail stores, NEC); 

Except 339115 - Exception is limited to lens grinding facilities that are primarily engaged in the retail sale of 

eyeglasses and contact lenses to prescription for individuals (previously classified under SIC 5995, Optical Goods 

Stores (optical laboratories grinding of lenses to prescription)); 

Except 339116 - Dental Laboratories (previously classified under SIC 8072, Dental Laboratories); 

111998 Limited to facilities primarily engaged in reducing maple sap to maple syrup (previously classified under SIC 2099, 

Food Preparations, NEC, Reducing Maple Sap to Maple Syrup); 

211112 Limited to facilities that recover sulfur from natural gas (previously classified under SIC 2819, Industrial Inorganic 

Chemicals, NEC (recovering sulfur from natural gas)); 

212324 Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating kaolin and clay 

(previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise Treated (grinding, washing, 

separating, etc. of minerals in SIC 1455)); 

212325 Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating clay and 

ceramic and refractory minerals (previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise 

Treated (grinding, washing, separating, etc. of minerals in SIC 1459)); 

212393 Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating chemical or 

fertilizer mineral raw materials (previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise 

Treated (grinding, washing, separating, etc. of minerals in SIC 1479)); 

212399 Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating nonmetallic 

minerals (previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise Treated (grinding, washing, 

separating, etc. of minerals in SIC 1499)); 

488390 Limited to facilities that are primarily engaged in providing routine repair and maintenance of ships and boats from 

floating drydocks (previously classified under SIC 3731, Shipbuilding and Repairing (floating drydocks not associated 
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88

with a shipyard)); 

511110 

511120 

511130 

511140 Except facilities that are primarily engaged in furnishing services for direct mail advertising including address list 

compilers, address list publishers, address list publishers and printing combined, address list publishing, business 

directory publishers, catalog of collections publishers, catalog of collections publishers and printing combined, mailing 

list compilers, directory compilers, and mailing list compiling services (previously classified under SIC 7331, Direct 

Mail Advertising Services (mailing list compilers)); 

511191 

511199 

512220 

512230 Except facilities primarily engaged in music copyright authorizing use, music copyright buying and licensing, and 

music publishers working on their own account (previously classified under SIC 8999, Services, NEC (music 

publishing)); 

519130 Limited to facilities primarily engaged in Internet newspaper publishing (previously classified under SIC 2711, 

Newspapers: Publishing, or Publishing and Printing), Internet periodical publishing (previously classified under SIC 

2721, Periodicals: Publishing, or Publishing and Printing), Internet book publishing (previously classified under SIC 

2731, Books: Publishing, or Publishing and Printing), miscellaneous Internet publishing (previously classified under 

SIC 2741, Miscellaneous Publishing), Internet greeting card publishers (previously classified under SIC 2771, Greeting 

Cards); 

541712 Limited to facilities that are primarily engaged in guided missile and space vehicle engine research and development 

(previously classified under SIC 3764, Guided Missile and Space Vehicle Propulsion Units and Propulsion Unit Parts), 

and in guided missile and space vehicle parts (except engines) research and development (previously classified under 

SIC 3769, Guided Missile and Space Vehicle Parts and Auxiliary Equipment, Not Elsewhere Classified); 

811490 Limited to facilities that are primarily engaged in repairing and servicing pleasure and sail boats without retailing new 

boats (previously classified under SIC 3732, Boat Building and Repairing (pleasure boat building)); 

Table E-2 

Facilities Required to Report to TRI (NAICS) 

(Corresponding to SIC codes other than SIC codes 20 through 39) 

Subsector 

or Industry 

Code 

Exceptions and/or Limitations 

212111 

212112 

212113 

212221 

212222 

212231 

212234 

212299 

221111 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce. 

221112 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce. 

221113 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce. 

221119 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce. 

221121 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce. 

221122 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce. 

424690 

424710

425110 Limited to facilities previously classified in SIC 5169, Chemicals and Allied Products, Not Elsewhere Classified. 

425120 Limited to facilities previously classified in SIC 5169, Chemicals and Allied Products, Not Elsewhere Classified. 

562112 Limited to facilities primarily engaged in solvent recovery services on a contract or fee basis (previously classified under 

SIC 7389, Business Services, NEC); 
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89

562211 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq. 

562212 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq. 

562213 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq. 

562219 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq. 

562920 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq.