ESTIMATES OF BURDEN HOURS

FOR ECONOMIC ANALYSES OF

THE TOXICS RELEASE INVENTORY PROGRAM

Cody Rice Analytical Support Branch Environmental Analysis Division Office of Environmental Information U.S. Environmental Protection Agency

June 10, 20021 The annual reportable amount of a chemical is calculated as the sum of the quantities released, used for energy recovery, recycled and treated. Form A cannot be used for persistent bioaccumulative toxic (PBT) chemicals that have a lower reporting threshold.

2 Introduction

The Office of Environmental Information administers the Toxics Release Inventory (TRI) program. This program requires annual reporting from facilities in manufacturing and certain other industry sectors, as well as federal facilities. Using readily available information and reasonable estimates, facilities are responsible for completing TRI reports on toxic chemical releases and other waste management activities.

The amount of time that facilities spend gathering information, making estimates, completing the TRI forms, keeping records, and mailing the forms represents the burden hours imposed by the program. Historically, burden hour estimates have been developed for various economic analyses and Information Collection Requests (ICRs) for the TRI program.

The primary TRI reporting instrument is the "Form R": a 5-page form addressing facility and chemical identity, chemical releases to various environmental media, off-site transfers, on-site waste treatment, on-site energy recovery, and source reduction and recycling. However, facilities with an annual reportable release amount of 500 pounds or less of a reportable chemical can take advantage of an alternate manufacture, process, or otherwise use threshold of one million pounds. 1 Facilities that qualify for this alternate threshold can submit a "Form A" instead of a Form R. Form A only contains data on facility and chemical identity. B ecause the Form A is simpler than the Form R, facilities that qualify for the alternate threshold expend less time on calculations, report completion and recordkeeping for chemicals that are reported on Form A.

This memo has the following objectives: 1) to describe the existing burden hour estimates, 2) to describe revisions to the burden hour estimates based on the experience of facilities reporting to TRI, and 3) to note areas for further research.

Existing Estimates

The tasks associated with TRI reporting are broken into the following major activities that are conducted for the facility or for the specific chemical being reported. Each bullet below describes the activity and the source of the burden hour estimate.

FACILITY

Rule Familiarization: If a facility is subject to TRI reporting for the first time, its staff must learn and understand the reporting requirements. At a minimum, this involves reading the reporting form instructions, but could also involve consulting EPA guidance documents, attending a training course, and/or calling the technical hotline. The burden3 associated with rule familiarization only occurs in the first year that a facility is subject to reporting. In subsequent years, the staff are familiar with the requirements that apply to their facility, and the facility does not incur this burden again. The burden hour estimate for this activity was developed in the economic analysis for the original rulemaking for the TRI program.

Compliance Determination: Facilities must determine whether they meet the criteria for reporting. A facility must report to TRI if it: (a) is within industry groups covered by the TRI program; (b) has 10 or more employees or the equivalent of 10 full-time employees; and (c) manufactures, processes, or uses a listed toxic chemicals above threshold levels. The incremental costs associated with the first two determinations are expected to be low, since most facilities are familiar with their industry group and number of employees. The third determination, however, requires the management and technical staff to determine the types of chemicals used at the facility, and whether they are manufactured, processes, or otherwise used above applicable reporting thresholds. The time spent making threshold determinations is expected to comprise the majority of time spent making a compliance determination. However, this burden is expected to decline in subsequent years the facility has developed a system for gathering readily available information or making reasonable estimates. Based on the economic analysis of the original rulemaking, the burden estimate for the first year of compliance determination is four times that for subsequent years.

Supplier Notification (if applicable): Facilities s upplying mixtures and trade name products containing TRI chemicals above de minimislevels must notify their customers of the contents of their products on an annual basis. This is required so that customers can make threshold calculations for their own facilities. Facility burden estimates reflect the median number of hours spent preparing supplier notification per a 1992 survey.

FORM R

Form R Calculations and Report Completion: Facilities that must report to TRI will incur additional costs to retrieve, process, review, and transcribe information to complete each report. Most of the time for form completion is to calculate releases and transfers; relatively little time is required to copy information to the form. Unless the facility qualifies for the alternate threshold, the facility must complete one Form R for each chemical it is reporting. This takes more time in the first year than in subsequent years. The subsequent year process consists of verifying and updating data, reviewing previous calculations, and modifying the information reported on the previous year’s Form R, rather than originating or retrieving data for the first time. The economic analysis for the original rulemaking estimated the time required to complete a report on a chemical for the first time to be 147 percent of the time required in subsequent years.

Form R Recordkeeping and Mailing : After a facility has completed the form, it incurs additional burden for recordkeeping. Recordkeeping allows a facility to use the4 information to make calculations in subsequent years, and as documentation in the event it receives a compliance audit. Fac ilities must maintain records such as estimation methodology and calculations, engineering reports, inventory, incident and reporting logs, and any other supporting materials needed to provide the information required on the Form R. Facilities must transmit Form Rs to EPA and State authorities. The estimates for mailing and recordkeeping include the 1993 update based on the economic analysis of the proposed rule to amend Form R pursuant to the Pollution Prevention Act. Recordkeeping and mailing costs are not expected to vary from the first year to subsequent years.

FORM A

Form A Calculations/Certification: Facilities must gather data and perform calculations to determine whether they qualify for a Form A. If a facility's annual reportable amount for a listed toxic chemical is 500 pounds or less, the fac ility is eligible to apply the alternate threshold of 1 million pounds manufactured, processed or otherwise used. The estimates for Form A calculations/certification are taken from the economic analysis of the alternate threshold. Per the economic analysis of the original rule, these estimates are multiplied by147 percent to calculate the first-year burden.

Form A Report Completion: If a facility is eligible to apply the alternate threshold, it must complete the Form A. The facility completes one Form A that contains certifications for all the listed toxic chemicals to which it is applying the alternate threshold. The estimates for report completion are taken from the economic analysis of the alternate threshold rule. Per the economic analysis of the original rule, these estimates are multiplied by147 percent to calculate the first-year burden.

Form A Recordkeeping and Mailing: After a facility has certified a listed toxic chemical as eligible for the alternate threshold, it incurs additional labor costs for recordkeeping and mailing. Recordkeeping allows a facility to use the information in making calculations in subsequent years, and as documentation in the event it receives a compliance audit. Facilities must transmit Form As to EPA and State authorities. The estimates for recordkeeping and mailing are taken from the economic analysis of the alternate threshold rule. Recordkeeping and mailing costs are not expected to vary from the first year to subsequent years.

Existing unit burden hour estimates by labor category and activity are summarized in Table 1. Note that rule familiarization, compliance determination, and s upplier notification (if applicable) are incurred at the facility level and do not vary with the number of reports filed. Calculations, form completion and recordkeeping/mailing are incurred for each report filed.

TABLE 1 EXISTING UNIT BURDEN HOUR ESTIMATES5 Activity Unit Burden Hour Estimates Total Managerial Technical Clerical
First Year of Reporting

Facility Rule Familiarization 12 22.5 0 34.5
Compliance Determination 4 12 0 16
Supplier Notification 0 7 17 24

Form R Calculations/Form Completion 20.9 45.2 2.9 69
Recordkeeping/Mailing 0 4 1 5

Form A Calculations/Certification 16.3 26.0 2.2 44.5
Recordkeeping/Mailing 0 2.4 0.6 3
Form Completion 0.15 1.8 0.15 2.1
Subsequent Years of Reporting

Facility Compliance Determination 1 3 0 4
Supplier Notification 0 7 17 24

Form R Calculations/Form Completion 14.3 30.8 2 47.1
Recordkeeping/Mailing 0 4 1 5

Form A Calculations/Certification 11.1 17.7 1.4 30.2
Recordkeeping/Mailing 0 2.4 0.6 3
Form Completion 0.1 1.2 0.1 1.46 Revised Estimates

The main issue with the existing estimates is that they have not been updated to reflect a variety of factors that have reduced reporting burden, especially after the first reporting year. Based on the economic analysis of the original rule, EPA expected that fewer hours would be required for reporting in subsequent years. However, based on respondent experience it appears that burden hours have fallen off further over the years than originally expected. The specific factors contributing to the decline in reporting burden are discussed below.

First, the existing burden hour estimates do not reflect changes in the availability of information to facility staff. At the beginning of the program, it was assumed that facilities would have to rely primarily on inventory records, Material Safety Data Sheets, and engineering estimates. Over time, a variety of other information sources have become more readily available. These sources include information on product composition and impurities from suppliers, improved and detailed guidance from EPA and trade associations, and emission factors provided by EPA. With the advent of the Internet, facilities have much greater access to information that assists in complying with the reporting requirements.

Second, facilities now have other state and federal reporting requirements that have been implemented since the beginning of the TRI program. Although it varies from facility to facility, these reports may include annual emission inventories, emission monitoring, hazardous waste generator reports, storm water discharge reports, and waste water discharge reports. Since these reports are precursors to TRI reporting and can be used to fulfill TRI reporting requirements, they have the effect of reducing the burden attributable to TRI.

Third, the burden hour estimates were largely developed when computerization and automation was just beginning. In the late 1980s, many fac ilities continued to rely on manual processes for report completion. Over time, facilities have gained much greater access to electronic reporting and recordkeeping options. There are now a variety of off-the-shelf computer software packages for environmental compliance, including EPA’s Automated Form R and the TRI-Made Easy software. Even simple spreadsheet programs like Excel or Lotus 1-2-3 greatly simplify the process of making calculations and updating information from previous reporting years.

Fourth, the existing burden hour estimates incorporate the assumption that every facility reports releases of each reported chemical to all environmental media: air, water, and land. This assumption leads to an overestimate of reporting burden because it implies that fac ilities will spend time gathering information, making calculations, and keeping records for a broader set of chemical management activities than is actually the case. In fact, for the 2000 reporting year, over 60 percent of Form Rs reported releases to a single medium. Another 12 percent reported no releases, but instead reported only on off-site transfers and on-site waste management. Only 1 percent of Form Rs included release data for all media.2 Another approach would be to sum the mid-points of the burden ranges for all facilities, then divide by the total number of Form Rs submitted by all the facilities. This yields an estimate of 12.6 hours per Form R.

7 The existing burden hour estimates reflect none of these factors. A review of feedback from reporting facilities reveals that the existing burden hour estimates represent substantial overestimates of actual reporting burden for most reporting facilities. The existing burden estimates for subsequent year compliance determination, Form R calculations and form completion, and recordkeeping/mailing are above the 95 thpercentile of per form burden reported by actual TRI respondents.

Estimates of the actual burden incurred by facilities reporting to TRI are available from the following sources:

1994 and 1995 Toxic Release Inventory: Data Quality Report 1996 Toxic Release Inventory: Data Quality Report 1999 Research Triangle Institute Informal and Formal Surveys of TRI Burden

The Data Quality Reports are part of an EPA program of site surveys to assess the quality of TRI data and to identify areas where improved guidance would be useful for improving the accuracy of future reported data. Sampled facilities are selected to obtain a random group of facilities from key industries to permit the results to be scaled up to the entire industry group. One of the questions asked of facilities is how much time is spent to fulfill the reporting requirements of Section 313 for the most recent reporting year. The Research Triangle Institute surveys were small scoping activities to identify factors related to variability in facility burden hours. From all of the sources, there are a total of 180 fac ilities that provided information about the amount of time needed to comply with TRI reporting requirements.

Using the estimates of total time expended for reporting and the number of Form Rs for each fac ility, it is possible to derive an estimate of average burden hours per Form R per facility. Most of the facility responses are in the form of range estimates of the total time required to complete all TRI-related activities. For each fac ility, the mid-point of the burden hour range was divided by the number of Form Rs that the facility filed to obtain an estimate of burden per form for each fac ility. The facility-level estimates were then averaged. For the 180 fac ilities in these sources, the average burden hours per Form R is 14.5 hours. 2This represents a "subsequent year" burden since the facilities had reported to TRI in previous years.

Based on the questions asked of the facilities, it would be reasonable to conclude that 14.5 hours per form includes all reporting activities, including compliance determination and recordkeeping/mailing. The facilities were asked about the total time required to comply with TRI reporting requirements including familiarization with the regulation and reporting instructions, completion and internal review of the reporting forms, and all documentation. However, for the purposes of this revision, the 14.5 hours per form are only being used to revise the burden hour estimate for Form R calculations and form completion in subsequent years. The3 Additionally, the "typical" facility may be better represented by the median value rather than the mean (or average) since most of the observations cluster toward the lower end of hours per form. The median value is 8.0 hours per Form R.

8 burden hour estimates for first-year activities, as well as for compliance determination and recordkeeping/mailing in subsequent years have not been modified. This will result in some overestimation of unit burden hours at the typical facility. 3

The main reason for this approach is that all of the responses used to generate the revised estimate were obtained prior to promulgation of lower TRI reporting thresholds for lead and other persistent bioaccumulative toxic (PBT) chemicals. Some commenters on these rules asserted that lower reporting thresholds would substantially increase unit reporting burden. EPA did not entirely agree. EPA estimated an incremental compliance determination burden of 2.7 hours in the first year and 0.7 hours in subsequent years for PBT chemicals, and 1.6 hours in the first year and 0.4 hours in subsequent years for lead. Not revising the burden hour estimates for facility-level compliance determination and recordkeeping/mailing more than accounts for any additional time that facilities may spend to make compliance determinations for chemicals with lower reporting thresholds. In the future, when EPA collects information about facilities that are filing TRI reports on these chemicals, the responses to questions about burden hours can be used to revise estimates for all activities rather than just Form R calculations and form completion.

In Table 2 below, the average burden hours per Form R per facility has been used to revise the "Form R Calculations and Form Completion" activity burden hours. For subsequent years of reporting, 14.5 hours have been distributed among managerial, technical, and clerical staff based on the historical percentage split of time between these labor categories for this activity. In previous analyses, the time required to complete a report in the first year of reporting has calculated as 147 percent of the time required in subsequent years. It is likely that the same factors that have reduced subsequent year burden also apply to first year reporting. However, EPA has chosen not to revise first-year burden hour estimates since all the available observations apply to subsequent year reporting. While there is a strong possibility that the historical relationship continues, more data are needed to verify this relationship.

For Form A, the calculations needed to determine eligibility are a subset of the calculations necessary to complete Form R. Thus, the time required to calculate the annual reportable amount was estimated in previous ICRs by aggregating EPA’s estimates of the time required to calculate each of the sections of Form R that are relevant to determining annual reportable amount. According to these estimates, calculations for a Form A take approximately 64 percent of the time of calculations for the Form R. Based on EPA’s revision to the unit burden estimates for Form R calculations and form completion, EPA estimates that calculating an annual reportable amount for Form A will require an average of 9.3 hours for each listed toxic chemical that the facility must report under EPCRA section 313. Table 2 reflects this revision. As with Form R, burden estimates for Form A completion or recordkeeping/mailing are unchanged. Likewise, estimates for reporting in the first year have not been modified.4 Note that one facility among the 9 facilities reported a much higher per chemical burden than the other 8 facilities. Without this outlier, the average of facility-level burden hours per chemical certification would be 3.8 to 4.9 hours per chemical certified.

9 In April 2002, EPA contacted nine fac ilities that file Form As to inquire about the typical facility level burden associated with using the reporting form. The total facility level burden estimates were reported in ranges. Depending on whether the midpoint or maximum of the range was used, the average of facility-level burden hours per chemical certification was reported at 11.2 to 15.5 hours. EPA’s estimate of 13.7 total hours for a facility certifying one chemical on a Form A falls within this range. 410 TABLE 2 REVISED UNIT BURDEN HOUR ESTIMATES

Activity Unit Burden Hour Estimates Total Managerial Technical Clerical

First Year of Reporting

Facility Rule Familiarization 12 22.5 0 34.5
Compliance Determination 4 12 0 16
Supplier Notification 0 7 17 24

Form R Calculations/Form Completion 20.9 45.2 2.9 69
Recordkeeping/Mailing 0 4 1 5

Form A Calculations/Certification 16.3 26 2.2 44.5
Recordkeeping/Mailing 0 2.4 0.6 3
Form Completion 0.15 1.8 0.15 2.1
Subsequent Years of Reporting

Facility Compliance Determination 1 3 0 4
Supplier Notification 0 7 17 24

Form R Calculations/Form Completion 4.4 9.5 0.6 14.5
Recordkeeping/Mailing 0 4 1 5

Form A Calculations/Certification 3.4 5.5 0.4 9.3
Recordkeeping/Mailing 0 2.4 0.6 3
Form Completion 0.1 1.2 0.1 1.45 EPA expects adoption rates of TRI-ME to increase rapidly. It would be reasonable to assume that adoption rates would be similar to current levels of electronic filing, which provide an indication of receptivity to computerbased report completion. For the 1999 reporting year, 73 percent of responses were r eceived electronically. For the 2000 reporting year, this percentage increased to 79 per cent. It would not be unreasonable to expect similar adoption rates for TRI-ME.

11 In an effort to reduce reporting burden further, EPA has developed intelligent software for the desktop computer called TRI

B Made Easy (TRI-ME). This software is designed to assist facilities in determining and completing their reporting obligations. A small sample of facilities that tested TRI-ME for the 2000 reporting year reported an average burden reduction of 25 percent in the activities of Form R Calculations and Form Completion and Recordkeeping/Mailing. For the Form A, this percentage burden reduction estimate can be applied to the activities of Calculations/Certification and Recordkeeping/Mailing. All facilities that used TRI-ME said that they would use it again in the future.

The facility responses that are used to revise the burden hour estimates in this memo were collected with reference to reporting years before the TRI-ME software was available. At the current time, TRI-ME burden reduction can be assessed against total Form R or Form A reporting burden using assumptions for TRI-ME adoption rates. In future years, the underlying adoption rates and burden reduction will be reflected in facility responses about the number of hours required to comply with TRI reporting requirements. The total estimated annual burden reduction attributable to TRI-ME at projected 2001 reporting levels assuming a 60 percent adoption rate is shown below. 5

TABLE 3 ANNUAL TRI-ME BURDEN REDUCTION

Burden Reduction Hours Number of Affected Forms Total Reduction

Per Form R (4.9) 52,870 (259,063)

Per Form A (3.1) 7,925 (24,568)

Total Burden Reduction Hours (283,631)12 References

Research Triangle Institute/Center for Economics Research, Memo from Smita Brunnermeier, et al to Joe Callahan (USEPA/OPPT), Subject: Informal Survey Results , May 7, 1999.

Research Triangle Institute/Center for Economics Research, Memo from Smita Brunnermeier, et al to Joe Callahan (USEPA/OPPT), Subject: Formal Survey Results , June 15, 1999.

U.S. EPA. Analysis of Compliance with the Supplier Notification Requirements under Section 313 of EPCRA , February 1992.

U.S. EPA. Regulatory Impact Analysis in Support of Final Rulemaking Under Section 313 of Title III of the Superf und Amendments and Reauthorization Act of 1986 . February 1988.

U.S. EPA. Regulatory Impact Analysis of the EPCRA Section 313 Alternate Threshold Final Rule , November 18, 1994.

U.S. EPA. Review and Update of Burden and Cost Estimates for EPA's Toxics Release Inventory Program , August 1993.

U.S. EPA. 1994 and 1995 Toxic Release Inventory: Data Quality Report , EPA 745-R-98-002, March 1998.

U.S. EPA. 1996 Toxic Release Inventory: Data Quality Report , EPA 745-R-98-016, December 1998.13 Data from Data Quality Reports: RY94-96

SIC ID PERSONNEL RANGE FORMR 25 DCDBS006 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 1 25 DCDBS008 CONSULTANT/CONTRACTOR <=20 HOURS 1 25 DCKCC012 FACILITY STAFF <=20 HOURS 1 25 DCKCC014 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 3 25 DCKCC017 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 1 25 DCKCC018 CORPORATE ENVIRONMENTAL STAFF 50-100 HOURS 9 25 DCKMM005 FACILITY STAFF <=20 HOURS 6 25 DCKMM007 FACILITY STAFF 21-50 HOURS 5 25 DCKMM008 CORPORATE ENVIRONMENTAL STAFF <=20 HOURS 2 25 DCKMM011 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 1 25 DCKPR012 CORPORATE ENVIRONMENTAL STAFF 21-50 HOURS 1 SAFETY DEPARTMENT STAFF 25 DCKPR013 CONSULTANT/CONTRACTOR <=20 HOURS 2 25 DCKPR014 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 1 FACILITY STAFF 25 DCKPR015 CORPORATE ENVIRONMENTAL STAFF 21-50 HOURS 3 25 DCRDR001 SAFETY DEPARTMENT STAFF 50-100 HOURS 1 25 LEXJLW007 FACILITY STAFF <=20 HOURS 2 25 LEXJLW008 CORPORATE ENVIRONMENTAL STAFF 21-50 HOURS 8 25 LEXJLW009 CORPORATE ENVIRONMENTAL STAFF 21-50 HOURS 3 25 LEXJLW010 CONSULTANT/CONTRACTOR 1 25 LEXJLW013 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 1 25 RTPMBL004 CORPORATE ENVIRONMENTAL STAFF <=20 HOURS 6 25 RTPMBL005 CORPORATE ENVIRONMENTAL STAFF 21-50 HOURS 5 25 RTPMOP004 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 5 25 RTPMOP005 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 5 25 RTPMOP008 CORPORATE ENVIRONMENTAL STAFF 21-50 HOURS 5 26 DCDBS010 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 6 26 DCDBS011 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 7 26 DCKMM014 FACILITY ENVIRONMENTAL STAFF 9-20 HOURS 3 26 DCKMM017 FACILITY STAFF <= 8 HOURS 2 26 DCKPR018 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 4 26 LEXJLW014 CORPORATE ENVIRONMENTAL STAFF <= 8 HOURS 1 26 RTPCAL001 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 3 26 RTPCAL002 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 3 26 RTPDBG001 FACILITY ENVIRONMENTAL STAFF >100 HOURS - 0 14 26 RTPMOP006 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 8 281 DCDBS001 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 4 SAFETY DEPARTMENT STAFF OPERATIONS AS WELL, PART OF THE TIME. 281 DCDMB001 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 8 281 DCDMB002 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 7 281 DCJJC001 FACILITY ENVIRONMENTAL STAFF 50-100 HOURS 14SIC ID PERSONNEL RANGE FORMR

14 CORPORATE ENVIRONMENTAL STAFF 281 DCKCC001 FACILITY STAFF 100-200 HOURS 7 281 DCKCC003 CONSULTANT/CONTRACTOR <=20 HOURS 2 281 DCKCC005 FACILITY STAFF <=20 HOURS 5 281 DCKCC007 FACILITY ENVIRONMENTAL STAFF 50-100 HOURS 9 281 DCKMM002 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 4 281 DCKMM003 CORPORATE ENVIRONMENTAL STAFF <=20 HOURS 3 281 DCKPR003 FACILITY STAFF <=20 HOURS 3 281 DCKPR005 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 2 281 DCKPR007 FACILITY STAFF <=20 HOURS 2 281 DCWRG001 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 5 281 LEXJLW002 CONSULTANT/CONTRACTOR <=20 HOURS 1 281 LEXJLW003 FACILITY ENVIRONMENTAL STAFF 50-100 HOURS 9 281 LEXJLW004 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 4 281 RTPMBL002 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 5 CORPORATE ENVIRONMENTAL STAFF FACILITY STAFF SAFETY DEPARTMENT STAFF 281 RTPMBL003 CORPORATE ENVIRONMENTAL STAFF 21-50 HOURS 1 285 DCDBS002 FACILITY STAFF <=20 HOURS 1 285 DCDBS003 FACILITY STAFF <=20 HOURS 2 TECHNICAL DIRECTOR 285 DCKCC002 FACILITY STAFF 21-50 HOURS 5 285 DCKCC004 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 3 285 DCKCC006 FACILITY STAFF <=20 HOURS 4 285 DCKCC008 FACILITY STAFF <=20 HOURS 2 285 DCKMM001 CONSULTANT/CONTRACTOR 21-50 HOURS 2 285 DCKPR001 CORPORATE ENVIRONMENTAL STAFF <=20 HOURS 1 285 DCKPR002 FACILITY STAFF 21-50 HOURS 4 285 DCKPR006 FACILITY STAFF 21-50 HOURS 4 285 DCKPR008 CORPORATE ENVIRONMENTAL STAFF 21-50 HOURS 1 FACILITY STAFF 285 DCPRB001 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 6 285 DCPRB002 FACILITY STAFF <=20 HOURS 1 285 LEXJLW001 CONSULTANT/CONTRACTOR <=20 HOURS 2 285 RTPML001 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 6 CORPORATE ENVIRONMENTAL STAFF FACILITY STAFF 285 RTPMOP001 FACILITY ENVIRONMENTAL STAFF 100-200 HOURS 8 SAFETY DEPARTMENT STAFF 285 RTPMOP003 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 9 286 DCKMM012 FACILITY STAFF <= 8 HOURS 2 286 DCKMM013 FACILITY STAFF 21-40 HOURS 2 286 DCKMM015 FACILITY STAFF <= 8 HOURS 1 286 DCKMM016 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 12 286 DCKPR016 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 5SIC ID PERSONNEL RANGE FORMR

15 286 DCKPR017 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 15 286 DCKPR019 FACILITY STAFF 41-100 HOURS 5 286 LEXJLW015 FACILITY ENVIRONMENTAL STAFF >100 HOURS - 0 19 286 LEXJLW016 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 12 286 RTPMOP007 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 12 FACILITY STAFF 30 DCDBS004 CORPORATE ENVIRONMENTAL STAFF <=20 HOURS 1 CONSULTANT/CONTRACTOR 30 DCDBS007 CONSULTANT/CONTRACTOR <=20 HOURS 1 30 DCDBS009 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 1 SAFETY DEPARTMENT STAFF 30 DCKCC009 FACILITY STAFF <=20 HOURS 1 30 DCKCC010 CORPORATE ENVIRONMENTAL STAFF 21-50 HOURS 3 30 DCKCC011 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 2 30 DCKCC013 FACILITY STAFF <=20 HOURS 1 30 DCKCC015 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 6 30 DCKCC016 CORPORATE ENVIRONMENTAL STAFF <=20 HOURS 1 30 DCKMM004 FACILITY ENVIRONMENTAL STAFF 50-100 HOURS 17 30 DCKMM006 FACILITY STAFF <=20 HOURS 3 30 DCKMM009 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 2 30 DCKMM010 FACILITY STAFF 21-50 HOURS 3 30 DCKPR009 FACILITY STAFF <=20 HOURS 2 30 DCKPR010 FACILITY STAFF 21-50 HOURS 2 SAFETY DEPARTMENT STAFF 30 DCKPR011 FACILITY STAFF 21-50 HOURS 2 30 DCRDR002 FACILITY ENVIRONMENTAL STAFF 21-50 HOURS 1 30 DCRDR003 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 2 30 LEXJLW005 FACILITY ENVIRONMENTAL STAFF <=20 HOURS 1 30 LEXJLW006 FACILITY STAFF <=20 HOURS 1 30 LEXJLW011 CONSULTANT/CONTRACTOR <=20 HOURS 1 30 LEXJLW012 CORPORATE ENVIRONMENTAL STAFF 21-50 HOURS 2 30 RTPMOP002 CONSULTANT/CONTRACTOR 21-50 HOURS 2 331 DCDBS014 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 9 331 DCJMR001 FACILITY STAFF <= 8 HOURS 1 PLANT MANAGER (1996). 331 DCKMM022 FACILITY STAFF 9-20 HOURS 5 331 DCKPR020 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 4 331 DCRDR006 FACILITY STAFF 41-100 HOURS 1 331 DCRDR012 CORPORATE ENVIRONMENTAL STAFF 41-100 HOURS 4 331 LEXJLW018 FACILITY ENVIRONMENTAL STAFF >100 HOURS - 120 5 331 RTPMOP010 CORPORATE ENVIRONMENTAL STAFF 9-20 HOURS 2 332 DCDBS012 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 3 332 DCDBS017 CORPORATE ENVIRONMENTAL STAFF 9-20 HOURS 1 332 DCKMM021 FACILITY STAFF 2 332 DCMDN001 CORPORATE ENVIRONMENTAL STAFF 41-100 HOURS 1 SAFETY DEPARTMENT STAFFSIC ID PERSONNEL RANGE FORMR

16 332 DCMJB001 FACILITY STAFF 21-40 HOURS 4 CONSULTANT/CONTRACTOR 332 DCRDR010 FACILITY STAFF <= 8 HOURS 1 332 DCRJM001 CONSULTANT/CONTRACTOR 21-40 HOURS 2 333 DCKPR026 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 10 CONSULTANT/CONTRACTOR 334 DCKMM018 CORPORATE ENVIRONMENTAL STAFF <= 8 HOURS 1 334 DCMJB007 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 1 334 LEXJLW024 CONSULTANT/CONTRACTOR 9-20 HOURS 4 335 DCDBS013 FACILITY STAFF 21-40 HOURS 3 335 DCDBS015 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 1 335 DCKPR025 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 2 335 DCMDN003 FACILITY ENVIRONMENTAL STAFF 9-20 HOURS 2 335 DCRDR009 FACILITY STAFF <= 8 HOURS 1 335 DCRDR011 FACILITY STAFF <= 8 HOURS 3 335 LEXJLW017 FACILITY STAFF <= 8 HOURS 1 335 LEXJLW019 PRESIDENT/OWNER OF COMPANY. <= 8 HOURS 1 367 DCKMM019 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 4 367 DCKMM020 FACILITY ENVIRONMENTAL STAFF 9-20 HOURS 5 367 DCKMM023 CONSULTANT/CONTRACTOR 41-100 HOURS 4 367 DCKMM026 CONSULTANT/CONTRACTOR 21-40 HOURS 1 367 DCKPR022 FACILITY ENVIRONMENTAL STAFF <= 8 HOURS 1 SAFETY DEPARTMENT STAFF 367 DCMJB005 FACILITY ENVIRONMENTAL STAFF 9-20 HOURS 4 367 DCRDR004 FACILITY ENVIRONMENTAL STAFF 9-20 HOURS 2 CORPORATE ENVIRONMENTAL STAFF SAFETY DEPARTMENT STAFF 367 DCRDR014 FACILITY STAFF <= 8 HOURS 1 367 LEXJLW023 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 6 367 RTPMOP009 CONSULTANT/CONTRACTOR 9-20 HOURS 1 367 RTPMOP011 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 7 369 DCRDR008 FACILITY STAFF 41-100 HOURS 1 369 LEXJLW020 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 3 369 LEXJLW021 CONSULTANT/CONTRACTOR 9-20 HOURS 1 371 DCDBS016 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 11 371 DCDBS018 CONSULTANT/CONTRACTOR <= 8 HOURS 1 371 DCDBS019 FACILITY ENVIRONMENTAL STAFF >100 HOURS - 160 3 371 DCKMM025 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 3 371 DCKPR021 MAINTENANCE SUPERVISOR <= 8 HOURS 1 371 DCKPR023 FACILITY ENVIRONMENTAL STAFF 9-20 HOURS 1 CONSULTANT/CONTRACTOR 371 DCKPR024 CONSULTANT/CONTRACTOR 41-100 HOURS 2 371 DCMJB002 CORPORATE ENVIRONMENTAL STAFF 41-100 HOURS 3 371 DCMJB003 FACILITY ENVIRONMENTAL STAFF 9-20 HOURS 4 371 DCMJB004 FACILITY ENVIRONMENTAL STAFF >100 HOURS - 200 14 371 DCMJB006 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 4SIC ID PERSONNEL RANGE FORMR

17 371 DCRDR005 FACILITY ENVIRONMENTAL STAFF <= 8 HOURS 2 371 DCRDR007 CORPORATE ENVIRONMENTAL STAFF >100 HOURS - 999 5 371 LEXJLW022 FACILITY ENVIRONMENTAL STAFF <= 8 HOURS 2 371 RTPMOP012 FACILITY ENVIRONMENTAL STAFF <= 8 HOURS 2 372 DCKMM024 CORPORATE ENVIRONMENTAL STAFF 9-20 HOURS 3 372 DCMDN002 FACILITY ENVIRONMENTAL STAFF 21-40 HOURS 2 372 DCRDR013 FACILITY ENVIRONMENTAL STAFF 41-100 HOURS 4 SAFETY DEPARTMENT STAFF 372 RTPMOP013 FACILITY ENVIRONMENTAL STAFF 9-20 HOURS 1

Data from RTI: RY99

Facility Name SIC Burden per Form R
James River Corp. 2611 8

Abbot Chemicals 2833 16

Pfizer Inc. 2833 14

Harris Paints 2851 88

Sunoco Inc 2911 9 -16
Edgewater Steel Ltd. 3312 3
Dynamet, Inc. 3356 8

GE Co. 3511 15
Pratt & Whitney 3724 53

Boise Cascade. 2611 7.7

UCAR Resinas 2821 76
Schering-Plough 2833 48
Chem Design Corp. 2869 8
Star Enterprises 2911 28
Washington Steel 3312 12

Avon Lomalinda 3471 8 Hazelett Strip Casting 3545 36
General Dynamics, Corp. 3714 1018 TRI-ME Users: RY00

TRIFID SIC FORM Rs MIN TOTAL BURDEN MAX TOTAL BURDEN AVG FACILITY AVG/FORM AVG % SAVINGS FROM 1999 37774MLBBTHIGHL 3732 1 0 8 4 4.0 5 28677JHNBLSALIS 2295 2 21 40 30.5 15.3 78 72301CPSCHBRIDG 2869 10 41 100 70.5 7.1 10

53021KNRC200IN 3089 1 0 8 4 4.0 35 17756YNGND16PAI 3535 2 21 40 30.5 15.3 15 73701PLLSB1301N 2041 1 9 20 14.5 14.5 20 27407CFLNC2750P 4953 1 9 20 14.5 14.5 15

Form A Filers: RY00

TRIFID SIC CHEMICALS ON FORM A MIN TOTAL BURDEN MAX TOTAL BURDEN AVG Facility AVG/CHEM Facility MAX/CHEM

30705SHWND616DU 2273 1 1 3 2 2.0 3.0 38654MNSHP10333 2653 1 6 8 7 7.0 8.0 07055BRTLP61WIL 2879 15 21 40 30.5 2.0 2.7 17044MRLTT30IND 2451 1 4 6 5 5.0 6.0 49068CMCST425LE 3086 8 0 1 0.5 0.1 0.1 68776SXCTY25GST 3321 2 9 20 14.5 7.3 10.0 43824SPRBN33715 3544 1 1 3 2 2.0 3.0 45154TRNTYFRONT 3743 1 41 100 70.5 70.5 100.0 28621PRDFRHWY26 2048 3 9 20 14.5 4.8 6.7