This ICR is
approved for two years. However, OMB is concerned that the current
alternate threshold provisions are not yielding the reduction in
burden that could be achieved. EPA is seeking to increase use of
the Form A by emphasizing its availability during TRI training
sessions, directly contacting eligible facilities to make them
aware of it as a reporting option, and modifying the reporting
package in a way that makes the Form A easier to identify and use.
However, these activities, while helpful, appear likely to yield
only modest additional burden reductions. EPA should thus: 1)
further consider options for reducing TRI reporting burden through
the use of Form A 2) incorporate such changes as it deems
appropriate into the next submission of this ICR, and 3) report to
OMB at that time on its consideration of burden reducing options
under these terms of clearance. In May of 1998, the Agency released
a report entitled "Analysis of Changes to the Alternate Threshold
Provisions" which discussed various options for reducing the burden
associated with the TRI program. This report formed a basis for
discussion of such changes by the Toxics Data Reporting (TDR)
Committee of the National Advisory Council for Environmental Policy
and Tecnology. This committee is currently completing its final
report. EPA incorporated one suggestion from the May report into
the current ICR. As a result, facilities may now report multiple
chemicals on a single Form A. This will result in an estimated
annual burden reduction of about 13,000 hours (0.2 percent of the
total burden associated with TRI reporting). EPA is to be commended
for adopting this burden reducing change, which should not
compromise the usefulness of the data collected in any way. The
report discussed many other possible changes. These were divided
into two basic categories: otpions that would not change Form A
eligibility and options for increasing Form A eligibility. In
addition to allowing multiple chemicals on a single form, the first
category included eliminating some facility level info from the
form, combining the Form A and Form R into a single form, allowing
a one-time rather than an annual certification, and not requiring a
written certification at all for eligible facilities. The second
category included adjusting the level of the waste threshold from
the current 500 pounds to either 1,000, 2,000, or 5,000 pounds,
adjusting the activity threshold from the current 1 million pounds
to 2, 5, or 10 million pounds, and changing the categories of waste
included in the waste threshold calculation (ie, excluding
quantities recycled and/or quantities used for energy recovery).
The report also discussed the possibility of offsetting the reduced
information associated with options in the latter category by
expanding the Form A to include some limited range reporting. EPA
should further consider all of these options. In particular, the
Agency should give serious consideration to the option of
increasing the waste threshold to either 2,000 or 5,000 pounds. As
indicated in the report, this would reduce reporting burden for the
TRI program by about 7 percent, while removing only about 0.1
percent of waste from comprehensive reporting under Form R. In
conjunction with such a change, the Agency might also consider
adding one-time releases (item 8.8 on the Form R) to the items
included in the waste threshold calculation, in order to address
the concern that significant one-time releases may otherwise go
unreported. Finally, in order to increase awareness of the Form A
option, the Agency should consider modifying the electronic
reporting software to specifically remind respondents up front of
this option and, if desired, lead them through the eligibility
calculations.
Inventory as of this Action
Requested
Previously Approved
02/28/2001
02/28/2001
01/31/1999
9,072
0
27,635
646,875
0
991,301
0
0
0
The Emergency Preparedness and
Community Right-to-Know Act (EPACRA) requires certain chemical
facilities to report their annual environmental releases of
specified chemicals if such releases exceed a determined threshold.
EPA has established an alternate threshold for facilities with low
release amounts of such chemicals. Each facilities using the
alternate threshold must file an annual certification stating that
the total releases of a given chemical did not exceed 500 pounds
for the reporting year and that the chemical was manufactured in an
amount not exeeding 1 million pounds during the reporting
year.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Alternate Threshold for Low Annual Reportable Amounts, Toxic Chemical Release Reporting