This collection was first approved in March of 1995 with the understanding that EPA would use the data from the July 1, 1996 reports to recalculate the number of respondents and the estimates of respondent burden and to make a determination whether the alternative threshold level should be changed. EPA's submission on August 2, 1996 claimed that because the reporting deadline was extended to August 1, 1996, the EPA did not have sufficient time with the data to comply with the earlier terms of clearance. Therefore, this collection of information is approved through June 1, 1998, to allow EPA to continue to collect this information and to evaluate its experience with the program. On the basis of this evaluation, EPA should seek to make changes, where appropriate, to the program such that they are effective for the 1997 report filed in July of 1998. Prior to submission of this collection for renewal, the EPA shall analyze the data it received in 1996 and the data that it will receive in 1997 to make the recalculations in burden referenced above and to make a determination whether rule changes are warranted. Specifically, the EPA should check its projections of reductions in paperwork burden against the actual number of the Forms A submitted. EPA should examine the effects of adopting a higher reportable amount such as 1000 or 5000 pounds and of raising the alternate threshold from one million pounds to five or ten million pounds. The EPA should also evaluate the possibility of excluding recycling and energy recovery from the reportable amount and the possibility of using quantities of releases rather than quantities of wastes as the basis for reporting. As part of this submission, the EPA shall assess the practical utility and burden associated with each of these requirements (under Form A and Form R) and respond to the following questions: 1) How many reports were filed using Form A, and how many would be filed if the rule were modified as discussed above? 2) What was the resultant reduction in paperwork burden, and how much would the bruden be reduced if the Form A requirements were modified? 3) What was the reduction in reported releases, and what would the reduction be for the alternatives? 4) What, if any, are the important losses in information associated with the various alternatives? EPA should submit an interim report to OMB by June of 1997 answering these questions for the 1995 Reports. If EPA determines that changes in the regulation are warranted, the Agency shall initiate a rulemaking promptly to make the necessary changes (see 5 CFR 1320.14(f)). OMB also reserves its right to initiate a proposal for change.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
05/31/1998
05/31/1998
09/30/1996
20,514
0
23,288
709,784
0
803,436
0
0
0
The Emergency Preparedness and Community Right-to-Know Act (EPCRA) 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 facility using the alternate threshold must file an annual certification stating that the total releases given chemical did not exceed 500 pounds for the reporting year and that the chemical was manufactured in an amount not exceeding 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