This ICR is
approved for two years. However, OMB continues to be concerned that
the current Form A is not yielding the expected reduction in
burden. EPA has stated that it 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 it easier to use. However, these
activities, while helpful, appear likely to yield at most modest
additional burden reductions. EPA should thus: 1) further consider
options for reducing TRI reporting burden through the use of the
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. The previous submission of this ICR was approved with
similar terms of clearance. Since then, EPA has increased the
burden of the TRI program through its PBT initiative. EPA does not
allow the use of Form A for PBT chemicals, reducing the number of
reports that are eligible for Form A. The previous terms of
clearance noted a number of burden reduction options discussed in a
1998 "Analysis of Changes to the Alternate Threshold Provisions"
and the subsequent report of the Toxic Data Reporting (TDR)
Committee of the National Advisory Council for Environmental Policy
and Technology. These reports discussed a broad range of burden
reduction options for the TRI program. Of particular relevance to
Form A were the options of adjusting the level of the waste
threshold from the current 500 lbs to either 1,000, 2,000, or 5,000
lbs, adjusting the activity threshold from the current 1 million
lbs to either 2, 5, or 10 million lbs, and changing the categories
of waste included in the waste threshold calculation (ie, excluding
quantities recycles and quantities used for energy recovery). In
light of the significant increase in TRI reporting burden since
this ICR was last approved, and the limited progress in achieving
meaningful burden reduction, EPA should seriously consider all of
these options, as well as other burden reduction options not
related to Form A. One promising option would be to move to either
alternate year reporting, or to allow a streamlined certification
of 'no significant change' in alternate years. EPA should report on
its consideration of these options in the next submission of this
ICR and/or the ICR for the Form R.
Inventory as of this Action
Requested
Previously Approved
03/31/2003
03/31/2003
02/28/2001
14,793
0
9,072
644,761
0
646,875
0
0
0
This ICR extends approval to collect
information under the Emergency Planning and Community
Right-to-Know Act (EPCRA) section 313 and section 6607 of the
Pollution Prevention Act (PPA) of 1990. Respondents submit
information concerning toxic chemical releases into the air, land
and water.
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