Ratio Based Methodology

1363.21 Ratio-Based Methodology.pdf

Toxic Chemical Release Reporting

Ratio Based Methodology

OMB: 2025-0009

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 2025-0009 can be found here:

2019-12-27 - No material or nonsubstantive change to a currently approved collection
2019-04-10 - No material or nonsubstantive change to a currently approved collection

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Revising TRI Burden to Ratio-Based Methodology
Information Collection Request Renewal (ICR) 2nd FR Notice

April 28, 2011
TRI Regulatory Development Branch
TRI Program Division
Office of Information Analysis and Access
Office of Environmental Information

Authors
EPA
Laura B. Nielsen, Ph.D.
Kara Koehrn
Andrew Prugar
Zachary Scott
Esmeralda Stuk
Abt Associates Inc.
Susan Day
Svetlana Semenova
Rebecca Fink

Table of Contents
Abstract
Acknowledgment
Introduction
Overview
TRI Program Burden Estimate Requirements and Uses
Background Research: Relevant History and Methodology Comparisons
Ratio-Based Burden Methodology, Methods, and Models
Benefits
Appendix A. Methodology Overview and Guide to Methods Technical
Appendices (B-E)
Appendix B. Steady State Total Burden Calculation
Appendix C. Form Element Estimation
Appendix D. First-Time Filer Estimation
Appendix E. Cost Conversion
Appendix F. Program Staff Tool
Appendix G. Abt Associates Engineering Studies
Appendix H. Peer Review Information

iii

iv
v
1
1
4
5
9
12

A-1 to A-18
B-1 to B-26
C-1 to C-16
D-1 to D-4
E-1 to E-6
F-1 to F-8
G-1 to G-64
H-1 to H-4

Abstract
The TRI Program Division is proposing to revise the TRI burden methodology to a Ratio-Based
Burden Methodology (RBBM) to boost efficiency and sharpen transparency. Through
simplifications, internal consistency, and better access, EPA staff and the general public will
obtain faster, more reliable, and more understandable burden estimates for a variety of uses. The
TRI Program Division envisions implementing this methodology in the 2012 ICR Renewal.
Thereafter, the methodology will also be employed in economic analyses associated with TRI
rulemakings.
RBBM simplifies calculations and imposes internal consistency while maintaining the overall
total Program burden estimate as a starting point. The revised structure consists of four ratio
models plus one base number, the Nominal Form R unit burden. The ratio models characterize
key relationships of TRI burden estimation. For example, the A/R model, a ratio of Form A
(single-chemical) to Form R burden, ensures internal consistency between Form A and Form R
burden estimates. The Nominal Form R unit burden provides a comprehensive unit burden of
35.7 hours per Form R and consequently also supports focused discussions about burden
estimate accuracy.
TRI’s burden estimates comply with Paperwork Reduction Act (PRA) requirements for
providing burden estimates, “to the extent practicable,” while reflecting a reasonable sense of
average conditions and an appropriate level of specificity. The activities included in burden
estimates are the same in RBBM as under the previous methodology. For activities associated
with filing TRI Form R/Form A chemical reports, burden estimates include: rule familiarization,
compliance determination, calculations and Form completion, and recordkeeping and
submission. For activities unrelated to Form reporting, burden estimates include: supplier
notification, non-reporter compliance determination, and petitions.
As a result of RBBM’s simplicity, internal consistency, and accessibility, the TRI Program
Division anticipates that staff will need to spend less time and effort developing TRI information
collection burden information. In addition, ease of re-creating estimates supports administrative
consistency, while improved access to calculations affords greater transparency.

Acknowledgment
The authors thank the following colleagues who provided a fresh perspective in their informal
reviews of portions, or of the entire draft, at various stages of document development.
Rachel Alford
Daniel Bushman, Ph.D.
Louise Camalier
Constance Downs
Olga Faktorovich
Thomas Forbes, Ph.D.
Gregory Nielsen
Barry Nussbaum, D.Sc.
Cody Rice
Denice Shaw, Ph.D.
Daniel Teitelbaum

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Revising TRI Burden to Ratio-Based Methodology
Introduction
The purpose of this document is to provide technical explanation and documentation for the
Ratio-Based Burden Methodology (RBBM), as currently proposed for use in the Toxics Release
Inventory (TRI) Program. In addition, EPA explains how RBBM will be able to provide
improvements in efficiency, administrative consistency, and transparency. EPA begins with an
overview of the methodology, followed by background information, and research comparing
burden estimate methodologies. EPA then explains the RBBM approach, including quantitative
details of its constituent methods, such as the Steady State Total Burden Calculation (page 10).
Lastly, EPA presents the benefits of using RBBM. Appendices A-E supplement the main body
of the report. More specifically, EPA provides an overview of the methodology in Appendix A,
followed by technical appendices for each of the constituent methods: Steady State Total Burden
Calculation, Form Element Estimation, First-Time Filer Estimation, and Cost Conversion
(Appendices B-E, respectively).
Additional appendices F-H are provided as reference material. Appendix F depicts the Program
Staff Tool, a Microsoft Excel spreadsheet which is designed to provide a user-friendly interface
for generating burden estimates. Appendix G provides the Abt Associates Engineering Studies,
which provide previously developed detailed data element-specific burden estimates used as the
building blocks for RBBM’s ratio models. Appendix H summarizes the May 2010 peer review of
an earlier draft of this document. Also useful for reference are: 1) the Form R and Form A ICR
Supporting Statements 1 from the 2008 TRI ICR, and 2) the Form R and Form A ICR Supporting
Statement 2 for the ICR slated in 2012, which illustrate the existing and revised methodologies,
respectively. The latter item is being published concurrently with this document (originally and
with this revised version).
Overview
Ratio-Based Burden Methodology (RBBM) simplifies calculations, establishes internal
consistency, and sharpens transparency while retaining the components of the existing
methodology and maintaining the overall total Program burden estimate as a starting point. EPA
initiated this methodology revision due to its experience with Information Collection Request
(ICR) renewals and rulemaking economic analyses (EAs) that were particularly complex and/or
performed under tight time constraints. In less formal settings, additional ideas for characterizing
burden emerged from staff experiences while generating burden estimates. Consequently, EPA
sought improvements on the current approach, as guided by two key questions: 1) What is the
simplest and easiest way to calculate burden? and 2) How can EPA best provide clearly defined
and consistent estimates?
The current methodology for estimating burden hours and cost is based on a system of 96 factors
organized into four categories as shown in Figure 1. There are 96 total factors because for each
of the four categories—persistent bioaccumulative and toxic (PBT) first year, PBT subsequent
1

Toxics Release Inventory (TRI) Form R Toxic Chemical Release Reporting Information Collection Request Supporting Statement. EPA ICR
#1363.15. March 02, 2008. and Toxics Release Inventory (TRI) Alternate Threshold For Low Annual Reportable Amounts; TRI Form A Toxic
Chemical Release Reporting Information Collection Request Supporting Statement. EPA ICR # 1704.09. March 2, 2008. Docket #EPA-HQ-TRI2007-0355.
2
Toxics Release Inventory (TRI) Form R and Form A Toxic Chemical Release Reporting Information Collection Request Supporting Statement.
EPA ICR#1363.21. OMB Control No. 2025-0009. Date Forthcoming. Docket # EPA-HQ-OEI-2010-0835; hereafter referred to as TRI 2012 ICR
Supporting Statement.

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Revising TRI Burden to Ratio-Based Methodology
year, nonPBT first year, nonPBT subsequent year—there are 12 factors (two for each facilitylevel and form-level, estimated across three labor categories—managerial, technical and
clerical). Taking those 12 factors across four categories and two Forms (R and A) yields this
total of 96 factors. For each category’s set of factors, such as Form R non-PBT subsequent year
unit burdens, a relevant subpopulation TRI chemical count must be provided – for example, the
number of subsequent year non-PBT Form R chemicals. The factors in Figure 1 are referred to as
OMB-approved, as these unit burdens are officially approved by the Office of Management and
Budget (OMB) for use in estimating TRI Program burden as of March 27, 2008.
Figure 1
Current Methodology Complexity: Numerous Burden Factors and Chemical Counts

In developing RBBM, EPA decided to restructure this system for several reasons: 1) calculations
could be greatly simplified via algebraic reduction, 2) relationships between interrelated
categories could be specified via ratio models to remove potential internal inconsistencies,
3) multiple scales could be unified to prevent certain accounting errors caused by doublecounting (i.e., facility-level converted to form-level factors). 3
Table 1 provides a structural comparison between the existing methodology and RBBM as
applied to Form R burden. 4 Note that RBBM consolidates PBT factors and first-year factors
within the base “Form R unit burden” to yield one unit burden instead of multiple unit burdens.
Moreover, this single unit burden is comprehensive and thus incorporates all activities (e.g. rule
familiarization, form completion, etc.) which contribute to the burden of Form R reporting.
3

Under the existing methodology, the double-counting potential exists due to the facility-level unit burdens in two situations 1) via the structure
by which Form A and Form R reporting is estimated separately with both estimates counting facility burden 2) the rulemaking context in which
additional reports are added from facilities that already handle facility level burden regardless of the changes imposed by the rule. Both these
sources of error are prevented in RBBM.
4
The same comparison applies for Form A, but is omitted for ease of presentation.

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Revising TRI Burden to Ratio-Based Methodology
Therefore, in addition to requiring fewer unit burdens (with fewer subpopulations to track),
RBBM’s comprehensive unit burden permits the estimation of total burden by simply
multiplying just one unit burden by the total number of chemicals. In this case, total “Form R
burden” can be estimated by “Form R unit burden” multiplied by the “number of Form R
chemicals.”
Table 1: Burden Methodology Calculation Factors and Unit Burdens – Form R
Current Burden via Existing Methodology
Estimate Description: Sum the numerous products of
factors multiplied by chemical counts or facilities
(depending on the scale of the factor).

Steady State Burden via RBBM
Estimate Description: multiply the
comprehensive unit burden by total
number of chemicals.
Estimation Factor

Estimation Factors
Per (chemical) form-level:
• hrs per PBT, subsequent year,
• hrs per PBT, first year
• hrs per non-PBT, subsequent year
• hrs per non-PBT, first year

Per (chemical) form-level:
• hrs per chemical*

per facility-level:
• hrs for PBT and non-PBT, subsequent year
• hrs for PBT and non-PBT, first year
Reported Unit Burdens
(do not include related facility-level burden)
Î 29.66 hrs per Form R non-PBT (subsequent year)
Î 53.34 hrs per Form R PBT (subsequent year)

Reported Unit Burden
Î 35.7 hrs per Form R

* Incorporates all the same considerations as the existing methodology. Simplifications are detailed in the
Ratio-Based Burden Methodology, Methods and Models Section (p.9). See also Appendix B.

Focusing on RBBM information in Table 1 to present the total burden estimate, Figure 2
provides the Steady State Total Burden Calculation, RBBM’s primary method. Steady State
Total Burden is the estimate of the ongoing TRI Program burden, as updated by rulemakings’
permanent impacts, but absent any first-time filer impacts. Note that the only inputs required for
this estimate are the total counts of Form R and Form A chemicals. Next, EPA describes the key
factors within RBBM’s reformulated structure.
The Nominal Form R unit burden is the unit burden for Form R. As a component of RBBM, it
provides the base number for the entire methodology. For the transition to RBBM, its value is
back-calculated in order to maintain the established baseline’s total burden. In practice, the
Nominal Form R unit burden provides the primary focal point for assessing and maintaining
RBBM’s accuracy.
Form A unit burden is defined as Nominal Form R unit burden multiplied by A/R, a model of the
ratio of Form A single-chemical burden 5 to Form R burden. The value for A/R is derived by
assessing the Form R burden for activities similarly required to complete a Form A. A/R
5
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.” Note that for Form R
reporting, there is only one chemical per Form.

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Revising TRI Burden to Ratio-Based Methodology
specifies the relationship between Form A and Form R burden. 6 The examples in Table 1 and
Figure 2 illustrate that RBBM incorporates the same components of the existing methodology,
but offers a much simpler formulation. Furthermore, the use of ratio models such as A/R ensures
internal consistency within the new structure.
Figure 2
Ratio-Based Burden Methodology
Two Unit Burdens; 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/hour†
†

Based on June 2010 wage data. Wage data: http://www.bls.gov/ncs/ect/#tables

TRI Burden Estimate Requirements and Uses
Under the Emergency Planning and Community Right to Know Act (EPCRA), the TRI Program,
as authorized under Section 313, requires reporting facilities to submit data annually on use and
management of toxic chemicals. As part of EPA’s responsibilities to the public under the
Paperwork Reduction Act (PRA), EPA must regularly satisfy requirements that permit
information collection from members of the general public, including industry participants in the
TRI reporting community. One of these requirements is to ensure that each information
collection exercise “…informs the person receiving the collection of information of—…(III) an
estimate, to the extent practicable, of the burden of the collection.” 7 Burden estimates encompass
“…the total time, effort, or financial resources expended by persons to generate, maintain, retain,
disclose, or provide information to or for a federal agency.” These estimates should consider
time needed to: 8
6

The bases for A/R include detailed burden estimates by task, making the A/R model verifiable and readily subject to validation. See Appendix B
for development and Appendix G for detailed burden estimates by task.
US National Archives and Records Administration, Paperwork Reduction Act of 1995, Accessed 23 Mar 2010 <
http://www.archives.gov/federal-register/laws/paperwork-reduction/3506.html >
8
See EPA. 1999. ICR Handbook: EPA’s Guide to Writing Information Collection Requests Under the Paperwork Reduction Act of 1995.
Accessed 2 Feb 2010 < http://www.epa.gov/wed/pages/opportunities/icrhndbk.pdf>
7

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Revising TRI Burden to Ratio-Based Methodology

•
•
•
•
•
•
•

Review instructions;
Develop, acquire, install, utilize technology and systems, for the purpose 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.

For the TRI Program, these considerations translate to factors that reflect industry efforts
associated with form burden—rule familiarization, compliance determination, calculations and
form completion, recordkeeping, and non-form burden—supplier notification, non-reporter
compliance determination, and petitions.
The TRI Program uses burden estimates in the context of three main types of Program activities:
ICR renewal, rulemaking economic analyses, and informal informational gathering. At the time
of the ICR renewal, which is performed every three years, EPA’s TRI Program must update the
burden estimates that OMB has on record for the current burden associated with TRI reporting.
The Supporting Statement for the ICR renewal provides estimates of the program’s ongoing
burden—or steady state total burden—in labor hours, and cost in current dollars. These estimates
are obtained based on actual conditions as measured in the most recent TRI reports. 9
In the context of a rulemaking, the economic analysis provides burden estimates in order to
predict the impact of the policy change(s) under consideration. Upon policy implementation, this
estimated incremental change in burden is added or subtracted from the current burden estimate
that OMB has on record. If the rulemaking increases the number of reporters or otherwise
imposes reporter start-up burden, the economic analysis also provides estimates of first-time filer
burden incurred during the first year of a policy change. Note that economic analysis estimates,
both steady state and first-time filer, are based on models—not actual conditions. If there are
differences between the economic analysis predictions and the actual conditions, these
differences are implicitly reconciled at the next ICR renewal as the ICR is based on actual
reporting of Form R and Form A chemicals. 10
Background Research: Relevant History and Methodology Comparisons
The information in this section provides background in preparation for presenting more detail
about RBBM in the next section. The methodology history explains how the TRI Program

9
Estimates based on actual conditions contrast to estimates based on model projections. Note that in the event that the TRI program implements
policy changes due to a rulemaking finalized in the course of the year of the ICR renewal project, the ICR renewal burden estimates are updated
using more current information and/or models.
10
For example, when new policy permits decreases in reporting that are not fully utilized, the economic analysis may predict a reduction in
reporting, while the ICR measures the actual reporting at levels higher than originally modeled/anticipated.

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burden methodology has evolved. Methodology comparisons show that EPA’s existing and
revised methodologies fit within the range of currently accepted practices. 11
Methodology History
Under the existing methodology, EPA calculates total industry burden estimates using a
methodology established at the TRI Program inception that has since been periodically reviewed
and approved by OMB during ICR renewals. For example, as the program underwent changes in
reporting—such as implementing the shorter Form A—the methodology underwent reviews and
occasional revisions. Beyond minor adjustments to include additional form elements, the biggest
revision occurred in the 2004 ICR Renewal when changes to the system of unit burden factors
were adopted.
As preparation prior to the 2004 ICR renewal, EPA staff questioned the magnitude of estimates
and related unit burdens which had not been updated since the beginning of the TRI program,
given the fact that the program had implemented technological advances designed to ease
reporter burden. 12 Based on numerous evidentiary sources, EPA proposed a systematic revision
to the methodology. After the public comment period and OMB review, partial revisions were
implemented which lowered total burden estimates by 49%, 13 and also resulted in: 14
• Reducing the amount of Form R Non-PBT unit burden, while holding PBT unit burden
constant, thereby unintentionally imposing a distinction in which PBT burden is 1.73 of
non-PBT burden (i.e., 73% higher). This change occurred as an offshoot of the revision
process, rather than as a deliberate specification.
• Maintaining the ratio of Form A unit burden to Form R unit burden at .64 as previously
determined. 15
Subsequently, during the Phase I Burden Reduction Rule, EPA proposed to revise the
methodology using a basis developed in Abt Associates Engineering Studies. The July 2004
document and methodology was peer-reviewed with results posted in the public docket
(Proposed Rule EPA HQ-TRI-2005-0073). The method was neither finalized nor formally
adopted into TRI burden estimation practice.
By the time of the 2008 ICR revision, TRI staff and management recognized sources of potential
internal inconsistency that, at a minimum, led to confusion and/or inefficiency. For example, the
ratio of .64 for Form A to Form R burden was not readily verifiable. Additionally, the effective
ratio of 1.73 for PBT to non-PBT burden was not directly specified, and therefore could not be
verified. Lastly, procedures for revising/adding form elements occasionally used a set of
estimates which were not reconciled to the whole (form) unit burden, and therefore could not be
11
Per analysis in Table 2. Sources: EPA -TRI Program Staff (June 2009); IRS – Office of Research, Taxpayer Analysis and Modeling Group
(June 2009).
12
An electronic version of the Reporting Forms and Instructions was initially implemented in desk-top software (TRI-ME CD) and later upgraded
to Web-based technology (TRI-MEweb).
13
Total TRI Program burden estimate was decreased from 6.03 million to 2.61 million hours based on Notices of OMB Action (called Paperwork
Reduction Submissions) for Form R ICR and Form A ICR. Submitted October 27, 2003; Approved January 9, 2004. Per the 2004 ICR
Supporting Statement, 85.95 % of the (57%) total reduction was associated with adjustment of “unit burden for Form R completion in subsequent
years from 47.1 to 14.5 hours,” yielding a 49% decrease in total burden associated with the methodology change. See Appendix B for full
breakdown of the 2004 ICR renewal 57% decrease.
14
For context and details, see: Rice, Cody. 2004. Terms of Clearance for TRI ICR Renewal. Regulations.gov. Accessed 23 Dec 2010

15
See Appendix B for additional detail and references to supporting material.

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Revising TRI Burden to Ratio-Based Methodology
applied consistently across Form R and Form A. As a result of these issues, EPA staff had
limited ability to manage questions about the origin and validity of burden estimates. From these
observations, EPA concluded that a revised methodology should require internally consistent and
verifiable unit burdens.
Methodology Comparisons
In the process of seeking guidance for RBBM’s design, EPA staff reviewed a range of
approaches to burden estimation in government information collections, all of which conform to
PRA requirements. Table 2 depicts methodology features from several high volume collections,
including TRI. In this discussion, the term “calibration” refers to a method by which estimates
are compared to, and reconciled with, an actual measurement of the quantity that they are
designed to estimate. 16 The IRS 1120 (U.S. Corporation Income Tax Return) and IRS 1040 (U.S.
Individual Income Tax Return) collections employ a lower and higher level of accuracy in their
methodologies, respectively, when compared to TRI. EPA’s TRI burden methodologies (both the
existing and the algebraically equivalent RBBM) fall in between, with high specificity but no
calibration via representative sampling. 17 Across the columns of Table 2, the differences in
approaches address different applications and correspondingly require different types of
maintenance.
With the IRS examples, additional specificity accompanies higher precision because the more
complex 1040 burden estimation employs calibration using a representative sample. In contrast,
TRI burden estimates are derived from best professional judgment without this type of
calibration. Generally, the TRI-type of methodology develops calculations drawing from an
appropriate amount of specificity and some sense of average values. Overall, calibrated estimates
are more accurate than uncalibrated estimates; but highly specified estimates are not necessarily
more precise (and hence not necessarily more accurate) than less specified estimates. In the
context of TRI’s uncalibrated estimates, increasing specificity (i.e., adding variables) adds
complexity without necessarily increasing precision. EPA concludes that neither TRI’s existing
nor revised methodologies require additional specificity. EPA also considered enhancing the TRI
methodology with calibration via a representative survey but did not wish to impose additional
burden on the TRI reporting community. TRI’s approach is appropriate and complies with PRA
requirements for providing burden estimates, “to the extent practicable” while reflecting a
reasonable sense of average conditions and an appropriate level of specificity. 18
In summary, the internal consistencies identified during the 2008 ICR Renewal, and the insight
above regarding appropriate complexity lay the groundwork for RBBM’s design. A simpler
formulation is derived with ratio models ensuring internal consistency across Forms R and
Forms A, as well as from form elements to whole forms.

This definition contrasts with the one used in scientific circles that discuss measurement techniques, where accuracy has two components: nonbias and precision. In such contexts, calibration is assured using a high precision “standard.” Outside this context (as in RBBM), estimates
achieve accuracy by approximating the average conditions and incorporating an appropriate level of specificity.
17
Note as a matter of context that the TRI Program’s methodology is the Agency’s most complex (per Rick Westlund, OEI Office of Information
Collection 1/13/2010).
18
RBBM allows for future enhancements. As the single base number, the Nominal Form R burden may be adjusted to reflect updates identified
via calibration or other sources.

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Table 2: Burden Estimation Methodology Features from Example Government Information Collections
Sources: EPA—TRI Program Staff (June 2009); IRS— Office of Research (June 2009)

IRS 1120
Corporate (ADL)
Uncalibrated/
Low Specificity

Description

TRI Current
Form R and Form A
Uncalibrated/High Specificity

Burden depends on:
• the number of lines on the
form instructions
• the number of fields
• the number of attachments
• the number of line items
completed

Burden depends on:
• Unit burdens for Form A and Form R (PBT,
non-PBT) set by informed decisions based
on best professional judgment and input via
Public Comment
• Estimates of Incremental increases to form
burden based on Abt Associates Engineering
estimates and case-by-case evaluations

Model burden based on
readily observable variables

Identify element-level processes; assign
values for associated activities

Methods
Development

Assumptions
Updates/Survey
Requirements

TRI Proposed (RBBM)
Form R and Form A
Uncalibrated/Simplified
Specificity
(Equivalent to TRI Current)
Burden depends on:
• Internally consistent and verifiable unit
burdens for Form A and Form R. Unit
burdens reflect the number of elements and
related calculations. Nominal Form R unit
burden set by informed decisions based on
best professional judgment and input via
Public Comment.
• Estimates of incremental increases to form
burden utilize internal consistent system of
standardized form element estimates
Restructure to simplify and to ensure
internal consistency. Retain previously
identified processes; utilize Abt Associates
Engineering estimates of element-level
burden on a relative basis (in ratio models).
• Model relationships between population
subsets as ratios
• Maintain same baseline burden as a
starting point.

IRS 1040
Individual (ITBM)
Calibrated/
High Specificity
Microsimulation Model:
• Burden is modeled as a
function of taxpayer
characteristics
• The model is applied to a
representative sample of tax
returns and the resulting
burden estimates extrapolated
to the population as a whole

Identify element-level
processes; calibrate via
representative survey
• Survey individuals’
completion time of complete
low level processes
• Model burden based on
taxpayer characteristics
• Generalize model results to
population

Few, strong assumptions

Several, unverifiable assumptions

Few, measurable assumptions

Many, validated assumptions

Based on survey data for one
population extended to other
populations
Updates as there are changes
to forms

Not based on survey data

Not based on survey data (capability exists
for future upgrade)

Updates as there are changes to forms;
otherwise, wholesale adjustments are nonsytematic
Satisfies PRA requirements

Updates as there are changes to forms;
otherwise wholesale adjustments
streamlined and internally consistent
• Easy to update

Model calibrated with 2008
survey data, update planned
for 2011.
Model inputs updated yearly

Easy to update

Strengths

• Accuracy (calibration)

• Increased understanding

• Robust
• Simple and transparent

• Robust
• Explicitly considers
preparation method (self or
tax-preparer)

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Revising TRI Burden to Ratio-Based Methodology
Ratio-Based Burden Methodology, Methods, and Models
The revised methodology simplifies a set of multiple, large matrices to four ratio models plus
one base number for Form R unit burden. This simplification converts the system to a new
structure, as depicted in the equation below.
Burden Hours = fct [(Nominal Form R Unit Burden), (A/R), (PBT/non-PBT), (FTFf)]
and
Cost = (Burden Hours)*WAWR
Where:

A/R =

Means “a function of”
Single base number for the entire methodology; provides
the focal point for assessing and maintaining estimate
accuracy
Ratio of burden for single-chemical Form A to Form R

PBT/non-PBT =

Ratio of burden for PBT chemical to non-PBT chemical

FTFf =
(First-Time Filer Factor)

Ratio of burden for first-time (first year) filers to steady
state (subsequent year) filers

WAWR =
(Weighted Average Wage Rate)

Cost conversion factor in current $ per hour; incorporates
fixed proportions of Managerial, Technical, and Clerical
labor categories.

fct
Nominal Form R Unit Burden=

Specifications Within a New Structure
The summary equation above applies to the entire system of methods and relevant models. In
this methodology’s final formulation, and as described below, RBBM accomplishes the
following design objectives:
• Internal consistency maintained via ratio models
o Steady state burden—A/R, PBT/non-PBT
o First-time filer burden factor—FTF f
o Standardized Form Element Burdens, as comprehensive estimates that are
consistent from element to Form, as well as across Form R and Form A
• Algebraic and substantive simplifications, including: 1) neglect the effects of first-time
filers in steady state burden estimates 19 2) set the PBT/non-PBT model equal to one20
• Unified scales across activity-specific unit burdens – i.e., facility-level factors were rescaled to (per chemical) form-level factors for both Form A and Form R
• One-step conversion from hours to current dollars, using WAWR
• Overall total Program burden estimate maintained as a starting point
19
The incremental contribution for first-time filing burden produces a very slight increase to the Steady State Total Burden estimate, as reflected
in the calculated effect of modeling error on the Steady State Total Burden estimate at -.04%. See Appendix B.
20
Specified as a ratio model, but set to the default value for the ratio equal to one, due to the lack of verifiable alternative. See Appendix B for
qualitative evidence considered (public comments and engineering studies).

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Table 3 presents the decision rules used to direct simplifications and ensure internal consistency.
See Appendices A-E for further detail. Regarding the ratio models, EPA used estimates for form
subtasks from the Abt Associates Engineering Studies as building blocks, particularly for A/R
and FTFf (See Appendix G for these studies). For example, the value for A/R is derived by
assessing the Form R burden for activities similarly required to complete a Form A.
Table 3: Methodology Development Decision Rules
Rule Description
1
Derive Form A numbers from Form R numbers using estimates of
burden by activity
2
Use Form R basis where additional complexity for Form A basis is
unmerited
3
Make simplifying assumptions where they are mathematically justified

5
6*

Make simplifying assumptions where a distinction is not backed up by
quantitative and/or statistical evidence (especially when the need for
evidence is expressed by stakeholders)
When scaling to Nominal Form R unit burden, scale up elements
equally, in proportion to their contributions to the total
Back-calculate the Form R unit burden in order to maintain the
established baseline’s total burden

Models
A/R
FTFf, WAWR
A/R Model regarding
First-Time Filers,
WAWR
A/R Model regarding
PBT/non-PBT
Standardized Form
Element Burdens
Nominal Form R unit
burden

* Preserving the existing methodology’s total burden estimate is important because TRI burden estimates are primarily used
to track changes from year to year against an established baseline. EPA defines the methodology transition point as the time
of the last ICR approval with conditions specified by 2008 ICR renewal projections. At that point in time, the Program
burden totals calculated under existing and revised methodologies are identical. See Appendix B for detailed calculations of
Nominal Form R unit burden.

The RBBM Models and Equations
Figure 4 depicts the entire system of equations for the RBBM. The values for key factors are:
• Nominal Form R unit burden is 35.7 hrs per Form R
• A/R is .615 hr/hr ; PBT/non-PBT is 1.0 hr/hr
• FTFf is 2.1 hr/hr
• WAWR (June 2010) is $49.62/hr.
See also Appendix C for Standardized Form Element Burdens and related procedures for updates
to the Nominal Form R unit burden, under RBBM.
Figure 4
RBBM System and Constituent Methods
Steady State Total Burden Calculation
Steady State Total Burden
= Form R Burden + Form A Burden + Non-Form Burden
= Nominal Form R Unit Burden*# Form R Chemicals
+ [Nominal Form R Unit Burden* (A/R)*(# Form A Chemicals )] + Non-Form Burden
4/28/11

Revising TRI Burden to Ratio-Based Methodology

Form Element Estimation
Nominal Form R unit burdennew = Nominal Form R unit burdenold + Form change burden
First-Time Filer Estimation
First-Time Filer Burden
= FTFf * (Relevant Steady State Burden)
= FTFf *[(Nominal Form R Unit Burden* # New Form R Chemicals)]
+ [(A/R) * Nominal Form R Unit Burden * # New Form A Chemicals]
Cost Conversion
Steady State Total Cost = (Steady State Total Burden)*WAWR

Ratio Models: Stability and Internal Consistency
Beyond imposing internal consistency and preventing related inconsistencies from developing in
the future, ratio models are inherently more (roughly) stable and therefore more robust to
changes than their component variables. For example, for A/R (the ratio of Form A burden to
Form R burden) the value of the actual ratio (.615) remains stable over the course of typical
Program changes. This ratio remains stable because the actual changes to Form R and Form A
impose similarly small incremental burden changes to both the numerator and the denominator
of the ratio, thus causing the ratio itself to remain roughly constant. 21 In contrast, the Nominal
Form R unit burden requires routine updating because typical changes to the Form R increase or
decrease actual reporting burden per Form R. Last, the ratio models are useful standalone metrics
because they quantify key relationships between two elements. For example, A/R is .615,
reflecting the burden of a Form A as 61.5% of the burden of a Form R, and implying that filing a
Form A instead of a Form R yields a 38.5% burden reduction per chemical.
Nominal Form R Unit Burden: Comprehensive Focus and High Utility
The Nominal Form R unit burden provides a number of functions. As already stated, it is the
base number for the entire methodology, providing a single focal point for discussions about
methodology accuracy. This contrasts with the existing methodology in which numerous factors
and variables are maintained and the suggestion to add more variables (e.g., staff turnover) arises
frequently. Instead, RBBM supports focused discussions about whether 35.7 hours per Form R is
the correct base number. Second, revisions are straightforward. In rulemaking and ICR revision,
Form R changes are estimated and applied to the Nominal Form R unit burden. Other changes in
the system are automatically propagated via the ratio models (to Form A and for first-time filers).
Similarly, when EPA receives information indicating that overall burden estimates are either too
high or too low, the Nominal Form R unit burden is the single primary point of adjustment.
As a clarification on RBBM’s design, note that Decision Rules 4 (PBT/non-PBT=1) and 6 (backcalculated Nominal Form R unit burden) both impact the definition for nominal Form burden, as
well as the resultant overall structure of RBBM. In choosing to leave the value of the PBT/non21
Note that in the event that the Form R and/or Form A undergo extreme revisions that alter the relationship between A/R burden, then A/R would
require updating.

4/28/11

Revising TRI Burden to Ratio-Based Methodology
PBT ratio at the default value of one, the back-calculated base number (Nominal Form R unit
burden) remains a single focal point for considering overall average conditions for Form R
burden per chemical. 22 This single focal point is afforded by the simplicity of the overall Steady
State Total Burden Calculation that also does not required a PBT/non-PBT model and tracking of
related separate subpopulations. Moreover, given that the back-calculated Nominal Form R unit
burden preserves the existing totals as a starting point (Decision Rule 6), RBBM carries forward
certain prior assumptions from the existing methodology without explicitly modeling them. In
particular, note that the higher PBT reporting burden is incorporated into the Nominal Form R
unit burden’s starting value of 35.7 hours/Form R, which is elevated above the value that would
have been otherwise obtained—at about 30 hours/form—had only non-PBT burden been used to
determine Nominal Form R unit burden. 23
In opting for simplicity over specificity via the RBBM approach (even if PBT/non-PBT burden
were quantified), EPA retains the sophistication of a single unit burden for Form R reporting
with Form A reporting burden closely linked. The Nominal Form R unit burden reflects overall
“average” conditions, without the need to add variables. In short, any effect that EPA needs to
consider is incorporated into the average conditions of the Nominal Form R unit burden.
In the event that the overall PBT/non-PBT relationship is determined, EPA could restructure to a
more complex total burden calculation, 24 or keep the simpler formulation by updating the
Nominal Form R unit burden (single base number) on a prorated basis. Regardless, EPA would
then be able to estimate burden differences associated with PBT chemical reporting, as needed.
EPA supports this value of 35.7 hours per Form R as a reasonable approximation of the actual
unit burden, based on years of review and scrutiny to which the current total burden estimate has
been subjected. The unit burden of 35.7 hours, in the context of a new system of ratio models, is
the culmination of prior accuracy assessments (see methodology history). Therefore, this basis is
legitimized for ultimately setting the magnitude of the Program total burden at this time.
Benefits
With the simplified and internally consistent calculations plus a user-friendly interface via the
Program Staff Tool (shown in Appendix F), EPA expects RBBM to streamline burden
estimation. In addition to saving time, RBBM enhances administrative consistency with shorter,
more straightforward procedures that are readily replicated and consistently communicated. Last,
RBBM increases transparency because burden information is available in a more accessible,
compact, and comprehensive format that is easier to use. As a result, EPA staff and the general
public will obtain an increased understanding of the key drivers of burden estimation for a
variety of purposes, including those encountered in the context of public policy changes.
Therefore, EPA recommends the adoption of RBBM for the TRI Program, beginning with the
2012 ICR renewal.

Moreover, RBBM’s total burden calculation does not have the complexity of tracking separate subpopulations for Form R PBT and non-PBT
chemical reports.
For the transition, the previous methodology’s inclusion of a higher PBT unit burden for 20% of chemical reports is rolled up into the new
back-calculated unit burden. Similar logic applies to first-time filer effects, though the impact is negligible.
24
Requires the inclusion of the PBT/non-PBT ratio and separate chemical counts for Form R PBT and non-PBT subpopulations.
23

4/28/11

Appendix A
Methodology Overview and Guide to Methods Technical Appendices (B – E)
This appendix presents an overview of the revised methodology, Ratio-Based Burden
Methodology (RBBM) as a guide to the other more detailed Appendices B-E. As such, this
appendix does not provide back-up evidence or justify assumptions; that information is covered
in the relevant detailed appendices:
•
•
•
•

Appendix B – Steady State Total Burden Calculation
Appendix C – Form Element Estimation
Appendix D – First-Time Filer Estimation
Appendix E – Cost Conversion

The methodology revision project that culminated as RBBM started in May 2009, with technical
document writing initiated in March 2010. The draft technical document was submitted for peer
review on May 1, 2010. The peer reviewers endorsed the methodology as credible and effective
(See Appendix H for summary). As a result, EPA left all of RBBM’s design and major
procedures in tact. EPA then revised the technical document, addressing specific
questions/critiques of the methodology and implementing editorial suggestions from peer
reviewers and other sources. Throughout the project, EPA employed interdisciplinary teams for
methodology development, document development, and document revisions.
RBBM development was guided by the methodology priorities of simplicity, internal
consistency, and transitional baseline continuity and was more precisely specified by broadly
applicable decision rules. These rules are presented on page 10 in the main report and discussed
herein. The methodology revision entails restructuring a set of large matrices to a system of four
ratio models plus one base number (Nominal Form R unit burden, derivation to follow).
Additionally, Standardized Form Element Burdens replace case-by-case engineering estimates
for use in updating unit burden to reflect Form changes, such as burden associated with adding a
new element.
There are two major classes of burden estimates in TRI applications: steady state burden and
first-time filer burden. Steady State Total Burden is the estimate of the ongoing TRI Program
burden, as updated by rulemakings’ permanent impacts, but absent any first-time filer impacts.
These are the burden estimates that OMB has on record that are re-estimated in full at ICR
renewal time. Similarly, when an economic analysis (EA) is conducted in association with a
rulemaking, the ongoing incremental change in burden is added or subtracted from the Steady
State Total Burden, constituting a sustained steady state change in burden. In a related
application, the Form Element Estimate provides revisions to unit burden due to changes in Form
R/Form A filing requirements which can occur either in the ICR renewal or in a rulemaking.
In contrast to steady state, first-time filer burden (previously termed first-year year burden)
accounts for the elevated level of effort that reporters incur during a start-up year. In RBBM,
first-time filer burden is estimated using a ratio model that reflects the increased burden over and
above relevant steady state burden. Given this structure, EPA first derives models supporting the
Steady State Total Burden estimate, including the restructuring and related Form Element
Estimation. Thereafter, First-Time Filer Estimation is presented. Last, Cost Conversion is
presented, as this method is applicable to all burden estimates.
4/28/11
A-1

Appendix A

Steady State Burden
The Steady State Total Burden Calculation consists of Form burden and non-Form burden. In the
next sections, EPA derives the portions of the restructured system pertaining to Form burden.
This first set of derivations demonstrates that the proposed approach is a greatly simplified
algebraic equivalent to the existing method. The next section provides the derivation for the A/R
model that is central to the new structure. After that, EPA presents a revised and slightly
modified calculation for non-Form burden that addresses TRI burden not directly captured by
filling out a Form R or A. EPA then provides the procedure for back-calculating the base
number, Nominal Form R unit burden. Finally, EPA presents an overview of the related Form
Element Estimation.
Restructuring the System
The existing method for estimating Form burden consists of an extensive system of matrices that
can be collapsed and further simplified. The matrix notation for Form R burden hours is:
Eqn. A-1: Form R Burden hours = [F]chem. category, activity, YR, labor category * [N]forms
Eqn. A-2: Form R Cost = [F]chem. category, activity, YR, labor category * [N]forms * [$] labor category
Where:
chem category =
activity =
YR=
labor category =

PBT or Non-PBT
Rule familiarization, compliance determination, form completion,
recordkeeping and submission
First year or subsequent year
Management, technical, or clerical labor

And where:
[F]chem category, activity,
YR, labor category

[N]forms
[$] labor category

18x3 matrix of reporting activity factors with subsets
depending on whether the Form is for a PBT or non-PBT
chemical, and a first year or subsequent year filing…with three
columns for the three labor categories (managerial, technical,
clerical)
1x18 vector of TRI chemical counts according to the
categories specified in matrix F
3x1 vector of current dollar wage rate ($/hr) for managerial,
technical, and clerical labor

Note that a parallel set of matrices exist for Form A burden estimation in the existing
methodology. However, as the new methodology derives Form A-related burden exclusively
from Form R, the derivation that follows need only pertain to Form R.
The detailed list of OMB-approved unit burdens as of March 27, 2008 for reporting activities
(hereafter known as factors) for Form R non-PBT and PBT chemicals are presented in Tables A4/28/11
A-2

Appendix A
1 and A-2, respectively. An alternative set of factors for non-PBT only, as developed in the Abt
Associates Engineering Studies (for source reference, see Appendix G) and derived by EPA, are
presented in Table A-3 for Form R and Form A. Table A-4 provides the slightly reformulated
version of Table A-3’s factors, incorporating RBBM conversion of facility-level unit burdens to
(per chemical) form-level. The totals in Table A-4 apply directly to building RBBM ratio models
(used later in Eqns. A-4, A-9, and A-10). For the purposes of deriving the system simplification,
however, Tables A-1 and A-2 may be combined to populate the comprehensive matrices below.
Note that these tables’ factors are a mixture of facility-level and form-level constants.
Table A-1: OMB-Approved Burden, Non-PBT
Managerial

Technical

Clerical

Total

22.5

34.5

20.5

44.4

2.8

67.66

Managerial

Technical

Clerical

Total

Rule Familiarization

Compliance Determination

7.55

16.08

1.03

24.66

Managerial

Technical

Clerical

Total

22.5

34.5

20.28

43.87

2.70

66.86

Managerial

Technical

Clerical

Total

Rule Familiarization

Compliance Determination

14.10

30.37

1.86

46.34

Rule Familiarization

first year

Compliance Determination

Form R

Calculations and Form
Completion
Recordkeeping

Facility
subsequent

Form R (non-PBT)

Facility

Form R

Calculations and Form
Completion
Recordkeeping

Table A-2: OMB-Approved Burden, PBT
Facility
first year

Compliance Determination

Form R

Form R (PBT)

Rule Familiarization

Calculations and Form
Completion
Recordkeeping

subsequent

Facility

Form R

Calculations and Form
Completion
Recordkeeping

4/28/11
A-3

Appendix A
Table A-3: Abt Associates Engineering Study Factors, Non-PBT with Derived Form A
Derived
Form A
Total*

Form R (non-PBT)

first year

Total
Managerial

Technical

Clerical

Facility

Rule Familiarization

22.5

23.5

13.7

14.7

Form R

Compliance Determination
Calculations and Form
Completion

0.37

10.49

10.86

3.39

Managerial

Technical

Clerical

Total

5
Derived
Form A
Total*

0.25

1.25

0.32

6.89

0.0

7.20

2.30

subsequent

Recordkeeping

Facility

Rule Familiarization

Form R

Compliance Determination
Calculations and Form
Completion

Recordkeeping
0
4
1
5
5
* 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.

Table A-4: Ratio-Based Burden Methodology “Building Blocks” for Ratio Models
Abt Associates
Factors,
Mixed Scales

Derived
Form A*

Form R

first year

Form R

Rule Familiarization

23.5

Compliance Determination

14.7

10.86

4.27

Calculations and Form Completion
Recordkeeping
Form Burden Per Chemical Total

Facility
subsequent

Form R (non-PBT )

Facility

N/A

Rule Familiarization
Compliance Determination

Form R

Ratio-Based Burden Methodology Unit
Burdens,
Consistent per Chemical Scale

Calculations and Form Completion
Recordkeeping

Form Burden Per Chemical Total

Ratio Model
Bases
R, A Chemical **

Derived
Form A*

Form R
6.07

6.90

3.80

4.31

10.86

4.27

N/A

25.73

20.48

0.32

0.37

R, A Chemical

R, A Chemical **

1.25

7.2

2.34

7.2

2.34

N/A

12.52

7.71

R, A Chemical

*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.
** Facility-level factors converted to form (per chemical) level factors via equivalent chemicals per facility for R (3.87) and A (3.41). See
Appendix B Supplement for derivations In practice Form R reports contain one chemical per report and Form A allows multiple
chemicals (2.3 on average).

4/28/11
A-4

Appendix A

Starting with the F * N matrix product (represented by Eqn. A-1), with F being an array of
factors (burden per form or facility), and N a vector of variables (form or facility counts), EPA
simplifies by collapsing the entire set of factors to one constant and reducing vector N to one
variable—total Form R chemical counts. However, in order to make this simplification, EPA
must convert the factors to the same unit of analysis (per chemical form-level) by dividing
facility-level factors by the applicable average number of Form R chemicals per facility, Rcpfe. 1
Expanding the matrix notation and standardizing the factors’ units, F * N becomes F′ * N.
Matrix System F′ * N
FNPBT,fYR,RF,m
Rcpfe
FNPBT,fYR,CD,m
Rcpfe
FNPBT,fYR,CFC,m

FNPBT,fYR,RF,t
Rcpfe
FNPBT,fYR,CD,t
Rcpfe
FNPBT,fYR,CFC,t

FNPBT,fYR,RF,c
Rcpfe
FNPBT,fYR,CD,c
Rcpfe
FNPBT,fYR,CFC,c

NNPBT, fYR

FNPBT,fYR,REC,m

FNPBT,fYR,REC,t

FNPBT,fYR,REC,c

NNPBT,fYR

FNPBT,sYR,RF,m
Rcpfe
FNPBT,sYR,CD,m
Rcpfe
FNPBT,sYR,CFC,m

FNPBT,sYR,RF,t
Rcpfe
FNPBT,sYR,CD,t
Rcpfe
FNPBT,sYR,CFC,t

FNPBT,sYR,RF,c
Rcpfe
FNPBT,sYR,CD,c
Rcpfe
FNPBT,sYR,CFC,c

NNPBT,sYR
NNPBT, sYR

FNPBT,sYR,REC,m

FNPBT,sYR,REC,t

FNPBT,sYR,REC,c

NNPBT,sYR

FPBT,fYR,RF,m
Rcpfe
FPBT,fYR,CD,m
Rcpfe
FPBT,fYR,CFC,m

FPBT,fYR,RF,t
Rcpfe
FPBT,fYR,CD,t
Rcpfe
FPBT,fYR,CFC,t

FPBT,fYR,RF,c
Rcpfe
FPBT,fYR,CD,c
Rcpfe
FPBT,fYR,CFC,c

FPBT,fYR,REC,m

FPBT,fYR,REC,t

FPBT,fYR,REC,c

NPBT,fYR

FPBT,sYR,RF,m
Rcpfe
FPBT,sYR,CD,m
Rcpfe
FPBT,sYR,CFC,m

FPBT,sYR,RF,t
Rcpfe
FPBT,sYR,CD,t
Rcpfe
FPBT,sYR,CFC,t

FPBT,sYR,RF,c
Rcpfe
FPBT,sYR,CD,c
Rcpfe
FPBT,sYR,CFC,c

NPBT,sYR
NPBT, sYR

FPBT,sYR,REC,m

FPBT,sYR,REC,t

FPBT,sYR,REC,c

NPBT,sYR

NNPBT,fYR

NNPBT,sYR

NNPBT,fYR
NPBT, fYR
NPBT,fYR

NPBT,sYR

Figure A-1: Sample Definition of Matrix Term

FPBT,fYR,RF,m
Where:
PBT = Chemical category is PBT form. (Other possibility is non-PBT)
fYR= Year is first year of filing. (Other possibility is subsequent year of filing)
RF = Activity is rule familiarization. (Other possibilities are compliance determination,
calculations and form completion, and recordkeeping and submission)
m=
Labor category is managerial. (Other possibilities are technical and clerical)
1

Although this appears to be a straightforward conversion, in practice it was not. EPA derived “equivalent chemical
per facility,” for Form R and Form A, based on distributions of Form R and Form A chemicals within and across
facilities, on average. See Appendix B Supplement for details.

4/28/11
A-5

Appendix A
To help clarify terms, Figure A-1 defines the terms for an example variable in the matrix. The
value of each variable is contained in Tables A-1, A-2 (existing methodology), and A-3, A-4
(revised methodology).
Assuming that the first-time filer effect is negligible and asserting the model that PBT/non-PBT
burden=1 (i.e., on average no quantifiable difference between burden for filing a PBT chemical
report versus a non-PBT), the matrix factors reduce to a simple sum. Correspondingly, the matrix
product reduces to the unit burden (hours per Form R chemical) times the total number of Form
R chemicals.
F′′ * N′ (with matrix N reduced to the constant NR for total number of Forms)
Matrix System F′′ * N′
FNPBT,sYR,RF,m
fpRe
FNPBT,sYR,CD,m
fpRe
FNPBT,sYR,CFC,m

FNPBT,sYR,RF,t
Rcpfe
FNPBT,sYR,CD,t
Rcpfe
FNPBT,sYR,CFC,t

FNPBT,sYR,RF,c
Rcpfe
FNPBT,sYR,CD,c
Rcpfe e
FNPBT,sYR,CFC,c

FNPBT,sYR,REC,m

FNPBT,sYR,REC,t

FNPBT,sYR,REC,c
4

Eqn. A-3: 2 Form R Burden Hours = NR﴾ ∑
i =1

∑

NR
NR
NR

F′′i,j ﴿ = NRCR

j =1

Where:
CR=

Sum of all factors in the matrix, reflecting the unit burden per Form R chemical

Intuitively, one would state this equation as follows: “the total Form R burden hours estimate is
the product of the Form R unit burden times the number of chemicals filed by Form R where the
unit burden consists of four contributing activities: rule familiarization, compliance
determination, calculations and form completion, and recordkeeping and submission.”
Ensuring Internal Consistency Using Ratio Models and Engineering Estimates
If EPA were to make simplifications such as “Form R burden hours = NRCR” and go no further,
EPA would greatly reduce the computational and reporting complexity for TRI program burden
calculations. However, this alone would not address one of the key concerns that led it to
develop a new method: internal consistency. Consistency across Forms R and A is desired, as
well as consistency in computing estimates of the first-time filing burden that affect new entrants
to the reporting community as a result of policy change. Ratio models of A/R and first year
burden/subsequent year burden (newly termed “first-time filer factor (FTFf)”) characterize the
relationships between these estimates, regardless of the magnitude of the values used in the
composite Form unit burdens. As seen by comparing Table A-1 and A-3, the OMB-approved
numbers are higher than the Abt Associates Engineering Studies numbers. 3 These differences in
absolute magnitude are not relevant to RBBM development of ratio models for the purpose of
2

This equation uses standard matrix notation where i refers to the row of the matrix and j refers to the column.
Differences are due to differences in origin: EPA OMB-approved estimates were defined at program inception
(with periodic revisions), while Abt Associates’ Engineering Study estimates were generated more than a decade
after program inception.

4/28/11
A-6

Appendix A
providing internal consistency. Specifically, the Abt Associates Engineering estimates are used
on a relative basis only, for building ratio models. Moreover, EPA concludes that the Abt
Associates Engineering estimates are appropriate for RBBM’s ratio models because they most
reliably quantify the relative burdens of various tasks making them useful for quantifying
relationships between key variables. As an added benefit, EPA’s use of the Abt Associates
Engineering estimates provides a means by which A/R and other models may be verified. 4 At
another level, the Abt Associates Engineering estimates inform updates to the Nominal Form R
unit burden which are internally consistent with the Form unit burden, based on Standardized
Form Element Burdens (see more information later in this appendix and also in Appendix C).
Several models were specified using the Abt Associates Engineering Studies Form R non-PBT
estimates presented in Table A-4. For clarification purposes, Table A-5 presents unit burden
components as a percent of total Form R unit burden. This format provides information about
activity-based components of unit burden on a percentage basis, regardless of the value of Form
R Nominal unit burden.

Table A-5: Ratio-Based Burden Methodology Components, Standardized to Form R Basis
Ratio-Based Burden Methodology
,
Unit Burdens
Consistent per Chemical Scale
100%=Form R Unit Burden
Derived
Form A*
%

Form R
%

Activity
Subsequent year
(Steady State)

Nominal Form R(non-PBT )

Ratio Model Bases

Facility Burden
Apportioned to
Form R

Rule Familiarization

R, A Chemical

Compliance Determination

Form R

Calculations and Form Completion
Recordkeeping
Form Burden Per Chemical Total
Percentage of Form R Unit Burden

R, A Chemical

2.58

2.93

57.49

18.64

39.93

100.00

61.50

In the A/R ratio model, EPA ensures that Form A unit burden is related to Form R unit burden
via the subset of tasks and data elements from Form R that are similarly required to complete
Form A. Using the values in Table A-4, and the relevant elements of Matrix System F′′ * N′, the
A/R ratio model is computed at .615 as follows:

See also discussions in Appendix B regarding benefits of ratio models and strengths/weaknesses of Abt Associates
Engineering Studies.

4/28/11
A-7

Appendix A
Eqn. A-4: A/R = (Sum of Form A Factors (as derived from Form R) / Sum of Form R Factors)
=

((FNPBT,sYR,RF,T +FNPBT,sYR,CD,T )/Acpfe )+FNPBT,sYR,CFC*,T +FNPBT,sYR,REC,T
----------------------------------------------------------------------------------------------------------------------------------

((FNPBT,sYR,RF,T +FNPBT,sYR,CD,T )/Rcpfe )+FNPBT,sYR,CFC,T +FNPBT,sYR,REC,T

Notes
1
2
3
4
5

Facility level factors are converted to Form level factors using Acpfe and Rcpfe
T subscript refers to managerial plus technical plus clerical labor
Acpfe refers to Equivalent Form A Chemicals per Facility (see Appendix B Supplement)
Rcpfe refers to Equivalent Form R Chemicals per Facility (see Appendix B Supplement)
CFC* refers to the Form A factor, as derived from Form R factor components; these burdens include
Form A eligibility determination with half of Form R’s Section 5 and 6 work plus all the tasks associated
with Form R elements that also occupy Form A

The A/R value of .615 has the following interpretation: “the burden of a Form A as 61.5% of the
burden of a Form R, implying that filing a Form A instead of a Form R yields a 38.5% burden
reduction per chemical.”
Transitioning to the New System
The final system of models calculates total burden as follows:
Eqn. A-5: 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 model of single-chemical Form A unit burden to Form R unit
burden 5
Nominal Form
R unit burden= Single base number for the entire methodology; provides the focal point
for assessing and maintaining estimate accuracy
To establish the starting point for RBBM that would provide a seamless transition to the new
methodology, EPA estimated the nominal Form unit burden that would not produce a change in
the Steady State Total Burden estimate. The back calculation yields a Nominal Form R unit
burden of 35.7 hours/Form R: 6
5

For purposes modeling, EPA refers to “Form R chemicals” and “Form A chemicals” in order to provide a
consistent metric across form types. In practice Form R reports contain one chemical per report and Form A allows
multiple chemicals (2.3 on average).
6
EPA defines the methodology revision’s transition point as the time of the last ICR approval with conditions
specified by 2008 ICR renewal projections. In the actual calculation EPA corrects for previous double-counting of
facility level burden among facilities filing both As and Rs in the last ICR renewal, shifting the baseline downward
slightly by 5460 hours (removes .13% overstatement). Non-Form Burden amounts are: Supplier Notification—

4/28/11
A-8

Appendix A
Eqn. A-6: Nominal Form R Unit Burden =
(Total Burden – Non-Form burden)/[# Form R Chemicals + ((A/R)* # Form A Chemicals)]
Form Element Estimation
Form Element Estimation provides a standardized and reproducible method for estimating
updates to unit burden associated with form changes, replacing the case-by-case engineering
approach used in the existing method. The model consists of Standardized Form Element
Burdens, organized by “type” of element. The generalized format for using this method is:
Egn. A-7: Nominal Form R unit burdennew
= Nominal Form R unit burdenold + Form change burden
Where:
Form change
burden=

estimate based on conditions of the form change, utilizing Standardized
Form Element Burdens

Form element estimation is applicable any time changes to the reporting Form R, and by
association, corresponding elements of the Form A, are involved. Changes to the reporting form
can occur at ICR renewal and during rulemakings. Such changes impact the Nominal Form R
unit burden. This method differs from the rest of RBBM’s burden estimation methods because
its specifications are tied to the magnitude of the Nominal Form R unit burden.
Figure A-2 at the end of this Appendix depicts the Standardized Form Element Burdens, as
mapped onto an RY 2009 Form R. See Appendix C for further details including a list of
Standardized Form Element Burdens by type of element, as well as related procedures for
updating the Nominal Form R unit burden.
First-Time Filer Estimation
First-time filer burden, referred to as first year burden in the existing methodology, historically
has two applications. First-time filer burden is estimated as part of the total Program burden
estimate in ICR renewals to account for the portion of the reporting community with new
entrants. The estimate of first-time filers is made by determining the number of facilities newly
reporting to TRI in the year the ICR is updated. The number of new TRI reporters serves as an
approximation for the number of new filers expected in any reporting year during the period
covered by the ICR renewal. In the revised RBBM formulation, the impact of additional firsttime reporter burden is neglected in the (newly termed) Steady State Total Burden Calculation.
In rulemakings, first-time filer burden is estimated to account for the start-up effect of a policy or
regulatory change to the TRI reporting requirements—for example, when a new sector is added
to the reporting community. In this example, during the year that to policy change is first
implemented, the new reporters incur start-up burden which then reduces to steady state burden
89,616 hours; Non-Reporters Compliance Determination—734,976 hours; and Petitions—925 hours (see
Appendix B for further explanation)

4/28/11
A-9

Appendix A
in the next year. In the case of EAs, the first-time filer burden includes both the burden to
facilities reporting to TRI for the first-time as well as the burden to existing filers in the first year
of a policy or regulatory change. Under RBBM, EAs still typically report both steady state and
first-time filer incremental burdens/costs associated with the new policy or regulation. For these
estimates, only Form burden is relevant. 7 Given the overarching estimation method (Eqn. A-11),
the first-time filer factor (FTFf) is derived below.
Eqn. A-8 First-Time Filer Burden = FTFf * Relevant Steady State Total Burden
Similar to the A/R model, the FTF model provides a consistent basis to estimate the first year
burden relative to steady state burden for both Form R and Form A. It is developed using the
ratio of Form R factors for the first year to Form R factors for subsequent years. Using the
values in Table A-4 and the relevant factors from Matrix System F′ * N, the first-time filer
factor, FTFf , for RBBM is computed at 2.1 as follows:
Eqn. A-9: FTFf =
((FNPBT,fYR,RF,T +FNPBT,fYR,CD,T )/Rcpfe )+FNPBT,fYR,CFC,T +FNPBT,fYR,REC,T
------------------------------------------------------------------------------------------------------------------------------

Notes
1
2
3

((FNPBT,sYR,RF,T +FNPBT,sYR,CD,T )/Rcpfe )+FNPBT,sYR,CFC,T +FNPBT,sYR,REC,T
Facility level factors are converted to Form level factors.
T subscript refers to managerial plus technical plus clerical labor.
Rcpfe refers to Equivalent Form R Chemicals per Facility (see Appendix B Supplement).

The FTFf of 2.1 has the following interpretation: “for any comparison of first-time filer to
ongoing filer burden, the elevated startup effort is roughly twice the normal ongoing burden.”
Cost Conversion
The Cost Conversion method involves developing a universal WAWR that incorporates fixed
proportions of Managerial, Technical and Clerical labor categories at values of .03, .89. and .08
respectively and can be applied to Form R burden, Form A burden and Steady State Total
Burdens. Similar to the burden estimate in Eqn A-3, for the cost estimate, the matrix calculation
is reduced to the following weighted average unit cost per Form times the number of Forms: 8
NR *(F′′ * $)
Matrix System NR *(F′′ * $)
FNPBT,sYR,RF,m
NR *
Rcpf
FNPBT,sYR,CD,m
Rcpfe
FNPBT,sYR,CFC,m

FNPBT,sYR,RF,t
Rcpfe
FNPBT,sYR,CD,t
Rcpfe
FNPBT,sYR,CFC,t

FNPBT,sYR,RF,c
Rcpfe
FNPBT,sYR,CD,c
Rcpfe
FNPBT,sYR,CFC,c

FNPBT,sYR,REC,m

FNPBT,sYR,REC,t

FNPBT,sYR,REC,c

$/hr
managerial

$/hr
technical

$/hr
clerical

EA’s report incremental burden associated with proposed changes; since non-Form burden components are
constant, they do not vary with changes in forms, yielding a zero effect in this context.
8
The existing method has been modified for ease of presentation. In practice, no devisor is used but rather, facility
burden is multiplied by the number of facilities and form burden is multiplied by the number of forms. Total facility
and form burden are then summed to equal total burden reported by Form R.

4/28/11
A-10

Appendix A
4

Eqn. A-10: Form R Costs = ((NR ∑ (
i =1

∑

F′′i,j ﴿* $j )﴿

j =1

Rearranging this equation to a Weighted Average Wage Rate (WAWR in current $/hr) from which
hours can be readily converted to cost (for Form R related burden) yields:
Eqn. A- 11: Form R Costs = Form R Burden * WAWR
Generalizing to the overall equation:
Eqn. A-12: Steady State Total Cost = Steady State Total Burden * WAWR
Intuitively, one would state this equation as follows: “the total steady state cost estimate is the
product of total burden times the weighted average $/hr labor rate.” The current WAWR (June
2010) 9 of $49.62/hour has the following interpretation: “for every hour of incremental burden
increased or decreased, the associated cost, on average, is $49.69 per hour.” WAWR provides a
universal conversion factor for all TRI key burden estimates, including Form R burden, Form A
burden, and Steady State Total Burden.
Methodology Decision Rules Summary
This appendix presented the conceptual bases for the new RBBM, including the generalized
steps by which the existing methodology’s system was restructured and simplified. In the
process of restructuring and simplifying, certain key development decision rules (summarized in
main report, p. 10) were established, including:
•

•
•

•

Rule 1: Derive Form A burden from Form R burden using estimates of burden by activity
—This decision rule, used in the A/R model, ensures transparency and internal
consistency by using the subset of tasks from Form R reporting that similarly apply to
Form A reporting.
Rule 2: Use Form R basis where additional complexity for Form A basis is unmerited—
This decision rule, used in the FTFf and WAWR models, provides universal models across
Form A, Form R, and total burdens.
Rule 3: Make simplifying assumptions where they are mathematically justified—This
decision rule is used in the A/R model in the context of the decision to exclude first-time
filer effects from models from the Steady State Burden Calculation. The rule is also used
in applying the WAWR universally across Form R, Form A, and total burden estimates.
Rule 4: Make simplifying assumptions where a distinction is not backed up by
quantitative and/or statistical evidence (especially when the need for evidence is
expressed by stakeholders)—This decision rule was used to set the value of the ratio
model for PBT/non-PBT burden equal to one.
Rule 5: When scaling from form element estimates to Nominal Form R unit burden, scale
elements equally, in proportion to their contributions to the total—This decision rule was
used in developing Standardized Form Element Burdens.

Wage data source: http://www.bls.gov/ncs/ect/#tables

4/28/11
A-11

Appendix A
•

Rule 6: Back-calculate the Form R unit burden in order to maintain the established
baseline’s total burden—This decision rule was used to set the starting value for Nominal
Form unit burden.

Appendices B-E present method development, including detailed analyses used to formulate and
refine distinct pieces of the overall methodology. These appendices, organized by each of the
constituent methods, comprehensively detail models and computational procedures of the
methodology. Additionally, key analytical decisions are discussed with assumptions validated
using empirical evidence where possible.

4/28/11
A-12

Appendix A
Figure A-2: Standardized Data Element Time Estimates Scaled to 35.7 Hours
Form Approved OMB Number: 2070-0093
Approval Expires: 03/31/2011Page 1 of 5
TRI Facility ID Number

(IMPORTANT: Type or print; read instructions before completing form)

FORM R

EPA

Section 313 of the Emergency Planning and
Community Right-to-Know Act of 1986, also
Known as Title III of the Superfund
Amend ments and Reauthorization Act

United States
Environmental Protection Agency

WHERE TO SEND COMPLETED FORMS:

This section only applies if you are revising or
withdrawing a previously submitted form,
otherwise leave bank.

TRI Data Processing
Center
P. O. Box 1513

Revision (enter up to two codes(s))

Toxic Chemical, Category or Generic Name

APPROPRIATE STATE OFFICE
(See instruction in Appendix E)
Withdrawal (enter up to two code(s))

IMPORTANT: See instructions to determine when “Not Applicable (NA)” boxes should be checked.
PART 1. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
Are you claiming the toxic chemical identified on page 2 trade secret?
0.006 hours
2.1
Yes (Answer question 2.2;
No (Do not answer
Attach substantiation forms)
question 2.2;
Go to Section 3)
SECTION 3. CERTIFICATION

0.006 hours

Is this copy Sanitized
Unsanitized
2.2
Answer only if “YES” in 2.1
0.006 hours

(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 Signed:

SECTION 4. FACILITY IDENTIFICATION
Facility or Establishment Name
0.002 hours

TRI Facility ID Number 0.002
hours
Facility or Establishment Name or Mailing Address (If different from street
address) 0.002 hours

Street 0.002 hours

Mailing Address 0.002 hours

City/County/State/Zip Code 0.002 hours

4.1

4.2
4.3

This report contains information for:

Country (Non-US) 0.002 hours

0.006 hours

(Important: Check c or d if applicable) a. an entire facility b. Part of a facility c. a Federal facility d. GOCO
Technical Contact Name
0.002 hours
Telephone Number (include area code)
0.002 hours
Email Address
0.002 hours

4.4

Public Contact Name
Email Address

4.5

NAICS Code(s)

4.6

Dun & Bradstreet
Number (s) (9 digits)

Telephone Number (include area code)
0.002 hours

0.002 hours
0.002 hours
Primary
a.0.002 hours b.

a. 0.002 hours
b.

SECTION 5. PARENT COMPANY INFORMATION
5.1

Name of Parent Company

5.2

Parent Company’s Dun & Bradstreet Number

0.002 hours
NA

0.002 hours

EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete.

4/28/11
A-13

Appendix A
(IMPORTANT: Type or print; read instructions before completing form)

Form Approved OMB Number: 2070-0093
Approval Expires: 03/31/2011 Page 2 of 5

TRI Facility ID Number

FORM R

Toxic Chemical, Category or
Generic Name

PART II. TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM

SECTION 1. TOXIC CHEMICAL IDENTITY
1.1
1.2

1.3

(Important: DO NOT complete this section if you completed Section 2 below.)

CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical
0.002 hours
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
0.002 hours
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked “yes”. Generic Name must be structurally descriptive.)
0.002 hours

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

0.002 hours

SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check all that apply.)

3.1

Manufacture the toxic chemical:
0.002 hours
a.
c.
d.
e.
f.

3.2

Produce b.
Import
If produce or import

For on-site use/processing

For sale/distribution

As a byproduct

As an impurity

Process the toxic chemical:
0.002 hours

Otherwise use the toxic chemical:
0.002 hours

3.3

As a reactant

As a formulation component

b.
As a
manufacturing aid

As an article component

Repackaging

As a chemical processing aid

Ancillary or other use

As an impurity

SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON SITEATANY TIME DURING THE CALENDAR YEAR
(Enter two digit code from instruction package.)
4.1
0.944 hours
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE

5.1

Fugitive or non-point
air emissions

5.2

Stack or point
air emissions

5.3

0.005 hours

NA
0.005 hours
Discharges to receiving streams or
water bodies (enter one name per box)

A. Total Release
(pounds/year*)
(Enter a range code** or estimate)

B. Basis of Estimate
(enter code)

3.264 hours

0.010 hours

1.879 hours

0.010 hours

1.881 hours

0.010 hours

C. % From Stormwater

Stream or Water Body Name
5.3.1

0.008 hours

0.416 hours

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. 01/2008) - 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.

4/28/11
A-14

Appendix A
Form Approved OMB Number: 2070-0093
Approval Expires: 03/31/2011 Page 3 of 5

(IMPORTANT: Type or print; read instructions before completing form)

TRI Facility ID Number

FORM R
PART II. CHEMICAL - SPECIFIC INFORMATION (CONTINUED)

Toxic Chemical, Category or Generic Name

SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ON SITE (continued)
NA

A. Total Release (pounds/year*)
(enter range code ** or estimate )

B. Basis of Estimate
(enter code)

Underground Injection onsite to Class I

0.005 hours

1.881 hours

0.010 hours

Underground Injection onsite

0.005 hours

1.881 hours

0.010 hours

0.005 hours
0.005 hours
0.005 hours

1.810 hours

0.010 hours

1.810 hours

0.010 hours

1.881 hours

0.010 hours

0.005 hours
0.005 hours
0.005 hours

1.810 hours

0.010 hours

1.810 hours

0.010 hours

1.810 hours

0.010 hours

5.4.1 Wells

5.4.2 to Class II-V Wells
5.5

Disposal to land onsite

5.5.1A RCRA Subtitle C landfills
5.5.1B Other landfills
Land treatment/application

5.5.2 farming

RCRA Subtitle C

5.5.3A surface impoundments
5.5.3B Other surface impoundments
5.5.4 Other disposal

SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1.A Total Quantity Transferred to POTWs and Basis of Estimate
6.1.A.1Total Transfers (pounds/year*)
6.1.A.2
(enter range code ** or estimate)
1.881 hours

0.010 hours
POTW Name

6.1.B______

0.008 hours
0.008 hours

POTW Address
City

Basis of Estimate
(enter code)

State 0.008 hours

0.008 hours

County 0.008 hours

Zip 0.008 hours

POTW Name

6.1.B______
POTW Address
City

State

County
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

Zip
(example: 1,2,3, etc.)

SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
6.2.______

Off-Site EPA Identification Number (RCRA ID No.)

0.008 hours

Off-Site Location Name 0.008 hours
Off-Site Address
City

0.008 hours

State

0.008 hours

EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete.

County

0.008 hours

Zip

0.008 hours

Country
(Non-US)

0.008
hours

* For Dioxin or Dioxin-like compounds, report in grams/year ** Range
Codes: A=1-10 pounds: B=1-499 pounds; C=500 - 999 pounds.

Yes

Is location under control of reporting facility or parent company?

0.008 hours

4/28/11
A-15

Appendix A
Form Approved OMB Number: 2070-0093
Approval Expires: 03/31/2011 Page 4 of 5

(IMPORTANT: Type or print; read instructions before completing form)

TRI Facility ID Number

FORM R

Toxic Chemical, Category or
Generic Name

PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (CONTINUED)
A. Total Transfers (pounds/year*)
(enter range code**or estimate)

B. Basis of Estimate
(enter code)

C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)

1. 1.810 hours

1. 0.010 hours

1 . M 0.010 hours

2.M

3.M

4.M

6.2______ Off-Site EPA Identification Number (RCRA ID No.)
Off-Site Location Name
Off-Site Address
City

State

County

Is location under control of reporting facility or parent company?
A. Total Transfers
(pounds/year*)
(enter range code**or estimate)

Country
(Non-US)

Zip
Yes

No
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter
code)

B. Basis of Estimate
(enter code)

1.
2.

1.M
2.M

3.
4.

3.M
4.M

SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY

Not Applicable (NA)Check here if no on-site waste treatment is applied to any
0.005 hourswaste stream containing the toxic chemical or chemical category

a. General
Waste Stream
[enter code]

d. Waste Treatment Efficiency
[enter 2 character code]

b. Waste Treatment Method(s) Sequence
[enter 3- or 4- character code(s)]
7A.1
3

1
4

7A.2a

6
7A.2
3

7
1
4

8
2
5

7A.3a

6
7A.3
3

7
1
4

8
2
5

7A.3d

7A.4a

6
7A.4
3

7
1
4

8
2
5

7A.4d

7A.5a

6
7A.5
3

7
1
4

8
2
5

7A.5d

7A.1a
0.162 hours

2
5

0.648 hours

7A.1d
0.416 hours
7A.2d

If additional pages of Part II, Section 6.2/7A are attached, indicate the total number of pages in this box .
and indicate the Part II, Section 6.2/7 page number in this box:
(example: 1,2,3,etc.)
EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete.
in grams/year

*For Dioxin or Dioxin-like compounds, report
**Range Codes: A=1 - 10 pounds; B=11 - 499 pounds
C= 500-999 pounds.

4/28/11
A-16

Appendix A
Form Approved OMB Number: 2070-0093
Approval Expires: 03/31/2011 Page 5 of 5

(IMPORTANT: Type or print; read instructions before completing form)

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
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)]
0.648 hours

Not Applicable (NA) – 0.005 hours
1

SECTION 7C. ON-SITE RECYCLING PROCESSES

Not Applicable (NA) – 0.005 hours

Check here if no on-site energy recovery is applied to any waste
stream containing the toxic chemical or chemical category.

Recycling Methods [enter 3-character code(s)]
1

0.648 hours
2

SECTION 8. SOURCE REDUCTION AND RECYLING ACT IVITIES
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
8.1a

Total on-site disposal to Class I
Underground InjectionWells, RCRA
Subtitle C landfills, and other landfills

0.009 hours

0.146 hours

0.030 hours

8.1b

Total other on-site disposal or other
releases

0.009 hours

0.146 hours

0.030 hours

Total off-site disposal to Class I
Underground Injection Wells, RCRA
Subtitle C landfills, and other landfills

0.009 hours

0.146 hours

0.030 hours

8.1d

Total other off-site disposal or other
releases

0.009 hours

0.146 hours

0.030 hours

8.2

Quantity used for energy recovery
onsite

0.009 hours

0.856 hours

0.030 hours

8.3

Quantity used for energy recovery
offsite

0.009 hours

0.146 hours

0.030 hours

8.4

Quantity recycled
onsite

0.009 hours

0.856 hours

0.030 hours

8.5

Quantity recycled offsite

0.009 hours

0.146 hours

0.030 hours

8.6

Quantity treated onsite

0.009 hours

0.856 hours

0.030 hours

8.7

Quantity treated offsite

0.009 hours

0.146 hours

0.030 hours

8.1c

8.8
8.9
8.10

Quantity released to the environment as a result of remedial actions, catastrophic events,
or one-time events not associated with production processes (pounds/year)*
0.944 hours
Production ratio or activity index

0.146 hours

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.
Source Reduction Activities
[enter code(s)]

Methods to Identify Activity (enter codes)

8.10.1 0.648 hours

a. 0.010 hours

8.10.2
8.10.3

a.
a.
a.

b.
b.
b.

c.
c.
c.

8.10.4
8.11

If you wish to submit additional optional information on source reduction, recycling, or pollution
control activities, check “Yes.”
EPA Form 9350 -1 (Rev. 01/2008) - Previous editions are obsolete.
in grams/year

Yes

0.000 hours
*For Dioxin or Dioxin-like compounds, report

*Range Codes: A=1 - 10 pounds; B=11 - 499 pounds C=
500-999 pound

4/28/11
A-17

Appendix A

4/28/11
A-18

Appendix B
Steady State Total Burden Calculation
This appendix presents and justifies the primary method of Ratio-Based Burden Methodology
(RBBM)—the Steady State Total Burden Calculation, including details of its development.
As stated earlier, Steady State Total Burden is the estimate of the ongoing TRI Program burden,
as updated by rulemakings’ permanent impacts, but absent any first-time filer impacts. Recall
from (Eqn. A- 5) of Appendix A: 1, 2, 3
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 model of single-chemical Form A unit burden to Form R unit
burden

Nominal Form
R Unit
Burden=

Single base number for the entire methodology; provides the focal point
for assessing and maintaining estimate accuracy

The components of this method include Form burden (A/R model and Nominal Form R unit
burden) and non-Form burden (petitions, supplier notification, and non-reporter compliance
determination). An important note about this method is the way its components support the
overarching methodology priorities of simplicity, internal consistency, and transitional baseline
continuity. The A/R model ensures internal consistency between Form R and Form A unit
burdens, and ultimately between total burdens for Form R and Form A chemicals. The Nominal
Form R unit burden is computed with two purposes in mind: to provide a seamless transition
from old to new methodology and to serve as the one point for adjustments and updates.
The first section of this appendix presents the existing system’s relevant characteristics and
explains why the new structure was chosen. This section is followed by a series of discussions on
method development for several models. These discussions include, as part of the relevant A/R
model specifications, the substantive simplifications including: 1) neglect the effects of first-time
filers in steady state burden estimates, and 2) set the value of PBT/non-PBT model equal to one.
1

This model also applies to estimates of incremental burden associated with a proposed policy or regulatory change.
In that case, the number of forms in the equation would represent the incremental number of forms associated with
the proposed change.
2
Note that the method’s formulation incorporates simplifications: a) Neglect the effect of first-time filers in the
steady state, and b) set the ratio model for PBT to non-PBT burden equal to one.
3
For purposes of modeling, EPA refers to “Form R Chemicals” and “Form A Chemicals” in order to provide a
consistent metric across form types. In practice Form R reports contain one chemical per report and Form A allows
multiple chemicals (2.3 on average).

4/28/11
B-1

Appendix B
Additionally, the details for specifying non-Form burden and for back calculating Nominal Form
R unit burden are provided.
This appendix does not address burden estimation associated with new Form elements, or related
procedures for updating Nominal Form R unit Burden, as these topics are covered as a separate
method in Appendix C. Similarly, as first-time filers are not included in RBBM’s formulation of
the Steady State Total Burden Calculation; that estimation, for calculating first-time effects in
rulemakings, is covered as a separate method in Appendix D.
Changes to an Existing System: Adding Simplicity and Internal Consistency
Two aspects of the existing methodology focused RBBM’s design. It was overly complex and it
lacked internal consistency (see discussion in this document’s main report). In order to provide
internal consistency, EPA redesigned the Steady State Burden Calculation to incorporate ratio
models (discussed in next section). In order to simplify, EPA developed the Steady State Burden
Calculation which requires a minimum number of variables (discussed further here).
The overarching simplification in RBBM is to algebraically reduce a complex matrix system, as
described in Appendix A. As an essential step in that simplification, EPA re-scaled facility-level
factors to (per chemical) form-level factors. EPA derived Equivalent Form R/A Chemicals per
Facility based on the distributions of Form R and Form A chemicals within and across facilities
(see Appendix B Supplement – Distribution Analysis for details). In addition to providing
simplification, the re-scaled factors prevent double-counting facility-level burden.
Under the existing methodology, double-counting potential occurs in two variants. First, when
total Form A and Form R burdens are estimated, both estimates count the burden for those
facilities filing both A and R chemicals. Second, when a new chemical is reported by a facility,
the incremental burden associated with the new chemical report does not discount for the fact
that the facility may already be filing other chemical forms. With RBBM, facility-level burden is
apportioned across (per chemical) form-level unit burdens, so that facility-level burden is now
accounted for on a “by chemicals” basis, with each chemical’s burden only counted once each.
As a secondary benefit of uniformly scaled factors, the RBBM form-level estimates are “fully
loaded” to incorporate all aspects of TRI reporting. For this reason, the resultant unit burdens
(Form R and the related Form A single-chemical) are comprehensive, preventing the need to
track multiple unit burdens for form and facility. Similarly, the Standardized Form Element
Burdens contain incremental elemental estimates that similarly incorporate all associated burden
(discussed in Appendix C).
As another essential step in the overarching simplification of algebraic reduction, EPA imposed
substantive simplifications to the Steady State Total Burden Calculation by: 1) neglecting the
effects of first-time filers in steady state burden estimates, and 2) setting the PBT/non-PBT
model’s ratio value equal to one. The first simplification is justified mathematically, as treating
the relevant 3% of TRI chemical reports as steady state filers instead of first-time filers decreases

4/28/11
B-2

Appendix B
the total steady state burden by .04%. 4 The second simplification is justified due to the absence
of an evidence-based verifiable alternative (see discussion section on the PBT/non-PBT model).
These simplifications, as adjustments to the overall burden calculation, improve the methodology
in two ways. First, they keep the equation simple. Had these simplifications not been made, the
Calculation would have required tracking subpopulations of PBT chemical filers and first-time
filers, making the method more complex. As it now stands, only two input variables are
required—number of Form R chemicals and number of Form A chemicals. A second benefit
from these simplifications is the sophistication of a single unit burden for Nominal Form R unit
burden with Form A reporting burden closely linked (see further discussion in Justification:
Back-Calculated Nominal Unit Burden).
Moving from Implicit to Explicit Ratios
Table B-1 provides the unit burdens and effective ratios embedded in the existing system. As
described in the main report, the A/R is .64 across PBT and non-PBT chemicals. Similarly, the
ratio for PBT/non-PBT is 1.73 across Form R and Form A chemicals.
Table B-1: Summary of Form-Based Unit Burdens from Existing Methodology
Subsequent Year Burden Hours per Single Chemical Form*
A/R=.64; PBT/non-PBT=1.73
Non-PBT
PBT
Form R
29.66
51.34
Form A
20.52
35.89 (no longer valid as PBTs
may not be reported on Form A)
(single chemical)**
*excludes facility-level burden for compliance determination
**single chemical Form A is used in unit burden comparisons, although multiple chemicals may be
reported on Form A (about 2.3 on average)
Source: Toxics Release Inventory TRI Form R Toxic Chemical Release Reporting Information Collection
Request Supporting Statement OMB Control Number 2070-0093 EPA ICR #1363.15. December 10, 2007.

In the case of A/R, the current ratio of .64 for Form A to R burden 5 is very close to RBBM’s
value of .615. However, with the Form A to Form R burden very different from the ratio of form
pages of .25, the ratio value needed to be more readily verifiable. Upon inspection, EPA
concluded that the reason for the apparently high ratio is due to labor-intensive calculations
required to determine Form A eligibility that are made regardless of final decision on Form type.
Using RBBM, the detailed estimates of the Abt Associates Engineering Studies substantiate this
finding with A/R burden estimated at .615. RBBM estimates Form A burden based on detailed

Based on 2008 ICR (RY 2007) chemical counts and models, see Findings under A/R Model in this Appendix.
For details and context for the A/R value of .64, see: Rice, Cody. 2004. Terms of Clearance for TRI ICR Renewal.
Regulations.gov. Accessed 23 Dec 2010 Additional references include: 1) the Regulatory Impact Analysis of the EPCRA Section 313 Alternate
Threshold Final Rule, Regulatory Impacts Branch, Economics, Exposure and Technology Division, Office of
Pollution Prevention and Toxics, US Environmental Protection Agency, November 18, 1994 and 2) memo from
Cody Rice (USEPA/OEI) to Amy Newman (USEPA/OEI) re: Terms of Clearance for TRI ICR Renewal, January
20, 2004. Sources used to derive the .64 figure included 1) the original TRI Regulatory Impact Analysis, 2) the
Pollution Prevention Act EA for the proposed rule from 1991, and 3) the 1/20/2004 Terms of Clearance Memo.
5

4/28/11
B-3

Appendix B
analysis of common tasks between Form A and Form R. 6 The RBBM approach to the A/R model
ensures internal consistency and provides verifiable unit burdens, thereby increasing
transparency.
Regarding the ratio of PBT/non-PBT burden, the existing system’s ratio unintentionally resulted
from discussions aimed at lowering totals with the decision to make a downward adjustment to
non-PBT unit burden, while holding PBT unit burden constant. 7 Under these circumstances, the
resultant ratio of 1.73 occurred as an offshoot of the revision process, rather than as a deliberate
specification. This value of 1.73 is very different than the “null” assumption of 1.0, leaving the
basis vulnerable to questions such as: Given the rationale that PBT chemical reporters incur
greater burden because they cannot use the de minimis exemption, how much greater should the
ratio be? How should the ratio be determined? Is there sufficient evidence to support the 73%
difference? Ideally, quantitative evidence obtained via representative sampling would provide
information on overall average conditions for TRI reporters. Regarding RBBM’s PBT/non-PBT
ratio model, EPA sought to specify a ratio value in a manner that would produce internally
consistent and verifiable unit burdens. 8
Justification: Ratio Models with Engineered Building Blocks
As the name implies, ratio models are central to RBBM’s design. As often as possible, EPA
formulates ratio models in order to characterize key relationships around which it wants to
ensure internal consistency. In this appendix, EPA uses A/R and PBT/non-PBT models; see also
Standardized Form Element Burdens, FTF, and WAWR models. The ratio structure has a number
of advantages:
• Ratios, as a type of measure, possess an absolute zero requiring less maintenance than
measures of the components separately.
• Ratio models themselves have intrinsic value, providing useful standalone metrics as they
quantify key relationships between two elements.
• Ratio models are inherently more stable and therefore more robust to changes than their
component variables.
Moreover, RBBM’s ratio models provide assurances that unit burdens are internally consistent
and verifiable because:
• Ratio models specify internal relationships.
• The bases for the ratio models (A/R, FTF, WAWR) are quantitatively derived.

Note that the burden required to determine eligibility to use Form A (as described here) is not the same as the
burden required to determine whether or not the Section 313 reporting requirements apply to a facility in general.
Form A eligibility is based on whether, on a per chemical basis, a facility has less than 500 lbs of total annual
reportable amount and that amounts manufactured, processed or otherwise used do not exceed one million lbs.
7
For details, Rice, Cody. 2004. Terms of Clearance for TRI ICR Renewal. Regulations.gov. Accessed 23 Dec 2010
.
8
Ultimately, in RBBM the PBT/non-Pbt value is specified as one. Note, however, that the higher PBT reporting
burden from the existing methodology is incorporated into RBBM’s Nominal Form R unit burden’s starting value of
35.7 hours/Form R. See discussion in Justification: Back-Calculated Nominal Unit Burden section.

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Appendix B
Regarding the robustness, RBBM’s ratio models are robust due to the inherent stability of
relationships that they characterize, as well as stability of related assumptions. For example, in
the technology advances by which reporting shifted from primarily paper to electronic
submission, the relationship between Form A burden and Form R burden remained largely
unchanged and of the same ratio, while the magnitude of total reporting burden was estimated to
decrease. This ratio remains stable because the changes to Form R and Form A impose similarly
small incremental burden changes to both the numerator and the denominator of the ratio, thus
causing the ratio itself to remain roughly constant. Note, however, that in the event that the Form
R and/or Form A undergo extreme revisions that alter the relationship between A/R burden, then
the A/R model would require updating.
EPA developed RBBM’s ratio models based on existing work and best available information.
Detailed burden estimates from the Abt Associates Engineering Studies are employed as
computational components of RBBM ratio models (see Appendix G for these studies). In these
studies, Abt Associates provided expertise for each study using a team of three staff with nearly
40 years of combined experience working with facilities on environmental issues. These staff
members had worked with hundreds of facilities on TRI reporting and other environmental
requirements. They had conducted inspections and provided technical assistance, served as TRI
trainers, conducted technical review on hundreds of TRI data withdrawal requests, conducted
hundreds of TRI data quality calls, worked for two of the Massachusetts Toxics Use Reduction
Act agencies, and worked as environmental staff at large manufacturing facilities. In short, the
authors have a thorough understanding of what is required in reporting, especially with regard to
the relative burden associated with each task in relation to others. The authors’ knowledge base
was tapped to evaluate burden consistently across reporting activities and develop a systematic
set of burden estimates.
The Abt Associates Engineering Studies themselves provide estimates of burden by activity,
with the “calculation and Form completion” activity broken down to element-by-element
estimates. This means that for each element of a Form R, the authors evaluated the
calculations/tasks involved and estimated burden. Moreover, within the Form R, the authors
assessed how frequently a response was provided for each element, and adjusted the element
burden by incidence weights. 9
Given the strengths of internal validity and internal consistency, the Abt Associates Engineering
Estimates are used as building blocks for ratio models in RBBM. Additionally, since these
estimates were derived after the TRI program underwent numerous technology advances, EPA
concludes that, on a relative basis, these estimates reflect updated and more current conditions
than those made at TRI program inception. EPA recognizes that the information from the Abt
Associates Engineering Studies drew from a non-representative sample of TRI reporters 10 , and
consequently uses the estimates to develop ratio models of relative relationships but not for
absolute measures (e.g. Form R compliance determination). Additionally, use of the Abt
Engineering estimates provides a means by which A/R and other models may be verified. For
9

The incidence rate was calculated using the frozen RY 2002 TRI data. All but one method of the RBBM use this
version of unit burdens (in models A/R, FTF, WAWR). The exception is the set of Form Element Burden Estimates,
for reasons described in Appendix C.
10
Note that this weakness does not pose problems in the context of designing ratio models reflecting relative
relationships; it is more problematic when revising absolute values for unit burdens.

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B-5

Appendix B
justifications of the values assigned to the specific ratios see detailed sections on the ratio models
themselves in this and other appendices.
Justification: Back-Calculated Nominal Unit Burden
RBBM’s base unit burden, Nominal Form R unit burden is a base number for the entire
methodology. Due to the simplifications described above, it provides a comprehensive single
focal point for discussions about methodology accuracy. For routine adjustments, such as Form
R revisions, estimates for increases or decreases in burden associated with the particular form
changes are applied to the Nominal Form R unit burden, with related changes automatically
propagated through the RBBM system via ratio models (e.g., to Form A, and for first-time
filers). As an additional RBBM feature, with the ratio models addressing key internal
relationships, Nominal Form R unit burden reflects overall average conditions for all remaining
unspecified effects, removing the need to revise the methodology by adding variables. 11
EPA considered the question: How should the value of the base unit burden be set? From the Abt
Associates Engineering Studies, one could ask, why not just sum up the Form R element-byelement estimates to set the value for the Form R unit burden of 7.06 hours? Instead, RBBM sets
the base unit burden based on the back-calculated number—35.7 hours per Form R—that
preserves the same total burden, assuming constant levels of Form R and Form A chemical
counts.
In managing the transition to RBBM, EPA placed priority on ensuring transitional baseline
continuity. This requirement preserves the baseline of total burden at its existing level, with
RBBM estimates starting at the point from which prior estimates left off. Note that EPA defines
the methodology revision’s transition point as the time of the last ICR approval. 12 Thereafter
updates are to be made according to RBBM, either via wholesale changes to the Nominal Form
R unit burden, or by making incremental changes to it using Standardized Form Element
Burdens. Given the simplified Steady State Total Burden Calculation, with the A/R key
relationship modeled and the total burden fixed, the only variable left unspecified is the base unit
burden. The resultant back-calculated value is 35.7 hours, and the variable is termed Nominal
Form R unit burden.
EPA refers to the back-calculated number as the Nominal Form R unit burden because it is a
base number without exact derivation from rigorous modeling. Mathematically, it represents the
Form R, non-PBT, subsequent year unit burden. In practice it serves as a proxy for overall
average conditions for all Form R’s (with Form A burden closely linked at 61.5% of that unit
burden). As noted above in the previous discussions on overarching simplifications, this unit
burden incorporates facility-level burdens, comprehensively reflecting all aspects of relevant TRI
reporting. 13
11

In this Appendix, the discussion has mainly focused on the PBT/non-PBT and first-time filer effects because they
were part of the previous methodology. The broader argument stated here applies to other unmodeled effects, such
as ongoing staff turnover.
12
Based on 2007 projections, see TRI 2008 ICR Supporting Statement.
13
Note also that Standardized Burden Element Burdens (See Appendix C), used to update the Nominal Form R unit
burden in the event of form changes, are also comprehensive (i.e.,“fully loaded”) and internally consistent with the
base unit burden.

4/28/11
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Appendix B
As a reflection of overall average Form R unit burden, RBBM’s Nominal Form R unit burden
carries forward certain prior assumptions from the existing methodology without explicitly
modeling them. In particular, note that the higher PBT reporting burden for 20% of Form Rs is
incorporated into the Nominal Form R unit burden’s starting value of 35.7 hours/Form R, which
is elevated above the value that would have been otherwise obtained—at about 30 hours/form—
had only non-PBT burden been used to determine Nominal Form R unit burden. 14
EPA supports this value of 35.7 hours per Form R as a reasonable approximation of the actual
unit burden, based on years of review and scrutiny to which the current total burden estimate has
been subjected. The unit burden of 35.7 hours, in the context of a new system of ratio models, is
the culmination of prior accuracy assessments, including a 49% decrease to the baseline in the
2004 ICR Renewal. 15 Therefore, this basis is legitimized for ultimately setting the magnitude of
the Program total burden at this time.
Method Development
In this section, EPA describes the development work and model-specific justifications for the
key components for the Steady State Total Burden Calculation. The section covers models for
Form Burden and constants for non-Form Burden. The back-calculated unit burden is presented
last, because it is specified last.
PBT/Non-PBT Model
The PBT/non-PBT model specifies unit burden for PBT chemicals with respect to non-PBT
chemicals. In this methodology, the value of this ratio is set equal to one:
Ratio of Form R PBT Unit Burden to Form
R non-PBT Unit Burden

[=]

Hours per PBT Form R
Hours per non-PBT Form R

Unlike most analytical decisions in the revised methodology, the decision to set the PBT/nonPBT equal to one is based on the lack of evidence. It is an assertion of a null hypothesis out of
concern that the existing system’s specification of 1.73 is unverifiable and could produce internal
inconsistencies. EPA concludes that in the event that a reasonable person asks: Why would a
PBT chemical require 73% more burden, on average than a non-PBT chemical? EPA should

Note from Table B-1 that form-level burden is 29.66 hours per Form R chemical. Adding facility level burdens
totaling 4 hours per facility, and given that each reporting facility manages about 4 Form R chemicals, yields the
rough estimate of 30 hours per non-PBT Form R chemical.
15
As an overall 57% downward adjustment, the TRI Program burden estimate was decreased from 6.03 million to
2.61 million hours according to Notices of OMB Action (called Paperwork Reduction Submissions) for Form R ICR
and Form A ICR. Submitted October 27, 2003. Approved January 9, 2004. Based on the TRI 2004 ICR Supporting
Statements, there were four sources (with relative contributions): 1) reducing non-PBT subsequent year burden from
47.1 to 14.5 hours (85.95%), 2) correcting the previous ICR due to Lead Rule implementation (6.37%), 3) changes
to actual reporting from previous ICR (.24%) and 3) a one-time adjustment for TRI-ME (7.44%). This yields a 49%
decrease in total burden associated with the methodology change from the first source.

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Appendix B
have a concrete, evidence-based response. In the absence of such quantitative evidence, the
fallback position was chosen.
This question has been extensively debated. On one side, public comments from industry express
concern about additional burden due to additional demands related to PBT reporting
requirements. One the other side, Abt Associates Engineering Studies find no substantial bases
for differences. Table B-3 provides the arguments on both sides. Regardless of credibility on
either side, both of which are compelling, neither position offers strong evidence of the most
likely average relationship representative of the TRI reporting population. EPA concludes that
the ratio of PBT to non-PBT reporting burden cannot be determined analytically using the
readily available information.
As an important qualifier, even though the ratio value for the model for PBT/non-PBT is set
equal to one, the overall Steady State Burden Calculation carries forward the elevated level of
burden related to the prior assumptions of higher PBT unit burden from the existing
methodology while not explicitly modeling the effect (see discussion earlier, under Justification:
Back-Calculated Nominal Unit Burden).
Table B-3: PBT Chemical Reporting Burden relative to non-PBT Chemicals
Industry Comments
Abt Associates Engineering Studies
SUMMARY
SUMMARY
Special conditions of PBT reporting, including Activities required for reporting PBT and nonno de minimis exception and no range
PBT chemicals are similar enough that the
reporting create higher burden for PBT
same unit burden hour estimate should be used.
reporting.
PBT reporting requires additional research,
inquiries of suppliers not required to provide
notification of de minimis levels of PBT chemicals,
additional calculations for compliance
determinations, additional calculations for Form R
completion and recordkeeping (extra burden
associated with obtaining and managing the
relevant data).

1) It does not appear, however, that the lack of the
de minimis exemption will increase the burden
associated with making release estimates due to a
need to assess additional waste streams.
2) Also, not being able to use range reporting does
not actually increase the reporting burden for PBT
filers. Even though range reporting is allowed for
non-PBT chemicals in Part II, Sections 5 and 6 of
the Form R, it is not allowed for same data
elements in Part II, Section 8. As a result, no fewer
calculations are necessary to complete a Form R for
non-PBTs versus PBTs due to range reporting.

Requires facilities to report PBT chemicals to a
precision level of .1 lbs for lead or .0001 grams for
dioxins; large number of facilities reporting one
pound or less; median lead release for all reporters
is one pound.*
*Lead and Lead Compounds Form R reports constitute about 55% of PBT chemical reports (and PBTs constitute
about 20% of total TRI chemical reports)—measured by average percentages in period between 2004-2007 in
Frozen TRI data for RY 2007

4/28/11
B-8

Appendix B
Sources:
1) Industry comments drawn from comment documents in docket #OEI-2003-0025 for EPA ICR No. 1363.12 and
EPA ICR 1363.13;in docket # OEI-2004-0006 for EPA ICR 1363.14; and from docket # TRI-2007-0355, EPA
ICR 1363.15
Abt Associates Engineering Studies (provided in Appendix G) based on development of Realistic Burden Estimates
for Total Form R Completion (also see description of these models in this Appendix’s “Justification: Ratio Models
with Engineered Building Blocks”).This analysis was conducted separately for non-PBT and PBT chemicals

In conclusion, EPA recommends the value for the PBT/non-PBT model of 1.0 hr/hr.
A/R Model
Given the decision to set PBT/non-PBT equal to one, the next question to address in developing
the Steady State Total Burden Calculation is: how to set the A/R ratio value? The A/R model
specifies the unit burden for Form A as a function of its components common to Form R, defined
by:

Ratio of Form A Unit Burden to Form R
Unit Burden

[=]

Hours per Single-Chemical Form A
Hours per Form R

Computed using the factor matrices for Form R and Form A (as derived from Form R) 16
presented in Appendix A:
4

A/R = ( ∑
i =1

∑
j =1

[A factors from F′′i,j] / ( ∑
i =1

∑

[F′′i,j ]﴿

j =1

In A/R model building, EPA ensures internal consistency between Form A and Form R. When
specifying the set of Form R activities similarly applicable to Form A, the factor for calculations
and form completion is based on the burden involved in Form A eligibility determination
(including half of Form R’s Section 5 and 6 work) plus all the tasks associated with Form R
elements that also occupy Form A. This level of detail was provided via the rigor of the Abt
Associates Engineering Studies. See Appendix A’s Table A-4 for calculation results for A/R
components, according to Form R and Form A. Also see Table A-5 for a comparison of relative
contributions from the various activities across Forms.
The design of this model required the following steps: 17
1. Rescale facility-level factors to form-level factors.
2. Reduce the factor matrices to sums for each Form A and Form R.
3. Compute the ratio of Form A to Form R burden.
4. Verify simplifying assumptions.
16

Where i denotes the row and j denotes the column from the Matrix F′′ in Appendix A.
See Appendix A for an overview of the derivations and page 10 of the main report for an overview of the decision
rules.
17

4/28/11
B-9

Appendix B
5. Assess model robustness to shifts in distributions of Form R and Form A chemicals
within and across facilities.
The key analytical decisions for developing this model include:
1. Deriving Equivalent Form R/A Chemicals per Facility for use in rescaling facility-level
factors to (per chemical) form-level factors (covered in Appendix B Supplement).
2. Determining how to translate the burden estimates for Form elements in Form R to
corresponding estimates for Form A.
3. Where possible, confirming simplifying assumptions.
Testing the A/R Model
Table B-4 presents the results of the tests that support EPA’s analytical decisions to incorporate
distributional effects in rescaling, to neglect the effect of first-time filers, and to employ the most
rigorous version of Abt Associates’ estimates (incidence weighted engineering estimates).
Column (1) shows the reference case, which is the most complex model without any
simplifications. The reference case has the following attributes:
•
•
•

Incorporates first-time filer effects
Uses the most rigorous version of the Abt Associates Engineering Studies’ estimates
(incidence-weighted “Realistic” estimates)
Rescales using Equivalent Form R/A Chemicals per Facility.

Each model run as shown in Columns (2) through (4) removes complexities one at a time to
support the recommended model in Column (5) which accepts only one simplification—to
neglect first-time filers. 18 Additionally, Column (6) provides a robustness test that shows how
much modeling error would be incurred if circumstances changed to a dramatically different
distribution of Form Rs/Form As within and across facilities. 19

EPA expected negligible first-time filer effects on the steady state burden because first-time filers account for
2.87% of the total chemicals filed and 6.16 % of facilities (average percentages in period between 2004-2007 per
Frozen TRI data for RY 2007 based on RY 2005).
19
EPA used distributions from TRI Phase II burden reduction conditions (see details in Appendix B Supplement).

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Appendix B
Table B-4: A/R Model Development Results and Analysis
Test Run
Description

(1)
REFERENCE
no
simplifications

(2)
Same as
(1) but
without
first-time
filer
adjustment

(3)
Same as (1)
but without
incidence
rate
adjustments

(4)
Same as (1)
but without
distribution
specificity*

(5)
RECOMMENDED
realistic
estimates with
incidence rate
adjustments**

(6)
Robustness
Test alternate
distribution
***

Model Form R
unit Burden
(hrs/Form R)

12.66

12.52

27.24

12.67

12.52

12.53

Model Form A
unit burden
(hrs/single
chem Form A)

7.76

7.67

13.16

7.95

7.71

7.67

A/R
0.613
0.612
0.483
0.628
0.615
A/R % difference from Reference
(Model Error)
-0.12
-21.22
2.41
0.39
* Does not account for potential double-counting of facility level burden among facilities reporting both Rs and As.
** Current A, R, A+R distributions, no first-time filer adjustments
*** Phase 2 Burden Reduction Rule

0.612
0.50

Findings
The recommended formulation of the A/R model with a value of .615 hr/hr, is robust to changes
in model assumptions as well as changes in actual conditions, as simulated, yielding differences
between A/R conditions and the A/R model under 0.5 %. Moreover, similar results are shown for
the Nominal Form R unit burden in Table B-5—with a corresponding difference of 1%.
Regarding the practical need for distributional considerations, given the relatively small
difference for A/R at 2.41%, 20 EPA considered making the additional simplification. However,
with the conversion factors (Equivalent Form R/A Chemicals per Facility— Rcpfe. Acpfe)
fundamental to RBBM overall, and integral to the development of several models (A/R, FTFf,
WAWR), EPA examined the robustness of the conversion factors themselves. Table B-5 presents
the result that even in the face of dramatic shifts in distribution, Equivalent Form R/A Chemicals
per Facility are reasonably robust, within about 10%.
Taking a more comprehensive view, EPA calculates the effects of 1) neglecting first-time filers
and 2) the alternate distribution on the Steady State Total Burden estimate. Regarding the
assumption to neglect the effect of first-time filer in the steady state, EPA calculates the effect of
modeling error on the Steady State Total Burden estimate at -.04% . Regarding the test for an
alternate distribution, EPA calculates the associated error of encountering different conditions
while using RBBM original models which results in an error of -.55% for Steady State Total
Burden.
20

The percent difference is calculated by taking the difference between the reference A/R model without
distributional specificity and the reference A/R model divided by the reference A/R model [((0.628-0.613)/0.613)
*100 =2.41% ]. Note that figures have been rounded.

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Appendix B

Table B-5: Nominal Form R Unit Burden and Equivalent Forms per Facility
Test Run
Description

A/R

(1)
REFERENCE
no
simplifications

(2)
Same as (1)
but without
first-time filer
adjustment

0.613

0.612

0.483

-0.12

A/R % difference from Reference
(Model Error)

Back
Calculated
Nominal
Form R Unit
Burden

35.75

Nominal Form R Unit Burden %
difference from Reference (Model
Error)
Equivalent
Form R
chemical/facility
3.869
chemical/Form R % difference from
Reference

(3)
Same as (1)
but without
incidence
rate
adjustments

(4)
Same as (1)
but without
distribution
specificity*

(5)
RECOMMENDED
realistic estimates
with incidence
rate adjustments**

(6)
Robustness
test alternate
distribution***

0.628

0.615

0.612

-21.22

2.41

0.39

0.50

35.75

37.15

35.59

35.72

35.99

0.02

3.92

-0.43

-0.07

-0.77

3.869

3.733

3.869

3.817

-3.53

0.00

-1.35

3.407

3.777

0.00

10.86

Equivalent
Form A
chemical/facility
3.407
3.407
3.407
2.302
chemical/Form A % difference from
Reference
-32.43
* Does not account for potential double-counting of facility level burden among facilities reporting both Rs and As.
**Current A, R, A+R distributions, no first-time filer adjustments
*** Phase 2 Burden Reduction Rule

Non-Form Burden
The non-Form burden portion of the Steady State Burden Calculation contains three components:
petitions, supplier notification, and non-reporter compliance determination. Each component and
the new method’s simplifying assumptions are presented below. 21
Burden associated with supplier notification applies to suppliers with customers subject to
EPCRA §313 reporting. These suppliers do not necessarily complete TRI reports/Forms
themselves. On an annual basis, 3,734 facilities are assumed to spend 24 hours each for a total
of 89,616 hours. This estimate is currently not regularly updated. It was reviewed in terms of
providing an adequate level of burden for the task and viewed as sufficiently high. Moving
forward with the same basis of numbers of facilities and hours per task—and supporting
transitional baseline continuity—a constant value of 89,616 hours is estimated.
21

For more detailed information regarding the existing method for non-form burden estimates, see TRI 2008 ICR
Supporting Statement.

4/28/11
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Appendix B
Burden associated with non-reporter compliance determination comes from facilities outside of
the TRI reporting community that have to determine whether they need to file a Form R or Form
A. On an annual basis, 183,744 facilities 22 are assumed to spend four hours each for a total of
734,976 hours. In this method, all facilities in NAICS-code-eligible sectors (with ten or more
employees) are assumed to incur compliance determination burden. When reviewing this
assumption, EPA concluded that it produces a highly overstated estimate because only those
facilities close to the cusp of TRI reporting thresholds for manufacture, process and otherwise
use, need to check their reporting eligibility regularly. In sum, the burden estimate was reviewed
in terms of providing an adequate level of burden for the task and viewed as sufficiently high.
For the sake of simplicity in support of transitional baseline continuity, this basis of numbers of
facilities and hours per task will be frozen and the new methodology estimates the current value
as a constant—734,976 hours.
Burden associated with petitions for the TRI program includes activities to research, prepare and
file a petition with EPA. In the existing method, five petitions per year are assumed at 185 hours
per petition, totaling 925 hours. This estimate is currently not regularly updated. It was reviewed
in terms of providing an adequate level of burden for the task and viewed as sufficiently high.
Moving forward with the same basis of numbers of petitions and hours per petition, as well as
supporting transitional baseline continuity, a constant value of 925 hours is estimated.
In comparison to the Form burden estimates, which vary with the number and types of Forms
that are being filed, the non-Form burden estimates remain constant in the Steady State Total
Burden Calculation. Moreover, as these estimates are sufficiently large, and in one case highly
overstated, they do not require any regular maintenance or further updates. The sum of non-Form
burden is constant at 825,517 hours.
Nominal Form R Unit Burden
Given overarching simplifications and RBBM’s objective of transitional baseline continuity,
Nominal Form R is back-calculated via the following equation: 23
Eqn. B-1: Nominal Form R Unit Burden
= (Total Burden – non-Form burden)/[(# Form R chemicals)+((A/R)*#Form A chemicals)]
EPA defines the methodology revision’s transition point as the time of the last ICR approval
with conditions specified by 2008 ICR renewal projections. This calculation produces a value of
35.7 hours per Form R chemical for the Nominal Form R unit burden. As shown in Table B-5,
22

The estimate for the number of facilities that are doing compliance determination but not reporting to TRI is
determined by subtracting reporters from the total number of facilities with ten or more employees in TRI-subject
NAICS codes. To compute the number of reporting facilities, EPA divides the current number of Form R reports
from the latest ICR by the average number of Forms per facility—66,751/3.7. Although non-Form burden has
historically been reported with the estimate for Form R burden in its ICR Supporting Statement, this is only done by
convention, as it reflects total non-Form burden for the TRI program.
23
In the actual calculation EPA corrects for double-counting of facility level burden among facilities filing both As
and Rs in the last ICR renewal, shifting the baseline downward slightly (administrative correction due to calculation
error). The double-count was caused by estimating facility-level burden twice for facilities that file both Forms R
and A. In the revised methodology the conversion factors for equivalent chemicals per facility used to rescale
facility unit burdens prevent double-counting.

4/28/11
B-13

Appendix B
the Nominal Form R unit burden is robust to changes in model assumptions as well as changes in
conditions, showing differences under 1%.
In April 2010, EPA tested the effectiveness of the back-calculated Nominal Form R unit burden
in providing transitional baseline continuity. In a spot-check comparison between RBBM Steady
State Total Burden and the TRI Program on-record burden numbers, results were within 2%. 24
Summary: Steady State Total Burden Method
Computation
Eqn. B-2: Steady State Total Burden = Form R burden + Form A burden + non-Form burden
= (Nominal Form R unit burden*# Form R chemicals)
+(Form R unit burden*(A/R)*#Form A chemicals) + non-Form burden
= 35.7*# Form R chemicals + [35.7 * .615 * # Form A chemicals] + 825,517
Where:
A/R=
Nominal
Form R unit
Burden=

Ratio model of single-chemical Form A unit burden to Form R unit
burden
Single base number for the entire methodology; provides the focal point
for assessing and maintaining estimate accuracy.

Assumptions
The following assumptions apply for the maintenance and update recommendations that follow:
1) Simplifying substantive assumptions remain valid. First-time filers in the steady state
have a negligible effect; PBT/non-PBT burden=1 due to lack of a verifiable alternative.
2) The Nominal Form R unit burden of 35.7 hours remains a reasonable estimate of unit
burden with Form R non-PBT remaining the most frequent type submission.
3) Relationships between reporting activities in the Abt Associates Engineering Studies
which are drawn from a subpopulation, as measured by best professional judgment of Abt
Associates’ engineers, are reasonably reflective of the true relationships in the total
reporting population overall.
4) The distribution for Form As/Form Rs within and across facilities stays within the range
of distributions in this study (see values for Equivalent R/A Chemicals per Facility in
Appendix B Supplement).
24

As of June 2010, the sum of burden hours “on record” was 3.87 million hours, based on Notices of OMB Action,
Form R ICR and Form A ICR March 27, 2009. The corresponding RBBM estimate is 3.93 million hours which is
within 2%. Note that this RBBM estimate does not include updates to the Form R unit burden to account for the
slight additional burden associated with dioxin reporting (see estimate in the TRI 2012 ICR Renewal Supporting
Statement).

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Appendix B
Maintenance and Update Recommendations
EPA evaluated maintenance needs for A/R, Nominal Form R unit burden, and Equivalent Form
R/A Chemicals per Facility. None of the models require updating on a routine basis. The A/R
model and the back-calculated Nominal Form R unit burden values are robust to extreme
changes in (per chemical) Form/facility distributions and model assumptions, with differences of
less than 1%. However, EPA notes that the A/R formulation is dependent on the conversion
factors used to rescale facility-level unit burdens to (per chemical) form level. Regarding the
conversion factors, EPA does not anticipate extreme changes in their values under status quo
operations (and even so, results here are within a 10% modeling error). However, in the event
that the program adds industry sector(s), the (per chemical) form/facility distribution could shift
due to the addition of large chemical counts of different distributions than the distributions
considered here.
As a practical matter, given that the requirements for ICR renewal reporting provide periodic
recalculation of the Equivalent Form R/A Chemicals per Facility, these numbers can be routinely
checked to be sure that this basis for the A/R model (and others—FTFf and WAWR) remains
valid. EPA recommends this routine check.

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Appendix B

Supplement– Distributional Analysis
Equivalent Form R Chemicals per Facility and
Equivalent Form A Chemicals per Facility
This supplement describes how and why the conversion factors, Equivalent Form R/A Chemicals
per Facility ( Rcpf e / Acpf e ) were developed. The factors are used to re-scale facility-level unit
burdens to (per chemical) form level unit burdens. This supplement describes:
• Why the scaling factors are needed;
• Formulas used to calculate the factors;
• Derivation of the formulas;
• Distributions for Forms R and A reporting under two scenarios; and
• Values for these factors under the two scenarios.
The derivations below provide a divisor for each facility-level unit burden that apportions facility
level burden to form level burden. Based on the distributions of Form As and Form Rs within
and across facilities, facility-level burden associated with Form R chemicals is apportioned
equally across Form R chemicals and facility-level burden associated with Form A chemicals is
apportioned equally across Form A chemicals. As a result of the derivations herein, these values,
as used for scaling facility-level factors to chemical level factors are (used in matrices of
Appendix A and Table A-4) are:
Equivalent Form R Chemicals per Facility, Rcpf e = 3.87
Equivalent Form A Chemicals per Facility, Acpf e = 3.42
Equivalent Form R Chemicals per Facility ( Rcpf e ) and Equivalent Form A Chemicals per
Facility ( Acpf e )
Facilities reporting to TRI incur facility-level burden, such as compliance determination. This
facility-level burden is incurred once per reporting cycle, regardless of how many forms a
facility files. Facility-level burden must be converted to a per chemical measure unit burden to be
incorporated into the chemical-level ratio model. The conversion entails breaking down and
apportioning the facility-level burden by chemical and it depends on the number and form-type
of chemicals filed at the average facility. Since EPA tracks burden differently for A and R
reporting, the apportionment must be calculated separately for Form R and Form A reporting,
with consideration of the combined Form distributions at facilities.
At the form level, R and A chemicals are reported differently, with Form Rs containing one
chemical per form and Form As containing one or multiple chemicals on the same form. In
actual reporting, a given facility may report any combination of Form types (Rs only, As only, or
Rs and As together).
For purposes of methods development and modeling, EPA refers to Form R chemicals and Form
A chemicals as the number of chemicals for which each form type is submitted. This metric puts
both types of reporting on the same basis, avoiding the awkward conversion to put Form As on a
per chemical basis, dividing by the average number of chemicals per form. In TRI program
4/28/11
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Appendix B
operations, the average number of chemicals per Form A is used to scale chemical counts to
form counts, as required to report to OMB the number of responses. It is also intuitively helpful
to know how many chemicals, on average, are reported via Form A. This conversion—based on
raw counts of chemicals and facilities—is different than the conversion described herein for
purposes of re-scaling facility-level unit burdens to per R/A chemical bases (here termed
Equivalent Form R/A Chemicals per Facility).
Since, Form Rs and Form As are considered separately in the model, two measures of facilitylevel burden per chemical are needed:

Bprc
Bpac

Facility-level burden per Form R chemical, in hrs/Form R chemical
Facility-level burden per Form A chemical, in hrs/Form A chemical

Equivalent Form R/A Chemicals per Facility are used to allocate facility-level burden to
chemical-level burden. For example, chemical-level unit burden (e.g., compliance determination
per Form R chemical) for Form Rs can be calculated by dividing facility-level burden associated
with Form R chemicals by Equivalent Form R Chemicals per Facility. Similarly, chemical-level
burden for Form As can be calculated by dividing facility-level burden associated with Form A
chemicals by Equivalent Form A Chemicals per Facility.
Rcpf e
Acpf e

Equivalent Form R Chemicals per Facility
Equivalent Form A Chemicals per Facility

These scaling factors are used instead of average forms per facility to adjust reporting burden in
a manner that prevents the potential double-counting of facility-level burden for that can occur
when a facilities that files both Form Rs and Form As. There are three types of facilities that
report to TRI (see Figure B-1):
• Facilities reporting only Form As (A Only),
• Facilities reporting both Form As and Form Rs (R+A), and
• Facilities reporting only Form Rs (R Only).
Figure B-1: Facility Types

If average forms per facility is used to allocate facility-level burden to chemical-level burden,
R+A facilities are double-counted (Figure B-2). Using Equivalent Form R/A Chemicals per
4/28/11
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Appendix B

Facility to apportion facility-level burden across forms removes this double-counting; these
measures account for the distribution of Form As and Rs within and across facilities.
Figure B-2: Double-Counting using Average Forms per Facility

Calculation of Bprc and Bpac using Rcpf e and Acpf e
EPA calculates Bprc and Bpac using a measure of nominal facility-level burden per facility
and Rpcf e and Apcf e . EPA calculates Rpcf e and Apcf e from the distributions of Form R and
Form A reporting among facility types. Specific measures used include counts of Form R
chemicals and Form A chemicals reported and counts of facilities reporting Form Rs and As.
The formulas Bprc and Rcpf e are as follows:

Bprc =

Bff OVERALL
Rcpf e

Rcpf e =

ηR =

, where

rc RTOT
f RONLY +η R f R + A

rc R + A
rc R + A + ac R + A

BffOVERALL = Nominal facility-level burden per facility overall, for all TRI filers
f R+ A = Number of R+A facilities
f RONLY = Number of R Only facilities
acR + A = Number of Form A chemicals reported to TRI by R+A facilities
rcR + A = Number of Form R chemicals reported to TRI by R+A facilities
rcRTOT = Number of Form R chemicals reported to TRI (by R+A and R Only facilities)
The formulas Bpac and Apcf e are as follows:
Bpac =

Acpf e =

ηA =

Bff OVERALL
Acpf e

, where

ac ATOT
f AONLY +η A f R + A

acR + A
rcR + A + acR + A

BffOVERALL = Nominal facility-level burden per facility overall, for all TRI filers
f R+ A = Number of R+A facilities
f AONLY = Number of A Only facilities
acR + A = Number of Form A chemicals reported to TRI by R+A facilities
rcR + A = Number of Form R chemicals reported to TRI by R+A facilities
4/28/11
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Appendix B

ac ATOT = Number of Form A chemicals reported to TRI (by R+A and A Only facilities)

Derivation of Formulas for Bprc , Bpac , Rcpf e , and Acpf e
Together, facility-level burden per Form R chemical ( Bprc ) and facility-level burden per Form
A chemical ( Bpac ) must account for facility-level burden from all three facility types (Table B6).

Bf RONLY
Bf AONLY
Bf R + A

Bf OVERALL

Total facility-level burden associated with Form R chemicals from R Only
facilities
Total facility-level burden associated with Form A chemicals from A Only
facilities
Total facility-level burden associated with Form A and R chemicals from R+A
facilities
Total facility-level burden associated with Form R chemicals and Form A
chemicals from all facilities

Table B-6: Facility-level Unit Burden
Facility Type
Form Type
A Only
A+R
R Only

Form A
Form A
Form R
Form R

Facility-Level Burden
Bf AONLY
Bf R + A

Bf OVERALL

Bf RONLY

All facility-level burden from R Only facilities is apportioned to Form R chemicals. Similarly, all
facility-level burden from A Only facilities is apportioned to Form A chemicals. To avoid
double-counting, facility-level burden from R+A facilities is split between Form R chemicals
and Form A chemicals (Table B-7).

Bf ATOT
Bf RTOT

Total facility-level burden associated with Form A chemicals from all facilities
reporting Form As
Total facility-level burden associated with Form R chemicals from all facilities
reporting Form Rs

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Appendix B

Table B-7: Apportionment of Facility-level Unit Burden to Rs and As
Facility Type
Form Type
Facility-Level Burden
Bf AONLY
A Only
Form A
Bf ATOT
Form A
Bf OVERALL
Bf R + A
A+R
Form R
Bf RTOT
Bf RONLY
R Only
Form R
The total facility-level burden for A+R facilities can be apportioned amongst form types using
the fraction of forms reported by A+R facilities that are Form Rs and Form As (Figure B-3,
Table B-8). This method assumes the magnitude of total facility-level burden for each form type
is distributed evenly with the number of forms in each type reported by A+R facilities.

ηR
ηA

rcR + A
acR + A

Fraction of the A+R facility-level burden that is associated with Form R
chemicals; used to apportion total facility-level burden from A+R facilities to
total facility-level burden for Form R chemicals
Fraction of the A+R facility-level burden that is associated with Form A
chemicals; used to apportion total facility-level burden from A+R facilities to
total facility-level burden for Form A chemicals
Number of Form R chemicals reported by A+R facilities
Number of Form A chemicals reported by A+R facilities

Eqn. 1 η R =

rc R + A
rc R + A + ac R + A

Eqn. 2 η A =

ac R + A
rc R + A + ac R + A

Note that η A + η R = 1 . Combining Eqn. 1 and Eqn. 2:
Eqn. 3 η A + η R =

rc R + A
rc R + A + ac R + A

ac R + A
rc R + A + ac R + A

rc R + A + ac R + A
rc R + A + ac R + A

Figure B-3: Fraction of Forms Reported By R+A Facilities
that are Form Rs And Form As

4/28/11
B-20

Appendix B
Table B-8: Apportionment of Facility-level Unit Burden from R+A Facilities
Facility Type
Form Type
Facility-Level Burden
Bf AONLY
A Only
Form A
Bf ATOT
η A ⋅ Bf R + A
Form A
Bf OVERALL
Bf R + A
A+R
η R ⋅ Bf R + A
Form R
Bf RTOT
Bf RONLY
R Only
Form R

Apportioning all facility-level burden from R Only facilities to Form R chemicals, all facilitylevel burden from A Only facilities to Form A chemicals, and splitting facility-level burden from
R+A facilities between Form R chemicals and Form A chemicals involves the following:
Eqn. 4 Bf RTOT = η R ⋅ Bf R + A + Bf RONLY
Eqn. 5 Bf ATOT = η A ⋅ Bf R + A + Bf AONLY
The total facility-level burden for all TRI filers can be apportioned amongst facility types using
the fraction of TRI reporters in each facility type (Figure B-4). This method assumes the fraction
of total facility-level burden incurred by each facility type is equal to the fraction of facilities in
each type.

f OVERALL
f RONLY
f AONLY
fR+ A
xRONLY
x AONLY
xR + A

Number of facilities reporting to TRI
Number of R Only facilities
Number of A Only facilities
Number of R+A facilities
Fraction of TRI reporters (facilities) reporting only Form Rs,
Fraction of TRI reporters (facilities) reporting only Form As
Fraction of TRI reporters (facilities) reporting Form Rs and As

Eqn. 6 xRONLY =

f RONLY
fOVERALL

Bf RONLY
BfOVERALL

Eqn. 7 x AONLY =

f AONLY
fOVERALL

Bf AONLY
BfOVERALL

Eqn. 8 xR+ A =

fR+ A
fOVERALL

Bf R + A
BfOVERALL

Combining Eqn. 4, Eqn. 6, and Eqn. 8:
Eqn. 9 Bf RTOT = xRONLY BfOVERALL + η R xR+ A BfOVERALL
Combining Eqn. 5, Eqn. 7, and Eqn. 8:
Eqn. 10

Bf ATOT = x AONLY BfOVERALL + η A xR+ A Bf OVERALL

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Appendix B
Figure B-4: The Fraction of Total Facility-Level Burden
Incurred by Each Facility Type

The total facility-level burden for all TRI filers divided by the total number of TRI filers equals
the facility-level burden per facility for all TRI filers.

BffOVERALL Facility-level burden per facility overall, for all TRI filers
Eqn. 11

BfOVERALL
fOVERALL

= Bff OVERALL

Combining Eqn. 9 and Eqn. 11:
Eqn. 12

Bf RTOT = xRONLY BffOVERALL ⋅ f OVERALL + η R xR+ A BffOVERALL ⋅ f OVERALL

Combining Eqn. 10 and Eqn. 11:
Eqn. 13

Bf ATOT = x AONLY Bff OVERALL ⋅ f OVERALL + η A xR+ A Bff OVERALL ⋅ f OVERALL

Total facility-level burden can be converted to facility-level burden per chemical by dividing by
number of chemicals:
Eqn. 14
Eqn. 15

Bprc =

Bf RTOT
rcRTOT

Bpac =

Bf ATOT
ac ATOT

Combining Eqn. 12 and Eqn. 14:
Eqn. 16

Bprc =

xRONLY BffOVERALL ⋅ fOVERALL +η R xR + A BffOVERALL ⋅ fOVERALL
rcRTOT

Simplifying Eqn. 16:
Eqn. 17

Bprc =

f RONLY +η R f R + A
rc RTOT

⋅ Bff OVERALL

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Appendix B

In Eqn. 17, f RONLY + η R f R + A represents the equivalent number of facilities associated with Form
R reporting. Equivalent Form R Chemicals per Facility equals the number of Form R chemicals
reported divided by this number of facilities.
Eqn. 18

Rcpf e =

rcRTOT
f RONLY +η R f R + A

Combining Eqn. 17 and Eqn. 18:
Eqn. 19

Bprc =

Bff OVERALL
Rcpf e

Combining Eqn. 13 and Eqn. 15:
Eqn. 20

Bpac =

x AONLY BffOVERALL ⋅ fOVERALL +η A xR + A BffOVERALL ⋅ f OVERALL
ac ATOT

Simplifying Eqn. 20:
Eqn. 21

Bpac =

f AONLY +η A f R + A
ac ATOT

Bff OVERALL

In Eqn. 21, f AONLY + η A f R + A represents the equivalent number of facilities associated with Form
A reporting. Equivalent Form A Chemicals per Facility equals the number of Form A chemicals
reported divided by this number of facilities.
Eqn. 22

Acpf e =

ac ATOT
f AONLY +η A f R + A

Combining Eqn. 23 and Eqn. 24:
Eqn. 23

Bpac =

Bff OVERALL
Acpf e

Calculation of Bprc , Bpac , Rcpf e , and Acpf e Under Current Operations

Bprc and Bpac can be calculated using the distribution of forms and facilities among facility
types under current operations as projected in the 2008 ICR renewal. This distribution is
presented in Table B-9.

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Appendix B

Table B-9: Form and Facility Distributions Under Current Operations - No Burden
Reduction
Average Number of
Count of Chemicals
Reporter
Unique
Chemicals
Type
Facilities
R
A
Total
R
A
Total
A Only
2,307
0
4,831
4,831
N/A
2.09
2.09
R Only
18,748 67,772
0 67,772
3.61
N/A
3.61
Both R and A
2,406 10,764
5,945 16,709
4.47
2.47
6.94
Total/Overall
23,461 78,536 10,776 89,312
3.73
2.30
3.81
Note: Raw form counts were used to match the 2008 ICR. Chemicals are not rolled up at
the facility-chemical level.
Source: TRI 2005 Public Data Release, RY 2005

Under current TRI operations,
• Nominal Facility-level burden=1.25 for non-PBT, subsequent year (compliance
determination only)
• Equivalent Form R Chemicals per Facility = 3.87
• Equivalent Form A Chemicals per Facility = 3.41
• Facility-level burden per Form R chemical = 0.32
• Facility-level burden per Form A chemical = 0.37 (Table B-10 and Table B-11)

Table B-10: Variables, Formulas,
and Values Used to Calculate
Facility-level Burden per Form R
Chemical Under Current Operations
Variable/Formula
Value
rcRTOT
78,536
rcR + A
10,764
acR + A
5,945
f RONLY
18,748
f R+ A
BffOVERALL

ηR =

rc R + A
rc R + A + ac R + A

Rcpf e =
Bprc =

rc RTOT
f RONLY +η R f R + A
Bff OVERALL
Rcpf e

Table B-11: Variables, Formulas,
and Values Used to Calculate
Facility-level Burden per Form A
Chemical Under Current Operations
Variable/Formula
Value
ac ATOT
10,776
rcR + A
10,764
acR + A
5,945
f AONLY
2,307

2,406
1.25

f R+ A
BffOVERALL

0.64

ηA =

3.87

Acpf e =

0.32

Bpac =

acR + A
rcR + A + acR + A

ac ATOT
f AONLY +η A f R + A
Bff OVERALL
Acpf e

0.36
3.41
0.37

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Appendix B
Calculation of Bprc , Bpac , Rpcf e , and Apcf e Under Alternate Operations

Bprc and Bpac were also calculated under an alternative scenario, using the distribution of Form
R/ Form A within and across facilities during phase II burden reduction conditions. This
alternative distribution is presented in Table B-12.
Table B-12: Form and Facility Distributions Under Alternate Conditions
Average Number of
Count of Chemicals
Reporter
Unique
Chemicals
Type
Facilities
R
A
Total
R
A
Total
A Only
4,020
0
8,096
8,096
N/A
2.01
2.01
R Only
13,226 35,196
0 35,196
2.66
N/A
2.66
Both R and
6,215 31,555 14,465 46,020
5.08
2.33
7.40
A
Total/Overa
23,461 66,751 22,561 89,312
3.80
2.21
3.81
ll
Note: Raw form counts were used to match the 2008 ICR. Chemicals were not rolled up
at the facility-chemical level.
Source: TRI 2005 Public Data Release, RY 2005

Under alternate conditions,
• Nominal Facility-level burden=1.25 for non-PBT, subsequent year (compliance
determination only)
• Equivalent Form R Chemicals per Facility = 3.82
• Equivalent Form A Chemicals per Facility = 3.78
• Facility-level burden per Form R chemical = 0.33
• Facility-level burden per Form A chemical = 0.33 (Table B-13 and Table B-14)

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Appendix B

Table B-13: Variables, Formulas,
and Values Used to Calculate
Facility-level Burden per Form R
Chemical Under Alternate
Conditions
Variable/Formula
Value
rcRTOT
66,751
rcR + A
31,555
acR + A
14,465
f RONLY
13,226
f R+ A
BffOVERALL

ηR =

rc R + A
rc R + A + ac R + A

Rcpf e =
Bprc =

rc RTOT
f RONLY +η R f R + A
Bff OVERALL
Rcpf e

Table B-14: Variables, Formulas, and
Values Used to Calculate Facility-level
Burden per Form A Chemical Under
Alternate Conditions
Variable/Formula
ac ATOT

Value
22,561

31,555
14,465

rcR + A
acR + A
f AONLY

6,215
1.25

4,020
6,215

f R+ A
BffOVERALL

0.69

ηA =

3.82

Acpf e =

0.33

Bpac =

1.25

acR + A
rcR + A + acR + A

0.31

ac ATOT
f AONLY +η A f R + A

3.78

Bff OVERALL

0.33

Acpf e

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Appendix C
Form Element Estimation
This appendix presents the Form Element Estimation method of the Ratio-Based Burden
Methodology (RBBM), including the models of Standardized Form Element Burdens. The
method provides a standardized set of form element burdens for use when estimating changes to
the Form R, as applied to the Nominal Form R unit burden. 1
This method is different from the other methods of RBBM in the way it implements the
methodology priorities of simplicity, internal consistency, and estimate baseline continuity.
Unlike the A/R, FTF and WAWR, this method’s models are closely tied to the methodology’s
base number, Nominal Form R unit burden. If estimates obtained by this method are not
considered in context of the unit burden used for reference, they may induce artificial baseline
shifts, or at a minimum, produce internal inconsistencies, as burden estimates due to form
changes do not adequately reflect their proportionate contribution to the total form unit burden.
The means by which this method maintains internal consistency with Nominal Form R unit
burden is by ensuring that the form elements of the Form R sum to the value (or close to the
value of) the Nominal Form R unit burden. Therefore, in the event that the Nominal Form R unit
burden undergoes a wholesale update or large change its value, the entire Form Element
Estimation method must be revised so that Standardized Form Element Burdens proportionately
add up to the value of the new Nominal Form R unit burden.
For simplicity, this method standardizes the Abt Associates Engineering Studies estimates to
develop Standardized Form Element Burdens. Standardization is achieved by organizing similar
form elements into standard categories, and then using average burdens. For internal consistency
between Standardized Form Element Burdens and the Nominal Form R unit burden, the elements
are scaled so that the sum of all element estimates is equal to the Nominal Form R unit burden of
35.7. Like the Nominal Form R unit burden, each form element estimate is fully loaded,
incorporating facility-level burden. This approach is consistent with Decision Rule #5 on page 10
in the main report. 2 With respect to transitional and ongoing baseline continuity, the method
ensures that the changes in unit burden are estimated in a manner that induces changes to the
baseline commensurate with intended changes in the form.
Form Element Estimation Method
Method Development
The method provides a way to quickly estimate an incremental burden associated with a form
change. The equation below represents the method for estimating the total burden after
accounting for the new data elements.
Nominal Form R unit burdennew = Nominal Form R unit burdenold + Form change burden
1

Changes that affect Form R may or may not affect Form A. In this methodology, when changes to Form R affect
Form A, they are theoretically captured when the Form R unit burden is multiplied by the A/R model. The A/R
model is not updated in conjunction with form changes, as it is sufficiently robust.
2
This scaling differs from scaling used in Abt Associates Engineering Studies (see references in Appendix G). In
the Engineering Studies, when scaling from “realistic” to “scaled” estimates, elements were not scaled up
proportionately. Some elements were considered “un-scalable.” This decision altered the relative proportions of each
element, compromising internal consistency and considered inappropriate for RBBM.

4/28/11

C-1

Appendix C

The form change burden could be a positive or negative number, depending on the nature of the
form elements that are added to, or removed from, Form R. In order to implement this feature,
EPA first developed a classification system of estimates related to the current form and then
scaled the standardized elements so they sum to the Nominal Form R unit burden. Key analytical
decisions included 1) defining the categories of the classification system that best represent the
form elements, and 2) specifying the scaling system that works best for this method’s objectives
as well as overall methodology objectives. The development steps are described below. Due to
the very long nature of the tables, they are all presented at the end of this Appendix with the
exception of Table C-5, which is brief and therefore included in the body of the Appendix.
Identifying Standardized Categories
As mentioned above, EPA developed a classification system of estimates related to the existing
Form R and then grouped data elements into standardized burden categories. This section
describes how the classification system was organized. Table C-1 provides the list of estimates
from the TRI RY 2002 Form R from the Abt Associates Engineering Studies (see Appendix G). 3
From this list, EPA defined categories and computed means and variance for each category.
This method groups elements into corresponding categories to which new data elements may
belong. Data elements were grouped into categories using the following criteria:
1. The information collected by the data element: release value, facility location
information, chemical identification information; and
2. The type of work required to fill out the data element: locating and reviewing
monitoring data, conducting a short information look-up, or typing a simple code.
Initially, data elements were grouped into categories with other elements that required the
collection of similar information. However, in some cases these initial categories had high
variability in estimated engineering burden. EPA reduced this variability by refining the
categories by type of work required. Data elements collecting estimates of source reduction and
recycling activity in the current year, for example, were initially grouped together yet varied
considerably in burden. This group was then split into two groups: one for quantities derived
from relevant Section 5 and 6 data elements and the other for source reduction and recycling
estimates with no relevant Section 5 and 6 data elements. The final list of data elements in their
respective categories is included in Table C-2.
The estimates are called raw estimates for the purpose of this study, as they did not contain
incidence weights, which were based on response frequencies by data element. EPA discussed
the merits and disadvantages of using the Abt Associates Engineering Studies fully engineered
numbers, as were used in A/R, FTF and WAWR. However, for the needs of this method, they
were not considered the most appropriate estimates. Given the setting in which EPA estimates
form changes, often the incidence rate for a new element is unknown, providing no basis for an
average or general assumption. Also, given the objective of Standardized Form Element
Burdens, raw data element estimates provided consistent information for data elements that are
3

Although the information drew from a non-representative sample of reporters, the study’s design insured a high
level of internal consistency due to its internal validity. See Appendix B for a complete discussion of the strengths
and weaknesses of Abt Associates Engineering Studies as they apply to RBBM.

4/28/11

C-2

Appendix C
theoretically the same without respect to reporter behavior. Similarly, knowing in advance that
the method will require scaled estimates used to update the Nominal Form R unit burden, then it
is desirable to have similar data elements possess the same standardized value. As a result of
these considerations, EPA decided to use the raw estimates without incidence weighting for the
pre-scaling basis of the method. This decision provides internal consistency from data elements
to Form and across Form R and Form A.
Scaling Options
EPA considered whether or not it was necessary to scale the standardized categories to the
Nominal Form R unit burden to ensure consistency between the Form Element Estimation
Method and the Nominal Form R unit burden. The following four options were considered:
• Option 1 – No scaling, use raw estimates (no incidence weighting)
• Option 2 – No scaling, use incidence weighted raw estimates
• Option 3 – Scale raw estimates (no incidence weighting) to Nominal Form R burden
(35.7 hours).
• Option 4 4 – Scale raw estimates (no incidence weighting) to Calculation and Form
Completion portion of Nominal Form R burden (20.4 hours)
EPA then ranked the first three options based on internal consistency, parsimony, intuitive
calculations, temporal consistency, ICR renewal implications and EA implications (see Table C4). With the highest rank, Option 3 was selected as the best approach. The main reasons for this
decision are as follows:
1. Scaling the raw estimate category so that the Form R totals 35.7 hours provides
consistency because 35.7 hours is the value of the Nominal Form R unit burden. As
with the Nominal Form R unit burden, the Standardized Form Element Burdens
reflect “fully loaded” estimates of all activities associated with Form R completion
(facility-level and per chemical form-level).
2. At face value, this scaling produces relatively intuitive calculations given
expectations that that the sum of category means should equal the total burden per
Form R.
Tables C-2 and C-3 present a general profile for each category of the Standardized Form
Element Burdens, including the number of data elements corresponding to each category, the
mean, and the standard deviation for each category with burden estimates raw and scaled to 35.7
hours, respectively.
Findings
The Form Element Estimation method is designed to provide a structured and reproducible
method for estimating burden associated with Form changes. When new form elements are
added to Form R, EPA staff will be able to use Table C-3 or Figure A-2 standardized burdens to
determine what change in burden (in hours) is associated with the form changes.
Additionally, with experience, EPA has discovered that form changes do not always manifest
themselves within the confines of this method’s framework for “add or subtract a form element.”
4

Note that Option 4 was considered at a later date and therefore, was not ranked.

4/28/11

C-3

Appendix C
In fact, changes are often so minuscule that EPA estimates them to have a negligible impact on
form-related burden. Table C-5 provides a list of changes of this nature.
Table C-5: Form Changes for Which Additional Burden is not Estimated
Form Change
Circumstance of Inestimable Burden
Code or Check Box (could include:
Where burden associated with data
indication of activity or reason, yes/no,
gathering and recording is negligible and
NA, etc.)
frequency of reporting the data element is
low. Or if response is already implied in
existing data element (e.g. addition of NA
box)
Clarification of existing required data fields Where clarification on reporting form is
including reorganization
made but no new information is required
Addition of optional open-ended question
No burden by convention
Method Summary
Computation
To illustrate how a revised Nominal Form R unit burden is calculated when new data elements
are added to Form R, assume that EPA is adding a new data element to capture an additional
EPA identification number such as the Facility Registry System (FRS) ID. If the analyst is
familiar with the specific existing data element or group of existing data elements to which the
new data element is similar, he/she can refer to the relevant categorical burden in the
Standardized Form Element Burdens listed in Table C-3 and in the Program Staff Tool.
Alternately, the analyst can look up a similar element’s standardized burden, as depicted in
Figure A-2. Table C-3 shows the time estimate for Facility Identification Information Codes
.0023 hours. The sample calculation of the new Nominal Form R unit burden is as follows:
Eqn. C-1: Form R Unit Burden when New Form Elements are Added
Nominal Form R unit burdennew = Nominal Form R unit burdenold + Form change burden
Nominal Form R unit burdennew = 35.7 hours + .0023 hours =35.7023 hours
Assumptions
When a new form element is added to Form R and the incremental burden associated with the
form element is selected from one of the categories, the following three assumptions are made:
1) The corresponding category is representative of the new data element. For this
assumption to hold true, reporter activity representing the new data element should be
similar to the activities comprising that general category.
2) The incidence weight for the new data element need not be considered in this method.
3) The Nominal Form R unit burden—as the calculated sum of form element burdens—
remains close to the value used to scale the system of form elements (35.7 hours) because
burden associated with form changes are small relative to the overall form burden.
4/28/11

C-4

Appendix C
Maintenance and Update Recommendations
This method does not require periodic updates. The decision on whether an update is necessary
should be made according to the following recommendation:
• For ICR renewals and EAs accompanying major rulemakings: review the form
element categories to ensure proper form element classification. Compare the scaling
basis of 35.7 to the current value assigned to Nominal Form R unit burden.
• For minor EAs and other minor analyses: no update is required.
In the event that the Nominal Form R unit burden undergoes a wholesale update or large change
in its value, the entire Form Element Estimation method must be revised to assure that
Standardized Form Element Burdens proportionately add up to the value of the new Nominal
Form R unit burden.

Table C-1: List of Categories and Corresponding Form Elements
Category

Form Part

Sub Section

Data Element
Name and official title

Certification

PART I. Facility Identification
Information

3: Certification

Signature
Date signed

Chemical
Identification
Information

PART II. Toxic Chemical
Release Inventory Reporting
Form

1.1: CAS Number

Section 1.1: CAS number

1.2: Toxic Chemical or Chemical
Category Name

Section 1.2: Toxic chemical
or chemical category name
Section 1.3: Generic chemical
name
Section 2.1: Generic chemical
name provided by supplier

1.3: Generic Chemical Name
2.1: Generic Chemical Name
Provided by Supplier
5.1: Fugitive or non-point air
emissions
5.2: Stack or point air emissions

Code or
Checkbox for
Readily
Available Info

PART II. Toxic Chemical
Release Inventory Reporting
Form

5.4.1: Underground injection
onsite to Class I wells
5.4.2: Underground injection
onsite to Class II-V wells

B. Basis of estimate
B. Basis of estimate
B. Basis of estimate
B. Basis of estimate

5.5.1A: RCRA Subtitle C landfills

B. Basis of estimate

5.5.1B: Other landfills

B. Basis of estimate

5.5.2: Land treatment/application
farming
5.5.3A: RCRA Subtitle C surface
impoundments

B. Basis of estimate
B. Basis of estimate

4/28/11

C-5

Appendix C
5.5.3B: Other surface
impoundments

B. Basis of estimate

5.5.4: Other disposal

B. Basis of estimate

6.1.A: Total quantity transferred to
POTWs and basis of estimate

6.1.A.2: Basis of estimate

7A.1e: Based on operating data?

7A.1e: Based on operating
data?

5.3: Discharges to receiving
streams or water bodies
6.2: Transfers to other off-site
locations
6.2: Transfers to other off-site
locations

Description of
M/P/OU at
Facility

Description of
Treatment or
Pollution
Prevention
Activity

Description of
Waste Stream at
Facility

PART II. Toxic Chemical
Release Inventory Reporting
Form

8.10: Did your facility engage in
any source reduction activities?
3.1: Manufacture the toxic
chemical
3.2: Process the toxic chemical
3.3: Otherwise use the toxic
chemical
7B: On-site energy recovery
processes

C: Type of waste treatment/
disposal/recycling/energy
recovery
Methods to identify activity
Section 3.1: Manufacture the
toxic chemical
Section 3.2: Process the toxic
chemical
Section 3.3: Otherwise use
the toxic chemical
Energy recovery methods
Recycling Methods

7A: On-site waste treatment
methods and efficiency
8.10: Did your facility engage in
any source reduction activities?

7A.1b: Waste treatment
method(s) sequence

7A: On-site waste treatment
methods and efficiency

7A.1a: General waste stream
(enter code)

4.6
5.2: Parent company's Dun &
Bradstreet number
PART 1. Facility Identification
Information

B: Basis of estimate

7C: On-site recycling processes

4.5

Facility
Identification
Information Codes

B. Basis of estimate

4.8: EPA identification number
(RCRA I.D. No.)
4.9: Facility NPDES permit
number(s)
4.10: Underground injection well
code (UIC) I.D. number(s)
4.1

Source reduction activities

Section 4.5 NAICS Code(s) (6
digits)
Section 4.6: Dunn and
Bradstreet Number(s) (9
digits)
Section 5.2: Parent
company's Dun & Bradstreet
number
Section 4.8: EPA
identification number (RCRA
I.D. No.)
Section 4.9: Facility NPDES
permit number(s)
Section 4.10: Underground
injection well code (UIC) I.D.
number(s)
TRI facility ID number

4/28/11

C-6

Appendix C
Degrees
Minutes
Facility
Identification
Information Geographic

PART 1. Facility Identification
Information

Seconds
4.6: Latitude
Degrees
Minutes
Seconds
Facility or establishment name
Street
City/county/state/zip code
4.1

Facility or establishment name
or mailing address (if different
from street address)
Mailing address

Facility
Identification
Information Name and
Contact

City/state/zip code
PART 1. Facility Identification
Information

Country (non-US)
Technical contact name
4.3

Telephone number
Email address
Public contact name

4.4
Telephone number

Form Type

PART 1. Facility Identification
Information

5.1: Name of parent company

Section 5.1: Name of parent
company

1: Reporting Year

Section 1: Reporting Year

2.1: Are you claiming the toxic
chemical identified on page 2
trade secret?
2.2: Is this copy sanitized or
unsanitized?

Section 2.1: Are you claiming
the toxic chemical identified
on page 2 trade secret?
Section 2.2: Is this copy
sanitized or unsanitized?
Section 4.2: This report
contains information for
(check a or b; check c or d if
applicable)

4.2: This report contains
information for (check a or b;
check c or d if applicable)

4/28/11

C-7

Appendix C

8.1a: Total on-site disposal to
Class I Underground Injection
Wells, RCRA Subtitle C landfills,
and other landfills

8.1b: Total other on-site disposal
or other releases

8.1c: Total off-site disposal to
Class I Underground Injection
Wells, RCRA Subtitle C landfills,
and other landfills

8.1d: Total other off-site disposal
or other releases

Future Year
Projection

PART II. Toxic Chemical
Release Inventory Reporting
Form

8.2: Quantity used for energy
recovery on-site

8.3: Quantity used for energy
recovery off-site

Column C: Following year
Column D: Second following
year
Column C: Following year
Column D: Second following
year
Column C: Following year
Column D: Second following
year
Column C: Following year
Column D: Second following
year
Column C: Following year
Column D: Second following
year
Column C: Following year
Column D: Second following
year
Column C: Following year

8.4: Quantity recycled on-site

Column D: Second following
year
Column C: Following year

8.5 Quantity recycled offsite

Column D: Second following
year
Column C: Following year

8.7: Quantity treated off-site

Column D: Second following
year
Column C: Following year

8.6: Quantity treated on-site

Measure of
Activity at
Facility

PART II. Toxic Chemical
Release Inventory Reporting
Form

8.9: Production ratio or activity
index
4.1

Column D: Second following
year
Section 8.9: Production ratio
or activity index
Section 4.1: Determine
maximum quantity on-site

4/28/11

C-8

Appendix C

PART II. Toxic Chemical
Measure of
Waste/Discharge Release Inventory Reporting
Form
Stream

7A.1c: Range of influent
concentration
5.3: Discharges to receiving
streams or water bodies
7A: On-site waste treatment
methods and efficiency
5.1: Fugitive or non-point air
emissions

7A.1c: Range of influent
concentration

5.2: Stack or point air emissions

5.4.1: Underground injection
onsite to Class I wells
5.4.2: Underground injection
onsite to Class II-V wells

PART II. Toxic Chemical
Release Inventory Reporting
Form

NA
NA
NA

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

7A: On-site waste treatment
methods and efficiency
7B: On-site energy recovery
processes

Quantity
Derived from
Relevant
Section 5 and 6
Data Elements

7A.1d: Waste treatment
efficiency estimate

5.5.1A: RCRA Subtitle C landfills

5.5.4: Other disposal

Optional Data
Element

C. % from stormwater

NA
NA
NA
NA
NA
NA

7C: On-site recycling processes

5.3: Discharges to receiving
streams or water bodies

PART II. Toxic Chemical
Release Inventory Reporting
Form

8.11: If you wish to submit
additional optional information on
source reduction, recycling, or
pollution control activities, check
“Yes.”

Section 8.11: If you wish to
submit additional optional
information on source
reduction, recycling, or
pollution control activities,
check “Yes.”

PART II. Toxic Chemical
Release Inventory Reporting
Form

8.1a: Total on-site disposal to
Class I Underground Injection
Wells, RCRA Subtitle C landfills,
and other landfills
8.1b: Total other on-site disposal
or other releases
8.1c: Total off-site disposal to
Class I Underground Injection
Wells, RCRA Subtitle C landfills,
and other landfills
8.1d: Total other off-site disposal
or other releases

Column B: Current reporting
year
Column B: Current reporting
year
Column B: Current reporting
year
Column B: Current reporting
year

4/28/11

C-9

Appendix C
8.3: Quantity used for energy
recovery off-site
8.5 Quantity recycled offsite
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
5.3: Discharges to receiving
streams or water bodies

Column B: Current reporting
year
Column B: Current reporting
year
Column B: Current reporting
year
Section 8.8: Quantity
released to the environment
as a result of remedial actions,
catastrophic events, or onetime events not associated
with production processes
5.3.1: Stream or water body
name
POTW name
POTW address
City

6.1.B: POTW
State
County
Zip
Receiving
Facility/Site
Identification
Information

Off-site EPA identification
number (RCRA ID No.)

PART II. Toxic Chemical
Release Inventory Reporting
Form

Off-site location name
Off-site address
City
6.2: Transfers to other off-site
locations

State
County
Zip
Country (non-US)
Is location under control of
reporting facility or parent
company?

Release
Quantity
Estimated Using
Emissions
Factors
Release
Quantity

PART II. Toxic Chemical
Release Inventory Reporting
Form

5.2: Stack or point air emissions

A. Total release

PART II. Toxic Chemical
Release Inventory Reporting

5.5.1A: RCRA Subtitle C landfills

A. Total release

4/28/11

C-10

Appendix C
Estimated Using
Facility Records

Form

5.5.1B: Other landfills
5.5.3A: RCRA Subtitle C surface
impoundments
5.5.3B: Other surface
impoundments
5.5.4: Other disposal
6.2: Transfers to other off-site
locations
5.4.1: Underground injection
onsite to Class I wells
5.4.2: Underground injection
onsite to Class II-V wells
5.5.2: Land treatment/application
farming
6.1.A: Total quantity transferred to
POTWs and basis of estimate
5.3: Discharges to receiving
streams or water bodies

Release
Quantity
Estimated Using
Physical and
Chemical
Properties of
Chemical and
Process
Operating
Conditions

SRR with No
Relevant
Section 5 and 6
Data Elements
Current Year

Value Reported
in Prior Year

PART II. Toxic Chemical
Release Inventory Reporting
Form

A. Total release
A. Total release
A. Total release
A. Total release
A: Total transfers
A. Total release
A. Total release
A. Total release
6.1.A.1: Total transfers
A. Total release

5.1: Fugitive or non-point air
emissions

A. Total release

8.2: Quantity used for energy
recovery on-site

Column B: Current reporting
year

8.4: Quantity recycled on-site

Column B: Current reporting
year

8.6: Quantity treated on-site

Column B: Current reporting
year

Column A: Prior year

4/28/11

C-11

Appendix C
8.2: Quantity used for energy
recovery on-site
8.3: Quantity used for energy
recovery off-site

Column A: Prior year
Column A: Prior year

8.4: Quantity recycled on-site

Column A: Prior year

8.5 Quantity recycled offsite

Column A: Prior year

8.6: Quantity treated on-site

Column A: Prior year

8.7: Quantity treated off-site

Column A: Prior year

4/28/11

C-12

Appendix C
Table C-2: Standardized Form Element Burden Categories (Raw Estimate Means and
Standard Deviations)
Number of Data
Elements

Category

Time
(Hours)
Mean
NA
0.0023
0.0096
0.0023

St Dev
NA
0.0000
0.0008
0.0000

3
Certification
4
Chemical Identification Information
15
Code or Checkbox for Readily Available Info
3
Description of M/P/OU at Facility
Description of Treatment or Pollution Prevention
4
0.6481
0.3502
Activity
1
0.1620
NV
Description of Waste Stream at Facility
4
0.0023
0.0000
Facility Identification Information - Codes
Facility Identification Information - Name and
14
0.0023
0.0000
Contact
4
0.0058
0.0023
Form Type
20
0.0301
0.0000
Future Year Projection
2
0.9444
0.1113
Measure of Activity at Facility
2
0.4157
0.4995
Measure of Waste/Discharge Stream
13
0.0046
0.0000
NA
1
0.0000
NV
Optional Data Element
Quantity Derived from Relevant Section 5 and 6 Data
8
0.1458
0.0000
Elements
16
0.0077
0.0044
Receiving Facility/Site Identification Information
Release Quantity Estimated Using Emissions
1
1.8795
NV
Factors
6
1.8100
0.4408
Release Quantity Estimated Using Facility Records
5
1.8810
0.2740
Release Quantity Estimated Using Monitored Values
Release Quantity Estimated Using Physical and
1
3.2636
NV
Chemical Properties of Chemical and Process
Operating Conditions
SRR with No Relevant Section 5 and 6 Data
3
0.8564
0.0000
Elements Current Year
10
0.0093
0.0000
Value Reported in Prior Year
NV indicates a value could not be calculated because there is only one data element in the category or
because total raw time is zero.

4/28/11

C-14

Appendix C
Table C-4: Example Evaluation of Options for Scaling, by Category

Internal
Consistency

Parsimony

Intuitive
Calculations

Temporal
Consistency

Option 1:
Raw Estimates/No
Incidence Weighting
(Sum of data elements=
21.43 hours)

Option 2:
Incidence Weighting
Included
(Sum of data
elements= 7.06 hours)

Rank
(1-3)

Comments
More consistent
with old method
(compared to
incidence
weighted
estimates.)

Easiest to
generate using
existing
engineering
burden
estimates.

Based on real
world experience
with form.

ICR Renewal
Implications

Would be adding raw
engineering estimate
to back calculated
nominal. Different
bases.

EA
Implications

Need to show nonincidence weighted
burden in EA.

Overall Rank

1.83

Comments

Requires
information on
how often data
elements are
filled out in a
given year.
Will have year
to year
variation.

Reflects the
reality that not
all facilities fill
out all data
elements.

Requires
information on
how often data
elements are
filled out in a
given year.
Will have year
to year
variation.

Option 3:
Scaled to Equal
Nominal Form R for
Raw or Incidence
Weighted
(Sum = 35.7 hours)
Rank
(1-3)

Comments

More
consistent with
the new
method moving
forward.

Simply scaling
from base.

Modeled
estimate.

More
consistent with
the new
method moving
forward.

Consistent with
reporting burden
for entire form
(nominal form
burden.)

Can scale both raw
and incidence
weighted.

2.5

1.66

Option 4:
Scaled to Equal
Nominal Form R
Proportion of
Calculations and
Form Completion
(Sum = 20.4 hours)
Rank
Comments
(1-3)
Equally
consistent as
Option3, but
more
NA
consistent
with total
form unit
burden

Simply
scaling from
base.

requires
explanation,
given
expectation
that elements
should add to
total Form
burden

More
consistent
with the new
method
moving
forward.

Consistent with
reporting burden
for appropriate
portion of entire
form (nominal
form burden.)
Can scale both
raw and
incidence
weighted.

4/28/11

C-15

Appendix C

4/28/11

C-16

Appendix D
First-Time Filer Estimation
This appendix presents the First-Time Filer Estimation method of the Ratio-Based Burden
Methodology (RBBM). As explained in Appendix A, first-time filer burden accounts for the
elevated level of effort that reporters incur during a start-up year. The existing method estimates
first-time filer burden in two instances. For ICR renewals, first-time filer burden is estimated as
part of total Program burden to account for new entrants to the reporting community in any given
reporting year. In RBBM terms, this estimate has a small effect on the Steady State Total Burden
Calculation. Second, first-time filer burden is used in economic analyses (EAs) supporting
rulemakings to evaluate the start-up effect of a policy or regulatory change to the TRI reporting
requirements, for example, when a new sector is added to the reporting community. As noted in
Appendix A, however, in the Ratio-Based Burden Methodology (RBBM), first-time filer burden
now applies to calculating EA start-up burden only, as it was shown to be negligible in the
overall Steady State Total Burden Calculation. First-Time Filer Estimation, as presented in
Appendix A, is envisioned as working in conjunction with estimates of steady state burden as
follows:
First-Time Filer Burden = FTFf * Relevant Steady State Total Burden
Model Development for ICR Renewal Burden
As stated in Appendix B, neglecting the impact of first-time filing in the steady state estimate is
justified mathematically because treating the relevant 3% of TRI chemical reports as steady state
filers instead of first-time filers decreases the Steady State Total Burden estimate by .04%, based
on 2008 ICR Renewal conditions. Therefore, with respect to ICR renewal burden estimates and
the Steady State Burden Calculation, EPA has concluded that incorporating first-time filer
burden has a negligible influence (see Appendix B).
Model Development for Economic Analysis Burden
In the context of EA work, EPA must estimate the incremental steady state and first-time impacts
that a policy or regulatory change would have on TRI reporting. Depending on the proposed
change, it may have significant first-time impacts when new reporters enter the TRI reporting
universe or when existing reporters complying with a new aspect of TRI reporting are getting up
to speed with the new policies or requirements. Therefore, when estimating the incremental
impacts associated with a policy change or rulemaking, first-time filer burden must be estimated.
It should be noted that first-time filer burden is a transient effect that will decrease to steady state
burden levels in the second year.
First-Time Filer Model
Under the existing methodology, first-time burden is estimated using the same method as that
used for steady state burden, i.e., using the two complex matrices and a separate count for firsttime filers. As described in Appendix A, the Steady State Total Burden Calculation simplifies
these calculations using ratio models and unit burdens from Abt Associates Engineering Studies.
Using the same development process, EPA provides internal consistency between estimates for
first-time and steady state reporting, as defined by the First-Time Filer factor, FTFf):
4/28/11

D-1

Appendix D

Ratio of First-Time Burden to
Steady State Burden

[=]

_First-Time Hours__
Steady State Hours

Computed using the factor matrices for Form R presented in Appendix A: 1
4

FTFf = ( ∑
i =1

∑
j =1

[first year factors from F′′i,j] / ( ∑
i =1

∑

[subsequent year factors from F′′i,j ]﴿

j =1

The FTFf is developed using the ratio of the burden associated with first-time Form R reporting
activities to the burden associated with steady state Form R reporting activities. See Appendix
A’s Eqn A-9 and Table A-4 for the model’s specific calculation.
Findings
The recommended value for the First-Time Filer Factor, FTFf , is 2.1 hr/hr, based on Form R
factors. EPA estimated the FTFf separately for Form R and Form A using several model
assumptions and distribution conditions similar to the design for A/R tests described in Appendix
B. Following Decision Rule #2 on page 10 of the main report, the Form R basis is used to apply
for all instances in which first-time filing is estimated, given that the additional complexity of
incorporating the Form A basis is unmerited. Table D-1 supports this decision as the difference
in estimates based on Form R (FTFR) versus those based on Form A (FTFA) do not differ
substantially.

Where i denotes the row and j denotes the column from the Matrix F′′ in Appendix A.

4/28/11

D-2

Appendix D
Table D-1: Estimation of First-Time Filer Factor for Form R and Form A
(2)
Same as (1), but
without Firsttime filer
adjustment

(3)
Same as (1),
but without
incidence rate
adjustments

(4)
Same as (1),
but without
distribution
specificity*

(5)
RECOMMENDED
-realistic
estimates with
incidence rate
adjustments**

(6)
Robustness
Test alternate
distribution***

12.66
Model Form A unit burden (hrs/single
-chemical Form A)

12.52

27.24

12.67

12.52

12.53

7.76

7.67

13.16

7.95

7.71

7.67

2.05

Test Run
Description

(1)
REFERENCE
no
simplifications

Model Form R unit burden (hrs/Form
R)

FTFR

2.05

1.67

2.08

2.05

2.06

FTFR % difference from Reference

0.00

-18.66

1.31

0.00

0.49

FTFA

2.66

2.51

2.14

3.28

2.66*

2.53

A/R

0.613

0.612

0.483

0.628

0.615

0.612

A/R % difference from Reference
-0.12
-21.22
2.41
0.39
0.50
* Does not account for potential double counting of facility level burden among facilities reporting both Form Rs and Form As.
**Current A, R, A+R distributions, no first-time filer adjustments. Based on the same conditions as for column 5 in Tables B-3 and B-4. See Eqn
A-12 for FTF derivation.
***Phase 2 Burden Reduction Rule.
Note: FTFA is only 23% higher than FTFR. According to Decision Rule # 2 in the main report Form R basis is used when complexity of Form A
basis is unmerited.

Method Summary
Computation
For first-time incremental burden: As noted above, first-time filer burden is only addressed in
the context of calculating EA start-up burden. Specifically, in any EA supporting a regulatory or
policy change, there will be costs incurred only in the first year of the change, in addition to the
sustained steady state costs associated with the change. Take, for example, the recent TRI
rulemaking adding 16 chemicals to the list of reportable chemicals. To estimate first-time filer
burden, the analyst will combine information on the unit burden associated with the filing of
forms for the new chemicals, the number of new chemicals and the FTFf . Note that in this
rulemaking, reporters are not expected to file Form As for any of the new chemicals. The analyst
would estimate first-time filer burden for the additional 186 Form Rs that are expected to be filed
as follows:
Eqn D-2: Total first-time filer burden associated with the rule adding 16 chemicals to TRI =
= FTFf *(Form R Relevant Steady State Burden for New Chemicals + Form A Relevant
Steady State Burden for New Chemicals)
4/28/11

D-3

Appendix D
= FTFf * (Nominal Form R unit burden* # New Form R chemicals + [(A/R) * Nominal
Form R unit burden] * # New Form A chemicals)
= 2.1*(35.7*186 + [.615*35.7]* 0)
= 13,944 hours
This first-time filer burden estimate will be reported in the EA along with steady state burden as
an estimate of the total burden associated with TRI reporting created by the proposed regulatory
or policy change.
Assumptions
Use of the FTF model for estimating first-time filer burden relies on the following assumptions:
• First-time and steady state burden as currently identified in the Abt Associates
Engineering Studies estimates for Form R is a reasonable reflection of the amount of time
it takes to complete reporting activities for the first-time relative to the steady state for
TRI reporting.
• The relationship between first-time and steady state burden does not vary between the
steady state and policy/regulatory change scenarios or across policy/regulatory change
scenarios.
• Relationships between reporting activities in the Abt Associates Engineering Studies that
are drawn from a subpopulation are reasonably reflective of the true relationships in the
total reporting population, as measured by the best professional judgment of Abt
Associates’ engineers.
Maintenance and Update Recommendations
The FTF model/method requires no maintenance. However, EPA notes that the FTF formulation
is dependent on the conversion factors used to rescale facility-level unit burdens to (per
chemical) form level. As shown in Appendix B, even in the face of dramatic shifts in
distribution, Equivalent Form R/A Chemicals per Facility are reasonably robust, within about
10%. However, in the event that the program adds industry sector(s), the (per chemical)
form/facility distribution could shift due to the addition of large chemical counts of substantially
different distributions of (per chemical) form type and/or number of chemicals per facility.
As a practical matter, given the requirements for ICR renewal reporting, periodic recalculations
of the Equivalent Form R/A Chemicals per Facility will be regularly available and can be
checked to be sure that this basis for the FTFf model (and others—A/R and WAWR) is still valid.
EPA recommends this routine check.

4/28/11

D-4

Appendix E
Cost Conversion
This appendix presents the Cost Conversion method of Ratio-Based Burden Methodology
(RBBM), including the weighted average wage rate (WAWR). WAWR provides and alternative to
separately computing wages for the three labor categories, Managerial, Technical and Clerical,
with each ICR renewal or rulemaking and instead specifies one up-front Cost Conversion
incorporating all three labor categories. As presented in Appendix A, this method is envisioned
as working primarily in conjunction with estimates of steady state burden as follows:
Eqn. E-1: Steady State Total Cost = (Steady State Total Burden)*WAWR
It should be noted that this method is the only method in the Ratio-Based Burden Methodology
(RBBM) that calibrates with updates to actual economic conditions, given the availability of
quarterly current wage data from the Bureau of Labor Statistics (BLS). It should also be noted
that this method uses information from the Abt Associates Engineering Studies to set the relative
proportions of each labor category reflecting current technology conditions. As with other
similarly developed models (A/R, FTE), updates may be required in the event that large changes
in the distributions of form counts/types across facilities affect the conversion factors (Equivalent
Form R/A Chemicals per Facility). Unlike these other models, which have no impact on
transitional baseline continuity, the WAWR under RBBM induces a slight one-time decrease
(5%) to the baseline for the total cost estimate, while not affecting the relevant burden hour
estimate.

Weighted Average Wage Rate (WAWR) Models
The WAWR ratio model determines costs associated with burden hour estimates, as defined by:
WAWR (Weighted Average Wage Rate):
Average loaded cost for a mix of managerial,
technical and clerical labor per hour of TRI
reporter burden

[=]

Current $/Hour

This model uses one wage rate that reflects an average estimate for all labor categories as
opposed to three different wage rates. The weighted hourly wage rate is developed by
combining the relative contribution of each labor category to total burden with current hourly
wages.
Procedure
As an example, to compute the steady state costs for Form R : 1

Form R burden only is used for initial illustrations, with verification of assumptions that the same bases apply to
Form A and steady state total costs. See key analytical decisions in this Appendix. For additional details on Form
R/A burden, and Steady State Total Burden calculations, see Appendix B.

4/28/11
E-1

Appendix E
Eqn. E-2: Form R Cost = Form R Burden Hours* WAWR
The WAWR for year YR is calculated as follows:
Eqn. E-3: WAWRYR = (pm * $/hr m,YR ) + (pt * $/hr t,YR ) + (pc * $/hr c,YR)
Where
WAWRYR =

WAWR in current dollars for year YR

pm, pt, pc =

proportions of the reporting burden for each labor
category, managerial, technical and clerical.

$/hr m,YR, $/hr t,YR, $/hrc,YR =

The wage rates for managerial, technical and clerical
labor for year YR, in current $/hour.

For Form R, as in Form A, and the Total Cost calculation, the proportions are constant, providing
fixed weights to the weighted average calculation:
Eqn. E-4: WAWRYR = (.03 * $/hr m,YR ) + (.89 * $/hr t,YR ) + (.08 * $/hr c,YR)
In this method, the burden is calculated in total and then multiplied by WAWR. Note that each
labor category wage rate must be obtained for the quarter and year of interest.
Method Development
The key analytical decisions for developing this method include:
1. Specifying the set of fixed weights that represent the proportion of the reporting burden
for each labor category: two options were considered: 1) weights developed using the
unit burden estimates from the existing methodology, or 1) weights developed using the
Abt Associates Engineering Studies. The fixed weights for Managerial, Technical and
Clerical labor categories are 0.03, 0.89 and 0.08, based on the Abt Associates
Engineering Studies, and 0.25, 0.68 and 0.07, based on the existing methodology,
respectively. Both sets of weights were derived using Form R burden as a basis (see
Decision Rule #2 on page 10 of the main report).
2. Determining if one WAWR can be used to convert From R, Form A, and total burdens to
costs. This determination involved verifying the assumption that a Form A WAWR is not
substantially different from a Form R WAWR in order to be able to use a standardized
form WAWR for calculating required for Form R. It also involved verifying that the same
WAWR could be applied to total burden to obtain total cost.
3. Recommending an update frequency.
Analyses to support these decisions are presented in order. The first set of analytical decisions
specifies the basis for the proposed fixed weights for proportions of each labor category. Should
EPA use existing methodology’s proportions or those implied by the Abt Associates engineering
estimates? Although RBBM has fully justified using the Abt Associates Engineering Study unit
4/28/11
E-2

Appendix E
burdens in ratio models (see Appendix B), in this particular method, the practice will induce a
slight (5%) one-time baseline shift of $2.65/hour, from $52.27/hour (using the existing
methodology) to $49.62/hour using RBBM. For many of the same reasons that the revised
methodology uses the Abt Associates Engineering Studies unit burdens for A/R and FTF, they
are preferred for WAWR as well. Advantages include internal consistency and the fact that these
estimates were made in 2004, reflecting technology advances since program inception. EPA
concludes that the slight one-time baseline shift for cost is acceptable, given the relative merits of
using the same building blocks used throughout RBBM.
Consequently, the WAWRs used for RBBM have a modified formulation from that of the existing
method because the RBBM fixed weights are derived using Abt Engineering Studies.. Recall that
the OMB-approved implied weights are 0.25, 0.68, and 0.07 and that RBBM weights are 0.03,
0.89, and 0.08 (see Appendix A, Table A-4 for a breakdown by activity). The resultant RBBM
weights as they apply to Form R reporting are presented in Table E-1 below.
Table E-1
Subsequent Year Reporting Burden – Per Form R Chemical
Activity
Management
Technical
Clerical
Rule Familiarization
0
0
0
Compliance Determination
0.069*
0.275*
0*
Calculations and Form Completion
0.320
6.890
0.0
Recordkeeping
0.000
4.000
1
Total Form level burden
0.389
11.165
1
Weights
0.03
0.89
0.08
*Facility-level factors converted to form (per chemical)-level factors via Equivalent Form R Chemicals
per Facility (3.87) See Eqn A-10 and Tables A-3 and A-4.
Source: Table A-3, Abt Associates Engineering Studies (see Appendix B and references in Appendix G)

The second set of analytical decisions verifies that the derived Form R WAWR weights may be
used for Form R burden, Form A burden, and total burden.
An analysis similar to the one presented in Table E-1 was conducted based on Form A, as
derived from Form R, for reporting activities resulting in management, technical, and clerical
weights of 0.03, 0.84 and 0.13, compared to Form R proportions of 0.03, 0.89 and 0.08,
respectively. EPA concluded that Form A weights are similar enough to Form R weights to allow
use of the Form R weights when computing Form A costs.
To assess WAWR’s applicability to total burden, EPA then analyzed the effect of using the Form
R WAWR to calculate total TRI reporting costs. EPA found that using the Form R based WAWR
yields total cost estimates that are less than 0.2% higher than a total cost calculation that uses
separate Form R and Form A WAWRs. Additionally, differences incurred by incorporating nonform burden are negligible. 2

This finding is based on an analysis of the per form comparable proportion of burden attributable to management,
technical, and clerical under the following two scenarios: Total reporting burden (including non-form activities such
as supplier notification and petitions) and form-related reporting burden only. In scenario one: total reporting
burden, the weights are as follows: 24 management, .66 technical, and .09 clerical. In scenario two: form-related

4/28/11
E-3

Appendix E

Given the findings from these two analyses, EPA concludes that the Form R WAWR is equally
applicable to Form R, Form A, and Steady State Total Cost estimates, using the weights for
Form R for each labor rate category. To compute WAWR, the cost of each activity by labor
category is developed by combining the burden in hours with hourly wage rates for the
appropriate labor category. An example calculation is presented in Table E-2.
Table E-2
Derivation of Weighted Average Wage Rate ($/hour), June 2010
Managerial
Technical
Clerical
Total Loaded Rate
$62.29
$51.37
$25.24
Weights
0.03 (3%)
0.89 (89%)
0.08 (8%)
Average Wage (weighted)
$49.62*
Source: http://www.bls.gov/news.release/ecec.t11.htm
Note: For comparison, the Form A weighted average wage is $48.30.
* Individual numbers may not result in the total due to rounding.

The weighted average loaded hourly wage rate across the three labor categories was $49.62 in
June 2010. This weighted average rate is applied to the total number of hours needed to complete
Form R and Form A (Nominal Form R and Form A unit burden where Form A unit burden is
derived from Form R unit burden using the A/R model) to estimate the unit cost per form. The
cost per form is then applied to the total TRI total burden to estimate the total TRI reporting cost.
The third analytical decision involves recommending the frequency of updating the method.
Since the information on wage rates is published quarterly by the Bureau of Labor Statistics
(BLS), updates to the WAWR should be made accordingly.
Findings
The RBBM-consistent basis using Abt Associates engineering estimates are preferred for
weighting labor categories within WAWR, for the same reason they are the basis for A/R and
FTF. They provide benefits of internal consistency and reflect more current conditions with
technology advances.

Method Summary
Computation
To update the WAWR for an ICR renewal or a major rulemaking, the following steps are
involved:

reporting burden only, the weights are as follows: 25 management, .68 technical, and .07 clerical. Both calculations
use 2008 ICR renewal estimates.

4/28/11
E-4

Appendix E
1. Obtain employer cost current wage rates for total and salary compensation 3 from BLS
for three labor categories: Managerial, Technical and Clerical labor. 4 Adjust each
upward to account for non-wage compensation: 17% overhead, 43.4% benefits.
2. Compute the weighted average wage rate, using the fixed weights reflecting burden
hours (0.03, 0.89 and 0.08) 5 to calculate the current WAWR2010 (e.g., $49.62/hour for
June 2010).
The following equation presents the estimation of total burden when updating the WAWR for an
ICR renewal or a major rulemaking using current wages from BLS (see Eqn B-2 for reference
regarding Steady State Total Burden).
Eqn. E-5:
Steady State Total Cost = Steady State Total Burden * WAWR2010
Steady State Total Cost = (Nominal Form R Unit Burden*# Form R Chemicals +
[Nominal Form R Unit Burden*(A/R)*# Form A Chemicals] + Non-Form
Burden)*WAWR2010
Total Cost
= (35.7*# Form R Chemicals + [35.7*.615*# Form A Chemicals] + 825,517)*
WAWR2010
Where WAWR2010 is calculated using Eqn. E-4 and the latest 2010 wage rates from BLS:
WAWR2010 = (.03 * $/hr m,2010) + (.89 * $/hr t,2010) + (.08 * $/hr c,2010)
Assumption
Wage rate proportions in WAWR of .03 for managerial labor, .89 for technical labor, and .08 for
clerical labor are reasonable estimates of actual conditions, on average, for the overall reporting
community.
Maintenance and Update Recommendations
Update WAWR in every burden estimate for which new information from BLS is available
(quarterly updates). The fixed weights of WAWR require no maintenance. However, EPA notes
that the values of these weights are dependent on the conversion factors used to rescale facilitylevel unit burdens to (per chemical) form level. As shown in Appendix B, even in the face of
dramatic shifts in distribution, Equivalent Form R/A Chemicals per Facility, within about 10%.
However, in the event that the program adds industry sector(s), the (per chemical) form/facility
3

Note that benefits may be calculated as the difference between total and salary compensation on a quarterly basis
(e.g., WAWR benefits are 43.4% of compensation for June 2010).
4
Corresponding BLS titles: Managerial = Management, business, and financial; Technical = Professional and
related; Clerical = Office and administrative support.
5
See calculation components and results in Table E-1.

4/28/11
E-5

Appendix E
distribution could shift due to the addition of large chemical counts of substantially different
distributions of (per chemical) form type and/or number of chemicals per facility.
As a practical matter, given the requirements for ICR renewal reporting, periodic recalculations
of the Equivalent Form R/A Chemicals per Facility will be regularly available and can be
checked to be sure that this basis for the fixed weights of the WAWR model (and others—A/R
and FTFf) are still valid. EPA recommends this routine check.

4/28/11
E-6

Appendix F
Program Staff Tool

F-1

4/28/11

Appendix F

DIRECTIONS:
The pink fields are user input cells. Your final estimates will be displayed in the dark green cells on this page. To see calculations and variables used in the
interface, including models and accounting parameters, refer to the “Reference Information” tab. If you need to change or add form elements, refer to
instructions and data under the “Form Element Estimates” tab.
DEFINITIONS:
Steady State Burden (SS) - estimate of ongoing Program burden, including permanent impacts from rulemakings, but absent first-time filer burden
First Time Filer Burden (FTF) - estimate to account for start-up burden incurred during the first year of a policy change
Weighted Average Wage Rate (WAWR) - consolidated wage rate that incorporates relevant proportions of managerial, technical, and clerical labor
Form R and Form A unit burdens - comprehensive unit burdens that incorporate all aspects of per chemical form-related burden, including: rule familiarization,
compliance determination, calculations and form completion, and recordkeeping and submission
Section 1: UNIT BURDEN
1. If you are adding form elements for this analysis, estimate the burden of these new elements using the procedure in the "Form Element Estimates" tab. Then
enter the sum of these estimates into the "Additional Burden per Form" user input cell. Note that for added form elements that only affect a subset of forms, we
do not discount based on incidence rate.
2. If you do not have additional form elements for this analysis, make sure the number in the "Additional Burden per Form" cell is 0.
Note: The newly calculated Form R Unit Burden will be used to calculate both total Form R and total Form A burden.
Section 2: CHEMICAL COUNTS
Complete this section according to whether you are estimating the full model (ICR) or incremental model (EA).
In the case of an ICR, enter the number of chemicals reported by Form A and Form R, or in the case of an EA, enter the change in the number of chemicals
reported by Form A and Form R in the "Incremental Change" input cells in Section 2.
Section 3: STEADY STATE BURDEN ESTIMATES
This section displays the final estimates in the dark green cells. For an ICR use the "Final Totals" and for an EA use the "Final Incremental Change."
Section 4: FIRST YEAR ADDITIONAL BURDEN DUE TO FIRST-TIME FILERS (FTF)
For EAs that initiate policy change that in turn causes a startup burden for first-time filers (FTF), enter the number of additional Form R and Form A chemicals
in this section to determine this burden due to FTFs.

F-2

4/28/11

Appendix F
Key
Models (see reference tab)
User inputs
Calculated numbers
Final estimates
Intermediate Calculations
Helpful hints

USER INPUTS AND MODELS

Section 1: UNIT BURDEN

ESTIMATES
Additional
Burden per
Form

Starting Point

Form R unit burden (hours per form)
Form A unit burden (hours per single-chemical
form)
Form A unit burden = (A/R) * Form R unit
burden

New Form R Burden Total

35.7

22.0

Section 2: CHEMICAL COUNTS
Number of Chemicals

Incremental
Change

Starting Point

Chemicals Total

Number chemicals reported on Form R

81,382

Number of chemicals reported on Form A
Note: Form A is units of chemicals rather than
responses

9,284

F-3

4/28/11

Appendix F

Section 3: STEADY STATE BURDEN ESTIMATES
Hours of Form Burden

Incremental
Change

Starting Point

Total Form R Burden (hrs)
Total Form A Burden (hrs)
Total Non-form Burden (hrs)

2,905,337
203,835
825,517

+
+

New Burden Hours
Total
0
0

=
=

2,905,337
203,835
825,517

Note: Incremental change numbers in
section 3 include new forms and any
changes in form unit burden.

Final
Incremental
Change

Totals and Cost Conversion
WAWR (current $/hr)
Total Burden (hrs)
Total Cost (dollars)

Final Totals

49.62
(Total Burden in hrs) * (June 2010 $
WAWR) =

Section 4: FIRST YEAR ADDITIONAL BURDEN DUE TO FIRST
TIME FILERS (FTF)
# of chemicals reported on Form R for
FTFs
# of chemicals reported on Form A for
FTFs

3,934,689

$195,231,097

Incremental
Change

0
0

FTF Form R Burden (hrs)

Form R Unit Burden * FTF # Form R Chemicals *
FTF Factor =

FTF Form A Burden (hrs)

Form A Unit Burden * FTF # Form A Chemicals *
FTF Factor =

FTF Total Burden (hrs)
FTF Total Cost (dollars)

(FTF Burden in hrs) * (June 2010 $ WAWR)=

F-4

0
$0

4/28/11

Appendix F

Reference Equations and Model Values
Equations used in Estimator:
Total Burden = Form R Burden + Form A Burden + NonForm 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)
NonForm Burden = (Petitions) + (Supplier Notification) + (Non-Reporters’ Burden)
Total Cost = Total Burden * (WAWR)
Where:
WAWR is the weighted average wage rate in current dollars/hr
First Time Filer Burden = (FTFf * relevant steady state burden)
Where:
FTFf = the first time filer factor
relevant steady state burden = [(# new Form R chemicals * Nominal Form R unit burden)] + [(# new Form A chemicals * Nominal Form R unit
burden * (A/R))]

F-5

4/28/11

Appendix F
Table 1. Values used in Estimator
Update Frequency

Last Updated

Name
Value
MODEL PARAMETERS

According to Tolerances

May 2010

A/R Model

0.615

None by Schedule

May 2010

Petitions

925

hrs

None by Schedule

May 2010

89,616

hrs

None by Schedule

May 2010

734,976

hrs

According to Tolerances

May 2010

Quarterly
As Form Changes are
Implemented in Rulemakings
and ICRs (note: verify
Rulemaking estimates at ICR)

June 2010

Feb 2011
Feb 2011

At Every ICR

Feb 2011

Supplier
Notification
Non-Reporter
Compliance
Determination
First Time Filer
Factor (FTFf)

=
2.1
WAWR

Units

hrs/hrs

Weighted
Average Wage
Rate (WAWR)
=
$49.62
$/hr
REFERENCE INFORMATION

Nominal Form R
Unit Burden
Form R
Chemicals per
Facility
Form A
Chemicals per
Form

35.7

hrs

3.68

chems/facility

2.31

chems/Form A

Description
A ratio of burdens for single-chemical Form A
to Form R.
Non-form burden, assumes 5 petitions per year
185 hours per petition.
Non-form burden, can apply to any facility but
basis is 24 hours per reporting facility as of
2008 ICR.
Non-Form burden, assumes 4 hours
compliance determination to all in NAICS with
over 10 employees as of 2008 ICR.
A ratio of the first-time filer burden to steady
state burden.
Dollars per hour ratio that incorporates
managerial, technical, and clerical labor rates.
Note: to update the WAWR, refer to the
guidance below.

Current Base number for Form R burden, given
the form elements approved at most recent
action (ICR or Rulemaking).

Based on number of chemicals per facility.
Based on number of chemicals per form, which
is assumed to be number of chemicals per
facility.

Guidance to Update the WAWR:
The WAWR is a dollar per hour ratio that is based on the managerial, technical, and clerical labor rates from the Employer
Cost for Employee Compensation Economic update published quarterly by the BLS.
To update the WAWR with the latest data from BLS, enter the most recently published values for Total Compensation and
Wages and Salaries in the table titled Employer Cost for Employee Compensation under the appropriate date. The
Benefits column will automatically calculate the Benefit amount for each labor type. The table titled WAWR will then
generate the new WAWR and present it under the appropriate date.
To use the new WAWR in the Estimator tab, update the reference formulas for $/hr and date in cells F30 and C30 to link to
the new WAWR and date. (For example, when updating to a September 2010 WAWR, cell F30 would be linked to F60
and cell C30 would be linked to F56.)

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Appendix F
Table 2. WAWR Calculation
WAWR
Date
Managerial
Technical
Clerical

December 2009
$61.42
$50.51
$24.99

March 2010
$62.32
$51.17
$25.22

June 2010
$62.29
$51.37
$25.24

$48.81

$49.44

$49.62

WAWR

EMPLOYER COST FOR EMPLOYEE COMPENSATION
Date
December 2009
Wages
Compensation
Total
and
Benefits
Component
Compensation
Salaries
Managerial
$54.91
$38.30
$16.61
Technical
$45.04
$32.16
$12.88

March 2010
Wages
Total
and
Compensation
Salaries
$55.73
$38.75
$45.63
$32.59

September 2010

Benefits
$16.98
$13.04

June 2010
Wages
Total
and
Compensation
Salaries
$55.69
$38.84
$45.81
$32.73

Benefits
$16.85
$13.08

Clerical
$22.33
$15.65
$6.68
$22.55
$15.73
$6.82
$22.56
$15.75
$6.81
Note: Corresponding BLS titles: Managerial = Management, business, and financial; Technical = Professional and related; Clerical = Office and administrative
support. Total Compensation and Wages and Salaries data is taken directly from ECEC, while Benefits data is derived from the ECEC data.
Source: Employer Cost for Employee Compensation, Table 9. BLS.
September 2010
Wages
Total
and
Compensation
Salaries

Benefits

OVERHEAD
17%
LABOR BURDEN WEIGHTS
Managerial
Technical

0.03
0.89

Clerical

0.08

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Appendix F

FORM R

EPA

TRI Facility ID Number

FORM R
United States
Environmental
Protection Agency

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 1513
Lanham, MD 20703-151

Toxic Chemical, Category or Generic Name

2. APPROPRIATE STATE OFFICE
(See instruction in Appendix E)

Revision (enter up to two codes(s))
Withdrawal (enter up to two code(s))
This section only applies if you are
revising or withdrawing a previously
submitted form, otherwise leave bank.
IMPORTANT: See instructions to determine when “Not Applicable (NA)” boxes should be checked.
PART 1. FACILITY IDENTIFICATION INFORMATION

NOTE:
For further details of this form image see Appendix A, Figure A-2.

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Appendix G
Abt Associates Engineering Studies
1) TRI Reporting Burden Estimates, Memo from Hilary Eustace, David Cooper, Susan Day, Abt
Associates to Paul Borst, EPA, July 16, 2004
2) Modified TRI Reporting Burden Estimates for Rule Familiarization, Compliance
Determination, and Form Completion from Susan Day, Abt Associates to Laura Nielsen, EPA,
December 2, 2010

NOTICE
Abt Associates Engineering Estimates in Ratio-Based Burden Methodology (RBBM)
As explained in Methodology History, the Abt Associates engineering estimates were proposed
in 2004, but neither finalized nor formally adopted into TRI burden estimation practice. In this
methodology revision and in the formulation of RBBM, EPA uses the estimates for a different
purpose than originally intended. Instead of using Abt Associates engineering estimates as a
basis for absolute values (i.e., the Nominal Form R unit burden), RBBM uses the estimates to
construct ratio models of key relationships (e.g., A/R), thereby only relying on the relative values
of the estimates and not absolute values.

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Appendix G

MEMORANDUM

TO:

Paul Borst, U.S. EPA

FROM:

Hilary Eustace, David Cooper, Susan Day

DATE:

July 16, 2004

RE:

TRI Reporting Burden Estimates

1. INTRODUCTION
EPA currently relies on previously developed OMB approved TRI reporting burden estimates
that reflect the total time required by facilities to complete activities such as rule familiarization,
compliance determination, form completion, record keeping/mailing, and supplier notification.
While form completion reporting burden estimates have been prepared for completion of the full
Form R, the total time is not broken down by the individual data elements that make up the form.
Data element specific burden estimates would allow for informed assessments and comparisons
of proposed TRI burden reduction methods as well as any future proposed Form R
modifications. In this memo, burden estimates are derived for every data element on the Form R
based on the activities TRI reporters undertake to complete each data element as well as the time
estimates for technical, managerial, and clerical staff at a typical facility to conduct these
activities. During the last TRI ICR renewal, EPA referenced industry data suggesting that TRI
reporting burden is lower than previously estimated. While the newly negotiated burden
estimates were revised downward for non-PBT chemicals, they were not lowered by as much as
EPA proposed. Furthermore, PBT chemical reporting burden was not lowered at all. The OMB
approved reporting estimates are presented in Table 1. The data element specific burden
estimates presented in this memo are estimated first to reflect the time it actually takes the typical
facility to fill out each data element. This burden is referred to as the “realistic burden.” Second,
the data element specific realistic burden estimates are scaled up so that summing them yields
the OMB approved burden estimate of form completion. Several sets of burden estimates were
prepared, including times for both electronic and paper form preparation for every category
outlined below:
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•

Appendix G
Realistic Burden Estimates for Every Form R Data Element: Realistic burden
estimates were prepared for every data element on the Form R based on best engineering
judgment for both management and technical time. Under the realistic scenario, no
clerical time is spent on form completion. Separate realistic burden estimates were
prepared for non-PBT and PBT chemicals.
Realistic Burden Estimates for Total Form R Completion: The realistic data element
burden estimates were weighted by the incidence rate, which is the total percentage of
forms containing information other than “NA” for the data element, in order to reflect the
fact that not all data elements will be completed on all forms. The incidence rate was
calculated using the frozen RY 2002 TRI data. This analysis was conducted separately
for non-PBT and PBT chemicals.
Scaled Burden Estimates for Every Form R Data Element for non-PBT Chemicals:
The realistic burden estimates generated for every data element for non-PBT chemicals
were scaled up to meet the current OMB-approved time estimate for calculations and
form completion for a Form R for a non-PBT chemical.
Scaled Burden Estimates for Every Form R Data Element for PBT Chemicals: The
realistic burden estimates generated for every data element for PBT chemicals were
scaled up to meet the current OMB-approved time estimate for calculations and form
completion for a Form R for a PBT chemical. Since the current OMB-approved time
estimate for calculations and form completion for a PBT chemical assumes that all data
elements are completed, these scaled data element time estimates were not multiplied by
the incidence rate for PBT chemicals.

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Appendix G
TABLE 1
OMB-APPROVED TIME ESTIMATES FOR FORM R
CALCULATIONS/FORM COMPLETION
Activity

Management

Technical

Clerical Total Hours

Calculations and report completion non-PBT chemicals

11.3

24.1

1.6

37.0

Calculations and report completion PBT chemicals

20.9

45.2

2.9

69.0

Calculations and report completion non-PBT chemicals

7.7

16.4

1.1

25.2

Calculations and report completion PBT chemicals

14.3

30.8

2.0

47.1

First year

Subsequent years

Source: Rice, Cody Memo: Terms of Clearance for TRI ICR Renewal. Jan 20, 2004.
An OMB-approved estimate for first time non-PBT filers does not exist; however, the RIA for
the original Section 313 rulemaking estimated the time required to complete a report in the first
year to be 147% of the time required in subsequent years. This factor was applied to the OMB
approved subsequent year non-PBT report completion times to calculate the first year non-PBT
completion times. (U.S. EPA Regulatory Impact Analysis in Support of Final Rulemaking
under Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986
(1988).
Realistic estimates, based on best engineering judgment, are presented in Section 2; Section 3
presents the realistic estimate scaled to the OMB approved Form R completion times. Within
each section, PBT and non-PBT reporting burden is examined separately due to differences in
methodology. The PBT and non-PBT chemical sub-sections are further divided into electronic
and paper methodology and results sub-sections.
2. REALISTIC REPORTING BURDEN ESTIMATES
2.1.A. Methodology for Electronic Submission
The basis for all of the burden estimates presented in this memo start with a realistic burden
estimate for a typical facility to prepare a Form R in the first year and all subsequent reporting
years. To generate this realistic burden estimate, the method described below was utilized. First,
the steps required for completion of each data element (field) on the Form R were identified.
Best engineering judgment was used to estimate the time to complete each step based on a
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Appendix G
reasonable and likely scenario for conducting the needed steps a typical facility. Best
engineering judgment was provided by a team of three staff with nearly 40 years of combined
experience working with facilities on environmental issues. These staff have worked with
hundreds of facilities on TRI reporting and other environmental requirements by conducting
inspections and providing technical assistance to hundreds of facilities, serving as TRI trainers,
conducting technical review on hundreds of TRI data withdrawal requests, conducting hundreds
of TRI data quality calls, working for two of the Massachusetts Toxics Use Reduction Act
agencies, and working as environmental staff at large manufacturing facilities.) Next, the total
time to complete each data element was estimated by summing together the labor hours required
to complete the set of steps necessary for each data element.
Best and worst-case scenarios of activities were considered when estimating the time required to
complete each step. The time estimates presented here reflect the most typical/likely scenario.
For example, scenarios to identify average discharge water flow rate range from transcribing
dozens of hand-written entries from manual meter observation to simply pulling this piece of
data from a fully-automated system. The likely scenario selected is that the typical facility will
have at least partial automation on data capture from their flow meter, but technical staff will
likely have to pull multiple pieces of information, interpret this information, and perform a few
calculations. Several Form R data elements will require the same or similar activities. To ensure
consistency, times were standardized for these activities. These standard times are presented in
Table 2 (refer to Excel spreadsheet).
For Form R data elements requiring a quantitative estimate of release or other waste management
quantities, the steps a facility would take to fill in the data elements were derived based on the
most common basis of estimate code reported for that field in the RY 2002 TRI data. The basis
of estimate code analysis is presented in Table 3 (refer to Excel spreadsheet). For example,
monitoring data was the most common basis of estimate code for off-site transfers to POTWs;
therefore, the steps required to make engineering calculations based on monitoring data were
used as the basis for the time estimate for this data element. In actuality, each facility would use
their best available data for completing each field. As a final check, estimated times for data
elements were compared with one another based on expected relative degree of difficulty.
The total realistic form completion burden was calculated by combining the time required to
complete each data element with the percent of times individual data elements are typically
completed. As mentioned above, this adjustment was made by weighting the data element
specific burden by the incidence rate for that element. For example, if a stack air release
quantity (either “0" or an actual quantity) was reported on 50% of all non-PBT Form Rs, the time
estimated to complete Part II, Section 5.2 of the Form R was multiplied by 50%. For data
elements that are required, it was assumed that 100% of forms had the data element filled out.
The final reporting burden is a realistic estimate of the total form completion time based on
engineering judgment. A separate analysis was done for non-PBT and PBT chemicals.

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Appendix G
As mentioned above, these burden estimates are based on the TRI reporting experiences of a
typical facility. It was, therefore, necessary to make the following assumptions about a typical
facility:
•

The facility is reasonably modern and well-organized.

•

The facility has internet access with reasonable connection speed.

•

Through rule familiarization, the technical staff are aware that written EPA TRI guidance
is available through the website.

•

Unless otherwise noted, the set of activities listed for a release estimate need only be
conducted once.

•

Unless otherwise noted, there is no difference in completing a data element for non-PBT
versus PBT chemicals. (Additional discussion on PBTs versus non-PBTs is provided
below).

•

Technical staff retain copies of the previous year’s reports in a readily available format.
Therefore, static information available from the previous year’s reports, such as RCRA
I.D., is assumed to require only typing time in subsequent years.

•

For subsequent year reports, technical staff will be able to locate, review, and interpret
information needed to prepare release and other waste management estimates more
quickly since they have already gone through the process.

•

For subsequent year reports, it is assumed that there are no significant changes to facility
operations or waste management practices.

•

Technical staff preparing the report will concurrently type this information into TRI-ME
and will not require clerical assistance in entering information into TRI-ME.

•

On the paper form estimates of reporting burden, clerical time consists entirely of typing
hard copy Form Rs; no other activities are undertaken. For example, technical staff
conduct all of the needed research for preparing the form.

Since more than 80% of Form Rs were filed electronically in RY 2002, it is assumed for the
realistic burden estimate that technical staff prepare the electronic form; therefore, no clerical
burden is estimated. Also, in the realistic burden estimate, management review time is based on
the maximum perceived level of management involvement at reporting facilities and is lower
than previous OMB approved management burden estimates. In the following sections, data
elements are presented as they appear on the Form R. Reporting burden estimates are presented
after each step for first year/subsequent years in minutes. If a step will take less time or does not
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Appendix G
need to be repeated in subsequent years, this will be reflected in the allotted time (i.e., a lower
time or “0" will be given for subsequent years).
As mentioned above, the calculations/form completion burden for non-PBT chemicals was
recently revised from 47.1 hours to 25.2 hours for non-PBT chemicals (Memo from Cody Rice
to Amy Newman: Terms of Clearance for TRI ICR Renewal. Jan 20, 2004). Reporting burden
associated with PBT chemicals was not revised due to trade association comments suggesting
that because range reporting and the de minimis exemption cannot be used for PBT chemicals,
form completion takes longer for a PBT chemical than a non-PBT chemical. While there may be
overall differences in TRI reporting burden between PBT and non-PBT forms, this difference is
largely due to compliance determination activities, not form completion.
Specifically, the de minimis exemption is not allowed for PBT chemicals. Therefore, compliance
determination may take longer for PBT chemicals, as additional mixtures may need to be
assessed for threshold quantity. It does not appear, however, that the lack of the de minimis
exemption will increase the burden associated with making release estimates due to a need to
assess additional waste streams. An analysis of the RY 2002 TRI data indicated that the average
number of reported “M” codes for off-site transfers was slightly lower for PBTs than for nonPBTs (2.55 versus 2.64, respectively). Assuming that different waste streams are indicated by
different waste management methods, as indicated by the “M” code, it appears that there were
slightly fewer differing waste streams for PBT chemicals than for non-PBT chemicals.
Also, not being able to use range reporting does not actually increase the reporting burden for
PBT filers. Range reporting is allowed for non-PBT chemicals in Part II, Sections 5 and 6 of the
Form R (on-site releases and off-site transfers of wastes), but is not allowed in Part II, Section 8
of the Form R. All release and other waste management quantities from Sections 5 and 6 are
also recorded in Section 8 of the Form R, therefore, actual estimates (versus range estimates) for
Sections 5 and 6 must be made to complete Section 8. As a result, no fewer calculations are
necessary to complete a Form R for non-PBTs versus PBTs due to range reporting. In addition,
range reporting is only allowed for releases less than 1,000 pounds, and calculations are needed
to determine which range is applicable.
As shown below, using best engineering judgment, there does not appear to be a significant
difference between calculations/form completion activities and burden for PBT versus non-PBT
chemicals. In fact, it is estimated that the calculations/form completion time for PBT chemicals
is slightly lower, primarily due to the fact that more EPA-published quantitative guidance is
available for PBT chemicals, such as emission factors. Analysis of RY 2002 TRI data shows the
following:
•

The most commonly reported basis of estimate codes were nearly identical for PBTs
versus non-PBTs.

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•

Appendix G
The percent of data elements filled out by RY 2002 filers was nearly the same for PBT
and non-PBT forms, with the difference being the percent was slightly lower for PBTs.
For data elements where multiple occurrences were reported (e.g., off-site transfer
locations, number of “M” codes for off-site transfers, number of reported on-site
treatment waste streams), the incidence rates were nearly identical for PBT and non-PBT
forms.

The derivation of the data element specific burden estimates is presented below. Only one
complete set of steps reflecting expected activities for both PBT and non-PBT chemicals is
provided for each data element (with a few minor exceptions) as there are no significant
differences in form completion activities. Minor differences expected between non-PBT and
PBT chemicals are noted in the individual data element discussions where they occur.
Data Element Specific Reporting Burden
Form R, Part I. Facility Identification Information
Section 1: Reporting Year
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
Technical staff will have knowledge of this information and will report it in Part I, Section 1 of
the Form R. (0.25 min/0.25 min)
Reporting Burden Associated with Part I, Section 1
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

0.25

Total

0.33

Section 2: Trade Secret Information
2.1 Are you claiming the toxic chemical identified on page 2 trade secret?
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
Technical staff will have knowledge of this information and will check yes or no in Part I,
Section 2.1 of the Form R. (0.08 min/0.08 min)

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Appendix G
Reporting Burden Associated with Part I, Section 2.1
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

0.08

Total

0.16

2.2 Is this copy sanitized or unsanitized?
Facilities must meet rigorous standards as outlined in 40 CFR 350 in order to claim trade secret
status; therefore, it is assumed a typical facility will check “no” in Part I, Section 2.1 of the Form
R, and subsequently Part I, Section 2.2 of the Form R will be left blank.
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
Technical staff will have knowledge of this information and will check yes or no in Part I,
Section 2.2 of the Form R. (0.08 min/0.08 min)
Reporting Burden Associated with Part I, Section 2.2
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

0.08

Total

0.16

Section 3: Certification
In RY 2002, more than 80% of Form R reports were filed via diskette or CDX submission.
Electronic signature occurs as part of the CDX submission process and with diskette submission
a separate signed letter is sent. Burden for this effort is allocated under “Record
keeping/Mailing” and therefore is not included in the “Calculations/Form Completion” burden
estimate outlined in this report. Thus, no management, technical, nor clerical burden associated
with this element of the Form R will be allocated for this analysis.
Section 4.1: Facility Identification (Name, Address)
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.67 min/0.67 min)
Technical staff will have knowledge of this information and will report it in Part I, Section 4.1 of
the Form R. (2.0 min/0 min)
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Appendix G
Reporting Burden Associated with Part I, Section 4.1
Personnel Type
Management

First Year Burden (minutes)
0.67

Subsequent Year Burden (minutes)
0.67

Technical

2.00

0.00

Total

2.67

0.67

Section 4.2: Reporting by Part
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
4.2a or 4.2b
Technical staff will have knowledge of this information, and will check off if this Form R is for
an entire facility or part of a facility in Part I, Section 4.2a or 4.2b, respectively, of the Form R.
(0.08 min/0.08 min)
Reporting Burden Associated with Part I, Section 4.2a or 4.2b
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

0.08

Total

0.16

4.2c or 4.2d
This section is only filled out if the Form R is from a federal facility or a government-owned,
contractor-operated (GOCO) entity conducting work on behalf of the federal government. Since
fewer than 5% of Form Rs are filled out by these facilities, this section will typically be left
blank.
Technical staff will have knowledge of this information, and will check off if this Form R is for a
federal facility or a GOCO in Part I, Section 4.2c or 4.2d, respectively, of the Form R. No time
is included for this step because it is filled out less than 5% of the time.
Section 4.3: Technical Contact Information (Name, Address, E-mail, Telephone)
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.25 min/0.25 min)
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Appendix G
Technical staff will have knowledge of this information and will report it in Part I, Section 4.3 of
the Form R. (0.75 min/ 0 min)
Reporting Burden Associated with Part I, Section 4.3
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

0.25

Technical

0.75

0.00

Total

1.00

0.25

Section 4.4: Public Contact Information (Name, Telephone)
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.17 min/0.17 min)
Technical staff will have knowledge of this information and will report it in Part I, Section 4.4 of
the Form R. (0.50 min/0 min)
Reporting Burden Associated with Part I, Section 4.4
Personnel Type
Management

First Year Burden (minutes)
0.17

Subsequent Year Burden (minutes)
0.17

Technical

0.50

0.00

Total

0.67

0.17

Section 4.5: SIC Code(s)
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
As an integral part of compliance determination, a facility will have determined which SIC codes
apply to the facility. Technical staff simply record this information in Part I, Section 4.5 of the
Form R. (0.25 min/0 min)
Reporting Burden Associated with Part I, Section 4.5
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

0.25

0.00

Total

0.33

0.08

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Appendix G
Section 4.6: Latitude/Longitude
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.50 min/0.50 min)
Technical staff will go to the TRI facility siting tool available on the EPA Web site and type in
their facility address. The tool will then report back the latitude and longitude. The technical
staff will record this information in Part I, Section 4.6 of the Form R. (4.5 min/0 min)
Reporting Burden Associated with Part I, Section 4.6
Personnel Type
Management

First Year Burden (minutes)
0.50

Subsequent Year Burden (minutes)
0.50

Technical

4.50

0.00

Total

5.00

0.50

Section 4.7: Dun & Bradstreet Number
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
Technical staff will obtain this information from elsewhere in the company by making a phone
call, checking files, or making an in-person information request. Once obtained, technical staff
will record this information in Part I, Section 4.7 of the Form R. (10.0 min/0 min)
Reporting Burden Associated with Part I, Section 4.7
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

10.00

0.00

Total

10.08

0.08

Section 4.8: EPA Identification Number (RCRA ID)
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
Unless hazardous waste manifests are stored with the technical staff preparing the report, they
will need to obtain this information from elsewhere in the company by making a phone call,
checking files, or making an in-person information request. For the purposes of this estimate, it
is assumed that technical staff will need to obtain this information from elsewhere. Once
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Appendix G
obtained, technical staff will record this information in Part I, Section 4.8 of the Form R. (10.0
min/0 min)
Reporting Burden Associated with Part I, Section 4.8
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

0.08

Technical

10.00

0.00

Total

10.08

0.08

Section 4.9: Facility NPDES Permit Number
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
Unless NPDES permit documents are stored with the technical staff preparing the report, they
will need to obtain this information from elsewhere in the company by making a phone call,
checking files, or making an in-person information request. For the purposes of this estimate, it
is assumed that technical staff will need to obtain this information from elsewhere. Once
obtained, technical staff will record this information in Part I, Section 4.9 of the Form R. (10.0
min/0 min)
Reporting Burden Associated with Part I, Section 4.9
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

10.00

0.00

Total

10.08

0.08

Section 4.10: Underground Injection Well Code (UIC I.D.)
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
Unless UIC permit documents are stored with the technical staff preparing the report, they will
need to obtain this information from elsewhere in the company by making a phone call, checking
files, or making an in-person information request. For the purposes of this estimate, it is
assumed that technical staff will need to obtain this information from elsewhere. Once obtained,
technical staff will record this information in Part I, Section 4.10 of the Form R. (10.0 min/0
min).

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Appendix G
Reporting Burden Associated with Part I, Section 4.10
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

10.00

0.00

Total

10.08

0.08

Section 5.1: Name of Parent Company
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
Technical staff will need to obtain this information from elsewhere in the company by making a
phone call, checking files, or making an in-person information request. Once obtained, technical
staff will record this information in Part I, Section 5.1 of the Form R. (10.0 min/0 min)
Reporting Burden Associated with Part I, Section 5.1
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

10.00

0.00

Total

10.08

0.08

Section 5.2: Parent Company’s Dun & Bradstreet Number
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
Technical staff will need to obtain this information from elsewhere in the company by making a
phone call, checking files, or making an in-person information request. Once obtained, technical
staff will record this information in Part I, Section 5.2 of the Form R. (10.0 min/0 min)
Reporting Burden Associated with Part I, Section 5.2
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

10.00

0.00

Total

10.08

0.08

G-14

4/28/11

Appendix G
Form R, Part II. Chemical-Specific Information
Section 1.1: CAS Number
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
Technical staff will have the CAS Number readily available from activities conducted during
compliance determination, such as review of Material Safety Data Sheets (MSDSs) or review of
the EPCRA Section 313 chemical list, and report it in Part II, Section 1.1 of the Form R. (0.25
min/0 min)
Reporting Burden Associated with Part II, Section 1.1
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

0.08

Technical

0.25

0.00

Total

0.33

0.08

Section 1.2: Toxic Chemical or Chemical Category Name
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
Technical staff will have the chemical name readily available from activities conducted during
compliance determination, such as review of Material Safety Data Sheets (MSDSs) or review of
the EPCRA Section 313 chemical list, and report it in Part II, Section 1.2 of the Form R. (0.25
min/0 min)
Reporting Burden Associated with Part II, Section 1.2
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

0.25

0.00

Total

0.33

0.08

Section 1.3: Generic Chemical Name
Facilities must meet rigorous standards as outlined in 40 CFR 350 in order to claim trade secret
status; therefore, this section of the Form R is not typically used. If a facility meets the standard
for trade secret status, this section of the Form R is completed instead of Part II, Sections 1.1 and
1.2. If this section is used, management burden includes proofreading this section as part of an
overall review of the Form R. (0.08 min/0.08 min)
G-15

4/28/11

Appendix G
Technical staff would create a generic, structurally descriptive chemical name and report it in
Part II, Section 1.3 of the Form R. (0.50 min/0 min)
Reporting Burden Associated with Part II, Section 1.3
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

0.08

Technical

0.50

0.00

Total

0.58

0.08

Section 1.4: Distribution of Each Member of the Dioxin and Dioxin-Like Compounds
Category
This section of the Form R is left blank unless the chemical is dioxin and dioxin-like compounds.
Therefore, for Form Rs for all other chemicals there is no management, technical, nor clerical
burden associated with this element. If the Form R is for dioxin and dioxin-like compounds,
management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
Technical staff would most likely obtain the distribution of each member of the dioxin and
dioxin-like compounds category for the appropriate activity from EPA’s document “EPCRA
Section 313 Guidance for Reporting Toxic Chemicals Within the Dioxin and Dioxin-like
Compounds Category” and report it in Part II, Section 1.4 of the Form R. (5 min/2 min)
Reporting Burden Associated with Part II, Section 1.4
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

5.00

2.00

Total

5.08

2.08

Section 2.1: Generic Chemical Name Provided by Supplier
This section of the Form R is only completed if the facility’s chemical supplier meets the
standard for trade secret status and is therefore not typically used. If the material supplied meets
the standard for trade secret status, this section of the Form R is completed instead of Part II,
Sections 1.1 and 1.2. If this section is used, management burden includes proofreading this
section as part of an overall review of the Form R. (0.08 min/ 0.08 min)

G-16

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Appendix G
Technical staff would have the generic chemical name provided by the supplier readily available
from activities conducted during compliance determination, such as review of Material Safety
Data Sheets (MSDSs), and report it in Part II, Section 2.1 of the Form R. (0.25 min/0 min)
Reporting Burden Associated with Part II, Section 2.1
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

0.08

Technical

0.25

0.00

Total

0.33

0.08

Section 3.1: Manufacture the Toxic Chemical
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
As an integral part of compliance determination, the facility becomes familiar with the EPCRA
Section 313 threshold activities that the chemical was involved in during the reporting year.
Therefore, technical staff simply check off the relevant descriptions of manufacturing activities
for the chemical presented in Part II, Section 3.1 of the Form R. (0.08 min/0 min)
Reporting Burden Associated with Part II, Section 3.1
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

0.08

0.00

Total

0.16

0.08

Section 3.2: Process the Toxic Chemical
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
As an integral part of compliance determination, the facility becomes familiar with the EPCRA
Section 313 threshold activities that the chemical was involved in during the reporting year.
Therefore, technical staff simply check off the relevant descriptions of processing activities for
the chemical presented in Part II, Section 3.2 of the Form R. (0.08 min/0 min)

G-17

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Appendix G
Reporting Burden Associated with Part II, Section 3.2
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

0.08

Technical

0.08

0.00

Total

0.16

0.08

Section 3.3: Otherwise Use the Toxic Chemical
Management burden includes proofreading this section as part of an overall review of the Form
R. (0.08 min/0.08 min)
As an integral part of compliance determination, the facility becomes familiar with the EPCRA
Section 313 threshold activities that the chemical was involved in during the reporting year.
Therefore, technical staff simply check off the relevant descriptions of otherwise use activities
for the chemical presented in Part II, Section 3.3 of the Form R. (0.08 min/0 min)
Reporting Burden Associated with Part II, Section 3.3
Personnel Type
Management

First Year Burden (minutes)
0.08

Subsequent Year Burden (minutes)
0.08

Technical

0.08

0.00

Total

0.16

0.08

Section 4.1: Maximum Amount of the Toxic Chemical On-Site at any Time During the
Calendar Year
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (1.08 min/ 0.91 min)
The maximum amount of toxic chemical on-site at any point during the year is reported as a
range code, with each range representing one order of magnitude. To determine the range
estimate for the maximum amount of the toxic chemical in storage, in process, and in on-site
wastes at any one point during the year, it is assumed the technical staff performs the steps
outlined below. The estimate is needed to identify a quantity within a very broad range, not to
identify a more exact quantity. For this reason, steps outlined here will take less time than when
conducted for a data element requiring a more precise estimate.
•

Determine the maximum quantity of the toxic chemical in storage at any point during the
calendar year by either reviewing inventory records or talking with operations staff. (9.00
min/9.00 min)
G-18

4/28/11

Appendix G
•

Determine the maximum quantity of the toxic chemical in process at any point during the
calendar year by either reviewing operations records or talking with operations staff.
(9.00 min/9.00 min)

•

Determine the maximum quantity of the toxic chemical in on-site wastes at any point
during the calendar year by either reviewing waste records, such as hazardous waste
manifests, or talking with operations staff. (9.00 min/9.00 min)

•

Sum together the storage, process, and waste quantities to calculate the maximum amount
of the toxic chemical on-site at any one point during the year. (3.00 min/3.00 min)

•

Locate the appropriate 2-digit code from the TRI Reporting Forms and Instructions and
report it in Part II, Section 4.1 of the Form R. (0.25 min/0.25 min)
Reporting Burden Associated with Part II, Section 4.1

Personnel Type
Management

First Year Burden (minutes)
1.08

Subsequent Year Burden (minutes)
0.91

Technical

30.25

Total

31.33

31.16

Section 5.1: Fugitive or Non-Point Air Emissions
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (3.08 min/2.58 min)
The most commonly reported basis of estimate code for fugitive air releases for both non-PBT
and PBT chemicals is “O,” other approaches. It is assumed the most typical approach would
involve an estimate based on use of physical and chemical properties and process operating
conditions. To estimate fugitive or non-point air emissions, technical staff would perform the
following steps:
•

Identify all fugitive release points for the chemical through review of air permits,
discussions with operations staff, review of process flow diagrams, or a visual inspection
of operations. (30.00 min/5.00 min)

•

Identify physical and chemical property data for the chemical, including volatility,
boiling point, etc. (5.00 min/5.00 min)

•

Identify relevant process operating conditions, such as temperature, turbulence, etc.,
(45.00 min/30.00 min)
G-19

4/28/11

•

Appendix G
Determine material usage quantity through a review of inventory records, purchase
records, operation records, or discussions with operations staff. (30.00 min/30.00 min)

•

Locate and review guidance from EPA, trade associations, or other sources, or air permit
information that provides quantitative assistance for estimating fugitive loss (e.g., EPA’s
Protocol for Equipment Leak Emission Estimates, air permit assumption of 1% loss of
volatiles due to transfers in an otherwise closed system). (60.00 min/30.00 min)

•

Make the best estimate of fugitive or non-point air emissions based upon the physical and
chemical properties and process operating conditions and report the value in Part II,
Section 5.1 of the Form R. (25.00 min/15.00 min)

•

Report whether the release estimate was based on monitoring data, mass balance,
published emission factor, or other engineering calculations by recording the code M, C,
E, or O, respectively, in Section 5.1.B of the Form R. (0.25 min/0.25 min)
Reporting Burden Associated with Part II, Section 5.1

Personnel Type
Management

First Year Burden (minutes)
3.08

Subsequent Year Burden (minutes)
2.58

Technical

195.25

115.08

Total

198.33

117.66

Section 5.2: Stack or Point Air Emissions
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (3.08 min/1.75 min)
The most commonly reported basis of estimate code for stack air releases for non-PBT chemicals
is “O,” other approaches. It is assumed the most typical approach uses non-published emission
factors. The most commonly reported basis of estimate code for stack air releases for PBT
chemicals is “E,” published emission factors. Using these emission factors, technical staff would
perform the following steps:
•

Identify all of the stack release points for the chemical. The process for identifying these
releases requires technical staff to perform any or all of the following steps: review air
permits or process flow diagrams, consult with operational/environmental staff, or
conduct a visual inspection of the facility. (30.00 min/5.00 min)

•

For each stack air release, locate the most applicable emission factor. For PBT
chemicals, EPA-published emission factors are obtained from numerous EPA sources,
including a chemical or industry specific guidance, AP-42, or the technology transfer
G-20

4/28/11

Appendix G
network (for TANKS program). (10/9 minutes) For non-PBT chemicals, emission
factors are obtained from sources such as trade associations and university research.
(30.00 min/15.00 min)
•

Determine the annual quantity of input material by reviewing purchase records, inventory
records, and/or operational records. (30.00 min/30.00 min)

•

Multiply this material usage quantity by the emission factor to determine the amount of
material released from each point during the year. If needed, convert the amount of
material released to pounds (or grams for dioxins) by applying the appropriate conversion
factor. (6.00 min/6.00 min)

It is assumed that there will be an average of two unique types of stack releases for each
chemical at a typical facility (i.e., two different emission factors would be applied). There are
economies of scale in quantifying the second release type due to concurrent activities, such as
searching the same sources to locate emission and conversion factors (4.00 min/4.00 min) and
reviewing the same sources to determine the annual quantity of input material. Technical staff
would perform the following steps:
•

•

Sum all of the quantified stack air releases for the given chemical to quantify the total
stack or point air emissions (lb/yr) and report the value in Part II, Section 5.2 of the Form
R. (1.00 min/1.00 min)

•

Report whether the release estimate was based on monitoring data, mass balance,
published emission factor, or other engineering calculations by recording the code M, C,
E, or O, respectively, in Section 5.2.B of the Form R. (0.25 min/0.25 min)
Reporting Burden Associated with Part II, Section 5.2

Personnel Type
Management

First Year Burden (minutes)
3.08

Subsequent Year Burden (minutes)
1.75

Technical

106.25

66.25

Total

109.33

68.00

G-21

4/28/11

Appendix G
Section 5.3: Discharges to Receiving Streams or Water Bodies
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (3.33 min/2.83 min)
The most commonly reported basis of estimate code for discharges to receiving streams or water
bodies is “M,” use of monitoring data, for both non-PBTs and PBTs. To estimate discharges to
receiving streams or water bodies, technical staff would perform the following steps:
Release Quantity from Process Water
1.

Locate and review the facility’s monitoring results for process water outfall(s) to
determine the chemical concentration for each monitoring point. (35.00 min/25.00 min)

Obtain flow rate data from the NPDES permit or a flow meter. If neither is available,
estimate the volume of wastewater generated by reviewing water usage data. The
estimated flow is calculated by dividing the volume of wastewater by the usage time
(e.g., days). (15.00 min/10.00 min)

Identify the number of discharge days by talking with operations staff. (15.00 min/15.00
min)

Multiply the identified chemical concentration (for one monitoring data point) by the
daily water flow rate to calculate the daily release for this point. Repeat this step for all
monitoring points, averaging the results together to calculate the average daily release.
Multiply the average daily release by the number of release days to calculate the total
annual release quantity. Apply any needed conversion factors to get the result in pounds.
(10.00 min/10.00 min)

Release Quantity from Storm Water
5.

Locate and review the facility’s monitoring results from storm water outfall(s) to
determine the chemical concentration for each monitoring point, and average them
together. Apply needed conversion factors to obtain the total annual release from storm
water in pounds. (45.00 min/35.00 min)

Locate the annual rainfall for the facility’s area, assuming 12 inches of snow is equivalent
to 1 inch of rain. (4.00 min/3.00 min)

Estimate the percent of land at the facility covered by asphalt, concrete, and unimproved
vegetation/soil. Technical staff generate a weighted-average runoff coefficient by
multiplying the percent of land area by the runoff coefficient for that land type. (30.00
min/5.00 min)
4/28/11
G-22

Appendix G
8.

Multiply the total annual rainfall by the weighted-average runoff coefficient, the total
area of the facility, and the conversion factor for gallons per cubic foot to calculate the
total annual storm water runoff in gallons. (5.00 min/5.00 min)

Multiply the total volume (gallons) of storm water by the chemical concentration to
calculate the total mass (pounds) of the chemical contained in the annual storm water
runoff. If needed, apply a conversion factor. (4.00 min/4.00 min)

Total Release Quantity
10.

Sum together the annual release quantity from process water with the annual release
quantity from storm water to obtain the total annual release quantity to water. Report the
total release (lb/yr) in Part II, Section 5.3.1.A of the Form R as the total releases to a
water body for a specific chemical. (2.00 min/2.00 min)

Basis of Estimate
11.

Report whether the release estimate was based on monitoring data, mass balance, a
published emission factor, or other engineering calculations by recording the code M, C,
E, or O, respectively, in Section 5.3.1.B of the Form R. (0.25 min/0.25 min)

Percent from Stormwater
12.

Divide the quantity of the chemical contained in the storm water by the total quantity of
the chemical released to water in order to calculate the percent of the chemical released
from storm water. Report this percentage in Part II, Section 5.3.1.C of the Form R. (2.00
min/2.00 min)

Note: Many facilities will not need to assess storm water in order to calculate release to water as
many TRI chemicals will not typically be found in storm water run-off, but will instead only be
found in process water. In order to reasonably estimate how much time should be allocated to a
typical facility for assessing storm water, a data analysis was conducted on the RY 2002 TRI
data. First, all form Rs for which 5.3A had a value of greater than or equal to zero were
identified. Second, within that set, the percentage of these forms that had a value of greater than
zero in 5.3C were identified. This analysis was conducted separately for non-PBTs and for
PBTs, with identified values of 39.3% and 44.4%, respectively. The total estimated burden for
identifying annual release quantity from storm water (steps 5 through 9 above) was then
multiplied by 39.3% for non-PBTs and by 44.4% for PBTs. This calculation is shown below:
Total percent from storm water burden multiplied by incidence rate for a value greater than zero
in 5.3.C when there was a value of greater than or equal to zero in 5.3.A:
non-PBTs:
(88.00 min/52.00 min) x 39.3% incidence = (34.58/20.44)
PBTs:
(88.00 min/52.00 min) x 44.4% incidence = (39.07/23.09)
4/28/11
G-23

Appendix G
This incidence-weighted value was added with the total estimated burden for identifying the
annual release quantity from process water to obtain the total calculation time estimate for 5.3.A.
The table below reflects the incidence-weighted value for storm water assessment.
Reporting Burden Associated with Part II, Section 5.3
Personnel Type
Management
Technical
Total

First Year Burden (minutes)
Non-PBT
3.33
113.83
117.16

PBT
3.33
118.32
121.65

Subsequent Year Burden (minutes)
Non-PBT
2.83
84.69
87.52

PBT
2.83
87.34
90.17

Section 5.4.1: Underground Injection On-Site to Class I Wells
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (2.08 min/1.75 min)
The most commonly reported basis of estimate code for releases to underground injection Class I
wells is “M,” use of monitoring data for both non-PBT and PBT chemicals. To estimate
quantities injected underground or on-site to Class I wells, the technical staff would perform the
following steps:
1.

Locate and review monitoring data for the facility, and then, for each monitoring event,
identify the concentration of the specific chemical in the waste stream. The chemical
concentrations from all monitoring events are then averaged. (35.00 min/25.00 min)

Either talk to operations staff, review production records and estimate waste generation,
review well operations records, or review well permit data/required injection well reports
to determine the total quantity of waste disposed via Class I wells for the reporting year.
(30.00 min/30.00 min)

Multiply the total quantity of waste disposed via Class I wells by the average
concentration of the specific chemical in the waste stream to calculate the total pounds of
the chemical released to Class I wells during the reporting year. If needed, apply a
conversion factor. Report the value (lb/yr) in Part II, Section 5.4.1.A of the Form R.
(8.00 min/8.00 min)

4/28/11

Appendix G
Reporting Burden Associated with Part II, Section 5.4.1
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

2.08

1.75

Technical

73.25

63.25

Total

75.33

65.00

Section 5.4.2: Underground Injection On-Site to Class II-V Wells
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (2.08 min/1.75 min)
The most commonly reported basis of estimate code for releases to underground injection Class
II-V wells is “M,” use of monitoring data for both non-PBT and PBT chemicals. To estimate
quantities injected underground or on-site to Class II-V wells, the technical staff would perform
the following steps:
1.

Locate and review monitoring data for the facility. Then, for each monitoring point,
identify the concentration of the specific chemical in the waste stream. The chemical
concentrations from all monitoring data points (events) are then averaged. (35.00
min/25.00 min)

Either talk to the operations staff, review production records and estimate waste
generation, review well operations records, or review well permit data/required injection
well reports to determine the total quantity of waste disposed via Class II-V wells for the
reporting year. (30.00 min/30.00 min)

Multiply the total quantity of waste disposed via Class II-V wells by the average
concentration of the specific chemical in the waste stream to calculate the total pounds of
the chemical released to Class II-V wells during the reporting year,. If needed, apply a
conversion factor. Report the value (lb/yr) in Part II, Section 5.4.2.A of the Form R.
(8.00 min/8.00 min)

G-25

4/28/11

Appendix G
Reporting Burden Associated with Part II, Section 5.4.2
Personnel Type
Management

First Year Burden (minutes)
2.08

Subsequent Year Burden (minutes)
1.75

Technical

73.25

63.25

Total

75.33

65.00

Section 5.5.1A: On-site Land Disposal via RCRA Subtitle C Landfills
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (3.08 min/1.75 min)
The most commonly reported basis of estimate code for releases to RCRA landfills is “O,” other
approaches, for both non-PBT and PBT chemicals. It is assumed technical staff would track the
generation and on-site disposal of these wastes as follows:
1.

Identify all waste streams containing the chemical of interest disposed of in RCRA
landfills. (30.00 min/5.00 min)

Review RCRA records (manifests and biennial reports) to determine the total quantity of
waste disposed of in RCRA landfills for the reporting year; or talk to operations staff,
review production records and estimate waste generation, or review on-site disposal
tracking records. (30.00 min/30.00 min)

Review RCRA waste characterization data, talk to operations staff, review any nonRCRA waste characterization information, or review production/activity Standard
Operating Procedures (SOPs) and process flow diagrams to determine the concentration
of a specific chemical disposed of in a RCRA landfill. (30.00 min/25.00 min)

Multiply the total quantity of waste disposed of in RCRA landfills by the average
concentration of the specific chemical in the waste stream to calculate the total pounds of
the chemical disposed of in RCRA landfills during the reporting year,. If needed, apply a
conversion factor. Report the value (lb/yr) in Part II, Section 5.5.1A.A of the Form R.
(6.00 min/6.00 min)
Report whether the release estimate was based on monitoring data, mass balance,
published emission factor, or other engineering calculations by recording the code M, C,
E, or O, respectively, in Section 5.5.1A.B of the Form R. (0.25 min/0.25 min)

G-26

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Appendix G
Reporting Burden Associated with Part II, Section 5.5.1A
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

3.08

1.75

Technical

96.25

66.25

Total

99.33

68.00

Section 5.5.1B: On-site Land Disposal via Other Landfills
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (3.08 min/1.75 min)
The most commonly reported basis of estimate code for releases to on-site non-RCRA landfills is
“O,” other approaches, for both non-PBT and PBT chemicals. It is assumed the technical staff
would track the generation and on-site disposal of these wastes as follows:
1.

Identify all waste streams containing the chemical of interest disposed of in on-site nonRCRA landfills. (30.00 min/5.00 min)

Talk to operations staff, review production records and estimate waste generation, or
review on-site disposal tracking records to determine the total quantity of waste disposed
of in non-RCRA landfills for the reporting year. (30.00 min/30.00 min)

Talk to operations staff, review any waste characterization information, or review
production/activity SOPs and process flow diagrams to determine the concentration of a
specific chemical disposed of in non-RCRA landfills. (30.00 min/25.00 min)

Multiply the total quantity of waste disposed via non-RCRA landfills by the average
concentration of the specific chemical in the waste stream to calculate the total pounds of
the chemical disposed of in non-RCRA landfills during the reporting year. If needed,
apply a conversion factor. Report the value (lb/yr) in Part II, Section 5.5.1B.A of the
Form R. (6.00 min/6.00 min)

G-27

4/28/11

Appendix G
Reporting Burden Associated with Part II, Section 5.5.1B
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

3.08

1.75

Technical

96.25

66.25

Total

99.33

68.00

Section 5.5.2: On-Site Land Disposal via Land Treatment/Application Farming
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (2.08 min/1.75 min for non-PBT filers; 3.08 min/1.75 min for PBT filers)
The most commonly reported basis of estimate code for releases via land treatment is “M,” use
of monitoring data, for non-PBT chemicals. To estimate the quantity going to on-site land
disposal via land treatment/application farming for non-PBT chemicals, the technical staff would
perform the following steps:
1.

Locate monitoring data and determine the chemical concentration in the waste stream for
each monitoring point. Then calculate an average chemical concentrations across all
monitoring data points (events). (35.00 min/ 25.00 min)

Talk to operations staff, review production records, and estimate waste generation, or
review on-site disposal tracking records (i.e., the number of land applications multiplied
by the average load size) to determine the total quantity of waste disposed via land
treatment/application farming for the reporting year. (30.00 min/30.00 min)

Multiply the total quantity of waste disposed via land treatment by the average
concentration of the specific chemical in the waste stream to calculate the total pounds of
the chemical disposed of on-site for land treatment/application farming during the
reporting year. If needed, apply a conversion factor. Report the value (lb/yr) in Part II,
Section 5.5.2.A of the Form R. (8 min/8 min)

The most commonly reported basis of estimate code for releases via land treatment is “O,” other
approaches, for PBT chemicals. To estimate the quantity going to on-site land disposal via land
treatment/application farming for PBT chemicals, the technical staff would perform the
following steps:

G-28

4/28/11

•

Appendix G
Identify all waste streams disposed of via land treatment that contain the chemical of
interest. (30.00 min/5.00 min)

•

Determining the total quantity of waste disposed of via land treatment for the reporting
year requires the technical staff to either talk to operations staff, review production
records and estimate waste generation, or review on-site disposal tracking records. (30.00
min/30.00 min)

•

Talk to operations staff, review any waste characterization information, or review
production/activity SOPs and process flow diagrams to generate chemical concentration
estimates of a specific chemical disposed of via land treatment. (30.00 min/25.00 min)

•

Multiply the total quantity of waste disposed via land treatment by the average
concentration of the specific chemical in the waste stream to calculate the total pounds of
the chemical disposed of via land treatment during the reporting year. If needed, apply a
conversion factor. Report the value (lb/yr) in Part II, Section 5.5.2.A of the Form R.
(6.00 min/6.00 min)

•

Report whether the release estimate was based on monitoring data, mass balance,
published emission factor, or other engineering calculations by recording the code M, C,
E, or O, respectively, in Section 5.5.2.B of the Form R. (0.25 min/0.25 min)
Reporting Burden Associated with Part II, Section 5.5.2
Personnel Type

Management
Technical
Total

First Year Burden (minutes)
Non-PBT
2.08
73.25
75.33

Subsequent Year Burden (minutes)

PBT
3.08
96.25
99.33

Non-PBT
1.75
63.25
65.00

PBT
1.75
66.25
68.00

Section 5.5.3A: RCRA Subtitle C Surface Impoundments
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (3.08 min/1.75 min)
The most commonly reported basis of estimate code for releases via RCRA surface
impoundments is “C,” mass balance, for both non-PBT and PBT chemicals. To estimate TRI
chemical quantities sent to RCRA landfills, technical staff would track the loss of this chemical
using a mass balance approach as follows:
•

Identify all waste streams disposed of via RCRA Subtitle C surface impoundments that
contain the chemical of interest. (30.00 min/5.00 min)
4/28/11
G-29

•

Appendix G
Determine the total annual chemical usage quantity through a review of production
records, a review of inventory records, or conversations with operations staff. (30.00
min/30.00 min)

•

Estimate the quantity of the chemical that goes out with the product through a review of
product QA/QC data or product specifications, or conversations with operations staff.
(30.00 min/25.00 min)

•

Subtract the quantity of the chemical in the product from the total chemical usage
quantity to determine the total waste quantity via mass balance. If the total waste quantity
is not disposed of via RCRA surface impoundment, the total waste quantity is multiplied
by the percentage of waste going to RCRA surface impoundments. If needed, apply a
conversion factor. Report the value (lb/yr) in Part II, Section 5.5.3A.A of the Form R.
(6.00 min/6.00 min)

•

Report whether the release estimate was based on monitoring data, mass balance,
published emission factor, or other engineering calculations by recording the code M, C,
E, or O, respectively, in Section 5.5.3A.B of the Form R. (0.25 min/0.25 min)
Reporting Burden Associated with Part II, Section 5.5.3A

Personnel Type
Management

First Year Burden (minutes)
3.08

Subsequent Year Burden (minutes)
1.75

Technical

96.25

66.25

Total

99.33

68.00

Section 5.5.3B: Other Surface Impoundments
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (3.08 min/1.75 min)
The most commonly reported basis of estimate code for releases via other surface impoundments
is “C,” mass balance, for both non-PBT and PBT chemicals. To estimate TRI chemical
quantities sent to other surface impoundments, technical staff would track the loss of this
chemical using a mass balance approach as follows:
•

Identify all waste streams disposed of via other surface impoundments that contain the
chemical of interest through a review of process flow diagrams, conversations with
operations staff, or a visual inspection of the process area. (30.00 min/5.00 min)

G-30

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Appendix G
Determine the total annual chemical usage quantity through a review of production
records, a review of inventory records, or conversations with operations staff. (30.00
min/30.00 min)

•

Estimate the quantity of chemical that goes out with the product through a review of
product QA/QC data or product specifications, or conversations with operations staff.
(30.00 min/25.00 min)

•

Subtract the quantity of the chemical in the product from the total chemical usage
quantity to determine the total waste quantity via mass balance. If the total waste quantity
is not disposed of via non-RCRA surface impoundment, the total waste quantity is
multiplied by the percentage of waste going to non-RCRA surface impoundments. If
needed, apply a conversion factor. Report the value (lb/yr) in Part II, Section 5.5.3B.A of
the Form R. (6.00 min/6.00 min)

•

Report whether the release estimate was based on monitoring data, mass balance,
published emission factor, or other engineering calculations by recording the code M, C,
E, or O, respectively, in Section 5.5.3B.B of the Form R. (0.25 min/0.25 min)
Reporting Burden Associated with Part II, Section 5.5.3B
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

3.08

1.75

Technical

96.25

66.25

Total

99.33

68.00

Section 5.5.4: Other On-Site Land Disposal
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (1.08 min/0.91 min)
Other on-site land disposal can include intentional storage of wastes on land (other than in
landfills, surface impounds or via land treatment/application farming), or unplanned releases to
land from spills and accidents. Best engineering judgement indicates that reporting in this
category is primarily due to unplanned releases from spills and accidents. While time estimates
are provided for both scenarios, the time allotted to this data element for the overall Form R
realistic burden estimate is from the unplanned release scenario only.
The most commonly reported basis of estimate code for other on-site land disposal is “O,” other
approaches, for both non-PBT and PBT chemicals. It is assumed that the approach used by
technical staff would be to track the generation and on-site disposal of these wastes as follows:
G-31

4/28/11

Appendix G
For planned other on-site disposal to land:
•

Identify all waste streams disposed of via other land disposal that contain the chemical of
interest. (30.00 min/5.00 min)

•

Talk to operations staff, review production records and estimate waste generation, or
review on-site disposal tracking records to determine the total quantity of waste disposed
of via other land disposal for the reporting year. (30.00 min/30.00 min)

•

For planned releases, multiply the total quantity of waste disposed via surface
impoundment by the average concentration of the specific chemical in the waste stream
to calculate the total release pounds of the chemical disposed of via other land disposal
during the reporting year. If needed, apply a conversion factor. (6.00 min/6.00 min)

For unplanned other on-site disposal to land:
•

For unplanned releases, determine the total quantity of the chemical released to land
during unplanned events, such as spills and accidents, by either reviewing spill reports,
contacting spill responders, or conducting a mass balance estimate based upon the
quantity of materials in storage tanks before and after the event. Report the value (lb/yr)
in Part II, Section 5.5.4.A of the Form R. (35.00 min/35.00 min)

•

Best engineering judgment indicates that most reporting in this section will come from
unplanned (accidental) releases. As such, the following table only provides time estimates
relevant to the reporting of these releases.
Reporting Burden Associated with Part II, Section 5.5.4
Personnel Type
Management

First Year Burden (minutes)
1.08

Subsequent Year Burden (minutes)
0.91

Technical

35.25

Total

36.33

36.16

G-32

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Appendix G
Section 6.1: Discharges to Publicly Owned Treatment Works
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (3.58 min/2.25 min)
The most commonly reported basis of estimate code for discharges to POTWs is “M,” use of
monitoring data, for both non-PBTs and PBTs. To estimate the total quantity of a TRI chemical
discharged to a POTW, technical staff would perform the following steps:
•

Locate and review monitoring data in order to identify the necessary chemical
concentration information. The monitoring data could be obtained by either reviewing
internal files or speaking directly with the pre-treatment coordinator at the POTW. (35.00
min/25.00 min)

•

Review flow meter data to locate flow rate data. If flow meter data are not available,
technical staff estimate the quantity of wastewater generated by reviewing water usage
data. This quantity is then divided by usage time (e.g., days) in order to calculate the
estimated flow. Alternatively, technical staff might request flow rate data directly from
the POTW. (15.00 min/10.00 min)

•

Talk with operations staff or contact the POTW to determine the number of days
wastewater was sent to the POTW. (15.00 min/15.00 min)

•

Multiply the identified chemical concentration (for one monitoring data point) by the
daily water flow rate to calculate the total mass of the chemical transferred to the POTW
on a daily basis. If needed, locate a conversion factor in order to report the final result in
units of pounds per day. Repeat the above steps for every monitoring result, then average
together all of the results. Multiply the pound per day release value by the total number
of discharge days per year to calculate the total annual transfers to POTWs in pounds.
Report the value (lb/yr) in Part II, Section 6.1.A.1 of the Form R. (8.00 min/8.00 min)

•

Report whether the release estimate was based on monitoring data, mass balance,
published emission factor, or other engineering calculations by recording the code M, C,
E, or O, respectively, in Part II, Section 6.1.A.2 of the Form R. (0.25 min/0.25 min)

An analysis of the RY 2002 showed that an average of one POTW per Form R was listed for
both non-PBT and PBT chemicals. For subsequent year reporting, it is assumed the facility will
be using the same POTW.
•

Technical staff will have the POTW name and location information readily available
from document review conducted for the release estimate. Technical staff will report this
information in Part II, Section 6.1.B.1 of the Form R. (1.50 min/0 min)
G-33

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Appendix G
Reporting Burden Associated with Part II, Section 6.1
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

3.58

2.25

Technical

74.75

58.25

Total

78.33

60.50

Section 6.2: Transfers to Other Off-Site Locations
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (4.83 min/3.42 min)
The most commonly reported basis of estimate code for transfers to other off-site locations is
“O,” other approaches, for both non-PBT and PBT chemicals. It is assumed that the approach
used by technical staff would be to track the off-site transfer of these wastes primarily using
waste characterization and waste transfer documentation as outlined below:
•

Identify all off-site transfers of unique waste streams containing the chemical of interest.
(30.00 min/ 5.00 min)

•

For the first unique waste stream, determine the concentration of the chemical in the
stream by either reviewing waste characterization profiles, contacting the facility’s
hazardous waste shipper to obtain their waste characterization information, or conducting
a mass balance evaluation. (30.00 min/30.00 min)

•

Determine the total quantity of the first unique waste stream that the facility ships offsite during the reporting year by reviewing hazardous waste manifests, invoices from
waste vendors, or talking to operations staff. (30.00 min/30.00 min)

•

For the first waste stream, multiply the chemical concentration by the total quantity of
waste shipped off-site to calculate the total quantity of the chemical shipped off-site for
the year. If needed, multiply by a conversion factor to obtain a final result in pounds.
(6.00 min/6.00 min)

An analysis of RY 2002 TRI data indicates that there was an average of approximately two offsite transfer locations and an average of approximately two reported “M” codes. Therefore, it is
assumed that on average, two unique waste streams are being transferred off-site. There are
economies of scale in estimating the quantity of the TRI chemical in the second waste stream due
to the concurrent activities of reviewing the same sources to determine the chemical
concentration in the waste and to estimate the annual quantity of waste transferred off-site. To
estimate the additional time needed to quantify the off-site transfer of the second waste stream
technical staff would perform the following:
G-34

4/28/11

Appendix G
•

For the second waste stream, determine the concentration of the chemical in the stream
by either reviewing waste characterization profiles, contacting the facility’s hazardous
waste shipper to obtain their waste characterization information, or conducting a mass
balance evaluation. Determine the total quantity of each unique waste stream that the
facility ships off-site during the reporting year. (5.00 min/5.00 min)

•

For the second waste stream, multiply the chemical concentration by the total quantity of
waste shipped off-site to calculate the total quantity of the chemical shipped off-site for
the year. If needed, multiply by a conversion factor to obtain a final result in pounds.
Calculate the total quantity of the chemical shipped off-site for all waste streams by
summing together the annual quantity of the chemical shipped off-site in each waste
stream. Report this result (lb/yr) in Part II, Section 6.2.A of the Form R. (6.00 min/6.00
min)

For both waste streams, technical staff would perform the following steps:
•

•

Report the type of waste treatment/disposal/recycling/energy recovery code by recording
the appropriate M-code in Section 6.2.C of the Form R. (0.25 min/0.25 min)

As indicated above, an analysis of RY 2002 TRI data showed that for off-site transfers, there was
an average of approximately two off-site transfer locations. For subsequent year reporting, it is
assumed the facility will not necessarily use the same off-site transfer locations. Due to the
competitive nature of the hazardous waste removal industry, market fluctuations, the search for
better pricing, and the fact that facilities can readily change vendors (unlike piping changes
needed to use a different POTW, for example), it is possible that facilities may be using different
off-site transfer locations from year-to-year. For this reason, it is not assumed that only one offsite transfer facility name and location will be pre-populated from loading last year’s forms, and
typing time is allotted to enter the second off-site transfer name and location information.
•

Technical staff will have the off-site transfer name and location information readily
available from document review conducted for the release estimate and will report this
information in Part II, Section 6.2.1 and 6.2.2 of the Form R. (4.17 min/2.08 min)

G-35

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Appendix G
Reporting Burden Associated with Part II, Section 6.2
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

4.83

3.42

Technical

112.17

84.58

Total

117.00

88.00

Management

Section 7A: On-Site Waste Treatment Methods and Efficiency
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (5.17 min/3.50min)
To complete Section 7A, technical staff perform the following steps:
•

Review process diagrams, review air or NPDES permits, or talk to the operations staff to
identify any on-site waste treatment activities. For the first waste stream, technical staff
perform the following steps:
•

Identify the type of waste stream (gaseous, wastewater, liquid waste, or solid
waste) and report the appropriate code in Part II, Section 7A.1a. (10.00 min/5.00
min)

•

Identify all of the treatment steps this waste stream passes through and the order
of occurrence. Locate the appropriate treatment codes representing the treatment
activity in the TRI Reporting Forms and Instructions and report them in the actual
order of occurrence in Part II, Section 7A.1b of the Form R. (20.00 min/5.00 min)

•

Locate and review monitoring data, or talk with operations staff to determine the range of
influent concentration. Report the appropriate range code for this concentration in Part
II, Section 7A.1.c of the Form R. (30.00 min/15.00 min)

•

Technical staff apply one of the approaches listed below to quantify the treatment
efficiency:
•

Review equipment manuals for manufacturer reported efficiencies.

•

Use pre- and post-treatment analytical data to calculate treatment efficiency by
subtracting the post-treatment chemical concentration from the pre-treatment
chemical concentration and then divide the result by the pre-treatment chemical
concentration.

•

Technical staff can also obtain the information by talking to operations staff.
G-36

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Appendix G
•

•

Report the treatment efficiency in Part II, Section 7A.1.d of the Form R (15.00
min/5.00 min).

Report whether the efficiency was calculated using monitoring data by checking yes or
no in Part II, Section 7A.1e of the Form R. (0.08 min/0.08 min)

An analysis of RY 2002 TRI data indicates that there was an average of approximately two waste
streams listed under on-site treatment in Section 7A. The additional steps technical staff would
take in identifying and reporting on-site treatment activities are outlined below. There are some
economies of scale in identifying on-site treatment activities for the second waste stream as a full
facility operations review was conducted as part of identifying if there are any waste streams
undergoing on-site treatment.
•

No additional time would be needed to identify types of waste streams undergoing on-site
treatment as the necessary review was already conducted to identify the first waste
stream. Therefore, no additional time is needed in Part II, Section 7A.2a for the second
waste stream (0.00min/0.00min).

•

Only incremental additional time would be needed to identify waste treatment activity
steps for the second waste stream as document review and discussions with operations
staff were already conducted to identify steps for the first waste stream. Therefore, the
following additional time is needed in Part II, Section 7A.2b for the second waste stream
(5.00min/2.00min).

•

Determining the range of the influent concentration for the second waste stream would
require the same time effort as for the first waste stream because technical staff would be
reviewing a different set of information, such as different laboratory reports. Therefore,
the following additional time is needed in Part II, Section 7A.2c for the second waste
stream (30.00min/15.00min).

•

Determining the treatment efficiency for the second waste stream would require the same
time effort as for the first waste stream because technical staff would be reviewing a
different set of information, such as different equipment manuals. Therefore, the
following additional time is needed in Part II, Section 7A.2d for the second waste stream
(15.00min/5.00min).

•

Report whether the efficiency for the second waste stream was calculated using
monitoring data by checking yes or no in Part II, Section 7A.2e of the Form R,. (0.08
min/0.08 min)

G-37

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Appendix G
Reporting Burden Associated with Part II, Section 7A
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

5.17

3.50

Technical

125.16

52.16

Total

130.33

55.66

Management

Section 7B: On-Site Energy Recovery Processes
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (1.0 min/0.83 min)
It is assumed that technical staff either review process flow diagrams or talk to operations staff in
order to identify any on-site energy recovery activities. For each waste stream that is undergoing
treatment for on-site energy recovery, technical staff locate the appropriate code for the activity
in the TRI Reporting Forms and Instructions. The codes are reported in descending order by
quantity of energy recycled in Part II, Section 7B of the Form R. (32.00 min/24.00 min)
Reporting Burden Associated with Part II, Section 7B
Personnel Type
Management

First Year Burden (minutes)
1.00

Subsequent Year Burden (minutes)
0.83

Technical

32.00

24.00

Total

33.00

24.83

Section 7C: On-Site Recycling Processes
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (1.0 min/0.83 min)
It is assumed that technical staff either review process flow diagrams or talk to operations staff in
order to identify any on-site recycling activities. For each waste stream that is undergoing
treatment for on-site recycling, technical staff locate the appropriate code for the activity in the
TRI Reporting Forms and Instructions. The codes are reported in descending order by quantity
of waste recycled in Part II, Section 7C of the Form R. (38.00 min/27.00 min)

G-38

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Appendix G
Reporting Burden Associated with Part II, Section 7C
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

1.00

0.83

Technical

38.00

27.00

Total

39.00

27.83

Section 8.1a: Total On-Site Disposal to Class I Underground Injection Wells, RCRA
Subtitle C Landfills, and Other Landfills
Management burden includes an assessment of whether quantities previously calculated for
Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as
proofreading this section as part of an overall review of the Form R. (0.50 min/0.50 min)
Four columns must be completed in this section, requiring technical staff to perform the
following steps:
•

Column A: Record "NA" in Part II, Section 8.1a, Column A of the Form R if the facility
is a first time filer. For subsequent reporting years, locate the release estimate from the
"Column B, Current Reporting Year" column from the previous year’s form and record
this quantity in Part II, Section 8.1a, Column A of the Form R. (0.25 min/0.25 min)

•

Column B: Sum together the quantities calculated in Part II, Sections 5.4.1, 5.5.1A, and
5.5.1B and then subtract any on-site release or disposal quantities due to catastrophic
events. Report the total quantity disposed of on-site via Class I Underground Injection
Wells, RCRA Subtitle C landfills, and other landfills in Part II, Section 8.1a, Column B
of the Form R. (5.00 min/5.00 min)

•

Column C: Make the best projection for the following year's release quantity and record
it in Part II, Section 8.1a, Column C of the Form R. If no source reduction activities are
planned, multiply the current year release estimate by the expected percentage change in
production for the following year. If source reduction activities are planned, make the
best estimate for how much this will reduce the release quantity for the following year.
(1.00 min/1.00 min)

•

Column D: Make the best projection for the second following year's release quantity and
record it in Part II, Section 8.1a, Column D of the Form R. If no source reduction
activities are planned, multiply the current year release estimate by the expected
percentage change in production for the second following year. If source reduction
activities are planned, make the best estimate of how much this will reduce the release
quantity for the second following year. (1.00 min/1.00 min)
Reporting Burden Associated with Part II, Section 8.1a
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Appendix G
Personnel Type
Management

First Year Burden (minutes)
0.50

Subsequent Year Burden (minutes)
0.50

Technical

7.25

Total

7.75

Section 8.1b: Total Other On-Site Disposal or Other Releases
Management burden includes an assessment of whether quantities previously calculated for
Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as
proofreading this section as part of an overall review of the Form R. (0.50 min/0.50 min)
Four columns must be completed in this section, requiring technical staff to perform the
following steps:
•

Column A: Record "NA" in Part II, Section 8.1b, Column A of the Form R if the facility
is a first time filer. For subsequent reporting years, locate the release estimate from the
"Column B, Current Reporting Year" column from the previous year’s form and record
this quantity in Part II, Section 8.1b, Column A of the Form R. (0.25 min/0.25 min)

•

Column B: Sum together the quantities calculated in Part II, Sections 5.1, 5.2, 5.3, 5.4.2,
5.5.2, 5.5.3A, 5.5.3B, and 5.5.4 and then subtract any on-site release or disposal
quantities due to catastrophic events. Report the total quantity disposed of on-site via
other disposal or other releases in Part II, Section 8.1b, Column B of the Form R. (5.00
min/5.00 min)

•

Column C: Make the best projection for the following year's release quantity and record
it in Part II, Section 8.1b, Column C of the Form R. If no source reduction activities are
planned, multiply the current year release estimate by the expected percentage change in
production for the following year. If source reduction activities are planned, make the
best estimate for how much this will reduce the release quantity for the following year.
(1.00 min/1.00 min)

•

Column D: Make the best projection for the second following year's release quantity and
record it in Part II, Section 8.1b, Column D of the Form R. If no source reduction
activities are planned, multiply the current year release estimate by the expected
percentage change in production for the second following year. If source reduction
activities are planned, make the best estimate of how much this will reduce the release
quantity for the second following year. (1.00 min/1.00 min)

G-40

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Appendix G
Reporting Burden Associated with Part II, Section 8.1b
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

0.5

0.50

Technical

7.25

Total

7.75

Section 8.1c: Total Off-Site Disposal to Class I Underground Injection Wells, RCRA
Subtitle C Landfills, and Other Landfills
Management burden includes an assessment of whether quantities previously calculated for
Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as
proofreading this section as part of an overall review of the Form R. (0.50 min/0.50 min)
Four columns must be completed in this section, requiring technical staff to perform the
following steps:
•

Column A: Record "NA" in Part II, Section 8.1c, Column A of the Form R if the facility
is a first time filer. For subsequent reporting years, locate the release estimate from the
"Column B, Current Reporting Year" column from the previous year’s form and record
this quantity in Part II, Section 8.1c, Column A of the Form R. (0.25 min/0.25 min)

•

Column B: Sum together the quantities calculated in Part II, Sections 6.1 (portion of
transfer that is untreated and ultimately disposed of in UIC Class I Wells, RCRA Subtitle
C landfills and other landfills) and 6.2 (quantities associated with M codes M64, M65,
and M81) and then subtract any off-site disposal quantities due to catastrophic events.
Report the total quantity disposed of off-site via Class I Underground Injection Wells,
RCRA Subtitle C landfills, and other landfills in Part II, Section 8.1c, Column B of the
Form R. (5.00 min/5.00 min)

•

Column C: Make the best projection for the following year's release quantity and record
it in Part II, Section 8.1c, Column C of the Form R. If no source reduction activities are
planned, multiply the current year release estimate by the expected percentage change in
production for the following year. If source reduction activities are planned, make the
best estimate for how much this will reduce the release quantity for the following year.
(1.00 min/1.00 min)

•

Column D: Make the best projection for the second following year's release quantity and
record it in Part II, Section 8.1c, Column D of the Form R. If no source reduction
activities are planned, multiply the current year release estimate by the expected
percentage change in production for the second following year. If source reduction
activities are planned, make the best estimate of how much this will reduce the release
quantity for the second following year. (1.00 min/1.00 min)
G-41

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Appendix G
Reporting Burden Associated with Part II, Section 8.1c
Personnel Type
Management

First Year Burden (minutes)
0.5

Subsequent Year Burden (minutes)
0.50

Technical

7.25

Total

7.75

Section 8.1d: Total Other Off-Site Disposal or Other Releases
Management burden includes an assessment of whether quantities previously calculated for
Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as
proofreading this section as part of an overall review of the Form R. (0.50 min/0.50 min)
Four columns must be completed in this section, requiring technical staff to perform the
following steps:
•

Column A: Record "NA" in Part II, Section 8.1d, Column A of the Form R if the facility
is a first time filer. For subsequent reporting years, locate the release estimate from the
"Column B, Current Reporting Year" column from the previous year’s form and record
this quantity in Part II, Section 8.1d, Column A of the Form R. (0.25 min/0.25 min)

•

Column B: Sum together the quantities calculated in Part II, Sections 6.1 (portion of
transfer that is untreated and ultimately disposed of in UIC Class II-V Wells, and land
disposal other than to landfills) and 6.2 (quantities associated with M codes M10, M41,
M62, M66, M67, M73, M79, M82, M90, M94, and M99) and then subtract any off-site
disposal quantities due to catastrophic events. Report the total quantity disposed of offsite via other disposal or other releases in Part II, Section 8.1d, Column B of the Form R.
(5.00 min/5.00 min)

•

Column C: Make the best projection for the following year's release quantity and record
it in Part II, Section 8.1d, Column C of the Form R. If no source reduction activities are
planned, multiply the current year release estimate by the expected percentage change in
production for the following year. If source reduction activities are planned, make the
best estimate for how much this will reduce the release quantity for the following year.
(1.00 min/1.00 min)

•

Column D: Make the best projection for the second following year's release quantity and
record it in Part II, Section 8.1d, Column D of the Form R. If no source reduction
activities are planned, multiply the current year release estimate by the expected
percentage change in production for the second following year. If source reduction
activities are planned, make the best estimate of how much this will reduce the release
quantity for the second following year. (1.00 min/1.00 min)
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Appendix G
Reporting Burden Associated with Part II, Section 8.1d
Personnel Type
Management

First Year Burden (minutes)
0.50

Subsequent Year Burden (minutes)
0.50

Technical

7.25

Total

7.75

Section 8.2: Quantity Used for Energy Recovery On-Site
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (1.25 min/1.08 min)
Four columns must be completed in this section, requiring technical staff to perform the
following steps:
•

Column A: Record "NA" in Part II, Section 8.2, Column A of the Form R if the facility
is a first time filer. For subsequent reporting years, locate the release estimate from the
"Column B, Current Reporting Year" column from the previous year’s form and record
this quantity in Part II, Section 8.2, Column A of the Form R. (0.25 min/0.25 min)

•

Column B: To estimate the quantity of the chemical used annually for actual energy
recovery on-site, refer to the recovery processes reported in Section 7B and either review
operations records or speak with operations staff. Report the total quantity used for
energy recovery on-site in Part II, Section 8.2, Column B of the Form R. (30.00
min/30.00 min)

•

Column C: Make the best projection for the following year's release quantity and record
it in Part II, Section 8.2, Column C of the Form R. If no source reduction activities are
planned, multiply the current year release estimate by the expected percentage change in
production for the following year. If source reduction activities are planned, make the
best estimate for how much this will reduce the release quantity for the following year.
(1.00 min/1.00 min)

•

Column D: Make the best projection for the second following year's release quantity and
record it in Part II, Section 8.2, Column D of the Form R. If no source reduction
activities are planned, multiply the current year release estimate by the expected
percentage change in production for the second following year. If source reduction
activities are planned, make the best estimate of how much this will reduce the release
quantity for the second following year. (1.00 min/1.00 min)

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Appendix G
Reporting Burden Associated with Part II, Section 8.2
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

1.25

1.08

Technical

32.25

Total

33.50

33.33

Section 8.3: Quantity Used for Energy Recovery Off-Site
Management burden includes an assessment of whether quantities previously calculated for
Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as
proofreading of this section as part of an overall review of the Form R. (0.50 min/0.50 min)
Four columns must be completed in this section, requiring technical staff to perform the
following steps:
•

Column A: Record "NA" in Part II, Section 8.3, Column A of the Form R if the facility is
a first time filer. For subsequent reporting years, locate the release estimate from the
"Column B, Current Reporting Year" column from the previous year’s form and record
this quantity in Part II, Section 8.3, Column A of the Form R. (0.25 min/0.25 min)

•

Column B: To estimate the quantity of the chemical used annually for energy recovery
off-site, subtract Section 8.8 (off-site energy recovery due to catastrophic events) from
Section 6.2 (quantities associated with energy recovery) and report the value in Part II,
Section 8.3, Column B of the Form R. (5.00 min/5.00 min)

•

Column C: Make the best projection for the following year's release quantity and record
it in Part II, Section 8.3, Column C of the Form R. If no source reduction activities are
planned, multiply the current year release estimate by the expected percentage change in
production for the following year. If source reduction activities are planned, make the
best estimate for how much this will reduce the release quantity for the following year.
(1.00 min/1.00 min)

•

Column D: Make the best projection for the second following year's release quantity and
record it in Part II, Section 8.3, Column D of the Form R. If no source reduction
activities are planned, multiply the current year release estimate by the expected
percentage change in production for the second following year. If source reduction
activities are planned, make the best estimate of how much this will reduce the release
quantity for the second following year. (1.00 min/1.00 min)

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Appendix G
Reporting Burden Associated with Part II, Section 8.3
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

0.5

0.50

Technical

7.25

Total

7.75

Section 8.4: Quantity Recycled On-Site
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (1.25 min/1.08 min)
Four columns must be completed in this section, requiring technical staff to perform the
following steps:
•

Column A: Record "NA" in Part II, Section 8.4, Column A of the Form R if the facility
is a first time filer. For subsequent reporting years, locate the release estimate from the
"Column B, Current Reporting Year" column from the previous year’s form and record
this quantity in Part II, Section 8.4, Column A of the Form R. (0.25 min/0.25 min)

•

Column B: Estimate the quantity of the chemical actually recycled on-site annually by
reviewing the information identified for Section 7C and either review operations records
or speak with operations staff. Report the total quantity recycled on-site in Part II,
Section 8.4, Column B of the Form R. (30.00 min/30.00 min)

•

Column C: Make the best projection for the following year's release quantity and record
it in Part II, Section 8.4, Column C of the Form R. If no source reduction activities are
planned, multiply the current year release estimate by the expected percentage change in
production for the following year. If source reduction activities are planned, make the
best estimate for how much this will reduce the release quantity for the following year.
(1.00 min/1.00 min)

•

Column D: Make the best projection for the second following year's release quantity and
record it in Part II, Section 8.4, Column D of the Form R. If no source reduction
activities are planned, multiply the current year release estimate by the expected
percentage change in production for the second following year. If source reduction
activities are planned, make the best estimate of how much this will reduce the release
quantity for the second following year. (1.00 min/1.00 min)

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Appendix G
Reporting Burden Associated with Part II, Section 8.4
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

1.25

1.08

Technical

32.25

Total

33.50

33.33

Section 8.5: Quantity Recycled Off-Site
Management burden includes an assessment of whether quantities previously calculated for
Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as
proofreading this section as part of an overall review of the Form R. (0.50 min/0.50 min)
Four columns must be completed in this section, requiring technical staff to perform the
following steps:
•

Column A: Record "NA" in Part II, Section 8.5, Column A of the Form R if the facility
is a first time filer. For subsequent reporting years, locate the release estimate from the
"Column B, Current Reporting Year" column from the previous year’s form and record
this quantity in Part II, Section 8.5, Column A of the Form R. (0.25 min/0.25 min)

•

Column B: To estimate the quantity of the chemical recycled annually off-site, subtract
Section 8.8 (off-site recycling due to catastrophic events) from Section 6.2 (quantities
associated with recycling) and report the value in Part II, Section 8.5, Column B of the
Form R. (5.00 min/5.00 min)

•

Column C: Make the best projection for the following year's release quantity and record
it in Part II, Section 8.5, Column C of the Form R. If no source reduction activities are
planned, multiply the current year release estimate by the expected percentage change in
production for the following year. If source reduction activities are planned, make the
best estimate for how much this will reduce the release quantity for the following year.
(1.00 min/1.00 min)

•

Column D: Make the best projection for the second following year's release quantity and
record it in Part II, Section 8.5, Column D of the Form R. If no source reduction
activities are planned, multiply the current year release estimate by the expected
percentage change in production for the second following year. If source reduction
activities are planned, make the best estimate of how much this will reduce the release
quantity for the second following year. (1.00 min/1.00 min)

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Appendix G
Reporting Burden Associated with Part II, Section 8.5
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

0.5

0.50

Technical

7.25

Total

7.75

Section 8.6: Quantity Treated On-Site
Management burden includes review of data, methods, and assumptions used to develop the
estimate. In some cases it also includes data quality activities such as comparing the values with
previous years. (1.25 min/1.08 min)
Four columns must be completed in this section, requiring technical staff to perform the
following steps:
•

Column A: Record "NA" in Part II, Section 8.6, Column A of the Form R if the facility
is a first time filer. For subsequent reporting years, locate the release estimate from the
"Column B, Current Reporting Year" column from the previous year’s form and record
this quantity in Part II, Section 8.6, Column A of the Form R. (0.25 min/0.25 min)

•

Column B: Estimate the quantity of the chemical actually treated on-site annually by
reviewing the information identified for Section 7A and either review operations records
or speak with operations staff. The total quantity treated on-site is reported in Part II,
Section 8.6, Column B of the Form R. (30.00 min/30.00 min)

•

Column C: Make the best projection for the following year's release quantity and record
it in Part II, Section 8.6, Column C of the Form R. If no source reduction activities are
planned, multiply the current year release estimate by the expected percentage change in
production for the following year. If source reduction activities are planned, make the
best estimate for how much this will reduce the release quantity for the following year.
(1.00 min/1.00 min)

•

Column D: Make the best projection for the second following year's release quantity and
record it in Part II, Section 8.6, Column D of the Form R. If no source reduction
activities are planned, multiply the current year release estimate by the expected
percentage change in production for the second following year. If source reduction
activities are planned, make the best estimate of how much this will reduce the release
quantity for the second following year. (1.00 min/1.00 min)

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Appendix G
Reporting Burden Associated with Part II, Section 8.6
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

1.25

1.08

Technical

32.25

Total

33.50

33.33

Section 8.7: Quantity Treated Off-Site
Management burden includes an assessment of whether quantities previously calculated for
Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as
proofreading this section as part of an overall review of the Form R. (0.50 min/0.50 min)
Four columns must be completed in this section, requiring technical staff to perform the
following steps:
•

Column A: Record "NA" in Part II, Section 8.7, Column A of the Form R if the facility is
a first time filer. For subsequent reporting years, locate the release estimate from the
"Column B, Current Reporting Year" column from the previous year’s form and record
this quantity in Part II, Section 8.7, Column A of the Form R. (0.25 min/0.25 min)

•

Column B: To estimate the quantity of the chemical treated off-site, sum together the
quantities from Section 6.1 (excluding most metal/metal category compounds) and
Section 6.2 (the quantities associated with treatment) and then subtract any portion of
Section 8.8 associated with off-site treatment due to catastrophic events. Report the total
quantity treated off-site in Part II, Section 8.7, Column B of the Form R. (5.00 min/5.00
min)

•

Column C: Make the best projection for the following year's release quantity and record
it in Part II, Section 8.7, Column C of the Form R. If no source reduction activities are
planned, multiply the current year release estimate by the expected percentage change in
production for the following year. If source reduction activities are planned, make the
best estimate for how much this will reduce the release quantity for the following year.
(1.00 min/1.00 min)

•

Column D: Make the best projection for the second following year's release quantity and
record it in Part II, Section 8.7, Column D of the Form R. If no source reduction
activities are planned, multiply the current year release estimate by the expected
percentage change in production for the second following year. If source reduction
activities are planned, make the best estimate of how much this will reduce the release
quantity for the second following year. (1.00 min/1.00 min)

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Appendix G
Reporting Burden Associated with Part II, Section 8.7
Personnel Type

First Year Burden (minutes)

Subsequent Year Burden (minutes)

Management

0.50

Technical

7.25

Total

7.75

Section 8.8: Quantity released to the Environment as a Result of Remedial Actions,
Catastrophic Events, or One-Time Events not Associated with Production Processes
Management burden includes an assessment of whether quantities previously calculated for
Sections 5 and 6 have been recorded in the correct subsection of Section 8 as well as
proofreading this section as part of an overall review of the Form R. (0.25 min/0.25 min)
Technical staff sum together the relevant quantities already estimated and record them in Part II,
Section 8.8, Column B of the Form R. (5.00 min/5.00 min)
Reporting Burden Associated with Part II, Section 8.8
Personnel Type
Management

First Year Burden (minutes)
0.25

Subsequent Year Burden (minutes)
0.25

Technical

5.00

Total

5.25

Section 8.9: Production Ratio or Activity Index
Management burden includes review of data, methods, and assumptions used to develop the
production ratio; and in some cases, data quality activities such as comparing the values with
previous years. (0.83 min/0.83 min)
Technical staff would perform the following steps to calculate the production ratio or activity
index:
•

Determine the annual production or activity level for the reporting year by either
reviewing production records or maintenance logs, or talking with the operations staff.
(30.00 min/30.00 min)

•

Determine the annual production or activity level for the previous year by reviewing
maintenance records or talking with operations staff. (5.00 min/5.00 min)

•

Divide the current year’s production or activity level by the prior year’s production or
activity level. Alternatively, review the waste minimization section of the RCRA report.
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Appendix G
Report the production ratio or activity index in Part II, Section 8.9 of the Form R. (1.00
min/1.00 min)
For facilities reporting for the first year, a production ratio is required if the facility
manufactured, processed or otherwise used the TRI chemical in the previous year, even if no
thresholds were exceeded. While some first year reports will be for completely new operations,
others will be for facilities that have exceeded threshold for the first time. For this reason, it was
assumed that calculation of the production ratio would be required for first year reports.
Reporting Burden Associated with Part II, Section 8.9
Personnel Type
Management

First Year Burden (minutes)
0.83

Subsequent Year Burden (minutes)
0.83

Technical

36.00

Total

36.83

Section 8.10: Did Your Facility Engage in any Source Reduction Activities?
Management burden includes review of data and methods used to identify source reduction
activities. (1.08 min/0.92 min)
To identify whether or not any source reduction activities were implemented, technical staff
either review SOPs; review any process, equipment, or material input changes; review the waste
minimization section of the RCRA report; or talk with operations staff. If source reduction
activities were implemented, technical staff locate the source reduction codes in the Reporting
Forms and Instructions and enter the codes in Section 8.10.1 of the Form R. Technical staff
enter the appropriate codes for Methods to Identify Activity in Section 8.10.1.a. (35.25
min/35.25 min)
Reporting Burden Associated with Part II, Section 8.10
Personnel Type
Management

First Year Burden (minutes)
1.08

Subsequent Year Burden (minutes)
0.92

Technical

35.25

Total

36.33

36.17

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Appendix G
Section 8.11: Is Additional Information on Source Reduction, Recycling or Pollution
Control Activities Included with this Report?
Provision of additional information on source reduction, recycling, or pollution control activities
is optional; therefore, there is no management, technical, nor clerical burden associated with this
element of the Form R.
Reporting Burden Associated with Part II, Section 8.11
Personnel Type
Management

First Year Burden (minutes)
0

Subsequent Year Burden (minutes)
0.00

0.00

Technical
Total

2.1.B. Results for Electronic Submission
Table 4 summarizes the total reporting burden associated with electronic submissions of PBT
and non-PBT forms. Tables 5 and 6 (refer to Excel spreadsheet) present the realistic and
incidence weighted reporting burden for every data element on the Form R for first year
electronic submissions of PBT and non-PBT reports. Tables 7 and 8 (refer to Excel spreadsheet)
present the realistic and incidence weighted reporting burden for every data element on the Form
R for subsequent year electronic submissions of PBT and non-PBT reports.
TABLE 4
TOTAL REPORTING BURDEN FOR ELECTRONIC SUBMISSIONS
Estimated realistic time per form (hr) Incidence weighted time per form (hr)
Management

Technical

Total

Management

Technical

Total

PBT

0.99

29.51

30.50

0.34

9.20

9.54

Non-PBT

0.98

29.38

30.36

0.37

10.49

10.86

First year

Subsequent years
PBT

0.77

20.98

21.75

0.29

6.17

6.46

Non-PBT

0.77

20.97

21.74

0.32

6.89

7.21

2.1.C. Methodology for Paper Submission
The only difference between electronic and paper submissions for first year and subsequent year
Form R reporting burden is clerical time. To generate a paper copy, clerical staff would take the
information prepared by the technical staff and type it onto a paper copy of the Form R.
Therefore, for both PBT and non-PBT chemicals, clerical times were estimated by dividing the
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G-51

Appendix G
currently approved OMB clerical times (Table 1) by the total number of fields on the Form R.
While it may not take the exact same amount of time to line up each data element for typing,
there is no reasonable way to estimate this, so giving equal time to each element was determined
to be the best method. The clerical time allotted to each element was then added to the estimate
for the electronic form (including management and technical time) for that element to generate
time estimates for every data element for PBT and non-PBT first and subsequent year reporting
via a paper Form R.
2.1.D. Results for Paper Submission
Table 9 summarizes the total reporting burden for paper submission of PBT and non-PBT forms.
Tables 10 and 11 (refer to Excel spreadsheet) present the realistic and incidence weighted
reporting burden for every data element on the Form R for first year paper submissions of PBT
and non-PBT reports. Tables 12 and 13 (refer to Excel spreadsheet) present the realistic and
incidence weighted reporting burden for every data element on the Form R for subsequent year
paper submissions of PBT and non-PBT reports.
TABLE 9
TOTAL REPORTING BURDEN FOR PAPER SUBMISSIONS
Estimated realistic time per form (hr)

Incidence weighted time per form (hr)

Management Technical Clerical Total Management Technical Clerical Total
First year
PBT

1.01

29.51

2.90

33.42

0.35

9.20

1.59

11.14

NonPBT

0.99

29.38

1.62

31.99

0.38

10.49

0.93

11.80

Subsequent years
PBT

0.78

21.17

2.00

23.95

0.30

6.33

1.10

7.73

NonPBT

0.78

21.17

1.10

23.05

0.33

7.05

0.63

8.01

3. SCALED REPORTING BURDEN ESTIMATES
3.1 Scaled Estimate for PBT Chemicals
In this section, the realistic technical reporting burden estimates developed for PBT chemicals
are used in combination with the currently-approved OMB form completion reporting burden
estimates to generate burden estimates for each data element consistent with the OMB total.
Four individual reporting burden scenarios are scaled up: first year electronic, subsequent year
electronic, first year paper, and subsequent year paper. The incidence weighted values are not
G-52

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Appendix G
used for PBT chemicals because the OMB burden estimate assumes all Form R fields are filled
out by all reporters.
3.1.A. Methodology for Scaled PBT Chemical Electronic Submissions
The OMB-approved form completion burden estimates for PBT first and subsequent year
technical burden are 45.2 and 30.8 hours, respectively. The following procedure was used to
scale the realistic electronic PBT data element burden estimates to these OMB-approved burden
estimates. Reporting burden is estimated for both first and subsequent years.
•

Technical reporting burden for data elements requiring only typing or typing plus a quick
information look-up (such as locating the facility’s D&B number) was estimated (86.25
min, 13.42 min). The times for these steps were assumed static and, therefore, were not
scaled up.

•

Total static time was subtracted from both the OMB approved technical burden (2712.0
min, 1848.0 min) and the total realistic technical burden (1770.32 min, 1258.51 min) to
estimate the total OMB (2625.75 min, 1834.58 min) and realistic (1684.07 min, 1245.09
min) times for those Form R data elements that require more complex information
gathering and calculations.

•

The OMB approved technical burden for nonstatic data elements was divided by the PBT
realistic burden for nonstatic data elements (i.e., 2625.75/1770.32; 1834.58/1258.71) to
calculate a scaling factor (1.56, 1.47). (Note that the PBT realistic estimates used here
were not incidence-weighted, as the OMB assumption for the current estimate for PBT
chemicals is that all data elements are completed).

•

The scaling factor was applied to all of the nonstatic realistic data element burden
estimates.

•

Realistic management burden estimates were generated by multiplying the scaled up
realistic technical burdens by the 20.9/45.2 or 14.3/30.8 hr ratio of management to
technical burden in the current OMB-approved burden estimate for first and subsequent
year reporting for PBT chemicals, respectively.

•

Scaled up management and technical times were added together for each data element to
estimate a total time for that data element.

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Appendix G
3.1.B. Results for PBT Chemical Electronic Submissions
Table 14 (refer to Excel spreadsheet) presents scaled management and technical burden estimates
for completing each data element of the Form R for first and subsequent year electronic
submissions of PBT reports.
3.1.C. Methodology for PBT Chemical Paper Submissions
The only difference between electronic and paper submission for Form R reporting burden is the
clerical time needed for typing. To generate a paper copy, clerical staff would take the
information prepared by the technical staff and type it onto a paper copy of the Form R. The
time required to type information into one data element on the Form R was considered to be
static and unrelated to the relative degree of difficulty in determining the information to be
entered into the field. For this reason, clerical time was not determined by scaling from the
realistic estimates generated for technical time. Instead, clerical times were estimated by
dividing the currently approved OMB clerical burden (Table 1) for PBT chemical submission by
the total number of data elements on the Form R.
While it may not take the exact same amount of time to line up each data element for typing,
there is no reasonable way to estimate this, so giving equal time to each element was determined
to be the best method. The clerical time allotted to each element was then added to the estimate
for the electronic form (including management and technical time) for that element to generate
scaled time estimates for every data element for PBT first and subsequent year reporting via a
paper Form R.
3.1.D. Results for PBT Chemical Paper Submission
Table 15 (refer to Excel spreadsheet) presents scaled management, technical, and clerical burden
estimates for completing each data element of the Form R for first and subsequent year
submissions of paper PBT chemical reports.
3.2 Scaled Estimate for non-PBT Chemicals
In this section, the realistic technical reporting burden estimates developed for non-PBT
chemicals are used in combination with the currently-approved OMB form completion reporting
burden estimates to generate burden estimates for each data element consistent with the OMB
total. Four individual reporting burden scenarios are scaled up: first year electronic, subsequent
year electronic, first year paper, and subsequent year paper. The incidence weighted values are
used for non-PBT chemicals because the OMB burden estimates for non-PBT chemicals are
based on actual reporting burden data from facilities.

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Appendix G
3.2.A. Methodology for non-PBT Chemical Electronic Submissions
The OMB-approved form completion burden estimate for non-PBT subsequent year technical
burden is 16.4 hours. A first-year estimate for non-PBT technical burden of 24.1 hours was
estimated by multiplying the subsequent year estimate by 147 percent. 1 The following
procedure was used to scale the realistic electronic non-PBT burden estimates to these OMBapproved burden estimates. Reporting burden is estimated for both first and subsequent years.
•

Technical reporting burden for data elements requiring only typing or typing plus a quick
information look-up (such as locating the facility’s D&B number) was estimated (59.0
min, 6.4min). The times for these steps were assumed static and, therefore, were not
scaled up.

•

Total static time was subtracted from both the OMB approved technical burden (1446.48
min, 984.0 min) and the total incidence-weighted realistic technical burden (629.49 min,
413.18 min) to estimate the total OMB (1387.48 min, 977.60 min) and realistic (570.49
min, 406.79 min) times for those Form R data elements that require more complex
information gathering and calculations.

•

The OMB approved technical burden for nonstatic data elements was divided by the nonPBT realistic burden for nonstatic data elements (i.e., 1387.48/570.49; 977.60/406.79) to
calculate a scaling factor (2.43, 2.40).

•

The scaling factor was applied to all of the nonstatic realistic data element burden
estimates.

•

Realistic management burdens were generated by multiplying the scaled up realistic
technical burdens by the 11.3/24.1 or 7.7/16.4 hr ratio of management to technical burden
in the current OMB-approved burden estimate for first and subsequent non-PBT
chemicals, respectively.

•

Scaled up management and technical times were added together for each data element to
estimate a total time for that data element.

An OMB-approved estimate for first time non-PBT filers does not exist; however, the RIA for
the original Section 313 rulemaking estimated the time required to complete a report in the first year to be
147% of the time required in subsequent years. This factor was applied to the OMB approved subsequent
year non-PBT report completion times to calculate the first year non-PBT completion times. (U.S. EPA
Regulatory Impact Analysis in Support of Final Rulemaking under Section 313 of Title III of the
Superfund Amendments and Reauthorization Act of 1986 (1988).

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Appendix G
3.2.B. Results for non-PBT Chemical Electronic Submissions
Table 16 (refer to Excel spreadsheet) presents scaled management and technical burden estimates
for completing each field of the Form R for first and subsequent year electronic submissions of
non-PBT reports.
3.2.C. Methodology for non-PBT Chemical Paper Submissions
The only difference between electronic and paper submission for Form R reporting burden is the
clerical time needed for typing. To generate a paper copy, clerical staff would take the
information prepared by the technical staff and type it onto a paper copy of the Form R. The
time required to type information into one data element on the Form R was considered to be
static and unrelated to the relative degree of difficulty in determining the information to be
entered into the field. For this reason, clerical time was not determined by scaling from the
realistic estimates generated for technical time. Instead, clerical times were estimated by
dividing the currently approved OMB clerical burden (Table 1) for non-PBT chemicals by the
total number of fields on the Form R.
While it may not take the exact same amount of time to line up each data element for typing,
there is no reasonable way to estimate this, so giving equal time to each element was determined
to be the best method. The clerical time allotted to each element was then added to the estimate
for the electronic form (including management and technical time) for that element to generate
time estimates for every data element for non-PBT first and subsequent year reporting via a
paper Form R.
3.2.D. Results for non-PBT Chemical Paper Submissions
Table 17 (refer to Excel spreadsheet) presents realistic management, technical, and clerical
burden estimates for completing each data element of the Form R for first and subsequent year
paper submissions of non-PBT reports.

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Appendix G

memorandum
To:

Laura Nielsen, U.S. EPA

From:

Susan Day

Date:

December 2, 2010

Subject:

Modified TRI Reporting Burden Estimates for Rule Familiarization and
Compliance Determination
________________________________________________________________________
1. INTRODUCTION
EPA currently relies on previously developed OMB approved TRI reporting burden estimates
that reflect the total time required by facilities to complete activities such as rule familiarization,
compliance determination, form completion, record keeping/mailing, and supplier notification.
In an earlier analysis (2004), Abt Associates Inc. developed new burden estimates for form
completion, broken down by the individual data elements that make up the Form R. 1 In that
assessment, a list of activities a facility typically conducts to complete each data element was
developed. Next, best professional judgment was used to estimate the time needed to complete
each activity. Finally, these times were summed together. The total form completion time
developed through that assessment was referred to as the “realistic burden.” This memo
summarizes the application of the same methodology to rule familiarization and compliance
determination in an analysis completed in 2005. “Realistic burden” estimates for each are
presented below.
In order to develop standardized estimates that are meaningful across the range of facility types,
sizes, and sectors reporting to TRI, the realistic burden is set to reflect activities at a typical TRIreporting facility. Assumptions about the typical facility are outlined below.

TRI Reporting Burden Estimates, Memo from Hilary Eustace, David Cooper, Susan Day, Abt Associates to Paul
Borst, EPA, July 16, 2004. Docket # EPA-HQ-TRI-2005-0073-0012.

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Appendix G
The typical facility:
• is mid-sized (somewhere between a small, single activity shop and a very large, very
complex operation).
• is representative of all sectors covered under TRI.
• is reasonably modern and well-organized.
• has internet access with reasonable connection speed.
• has technical staff with sufficient expertise to readily understand the chemical and industrial
concepts necessary for TRI program comprehension.
• will not be right at threshold for employees or chemicals, but will be well above or well
below threshold. Therefore, once these determinations are made, they will not need to be reassessed every year.
• conducts quantitative threshold assessments for 6 chemicals, and files TRI reports for 3 of
these. Each chemical is typically involved in only one threshold activity.
2. COMPLIANCE DETERMINATION
2.1 Realistic Burden – First Year
To make a compliance determination the typical facility will need to conduct facility level
activities such as NAICS code and employee assessment and a chemical list determination. In
addition, chemical-specific threshold quantity determinations must be made. The activities a
typical facility would conduct in making their compliance determination and associated burden
estimates are presented in this section.
2.1.1 Facility Level Activities
NAICS Code Assessment
To conduct the NAICS code assessment, (i.e., is the facility in an EPCRA section 313-covered
NAICS code?) technical staff will call accounting or other corporate department for this
information (10.00 min/0.17 hour).
Employee Threshold Assessment
To conduct the employee threshold assessment, (i.e., does the facility exceed the EPCRA section
313 20,000 hour employee threshold?) technical staff will determine the whole set of full- and
part-time employees, temps, contractors (excepting drivers and janitorial contractors), and offsite corporate support by checking with payroll and other management, supervisory, or
accounting staff as necessary (30.00 min/0.5 hour).
Next, technical staff will calculate the total hours worked by this group during the full calendar
year or up until a clear determination is made that the facility is above or below the 20,000 hour
threshold by summing together quantities on timesheets or accounting system totals (30.00 min/
0.5 hour).
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Appendix G
Chemical List Determination
To determine which TRI chemicals are present, technical staff will:
• Compare all materials (including mixtures, alloys, and fuels) used/manufactured at the
facility to the EPCRA section 313 (TRI) list. This task will involve:
o Gathering all MSDSs, or other batch info, product specs, certificates of analysis,
labeling information, etc (60.00 mins/1.0 hour).
o Reviewing the “Regulatory Information” section of the MSDS. Where an MSDS
is not available, technical staff will compare available supplier data on chemical
constituents with the TRI chemical list (90.00 min/1.5 hours).
o For PBT chemicals, technical staff will assess if there are likely PBT chemicals
present at below de minimis in mixtures used by the facility. This step is needed
since the de minimis exemption is allowed for supplier notification, but is not
allowed for PBT chemicals for threshold determination or release reporting (60.00
min/1.0 hour).
Table 1: Facility-Level Compliance Determination Burden
NAICS Code Assessment
0.17 technical hours
Employee Threshold Assessment
1.0 technical hours
Chemical List Determination
3.5 technical hours
Total
4.67 technical hours
2.1.2 Chemical-Specific Activities
As mentioned above, the typical facility will conduct quantitative threshold assessments for six
chemicals. For each TRI chemical, technical staff will review all manufacture/uses of the
chemical at the facility to determine if they fall under the definition of manufacture, process, or
otherwise use. This task will involve talking with operations staff, facility chemists, reviewing
process flow diagrams, conducting facility walkthrough and reviewing standard operating
procedures (30.00 min/0.5 hours).
For each TRI chemical manufactured, processed, or otherwise used, technical staff will
determine the total annual quantity of the chemical for each threshold activity. This activity will
include determining the percentage of the TRI chemical in a mixture, alloy, or fuel. The method
to calculate threshold quantity for process OR otherwise use is:
• Determine the material usage quantity within each applicable threshold activity through a
review of inventory records, purchase records, operation records, or discussions with
operations staff (30.00 mins/0.5 hours). This task may require a determination of the total
material usage quantity through inventory or purchase records, followed by dividing this total
into the different threshold activities through operations records or discussions with
operations staff. For the purposes of this analysis, however, it is assumed that each chemical
typically falls within only one threshold activity.
• If the material used is a mixture, determine the chemical concentration in the mixture through
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•

Appendix G
a review of the MSDS, batch analysis, or other supplier information (30.00 min/0.5 hours).
Multiply total material usage quantity by chemical concentration to determine total annual
chemical usage quantity (2.00 min/0.03 hours).

The total time required to calculate a threshold quantity for process or otherwise use is 62.00
min/1.0 hour.
For intentional manufacture, technical staff will determine the annual quantity manufactured
through production records (30.00 min/0.5 hours).
The method used to calculate the threshold quantity for coincidental manufacture is to determine
the annual quantity for combustion products and reaction by-products or impurities as follows:
• Combustion products: Technical staff will determine the annual quantity manufactured
through use of emission factors by:
o Locating the most applicable emission factor. Numerous EPA sources are
available such as AP-42 TRI chemical specific and industry specific guidance.
Non-EPA sources include university research and trade associations (30.00
min/0.5 hours).
o Determining the annual quantity of input material by reviewing purchase records,
inventory records, and/or operational records (30.00 min/0.5 hours).
o Multiplying this material usage quantity by the emission factor to determine the
amount of material released from each point during the year and, if necessary,
converting the amount of material released to pounds (or grams for dioxins) by
applying the appropriate conversion factor (6.00 min/0.1 hours).
o Finding the average pollution control efficiency for the emission factor from the
AP-42 listing or emission factor source, or identifying if the emission factor was
generated from uncontrolled sources. Using this pollution control efficiency,
technical staff will extrapolate the total quantity generated from the quantity
emitted (10.00 min/0.17 hours).
o The total time required to calculate a threshold quantity in coincidental
manufacture is 76.00 min/1.27 hours.
• Reaction by-products or impurities: Technical staff will identify the quantity of chemical
coincidentally manufactured through discussions with facility chemists, production records,
operations staff, chemistry literature, or EPA TRI guidance documents (45.00 min/0.75
hours).
Once annual threshold quantities have been calculated, technical staff will compare the annual
threshold quantities for each chemical with the TRI regulatory threshold limits by entering the
threshold quantity in TRI-MEweb for each chemical. TRI-MEweb will indicate for which
chemicals TRI regulatory thresholds have been exceeded (0.25 min/0.0 hours).

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Appendix G
Average Realistic Chemical-Specific Threshold Assessment
It is assumed in this analysis that a chemical is typically only involved in one threshold activity
at a facility. However, this activity may be a processing, an otherwise use, or a manufacturing
activity. As outlined above, the total time to calculate the threshold quantity for a chemical
involved in a processing activity or an otherwise use is 62.00 minutes or 1.0 hour. There are
three different scenarios for calculating the threshold quantity for a chemical involved in a
manufacturing activity depending on whether the chemical is intentionally manufactured, a
product of combustion, or a reaction by-product or impurity (0.5 hours, 1.27 hours, or 0.75
hours, respectively). The average burden of these three methods is 0.8 hours. Since estimates
for intentional manufacture and coincidental manufacture of combustion products or reaction byproducts and impurities may not occur with equal frequency, this average has been rounded up to
1.0 hour. In addition, manufacturing, processing, or otherwise use activities may not occur at the
same frequency. Therefore, a more accurate estimate is made if estimates for all three activities
are rounded up to the most burdensome. The resulting burden estimates are summarized in
Table 2.
Table 2: Average Chemical-Specific Threshold Assessment Burden
Otherwise Use chemical specific threshold quantitative assessment
1.0 technical hour
Processing chemical specific threshold quantitative assessment
1.0 technical hour
Manufacturing chemical specific threshold quantitative assessment
1.0 technical hour
Average burden for quantitative assessment of different threshold
1.0 technical hour
activities
Total Realistic Chemical-Specific Threshold Assessment Burden
To make a compliance determination, a facility must 1) determine the appropriate threshold
activity for each chemical; 2) determine the quantity of chemical used in the threshold activity,
and 3) compare the quantity of chemical being used in a threshold activity to TRI regulatory
reporting thresholds. As outlined above, it will take a facility 30.0 minutes or 0.5 hours to
determine in which threshold activity the chemical is used. On average, 1.0 hour will be
required to determine the quantity of chemical being used in a threshold activity. Finally, it will
take a facility 0.25 minutes or 0.0 hours to enter this quantity into TRI-MEweb for comparison
with TRI regulatory reporting thresholds. A summation of burden estimates associated with
these three activities is presented in Table 3.
Table 3: Total Realistic Chemical-Specific Threshold Assessment Burden
Determine which threshold activity is occurring
0.5 technical hours
Average quantitative assessment burden
1.0 technical hour
Enter threshold quantity in TRI-MEweb
0.0 technical hours
Total Per Chemical Burden
1.5 technical hours

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Appendix G
2.1.3 Total Realistic First Year Compliance Determination Burden
Total realistic first year compliance determination burden is estimated by summing the facility
level compliance determination burdens and the chemical-specific compliance determination
burden across the six chemicals for which a typical facility will need to conduct threshold
assessments. The estimated total realistic first year compliance determination burden is
presented in Table 4.
Table 4: Total Realistic First-Year Compliance Determination Burden
Facility level burden
4.67 technical hours
6 chemicals x 1.5 hour / chemical
9.0 technical hours
Total
13.67 technical hours
2.2 Realistic Burden – Subsequent Year
In subsequent years it is assumed that NAICS code and employee threshold determinations will
typically not need to be reassessed, thus no burden will be incurred. It is also assumed that no
new activities are required relative to quantitative threshold assessments. Some time is, however,
required to review facility activities and ensure that no significant changes have occurred.
2.2.1 Facility Level Activities
At the facility level, technical staff will assess facility activities and products/mixtures used to
determine if there are significant process and/or chemical use changes at the facility requiring
modified or new quantitative threshold assessments. As part of this assessment, they will talk to
production staff, review operations records, and review MSDSs (60.00 min/1.0 hour).
Subsequent year burden estimates for compliance determination activities are summarized in
Table 5.
Table 5: Total Realistic Subsequent Year Compliance Determination
Burden With No Staff or Process Changes
NAICS Assessment
0.0 technical hours
Employee Threshold
0.0 technical hours
Facility level review of operations to determine that there
1.0 technical hour
were no significant chemical use and/or process changes
Total
1.0 technical hour

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Appendix G
2.3 Summary of Compliance Determination Burden Estimates
Table 6 summarizes the realistic burden estimates developed in this analysis. Realistic
management burden estimates are based on best professional judgment of what is actually
occurring at a typical TRI-reporting facility. No clerical burden is provided as it is assumed that
a typical facility will be using TRI-MEweb, and that technical staff will conduct the data entry
into TRI-MEweb as part of their efforts.
Table 6: Compliance Determination Unit Burden Hour Estimates
st

Realistic Estimate – 1 year

Management
1

Technical
13.67

Clerical
0

Total Hours
14.67

0.25

1.25

4
1

12
3

0
0

16
4

Realistic Estimate – subs year
st

Current OMB Estimate – 1 year
Current OMB Estimate – subs year
3. RULE FAMILIARIZATION
3.1 Realistic Burden Estimate - First Year

To familiarize themselves with the TRI reporting requirements, the typical facility will need to
review TRI program content both generally and as applicable to their facility by:
• Reading the Reporting Forms and Instructions booklet (600 min/10 hours).
• Reviewing all or selected portions of relevant EPA TRI guidance documents including:
o Q & A document (120 min/2 hours)
o Industry-specific guidance (if it exists) or most closely applicable (90 min /1.5
hour)
o Electricity Generating Facilities Guidance (for fuels use) (30 min/0.5 hours)
o Chemical Specific Guidance(s) (120min/2 hours)
• Attending a training session (360 min/6-hour live session or both halves of a web-based
training).
• Contacting the EPCRA hotline or other information resource for clarifications/facilityspecific determinations (30 min/0.5 hours).
Summing across these activities, the total realistic first year rule familiarization burden is
estimated at 1,350 min/22.5 hours.
3.2 Realistic Burden - Subsequent Year
It is assumed that no rule familiarization will occur in subsequent years. Even with a process
change, technical staff will use existing knowledge of the TRI program to determine how TRI
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Appendix G
applies to this process change. Table 7 summarizes rule familiarization burden estimates for the
first and subsequent years.
Table 7: Rule Familiarization Unit Burden Hour Estimates
st

Realistic Estimate – 1 year
Realistic Estimate – subs year
st

Current OMB Estimate – 1 year
Current OMB Estimate – subs year

Management Technical
1
22.5

Clerical
0

Total Hours
23.5

12
0

22.5
0

0
0

34.5
0

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Appendix H
Peer Review Summary Statement with EPA Responses
This technical document underwent peer review to assess the integrity and value of the revised
methodology, Ratio-Based Burden Methodology (RBBM). The reviewers represented academia,
industry, and non-profit sectors with expertise in industrial engineering, social science/public
policy, and mathematical methodology (see Table H-1 below). Overall the reviewers were
positive, concluding that the methodology changes:
• Are reasonable, appropriate, and well-supported
• Achieve efficiency, administrative constancy, and transparency
Table H-1: Peer Reviewers Represent a Range of Disciplines and Perspectives
Reviewer Name
Jeffrey Burke, BA

Mark Cohen, PhD Economics
Mark Stephan, PhD, Politics,
Associate Professor
Michael Walls, MBA, JD

Joelie Zak, BS, BA

Organization
Executive Director, National
Pollution Prevention
Roundtable (in addition to
twenty-plus years experience
as Senior Environmental
Scientist with US EPA Region
3)
Vice President for Research,
Resources for the Future
Associate Professor,
Washington State University
VP, Regulatory and Technical
Affairs, American Chemistry
Council
Executive VP of Scientific
Control Laboratories

Sector Representing
Non-profit/Government

Social Science/Public Policy
Social Science/Public Policy,
Mathematical Methodology
Social Science/Public Policy

Engineering/Science

Reviewers were asked for overall impressions and assessments of 1) goal attainment, 2) validity
and consistent application of methodology decision rules/assumptions, and 3) model
maintenance requirements. Beyond these assessments, EPA requested comments on the merits
and methods of survey calibration.
On goal attainment, reviewers generally agreed that the stated goals of simplification, improved
internal consistency, and improved transparency are met (with only one disagreeing about
transparency). Additional perceived benefits included: 1) increased access to burden estimates
and 2) better understanding of uncertainties associated with TRI burden estimates.
Regarding decision rules and assumptions, reviewers consistently agreed with the internal logic
and conclusions of the Ratio-Based Burden Methodology. However, two noteworthy exceptions
in which one or more reviewers raised concerns: 1) setting the value of for PBT/non-PBT burden
equal to one, and 2) holding non-Form burden constant.

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H -1

Appendix H
In response to EPA’s solicitation for input on survey calibration as a future enhancement, three
out of five reviewers recommended this type of enhancement (including one non-industry
reviewer). More information is provided in EPA’s response below.
Based on the peer review endorsement, EPA concluded that the methodology is sound without
need of design changes or major procedural adjustments. Regarding document quality, the body
of the report is considered well-written with Appendices receiving mixed reviews (although
considered very thorough). EPA has revised the document, addressing specific
questions/critiques of the methodology and implementing editorial suggestions from peer
reviewers and other sources.

SELECTED REVIEWER COMMENTS AND EPA RESPONSES
While reviewer comments were generally positive, EPA believes that responses and additional
explanations on several issues are justified to ensure that EPA’s position is clear and to avoid
potential misunderstandings.
1. Accuracy Questions Remain on Burden Hours
Review Comments: Although it is beneficial to simplify calculations, there is still a need to
validate the burden estimates to be sure they are representative of reporter experiences. For
example, one reviewer stated, “The measure of the new methodology’s estimate should not be a
simple comparison to the estimates generated under the prior methodology—the new
methodology should return significant improvements in the (absolute) estimation of TRI
burden.”
EPA Response: EPA acknowledges that some reviewers (here and in public comment venues)
question the credibility of the system of factors used to characterize reporting activities, as well
as values assigned to those factors. EPA believes these bases, as implemented in both the
existing and revised methodologies, comply with PRA requirements that burden estimates be
provided, “to the extent practicable.” TRI burden estimates reflect a reasonable sense of the
average conditions and an appropriate level of specificity. Further, EPA emphasizes that the
purpose of TRI burden estimates—and its burden accounting system in general—is to track
changes from year to year against an established baseline.

2. PBT Burden—Modeling versus Accounting
Review Comments: Some reviewers are concerned by the methodology’s simplification that
sets PBT/non-PBT burden equal to one, due to lack of evidence to quantify an average value
representative of the overall reporter population. One reviewer asserts, “ …in real life reporting,
there is currently extra burden placed on specific PBT chemical TRI filings that does not seem to
be accounted for in the existing or new model.” Another states, “ACC does not agree with the
conclusion that reporting for PBT and non-PBT substances are similar enough to allow the same
unit-burden-hour estimate. PBT reporting as a whole takes more time than non PBTs, largely due
to the de minimis exception not applicable to non-PBT substances.”
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Appendix H
EPA Response: There are two parts to this response. First and foremost, EPA recognizes the
need to distinguish between PBT and non-PBT burden by including a specific ratio model for
that purpose. At this time, however, EPA is unable to specify the value of the ratio in the context
of RBBM which requires verifiable and internally consistent unit burdens. Without
substantiating evidence for this type of model assertion (see Decision Rules in main report) EPA
has decided to implement a default ratio equal to one, while providing a placeholder for later
revision in the event that additional information becomes available. Second, though the value of
the ratio is left unspecified, this methodology revision carries forward certain prior assumptions
so that the net effect of PBT reporting is incorporated in overall totals. Specifically, the previous
calculation’s effects of a higher PBT unit burden for 20% of chemicals are rolled up into the new
unit burden (Nominal Form R unit burden). In back-calculating this base number of 35.7 hours
per Form R, the unit burden reflects overall average conditions, and is elevated above the value
that would have been otherwise obtained—at about 30 hours/form—had only non-PBT burden
been used to determine Nominal Form R unit burden. An important note on RBBM and its
benefits: the simplified comprehensive Nominal Form R unit burden plus the A/R model (which
links to Form A unit burden) provides a focal point for burden-estimate discussions, reducing
confusion associated with keeping up with additional unit burdens and chemical counts from
multiple subpopulations.
3. Survey Calibration Enhancement
Review Comments: Three out of five reviewers recommend enhancement via some form of
survey calibration. Of these three, the two industry reviewers make their recommendations based
on 1) concerns that the burden estimates are generally too low and 2) the need to measure a
distinction between PBT and non-PBT reporting burden. The third supporter does not see the
need, but admits that pressure from any party would merit survey calibration. One of the nonsupporters does not recommend survey calibration for this application, but stresses that EPA is
not correctly focused on the purpose of survey calibration. This reviewer states that the purpose
of survey calibrated burden estimates is to determine if data elements should be dropped or
altered (i.e., consider cost of the information compared to its value).
EPA Response: EPA appreciates the thoughtfulness and thoroughness of the reviewers’
comments on survey calibration. At this time, and as stated above, EPA believes the current
bases comply with PRA requirements for reasonable estimates. In addition to increased Agency
effort, EPA is concerned about imposing additional burden on the reporting community to
participate in a survey designed for the purposes of calibrating burden estimates.
4. DIOXIN (and Form R Schedule 1) Burden Not Included
Review Comment: The revised methodology does not address Dioxin reporting (implemented
in 2007) and the burden contributions from Form R Schedule 1.
EPA Response: At the time of the calculations for the revised methodology, conditions are
those of the 2008 ICR. As such, the Form R Schedule 1 requirement was not in place.
Subsequently, the addition of Form R Schedule 1 reporting is estimated in the Supporting
Statement of the 2012 ICR Renewal, using the techniques of RBBM’s Form Element Estimation
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H -3

Appendix H
(in Appendix C). Note, however, that the impact of Schedule 1 burden on total Form R burden is
very small (.00516 hours overall per Form R).
5. Weighted Average Wage Rate (WAWR) of $51 Seems Low
Review Comment: According to one reviewer “In general the weighted average wage rate of
$51 seems low given the engineering and managerial expertise required. We are aware that in
similar (and admittedly less complicated) analyses conducted in other areas, the 90th percentile
would be used and adjusted upward by 40 percent to get to a more accurate representation of
non-wage compensation. In addition, with electronic data entry and submittal, there may well not
be any appreciable clerical involvement with TRI reporting. The use of the clerical wage level
also results in an average wage rate that is too low.”
EPA Response: The WAWR is based on statistics generated by the US Department of Labor
Bureau of Labor Statistics (BLS) and includes non-wage compensation. As shown in the table
below, EPA uses the average wage rate and adjusts upward by 60.40% (in this June 2010
example) to incorporate non-wage compensation. EPA’s WAWR method weights each category
of management, technical, and clerical labor according to the proportional contribution (.03, .89,
and .08 respectively) as defined in Appendix E based on the Abt Associates Engineering Studies.
The value of $51 reflects these analytical decisions for September 2009 conditions using a
method whereby wage rates are updated to current dollars using the employment cost index (no
longer used in RBBM). Applying the current version of RBBM and June 2010 conditions, the
result of $49.62/hr is obtained. Further detail is provided in the table below.
Table H-2: Derivation of the Weighted Average Wage Rate (WAWR)
(June 2010)

Wage Type
(Burden Proportion)
Occupational Type
Wages and Salaries
Total benefits
Overhead
Total Loaded Rate
WAWR Contribution

Managerial
(.03)
Management,
business,
and financial
$38.84
$16.85
$6.60
$62.29
1.87

Technical
(.89)
Professional and
related
$32.73
$13.08
$5.56
$51.37
45.72

Clerical
(.08)
Office and
administrative
support
$15.75
$6.81
$2.68
$25.24
2.02

WAWR
Composite
WAWR $/hr

49.62

Based on June 2010 wage data. http://www.bls.gov/ncs/ect/#tables.

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H -4

File Type	application/pdf
File Title	Revising TRI Burden to Ratio-Based Methodology
Author	LynchL
File Modified	2011-05-18
File Created	2011-04-29