On January 10, 2005, the United States Environmental Protection Agency (USEPA) proposed changes to the Toxics Release Inventory Reporting Forms (Form A and R).  Comments to the above proposed changes; identified by the Docket ID No. TRI-2004-00001, must be received by the USEPA on or before March 11, 2005.  The USEPA expects to complete comment review and adoption of the new changes in time for the 2006 reporting year.  The following are the list of proposed changes to the current TRI Form A and R:

¨ Replacement of Certain Facility Data Reporting Requirements With Existing USEPA Data from the USEPA Facility Data Registry (Section 4.6 and 4.8 through 4.10 of Forms A and R)

· Removal of the Reporting Requirement for Facility Data (latitude/longitude coordinates, permit and environmental program identification numbers other than the TRI facility identification number) from the TRI Forms.

· Removal of the Latitude/Longitude Reporting Requirement

· Removal of Reporting Requirement for the USEPA Permit and Program Identification Numbers (Section 4.8 and 4.9 and 4.10 of Forms A and R).

¨ Removal of the Reporting Requirement for Determining the Percentage of the Total Quantity of Toxic Release Contributed by Stormwater (Part II, Section 5.3 Column C of Form R)

¨ Modifications to the Reporting Requirement for On-Site Water Treatment Methods and Efficiency (Part II, Section 7 of Form R)

· Section 7A – On-Site Waste Treatment Methods and Efficiency, Column B – Waste Treatment Method(s) Sequence.  The current codes would be replaced by the 18 hazardous waste treatment codes currently used in the USEPA biennial Hazardous Waste Reports.

· Section 7A – On-Site Waste Treatment Methods and Efficiency, Column C – Range of Influent Concentration.  This section is proposed to be eliminated or made optional.

· Section 7A – On-Site Waste Treatment Methods and Efficiency Column D – Waste Treatment Efficiency Estimate.  USEPA is proposing to allow facilities to report their treatment efficiency as a range instead of an exact percentage.

· Section 7A – On-Site Waste Treatment Methods and Efficiency Column E – Based on Operating Data.  USEPA is proposing to remove this data field.

· Section 7C – On-Site Recycling Processes.  USEPA is proposing to eliminate the current recycling codes and replacing them with three reclamation and recovery management codes used in USEPA’s biennial Hazardous Waste Report.

¨ Removal of Reporting Data Field for Optional Submission of Additional Information (Part II, Section 8.11 of Form R).  USEPA is proposing to modify the Form R to include an optional checkbox allowing facilities that provide additional information to check “yes”, if they use the test box feature or send USEPA additional information in hardcopy.  Reporting facilities that do not with to provide additional information would no longer need to check “no”, in Section 8.11.

USEPA is also proposing the following technical corrections to the Title 40 Code of Federal Regulations (CFR), Part 372.85.

· Giving reference to the TRI Web site to obtain the Form R instead of publishing in the regulations an address from which to request copies of TRI forms.

· Deletion of Title 40 CFR, Part 372.85(b)(18) because the regulation has expired and has no effect on the current reporting obligations.

A second rulemaking, to be proposed later in 2005, will examine the potential for more significant reporting modifications with greater potential impact on reducing reporting burden.  To obtain a copy of the proposed changes or submit comments to the above proposed changes, please refer to the following: http://epa.gov/EPA-TOX/2005/January/Day-10/

  Author:  Sharon S. Diday

Date:  Jan 2005

 Back to Articles