20
Toxic Chemicals
After the deadline, the EPA and state personnel must review the reports to
ensure accuracy.
Once all the reporting is complete, the EPA posts the results online, within easy
access of the public. The data can be searched by facility, area, chemical type,
amount, and other variables.
FINANCIAL IMPACTS
Violators of the requirements of this regulation are liable for a civil penalty of up to
$25,000 each day for each violation. Facilities are financially responsible for their
own reporting requirements.
The cost to the EPA to process the Form A Certification Statements can be broken
down into fixed costs and variable costs. Fixed costs include full-time employees
(FTEs) and other recurring EPA costs. The variable component depends on the
number of forms. It reflects total data-processing costs divided by the total number
of paper reports processed in the 2002 reporting year. The EPA expends $26 in variable costs for each form processed. A total of 1,800 Form A Certification Statements
were filed in the 2002 reporting year. Thus, the total annual burden to the EPA is
estimated to be $46,800 in variable costs for the Form A Certification Statement.
The cost to facilities is outlined in Table 3.1.
To estimate the EPA burden and cost to process the Form R Certification Statements, costs are separated into a fixed component and a variable component. Activities and expenses that are not greatly affected by marginal changes in numbers of
reports are treated as fixed. These include rent for the EPCRA reporting center,
development costs for data access tools, compliance assistance measures, and other
activities and expenses. The variable component is the amount that varies depending on the number of forms. The variable component reflects total extramural
data-processing costs divided by the total number of reports processed in the 2003
reporting year. For each form processed, $0.8 million in fixed costs and 26.3 FTEs
are required to conduct the EPA activities described plus an additional $35 in variable costs for each. The cost to facilities, as estimated by the EPA, in both time and
money is outlined in Tables 3.2 and 3.3.
LIMITATIONS OF TRI PROGRAM
TRI chemicals vary widely in toxicity or their potential to produce toxic effects.
Publication of the data tends to center on total pounds released rather than toxic
impact. As a result, some high-volume releases of less-toxic chemicals may appear to
be more serious than lower-volume releases of highly toxic chemicals, when just the
opposite may be true. This is confounded because of the large number of chemicals
and complexity in taking toxicity into account.
The potential for exposure may be greater the longer the chemical remains
unchanged in the environment. Sunlight, heat, or microorganisms may or may not
decompose the chemical. Smaller releases of a persistent, highly toxic chemical
may create a more serious problem than larger releases of a chemical that is rapidly
converted to a less-toxic form.
Toxic Chemicals
After the deadline, the EPA and state personnel must review the reports to
ensure accuracy.
Once all the reporting is complete, the EPA posts the results online, within easy
access of the public. The data can be searched by facility, area, chemical type,
amount, and other variables.
FINANCIAL IMPACTS
Violators of the requirements of this regulation are liable for a civil penalty of up to
$25,000 each day for each violation. Facilities are financially responsible for their
own reporting requirements.
The cost to the EPA to process the Form A Certification Statements can be broken
down into fixed costs and variable costs. Fixed costs include full-time employees
(FTEs) and other recurring EPA costs. The variable component depends on the
number of forms. It reflects total data-processing costs divided by the total number
of paper reports processed in the 2002 reporting year. The EPA expends $26 in variable costs for each form processed. A total of 1,800 Form A Certification Statements
were filed in the 2002 reporting year. Thus, the total annual burden to the EPA is
estimated to be $46,800 in variable costs for the Form A Certification Statement.
The cost to facilities is outlined in Table 3.1.
To estimate the EPA burden and cost to process the Form R Certification Statements, costs are separated into a fixed component and a variable component. Activities and expenses that are not greatly affected by marginal changes in numbers of
reports are treated as fixed. These include rent for the EPCRA reporting center,
development costs for data access tools, compliance assistance measures, and other
activities and expenses. The variable component is the amount that varies depending on the number of forms. The variable component reflects total extramural
data-processing costs divided by the total number of reports processed in the 2003
reporting year. For each form processed, $0.8 million in fixed costs and 26.3 FTEs
are required to conduct the EPA activities described plus an additional $35 in variable costs for each. The cost to facilities, as estimated by the EPA, in both time and
money is outlined in Tables 3.2 and 3.3.
LIMITATIONS OF TRI PROGRAM
TRI chemicals vary widely in toxicity or their potential to produce toxic effects.
Publication of the data tends to center on total pounds released rather than toxic
impact. As a result, some high-volume releases of less-toxic chemicals may appear to
be more serious than lower-volume releases of highly toxic chemicals, when just the
opposite may be true. This is confounded because of the large number of chemicals
and complexity in taking toxicity into account.
The potential for exposure may be greater the longer the chemical remains
unchanged in the environment. Sunlight, heat, or microorganisms may or may not
decompose the chemical. Smaller releases of a persistent, highly toxic chemical
may create a more serious problem than larger releases of a chemical that is rapidly
converted to a less-toxic form.