21
Toxic Chemical Release Reporting
TABLE 3.1
Form A Annual Burden and Cost per Facility (Assuming 1, 2, or 3 Chemicals)
Number of Chemicals Reported on Each Form A
1 Chemical
2 Chemicals
3 Chemicals
Activity
Hours
Cost
Hours
Cost
Hours
Cost
First-Year Filers
Rule familiarization: first-time filers
34.5
$1,644
34.5
$1,644
34.5
$1,644
Calculations/certification: first-time filers
44.5
$2,081
89
$4,162
133.5
$6,243
Form A completion: first-time filers
1.6
$70
1.6
$70
1.6
$70
Recordkeeping/submission
3
$122
6
$244
9
$366
Total per facility
83.6
$3,917
131.1
$6,120
178.6
$8,323
Average per chemical
83.6
$3,917
65.5
$3,060
59.5
$2,774
Subsequent Year Filers
Calculations/certification: subsequent
16.2
$759
32.4
$1,518
48.6
$2,277
year filers
Form A completion: subsequent year filers
1.3
$58
1.3
$58
1.3
$58
Recordkeeping/submission
3
$122
6
$244
9
$366
Total per facility
20.5
$939
39.7
$1,820
58.9
$2,701
Average per chemical
20.5
$939
19.8
$910
19.7
$900
Source: EPA 2005b.
TABLE 3.2
Form R Average Annual Burden Hour Estimate by Activity
Total
Category
Activity
Management
Technical
Clerical
Hours
Facility
Compliance determination:
1
3
0
4
level
all facilities
Rule familiarization: first-time filers
12
22.5
0
34.5
Supplier notification
0
7
17
24
Per
Calculations and report completion:
20.3
43.9
2.7
66.8
Form R
first-time filers, PBTs
Calculations and report completion:
20.5
44.4
2.8
67.6
first-time filers, non-PBTs
Calculations and report completion:
14.1
30.4
1.9
46.3
subsequent year filers, PBTs
Calculations and report completion:
7.5
16.1
1.0
24.6
subsequent year filers, non-PBTs
Recordkeeping/submission: all filers
0
4
1
5
Source: EPA 2005b.