United States Prevention, Pesticides, EPA 749-R-94-001
Environmental Protection And Toxic Substances July 1994
Agency (7407)
&EPA Expansion Strategy For The TRI
Information Management System
Printed on Recycled Paper
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Contents
Executive Summary ii
Introduction l
The Current TRI Workload 1
TRI Expansion Strategy 2
The TRI Information Management System 4
Capacity of the TRI Information Processing System 8
Information Processing Cost of TRI Expansion 12
Conclusions 12
List of Tables
Table 1 TRI Expansion Schedule 3
Table 2 Cost of TRI Information Processing
for Reporting Year 1991 8
List of Figures
Figure 1 Required % Electronic Submissions
to Reach System Capacity 11
Figure 2 TRI Data Entry Cost at System Capacity 13
Figure 3 TRI Information Processing Cost
at System Capacity 14
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Executive Summary
In 1986 Congress passed the Emergency Planning and Community
Right-to-Know Act (EPCRA) to provide citizens with the "right to
know" about toxic chemicals in their communities. By July 1 of
each year, facilities must report to EPA their releases of toxic
chemicals to the environment if the facilities are in the
manufacturing sector, have ten or more full-time employees, and
manufacture, process, or import more than certain amounts of
listed chemicals and categories. As required by EPCRA, EPA makes
this data publicly available in a database called the Toxics
Release Inventory (TRI).
Congress and the public have expressed a desire to expand
TRI reporting to cover additional chemicals and facilities. EPA
plans to expand TRI reporting requirements in two phases. In
phase I, EPA is adding approximately 350 chemicals to the list
and considering establishing an alternative reporting threshold
for facilities with small volume releases. In phase II, EPA will
require facilities in certain non-manufacturing industries to
submit reports. EPA must ensure that it has the capacity to
process the expanded number of annual forms.
EPA has created the TRI Information Management System to
process TRI forms. The system consists of EPA performance goals
and EPA resources. The performance goals ensure accuracy of
data, timeliness of release of the data, and availability of the
data to the public. EPA resources consist of the processing
facility, the processing system, EPA staff, and the budget to pay
for facilities, equipment and contractor services. All
processing is done at the EPCRA Reporting Center (ERC) in
Ballston, Virginia.
EPA defines the capacity of the TRI Information Management
System as the number of data elements that can be processed
during a reporting cycle using available EPA resources while
meeting goals for accuracy, timeliness and availability. A data
element is a single unit of information on the reporting form
(e.g., a facility name, a release number).
For reporting year 1991, EPA processed 9.6 million data
elements. Phase I chemical expansion will add about 3.6 million
data elements. If EPA implements the small volume release
provision, about 1.4 million data elements will be eliminated.
With the small volume release provision, phase I expansion will
increase the number of data elements EPA must process by 2.2
million, or 23 percent over 1991.
The number of data elements that will be added in Phase II
facility expansion depends on final decisions about which non-
manufacturing industrial categories should be included.
EPA has determined that the processing capacity of the
current TRI Information System is about 20 million data elements
per reporting cycle. This is based on an analysis of operations
during the 1991 reporting cycle and implementation of
enhancements such as document imaging and the addition of extra
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Expansion Strategy for the TRI Information Management System
processing workstations and shifts. Phase I expansion along with
the small volume provision will result in about 11.8 million data
elements per year, well within the processing capacity of the
existing TRI Information Management System.
The processing capacity of the system is highly dependent on
the number of forms that are electronically submitted. The
processing capacity with no electronic submissions, i.e., all
forms are submitted on paper, is about 12 million data elements.
All forms will have to be electronically submitted to reach the
maximum capacity of about 20 million data elements.
There is significant potential to increase the number of
electronic submissions. For reporting year 1991, 12 percent of
all forms were electronically submitted. This increased to 35
percent for reporting year 1992. EPA believes that with
voluntary efforts, 60-70 percent of all forms could be
electronically submitted, resulting in a system capacity of 17-18
million data elements per reporting cycle. Depending on the
number of electronic submissions, EPA could add up to eight
million data elements (almost 80,000 forms) from phase II
facility expansion using the existing information management
system.
Because of the importance of electronic submissions to TRI
processing capacity, EPA is pursuing several approaches to
increase electronic submissions. EPA is encouraging companies
that submit the large numbers of forms to submit them
electronically. EPA will begin an evaluation and pilot of
electronic data interchange (EDI) during fiscal year 1994.
This paper does not address capacity beyond 20 million data
elements per reporting cycle. Exceeding 20 million data elements
would require substantial revision of the information management
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Expansion Strategy for the
TRI Information Management System
Introduction
In October of 1986, Congress passed the Superfund Amendments
and Reauthorization Act (SARA). Title III, Section 313 of SARA,
also known as the "Emergency Planning and Community Right-to-Know
Act" (EPCRA), is based on the premise that citizens have a "right
to know" about toxic chemicals in their communities.
EPCRA requires certain businesses to submit annual reports
on the amounts of toxic chemicals their facilities released into
the environment or are transferred away from their facilities to
other sites. EPCRA also mandates that an inventory containing
this data be established and made publicly available through a
computer database and other means. The Toxics Release Inventory
(TRI) was established by EPA to meet these legislative
requirements.
The TRI has been very successful in informing citizens about
toxic chemical releases. There is a great deal of interest on
the part of Congress and the public in increasing the utility of
the TRI. EPA is considering various options for expansion, and
Congress is considering new legislation that will expand EPCRA's
coverage.
EPA spends considerable resources processing TRI submissions
and making the information publicly available. Any expansion of
reporting requirements must be carefully managed to ensure that
accurate data can continue to be made available to the public in
a timely manner.
EPA must ensure that the TRI Information Management System
has adequate capacity to process TRI forms. EPA defines the
capacity of the TRI Information Management System as the number
of data elements that can be processed during a reporting cycle
using EPA resources while meeting goals for accuracy, timeliness,
and availability.
The Current TRI Workload
Section 313 of EPCRA mandates facilities to report if,
during the calendar year, they meet the following conditions:
• Are in the manufacturing sector (SIC codes 20-39); and
• Have ten or more full-time employees; and
• Manufacture, import, or process 25,000 pounds or more
of a listed chemicals, or use 10,000 pounds or more of
a listed chemical. There are currently about 350
chemicals and chemical categories on the list.
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Expansion Strategy for the TRI Information Management System
By July I of each year, owners or operators of facilities
that meet these criteria must submit reports to EPA for the
previous calendar year. Reports are submitted on the Toxic
Chemical Release Inventory Reporting Form, also known as Form R.
For the 1991 reporting year, EPA processed about 93,000
forms (facilities submit one form per chemical). Of these, about
12 percent were electronically submitted; the remaining 88
percent were submitted on paper. The 93,000 forms represent
about 9.6 million data elements.1
The number of forms per year has remained fairly consistent
since 1987, the first reporting year. Prior to the 1991
reporting year, EPA entered 64 data elements per form. In 1991,
with the addition of pollution prevention information required by
the Pollution Prevention Act of 1990, the number of data elements
entered from Form R increased to 103.
TRI Expansion Strategy
EPA is proposing to expand TRI reporting in two phases. In
phase I, EPA will focus on adding chemicals to the chemical list.
In phase II, EPA will focus on adding non-manufacturing
industries to the facility list. EPA has chosen to focus on
chemicals first because screening has already been accomplished
on many candidates and there is a well established process for
chemical list modification. Facility expansion will occur later
because it requires substantial analysis and justification.
For phase I, EPA has identified about 350 chemicals that
meet the statutory criteria for addition to the list and are
produced in sufficient quantities to justify annual reporting.
These include ozone depleting chemicals (HCFCs), RCRA chemicals,
pesticide active ingredients and about 150 other chemicals drawn
from Right-to-Know More legislation and other Federal statutes
such as the Clean Air Act and Clean Water Act. Federal
facilities are also being added under phase I.
1 A data element is a single unit of information reported
on Form R. (e.g., facility address, number of pounds of the
chemical released to the air) that is entered into the TRI
Information Management System. The number of data elements
processed in a reporting cycle, is calculated by multiplying the
average number of data elements entered per form by the number of
forms received in the reporting cycle. There were 103 data
elements entered into the system for each 1991 form, and 93,000
forms submitted (including prior year revisions) resulting in the
processing of 9.6 million data elements for the 1991 reporting
cycle.
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Expansion Strategy for the TRI Information Management System
EPA is considering an alternative threshold for small volume
releases. Under this provision, EPA would establish a higher
threshold for a category of facilities that have releases below a
certain volume level. Facilities that fall below this release
volume would not be required to submit a full TRI report. Only a
shorter certification statement would be required.
EPA estimates that phase I expansion, which will be
implemented in reporting years 1994 and 1995, will add about
35,000 new forms in each reporting cycle, resulting in an
additional 3.6 million data elements.
EPA estimates the small volume provision might be
implemented in reporting year 1995 and could replace about 20,000
full reports with shorter certification statements. This would
eliminate about 1.4 million data elements per year.
For phase II, which will be implemented after reporting year
1995, EPA will add reporting by non-manufacturing facilities that
contribute significant release volumes. Adding these facilities
will provide a more complete picture of the sources responsible
for chemical releases in a community. The number of new forms
will be based on final decisions about which non-manufacturing
should be added.
Table 1
TRI Expansion Schedule
Phase
Reporting Year
Chemical Expansion
Facility Expansion
Small Volume Provision
Number of Forms
Full Forms
Cert. Stmts.
Total Forms
Number of Million Data
Elements
Full Forms
Cert. Stmts.
Total Forms
I
1993
93,000
93,000
9.6
9.6
1994
RCRA U
List,
HCFC
Federal
Fac.
100,000
100,000
10.3
• 10.3
1995
RTK More
Lists,
Pesticide
AI
Cert.
Stmts.
108,000
20,000
128,000
11.1
0.7
11.8
II
1996
Non-
Mfgr.
Fac.
To be
Deter-
mined
To be
Deter-
mined
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Expansion Strategy for the TRI Information Management System
The TRI Information Management System
EPA has established a TRI information management system to
meet its responsibilities under EPCRA. The system consists of
two components: EPA performance goals, and EPA resources. The
performance goals ensure that accurate, timely information is
made available to the public. The resources provide the means to
accomplish the goals. Both the performance goals and the
resources combine to define the capacity of the TRI Information
Management System to process TRI information.
EPA Performance Goals
EPA has established three performance goals:
• Accuracy,
• Timeliness, and
• Availability.
Accuracy
To be of use to the wide variety of users envisioned in
the EPCRA legislation, the information in the TRI database
must be accurate. The accuracy goal consists of two sub-
goals.
The first accuracy sub-goal ensures that the TRI
database accurately reflects what is reported by facilities.
EPA has defined this component as achieving near 100 percent
data entry accuracy for certain key data fields,
particularly those fields that characterize chemical
releases, and over 98 percent data entry accuracy for all
fields. EPA has consistently achieved this goal. A 1991
GAO investigation of data quality on 11 important fields
found 99.7 percent accuracy for 1988 reporting year data.
EPA's own audit of about three percent of reporting year
1990 forms found a data entry accuracy rate of 99.5 percent
for release value fields.
EPA uses several processes to maintain this high level
of data accuracy. All release numbers are reviewed after
data entry. In addition, three percent of all forms are
subject to verification of data entry of all data elements.
All submitters receive a printout of their release and
transfer data after entry into the system and are given an
opportunity to verify its accuracy.
The second accuracy sub-goal ensures that facilities
accurately report their releases. This is accomplished
through guidance materials, a technical support hotline,
facility inspections and, if necessary, enforcement actions.
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Expansion Strategy for the TRI Information Management System
Identification of non-submitters is a high priority. EPA
sends submitters a notice of technical error (NOTE) when it
identifies errors on the reporting form. EPA provides
technical and compliance support to submitters to correct
errors. EPA sends to states reports of major facility
releases and gives states an opportunity to identify errors.
EPA, along with states, conduct a considerable amount of
outreach and training. EPA provides a technical hotline to
ensure that facilities have every opportunity to submit
accurate information.
Timeliness
Data must be available to users within a reasonable
time after it is submitted to EPA. EPA has defined the
timeliness goal as releasing the data to the public in an
on-line database within nine months of the July 1 reporting
deadline. Meeting this goal requires that EPA balance the
need for accurate data with the public's desire to have it
as quickly as possible.
EPA achieved the nine month goal for the first time
with reporting year 1991 processing. EPA processed
reporting year 1991 forms between September 1992 and April
1993.2 Despite the shorter time available and the increased
number of data elements (from 6.0 million for 1990 to 9.6
million for 1991), EPA was able to achieve its goal to
complete data processing by the beginning of April, 1993.
The public release of the 1991 data occurred during May,
1993. EPA is on schedule to release 1992 data in April,
1994.
Availability
The availability performance goal ensures that EPA
meets, its statutory mandate to make TRI data available to
the public on-line and through other means. EPA recognizes
that the public consists of many different types of users
with varying needs. The primary mechanism for making TRI
data available is on-line through the National Library of
Medicine (NLM). This is an easily accessible database with
a nominal charge for on-line usage. EPA also makes TRI data
available on-line through RTK Net, a database used mainly by
environmental and public interest groups. States and other
government users can access the TRI data on EPA's mainframe
2 Data processing would normally have started in July.
However, the 1991 reporting form contained new data elements added
by the Pollution Prevention Act. Approval of the revised FY 1991
reporting form was delayed. EPA therefore exercised enforcement
discretion and allowed companies to submit 1991 reports by
September 1 instead of the statutory July 1 deadline. Data
processing for the 1991 forms therefore started in September.
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Expansion Strategy for the TRI Information Management System
computer. EPA also makes data available through other means
such as a written reports, magnetic tape, computer
diskettes, and CD-ROM.
EPA has a number of projects underway to assess the
public's use of the information and to find new ways to make
it accessible. EPA is investigating ways to link TRI data
with other kinds of environmental data to enhance data
usefulness.
EPA Resources
EPA resources consist of four components:
• Budget,
• Staff,
• Processing Facility, and
• Processing System.
Budget and Staff
The EPA budget is the dollars available to pay for
facilities, equipment, and contractor services. For
Reporting Year 1991, EPA spent about $5.6 million for TRI
information processing. This required 16.6 EPA full time
equivalent (FTE) staff.
Processing Facility
The processing facility is the site at which TRI forms
are processed and stored. The facility must be large enough
to accommodate the contractor-run operation. This includes
room to receive and store forms, and room for data entry
workstations. In October, 1992 EPA moved the EPCRA
Reporting Center (ERC) to a new, larger facility in
Ballston, Virginia to accommodate expansion from the PPA and
to prepare for future expansion.
Processing System
The processing system includes procedures and equipment
to process and quality assure TRI data, make the data
available, and archive forms. It also includes computer
hardware and software. The current processing system
includes a local area network (LAN) at the EPCRA Reporting
Center (ERC) and the EPA mainframe at Research Triangle
Park, North Carolina.
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Expansion Strategy for the TRI Information Management System
Information Processing
The information processing budget consists of six components
needed to prepare the data for use. These are:
• ERC Fixed Costs: .Cost of rent for the EPCRA Reporting
Center, contractor management overhead, EPA program
management overhead, and form storage.
• Data Entry: Cost to receive forms and enter them into the
computer system. This cost is highly dependent on the
number of forms, the number of data elements per form and
whether the form is submitted on paper or electronically.
It costs EPA much less to enter an electronic form (i.e.,
one submitted on diskette) than it does to enter a paper
form.
• Data Quality: Cost to quality assure the data. This
includes reviewing forms for accuracy, generating notices of
noncompliance (NONs) and notices of technical error (NOTEs),
data reconciliation, providing submitters with an
opportunity to review the accuracy of their reports after
the data is entered, and ensuring that a submitter's forms
can be linked across multiple reporting years. This cost is
also highly dependent on the number of forms and data
elements per form. Forms submitted electronically generally
require less quality assurance effort than paper forms.
• Magnetic Media: EPA provides submitters, free of charge, a
computer program that runs on IBM compatible computers.
This program allows a company to submit its TRI reports on a
diskette, i.e., electronically. This budget component
includes the cost to produce the program, provide user
support, and provide support to some vendors who
independently produce their own versions of the reporting
program.
• Computer Systems: Cost to maintain computer systems to
process and store the data. Data is originally entered on a
local area network (LAN) at the ERC. Data entry
verification and some quality assurance is done before the
data is uploaded to EPA's mainframe. Additional quality
assurance is done on the mainframe. The mainframe contains
the official version of the TRI known as TRIS. It is
accessible by EPA and states. This category includes the
cost to maintain the mainframe-and LAN hardware and
software, and to modify the software to accommodate changes
in reporting requirements.
• Data Analysis: Cost to develop tools to use TRI data,
analyze data to support EPA needs, and prepare data for use
by others.
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Expansion Strategy for the TRI Information Management System
Table 2 summarizes the cost of TRI information processing
for Reporting Year 1991.
Table 2
Cost of TRI Information Processing for
Reporting Year 1991
Category
ERG Fixed Costs
Data Entry
Data Quality
Magnetic Media
Computer Systems
Data Analysis
Total
FTEs
3.0
3.6
3.3
1.1
2.8
2.8
16.6
Dollars
(Thousands)
1,650.0
2,159.0
785.0
180.0
540.0
280.0
5,594.0
Capacity of the TRI Information Processing System
Efficiency Evaluations and Improvements
The TRI Information Management System began operation in
1988 to process.forms for reporting year 1987, the initial
reporting year. Recognizing the need to make the operation as
efficient as possible, EPA contracted with a management
consulting firm to evaluate EPCRA Reporting Center operations. In
July, 1990, EPA received the final consultant report. The report
contained numerous recommendations, the most important of which
were:
• Combine two separate contracts (one for systems
development and another for forms processing) into a
single .contract to improve management and operational
efficiency.
• Develop and distribute of a software package to allow
companies to submit TRI data on microcomputer diskette.
These recommendations, along with others, were implemented.
In August, 1992, the same consultant completed a follow-up
study which examined ways to expand the system to handle more
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Expansion Strategy for the TRI Information Management System
forms. The report concluded that EPA would have to fundamentally
redesign the information management system if it became necessary
to expand TRI beyond 14-15 million data elements per reporting
cycle.
EPA did not accept the consultant's conclusions about the limit
"on the number of forms that could be processed during a reporting
cycle. In September, 1992 EPA staff conducted a comprehensive
review of system operations with the goal of identifying ways to
increase system efficiency. Based on that review, EPA
implemented the following actions for processing reporting year
1991 forms:
• Expansion of the night shift for data entry allowing
about 30 percent more data to be entered.
• Institution of preventive maintenance versus reactive
maintenance of computer systems resulting in no major
down time, allowing full operation over all shifts.
• Expansion of the LAN by adding another file server,
allowing simultaneous data entry and data
reconciliation operations to be conducted.
• Enhancement of the LAN data entry software to increase
the efficiency of data entry operators.
• Establishment of a computer system to track all forms
by using barcodes, resulting in substantially increased.
efficiency by reducing the waiting time for forms
needed during data reconciliation.
Experience gained while processing 1991 forms, which was
started in September, 1992 and was completed in April, 1993, has
confirmed that implementation- of the above measures substantially
improved reporting center operations. For reporting year 1991,
EPA faced a 60 percent increase in data (from 6.0 million for
1990 to 9.6 million for 1991) and a two month shorter time period
to process the data. Despite the shorter time available and the
increased number of data elements, EPA was able to achieve its
goal to complete data processing by the beginning of April, 1993.
About 60 percent more data was processed in 20 percent less time
than in previous years.
Additionally, in the Fall of 1992, EPA received a
preliminary report from the EPCRA Reporting Center contractor
suggesting that the LAN used by the ERG for data entry could be
expanded beyond its current capacity. Further analysis and the
experience gained while processing the 1991 reporting year forms
has proven that the LAN can be expanded further while maintaining
efficient operations.
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Expansion Strategy for the TRI Information Management System
Analysis of the Processing Capacity of the Existing TRI
Information Processing System
Reporting Year 1991 is the base year for the capacity
analysis. For that year, the ERC operated at full capacity and
processed a total of 9.6 million data elements (MDE).
EPA has identified several additional areas where the
capacity of the existing system can be increased. These are:
• General efficiencies which include minor improvements
such as changes in document handling procedures.
• The implementation of a document imaging system,
scheduled for July, 1994. This will reduce delays in
processing due to unavailability of files for data
entry and quality assurance.
• Additional workstations for data entry and
reconciliation and an expanded shift during peak
processing periods.
EPA has analyzed the potential increase in capacity from
these improvements and the impact of electronic submissions on
processing capacity. Based on this analysis EPA has developed a
model of the processing capacity of the existing TRI information
management system as a function of the percentage of electronic
submissions. The model estimates that the system capacity ranges
from 12 MDE with no electronic submissions to 20 MDE when all
forms are electronically submitted.
The capacity of the existing TRI information management
system is highly dependent on the number of forms electronically
submitted. The capacity of the system increases as the
percentage of electronic forms increases. Figure 1 shows the
percentage of electronic forms required to achieve various levels
of system capacity. The maximum capacity of the existing system
with the proposed improvements (20 MDE) can be achieved if all
forms are electronically submitted.
Potential for Electronic Submissions
There is significant potential for increasing the number of
TRI forms electronically submitted. The number of electronic
forms increased from 12 percent in Reporting Year 1991 to 35
percent in Reporting Year 1992. In Reporting Year 1992, about
1,000 parent companies (out of about 22,000 companies) accounted
for almost 40 percent of the electronic forms. If these 1,000
companies had submitted all their forms electronically, the
overall percentage of electronic submissions would have increased
from 35 percent: to about 50 percent.
EPA's strategy on electronic submissions is to make a
special outreach effort to the companies that submitted the most
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Figure 1
Required % Electronic Submissions
To Reach System Capacity
100
o
'co
E 80-
_Q
D
(/)
•1 60 H
O
•M
O
rr? 4OH
20-
D
C7
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Expansion Strategy for the TRI Information Management System
paper forms in Reporting Year 1992 to encourage them to
electronically submit their Reporting Year 1993 forms. In
addition, EPA is working with trade associations, such as the
Chemical Manufacturers Association, to develop programs to
encourage their members to submit electronically. EPA has
already enhanced it's electronic reporting package to make it
more user-friendly and plans to expand user support for Reporting
Year 1993. EPA will begin an evaluation and pilot of electronic
data interchange (EDI) during fiscal year 1994.
EPA's believes that with voluntary efforts, 60-70 percent of
all forms could be electronically submitted. This would make the
processing capacity 17-18 million data elements per reporting
cycle. To increase to 20 million data elements would require
electronic reporting from all submitters.
Information Processing Cost of TRI Expansion
EPA has developed a model for the six categories of cost for
information processing (ERC fixed cost, data entry, data quality,
magnetic media, computer systems, and data analysis). The model
identifies fixed costs and incremental costs that vary with the
number of forms to be processed.
The major saving from electronic submissions is in data
entry. There is some saving in data quality because forms
electronically submitted tend to require less review and
correction.
It costs EPA about $25.00 to enter a paper form and about
$7.00 to enter an electronic form. As the number of electronic
forms increases, the system capacity increases and the total data
entry cost decreases. This is illustrated in Figure 2.
Figure 3 shows the relationship between information system
capacity and total processing cost. Although the data entry cost
decreases as the number of electronic forms increases, other
processing costs increase because of the larger number of forms.
Once entered, there is little difference in the subsequent
processing cost of paper and electronic forms. However, the
total cost of information processing remains almost constant
because data entry is a large portion of the total processing
cost.
Conclusions
The processing capacity of the system is highly dependent on
the number of forms that are electronically submitted. The
capacity with no electronic submissions, i.e., all forms are
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Figure 2
TRI Data Entry Cost
At System Capacity
U)
I
0
12
13 14 15 16 17 18 19
System Capacity (Million Data Elements)
20
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Figure 3
TRI Information Processing Cost
At System Capacity
8
6-
0)
§5
3
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Expansion Strategy for the TRI Information Management System
submitted on paper, is 12 million data elements. To reach the
maximum capacity of about 20 million data elements requires that
all forms be electronically submitted. EPA believes that with
voluntary efforts, 60-70 percent of forms will be electronically
submitted, making the capacity of the existing TRI information
processing system 16-18 million data elements per reporting
cycle.
EPA has enough capacity to process the increased number of
forms from phase I chemical expansion. EPA can also add new
forms (up to about 80,000) from phase II facility expansion using
the existing information management system.
Because electronic forms cost less than paper forms to enter
in the system, the total information processing cost remains
almost constant as the system capacity increases. EPA can
process up to about 20 million data elements per reporting cycle
with about the about same budget as required for 12 million data
elements because of the larger number of electronic submissions.
This paper does not address capacity beyond 20 million data
elements per reporting cycle. Achieving these capacities would
require substantial expansion or revision of the information
management system.
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