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EPARulemakingEPA-HQ-TRI-2002-0001

Dioxin and Dioxin-like Compounds: Toxic Equivalency Reporting: Community Right-to-Know Toxic Chemical Release Reporting

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Jun 12, 2024
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closed 7753d ago
American Petroleum Institute filings
2

Activity

American Petroleum Institute filed 2 comments on this docket between May 6, 2005 and May 13, 2005. 17 other organizations filed here. The comment window closed 7753d ago.

What American Petroleum Institute filed (2)

May 13, 2005· Comment submitted by Howard J. Feldman, Director, Regulatory Analysis and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-TRI-2002-0001-0048

Filed on regulations.gov — full text not in the inline record.

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May 6, 2005· Comment submitted by Howard J. Feldman, Director, Regulatory Analysis and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-TRI-2002-0001-0040

API supports the concept that releases and transfers of dioxins and dioxin-like compounds should be reported in units of toxic equivalents (TEQs). It is possible to accomplish this by minor modifications to Form R, in a manner that would not increase TRI reporting burden. Specifically, EPA should keep section 1.4 of Form R (for reporting the most representative distribution of each member of the category) and change the units for reporting in the rest of Form R from grams to TEQs. EPA?s proposal would unnecessarily increase the burden of TRI reporting by creating an entire new 10-page form for dioxins reporting (Form R-D). API urges EPA to revise TRI reporting requirements so that dioxins and dioxin-like compounds are reported in TEQs, but to do so in a manner that does not significantly increase TRI reporting burden. Please see the attachment for the remainder if this comment.

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Abstract

Contact: Daniel Bushman, Petitions Coordinator EPA (2844T) 1200 Pennsylvania Ave NW Washington, DC 20460 202 566-0743 bushman.daniel@epa.gov

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Co-filers (17)

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Dioxin and Dioxin-like Compounds: Toxic Equivalency Reporting: Community Right-to-Know Toxic Chemical Release Reporting (EPA) — American Petroleum Institute | OpenPolis