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EPANonrulemakingEPA-HQ-TRI-2003-0001

Toxic Chemical Release Reporting; Community Right-to-Know; Notice of On-line Dialogue

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Apr 16, 2024
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closed 8210d ago
League of Women Voters filings
2

Activity

League of Women Voters filed 2 comments on this docket between Jan 30, 2004 and Feb 3, 2004. 105 other organizations filed here. The comment window closed 8210d ago.

What League of Women Voters filed (2)

Feb 3, 2004· Public comment submitted by an anonymous commenter representing the League of Women Voters - New Hampshire· EPA-HQ-TRI-2003-0001-0297

ID#TRI-2003-0001 Phase II Stakeholder Comment Option 3 Re: Toxics Release Inventory Reporting Burden Reduction I am writing on behalf of the League of Women Voters New Hampshire as a community activist in New Hampshire, and worked with the Toxics Release Inventory (TRI) data for 12 years in Kentucky as the Madison County Solid Waste Coordinator. The TRI data have been an extremely valuable tool in working with industrial facilities, other environmental groups, and citizens groups looking to protect the environment and understanding issues of waste management. After examining the burden reduction options set out in the online stakeholder dialogue, I have believe that they will make it much more difficult to obtain chemical-specific information on releases to the environment, off-site transfers, and production-related waste. Most troubling is the option of expanding Form A eligibility by excluding on- and off-site recycling from the threshold. EPA has supported reuse and recycling efforts including changing recycling reporting under RCRA, the fact remains that ?recycling? at facilities is an industrial process that can involve tens of thousands of pounds of toxic chemicals. Even if these chemicals are not routinely released to the environment, the presence of these chemicals on site in large quantities increases the potential for accidents, terrorist attack opportunities and worker exposure. And if the Agency?s RCRA proposal is adopted, TRI will be the only way that communities will be able to learn about significant amounts of off-site transfers to recycling through their local neighborhoods, since RCRA manifests will no longer be required in many cases. While the Agency?s analysis makes the argument that very little data are lost in the aggregate, the proposals - especially those that expand the eligibility for Form A - can have a huge impact in individual states, and on facilities in specific industries in those states. option 3

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Jan 30, 2004· Public comment submitted by Sally Davis representing League of Women Voters New Hampshire· EPA-HQ-TRI-2003-0001-0744

option 6

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Abstract

Point of Contact: Larry Reisman; Telephone 202-566-0751; Email reisman.larry@epa.gov; Mail Code 2844T; Office OIAA

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Co-filers (105)

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