1
Summary
of
API
Meeting
September
25,
2003
Attendees:
Randy
Hill,
Acting
Director,
TRI
Program
Division;
Michelle
Price,
Acting
Chief,
TRI
Regulatory
Development
Branch;
John
King,
Marathon
Ashland
Petroleum;
Clay
Freeberg,
Chevron/
Texaco;
Mary
Catherine
Fish;
MCF
Consulting;
Jonnie
Martin,
Shell
Oil
Products
US;
Al
Collins,
Occidental;
Tom
Yarnick,
ExxonMobil;
Lakeisha
Harrison,
API;
Erik
Milito,
API;
Alice
Cuouie,
API;
Glen
Barrett,
API
Summary:

Mr.
Hill
gave
a
summary
of
activities
related
to
the
ICR
and
renewal
status.
On
Tuesday,
July
1,
2003,
Federal
Register
(
FR)
notices
were
published
that
began
the
Information
Collection
Request
(
ICR)
renewal
process
for
the
TRI
Reporting
Form
R
(
68
FR
39074)
and
the
Form
A
Certification
Statement
(
68
FR
39071).
The
TRI
Program
is
seeking
OMB
approval
in
compliance
with
the
Paperwork
Reduction
Act
(
PRA)
for
these
two
collection
activities
that
are
due
to
expire
on
October
31,
2003.
The
EPA
docket
for
this
action,
OEI­
2003­
0025
received
over
50
comment
submissions.

For
the
Form
R
ICR
renewal,
the
TRI
Program
sought
public
comment
on
extensive
changes
to
the
Form
R
in
an
effort
to
collect
information
in
a
more
logical
and
easier
manner.
However,
in
light
of
significant
comments
from
States,
the
regulated
community
and
other
TRI
data
users
concerning
the
implementation
burden
of
so
many
changes
at
once,
EPA
considering
deferring
many
of
the
proposed
changes,
especially
those
changes
proposed
in
sections
5
and
6.

With
regard
to
the
changes
proposed
in
section
8.1,
many
respondents
supported
these
changes
to
the
Form
R.
Others
recommended
additional
changes
to
further
clarify
Section
8.1.
Some
were
opposed
to
all
proposed
changes
to
Section
8.

Participant
asked
if
EPA
had
reviewed
the
API
comments.
Mr.
Hill
responded
that
EPA
was
reviewing
all
comments,
including
those
from
API.

Participant
asked
if
EPA
had
made
decisions
about
how
the
form
changes
would
be
implemented
in
the
Public
Data
Release
(
PDR).
Mr.
Hill
explained
that
the
Agency
had
not
made
decisions
about
the
PDR
and
that
the
program
was
currently
reviewing
the
entire
TRI
data
cycle
and
all
PDR
products.

Participant
asked
if
we
would
go
back
to
using
M
codes
if
the
changes
proposed
in
sections
5
and
6
were
deferred.
Mr.
Hill
said
yes.

Participant
asked
how
EPA
would
respond
to
comments
and
how
they
would
know
when
the
2
form
was
approved
by
OMB.
Mr.
Hill
explained
that
EPA
would
include
a
summary
of
the
comments
and
the
Agency's
response
in
the
materials
submitted
to
OMB
when
EPA
resubmits
the
ICR
renewal
package.
He
noted
that
the
response
to
comments
is
for
an
ICR,
not
a
rulemaking,
so
it
will
be
at
a
more
general
level
than
a
rulemaking
response
to
comments.
Mr.
Hill
also
noted
that
an
FR
notice
will
be
published
when
the
forms
are
approved
by
OMB.

Participant
asked
about
EPA's
burden
estimates
and
why
they
didn't
reflect
the
burden
from
the
additional
data
elements
proposed
by
EPA.
Mr.
Hill
explained
that
the
data
elements
proposed
were
not
new,
that
they
were
just
a
different
format
to
collect
the
same
information.
He
also
noted
that
some
ICR
commenters
were
confused
by
EPA's
lower
burden
estimates
given
expanded
data
elements
on
the
form.
Mr.
Hill
admitted
that
EPA
could
have
done
a
better
job
explaining
this
how
the
form
changes
related
to
the
burden
estimates.

Meeting
concluded
at
1
pm.
