Meeting with the National Petrochemical & Refiners Association with EPA 

Purpose:  To Discuss Proposed Modifications to IUR rule

October 5, 2010

Attendees:  Jim Cooper, NPRA; Jeff Gunnulfsen, NPRA, Ward Penberthy,
EPA; Jim Willis, EPA; Sara Hisel-McCoy, EPA; Karen Hoffman, EPA

On October 5, 2010, EPA met with the National Petrochemical & Refiners
Association (NPRA) to discuss some of the proposed modifications to the
Inventory Update Reporting (IUR) rule. NPRA is a national trade
association that represents U.S. refiners and petrochemical
manufacturers. During the meeting, EPA answered questions that clarified
several of the proposed requirements. Topics discussed include: the IUR
electronic reporting software and the opportunity for testing and
training; whether the Agency considered proposing the optional (instead
of mandatory) use of the reporting tool; the dynamic nature of chemicals
manufactured in the U.S. and its effect on production volume from year
to year. For the reporting of processing and use information, NPRA
commented on the burden associated with eliminating the 300,000 lb.
reporting threshold and the replacement of the "readily obtainable"
reporting standard with the more stringent "known to or reasonably
ascertainable by" reporting standard.

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