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Project
No.:
0172.01.005.062
DISTRIBUTION
Page
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Project
Name:
304m
National
Strategy
TELEPHONE
CALL
RECORD
Outgoing
Call
Date:
10/
16/
03
Time:
3:
30
pm
Company
Name:
US
EPA/
TRI
Contact
Name:
Dan
Bushman,
Ph.
D.

Phone
No.:
(
202)
566­
0743
Name:
Betsy
Bicknell
Eastern
Research
Group,
Inc.

GENERAL
SUBJECT
:
TRI
Reporting
of
Dioxin
and
Dioxin­
Like
Compounds
TOPICS
DISCUSSED
AND
ACTION
TAKEN
After
some
introductory
e­
mail
correspondence
(
attached)
I
called
Dan
Bushman,
Ph.
D.,
of
EPA's
TRI
office
to
discuss
TRI
reporting
of
dioxin
and
dioxin­
like
compounds.

Dr.
Bushman
explained
that
2000
was
the
first
year
for
dioxin
reporting.
After
receiving
the
reports
for
that
year,
he
called
facilities
that
reported
higher
dioxin
releases
than
the
rest
of
their
SIC
code.
After
bringing
these
high
reported
releases
to
their
attention,
some
facilities
corrected
their
reports.
Unit
errors
were
fairly
common,
even
from
larger
companies.
These
corrections
are
incorporated
in
to
the
current
release
of
TRI
2000.

Facilities
use
a
combination
of
measurements
and
emission
factors
to
estimate
their
dioxin
releases.
Dioxins
were
detected
in
the
releases
from
the
manufacture
of
titanium
dioxide.
Dioxins
had
not
previously
been
identified
with
this
process.

I
asked
Dr.
Bushman
if
he
had
any
insights
into
the
sources
of
dioxins
from
petroleum
refineries.
He
mentioned
catalyst
regeneration,
and
that
he
thought
the
refineries
had
changed
their
process
to
reduce
dioxin
generation.
I
mentioned
that
17
refineries
reported
dioxin
releases,
but
he
didn't
offer
any
suggestions
as
to
what
made
them
different
from
facilities
that
did
not
report
dioxin
releases.

I
asked
Dr.
Bushman
how
facilities
develop
their
congener
distributions.
He
explained
that
TRI
instructs
facilities
to
report
one
distribution
for
their
entire
plant
releases,
based
on
the
best
data
they
have.
Thus,
even
if
they
have
measurements
of
multiple
wastestreams,
they
report
one
distribution.
Some
members
of
the
Chlorine
Chemistry
Council
(
CCC)
think
this
approach
does
not
properly
describe
their
releases.
They
have
made
estimates
based
on
a
wastestream­
by­
wastestream
approach.
Dr.
Bushman
believes
that
these
data
are
most
likely
based
on
actual
measurements
or
emission
factors
based
on
actual
measurements.
According
to
Dr.
Bushman,
these
TEQ
will
differ
from
what
we
would
calculate
by
multiplying
the
reported
congener
distributions
by
the
reported
"
TM­
17."
The
EPA
TRI
webpage
has
a
link
to
the
CCC
website
with
TEQ
releases,
by
plant,
by
release
medium.
?
Need
to
return
call
by
/
at/
between
and
.
Signature:
Dr.
Bushman
senses
that
companies
are
sensitive
about
their
releases
and
are
unlikely
to
hugely
overestimate
their
dioxin
releases.
In
addition,
the
dioxin
guidance
allows
reporting
facilities
to
use
"
0"
for
<
method
detection
limit,
if
they
measured
using
method
1613.
(
my
simplified
paraphrase,
see
attached
e­
mail
for
full
details).

I
asked
Dr.
Bushman
if
he
had
any
insights
as
to
how
facilities
report
releases
of
total
PACs.
He
referred
me
to
Gail
Froiman
202
566­
0697,
who
was
responsible
for
the
PAC
Reporting
Guidance
Document.

For
overall
TRI
data
quality
issues
he
referred
me
to
Velu
Senthil
202
566­
0749.
