Februay
11,2002
The
Honorable
Job
D.
Graham
Aclmi&
txator,
Office
of
­
tion
and
Regulatory
A5%
rs
'
bfiice
of
Management
d
Budget
Eiseahowa
Executive
Office
Building
17"
rmdJ?
enxi~
lvada
Averme
NtK
Washington
DC
20503
m.
change
b
TRI
Reporting
of
Dioxin
Dear
Ad;
ninistratar
Oraham:

We
the
undersigned
associations
undemmd
that
EPA
i
s
considering
change
to
the
r
e
p
o
m
of
dioxins
in
the
Toxics
Relemc
hvmtory
by
adding
h%
iC
equivdeclts
(
TEQ)
dab
t0
the'exisriag
data
program.
W
e
str~
ngly
support
this
chango
and
believe
it
to
be
a
ConStrWc
addition
that
will
provide
the
public
with
a
better
undmtandiag
of
dioxin
data
Q
the
While
some
might
suggest
that
this
is
an
additional
burdm
io
reportors,
we
believe
the
additional
a
b
r
t
is
minor
compared
fo
the
benefits
to
companies
and
tu
the
public.
FLathemaora,
the
addi6on
of
TEQ
data
would
be
consistent
with
O
m
s
recently
released
Guidelines
for
Emwing
and
Mmimizing
the
Qun&,
Obje&*&
Utiliry
and
In&@&
of
Infinnation
Dissmlnazed
by
Federal
Agencies
brcause
TEQ
data
is
mon
m
e
d
@
to
the
ppblic
and
consistant
with
otlla
programs.

The
category
of
dioxin
and
diaxh­
likc
compounds
in
the
TRI
is
composed
of
a
group
of
17
compo~~~
ds
with
vastly
d
i
E
i
t
toxicities.
Thc
TEQ
metric
was
dcvcloped
to
account
fur
fhrse
different
toxicities
and
has
been
adopted
as
the
stylard
mdmd
far
reporting
inventories
of
dioxin
and
dioxin­
like
coupaunds
by
USEPA
apd
intmnational
agenaes.
Udorhmately,
the
TRI
currently
simply
adds
the
mssses
of
fhe
17
dil erent
compounds
producing
a
meaningless
measure
of
releases
of
dioxins
because
it
fails
to
accout
for
the
Vastly
differwt
toddties.
It
is
460
very
confbsing
to
the
pnblia
because
it
is
~
S
m
t
witb
thc
well­
established
and
more
meanin@
ISPA
Inventory
C
J
~
S
m
c
a
of
Diarln
and
Diozin­
Lik
compounds.

Tbt
addition
of
TEQ
repoxtkg
is
anticipatai
to
only
minimally
in­
the
initial
p
q
a
~
o
r
k
burden
to
repcudrig
compapies,
Momva,
the
data
will
;
Jso
be
of
value
to
the
OfEice
of
Pollution
Prevmtion
and
Toxics
(
OPPT)
to
update
the
Inventory
of
Sources
uf
Dio&
uad
Dioxin
Like
Compounds.
TEQ
data
in
the
TRl
would
allow
OPPT
to
update
its
information
on
industry
somes
of
dioxin
more
hquently
and
eliminate
redundant
data
gathering.
The
member
Comparb
of
the
rmdasigned
associations
eaoour.
age
the
TEQ
reporting
of
dioxin
and
dioxiu­
lilce
compounds
because
it
will
pvide
the
public
with
mare
rn­

informatioli
and
allow
OUT
members
to
place
these
rdeases
in
context
with
other
mums
of
kverrta~
y
of
Somcs
ofDiosdn
md
Did,
n­
L&
c
C..
rrrpoun&

05/
06/
20.02
FRI
09:
17
[
TX/
RT
NO
59191
m002
OE
I
dioxin
not
~
dvered
by
TRI.
Furthcrmorc,
we
hope
that
thare
will
be,=
opportunity
for
reponas
to
subsnit
TEQ
data
for
h
e
2000
and
2001
reporting
years
so
that
which
trkj\
d
data
can
be
established.

If
EPA
d
o
a
submit
t
h
i
e
change,
we
would
hope
that
O
m
wodd
expedite
its
revim
and
support
the
addition
of
TEQ
r
e
p
o
m
to
the
TIU.
If
you
have
any
questim
or
would
lilre
to
meet
to
discuss
this,
please
call
Keith
chriman
at
the
Chlorine
Chemispy
C
a
d
at
(
703)
741
­
5935.

sincerely,

Executive
Dkector
Chlorine
Chernisay
Comd
Vice
Presidenx
hcricanQzanwtry
'
Council
Thomas
B.
Carter
Director
Envirpnmcntal
A
f
f
i
s
mcrican
portland
Cement
Alliance
Vice
President
mwiromtmt,
~
4
t
h
Safety
T
~
C
A.
lumiaum
Association
Sharon
H.
Kneiss
Vice
P
e
d
a
t
Regulatory­
­
berican
Forest
&
Papa
Assocbhl
Q&
an
J.
Sbea,
Executive
Director
Environment
'

Edison
Eleceic
InstiMe
