1
TRI
Burden
Reduction
Stakeholder
Briefing
October
19,
2004
Meeting
Summary
EPA
Presenters:
Mike
Flynn
Mike
Petruska
Kevin
Donovan
Shelley
Fudge
Paul
Borst
EPA
Attendees:
Elsa
Bishop
Karen
Brown
John
Cooper
Evie
Cummings
Steve
DeVito
John
Dombrowski
Marc
Edmonds
Erin
Koch
Kathleen
Meir
Kevin
Minoli
Michelle
Price
Angela
Suber
Cassandra
Vail
Stakeholder
Attendees:
Todd
Abel,
CCC
David
Ailor,
ACCCI/
NOPA
William
Allmond,
National
Association
of
Chemical
Distributors
John
Arnett,
Copper
and
Brass
Fabricators
Council
Andrew
Bopp,
Society
of
Glass
and
Ceramic
Decorators
Kevin
Bromberg,
U.
S.
Small
Business
Administration
Dr.
Norbert
Dee,
National
Petrochemicals
and
Refiners
Association
Rick
Deery,
Resources
Committee,
House
Lisa
Edouard,
AF&
PA
Julia
Festa,
AF&
PA
Mary
Catherine
Fish,
MCF
Consulting,
Inc.
Elizabeth
Gaudio,
National
Federation
of
Independent
Business
Jennifer,
Giboon,
National
Association
of
Chemical
Distributors
Jeff
Gunnulfsen,
SOCMA
Edward
Herbert,
National
Ready
Mixed
Concrete
Association
Steve
Higley,
Senate
EPW
Maj.
Office
Joseph
Johnson,
SBA
Advocacy
John
King,
American
Petroleum
Institute
2
Sean
Moulton,
OMB
Watch
Andy
Opperman,
New
Jersep
DEP
Paul
Orum,
Working
Group
on
Community
Right­
to­
Know
Jane
Powers,
U.
S.
Department
of
Energy
Danielle
Quist,
House
Government
Reform
 
Sub
Reg
Affairs
Tiernan
Sittenfeld,
U.
S.
Public
Interest
Research
Group
Ann
Smith­
Reiser,
Analytical
Services
Corporation
Dean
Scott,
Bureau
of
National
Affairs
George
Sorvalis,
Working
Group
on
Community
Right­
to­
Know
Bruce
Steiner,
American
Iron
and
Steel
Institutes
Derek
Swick,
American
Petroleum
Institute
Danielle
Waterfield,
Specialty
Graphic
Imaging
Association
Lee
Zeugin,
Hunter
and
Williams;
Edison
Electric
Institutes
Meeting
Format
and
Process:

Introductory
remarks
were
presented
by:
Mike
Flynn,
Director,
Office
of
Information
Analysis
and
Access,
and
Mike
Petruska,
Director,
TRI
Program
Division.
Formal
presentations
by
EPA
updating
various
aspects
of
TRI
burden
reduction
were
as
follows
(
note:
full
versions
of
the
meeting
presentations
can
be
found
in
the
docket,
and
are
important
to
understanding
the
questions
and
comments
relative
to
these
presentations
as
outlined
in
this
meeting
summary
report):

1)
Review
of
Overall
Burden
Reduction
Strategy
Presenter:
Kevin
Donovan,
U.
S.
EPA,
TRI
Program
Division
Overview:
An
overview
and
status
update
on
EPA's
efforts
towards
TRI
burden
reduction
was
presented,
including
projected
timeframes.
(
filename:
1­
overallburdredstrategy.
pdf)

2)
TRI
Reporting
Forms
Modification
Rule
Presenter:
Shelley
Fudge,
U.
S.
EPA,
TRI
Program
Division
Overview:
An
outline
of
a
new
proposal
for
TRI
reporting
forms
modification
was
presented.
This
proposal
supplements
the
burden
reduction
options
as
previously
presented
in
the
TRI
burden
reduction
stakeholder
dialogue
white
paper.
This
proposal
includes
removal
or
modifications
to
reporting
for
Part
I,
Sections
4.6,
4.8,
4.9,
and
4.10,
of
the
Form
R
and
the
Form
A
Certification
Statement,
and
Part
II,
Sections
5.3.1.
C,
7A.
1b,
7A.
1c,
7A.
1d,
7A.
1e,
7B,
7C,
and
8.11
of
the
Form
R.
(
filename:
2­
formsmodification.
pdf)

3)
TRI
Program­
Related
Burden
Reduction
Options
and
Public
Comment
Summary
Presenter:
Kevin
Donovan,
U.
S.
EPA,
TRI
Program
Division
Overview:
The
burden
reduction
options
as
previously
presented
in
the
TRI
burden
reduction
stakeholder
dialogue
white
paper
were
outlined.
A
summary
of
comments
received
to
date
on
each
of
the
options
was
presented.
(
filename:
3­
burdredoptions.
pdf)
3
4)
Approach
to
Options
Analysis
Presenter:
Paul
Borst,
U.
S.
EPA,
Analytical
Support
Branch,
Environmental
Analysis
Division
Overview:
An
overview
of
completed
and
proposed
TRI
data
analyses
conducted
in
support
of
burden
reduction
options
assessment
was
presented.
(
filename:
4­
optionsanalysis.
pdf)

Following
each
presentation
was
a
discussion
period
for
audience
questions
and
comments
and
EPA
response
to
questions
and
comments.
An
additional
discussion
period
for
audience
questions
and
comments
on
any
of
the
presentations
or
aspects
of
burden
reduction
was
given
at
the
end
of
the
day.
A
summary
of
all
comments
was
presented
back
to
the
meeting
attendees
at
the
end
of
each
discussion
to
ensure
that
audience
comments
had
been
accurately
understood
and
recorded.
The
following
sections
of
this
meeting
summary
present
the
content
of
these
discussion
sessions,
organized
around
the
proposed
TRI
burden
reduction
options.

Audience
members
indicated
that
they
had
no
additional
questions
or
comments,
and
the
meeting
was
closed.
EPA
indicated
that
further
comments
and
suggestions
on
TRI
burden
reduction
are
welcomed
in
the
future.

General
Comments:

 
In
response
to
comments
about
potential
new
ideas
for
burden
reduction,
EPA
responded
that
there
are
many
EPA
initiatives
currently
underway
that
are
in
line
with
the
ideas
received
under
the
stakeholder
dialogue,
in
particular
regarding
data
collection
and
access,
but
are
not
formally
being
called
burden
reduction.
These
include:
o
Development
of
a
new
Form
R
for
dioxins
that
will
use
TEQs
(
toxicity
equivalencies).
o
An
increasingly
web­
based
approach
to
TRI
reporting.
o
Enhancements
to
the
TRI­
ME
software.
o
An
overhaul
of
TRI
explorer
and
Envirofacts.
o
Expanded
presentation
of
context
around
TRI
data.

 
There
were
several
comments
on
the
use
of
range
codes
in
general
on
multiple
data
elements
on
the
Form
R.
These
included:
o
Use
of
range
codes
leads
to
misleading
data
as
reported
in
the
public
data
release
because
the
midpoint
of
the
range
is
reported
out.
This
furthers
the
misperception
because
use
of
range
codes
does
not
require
precise
estimates,
but
an
actual
quantity
is
reported
and,
also,
the
midpoint
quantity
is
reported
when
an
actual
release
or
transfer
of
a
quantity
at
the
top
or
the
bottom
range
may
have
occurred.
o
Use
of
this
less
accurate
midpoint
data
is
frustrating
to
data
users.
Use
of
range
codes
should
be
eliminated.
4
o
More
precise
release
data
(
versus
less
precise
range
reporting)
is
important
to
those
in
the
impact
area
of
releasing
facilities.
This
is
particularly
important
to
locals
surrounded
by
multiple
TRI­
reporting
facilities.
o
The
imprecision
of
the
data
from
range
code
use
becomes
cumulatively
worse
in
the
area
of
impact
of
multiple
facilities
and
also
over
multiple
years
in
making
risk
estimates.
o
EPA
reauthorized
use
of
range
codes
in
the
1990s.

 
There
were
comments
questioning
the
validity
of
apparent
assumptions
that
have
come
out
of
the
TRI
burden
reduction
stakeholder
process.
The
following
is
an
assessment
by
the
commenter
of
these
perceived
assumptions:
o
A
small
business
does
not
necessarily
indicate
a
small
release.
o
A
small
release
quantity
does
not
necessarily
indicate
an
unimportant
release
or
low
risk
or
harm
because:


Small
releases
of
highly
toxic
chemicals
can
present
high
risk
or
harm.


The
potential
risk
is
important
to
the
local
population
impacted
by
the
release.
National
release
totals
are
not
meaningful,
the
local
risk
is
meaningful.
o
Zero
releasers
may
have
large
waste
streams.
o
Waste
management
activities
such
as
recycling
can
have
significant
impacts,
impacts
are
not
just
from
releases.
For
example,
recycling
can
cause
serious
risk
or
harm
through
worker
exposure
and
many
seriouslycontaminated
sites
were
created
through
recycling
activities.
o
A
number
of
proposed
details
of
the
burden
reduction
options
give
credit
for
or
suggest
eliminating
reporting
on
recycling
and
energy
recovery.
Do
not
give
incentives
for
recycling,
instead,
place
more
emphasis
on
encouraging
source
reduction.
Source
reduction
can
lead
to
significant
financial
savings
versus
recycling.
The
Pollution
Prevention
Act
is
about
source
reduction,
and
this
is
not
getting
enough
consideration.
o
Use
of
range
codes
should
be
reduced
or
eliminated,
not
expanded.

 
One
commenter
reported
that
his
review
of
all
of
the
comments
to
the
TRI
burden
reduction
options
received
through
the
stakeholder
dialogue
showed
that
80%
of
comments
were
against
moving
forward
with
any
TRI
burden
reduction
that
resulted
in
less
information.

 
One
commenter
questioned
the
current
baseline
estimate
for
TRI
reporting
burden,
stating,
for
example,
that
credit
is
not
given
for
the
TRI­
ME
software
which
does
reduce
burden
through
pre­
populating
information
from
the
previous
years'
forms,
etc.
EPA
responded
that
the
2006
ICR
will
be
accepting
comments
on
this
baseline.

 
There
was
a
suggestion
that
TRI
training
courses
be
given
earlier
in
the
year
to
allow
facilities
more
time
to
prepare
TRI
reports.
EPA
responded
that
they
need
5
to
wait
to
initiate
courses
until
they
have
received
OMB
approval
for
the
new
reporting
year's
forms
and
instructions.

 
There
was
a
suggestion
that
a
check
box
be
added
to
the
TRI­
ME
software
indicating
that
"
We
don't
use
underground
injection
wells
and
never
have"
in
order
to
avoid
having
to
pass
through
queries
on
this
data
element.
EPA
indicated
that
the
incidence
rate
for
reporting
in
this
data
element
is
less
than
one
percent.

 
There
was
a
comment
specific
to
the
cement
and
limestone
industry
that
very
few
limestone
suppliers
provide
constituent
information.
While
industry
is
not
required
to
conduct
laboratory
analysis
for
TRI
reporting,
the
lack
of
information
from
suppliers
and
this
sector's
belief
that
the
AP­
42
emission
factors
relative
to
their
industry
need
updating
has
left
them
in
a
difficult
situation.
EPA
has
agreed
to
work
further
with
this
commenter
outside
of
the
context
of
the
burden
reduction
stakeholder
process.

Forms
Modification:

General
Comments/
Questions:
 
A
question
was
posed
as
to
how
data
such
as
RCRA
i.
d.
would
be
obtained
if
there
was
nothing
in
FRS.
EPA
responded
that
there
are
multiple
methods,
such
as
an
address
matching
procedure,
to
link
to
this
data.
 
A
question
was
posed
as
to
how
a
facility
could
report
or
correct
errors
if
certain
data
elements
are
pulled
from
FRS
instead
of
self­
reported
by
the
facility.
EPA
responded
that
they
are
developing
a
procedure
to
report
such
errors.
 
Regarding
a
proposal
for
changing
7A.
1d
(
on­
site
waste
treatment
efficiency)
from
a
percentage
to
a
range
code,
a
question
was
posed
as
to
how
does
this
reduce
burden?
EPA
and
others
responded
that
this
lessens
the
required
data
collection
and
calculations,
as
a
less
precise
estimation
is
needed,
thus
use
of
range
codes
does
lessen
burden.
 
Regarding
proposed
changes
to
7A.
1d
(
on­
site
waste
treatment
efficiency)
and
7B
(
energy
recovery
method
used),
a
question
was
posed
asking
why
wouldn't
facilities
need
to
know
this
information.
EPA
responded
that
these
modifications
were
proposed
in
an
effort
to
make
things
easier
for
reporting
facilities.
 
EPA
indicated
that
one
of
the
justifications
for
proposed
removal
or
modification
of
certain
data
elements
was
lack
of
use.
A
few
questions
were
posed
asking
if
potential
data
users
(
both
inside
and
outside
of
EPA)
had
been
considered
when
removal
or
modification
of
certain
Form
R
elements
was
proposed,
for
example
those
within
EPA
who
look
at
effluent
guidelines.
EPA
responded
that
while
a
formal
workgroup
was
not
required
for
this
streamlined
rule,
EPA
is
working
closely
with
a
regional
workgroup
on
the
proposed
forms
modification
rule
and
is
carefully
considering
data
users.
EPA
also
indicated
that
how
TRI
data
are
used
has
been
closely
examined,
with
these
results
included
in
a
TRI
data
use
paper
that
is
available
on
the
EPA
website.
 
Relative
to
potential
removal
of
the
8.11
checkbox,
a
few
questions
were
posed
as
to
why
or
how
this
optional
pollution
prevention
information
may
be
useful?
6
EPA
responded
that
providing
a
way
for
facilities
to
report
optional
pollution
prevention
narratives
is
a
statutory
requirement
of
the
Pollution
Prevention
Act.
Others
responded
that
valuable
and
innovative
pollution
prevention
ideas
would
be
highly
useful
to
peer
facilities.

Comments
in
Favor:
 
A
comment
was
made
applauding
EPA's
effort
to
take
a
hard
look
at
the
Form
R
and
modify
or
eliminate
certain
data
elements.

Comments
Opposed:
There
were
no
comments
in
strong
opposition
to
the
proposed
forms
modification.

Option
1
(
Higher
Reporting
Thresholds
for
Small
Businesses):

General
Comments:
There
were
no
comments
on
this
option
other
than
those
in
favor
and
in
opposition
as
outlined
below.

Comments
in
Favor:
 
One
industry
trade
group
representative
indicated
their
strong
favor
for
this
option,
in
particular
higher
reporting
threshold
for
small
businesses.

Comments
Opposed:
 
One
environmental
group
representative
indicated
their
strong
opposition
to
this
option,
stating
that
a
small
business
does
not
mean
a
small
or
insignificant
release.

Option
2
(
Higher
Reporting
Thresholds
for
a
Category
of
Facilities
or
a
Class
of
Chemicals
with
Small
Reportable
Amounts):

General
Comments:

 
Aside
from
the
comment
on
petroleum
bulk
stations
below,
it
was
indicated
by
one
commenter
that
research
on
the
TRI
data
did
not
identify
any
good
candidate
sectors
for
this
option.
 
There
was
discussion
on
different
reporting
requirements,
such
as
threshold,
for
different
TRI
chemicals.
Comments
included:
o
EPA
reported
that
there
has
been
an
on­
going
review
of
TRI
chemicals
in
light
of
the
criteria
set
forth
for
TRI
chemicals.
All
chemicals
evaluated
to
date
meet
the
criteria.
EPA
further
indicated
that
resources
go
towards
evaluating
and
responding
to
petitions
to
de­
list
chemicals
from
TRI.
o
There
was
a
comment
that
copper
is
only
toxic
in
the
ionic
form,
but
that
current
reporting
combines
quantities
of
the
elemental
metal
together
with
copper
present
as
a
copper
compound.
It
was
noted
that
a
previous
petition
to
de­
list
copper
was
denied
by
EPA.
7
o
There
was
a
suggestion
that
toxicity
equivalencies
(
TEQs)
be
used
for
metals.
o
There
was
a
comment
that
there
is
no
differentiation
between
chemicals
with
varying
levels
of
toxicity
in
TRI
reporting
requirements.
A
response
to
this
comment
indicated
that
it
is
extremely
difficult
to
assign
comparative
toxicity
levels
because
of
the
need
to
rank
or
compare
different
toxic
effects
such
as
cancer
versus
birth
defects.

Comments
in
Favor:
 
One
commenter
indicated
that
petroleum
bulk
stations
contribute
to
less
than
onetenth
of
one
percent
of
total
TRI
releases,
and
this
means
this
sector
shoulders
a
disproportionate
share
of
reporting
burden.

Comments
Opposed:
There
were
no
comments
in
strong
opposition
to
this
option.

Option
3
(
Expanding
Eligibility
for
the
Form
A
Certification
Statement):

General
Comments:
 
It
was
reported
out
by
EPA
and
others
present
that
the
Form
A
Certification
is
widely
underused,
even
when
the
Form
A
Certification
eligibility
has
been
met.
A
comment
in
response
indicated
that
liability
concerns
prevent
some
facilities
from
using
the
Form
A
due
to
fear
that
they
will
make
an
error
in
determining
eligibility,
and
will
be
at
risk
for
an
enforcement
action
for
non­
reporting
(
i.
e.,
submitting
a
Form
A
when
a
Form
R
was
required).
One
commenter
suggested
that
there
be
equal
enforcement
for
an
error
in
determining
Form
A
eligibility
and
a
calculation
error
on
a
Form
R.

Comments
in
Favor:
There
were
no
comments
in
strong
support
of
this
option.

Comments
Opposed:
There
were
no
comments
in
strong
opposition
to
this
option.

Option
4
(
Creating
a
New,
"
No
Significant
Change"
Certification
Statement):

General
Comments:
 
EPA
indicated
that
data
analysis
for
this
option
has
focused
on
identifying
the
most
appropriate
proxy
or
metric
for
use
in
determining
"
No
Significant
Change"
(
NSC)
that
would
not
require
full
calculation
of
release
and
other
waste
8
management
quantities.
Questions
were
posed
regarding
what
correlational
analyses
have
been
conducted
by
EPA.
EPA
responded
that:
o
Production
ratio
has
been
correlated
with
total
releases
and
also
production
related
waste.
o
All
on­
site
versus
off­
site
releases
have
been
examined,
as
well
as
looking
at
combined
on­
and
off­
site
releases
by
specific
media.
o
Production
related
waste
has
been
correlated
with
recycling
plus
energy
recovery
versus
treatment
plus
disposal.
 
EPA
indicated
that
the
data
loss
from
the
No
Significant
Change
(
NSC)
option
will
be
mitigated
if
the
parameter
selected
for
NSC
determination
serves
as
a
good
proxy
for
related
data
fields.
o
Several
proxy
ideas
were
put
forth:


Use
section
8.1,
total
releases.
One
commenter
suggested
that
this
parameter
should
only
be
used
if
the
facility
can
state
that
there
were
no
changes
to
waste
management
techniques
used.


Use
the
sum
of
sections
8.1
 
8.7
(
total
production­
related
waste).
It
was
suggested
by
one
commenter
that
this
could
be
effectively
used
for
correlational
analysis,
but
should
not
be
used
for
NSC
determination.


Use
the
production
ratio.


Use
a
re­
defined
production
ratio
(
that
more
closely
corresponds
with
waste
generation
versus
simply
production
level).


Give
a
choice
of
the
above
parameters
for
use
as
the
proxy.


Use
a
combination
of
multiple
parameters
as
the
proxy.


Use
a
qualitative
determination,
such
as
"
there
was
no
change
in
the
process
at
the
facility."
 
The
following
parameters
were
suggested
by
one
commenter
if
this
option
is
used:
o
Begin
with
allowing
a
baseline
to
three­
year
period
for
allowed
use
of
this
option,
then
increase
this
to
five
years.
o
Use
five
percent
as
the
standard
for
"
No
Significant
Change."
o
Use
a
production­
ratio
type
metric,
but
ensure
that
it
is
strongly
correlated
with
generation
of
wastes.
o
Do
not
allow
this
option
for
PBT
chemicals.
 
Another
commenter
suggested
using
a
five
percent
change
to
total
releases
(
8.1)
in
combination
with
a
higher
percentage
allowance
for
changes
in
where
the
material
is
going
(
i.
e.,
to
which
media).
Relative
to
this
comment,
it
was
asked
which
matters
more,
on­
site
versus
off­
site
or
to
which
media
the
waste
is
released.
EPA
indicated
that
media
was
more
important
than
on­
site
versus
offsite
 
EPA
indicated
that
the
current
definition
for
production
ratio
is
more
closely
correlated
with
production
of
product
versus
generation
of
wastes.
It
was
suggested
that
it
may
be
useful
to
modify
the
definition
of
production
ratio
such
that
it
does
more
closely
correspond
with
waste
generation,
and
then
use
this
as
the
metric
for
the
"
No
Significant
Change"
(
NSC)
option.
9
 
One
commenter
suggested
a
"
Form
NSC
De
Minimis"
for
facilities
with
less
than
five
pounds
of
total
on­
site
releases
in
combination
with
less
than
a
20
percent
change
in
total
releases.

Comments
in
Favor:
 
Two
industry
trade
group
representatives
indicated
their
strong
favor
for
this
option.
 
A
suggestion
was
put
forth
that
using
the
NSC
option
in
combination
with
an
enhanced
Form
A
would
provide
effective
burden
reduction
for
the
greatest
number
of
facilities.
This
commenter
indicated
that
the
enhanced
Form
A
should
include
extended
eligibility,
plus
providing
some
release
and
other
waste
management
quantities
through
use
of
range
codes.

Comments
Opposed:
 
A
cautionary
comment
was
put
forth
that
there
should
be
a
determination
as
to
the
accuracy
of
the
baseline
information
before
an
NSC
option
is
implemented.
It
was
suggested
that
monitoring
may
be
needed
to
replace
or
confirm
use
of
existing
published
emission
factors,
as
there
was
a
study
indicating
that
air
releases
may
be
underreported
with
use
of
emission
factors.

Option
5
(
Use
of
Range
Reporting
for
Section
8
of
the
Form
R):

There
were
no
comments
put
forth
specific
to
this
option.
There
was
a
great
deal
of
discussion
on
use
of
range
codes
in
general
as
outlined
beginning
on
page
three
of
this
document
in
the
"
General
Comments"
section.

New
Proposals
for
Burden
Reduction:

 
A
suggestion
was
put
forth
to
have
the
TRI­
ME
software
automatically
make
the
calculations
for
quantities
reported
in
sub­
sections
of
Sections
5
and
6
of
the
Form
R
that
are
totaled
up
for
certain
sub­
sections
of
Section
8
of
the
Form
R.
 
A
suggestion
was
put
forth
to
eliminate
Form
R
data
element
Part
I,
Section
4.7,
Dun
and
Bradstreet
number.
A
related
suggestion
was
to
replace
use
of
the
parent
company
Dun
and
Bradstreet
number
in
Part
I,
Section
5.1,
with
the
tax
identification
number,
which
was
considered
easier
to
locate.
 
An
alternate
reporting
year
option
was
mentioned.
EPA
responded
that
they
have
heard
from
facilities
that
biennial
data
collection
is
actually
more
complex
than
annual
tracking,
and
that
the
no
significant
change
option
was
considered
a
better
but
comparable
replacement
for
the
alternate
reporting
year
option.
 
A
suggestion
was
put
forth
to
reinstate
the
de
minimis
exemption
for
lead
(
note
that
the
de
minimis
exemption
currently
applies
to
lead
contained
in
stainless
steel,
brass,
or
bronze
alloys)
and
also
for
all
PBTs.
 
A
suggestion
was
put
forth
to
make
lead
a
non­
PBT.
This
commenter
indicated
that
several
of
his
facilities
began
reporting
when
lead
was
designated
as
a
PBT,
and
these
facilities
are
typically
zero
release
reporters.
10
 
A
suggestion
was
put
forth
to
eliminate
duplicate
reporting
of
releases
and
other
waste
management
quantities
by
facilities
generating
wastes
and
also
by
the
receiving
facilities
that
dispose
of
or
otherwise
manage
these
wastes.
 
A
suggestion
was
put
forth
to
mandate
use
of
the
TRI­
ME
software.
The
commenter
indicated
that
this
would
decrease
burden
and
increase
data
quality.
It
was
discussed
that
a
waiver
provision
would
be
needed
for
facilities
that
may
not
have
computers.
Furthering
this
suggestion
was
the
comment
that
one
or
more
of
the
burden
reduction
options
could
be
implemented
coupled
with
a
requirement
for
electronic
submission.
Another
commenter
indicated
that
electronic
submission
is
slow
and
difficult
with
a
dial­
up
modem.
EPA
noted
that
the
regions
will
be
making
a
significant
effort
this
year
to
reach
out
to
facilities
that
use
TRI­
ME,
but
still
report
via
paper
or
diskette,
and
encourage
electronic
reporting
via
CDX.
 
A
suggestion
was
put
forth
to
eliminate
zero
release
reports.
 
A
suggestion
was
put
forth
to
enhance
the
quality
and
distribution
of
EPA
TRI
guidance
documents.
 
A
suggestion
was
put
forth
to
eliminate
the
requirement
to
consider
non­
isolated
intermediates
towards
the
manufacturing
threshold.
 
A
suggestion
was
put
forth
to
use
toxicity
equivalencies
(
TEQs)
for
dioxin
reporting.
As
noted
above
under
General
Comments,
this
is
currently
in
process
at
EPA.
 
A
suggestion
was
put
forth
to
present
TRI
data
in
greater
context.
As
noted
above
under
General
Comments,
this
is
currently
in
process
at
EPA.
