                           Summary of Conversation 
Environmental Protection Agency (EPA) and the American Petroleum Institute (API)
                                August 17, 2017

David Turk (EPA) spoke with Timothy Steffek (API) on August 17, 2017 to discuss further API's comment on renewal of the Environmental Protection Agency ICR entitled: ``Toxic Chemical Release Reporting and Renewals of Form R, Form A, and Form R Schedule 1'' and identified by EPA ICR No. 1363.26 and OMB Control No. 2025 - 0009 (Docket ID: EPA-HQ-TRI-2017-0057, Document ID for API's comment: EPA-HQ-TRI-2017-0057-0015).  

The discussion focused on API's comment on three proposed changes in the proposed ICR renewal: 

 Including optional information textbox on Form A Certification Statement, 
 Indicating whether an air release contains chromium-VI (hexavalent chromium), and 
 Separating Section 8.8 into separate boxes for quantities associated with (1) remedial actions, (2) catastrophic events, and (3) one-time events not associated with production processes.

Including optional information textbox on Form A Certification Statement

      API reiterated the concern that optional information could be viewed as required in various contexts, and expressed a general preference for strictly delineated data elements than open text fields.

Indicating whether an air release contains chromium-VI (hexavalent chromium)

      API indicated that it would be burdensome and difficult for facilities to separate out quantities of air releases containing hexavalent chromium using currently available data being used and expressed a strong concern about the ability to report accurately were this element were it to be required. 

Separating Section 8.8 into separate boxes for quantities associated with (1) remedial actions, (2) catastrophic events, and (3) one-time events not associated with production processes

      API indicated that reporting required under other regulatory requirements (e.g., reporting to the National Response Center) might not be triggered by applicable regulatory requirements and that separating TRI reporting of Section 8.8 into the three categories proposed could create the inaccurate appearance that these other applicable regulatory requirements are not being met. 
