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TRI dioxin

  fyi, the 3rd p'graph of the letter is a bit of info on the guidelines epa
  is supposed to follow in deciding reporting thresholds for TRI, and on how
  facilities employ the reporting threshold.  -tony
  Docket Control # OPPTS - 400111         TRI Listing & Threshold for Dioxins
  4 Sept. '97
  Dear OPPT Docket:
  EPA should analyze for dioxins (as pcdd/f and indiv. congeners) the
  enclosed three soil samples (taken near known sources of dioxin emissions
  to the air in my town, see appendix below) and similar ones it receives for
  this docket control #.  It is likely the concentrations will be higher than
  typical background levels of 2-20 ppt TEq (typical rural to urban levels).
  That these compound are repeatedly documented toxins at levels to which
  many of us have already accumulated in our bodies, and that background and
  elevated environmental concentrations have led to this dangerous situation,
  urgently speaks to the need for the public's right-to-know about sources
  and levels of dioxins emissions.
  I.e., the TRI reporting threshold should be zero.  This will be easier for
  facilities to estimate, they won't have to go through the complicated
  calculations to determine if they meet a threshold.  Failing that, EPA is
  required to set the reporting threshold based on the risk and environmental
  levels of this family of toxins.
  Tony Tweedale
  tony tweedale