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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.