ASTSWMO Publications

Position Papers

ASTSWMO 128(a) Position Paper

(5/17/2017) - On January 11, 2002, President Bush signed the Small Business Liability Relief and Brownfields Revitalization Act (Pub.L.No. 107-118, 115 stat. 2356, "the Brownfields Law"). The Brownfields Law amended the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) by ... Read More

Cathode Ray Tubes (CRT) Management Position Paper

(4/17/2017) - Due to the fast-paced changes in technology and consumer interest in buying new electronic products, many States are seeing an increase in the amount of older electronic items being discarded. Monitors and televisions with cathode ray tube (CRT) technology are ... Read More

ASTSWMO Position Paper on Performance-Based Contracting at Federal Facilities

(3/17/2017) - Performance-based contracting (PBC) is frequently used for implementing environmental cleanup work at federal facilities under the Defense Environmental Restoration Program (DERP). The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) has produced two white papers on the subject: ... Read More

ASTSWMO Position on Advanced Geophysical Classification for Munitions Response

(1/17/2017) - The Department of Defense (DoD) developed the advanced geophysical classification for munitions response process (hereafter referred to as advanced geophysical classification, or AGC) to improve the efficiency and effectiveness of munitions cleanup.1 AGC represents a major change in how munitions ... Read More

ASTSWMO Position Paper on RCRA Subtitle C Hazardous Waste Program Information and RCRAInfo Database Operation and Maintenance

(10/17/2016) - Since the enactment of the Resource Conservation and Recovery Act (RCRA) in 1976 and subsequent amendments, the U.S. Environmental Protection Agency (EPA) has developed and maintained several information systems. These evolving information management systems are necessary for tracking and maintaining ... Read More

ASTSWMO Position Paper on Federal Regulation of Coal Combustion Residuals

(10/17/2016) - On April 17, 2015, the U.S. Environmental Protection Agency (EPA) published the final rule, Hazardous and Solid Waste Management System; Disposal of Coal Combustion Residuals From Electric Utilities (80 FR 21301). This Position Paper is a brief update from ASTSWMO ... Read More

ASTSWMO Policy Position on UST Open Bermed Containment Systems

(7/17/2016) - This position paper addresses open bermed containment systems that are used to meet the spill prevention equipment requirements for underground storage tanks (USTs) outlined in 40 CFR 280.20(c). Bermed containment systems are configured with small concrete berms or curbing that ... Read More

ASTSWMO Position Paper on Coal Combustion Residuals

(7/20/2014) - On June 21, 2010, the U.S. Environmental Protection Agency (EPA) proposed the rule, Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities (75 FR 35127). In this rulemaking, EPA ... Read More

ASTSWMO Position Paper on Site Assessment Funding

(5/20/2014) - Traditionally, the CERCLA Site Assessment program was considered simply a part of the Superfund Remedial Process, intended to identify and qualify sites for listing on the National Priorities List (NPL). If viewed in that limited context, funding the Site Assessment ... Read More

ASTSWMO Position Paper on 128(a) Funding

(5/9/2014) - On January 11, 2002, President Bush signed the Small Business Liability Relief and Brownfields Revitalization Act (Pub.L.No. 107-118, 115 stat. 2356, "the Brownfields Law"). The Brownfields Law amended the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) by ... Read More

ASTSWMO Policy Position Paper on Federal Facilities

(10/20/2013) - Environmental compliance and remediation at active, closed, and transferred federal facilities continues to be one of the most complex and controversial issues in State-federal relationships. The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) has consistently supported individual ... Read More

ASTSWMO Position Paper on e-Manifest Funding

(10/15/2013) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) strongly supports the development of the e-Manifest system that is currently underway. We and our member States, Territories and the District of Columbia (States) have supported this system since ... Read More

ASTSWMO Subtitle D Post-Closure Position Paper

(7/16/2013) - Regulations promulgated approximately twenty years ago by individual States under the authority of Subtitle D of the Resource Conservation and Recovery Act (RCRA) include provisions regarding the post-closure care of municipal solid waste (MSW) landfills. The Subtitle D regulations establish ... Read More

ASTSWMO Position Paper: A New Regulatory Approach to Pharmaceutical Waste Management

(4/15/2013) - Many studies have demonstrated that pharmaceutical compounds are making their way into the environment. Although little can be done to prevent some pharmaceuticals from reaching environmental receptors, the destiny of waste pharmaceuticals can be controlled. The Association of State and ... Read More

ASTSWMO Position Paper on the Importance of Community Involvement

(7/20/2012) - The history of community involvement in the environmental field has been one of staggered improvement across the nation. The process, priority, and status of community involvement differs significantly not only from each of the 50 States and six Territories, but ... Read More

ASTSWMO Request for Extension of the Comment Period of the Proposed Rule Hazardous and Solid Waste Management Systems; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals from Electric Utilities

(8/20/2010) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) respectfully requests a 120 day extension of the comment period for EPA's proposed rulemaking for the Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes: Disposal ... Read More

Comment Letters

The comments on this page were made on behalf of the entire Association. For program-specific comment letters, please visit the program’s publications page.

ASTSWMO Comments on EPA Strategic Plan

(10/31/2017) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Board of Directors appreciates the opportunity to provide the enclosed comments on the Draft FY 2018-2022 EPA Strategic Plan. ASTSWMO is an association representing the waste management and remediation ... Read More

ASTSWMO Comments on Proposed CERCLA 108(b) Rule

(7/10/2017) - On behalf of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO), I would like to submit the following comments and concerns on the proposed rule for Financial Responsibility Requirements Under CERCLA §108(b) for Classes of Facilities in ... Read More

Comments on the Proposed Revision to the RD&D Permits Rule for MSW Landfills

(12/16/2015) - ASTSWMO appreciates the opportunity to provide comments on the U.S. Environmental Protection Agency (EPA) proposed rule, Revision to the Research, Development and Demonstration (RD&D) Permits Rule for Municipal Solid Waste Landfills, published in the Federal Register on November 13, 2015 ... Read More

The ASTSWMO letter to the House Armed Services Committtee regarding the FY 2015 budget request for Department of Defense Environmental Restoration Programs.

(5/6/2014) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) respectfully requests that the House Armed Services Committee carefully review and reconsider the Fiscal Year (FY) 2015 budget request for the Department of Defense (DOD) Environmental Restoration Programs.

ASTSWMO Letter to OMB on e-Manifest

(2/6/2014) - The Board of Directors of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) recently adopted the enclosed position paper, "e-Manifest System Development Funding". We wanted to share this position paper with you so that you are aware ... Read More

LUST Task Force and Tanks Subcommittee Comments on the Draft U.S. EPA “Guidance for Addressing Petroleum Vapor Intrusion at Leaking Underground Storage Tank Sites”

(6/17/2013) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Tanks Subcommittee, through the Leaking Underground Storage Tank (LUST) Task Force, is providing the following comments to the April 2013 draft guidance titled, “Guidance for Addressing Petroleum Vapor Intrusion ... Read More

ASTSWMO Comments on Plan EJ 2014: Considering EJ in EPA’s Permitting Process

(8/24/2012) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) is providing the following comments to the U.S. Environmental Protection Agency regarding “EPA Activities to Promote Environmental Justice in the Permit Application Process” (77 FR 38051), published in the ... Read More

ASTSWMO letter to U.S. Nuclear Regulatory Commission in response to the Commission’s denial of ASTSWMO’s 2009 petition for rulemaking on tritium exit signs

(8/2/2012) - Thank you for your response dated December 2, 2011, to the petition for rulemaking (PRM) submitted to the U.S. Nuclear Regulatory Commission (NRC) in December 2009 by the Association of State and Territorial Solid Waste Management Officials (ASTSWMO). We are ... Read More

ASTSWMO letter to the Senate Appropriations Committee, Subcommittee on Defense regarding FY 2013 Formerly Used Defense Sites Budget Request

(5/21/2012) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) respectfully requests that the Senate Appropriations Committee, Subcommittee on Defense carefully review and reconsider the FY 2013 Budget Request for the Department of Defense (DOD) program dedicated to restoring ... Read More

ASTSWMO Comments on U.S. EPA Proposal to Revise UST Regulations

(4/11/2012) - ASTSWMO offers the following comments on U.S Environmental Protection Agency's proposed rule-making for the Underground Storage Tank Regulations, published in the Federal Register on November 18, 2011

Identification of Non-Hazardous Secondary Materials That Are Solid Waste

(2/16/2012) - The Municipal D Waste Task Force within the Materials Management Subcommittee of the Association of State and Tenitorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments regarding the U.S. Environmental Protection Agency's ("EPA") proposed Commercial and Industrial ... Read More

ASTSWMO Comments on the December 9, 2011 Report titled “EPA Must Improve Oversight of State Enforcement”

(12/15/2011) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) has reviewed the December 9, 2011 report titled EPA Must Improve Oversight of State Enforcement (the Report) and is compelled to respond due to what we believe is a ... Read More

Comments on the MSW Characterization Report Docket ID No. EPA-HQ-RCRA-2011-0178

(11/16/2011) - The Municipal Solid Waste (MSW) Recycling Task Force within the Solid Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments in response to the U.S. Environmental Agency's (EPA) request ... Read More

ASTSWMO Comments on the CCR Notice of Data Availability

(11/14/2011) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) has reviewed the December 9, 2011 report titled EPA Must Improve Oversight of State Enforcement (the Report) and is compelled to respond due to what we believe is a ... Read More

ASTSWMO Comments on Definition of Solid Waste Notice Proposed Rule

(10/20/2011) - The Hazardous Waste Recycling and Program Information Management Task Forces (Task Forces) of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Hazardous Waste Subcommittee, have reviewed the July 22, 2011 Proposed Rule concerning potential revisions to the ... Read More

The Hazardous Waste and Solid Waste Subcommittees provide input on the RCRA Messaging initiative.

(10/15/2011) - The Hazardous Waste and Solid Waste Subcommittees of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciate your invitation to  provide input on the "RCRA Messaging" initiative. In this letter, we offer our perspectives on this initiative ... Read More

The Hazardous Waste Recycling and Program Information Management Task Forces comment on the Definition of Solid Waste Notice Proposed Rule (76 FR 44094)

(10/15/2011) - The Hazardous Waste Recycling and Program Information Management Task Forces (Task Forces) of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Hazardous Waste Subcommittee, have reviewed the July 22, 2011 Proposed Rule concerning potential revisions to the ... Read More

ASTSWMO Comments on the MSW Characterization Report

(9/30/2011) - The Municipal Solid Waste (MSW) Recycling Task Force within the Solid Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments in response to the U.S. Environmental Agency's (EPA) request ... Read More

Comments on the MSW Characterization Report Docket ID No. EPA-HQ-RCRA-2011-0178

(9/17/2011) - The Municipal Solid Waste (MSW) Recycling Task Force within the Solid Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments in response to the U.S. Environmental Agency's (EPA) request ... Read More

The Subcommittee requests a 60-day extension of the comment period for the Environmental Protection Agency’s (EPA) supplemental proposal to revise the definition of solid waste (DSW) rule

(8/15/2011) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Hazardous Waste Subcommittee respectfully requests a 60-day extension of the comment period for the Environmental Protection Agency’s (EPA) supplemental proposal to revise the definition of solid waste (DSW) rule. ... Read More

ASTSWMO Comments on U.S. EPA’s upcoming proposal for regulations promulgated under §108(b) of CERCLA

(5/20/2011) - On behalf of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO), I would like to thank you for the time you and your staff have invested in considering our concerns on EPA’s upcoming proposal for regulations promulgated ... Read More

ASTSWMO Comments on U.S. EPA’s Plan EJ 2014

(4/29/2011) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) is providing the following comments to the 10 Dockets referenced above regarding the U.S. Environmental Protection Agency’s (EPA’s) Plan EJ 2014 draft implementation plans. In addition, specifics comments to ... Read More

ASTSWMO Comments on Potential Addition of Vapor Intrusion (VI) Component to Hazard Ranking System

(4/15/2011) - ASTSWMO is forwarding the attached comments to U.S. Environmental Protection Agency's Potential Addition of Vapor Intrusion Component to the Hazard Ranking System, Published by the Federal Register on January 31, 2011.

Identification of Non-Hazardous Secondary Materials That Are Solid Waste

(8/17/2010) - ASTSWMO appreciates the opportunity to provide comments on the proposed rule, Identification of Non-Hazardous Secondary Materials That Are Solid Waste, published in the Federal Register on June 4, 2010 (75 FR 3 1844). These comments have not been reviewed or ... Read More

Final Performance Systems Survey, Developed by the Performance Systems Task Force

(4/15/2010) - The Performance Systems Task Force of the Hazardous Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) has engaged in activities to coordinate States’ efforts in identifying opportunities for facility specific flexibility under the RCRA ... Read More

ASTSWMO Comments on its partnership with the Department of Defense

(9/8/2006) - It has come to the attention of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) that questions have been raised about the nature of our association and the work our members do, particularly in relation to the ... Read More

ASTSWMO Comments on the Proposed Rule, Revisions to the Definition of Solid Waste

(2/27/2004) - The Board of Directors of the Association of State and Territorial Solid Waste Management Officials (herein referred to as “ASTSWMO”) has reviewed the October 28, 2003 proposed rule (68 FR 61558) containing suggested revisions to the definition of solid waste. ... Read More

Newsletter

The ASTSWMO Newsletter is distributed to members via email and posted to this page once every quarter. To receive the newsletter by email, please contact TJ Gannon, ASTSWMO Information Technology Specialist, at (202) 640-1065 or timothyg@astswmo.org.

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