2021 CME Task Force Comments on Draft RCRA Air Emissions Memo

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The Compliance Monitoring and Enforcement (CME) Task Force within the Hazardous Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to comment on the draft memorandum, “Applicability of Resource Conservation and Recovery Act (RCRA) Organic Air Emission Standards to Equipment and/or Closure Devices, Subpart BB versus Subpart CC”, from the Director of the Office of Resource Conservation and Recovery (ORCR) within the U.S. Environmental Protection Agency (EPA). The Task Force received the draft memorandum that was circulated via e-mail on August 4, 2021, for a 60-day public comment period. These Task Force comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition to these comments, individual State or Territorial hazardous waste programs may provide input directly to EPA based on their own perspectives and experiences.