Comments on the Proposed Management Standards for Hazardous Waste Pharmaceuticals

The Compliance Monitoring and Enforcement Task Force within the Hazardous Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments on the proposed rule, Management Standards for Hazardous Waste Pharmaceuticals, published in the Federal Register on September 25, 2015 (80 FR 58013). These comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial hazardous waste programs may also provide comments based on their own State perspectives and experiences.

Comments on the Proposed Hazardous Waste Generator Improvements Rule

The Compliance Monitoring and Enforcement Task Force within the Hazardous Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments on the proposed rule, Hazardous Waste Generator Improvements, published in the Federal Register on September 25, 2015 (80 FR 57917). These comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial hazardous waste programs may also provide comments based on their own State perspectives and experiences.

Perfluorinated Chemicals (PFCs): PFOA & PFOS Information Paper

ASTSWMO prepared this paper to provide our members with information on perfluorinated chemicals (PFCs), which are emerging contaminants of concern. This document focuses on two specific PFCs – perfluorooctanioc acid (PFOA) and perfluorooctane sulfonate (PFOS) – and contains introductory information and resources on its historical and current uses, effects on human health and the environment, and current State and federal guidelines for investigation and remediation.

ASTSWMO Hazardous Waste Subcommittee Members in Action Fact Sheet

In fulfillment of one of its tasks in its Strategic Plan Work Plan, the Hazardous Waste Subcommittee developed a one-page fact sheet that summarizes what it means to be a member of the Subcommittee and its Task Forces. The fact sheet is based on ASTSWMO’s Members in Action Guidance Document, and it includes the link to the document.

State Approaches to Managing Institutional Controls and Ensuring Long-Term Protectiveness at LUST Sites

The document is the result of recent discussions at ASTSWMO meetings and an information request sent to all States, Territories, and the District of Columbia (States) that focused on how State tanks programs manage institutional controls and ensure long-term protectiveness of remedies at LUST sites. Included in the report are policies, tools, and practices from the 35 States that responded to the request for information, and brief summaries where applicable.

Uniform Environmental Covenants Act: Implementation at Federal Facilities

ASTSWMO developed this report to evaluate how the Uniform Environmental Covenants Act (UECA) is being used at federal facilities. This document provides an introduction to LUCs and the UECA; a summary of State-specific regulations and policies specific to UECA and LUCs; an analysis of information provided by States concerning the use of UECA and LUCs at federal facilities; and offers recommendations for States. Case studies from States that use alternative statutes for LUCs are also provided.

State Regulations and Policies for Control of Naturally-Occurring and Accelerator Produced Radioactive Materials (NARM) and Technologically Enhanced Naturally-Occurring Radioactive Materials (TENORM)

Between 2011 and 2012, the Association of State and Territorial Solid Waste Management Officials’ (ASTSWMO’s) Radiation Focus Group developed three reference documents on naturally-occurring, radioactive materials (NORM). The first, Incidental TENORM: A Guidance for State Solid Waste Managers (April 2011), provides information to inform solid waste managers about technologicallyenhanced, naturally-occurring, radioactive materials (TENORM), including an introduction to these materials, toxicity, waste generation, and disposal. This guidance document was followed up by the release of two fact sheets: TENORM Associated with Drinking Water Treatment (May 2011) and TENORM Associated with Shale Gas Operations (July 2012).

Product Stewardship Program Evaluation Tool

This tool was developed as a follow-up piece to the ASTSWMO Product Stewardship Framework Policy document, which is described in a subsequent section. As noted in the policy document, under a framework approach, States can define the product stewardship program structure, set criteria for selecting products and then add products to the stewardship program either by regulation or legislative authorization. Therefore, the State programs that are the focus of this guidance are those that have been created by regulation and/or legislation, and as such include data requirements. Voluntary State product stewardship programs are outside of the scope of the tool, though those programs may be able to use some of the concepts.

Lead Scavengers Survey Report

In 2013, the Tanks Subcommittee’s LUST Task Force requested information from all States and Territories to determine what activites the tanks programs are taking to identify and remediate the lead scavengers 1,2-dibromoethane (EDB) and 1,2-dichloroethane (1,2 DCA). Thirty-five States responded and the Task Force found that there continues to be great variation from State to State on how lead scavenger issues are addressed, which is summarized in this report.