ASTSWMO Materials Management Subcommittee Comments on 2020 EPA Draft National Recycling Strategy

The Materials Management Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments on EPA’s Draft National Recycling Strategy and the new U.S. National Recycling Goal to increase the national recycling rate to 50 percent by 2030. The following comments are from the Subcommittee and have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial (State) programs may also provide comments based on their own State perspectives and experiences.

2020 SMM Task Force Comments on EPA’s National Recycling Goals

Members of the Sustainable Materials Management (SMM) Task Force within the Materials Management Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) have been participants in EPA’s America Recycles Day efforts to create the National Framework for Advancing the U.S. Recycling System. We understand the difficulty of establishing a national set of recycling goals and appreciate the continued efforts to further enhance the nation’s recycling system. We are pleased to continue working with EPA to address the challenges in the country’s recycling system.

ASTSWMO Comments to Nuclear Regulatory Commission Proposed Interpretative Rule

The Materials Management and Hazardous Waste Subcommittees of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciate the opportunity to jointly provide comments on the U.S. Nuclear Regulatory Commission’s (NRC’s) Proposed Interpretive Rule, Transfer of Very Low-Level Waste to Exempt Persons for Disposal NRC-2020-0065, published in the Federal Register on March 6, 2020 (85 FR 45). These comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial radiological, solid waste, and hazardous waste programs may also provide comments based on their own perspectives and experiences.

ASTSWMO Solid Waste Disposal and Conversion Task Force Comments Proposed to Federal CCR Permit Program

The Solid Waste Disposal and Conversion Task Force within the Materials Management Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments on the U.S. Environmental Protection Agency (EPA) proposed rule, Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals From Electric Utilities; Federal CCR Permit Program, published in the Federal Register on February 20, 2020 (85 FR 9940). These comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial solid waste programs may also provide comments based on their own perspectives and experiences.

Draft Interim Recommendations for Addressing Groundwater Contaminated with PFOA and PFOS

The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments on the U.S. Environmental Protection Agency’s (EPA’s) Draft Interim Recommendations for Addressing Groundwater Contaminated with PFOA and PFOS. ASTSWMO is an association representing the waste management and remediation programs of the 50 U.S. States, five Territories, and the District of Columbia (States). These comments are being submitted by ASTSWMO’s PFAS Workgroup, which includes representatives from ASTSWMO’s Board of Directors and program Subcommittees. These comments have not been reviewed or adopted by the ASTSWMO Board of Directors.

State environmental associations respond to EPA’s PFAS Action Plan April 2019

We appreciate the U.S. Environmental Protection Agency’s (EPA’s) development of its Per-and Polyfluoroalkyl Substances (PFAS) Action Plan in response to the feedback EPA received during the May 2018 PFAS National Leadership Summit and other public engagements. The Action Plan demonstrates EPA’s acknowledgment of the several challenges States, Interstates and Territories (States) are facing related to PFAS.

ASTSWMO Comments on EPA Strategic Plan

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 programs of the 50 States, five Territories and the District of Columbia (States).

ASTSWMO Comments on Proposed CERCLA 108(b) Rule

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 the Hardrock Mining Industry (the proposed rule), published in the Federal Register on January 11, 2017.

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

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 (80 FR 70180). These comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial solid waste programs may also provide comments based on their own perspectives and experiences.