ASTSWMO Comment Letter to EPA’s Proposed Rule to Designate PFOA and PFOS as CERCLA Hazardous Substances

The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments regarding the U.S. Environmental Protection Agency’s (EPA) Proposed Rule, Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Hazardous Substances.

2021 CME Task Force Comments on Draft RCRA Air Emissions Memo

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.

ASTSWMO COMMENTS on EPA’s Draft FY 2022 – 2026 EPA Strategic Plan

The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) is an association representing the waste management and remediation programs of the 50 States, five Territories and the District of Columbia (States). The ASTSWMO Board of Directors appreciates the opportunity to comment on the Draft FY 2022-2026 U.S. Environmental Protection Agency (EPA) Strategic Plan.
Overall, the ASTSWMO Board of Directors is encouraged with the EPA plan, which is in line with many of our Association’s goals. Specifically, EPA’s Draft Strategic Plan, Goal 6: Safeguard and Revitalize Communities, aligns with ASTSWMO’s mission. The need to protect communities and improve the livelihood of all Americans is at the heart of our work. We applaud continued partnerships and collaborative goal setting. We offer the following general and specific comments.

ACWA, ASDWA, ASTSWMO & ECOS Joint Comment Letter to EPA on CWA Effluent Limitations Guidelines and Standards: OCPSF Point Source Category Proposed Rulemaking

ASTSWMO joined ACWA, ASDWA and ECOS in submitting a joint comment letter to EPA on its proposed rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards (EPA-HQ-OW-2020-0582) relating to the effluent limitations guidelines, pretreatment standards and new source performance standards applicable to the Organic Chemicals, Plastics and Synthetic Fibers (OCPSF) point source category to address discharges from manufacturers of PFAS.