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.
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.
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.
Comments by the ASTSWMO Tanks Subcommittee regarding US EPA’s Proposed Rule for E15 Fuel Dispenser Labeling and Compatibility with Underground Storage Tanks (86 FR 5094) provided to EPA on April 15, 2021.
Comments by the ASTSWMO Sustainable Materials Management (SMM) Task Force regarding EPA’s measurement methodology for increasing the national recycling rate to 50% by 2030, provided to EPA on March 8, 2021.
The ASTSWMO Hazardous Waste Subcommittee provided comments to the EPA Hazardous Waste Electronic System (“e-Manifest”) Advisory Board for the Board’s public meeting on March 2-4, 2021, on the meeting theme, “Looking Ahead: Setting E-Manifest Program Priorities and User Fees for FY2022 and FY2023.”
On February 19, 2021, the ASTSWMO CEC Steering Committee submitted comments to EPA on their Interim PFAS Destruction and Disposal Guidance. Visit Docket EPA-HQ-OLEM-2020-0527 on Regulations.gov to review the interim guidance document and other supporting materials and public comments.
The Solid Waste Disposal and Conversion Task Force of ASTSWMO’s Materials Management Subcommittee submitted comments to EPA on February 11, 2021 regarding the Advance Notice of Proposed Rulemaking (ANPRM) for Coal Combustion Residuals (CCR) Legacy Surface Impoundments.
Compliance Monitoring and Enforcement Task Force within the ASTSWMO Hazardous Waste Subcommittee provided feedback regarding the fiscal year performance data that the U.S. Environmental Protection Agency (EPA) proposed to use in conducting State Review Framework (SRF) reviews in FY2021.
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.