Identification of Non-Hazardous Secondary Materials That Are Solid Waste

The Municipal D Waste Task Force within the Materials Management Subcommittee of the Association of State and Tenitorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments regarding the U.S. Environmental Protection Agency’s (“EPA”) proposed Commercial and Industrial Solid Waste Incineration Units.

Reconsideration and Proposed Amendments: Non-Hazardous Secondary Materials That Are Solid Waste (cumulatively called the “CISWI Reconsideration,” 76 FR 80452, December 23, 2011).

The Hazardous Waste and Solid Waste Subcommittees provide input on the RCRA Messaging initiative.

The Hazardous Waste and Solid Waste Subcommittees of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciate your invitation to  provide input on the “RCRA Messaging” initiative. In this letter, we offer our perspectives on this initiative and the value of the RCRA Subtitle C and D programs as well as additional State and Territorial (State) programs and their continuing accomplishments. At their heart, the Resource Conservation and Recovery Act and equivalent State programs are pollution prevention and resource conservation programs. This is truer now than when RCRA first became law, as evidenced by substantial reductions in the amount of hazardous waste generated across the nation and shifts towards use of less-toxic, more environmentally friendly materials in manufacturing and production operations. We believe this fundamental shift in thinking was brought about by RCRA and its implementing regulations.

State RCRA Subtitle C Core Hazardous Waste Management Program Implementation Costs

At the direction of the ASTSWMO Board of Directors, the ASTSWMO Hazardous Waste Subcommittee has evaluated the RCRA Subtitle C Program (hereafter referred to as “RCRA C” or “RCRA” in this report) administered by States to determine the nature and costs of implementing a complete and adequate Program. As a part of this effort, the Subcommittee and its Task Forces have identified the major components of the RCRA C Core Program, established a consistent methodology for collecting program implementation cost information, and collected detailed cost information from ten States as a pilot study to estimate the national cost of implementing the RCRA C Core Program. The RCRA C Core Program consists of permitting, remediation (closure, corrective action), compliance, enforcement, and program development activities.