Coalition for Responsible Waste Incineration

CRWI Comments on Selected Rules

One of CRWI's goals is to provide comments to government regulators and lawmakers on pending regulations and legislation. Below are comments on selected EPA rulemakings that have been filed since 1998. The date at the end of the line refers to the date the comments were submitted, not the Federal Register notice date. For copies of comments on earlier rulemakings, please contact us. Please choose from the following selections:

Boiler Mact

CISWI

OSWRO

Other MACT rules

Startup, shutdown, and malfunction provisions

Regulatory reform

Testing and test methods

RCRA/Solid waste

Miscellaneous

HWC MACT

Comments on the proposed rule to remove the malfunction exceptions - September 24, 2024

Comments on TCEQ's draft CPT report format guidelines - January 9, 2017

Comments on EPA's "legal analysis" - November 27, 2007

Comments on the proposed modifications to the comparable fuels exclusion - September 14, 2007

Comments on second reconsideration notice for the Hazardous Waste Combustor MACT rule - October 23, 2006

Potential corrections to the October 12, 2005, final HWC MACT rule - March 14, 2006

Background paper and slides presented to OMB - August 26, 2005

Comments on the Direct Request for Comments (HWC MACT rule) - February 4, 2005

Cover letter, Comments, and revised Appendix A on the proposed permanent replacement HWC MACT standards - July 6, 2004

Comments to the Office of Management and Budget on the proposed permanent replacement HWC MACT standards - February 3, 2004

HWC MACT Database NODA - August 16, 2002

Public Health Reviews of Hazardous Waste Thermal Treatment Technologies - April 23, 2001

Region 6 Risk Assessment Guidance Document - January 28, 1999

Region 4 Trial Burn Guidance Document - November 24, 1998

Boiler MACT

Comments on the 2020 boiler remand proposed rule - October 23, 2020

Comments and Appendix on the 2015 boiler reconsideration proposed rule - March 9, 2015

Comments and Appendix on the proposed reconsideration of the major source boiler rule - February 20, 2012

Comments and Appendix on the proposed Industrial Boiler and Process Heaters - August 23, 2010

Comments on the reconsideration notice for the industrial boiler MACT rule - August 11, 2005

CISWI

Comments on the 2015 CISWI reconsideration proposed rule -- March 9, 2015

Comments on the proposed reconsideration of the CISWI rule - February 20, 2012

Comments and Appendices on the proposed Commercial and Industrial Solid Waste Incineration Units - August 23, 2010

Commercial and Industrial Solid Waste Incineration Units - January 31, 2000

OSWRO

Comments on the 2017 OSWRO reconsideration proposed rule - September 21, 2017

Comments on the risk and technology review revisions of the Off-Site Waste and Recovery Operations rule - August 29, 2014

Other MACT rules

Comments on the major source reclassification proposed rule - September 24, 2019

Comments on the MATS reconsideration proposed rule - January 7, 2013

Comments on the Portland Cement MACT reconsideration proposed rule - August 17, 2012

Comments and the Appendix, on the proposed EGU MACT rule - August 4, 2011

Comments on the proposed sewage sludge rule and the appendices (Steger paper, Johnson paper, and the EPA paper on analytical detection and quantification levels) - November 29, 2010

Comments on the proposed Portland cement MACT rule - September 4, 2009

Comments on the proposed standards for Hospital/Medical/Infectious Waste Incineration rule - February 17, 2009

General Provisions Proposed Rule - May 22, 2001

Startup, shutdown, and malfunction provisions

Comments on the emergency affirmative defense proposed rule - August 15, 2016

Comments on the affirmative defense provisions of the generic MACT and phenolic resins RTR proposed rule - March 10, 2014

Comments on the affirmative defense provisions of the flexible polyurethane foam production RTR proposed rule - December 4, 2013

Comments on the SSM SIP call proposed rule - May 13, 2013

Comments on the affirmative defense provisions of the gas turbine NSPS proposed rule - December 21, 2012

Comments on the affirmative defense provisions of the secondary aluminum production proposed rule - April 13, 2012

Comments on the affirmative defense provisions for chemical manufacturing area sources - March 30, 2012

Comments on the affirmative defense provisions of the Group IV polymer, Pesticide Active Ingredient, and Polyether production proposed rule - March 9, 2012

Comments on the affirmative defense provisions of the pulp and paper RTR proposed rule - February 27, 2012

Comments on the affirmative defense provisions of the mineral wool production proposed rule - February 3, 2012

Comments on the affirmative defense provisions of the wool fiberglass manufacturers proposed rule - February 3, 2012

Comments on the affirmative defense provisions of the ferroalloy production residual risk and technology proposed rule - January 31, 2012

Comments on the affirmative defense provisions of the New Source Performance Standards Review for nitric acid plants - November 28, 2011

Comments on the Primary Lead Smelting proposed rule - April 19, 2011

Comments on the SSM provisions of the residual risk and technology review for the shipbuilding and wood finishing MACT rules - February 22, 2011

Comments on the SSM provisions of the residual risk and technology review for 6 MACT rules - December 6, 2010

Comments on the proposed changes to the SSM plans in the General Provisions (reconsideration notice) - September 12, 2005

Comments on the coke oven residual risk proposed rule - October 8, 2004

General Provisions Proposed Rule - January 21, 2003

General Provisions 113(g) Notice - September 25, 2002

Regulatory reform

Comments on the 2017 Executive Order 13777 regulatory reform request - May 15, 2017

Comments on Executive Order 13563 to periodically review regulations - April 4, 2011

Potential corrections to the April 4, 2006, Burden Reduction final rule - June 15, 2006

Burden Reduction Initiative; NODA - December 15, 2003

Burden Reduction Proposed Rule - April 17, 2002

Burden Reduction Project - September 20, 1999

Testing and test methods

Comments and EPA email thread on the 2022 revisions to test methods - June 27, 2022

Comments on TCEQ's CPT reporting spreadsheet - April 10, 2020

Comments on the modifications to Method 23 - March 16, 2020

Comments on the 2019 revisions to the ignitable liquids determination - June 3, 2019

Comments on the 2018 revisions to test methods - March 27, 2018

Comments on the 2015 revisions to test methods, performance specifications, and testing regulations - December 9, 2015

Comments on Performance Specification 18 and Procedure 6 - July 12, 2014

Informal comments on draft Performance Specification 18, HCl CEMs - May 28, 2013

Comments on the proposed revisions to test methods - March 9, 2012

Comments on proposed Performance Specification 17 and Procedure 4 - February 5, 2009

Comments to the Office of Management and Budget on the cost of proposed Performance Specification 17 and Procedure 4 - November 7, 2008

Comments on the proposed provisions to allow the use of force majeure to postpone performance testing - November 7, 2006

Comments on the draft PS 11 guidance document - April 29, 2005

Comments on the Clean Air Act National Stack Testing Guidance document - June 27, 2005

Methods Innovation Proposed Rule - February 20, 2003

RCRA/solid waste

Comments on including electronic notifications to satisfy RCRA notification requirements - February 14, 2022

Comments on the Hazardous Waste Generator Improvements proposed rule - December 24, 2015

Comments on the 2015 revisions to the export-import regulations - December 18, 2015

Comments on the 2014 revisions to the WAP guidance document - August 25, 2014

Informal comments on the 2013 revisions to the WAP guidance document - June 14, 2013

Comments and Appendix on the proposed reconsideration of the Non-Hazardous Secondary Materials rule - February 20, 2012

Comments on the proposed changes to the Definition of Solid Waste rule - October 20, 2011

Comments on the Direct Final Rule to modify how 90-day RCRA tanks are labeled - May 3, 2010.

Standardized Permits Proposed Rule - December 11, 2001

Uniform Manifest Proposed Rule - October 3, 2001

Draft Guidance for National Hazardous Waste Ombudsman and Regional Superfund Ombudsmen Program - March 5, 2001

Land Disposal Restriction Reforms - September 18, 2000

Hazardous Waste Identification Proposed Rule - February 17, 2000

Miscellaneous

Comments on the proposed rule to add requirements for open burn/open detonation units - June 19, 2024

Comments on the proposed rule to add nine PFAS compoundst to Appendix VIII - March 8, 2024

Comments on the proposed rule to modify the definition of solid waste as applicable to the Corrective Action Program - March 26, 2024

Comments on Washington State's draft environmental impact assessment for destruction of AFFF - February 5, 2024

Talking points for a meeting with OIRA on the revisions to EPA's PFAS disposal and destruction guidance - November 28, 2023

Errors in the Sierra Club/EarthJustice incneration paper sumnitted to OIRA - November 28, 2023

Comments on the proposed revisions to the Air Emissions Reporting Rule - November 17, 2023

Comments on advanced notice of proposed rulemaking on PFAS in the environment - July 26, 2023

Comments on the proposed amendments to the Risk Management Plan provisions - October 31, 2022

Responses to the OSTP's request for information on a federal government PFAS strategy - August 29, 2022

Comments on the Clean Water Act Hazardsou Substances worst case discharge planning regulations - July 26, 2022

Request to OLEM to extend waste generator extensions - January 24, 2022

EPA OLEM's reply to our request - February 17, 2022

Suggestions to not include TSDFs in the current Section 311(j)(5) rulemaking - December 10, 2021

Comments on the Interim PFAS Disposal and Destruction Guidance document - February 22, 2021

Requested clarification on which events are reportable under 40 CFR 1604 - October 27, 2020

How permitted hazardous waste incinerators meet the 2020 NDAA statutory requirements - April 17, 2020

Comments on the Chemical Safety Board accidental release reporting proposed rule - January 13, 2020

Responses to EPA's request for comments on their Stationary Source Audit Program - December 10, 2019

Comments on EPA's draft PCB guidance document - January 25, 2019

Comments on the Clean Water Act Hazardous Substances Spill Prevention; Proposed Action - August 24, 2018

Comments on Veolia's 2014 draft Title V permit - December 19, 2014

Comments on Veolia's draft Title V permit - April 1, 2013

Comments on the proposed rule to restructure the stationary source audit program - August 5, 2009

Comments on the proposed greenhouse gas registry rule - June 9, 2009

Comments on proposed modifications of the audit policy for new owners - July 13, 2007

Comments on proposed modification to the TRI reporting requirements for dioxins and dioxin-like compounds - May 2, 2005

Dioxin Reassessment Documents - November 17, 2000

Ecological Screening Risk Assessment Guidance Document - August 9, 2000

Guidance for Reporting Dioxin under TRI - July 17, 2000

Letter to OMB on PM CEMs and Timing Issues - June 7, 1999

Safety-Kleen Petition - June 1, 1999

TRI Reporting of Persistent Bioaccumulative Chemicals - April 2, 1999