Coalition for Responsible Waste Incineration

November 17, 2000

Technical Information Staff (8623D)
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Ariel Rios Building
Washington, DC 20460

Re: Draft Dioxin Reassessment Documents

The Coalition for Responsible Waste Incineration (CRWI) is pleased to submit comments on Chapter 8, Chapter 9, and Part III of the Draft Dioxin Reassessment Documents (65 FR 59186, October 4, 2000). CRWI represents ten companies that operate hazardous waste combustion units and eight other companies with interests in hazardous waste combustion. These companies account for a significant portion of the U.S. capacity for hazardous waste combustion. In addition, CRWI is advised by a number of academic members with research interests in hazardous waste combustion. Since its inception, CRWI has encouraged its members to reduce the generation of hazardous waste. However, for certain hazardous waste streams, CRWI believes that combustion is a safe and effective method of treatment, reducing both the volume and toxicity of the waste treated. CRWI seeks to help its member companies both to improve their operations and to provide lawmakers and regulators helpful data and comments.

CRWI supports the peer review process and commends EPA for holding two peer reviews of the three revised chapters. CRWI supports the findings of the peer review panel held in July and urges EPA to implement those recommendations. CRWI also agrees with a number of the concerns expressed by the Science Advisory Board (SAB) review committee. However, since that report was not available by the time these comments had to be submitted, it is not possible to comment on the official report from the SAB review Committee.

While CRWI recognizes that considerable efforts have been undertaken to revise USEPA's draft 1994 Dioxin Reassessment, we believe that the draft final Dioxin Reassessment does not accomplish the following key Agency objectives:

  1. Provide sound scientific and technical methodology to credibly support risk management decisions regarding potential exposure to dioxins;
  2. Implement the Agency's key science and science policy objectives with respect to risk assessment and risk management;
  3. Implement an effective stake-holder and public comment process specifically designed to address the unique complexity, novelty and controversial nature of the Dioxin Reassessment; and
  4. Ensure that credible science is incorporated into the methodology prior to finalization.

Again, thank you for the opportunity to comment on this document. Our specific comments are attached. If there are any questions, please contact me (202-775-9869 or

Sincerely yours,

Melvin E. Keener, Ph.D.
Executive Director

NOTE: The attachment to this letter can be obtained by contacting CRWI.

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