 Coalition for
Responsible Waste Incineration
February 17, 2000
RCRA Docket Information Center
Office of Solid Waste (5305W)
U. S. Environmental Protection Agency Headquarters
401 M Street, SW
Washington, DC 20460
RE: Docket No. F-99-WH2P-FFFFF
The Coalition for Responsible Waste Incineration (CRWI) is
pleased to submit comments on the Hazardous Waste Identification
Rule (HWIR): Identification and listing of Hazardous Waste; Proposed
Rule (64 FR 63382, November 19, 1999). CRWI represents sixteen
companies with hazardous waste combustion interests. 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 would like to comment on the following three areas.
- CRWI agrees with the Agency that residuals from wastes
listed solely because they exhibit the ignitability, corrosivity,
and/or reactivity characteristic should not continue to be defined as
hazardous waste after the characteristic has been removed through
treatment. Where incineration is successfully used to remove the
ignitability characteristic, the resulting ash will not exhibit the
ignitability characteristic and should no longer be treated as such.
Thus, CRWI supports EPA's proposed action to exempt all 29 waste codes
listed in Table 1 of the preamble (64 FR 63390) if they are
de-characterized and meet all appropriate land disposal restriction
treatment standards.
- EPA specifically requested comments on whether F003 listed
waste should be included because some of the solvents that are listed
due to their ignitability characteristic could also be listed for
toxicity as well. High-temperature incineration of organic compounds
(especially ones listed due to an ignitability characteristic) will
destroy those compounds. If those organic compounds no longer exist in
the residual material, that material will not exhibit either the
ignitability or the toxicity characteristic. Thus, the treatment for
ignitability will also remove the toxicity characteristic. For this
reason, CRIW supports including F003 in this exemption.
- EPA also requested comments on the Chemical Manufacturers
Association (CMA) suggested exclusions. CRWI wishes to comment only on
the suggestion that residues derived from the combustion of hazardous
waste be considered a new point of generation. CRWI agrees with CMA
that the resulting ash is neither physically or chemically similar to
the original listed waste and should be evaluated on it own merits for
characteristics of being a hazardous waste. However, we are concerned
that the creation of a new multi-source listing code (similar to F039)
may result in additional testing. CRWI does not see the merits of
requiring a complete battery of tests on incinerator ash simply because
it now has its own multi-source listing code. As long as facility
operators can use knowledge of the constituents of the original waste
to decide which tests are appropriate for each batch of ash, CRWI
supports this concept. However, CRWI cannot support the development of
a multi-source listing code if it will result in additional testing.
Thank you for considering these comments. If you have any questions,
please contact me (202-775-9869 or crwi@erols.com).
Sincerely yours,
Melvin E. Keener, Ph.D.
Executive Director
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