Forwarded:
Replies to gary@garyliss.com
Date: Thu, 24 Feb 2000 14:47:15 -0800
From: Gary Liss <gary@garyliss.com>
Subject: ALERT: LANDFILL COMMENTS DUE TO EPA 2/29
The EPA is soliciting comments on Subtitle D landfill regulations for the
first time in a decade. Comments are due 2/29 to EPA.
If you feel like I do that Subtitle D regulations are inadequate and
undermine the economics of recycling, I urge you to send a letter or email
at least to EPA saying that you agree with the recommendations below from
the National Recycling Coalition. NRC is sending in a more detailed letter
that includes these recommendations as part of it. If you would like a
copy of the full NRC letter, please contact Edgar Miller at
EdgarM@NRC-Recycle.org or myself and we can send that to you as a MS WORD
attachment.
You can be sure that those who fought to weaken the Subtitle D regulations
will be telling EPA that they are wonderful as they are. We need to get
hundreds of letters and emails going to EPA by 2/29 to demonstrate to EPA
that there are
many people concerned about this issue.
If you are not comfortable sending a letter yourself, please think of who
you know that might be able to send something and urge their action ASAP.
Please copy me on any letter you send in by email, so I can share those
with NRC.
Thanks for anything you can do!
Gary Liss
*********************************************************
Send an original and two copies of comments referencing docket number
F-1999-MLFN-FFFFF to : RCRA Docket Information Center, Office of Solid
Waste (5305G), U.S. Environmental Protection Agency Headquarters (EPA,HQ),
401 M Street, SW, Washington, DC 20460.
Comments may also be submitted electronically to: rcra-docket@epa.gov.
Comments in electronic format should also be identified by the docket
number F-1999-MLFN-FFFFF. All electronic comments must be submitted as an
ASCII (TEXT) file avoiding the use of special characters and any form of
encryption.
For Further Information from EPA Contact:
- For general information, contact the RCRA Hotline at 800 424-9346 or TDD
800 553-7672 (hearing impaired). In the Washington, DC, metropolitan area,
call 703 412-9810 or TDD 703-412-3323.
- For information on specific aspects of this notice, contact Dwight
Hlustick, Office of Solid Waste (5306W), U.S. Environmental Protection
Agency, 401 M Street, SW, Washington, DC 20460, 703-308-8647,
[hlustick.dwight@epa.gov]
For copy of the original notice in the Federal
Register: http://www.epa.gov/epaoswer/non-hw/muncpl/landfill.htm
*********************************************************
Key NRC Subtitle D Landfill Regulations Comments
NRC respectfully requests that EPA focus its evaluation of Subtitle D
regulations on the need to completely restructure the regulatory mechanisms
currently in place to manage solid waste as summarized in the five issues
listed below.
(1) Entombment. EPA should consider restructuring the overall
regulatory approach of entombment and consider changing this approach to
one which requires pre-treating the municipal discard stream so that the
resulting waste load which is discarded in the ground becomes benign and no
longer requires continuing isolation and monitoring to protect human health
and the environment.
(2) Financial Assurance. EPA should strengthen the existing financial
assurance regulations by eliminating various forms of self insurance,
extending the liability period from 30 years through perpetuity or until
such time as the waste load is determined to be benign, and requiring third
party insurance for worst-case corrective action. Extending the liability
through perpetuity is already law in California and would more accurately
reflect the uncertain, but potentially long-term risk these facilities may
pose.
(3) Small Generator Exemption. EPA should consider eliminating the
small quantity generator hazardous waste exemption, recognizing that the
existence of this exemption is one of the reasons NRC believes
pre-treatment of municipal solid waste should be required.
(4) Mega-fills. EPA should consider placing a moratorium on the
permitting of new landfills for which an application has not yet been made
for facilities with elevations greater than 300 feet until engineering
studies have validated the long term side slope stability and functioning
of the leachate collection systems in mega-size landfills.
(5) RECYCLING CONDITIONS FOR LANDFILL PERMITS EPA should review key
landfill permit conditions adopted around the country to foster waste
prevention, source separation and recycling as conditions of landfill
permits. EPA should consider requiring minimum standards of recycling to
be included in future landfill permits to integrate and achieve EPA's 35%
national recycling goal. EPA should recommend additional recycling and
source reduction requirements to be considered and implemented by state and
local enforcement agencies in reviewing environmental documents and
adoption of mitigation conditions on state and local solid waste permits
and local land use permits for all landfills.
Gary Liss
916-652-7850
Fax: 916-652-0485
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