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Financial Responsibility Requirements under CERCLA 108(b) for Facilities in the Hard Rock Mining Industry

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American Iron and Steel Institute filings
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American Iron and Steel Institute filed 2 comments on this docket between Feb 7, 2017 and Jul 18, 2017. 77 other organizations filed here. The comment window closed 3304d ago.

What American Iron and Steel Institute filed (2)

Jul 18, 2017· Comment submitted by Paul Balserak Vice President, Environment American Iron and Steel Institute (AISI)· EPA-HQ-SFUND-2015-0781-2781

July 11, 2017 The Honorable Scott Pruitt, Administrator U.S. Environmental Protection Agency William Jefferson Clinton Building 1200 Pennsylvania Avenue, NW Washington, D.C. 20460 Re:Proposed Rule; Financial Responsibility Requirements Under CERCLA 108(b) for Classes of Facilities in the Hardrock Mining Industry, 82 Fed. Reg. 3,338 (Jan. 11, 2017); Docket ID EPA-HQ-SFUND-2015-0781 Administrator Pruitt: The American Iron and Steel Institute (AISI) appreciates this opportunity to comment on the Environmental Protection Agency's proposal to include iron ore mining as a form of "hardrock mining" requiring financial responsibility regulation pursuant to CERCLA 108(b) (Financial Responsibility Requirements Under CERCLA 108(b) for Classes of Facilities in the Hardrock Mining, 82 Fed. Reg. 3,388 (Jan. 11, 2017)). For over 150 years, AISI has sought to effectively influence public policy, educate, and shape public opinion in support of a strong, sustainable U.S. and North American steel industry committed to manufacturing products that meet society's needs. AISI serves as the voice of the North American steel industry in the public policy arena and advances the case for steel in the marketplace as the material of choice. AISI also plays a lead role in the development and application of new steels and steelmaking technology. AISI comprises 19 member companies, including integrated and electric furnace steelmakers, and approximately 120 associate members who are suppliers to or customers of the steel industry. AISI members have a direct interest in the Proposed Rule, which, as currently drafted, would impose onerous and financially crippling new requirements on their operations with no resulting benefit to the public. As explained in the attached detailed comments, these proposed new requirements are unwarranted for the iron ore mining sector. Please contact me (pbalserak@steel.org, (202) 452-7122) if you or members of your team have any questions regarding AISI's comments. Sincerely, Paul Balserak Vice President, Environment American Iron and Steel Institute

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Feb 7, 2017· Comment submitted by Paul Balserak, Vice President, Environment, American Iron and Steel Institute (AISI)· EPA-HQ-SFUND-2015-0781-2226

Request for extension to comment period for CERCLA 108b HRM proposal. Paul Balserak, Vice President American Iron and Steel Institute

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Abstract

EPA is proposing regulations under Section 108(b) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) that will require certain classes within the Hard Rock Mining Industry to establish and maintain evidence of financial responsibility consistent with the degree and duration of risk association with the production, transportation, treatment, storage, or disposal of hazardous substances.

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Co-filers (77)

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