Jun 9, 2003· Comment submitted by Ted Steichent, Senior Regulatory Analyst, American Petroleum Institute (API)· EPA-HQ-RCRA-2002-0028-0101
API supports this headworks proposed rule where it provides for appropriate flexibility in methods available to best safely handle wastes. API supports the option of demonstrating compliance with the headworks exemption by direct monitoring. API also supports the proposal to broaden the use of the de minimis exemption (40 CFR ?261.3(a)(2)(iv)). However, API has concerns about certain of the requirements associated with this proposed broadening of that exemption, and with the definition of de minimis. API also strongly urges EPA to continue its efforts to propose to exempt F039 (multi-source leachate), especially from captive on-site landfills. Attached please find more specific comments on the headworks proposal.