Attached please find the comments of the Association of American Railroads and the American Shortline and Regional Railroad Association.
Proposed Response to Petition to Revise the Non-Hazardous Secondary Material Standards Under Part 241
Activity
Association of American Railroads filed 2 comments on this docket between Mar 29, 2022 and Mar 31, 2022. 0 other organizations filed here. The comment window closed 1582d ago.
What Association of American Railroads filed (2)
Attached please find the comments of the Association of American Railroads and the American Short Line and Regional Railroad Association.
Abstract
The EPA is responding to a rulemaking petition from American Forest and Paper Association et. al. requesting amendments to the Non-Hazardous Secondary Materials (NHSM) regulations, under the Resource Conservation and Recovery Act (RCRA). The NHSM regulations establish standards and procedures for identifying whether non-hazardous secondary materials are solid wastes when legitimately used as fuels or ingredients in combustion units. The petition requested the following amendments: 1) change from mandatory to “should consider” the legitimacy criterion for comparison of contaminants in the NHSM to the traditional fuel the unit is designed to burn; 2) remove associated designed to burn and other limitations for creosote- treated railroad ties (CTRT); and 3) revise the definition of paper recycling residuals (PRRs) that can be burned as non-waste to include non-fiber materials.
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