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EPARulemakingEPA-HQ-OLEM-2018-0830

Modernizing Ignitable Liquids Determinations

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Environmental Technology Council filings
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Environmental Technology Council filed 1 comment on this docket between Jun 5, 2019 and Jun 5, 2019. 3 other organizations filed here. The comment window closed 2612d ago.

What Environmental Technology Council filed (1)

Jun 5, 2019· Comment submitted by David Case, Executive Director, Environmental Technology Council (ETC)· EPA-HQ-OLEM-2018-0830-0170

On behalf of its member companies, the Environmental Technology Council (ETC) respectfully submits these comments on EPAs proposed rule entitled Modernizing Ignitable Liquids Determinations, 84 Fed. Reg. 12539 (April 2, 2019). ETC is the leading trade association of commercial firms that provide technologies and services to customers for the recycling, treatment, and secure disposal of industrial and hazardous wastes.

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Abstract

Certain reference testing methodologies and test methods from SW-846 are incorporated by reference into the regulations that implement Subtitle C of RCRA. EPA updates the content of SW-846 over time as new information and data are developed or supporting changes are needed due to the advances in analytical instrumentation and or techniques for testing and monitoring compliance. This proposal consists of five actions. First, EPA proposes to update the flash point test methods from 1978, 1979, and 1980 (required for determining if a liquid waste is an ignitable hazardous waste) to include current ASTM International (ASTM) standards. Second, EPA is proposing to codify existing guidance regarding the regulatory exclusion in the ignitable characteristic for aqueous liquids containing alcohols and is requesting comment on whether additional changes may be warranted. Third, EPA is proposing to codify existing sampling guidance for ignitable waste mixtures having multiple phases. Fourth, EPA is proposing to update cross references to Department of Transportation (U.S. DOT) regulations and to remove obsolete information in the ignitability regulation. Finally, EPA is proposing to provide alternatives to the use of mercury thermometers in the air sampling and stack emissions methods 0010, 0011, 0020, 0023A, and 0051 in SW-846. Adding the option of using non-mercury thermometers in place of mercury thermometers would provide the regulated community with increased flexibility in their implementation of these required test methods. The use of alternatives to mercury thermometers is consistent with previous Agency actions and helps achieve the Agency’s goal of minimizing the use of mercury.

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Modernizing Ignitable Liquids Determinations (EPA) — Environmental Technology Council | OpenPolis