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EPARulemakingEPA-HQ-OLEM-2018-0830

Modernizing Ignitable Liquids Determinations

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National Association of Chain Drug Stores filings
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National Association of Chain Drug Stores filed 1 comment on this docket between Jun 10, 2019 and Jun 10, 2019. 3 other organizations filed here. The comment window closed 2612d ago.

What National Association of Chain Drug Stores filed (1)

Jun 10, 2019· Comment submitted by Austen Jensen, Senior Vice President, Government Affairs, Retail Industry Leaders Association (RILA) and Kevin Nicholson, Vice President, Public Policy and Regulatory Affairs, National Association of Chain Drug Stores (NACDS)· EPA-HQ-OLEM-2018-0830-0175

Please see the attached joint comments by the Retail Industry Leaders Association (RILA) and the National Association of Chain Drug Stores (NACDS), on the EPA proposal entitled "Modernizing Ignitable Liquids Determinations," which was published in the Federal Register on April 2, 2019. Austen Jensen Senior Vice President, Government Affairs Retail Industry Leaders Association 99 M Street SE, Suite 700 Washington, DC 20003 (703) 600-2033-direct (703) 244-0179-cell Austen.jensen@rila.org www.rila.org

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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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