NORA: EPA Official to address Proposed Rule at Mid-Year Meeting - participate in Q & A 

EPA Official will address Proposed Solid Waste Rule at the 2010 NORA Mid-Year Meeting  

NORA has arranged for EPA Official George Faison to attend the 2010 NORA Mid-Year Meeting. He will provide the lunch presentation (on June 21) regarding EPA's Proposed Rule titled "Identification of Non-Hazardous Secondary Materials that are Solid Waste." Faison will also answer questions of attendees.

The 2010 NORA Mid-Year Meeting will be held June 20-22, 2010. To register for this event, click here. To reserve your room within the NORA block (just $179/night), call the Hotel Monaco Alexandria at 800-546-7866. Attendees should plan on arriving on the afternoon of June 20 and departing late on the afternoon of June 22.

Here is what we know now:

• EPA has provided a "Federal Register Notice - Pre-Publication" version of their "Identification of Non-Hazardous Materials That Are Solid Waste". To open this document, click here.
• It is important to note that this has not appeared in the Federal Register yet, so this copy is "unofficial". 
• Once it appears in the Federal Register, NORA and its members will have 45 days to comment. This comment deadline will likely be AFTER the NORA Mid-Year meeting. Attendees at the Mid-Year meeting will assist in finalizing NORA's comments.
• In the proposed rule, EPA has two primary sections related to Used Oil - A "Proposed Approach" and an "Alternative Approach". 
• Starting on page 77, you can read about EPA's "Proposed Approach" which states that: 
• On-spec used oil will not be classified as a solid waste and will continue to be regulated by Part 279 and will continue to be allowed to be combusted in facilities that meet Section 112 of the Clean Air Act, such as asphalt plants;  
• Off-spec used oil will be classified as a solid waste and will now need to meet Section 129 of the Clean Air Act or be blended to meet on-spec rules.
• The space heater exemption will be eliminated if the space heater burns off-spec used oil.
• Starting on page 154, you can read about EPA's "Alternative Approach" which would declare virtually all used oil to be a solid waste. It could be combusted in facilities that meet Section 129 of the Clean Air Act.

What is NORA doing now:

• Researching all angles on this issue and providing regular communications to members.
• Securing an EPA speaker on the topic for the Mid-Year Meeting.
• Coordinating with related associations that may be affected by this proposed rule. Currently, NORA is reaching out to the National Asphalt Pavers Association, the American Petroleum Institute, the Portland Cement Association and many others.
• Once the proposed rule is published in the Federal Register, we will officially begin to request input from all members. NORA will develop comments for the EPA that the association will submit. In addition, NORA will develop a template for members to use to assist in preparing their own comments.

What should YOU be doing now: