This joint ECOS ASTSWMO letter addresses concern with an implementation issue regarding the proposed RCRA Subtitle D option. The suggestion is that U.S. EPA, in promulgating a final rule under
Subtitle D, should establish a mechanism by which the agency acknowledges that a State permit
program that meets or exceeds the federal minimum CCR standards has primary authority to directly
administer the federal Subtitle D rule. This letter concludes with the associations offering assistance in the development of a mechanism to avoid the situation of a dual State and federal regulatory regime for CCRs.
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