  SEQ CHAPTER \h \r 1 

MEMORANDUM

TO:		Toni Jones, Charlene Spells, Ketan Patel, U.S. Environmental
Protection Agency

FROM:  	Jason Huckaby, Eastern Research Group, Inc.

DATE:  	August 12, 2010

SUBJECT:  	Teleconference Meeting Summary with Reusable Industrial
Packaging Association (RIPA) 

INTRODUCTION

A telephone conference between representatives of U.S. Environmental
Protection Agency (EPA) and the Reusable Industrial Packaging
Association (RIPA) was held so that RIPA could present their comments
and concerns on the proposed Commercial and Industrial Solid Waste
Incineration (CISWI) emission guidelines and new source performance
standards.

ATTENDEES

C.L. Pettit, RIPA

Larry Bierlein, RIPA Counsel

Kay Rykowski, Industrial Container Services, LLC (RIPA member
representative)

Toni Wyche Jones, EPA

Ketan Patel, EPA

Charlene Spells, EPA

Paul Versace, EPA

Robin Dunkins, EPA

Jason Huckaby, ERG

TIME and DATE

10:30 to 11:00 AM on August 9, 2010

AGENDA

See Attached agenda prepared by RIPA.

DISCUSSION SUMMARY

The meeting discussion followed the agenda, opening with an introduction
of attendees.  Principle talking points are summarized below.



Attachment:  Agenda

Teleconference Call

Monday August 9, 2010

10:30 am – 11:00 am

Dial (919) 541 – 4332 (no PIN or Passcode needed)

U.S. EPA Office of Air and Radiation (Research Triangle Park, NC)

and

Reusable Industrial Packaging Association

Re:	Commercial and Industrial Solid Waste Incineration Units (CISWI)

NPRM June 4, 2010; 75 Fed. Reg. 31937

I.  	Introductions

II.  	Drum Furnaces are not Ovens

III. 	Materials Throughput is not Comparable

IV.	Was EPA’s Methodology in Calculating Limits Flawed?

V.	Cost Impacts Were Grossly Underestimated

	

VI.	Applicability of December Deadline

	

VII.     	Emptied Drums in Reconditioning Networks Are Not Discarded

VIII.      Jobs Impact 

IX.	Conclusion

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