September
3,
2004
MEMORANDUM
FROM:
Steven
Silverman,
Attorney,
EPA
TO:
Hazardous
Waste
Combustor
MACT
Rule
Docket
(
OAR­
2004­
0022)

RE:
Meeting
with
David
Case,
Environmental
Technology
Council
On
September
3,
2004,
I
met
with
David
Case,
Director
of
the
Environmental
Technology
Council.
We
discussed
the
ETC's
comments
to
the
April
20
proposed
rule,
and
also
discussed
comments
submitted
by
Earthjustice/
Sierra
Club.
Among
issues
we
discussed
were
floor
methodologies,
the
function
of
a
PM
standard,
whether
feed
control
is
suitable
for
raw
material
inputs
into
hazardous
waste
combustion
devices,
and
how
EPA
arrived
at
the
proposed
variability
factors.
We
also
discussed
ETC's
alternative
methodology
for
deriving
MACT
floors,
and
whether
ETC
had
verified
the
identities
of
the
sources
that
would
be
screened
out
under
the
ETC
approach.
