September
15,
2004
MEMORANDUM
From:
Michael
Galbraith,
USEPA/
OSW
To:
Hazardous
Waste
Combustor
MACT
Rule
Docket,
OAR
2004­
0022
Subject:
September
9,
2004
Meeting
with
Environmental
Technology
Council
On
September
9,
2004,
the
Environmental
Technology
Council
(
ETC),
represented
by
Dave
Case
and
Bill
Ziegler,
met
with
USEPA
staff
(
Michael
Galbraith,
Bob
Holloway,
Frank
Behan,
Shiva
Garg,
Steve
Silverman
and
Nelson
Andrews)
to
discuss
the
hazardous
waste
combustor
MACT
proposal.

The
discussion
focused
on
ETC
and
Sierra
Clubs'
comments
submitted
on
the
proposal,
and
included
topics
such
as
the
legal
justification
of
the
proposed
floor
methodologies,
justification
for
issuing
particulate
matter
standards
as
surrogate
controls
for
metal
HAPs,
and
EPA's
proposed
approach
to
not
identify
feed
control
of
raw
material
HAPs
(
and
nonhazardous
waste
fuel
HAPs)
as
a
floor
control
technology.

ETC
indicated
that
they
would
be
submitting
supplemental
comments
on
the
Hazardous
Waste
Combustor
MACT
proposal
in
the
near
future.
