MEMORANDUM

SUBJECT: 	3-22-12 Meeting with Industry Coalition on December 2011 NHSM
Proposal

FROM:	Tab Tesnau

Office of Resource Conservation and Recovery

TO:		Docket ID No. EPA-HQ-RCRA-2008-0329

On March 22, 2012, EPA met with various members of an industry coalition
(including the forest product industry) to discuss their issues and
concerns with proposed revisions to the Non-Hazardous Secondary
Materials (NHSM), published in the Federal Register on December 23, 2011
(76 FR 80452).

During that meeting, industry members expressed concerns with the
overall structure of the NHSM rule, as well as provided information as
to why various NHSMs should be listed as categorical non-waste fuels,
including resinated wood, tire-derived fuel, wastewater treatment
residuals (i.e., pulp and paper sludges), paper recycling residuals/OCC
rejects, processed construction and demolition (C&D) wood, and
non-hazardous treated wood.  EPA asked clarifying questions.  Both the
agenda for the meeting as well as a list of attendees are attached.

Attachments



Industry Coalition meeting with EPA on NHSM

March 22 from 1 to 2:30

Logistics:

Location: ORCR, Two Potomac Yard (North Building); 2733 Crystal Drive; 

Arlington/Crystal City, VA; Room 6100 

Attending: Tim Hunt (AF&PA/AWC), Paul Noe (AF&PA), Jeff Shumaker (IP),
Mike Curtis (GP), Corey Brandt (RockTenn), Steve Woock (Weyerhaeuser),
Rob Kaufmann (Koch), Vipin Varma (NCASI), Susan Bodine, Tracey Norberg
(RMA), Sarah Amick (RMA), Bill Turley (CRMA), Gary Melow (BPA) 

Draft Agenda

Introductions 

Legal issues (5 minutes)

Program Structure (35 minutes)

Contained gas 

Contaminant comparisons

Definitions

Petition process 

Homogeneous material

Comfort letters

Non-waste fuel listing (45 minutes)

Resinated wood

TDF

Wastewater Treatment Residuals 

Paper recycling residuals/OCC rejects

Processed C&D

Non-hazardous treated wood

Other materials

Wrap Up (5 minutes):

Summarize key outstanding questions

Other issues – rule schedule

