Preparation of Greenhouse Gas Monitoring Plan

Preparation of Greenhouse Gas Monitoring Plan

Industry:
Medical/Infectious Waste Incineration (HMIWI)
CO2

Service Area:
Multimedia Regulatory Analysis

Client's Challenge

The U.S. Environmental Protection Agency (U.S. EPA) developed proposed revisions to 40 CFR Part 60, Subparts Ce and Ec that dramatically changed the process for developing emission limits and, ultimately, the emission limits themselves.  In addition, there were other proposed revisions to waste management planning, monitoring, and overall compliance management.  These proposed revisions drastically impacted an entire industry sector and required the development of a technical and legal comment document to address the potential impacts on the industry and to preserve the industry’s right for further legal action.

ALL4's Solution

Early in the process ALL4 recognized the potential impact of the proposed regulatory revisions on the HMIWI industry.  ALL4 saw the need for assembling a superior technical/legal team and the importance of enlisting collaboration throughout the industry.  While working with a key MWI stakeholder, ALL4 helped to assemble a team of legal, technical, and industry representatives to thoroughly review and comment on the proposed regulation.  In addition, the impact of approach that U.S. EPA employed to develop the proposed emission limits had the potential to dramatically impact future rulemaking on a national level across multiple manufacturing sectors.  As a result, ALL4 also coordinated with other industry groups to help highlight the U.S. EPA’s approach and encourage comments from a wide range of industries.

The Results

The direct result of ALL4’s development and support of the MWI’s comments was the revision of several key emission limits in the final regulation that were published and further revised in a subsequent technical amendment.  The revisions were supported by sound science and provide more realistic limits for the regulated industry.  In addition, ALL4’s work with MWI and coordination with other industry groups has preserved the right to further legal action regarding the approach that U.S. EPA used to develop the emission limits.

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