 Coalition for
Responsible Waste Incineration
November 17, 2000
Technical Information Staff (8623D)
NCEA-W
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Ariel Rios Building
Washington, DC 20460
Re: Draft Dioxin Reassessment Documents
The Coalition for Responsible Waste Incineration (CRWI) is
pleased to submit comments on Chapter 8, Chapter 9, and Part III of the
Draft Dioxin Reassessment Documents (65 FR 59186, October 4, 2000).
CRWI represents ten companies that operate hazardous waste combustion
units and eight other companies with interests in hazardous waste
combustion. These companies account for a significant portion of the
U.S. capacity for hazardous waste combustion. In addition, CRWI is
advised by a number of academic members with research interests in
hazardous waste combustion. Since its inception, CRWI has encouraged
its members to reduce the generation of hazardous waste. However, for
certain hazardous waste streams, CRWI believes that combustion is a
safe and effective method of treatment, reducing both the volume and
toxicity of the waste treated. CRWI seeks to help its member companies
both to improve their operations and to provide lawmakers and
regulators helpful data and comments.
CRWI supports the peer review process and commends EPA for
holding two peer reviews of the three revised chapters. CRWI supports
the findings of the peer review panel held in July and urges EPA to
implement those recommendations. CRWI also agrees with a number of the
concerns expressed by the Science Advisory Board (SAB) review
committee. However, since that report was not available by the time
these comments had to be submitted, it is not possible to comment on
the official report from the SAB review Committee.
While CRWI recognizes that considerable efforts have been
undertaken to revise USEPA's draft 1994 Dioxin Reassessment, we believe
that the draft final Dioxin Reassessment does not accomplish
the following key Agency objectives:
- Provide sound scientific and technical methodology
to credibly support risk management decisions regarding potential
exposure to dioxins;
- Implement the Agency's key science and science policy
objectives with respect to risk assessment and risk management;
- Implement an effective stake-holder and public comment
process specifically designed to address the unique complexity,
novelty and controversial nature of the Dioxin Reassessment; and
- Ensure that credible science is incorporated into the
methodology prior to finalization.
Again, thank you for the opportunity to comment on this
document. Our specific comments are attached. If there are any
questions, please contact me (202-775-9869 or crwi@erols.com).
Sincerely yours,
Melvin E. Keener, Ph.D.
Executive Director
NOTE: The attachment to this letter can be obtained by
contacting CRWI.
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