EPA issues final revisions to Non-Hazardous Secondary Materials Rule, but questions remain

Vol. 44 No. 4

Susan Parker Bodine is a partner at Barnes & Thornburg LLP and is a former assistant administrator of EPA’s Office of Solid Waste and Emergency Response.

On February 7, 2013, the Environmental Protection Agency (EPA) published in the Federal Register the final rule on “Non-Hazardous Secondary Materials That Are Solid Waste” (New NHSM Rule). This Rule was published in the same Federal Register notice as the final “Commercial and Industrial Solid Waste Incineration Units” (New CISWI Rule). EPA published another related rule, the “Final Emission Standards for Major Source Industrial, Commercial, and Institutional Boilers and Process Heaters” (New Boiler MACT Rule), on January 31, 2013.

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The Law of Adaptation to Climate Change: United States and International Aspects