Since publication of EPA’s non-hazardous secondary material (NHSM), boiler maximum achievable control technology (boiler MACT) and commercial and industrial solid waste incinerator (CISWI) rules earlier this year, EPA has quietly issued written assurances to companies that some of their waste streams can be classified as fuel rather than waste, thus placing incineration of the materials under the less stringent boiler MACT rule rather than the CISWI rule.  Industry representatives welcome this flexibility, but environmentalists criticize the use of informal letters that were not provided for in the February 7 rules.  To date, it is known that EPA has informed Waste… Read more