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S.3277

Energy and Resources Recovery Act of 1974

Page 3, line 8

Insert "economically" before word practicable.

Page 3, line 16

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Sub-para. 3 delete; hazardous wastes need to be treated under separate legislation.

Page 4, line 11

Section 217: Question need for separate Energy and Resources Recovery Office. Believe this is unnecessary and creates additional bureaucracy, existing Solid Waste Office can assume additional duties.

Page 4, line 18

Change "one year" to "two years". This is a new area of endeavor and time frames must be extended to permit adequate and comprehensive studies.

Page 4, line 23

Strike "hazardous"

Page 5, line 2

Strike Section (1) since it relates to hazardous wastes.

Page 8, line 17

One year is not sufficient time to establish guidelines.

Page 9, line 8

Para. (b) Comment: This section appears to ignore economics. Technology and practices may exist that have no economic incentive that will lead toward development.

Page 9, line 16

Change "one year" to "two years".

Page 9, line 21

Para. (b) Comment: Packaging standards could have a severe impact upon the packaging industry and I question the desirability of establishing such standards. If standards are necessary it must be a uniform standard established at the Federal level and not left to the discretion of the States, (Fara. c).

Page 12, line 8

Para. h: Fee system requires clarification.

This is a broad section with no direction or guideline given as how system would work or be applied.

Page 14, line 4

Sec. 226: "States Energy and Resources Recovery Institutes," this section could be deleted and function administrated by EPA. This represents duplication of activities by each State and is unwarranted and uneconomical.

S.1086

Hazardouse Waste Management Act of 1973

Page 6, line 5, Section 4a

Eighteen months should be allowed to identify hazardous wastes with additional twelve months to establish standards.

Page 15, line 6, Paragraph c

This section appears to be out of place in this bill. Rating setting should be in a general solid waste bill not one on hazardous waste.

Page 19, line 20, Paragraph b

The environmental

If

Exemption should not be granted to Federal Agencies.
damage caused by hazardous wastes is the same regardless of source.
industry must comply, so should Federal Installations.

Page 20, line 8, Paragraph c

This paragraph appears out of place in this hazardous waste bill.

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Pursuant to the Committee's notice in the Congressional Record of July 8,

I submit herewith ten copies of my statement to be included in the record of

the hearings on solid waste management held by the Panel on Materials Policy of the Subcommittee on Environmental Pollution.

Sincerely

Kalteng

Ralph L. Harding Jr.

RLH:crf

STATEMENT OF RALPH L. HARDING JR.

PRESIDENT, THE SOCIETY OF THE PLASTICS INDUSTRY INC.
BEFORE THE SENATE COMMITTEE ON PUBLIC WORKS
SUBCOMMITTEE ON ENVIRONMENTAL POLLUTION
PANEL ON MATERIALS POLICY

Mr. Chairman, and members of the subcommittee, my name is Ralph L. Harding Jr.

I am president of The Society of the Plastics Industry, Inc., the principal trade association and spokesman for the plastics industry. We represent more than

1,200 companies which are engaged in manufacturing and distributing plastics and plastic products. These companies account for more than 75 percent of the plastic products sold in this country.

We recognize both the immediacy and the difficulty of developing a comprehensive solid waste management program and commend the Chairman and members of the subcommittee for the thorough and diligent effort they have made to seek out all views on the problem so that a responsive clean bill can be drafted at the conclusion of these hearings.

It has been the position of The Society of the Plastics Industry in response to various solid waste management and energy conversion proposals that we favor a systems approach to solid waste management which includes the utilization of energy recovery and recycling methods.

The typical heat content

Plastics, on the other hand,

With respect to energy production from solid wastes, plastics are uniquely constituted to provide high energy when burned as fuel. for municipal waste is about 4,700 BTUs per pound. have an average heat content of approximately 19,000 BTUs per pound--which is comparable to the heat value of fuel oil and even higher than some grades of coal. While the plastics content of municipal wastes ranges from approximately one to four percent of the total, the energy value of this fraction is about six percent

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