Comments on NY Part 360 Series regulations, Solid Waste Management Facilities

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We appreciate NYSDEC’s efforts to strengthen the regulations, most of which have not been revised in decades. While the New York Code, Rules and Regulations (NYCRR) Part 360 series covers many aspects of solid waste management, we focus our comments on those related to oil and gas exploration, development, and production wastes (collectively known as E&P waste). Specific topics covered include the characterization of oil and gas wastes; management and disposal procedures at landfills, including those related to landfill leachate; radioactivity detection; and the Beneficial Use Determination program for oil and gas brine.