Summary of EPA Teleconference with Safety-Kleen

May 8, 2007

On Friday, May 4, 2007, Definition of Solid Waste team members from the
Office of Solid Waste (OSW) participated in a conference call with
representatives from Safety-Kleen.   In response to questions from
Safety-Kleen, EPA clarified a number of issues.  EPA clarified that when
we proposed to not allow brokers to participate in the exclusion we were
not envisioning a transfer facility that is owned by the recycler.  EPA
urged Safety-Kleen to comment on this issue if they believe these
facilities should be allowed to participate in the exclusion.  In
response to questions about the legitimacy proposal and how it relates
to current guidance, EPA indicated that the original 2003 proposal was
the best source of information.  EPA also clarified that, as indicated
in the preamble, the storage conditions could take into account both the
physical container and the environmental setting.   In relation to the
proposed financial assurance requirement, EPA is interest in
alternatives specific to how this would be applied at recycling
facilities, but we did not intend to open up for comment the current
financial assurance program, which is being addressed in a separate
initiative.  Finally, in response to questions specifically related to
transportation and interstate commerce, EPA reiterated the preamble
discussion that explains that this rule is less stringent that the
current federal program and that States would not be required to adopt
it, although EPA will encourage them to do so.

Tracy Atagi		Environmental Protection Agency	

	Betsy Devlin		Environmental Protection Agency

	Charlotte Mooney	Environmental Protection Agency

	Marybeth Sheridan	Environmental Protection Agency

	Mike Fusco		Safety-Kleen

	Lyn Longshore	Safety-Kleen

