January
20,
2004
Robert
L.
Springer
5301W
U.
S.
Environmental
Protection
Agency
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
NW
Washington
DC
20460
Dear
Mr.
Springer:

Sierra
Club
and
UNITE
write
to
request
a
public
hearing
on
U.
S.
EPA's
proposal
rule
to
grant
conditional
exclusions
from
hazardous
waste
and
solid
waste
for
solventcontaminated
industrial
wipes.
This
proposed
rule
was
published
in
the
Federal
Register
on
November
20,
2003
at
68
Federal
Register
65586.

We
believe
that
this
proposed
rule,
if
made
final
in
its
current
form,
would
create
unsafe
workplaces
for
laundry
workers
and
result
in
unnecessary
discharges
of
solventcontaminated
wastewater
to
rivers,
streams
and
lakes.
We
also
question
the
legality
of
the
proposal's
view
that
solvent­
contaminated
wipes
should
not
be
considered
a
solid
and
hazardous
waste.

Given
the
importance
of
these
issues,
we
hope
that
the
EPA
will
grant
our
request
for
a
public
hearing
on
this
proposed
rule.
Thank
you
for
considering
our
views.

Sincerely,

Ed
Hopkins
Eric
Frumin
Director,
Environmental
Quality
Program
Health
and
Safety
Director
Sierra
Club
UNITE
408
C
Street,
NE
275
7th
Avenue
Washington,
DC
20015
New
York,
New
York
10001
202­
675­
7908
212­
265­
7000
