Kristin Fitzgerald/DC/USEPA/US 

12/20/2006 10:58 AM	To

	peter_reinhardt@unc.edu, sandra.neuse@usg.edu

	cc

	

	bcc

	Patricia Mercer/DC/USEPA/US@EPA; Meg McCarthy/DC/USEPA/US@EPA; James 

Michael/DC/USEPA/US@EPA; Betsy Devlin/DC/USEPA/US@EPA

	Subject

	Follow-up Question to CSHEMA comments

	

	

Peter A. Reinhardt and Sandra Lynn Neuse

Co-Chairs, Government Relations Committee

Campus Safety, Health and Environmental Management Association

Division of the National Safety Council

Dear Mr. Reinhardt and Ms. Neuse,

 Thank you for your comments on EPA’s Proposed Rule: Subpart
K—Standards 

Applicable to Academic Laboratories (71 Federal Register 29712) on
behalf 

of the Campus Safety Health and Environmental Management Association 

(CSHEMA), a division of the National Safety Council.

In response to CSHEMA’s comments (Docket Number 

EPA-HQ-RCRA-2003-0012-0078.1), EPA has a follow-up question.  In the 

preamble to the proposed rule (page 29720), EPA estimated that hazardous


laboratory waste constitutes 9% of the annual hazardous waste generated
by 

college and university large quantity generators.  EPA based this number


on data submitted to EPA by colleges and universities that are large 

quantity generators, as part of the 2001 Biennial Report.  

In contrast, on page 37 of CSHEMA’s comments to the docket, CSHEMA 

commented that “an informal poll of large quantity generator academic 

institutions indicates that laboratory waste represents between 65% and 

95% of annual hazardous waste generation.”  EPA is very interested in
data 

that CSHEMA has and can provide to support this assertion.  This 

information would be beneficial to EPA in its development of the final 

rule, in order to have a fuller understanding of the laboratory waste 

generation patterns at colleges and universities.  Unfortunately, this 

comment is not useful to EPA without supporting data that can
substantiate 

or validate the results of the “informal poll.”  EPA would find it
helpful 

if you could provide an explanation of the origins of the data, and how
or 

why the data may differ from the Biennial Report data we relied on.  In 

addition, we would appreciate a timely response to allow us to
incorporate 

any information you may provide into the decision-making process, as 

appropriate.   Please provide a response by the end of January 2007.  If


you are unable to provide a response by then, please contact us to let
us 

know if and when you could provide a timely response.  

Any supporting information you provide to EPA will be made publicly 

available in the docket for the rulemaking, unless the information is 

claimed as Confidential Business Information (CBI). Therefore, if you 

submit any information that you claim as CBI, clearly mark all of the 

information that you claim to be CBI.  Information so marked will not be


disclosed, except in accordance with procedures set forth in 40 CFR part


2.  Please do not fax any information claimed as CBI.  For additional 

information on how to submit CBI, refer to page 29713, of the May 23, 

2006, Federal Register, proposed rule for academic laboratories, or 

contact LaShan Haynes, the Office of Solid Waste CBI contact, at (703) 

605-0516, Haynes.LaShan@epa.gov.

Again, thank you for your comments on the proposed standards for
academic 

laboratories.  Please direct any questions or response to this letter to


any member of EPA’s labs team:  

Patricia Mercer, (703) 308-8408, Mercer.Patricia@epa.gov

Meg McCarthy, (703) 308-8653, McCarthy.Meg@epa.gov

Kristin Fitzgerald, (703) 308-8286, Fitzgerald.Kristin@epa.gov

**************************************************************

Kristin Fitzgerald

US EPA - Office of Solid Waste

mail code:  5304P

phone:  703-308-8286

fax:  703-308-0522

email:  fitzgerald.kristin@epa.gov

work schedule:  Tuesday/Thursday

