Kristin Fitzgerald/DC/USEPA/US 

12/20/2006 04:34 PM	To

	cindy@uic.edu

	cc

	

	bcc

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

Michael/DC/USEPA/US@EPA

	Subject

	Follow-up Question to UIC's Comment

	

	

Cynthia Klein-Banai

Assistant Director for Chemical Safety

University of Illinois at Chicago

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

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

of University of Illinois at Chicago (UIC).

In response to UIC’s comments (Docket Number 

EPA-HQ-RCRA-2003-0012-0154.1), 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 1 of UIC’s comments to the docket, you commented 

that, “This number does not appear to be accurate.  For instance,
[the] 

amount of hazardous waste generated by laboratories at UIC has averaged 

93% over the past seven years.  The average total amount of waste is 

74,000 lbs/yr, with 68,820 lbs being laboratory derived hazardous
waste.”  

EPA is very interested in any data that UIC 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 UIC’s waste generation.  EPA would
find 

it helpful if you could provide an explanation of the origins of the
data 

(e.g., what year are the data from, what is included/excluded in the 

categories of laboratory waste and hazardous waste), 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

