Meg McCarthy/DC/USEPA/US 

01/17/2007 03:06 PM	To

	jim.roewer@uswag.org

	cc

	

	bcc

	Patricia Mercer/DC/USEPA/US@EPA; Kristin Fitzgerald/DC/USEPA/US@EPA;
James 

Michael/DC/USEPA/US@EPA

	Subject

	Follow-up Questions on USWAG's Comment

	

	

Jim Roewer, Executive Director

Utilities Solid Waste Activities Group

c/o Edison Electric Institute

701 Pennsylvania Avenue, NW

Washington, DC  20004-2696

Dear Mr. Roewer:

 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 Utility Solid Waste Activities Group (USWAG).

In response to USWAG’s comments (Docket Number 

EPA-HQ-RCRA-2003-0012-0179), EPA has a few follow-up questions.  On page
2 

of USWAG’s comments you indicate that many of USWAG’s member
companies 

operate “utility laboratories” that would benefit from the
provisions in 

Subpart K, particularly the laboratory clean-out provisions.  EPA is
very 

interested in any information and data that USWAG can provide to give a 

clearer picture of how a utility laboratory functions.  For example, any


information or data describing these utility laboratories, their 

activities and their hazardous waste generation patterns would be 

beneficial to EPA in its development of the final rule.  Are these
utility 

laboratories conducting research?  Are they conducting quality checks or


tests?  Do their activities differ day-to-day or are they fairly routine


and/or repetitive?  What types of hazardous wastes are generated at
these 

utility laboratories?  In what amounts are these wastes generated?  EPA 

would find it helpful if you could provide any answers, explanations or 

data relating to any of the above questions.  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 February 16, 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

