Kristin Fitzgerald/DC/USEPA/US 

12/20/2006 05:37 PM	To

	kav@u.washington.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 UW's Comment

	

	

Karen VanDusen

Director, Environmental Health and Safety

University of Washington

 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 University of Washington (UW).

In response to UW’s comments (Docket Number
EPA-HQ-RCRA-2003-0012-0144.1), 

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 UW’s comments to the docket, you commented
that, 

“The University of Washington is a LQG, and laboratory waste at this 

institution represents approximately 65% of our annual hazardous waste 

generation, based on 2004 data analysis.”  EPA is very interested in
any 

additional data that University of Washington 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 University of Washington’s waste 

generation.  EPA would find it helpful if you could provide an
explanation 

of the origins of the data (e.g., 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

