May 31, 2016 
Memorandum to the Docket
From: Jim O'Leary
Subject: Telephone conversation with Tom Baker, Veolia ES Technical Solutions 
On April 14, or there about, I had a telephone conversation with Tom Baker, Senior Director, Environment and Transportation, Veolia North America, Industrial Business. The conversation focused on better understanding his comments on the Hazardous Waste Generator Improvements proposed rule. In particular, the discussion centered on the following:  
 Use of a bar code.  In our previous discussion on this subject, you mentioned that the bar coding system the waste management  industry uses  contains waste profile information sufficient for Veolia (or another waste management company) to effectively manage the hazardous waste that a Veolia facility receives. At issue is whether the bar code actually contains/identifies the RCRA waste codes that might appear on a container vs. waste profiling information that is equally equivalent to the RCRA waste codes in managing the waste effectively. In reading Veolia's and ETC's comments too, my understanding is that the bar coding system has equivalent information, or information sufficient to effectively treat the waste and meet LDRs, but not the actual RCRA waste codes because it isn't necessary. Right?
 Bulk and non-bulk shipments. As you know, our regs at  §262.32 associated with the marking of containers discusses what a generator must do before transporting HW off-site in terms of marking each container of 119 gallons or less, including marking the container with the words "Hazardous Waste." But what markings does the waste management industry use for bulk shipping, or shipments of hazardous waste over 119 gallons? If Veolia or another waste management company is accumulating or consolidating hazardous wastes in a rail car or a tanker truck at its facility, I'm assuming the words "Hazardous Waste" have to appear on that rail car or tanker truck. Right? But does Veolia remove the Hazardous Waste placard/label prior to shipping the waste to comply with DOT regs or does Veolia leave the Hazardous Waste marking on because it doesn't interfere with DOT regs and the actual removal of the words Hazardous Waste is simply an inconvenience Veolia has to live with? I'm assuming the rail car/tanker truck would have the necessary DOT hazard placard so that is not a problem. Right? I bring this up because some commenters were concerned that what we were proposing might interfere with DOT regulations and we are not going to do that. 
 Hazardous waste received from CESQGs by Veolia (and other waste management facilities). How does Veolia and other waste management facilities deal with CESQG wastes (or other hazardous wastes) that do not have to comply with RCRA marking and labeling requirements?  For example, CESQGs do not have to comply with §262.32 requirements but they have to comply with the applicable DOT regulations. What takes place between Veolia and a CESQG if the CESQG wants to have its hazardous waste managed by Veolia? I'm assuming Veolia first profiles the waste. Right? What happens once the waste arrives at the Veolia facility? Does Veolia mark the container with the words Hazardous Waste"? Mark the contents? Stick a waste profile bar code on the container? DOT hazard label on the container? 
  

