Date: Fri, 9 Apr 2004 09:29:20 -0400
Reply-To: Ralph Stuart <rstuart**At_Symbol_Here**>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Ralph Stuart <rstuart**At_Symbol_Here**>
Subject: HW Generator Initiative

From: rota.ken**At_Symbol_Here** [mailto:rota.ken**At_Symbol_Here**]
Sent: Thursday, April 08, 2004 7:16 AM
Re:   HW Generator Initiative

I want to make you aware of a public meeting EPA intends to hold on
May 4, 2004 from 9:00 am to 5:00 pm at the Tip O'Neil Building in
downtown Boston, Massachusetts to obtain input from its many
stakeholders on the effectiveness of the Resource Conservation and
Recovery Act's (RCRA's) hazardous waste generator regulatory program.
I will send you a copy of the Federal Notice announcing the public
meeting as soon as it is published. I've also attached a copy of the
draft agenda for your information.

By way of background, the Agency promulgated regulations in 1980
applicable to generators of hazardous waste.  These regulations were
amended in 1986 to address small quantity generators and again in the
late 1980's and early 1990's to address land disposal restrictions
and air emission control requirements for generators, respectively.
These regulations are found at 40 CFR Part 261.5 and 40 CFR Part 262.
These regulations establish procedures and requirements for the
management of hazardous waste on-site and off-site for both large and
small quantity generators (LQGs and SQGs), as well as conditionally
exempt small quantity generators (CESQGs).

The implementation of the generator regulations have played a major
role in ensuring that hazardous waste has been properly managed.
However, during the twenty years since their implementation,
generators complying with the regulations, and States implementing
the hazardous waste program, have developed a great deal of
experience with this program.  These experiences have been both
positive and challenging. On the positive side, they include
thousands of generators instituting programs that successfully
prevent spills and accidents and ensure the safe management of
hazardous waste. They also include EPA and the States developing
effective training, compliance and technical assistance programs that
support hazardous waste generators.

These successes, however,  have not come without challenges.
Stakeholders tell us that they find the RCRA hazardous waste
regulatory program to be very complex. Some generators believe the
regulations are confusing. This may be particularly true for small
businesses who often do not have the in-house capabilities or
resources to devote to understanding and complying with the hazardous
waste regulations.  In other cases, EPA has heard that some hazardous
waste generator regulations duplicate other federal regulations. Some
stakeholders, conversely, are concerned that gaps may exist in the
current regulations that could impede the safe management of
hazardous waste.

With these challenges as background, the objective of this public
meeting is to collect pertinent information from key stakeholders
that will allow EPA to evaluate the effectiveness of the hazardous
waste generator regulatory program and to determine if changes to the
program are necessary. If so, EPA will develop and implement a
hazardous waste generator program strategy with the goals of
fostering improved program effectiveness, fostering a pollution
prevention stewardship philosophy, and reducing compliance cost,
where practicable. (Note: This effort focuses only on those generator
regulations in 40 CFR Parts 261.5 and 262, and those management
requirements in 40 CFR Part 265 referenced in those generator

We are not addressing issues associated with the definition of solid
waste, hazardous waste identification regulations associated with
listings and characteristics, or export provisions.)

Ken R.

Kenneth B. Rota, Chief RCRA Compliance Unit US EPA - New England
Region 1 Congress Street, Suite 1100 Boston, MA 02114-2023

Direct Tel: (617) 918-1751 Office Fax: (617) 918-1809

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