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Relief for Mixed Waste: Comments due 10/3/96
Colleagues,
Please, consider submitting a comment on EPA Permit Improvement Team's
(PIT) Concept Paper. The comment deadline has been extended to
October 3, 1996. PIT recommendations may relieve some of the regulatory
problems of managing mixed waste.
Thank you,
Peter A. Reinhardt
Assistant Director, Chemical & Environmental Safety
University of Wisconsin-Madison Safety Department
30 N. Murray St., Madison, WI 53115-2609
608/262-9735 FAX: 608/262-6767
peter.reinhardt@mail.admin.wisc.edu
......................................................
Some of the PIT recommendations are:
1. To establish a general boilerplate permit and promote the use of
general permits for non-commercial storage or treatment facilities,
including, for example, laboratories.
Note that EPA requires a permit for DIS storage of mixed waste for >90
days if you are a large quantity generator. Treatment is a solution for
some mixed waste, but EPA requires a costly permit. A general permit
would likely make EPA permitting much easier.
2. Extend the generator storage time frames from 90 to 270 days for
laboratories as part of regulatory invention.
This would allow DIS without a permit for very short half-lived laboratory
mixed waste. This would also allow laboratories to reduce pickup costs for
very small shipments of mixed waste.
A DRAFT of the University of Wisconsin-Madison comments follows:
The University of Wisconsin Madison (University) submits the following
comments in strong support of the U.S. Environmental Protection Agency
(EPA) Permits Improvement Team's (PIT) recommendations in the "Concept
Paper on Environmental Permitting and Task Force Recommendations." This
letter is in response to EPA's request for comments published in the 19
July 1996 Federal Register (61 FR 37744). On 11 September, EPA extended
the comment period until 3 October (61 FR 47931).
Summary of UW-Madison Comments
We very strongly support the following Task Force recommendations for the
RCRA Base Permit Program. We are very pleased that the recommendations
specifically address laboratories. These changes would improve waste
management efficiency, promote recycling, reuse and reclamation, and reduce
risks to health and the environment. A detailed explanation of our comments
follows this summary:
-- We support EPA's objective of making environmental permitting more
efficient and based on performance.
-- We support EPA's recommendation to extend the generator storage time
frames from 90 to 270 days for laboratories as part of regulatory
re-invention.
-- We support EPA's recommendation for general (boilerplate) permits for
non commercial storage, especially for laboratories.
-- We support EPA's recommendation for general permits for non commercial
treatment, especially for laboratory waste.
-- We urge EPA to consider conditional exemptions for generator storage
of laboratory waste when there are no available commercial disposal
options and when short half-life mixed waste is held in an NRC approved
decay-in-storage program. A conditional or de minimis exemption should be
provided for very small scale treatment of laboratory waste.
-- We ask that EPA allow generators of laboratory waste to utilize any
new extensions, general permits and conditional exemptions at the
generator's accumulation or storage facility. To be truly beneficial, the
changes should pertain to laboratory waste and not limited to a laboratory
in which the waste is generated.
-- We urge EPA to take this opportunity to clarify or provide guidance to
allow treatment without a permit as part of a laboratory process, at the
end of an experiment, and in containers in satellite accumulation areas.
EPA also needs to clarify that radioactive decay of mixed waste is not
treatment.
..................................................................
The concept paper on Environmental Permitting and Task Force
Recommendations is available for downloading from the Web at:
http://www.epa.gov/docs/OSWRCRA/hazwaste/permit/pit/pitdoc.txt.html
or within the http://www.epa.gov/ perform a search on Permit Improvement
team.
EPA Contact:
Lance Miller 908-321-6782, 609-292-1909, or e-mail:
miller.lance@epamail.epa.gov
.........................................................
[Federal Register: July 19, 1996 (Volume 61, Number 140)] [Notices]
[Page 37744]
------------------------------------------------------------
ENVIRONMENTAL PROTECTION AGENCY
[FRL-5536-4]
Notice of Availability of Permits Improvement Team; Concept Paper
on Environmental Permitting and Task Force Recommendations; Final Draft
Recommendation
ACTION: Notice of availability and request for comments.
---------------------------------------------------------------
SUMMARY: This notice announces the availability of the document ``Concept
Paper on Environmental Permitting and Task Force Recommendations'' and the
Agency's request for stakeholder comment. As part of the Administration's
program to ``Reinvent Environmental Regulation,'' the U.S. Environmental
Protection Agency created a Permits Improvement Team (PIT) to evaluate the
Agency's permitting programs, those administered by states, tribes and
local agencies and those administered directly by EPA, and to develop
recommendations to improve the effectiveness and efficiency of the
permitting process.
DATES: Written comments must be postmarked or submitted by hand or
electronically by no later than September 3, 1996. Due to the previous
stakeholder involvement in the development of the PIT recommendations,
including the recent (May 10, 1996) Federal Register notice, this comment
period will not be extended. Thus, this is the final opportunity for public
comment on these recommendations.
ADDRESSES: Send an original and two copies of the comments to Docket Number
F-96-PT2A-FFFFF, located at the RCRA Docket.
Official mailing address is:
RCRA Information Center
U.S. Environmental Protection Agency (5035W)
401 M Street, S.W.
Washington, D.C. 20460
Note: The mailing address for the RCRA Information Center has not changed,
however, the office moved in November 1995. Therefore, hand-delivered
comments should be taken to the new address:
1235 Jefferson Davis Highway
First Floor
Arlington, Virginia
Please, refer to section ``Supplementary Information'' regarding the
paperless office effort for submitting public comments.
FOR FURTHER INFORMATION CONTACT: Lance Miller, PIT Executive Director at
Permits Improvement Team, Mail Stop 100, 2890 Woodbridge Ave., Edison NJ
08837, phone: (908) 321-6782.
SUPPLEMENTARY INFORMATION:
Availability of Document
The PIT Concept Paper on Environmental Permitting and Task Force
Recommendations follows this notice. In addition, the document can be
obtained via the internet at `gopher://gopher.epa.gov' or `http://
www.epa.gov'. After reaching either of these internet sites, locate the
search function and type `Permit Improvement Team' to locate the Concept
Paper on Environmental Permitting and Task Force Recommendations.
Background Information
The PIT was established in July 1994 and is composed of
representatives from EPA Headquarters and Regional offices and state,
tribal and local permitting agencies. The PIT held numerous stakeholder
meetings to solicit input on the most critical permitting issues as well as
to obtain feedback on the PIT's initial recommendations.
Although significant input on the PIT's recommendations has been
received through the stakeholder meetings, a final opportunity to review
and comment on the recommendations is being provided to ensure that all
stakeholders have an opportunity to participate in the development of the
significant change in direction for permitting programs that is being
contemplated. The Agency intends to use the concept paper on environmental
permitting as an overall guide for reforms to permit programs, where
appropriate. The individual recommendations contained in the document will
be considered by program and regional offices as they develop specific
plans in response to the concepts discussed in the PIT recommendations.
These plans will include providing assistance to states and tribes that
choose to consider and implement appropriate permit reform. As specific
program changes are developed, opportunities for stakeholder input will be
provided. It is anticipated that stakeholders will use the final concept
paper, as well as other relevant documents and authorities such as
applicable statutes, in their review of specific permit program changes.
This will help to provide all stakeholders with a common context when
commenting on these specific changes.
For some permitting programs, minor changes may be needed to
implement many of the concepts specified in the document; while other
programs may require more significant modifications. Some of these
modifications may also require changes to statutes and regulations and
could necessitate technical research and analysis prior to revising permit
programs to conform with the recommendations. Therefore, the time-frame to
implement the recommendations could range from several months to many
years. The Agency notes that current permitting system were developed over
the last three decades, and that changes need to be made within the
existing systems while they evolve to the approach envisioned in the
concept paper. Furthermore, as implementation proceeds, it is likely that
some of the concepts will require revision based on new information.
Paperless Office Effort
EPA is asking prospective commenters to voluntarily submit one
additional copy of their comments on labeled personal computer diskettes in
ASCII (TEXT) format or a word processing format that can be converted to
ACSII (TEXT). It is essential to specify on the disk label the word
processing software and version/edition as well as the commenter's name.
This will allow EPA to convert the comments into one of the word processing
formats utilized by the Agency. Please use mailing envelopes designed to
physically protect the submitted diskettes. EPA emphasizes that submission
of comments on diskettes is not mandatory, nor will it result in any
advantage or disadvantage to any commenter. Rather, EPA is experimenting
with this procedure as an attempt to expedite our internal review and
response to comments. This expedited procedure is in conjunction with the
Agency ``Paperless Office'' campaign.
Elliott P. Laws,
Designated Federal Official.
[FR Doc. 96-18196 Filed 7-18-96; 8:45 am] BILLING CODE 6560-50-M