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RE: Relief for Mixed Waste: Comments due 10/3/96




The October 3, 1996, deadline extension has already passed.  Is there a 
later date?

Thank you,

Bill Spell
bills@deq.state.la.us
 ----------
From: radsafe
To: Multiple recipients of list
Subject: Relief for Mixed Waste: Comments due 10/3/96
Date: Friday, September 27, 1996 3:25PM

     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