From: rota.ken**At_Symbol_Here**epamail.epa.gov [mailto:rota.ken**At_Symbol_Here**epamail.epa.gov] 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 regulations. http://www.epa.gov 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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