Project XL Final Rule	Final Project Agreement Final Agreement XL Stakeholders Leighton Letter Regulatory Relief XL Rule	Legal Aspects RCRA and Labs LSEM RCRA interp Minimizing Costs Current Reg Arena UConn RCRA Workshop Yale RCRA Inspection	UVM XL Info Development of a Laboratory EMP Glassware Waste Project Waste Min Project Contacts and Info	RCRA LabWAM Priorities and Accomplishments Background Information Fixing RCRA (Powerpoint) Chemical Safety Levels Kids in Labs (Powerpoint) California Colorado Enforcement Region 1 Region 2 Region 3
The R&D NESHAP Development Process Clean Air Act
Pilot Schools' Draft EMP's	Boston College BC Plan BC Standards	UMASS Boston EMP Environmental Management Standard	University of Vermont EMP Lab Workers' FAQ's The Rule, UVM docs
Baseline Report	Informatics	Green Bridge	Websites	LabXL Home

APPENDIX 3

The following specific regulatory relief for laboratories is sought as a result of the temporary conditional deferral of waste determination as described in the text of the FPA.

The following fundamental regulatory relief is proposed:

Regulatory Relief Requested	Federal Citation	State Citation	Operative Effect of Relief Requested
Add the following new paragraph (j) to 262.10: (j) Universities that are participating in the Laboratory XL project are theUniversity of Massachusetts Boston in Boston, Massachusetts, Boston College in Boston, Massaschusetts, an dthe University of Vermont in Burlington, VT ("Universities"). The Universities generate laboratory wastes (as defined in 40 CFR 262.102) some of which may be hazardous wastes. As long as the Universities comply with all the requirements of 40 CFR part 262 subpart J, the Universities' laboratories which are participating in the Universties Laboratories XL Project are not subject to the provisions of 40 CFR 262.11, 262.34(c), 40 CFR Part 264, 40 CFR part 265 or the permit requirements of 40 CFR part 270 with respect to laboratory wastes.	40 CFR 262.10 "Purpose, Applicability and Scope"	VT "Purpose, Scope and Applicability" in 7-301. (A comparable addition to the general language in 7-301 would be required in the form of a rulemaking or a consent order or agreement) MA "Purpose, Scope and Applicability" in 30.301 (The State will address the applicability of 30.301 through an appropriate legal mechanism).	Allows the Universities to manage hazardous waste under the well defined scheme outlined in Subpart J as an alternative to managing the wastes under satellite storage requirements of 262.34(c). Management of laboratory wastes would be effectively managed and adequately regulated in accordance with the institutional EMP and be subject to specific minimum performance standards for the handling and management of laboratory wastes.
Hazardous Waste Determination	262.11 Hazardous Waste Determination	VT "Hazardous Waste Determination" listed in 7-202, 7-303, and 7-305(b) MA "When a Waste Becomes a Hazardous Waste" 30.302	Explicitly identifies the point where Universities will be responsible for making hazardous waste determination. Once laboratory wastes are received at the hazardous waste accumulation area, University staff would determine, in accordance with 262.11,, whether any solid waste is hazardous waste. This approach would be conditioned on the laboratory waste being managed in conformance with the EMP and minimum performance criteria up until the point it is received as at the hazardous waste accumulation area (or at the laboratory if sent to a TSD).
Satellite Accumulation	262.34 (c)(1)	VT 7-310 MA30.340(4)(c)(1-2) and SQG at 30.351(4)	Same or lower quantity thresholds maintained. Laboratory wastes are adequately regulated managed in accordance with the enforceable minimum performance criteria in the XL project.
Satellite Accumulation	262,34 (c)(2)	VT 70310(a)(7) MA 30.340(4)(c)(2) and SQG at 30.351(4)(d)	Minimum performance criteria that laboratories have 30 dats, once threshold is reached, to remove laboratory wastes to hazardous waste accumulation areas or TSD.
Satellite Accumulation		VT 7-310(c) MA 30.340(4)(c) and SQG at 30.351(4)(c)	Each institution's EMP defines the procedure(s) for management of containers of laboratory waste, but tere is a 55 gallon limit per laboratory and a 110 gallon limitation on the total amount of waste
Closed Container	265.173(a) as referenced by 262.34(c)(1)(i)	VT 7-310(a)(4) MA30.685(1) referenced from 30.340	Containers must be closed except when adding and removing waste and minimum performance criteria additionally define in line waste collection containers for laboratory scale experimentation as adding waste.