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July 2017 • The PCB Magazine 57 President of Creation Technol- ogies and Chair of the IPC GR Committee, said he has six facil- ities that all filed that they had reported zero pounds and they must do that every year. Goldman: That's a substantial cost. Abrams: He said he thinks that cost is much higher, that it's un- derestimated. In any case, as the administrator said, "So ev- ery year you do this to tell us ev- ery year that you release no pounds?" We said, "Yes." He noted that 100 pounds was a pret- ty low threshold. We said it used to be 25,000 pounds until EPA lowered it, and he asked what the basis was for that. Goldman: There was none. Abrams: Well, I think I might have gotten the quote of the day when I said "junk science." More accurately, it was inappropriate or manip- ulated science, but junk science just makes a much better sound bite. He said he'd look into that. Then Phil Titterton of TTM raised a third is- sue, which is the RCRA Hazardous Waste Gener- ators Rule. These are the requirements for com- panies that generate hazardous waste on their facility—often very small amounts. Most of our members are very small quantity generators or small generators. This was, I should say, a rule that was issued by EPA in November 2016 to consolidate 40 years of generator requirements that were here, there and everywhere in the reg- ulations. Most of the rule we like. It brings clar- ity. It's much easier to read. But in that reorga- nization EPA took many of what used to be re- quirements and put them as conditions of ex- clusion. Meaning, exclusion from treatment as the most serious of hazardous waste facilities, a hazardous waste treatment storage and disposal facility (TSDF), which requires an operating per- mit. This is a very serious thing. Goldman: That is serious. Abrams: Well, these are the com- panies normally that take in waste, store it, and treat it. Goldman: They're separate from generators, right? Abrams: They should be. How- ever, the way that this was or- ganized, if you fail any of these conditions of exclusion, you've violated your conditions and EPA can enforce against you as an illegal treatment, storage and disposal facili- ty that's not meeting all these things and is un- permitted. It could be as simple as the label on a drum. Instead of saying "Hazardous waste June 2017," maybe you said, "Waste/Hazardous." This is a very serious liability matter. We joined eight other trade associations in filing a suit against the EPA on this issue in January, but we would like very much not to litigate. We filed to preserve our legal options, but as we told the administrator yesterday, we would like very much to work with the EPA on a new rule that addresses just this small part of the rule. Those were the three issues that we raised during the meeting. The administrator [Scott Pruitt] was responsive on all of them and talk- ed for a bit. Goldman: Others said he made assignments to staff? Abrams: Just to look into it. That would be ac- curate. He talked a bit just about his perspective and added that you can have a business envi- ronment and still protect the environment. He talked a little bit about America's history and growth and how we've managed to grow and clean up the environment at the same time. It was just very refreshing. Goldman: What's next on the environmental front? IMPACT Interviews