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New England Universities Laboratories
New England University Labs Proposal
Table 5: Summary of Regulatory Relief Sought for Component #2
Small-Scale Treatment of Laboratory Process Byproducts
The following general regulatory relief is proposed:
| Regulatory Relief Requested | Federal Citation | State Citation | Operative Effect of Relief Requested |
| In effect, to add an additional exclusion so that the hazardous waste treatment requirements do not apply to the small-scale treatment of laboratory process byproducts, by the generator of such byproducts, where the following requirements are met (insert minimum treatment criteria from Environmental Management Standard). | 264.1(g) 265.1(c) Purpose, Scope and Applicability |
30.501(2) | Small scale treatment of laboratory process products by generator is excluded from parts 264 and 265 and 310 CMR 30.500, 30.600, 30.800 and 30.900 |
Two general prohibitions (one from 40 CFR and one from 310 CMR 30 regulations) from which relief would be specifically sought are cited below. Because of the broad nature of this small-scale treatment exclusion, we have not, in the context of this proposal, described in detail all sections of parts 124, 264 and 265 and equivalent Massachusetts' regulations from which the University of Massachusetts would be exempt.
| Regulatory Requirement | Federal Citation | State Citation | Description of Regulatory Requirement | Description of Alternative Approach | Clarification or Relief |
| Generator Scope | 262.10 Note 2 | A generator who treats, stores or disposes of hazardous waste on-site must comply with the applicable standards and permit requirements set forth in 40 CFR parts 264, 265, 266, 268 and 270 | Small scale treatment of laboratory process byproducts would be exempt from these requirements under the exclusion granted at 264.1 (g) and 265.1 (c) | Relief | |
| Treatment Prohibition | 30.354(1) "For Those Who Treat, Store, Use or Dispose of Hazardous Waste at the Site of Generation" |
A generator who treats... hazardous waste at the site of generation shall comply with 310 CMR 30.001 through 30.099 and applicable provisions of 310 CMR 30.200, 30.500, 30.600, 30.800 and 30.900 with respect to those wastes. | Small scale treatment of laboratory process byproducts would be exempt from 310 CMR 30.500, 30.600, 30.800 and 30.900 under the exclusion granted at 30.501(2) | Relief |