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RCRA Regulatory Interpretation Key Definition Issues for Labs

  1. “Operator in control of process”

  2. “At or near point of generation”

  3. WAA training requirements for researchers taking waste to 90-day area

  4. Unitary campus - “affiliates” operating on contiguous campus

  5. “Generator” entitled to rely on generator knowledge of waste

  6. Lab “waste water” vs. lab “waste”

  7. Experimental protocols as “treatment”

  8. Release reporting in labs

  9. Expired chemicals

  10. US/DOT Hazardous waste packaging - on-site roads with public access

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