Comment submitted by J. Clark

james clark <clark3@CLEMSON.EDU> 07/27/2006 03:59 PM To: Group Rcra-Docket@EPA cc: Subject: Docket ID No. EPA-HQ-RCRA-2003-0012 The following is in response to EPA's request on p29722 of the 5/23/06 FR for comment on whether it would be appropriate to allow CESQG's to take advantage of the proposed regulatory incentives for conducting laboratory clean-outs. An annual laboratory clean-out which does not count toward determination of generator status is an excellent incentive for both SQG's and CESQG's. The need to provide an incentive for SQG's to eliminate "legacy" chemicals discussed on p29738 applies equally to CESQG's. Actually, the threat of changing generator status is an even greater barrier to clean-outs for the SQCEG as the change threshold is lower and the change impact far more severe. The proposed addition of para (c)(7) to 261.5 is wholeheartedly endorsed.