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Solvent Contaminated Wipes Rule Frequent Questions
- Why did EPA publish a Notice of Data Availability and not a revised proposal?
The purpose of the NODA was to provide new information on the risk analysis and allow the public to comment. Commenters on the proposed rule focused their attention on the risk analysis and we wanted to provide the public with an opportunity to review changes to the risk analysis and offer additional comments.
- Why did EPA revise the risk analysis?
We revised the risk analysis because we received numerous comments during the proposal comment period expressing concern with the methodology used for the previous analysis and the parameters that we used in the analysis. We reviewed the comments and incorporated them as appropriate into the new risk analysis.
- What are the results of the new risk analysis?
The risk analysis showed that most of the F001-F005 listed solvents would pose little to no risk if the wipes and laundry sludge were disposed in lined landfills. A few solvents did show a potential for risk in unlined landfills. We will decide the right procedures for managing the solvent-contaminated wipes and laundry sludges in the final rule.
Was the new risk analysis peer reviewed? If so, how did you address the reviewers' comments?
Four external experts reviewed the analysis. The peer reviewers were Dr. C. David Cooper, University of Central Florida, Dr. Dale Hattis, Clark University, Dr. S. Ranji Ranjithan, North Carolina State, and Dr. Timothy Townsend, University of Florida. Each expert had a different area of expertise, which we believe provided us with a thorough review. We reevaluated the risk analysis based on the reviewers' comments and changed the analysis where necessary and appropriate. The response- to-comments document discusses changes to the analysis based on the peer reviews.
- How does this analysis differ from the one used to support the proposed wipes rule?
For this analysis, we used models specifically developed to estimate risk in municipal solid waste landfills. Due to a finding by the Science Advisory Board on our existing landfill model, it was necessary for us to develop a new landfill model to more accurately measure risk in a municipal solid waste landfill. We also updated the information where new information was available and incorporated the comments from the proposal as appropriate.
- Have you made a decision on how the solvent-contaminated wipes and laundry sludge will be managed?
We have not made a final decision on how the solvent-contaminated wipes and laundry sludge will be managed. We want to review the comments we receive from the NODA before making that decision. If appropriate, we may make changes to the risk analysis based on comments received from the NODA. The risk analysis is an important supporting document for developing management conditions for the wipes and sludge.
- When will the final wipes rule be published?
Revising the risk analysis and publishing a NODA has delayed final rule promulgation. The complexity of the responses received on the NODA will determine how much longer it will take before we can finish the rule.
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