HWIR Status

[Ronald_A_Del_Mar@rl.gov]

     Does anybody know the status of the proposed Hazardous Waste 
     Identification Rule (HWIR) amendement to 40 CFR 261.  Is this ever 
     going to become law?
     
     The reason I ask is that the proposed rule makes several statements 
     that the proposed "risk-based" hazardous waste listing process is 
     supposed to "encourage pollution prevention and waste minimization."  
     I guess it depends on your definition of pollution prevention, but I 
     fail to see how the HWIR would encourage pollution prevention.  I 
     don't consider changing the regulatory status of a waste to be 
     "pollution prevention."  Is there something in here that I am missing? 
     
     I am putting together a justification section for a pollution 
     prevention program as part of an overall project proposal. In addition 
     to things like potential costs savings, environmental benefits, and 
     reducing a companies regulatory burden and liability, I am trying to 
     look at all of the regulatory drivers for having a pollution 
     prevention program. Somebody suggested I look at the HWIR. I guess I'm 
     having trouble seeing how the HWIR (if adopted) would provide any 
     extra regulatory incentive for having a pollution prevention program 
     that is not already in RCRA (i.e., required certifying statements on 
     manifests, biannual/annual reports, and TSD permit applications).  Can 
     anybody shed light on this?
     
     Ron Del Mar
     Fluor Daniel Northwest
     (509) 376-1967
     ronald_a_del_mar@rl.gov