Why are CESQGs allowed to participate in Subpart K when they were not included at proposal?
For the proposal, EPA believed that CESQGs would not want to participate in Subpart K because many of the provisions of Subpart K are more stringent than those to which they are currently subject. For example, CESQGs are currently not subject to the controls that apply to satellite accumulation areas and do not have to comply with the additional requirements applicable to LQGs and SQGs. However, commenters indicated that by allowing CESQGs to operate under this new set of regulations, EPA would be facilitating the creation of institution-wide hazardous waste management plans and systems at eligible academic entities.
