Delisting Hazardous Wastes Under RCRA: A Response to Compton and Patterson
In their article Delisting Hazardous Wastes—Do the RCRA Amendments Spell Relief?1 Ms. Compton and Mr. Patterson discuss the Environmental Protection Agency's (EPA's) rules for delisting hazardous wastes under the Resource Conservation and Recovery Act (RCRA),2 the Agency's implementation of these rules, and the recent statutory amendments dealing with delistings. Working at EPA, my biases naturally differ from those of the authors. Acknowledging these biases, I nevertheless believe that their article contains a number of mischaracterizations about the Agency's rules and actions. I also think that they have misread parts of the new statute. In some cases the misreadings are serious. I would like to describe briefly EPA's delisting rules and actions to date, summarize my view of the 1984 RCRA amendments on delisting, and give my views on future Agency actions in this area—responding to Ms. Compton and Mr. Patterson along the way when appropriate. My views are necessarily my own, and are not statements of EPA policy.