Requested Flexibility. This Agreement will function as an “umbrella FPA,” and does not describe any specific federal regulatory flexibility. Facility-, group- or media-specific addenda that describe case- specific agreements with any associated regulatory or policy flexibilities will be negotiated and signed separately, and will be attached to this umbrella FPA. Laboratories are highly diverse facilities that conduct a wide range of research activities. Some of these activities are subject to government regulation, including regulation by EPA. The following is a partial list of EPA regulations that apply to laboratories: . RCRA S Storage and disposal of hazardous wastes S Regulation of underground storage tanks . EPCRA S Emergency planning S Chemical reporting S Annual inventory reporting S Annual release reporting . CAAA S NAAQS for facilities located in nonattainment areas S New source review permits for new facilities or modifications existing facilities (nonattainment areas) S PSD permits for new facilities or modifications to existing facilities (attainment areas) S MACT standards for major air toxics sources S Title V operating permits S Risk management planning S Use of ozone-depleting substances . CWA S Pretreatment for discharge of process waters S Control of stormwater discharges S Oil spill control and countermeasure plans . TSCA S Premanufacture notification for new chemicals S PCBs in electrical equipment S Asbestos insulation and building products S Lead in drinking water systems S Metalworking fluids S Storage and disposal of hazardous wastes S Regulation of underground storage tanks At this point in the development of the Labs21 initiative, EPA has not analyzed any requests for regulatory flexibility under regulations affecting laboratories. The inclusion of this list with this FPA does not imply that EPA has evaluated any specific flexibility as part of this umbrella FPA, nor is it intended to constitute a formal start to granting or committing to grant specific waivers.
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