BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CERTIFICATE OF SERVICE

ABC RECYCLING COMPANY

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

PROPOSED

AMENDMENTS TO THE

BOARD'S SPECIAL WASTE

REGULATIONS CONCERNING

USED OIL, 35 ILL. ADM. CODE 808, 809

)

R06-20

(Rulemaking -Land)

NOTICE OF FILING

Dorothy Gunn, Clerk

of the Board

Illinois Pollution Control Board

James R. Thompson Center

100 W. Randolph, Suite 11-500

Chicago, Illinois 60601

(ELECTRONIC FILING)

Matthew

J. Dunn

Environmental Bureau

Chief

Office of the Attorney General

Environmental Bureau North

69 West Washington Street,

Suite1800

Chicago, Illinois 60602

Claire A. Manning

Brown,

Hay & Stephens, LLP

700

First Mercantile Bank Building

205 South Fifth St., P.O. Box 2459

Springfield, Illinois

62705-2459

William Richardson, Chief Legal Counsel

Office of Legal Counsel

Illinois Dept.

of Natural Resources

One Natural Resources Way

Springfield, Illinois 62702-1271

Tim Fox, Hearing Officer

Illinois Pollution Control Board

James

Thompson Center

100 W. Randolph St.

Suite 11-500

Chicago, Illinois 60601

Deirdre

Hirner, Executive Director

Illinois Environmental Regulatory Group

3150 Roland Avenue

Springfield, Illinois

62703

PLEASE

TAKE NOTICE that I have today filed with the Office ofthe Clerk ofthe

Illinois Pollution Control Board the ILLINOIS ENVIRONMENTAL PROTECTION AGENCY'S

RESPONSE TO NORA'S COMMENTS,

a copy of which is herewith served upon you.

DATE:

/-/

-() '1

1021 North Grand Avenue East

P.O. Box 19276

Springfield, lllinois 62794-9276

(217) 782-5544

ILLINOIS ENVIRONMENTAL PROTECTION

AGENCY

~?;1:~._

By:

~11~

. teph ie Flowers

Assistant Counsel

Division

of Legal Counsel

Electronic filing - Received, Clerk's Office, January 14, 2009

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

PROPOSED

AMENDMENTS TO THE

BOARD'S SPECIAL WASTE

REGULATIONS CONCERNING

USED OIL, 35 ILL. ADM. CODE 808, 809

)

R06-20

(Rulemaking -Land)

THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY'S

RESPONSE

TO NORA'S COMMENTS

NOW COMES the Illinois Environmental Protection Agency ("Illinois EPA"), by and

through one

of its attorneys, Stephanie Flowers, and respectfully submits the following in

response to the Additional Comments

of NORA filed with the Illinois Pollution Control Board

("Board") by the Association of Responsible Recyclers ("NORA") in the above-entitled matter

on December 15,2008.

NORA'S GENERAL COMMENTS

NORA comments that the Illinois EPA provided no substantive response to a letter from

Ms. Manning dated April 2,

2008 and that the Illinois EPA has not approached NORA at

any time since the

October 1, 2008 hearing. In response the Illinois EPA would like to

state that

NORA has also not contacted the Illinois EPA since the October 1, 2008

hearing, although neither party was required to contact the other. In addition, please see

Attachment

#1 which is a letter dated April 23, 2008 from Illinois EPA responding to the

April 2,

2008 letter from Ms. Manning.

NORA comments that the Illinois EPA requires manifesting of nonhazardous waste but

does not have the manifests sent to the Illinois

EPA headquarters and also that use of a

hazardous waste manifest for shipments

of non-hazardous materials misrepresents the

Electronic filing - Received, Clerk's Office, January 14, 2009

* * * * * PC # 74 * * * * *

material to those who come in contact with the shipments.

response the Illinois EPA

would like to state that this is a statutorily designed system with the Illinois legislature at

Section 22.01 of the Illinois Environmental Act requiring manifests of non-hazardous

materials to be identical to manifests required for the shipment

of hazardous waste but

also stating that generators are not required to submit copies

of non-hazardous special

waste manifests to the Illinois EPA.

NORA comments that Illinois regulations should be in congruence with the federal

regulations and the regulations

of states adjacent to Illinois. However, Illinois is allowed

to and has chosen to regulate special waste in a more stringent manner than the federal

government.

If NORA believes that Illinois should abandon its special waste regulations

to correspond with other states then the Illinois EP A believes that argument should be

discussed clearly and should not be hidden in the discussion

of a manifest exemption for

used oil.

NORA comments that its proposed shipping paper would allow (1) the Illinois EPA

required information, (2) the

USDOT required information, and (3) any business

information used

by the transporter. However, in previous comments the Illinois EPA

has pointed out that both the Illinois EPA required information and the

USDOT required

information are satisfied

by the use of a manifest. Therefore Illinois EPA would like to

note that it is the transporters business information that

NORA wishes to be included on a

shipping paper and which requires duplicative paperwork. Furthermore, a comparison

between

NORA's form submitted at the October 1,2008 hearing and the uniform non-

hazardous waste manifest required

by the Illinois EPA (see Attachment #2 and #3) shows

Electronic filing - Received, Clerk's Office, January 14, 2009

very little difference between the two fonns. Much ofthe additional infonnation

included on

NORA's fonn may fit on the unifonn non-hazardous waste manifest.

NORA comments that its proposal does not affect any substantive requirements and that

its proposal would be protective

of human health and the environment because generators

and transporters would not have to focus

on duplicative and expensive paperwork. In

response the Illinois EP A would like to point out that the same paperwork would be

required for

NORA's shipping paper as for the unifonn non-hazardo.us waste manifest

since there is very little difference between the two fonns. Duplicative paperwork could

be reduced

by adding the additional business infonnation in the available space on the

manifest.

In fact, the Illinois EPA believes that NORA's proposal would increase the

paperwork required for the used oil industry because

of the need of the generator to

document compliance with the

50% by volume used oil mixtures, the 5,000 BTU used oil

mixtures, and the recoverable quantities used oil mixtures included in

NORA's proposal.

Therefore, Illinois EPA believes that

NORA's true intent is not reduction of paperwork

but relaxation

of the special waste regulations to allow certain mixtures of used oil and

other special waste to

be received by used oil facilities that are not pennitted to take

special waste. This is a substantive request. Furthennore,

NORA proposes to allow

transporters to use their own tracking system for any waste that has been mixed with used

oil, but the Illinois EPA believes that it is the generator, not the transporter, who would

have the best knowledge

of what waste was added to a used oil and other special waste

mixture and that therefore the generator would

be the person best suited to initiate a

document that tracks the movement

of the mixture and notifies the receiving facility of

the other materials mixed with the used oil.

Electronic filing - Received, Clerk's Office, January 14, 2009

* * * * * PC # 74 * * * * *

6 NORA comments that its proposal is a compromise that the Illinois EPA has not

supported. However, the Illinois

EPA has supported a manifest and hauling permit

exemption for used oil as defined in Part 739. The Illinois

EPA cannot support a

manifest exemption for mixtures

of used oil and other special waste that should be

received only at a properly permitted special waste facility. The Illinois EPA believes the

best system is for a shipment that is only used oil, the used oil tracking requirements

apply,

but if the shipment also contains some other special waste, the generator initiates a

manifest to alert the transporter and receiving facility that other special waste has been

mixed with the used oil. For this reason, the Illinois

EPA recommends that the Board

adopt the language

of its first notice proposal.

NORA'S PROPOSED LANGUAGE

The Illinois

EPA's concern is that NORA has proposed an exemption that goes beyond

the original manifest exemption. The following language in

NORA's proposal exempts

used oil from Parts 808 and 809 and also other special wastes that

may be subject to the

management requirements under Part 739 solely because they are mixed with used oil:

"4) Used oil and the following post use mixtures are subject to regulation

as used oil under this Part, and are exempt from 35 Ill. Adm. Code 808

and

809:"

The language in the proposal would exempt used oil and materials subject to regulation

under Part 739 from the definition

of special waste and the special waste management

requirements including the reporting requirements. However please see Section 2(b) at

the following website, http://www.epa.gov/osw/conserve/materials/usedoil/support.htm.

wherein

USEP A found that the reporting requirements for used oil were essential stating,

Electronic filing - Received, Clerk's Office, January 14, 2009

"The biennial reports will help EPA develop Phase II management

standards that

may include incentives for encouraging DIY -generated

(do-it- yourself) used oil recycling and/or more stringent management

standards for a particular form

of recycling. The biennial reports also help

the Agency monitor the flow and disposition

of used oil and allow the

Agency to assess the relative amounts

of used oil that are recycled in

different

manners."

Furthermore, exempting wastes subject to regulation under Part 739 from Parts 808 and

809 would require the

establishmen~

of a second reporting system to satisfy the

requirements

of Section 739. 157(b). The reporting requirements of Section 739.157(b)

are currently

met by satisfying the reporting requirements in Subpart E of Part 809.

Therefore, the Illinois EPA believes that used oil and other wastes subject to regulation

under Part 739 should remain special wastes subject to the reporting requirements and

should not

be exempt from Parts 808 and 809.

The Illinois EPA also has concerns regarding the following language in NORA's

proposal regarding de minimis or recoverable amounts of used oil in wastewater:

"B)Nonhazardous waste water contaminated by or mixed with used oil, both

generated

by the same generator and which contain more than a de minimis

(recoverable) quantity

of used oil."

The amount of oil that would be considered recoverable varies from facility to facility

depending on the types

of processes and efficiency of each component of the treatment

system. (See

October 1, 2008 Hearing Transcript Page 85 Line 17 through Page 87 Line

4 and Page 164 Lines 4-15). Based on

NORA's testimony the generator may know the

facility where the oil is bulked but the treatment facility

may change depending on

characteristics of the oil mixture and price of treatment. Some systems that would receive

the waste water are not used oil treatment units,

but waste water treatment units that use

chemical and biological methods to treat the water to meet discharge standards. The

Illinois

EPA's concern is that since the generator may not know the end facility that

Electronic filing - Received, Clerk's Office, January 14, 2009

* * * * * PC # 74 * * * * *

receives the used oil and wastewater mixture, the generator would not be able to

determine

if the wastewater had recoverable amounts of used oil and therefore the

generator could not determine

if the waste was exempt from manifesting requirements

under the manifest exemption language proposed

by NORA.

With the proposed

Parts 739.124 and 739. 146(a)(6), Illinois EPA's concern is that NORA

proposes tracking requirements that call for

th~

"classification" and "description" of the

non used oil materials but does not define these terms.

The Illinois

EPA is concerned with language at proposed Part 739. 146(a)(6) requiring the

use of a Part 809 special waste manifest for hazardous waste when hazardous waste is

subject to the uniform hazardous waste manifest requirements.

The Illinois EPA is also concerned with the language at proposed Part 739. 146(b)(6)

which references an ASTM specification but does not fully identify or incorporate a

specific ASTM specification.

Because

of the reasons specified above the Illinois EPA recommends that the Board proceed to

adopt its first notice proposal.

DATED:

1021 North Grand

Avenue

/ '-/-

East

P.O. Box 19276

Springfield, Illinois 62794-9276

(217) 782-5544

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

BY;kt~~

Assistant Counsel

Division

of Legal Counsel

Electronic filing - Received, Clerk's Office, January 14, 2009

CERTIFICATE OF SERVICE

I, STEPHANIE FLOWERS, an attorney, do certify that I filed electronically with the

Office of the Clerk of the Illinois Pollution Control Board the ILLINOIS ENVIRONMENTAL

PROTECTION

AGENCY'S RESPONSE TO NORA'S COMMENTS and will cause the same

be served upon the following persons, by placing a true and correct copy in an envelope

addressed to:

Dorothy Gunn, Clerk

of the Board

Illinois Pollution Control Board

James

R. Thompson Center

100 W. Randolph, Suite 11-500

Chicago, Illinois 60601

Matthew J. Dunn

Environmental Bureau

Chief

Office of the Attorney General

Environmental Bureau North

69 West Washington Street, Suite

1800

Chicago, Illinois 60602

Claire A. Manning

Brown,

Hay

Stephens, LLP

700

First Mercantile Bank Building

205 South Fifth St., P.O. Box 2459

Springfield, Illinois 62705-2459

William Richardson,

Chief Legal Counsel

Office of Legal Counsel

Illinois Dept.

of Natural Resources

One Natural Resources Way

Springfield, Illinois 62702-1271

Tim Fox, Hearing

Officer

Illinois Pollution Control Board

James

R. Thompson Center

100 W. Randolph St.

Suite 11-500

Chicago, Illinois 60601

Deirdre

Himer, Executive Director

Illinois Environmental Regulatory Group

215 East Adams Street

Springfield, Illinois 62701

and mailing it

by First Class Mail from Springfield, Illinois on January 14, 2009 with sufficient

postage affixed.

DATED:

1021 North Grand Avenue East

P.O. Box 19276

Springfield, Illinois 62794-9276

(217) 782-5544

S'TEPH

Q{~J-~

IE FLOWERS

Electronic filing - Received, Clerk's Office, January 14, 2009

* * * * * PC # 74 * * * * *

.,,,

~LLlNOIS

!ENVIRONMENTAL PROTECTION AGENCY

(ofj

====================FF='==~===='======================

1021 NORTH GRAND AVENUE EAST, P.O. Box 19276, SPRINGFIELD, ILLINOIS 62794-9276 - ( 217) 782-3397

JAMES R. THOMPSON CENTER, 100 WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60601

'(312) 814-6026

ROD R. BLAGOJEVICH, GOVERNOR

DOUGLAS

SCOTT, DIRECTOR

April 23,2008

Claire A. Manning, Esq.

Brown,

Hay

Stephens, LLP

205 S.

Fifth Street, Suite 700

P.o. Box 2459

Springfield, Illinois 62705-2459

Dear Ms. Manning:

The Illinois Environmental Protection Agency ("IEPA") has reviewed your letter

received

by the IEPA on April 3, 2008 requesting further negotiation of amendments to

the special waste regulations regarding an exemption for used oil from manifests

and

hauler permits. With regard to the proposed "Mixtures not subject to Illinois Special

Waste

Manifesting" set forth on the attachment to the letter the IEP A states the

following:

(1) Small Quantity Hazardous Waste - The

IEPA's position is that small quantity

hazardous waste must

be manifested pursuant to Part 809 even if mixed with used oil. If

mixed with used oil small quantity hazardous waste may also be subject to the used oil

regulations at

Part 739.

(2) Materials containing

or otherwise contaminated by used oil - The IEP A's position is

that materials containing or otherwise contaminated

by used oil must be manifested

pursuant to

Part 809 even if mixed with used oiL If mixed with used oil these materials

may also be subject to the used oil regulations at Part 739. Regarding NORA's

suggestion of setting a BTU value for manifest exemption, the IEP A believes this would

create the need for a regulatory program that would

be more burdensome than

manifesting.

(3) Mixtures of Used Oil and Fuels - The IEPA's position is that fuels in used oil are not

a special waste because they are presumed to

be going for burning (the original intended

use) and are therefore not disposed. Fuels would not

be subj ect to special waste

manifesting

but would be subject to Part 739 when mixed with used oil. However, fuel

and used oil going to

be disposed (including incineration) would be subject to other

regulations and not

Part 739.

(4) Nonhazardous Wastewater Mixed

with Used Oil - The IEPA's position is that

wastewater that is mixed with used oil through use

or unintentional contamination during

ROCKFORD - 4302 North Main Stree't, Rockford, IL 611 03 - (815) 987.7760 0

DES PLAINES - 9511 W. Harrison St., Des Plaines, IL 60016 - (847) 294-4000

ELGIN - 595 South State, Elgin, IL 60123 - (847) 608-3131

PEORIA - 5415 N. University St., Peoria, IL 61614 - (309) 693-5463

BUREAU OF LAND - PEORIA - 7620 N. University St., Peoria, IL 61614 - (309) 693-5462

CHAMPAIGN - 2125 Sooth First Street, Champaign, IL 61820 - (217) 278-5800

SPRINGFIELD -

4500~.

Sixth Street Rd., Springfield, IL 62706 - (217) 786-6892

COLLINSVILLE - 2009 Mall Street, Collinsville, IL 62234 - (618) 346-5120

MARION - 2309 W. Main St., Suite 116, Marion, IL 61959 - (618) 993-7200

PRINTED ON RECYCLED PAI'E/l

Electronic filing - Received, Clerk's Office, January 14, 2009

* * * * * PC # 74 * * * * *

collection or storage by the generator is subject to Part 739 and should be allowed a

special waste manifesting exemption. However, the

IEP A believes that there are possibly

only two scenarios where a special waste manifesting exemption would apply.

One is

cutting fluids that contain a lot

of water and the second is used oil that contains water due

to storage contamination. All other wastewater requires a special waste manifest

pursuant to

Part 809 and may also be subject to the used oil regulations at Part 739 when

mixed with used oil.

Based on the foregoing comments the

IEPA cannot support NORA's proposed

amendments set forth in the letter. The

IEP A comments were based on the proposed

amendments as written. The

IEP A reserves the right to offer additional comments should

any proposed amendments be submitted

to the Illinois Pollution Control Board. If you

have any further questions or concerns, please feel free to contact me

by phone at 217-

782-6494 or

by email at stephanie.flowers@illinois.gov.

Sincerely,

Stephanie Flowers

Assistant Counsel

Division

of Legal Counsel

Illinois Environmental

Protection Agency

cc: Ted Dragovich

Electronic filing - Received, Clerk's Office, January 14, 2009

* * * * * PC # 74 * * * * *

~ervlce

Kecelpt

l~O.

UUUUU

UIIU:; __ , __ , __

ABC RECYCLING COMPANY

Generator ID No.:

Generator:

Site Address:

Telephone:

Fax:

Destination :

Tel.

e-mail:

Shipping

US DOT Description/Hazard Class

Unit

Other:

1234 COLLECTION STREET

ANYWHERE, IL 00000

(000) 000-0000

Fax

Billing Address:

e-mail

Quantity

Gallons

Pounds

Drums

- --

Payment

IEPA Transporter

No.

Driver:

Phone:

ILD #00000000000

USEPA #0000000000

Illinois Special Waste No.

(if

applicable)

Check No.!Date

Billed

Electronic filing - Received, Clerk's Office, January 14, 2009

* * * * * PC # 74 * * * * *

Additional Special Waste Information

(if

applicable):

AdditionruDescription: ____________________________________________________________________________________ __

Date(s) Generated: _____________________ "--________________________________________________________________ _

Location Generated: _________________________ ---;-__________________________

-.,.~

__________ _

Speciru Handling Instructions: ___________________________________________________________

Discrepancy Issues (if any): _____________________________________________________________ _

Receiving Facility: ___ ---:-__________________________________________________________ _

Name & Signature of Person Accepting Delivery at Receiving Facility: _________________________________________ _

GENERATOR'S/OFFEROR'S

CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, package, marked and

labeled/placarded, and are in

all

respects in proper conditions for transport according to applicable international and national governmental regulations.

export shipment and I am the Primary Exporter, I certify that the

contents

of this consignment conform to the terms of the attached EPA Acknowledge of Consent. I certify that the waste minimization statement identified in 40CFR 262.27(a) (if! am a large quantity generator) or (b) (if!

am a small quantity generator) is true.

ABC Recycling collects, transports and markets used

oils and non-hazardo)lS wastes in accordance with the requirements of 40 CFR Part 279 and applicable regulations. Generator is responsible for properly classifying their

waste streams

as used oil or non-hazardous waste in accordance with the provisions of 40 CFR 262. I 1 and applicable state laws. ABC Recycling Will collect and transport the non-hazardous materials, based on Generator's

representation

of the materials, in accordance with

all

applicable local, state and federal regulations. Based on representation made by the Generator regarding the type of material generated, ABC Recycling may screen the

materials at the time of collection; and may take and

retain

a SlI1l!Ple of the materials collCeled. ....... Oil's failure' to screen Generators materials, or take a retain sample, in no way constitutes a waiver of Generators

obligatio!). t.o properly clas.sify their waste streams. ABC ReCyclm.s relies on the Get!erators

representatio~,

and the GCIlerator is rc;sponsible

fo~

. informing ABC

Recyc~ng

of any process cbl!nges

that

may alter the

chaJllctenstlcs

ofille matenal(s) collected. Generator agn;es to provlae access to collection

tanks

and/or containers for sampling and addItional analYSIS for unacceptable matenals:

collected matenal(s) from Generator are

not as represented and confiriried unacceptable throu!!l1 further analysis - Generator agrees to accept return of material(s) ana all materials subsequently contaminated or the proper disposal of matenal(s} - Generator is

responsil)le for all costs and expenses related to, or ariSIng from the proper management and disposal of the unacceptable material(s), and the disposal of material(s) subsequently contamina1i:d thereby.

Generator certifies warrants

and

represents that the materials provided hereunder have not been mixed, combined, or otherwise blended in any quantity with hazardous waste materials under applicable laws, including but not

limited to 40CFR Part 261 generated by

this

facility. Generator agrees to indemnify and hold harmless

ABC

Recycling, its officers, directors, employees and agents from and against any and

all

losses, damages, penalties,

demands, claims, judgments, or expenses of any kirid related thereto, including alIlegaJ, remediation and disposal costs arising out of or in any way rehited to a breach of the above warranty by the Generator.

EMERGENCY RESPONSE

1-000~OOO-OOOO

X: ____

~~~~~~

__ --__ __

Generator's Printed Name & Signature

______

~-=~~~

~-=~

____ __

Transporter's Printed Name

Signature

x. __

____

~~~~~~--~~--

Second Transporter's Printed Name & Signature Address:

Transporter Permit No.

Tel:, ______ _

Third

X~~~~--~~~~~~--~~~

Transporter's Printed Name

Signature

Address:

Transporter Permit No.

Tel. _____ _

Form IPCB#1

White - Customer Copy

Yellow - Regulatory File Copy

Pink -

Accounting

Copy

Blue Copy - Data EDtry

Copy

~poNOit~~

Nitu~\

Electronic filing - Received, Clerk's Office, January 14, 2009

Please print or type (Form designed for use on elite (12

pitch) typewriter)

Form Approved OMS No 2050 0039

UNIFORM HAZARDOUS

11.

Generator ID Number

WASTE MANIFEST

/2. Page 1 of /3. Emergency

Respo~se

Phone

rcr5

5. Generators Name and Mailing Address

2mg 3 92

GBF

Generators Site Address (if different than mailing address)

Generators

6. Transporter

Phone:

1 Company Name

---

U.S. EPA ID Number

7. Transporter 2 Company Name

U.S. EPA ID Number

8. DeSignated Facility Name and Site Address

U.S. EPA ID Number

if)

Facility's Phone:

9a.

9b.

U.S. DOT DeSCription (including Proper Shipping Name, Hazard Class, ID Number,

10. Containers

11. Total

12. Unit

13. Waste Codes

and Packing Group (if any))

No.

/Type

Quantity

WtNol.

a::

._+

.-~-.-+--

/--._---

14. Special Handling Instructions and Additional Information

15.

GENERATOR'S/OFFEROR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged,

marked and labeled/placarded, and are in all respects in proper condition for transport according to applicable international and national governmental regulations. If export shipment and I am the Primary

Exporter, I certify that the contents of this consignment conform to the terms of the attached EPA Acknowledgment of Consent.

I certify that the waste minimization statement identified in 40 CFR 262.27(a) (if I am a large quantity generator) or (b) (if I am a small quantity generator) is true.

Generators/Offeror's PrintedlTyped Name

Signature

Month

Day

Year

....I

16. International Shipments

Import to U.S.

Export from

U.S .

Port of entry/exit:

Transporter Signature (for exports only):

Date leaving U.S.:

a::

17. Transporter Acknowledgment of Receipt of Materials

a::

I-

Transporter 1 PrintedlTyped Name

Signature

Month

Day

Year

0..

Transporter 2 PrintedlTyped Name

Signature

Month

Day

Year

a::

18. Discrepancy

18a. Discrepancy Indication Space

Quantity

Type

Residue

Partial Rejection

Full Rejection

Manifest Reference Number:

18b. Alternate Facility (or Generator)

U.S. EPA ID Number

....I

Facility's Phone:

18c. Signature of Alternate Facility (or Generator)

I Month I

Day

Year

19. Hazardous Waste Report Management Method Codes (i.e., codes for hazardous waste treatment, disposal, and recycling systems)

20. Designated Facility Owner or Operator: Certification of receipt of hazardous materials covered by the manifest except as noted in Item 18a

PrintedlTyped Name

Signature

Month

Day

Year

EPA Form 8700-22 (Rev. 3-05) PrevIous edilions are obsolete.

Electronic filing - Received, Clerk's Office, January 14, 2009