Do you allow Confidential Business Information (CBI) claims on the Hazardous Waste Report? If so please describe which forms and data elements you allow CBI claims on and the basis for the claim.

Region 1 Lynn Hanifan, Wendy Nye, Kathleen Lynch 617-918-1644 Region 2 Norman Rost, Betsy Lopez212-637-4132, 3194 Region 4 Margaret Olson 404-562-8601 Region 5 Dan Bakk 312-886-4158 Region 6 Buddy Jones 214-665-8163 Region 7 Beth Koesterer, Cynthia Sehnert-Jones 913-551-7673 Region 9 Sue Durbin 415-972-3329 Region 10Terri Griffith, Ted Enderle, Ofelia Erickson 206-553-8511 Idaho Rene' Anderson 208/373-0210 randerso@deq.state.id.us Kansas Linda Prockish 785/296-0005 LPROCKIS@KDHE.STATE.KS.US WisconsinDavid Kollasch 608-264-6022 david.kollasch@dnr.state.wi.us New YorkDoug Nevel (518) 402-8610 dxnevel@gw.dec.state.ny.us South Carolina

Cheryl Coleman 803-896-4135 Colemact@dhec.sc.gov WyomingTim Link 307-777-7164 tlink@state.wy.us Nevada Alene Coulson 775-687-9464 acoulson@ndep.nv.gov OklahomaAl Coulter 405-702-5100 al.coulter@deq.state.ok.us North Dakota

Christine Roob 701-476-4121 croob@state.nd.us New Mexico

Linda Montoya 505-428-2503 Linda_Montoya@nmenv.state.nm.us Colorado Mira Neumiller (303) 692-3350 mira.neumiller@state.co.us Ohio Paula Canter 614-644-2923 paula.canter@epa.state.oh.us Arkansas Tom Ezell (501) 682-0876 ezell@adeq.state.ar.us Guam Michael O'Mallan (671) 475-1605 momallan@guamepa.govguam.net Washington DC

Mark Hughes (202) 535-2285 mark.hughes@dc.gov New Hampshire

Raymond Gordon (603) 271-6350 rgordon@des.state.nh.us MinnesotaJelil Abdella 651-297-8329 a-jelil.abdella@pca.state.mn.us Arizona Wilma Molitor 602 771 4147 MOLITOR.WILMA@EV.STATE.AZ.US Indiana Jenny Ranck Dooley 317-232-8925 jrdooley@dem.state.in.us Montana Mark Hall (406) 444-4096 mahall@state.mt.us North Carolina

Larry Wilson 919 733-2178 ext. 210larry.wilson@ncmail.net Missouri David Green 573-751-3204 david.green@dnr.mo.gov Oregon John Mathews 503-229-5055 mathews.john@deq.state.or.us Washington

Ed Bentley (360) 407-6466 eben461@ecy.wa.gov NebraskaTeri Swarts 4024714218teri.swarts@ndeq.state.ne.us Georgia Verona Barnes 404/657-8614 verona_barnes@dnr.state.ga.us Massachusetts

David J. Biggers 617-292-5787 DAVID.BIGGERS@STATE.MA.US Virginia Dan Gwinner 804-698-4218 dsgwinner@deq.virginia.gov MississippiMario Baroni 601-961-5788 mario_baroni@deq.state.ms.us Illinois Hope Wright 217/785-2361 Hope.Wright@epa.state.il.us Florida Michael Redig 850-245-8774 michael.redig@floridadep.net Kentucky Malinda Mays 502/ 564-6716 x237 Malinda.Mays@ky.gov Vermont Lynn Metcalf 802-241-3898 lynn.metcalf@anr.state.vt.us South Dakota

Carrie Jacobson 605-773-3153 Carrie.Jacobson@state.sd.us Michigan Elizabeth A. Bols 616.356.0235 bolse@michigan.gov Louisiana James D. Miller 225-219-3242 james.miller@la.gov Alabama Stephen Maurer 334-271-7940 scm@adem.state.al.usUtah Rusty Lundberg 801-538-6765 rlundberg@utah.gov

MarylandCaj Didigu 410-537-3344 cdidigu@mde.state.md.us Rhode Island

Theresa M. Ryan 401-222-1360 ext 7132 tryan@dem.state.ri.us Texas Carol Gensweider 512-239-6861 cgenswei@tceq.state.tx.us CaliforniaJim Bohon 916-255-4091 jbohon@dtsc.ca.gov Maine Cherrie Plummer 207-287-7882 cherrie.f.plummer@maine.gov Connecticut

Inga Rubecka (860) 424-3566 inga.rubecka@po.state.ct.us Delaware Don Short 302.739.3689 Donald.Short@state.de.us Hawaii Rudy Bilan (808)586-4226 rbilan@eha.health.state.hi.us Navajo Nation

Arlene Luther 928 871-7993 arleneluther@navajo.org New JerseyMike Hastry (609) 588-3716 mike.hastry@dep.state.nj.usDo you allow Confidential Business Information (CBI) claims on the Hazardous Waste Report? If so please describe which forms and data elements you allow CBI claims on and the basis for the claim.

**Answer**

No

Not Applicable Yes - We do allow facilities to claim the waste stream description as CBI.

Yes No. YES----All or part of the BR report forms
Yes GM and WR forms- waste desc. quantities codes Yes there are only a few companys in SC that have confidential data. Most companys in SC are open to the public as far as reviews. Quarterly report and notification data are allowed to be reviewed by the public unless the company request through our Legal office that there records are confidential.

No No No. Yes. According to State Regs that incorprate federal requirements. We may but it is discouraged and have not had any for several cycles. WR data could be CBI Ohio TSD facilities can claim CBI on the customer's name EPA ID street address city and zip code (but not state). This is based on Ohio's Trade Secret law not on a policy. They must substantiate the claim on each report submitted. Because RCRAInfo doesn't have a CBI flag or protection from release to unauthorized individuals Ohio must mask the customer's ID in the BR data submitted to US EPA. This renders the information useless for obtaining information on specific generators. No. All elements of the Hazardous Waste Report are subjet to State's FOIA. No DC allows CBI only to the extent that EPA does. NO no such thing in NH. All RCRA data gets poted on our state web site for the world to view. NA WE HAVE NOT HAD ANY REQUESTS FOR THIS (CBI) FOR MANY YEARS. We haven't had to deal with this. No
no Yes but no one has claimed it since the forms have changed so it cannot be answered in any further detail.

no CBI NDEQ has Title 115 Regulations that state how facilities can request confidentiality of information; which goes through our Legal Services area for approval of any CBI claims. Allow CBI if request. We usually have one or two & we do not dispute their claims or try to argue validity. One we get each cycle is Coca-Cola & their attorneys will never allow any BR data to go public. How D001 waste might reveal the formula for Coke is beyond us but we just don't have resources to argue. It's a minimal amount of waste each cycle. YES No NO NO we challenge and deny any such claim and successfully fought two such claims through the court. Yes form OI - confidential customer base Yes. Form 3. Customer lists waste shipped on-site from a different facility.
Thus far we haven't had a company request CBI. If a request was made we would discuss the issue with the company to determine what information would specifically need to be claimed CBI. NO!! The state has a mechanism by which reporters may request confidentiality prior to reporting although there has never been such a claim made for any past reporting periods.
noUtah law does allow for CBI claims related to information submitted to DEQ. We have accepted a CBI claim from an explosives manufacturer for purposes of trade secret concerns as it relates to waste characteristics information.

No we never have a request for confidential status.
No handler has claimed CBI on their reports in Maine. Yes. GM forms. Trade secret.
Yes. Generators must formally request in writing CBI claims and State will determine applicability. No one has every used this claim. We have never received a request. It would be considered if received.Yes there are only a few companys in SC that have confidential data. Most companys in SC are open to the public as far as reviews. Quarterly report and notification data are allowed to be reviewed by the public unless the company request through our Legal office that there records are confidential.

Ohio TSD facilities can claim CBI on the customer's name EPA ID street address city and zip code (but not state). This is based on Ohio's Trade Secret law not on a policy. They must substantiate the claim on each report submitted. Because RCRAInfo doesn't have a CBI flag or protection from release to unauthorized individuals Ohio must mask the customer's ID in the BR data submitted to US EPA. This renders the information useless for obtaining information on specific generators.

Yes but no one has claimed it since the forms have changed so it cannot be answered in any further detail.

NDEQ has Title 115 Regulations that state how facilities can request confidentiality of information; which goes through our Legal Services area for approval of any CBI claims. Allow CBI if request. We usually have one or two & we do not dispute their claims or try to argue validity. One we get each cycle is Coca-Cola & their attorneys will never allow any BR data to go public. How D001 waste might reveal the formula for Coke is beyond us but we just don't have resources to argue. It's a minimal amount of waste each cycle.

Thus far we haven't had a company request CBI. If a request was made we would discuss the issue with the company to determine what information would specifically need to be claimed CBI.
The state has a mechanism by which reporters may request confidentiality prior to reporting although there has never been such a claim made for any past reporting periods.Utah law does allow for CBI claims related to information submitted to DEQ. We have accepted a CBI claim from an explosives manufacturer for purposes of trade secret concerns as it relates to waste characteristics information.Yes there are only a few companys in SC that have confidential data. Most companys in SC are open to the public as far as reviews. Quarterly report and notification data are allowed to be reviewed by the public unless the company request through our Legal office that there records are confidential.

Ohio TSD facilities can claim CBI on the customer's name EPA ID street address city and zip code (but not state). This is based on Ohio's Trade Secret law not on a policy. They must substantiate the claim on each report submitted. Because RCRAInfo doesn't have a CBI flag or protection from release to unauthorized individuals Ohio must mask the customer's ID in the BR data submitted to US EPA. This renders the information useless for obtaining information on specific generators.

Allow CBI if request. We usually have one or two & we do not dispute their claims or try to argue validity. One we get each cycle is Coca-Cola & their attorneys will never allow any BR data to go public. How D001 waste might reveal the formula for Coke is beyond us but we just don't have resources to argue. It's a minimal amount of waste each cycle.Utah law does allow for CBI claims related to information submitted to DEQ. We have accepted a CBI claim from an explosives manufacturer for purposes of trade secret concerns as it relates to waste characteristics information.Ohio TSD facilities can claim CBI on the customer's name EPA ID street address city and zip code (but not state). This is based on Ohio's Trade Secret law not on a policy. They must substantiate the claim on each report submitted. Because RCRAInfo doesn't have a CBI flag or protection from release to unauthorized individuals Ohio must mask the customer's ID in the BR data submitted to US EPA. This renders the information useless for obtaining information on specific generators.

Allow CBI if request. We usually have one or two & we do not dispute their claims or try to argue validity. One we get each cycle is Coca-Cola & their attorneys will never allow any BR data to go public. How D001 waste might reveal the formula for Coke is beyond us but we just don't have resources to argue. It's a minimal amount of waste each cycle.Ohio TSD facilities can claim CBI on the customer's name EPA ID street address city and zip code (but not state). This is based on Ohio's Trade Secret law not on a policy. They must substantiate the claim on each report submitted. Because RCRAInfo doesn't have a CBI flag or protection from release to unauthorized individuals Ohio must mask the customer's ID in the BR data submitted to US EPA. This renders the information useless for obtaining information on specific generators.