1

MEMORANDUM 

Date: June 30, 2011

To: Docket EPA-HQ-RCRA-2010-0742

From: Amanda Geldard

Subject: EPA’s Evaluation of Data Collected from Notifications Submitted under the 2008 

Definition of Solid Waste Exclusions

This memo summarizes information that EPA has compiled from Definition of Solid Waste (DSW) 

notifications submitted as of April 26, 2011. Detailed documentation is included in the attachments. This 

information has been reported by facilities managing hazardous secondary materials under the 2008 

DSW final rule exclusions and has been entered into RCRAInfo1by the state or EPA region.

Under the 2008 DSW final rule exclusions, facilities are required to notify their regulatory 

authority using the Site ID form (EPA form 8700-12) prior to operating under the exclusion and every 

other year thereafter. The notifications document how many facilities are using the exclusions, what 

type of exclusion is being used, and quantities of hazardous secondary material being managed and 

reclaimed under the exclusions. From this information, EPA has also drawn some conclusions about

whether the 2008 rule has increased reclamation of hazardous secondary materials and whether 

facilities are realizing any economic benefits from using the exclusions. 

Overview of Facilities Operating under the 2008 DSW Exclusions

As of April 26, 2011, there are 49 facilities2that are currently managing hazardous secondary 

materials under the 2008 DSW exclusions. A total of 25 facilities are operating under the generatorcontrolled exclusion (40 CFR 261.4(a)(2)(ii)), 21 of which are generating and reclaiming onsite and 4 are 

generating and reclaiming within the same company. (There are no facilities operating under the tollingexclusion.) A total of 273

facilities are operating under the transfer-based exclusion (40 CFR 

261.4(a)(24)), 23 of which are generators transferring off-site and four are reclamation facilities. All four 

reclamation facilities are RCRA permitted. (There are no unpermitted reclaimers operating under the

transfer-based exclusion.) Additionally, no intermediate facilities have notified. These results can be 

found in Attachment 1.

 

1

The RCRAInfo data system is the national repository for RCRA Subtitle C information. RCRAInfo is exclusively for 

the use of EPA employees, as well as State and Territorial environmental agencies, working in their official 

capacities.

2

The relatively low number of 49 facilities operating under the rule is a reflection of how few states have adopted 

the 2008 rule. Currently, the rule is only effective in six states: Alaska and Iowa (in which EPA manages the RCRA 

program) as well as Idaho, Illinois, New Jersey, and Pennsylvania. The rule is also effective in tribal areas and many 

of the territories (as of April 26, 2011, only one facility in the Virgin Islands has notified).

3

Some facilities are managing hazardous secondary materials under both the transfer-based and generatorcontrolled exclusion.
2

Increased Reclamation under DSW Exclusions

The notifications document that over 50,000 tons of hazardous secondary materials were 

reclaimed under the 2008 DSW final rule exclusions during 2009. (EPA receives this information from the 

re-notifications, which report quantities reclaimed within each odd-numbered year.) Additionally, by 

comparing a facility’s DSW notification to its 2007 or 2009 biennial report (where one exists), we can 

make conclusions regarding whether the rule has encouraged increases in hazardous secondary material 

recycling. We count 15 (32%) facilities that have either started or substantially increased reclamation 

under the 2008 exclusions. This includes, in many cases, facilities that reported burning spent solvents 

for energy recovery in their 2007 or 2009 biennial report and then notified that they are reclaiming the 

spent solvents under the 2008 final rule. We also count three cases where facilities switched from land 

disposing spent pickle liquor to reclaiming the hazardous secondary material under the rule. These 

results are reported in Attachments 2 and 3.

Potential Cost Savings under DSW Exclusions

The notifications also yield information suggesting that facilities are realizing economic benefits 

from the 2008 DSW exclusions. For example, 8 (16%) facilities reported a change in generator status in 

their DSW notification. (Because hazardous secondary materials managed in compliance with the 2008 

exclusions are no longer solid and hazardous wastes, a facility does not count these materials towards 

their generator status.) These results are reported in Attachment 4. This decrease in generator status 

can be presumed to translate to reduced regulatory requirements and thus cost savings for these 

facilities. 

List of Attachments:

- Attachment 1: Summary of Definition of Solid Waste Final Rule Notifications as of April 26, 2011

- Attachment 2: Actual Tons Reclaimed in 2009 under the 2008 DSW Exclusions 

- Attachment 3: List of Facilities that Likely Started or Increased Recycling under the 2008 DSW 

Exclusions

- Attachment 4: List of Facilities that Reported a Decrease in Generator Status in their DSW 

Notifications
3

Attachment 1: 

Summary of Definition of Solid Waste Final Rule Notifications as of April 26, 2011

Under the Revisions to the Definition of Solid Waste (DSW) final rule, published October 30, 2008 (73 FR 64668), facilities are required to notify their regulatory 

authority prior to managing hazardous secondary materials under the DSW rule and every other year thereafter. EPA is providing this Summary of Definition of 

Solid Waste Final Rule Notifications to allow public access to the information received from these notifications. Note: The information from the notifications is 

reported as it was submitted by the companies; some information from recent re-notifications may not be included.

State # of facilities that have submitted a DSW notification

Iowa 16

New Jersey 12

Pennsylvania 20

Virgin Islands 1

TOTAL 49

Facility Type # of facilities0F

4

Generator-controlled exclusion, reclaiming onsite 21

Generator-controlled exclusion, reclaiming within same company 4

Generator-controlled exclusion, tolling 0

Transfer-based exclusion, generator transferring offsite 23

Transfer-based exclusion, reclamation facility1 F

5

4

Transfer-based exclusion, intermediate facility 0

Transfer-based exclusion, generator exporting HSM 0

Transfer-based exclusion, reclamation facility importing HSM 0

Hazardous Secondary Material Type # of facilities2F

6

Spent Solvents (F001-F005, D035, plus D001) 23

Electric arc furnace dust (K061) 6

Spent pickle liquor (K062) 6

WW treatment sludges; plating bath residues from electroplating operations (F006;F007;F008) 5

Petroleum refining sludges; tank sediments (F037;F038;K050;K051;K169;K170) 1

Ignitable and/or corrosive (only) (D001, D002) 11

Characteristically toxic for metals (D004-D011)3F

7

 3

Other characteristically toxic (D012-D043, except D035) 4

 

4

Some facilities notified they are operating as multiple facility types and thus are counted more than once in this column.

5

Four reclaimers have notified under the rule (INMETCO Ellwood City, PA; Safety-Kleen Linden, NJ; Veolia Middlesex, NJ and World Resources Company Pottsville, PA). All have notified they have 

financial assurance.

6

Some facilities notified they are managing multiple types of hazardous secondary materials and thus are counted more than once in this column.

7 May also be ignitable or corrosive.
4

List of Facilities that have Notified Under the Definition of Solid Waste Final Rule:

EPA ID Name City State NAICS 

Description Facility Description

Waste codes for 

Hazardous 

Secondary 

Material

Estimated 

Annual 

Quantity4 F

Start 

Date

Iowa

IA0000362905

Curries 12th 

St NW

Facility

Mason City IA

Metal Window 

and Door 

Manufacturing

HSM Generator reclaiming onsite D001;D035;F005 13 tons Jan-09

IAD043490150 Curries 9th 

Street Facility Mason City IA

Metal Window 

and Door 

Manufacturing

HSM Generator reclaiming onsite D001;D035;F005 5 tons Jan-09

IAD055803423

Diamond 

Vogel Paint 

Co., Inc.

Burlington IA

Paint and 

Coating 

Manufacturing

HSM Generator transferring 

within "same company" D001;F003;F005 17 tons Jan-10

IAR000006577

Eagle River 

Window and 

Door Inc

Dubuque IA

Metal Window 

and Door 

Manufacturing

HSM Generator reclaiming onsite D001;D007;F003 69 tons May-10

IAR000007013

Fres-co 

System USA, 

Inc

Red Oak IA Commercial 

Gravure Printing HSM Generator reclaiming onsite D001;F003 6 tons Mar-10

IA0000990762

Iowa 

Contract 

Fabricators 

Inc

Riceville IA

Motor Vehicle 

Body 

Manufacturing

HSM Generator transferring 

offsite

D001;D035;F003;

F005 31 tons Mar-09

IAD005286539

Iowa Mold 

Tooling 

Company Inc

Garner IA

Construction 

Machinery 

Manufacturing

HSM Generator transferring 

offsite

D001;D035;F003;

F005 25 tons Mar-09

IAD073489726

John Deere 

Davenport 

Works

Davenport IA

Construction 

Machinery 

Manufacturing

HSM Generator reclaiming onsite D001 50 tons May-10
5

EPA ID Name City State NAICS 

Description Facility Description

Waste codes for 

Hazardous 

Secondary 

Material

Estimated 

Annual 

Quantity4 F

Start 

Date

IAD069624500

John Deere 

Des Moines 

Works

Ankeny IA

Farm Machinery 

and Equipment 

Manufacturing

HSM Generator reclaiming onsite D001;D035;F003;

F005 40 tons Nov-09

IAD005269527

John Deere 

Dubuque 

Works

Dubuque IA

Construction 

Machinery 

Manufacturing

HSM Generator reclaiming onsite D001 21 tons Apr-10

IAD000678094

John Deere 

Engine 

Works

Waterloo IA

Other Engine 

Equipment 

Manufacturing

HSM Generator reclaiming onsite D001 33 tons Aug-09

IAD005291182

John Deere 

Ottumwa 

Works

Ottumwa IA

Farm Machinery 

and Equipment 

Manufacturing

HSM Generator reclaiming onsite D001;F005 17 tons Dec-10

IAD000805168

John Deere 

Waterloo 

Works

Waterloo IA

Farm Machinery 

and Equipment 

Manufacturing

HSM Generator reclaiming onsite D001 56 tons Oct-09

IAR000007377 Siegwerk 

USA Co Des Moines IA Printing Ink Manufacturing

HSM Generator transferring 

within "same company" D001 125 tons Mar-09

IAD078096732 Siegwerk 

USA Co Des Moines IA Printing Ink Manufacturing

HSM Generator reclaiming onsite; 

Reclaimer receiving HSM from 

within "same company"

D001 250 tons Mar-09

IAD007276728 Vogel Paint & 

Wax Co Inc Orange City IA

Paint and 

Coating 

Manufacturing

HSM Generator reclaiming onsite D001;D035;F003;

F005 900 tons Feb-09

New Jersey

NJD051415909 Aleris Rolled 

Products, Inc Clayton NJ

Aluminum

Sheet, Plate, 

and Foil 

Manufacturing

HSM Generator transferring 

offsite

D001;D005;D006;

D007;D008;F005 60 tons Jul-10
6

EPA ID Name City State NAICS 

Description Facility Description

Waste codes for 

Hazardous 

Secondary 

Material

Estimated 

Annual 

Quantity4 F

Start 

Date

NJD002338267 Aluminum

Shapes LLC Delair NJ

Secondary 

Smelting and 

Alloying of 

Aluminum

HSM Generator reclaiming onsite D001;F005 11 tons Jul-09

NJR000036301 Anadigics, 

Inc. Warren NJ

Semiconductor 

and Related 

Device 

Manufacturing

HSM Generator transferring 

offsite D001;D004 52 tons Jan-09

NJD981483035 Melton Sales 

& Service Bordentown NJ

Industrial Truck, 

Tractor, Trailer, 

and Stacker 

Machinery 

Manufacturing

HSM Generator transferring 

offsite

D001;D035;D039;

F002:F003;F005 3 tons Jul-10

NJR000075796 Melton Sales 

& Service Burlington NJ

Industrial Truck, 

Tractor, Trailer, 

and Stacker 

Machinery 

Manufacturing

HSM Generator transferring 

offsite

D001;D035;D039;

F002:F003;F005 6 tons Jul-10

NJD011806122 Oticon Somerset NJ

Electromedical 

and 

Electrotherapeu

tic Apparatus 

Manufacturing

HSM Generator transferring 

offsite D001 1 ton Mar-11

NJD002182897 Safety-Kleen 

Systems, Inc Linden NJ

Hazardous 

Waste 

Treatment and 

Disposal

Reclaimer receiving HSM from 

offsite

D001;D018;D035; 

D039;D040;F003;

F005

15,910 tons Jun-09

NJD986629491 Sancoa 

International Lumberton NJ Commercial Gravure Printing

HSM Generator transferring 

offsite

D001;D035;F003;

F005 14 tons Aug-10

NJD064344575

Siegfried 

USA 

Incorporated

Pennsville NJ

Medicinal and 

Botanical 

Manufacturing

HSM Generator reclaiming onsite; 

HSM Generator transferring 

offsite

D001;D002;F003;

F005 110 tons Aug-09

NJD065710311 Silverton 

Marine Corp Millville NJ Boat Building HSM Generator reclaiming onsite D001;F003 5 tons Jan-10
7

EPA ID Name City State NAICS 

Description Facility Description

Waste codes for 

Hazardous 

Secondary 

Material

Estimated 

Annual 

Quantity4 F

Start 

Date

NJD002454544

Veolia ES 

Technical 

Solutions 

LLC

Middlesex NJ

Hazardous 

Waste 

Treatment and 

Disposal

Reclaimer receiving HSM from 

offsite

D001;D040;F001;

F002;F003 80 tons Sep-09

NJD002482545 Viking Yacht

Company New Gretna NJ Boat Building HSM Generator transferring offsite D001;F003 70 tons Dec-09

Pennsylvania

PAD004335154

Allegheny 

Ludlum 

Corporation –

Brackenridge 

Brackenridge PA Iron and Steel 

Mills

HSM Generator transferring 

offsite

K061;K062;D002;

D007 9,400 tons Dec-08

PAD057629479 Allvac 

Latrobe PLT Latrobe PA Iron and Steel Mills

HSM Generator transferring 

offsite K061 400 tons Dec-08

PAD003025418

BAE 

Systems, 

Land & 

Armaments

York PA

Military Armored 

Vehicle, Tank, 

and Tank 

Component 

Manufacturing

HSM Generator transferring 

offsite D001;F003 40 tons Sep-09

PAD002344315

Carpenter 

Technology 

Corporation

Reading PA Iron and Steel 

Mills

HSM Generator reclaiming onsite; 

HSM Generator transferring 

offsite

K061;K062;F001;

F006;F007;F008 13,541 tons Jul-09

PAD003043353

Cherokee 

Pharmaceutic

als, LLC

Riverside PA

Medicinal and 

Botanical 

Manufacturing

HSM Generator transferring 

offsite D001;D002 200 tons Jul-09

PAD053276085

Cleveland 

Steel 

Container 

Corp

Quakertown PA Metal Can 

Manufacturing

HSM Generator transferring 

offsite

D001;D018;D039;

D040 2 tons Mar-11
8

EPA ID Name City State NAICS 

Description Facility Description

Waste codes for 

Hazardous 

Secondary 

Material

Estimated 

Annual 

Quantity4 F

Start 

Date

PAD987278082 Greenville 

Metals, Inc Transfer PA

Secondary 

Smelting, 

Refining, and 

Alloying of 

Nonferrous 

Metal (except 

Copper and 

Aluminum)

HSM Generator transferring 

offsite K061 400 tons Nov-10

PAD087561015

International 

Metals 

Reclamation 

Company, 

Inc

Ellwood City PA

Nonferrous 

Metal (Except 

Aluminum) 

Smelting and 

Refining

Reclaimer receiving HSM from 

offsite

K061;K062;F006;

D001;D002;D003;

D004

20,500 tons Jun-09

PAR000510602

Jewell 

Acquisition, 

LLC –

Midland 

Midland PA Iron and Steel 

Mills

HSM Generator transferring 

offsite K061 750 tons Dec-08

PAD004338091

John 

Maneely Co 

Wheatland 

Tube Division

Wheatland PA

Iron and Steel 

Pipe and Tube 

Manufacturing 

from Purchased 

Steel

HSM Generator reclaiming onsite D002;K062 4,200 tons Feb-10

PAR000038067

John 

Maneely Co 

Wheatland 

Tube Division

Wheatland PA

Iron and Steel 

Pipe and Tube 

Manufacturing 

from Purchased 

Steel

HSM Generator reclaiming onsite D002;K062 4,200 tons Feb-10

PAD004322863

John 

Maneely Co 

Wheatland 

Tube Division

Sharon PA

Iron and Steel 

Pipe and Tube 

Manufacturing 

from Purchased 

Steel

HSM Generator reclaiming onsite K062 500 tons Feb-10

PAR000519322

Johnson 

Matthey 

Emissions 

Control 

Technologies

Smithfield PA

All Other Motor 

Vehicle Parts 

Manufacturing

HSM Generator transferring 

within "same company" D002 12 tons Aug-09
9

EPA ID Name City State NAICS 

Description Facility Description

Waste codes for 

Hazardous 

Secondary 

Material

Estimated 

Annual 

Quantity4 F

Start 

Date

PAD002283547

National 

Label 

Company

Lafayette Hill PA

Other 

Commercial 

Printing

HSM Generator transferring 

offsite D001 48 tons Sep-10

PAR000033993 Penn Color 

Inc Hatfield PA

Paint and 

Coating 

Manufacturing

HSM Generator reclaiming onsite D001 500 tons Feb-10

PAD002292068 Rohm and 

Haas Co Bristol PA

Plastics Material 

and Resin 

Manufacturing

HSM Generator transferring 

offsite

D001;D035;F003;

F005 420 tons Oct-10

PAD043882323

Spectrum 

Control 

Technology 

Inc

State College PA

Electronic 

Capacitor 

Manufacturing

HSM Generator transferring 

offsite F006 7 tons Mar-10

PAD981037377 Triangle 

Circuits Oakmont PA

Bare Printed 

Circuit Board 

Manufacturing

HSM Generator transferring 

offsite F006 25 tons Jan-10

PAD981038227

World 

Resources 

Company

Pottsville PA

All Other 

Miscellaneous 

Nonmetallic 

Mineral Product 

Manufacturing

Reclaimer receiving HSM from 

offsite F006 50 tons Feb-10

PAD000766147 Yorktowne 

Inc Mifflinburg PA

Wood Kitchen 

Cabinet and 

Countertop 

Manufacturing

HSM Generator transferring 

offsite D001;D002;F003 1 ton Aug-10

U.S. Virgin Islands

VID980536080 Hovensa LLC Christiansted VI Petroleum 

Refineries HSM Generator reclaiming onsite F037;F038;K050;K051;K169;K170 3,902 tons Oct-09
10

Attachment 2: 

Actual Tons Reclaimed in 2009 under the 2008 DSW Exclusions

# EPA ID Facility Name Facility Description Mgmt Start 

Date

Hazardous Secondary 

Material (Reported as 

Hazardous Waste Code)

Tons of Hazardous 

Secondary Material 

Reclaimed in 2009

1 IA0000362905 Curries 12th St NW Facility Generator reclaiming onsite Jan-09 D001;D035;F005 15

2 IAD043490150 Curries 9th Street Facility Generator reclaiming onsite Jan-09 D001;D035;F005 8

3 IA0000990762 Iowa Contract Fabricators 

Inc Generator transferring offsite Mar-09 D001;D035;F003;F005 31

4 IAD005286539 Iowa Mold Tooling Company 

Inc Generator transferring offsite Mar-09 D001;D035;F003;F005 25

5 IAD069624500 John Deere Des Moines 

Works Generator reclaiming onsite Nov-09 D001;D035;F003;F005 3

6 IAD000678094 John Deere Engine Works Generator reclaiming onsite Aug-09 D001 5

7 IAD000805168 John Deere Waterloo Works Generator reclaiming onsite Oct-09 D001 1

8 IAR000007377 Siegwerk USA Co Generator transferring within 

the “same company” Mar-09 D001 85

9 IAD078096732 Siegwerk USA Co

Generator reclaiming onsite; 

Reclaimer receiving within the 

“same company”

Mar-09 D001 10

10 IAD007276728 Vogel Paint & Wax Co Inc Generator reclaiming onsite Feb-09 D001;D035;F003;F005 877

11 NJD002338267 Aluminum Shapes LLC Generator reclaiming onsite Jul-09 D001;F005 4

12 NJR000036301 Anadigics, Inc. Generator transferring offsite Jan-09 D001;D004 Not available

13 NJD002182897 Safety-Kleen Systems, Inc Reclaimer receiving from 

offsite Jun-09 D001;D018;D035;D039;D040;F003;F005 689

14 NJD064344575 Siegfried USA Incorporated Generator reclaiming onsite; 

Generator transferring offsite Aug-09 D001;D002;F003;F005 97
11

# EPA ID Facility Name Facility Description Mgmt Start 

Date

Hazardous Secondary 

Material (Reported as 

Hazardous Waste Code)

Tons of Hazardous 

Secondary Material 

Reclaimed in 2009

15 NJD002454544 Veolia ES Technical 

Solutions LLC

Reclaimer receiving from 

offsite Sep-09 D001;D040;F001;F002;F003 1

16 NJD002482545 Viking Yacht Company Generator transferring offsite Dec-09 D001;F003 0

17 PAD004335154 Allegheny Ludlum 

Corporation – Brackenridge Generator transferring offsite Dec-08 K061;K062;D002;D007 9,322

18 PAD057629479 Allvac Latrobe PLT Generator transferring offsite Dec-08 K061 187

19 PAD003025418 BAE Systems, Land & 

Armaments Generator transferring offsite Sep-09 D001;F003 40

20 PAD00234431 Carpenter Technology 

Corporation

Generator reclaiming onsite;

Generator transferring offsite Jul-09 K061;K062;F001;F006;F007;F008 12,302

21 PAD003043353 Cherokee Pharmaceuticals, 

LLC Generator transferring offsite Jul-09 D001;D002 0

22 PAD087561015 International Metals 

Reclamation Company, Inc

Reclaimer receiving from 

offsite Jun-09 K061;K062;F006;D001;D002;D003;D004 1,258

23 PAR000510602 Jewell Acquisition, LLC –

Midland Generator transferring offsite Dec-08 K061 187

24 PAR000519322 Johnson Matthey Emissions 

Control Technologies

Generator transferring within 

“same company” Aug-09 D002 12

25 PAD004338091 John Maneely Co 

Wheatland Tube Division Generator reclaiming onsite Dec-08 D002;K062 28,635

26 PAR000038067 John Maneely Co 

Wheatland Tube Division Generator reclaiming onsite Dec-08 D002;K062 4,140

27 PAD004322863 John Maneely Co 

Wheatland Tube Division Generator reclaiming onsite Dec-08 K062 2,210

28 VID980536080 Hovensa LLC Generator reclaiming onsite Oct-09 F037;F038;K050;K051;K169;

K170 4,910
12

Attachment 3: 

List of Facilities that Likely Started or Increased Recycling under the 2008 DSW Exclusions

Facilities are included in the table below if they 1) submitted a biennial report in 2007 or 2009; and 2) their biennial report did not report any recycling of 

the wastestream that was included in the facility’s DSW notification; or 3) the biennial report included recycling of the wastestream but at significantly 

lower quantities that what was included in the DSW notification.

The results reflect only what EPA has been able to compile using available data and have not been independently confirmed with the facilities operating 

under the exclusions.

# EPA ID Facility Name Facility Description Notes

1 IAR000006577 Eagle River Window and 

Door Generator reclaiming onsite

In their 2009 BR, Eagle River reported sending D001, F003 waste to fuel 

blending. The facility began reclaiming D001, F003, and D007 hazardous 

secondary materials under the exclusions starting May 2010.

2 IAD005286539 Iowa Mold Tooling 

Company Inc Generator transferring offsite

In their 2007 BR, Iowa Mold Tooling reported recycling F005 waste and 

sent D001, F003, and F005 waste for fuel blending. The facility began 

reclaiming D001, D035, F003, and F005 hazardous secondary materials 

under the exclusions in March 2009.

3 IAD069624500 John Deere Des Moines 

Works Generator reclaiming onsite

In their 2007 BR, John Deere Des Moines reported sending D001, D035, 

and F003 waste to fuel blending. The facility began reclaiming D001, D035, 

F003, and F005 hazardous secondary materials under the exclusions in 

November 2009.

4 IAD005291182 John Deere Ottumwa 

Works Generator reclaiming onsite

In their 2007 and 2009 BR, John Deere Ottumwa reported sending D001 

and F005 waste for fuel blending and incineration, respectively. The facility 

began reclaiming D001 and F005 hazardous secondary materials under the 

exclusions in December 2010.

5 IAD078096732 Siegwerk USA Co Generator transferring within 

“same company”

In their 2007 BR, Siegwerk reported sending D001 waste for energy 

recovery. The facility began reclaiming D001 hazardous secondary 

materials under the exclusions in March 2009.

6 IAR000007377 Siegwerk USA Co

Generator reclaiming onsite; 

Reclaimer receiving from 

within “same company”

In their 2007 BR, Siegwerk reported sending D001 waste for energy 

recovery. The facility began reclaiming D001 hazardous secondary 

materials under the exclusions in March 2009.
13

7 IAD007276728 Vogel Paint & Wax Co Inc Generator reclaiming onsite

In their 2007 BR, Vogel Paint & Wax reported sending F003 and F005 waste 

for fuel blending. The facility began reclaiming D001, D035, F003, and F005 

hazardous secondary materials under the exclusions in February 2009.

8 NJD051415909 Aleris Rolled Products Inc Generator transferring offsite

In their 2009 BR, Aleris Rolled Products reported sending D001, D005, 

D006, D007, D008, and F005 waste for fuel blending and energy recovery.

The facility began reclaiming D001, D005, D006, D007, D008, and F005 

hazardous secondary materials under the exclusions in July 2010.

9 NJD986629491 Sancoa International Generator transferring offsite

In their 2009 BR, Sancoa reported sending D001, D035, and F003 waste for 

fuel blending. The facility began reclaiming D001, D035, F003, and F005 

hazardous secondary materials under the exclusions in August 2010.

10 NJD064344575 Siegfried USA Inc Generator reclaiming onsite; 

Generator transferring offsite

In their 2007 BR, Siegfried reported sending D001, F003 and F005 wastes 

for fuel blending. The facility began reclaiming D001, D002, F003, and F005 

hazardous secondary materials under the exclusions in August 2009.

11 PAD004338091 John Maneely Co 

Wheatland Tube Division Generator reclaiming onsite

In their 2007 and 2009 BR, John Maneely reported sending D002 and K062 

waste for deep well injection and chemical stabilization, respectively. The 

facility began reclaiming D002 and K062 hazardous secondary materials 

under the exclusions in February 2010.

12 PAR000038067 John Maneely Co 

Wheatland Tube Division Generator reclaiming onsite

In their 2009 BR, John Maneely reported sending D002 and K062 waste for 

deep well injection. The facility began reclaiming D002 and K062 hazardous 

secondary materials under the exclusions in February 2010.

13 PAD004322863 John Maneely Co 

Wheatland Tube Division Generator reclaiming onsite

In their 2009 BR, John Maneely reported sending D002 and K062 waste for 

deep well injection. The facility began reclaiming D002 and K062 hazardous 

secondary materials under the exclusions in February 2010.

14 PAD002283547 National Label Company Generator transferring offsite

In their 2009 BR, National Label reported sending D001 waste to fuel 

blending. The facility began reclaiming D001 hazardous secondary 

materials under the exclusions in September 2010.

15 PAD000766147 Yorktowne Inc Generator transferring offsite

In their 2007 BR, Yorktowne reported sending D001 waste to fuel burning.

The facility began reclaiming D001, D002, and F003 hazardous secondary 

materials under the exclusions in August 2010.
14

Attachment 4: 

List of Facilities that Reported a Decrease in Generator Status when Notifying under the DSW Exclusions

Facilities are included in the table below if their DSW notification also included a change in generator status.

# EPA ID Facility Name Facility Description Pre-DSW 

Generator Status

Post-DSW 

Generator Status

1 IA0000362905 Curries 12th St NW Facility Generator reclaiming onsite LQG SQG

2 IA0000990762 Iowa Contract Fabricators Inc Generator transferring offsite LQG SQG

3 IAD005286539 Iowa Mold Tooling Company Inc Generator transferring offsite LQG SQG

4 NJD986629491 Sancoa International Generator transferring offsite LQG SQG

5 NJD065710311 Silverton Marine Corp Generator reclaiming onsite LQG SQG

6 NJD002482545 Viking Yacht Company Generator transferring offsite LQG SQG

7 PAD003025418 BAE Systems Land & Armaments Generator transferring offsite LQG CESQG

8 PAD002283547 National Label Company Generator transferring offsite LQG SQG