Document YGQ4Q8E3Q0vrzLyJazpLVJN6V

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At Bunge Corporation 19560 Bunge Avenue Council Bluffs, IA 51502 (712) 366-8446 EPA ID Number: IAR000005959 On June 7, 2022 By Eastern Research Group, Inc. For U.S ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assurance Division 1.0 INTRODUCTION At the request of the Enforcement and Compliance Assurance Division/Chemical Branch/RCRA Section (ECAD/CB/RCRA) of the U.S. Environmental Protection Agency (EPA) Region 7, Eastern Research Group, Inc. (ERG) conducted a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at Bunge Corporation (Bunge) in Council Bluffs, Iowa on June 7, 2022. The CEI was conducted under the authority of Section 3007(a) of RCRA, as amended. Throughout the CEI, data and information were collected to determine compliance with the applicable regulatory and statutory requirements. The inspection report and attachments present the results of the CEI. 2.0 PARTICIPANTS Bunge Corporation: Joe Score, Compliance Manager Becky Coleman, EHS Coordinator James Burris, Environmental Specialist, Corporate in St. Louis EPA Representative, ERG: Joseph Watson, Senior Chemical Engineer 3.0 INSPECTION PRECEDURES After arriving unannounced at Bunge at approximately 08:35, I performed a drive-by visual inspection of the facility and took a photograph before beginning the inspection and did not note any areas of concern. I then entered the main entrance and I introduced myself to the front desk attendant. I explained my reason for being on site is to conduct a RCRA CEI and asked to meet with the facility personnel who manages hazardous waste on site. Mr. Score then greeted me in the lobby and led me to the training room to begin the opening conference at approximately 09:00. I initiated the opening conference with Mr. Score, Mr. Burris, and Ms. Coleman as Bunge representatives. I presented Mr. Score and Ms. Coleman with my inspector credentials and business card, as well as the business card of the EPA Task Order Contracting Officer Representative, Mr. Trevor Urban. I then presented a copy of RCRA Section 3007(a), which contains EPA's inspection authority. I explained my need to collect accurate information and presented them with a copy of Title 18 U.S. Code, Sections 1001 and 1002. I then presented Mr. Score with a copy of the Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA in Connection with Inspections and reviewed Bunge's confidentiality rights. I informed Mr. Score that I would provide a Confidentiality Notice at the end of this inspection. The inspection consisted of a discussion of facility operations, waste generation and waste management, a review of waste management records, and a visual inspection of the waste generation and management areas. Mr. Score explained facility operations and locations of hazardous waste generation and management. During the discussion, Bunge's confidential business information policy was discussed. Bunge's policy states that all photographs and documents requested during an inspection must be approved by their legal department before they can be provided to the inspector to take off site. All documents requested on June 7, 2022 were emailed to corporate for review. I completed the Receipt for Documents and Samples and the Confidentiality Notice (Notice) prior to exiting the facility on June 7, 2022 but did not leave the facility with any documents. On June 8, 2022, I received an email from Joe Score providing electronic documents of the files I requested the previous day. The email stated that Bunge will claim the plot plan/site map and the aerial photo indicating waste/recycling collection points as confidential business information since Bunge had concerns about potentially identifying waste generation points and waste collection points on a map in a public document. The Receipt for Documents and Samples and the Notice was signed by Mr. Score on June 8, 2022. A separate email was sent containing photographs. I did not download the plot plan/site map and the aerial photo indicating waste/recycling collection points from the email to eliminate managing any portions of this report as confidential business information. Therefore, an aerial photograph was taken from Google Maps to generically show the facility in relation to its surroundings (see Attachment 1). As stated above, at the conclusion of the inspection, on June 7, 2022, I provided Mr. Score with a Confidentiality Notice, and Receipt for Documents and Samples which Mr. Score signed as acknowledgement of receipt and provided in the email on June 8, 2022 (see Attachments 5 and 6, respectively). Mr. Score identified the plot plan/site map and the aerial photo indicating waste/recycling collection points as confidential business information on the Notice. On August 4,, 2022, I contacted Mr. Score to confirm that there are no facility process areas or waste 2 management sites physically identified on the generic map downloaded from Google Maps. I also told him that I did include physical descriptions in the report where waste is generated and managed in the facility but these descriptions are not related to physical locations on the map. I asked Mr. Score if the generic Google map would be acceptable to resolving any previous confidential business information Notice claims by Bunge. Mr. Score stated that this was acceptable to him since there were no process areas or waste management sites physically identified on the generic site map. During the visual inspection of the facility, Mr. Score guided me throughout the facility in order to conduct thorough evaluations of the facility's satellite accumulation areas (SAAs) and central accumulation area (CAA). At the time of the inspection, the facility was operating two SAAs, one CAA, and one universal waste accumulation area for batteries. The facility was not handling universal waste at the time of the inspection. Bunge uses six nonhazardous parts washers in the maintenance area and throughout the facility. I conducted an in-depth visual inspection of the SAAs, the CAA, the universal waste accumulation area, used oil storage area, and all manufacturing areas. Eight photographs were collected as inspection documentation and are shown in Attachments 2 and 3. I took the initial photograph at the entrance of the facility. Due to the use of solvents on site, only intrinsically safe equipment is allowed to be used in the plant area. As a result, Mr. Score took the remaining photographs using an intrinsically safe device. Information collected during the inspection is documented on the EPA Inspection Checklist (see Attachment 4). I followed the inspection procedures discussed in the RCRA CEI Standard Operating Procedure (No. 2321.01D), unless noted differently. The following inspection documents and compliance assistance handouts were left with Bunge: RCRA Section 3007(a) Title 18 U.S. Code, Sections 1001 and 1002 Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA in Connection with Inspections Confidentiality Notice (Facility copy) Receipt of Documents and Samples (Facility copy) Security Awareness Commercial Motor Vehicle Transportation Security Planning EPA E-Manifest Fact Sheet U.S. EPA Small Business Resources U.S. EPA Publication, Managing Your Hazardous Waste U.S. EPA Publication, Managing Used Oil-Advice for Small Businesses PowerPoint Presentation, 2013 Solvent Wipes Final Rule Pollution Engineering Article, 10 Common Questions for Waste Generators Iowa Department of Natural Resources (IDNR) Waste Exchange Folder and P2 Brochures IDNR Management of Fluorescent Lamps for Businesses Information Sheets IDNR Aerosol Can Disposal for Businesses Information Sheet University of Northern Iowa Waste Reduction Center Information Card 3 Solvent-Contaminated Wipes Final Rule Summary Chart 4.0 FINDINGS AND OBSERVATIONS Facility Information and Operations Bunge began operating in 1999 and currently employs approximately 125 people. The facility operates 24/7 operating a 12-hour shift schedule. The facility has a footprint of approximately 260,000 square feet. The facility representatives did not know the area of the site property and were unable to provide an estimate. Bunge's operations consist of processing soybeans into soy meal, soy oil, and livestock dietary feed. The primary raw materials used are soybeans, diatomaceous earth, and solvents. The major manufacturing or processing operations that generate waste streams include a quality control (QC) lab, maintenance activities, and soybean processing. The following waste streams are produced: QC lab waste, spent diatomaceous earth `spent bleaching earth', nonhazardous rags/personal protective equipment (PPE), aerosol cans, nonhazardous parts washer solutions, scrap metal, used oil, used oil filters, nonhazardous waste lamps, universal waste batteries, sump sludge, and general trash. 4.2 RCRA Status According to the Hazardous Waste Site Info Verification Report for Inspector (see Attachment 7), Bunge notified as a federal Small Quantity Generator (SQG) of D001, D002, D007, and F003 hazardous wastes. I asked Mr. Score to review the Hazardous Waste Site Info Verification Report for Inspector, which I provided prior to records review and visual inspection of the waste generation areas. Mr. Score provided site contact and owner information. After reviewing the records and walking through the facility, it appears that the facility is operating as a federal SQG of D001, D002, D007, and F003 hazardous wastes, a generator of used oil, and a small quantity handler (SQH) of universal waste. Bunge generates approximately 700 pounds of hazardous waste monthly based on a review of facility records, a visual inspection of process and waste management areas, and interviewing personnel. Bunge was never previously inspected for RCRA compliance. 4.3 Facility Waste Streams and Management A Waste Stream and Waste Handling Table for Bunge is presented below. The table describes waste streams generated, generation process/rates, hazardous waste determinations, and onsite/off-site management. The rest of this page left blank intentionally. 4 WASTE GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE OFF-SITE STREAM PROCESS DETERMINATION GENERATION MANAGEMENT MANAGEMENT # RATE 1 Laboratory Laboratory D001 and F003 (Based Four 55-gallon Initially collected in Hydrite Chemical Waste QA Waste on process knowledge containers every 1-gallon containers (IAT200010593) in Testing of three months in the laboratory Waterloo, IA to Hydrite Soybean Seeds and transferred into Chemical Co. and Oils 55-gallon (WID000808824) in (Waste Profile containers in the Cottage Grove, WI for included in CAA reclamation Attachment 8) 2 Spent Soybean oil Nonhazardous (based on 1,950 tons per 40-yard container Darling Ingredients Bleaching refining process knowledge and year Muscatine, IA for Earth knowledge of the recycling (Sample (Nonhazardous product) Nonhazardous Waste Industrial Solid Manifest - Attachment (Waste Profile 10) included in Attachment 9) 3 Lab Miscellaneous Nonhazardous (based on Unknown - not General trash 20- Waste Connections in Solids/Oily lab solids, PPE, process knowledge and tracked yard container Ceresco, NE to Loess Rags / PPE absorbent pads, knowledge of the Hills Regional Sanitary used paint product) Landfill in Mitchell buckets/cups Malvern, IA (IAD000678185) for landfill 4 Grease/Used Clean up from Nonhazardous (based on Four 55-gallon 55-gallon container Clean Harbors Deer Trail oil Absorbent spills absorbent process knowledge and containers per LLC in Deer Trail, CO (Waste Profile material knowledge of the year (COD991300484) for included in product) disposal or fuel blending Attachment 11) 5 WASTE GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE OFF-SITE STREAM PROCESS DETERMINATION GENERATION MANAGEMENT MANAGEMENT # RATE 5 Aerosol Cans Use aerosol can Use can until RCRA Unknown - not General trash 20- Heimes Corporation/ESI until empty and empty and replacing tracked yard container of Omaha, NE dispose of in aerosol cans containing (NER00008128) collects scrap metal hazardous materials with and transports to the recycling. aerosol cans containing Loess Hills Regional nonhazardous materials, Sanitary Landfill in (SDS included in Mitchell Malvern, IA Attachment 12). (IAD000678185) for landfill 6 Sump Plant shutdown Nonhazardous (based on Approximately 10,000-gallon frac Heimes Corporation/ESI Skimming and and cleanout process knowledge and 2,000 gallons per tanks of Omaha, NE Sludge knowledge of the event (NER00008128) collects product) and transports to the Loess Hills Regional Sanitary Landfill in Mitchell Malvern, IA (IAD000678185) for landfill (Special Waste Manifest Disposal Ticket - Attachment 13). 7 Nonhazardous Cleaning oil and Nonhazardous (based on 300 gallons In parts washer Safety Kleen in Omaha Parts Washer greases off small process knowledge and serviced every NE (NED981495724) for Solvent (SDS maintenance knowledge of the three months recycling (Invoice - included in tools and parts product) Attachment 15) Attachment 14) 6 WASTE STREAM # 8 Used Oil 9 Used Oil Filters GENERATION PROCESS Maintenance of facility machinery and equipment HAZARDOUS WASTE DETERMINATION Nonhazardous/Excluded (managed as used oil per 40 CFR 279) ESTIMATED GENERATION RATE 1,200 gallons per year ON-SITE MANAGEMENT 350-gallon and 275-gallon containers Facility maintenance Nonhazardous (based on process knowledge and knowledge of the product) 55-gallon drum per year Hot drained and punctured and then added to general trash 20-yard container OFF-SITE MANAGEMENT Product Recovery and Recycling of Fort Calhoun, NE (NER000502732) (Invoice - Attachment 16) for recycling Waste Connections in Ceresco, NE to Loess Hills Regional Sanitary Landfill in Mitchell Malvern, IA (IAD000678185) for landfill 10 Scrap Metal Facility operations Excluded (based on management and process knowledge) recycled as scrap metal 500,000 pounds per year Various sizes ranging up to 5yard containers Alter Metal Recycling Council Bluffs, Council Bluffs, IA (IAD056841117) for recycling (Invoice Attachment 17) 11 Waste Fluorescent Lamps Facility maintenance Nonhazardous Use green-tip fluorescent lamps disposed of in trash. Has not shipped lamps off site in over one year General trash 20yard container Waste Connections in Omaha, NE to Loess Hills Regional Sanitary Landfill in Mitchell Malvern, IA (IAD000678185) for landfill 7 WASTE GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE OFF-SITE STREAM PROCESS DETERMINATION GENERATION MANAGEMENT MANAGEMENT # RATE 12 Waste Grain Railcar cleanout, Nonhazardous (based on Unknown - not 40-yard container Johnson Coopering of Products residuals process knowledge and tracked Council Bluffs, IA, knowledge of the primarily composted product) 13 Paper/Corrugat Facility Nonhazardous (based on Six tons per year General trash 20- Waste Connections in ed Cardboard Operations process knowledge and (Waste Tracking yard container Omaha, NE to First Star knowledge of the Spreadsheet Fiber in Omaha, NE for product) 2021 - recycling or reprocessing Attachment 18) 14 Universal Facility Nonhazardous/Excluded Three 5-gallon 5-gallon container Veolia ES Technical Waste maintenance (managed as universal containers per Solutions, LLC in Port Batteries waste) year Washington, WI (WID988566543) for recycling (Invoice - Attachment 19) 15 Laboratory Waste D001, D002, and Periodic cleanout of D007 (Based on expired lab chemicals Less than 10 gallons per year LabPak Hydrite Chemical (IAT200010593) in Chemicals process Waterloo, IA to Clean knowledge Harbors Environmental Services, Inc. (NED981723513) in Kimball, NE for disposal or incineration. 16 General Trash Facility Nonhazardous (based on Approximately General trash 20- Waste Connections in operations process knowledge and 1,300 Short yard container Omaha, NE to Loess knowledge of the Tons per Year Hills Regional Sanitary product) Landfill in Mitchell Malvern, IA (IAD000678185) for landfill 8 Less-Than-180-Day Hazardous Waste Accumulation Area Bunge has one less than 180-day CAA on site, which is located in a room connected to the QC Lab. The exterior of the door had signage identifying the area as a CAA. I asked Mr. Score why there was not a no smoking sign on the door. Mr. Score stated smoking is not allowed in the facility due to the extensive use of solvents on site. Therefore, it would not be possible for any smoking to occur near or at the CAA. He also stated that is why he had to use an intrinsically safe device to take photographs. I told Mr. Score of the requirement of posting a no smoking sign. I did not leave a finding for this issue but further EPA review may add a finding for this issue. Inside the CAA, I observed hazardous lab waste being accumulated (see Attachment 3, Photos 3-4). There was a total of three 55-gallon containers of lab waste being accumulated in the CAA. The three 55-gallon containers were closed, in good condition, were labeled as "Hazardous Waste", labeled with an indication of the nature of the hazard, and had accumulation start dates. During the visual inspection, I observed all labels facing a direction that could be visible to personnel conducting CAA inspections. The oldest accumulation start date observed was March 17, 2022, which was observed on a 55-gallon container of hazardous lab waste. March 17, 2022 is within 180 days prior to the date of the inspection. I observed adequate aisle space to allow for container inspections and access in the event of a spill. The containers were located upon spill containment pallets. I observed spill control equipment, and related safety equipment in close proximity to the CAA. Operators handling hazardous waste are trained to use their two-way radio system in case of emergencies. Bunge has posted the required emergency response information next to the phone located in close proximity to the CAA. In addition, safety and emergency equipment were present and in satisfactory condition near the CAA as required per 40 CFR 262.16(b)(9)(ii). Mr. Score explained this area is restricted and only staff actively managing hazardous waste who have been adequately trained and complete annual refresher training have access to the CAA. I asked Mr. Score if the facility inspected the CAA. Mr. Score stated the facility inspected the CAA at least weekly and had weekly inspection logs. During records review, Mr. Zach Polson, Quality Manager, provided inspection logs for the CAA. I reviewed the logs, and it appeared the facility was adequately performing weekly inspections of the CAA. An example of a CAA log is provided in Attachment 20. I did not note any issues or findings at the CAA during the inspection. Satellite Accumulation Areas I observed two satellite areas during the visual inspection. The table below shows the SAA name or location, waste type, volume of waste observed, and container type. 9 SAA # 1 2 SAA Name or Location QC Lab QC Lab Waste Type Laboratory Waste Laboratory Waste Volume of Waste 0.25 gallons 0.1 gallons Container Type 1-gallon container 1-gallon container During the visual inspection, I observed two SAAs in the QC Lab accumulating hazardous laboratory waste from the testing of soybean oil and seeds. A detailed discussion of the laboratory is included in Section 4.7 of this report. The hazardous waste accumulation containers observed in the SAAs were in good condition, closed, labeled with the indication of the nature of the hazard, and labeled with the words "Hazardous Waste" (see Attachment 3, Photo 5). I reviewed the management of the SAAs, and no issues or findings were noted. Soybean Processing Operations During the visual inspection, I observed soybean processing operations with descriptions provided by Mr. Score. Truckloads of soybeans arrive onsite via railcar and truck. Probing stations on site check the shipments for the quality of the beans and foreign debris in the shipment. Shipments are accepted or rejected based on quality standards. The shipments are unloaded and sent to a dryer to crack the hulls. Waste grain products are collected by Johnson Coopering primarily for composting. Soybeans are then sent to a tempering bin. The soybeans are then sent to a prep building where the hulls are removed. The hulls are then collected and pelletized and sold for its high fiber content. The soybeans are further processed before being sent to the extraction plant for recovering the oil with a solvent extract process. This process generates flakes which are sold as a high protein meal and a crude soybean oil which is sent to the refinery for further processing. Bunge has a Title V permit for the facility including the soybean processing operations (see Attachment 21). The crude soybean oil sent to the refinery undergoes further processing with heat and an aqueous solution before centrifuging out the oil. Bunge reuses the aqueous solution. The oil undergoes further processing through a diatomaceous earth/sand filter to remove minerals such as iron, manganese, and calcium. Bunge ships the spent bleaching earth (diatomaceous earth/sand) to Darling Ingredients Muscatine, IA for additional oil recovery and recycling (see Attachment 3, Photo 6). As of April 2022, the facility has started to accumulate a nickel catalyst used in the process for recycling but has not had a shipment sent out for recycling as of the date of the inspection. The soybean oil is further processed generating the final oil product and a soy distillate used in animal feed. Periodically, the sumps in the processing are cleaned out by Heimes Corporation/ESI and the nonhazardous sludge is disposed of in the Loess Hills Regional Sanitary Landfill. I did not observe or note any issues or findings with soybean processing operations. 10 Quality Control Laboratory Bunge operates a QC Lab which generates most of the hazardous waste at the facility. The most common hazardous waste generates are D001 and F003 hazardous wastes. These wastes are generated from using acetone in various analytical testing procedures. The waste profile for this waste stream is provided in Attachment 8. The QC lab primarily conducts quality assurance testing of soybean oil and seeds. Typical analyses include percent peroxide values, percent fatty acid, and percent soaps. Bunge operates two SAAs, each with a one-gallon container to accumulate spent hazardous waste. The two SAA containers are then transferred into a 55-gallon container in the CAA at the end of each day. The lab periodically generates small quantities of LabPak wastes when disposing of expired or unused chemicals. The last shipment of LabPak waste also included D002 and D007 hazardous waste codes for reagents used. I did not observe or note any issues or findings with QC Lab operations Parts Washers At the time of the inspection, the facility was operating six 55-gallon parts washers located throughout the facility. Mr. Score explained the parts washer is used by maintenance staff to clean greases and oils off of small tools. Mr. Score stated the facility parts washer solution is a nonhazardous parts washer solution and the parts washers are serviced once every three months by Safety Kleen. The parts washers holds approximately 50 gallons of solvent solution (see Attachment 3, Photo 8). The SDS for the parts washer is provided in Attachment 14. An invoice for how servicing is documented is provided in Attachment 15. I did not note any issues or findings with any of the parts washers. Universal Waste Accumulation Area Bunge manages universal waste next to the maintenance area. At the time of the inspection, I did not observe any universal waste currently being managed or accumulated on site. At the time of the inspection, the facility was not accumulating universal waste batteries on site. A receipt of a recent shipment of universal waste batteries for recycling is shown in Attachment 19. Mr. Score stated that the facility uses green-tip universal waste lamps in facility areas that have not converted over to light emitting diode (LED) lights. During the visual inspection, I only observed green-tipped fluorescent lights being used. The green-tip fluorescent lamps are disposed of in the general trash. I reviewed the management of all universal waste storage areas throughout the facility and no issues or findings were noted. Used Oil I visually observed the used oil storage areas on site. Used Oil is generated from facility maintenance of equipment. The oil storage area contained two 350-gallon and one 275-gallon 11 totes that store used oil (see Attachment 4, Photo 7). The totes were closed, in good condition, and labeled as "Used Oil". An invoice is provided for off-site shipments as an example in Attachment 16. I did not note any issues or findings at the used oil storage area. Other Regulatory Requirements I reviewed the preparedness, prevention, and emergency requirements and no issues or findings were noted. Preparedness, Prevention, and Emergency Requirements - Safety and emergency equipment were present and in satisfactory condition in areas throughout the facility, including in close proximity to the CAA (as noted in Section 4.4 of this report). Appropriate arrangements and coordination were made with necessary State and local emergency agencies. I reviewed the preparedness, prevention, and emergency requirements and no issues or findings were noted. Based on the visual inspection and discussions with employees, it appeared the employees are familiar with waste handling and emergency procedures. The employees appeared to be aware of RCRA regulations and were knowledgeable of waste management and handling. Mr. Gregory explained as a best management practice, the facility refreshes hazardous waste training annually. I reviewed the personnel training requirements, and no issues or findings were noted. Manifest and Land Disposal Restriction (LDR) Requirements - Bunge maintained records of manifests on site at the time of inspection dating back three years. A total of 13 hazardous waste manifests were generated in the last three years and 13 of these manifests were reviewed on site. Examples of hazardous waste manifests are provided in Attachment 22. The example manifests in Attachment 22 was printed from EPA's RCRAInfo while on site since I was unable to take any documents off site without going through Bunge's internal confidential business information review process first. All manifests reviewed were signed by the required parties and returned in the required timeframe. I reviewed all other manifest and LDR requirements and no issues or findings were noted. I observed no issues or findings during this inspection. However, further EPA review may add findings. Joseph Digitally signed by Joseph Watson _W___a__t__s_o___n______________-_0_4_'_00' Date: 2022.08.04 16:25:58 Joseph Watson Senior Chemical Engineer Date: August 4, 2022 12 AMBER Digitally signed by AMBER WHISNANT _W____H___I_S__N___A___N___T___1_7__:4_4_:_5_4 -05'00' Date: 2022.08.05 Amber Whisnant Section Chief ECAD/CB/RCRA, EPA Region 7 Date: _________________ Attachments: 1. Aerial Photograph (1 page) 2. Bunge Corporation Photolog (1 page) 3. Bunge Corporation Photos (8 photos/9 pages) 4. EPA Inspection Checklist (25 pages) 5. Confidentiality Notice (1 page) 6. Receipt for Documents and Samples (1 page) 7. Hazardous Waste Site Info Verification Report for Inspector (1 page) 8. QA Testing Lab Waste Profile (4 pages) 9. Spent Bleaching Earth Waste Profiles (2 pages) 10. Spent Bleaching Earth Nonhazardous Waste Manifest (1 page) 11. Grease Used Oil Absorbent Waste Profile (3 pages) 12. Knocker Loose SDS (11 pages) 13. Sump Sludge Special Waste Manifest Disposal Ticket (1 page) 14. Parts Washer SDS (13 pages) 15. Parts Washer Invoice (2 pages) 16. Used Oil Invoice (1 page) 17. Scrap Metal Recycling Invoice (1 page) 18. Waste Tracking Spreadsheet (1 page) 19. Universal Waste Battery Recycling Receipt (1 page) 20. CAA Log (2 pages) 21. Title V Permit (100 pages) 22. Hazardous Waste Manifest (2 pages) 13