Anonymous public comment

COMMENT: This Federal Register is misleading to generators of PCB waste because it makes no mention of the need for a generator to submit form 7710-53 EVEN WHEN they intend to use their existing RCRA EPA ID number when manifesting PCB waste. This requirement is found through the www.epa.gov/pcb link given in 761.205(a)(3) [Click on “Notification of PCB Activity Form” and then click on “Instructions (PDF)" to reach what is entitled “Item-by-Item Instructions for Completing EPA Form 7710-53”] Those instructions say under the subheading of “Item 2--EPA identification number (IF ALREADY ASSIGNED UNDER RCRA):”-------- “A notifier may use their RCRA Identification number prior to receipt of written verification from EPA ONCE THEY HAVE CONFIRMED THAT EPA IS IN RECEIPT OF THEIR PCB NOTIFICATION FORM.”---------------------------------------------------------------------------------------It is clear from this instruction that a generator with a RCRA EPA ID number is not allowed to use that number for manifested PCB shipments UNLESS he/she has submitted a 7710-53 form to EPA.This difference between RCRA haz waste manifesting and TSCA PCB manifesting should have been disclosed in the rulemaking preamble, since readers would reasonably expect EPA to have disclosed in the Fed Reg such an important difference between the RCRA manifesting requirements and the TSCA PCB manifesting requirements. On page 54821 arguably is where this difference should have appeared under the heading “40 CFR 761.207(a)(1), (2), and (3)—general manifest requirements for generators”, perhaps along with the two examples given there of “including the date for removal from service for disposal “and “the PCB article’s serial number on the manifest.”