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co-generators of these still bottoms, and the RCRA regulations regarding generators, found at 40 CFR Part 262, are applicable to both. However, this does not mean that both generators must satisfy each regulatory requirement individually. When two or more parties contribute to the generation of a hazardous waste, as is the case in the generation of the still bottoms, these requirements are satisfied if one of the parties assumes and performs the duties of the generator on behalf of both the parties (45 FR 72026, October 30, 1980). Therefore,by mutual agreement either party could perform the generator responsibilities of recordkeeping,reporting, and manifesting for the still bottom waste. Typically, these duties are assumed by the original generator who owns the site. Nevertheless, EPA reserves the right to enforce against any and all persons who fit the definition of"generator" in a particular case if the requirements of Part 262 are not adequately met. For more discussion on generator responsibilities, see the October 30, 1980 Federal Register notice referenced above. Regarding the notification process, generator notifications under section 3010 of RCRA are generally required only once, at the time that RCRA regulations initially become applicable to the generator. It is through the notification process that a generator obtains an EPA identification number. If the original generator has already submitted a notification and received an EPA identification number, and if this generator consents to performing the generator duties for the still bottoms as described above, then, additional notification is not required for the mobile unit to perform the recycling operation. This arrangement appears to fit the circumstances described in your letter. However, should the agreement between ETG and a particular client prescribe that ETG be generator of record for the still bottoms,including manifesting the residue,ETG would need to obtain an EPA identification number for that particular site by submitting a notification form (40 CFR 262.12(a)). You also inquire about the applicability of the permitting requirements to the generator or the mobile unit operator. Your letter correctly states that a hazardous waste recycling process is exempt from the RCRA permitting requirements (40 CFR 261.6(c)). Therefore,neither ETG nor the generator would be obligated to obtain a permit for the recycling RO 13280