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     0013-
                                                TABLE OF CONTENTS
-4
  •V
PREFACE	1-1
                                                        t
EXECUTIVE  SUMMARY	ii-1

CHAPTER 1  INTRODUCTION	1-1
1.1    Purpose of the Fatality Identification Data Standard (FIDS)	.	..		1-2
1J2    Background of the FIDS		1-3
1.3    Summary of the Standard............—................—.—.—.		1-3
1-4    Applicability of the Standard		1-5

CHAPTER J  AGENCY-WIDE FIDS IMPLEMENTATION PLAN	2-1
2.1    Steps and Schedule to Implement the FIDS	2-1
22    OIRM Resources for FIDS Implementation Activities...	2-7
2.3    Waivers from the FIDS	,	2-9

CHAPTER 3  RESPONSIBILITIES  FOR FIDS  IMPLEMENTATION	3-1
3.1    The Facility Identification Advisory Task Force (FIAT)	3-1
3.2    EPA Headquarters Responsibilities under the FIDS	3*2
3.3    Regional Responsibilities under the FIDS	3-11
3.4    Responsibilities of States under the FIDS	3-13

CHAPTER 4  INDIVIDUAL PROGRAM FIDS IMPLEMENTATION PLANS	4-1
4.1    Number and Types of Facilities	4-1
4.2    New Sources in FINDS	4-3
4.3    Status of Key Data Elements	4-3
4.4    Changing Documentation	.....4-6
4.5    Synchronized Updates with FINDS...	4-7
4.6    Roles and Responsibilities	4-8
4.7    Implementation Schedule	4-8
4.8    Quality Assurance  Processes	4«8
4.9    Resource Availability and Constraints	4-9

APPENDIX  A-       Facility Identification Data Standard	."	A-l

APPENDIX  B-       Recommendations for Assignment of Facility ID Codes by
                     Major  Environmental Program	B-l
                 APPENDIX  C-

                 APPENDIX  D-
                     EPA Forms Relevant to the FIDS	C -1

                     FINDS Data Element Dictionary	-D-l
   C\J
   04
   CM
                                      2/12/92 FIDSIP
                                              HEADQUARTERS LIBRARY

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                                    LIST  OF EXHIBITS
Exhibit 1-1
Exhibit 1-2
 Exhibit 2-1
 Exhibit M

 Exhibit 3-2

 Exhibit 3-3

 Exhibit 3-4

 Exhibit 3-5

 Exhibit 4-1
 Exhibit 4-2

  Exhibit C-l
  Exhibit C-2
Facility ID Code Assignment Process Flow	
                                   '                               •*- ^"*
Facility Concept	         ^
Guidelines ft*EPAFtcBitylD Cod* Assignment	  '^
Agency-Wide FIDS Implementation Schedule	
OAWWmMRespoMJbiliiiesunderlheEPAFacaity          	^
 Identification Data Standard —.—••—••—•••—•	•••••••	
               of Non-Media Program Offices                            3.7
                    V Identification Data Standard	
                 EPAHeadq^BMetolJ^mOffices      		^
          EPA Facility Identification Data Standard	
  Resnonsibilities of EPA Regional Office Staff                            3.12
  SK?EPA Facility Idemificauon  Da« Standard		;-J
  Responsibilities of Slates under the EPA Facility            	3.u
  Identification Data Standard	
  Individual Program Implementation Plan Summary	
  Status of Presence of Facility ID Codes in                  	4.5
  EPA  Program  Systems	
  Review of the 637 Forms in the EPA Forms Catalog	'C'2
  List of Forms by Program that Possibly Need         -     	c.3
  to Be Modified for FIDS Compliance	
                                             2/12/92 FIDSIP

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                                            PREFACE


        This January 30,1992, draft Of the F.effitv Identification Data Standard Imptemmnitiftn WMI refects the

 comments and suggestions received from internal OIRM review of a prior version. Thanks to all Agency offices for

 reviewing and concurring on the Facility Identification Data Standard, which will enable consistent application of

 the Facility ID and realize significant benefits.


        Support for development of this draft was provided by Booz*AUen & Hamilton Inc. under EPA contract

 •68-W9-Q037, Delivery Order *094.
        Comments on this draft should be transmitted to OIRM to be considered for inclusion in the next version.

.Any comments or questions on this draft should be directed to:


        Jeff Sabol, Program Manager for Data Administration
        Information Management Branch (PM-21 ID)
        Information Management and Services Division
        Office of Information Resources Management
        U.S. Environmental Protection Agency
        401 M Street. S.W.
        Washington, D.C. 20460
        Phone:
        Fax:
        EPA Email.
(202/FTS) 260-8974
(202/FTS) 260-3923
SaboU
FIDSIP 2/12/92

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                                     Executive Summary
                                                             f
       The Facility Identification Data Standard (FIDS) became effective on April 9,1990. after formal Agency-
wide review, when it became EPA Order f 2180.3. The objective of the FIDS is to unify facility data maintained by
different EPA programs. The FIDS institutes the assignment of a unique identifier to facilities regulated under
Federal environmental laws. In addition, this "EPA facility identification code* is to be pan of every data collection.
whether manual or automated, containing information on that facility. The FIDS wffl improve the compatibility of
all Agency facility data by providing a fundamental piece of linkable" information, (he EPA facility ID code, to all
facility-oriented data, allowing integration across systems and data from different sources. Assignment of EPA
facility ID codes will be done using the Facility INDex System (FINDS), an EPA data base containing an inventory
of facilities to which ID codes have been assigned.

        This  Facility  Identification  Data  Standard  Implementation  Plan provides  guidance  for
 implementing the FIDS. This plan details the schedule of steps that must be performed across the Agency, roles and
 responsibilities of the various participants of the FIDS, and the components of individual program implementation
 plans. The FIDS is expected to require five years to implement completely throughout EPA, its regulatory partners,
 and the regulated community.

         There are six basic steps to Agency-wide FIDS implementation:

          •       Reconcile Priority I systems
          •       Establish the Facility Identification Advisory Task Force (FIAT)
          •       Develop program-specific FIDS implementation plans
          •      Revise data systems
          •       Revise data collection and correspondence instruments
          •       Commence on-going procedures and syrichroniied systems/FDsDS updates.

          The First step in implementing the FIDS, initial reconciliation  between FINDS and Priority I program
   systems, has been completed.  Priority 1 data systems include ROWS (OSW). CERCLJS (OSWER). Enforcement
   Docket System (OE). TR1S  (OTS). AIRS (OAQPS), FFIS (OFA). PCS (OW/OWEP).  This step  has been
   performed 10 ensure thai a facility ID code has been assigned to. and a FINDS record has been created for.all facffiiies
   currently in national program systems. In addition, initial  reconciliation transfers the necessary data from the
   program systems to FINDS through synchronized updates of FINDS with program systems as (hey change.
    RDSIP 2/12/92                                   U"!

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        The next step will be the establishment of the Facility Identification Advisory Task Force (FIAT) to
monitor all activities related to the FIDS and facilitate changes to the implementation plan as necessary. FIAT
establishment, including detenninatioo of its membership, charier, and procedures should be completed by December
1991.

        The third step to implement the FIDS is to develop program-specific implementation plans which identify
those entities of environmental concern within each program that are within the scope of the FIDS, and to map out
the process for synchronizing  of  program system updates (either manual or automated) with FINDS.
Implementation plans should address the following nine key components: Dumber and type of facilities, new data
aouree identification in FINDS, status of key data elements needed for the FIDS in each program data collection,
changes of programmatic forms (optional) or other data collection/documentation tools, automated updates, roles and
responsibilities, implementation schedule, quality assurance, and resource availability and constraints. The proposed
target date for completion of all program FIDS implementation plans is December 1992.

        Data system revision is the next step in Agency-wide FIDS implementation.  This will involve modifying
program systems to house the EPA facility identification code and developing a process to ensure correspondence
between facility identification data in program systems and FINDS.  Modification of Priority I program systems
should be completed by June 1992. Non-Priority 1 systems should be modified by December 1994.  This step also
involves developing lat/long data for facility records in FINDS by June 1992.

        Revision of data collection  and correspondence instruments (forms, correspondence, and  other paper
documentation) used by programs should be conducted simultaneously with the program system redesign.  This will
ensure that the facility ID code is a routine pan of all facility related data collection and that there is a process in
place enabling  consistency between program paper records, data systems, and FINDS.  Any modification of
documents for Priority I program systems should be completed by June 1992. Modification for all other applicable
documents should be completed by December 1994.

        Responsibility to implement the FIDS is shared by both media and non-media program staff at a variety of
governmental levels including EPA Headquarters, EPA legions, states, local governments, and the regulated
community. Full implementation of the FIDS wiD be monitored by the FIAT. In particular, the FIAT will develop
approaches to overcoming any impediments, review waiver requests, and present recommendations  to the IRM
Steering Committee.
FIDSIP 2/1202
                                                 li-2

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«M users of FINDS by entering toa and assigning ID codes.
                                                 ii-3
    FIDS1P 2/12/92
                                                                                       *"*


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   Chapter 1
INTRODUCTION

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Chapter  1
INTRODUCTION
        The U.S. Environmental Protection Agency (EPA) is actively developing and implementing data
 standards tnd policies1 to improve Agency-wide data consistency and sharing potential. IPA's actions
 clearly underscore its commitment to improve its data sharing capabilities, leverage its investment in data
 and enhance the compatibility of environmental data. EPA has established or initialed work on Agency-
 wide data standards or policies for.

         •       The use of Chemical Abstract Service (CAS) numbers to define chemical substances
         •       The format for electronic transmission of laboratory measurement data
         •       The minimum set of data elements to be collected when taking ground water samples
         •       The  location of  latitude/longitude coordinates associated with every entity  of
                environmental concern
         •      The approach for electronic reporting by regulated entities
         •      The use of a consistent coding scheme identifying all facilities regulated under Federal
                environmental laws.

         This document refers to die Facility Identification Data Standard (FIDS), presented in its entirety in
   Appendix A. The FIDS is a data management standard that will improve the compatibility of all Agency
   facility data by providing a fundamental piece of "linkable" information, the EPA facility ID code, for all
   facility-oriented data collections.

           This document presents the FIDS implementation plan to be followed by EPA and its partners in
   environmental protection, as required in Section 7(a)(2) of the Facility Identification Data Standard.  The
   remainder of this chapter discusses the purpose, background, objectives, and applicability of the FIDS.

    within CHRM.

    FIDSI? 3/13/92

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1.1 PURPOSE OF  THE  FACILITY
       IDENTIFICATION  DATA  STANDARD
                                        __      4
       The FIDS was developed 10 provide the Agency with a unique identifier thai all programs will
apply to individual facilities. .Hie impetus for  development of the FIDS was thai the various media
programs often labelled the same regulated entity differently, with each program using its own coding
acberoe. This situation resulted in nsers of different Agency computer systems having difficulty determining
whether data retrieved from two different systems were actually data about the same facility. This
phenomenon, an inability to link corresponding facility data across programs, impeded EPA from achieving
optimum effectiveness in regulating facilities  using all available information resources.  With  the
implementation of the FIDS, an Agency-wide coding scheme was established that will be the same for
Agency facility data across all programs.

       This new coding scheme utilizes the EPA facility Identification code, and is to be used by
all programs for facility identification. The EPA facility identification code (which may be referred to as the
'Facility ID code**) is 10 be assigned to every facility regulated under Federal environmental protection
laws3. In addition, the facility identification code assigned to a facility is to be pan of every data collection,
whether manual or automated, containing information on that facility. Programs may continue to use their
own identification coding schemes internally, but, in addition, they must maintain the EPA facility
identification code.

       Full adoption of the FIDS by all EPA programs and  their state and industry partners in
environmental protection  will enhance current capabilities to identify and share existing facility dam,
improve the quality and consistency of all facility data, and ultimately reduce some of the need to collect
new data. For example, ongoing Agency initiatives that will benefit from the FIDS include enforcement.
pollution prevention initiatives, risk-based decision making/comparative risk analysts, vulnerability
assessments, and "hot-spot" identification. All of these efforts are multi-media in nature and benefit from
improved capabilities to gather together all relevant data about a facility.
2 - This code it no knf e* referred to «ihe *EPA ID code* 10 avoid eonfurion wiih previous coding schemes
3 _ ID *„ eaablisk a data gundordfor mime facility identification codes to he maintained in all EPA data
    eoUectwiu containing information anfaciliiiet regulated ty EfA wider authority cf Federal environmental
    Initiation;- EPA Order 21103.40/90, See. 1. p. 1
FIDSIP 2/12/92
1-2

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 1.2  BACKGROUND  OF THE FIDS

        In 1988, a detailed feasibility analysis of adopting a "facility-level data standard" was performed4.
 Many different options were considered, including:

        •      Basing an identification code on the location of a facility (by embedding latitude/longitude
               coordinates in the code) which might define where a facility is located
        •      Basing an identification code on the Standard Industrial Classification (SIC) code which
               could define the type of facility
        •       Appending to the code called "the EPA ID code* another code describing a portion of the
               facility
        *       Basing an identification code on the Dun & Bradstreei (D & B) number to define who
               owns the facility.

        The options were analyzed to identify which one would be most beneficial to all environmental
programs.  None of the options examined thai involved embedding or appending a meaning into the
existing ID code would have been beneficial to all environmental programs.  In short, there was no one
tingle type of information thai was used by all the programs or was applicable to all types of facilities, so
a single coding scheme which was somewhat descriptive of each facility could not be applied uniformly
throughout the Agency. Therefore, an identification code that would be unique to each facility, but have no
embedded meaning, was recommended. This conclusion formed the foundation of the FIDS, which was
presented for Agency-wide review in December of 1989. All components of the Agency, including all
regions and all programs concurred with the recommendations. Thus, the Facility Identification Daia
Standard was made final in April 1990."

1.3  SUMMARY  OF THE STANDARD

        The Facility Identification Data Standard establishes that each facility regulated under Federal
environmental laws will have a unique facility  identification  code (referred to as  the 'EPA facility
identification code" the "facility ID code" or the 'EPA facility ID") which will serve as the primary EPA
facility identifier and thus be the same for that facility across all Agency information collections. The EPA
facility ID code is to be composed of 12 characters. The first two are the FPS alphabetic code for the state
in which the facility is located, and the last 10 are digits that have no embedded meaning beyond serving as
a unique identifier for that facility.
4 -
                          EPA F«ri«tv Iffl* "•" Sundtrf-- ORMAMSD. 1988
FIDSIP 2/12/92
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           1.3.1       FINDS
                                                   4
           Section 6 of the FIDS establishes the process of assigning EPA facility ID codes through
    • central facility data base maintained by the Office of Information Resources Management
    (OIRM). Exhibit 1-1 illustrates this process.  (HUM'S central facility data base is the Facility
    JMDcx System (FINDS), which, is a computerized data base containing an inventory of facilities
    regulated under Federal environmental laws.  Each record in the FINDS data base represents a
    unique facility, distinguished bom other unique facilities by its EPA facility ID code. For each
    facility record, FINDS contains basic identification information (name, address, etc.) and a reference
     10 sources of more detailed program data about that facility. Two documents that detail FINDS
     guidelines are available:  the FINDS User's Manual and the Procedures for Indiana Sute
     Participation. These documents provide guidelines for some frequently encountered problems, such
     as resolution of program data discrepancies, usage of naming conventions, and application of
     common abbreviations.

     1.3.2   EPA  FACILITY IDs IN  PROGRAM DATA  BASES

             A crucial factor in achieving EPA's goal of improved data sharing is the presence of a
      common  denominator, a facility identification code, in every Agency data base containing facility
      data. EPA facility identification  codes art  required  for me  in every  facility-
      oriented EPA data collection, both manual and automated.  EPA facility IDs do not
      preclude any other identification codes used by the programs. Instead, they are fo addition  to the
      program identification codes (i.e., the program system must maintain both). Thus, there will be
       complete correspondence between program facility data and EPA's inventory of facility data sources
       maintained in FINDS.

1.4  APPLICABILITY OF THE  STANDARD

        The FIDS is applicable only to certain entities of environmental concern. These entities are
facilities that are regulated under Federal environmental laws. EPA facility ID codes, however, can be
assigned to non-regulated or exempt facilities u the discretion of the program (such as those regulated under
state, but not Federal, environmental laws)5 to assure historical continuity in data about those facilities
 5- "-JAe] principles of the Standard can be extended to cover
 Discretion.*
 FIDSIP 2/12/92                                 *'5
                                                                            lee

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 should they ever become regulated under Federal environmental law. More detailed guidance on the
 o^uudon of a "facility" is given in the «ections below.  ,

        1.4.1        FACILITIES TO WHICH EPA FACILITY ID
                       CODES MUST BE ASSIGNED

                The word 'facility' represents a wide range of entities as defined by each of the
        environmental media programs within EPA,  Inconsistency in the definition of a "facility* among
        the environmental programs poses a challenge in ensuring the uniform assignment of facility
        identification codes. It is difficult to have • tingle, all-encompassing facility definition that
        satisfies the specifications of all the programs. Therefore, the FIDS defines a facility as '...a
        Vocational entity, deliberately established as a the far designated activities, but not primarily for
        habitation (even though on-rite habitation  may be necessary to (he execution of the primary
        activities). Examples include a factory, a military base, a college, a hospital, a national park, en
        office building, or a prison." 6 This definition, while seemingly general, allows program managers
        (who help determine whether an entity should have an EPA facility ID code) to  apply c
        "common-sense" approach to uniquely  defining a facility.  This approach is taken
        because, among the various environmental laws, a facility:

                •       Might be a discrete location (e.g., with well-defined properly boundaries) ai
                       which there is environmental regulatory activity (e.g.. a permit has been issued
                       to this location, or monitoring at this location is required)
                •       Might be separate areas  linked by a common  environmental concern
                       (e.g., a spill spanning several properties), and might represent a "site" rather than
                       a single plant
                •       Might have several geographically  separate portions which are linked  by
                       common ownership (e.g.,  a Federal facility with non-contiguous sections).

               Exhibit 1-2 illustrates these three  ways that  an entity could be conceptualized as a
        'facility.' Program managers, in developing and implementing their FIDS implementation plans
        (Chapter 4). will ultimately identify which of their regulated entities are within the scope of the
        FIDS.  They night apply the following  conditions when  deciding whether an entity  of
        environmental concern is a facility*:

               •       Is the entity the most all-encompassing level, defined by commonality  of
                       ownership or similar environmental circumstances?
* - Appendix A. EPA OtOa 2180J. 49/90. p. S, Section Ks)
FIDSIP 2/12/92
                                                1-C

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                 Ediibit 1-2
             Facility Concept
                           ENVIRON-
                           MENTAL
                           CONCERN
             OWNERSHIP
HDSIP 2/12/92
                       1-7

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               •      Do activities occur that are regulated tinder Federal environmental law?
               •      Do or Could those activities came envimnm«ttiuJ concern at thai location?

               If an entity meets all of these considerations, whether it is regulated by EPA or a
       delegated slate, it is within the scope of the FIDS. One rale is always true: every facility will be
       assigned only one EPA facility identification code, although a single facility may be regulated by
       many programs and thus have many program IDs.

               Exhibit 1-3 summarizes the guidelines for assigning EPA facility identification codes to
       entities of environmental concern. Appendix B presents suggestions for what could be considered 2 I
       "facility" within each national environmental program. The sections below offer more detailed
       guidelines for determining whether an entity of environmental concern is indeed a "facility."
               1.4.1.1
REGULATED  FACILITIES
                      The ultimate source identifying which "entities" are considered "facilities" is
               found within the statutes of Federal environmental laws. If a facility comes under the
               jurisdiction of any Federal environmental law administered by EPA, regardless of whether
               that law is actually implemented by EPA. a delegated state, or a local agency, then ii
               must be included in FINDS and issued an EPA facility ID code. The responsibility for
               implementing the many environmental programs varies, with EPA  managing some
               programs (Superfund, TSCA'. FIFRA&) and states managing others (RCRA9,
               NPDES'O, CAA", SDWA*2). This fact has implications in delegating responsibilities
               for assigning EPA facility ID codes.  Chapter 3 discusses responsibilities among the
               various participants of facility ID code assignment in detail.

               1.4.1.2      NON-REGULATED  FACILITIES

                       In certain cutrs it may be appropriate to assign EPA facility ID codes to entities
               that are not regulated. Such cases might include:
' - Toxic Substance* Control Act (TSCA)
* - Fed
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                                                1-9

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                        •       Facilities thai have been exempted from environmental regulation (but
                                mjghi otherwise be regulated if not for the exemption, for example, if
                                they wee "grandfathered out* when a law was enaaed13)
                        •       Plenties regulated wider sate environmental laws that are not regulated
                                by any FederaJ environmental laws
                        •       Facilities that are meted because of possible environmental effects, ton
                                •re not yet regulated per te.

                        This last ase Bhows die value of the "common tense approach" to assignment
                of facility ID codes. A facility which is currently tracked but not regulated, or which is
                regulated under state, but not Federal, law is not required to have an EPA facility ID code
                under the FIDS.  Tracking information on that facility by assigning an EPA facility ID
                code to it before it actually attains "facility status* will ensure continuity in information
                tracking about (he facility should its status change.  Therefore, alignment of EPA
                facility  ID cedes  to  non-regulated  facilities  tt  encouraged  (but  not
                required).

                1.4.1.3 COMPLEX  FACILITIES
                        The FIDS requires  that the facility ID code be assigned to the most "all-
                encompassing" interpretation of a facility'4, meaning that what could be considered
                subponions of a facility (such as individual point sources, non-contiguous portions, or
                operable units) are not facilities themselves, but are "pans of the whole" which must bs
                linked by the same EPA facility ID code. In other words. EPA facility ID codes are to be
                assigned to all environmentally-regulated facilities, and all subponions of a facility such
                as its outfalls and waste disposal areas are to have the same EPA facility ID code as the
                most all-encompassing level of what can be considered the facility15. This is particularly
                relevant to:
                               Facilities regulated under several lavs  ~ Many facilities are
                               regulated under several  environmental laws because  they have
                               sabportions that meet the criteria for "regulated entity' under all those
                               taws, such under both EPCRA1* and NPDES.
                                                                                       most
& — For ample, there hive been "•mnimm of tius rinution in die retuthoriuiion of die Clean Air Aci
14 - "Intome cases, a facility with complex, multiple fnactitna may have several ptanu or establishments
operoiinj within to property boundaries. For these fadliues. ID cotes »iU generally oe asstfied to tkt
comprehensive "level- FIDS. 4000. Sec. Lb, p. 6.
"- Sub-portions have to be linked to the aD-encomparinf facility level in the data bate n that FINDS can
feeofttize Ac facility-level data within the  rytifm
1« » Emergency PUnninj md Community Rijhl-io-Kiiow Act (EFCRA)
FIDSIP 2/12/92
                                                 1-10

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                   •      Facilities with non-contiguous portions •• Many facilities are
                          composed of aevenl portions that ait separated by other things (such as
                          nads or another property) that are not pan of the facility. Each of the
                          non-contiguous portions of the facility will carry the same EPA facility
                          ID code, indicating that • relationship exists between these different
                           locations.

                    •       Off-titt portions - Occasionally, adverse environmental impacts
                           not within property boundaries of a facility can be directly attributable
                           to activities of the facility. Certain of these off-facility sites may have
                           cleanup  activities. Or, a facility might be required to have off-site
                           monitoring stations. Although these off-site locations  may get their
                           own program-specific ID codes, they all should carry the same EPA
                           facility ID code as the facility with which they are associated.17. This
                           is particularly true for RCRA ground water monitoring wells which are
                            stored individually, not by facility, in STORET.


                    I/, in  a  particular case,  thert  it  ambiguity about  the level  to

             which the facility  ID codt should bt assigned (i.e.,  which   level  is  the

             "most  comprehensive"),  the  decision  should   be   based  upon   the

             environmental circumstances of the  cite.18 For  example:

                     *       If all  the facilities  within an  Industrial park  are  linked by
                             a common environmental  concern, such as one that results in
                             designating the whole park  as a single  Superfund site, or there is
                             common ownership and one Form R  submitted under EPCRA (Title
                             III)  is appropriate,  then  the  tile  is  assigned  a tingle EPA
                             facility  ID  code

                      •      If the entities are  unique and  independent from  others  with
                              which they happen to be in close proximity (or share a location) anil
                              have  no common linkage  other than location,  they  could be
                              considered  separate facilities  and could  thus  each  be
                              assigned  separate  EPA facility ID  codes.


                       Facility situations are so unique and varied that it is impossible to cover all

              . possible scenarios or to develop a generalized rule satisfactory for all situations. If ir

               therefore crucial  to have professional  staff involved  In  EPA facility ID

               code assignment  and  a mechanism  In  place  to resolve   discrepancies.

               Particularly troubling definitional cases should be brought before the Facility

               Identification Advisory Task Force (FIAT) for resolution. A brief description of the FIAT

               is given in Chapters 2 and 3.


17 - Off-aite portions have to be linked to (he all-encwnjwMini tacfflry level to the dit* base so thtt FINDS ca
recognize the facility-level daia within the lytten.
18 - "fa tome easts,  a facility with complex, multiple fimcfums  may have several plant* or aaabl'ohmeni*
operating within 'at property boundaries. For these faolitia. ID codes will generally be atsifned to ike most
comprehensive level.' However, a temple* facility with multiple establishments or cperaiont may receive
several IDs ? more than one code it appropriate.- EPA Orfer 21S03,4/9/90, Sec. K*\ P 6
 HDSff 2/1M2                                    M*

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       1.4.2     FACILITIES THAT  ALREADY  HAVE  "EPA  ID
                   CODESMTIOM FINPS

               FINDS was already operational at the time that the FIDS was established (April, 1990).
       Staff from the hazardous waste programs, both RCRA and Superfund, teljed heavily upon FINDS
       ID assign facility identification codes for creating records in their own program data bases and
       Hacking other sources of data for their facilities. Therefore, identification codes had already been
       assigned through FINDS to many facilities, particularly hazardous waste facilities, by April of
       1990. UK FINDS identification codes were 12 digits long and had either a DUNS19 number or a
       GSA20 code embedded in them.  Some of the programs needing these codes, in particular RCRA
       and Office of Federal Activities, used the codes embedded in the FINDS identification codes to son
       through and select facility records, or relate those  facilities to other data bases (such as Dun &
       Biadstreet}.
               These FINDS ID codes are "grandfathered" in the FIDS and do not need to be replaced
        with the new EPA facility identification codes. Facilities to which  "EPA ID cedes" had
        beta assigned prior to adoption  of the FIDS do  act have to have them  replaced
        with  new EPA  facility Identification codes  (the data  element  name,  however,
        should be changed to "EPA Facility Identification  Code").  However,  the  minimum
        set of data elements required for FINDS still needs to be provided for synchronized updates in order
        to keep FINDS current. The appendix to the FIDS clearly states mat "...These codes do not have
        to be replaced, if., new standardaedlD coda for these facilities need not be assigned. ": !
               By "grandfathering in" the IDs assigned prior to adoption of the FIDS, as we!) as by
       assigning new IDs to new facilities according to the standard, the population of identification codes
       assigned by FINDS will eventually become a mixture of old and new codes. Because of this
       heterogeneity, program systems will no longer be able to rely upon embedded meaning in these
       codes. This may mean developing an independence to any meaning embedded in the ID codes (such
       as software that assumes that pan of the ID code is a DUNS number). This aspect should be
       considered in the program implementation plans (Chapter 4).
  - Don ft Brtdstreei DUNS Univeni] Namberinf System
 0- Ccneril Services Adraraimtian (GSA)
 > - Appendix IP EPA Older 21103,4/9/90. Sac. 4A. pp. A-4 a> A-3
HDSIP 2/12/92
1-12

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                            -.• I-..}
  1.4.3        ENTITIES THAT ARE NOJ  FACILITIES


          There are many entities of environmental concern that are not 'facilities." These entities

  ve not locationally based and/or permanent. Such entities include:

          •       Placet   that   CAR   be   locatlonally  Identified   by   their
                  latitude/longitude  coordinates  and about which data  art collected.
                  tuch as  ambient  monitoring nations, fiver reaches, protected habitats, or
                  ecoregions, which ait tracked or monitored for their environmental significance
                  but ve mot (nor  tnt  vill be) regulated

           •       Businesses  that fte  regulated but  cannot  be  Identified by their
                  "environmental"  location   becoute  they  are  mobile, such  as
                  transporters of wastes or water haulers

           •      Temporary  entities, auch as highway spills that ve quickly cleaned up. or
                   portable operators, that operate at a particular location (with a permit) for a shon
                   period of time and then move to another location to operate (e.g., barges, mobile

                   air pollution sources)

           •       Corporate  locations thai  may be identifiable by their Dun & Bradstreet
                   numbers, but  at  which no activity which  could cause  pollution  at
                   that location  occurs,  such as corporate  headquarters  offices or broker
                   locations (these companies may be permit holders for regulated activities ai other
                   aiies, and those sites would be "facilities")

                   Places for which permits  to build have been applied, but which have not
                   yet  been  constructed.

            There are, and will be, entities that do not Hi existing definitions or  guidelines. For

     example, uncontrolled hazardous waste sites are almost all unique in their spatial, ecological and

     corporate circumstances. Therefore, careful control and experienced judgement must be used in

     determining whether an entity is a "facility"  that requires assignment of an EPA facility ID code.

     The FIAT, as introduced in Chapter  2,  will act as the oversight organization  for FIDS

      implementation and will be responsible for determining whether an entity type is within the scope

      of the FIDS.  Additional responsibilities of the FIAT will be discussed in Chapter 3.
FIDSIP 2/KW2                                  *"13

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              Chapter 2
AGENCY-WIDE FIDS IMPLEMENTATION PLAN

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Chapter  2

AGENCY-WIDE  FIDS
IMPLEMENTATION   PLAN

      Implementation of the FIDS is in Agency-wide undertaking and wffl require careful coordination
among all participants. For implementation to be completed within a suitable time frame, there is a
schedule of steps that must be performed across the Agency. Progress in meeting this exact schedule may
be affected by the timing of events within each individual program, the cooperation of FIDS panicipams,
and resource availability.

      There are six basic sups to Agency-wide FIDS implementation:
            Initial reconciliation of Priority I systems
            Establishment of the Facility Identification Advisory Task Force
            Development of program-specific FIDS implementation plans
            Revision of data systems
            Revision of data collection and correspondence instruments
            Revision of on-going procedures and commencement of synchronized updates.
      The first section of this chapter details these basic steps. There are other critical components to
the Agency-wide FIDS implementation plan including the identification of resources needed to implement
the FIDS and establishment of a process for waivers. These topics are discussed in the second and third
sections of this chapter.


2.1  STEPS  AND  SCHEDULE TO  IMPLEMENT
       THE FIDS

      Exhibit 2-1 displays the schedule for each step in implementing the FIDS. Full implementation of
the FIDS is expected to require five yean and will be conducted throughout the Agency, its regulatory
partners, and the regulated community.  The steps in the FIDS implementation plan and the dependencies
between them arc discussed m the sections below.
FIDSIP 2/1202
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RDSIP 2/1202
                                           2-2

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        2.1.1    COMPLETION  OF INITIAL RECONCILIATIONS
                                                    t
              The first step in implementing the FIDS has been to conduct initial data reconciliations
        between FINDS and Priority I data systems. Priority I data systems include RCRIS (OSW);
        CERCUS (OSWER); Enforcement Docket System (OECM); TR1 (OTS); AIRS (OAQPS); FF1S
        (OFA); PCS (OWAOWEP). These reconciliations have been performed to:

              •      Ensure that there is • FINDS facility record for every facility in the Priority 1
                     data bases
              •      Ensure that EPA facility ID codes are assigned to each facility currently in the
                     program systems
              •      Transfer the necessary data from the program systems to FINDS to perform
                     synchronized updates when (he development of synchronized update software is
                     complete.

              Initial reconciliations between  FINDS and Priority I program   systems
       hove  been  completed**  through a combination  of automated and manual processes.
       Continual synchronized updates with the Priority I systems are ideally targeted to begin in June
       1992.

       2.1.2     ESTABLISHMENT    OF    THE     FACILITY
                  IDENTIFICATION  ADVISORY   TASK   FORCE
                  (FIAT)

              The Facility Identification Advisory Task  Force (FIAT) will be  the organization
       overseeing FIDS implementation.  It will resolve questions relating to the definition of a
       "facility." The FIAT also will monitor all activities related to the FIDS and facilitate changes to
       the implementation plan as necessary. There are several steps to establishing the FIAT:

              •      Appointment of FIAT members
              •      Development of the FIAT charter
              •      Establishment of procedures for the FIAT to follow.

              The  Assistant  Administrator  for lite  Office  of 'Administration  and
       Resources  Management (OAKM)  will tolielt representatives  from   non*OARM
       organizations, $ueh ts  EPA  regional offices and nates.  The Chair of the 1RM
       Steering  Committee  will appoint  the  FIAT members from within OIRM.  The
22- "Re-updttes* ire being performed periodically until (he tynchroniud npdue pi

FIDSIP 2/12/92                                2-3
; it futtliied.

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          FIAT will be etairrd by ihe Piogram M.ager for Data Aoministnuion. Alt memben */ rt.
          FIAT  will be Uentifltd by the  end of Jforember iff].
                The FIAT
         activity.

         inisaonindeatL filiation of the FIAT charter is in.ponantforAgency.wide establishment of
         its role .nd authority. TkchinerfarlheFUT is tobcmified by Ae middle of December 1991.

                Concurrently, die FIAT MB develop procedural guidelines for its activities.  These
         guidelines will:
                       JJBXUCIpBXIlS
°f eommuni««i°n
                                                               FIAT members and FIDS
                                                                     clrcumstances
                                           for.each1RAT -tivity (which will include program-
                          ific FIDS impleroenuiuon plan review, waiver request reviews  svstem
               FIAT   tttobliihmtnt,  Including  termination  »/ i«   mtmbership,
        thantr end  procures, thovld bt complete* by the end of December 1991.  At
        that  point,  media program managers will have a forum for submitting their program
        implementation plans, the next key step in FIDS implementation,
        2.1.3    COMPLETION     OF     PROGRAM
                   IMPLEMENTATION  PLANS
                                      FIDS
               The FIDS requires that FIDS Program Implementation Plans be developed by program
        managers^ across the Agency. TJwse plans are lo identify entities of environmental concern
        within each program thai «re within the acope of the FIDS (and must be assigned EPA facility ID
        wdes).  Tbe plans also should -map oof the process for program system synchronization with
        FINDS by either manual or automated techniques. Chapter 4 of (his document describes the
        essential components of program implementation plans.
B > EPA Order 21*0.3.40/90. S«. 7
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                Any one program may have levenl data collections containing facility data. Each FIDS
        implementation plan, white being specific to one program, may address several data collections
        (manual and automated). Priorities may have to be established to systems within a program for
        reasons of practicality or resource constraints.

                The  larger  fate for  completion  of all program  FIDS Implementation
        flam is the end of December 1991.  This date allows enough time to accommodate the
        FIDS in the budget planning process of every program.   The exception is FIDS
        implementation  plant for programs with  thote  tystems to be  synchronized firtt
        (Lt.t  Priority I tystems)  which thouU be completed by April 1992.

                States volunteering to participate in the FIDS  may be given data entry privileges to
        FINDS on a case-by-case basis, in order to have data entry access to FINDS, state procedures
        (similar to program implementation plans) should be developed by the states in cooperation with
        FINDS management.

        2.1.4    REVISION OF INDIVIDUAL DATA SYSTEMS

               The next step in Agency-wide implementation of the FIDS is to ensure that all applicable
        computerized data systems meet FIDS requirements. Program systems will be modified to house
        the EPA facility identification code and a process will be established to ensure correspondence
        between the facility data in  program  systems and the data in FINDS.  This step involves
        developing a way of distinguishing/aciliries in the data base from other entities outside the scope
        of FIDS.
               Each of the steps to modify program systems in support of the FIDS must be identified
        in the individual program implementation plans (Chapter 4).  Completion of Priority I
        program  systems modifications ere  targeted for June 1992.  Modification of  all
        other facility-related tystems  addressed  In program FIDS implementation  plans
        that  are  not Priority I must be completed  by December 1994.

               Another facet of this system revision step is to make lat/long data available for facilities
        in FINDS whenever possible. OUtM is undertaking an address matching Cadd-mat") project which
        should produce geographic coordinates O»v1ongs") for all FINDS facilities. This serves to
        minimize duplicate tocational data collection efforts for the programs. The anticipated completion
        date for this ladd-mat" effort k lone 1992.
F1DSIP 2/12/92
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         2.1.5       REVISION OF DATA  COLLECTION AND
                      CORRESPONDENCE INSTRUMENTS

               Tie FIDS is applicable to manual information as well as computerized data systems24.
         It applies 10 selected forms, correspondence, and other •fcaper" documentation. Revision of these
         instruments should be conducted in concert with system redesign. Instrument modification ensures
         that uniform facility identification is a routine step in all facility-related data collection, and that
         fte process is in place to ensure consistency between program paper records, program data systems.
         and FINDS.

               Section 4.4 and Appendix C of this document identify forms and other instruments (such
         as surveys or contracts) for which modification might be necessary to include the EPA facility ID
         code. Modification of data collection instruments and correspondence may involve several steps.
         such as notification in the Federal Register, obtaining OMB approval, and pre-printing forms and
         surveys that are sent out by EPA.  One or more of these activities may be necessary depending on
         the program.

               Documentation instrument modification may begin upon  completion of the  program
        implementation plans.   Changes to data Input forms for Priority I systems  should
        be  completed  by  June  1992.    Modification  for  ell  ether applicable
        documentation instruments should be  completed  by December  1994, coinciding
        with completion  «/ program  system modifications.

        2.1.6    ON-GOING   PROCEDURES  AND  COMMENCE-
                  MENT OF SYNCHRONIZED UPDATING

              By the beginning of 1995:
                     Program implementation plans shall have been completed and will include
                     procedures to ensure that the information necessary to assign facility ID codes is
                     available and transmitted to HNDS
                     ftogram forms, correspondence, and other documentation instruments should be
                     modiSed to include the EPA facility ID code
24- -_«rt«niied or mntial data «Dectico*_- (EPA Onto WIOJ 4/8/90, Sec. 2, Para. 1),
    IEPA faciliiy ID code*] sap j^rf,^ &„»_- 
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                   Program lystems for both Piiority-1 and other EPA data bases wBl have teen
                   Bxxlified to:
                          House the EPA fccflity ID code
                          Synchronize iBtomiiically with FINDS
             Upon completion of these Heps, the EPA facility ID coding scheme will become an on-
      going process to be followed by EPA, its regulated community, state partner*, and agents
      (grantees, etc.)-  FINDS management wfll maintain its data base, by assigning EPA facility ID
      codes and performing automated synchronized updates.
                                                        >

2.2   OIRM       RESOURCES       FOR       FIDS
        IMPLEMENTATION ACTIVITIES

       In order to complete the steps to implement the FIDS, OIRM can provide support in the following

areas:
        •      Guidance in developing individual program implementation plans (see Chapter 4)
        •      State encouragement through SEDM grants or other mechanisms
        •      Development of synchronized update software
              Participation in the FIAT
              Redesign and maintenance of FINDS, including development of data quality feedback
               procedure development and address matching to provide lat/longs to applicable facility
               lecords
        •      Technical consulting.

         Each of these resources is described briefly below.
         2.2.1    GUIDANCE    IN    PROGRAM    FIDS   PLAN
                   DEVELOPMENT

                Chapter 4 of this document presents guidelines for the components of a program FIDS
         implementation plan. Further assistance may be available from the FIAT upon request.
   FIDSIP 2A2/92                               2"7

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       2.2.2    STATE  EPA  DATA  MANAGEMENT PROGRAM
                 GRANTS
                                          <

              Although cutes are not required to participate directly in FINDS, they must adhere to the
       FIDS for facilities that they regulate under federal environmental laws. FINDS synchronized
       qxlates will ensure for noes that their facilities, regulated under federal environmental law and in
       national data bases, art assigned EPA facility ID codes. EPA's SEDM Program has a financial
       assistance program available for activities that result in improved data sharing between states and
       EPA. States can apply these funds towards developing their own FINDS procedural documentation
       Since FIDS implementation aligns closely with the goals of the SEDM program.  SEDM's
       financial assistance program has a yearly competition held at the Regional level.  States must
       submit a proposal to be considered.  SEDM may also provide contractor resources to states for
       such activities.

       2.2.3    FINDS  ENHANCEMENTS

              OIRM is currently developing software to perform synchronized updates between FINDS
       and major EPA program data bases. Other enhancements (such as the addition of locadonal data
       storage capabilities and the creation of lat/Iongs for facilities by address matching) are also being
       made to FINDS with the goal of providing a responsive, high-quality, comprehensive agency data
       base of facility-related information.

       2.2.4    PARTICIPATION     IN     THE    FACILITY
                 IDENTIFICATION   ADVISORY   TASK   FORCE
                 (FIAT)

             The FIAT will have several dedicated members from OIRM. as mentioned in Section
       2.1.1 of this Chapter, minding the EPA Program Manger for Data Administrator, who will serve
       as FIAT chair. The chair of the FIAT will communicate its recommendations to the chair of the
       IRM Steering Committee on requirements to implement the FIDS more effectively and other
       issues for attention.
FIDSIP 2/12/92

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     2.2.5    FINDS  MAINTENANCE
      M*. *» «n «w- - •-":rz±lTZ.ll« A^™^
database. iroinaie
                               lit  control. ORM will wok, through the FIAT, to
      component of FINDS maintenance is quality control.
      develop data quality feedback procedures for FINDS.
2.3  WAIVERS  FROM THE FIDS

       Situations nay vise where it is not useful or possible to conform to FIDS requirements. In
anticipation  of these situations, the  FIDS includes  « provision /or  waivers25.  The waiver
provision in the FIDS serves to:
       •     Incorporate a measure of reasonableness in FIDS implementation
       •     Demonstrate sensitivity to the complexities of adhering to FIDS requirements
       •     Develop an approach ensuring ihe uniform administration of the FIDS
       •     Ensure that FIDS objectives are given serious consideration by all programs.

       The FIAT is responsible for establishing criteria for reviewing waiver requests. Waiver requests
 should be initiated by program managers and transmitted through their Senior Information Resources
 Management Officer (SIRMO). The HAT will review all waiver requests and prepare recommendations for
 the chair of ihe IRM Steering Committee, who will make ihe final decisions.  Some general guidelines for
 Ihe waiver process are discussed below.

        2.3.1    CONDITIONS   WHEN    WAIVERS   MAY   BE
                  APPROPRIATE

               There may be situations when adherence to FIDS requirements is difficult, impractical, or
         not valuable. Waiver requests inay be apprciwiate for a romberrf
                •      The EPA facility rocofc assignment itquireinent
                      Data collections to which the FIDS applies
                      The schedule for implementation
                •      The necessary system or instrument modifications.

   25 - "-J**r« may etui. turner, eattt « wtirf aaptionf u> (he n^turmaa* oftttit Order art warrant*}. /„
       these eases, prof ram offices dull  demonstrate reasons for wah«r...Jte Wl>b*t <#** **" ** ""'/>«' in
       wrtrtif of At dispotition of Ac water.' EPA Crier 21803. 4/9/90, See. 9. pp. *•?
         2/1J02                              2"9

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                   Start*, fa «tkl, mho, M, be vtnfto, ^^ ^
                  .      The likelihood that the data collection wOJ never be needed by or accessible to
                         secondary data users.

                  The FIAT wffl clarify the exact conditions and criteria for reviewing waivers.  Waiver
          applications are not encouraged and wflj not be granted except when At waiver justification can be
          demonstrated to be of extreme importance to the operation of the program.

          2.3.2    PROCEDURES  FOR WAIVER  APPLICATIONS

                 Waivers will be  granted based upon written applications prepared  by program
          managers that are submitted to the FIAT. The applications should include:

                 •      A thorough description of the data collection or group of regulated entities.
                        including its purpose, intended use, attributable information, and type of data
                        housed in the collection or available about the regulated entity
                 •       A discussion of FIDS requirements, with a clear explanation of FIDS provisions
                        that are in conflict with the program mission
                 •       A sufficient demonstration that there is no need for secondary use of this data
                        collection (in the case of waivers for a particular data collection).

                Prior to submission of the waiver application to the FIAT, the  program manager
         preparing the waiver  application  must get concurrence from the SIRMO of thai
         program.  A memo from the SIRMO to the FIAT should be part of the waiver application
         identifying the compatibility of the waiver request with the overall program and Agency
         objectives, and confirming concurrence with the waiver request

                Applicants  should submit waiver  nguests to the chair of the  FIAT.  The
        FIAT will review the waiver request and prepare a report summarizing its support or disagreement
        with it  The report wfll be delivered within one month of receipt to  the Director of OIRM, who
        will make the final determination  as to whether a waiver is granted or denied.26 The Director of
        OIRM will respond to the applicant, in writing, with approval or denial of the waiver request,
        within two weeks of receiving FIAT recommendations.
36 - ".-Tfce process to apply for a water if as foUowt-iubmit application to aw Director of OIRM, who has
    iwponiibfliiy for find dupo*iiiai>."  EPA Order 210903.40/90. Sec. *c), p. 6
FIDSIP 2/1202
                                              MO

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         2.3.3    CRITERIA  FOR WAIVER  DECISIONS

                The HAT wiD establish a uniform process for making recommendations to grant/deny
         FIDS waiver requests.  Because of great variability in the objectives, processes, and data
         collections of the many environmental programs, each waiver request will be considered on its own
         •writ  The following criteria, however, may be applied by the FIAT when reviewing a waiver
         ropiest

                       Incompatibility of the FIDS with the mission/purpose of the data collection
                •       Undue burden to me program or regulated community
                •       Inability to provide the information necessary to assure facility uniqueness and
                       assign an identificati
                       Improbability that the data coUecti on will be needed by secondary users
                       Competing priorities for limited  resources which outweigh  the  FIDS
                       requirements
                       Alternative ways of meeting the objectives of the FIDS.
               The FIAT will maintain documentation of every waiver decision and its rationale. This
        documentation will be useful in applying the same reasoning or criteria to future waiver
        applications and can be shared with other program offices considering development of waiver
        applications.
FIDS1P 2A2/92
2-11

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                Chapters
RESPONSIBILITIES FOR FTOS IMPLEMENTATION

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Chapter  3
RESPONSIBILITIES  FOR  FIDS
IMPLEMENTATION
      Section 2 of the FIDS Kates that "The requirements of (his Order apply to ell programs
responsible for data on regulated facilities reported 10 EPA end kept in automated or manual information
collections developed for programmatic, research, or administrative purposes?1* Responsibility is shared
by both media and non-media program staff at a variety of governmental levels, including EPA headquarters
naff, EPA regional participants, nave and local government participants and delegates, as well as the
(egulaied industrial community18. This chapter specifies the responsibilities of the various participants in
implementation of the FIDS.
3.1 THE  FACILITY  IDENTIFICATION
      ADVISORY  TASK FORCE (FIAT)

      The FIDS is expected to have broad impact on the Agency as a whole. For that reason, a forum
representing all participants has been created to oversee FIDS implementation and to address issues that
•rise. This forum is the Facility Identification Advisory Task Force (the "FIAT). The chair of the IRM
Steering Committee, to whom the FIAT will report, will appoint HAT members from OIRM.  Other
members will be invited by the Assistant Administrator for Administration and Resources Management
(OARM) from organizations such as EPA program offices, regional offices, and states. The chair of the
FIAT will be the Program Manager for Data Administration.

      The FIAT will monitor the status of FIDS implementation and maintenance, and will present
recommendations to the chair of the IRM Steering Committee.  Specifically, the responsibilities of
the FIAT ere to:

      *     Track the ttatus of  FIDS  Implementation  within  each of the major
            environmental programs, end develop approaches to overcoming  Impediments
            to FIDS adoption and implementation within and/or between the programs
27 - EPA Order 21803,4/9/90. p. 1
28 - EPA Order 21803,4/9/90, Sec. 7. pp. 4-5
FEDSIP 2/12/92

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          •      Develop criteria for processing requests for waivers from the FIDS, and
                make recommendations to the  Director of OIRM on framing or denying
                specific  welter requests

          •      Receive,  review,  and  comment  an Individual Program  or  Slate
                Implementation  flans

          •      Recommend operational policies regarding the FIDS end FINDS to the
                IRM Steering Committee is tunes vise

          *      frovldt guidance on the  content!  of the memoranda  of undemanding
                that  will  he developed between program end OIRM, documenting  the
                linkages between FINDS and their program system(s)
         •      Make decisions on what constitutes a  "facility", expanding on the guidance in
                Ibis document

         •      Develop t process for  Identifying new facllity-ortented data  oases to bt
                automatically reconciled with FINDS  and ensure that all such new  data
                bases/systems adhere to the FIDS
         •     froride status reports to the participating program, regional and state community
               on the Implementation of the FIDS.

         The members of the FIAT will act as emissaries, transmitting guidance, operational policy, and
  information to the rest of the Agency, states, and regulated community. The responsibilities of these other
  organizations under the FIDS are identified below.


  3.2  EPA HEADQUARTERS RESPONSIBILITIES
        UNDER THE FIDS

        EPA headquarters cuff are responsible for the large-scale adoption and implementation of the
 FIDS. The responsibilities both for non-media and media program personnel are described in the sections
 that follow.
       3.2.1
NON-MEDIA   HEADQUARTERS   PROGRAM
OFFICES
              Non-media headquarters programs ait defined, for mis implementation guidance document,
       •* those which do not necessarily implement a specific environmental law but serve the EPA
       ewimtmitytsawhole. These programs include the Office of Wonnation Resources Management
       (OIRM); the Office of Policy Wanning and Evaluation (OPPE); and the Office of Research and
       Development (ORD). At ihe teadquarteri kvel. these Jioiips are responrible for ensuring that all
       mechanisms are in place and processes are established »that the media programs, regions, states.
FIDSIP 2/12/92
                                         9-2

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  and regulated community can fulfill their responsibilities.  The specific responsibilities of the
  various non-media programs under me FIDS are presented below.

          3.2.1.1  The   Office   of   Administration   and   Resources
                     Management (OARM)

                  OARM is responsible for a broad array of issues, including human resources,
           EPA buildings, financial administrati on, and information resources management Within
           OARM. OIRM oversees or participates m all Agency information resources management
           activities, including system devebpmeni/enhancement, records management information
           dissemination, data management, bardware/sof ware/telecommunications acquisition and
           management, administrative records tracking, and other related activities. The FIDS79
           states that OIRM is responsible to:
                   •       Develop,  implement, and  ensure  adherence  to  this  data
                   •      Develop 0 management flan (this document) describing steps for
                          implementation of the standard
                   •      Provide guidance  end  technical  assistance  in  meeting the
                           requirements of this standard
                    •       Provide unique facility Identification todes in an efficient and
                           responsive manner
                    •      Maintain a central facility data base with identification codes
                           and basic information associated with each facility (FINDS)
                    •      Oversee resolution of conflicts regarding applicability or other
                           issues relating to the standard.

                     OARM and OIRM will oversee the initiation of the FIAT. Other FIDS
              responsibilities are attributed mainly to  two OIRM divisions:  the Information
              Management and  Services Division  (1MSD). responsible for  Agency-wide data
              administration, and die Program Systems Division (PSD), responsible for system
              development including FINDS and data integration tools. Exhibit 3*1 summarizes
              OARM responsibilities under the FIDS.
29 - EPA Order 21803,4/9/90. Sec. 7«, p. 4
HDSIP 2/12/92                                  34

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RDSIP 2/12*2

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        The .pecifie MpniMB*' */ WSD ***" '*' "DS "' "
                                                           Task  Force, 10


                                                           !ieilttI10n

                                              «««  * ^ FIDS Uirough the
                      Provide guidance  for  modtfylng f*r«*  or  changing

                      frocedure'to  addreti  FIDS requirement*.
                PSD                       F1NDS
                              Jt.*. wt wr.« praatol *«»««»u 10 illo. •»

                              participanon in FINDS


                              /„„„,«/ f Mir9  ««"'( 3»w lo 8ssure hiEh'
                              quality data and adherence to this aandard


                              Have FINDS  management representation  in the

                              FIAT
                                          ^  -# vmtrsan     with each program

                         Engage tn memoranda tf *^S the scope of the FIDS, to
                         program systems tnd FINDS .
_	                      ___  i, grORET aB oth« EPA Mwmd


K-IW.^^^^ZS?**11*'**'*
   program lyaant are managed wiUun program efficei.



FIDSP ana/92                             *'5

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                            National Data Fwcessing DM*, (NDPD) in OARM is responsible for

                 providing hardware, software. and telecommunications to meet the needs of the Agency.

                             responslbUMtt ,/ tte M>«> M
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HDSIP2AW2
                                      S-7

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                                Ensure   that   ike  EPA   facility  ID  teat  is  used
                                appropriately in all facility-related  data collecUon or analysis
                                activities,  including laboratory reporting

                         .       Support  FIDS  requirements  tn  Data  Quality  Objtctives
                                (DQO) development efforts forfacility-rtlated data collection activities.



                 3.2.1.4      Other Non-Media Organizations



                        The FIDS identifies responsibilities for several other non-media EPA groups
                 (also summarized in Exhibit 3-2). These include:


                        •      The  Proeuremtitt and  Contracts  Management Division,
                               which will  be responsible for entitling  FIDS requirements ere
                               adheres to  tit contracts issued by EPA

                        •      The Office of  Federal Activities  which  is responsible for
                               adopting FIDS requirements  and coordinating with FINDS in
                               the   maintenance  cf its Federal  Facilities  Information
                               System  (FFIS), and encouraging the  use  of  EPA facility
                               Identification cedes by  other Federal agencies.


                        The Grants Administration Division in OARM also has a role in the

                FIDS.  This office will be responsible for ensuring adherence to  the FIDS by

                grantees through grant stipulations in cases where grant recipients  are acting for
                EPA under delegated authority.



        3.2.2   EPA Headquarters Media Programs



                Media programs are defined as those programs in EPA with the authority to implement

        Federal environmental laws. They include the Office of Water (dean Water Act and Safe Drinking

        Water Act), the Office of Air  and Radiation (Clean Air Act), the Office of Solid Waste and

        Emergency Response (CERCLA/SARA and the Resource Conservation and Recovery Act), and

        the Office of Pesticides and Toxic Substances (Toxic Substances Control Act; Federal Insecticide,

        Fungicide and Rodenticide Act and the Emergency Preparedness and Community Right-to-Know
        Act of SARA).



               Exhibit 3-3 summarizes media program responsibilities for the FIDS.  Media program

       personnel In EPA Headquarters play a coordination role for the FIDS.  As such, they art
       responsible  to:
HDS1P 2/13/92
                                              3-8

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FIDSIP
               3-9

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                               FIDS Program Implementation Flans with guidance and
                      •usance from OIRM (the contents of which ire described in Chapter 4 of this
                      document)              <

               •      Engage la memoranda of understanding with OIRM, documenting the
                      activities and processes for linking their program system(s) to FINDS

                      Impltmtnt  FIDS mud FINDS coordination  with their regional and
                      gtaie counterparts, through cooperative agreements, grant stipulations, and
                      other tools (which are to be identified in their FIDS implementation plans)

               •      Revise their  information management tools, such  as forms and
                      electronic information reporting equipment to ensure adherence to the
                      FIDS

                      Prepare their  national  data  systems  to   house  EPA  facility ID
                      codes and, If appropriate, have synchronized  updates with FINDS

               •      Provide  support  for  FIDS  implementation   throughout   the
                      program with  personnel,  agents, grantees, delegates and the regulated
                      community

               •      Provide FINDS  with  the  basic identification data necessary to create
                      facility records and assign facility identification  codes (including distinction
                      between records relating to facilities and corporations)

               •      Ensure  the  timeliness   and  accuracy of the   basic  descriptive
                      information In FINDS from their program systems by developing a process
                      to coordinate with FINDS in data updates and error resolution3 *

                      Ensure that  EPA  facility ID  codes  accompany all  their facility
                      data in manual and automated data collections

               •      Notify the  FIAT  when any  part  of  the  approved  Program
                      Implementation Plan  cannot oe  adhered to

               •      Prepare waiver requests  for  submission to the Facility Identification
                      Advisory Task Force when necessary

               •      Have  a representative (through  the System  Managers  group) on the
                      FIAT.


               Many of the responsibilities of EPA Headquarters staff for implementing any media

        program are shared with their  counterparts in  the EPA regional  offices.  The regional

        responsibilities under the FIDS are described in the next section.
  - ProjTwn personnel wfll work with (he OIRM (FINDS) tytlem onager m keepini die descriptive informttior.
    up-to-date by notifying OIRM through euiomated procedure* when they become iwaie of * change in this
    mformauon." Appendix to EPA (Ma 2180J. 4/9/90. Sec. S.I. p. A-S
HDSIP 2/12/92
1.10

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3.3 REGIONAL    RESPONSIBILITIES   UNDER

       THE FIDS

                                                      i

       Regional participants include information management, media-, and non-media program personnel

(summarized in Exhibit 3-4). Tbe role of regional program staff is to ensure that assignment and use of

EPA fatality ID codes in all facfliry-felaied activities (e.g., permitting, inspections, etc.) is completed, that

the necessary information is available and correct, and that discrepancies arc resolved.  The specific

responsibilities of regional media program tuff art le:


       •       Entire the commitment of both program end tale  administration  ttaff to
               participate in EPA facility identification code assignment and FINDS upkeep

       •       Ensure that all  processes  ere  In place for assignment end use  of EPA
              facility ID codes among state and regional program participants (including inspectors.
               laboratory staff, contractors, etc.) through use of reporting forms, standard procedures, etc.

       •       Encourage ttote counterparts to  adopt  the FIDS (largely  through the  Regional
               SEDM liaison) and coordinate with state counterparts who are actually using FINDS to
               resolve data discrepancies

       •       Coordinate  with  regional IKM and  program ttaff 10  obtain EPA facility
               Identification codes,  resolve  discrepancies  in  basic facility  Identification
               data, and update the  FINDS source reference file by providing regional daia
               base administrators with all the necessary information to assign a facility ID code and
               update FINDS facility records  in a timely manner for those facilities not covered by
               synchronized updates

       •       Review  $ynchronized update  transaction  reports (if  asked) to ensure that
             .  FINDS data are comet and complete

       •       Verify that every facility ID tode assigned through FINDS is placed in
               motional program data systems, on hardcopy records, and is used in documentation
               such as correspondence, records, reports, etc.


       Non-media  regional FIDS participants  include IRM and technical personnel. The

responsibilities  of the regional information management  ttaff are to:

       •       Work  with regional media program personnel to  maintain FINDS and obtain
               EPA facility ID codes

               Communicate the importance  of ttate adoption  of  the FIDS,  provide
               FINDS information to states, and provide guidance or assistance in developing state
               FINDS procedures through the SEDM liaisons employing mechanisms such as grants,
               cooperative agreements, and contracts.


       Hie other regional participants, such as Environmental Services Division (ESD) staff, are equally

responsible for ensuring that aD facility-related activities such as sampling, inspections, etc. adhere to FIDS

requirements, particularly when  documentation of data related  to  a  facility  is  involved.
FTOSIP 2/12/92
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PIDSIP 2/12/92
                                                  S-12

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3.4 RESPONSIBILITIES  OF  STATES  UNDER
    THE FIDS

    Sine participants wOl play in increasingly crucial role in implementing the FIDS. This is due to
die expanding capabilities states have 10 collect and manage their own information and die trend towards
distributing the responsibility of administering environmental programs to regional, state, and local
agencies. There is also a growing need to share data that had been difficult to access by anyone outside the
immediate organization. Data sundardixation, which will result from full-scale FIDS adoption, will
improve states* abilities to share data with EPA and other states.
     States BJLV uphold the requirements of the FIDS for facilities regulated under
Federal environmental laws whether or not those facilities are also regulated under state taws (or by
the state as a delegate of EPA). States must use EPA facility identification codes in all data from activities
conducted because of Federal environmental laws (e.g., inspection reporting, system maintenance).
However, flares do mot necessarily have to become vn-Iint vsers of FINDS. States may
use FINDS in one of several ways:
     •   As indirect usen, through the EPA regional office program and FINDS staff
         As primary users (i.e., direct participants) of FINDS, entering data and assigning ID
         codes to faciuties under Federal and (if elected) state environmental laws.

     EPA regional personnel, including SEDM liaisons, will share the responsibilities of adopting the
 FIDS with the states in their region whether or not a state directly enters data into FINDS. The
 responsibilities of states under the FIDS, boih indirectly and/or primarily are summarized in Exhibit 3-5 and
      3.4.1 STATES INDIRECTLY USING FINDS
      .«„.—.-—rrjrrrrrr:
      r:rr-:i™- -—r=rs:
      =.=trriiitsr™-.
      =^=r=rrr=rr=r=
   FIDSIP 2/12/92

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RDSIP2A202
                                          3-14

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            stadirecilywing to FINDS:

















                                     —«.i. *.. .,turine a process for
                               ve i

              EfA
   SEDM M
342
          STATES DIRECTLY USING FINDS
                               •«« to FINDS wUI pn*»Wy have iwo types of
                               ics                     ^ ^
                             «
           St.« ^e^dec^ wve


         that «e involved:  IRM        who are •*•*   ^
                                              **"*
   Dtu Mmtjement (SEDM) Uiisen i



FIDSIP 2/12/92                         '*•»*

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            resources, and program personnel who execute ihe day-unlay activities of iheir programs. Tine role

            of state IKM penoaneP* so using FINDS is to serve is the central coordinator within the

            state for adoption of the FIDS. Similar to EPA regional 1RM suff. they art responsible to:

                   •       Develop  itate-tpecific procedures for •cent  to  FINDS, working
                           with FINDS management and state and regional program and DIM personnel, as
                           well as local government participants if necessary

                           Monitor  tkt  state-wide  assignment of  EFA  facility ID codes to
                           Utilities under Federal few and. if elected, also those under state environmental
                           law

                  •       Coordinate  with EFA  for Ihe assignment of EPA facility ID codes
                          performed by EPA (such as for CERCLJS or for programs not delegated to the
                          state), ensuring that EPA has current, correct facility identification information,
                          and (hat facility IDs assigned at the regional level are transmitted back to their
                          state program staff

                  •       Coordinate  with  EPA to  oversee and facilitate  the resolution  of
                          data discrepancies between program data and other collections (other siate
                          systems, national program systems) or FINDS on the basic facility identification
                          data so that all facility identification data are in concert

                  •        Notffy  other state and regional  participants  of changes  to  basic
                         facility identification data  and/or FINDS facility records  of which
                          they should be aware

                  *       Perform periodic quality  assurance  reviews  for  data consistency,
                         accuracy, etc.

                  •       Servt as the heat group for FiNDS information.


                 State program personnel for states with direct access to FINDS will have an active

         role, ensuring the proper and complete assignment of facility ID codes. These participants have

         ihe best understanding of what a unique facility is, and are in the best position to assign IDs to

         them, identify mistakes, and participate in error resolution.  Their responsibilities are to:

                 •      Ensure Ihe  commitment of both program  and data entry  staff to
                        participate in facility identification code assignment and FINDS upkeep

                •      Ensure  that ell  processes  are in place for assignment and use of
                        EPA facility ID totes among field staff, local government staff, inspectors.
                        laboratory staff, contractors, etc.. through use of reporting forms, standard
                        procedures, etc.

                •       Ensure  creation  of   mow  facility records  In  FINDS and  keep
                        existing records current and accurate for those facilities not already
                        contained in FINDS but which are regulated under Federal environmental law
                        (Whether Or not Mthnritv far the faw »»« fc*-» «i-«-~«•« — -•-	
FIDSIP 2/12/92


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                     to* 
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                Chapter 4
INDIVIDUAL PROGRAM IMPLEMENTATION PLANS

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Chapter  4


INDIVIDUAL PROGRAM  FIDS


IMPLEMENTATION PLANS


      Media program managers are responsible for developing individual program implementation plans

for the FIDS. Assistance in developing these plans is provided in me guidance given below and through the

FIAT (discussed in Chapter 3). Tbe PUT will review the plans and provide feedback on their adequacy as

well as how those plans are to be coordinated with those of other programs and the Agency overall. The

FIAT can be used as a resource for programs to resolve problems during development of their plans.


      This chapter describes the components to be included in individual program FIDS implementation

plans. Program FIDS implementation plans should have the following nine key components:


            Number and types of facilities
            New sources in FINDS
            Status of key data elements in each national program data collection
            Changes to programmatic forms or other data collection/documentation tools
            Automated updates
            Rotes and responsibilities
            Implementation schedule
            Quality assurance, and
            Resource availability and constraints.


      Exhibit 4-1 summarizes the components of program FIDS implementation plans.  Detailed

explanations of these components are given below.


4.1 NUMBER AND TYPES  OF FACILITIES


      Each program plan  thotild fddntt the types •/ program  tntitiei thai  art within

the scope of the FIDS in accordance with the guidance given in Chapter 1  of this document.

Specifically, the plan should detail:


      •     The regulatory definition of each type of facility

            How many of each type of facility are in the program universe

      •     How to distinguish entities within the scope of the FIDS from non-facility entities to
            which EPA facility ID codes should not be assigned (and which must be segregated from
            facility records during synchronized updates with FINDS)

      *      The number of facilities thai already have been assigned EPA facility ID codes and the
            number ID which ID codes have ye* to be assigned
FIDS1P 2/12/92
4.1

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HDSIP 2/12/92
                                              4.2

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              The number of facilities for which baric identification data in the program data base are
              adequate for FINDS to create facility records (see following section) and the number
              expected not to have adequate information
                                                    <
              The distinction of Federal fatalities and facilities on Indian lands from other facilities.
       Appendix B of this

by media program.
presents • listing of possible facilities within the scope of the FIDS
4.2   NEW SOURCES  IN FINDS


       Tht  program  Implementation plan  should identify ell program systems  (or

other significant data collectiont) that might ft  appropriate at data  sources referenced

fa FINDS. The more source references in FINDS, the more valuable FINDS becomes as the 'pointer

system" for facilities regulated under Federal environmental law. For sources not currently referenced in

FINDS, die plan should address the following information about the system:
              The system name and acronym (if available)
              Mission that the system supports
              Impetus for developing the system (e.g.,regulatory, enforcement, etc.)
              General type of information housed in the system
              Source of system information
              Software and hardware
              Physical location
              Frequency of update
              Uses/analyses performed with this system.
       This information will aid FINDS management in their decision to add the system to FINDS as a

source reference.
4.3   STATUS  OF  KEY DATA ELEMENTS


       Implementation of the FIDS hinges on two types of key data: the EPA facility ID code and data
used to uniquely identify a facility. Toe following subsections discuss each of these data types.


       4.3.1    EPA FACILITY ID  CODE  DATA ELEMENT


             The FIDS requires EPA programs to incorporate the EPA facility ID code into data
       collections that contain facility data.  This  action may require a system modification effort.
       Program  FIDS Implementation flans  should dttcrlbe any  modification tffon
FIDSIP 2/12/92
             4-3

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**ctttary to incorporate  EPA /ocUlt* in
                                    *
                                                            tmtt>  <*ifli"*
           HNDS
           HMDS.

          4.3.2   DATA  REQUIRED FOR  ASSIGNING  FACILITY
                    ID  CODES



                 Program  plans must address kow  basic  Identification  data  will  be

          acquired and transferred for facility ID code assignment, including:


                 •      Specific program data elements thai will serve as basic facility identification
                       information (i.e., a cross-reference of the data elements within the program
                       system and the data elements needed for FINDS)
           Sources and availability of these data


           Any additional data needed for updates and/or ID code assignment (i.e.. needed
           FINDS but not currently in the program system).


                        of data
                                                                                  b>

                      Facility name
                      Address
                      City
                             code
                           €od€ fottal
                          code
                      Federal facility  Indicator
                            land Indicator

                            **"*** <*•€., eodt for national tystem or
                            w  (Utntyicatlon «rfr for facility n£d"a
                            may benquried in the future.

FIDSIP 2/12/92

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FIDSIP 2A2/92
                                               4-5

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          Media prog™ manager, .re required to submit this ^^ m « ^ dements for ID code
          •signment and record nuinteunce.  Appendix D presents «he FINDS data dement dictionary.
          including format and definition, for the dam elements identified above.  Ii is not necessary for
          programs to have the exact data element structure in their own data bases « in the FINDS data
          clement dicto-iy. Neither EPA ftcffity m code assfenmem ^ npdMe$ „* R^ ^ te
          perfc^ed without tbe«ce*»yd«i from progrmj. In some cases, if a facility addressisnot
          mU*. . FINDS facHity neon) «»y «fl, ^ «.« ^ ^.^^ ^^ ^^^
                                              An e»mple of this type may be wells and faculties
          I«cess for assignin* EPA facility IDs ^ creating FINDS records for those facilities without
          Recife addresses.
  4.4  CHANGING DOCUMENTATION

         The FIDS requires programs to include EPA facility ID codes not only in their data bases, but also
  in all facility-related documentation.  Therefore, programs must tfteffy in their plans the forms
  and  other  tools used for fata  collection  or  documentation  that will  include  the  EPA
 facility ID code.  Programs should add a new place for EPA facility ID code on selected documentation
  or rename the existing label to "EPA facility ID code."  Submission of the EPA facility ID code to EPA by
  the regulated community is encouraged but not required on correspondence and  report submissions.
  Documentation on which a facility ID code is to be shown should indicate thai if a responder does not know
 the EPA facility ID for a facility, EPA personnel will supply it for them on the documentation after
 submission.  Inquires should not be directed to FINDS managemennt for this information. Program
 implementation plans should identify where changes might be appropriate to the following documentation:
        •      Reporting forms*4 • Documents distributed by EPA to collect information, such as
               the Hazardous Waste  Notification  Form (EPA Form 8700-12), Notification  fot
               Underground Storage Tanks (EPA Form 7530), and the  Toxic  Chemical Release
               Inventory Reporting Form "R" (EPA Form 9350-1)
               Manifests - Documents recording the transfer of hazardous wastes from one party to
               another, such as toe Uniform Hatardout Waste Manifest (EPA Form 8700-22)
        *       Jtrp0m»Studies or other documents produced during an infmmation-gaihering exercise
               performed by EPA, such as Super/and Remedial ActionlFeosibiUty Studies (RJ/FS)
               Grants cud agreements - Documents i
               «KdenI funds by the regulated or T '
               SUUfillUIWt f*nnmmii I*   A	
- J to confirm an understanding of the use
I community, such as grants for POTWs or

FJDSIP 2/1202

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        •      Existing automated flits • Data bases such is CERCL1S

        •      Correspondence • Typical EPA documentation between parties such as a letter from a
               regulatory program to a facility owner

        •      Questionnalreslsurveys » Periodic infonnttion gathering tools used by EPA whr.ii
               members of the regulated community are contacted to update ot correct existing
               information, such as RCRA biennial reviews

        •      Notification documents • Documents through  which members of the regulated
               community (or potentially regulated community) contact EPA informing them of their
               existence, location, type of business, etc., in anticipation of further regulatory action,
               such as applications for waste water discharge permits (EPA Application Forms 1 and 2C
               «EPAFortr,3510-2C)

        »      Permits »Documents that legally define allowable  activities under regulation, such as
               NPDES permits, air permits, and RCRA permits.


        Appendix C suggests program forms that may need to be modified for the FIDS. Program FIDS

implementation plans should specify exactly which forms will conform to FIDS information requirements.
4.5  SYNCHRONIZED UPDATES  WITH FINDS


       Each program implementation plan should include the detailed mechanism to  be

•serf for  performing synchronized updates of pertinent systems and FINDS,  OIRM will

work with program system managers to develop these mechanisms. Topics to be addressed in the FIDS

plan include:


       *      How to distinguish between records  within  the system that are facility-
              related and thus should be added to FINDS (e.g.. records that are under the scope of the
              FIDS that should be included in automated updaus) from those that are not

       •      Dora  elements In  the program  data  base to  be used  In the automated
              FINDS updates (e.g,. facility name, actual street address, city, state, county, ZIP Code
              and program system ID code)

              How program systems  will be modified to store the EPA facility ID code and
              required name and address information

       V     How to Identify program  tystem  records  that represent  tub-portions  of
              the tamt facility  and thus should have the same EPA facility  ID as other sub-
              portions of that facility (t£., several NPDES permits issued to a single facility)

              Frequency  of tystem  updates  to facility Identification data  elements


       The synchronized update process complements but does not preclude the need for manual data entry

to FINDS.  Manual data entry (and, consequently, assignment of facility ID codes) may be necessary for
FIDSIP 3/12/92
4-7

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new facilities not included in national program systems, state-regulated facilities, or facilities only in
sources not synchronized wiA FINDS.


4.6   ROLES AND RESPONSIBILITIES
       The implementation of (he FIDS will involve the coordination of many participants. Each plan
should  address  the Mitt  mud  responsibilities af  different  program  personnel  in
Implementation. Roles and responsibilities abould be defined for die following positions:
              Assistant Administrators, Associate Administrators, Regional Administrators
              laboratory Directors and the Genera) Counsel
              Senior Information Resources Management Officials (SIRMOs)
              Program Managers
              Data Base Managers
              Permit Writers
              Site Managers
              Field Investigators
              Compliance Monitors.
       Roles and responsibilities, as described in the program FIDS implementation plan, should address
FIAT participation, data discrepancy resolution roles, channels of communication, authorized decision -
makers, and other activities necessary to fully implement the FIDS. Clear articulation of the roles and
responsibilities of program participants under the FIDS will clarify the process for communication and
issue resolution.


4.7   IMPLEMENTATION  SCHEDULE

       Each plan  should address  the schedule  for til  Internal program  activities
necessary  to comply with the FIDS,  Including priorities for Initiation  and completion
of activities. Activities include all those mentioned in this chapter (e.g., form redesign, data base
changes and updates, personnel responsibility designation, etc.).  In addition, dependencies of the various
activities should be identified in anticipation of critical junctures and/or decision points.


4.8   QUALITY ASSURANCE   PROCESSES

       Because the FIDS may require changes in some program operating procedures, each plan
thould address how  quality  assurance  ("QA")  will he  tarried  ant In the FIDS
FIDSIP 2/12/92

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 tap/cmcntafioR frocett. Tne plan should describe a QA process that specifically assures the

 following:


        •      Program definition and use of the term 'facility* corresponds to specifications in the
               FIDS

        •      EPA facility ID codes ait used as identifiers in all data systems and in all appropriate
               farms and correspondence

        •      Program data bases are linked to FINDS by a process that avoids duplicate assignment of
               an EPA facility ID code to multiple facilities and that avoids multiple codes being
               assigned to a single facility

        •      Program data bases link sub-portions of a facility in such a way that they are assigned the
               tame EPA facility ID code

        •      Automated updates will occur smoothly with little introduction of error

        •      Mechanisms are in place to resolve facility data discrepancies with FINDS

        •      Programs have changed their data collection devices and the new processes are running
               smoothly

        *      Responsibilities are suitably assigned

        •      Implementation schedules are flexible enough so as to allow systematic changes according
               to varying priorities and constraints.


        Sound quality assurance plans for the FIDS will ensure that synchronized updates run smoothly

and that manual corrections on the pan of program staff or FINDS analysts are kept to a minimum.



4.9   RESOURCE AVAILABILITY  AND

         CONSTRAINTS



        Program managers may be confronted with obstacles during the implementation of the FIDS.

Program FIDS Implementation  flans should Utnllfy  retouret  ant ether  eenstraints,

such as timing or dependence on other parties or events, that could affect the specific activities necessary to

comply with the FIDS. If possible, the plan should identify options for addressing each constraint.
FIDSIP 2/12/92
                                             4.9

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          Appendix A
FACILITY IDENTIFIC ATION DATA
          STANDARD

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        Me.
pprovsl OlM:
                2180;3

                April 9.  1990
                    FACILITY IDENTIFICATION DATA STANDARD
      1.  PURPOSE.   This Transmittal issues a  new  EPA Order
      "Facility Identification Data standard".

      2.   EXPLANATION.   This Order  establishes  a data  standard  :
      unique facility  identification codes  to be  maintained in a::  l
      data collections  containing information  on facilities  reculat
      by EPA.

      3.    FILING  INSTRUCTIONS.    rile  the attached  in  a tr.re*-:•:•
      binder established for the  Directives System.
                          Robert A.  English, Chief.
                      Agency Management Analysis Branch
                i*w*in«  eu
t3ti.U(i-Mi
              Information Resources  Management

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EPA
IcMtenNo.: 2180.3

Ml Data:   4/9/90
                 FACILITY IDEKTIFICATION DATA STANDARD

       PURPOSE.   This Order establishes a data standard for unique
       facility  identification codes to be maintained in all EPA
       data collections containing  information on facilities
       regulated by EPA under authority of Federal environmental
       legislation.  Standardization of the format and content of
       facility  identification codes will enhance data integration
       capabilities and increase the utility of all EPA data on
       facilities.

       SCOPE AND APPLICABILITY.   The requirements of this Order
       apply to  all programs responsible for data on regulated
       facilities reported to EPA and kept in automated or manual
       information  collections developed for programmatic,
       research,  or administrative  purposes.  The Order applies to
       programs  operating both existing or future Agency systems in
       support of Federal environmental regulations.

       The principles of the standard can be extended to cover
       nonregulated facilities at program office discretion.
       Excluded  from the standard are data monitoring or
       observation  points, unless they are associated with a
       facility.  In that case,  the information collection must
       allow association of such data with the relevant facility.
                                                       .
       REFERENCE.  Chapter 5 of the EPA IRM Policy Manual sets
       forth the general principles on data standards within the
       Agency.   This Order defines  one of several data standards
       for use by EPA in .implementing the policy.

       BACKGROUND.
       a.
Adoption of a consistent, Agency-wide coding scheme for
facility identification will enhance the utility of EPA
data by increasing access to and integration of
facility information.
                                     A-l

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 EPA ORDER
2180.3
 4/9/90
                                                                   r
     b.   Since the early 1980s, EPA has striven to create a
         standard ID coding scheme for facilities that can be
         used not only in individual programs, but across the
         Agency as a whole.

     c.   There now exists an urgent need for improved data
         integration capabilities.  These capabilities provide
         the underpinnings for the comprehensive analyses of
         environmental conditions that increasingly guide EPA's
         initiatives in protecting and improving the environment.
         Examples of such analyses include risk  assessment,
         compliance behavior determination, vulnerability
         assessments, "hot-spot" identification,  research and
         modeling, and special inter-program studies.

    d.   Environmental legislation and regulation often define
         specifically the meaning of the term "facility11 for EPA
         programs.  The resulting differences in use of facility
         identifiers make it difficult to compare and integrate
         information on the same facility in different data
         bases.

    e.   A variety of descriptors, such as SIC (Standard
         Industrial Classification) codes and DUNS (Data
         Universal Numbering System) numbers, are available to
         programs for describing the corporate characteristics
         of a site.  A new data standard is needed to establish
         that,  for EPA information management purposes, the
         uniqueness of a facility is based upon its location
         rather than corporate characteristics.

    f.   EPA has implemented other data standards, as well as
         standards for hardware and software.  Adoption of a
         standardized facility identification code will help the
         Agency realize the potential benefits of these
         standards for information integration and analysis.

5.  AUTHORITIES.  -.

    a.   15 CFR Subtitle A,  Part 6,  Standardization of Data
         Elements anrf
    b.   OMB Circular A-130, Management of Federal Information
         Resources.
                                  A-2

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EPA ORDER                                               2180.3
                                                        4/9/90



6. POLICY.  This Order establishes an EPA standard that  each
   facility regulated by EPA will have a unique  facility ID
   code, which will be the same for that  facility across all
   EPA collections of information.   Therefore:
   .a.
Any collection of infomation assembled by or for EPA
with data that describe a facility regulated by EPA
under authority of Federal environmental statutes,
including facilities regulated by state programs with
delegated authority from EPA, shall contain in each
record on or related to a single facility the facility
identification code described in this Order and its
appendix.  The identification code for any one facility
will be the same in all EPA collections of information.

At the discretion of program offices, nonregulated
facilities nay also receive EPA IDs.

The facility identification code shall be comprised of
a unique 12-character  identification code controlled
and issued through the EPA central  facility  data  base.

The central facility data base will be operated by the
Office of Information  Resources Management.   The
objectives in maintaining this central data  base  are:

 (1)  To provide  a concise, comprehensive inventory of
     facilities  regulated by EPA

 (2)  To provide  users  with a simple method for
     determining a  facility's ID code and ascertaining
     which program  systems keep information on each
      facility.

 The data element field used to store the identification
 code in program systems should be readily accessible to
 system users.   The data element need not be a required
 field f01*-initial data entry, but should always
 eventually-be filled.

 Program personnel may continue to use any
 program-specific identifiers (including DUNS numbers)
 needed to support the program mission, provided that
 such identifiers are  kept in addition to the facility
 identification code established in this Order.
                                     A-3

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 EPA ORDER
                                                          2180.3
                                                           4/9/90
          In the interest of maintaining the confidentiality of
          Confidential Business Information (CBI)  daS Jeptby
          the Agency,  information collections with CBI data  will
          be considered as special cases.
                         .*   COBP1?te  inpleaentation of this
          standard by 1995,  in recognition of the extensive time
                                           by pro*""s and OIRM
    h.
                         becoines *«ective, adherence to the
                        eC°?f \£ey Step in the Development of
                         5:ollections-  Existing information
            ™   K     , ** ,"ade consistent with the standard
         through phased implementation.  This phasing will take
         into account system capabilities and needs.
7.
    a.
 The Office of Information Resources Management (OIRK)
 shall:
         (1)

         (2)

         (3)
         (5)
         (6)
   b.
      Develop, implement, and ensure adherence to this
      data standard.
      Develop a management plan describing steps for
      implementation of the standard.
      Provide guidance and technical assistance in
     meeting the requirements of this  standard.
      Provide unique facility identification codes in an
      efficient and responsive manner.
      Maintain a central facility data base with
      identification codes and basic information
      associated with each facility.
      Oversee resolution of conflicts regarding
      applicability or other  issues  relating to the
      standard.

Assistant/Administrators, Associate Administrators,
Regional Administrators, Laboratory Directors, the
General Counsel, and Heads of Headquarters Staff
Offices shall establish procedures within their
respective organizations to ensure compliance with the
requirements of this data standard.  Such procedures
shall include the following:

(1)   Oversee development of individual program
     implementation plans.
                                 A-4

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EPA ORDER                                               2180.3
                                                        4/9/90


          (2)  Ensure that program representatives supply the
              central facility data base with program-specific
              IDs and with the key information necessary to
              assign the EPA ID code  (e.g.. name, address,

              etc.).

          (3)  Ensure that each system containing facility
              information maintains a data element field for the
              standardized  facility identification code.

          (4)  Ensure that each  facility record  — both new and
              existing — carries the standardized  facility
               identification code from  the central  facility data

              base.

          (5)   Inform facility representatives of their ID codes,
               as appropriate, and incorporate the codes into
               reporting forms.

          (6)   Notify OIRM of any difficulty in meeting the
               requirements of the data standard within the  time
               frame specified in the program implementation

               plan.

          The Procurement and Contracts Management Division shall
          work with EPA Program and Regional Offices  and
          Laboratories  to ensure  that,  where appropriate,  the
          requirements  of this  standard are incorporated  into EPA
          <~<~-t*.*.»s*+e -
           contracts.

      d.
        COIVUCOWko .

        The Grants Administration Division shall  work with EPA
        grants management offices to require a special
        condition  in future award documents mandating
        assistance recipients to use facility ID codes for any
        facility-related information collected under the
        assistance agreement, in cases where recipients are
        acting for EPA under delegated authority.


8.  DEFINITIONS.  "\
                   V
    a.   A "FACILITY" is a locational entity, deliberately
         established as a site for designated activities, but
         not primarily for habitation  (even though on-site
         habitation »ay be necessary to the execution  of the
         primary activities).  Examples include a factory,  a
         military base, a college, hospital,  national  park,
         office building, or prison.   (Adapted from  FIPS Pub.

         55.)
                                       A-5

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EPA ORDER
                                                     2180.3

                                                     4/9/90
         In some cases,  a facility with complex, multiple
         functions nay have several plants or establishments
         operating within its property boundaries.   For these
         facilities,  10  codes will generally be assigned to the
         •ost comprehensive "level."  However, a complex
         facility with multiple establishments or operations may
         receive several IDs, if nore than one code  is
         appropriate.

         A facility nay  include wells or pipes located off  the
         facility property.   Although these "sub-units" will not
         ordinarily receive separate facility ID codes, program
         systems should  be able to associate data on the
         sub-units with  the record for the facility  itself.

    b.    "FACILITY IDENTIFICATION CODE" is a 12-character code
         that uniquely identifies a facility.  The appendix to
         this Order describes the format of the code in detail.

    c.    A "FACILITY IDENTIFICATION DATA STANDARD" is the
         requirement,  in terns of format and content, that  every
         record  of information referring to a particular facility
         contain a data  element field with a unique  facility
         identification  code.   This code is to be used
         consistently  across  all collections of information
         containing information on the same facility.

    PROVISION FOR WAIVER,  in general,  OIRM will attempt to work
    with  program offices to develop a feasible implementation
    schedule  for the standard.   There nay  exist, however, cases
    in which  exceptions  to the requirements of this Order are
    warranted.   Zn these cases,  program offices shall
    demonstrate  reasons  for waiver.   The process to apply for a
    waiver  is as  follows:

    a.    Draft an  application  for waiver to OIRM outlining the
         reasons why the facility identification data standard
         should no.t be implemented  in the  information
         collection.
                  » •

    b.    Obtain approval by the decision official in the
         requesting office and the respective Senior Information
         Resources Management Official  (SIRMO).

   c.   Submit application to the Director of OIRM,  who has
        responsibility for .final disposition.
                                  A-6

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   EPA ORDER
2180.3
4/9/90
    The applying office will be notified in writing of the
    disposition of the waiver.

10. PROCEDURES.  The appendix to this Order contains preliminary
    information relevant to implementation of the standard.
    OIRM vill also issue a management plan, which will describe
    the general steps and overall schedule for implementation of
    the standard over the next five years.  In addition to the
    Agency management plan, programs will develop individual
    implementation plans together with OIRM.  These plans vill
    consider program-specific capabilities and needs.
                                    Charles L. Gr>rtzle
                                Assistant Administrator for
                                    Administration and
                                   Resources Management
                                   A-7

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EPA ORDER
2180.3

 4/9/90
                    APPENDIX TO THE FACILTTY
                  TDENTIFICATIOK DATA STANDARD
1.0  INTRODUCTION
     1»1  Purpose of Appendix

          The purpose of this appendix is to provide  further
     detail on the facility identification data standard
     announced in the preceding Order.  While the Order
     introduces the data standard,  it does not contain  the full
     level of detail necessary for programs to form a working
     understanding of the standard.

          In addition to this appendix, an Agency-vide
     implementation plan vill be issued through the Office of
     Information Resources Management (OIRM).  This
     implementation plan vill cover in detail such issues as
     overall schedule for implementation, instructions  for
     applying for vaivers,  procedures adopted by OIRM to  ensure
     adherence to this standard,  and the role of the  central
     facility index system (FINDS).
     1.2  Background of the  Facility Identification Data
         Standard
         The Agency has long striven to create a standard
    coding scheme for facility ID codes that could be used not
    only in individual programs, but across the Agency as a
    whole.  Such a scheme vould help EPA more readily generate
    facility-specific responses to public inquiries and
    determine patterns of compliance behavior across programs.

         These reasons, however, are only part of the
    justification* for adopting this new standard.  EPA is
    experiencing*"^ vigorous trend towards cross-media analyses
    such as site characterizations, risk assessments and other
    environmental analyses that require the integration of data
    on individual facilities from diverse sources.  The net
    result is an even greater need for data integration and ,
    sharing across different environmental media and programs.
    This trend is often acknowledged by staff in single-media
    programs, vho now face increasing demands for data sharing
    and integration.
                                  A-8

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EPA ORDER                                              2180.3
                                                        4/9/90


          OIRM, in order to support the Agency's needs for data
    • sharing and integration, has established an information
     management policy on Data Standards.  Substantial
     implementation costs night be expected to be associated
     with promulgation of numerous retroactive data standards,
     and in the start-up phase many programs responsible for
     implementing these standards vould derive few immediate
     benefits.  For this reason, OIRM is taking a very measured
     approach and has identified only two standards as being of

     paramount importance.

          The  facility ID data  standard  is one.  The other is
     embodied  in the locational data policy, which establishes
     latitude  and  longitude,  in an internationally-compatible
     format, as the Agency*6 preferred locational coordinate
     system.   Both are undergoing concurrent green border review
     and will  be complementary when implemented.  Adoption of
     these selected  standards at this time is  absolutely
     essential if  the Agency is to respond effectively to the
     anticipated data  integration needs of the future.

           As discussed above, OIRM will issue a management plan
      for the facility ID data standard, which will describe the
      general steps and overall schedule for implementation of
      the standard over the next five years.  In addition to the
      Agency plan,  programs will develop individual
      implementation plans together with OIRM.  These plans will
      consider program capabilities and needs with respect to

      implementation.
           OIRM has attempted to  furnish program personnel with
      ample opportunity to provide input on  the development of
      the  facility identification data standard.  To this end,
      program  and  system managers from EPA Headquarters,  Regions,
      and  states have been asked  to contribute both to the
      development  of the  standard and to the formulation of this
      Order.   Only with  full program support and participation
       can OIRM establish a data standards  program that will meet
       EPA's needsifepth now and in the future.

  2.0  STRUCTURE OF TfiE FACILITY TDEKTIFTCATION CODE   -

       The facility identification code is the key feature of this
  facility identification data standard.  This code will consist
  of a 12-character standardized identification (ID) code.  The
  first two characters will be the Federal Information Processing
  Standard  (FIPS)  two-letter  abbreviation for the state or
  territory in which the facility  is located.   Abbreviations will.
  also be used for facilities located  outside  of the U.S.,  for
  example  in Canada or Mexico.
                                     A-9

-------
EPA ORDER
2180.3

4/9/90
     The remaining ten characters of the code will include a
check digit, will have no inherent meaning, and will not attempt
to describe, categorize or classify the facility in any way.
This applies only to new facility ID codes issued after the
effective date of implementation.  Identification codes issued
previously under OXRM's Facility Index Data System (FINDS) nay
be retained.

3.0  SOURCE OF TffE STANDARDIZED FACILITY ID CODE

     OIRM will maintain a central facility data base with basic
information on each facility such as name, address, etc.  This
data base vill serve as an inventory of facilities of interest
to EPA.  It vill also be the Beans through which the unique,
standardized facility ID codes will be assigned.  OIRM, in
cooperation with program offices, will develop methods and
procedures for assigning unique ID codes efficiently. • These
procedures will be defined in the program-specific
implementation plans, and will be automated as fully as possible

    To create or identify a pre-existing ID code, key information
on  the facility, including particularly the facility name and
address or other location information, must be made available to
the central facility index system via these procedures.  OIRK
will develop effective and efficient procedures for ID
assignments.

4.0  S£OPp OF THE FACILITY IDENTIFICATION DATA STANDARD

     Section 2 of the Order, Scope and Applicability, presents
the official scope of the facility identification data standard.
 This section augments that discussion in an attempt to
anticipate questions that program managers may have regarding
applicability of the standard.

     4.1  Definition of a Facility

          Successful implementation of a facility identification
     data standard hinges on a consistent understanding of what
     "facility" means.  A common understanding is necessary for
     determining to which facilities the standard applies.  An
     Agency-wide definition of "facility" is difficult to
     establish, however, because of differences in Federal
     legislation, which prescribe the program definitions of
     "facility."  As a result, perceptions of facilities differ
     from program to program.
                                   A-10

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EPA ORDER                                               2180.3
                                                        4/9/90


          Differences notwithstanding, most program managers
     have developed a common-sense definition of a facility.  In
     this approach, a facility is a single contiguous
     property—either an entire property or the portion thereof
     that is of regulatory concern.  Variability in definitions
     of facilities usually occurs because different portions of
     facilities are regulated, not because of differences in

     facilities per se.

          OIRM intends to establish a Facility Advisory
     Committee composed of Agency program office representatives
     to assist in implementing the data standard.   Should
      further clarification of a  standard facility  definition be
     required, the committee nay be called  to. resolve the  issue.

      4.2  Inclusion  of Non-EPA-recrulated Facilities

           If desired,  a  facility ID code may be assigned to a
      facility not regulated by EPA.   Such a scenario might
      arise, for example,  if program personnel need ID codes for
      facilities of interest to EPA,  but located outside of the
      United States.   Additionally, ID codes can be assigned to
      state-regulated facilities, if appropriate.

      4.3  Use of Concurrent Program  identifiers

           Many program-specific codes are now used to identify
      facilities  (e.g., permit numbers or site IDs).   Program
      personnel may continue to use these identifiers in their
      own data collections under this standard, provided that the
      program information system accommodates both the
      standardized ID code and the program-specific identifiers.

            If an information collection stores  other
       identification codes  in addition to  the standardized ID
       code, these codes  should be provided to the central data
       base under the procedures outlined in each program
       implementation plan.   The central data base can then store
       listings ofjboth facility and program-specific ID codes,
       which will further facilitate data integration and sharing.
                     »*                                  **
       4.4  Use of Previously  Assigned EPJ\ IP Codes
            Facilities regulated by some programs  have already
       been assigned EPA ID codes through FINDS under the current,
        DUNS-based numbering scheme.   (DUNS is the  Dun &  Bradstreet
       JBata Universal Cumbering System for corporations.)  These
        codes do not have to  be replaced, i.e., new standardized ID
                                       A-ll

-------
 EPA ORDER
2180.3
4/9/90
     codes for these facilities need not be *««*„„ ,»   „
     if an EPA ID number was assigned iStSnlni^E  *   However<
     staff but was not entered into T1VDS  Siiy.£uf??ra"
     notified of this number and the faciiit^-S     b
     r.cmti.. and their
5.0  RELATIONSHIP OF THE FACILITY IDENTIFICATION DATA STANDARD
     TO FINDS
     Assignment of EPA ID codes already occurs through a central
     data base—FINDS—for several EPA programs.  This data base
     will  continue to operate under the new data standard.  Some
     features of the current FINDS operation will remain the
     sane, while  others will be modified to make the system more
     responsive to  program needs under the new standard.

     5.1  Similarities Between Old and New Operations

          Similarities between the old and the new FINDS are as
     follows:

               Program data managers will obtain facility ID
               codes through the central data base.

               The central data base will continue to house
               basic descriptive information on each facility.

               The central data base will have the Dun and
               Bradstreet (DAB) file available to obtain
               descriptive information on facilities.
               Information supplied by the program offices will
               be used in conjunction with D&B data to ensure
               the accuracy of facility information in the
               central data base.
                 V.
               Program personnel will work with the OIRK system
               manager in Keeping the descriptive information
               up-to-date by notifying OIRM through automated
               procedures when they become aware of a change in
               this information.  OIRM will vork with program
               offices to accomplish regular and responsive
               updating.„
                                    A-12

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EPA ORDER
2180.3

 4/9/90
     5.2  pifferences Between the Old and the New FINDS

          Differences between the current and the new FINDS are
     as follows:

               The new identification code will no longer be
               based on the 9-digit DUNS identification code.

               EPA will actively encourage states to use FINDS
               and to supply information to it on facilities
               regulated by state law.

               To the extent possible,  the system will store
               information on all regulated facilities reported
               to EPA,  and will not exclude facilities based on
               size or type of operations.

     5.3  Use and Availability of DDKS  Numbers

          OIRM has based the decision to use a unique,
     nondescriptive ID rather than a DUNS-based ID on a
     determination that,  due to facility definition problems,
     the DUNS number does not fully meet EPA's needs for a
     unique  ID code.   For example,  when an establishment moves,
     the DUNS number moves with it,  and many EPA programs in
     this  case would require new permit numbers to be assigned.

          The fact that the facility ID code will no longer be
     based on the DUNS  number does not  diminish the importance
     of  these numbers.   OIRM continues  to encourage programs to
     collect and maintain DUNS numbers  in their information
     systems, if these  numbers are needed for the program
     mission.  So that  program personnel can obtain these
     numbers more easily,  EPA will  continue to purchase on-line
     access  to the Dun  and Bradstreet file of facilities.
     5.4  Relationship of Facility Identification Data Standard
         to Locational Data Policy
         OIRM has"/previously issued two data standards, one for
    use of Chemical. Abstract Service numbers and the other for
    electronic transmission of laboratory data  (EPA Orders No.
    2180.1 and No.  2180.2).  OIRM is also planning to issue a
    locational data policy, currently in green border review.
    This policy establishes the principles for collecting and
                                 A-13

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 EPA ORDER
                                                         2180.3
                                                         4/9/90
     documenting latitude/longitude coordinates for facilities,
     sites and monitoring and observation points regulated or
     tracked under federal environmental programs within EPA's
     jurisdiction.

          All of these efforts are related in that they increase
     the potential for data sharing and integration.  The
     locational data policy, however, is directly related to the
     facility identification data standard.  These two efforts
     complement each other by providing primary identification
     and locational information on entities of interest to EPA.
     An important difference in scope is that the facility ID
     data standard applies primarily to regulated facilities,
     vhereas the locational data policy covers both facilities
     and other locations, such as monitoring stations, where
     environmental data are collected.  FINDS will continue to
     allow entry of locational information for facilities.

*-°  IMPLEMENTATION OF THE FACILITY IDENTIFICATION DATA STANDARD
  ;
     OIRM intends to establish an advisory committee composed of
Agency program office representatives to assist in the
implementation of the data standard.

     €.1  Schedulefor Implementation of thisStandard

          In the forthcoming Agency implementation plan, OIRM
     will publish the general schedule for implementation of the
     standard over the next five years.  This plan will be
     followed by development of individual program
     implementation plans, which programs will formulate
     together with OIRM.  For the individual program plans, OIRK
     will work on a one-to-one basis with program staff to
     develop a realistic implementation schedule that takes into
     account such factors as mission priorities, system
     capabilities; and the size of the information collection.
     OIRM recognizes that implementation of the standard is a
     large-scale undertaking, and it has already considered that
     for some program offices, implementation should be phased
     over several years.
                                   A-14

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                                                          2180.3

IP* ORDER                                                 
-------

-------
Appendix B
                OF FACILITY

-------

-------
FIDSIP2/12/92
                                                  B-l

-------
HD5IP2/12/92
                                                  B-2

-------
HDSIP2/1202

-------

-------
HDSIF2/1202
                                         B5

-------
               (if   i.N
FIDS172/12/92

-------
          Appendix C
EPA FORMS RELEVANT TO THE FIDS

-------

-------
                                    Appendix  C

               EPA Forms Relevant  to the FIDS

      To tatilitate development of Program Implementation Plans. OIRM briefly studied the forms listed
fa Ihe EPA April 1989 Forms dialog to determine whether forms required update to ensure compliance
with die FIDS. The methodology of the study was as follows:
       •       Identifying from the tides of the 637 EPA Forms found in the EPA Forms Catalog those
              that might be relevant to the Facility Identification Data Standard

       »      Examining each of these forms to determine which ones contained any relevant location*!
               information, such as facility name, address, tat/long, etc.

       •       Reviewing whether a place for EPA ID code appeared on me form

       Exhibit C-l shows the outcome of this study.  Of the 637 forms listed in the EPA Forms
Catalog. 59% were eliminated from review based on their tides, the remaining 262 forms were examined
to determine if they contain relevant facility information;  57 of the 262 forms were found to relate to
facilities. These forms were then examined to determine the extent to which they already have complied
with the FIDS.  The list  of these relevant forms  is presented by program in Exhibit C-2.  The
Implementation plans of each program must include an approach to ensuring that EPA facility ID code is
 added to relevant forms.
   FIDSIP2/1W2

-------
    a

   1
RDSIP2A2/92

-------
2070-11
9510-1
 3320-1
 3510-1

  3510-2B
           a/si)
                              Eiblblt C-2
List of Forms by Program that  Possibly  Need  to Be
              Modified for  FIDS Compliance

                          Superfund Program

                        porr? Title
                        Potential Hazardous Waste Site-Site Inspection Report (Site
                        Identification)
                        Potential Hazardous Waste Site Preliminary Assessment
                        Potential Hazardous Waste Site-Site Inspection Report
                        Potential Hazardous Waste Site-Current Disposition
                        Technical Enforcement Support at Hazardous Waste Sites
                         Organic Traffic Report (for CLP use only)
                         Toxic Chemical Release Inventory Reporting Form (Form
                         R)
                         Substantiation to Accompany Claims of Trade Secrecy:
                         Emergency Planning/Community Right-to Know Act

                              Water Program
             Pate
             (ND)
             (8/90)

             (6/80)
2070-12
2070-13
2070-14
9100-1
9110-2
9350-1
a/8D
a/si)
a-8D
(2/88)
(8/88)
(1/90)
             a/88)
  3510-2C     (6/80)
   3510-2D     (9/86)
   3510-2E
   3560-3
   356M
   7500-52
   7500-53
              a/86)
              (3/85)
              (2/80)
              (6/80)
              (9/80)
                          |*yp" » '"*-
                          NPDES Discharge Monitoring Report
                          Application Form 1-General Information-Consolidated
                          Permits Program
                          Application for Permit to Discharge Information-
                          Consolidated Permits Program (Form 2B)
                          Application Form 2C-Wastewater Discharge Mormauon-
                          Consolidated Permits Program
                          Application Form 2D-New Sources and Dischargers:
                          Application for Penmtio Discharge Process Wastewater
                          Facilities WhichDo Not Process Wastewater
                           NPDES Compliance Inspection Report
                           Deficiency Notice-NPDES
                           SPCC Inspection Summary Sheet
                           SPCC Inspection Held Sheet
   HDSIP2A2/92
                                          C-3

-------
Form*
7500-60
7520-6
7520-7
7520-8
7520-9
7520-10
7520-11
7520-12
7520-14
7530-1
7550-6
7550-22
7550-23
Form #
7710-3C
7740-5
7710-35
7710-52
7710-53
7740-21
PJ&
(3/87)
(10/85)
(9/90)
(9/90)
(2/84)
(9/90)
(9/90)
(9/90)
(9/90)
(9/88)
(1/73)
(7/73)
(7/73)
Dale
(9/90)
(3/83)
(5/82)
(ND)
(12/89)
(3/90)
                           Exhibit  C-2  (contlDotd)

                           Water Program (tont)

                         Form Tide
                         Ovfl Litigation Re view
                         UIC Permit Application
                         Application to Transfer Permit
                         Injection Well Monitoring Report
                         Completion Form for Injection Wells
                         Completion Report for Brine Disposal, Hydrocarbon
                         Storage or Enhanced Recovery Well
                         Annual Disposalflnjection Well Monitoring Report
                         Well Rework Record
                         Plugging and Abandonment Plan
                         Notification for USTs
                         NPDES Application for Permit to Discharge-Short Form A
                         NPDES Application for Permit to Discharge-Standard Form
                         A-Municipal
                         NPDES Application for Permit to Discharge Wastewater-
                         Standard Form C

                              Toxics Program

                         Form Title
                         Chemical Substance Inventory Report
                         TSCA Investigation Summary
                         Manufacturer's Report Preliminary Assessment Information
                         Comprehensive Assessment Information Rule-Reporting
                         Form
                         Notification of PCS Activity
                         Mercury Reporting
HDSIP 2/12/92
C-4

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                            Exhibit C-2 (continued)
3510-3A
pate
(5/80)
3510-3B     (5/80)

8700-12     (6/85)
8700-12B    (2/80)

8700-13A     (5/80)
 8700-22      (9/88)
 8700-22A     (9/88)
Form*
3520-2
3520-3
3520-7
pate
(5/85)
(5/76)
(9/87)
  3540-2
  3540-5
  3540-8

   3540-8A

   3540-16

   3540-20
   3540-22
   pate
   (3/77)
   (5/76)
   (11/88)

   (11/88)

   (10/81)

    (4/75)
    (4/75)
  Solid Waste Program

pormTifle
Acknowledgement of Application for a Hazardous Waste
Pencil
Acknowledgement of Application for a Hazardous Waste
Permit (Verification)
Notification of Hazardous Waste Activity
Acknowledgement of Notification of Hazardous Waste
 Activity
 Generator's Annual Report
 Uniform Hazardous Waste Manifest
 Uniform Hazardous Waste Manifest (Continuation Sheet)

        Air  Program

  fonryTitle
  Lead Additive Report for Refinery
  Lead Additive Report for Manufacturing Facility or Site
  Notice of Violation of Section 211 of the dean Air Act

      Pesticides Program

  form Title
   Notice of Inspection
   Report of Analysis
   Application for Registration of Pesticide Producing
   Establishments
   Application for Registration of Pesticide Producing
   Establishments
   Pesticides Report for Registration of Pesticide Producing
   Establishments
   Use Investigation Report
    Corrective Action Report
    FIDSIP 2/12/92
                                             C-5

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   3540-25
   3540-26
   8500-1
   8580-7
   Form#
   3500-5
 (3/77)
 (3/77)
 (6/83)
 (3/83)
Daie
(5/90)
   Exhibit  C-2 (continued)

    Ptsticides Program

 Notice of Pfesticide Use/Misuse Inspection
 Receipt for Pesticide Use/Misuse Samples
 TSCA, HFRA, SARA Tide ffl Investigation Report
 FD=RA Investigation Summary

  Enforcement Program

Form Tiflf
Fuels FieW Inspection
HDSP a/12/92
                                        C-6

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          Appendix D
FINDS DATA ELEMENT DICTIONARY

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                         App.ndt* D
      FINDS DATA ELEMENT DICTIONARY
DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:
EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:

VALUES/MEANINGS
DEPENDENCIES:
REPEATING GROUP:
 INTERNAL FORMAT:
 REMARKS:
  CURRENT DATA NAME:
  CURRENT DATA FILE:
ADDRESS
GROUP
N/A
FINDS-FAC-ADA
FJNDS-ACT-ADA
FACTS2-DNB-ADA
N/A
N/A
Use to indicate address as defined by the
Post Office
N/A
 N/A
 No
 STANDARD COMPRESSION
 The address group consists of the following
 elementary fields:
 STREET-NBR
 PRE-DIRECTIONAL-IND
 STREET-NAME
 STREET-NAME-SUFFIX
 POST-DIRECTIONAL-IND
  SECONDARY ADDRESS
  N/A
  N/A
   RDSIP 2/12/92
                                  D-1

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:

PHYSICAL RECORD:
EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:
VALUES/MEANINGS
DEPENDENCIES:
REPEATING GROUP:
INTERNAL FORMAT:
REMARKS:
CURRENT DATA NAME:
CURRENT DATA FILE:
QTY
ELEMENTARY
FACILITY
D&B COMPANY
FINDS2-FAC-ADA
FINDS2-ACT-ADA
FACTS2-DNB-ADA
ALPHANUMERIC
30
The city name. For Program Office
Transactions it may be the physical location
or a mailing location.
N/A
Required for a Facility Index File Record
No
NULL SUPPRESSED
The length is standardized at 30 bytes. The
FACTS D&B filed length as of February
28,1991 was 13 bytes; however, the DM1
input tape field length at that time was 20.
CITY-NAME, CITY
FACTS-DNB, FINDS -FACILITY
FIDS? 2/12/92
  D-2

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:
EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:

VALUES/MEANINGS
DEPENDENCIES:
REPEATING GROUP:
INTERNAL FORMAT:
REMARKS:
CURRENT DATA NAME:
CURRENT DATA FILE:
COUNTY-CODE
ELEMENTARY
D&B COMPANY
FINDS-FAC-ADA
FINDS-ACT-ADA
FACTS2-DNB-ADA
ALPHANUMERIC
3
A numeric code which puts counties in
alphabetical sequence within a state.
N/A
N/A
No
N/A
Examine merging D&B County-Codes with
ZIP - where County is in a table file
implementation.
COUNTY-CODE
FACTS-DNB
FIDSIP 2/12/92
  D-3

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:
EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:

VALUES/MEANINGS
DEPENDENCIES:
REPEATING GROUP:
INTERNAL FORMAT:
REMARKS:
CURRENT DATA NAME:
CURRENT DATA FILE:
FACILITY-NAME

Program Office Transaction
Program Office Lai/Long Coordinate
Program Office/Facility Match Candidate
Facility
Facility/D&B Match Candidate
FINDS2-FAC-ADA
FINDS2-ACT-ADA
FACTS2-DNB-ADA
ALPHANUMERIC
50
The name by which a facility or D&8
business entity is known.
N/A
Required for all Facility Index File Records
No
NULL SUPPRESSED
N/A
FACQ.rry.NAME
FINDS-FACILITY
HDSIP2/1Z/92

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:

EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:

VALUES/MEANINGS

DEPENDENCIES:

 REPEATING GROUP:
 INTERNAL FORMAT:
 REMARKS:
 CURRENT DATA NAME:
 CURRENT DATA FILE:
FEDERAL-FACILITY-IND
ELEMENTARY
Facility
HNDS2-FAC-ADA
FWDS2-ACT-ADA
ALPHANUMERIC
1
Indicates whether or not die facility is a
federal facility.
Y= Federal Facility
 N* NOT a Federal Facility
 Required in Facility Index File Records; the
 field will default to"N".
 No
 NULL SUPPRESSED
 N/A
 FEDERAL-FACnJTY-lND
 FINDS-FACILITY
   HDSIP 2/12/92
                                     D-5

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:

EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:

VALUES/MEANINGS

DEPENDENCIES:
REPEATING GROUP:
INTERNAL FORMAT:
REMARKS:
CURRENT DATA NAME:
CURRENT DATA FILE:
INDIAN-LAND-IND

Facility
HNDS2-FAC-ADA
FINDS2-ACT-ADA
ALPHANUMERIC
i
Indicates whether or not a facility is located
on Indian Land.
Blank = No (default)
N/A
No
NULL SUPPRESSED
N/A
INDIAN-LAND
FINDS-FACILITY
HDSTP 2/12/92

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DATA NAME:
DATATYPE:
LOGICAL RECORD:

PHYSICAL RECORD:
 EXTERNAL FORMAT:
 EXTERNAL LENGTH:
 DESCRIPTION:

 VALUES/MEANINGS
  DEPENDENCIES:
  REPEATING GROUP:
  INTERNAL FORMAT:
  REMARKS:
pOST-DlRECnONAL-lND
ELEMENTARY
Program Office Transaction Facility
D&B Company
HNDS2-FAC-ADA
FJNDS2-ACT-ADA
FACTS2-DNB-ADA
ALPHANUMERIC
 2
 A geographic direction which follows the
 street name.
 EXAMPLE:
                                      : Northwest
                                      s Southwest
                                      i Northeast
                                      = Southeast
                                      = Nonh
                                      B South
 NW
 SW
 NE
 SE
 N
 S
 E
  W
  N/A
  No
  NULL SUPPRESSED
  N/A
   F1DSIP 2A2/92
                                     D-7

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:
EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:

VALUES/MEANINGS
DEPENDENCIES:
REPEATING GROUP:
INTERNAL FORMAT:
REMARKS:
PRE-DlRECnONAL-lND
ELEMENTARY
ftogram Office Transaction
Facility
D&B Company
FJNDS2-FAC-ADA
FINDS2-ACT-ADA
FACTS2-DNB-ADA
ALPHANUMERIC
2
A geographic direction which precedes the
street name.
EXAMPLE:
NW  m Northwest
     * Southwest
     «= Northeast
     = Southeast
     • North
     = South
     eEast
     *West
SW
NE
SE
N
S
E
W
N/A
No
NULL SUPPRESSED
N/A
FTOSIP 2/12/92

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:

EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:
 VALUES/MEANINGS
 DEPENDENCIES:
 REPEATING GROUP:
 INTERNAL FORMAT:
 REMARKS:
 CURRENT DATA NAME:

 CURRENT DATA FILE:
SECONDARY-ADDRESS
ELEMENTARY
Program Office Transaction Facility
D&B Company
ALPHANUMERIC
20
Contains additional identifier information to
locate a facility within a building (Suite A,
Apartment 3B, ecu).
N/A
 N/A
 No
 NULL SUPPRESSED
 N/A
 STREET-ADDRESS l, STREET-ADDRESSZ,
 STREET-ADDRESS
 FINDS-FACILrrYJFINDS-FACILlTY,
 FACTS-DNB
   HDSff WV92
                                     D-9

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:
EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:

VALUES/MEANINGS
DEPENDENCIES:
REPEATING GROUP:
INTERNAL FORMAT:
REMARKS:
CURRENT DATA NAME:
CURRENT DATA FILE:
SOURCE-DESCRIPTION

N/A
HNDS2-TBL-ADA
ALPHANUMERIC
20
Identifies the record type related to each
source value.
N/A
N/A
No
NULL SUPPRESSED
N/A
N/A
N/A
FTOSIP 2/12/92
 D-10

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:

EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:
 VALUES/MEANINGS
 DEPENDENCIES:
 REPEATING GROUP:
 INTERNAL FORMAT:
 REMARKS:
 CURRENT DATA NAME:
 CURRENT DATA FILE:
SOURCE-ID
ELEMENTARY
SOURCE-INFORMATION
FINDS2-FAC-ADA
FINDS2.ACT-ADA
ALPHANUMERIC
30
The unique identifier of the facility,
monitoring point, or permit as earned by a
Program Office database on D&B
 N/A
 N/A
 No
 NULL SUPPRESSED
 N/A
 SOURCE-ID
 FINDS-FACILITY
    FIDSIP 2/1W2
                                    D-ll

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:
EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:

VALUES/MEANINGS

DEPENDENCIES:
REPEATING GROUP:
INTERNAL FORMAT:
REMARKS:
CURRENT DATA NAME:
CURRENT DATA FILE:
STATE
ELEMB
Ptogram Office Transaction
Facility
State-FIPS/State
FINDS2-FAC-ADA
FINDS2-ACT-ADA
HNDS2-DNB-ADA
ALPHANUMERIC
2
A state postal abbreviation. It may be the
physical location or a mailing location.
Valid U.S. postal abbreviations and
meaning.
Required for a Facility Index File Record
where it must equal the first two characters
of FINDS-ID. It roust be present in the
Table-File.
No
NULL SUPPRESSED
N/A
STATE, STATE-ABBR
FINDS-FACILITY, FACTS-DNB
HDSIP 2/1M2
                                  D-12

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:
EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:
VALUES/MEANINGS
DEPENDENCIES:
REPEATING GROUP:
INTERNAL FORMAT:
REMARKS:
CURRENT DATA NAME:

CURRENT DATA FILE:
STREET-NAME

Program Office Transaction
Facility
D&B Company
HNDS2-FAC-ADA
FINDS2.ACT-ADA
FINDS2-DNB-ADA
ALPHANUMERIC
45
The name of the street as given in a mailing
address. May contain the entire street
address if the address cannot be broken
down into its component pans.
N/A
N/A
No
NULL SUPPRESSED
N/A
STREET-ADDRESS 1, STREET- ADDRESS2,
STREET-ADDRESS
FINDS-FACILn^JINDS-FACIUTY,
FACTS-DNB
HDSIP 2/1202
  D-13

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:
EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:

VALUES/MEANINGS
DEPENDENCIES:
REPEATING GROUP:
INTERNAL FORMAT:
REMARKS:
CURRENT DATA NAME:

CURRENT DATA FILE:
STOEET-NAME-SUFHX
ELEMENTARY
ftogram Office Transaction
Facility
D&B Company
FJNDS2-FAC-ADA
FJNDS2-ACT-ADA
FINDS2-DNB-ADA
ALPHANUMERIC
4
The trailing designator in the street address
(Avenue, Road, Drive, Etc.)
N/A
N/A
No
NULL SUPPRESSED
N/A
STREET-ADDRESS 1, STREET-ADDRESS:,
STREET-ADDRESS
FINDS-FACILITy^INDS-FACILIT'i',
FACTS-DNB
FIDSIP 2/12/92
 D44

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:
EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:
VALUES/MEANINGS
DEPENDENCIES:
REPEATING GROUP:
INTERNAL FORMAT:
REMARKS:
CURRENT DATA NAME:

CURRENT DATA FILE:
STREET-NBR
ELEMENTARY
Program Office Transaction
Facility
D&B Company
FINDS2-FAC-ADA
FINDS2-ACT-ADA
HNDS2-DNB-ADA
ALPHANUMERIC
10
The numeric or alphanumeric component of
the street address which proceeds the street
name.
N/A
N/A
No
NULL SUPPRESSED
N/A
STREET-ADDRESS 1, STREET-ADDRESS!,
STREET-ADDRESS
FINDS-FACILITYJTNDS-FACILrrY,
FACTS-DNB
HDSIP2A2/92
                                 D-15

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DATA NAME:
DATA TYPE:
LOGICAL RECORD:
PHYSICAL RECORD:
EXTERNAL FORMAT:
EXTERNAL LENGTH:
DESCRIPTION:
VALUES/MEANINGS
DEPENDENCIES:

REPEATING GROUP:
INTERNAL FORMAT:
REMARKS:

CURRENT DATA NAME:
CURRENT DATA FILE:
 ZIP-CODE

 Program Office Transaction
 Facility
 D&B Company
 HNDS2-FAC-ADA
 FINDS2-ACT-ADA
 HNDS2-DNB-ADA
 ALPHANUMERIC
.9
 A U.S. Postal Zone Improvement Plan
 (ZIP) Code. It may be the physical
 location, a mailing location, or the nearest
 zip code location.
 N/A
 Required for al!  Facility Index File
 Records.
 No
 NULL SUPPRESSED
 In the FRDS-D data, this filed may be the
 nearest zip code location
 ZIP-CODE
 FINDS-FACILITY, FACTS-DNB
FIDSIP 2/12/92
  D-16

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