s ^Mfa\ Office of Inspector General
\SH&J Report of Audit
BIENNIAL HAZARDOUS WASTE DATA:
OPPORTUNITY FOR IMPROVEMENT
Audit Report No. E1DSF6-11-0001-7100114
February 18,1997
^
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Inspector General Division
Conducting the Audit: Headquarters Audit Division
Washington, DC
Regions Covered: Regions 4, 5, 7
Program Office Involved: Office of Solid Waste and Emergency
Response
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dooi
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
I 3 1997
OFFICE OF
THE INSPECTOR GENERAL
MEMORANDUM
SUBJECT: Biennial Hazardous Waste Data: Opportunity
for Improvement
Audit Report No. E1DSF6-11-0001-7100114
FROM:
TO:
Michael Simmons
Deputy Assistant Inspector General
for Internal Audits
Timothy Fields, Jr.
Acting Assistant Administrator
for Solid Waste and Emergency Response
Attached is our final report entitled Biennial Hazardous
Waste Data: Opportunity for Improvement. Our overall audit
objectives were t9 determine if the National Biennial RCRA
Hazardous Waste Report (Biennial Report) process (1) results in
the users obtaining the information needed to make sound
regulatory decisions and (2) provides complete, accurate, and
timely information to help manage EPA's hazardous waste program;
This report identifies corrective actions the Office of
Inspector General (OIG) recommends to improve the Biennial Report
process and the Biennial Reporting System (BRS) . As such, it
represents the opinion of the OIG. Final determinations on
matters in the report will be made by EPA managers in accordance
with established EPA audit resolution procedures. Accordingly,
the findings described in this report do not necessarily
represent the final EPA position.
We have designated you as the action official for this
report. In accordance with EPA Order 2750, the action official
is required to provide this office with a written response to the
audit report within 90 days of the final report date. For any
corrective actions planned but not completed by the response
date, reference to specific milestone dates will assist this
office in closing the report in our audit tracking system.
fl*cycled/R»cyel»bl« • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)
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The response by the Office of Solid Waste and Emergency
Response (OSWER) to our draft report is included as Appendix I.
Based on OSWER's response to the draft report and prior
discussions with OSWER officials, we made appropriate changes to
this final report.
We appreciate the cooperation extended to our auditors by
your Office of Solid Waste managers and staff during this audit.
If you or your staff have any questions about this report, please
contact Edward Gekosky, Divisional Inspector General for Audit,
Headquarters Audit Division, at (703)308-8222.
Attachment
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Biennial Hazardous Waste Data:
Opportunity for Improvement
EXECUTIVE SUMMARY
PURPOSE
BACKGROUND
The purpose of the audit was to evaluate the
Environmental Protection Agency's (EPA)
process for collecting and reporting on
biennial hazardous waste information. Our
specific objectives were to determine if the
overall process: (l) results in the users
obtaining the information needed to make
sound regulatory decisions, and (2) provides
complete, accurate, and timely information to
help manage EPA's hazardous waste program.
Subtitle C of the 1976 Resource Conservation
and Recovery Act (RCRA) establishes a program
to manage hazardous wastes from "cradle-to-
grave" to ensure that they are handled in a
manner that protects human health and the
environment. RCRA requires EPA to collect
information on the generation and disposal of
hazardous waste every two years. To meet
these requirements, EPA established a process
that produces the National Biennial RCRA
Hazardous Waste Report (Biennial Report).
EPA develops the package of biennial
reporting forms and instructions and sends
them to the states every two years. After
the states receive the forms, they send them
to and collect them from the generators, and
treatment, storage, and disposal facilities
(TSDs), check data quality, and send the
information back to EPA regional offices.
Most, but not all states also enter the data
into EPA's Biennial Reporting System (BRS).
The regions accumulate the states' data,
further check data quality and then send the
results to EPA's Office of Solid Waste (OSW)
in the Office of Solid Waste and Emergency
Response (OSWER). OSW accumulates the
regional data, and does final quality checks,
consulting with the regions and states to
identify potential errors. According to OSW,
states must verify and correct the errors.
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Biennial Hazardous Waste Data:
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OSW then develops and publishes the Biennial
Report every two years.
RESULTS IN BRIEF
We found that EPA's overall Biennial Report
process can be improved. Specifically, we
found that the:
— Biennial Report process and the BRS are
complex for many users.
Biennial Report changes made by the
Agency for 1997 will eliminate the
collection of some future hazardous
waste data.
EPA has taken some steps to ease the
reporting burden for entities required to
submit data for the 1997 Biennial Report.
The Office of Solid Waste created a Biennial
Report Project Team to study and recommend
ways to improve the program. In addition,
OSW is working to improve RCRA information
overall through the Waste Information Needs
(WIN) initiative. However, our interviews of
state and EPA officials, reports by the
National Governors Association (NGA) and
other organizations and additional analyses
and documents identify key issues that need
to be considered and improved.
We commend the Agency on their efforts, and
believe the efforts will help Biennial
Reports to present a more accurate picture of
hazardous waste in the U.S.
PRINCIPAL FINDINGS
Biennial Report
Process and tne
BRS Need
Improvement
Our findings are summarized below and
discussed in detail in CHAPTERS 2 and 3
this report.
of
The overall Biennial Report process reflects
the complexity of RCRA and is difficult for
generators and TSDs that have to report
hazardous waste information. During the
audit, we found that the regions and states
often view the Biennial Report process and
BRS as being a complex and difficult
information reporting process.
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Biennial Hazardous waste Data:
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Data Are Not
Easily Obtained
From BR8
EPA Needs to
Emphasize
Electronic
Enhancements
and Reporting
Biennial reporting forms and instructions
need to be streamlined. EPA's instruction
and forms package for the 1995 Biennial
Report is lengthy and complex to fill out
according to state officials we interviewed
who deal directly with the regulated
community. States have devised their own,
shorter versions of the package and have
adopted other techniques to ease the
reporting burden.
To help reduce errors and increase reporting
accuracy, OSW should revise codes (system
type, form and source) or data elements
unique to the Biennial Report so they more
closely parallel the data categories
regularly used by facilities. Potential for
data errors increases when facilities have to
fill out biennial report forms using some
codes that they are not used to dealing with
in daily management of their hazardous
wastes. This has been a longstanding concern
among some state officials.
The BRS was designed by EPA to meet the
statutory requirement of reporting every two
years on the amount and types of hazardous
waste generated in this country. OSW
officials told us they provide the user
community with the ability to request
enhancements to make BRS data more
"obtainable." We found many users have
raised concerns about obtaining useable data
from BRS. One of the main concerns is that
the BRS programming language, FOCUS, is a
difficult language to learn and .to use. We
were told that only a few people have the
requisite expertise with FOCUS to program
necessary reports from BRS.
Implementers of the Biennial Report believe
that expanded use of electronic technology
and reporting is needed. Similar concerns
were raised in a recent report by NGA, and by
an EPA sponsored study covering
implementation of BRS and the Resource
Conservation and Recovery Information System
(RCRIS). OSW should work to make
enhancements better known to the states which
iii
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Biennial Hazardous Waste Data:
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Planned changes
for 1997 Biennial
Report May Not
Meet statutory
Requirements
RECOMMENDATIONS
would improve their electronic reporting
activities in connection with BRS.
A statutory requirement for EPA requires
facilities to report efforts undertaken to
reduce the volume and toxicity of hazardous
wastes generated. EPA and state regulatory
agencies have used Biennial Report data to
measure the efforts of waste minimization.
However, waste minimization reporting was
removed from the 1997 Biennial Report
process. To assure waste minimization is
occurring, EPA must be able to accurately
assess and measure the progress of waste
minimization.
EPA has made other 1997 Biennial Report
changes that affect the Agency's ability to.
characterize and manage the nation's
hazardous waste program. EPA is no longer
collecting capacity planning data in the
Biennial Report process. In addition, the
Agency has initiated changes to ensure that
wastewater data.does not skew Biennial Report
information.
All of our specific recommendations follow
the findings in CHAPTERS 2 and 3. In
summary, we are recommending that the
Assistant Administrator for the Office of
Solid Waste and Emergency Response initiate
the following actions for the 1999 Biennial
Report process, or as soon as possible to:
Streamline and redesign the Biennial
Report forms and instructions to make
them clearer and easier for generators
and TSDs to complete.
Revise the Biennial Report codes (system
type, form and source) to avoid the
confusion experienced by generators and
TSDs.
Educate the states regarding the use of
existing electronic enhancements to
improve their data collection and
reporting activities.
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Biennial Hazardous waste Data;
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Improve the availability and access for
all users by making BRS available at
users desktop computers.
Assess the type of data required and
specify how the RCRA Section 3002(a)
reporting requirement will be met.
Ensure states receive specific
information for their waste planning
efforts from any future Agency waste
capacity reassessments.
AGENCY COMMENTS
AND OIG EVALUATION
In their February 11, 1997 response to our
draft report, OSWER officials stated they
agree with the recommendations contained in
the report. They further state they have
planned appropriate actions to implement
changes in the biennial reporting process and
the BRS according to the recommendations in
our report. They said the recommendations
that we developed were both meaningful and
practical ones that will improve the biennial
reporting process and the BRS (see Appendix I
for the full response).
We believe the Agency's response to our draft
report and their willingness to plan and
initiate corrective actions based on the
findings and recommendations will bring
significant improvement and changes to the
current situation. We further believe that
the biennial reporting process and the BRS
will be strengthened, and thus, the
corrective actions will result in a better
and more usable Biennial Report.
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TABLE OF CONTENTS
PAGE
EXECUTIVE SUMMARY i
CHAPTER 1 - INTRODUCTION 1
PURPOSE 1
BACKGROUND 1
SCOPE AND METHODOLOGY 3
MANAGEMENT CONTROLS 4
PRIOR AUDIT COVERAGE 5
AGENCY EFFORTS TO IMPROVE THE BIENNIAL
REPORTING PROCESS 5
CHAPTER 2 - THE BIENNIAL REPORT PROCESS
AND BR8 ARE COMPLEX 7
BIENNIAL REPORTING INSTRUCTIONS
NEED TO BE STREAMLINED 7
CODES UNIQUE TO THE BIENNIAL REPORT
NEED TO BE REASSESSED 9
DATA ARE NOT EASILY
OBTAINED FROM BRS 10
EXPANDED USE OF COMPUTER TECHNOLOGY
NEEDS TO BE PURSUED 11
ACCESS TO BRS FILES NEEDS
TO BE IMPROVED 13
RECOMMENDATIONS 14
AGENCY COMMENTS AND OIG EVALUATION .15
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TABLE OF CONTENTS
PAGE
CHAPTER 3 - IMPACT OF EPA'a 1997 BIENNIAL
REPORT CHANGES 17
WHY WASTE MINIMIZATION REPORTING
IS IMPORTANT 17
1997 BIENNIAL REPORT ICR MAY NOT MEET
WASTE MINIMIZATION STATUTORY
REQUIREMENTS . 18
WASTE MINIMIZATION INSTRUCTIONS WERE
DIFFICULT FOR FACILITIES TO
UNDERSTAND 20
AGENCY CONCLUDED THAT HAZARDOUS
WASTE CAPACITY IS ADEQUATE 21
(
WASTEWATER CAN SKEW HAZARDOUS
WASTE DATA 23
RECOMMENDATIONS . 24
AGENCY COMMENTS AND OIG EVALUATION 25
APPENDIX I - AGENCY RESPONSE TO DRAFT REPORT 27
APPENDIX XI - REPORT DISTRIBUTION 35
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CHAPTER 1
INTRODUCTION
PURPOSE
BACKGROUND
Legislative
Requirement
The purpose of the audit was to evaluate the
Environmental Protection Agency's (EPA)
process for collecting and reporting on
hazardous waste information. Our specific
objectives were to determine if the overall
process: (1) results in the users obtaining
the information needed to make sound
regulatory decisions, and (2) provides
complete, accurate, and timely information to
help manage EPA's hazardous.waste program.
Federal regulations specify that solid waste
is hazardous if it (1) exhibits any of the
characteristics of a hazardous waste
(ignitability, corrosivity, reactivity or
toxicity); or (2) has been named as a
hazardous waste and listed as such in the
regulations. Certain wastes are deemed acute
hazardous wastes because they are so
dangerous in small amounts that EPA regulates
them the same as larger amounts of other
hazardous wastes.
Federal law requires EPA to collect
information about hazardous waste generation
and disposition. Concern about hazardous
waste led Congress to write data collection
into the law in 1976 and to revise it in
1984. The 1976 Resource Conservation and
Recovery Act (RCRA) established the nation's
basic hazardous waste management system under
Subtitle C of the Solid Waste Disposal Act
(SWDA). Subtitle C establishes a program to
manage hazardous wastes from "cradle-to-
grave" to ensure that they are handled in a
manner that protects human health and the
environment. RCRA required EPA to collect
information on the generation and disposal of
hazardous waste quantities.
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Biennial Hazardous Waste Data:
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Biennial Reporting
Process
RCRA was revised by the Hazardous and Solid
Waste Amendments (HSWA) of 1984 (P.L. 98-616)
which changed the hazardous waste reporting
requirements. HSWA (1) changed the periodic
reporting requirement to at least once every
two years, (2) required companies that
generate waste (generators) to report on the
nature of the waste (in addition to the
quantities), (3) added a new requirement to
report on efforts undertaken during the one-
year period to reduce the volume and toxicity
of waste generated, and (4) added a new
requirement to report changes in volume and
toxicity' actually achieved during that one-
year period when compared to previous years.
To meet these requirements, EPA established a
process to develop a National Biennial RCRA
Hazardous Waste Report (Biennial Report).
EPA develops a package of biennial reporting
forms and instructions and sends them to the
states every two years. To be able to.
collect the biennial report information, EPA
needs to have an Information Collection
Request (ICR) approved by the Office of
Management and Budget (OMB). After the
states receive the forms, they send them to
and collect them from the generators, and
treatment/ storage, and disposal facilities
(TSDs), check data quality, and send the
information back to EPA regional offices.
Most, but not all, states also enter the data
into EPA's Biennial Reporting System (BRS).
In some cases, regional offices enter the
data for states. The regions accumulate the
states' data, further check data quality and
then send the results to EPA's Office of
Solid Waste (OSW) in the Office of Solid
Waste and Emergency Response (OSWER). OSW
accumulates the regional data, and does final
quality checks, consulting with the regions
and states to identify potential errors.
According to OSW, states must verify and
correct the errors. OSW also develops and
publishes the Biennial Report.
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Biennial Hazardous Waste Data:
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EPA uses Biennial Report information for
internal purposes including rule making,
regulatory analysis, waste minimization,
capacity planning and analysis to meet
requirements of the Superfund Amendments and
Reauthorization Act (SARA). In addition,
states use the information to assess user
fees, and target enforcement activities such
as inspections.
The RCRA program has been largely delegated
to the states with some oversight by EPA.
EPA believes the states are in a better
position to administer the program and
respond to specific state and local needs.
As a result, implementation varies at the
state level. For example, states may collect
data every year, or collect additional data
as well. In fact, some states use their own
data systems or forms to compile and track
waste data within the state. As many as 10
states use their own data systems to enter
and collect the information.
Large quantity generators (LQGs) are required
to submit Biennial Report information. A LQG
is defined as one that generates 2,200 pounds
of RCRA hazardous waste in any single month,
or 2.2 pounds of RCRA acute hazardous waste.
Under the authority of the law, EPA extended
the reporting requirements to TSDs for the
wastes they receive. According to the 1993
Biennial Report, 24,362 LQGs produced 258
million tons of hazardous wastes and 2,584
TSDs managed 235 million .tons.
SCOPE AND
METHODOLOGY
Our audit focus was on the 1995 Biennial
Report effort and the 1993 Biennial Report
which was issued in August 1995. The audit
covered Biennial Report implementation in
OSW, Regions 4, 5 and 7, and the states of
Florida, Illinois, Iowa, Kentucky, Michigan,
Ohio, and Tennessee. For each state, we
spoke with officials who implemented the data
collection and input, as well as key users of
the data. We reviewed applicable
documentation at each location, such as EPA
and the state policy and procedure guidance,
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Biennial Hazardous Waste Data:
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MANAGEMENT
CONTROLS
and any state system related to the Biennial
Report process.
We chose these EPA regional offices and
states to learn about Biennial Report
implementation from varied perspectives based
on information we obtained from EPA and other
groups. We interviewed staff at the National
Governors' Association (NGA) and discussed
their review of the Biennial Report process.
We also talked to Association of State and
Territorial Solid Waste Management Officials
(ASTSWMO) on their Biennial Report concerns.
We further coordinated with the General
Accounting Office (GAO) on its past and
current audit work in this area. We reviewed
applicable laws, policies, procedures,
management controls, relevant reports and
other EPA and state documentation on the
biennial reporting process.
We reviewed comments on the biennial
reporting process submitted to EPA over the
years, including feedback that EPA received
before OMB approval of the ICR for the 1997
Biennial Report process. We performed our
audit in accordance with Government Aud
standards (1994 Revision) issued by the
Comptroller General of the United States.
We reviewed annual reports prepared by EPA,
OSWER and OSW for 1994 and 1995 to meet the
requirements of the Federal Managers'
Financial Integrity Act (FMFIA).
Environmental data quality has been a cross-
cutting Agency-level material weakness since
1992. The FMFIA reports indicated OSW worked
with EPA's Office of Research and Development
(ORD) to address the concern.
Our review included inquiries of internal
controls and procedures related to the audit
objectives. We obtained and reviewed
relevant written management controls when
available at EPA headquarters, as well as
regional offices we visited. Because of the
delegated nature of the RCRA program, OSW
relies on the states to implement data
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Biennial Hazardous Waste Data:
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PRIOR AUDIT
COVERAGE
AGENCY EFFORTS
TO IMPROVE THE
BIENNIAL REPORTING
PROCESS
collection for the Biennial Report and
ensure the data is valid and reliable.
The EPA Office of Inspector General (OIG) has
issued several reports on the RCRA program,
including a 1995 report on manifesting
requirements. GAO issued a 1995 report on
the Resource Conservation and Recovery
Information System (RCRIS) which is a
separate RCRA data system. During 1990-1992,
GAO issued several reports on EPA's efforts
to acquire information about hazardous waste,
including three reports that focused on waste
minimization efforts. The Biennial Report
was used in collecting waste minimization
data, and EPA made some changes in response
to the GAO recommendations.
The Agency has taken steps to improve the
Biennial Report process and BRS. For
example, OSW has undertaken a long-range
effort, the Waste Information Needs (WIN)
initiative, that will include an assessment
of future RCRA data and technology needs.
The projected WIN goals include reducing the
reporting burden for industry, states and the
regions while ensuring accurate data for
tracking national results and for regulatory
and reporting requirements. Completion for
the WIN initiative is projected to be in
1999, although this time frame may be moved
further into the future.
In April 1996, OSW started a Biennial Report
Project Team whose mission is to devise a
better Biennial Report program. Its team
charter continues through March 1998. It
outlines basic steps for work on the 1997
Biennial Report process, and covers some ways
to change the Biennial Report process for
1999. They plan to analyze issues identified
in past biennial reports and related RCRA
information reviews, and integrate initial
WIN effort findings.
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Biennial Hazardous Waste Data:
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We commend the Agency on their efforts, and
believe the efforts will help Biennial
Reports to present a more accurate picture of
hazardous waste in the U.S. In our opinion,
these efforts should also help the regions
and states to more easily use BRS in the
future.
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Biennial Hazardous waste Data:
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CHAPTER 2
THE BIENNIAL REPORT PROCESS
AND BRS ARE COMPLEX
The overall Biennial Report process reflects
the complexity of RCRA and is difficult for
generators and TSDs that have to report
hazardous waste information. Biennial Report
forms and instructions are complex and
lengthy, containing over 150 pages and
require an average of about 22 hours to
complete. In addition, the Biennial Report
codes (system type, form and source) are
confusing and have potential for data errors.
BRS data is not easy to obtain from the
system. Further, the Agency needs to
emphasize better use of electronic reporting
enhancements, and add a simultaneous user
capability to the BRS. Often managers and
staff lack the computer skills necessary to
successfully utilize BRS and obtain the
information needed. As a result, the regions
and states often view BRS as complex and
difficult to use.
BIENNIAL REPORTING
INSTRUCTIONS NEED
TO BE STREAMLINED
EPA's instructions and forms package for the
1995 Biennial Report includes over 150 pages.
The package includes 47 pages of
instructions, seven pages of definitions, 46
pages of codes for use in filling out the
forms, 53 pages of examples of completed
forms, and several pages that include blank
forms and a checklist. During our audit, we
found several states had replaced the lengthy
EPA Biennial Report instructions and forms
package with their own shorter versions.
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Biennial Hazardous Waste Data:
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State officials often mentioned problems with
data collection. According to state
officials we interviewed, the forms are
difficult to fill out because of the length
and complicated nature of the package.
Illinois State officials found some
generators within their state experienced
problems filling out the forms. To correct
this problem, Illinois has now streamlined
and improved its instructions that are sent
to the generators. Illinois has redesigned
their forms to make them easier to
understand, fill out and enter into its data
system.
Other states also streamlined their packages.
For example, Tennessee has less than 25
pages, including the forms that make up its
entire package. Kentucky also made changes
to its forms and instructions package and
reduced the size to 34 pages. These forms
are slightly longer than the EPA versions but
the instructions are considerably shorter.
Kentucky streamlined its package by including
some of the choices and instructions directly
on the form.
OSW officials recognize the need to simplify
the reporting requirement but also believe
the regulated community has developed a good
understanding of the forms and instructions
because of a significant reduction in calls
to their Biennial Report hotline over the
last three biennial reporting cycles. State
officials who deal directly with the
regulated community's questions believe the
EPA.package should be streamlined.
While EPA will be eliminating a form and
modifying the instruction package for 1997,
we believe the Agency has an opportunity to
further streamline and simplify the forms and
instruction package. The state changes
discussed above suggest that OSH may be able
to streamline the EPA package for the 1999
Biennial Report without eliminating any
necessary data elements, codes or
instructions. Although we have not made
specific suggestions for changes, we believe
a side-by-side comparison with several state
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Biennial Hazardous Waste Data:
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CODES UNIQUE TO
THE BIENNIAL
REPORT HEED TO
BE REASSESSED
packages would be helpful in identifying ways
to simplify the existing EPA package.
Unlike the codes used in manifests (a control
and transport document that accompanies
hazardous waste from the generator to a TSD),
and in RCRIS, some Biennial Report codes
(system type, form and source) differ from
codes that generators use in the daily
management of their hazardous wastes.
Because some of these Biennial Report codes
are only used every two years, confusion and
potential for data errors may result. In
fact, this has been a longstanding concern
among some state officials.
In a 1993 letter to EPA, one state expressed
a desire to see the BRS codes (system type,
form and source) made equivalent to the
corresponding codes in RCRIS. In addition,
N6A in 1995 recommended that EPA revise and
simplify the waste codes (system type, form
and source) used in the Biennial Report and
develop a consistent set of codes for all EPA
hazardous waste reporting programs. In
responding to EPA's March 15, 1996, request
for comments on changing the Biennial Report,
Kentucky noted that:
There are numerous examples where
the Biennial .Report fails to be
consistent with the hazardous waste
record keeping requirements. The
. Biennial Report adopts an entire
set of codes for system type, form
and source that appear nowhere in
the regulatory record keeping
requirements — thus each generator
must evaluate, scrutinize and
select the most appropriate codes
for reporting an entire years'
worth of data based on speculation
rather than records. Since the
report is a certified document, it
places the generator or facility in
jeopardy of enforcement action for
errors or omissions. It cannot be
compared to on-site records by an
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Biennial Hazardous Waste Data;
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inspector for compliance
evaluation*
One state official recommended that Biennial
Report information should be obtained from
records that can be verified in the field
such as a company manifest or operating
records. Another state pointed out that the
Biennial Report waste codes and process codes
are different from the ones that the
regulated community is required to use for
their operating log. The state's concern was
that only one set of codes should be used for
the same item, no matter whether the code
relates to a company operating log or to EPA
Biennial Report data.
ORD's Quality Assurance Management Staff
reviewed OSW's quality system in June 1994.
ORD's recommendations did not specifically
address the Biennial Report, BRS, or related
data quality. However, based on their inter-
views and document reviews, the ORD staff
commented that the complexity of reporting
codes makes the BRS difficult to use.
When OMB recently approved EPA's ICR for the
1997 Biennial Report, OMB required that EPA,
in the future 1999 Biennial Report cycle,
take steps to reduce the burden on reporting
facilities by changing the waste handling and
characterization codes used in the Biennial
Report and other RCRA information processes.
While EPA's WIN Initiative may consider this
issue in a broader sense, WIN may not be
completed before the Agency has to
incorporate OMB's data collection concerns
for the 1999 Biennial Report. We believe OSW
should address this issue of changing codes
(system type, form and source) for the 1999
Biennial Report to make sure OMB concerns are
satisfied in due time.
DATA ARE HOT
EASILY OBTAINED
FROM BRS
The BRS was designed by EPA to meet the
statutory requirement of reporting every two
years on the amount and types of hazardous
waste generated in this country. OSW
officials provide the user community with the
ability to request enhancements to make BRS
10
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Biennial Hazardous waste Data:
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data more "obtainable." However, we found
many users have raised concerns about
obtaining useable data from BRS. One of the
main concerns is that the BRS programming
language, FOCUS, is a difficult language to
learn and to use. Pew people have the
requisite expertise with FOCUS to program
necessary reports from BRS.
The average user's ability to access data and
generate selected information and reports
from BRS is limited. In some of the states
we reviewed, officials said EPA headquarters
provided only limited support for obtaining
reports from BRS. The September 12, 1996,
draft EPA Hazardous Waste Program Information
Strategy Plan acknowledges that BRS is
difficult to access because it is on the EPA
mainframe, and programmed in a software
language (FOCUS) that is difficult to use.
Officials in several states also expressed
concern that they did not have personnel with
the necessary level of skill in FOCUS to
generate reports from BRS necessary to help
manage their RCRA state programs.
Recognizing the difficulty users have with
FOCUS, EPA developed the Reporting Database
(RDB) to assist users in obtaining reports
from BRS. Yet, EPA's own user manual for the
ROB (December 1993) states that successful
reporting with current BRS databases requires
programming skills beyond most BRS user
capabilities. One of the objectives for
creating the RDB was to reduce the requisite
knowledge of FOCUS that users need to
generate reports from BRS. However, none of
the states or regions we visited mentioned
the RDB. Several individuals did mention the
difficulty in obtaining information from BRS.
EXPANDED USE OF
COMPUTER TECH-
NOLOGY NEEDS TO
BE PURSUED
Our interviews with regional and state
officials show that users of the Biennial
Report believe that expanded use of
electronic technology and better reporting is
needed. Similar concerns were raised in a
recent report by N6A, and by an EPA sponsored
study covering RCRIS and BRS implementation.
11
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Biennial Hazardous Waste Data:
Opportunity for Improvement
OSW is familiar with state level innovations
to improve effectiveness of data collection
and management. It is also familiar with the
extensive comments on the subject in the NGA
report. Participants in the EPA sponsored
study that assessed RCRIS and BRS also
discussed the need for making Biennial Report
.information more accessible and easy to use.
Officials we interviewed mentioned similar
concerns.
The State of Florida found data entry and
reporting to be very cumbersome. Florida
officials had to resolve their concerns by
developing BRSDISK which is a personal
computer program containing a diskette
version for the Biennial Report forms. They
use BRSDISK (also referred to as the "Smart
Form") for entering data and compiling the
data into a commercially available database
program which allows them to develop their
own reports. They told us that the program
has saved data entry time and increased
overall data accuracy. BRSDISK uses the flat
file structures published in EPA's Electronic
Reporting Guide.
Florida's computer expertise allowed them to
overcome problems normally associated with
BRS. A key Florida official explained that
the state's reporting facilities needed more
"friendly" data entry and built-in quality
control checks than what was provided by BRS.
The BRSDISK program was designed to check
internal consistency and accuracy within each
submitted report. When data entry is
complete, all forms are checked for
completeness, cross checked for internal
integrity and checked against lists of valid
entries. In effect, Florida's program
minimized problems their reporting facilities
had experienced with the large Biennial
Report forms package and actually reduced the
time it took to enter the data. They have
shared the BRSDISK program with other states
which has helped resolve similar computer
related problems with BRS.
12
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Biennial Hazardous Waste Data:
Opportunity for improvement
Although the WIN Initiative may lead to
changes in the BRS, they will not occur until
several years in the future. OSW officials
recently informed us they are planning to
enter into a partnership with the NGA in 1997
to examine the use of electronic reporting
for BRS. We believe OSW should emphasize to
the states the use of electronic
enhancements, starting with innovations that
are already being used by various states and
regions. Some of these enhancements could be
used to test WIN initiative ideas. We
believe OSW should work to make enhancements
known to other states, to improve electronic
reporting.activities nationwide.
ACCESS TO BRS
FILES NEEDS TO
BE IMPROVED
Biennial Report users would benefit from
having a simultaneous user capability to help
improve their work. We found that the BRS
mainframe software slows data entry for a
user. For example, officials at two regions
and three states stated that the BRS does not
allow more than one person to have access to
the system at the same time.
A regional official explained that while a
state is entering data, the regional office
could not run a report at the same time. The
region had to wait for the state to log off
the system. This slows and complicates the
process for obtaining reports. The regional
official described the capability needed as a
simultaneous update capability. This concern
was also raised by the NGA in a report dated
June 5, 1995, which recommended that EPA
allow simultaneous users to enter Biennial
Report data.
OSW officials told us that while they did not
change BRS to allow a simultaneous user
capability because of limited available
resources, they implemented changes to permit
data entry into multiple BRS databases. They
also streamlined the effort required to
combine the multiple databases into a single
BRS database after completing the data entry
process. During the audit, we were told that
use of multiple databases can cause merging
problems and data inaccuracies when the data
13
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Biennial Hazardous waste Data:
Opportunity for Improvement
is transferred into the single database.
Also a regional official pointed out that
RCRIS has a simultaneous user capability.
Another official said RCRIS and BRS use the
same programming language and were described
as old mainframe type systems that are
difficult to work with for most users. We
believe that a simultaneous user capability
would assist the states and regions to
provide more efficient data entry for
Biennial Report reporting.
RECOMMENDATIONS
We recommend the Assistant Administrator for
the Office of Solid Waste and Emergency
Response initiate the following actions for
the 1999 Biennial Report process or as soon
as possible:
2-1.
2-2.
2-3.
2-4.
Streamline and redesign the
Biennial Report forms and
instructions to make them clearer
and easier for generators and TSDs
to complete. During this process,
OSW should examine the changes that
selected states made to their
individual forms and instruction
packages and incorporate the best
improvements.
Revise the Biennial Report codes
(system type, form and source) to
reduce the confusion experienced by
generators and TSDs.
Reemphasize the Reporting Database
and provide additional training on
it to assist users in obtaining
more useful information from BRS.
Educate the states regarding the
use of existing electronic
enhancements to improve their data
collection and reporting
activities.
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Biennial Hazardous Waste Data:
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2*5. Improve the availability and access
for all users by making BRS
available at users desktop
computers.
2-6. Revisit the issue of allowing
simultaneous user capability to
improve the BRS by permitting more
efficient data entry.
AGENCY COMMENTS
AND OI6 EVALUATION
The Agency agreed with the recommendations
in our report. The Agency will for the 1999
Biennial Report make additional streamlining
changes to the instructions and forms and
will review selected state actions and
incorporate improvements. OSW has allocated
funds to reevaluate state information and
requirements for hazardous waste activity
reporting relating to codes. This study will
begin later during FY 1997 and should be
completed in early 1998.
In the fall of 1997, OSW plans to conduct BRS
training sessions for state users that will
emphasize the Reporting Database to help them
obtain useful information from BRS. During
the training sessions, OSW will also educate
state users about different electronic
reporting enhancements. In addition, OSW
will work with the National Governors'
Association to provide state users with
shared experiences concerning use of
electronic reporting for the.Biennial Report.
OSW also will develop a simultaneous user
capability to simplify data entry for the
1997 Biennial Report process.
We agree with these actions and believe they
will result in an easier and more useful
Biennial Report process and BRS.
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Biennial Hazardous Waste Data;
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16
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Biennial Hazardous Waste Data;
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CHAPTER 3
IMPACT OF EPA's 1997 BIENNIAL
REPORT CHANGES
EPA has made recent Biennial Report changes
that affect the Agency's ability to
characterize and manage the nation's
hazardous waste program. First, the Agency
will no longer gather information or report
on waste minimization activities. Second,
EPA is no longer collecting hazardous waste
capacity planning data in the Biennial Report
process. Third, the Agency has initiated
changes to ensure that wastewater data does
not skew Biennial Report information.
WHY WASTE
MINIMIZATION
REPORTING IS
IMPORTANT
One of the main goals of RCRA is to minimize
the generation of hazardous waste in this
country. The statute states:
The objectives of this Act are
to promote the protection of
health, and the environment
and to conserve valuable
material and energy resources
by...minimizing the generation
of hazardous waste and the
land disposal of hazardous
waste by encouraging process
substitution, materials
recovery, properly conducted
recycling and reuse, and
treatment.
EPA and other regulatory agencies in the
states have used Biennial Report data to
measure the progress of waste minimization.
However, the Information Collection
Request(ICR) for the 1997 Biennial Report
data collection process does not include the
17
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Biennial Hazardous Waste Data:
Opportunity for Improvement
1997 BIENNIAL
REPORT ICR MAY
NOT MEET WASTE
MINIMIZATION
STATUTORY
REQUIREMENTS
requirement for reporting on waste
minimization activities.
Waste minimization is an important tool in
assuring the protection of human health and
the environment, and in conserving valuable
resources. However, state officials told us
that better information needs to be collected
on the amount of waste minimized, recycled,
reused, or sold for reuse. For example,
Kentucky has one facility that was the
state's largest generator of hydrochloric
acid waste. The acid was disposed by
underground injection until a market was
found for the waste. Now, the waste is no
longer counted as a generated waste.
The fact that this facility was able to find
a market for this waste is noteworthy and
should be shared with other industry
facilities in the hope of reducing other
wastes. Normally, a state does not know why
or when a waste is no longer generated.
States would like to have this type of
information available, but the only way to
find out about reuse or recycling is to go to
the industry itself.
According to Section 3002 (a) of RCRA,
regulated entities must report every two
years on various activities including:
the efforts undertaken during
the year to reduce the volume
and toxlcity of waste
generated and the changes in
volume and toxicity of waste
actually achieved during the
year in question in comparison
with previous years.
While this reporting is not required to be
part of the Biennial Report, it is a required
reporting item for OSW. According to OSW
officials, the waste minimization questions
appearing in the 1995 Biennial Report forms
were not providing useful information. OSW
also said that the questions gave an
incomplete picture of waste minimization
16
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Biennial Hazardous Waste Data:
Opportunity for Improvement
activities nationwide because responding to
the questions was optional. As part of an
effort to achieve a 25% reduction of the
paperwork burden on regulated entities, EPA
eliminated the waste minimization questions
from two forms in the 1997 Biennial Report
package. None of the other forms in the
Biennial Report package include this
information on minimization activities. We
believe the resulting 1997 Biennial Report
data collection will not contain the
information required to meet the statutory
requirement.
While the Biennial Report is not specified as
the required report for obtaining waste
minimization data, the Agency will have to
find another data source as long as this is a
statutory requirement. In fact, the Biennial
Report ICR states that there are "other
sources" for waste minimization data, but the
Agency did not clearly identify the way in
which this requirement will be met. "other
sources" of data might include: (1) the
certification on the manifest; (2) Toxics
Release Inventory (TRI) waste minimization
information; and (3) comparisons of the
amount of hazardous waste produced between
1995 and 1997. Yet, these other sources do
not appear to be adequate to meet the
statutory requirements.
First, no federal requirement exists for RCRA
manifests to be submitted to an outside
entity such as the state or EPA. As a
result, manifest information would only be
available where a state requires generators
to submit manifests to the appropriate state
agency. Even so, manifests would not contain
all the information specified by RCRA Section
3002(a). Second/ though TRI waste
minimization data may be extensive, an EPA
work group concluded in October 1993 that the
universe of facilities that report under both
TRI and BRS only contains a 25% overlap of
facilities, and that wastes reported under
both TRI and BRS only had a 15% overlap.
Third, OSW is trying to develop a methodology
to measure and evaluate progress towards the
waste minimization goals using 1991 data as
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Biennial Hazardous Waste Data:
Opportunity for Improvement
compared to 1999 data. OSW will face a
problem doing this comparison because the
waste minimization questions have been
eliminated from the 1997, and possibly the
1999, Biennial Report process. Even using
OSWs methodology as a substitute for future
Biennial Report data, OSW will still need
information on "efforts undertaken during the
biennial reporting year to reduce the volume
and toxicity of waste generated" to meet the
statutory requirement. We believe that the .
Agency clearly needs to determine how it will
satisfy the statutory waste minimization
reporting requirements.
WASTE MINIMIZATION
INSTRUCTIONS WERE
DIFFICULT FOR
FACILITIES TO
UNDERSTAND
An additional concern is that the Biennial
Report instructions for waste minimization
activities was often viewed as unclear and
difficult for regulated entities to
understand. Because of the difficulty in
understanding the instructions, waste
minimization information provided by the
reporting community may not always have been
complete or accurate. Thus, presenting a
true national picture for waste minimization
information and activity was often difficult
to determine. This issue exists regardless
of whether waste minimization reporting is
part of the Biennial Report process, or if it
is to be satisfied some other way.
Several of the states we visited commented
that most of the questions they had gotten
from generators in the past were related to
the waste minimization section of .the
Biennial Report forms. One state we visited
had taken actions to improve its waste
minimization information. For example, the
Illinois State Office of Pollution Prevention
helped rewrite the instructions for the waste
minimization portion of the report. For any
future effort, we believe EPA needs to make
the instructions for waste minimization more
understandable.
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Biennial Hazardous waste Data:
opportunity for improvement
AGENCY CONCLUDED
THAT HAZARDOUS
WASTE CAPACITY
IS ADEQUATE
capacity Planning
Data Was Requested
starting with 1993
Biennial Report
Information collected for the Biennial Report
has been used to assist states in preparing
their hazardous waste capacity assurance
plans required by the Comprehensive
Environmental Response, Compensation and
Liability Act of 1980 (CERCLA), as amended.
CERCLA requires states to assure that
adequate capacity exists to manage hazardous
wastes generated in their states for 20
years, before EPA can expend any Superfund
Remedial Action Trust funds in the states.
EPA used data submitted by the states to
determine national capacity. The Agency's
1996 National Capacity Assessment Report
states that EPA's analysis has shown adequate
national capacity through the year 2013, but
that hazardous waste planning activities
should continue at the state level. The
report also concludes that:
...there is no guarantee that the
current projected surpluses of
hazardous waste management capacity
will continue to exist. Because of
this the Agency will continue to
assess the national capacity
situation — and will continue to
collect and evaluate additional
data to ensure that the require-
ments of CERCLA 104 (c)(9) are
satisfied.
A 1990 EPA report on RCRA implementation
recommended that the Biennial Report be used
to support the capacity planning process.
EPA and NGA worked together to revise the
Biennial Report for 1991 to include the
collection of data for capacity planning.
Starting in 1993, OMB required the Agency to
identify which parts of the Biennial Report
forms submitters were required to fill out,
and which ones were voluntary. The form
containing the capacity data was designated
as voluntary. OMB's concern was to reduce
the paperwork burden on those filling out the
forms.
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Biennial Hazardous Waste Data:
Opportunity for Improvement
Capacity Planning starting with the 1997 Biennial Report,
Data will HO Longer capacity planning data will not be collected.
Be Collected in the Although one of the primary data sources for
Biennial Report states' capacity analyses was the Biennial
Process Report, the Agency obtained OMB approval to
eliminate the Biennial Report form that was
used to collect the capacity planning data.
While some states have other sources for
capacity planning, some have relied on the
Biennial Report data. OSW officials believe
that other sources of data are available to
track capacity. Their position is that most
states do in-state or regional capacity
planning, and as a result they support
removing the statutory reguirement from
CERCLA.
OSW expects capacity planning requirements to
be eliminated when the Superfund legislation
is reauthorized and does not expect to
collect any more information using future
Biennial Report data. They believe that in
the future states will be responsible for
planning and managing their own waste
capacity. Currently, EPA is treating the
1996 report as baseline information and will
examine the effect of any changes in future
legislation. OSW officials told us they have
updated the waste .capacity baseline with
specific Agency and private sector capacity
analyses.
A majority of states supported removal of the
capacity information from the Biennial Report
process, while some states did not. A
regional official told us that eliminating
capacity planning from the Biennial Report
process was a mistake, because it provided
needed consistency for planning purposes.
Further, some states depend on and use
Biennial Report data to plan and manage their
waste capacity. In the absence of the
collection of capacity planning information
using the Biennial Report process, we believe
that EPA should ensure states receive
specific information from future Agency
updated assessments. Providing information
to the states would help EPA to address the
adequacy of the Nation's hazardous waste
22
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Biennial Hazardous Waste Data:
Opportunity for improvement
WASTEWATER CAN
SKEW HAZARDOUS
WASTE DATA
EPA Resolves
a Similar
Wastewater
Concern
capacity to treat and dispose of hazardous
waste.
A large amount of hazardous wastewater is
produced in the United States. According to
the 1993 Biennial Report, 258 million tons of
RCRA hazardous waste were generated. Of the
258 million tons of hazardous waste, at least
85% or 220 million tons was managed
wastewater. The large quantities of
wastewater represent relatively few wastes,
if the water was concentrated to a solid
mass/ and tend to skew Biennial Report data.
The Agency is interested mainly in solid
waste amounts because of the increased risk
associated with hazardous solid waste.
One example of hazardous waste being
overstated by wastewater was in Tennessee
where one facility accounted for 99% or 33.5
million tons of the state's total hazardous
waste generation. Of this amount, 33.4
million tons were actually wastewater.
Another example where wastewater caused
overstatement was found in New Jersey. In
that state one facility accounted for 95% or
17_1 million tons of the state's total
hazardous waste generation. Of this amount,
about 17 million tons was wastewater. We
believe that OSW should develop a means (for
example, a chart) to more clearly show the
users of the National Biennial RCRA Hazardous
Waste Report the impact of hazardous
wastewater amounts on the data as compared to
lesser non-aqueous solid hazardous waste
amounts.
In a related issue, EPA has resolved a long
standing concern about exempt wastewater
being included in the Biennial Report data
from generators and TSDs. For the 1995
Biennial Report, if a generator or TSD had
even one RCRA-permitted process on site, then
all hazardous wastewater was included in
their data submission. OSW has now
determined, for the 1997 Biennial Report that
generators and TSDs will no longer be
required to report any RCRA hazardous wastes
23
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Biennial Hazardous Waste Data:
Opportunity for improvement
managed in exempt units, including wastewater
quantities.
We also had identified this particular issue
and planned on making a recommendation to
address this point. Since OSW has now taken
this action, we are not making a
recommendation to address this issue.
However, we are making a recommendation to
address the impact that hazardous wastewater
has on the National Biennial Report data as
we have discussed above.
RECOMMENDATIONS
We recommend the Assistant Administrator for
the Office of Solid Waste and Emergency
Response:
3-1.
3-2.
3-3.
3-4.
Assess the type of data required
and specify how RCRA Section
3002(a)'s reporting requirement
will be met.
Recommend changes to Section
3002(a) during RCRA reauthorization
to better match Agency reporting
abilities with the statutory
requirement for waste minimization
reporting.
Ensure states receive specific
information for their waste
planning efforts from any future
Agency waste capacity
reassessments.
Develop a means (such as a chart)
to more clearly show the users of
the National Biennial RCRA
Hazardous Waste Report the impact
of hazardous wastewater amounts on
the data as compared to lesser non-
aqueous solid hazardous waste
amounts.
24
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Biennial Hazardous waste Data:
Opportunity for Improvement
AGENCY COMMENTS
AND OIG EVALUATION
OSWER agrees with the recommendations in our
report. For waste minimization, OSWER will
assess the data required to meet the
requirements and will determine what
information it needs to collect and report
under Section 3002 (a) of RCRA. OSWER also
plans during its evaluation of waste
minimization information needs to determine
what statutory changes may be needed and
proposed during the RCRA reauthorization
process. Further, OSW agreed to provide any
future EPA results of waste planning analysis
and planned changes in capacity to the states
to help them with their individual capacity
planning efforts. Finally, OSW will develop
and provide detailed information regarding
each state's hazardous wastewater and non-
wastewater quantities for its 1995 Biennial
Report which is currently under development.
We believe these Agency corrective actions
will address our findings and recommendations
contained in this chapter. Further, we
believe these Agency actions will result in
significant improvements to the current
Agency program.
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Biennial Hazardous waste Data:
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26
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«l° «•«*..
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
APPENDIX I
FEB ! I
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
MEMORANDUM
SUBJECT: Response to Draft Audit Report No. E1DSF6-11-0001
"Biennial Hazardous Waste Data:
Opportunity for Imnubveme/it"
f(
FROM: Elliott P. Laws rfl^^Zfy -jfayj/jS^ty
Assistant Administrator/
L
for Solid Waste and •EnJffrgencyy Response
TO: Michael D. Simmons
Deputy Assistant Inspector General
For Internal Audits
The Office of Solid Waste and Emergency Response (OSWER) has
reviewed the subject draft audit report, and we concur with the
recommendations made in the report.
We have planned appropriate actions to implement changes in
the biennial reporting process and the Biennial Reporting System
(BRS) data system according to these recommendations. Specific
responses are provided in the attachment to this memorandum.
We appreciate the opportunity to review and comment on this
report. We also wish to express our thanks to the Headquarters
Audit Division for the amount of time and hard work they were
willing to invest in this audit process. Their concerted effort
to understand these issues led to the development of meaningful
and practical recommendations that we believe will improve the
biennial reporting process and the BRS data system.
If you have any questions, please contact Myra Galbreath
of the Office of Solid Waste (OSW) at 703-308-8739, or
Andrew Kreider, OSWER audit liaison, at 202-260-9192.
Attachment
27
R*cycl««n*cyd«M« • Prtnttd with V«gM*>to 01 B*M4 Into on 100% RwydMj PUN* (40% PostoonsuiMf)
-------
APPENDIX I
cc: Tim Fields
Michael Shapiro
Myra Galbreath
Dev Barnes
Johnsie Webster
Andrew Kreider
Anne Andrews
Jess Plonka
Michael Prater
28
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OSWER Response to Draft Biennial Report Audit Recommendations
APPENDIX I
Page: 1
Recommendat j-gn 2 -1
Streamline and redesign the Biennial Report forms and
instructions to make them clearer and easier for generators and
TSDs to complete. During this process, OSW should examine the
changes that selected states made to their individual forms and
instruction packages and incorporate the best improvements.
Response
The Office of Solid Waste (OSW) agrees with the finding that
the Biennial Reporting (BR) requirement reflects the complexity
of the Resource Conservation and Recovery Act (RCRA). OSW has
taken significant steps to simplify reporting for the 1997
reporting cycle and is engaged in a longer-term effort to reduce
the complexity and burden of hazardous waste reporting. OSW has
included states in the development of past biennial reporting
forms including the changes introduced for 1997. In accordance
with the recommendation, OSW will consult with states regarding
potential streamlining changes and state innovations for the 1999
reporting forms.
The streamlining changes developed for the 1997 BR forms
cycle achieve a 21% reduction in the overall volume of the
reporting package and even greater reductions in complexity.
Following consultation with states, regulated industry and the
public, OSW eliminated the requirement to report waste
minimization, process systems and exempt waste information
beginning with the 1997 report cycle. OSW also consulted with
states to identify improvements to the 1997 reporting forms and
instructions. These changes achieve significant streamlining of
the reporting requirement by eliminating 44% (21) of the
instruction pages, 20% (II)1 of the example pages, and 4% (2) of
the code list pages. Furthermore, the sections eliminated were
the most complex and least understood portions of the reporting
requirement.
Recommendation 2-2
Revise the Biennial Report codes (system type, form and source)
to reduce the confusion experienced by generators and TSDs.
29
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OSWER Response to Draft Biennial Report Audit Recommendations
APPENDIX I
Page: 2
Response
OSW agrees that every effort must be made to minimize
respondent confusion regarding the categorization and
classification of wastes and their management. OSW also agrees
that codes and classifications for RCRA waste handling should be
as consistent as feasible across RCRA record keeping and
reporting requirements. Improved consistency in RCRA information
and reporting requirements is a major goal of the Waste
Information Needs (WIN) initiative.
OSW has allocated funds to begin a re-evaluation of state
information and implementation requirements with regards to
hazardous waste activity reporting. States will lead this WIN
initiative analysis of hazardous waste activity monitoring and
reporting requirements. This focused study is targeted to begin
in fiscal year 1997 and should be completed in early 1998.
Both source and form code are optional fields for national
reporting and OSW proposed eliminating them from the 1997 EPA BR
forms. States opposed this change and industry comment regarding
changes to the 1997 BR reporting requested that changes to the
requirement should be minimized until states and EPA have agreed
upon major revisions to the requirement. A review of. customized
state forms packages shows that most translating states also
continue to rely on the BR system type codes to classify waste
management methods. OSW believes that further changes to the
biennial reporting requirement, beyond those planned for 1997,
should be considered within the context of a complete re-
assessment of hazardous waste activity reporting as is being
pursued under the WIN initiative in fiscal year 1997.
Recommendation 2-3 •
Re-emphasize the Reporting Database and provide additional
training on it to assist users in obtaining more useful
information from BRS.
Response
OSW recognizes that ad-hoc or custom reporting from BRS is
difficult for system users who are not skilled in the FOCUS query
language. To address this issue OSW offers yearly training
30
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OSWER Response to Draft Biennial Report Audit Recommendations
APPENDIX I
Page: 3
sessions in BRS reporting (except 1996 due to budget
constraints). OSW plans to conduct BRS training sessions again
in the Fall of calendar year 1997. In accordance with the
recommendation, OSW will emphasize BRS data access and reporting
tools including the Reporting Data Base.
Recommendation 2-4
Educate the states regarding the use of existing electronic
enhancements to improve their data collection and reporting
activities.
Response
OSW recognizes that some states have achieved significant
innovations in the area of electronic reporting. OSW has
supported the use of these innovations in conjunction with BRS
and will continue to do so. In accordance with the
recommendation, OSW is working with the National Governors
Association (NGA) to support a forum for states to share their
experiences and innovations in BRS electronic reporting. OSW will
share the information developed in this forum with states and
will emphasize BRS electronic reporting support in the Fall 1997
BRS training sessions.
Re e ommenda t i on 2-5
Improve the availability and access for all users by making BRS
available at users desktops.
Response
OSW agrees that BRS data should be made available to users
via their desktop systems. While comprehensive BRS systems re-
design is a long term effort that must be pursued under WIN, OSW
has been involved in several projects to provide desktop access
to BRS data. BRS desktop access is currently available from the
following sources: Internet access to BRS data via the Right To
Know Network (RTK-Net) web site at http://www.rtk.net; and CD-ROM
access to BRS data via the commercially produced "Environmental
Factors* CD-ROM. OSW is also collaborating with the Office of
Information Resources Management (OIRM) on the integration of BRS
31
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APPENDIX I
OSWER Response to Draft Biennial Report Audit Recommendations
Page: 4
data in the Agency-wide EnviroFacts data base and with the Office
of Enforcement and Compliance Assurance, (OECAJ on the integration
of BRS data with the Integrated Data for Enforcement Analysis
(IDEA) data base.
In addition, OSW is beginning a pilot project during 1997 to
transfer BRS data to Oracle databases. While this pilot is not
expected to produce desktop accessibility for BRS data in 1997,
the longer-term goal of the project is to provide a desktop
interface to BRS data bases via EPA's wide area network arid the
Internet.
Recommendst i on 2-6
Revisit the issue of allowing simultaneous- user capability to
improve the BRS by permitting efficient data entry.
Response
OSW agrees that simultaneous update capability will simplify
the BR data entry process and intends to introduce this
capability for the 1997 reporting cycle.
Recomniendat ion 3-1
Assess the type of data required and specify how RCRA Section
3002 (a)'s reporting requirement will be met.
Response
OSW agrees that we need to assess the type of data needed
for waste minimization purposes and their relationship to the
reporting requirements of RCRA Section 3002(a). In accordance
with the Inspector General's (IG) recommendation, OSW is
currently in the process of evaluating the best methods for
satisfying the information requirements related to' RCRA 3002 (a).
This evaluation is examining data needs from several
perspectives: 1) meeting the data needs of the Waste Minimization
National Plan (WMNP) and Government Performance and Results Act
(GPRA); 2) meeting the needs of regions and states as they relate
to the WMNP and GPRA; and 3) meeting the needs of waste
minimization trend reporting. OSW will evaluate not just the
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OSWER Response to Draft Biennial Report Audit Recommendations
APPENDIX I
Page: 5
Biennial Reporting System for meeting data needs, but also the
Toxics Release Inventory (TRI) and other reporting systems.
• For waste minimization, these different systems (with their
own and somewhat divergent focuses) are each expected to provide
partial but potentially complementary information -- quantities
of waste streams versus quantities of constituent chemicals in
waste streams, for example. Obtaining an understanding of what
information each system can offer about waste minimization is
vital for the development of a robust waste minimization
measurement methodology as well as for identifying the general
trends"in waste minimization that may be occurring. By
evaluating the information from these different systems, OSW
believes that the requirements of 3002 (a) should be met.
Recommendation 3-2
Recommend changes to section 3002 (a) during RCRA re-
authorization to better match Agency reporting abilities with the
statutory requirements for waste minimization reporting.
Response
In accordance with the IG recommendation, OSW is
reevaluating the information needed for waste minimization
purposes. If OSW finds that it is statutorily constrained by the
reporting requirements under RCRA to meet its waste minimization
needs, OSW agrees that the reauthorization process can be a good
mechanism to alleviate those constraints. Alternatively, if OSW
finds that some of the reporting requirements are unnecessary,
again, the reauthorization process can be a good mechanism to
remove those requirements deemed unnecessary.
Recpmtnendation 3-3
Ensure states receive specific information for their waste
planning efforts from any future reassessments.
Response
OSW agrees that any future EPA analysis regarding observed
and/or planned changes in capacity should be made available to
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APPENDIX I
OSWER Response to Draft Biennial Report Audit Recommendations
Page: 6
states and will do so.
Recommendation 3-4 - ..
Develop a means (such as a chart) to more clearly show the users
of the National Biennial RCRA Hazardous Waste Report the impact
of wastewater amounts on the data as compared to lesser non-
aqueous solid hazardous waste amounts.
Response
The National Biennial RCRA Hazardous Waste Report currently
identifies the quantities of wastewater and non-wastewater
management and their relative percentages of the total reported
management. Based on the IG recommendation, OSW will enhance
this chart to show how the wastewater and non-wastewater
quantities are broken out for each state. OSW will implement this
change beginning with the 1995 report.
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Biennial Hazardous waste Data;
Opportunity for Improvement
APPENDIX II
Page 1 of 2
REPORT DISTRIBUTION
Office of Inspector General
Inspector General (2410)
Assistant Inspector General for Audit (2421)
EPA Headquarters
Assistant Administrator for Solid Waste
And Emergency Response (5101)
Assistant Administrator for Administration
And Resources Management (3101)
Associate Administrator for Regional
Operations and State/Local Relations (1501)
Associate Administrator for Congressional
And Legislative Affairs (1301)
Associate Administrator for Communication,
Education, and Public Affairs (1701)
Agency Followup Official, Office of
Administration and Resources Management (3101)
Agency Followup Coordinator, Attn: Director,
Resource Management Division (3304)
Headquarters Library (3304)
Director, Office of Solid Waste (5301)
Acting Director,. Communication, Information,
And Resource Management Division (5305)'
Director, Hazardous Waste Minimization and
And Management Division (5302)
Director, Economics, Methods, and Risk
Analysis Division (5307)
35
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Biennial Hazardous Waste Data:
Opportunity for Improvement
Audit Coordinator, Office of Solid Waste
and Emergency Response (5101)
Regional Offices
Regional Administrators, Region 1 through 10
Audit Coordinator, Region 4
Audit Coordinator, Region 5
Audit Coordinator, Region 7
State and Other Offices
Florida Department of Environmental Protection
Illinois Environmental Protection Agency
Iowa Department of Natural Resources
Kentucky Department for Environmental Protection
Michigan Department of Environmental Quality
Ohio Environmental Protection Agency
Tennessee Department of Environment and Conservation
National Governors' Association
Association of State and Territorial
Solid Waste Management Officials
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