United States Solid Waste and EPA530-R-00-004
Environmental Protection Emergency Response January 2000
Agency (5305W) www.epa.gov/osw
v>EPA WIN/INFORMED:
Universe Identification,
Waste Activity
Monitoring, Program Area
Analysis; Final Report
Printed on paper that contains at least 30 percent postconsumer fiber
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WIN/INFORMED
UNIVERSE IDENTIFICATION
WASTE ACTIVITY MONITORING
PROGRAM AREA ANALYSIS
FINAL REPORT
January 28th, 2000
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Acknowledgements
We would like to thank the following individuals for their help with the development of this
report:
Beverley Allen
Elizabeth Bols
Leslie Brennan
Paula Cantor
Janet Cornelissons
Walt Derieux
Harold "Butch" Dye
Debbie Goodwin
Michael Hillard
Harriett Jones
Scott Latham
Dave Levy
Matt Loesel
Rusty Lundberg
Bud McCarty
John Mitchell
Jessica Ogle
Les Otte
Sue Parker
Sarah Rasmussen
Jane Ratcliffe
Lynn Singleton
Allan Tinsley
Karen Way
Caroline Westerfer
Prepared By
WINDSOR SOLUTIONS, INC.
4000 KRUSE WAY PLACE
BUILDING 2, SUITE 160
LAKE OSWEGO, OR 97035
(503) 675 7833
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EXECUTIVE SUMMARY
EXECUTIVE SUMMARY
Background
The WIN/INFORMED initiative is an information reinvention project established jointly by the
States and the Environmental Protection Agency (EPA). The objective of this initiative is to
reassess the information needs of the hazardous waste management program operating under
Subtitle C of the Resource Conservation and Recovery Act (RCRA). Through WIN/INFORMED,
EPA and States aim to jointly identify, and share where appropriate, the information needed to
effectively manage the RCRA program.
To achieve this goal, strategic planning for the WIN/INFORMED initiative focused on dividing the
RCRA program into five logical groupings of program functions and information needs, termed
program areas. These are:
Universe Identification (UID)
Waste Activity Monitoring (WAM)
Handler Monitoring and Assistance (HMA)
Permitting and Corrective Action (PCA)
Program Evaluation (PE)
This Final Report presents the findings and recommendations resulting from the combined
Program Area Analysis (PAA) project conducted for the UID and WAM program areas.
Project Approach
Although originally planned to be undertaken individually, analysis tasks for the UID and WAM
program areas were combined to realize significant time and cost savings by conducting national
review and implementation planning tasks for these closely related projects at the same time.
A joint team consisting of program staff from States, EPA Regional Offices, and EPA
headquarters Office of Solid Waste and Office of Enforcement and Compliance Assurance
conducted the PAA project. Program staff participated directly in the project, providing practical
experience with the implementation of the RCRA program in their organizations.
Initial information gathering sessions were conducted with participating States and EPA Regional
and headquarters offices. Selected program experts reviewed preliminary findings and
recommendations through two separate "critical" review processes.
All States, Regions and Offices of EPA then subjected these recommendations to a thorough
National Review before the project findings were confirmed by the PAA Team, resulting in three
main project deliverables:
Information Needs The information that must be made available to successfully
implement the RCRA program.
Recommended Improvements The changes to current information collection and management
procedures that are necessary to meet the required information
needs.
Implementation Plan An outline for how these recommendations should be organized
and further designed and implemented.
FINAL REPORT PAGE: i
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EXECUTIVE SUMMARY
This Final Report presents these deliverables. An additional set of Technical Deliverables also
resulted from this PAA project, including conceptual models of how RCRA program information
should be collected and organized. These have been provided under separate cover.
Recommended Information Needs
An important goal of the WIN/INFORMED initiative is to identify information that must be
collected and made available to all program staff to support the implementation of the RCRA
program. The following recommendations are made with respect to identifying and organizing
these information needs.
Common organizing framework
Many of the concerns expressed by PAA participants with respect to current RCRA program
information can be attributed to varying interpretations of the information and poor current data
quality. Before attempting to resolve these problems the PAA Team first agreed upon a common
framework to organize the information needs. This framework is outlined in Table 1.
NATIONAL INFORMATION
SHARED INFORMATION
Has a common, precise definition (i.e., always means the same thing)
Has mandatory creation or collection
Is maintained to a specified level of quality and
currency
Relies on Federal rule to support the authority for its
collection
Is always accessible to all regulators from national
data systems
Is optionally created or collected
May be collected in many different ways and is not
always current or fully qualified
Does not depend on Federal authority for its
collection
Is only submitted to national data systems at the
discretion of the implementer.
Table 1: Definition and Principles of National and Shared Information
National systems will accommodate both national and shared information needs
Capabilities will be provided in national implementer systems to support the tracking of both
national and shared information needs. This will enable implementers that do not have their own
information systems to track and share all important information with other RCRA program staff
whether that information is needed by the entire program or a smaller subset of the implementer
community.
It is important to note, however, that shared information will, by definition, represent only a
partial set of implementers and may hence provide an incomplete picture. Care must be used
when interpreting shared information. To avoid potential confusion, the appropriate meta-data
should be provided to ensure that program users are aware of the level of completeness for shared
information needs and that a consistent level of data quality cannot be assured.
PAGE: ii
FINAL REPORT
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EXECUTIVE SUMMARY
PROGRAM
AREA
INFORMATION
NEED
CATEGORY
NATIONAL
INFORMATION
NEEDS
SHARED
INFORMATION
NEEDS
Universe Identification
RCRA Site
Identification
EPA identification number
Facility registry identifier
Site name
Location address (i.e., street
address, locality, ZIP, state)
Location county
Location coordinates
Location MAD codes
NAICS code
Discovery date
Notification date
Exempt from notification
Emergency site
Land owner type
Mailing address
Number of employees
State identifier
Site legal name
RCRA Site
Responsibility and
Contacts
Owner name
Owner type
Operator name
Operator type
Site contact name
Site contact phone
D&B number
Site contact address
RCRA Site
Activity
State generator status
Federal generator status
Hazardous waste transporter
Hazardous waste fuel marketer
Underground injection
Used oil transfer station
Used oil burners
Used oil processor
Used oil refiner
Used oil marketer
Used oil transporter
Universal waste handler
Hazardous waste import agent
Mixed radioactive waste handler
GPRA corrective action universe
GPRA operating permit universe
GPRA post closure universe
Annual BOY enforcement universe
TSDF unit type
TSDF unit commercial type
TSDF unit operating status
TSDF unit legal status
Hazardous waste recycler
Hazardous waste transfer station
Waste codes
TSDF unit location
Waste Activity Monitoring
Waste generation,
shipment, receipt, and
management
Originating EPA ID
Destination EPA ID
Federal waste codes
State waste codes
Quantity
Unit of measure
Management method
Source of waste
Destination country
Originating country
Waste form
Mixed radioactive waste
Waste description
Transporter EPA ID
Shipped date
Received date
Manifest number
Foreign recipient
Border crossing
Table 2: Program Area Information Needs
FINAL REPORT
PAGE: iii
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EXECUTIVE SUMMARY
National and shared information needs
The PAA Team used this framework to organize the information needs of the UID and WAM
program areas into four main categories. Table 2 on the previous page lists these information
needs according to the above framework and these four categories.
The following points should be considered when reviewing this table:
Certain information needs are represented in italicized font in the table. These information
needs are all related to the Permitting and Corrective Action program area and include TSDF
management system units. These were not considered by the PAA Team to be part of the
scope of the UID or WAM PAAs but were captured to provide support for some of the
recommended improvements.
The UID information needs listed have been reconciled with the national "Facility Data
Standards" guide recently developed jointly by EPA and States. This will facilitate future
cross-media data sharing by the RCRA program.
The national information needs for the Waste Generation, Shipment, Receipt, and
Management information need category are only "national" for TSDFs and LQGs. For all
other types of RCRA Sites1 these information needs are "shared".
Recommended Information Management Improvements
The following recommendations are proposed for improvements to the current RCRA program
information collection and management procedures. These recommendations and the current
procedures used by the RCRA program for the UID and WAM program areas are illustrated in
Figure 1. Each recommendation has been superimposed on the diagram relative to the current
procedures that would be affected, and is associated with a number referenced in the text below.
Identification of Sites
Current Situation
Implementing agencies currently assign an EPA identification number to all handlers of
hazardous waste that submit an EPA Notification form (8700-12) or equivalent. Although only a
single number is typically assigned to a RCRA Site, there are occasions where the same RCRA
Site may be assigned several numbers.
Emergency and temporary sites are those for whom waste generation activity is limited to a
single, perhaps protracted event. An example of such a site would be one whose waste generation
activity is associated with decommissioning of a production process. These RCRA Sites are
currently tracked inconsistently in national information systems although all such sites are subject
to RCRA regulations governing the handling of wastes that they generate.
Conditionally exempt small quantity generators are not required to notify under RCRA, but
despite this, many apply for and are issued an EPA identification number. While these sites are
known to the relevant implementing agency, they are rarely tracked in national information
systems.
1 A specific location that is currently, or has in the past, conducted waste handling activities of interest to the RCRA
Subtitle C program, as promulgated in either the Federal Register or by individual State or Territory statutes.
PAGE: iv FINAL REPORT
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EXECUTIVE SUMMARY
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Figure 1: Recommended Improvements to Current Information Management
FINAL REPORT
PAGE: v
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EXECUTIVE SUMMARY
The RCRA program has a need to be able to identify RCRA Sites that at some time in the past
failed to notify the relevant implementing agency of their RCRA regulated activities according to
the regulations.
Recommendations (1, 3, 4, 5)
The Team recommends that all sites of interest to the RCRA program that notify the
implementing agency of their activity will be assigned an EPA identification number and will be
tracked in the national information system, including emergency, temporary and conditionally
exempt sites. This identification number will be retained over time regardless of activity or
ownership changes at the RCRA Site, except under exceptional circumstances that will be
documented in national guidance. Sites will be tracked in the national information system as
soon as they are known to the implementing agency and will be flagged if found subsequently to
have no need to have notified. Emergency sites will also be identified specifically.
Identification of Universes
Current Situation
All RCRA regulatory agencies have a clear need to be able to identify groups of RCRA Sites that
share certain regulatory characteristics, for example:
those RCRA Sites that must meet the requirements imposed on generators of large quantities
of hazardous wastes
those RCRA Sites that must meet the requirements of an operating waste management facility
those RCRA Sites that are subject to regulations governing sites that store hazardous wastes
Currently, the various organizations that implement the RCRA program often vary in their
reporting of these groupings of RCRA Sites, which leads to confusion and misunderstanding. In
some cases this is due to differences in program implementation between the organizations, for
example, with respect to the definition of a "large quantity generator", and in others, due to lack
of consistent terminology.
Recommendations (6, 19, 20)
To enable improved information sharing and to ensure consistency, the PAA Team recommends a
number of improvements.
Given the differing regulatory application of generator status definitions and the difficulty in
translating these, the Team recommends that any applicable generator status designation be
recorded for a RCRA Site, whether Federally or State-defined. If State-specific regulations result
in a different regulatory status for a generator, then both State and Federal statuses would be
collected and made available nationally.
Sites involved in the management of hazardous wastes should be defined consistently both with
respect to the type of management activity being performed, for example, treatment, but also with
respect to the regulatory oversight under which they operate, for example, subject to corrective
action.
PAGE: vi FINAL REPORT
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EXECUTIVE SUMMARY
Revise Notification Form
Current Situation
Currently, RCRA Site identification data is collected on several different forms, with a single
RCRA Site being required to submit very similar information several times on each form with
inconsistent data element definitions and instructions.
During the PAA project, RCRA program staff identified a number of areas in which the basic
identification information collected about a RCRA Site could be enhanced to provide significant
benefit. In some cases, additional information needs were identified that are not met by the
current data collection procedures, and in others, redundant information appears to be collected.
Recommendations (7, 8, 10)
A new reporting form will be developed to harmonize the RCRA Site identification information
that is required by the RCRA program. This form will include consolidated and standardized
field definitions. This standardized form will replace site information collection mechanisms
used on the Notification form, Permit Part A form, and Biennial Reporting forms.
At the same time, the opportunity will be taken to enhance the information collected on the forms.
A number of additional data elements will be collected, including:
An indication that the RCRA Site is a handler of large quantities of universal waste.
The operator name (in addition to the owner name).
The relevant North American Industrial Classification System (NAICS) code.
An indication that the RCRA Site handles radioactive wastes.
An indication that the RCRA Site imports hazardous wastes.
Additionally, the waste code information that is currently collected will eventually be removed
from the Notification form. The waste code information is of limited use given that it is not
updated regularly and the accuracy of reporting by generators. Waste activity information will be
better served through the PAA Team's recommendation to collect quarterly TSDF data
electronically, discussed later in this section.
Study feasibility of periodic verification of RCRA Site information
Current Situation
Effective implementation of the RCRA program requires accurate information about the universe
of RCRA Sites regulated under the program. This information supports a variety of activities
including resource planning, inspection targeting, regulatory impact analysis and assessment of
program effectiveness.
RCRA Sites are required to notify the implementing agency when RCRA regulated activities
commence, however, there is no regulatory requirement for RCRA Sites to provide updated
information at any time, even if the RCRA Site identification information changes. Thus, much
of the information available to the program is outdated, with some having not been verified since
the original 1980 notification.
Recommendation (2)
The RCRA program should conduct a design study to evaluate the feasibility of requiring some
kind of periodic verification process for basic information about all RCRA regulated sites. While
FINAL REPORT PAGE: vii
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EXECUTIVE SUMMARY
this practice may represent an additional reporting burden for some members of the regulated
community and the implementer at the outset, the improved quality of data available to the RCRA
program that would result would significantly enhance the effectiveness of the program.
The feasibility study should consider the mechanism by which such verification could be
performed, the nature of the requirement, mandatory or optional, the most cost-effective
frequency of information collection and the universe of RCRA Sites to be affected.
Study feasibility of quarterly electronic TSDF waste reporting
Current Situation
The current biennial submission of information concerning the generation and management of
hazardous wastes is considered insufficient by many program staff (although some States have
increased the frequency of collection of this information). More timely access to current, high
quality waste generation and management information would provide significant benefits to the
program for such activities as inspection planning and waste minimization.
Recommendation (11,12)
Two closely related recommendations are proposed to address this issue:
1. Require all TSDFs to report waste receipt information electronically on a regular basis to a
central nationally available data repository.
2. Produce pre-populated waste generation forms to be sent to generators of hazardous waste for
verification and amendment to become the generator's Biennial Reporting form submission.
Both of these recommendations would require national rule implementation and consistent CBI
guidance to be completely effective.
Improve reported waste data
Current Situation
PAA participants identified a number of desirable changes to the type of waste generation and
management information that is collected by the Biennial Reporting forms or State equivalents.
There is a clear need to understand the types of industrial or waste management processes from
which hazardous wastes originate, for use in analysis, targeting and outreach activities.
The requirement for RCRA Sites to biennially report wastes that are not used in their generator
status determination is unclear, resulting in significant confusion on the part of the regulated
community.
The use of density information for weight unit conversion on waste reports is also confusing and
has been shown to result in data quality issues.
Several project participants suggested that the existing Source, Origin, Form and Management
code structures used in the Biennial Reporting forms could benefit from streamlining.
The Uniform Manifest Document does not currently require the physical address from which the
waste shipment was collected. The generator's mailing address is required, but this can often be
very different to the generating RCRA Site's physical address. This can make it difficult to tie
the manifest to the point of generation.
Certain data elements are currently collected redundantly on the Biennial Reporting forms or
equivalents.
PAGE: viii FINAL REPORT
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EXECUTIVE SUMMARY
Recommendations (16, 17, 18, 24, 25)
The Team recommends that the Biennial Reporting forms or State equivalents be revised to
require that generators report only those wastes that they use in their generator status
determination.
Generators will specify the source of waste generation.
All waste reporting should be performed using weight units.
A more streamlined set of waste reporting codes should be adopted.
The Uniform Manifest Document and associated instructions should be revised to record the
physical site address including country of the originating generator of the waste shipment,
replacing the reporting of mailing address on the manifest.
Redundant data elements should be removed from waste reporting forms.
Improved Import and Export Reporting
Current Situation
States currently have only limited visibility to information about wastes that are shipped out of
the country. Similarly, States also have only limited knowledge of wastes imported since the
"generator" from whom waste is received is often an agent company located in the State.
Recommendation (13, 14)
Provide States with a reliable source of export information by making the existing waste export
data collected by OECA, available to the RCRA program.
Require import agents to indicate their import activities when they notify and require that TSDFs
reporting waste receipts from such agents indicate the importer and the country of origin of the
waste.
Supporting improvements to the RCRA program information systems
Current Situation
Various general improvements were identified during the course of the PAA project to improve
the quality and completeness of the information available to the RCRA program. These
improvements could be implemented without requiring additional data collection from the
regulated community.
Recommendation (21, 22, 23, 26)
Provide a single source of information to support the RCRA program by integrating the existing
information systems.
Provide functionality to automatically derive location coordinate information from the physical
address of a RCRA site.
Provide historical tracking capability for important information such as site name, owner and
operator name and generator status.
Provide improved information access capabilities to RCRA program staff.
Provide enhanced capabilities to track the source of waste handling activity information about a
RCRA Site.
FINAL REPORT PAGE: ix
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EXECUTIVE SUMMARY
Implementation Plan
An implementation plan has been developed to outline a possible approach to the further
development and implementation of the report's recommendations.
Implementation Planning Considerations
The methodology employed by this PAA calls for the project's recommendations to be further
developed by one or more subsequent Program System Design (PSD) projects. The PAA
recommendations have been organized into smaller discrete groupings allowing the design
process to be more manageable. Care has been taken to ensure that the scope of each design
project takes account of inter-dependencies between recommendations.
There are two primary drivers for the planning and scoping of PSD projects.
1. Inter-dependencies between recommendations may be significant enough to require that
recommendations be developed in parallel with each other.
2. Some recommendations require modification of national reporting mechanisms and
consequent regulatory change. Given the formal and time dependent processes required for
regulatory change, recommendations with similar regulatory impacts should clearly be
implemented together.
Implementation Projects
The PAA Team identified four implementation projects based on logical groupings of the
recommendations. Each has been described in terms of the recommendations included in the
project and the inter-dependencies between the projects. Each project will be lead by either
States or EPA, where the lead organization will be expected to provide a greater level of support
to the project.
Project 1: ICR Reliant System Changes
This project will design the policies/procedures, reporting mechanisms, and information system
changes required by those PAA recommendations that require only ICR changes. By grouping
these recommendations together, the changes to the reporting forms, data entry screens and
regulations can be accomplished in unison, allowing for coordinated ICR changes and ensuring
consistent design and implementation.
This design project will commence as soon as possible, to ensure that those recommendations that
are effected by the Biennial Report ICR will be implemented within the 2000 ICR process. If this
is not accomplished, then these recommendations will not be implemented until the 2002 Biennial
Report ICR cycle. The project will also implement changes to the ICRs for the Notification form,
Part A Permit Application, Uniform Manifest Document, and Export Report. Associated
information systems functionality will also be redesigned to ensure consistency with paper forms.
The project will be led by EPA with design expected to take approximately five months to
complete and the anticipated ICR changes expected to take approximately six months to
complete.
Project 2: Site Verification and TSD Quarterly Reporting
This project groups those recommendations that have the greatest impact to existing regulatory
and/or information management practices together with other recommendations that are critically
dependent on these. These have been segregated from the other recommendations due to their
need for further feasibility study and also due to length of time required perform the studies.
PAGE: x FINAL REPORT
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EXECUTIVE SUMMARY
Site Verification
The project will study the feasibility of alternative mechanisms by which site identification data
can be verified by RCRA Sites. The project will estimate the costs and burden that would be
imposed upon the regulated community and RCRA implementers for several different types of
implementation. Considerations will include; the affected program universe, the nature of the
requirement (optional or mandatory), and optionality. Extensive use will be made of
benchmarking studies and industry outreach.
TSDF Quarterly Electronic Reporting
The project will study the feasibility of the quarterly electronic reporting of waste receipt data
from the nation's TSDFs. This would include the evaluation and design of the reporting
mechanism, a national repository and State/EPA data interchange mechanisms, and the pre-
population of generators biennial hazardous waste reports.
Again, extensive outreach to TSDFs will be included to gauge support and burden.
States will lead this project. The feasibility study for this project would take six months to
complete and would include a national review with subsequent design tasks taking approximately
four months and nine months respectively. The anticipated regulatory change would take
approximately two years to implement.
Project 3: Data Integration into RCRAInfo
This project will include those recommendations that impact information management systems
only, and do not require changes to data collection mechanisms. The project will determine how
the RCRAInfo data and functionality for site identification information will be integrated and
modified.
The project will be EPA lead and would take approximately six months to complete, including a
national review.
Project 4: New Guidance
This project groups the remaining recommendations that either require new guidance to be
developed or encompass practices that when implemented will improve the quality of information
that is currently inconsistently reported.
This project will be EPA lead and will take approximately six months to complete.
Implementation Schedule
An implementation plan has been developed that takes into consideration the inter-dependencies
between the four projects discussed above and the EPA and State resources available to support
the performance of these projects. This is outlined in Figure 2: Schedule of Implementation
Projects on the following page. Four types of implementation task are shown:
1. PSD projects -will examine and detail the manner in which existing regulations, reporting
forms, and information management systems will change.
2. Feasibility studies - will further consider the implications of the most significant changes to
existing reporting mechanisms and will determine the most practical mechanisms for
implementing the recommendations.
3. Regulatory change tasks - will perform the Rulemaking or ICR Processes required by some
PA A recommendations.
FINAL REPORT PAGE: xi
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EXECUTIVE SUMMARY
4. Implementation projects - will institute the changes as specified by the PSD projects.
PAGE: xii FINAL REPORT
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EXECUTIVE SUMMARY
ID
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Task Name
i) IUK Kenant oystem unanges
PSD
2001 Biennial Report Draft ICR Due
ICR Processes
Implementation
2) Site Verification & TSD Quarterly Report
Feasibility Study - State Lead
Decision/National Review
Site Verification PSD
Site Verification Decision/National Review
Site Verification Rule Making
TSD Quarterly Reporting PSD w/Pilot
TSD Quarterly Reporting Decision/National Review
TSD Quarterly Reporting Rule Making
3) Data Integration Into RCRAInfo
Site Identification Data PSD
1999 Biennial Report Data Received
Site Identification Data Implementation
Waste Activity Data Integration PSD
Waste Activity Data Integration Implementation
4) New Guidance
PSD
Implementation
D
2000
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Figure 2: Schedule of Implementation Projects
FINAL REPORT
PAGE: xiii
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Table of Contents
EXECUTIVE SUMMARY i
REPORT ORGANIZATION 3
GLOSSARY OF TERMS AND ACRONYMS 5
INTRODUCTION 9
PROJECT BACKGROUND 9
UID WAM PROGRAM AREA ANALYSIS PROJECT 9
PROJECT INVOLVEMENT 10
PROJECT SCOPE 12
WIN/INFORMED APPROACH 15
INTRODUCTION 15
PROGRAM AREA ANALYSIS (PAA) 15
PROGRAM SYSTEM DESIGN (PSD) 17
PROGRAM SYSTEM IMPLEMENTATION (PSI) 17
SUMMARY 17
FINDINGS AND RECOMMENDATIONS 19
INTRODUCTION 19
RECOMMENDED INFORMATION NEEDS 20
1) Common organizing framework 20
2) National systems will accommodate both national and shared information needs 21
3) National and shared information needs 21
RECOMMENDED INFORMATION MANAGEMENT IMPROVEMENTS 23
1) Issue guidance on EPA identification number assignment 25
2) Study feasibility of periodic verification ofRCRA Site information 28
3) Track all notifying CESQGs nationally 33
4) Track all emergency and temporary sites nationally 36
5) Track all non-notifiers nationally 39
6) Collect both State and Federal generator status from States 42
7) Merge common elements of current site identification forms 46
8) Add Additional Data Elements to Notification Form 49
9) Provide for standard notification by large quantity handlers of universal wastes 51
10) Remove waste codes from Notification Form 53
11) Study feasibility of quarterly electronic reporting of TSDF waste receipts 55
12) Confidential Business Information (CBI) 62
13) Tracking Hazardous Waste Exports 64
14) Tracking Imports of Hazardous Wastes 66
15) Clarify Types of Hazardous Wastes to be reported 68
16) Streamline Source, Origin, Form, and Management Codes 71
17) Removal of Data Elements from Biennial Reporting forms 79
18) Streamline Unit of Measurement Reporting 83
19) Issue guidance on TSDF nomenclature 85
20) Implement standard definitions for programmatic TSDF universes 88
21) Determine location coordinates for a RCRA Site 91
22) Record historical changes to RCRA Site name, operator name, owner name, and regulated
activity status 93
FINAL REPORT PAGE: 1
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23) Provide an integrated source ofRCRA program information 94
24) Additional Information Collection using the Manifest. 95
25) Make Source Code a National Data Element. 97
CONSOLIDATED OVERVIEW OF THE RECOMMENDATIONS 100
INFORMATION ACCESS CAPABILITIES 104
IMPLEMENTATION PLAN 109
IMPLEMENTATION PLANNING CONSIDERATIONS 109
IMPLEMENTATION PROJECTS 112
IMPLEMENTATION SCHEDULE 117
APPENDICES 121
APPENDIX I: PROGRAM AREA ANALYSIS PROCESS
APPENDIX II: PROGRAM SYSTEM DESIGN TASKS
APPENDIX III: INFORMATION NEED DEFINITIONS
APPENDIX IV: CURRENT SYSTEMS ASSESSMENT
APPENDIX V: TSDF UNIVERSE DEFINITIONS
APPENDIX VI: RELATED INITIATIVE STATUS
APPENDIX VII: SUPPLEMENTARY POLICY PROCEDURAL ISSUES
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REPORT ORGANIZATION
REPORT ORGANIZATION
The remainder of this Final Report is organized into the following sections:
Glossary of Terms
Presents descriptions of a number of acronyms and specific technical and programmatic terms
used throughout this report.
Introduction
Describes the background to the WIN/INFORMED initiative and the combined Universe
Identification and Waste Activity Monitoring Program Area Analysis, including the scope of the
project and the participating organizations.
WIN/INFORMED Approach
Outlines the approach being used to conduct the WIN/INFORMED initiative with specific reference
to the purpose and outputs of the Program Area Analysis phase.
Findings and Recommendations
This section presents the findings from the project's analysis and provides recommendations on
how the existing information collection and management procedures should be improved and
streamlined. This section also describes how access to RCRA program information should be
enhanced to be able to answer the types of questions typically asked by or of program staff.
Implementation Plan
Provides a high-level outline of the system design project that should be undertaken to consider
each of the project's recommendations and which would result in implementation of new system
functionality
Appendices
A number of appendices are attached to this report, which provide supporting materials.
Appendix I: Program Area Analysis Process
Appendix II: Program System Design Tasks
Appendix III: Information Need Definitions
Appendix IV: Current Systems Assessment
Appendix V: TSDF Universe Definitions
Appendix VI: Related Initiative Status
Appendix VII: Supplementary Policy Procedural Issues
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GLOSSARY OF TERMS
GLOSSARY OF TERMS AND ACRONYMS
Glossary of terms
The following terms have been used throughout the report.
Biennial Report
Biennial Reporting Forms
Broader in Scope
Form Elements
Generator
GM Form
Implementer
Information Need
Information system
Key Question
Management Method
More Stringent Than
PAA Participants
Report generated by EPA summarizing data submitted by
respondents to the Hazardous Waste Report (EPA form 8700-
13 A, or State equivalent). The content of this report is used to
summarize and understand waste generation management
activities, as well as for communication to the public.
The Hazardous Waste Report instructions and forms federally
required to be submitted by LQGs and TSDFs every other (odd)
year (i.e., EPA form 8700-13A/B).
Provisions that (1) allow State to regulate more entities or wastes
than the federal code or (2) add an aspect to a state's statute or
regulations for which there is no federal counterpart.
The fields that allow data to be entered on a reporting form.
An abbreviation for Hazardous Waste Generator.
An abbreviation for the Waste Generation and Management
Form of the Biennial Reporting Forms.
The State agency or EPA Region responsible for implementing
the RCRA program in a given state.
A type of information that is required to support programmatic
activities, decisions and analyses. For example, Site name.
A combination of regulations, data collection mechanisms (e.g.
paper forms), computer data systems, and manual procedures
that together support the collection, management and use of
information.
A question that is regularly asked of program staff by external
entities, or asked by program staff to support their programmatic
activities.
Describes the type of system used to treat, store or dispose of
hazardous waste. This term is synonymous with System Type
Code.
State implemented rules that subsume RCRA, but which applies
more stringent regulation to the same population as would be
regulated under Federal authority.
The members of the PAA Team and other knowledgeable staff
from their agencies (that assisted during INA Sessions and draft
report Critical Reviews), and a few other organizations' staff that
also assisted during the Critical Review.
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GLOSSARY OF TERMS
PAA Recommendation
PAA Team
RCRA Site
Region
Regulator
State
Transporter
Waste
WR Form
A proposed improvement to what RCRA information is collected
and the way in which it would best be collected and managed in
the future.
The core team that developed the recommendations and findings
made up of one RCRA program expert from each of a small set
of States, EPA Regions and EPA OSW and OECA.
A specific location that is currently, or has in the past, conducted
waste handling activities of interest to the RCRA Subtitle C
program, as promulgated in either the Federal Register or by
individual State or Territory statutes. The location may be
described by physical address, by description or by geographic
coordinates.
An abbreviation for EPA Region, i.e., one of the ten Regional
offices of EPA.
A State or federal agency that defines or implements rule under
RCRA.
An abbreviation for "State environmental agency".
An abbreviation for Hazardous Waste Transporter.
An abbreviation for Hazardous Waste as defined under RCRA.
An abbreviation for the Waste Received From Off Site Form of
the Biennial Reporting Forms
Acronyms
The following acronyms are used throughout the report.
ASTSWMO
BIF
BIS
BRS
BSD
CEI
CESQG
ESC
EPA
FOIA
GEMS
GPRA
GPS
HSWA
Association of State and Territorial Solid Waste Management
Officials
Boilers and or Industrial Furnaces
Broader In Scope
Biennial Reporting System
Business Systems Design
Compliance and Evaluation Inspection
Conditionally Exempt Small Quantity Generator
Executive Steering Committee
Environmental Protection Agency
Freedom of Information Act
General Enforcement Management System
Government Performance and Review Act
Global Positioning System
Hazardous and Solid Waste Amendments
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GLOSSARY OF TERMS
1C
INA
ISP
LQG
MAD
MST
NAICS
NCAPS
NGA
NPDES
OECA
OSW
PAA
PBT
PE
PMG
PMP
RCRA
RCRIS
SEES
SIC
SQG
TSDF
TUG
UID
USPS
WAM
WIN/INFORMED
Identification and Certification
Information Needs Assessment
Information Strategy Plan
Large Quantity Generator
Method Accuracy Descriptor
More Stringent Than
North American Industrial Classification System
National Corrective Action Prioritization Systems
National Governors Association
National Pollutant Discharge Elimination System
Office of Enforcement and Compliance Assurance
Office of Solid Waste
Program Area Analysis
Persistent, Bioaccumulative and Toxic
Program Evaluation
Project Management Group
Project Management Plan
Resource Conservation and Recovery Act (for this report the
specific reference is to Subtitle C only)
RCRA Information System
State Electronic Commerce/Electronic Data Interchange
(EC/EDI) Steering Committee
Standard Industrial Classification
Small Quantity Generator
Treatment, Storage, or Disposal facility
TSDF Universe Group
Universe Identification PAA Project
United States Postal Service
Waste Activity Monitoring PAA
Waste Information Needs / Information Needs for Making
Environmental Decisions
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GLOSSARY OF TERMS
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INTRODUCTION
INTRODUCTION
Project Background
The WIN/INFORMED initiative was established jointly by the States and the Environmental
Protection Agency (EPA). WIN stands for Waste Information Needs and derives from planning
work undertaken by the EPA. INFORMED stands for Information Needs for Making
Environmental Decisions and derives from State planning work.
The objective of this initiative is to reassess the information needs of the hazardous waste
management program operating under Subtitle C of the Resource Conservation and Recovery Act
(RCRA). With WIN/INFORMED, EPA and States aim to jointly identify, and share where
appropriate, the information needed to manage the RCRA program effectively.
The goal of WIN/INFORMED is to improve the collection, use and management of hazardous
waste information at the national level, to make that information readily available to EPA, States,
Tribes, and the public, and to support the effective implementation of the hazardous waste
program.
To achieve this goal, the WIN/INFORMED initiative has been organized into four discrete phases.
Each phase will consist of a number of inter-dependent projects, structured to allow constant
progress to be made towards the objectives without the risks associated with a very large-scale
redevelopment effort. The four phases are planning, analysis, design, and implementation.
States and EPA conducted separate planning projects to broadly document their own information
needs. Completed in late 1996, these efforts resulted in two Information Strategy Plans (ISPs),
both of which identified priority improvements to be made to the information collection and
management systems used to support program implementation.
An ISP identifies natural groupings of program functions and information needs, which are
referred to as "program areas." The State ISP identified three priority program areas for analysis.
These were Universe Identification (UID), Waste Activity Monitoring (WAM), and Handler
Monitoring and Assistance. These areas all address program implementation activities. The EPA
ISP identified the Permitting and Corrective Action program area, which addresses
implementation activities, and the Program Evaluation program area. States and EPA agreed to
form a partnership to conduct the remaining phases of these five program areas beginning with
the analysis of each program area. Analysis of the Program Evaluation program area was
completed early in 1999.
UID WAM Program Area Analysis Project
The UID Program Area Analysis (PAA) began in October 1998 and the project's preliminary
findings and recommendations were presented for review by selected program experts during
March 1999. The development of clear definitions for certain programmatic universes of RCRA
Sites was considered to be part of the scope of the UID program area. A small sub-group from the
PAA Team was formed to review the existing programmatic universes and to develop a draft set
of revised universe definitions based on current program priorities and known concerns with the
current definitions.
In January 1999, the WIN/INFORMED Executive Steering Committee asked the UID PAA Team
to begin the analysis of the WAM program area in parallel to the analysis of the UID program
area. This strategy was designed to realize significant time and cost savings by conducting the
FINAL REPORT PAGE: 9
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INTRODUCTION
national review and later systems implementation planning stages of these closely related projects
at the same time.
Analysis of the WAM program area began in February 1999 with the project's preliminary
findings and recommendations for this program area presented for review by selected program
experts during June 1999. Following the completion of this review, the UID and WAM analysis
projects were combined.
Having been reviewed, the preliminary findings and recommendations from both projects were
refined and then presented in the form of a Draft Report for national review by all States,
Territories, EPA Regional Offices and the EPA Offices of Solid Waste and Enforcement and
Compliance Assistance. Following this national review, which took place during September and
October of 1999, the project findings were updated to reflect input from reviewers. A plan was
also developed to guide the design and implementation of the recommendations from the project.
This Final Report presents the PAA project's confirmed recommendations for future RCRA
program information management, together with an implementation plan.
The following table summarizes the key milestones for the combined UID and WAM project.
Milestone Date
UID Project start 8/31/98
UID INA Sessions 10/12/98 - 12/4/98
UID Critical Review 3/1/99 - 4/2/99
WAM Project start 1/4/99
WAM INA Sessions 3/15/99 - 4/15/99
WAM Critical Review 6114/99 - 7/9/99
Present draft final report to ESC 8/16/99
National Review 9/6/99 - 10/29/99
Present Final Report to ESC 12/9/99
Release Final Report 1/28/99
Project Involvement
A fundamental element of the WIN/INFORMED initiative is the regular and timely involvement of
a wide range of stakeholders. Each WIN/INFORMED project is directed by a PAA Team consisting
of program staff from States, EPA Headquarters Program Offices and EPA Regional Offices,
who participate directly in the projects, providing practical experience with the implementation of
the RCRA program in their organizations.
The PAA Team responsible for directing this PAA project and for developing this Final Report
included the following organizations:
State of Kansas (UID program area)
State of Michigan (WAM program area)
State of New Hampshire
State of New York
State of North Carolina
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INTRODUCTION
State of South Carolina
State of Utah
EPA Region V
EPA Region VII
EPA Office of Solid Waste
EPA Office of Enforcement and Compliance Assurance
Representatives from each of these organizations participated in the project, with the project
being led jointly by Bud McCarty from the State of North Carolina and Les Otte from the EPA
Office of Solid Waste.
Additional feedback was provided by the States of Kansas, Ohio, Maryland, Texas, EPA Region
6, and the Facility Data Standards workgroup during earlier critical reviews of the PAA findings.
Cross-project management and communication was provided by a Coordinating Committee
which helped to establish schedules and milestones, manage resources, and coordinates the
various PAA teams. Representatives are again drawn from both State and EPA organizations.
High-level direction and policy-making support was provided to the project by an Executive
Steering Committee that includes representatives from senior EPA and State management.
Figure 3 illustrates the project organization.
Executive Steering Committee
Mike Savage
Catherine Sharp
Mike Bussell
Elizabeth Cotsworth
Mike Stalh
Mark Day
OH
OK
Region 10
OSW
OECA
OIRM
Coordinating Committee
Allan Tinsley
Rusty Lundberg
Matt Loesel
Kevin Phelps
Sara Rasmussen
David Meredith
Sue Parker
Scott Latham
SC
UT
Region 6
OSW
OSW
OECA
OSW
OSW
Windsor Solutions
Guy Outred
Kevin Jeffery
Norman Read
Steve Rosen berger
UID / WAM PAA Team
Bud McCarty
Les Otte
Allan Tinsley
Debbie Goodwin
Harriett Jones
Jane Ratcliffe
John Mitchell
Leslie Brennan
Rusty Lundberg
Karen Way
Walt Derieux
Dave Levy
Beverly Allen
Elizabeth Bols
Mike Hillard
NC (State Lead)
OSW (EPA Lead)
SC
OECA
Region 7
Region 5
KS
NY
UT
NH
OECA
OSW
OSW
Ml
OSW
PAA Project
Management Group
Allan Tinsley
Bud McCarty
Les Otte
Sue Parker
Scott Latham
SC
NC
OSW
OSW
OSW
Figure 3: Project Organization Chart
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INTRODUCTION
Project Scope
The goal of this PAA project was to examine the information needs of the UID and WAM
program areas, and to consider how current information collection and management procedures
meet those needs. The project then sets out to recommend improvements for specific areas where
existing procedures do not meet current or anticipated information needs.
RCRA Implementation
Universe Identification
1
1
RCRA Site Identification J
RCRA Site Activity Identification 1
)
[Waste Activity Monitoring
Waste Generation Monitoring
Waste Management Monitoring
^Handler Monitoring and Assistance
^Permitting and Corrective Action
t etc.
Figure 4: UID/WAM Functional Scope
The scope of the UID and WAM program areas was broadly defined during the States' ISP. This
is illustrated in Figure 4: UID/WAM Functional Scope, with the shaded area encompassing the
scope of these two program areas.
Using this broad outline, the PAA Team defined this scope more explicitly using the following
three dimensions:
the information needed to support these program areas
the collection mechanisms used to gather this information
the specific policy and procedure issues that pertain to the information collection and
management procedures
Care was taken during the scope refinement stage of the project to ensure that the project scope
was kept straightforward, setting realistic goals for the resources and budgets available to the
PAA Team. In some cases, information needs, collection mechanisms and issues were excluded
from the combined project scope to be addressed as part of separate initiatives at a later time.
The following paragraphs outline the scope of the project that was used by the PAA Team when
developing the findings documented in this Final Report.
Information Needs
The PAA Team focused on the following areas of information needed to support the UID and
WAM program areas. Examples of some of the needs are provided here. A more detailed
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INTRODUCTION
discussion of the specific information needs may be found in the Findings and Recommendations
section of this Final Report.
Site Identification EPA identification number, mailing address, location coordinates.
Site Activities generator status, used oil activities, industry type.
Site Contacts owner name, site contact name.
Waste Generation waste codes, quantity, generating process.
Waste Shipment shipment date, border crossing, manifest number.
Waste Receipt waste codes, transporter EPA identification number.
Waste Management waste description, management method.
A number of needs were identified by the team during the information gathering phase of the
project that are required by individual organizations to implement the RCRA program. These
needs, while important to the specific organization, have been excluded from the PAA project
recommendations included in this Final Report. This report focuses instead only on the national
and shared RCRA program needs.
Data Collection Mechanisms
The project scope included the following data collection mechanisms for universe identification
and waste activity information. It should be noted that many of these mechanisms collect or
update additional information that is outside of the scope of either the UID or WAM program
areas. These will be further detailed during subsequent analysis efforts, for example, the "Part A
Application" gathers various permitted unit information and will be further evaluated as part of
the Permitting and Corrective Action PAA.
Notification forms
Part A Applications
Periodic Waste Activity Reports (i.e., Biennial Reporting forms and other State
derivatives)
Export Reports
Manifests
Transporter Permit Applications
Emergency Site Notification
Policy / Procedural Issues
During the initial information gathering phases for the UID and WAM program areas, and
throughout the combined project, a number of important policy and procedural issues were
identified that impact information collection and use within the program areas. The PAA project
developed resolutions for many of these issues which have been incorporated into the
recommendations presented in this Final Report.
A number of issues were excluded from consideration during the PAA project for one or more of
the following reasons:
1. Resolution of the issue was not believed to be critical to the success of the PAA project.
2. The issue is specific to a small number of organizations and is not considered significant for
national resolution.
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INTRODUCTION
3. The issue will affect design and/or implementation of the project's recommendations but does
not have a bearing on information needs and management.
These excluded issues are detailed in Appendix VII.
Related Initiatives
Finally, during the course of the project, the PAA team identified and tracked a number of
initiatives related to the UID and WAM program areas being undertaken by EPA and States
under various frameworks. The impact of these initiatives on the combined project was assessed
and the project's recommendations address these impacts as appropriate. A full listing of the
initiatives tracked by the PAA Team may be found in Appendix VI.
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WIN/INFORMED APPROACH
WIN/INFORMED APPROACH
Introduction
The WIN/INFORMED initiative is employing a structured approach called the Information
Engineering Methodology (IBM) to analyze, design and implement information management
systems to support the RCRA program. This full life-cycle methodology is well suited to the
development of complex, enterprise-wide information systems, particularly those that require a high
degree of data sharing.
Implementation of the RCRA program is complex requiring multiple organizations to share large
amounts of information. By applying IBM principles to break down the complexity of the entire
RCRA program into a number of discrete "program areas", the WIN/INFORMED initiative is able
to focus attention and resources effectively.
As discussed briefly in the Introduction section of this Final Report, the first IBM phase,
Information Strategy Planning defined the program areas that make up the RCRA program and
provided a logical order in which they should be addressed. The remainder of this section
describes the three subsequent phases of the IBM that must be conducted for each program area to
realize the WIN/INFORMED goal of improved information management.
Program Area Analysis (PAA) Understand the program's needs for information,
consider how well those needs are supported by existing
systems, and identify improvements.
Program System Design (PSD) Describe how the existing systems should change to
effect the improvements. Provide an understanding of
the costs and effort involved in implementing program
changes.
Program System Implementation (PSI) Implement the necessary changes to the current
information management environment, including
automated and manual procedure improvements.
Figure 5: The Phases of WIN/Informed Projects on the following page, shows how these three
phases interrelate for a given program area. The rounded boxes represent the three sequential
phases. The core deliverables are described for each phase, and are shown being passed between
the phases, illustrating the progressive detailing of the program area as initial findings lead to
implementation of real information management changes. The final deliverable, a new or
modified information management system, is represented at the bottom right corner of the
diagram.
National consensus on the findings of each phase is sought before the next phase begins.
Program Area Analysis (PAA)
This phase of the IBM results in an analytical assessment of the program's needs for information
management and a set of general recommendations for both data management and process
improvements. This is achieved by identifying program needs for information management, and
comparing those needs to the support provided by the current systems. This comparison helps to
identify which needs are currently poorly supported and allows recommendations to be developed
to improve this support.
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WIN/INFORMED APPROACH
Program
Area
Analysis
""" V
Confirmed
recommendations for:
- Information Needs
- Improving data mgmt.
Technical Deliverables
- Data model
- Process model
7
Program
System
Design
WHAT
the program needs
to be supported
Confirmed
specifications for
changes to:
- Regulations
- Data collection forms
- Database systems
- Manual procedures
Implementation Pla
HOW
the program should
be supported
n.
Program needs
supported by new
system
environment
Program
System
Implementation
New / modified:
- Regulations
- Data collection forms
- Database systems
- Manual procedures
National consensus
National consensus
Figure 5: The Phases of WIN/Informed Projects
The products of a PAA include a set of nationally confirmed recommendations, together with a
set of technical deliverables that provide a conceptual model of the program information
management needs..
The project recommendations are presented towards the end of the PAA project allowing for
national consensus with respect to:
the program needs
the problems with the existing systems
the envisioned improvements (e.g., recommendations)
Although the implications of the recommendations for change are understood only at a high level
at the end of the PAA, they should provide an indication of the likely effects of such change. This
allows reviewers to determine whether or not each recommendation should be considered further
during the subsequent design phase.
Following the national review of the findings and recommendations of the PAA, the PAA Team
organizes the recommendations into logical groups based on their priorities and dependencies.
The WIN/INFORMED Coordinating Committee and Executive Steering Committee reviews these
groups with consideration given to funding and other resource constraints before determining
which groups should be further evaluated in the next phase, Program System Design.
A more detailed description of the tasks that make up this phase can be found in Appendix I.
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WIN/INFORMED APPROACH
Program System Design (PSD)
This phase is concerned first with determining the feasibility of the recommendations from the
PAA, and then developing detailed plans and specifications needed to implement the necessary
changes to national information systems. Using techniques such as prototyping, the PSD project
evaluates the specific implications of each PAA recommendation. By exploring these
implications in greater detail, the PSD project may identify complexities that were not identified
during the PAA.
This "reality check" may require some of the PAA recommendations to be modified or even
deferred for future consideration. For example, costs, complexity and appropriateness of the
recommendation will be considered in the light of current program operating constraints.
A PSD project results in a nationally confirmed "blueprint" for implementation, including
designed data collection form changes, new system functionality and/or existing system change
specifications, and an implementation plan with resource estimates.
A more detailed description of the tasks that make up this phase can be found in Appendix II.
Program System Implementation (PSI)
This final phase in the WIN/INFORMED application of the IBM uses the specifications developed
during the previous phase to build new system functionality or modify existing systems. The PSI
project will result in actual changes to the existing systems environment, including database
systems, data collection forms, manual procedures and, if necessary, regulations.
Summary
The IBM provides a framework for information systems development that allows improvements
to be made incrementally and the project to be undertaken in discrete manageable steps. This
framework allows a complete picture of the information systems needs to be built from high-level
business requirements to specific implementation details.
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WIN/INFORMED APPROACH
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FINDINGS AND RECOMMENDATIONS
FINDINGS AND RECOMMENDATIONS
Introduction
As stated previously, the goal of the PAA project is to conduct a fundamental reappraisal of
information collection and management procedures needed to support the program. This includes
consideration of three components:
the types of information needed to effectively implement the program,
the activities required to collect that information, and,
the capabilities required to access the information.
Draft recommendations were developed for the combined UID and WAM program area
addressing each of these three components. Following a national review of these draft
recommendations the PAA Team made a number of changes and clarifications resulting in a set
of confirmed recommendations. A confirmed recommendation, therefore:
1. Is an improvement to the management of RCRA program information that is believed to be
the most effective way of adequately supporting critical program needs.
2. Appears to have no major implementation obstacles.
3. Has been subjected to a national consensus review.
This section of the Final Report presents the confirmed recommendations from the PAA project.
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FINDINGS AND RECOMMENDATIONS
Recommended Information Needs
An important goal of the WIN/INFORMED initiative is to identify those information needs that
must be collected and made available to all program staff to support the implementation of the
RCRA program. The following recommendations are proposed with respect to RCRA program
information needs.
1) Common organizing framework
Many of the concerns expressed by PAA participants with respect to current RCRA program
information can be attributed to varying interpretations of that information and poor current data
quality. Before attempting to resolve these problems the PAA Team first agreed upon a common
framework to organize the information needs. This framework is outlined in Table 3.
NATIONAL INFORMATION
SHARED INFORMATION
Has a common, precise definition (i.e., always means the same thing)2
Has mandatory creation or collection3
Is maintained to a specified level of quality and
currency4
Relies on Federal rule to support the authority for its
collection5
Is always accessible to all regulators from national
data systems 6
Is optionally created or collected
May be collected in many different ways and is not
always current or fully qualified
Does not depend on Federal authority for its
collection
Is only submitted to national data systems at the
discretion of the implementer.
Table 3: Definition and Principles of National and Shared Information
In the past, the existing RCRA information systems have referred to data elements as "core" or
"non-core" to indicate similar concepts to those described in Table 3. These terms have been
intentionally excluded from this Final Report in an attempt to avoid some of the confusion and
misinterpretation that many PAA participants have experienced with their use.
2 Implementers, particularly the States, value the ability provided by the RCRA statute to tailor their programs to fit
their own needs and situations. On the other hand, information systems are by definition highly structured and rigid
and must remain so if their data content is to be shared by all implementers. As a consequence, even careful definitions
may limit flexibility. At a minimum, some implementers may be unable to track certain information in national
systems, because their business definition of that data does not conform to the national definitions. Implementers will
thus be faced with the difficult choice of tracking the information in some other way, or changing their own program
practices. Where a common, precise definition cannot be agreed, information cannot be either national or shared.
National information must be tracked except where the implementer is not authorized for that aspect of the RCRA
program; i.e., some national information will remain essentially voluntary, either on the part of the implementer (as in
the case of the Universal Waste rules) or the affected entity (as in the case of CESQGs).
4 Putting in place standards for data currency and quality will enable useful sharing, but requires additional attention
from all implementers.
5 This is true for all national information needs that are collected from the regulated community, however, a Federal
rule is not required in cases where the information is identified directly by the program (e.g., RCRA Site discovery
date, location coordinates, notification date).
As implementers begin to share information, certain standards for use and dissemination must be defined to prevent
misunderstanding, especially if the data is to be made publicly available.
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FINDINGS AND RECOMMENDATIONS
2) National systems will accommodate both national and shared
information needs
Capabilities will be provided in national implementer systems to support the tracking of both
national and shared information needs. This will enable implementers that do not have their own
information systems to track and share all important information with other RCRA program staff
whether that information is needed by the entire program or a smaller subset of the implementer
community.
It is important to note, however, that shared information will, by definition, represent only a
partial set of implementers and therefore provides an incomplete picture. Care must be used
when interpreting shared information. To avoid potential confusion, the appropriate meta-data
must be provided to ensure that program users are aware of the level of completeness for shared
information needs and that a consistent level of data quality cannot be assured.
National Review Feedback
Most States and Regions currently collect some of the information needs designated as shared
needs and would be able and willing to share this information with other implementers.
3) National and shared information needs
The PAA Team employed this framework to organize the information needs of the UID and
WAM program areas into four main categories. Table 4 on the following page lists these
information needs according to the above framework and these four categories.
The following points should be considered when reviewing this table:
Certain information needs are represented in italicized font in the table. These information
needs are all related to the Permitting and Corrective Action program area and include TSDF
management system units. These were not considered by the PAA Team to be part of the
scope of the UID or WAM PAAs but were captured to provide support for some of the
recommended improvements.
The UID information needs listed have been reconciled with the national "Facility Data
Standards" guide recently developed jointly by EPA and States. This will facilitate future
cross-media data sharing by the RCRA program.
The national information needs for the Waste Generation, Shipment, Receipt, and
Management information need category are only "national" for TSDFs and LQGs. For all
other types of RCRA Sites these information needs are "shared".
Definitions for each of the information needs in Table 4 can be found in Appendix III.
National Review Feedback
During the National Review of the Draft Report from this project, States and Regions were asked
to comment on the set of needs defined by the PAA Team in Table 4. These comments were
reviewed and evaluated by the PAA Team who subsequently made a number of revisions to the
sets of information needs which are presented in Table 4.
The PAA team acknowledged that some of the data elements targeted for removal from forms
may continue to be collected by implementing agencies. As a result several of these information
needs were designated as shared needs, to provide a means to store this data for those who choose
to do so.
FINAL REPORT PAGE: 21
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FINDINGS AND RECOMMENDATIONS
PROGRAM
AREA
INFORMATION
NEED
CATEGORY
NATIONAL
INFORMATION
NEEDS
SHARED
INFORMATION
NEEDS
Universe Identification
RCRA Site
Identification
EPA identification number
Facility registry identifier
Site name
Location address (i.e., street
address, locality, ZIP, state)
Location county
Location coordinates
Location MAD codes
NAICS code
Discovery date
Notification date
Exempt from notification
Emergency site
Land owner type
Mailing address
Number of employees
State identifier
Site legal name
RCRA Site
Responsibility and
Contacts
Owner name
Owner type
Operator name
Operator type
Site contact name
Site contact phone
D&B number
Site contact address
RCRA Site
Activity
State generator status
Federal generator status
Hazardous waste transporter
Hazardous waste fuel marketer
Underground injection
Used oil transfer station
Used oil burners
Used oil processor
Used oil refiner
Used oil marketer
Used oil transporter
Universal waste handler
Hazardous waste import agent
Mixed radioactive waste handler
GPRA corrective action universe
GPRA operating permit universe
GPRA post closure universe
Annual BOY enforcement universe
TSDF unit type
TSDF unit commercial type
TSDF unit operating status
TSDF unit legal status
Hazardous waste recycler
Hazardous waste transfer station
Waste codes
TSDF unit location
Waste Activity Monitoring
Waste generation,
shipment, receipt, and
management
Originating EPA ID
Destination EPA ID
Federal waste codes
State waste codes
Quantity
Unit of measure
Management method
Source of waste
Destination country
Originating country
Waste form
Mixed radioactive waste
Waste description
Transporter EPA ID
Shipped date
Received date
Manifest number
Foreign recipient
Border crossing
Table 4 : Program Information Needs
PAGE: 22
FINAL REPORT
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FINDINGS AND RECOMMENDATIONS
Recommended Information Management Improvements
Introduction
The PAA project seeks to contrast the program's information needs with the support provided by
existing information systems. Where the existing systems were found to inadequately support the
needs, a "policy/procedural issue" was identified. The PAA Team considered each of these
policy/procedural issues, and the alternatives for how they might be resolved. This section
provides a discussion of the improvements that the PAA Team has proposed to resolve these
issues.
For some issues, the PAA Team concluded that the current practice represented the most
workable solutions to the given problem. In other cases, issues were not considered due to time,
budget and/or scope constraints on the project. Both of these type of issues are listed in Appendix
VII.
Figure 6: Recommended Improvements to Current Information on the following page is intended
to place each of the PAA project's recommendations in the overall context of the information
collection process employed by the RCRA program. The figure describes a simplified picture of
the main mechanisms currently used for collecting UID and WAM information. For a more
complete description of these mechanisms please refer to Appendix IV. Each of the PAA
project's recommendations has been superimposed upon the diagram, and has been placed
relative to the area of the current system where a change is being recommended.
Each recommendation has been documented as follows:
Summary provides the major elements of the recommendation.
Program Need describes the underlying RCRA program needs that the
recommendation addresses.
Problem Analysis describes why the program need is not currently being supported
by the existing systems.
Recommendation describes the PAA Team's recommendation of how the current
situation should change to better support the program need.
Design Considerations describes the anticipated benefits, concerns, and likely steps
required to implement the recommendation. These implications
will be further evaluated during the PSD phase subsequent to
PAA.
Other Options Considered lists the alternative options that were considered during the PAA
to resolve the issue.
Dependencies describe how implementation of the recommendation is reliant
upon the implementation of other specified PAA
recommendations.
National Review Feedback summarizes any key observations or corrections proposed by
reviewers of the Draft Report recommendations.
The recommendations that follow are ordered based generally on their appearance in the
following figure. No specific importance or priority should be inferred from this ordering.
FINAL REPORT PAGE: 23
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FINDINGS AND RECOMMENDATIONS
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Figure 6: Recommended Improvements to Current Information
PAGE: 24
FINAL REPORT
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FINDINGS AND RECOMMENDATIONS
1) Issue guidance on EPA identification number assignment
Summary
Combine and make available all current guidance indicating that as a general rule, a single EPA
identification number will be assigned to a specific RCRA Site and retained regardless of changes
in ownership or activity.
Program Need
RCRA regulations require persons handling hazardous waste to submit EPA Form 8700-12 or a
State equivalent to obtain an EPA identification number. The implementing agency then assigns
an EPA identification number to the applicant (i.e., technically, the owner or operator; owner is
used below to mean both). This number is then used to consistently identify an individual
RCRA Site.
EPA's Office of Solid Waste has published a number of memos and letters to facilities detailing
how EPA identification numbers should be assigned. The general understanding among State and
EPA program staff is that for any given location, only one EPA identification number should be
issued. However, EPA has not issued comprehensive guidance on this issue and the basis for the
policy is not stated in Federal regulation.
Effective data sharing requires a consistent national practice with respect to the assignment of
EPA identification numbers to RCRA Sites.
Problem Analysis
Existing documentation covering EPA identification number assignment is not currently
compiled into a clear accessible format for implementers' reference. EPA identification numbers
have generally been assigned to a specific RCRA Site location with the intention that this number
should not change over time. Not having clear guidance has resulted in inconsistent assignment
of identification numbers for the same RCRA Site. For example some companies request that the
implementer assign a new EPA identification number when they take over an existing RCRA
Site, to avoid association with the previous owner's environmental record. As a result of this,
companies that have taken ownership of an existing RCRA Site have complained that EPA's
Envirofacts system (or other reports) includes the prior owner's compliance record.
Documentation that is available has not addressed the many practical situations that may require
the implementing agency to assign a new EPA identification number. Some examples of these
are:
When a RCRA Site splits or combines property (potentially along with a change of
ownership).
For closed military bases, the Department of Defense requires new owners of parcels to
obtain new EPA identification numbers. In many cases the old EPA identification number is
still used by Department of Defense for areas that are being cleaned up.
Recommendation
For the purposes of the RCRA program, a RCRA Site is identified as a specific location which is
currently, or has in the past, conducted waste handling activities of interest to the RCRA Subtitle
C program, as promulgated in either the Federal Register or individual State statutes. The
location may be described by a physical address, and/or by description, and/or by geographic
coordinates.
FINAL REPORT PAGE: 25
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FINDINGS AND RECOMMENDATIONS
All current guidance related to the assignment of EPA identification numbers is to be compiled
and distributed. The guidance will indicate that as a general rule, a single EPA identification
number should be assigned to a location for all situations. This number would be retained even
under the following situations:
A new party acquires the property or operation of the site.
A new name is adopted for the site.
The owner adds new hazardous waste activities at the location (e.g., a generator begins to
also treat hazardous waste).
The owner begins new hazardous wastes activities that require updating the information (e.g.,
the owner begins to generate universal waste).
The location address information - not the physical site location - is changed (e.g., a rural
route becomes a named road or the site "front door" is moved from one bordering street to
another street).
Specific examples of instances when this general rule cannot be applied will be considered during
the design of this recommendation and will be documented in the guidance. Some examples of
such instances are:
Other federal agencies privatize and subdivide a site (e.g., Department of Energy)
Vendor A is responsible for a spill at Customer B's site that has a valid EPA identification
number. Vendor A is responsible for the clean-up at site B and requires a new EPA
identification number for the clean-up site, distinct from Customer B's number.
RCRA Site goes out of business. The site is then subdivided into several smaller units some
with their own RCRA regulated activities, necessitating assignment of additional EPA
identification numbers
A business wants to split an existing RCRA Site into multiple subsidiaries. The parent
corporation maintains ownership, but the subsidiaries are the operators.
Airports have multiple airlines and service companies that lease property from the airport.
The portion of the airport used by leasing the company may expand or contract or move.
A TSDF has been designated clean closed but not gone through corrective action. The
property is then subdivided and sold into smaller units. The original EPA identification
number is maintained for the entire site for future potential corrective action, but each of the
smaller units are assigned their own EPA identification number.
Adjacent properties, each with their own identification number and businesses, merge
operations.
Design Considerations
1) National systems must be able to associate multiple EPA identification numbers to a RCRA
Site to cater to the exceptional circumstances.
2) Allowances must be made during design for those existing RCRA Sites and associated EPA
identification numbers that are not compliant with the guidance.
3) Systems that provide public access to RCRA Site information must be evaluated and
potentially redeveloped to ensure that they correctly present historical information about EPA
identification number. For example, the systems would need to indicate that data on previous
PAGE: 26 FINAL REPORT
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FINDINGS AND RECOMMENDATIONS
compliance problems at a RCRA Site is not associated to the current owner/operator, even
though they share the same EPA identification number.
Other Options Considered
1) Only assign an EPA identification number once for a location in all situations. Require new
owners to use this number.
2) Always assign a new EPA identification number to a location when there is a new owner of
the property. Relate to the previous EPA identification number information to allow
assessment of a site's history.
Dependencies
22) Record historical changes to RCRA Site name, operator name, owner name, and
regulated activity status
This is a partial dependency.
This will support the need to track changes in the name and ownership of the RCRA Site over
time, such that new EPA identification numbers will not be required each time a change occurs.
FINAL REPORT PAGE: 27
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FINDINGS AND RECOMMENDATIONS
2) Study feasibility of periodic verification of RCRA Site information
Summary
Study the feasibility of instituting some form of verification of basic site identification
information from RCRA regulated sites having a valid assigned EPA identification number. The
study would include an assessment of both mandatory or optional verification as well as
considering the appropriate frequency for the verification process and the most practical
universe(s) of RCRA regulated sites that should be included. The most appropriate mechanism
for verification would also be evaluated, for example, the use of forms pre-populated with
available information about the RCRA site.
Program Need
The notification process is the initial means for identifying hazardous waste sites under the
RCRA program. Currently, there is no formal or Federally mandated process to verify or update
the notification information collected by EPA or the States from RCRA Sites.
To have a meaningful picture of the regulated universe, implementers must be able to distinguish
between active and inactive RCRA Sites. There is a need to know when a RCRA Site no longer
conducts any RCRA-regulated activities and is not of active interest to an implementer, except
historically.
Accurate information about the universe of all RCRA regulated sites, including SQGs and others
having a valid EPA identification number, supports the following RCRA program activities:
resource allocation and planning
planning and targeting for inspections and technical assistance
national program planning and reporting
respond to public information requests
regulatory impact analysis
environmental justice analysis
waste minimization
assessing program effectiveness (EPA)
grant distribution (EPA)
support of fee collection mechanisms (States)
Problem Analysis
At the inception of the RCRA program, hazardous waste handlers were required to initially notify
the EPA by completing and submitting a "Notification of Hazardous Waste Activity" form. Most
RCRA Sites submitted the Notification form because they actually generated, transported, and/or
managed hazardous waste and were subject to regulation.
Once a RCRA Site submits a Notification form, there is no Federal regulation requiring the
RCRA Site to inform the implementer of any changed information. For example, if their
generator status changes from large quantity to small quantity or the RCRA Site is no longer
handling hazardous waste or changes the types of waste being generated. When RCRA Sites
cease operation, or stop generating hazardous waste, they can be considered inactive. Some
PAGE: 28 FINAL REPORT
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FINDINGS AND RECOMMENDATIONS
current methods used to determine activity are periodic reporting, site visits, bankruptcy notices,
or returned mail.
Given this lack of regular update, the site information available to the RCRA program can
quickly become outdated and inaccurate for one or more of the following reasons:
For RCRA Sites that do not file Biennial Reporting forms or State equivalents (typically
SQGs, transporters, some used oil handlers, and universal waste handlers), much of the
notification data is very old, some of it based on the initial 1980 notifications.
Some information, such as the RCRA Site's contact person or generator status, may change
frequently.
When a RCRA Site goes out of business it is likely that the State or EPA will not be informed
unless a new owner notifies.
The information collected in the Federal Biennial Reporting forms is used by only some
States to update the associated data recorded in RCRIS.
The lack of capabilities in RCRIS and BRS for easy access to data, have led to minimal
maintenance of that information by users and collectors of the data.
Some businesses, unfamiliar with the new hazardous waste regulations, notified EPA during
the early years of the program despite being uncertain whether they were actually required to
do so. This is referred to as "protective filing" meaning they were protecting themselves
from possibly being in violation of the notification requirement even if they were not actually
legally subject to it.
CESQGs are not required to notify, but may if they wish to. Many commercial TSDFs
require CESQGs to have a valid EPA identification number assigned before they will receive
their hazardous waste. Most States do not require any periodic verification of CESQGs
identification data.
Some States have taken this issue in hand by implementing a periodic verification process to
improve data quality. Benchmarking of existing implementations of this recommendation by the
States of Indiana and Oregon provided the following information:
INDIANA
OREGON
perform verification biennially to LQGs and
variably to SQGs
1000 LQGs regularly sent verification forms
response rate from regulated community is
good
70% to 80% of returns include some
modification to handler details
80 hours for State to prepare and send forms
100 hours for State to process modifications
estimated completion time is 10 minutes per
facility
no negative feedback from regulated community
perform verification annually to all registered
LQGs, SQGs and CESQGs
240 LQGs, 560 SQGs and 3000 CESQGs are
sent verification forms
viewed favorably by regulated community
40 hours for State to prepare and send forms
320 hours for State to process modifications
estimated completion time is 10 minutes per
facility
FINAL REPORT
PAGE: 29
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FINDINGS AND RECOMMENDATIONS
A limited survey was conducted of 11 States to evaluate the current business practice with respect
to verification.
Survey Results
3 of 11 survey respondents perform some type of systematic annual verification process.
Of these 3 States, 2 include SQGs in the verification and all use some form of pre-populated form.
Where States employ such a process, 2 of 3 have a mandatory requirement while the third allows
response to be optional but typically experiences a 90% response rate from the regulated universe.
Where no such process is employed, States rely instead on other information sources such as
inspections and waste reports.
Where States currently perform periodic verification this is often associated to regular reporting
of waste information and as such most often focuses only on LQGs and TSDFs, although several
States also collect SQG information. Many States conduct such verification to improve RCRA
Site data quality specifically to support revenue generation activities. This provides a greater
incentive for both RCRA Site and State to have good quality data, and results in varying data
collection/quality across States with different fee structures and invoicing periods.
Implementation of such verification procedures, while clearly resulting in improved data quality,
also imposes some additional reporting burden on the regulated community and on the
responsible organization.
Recommendation
Some form of periodic verification of notification data should be implemented. A design study
should be undertaken to consider how best to perform this verification with a focus on
determining the optimum balance between improved data quality and the associated data
collection burden. The study will include an assessment of the feasibility of various approaches,
an initial cost-benefit analysis and more detailed benchmarking. It will result in a recommended
approach for detailed design consideration.
This study will consider four main factors:
Nature of requirement
The study will consider whether RCRA Sites should be required to re-verify their information or
whether this should be optional. Although it is generally assumed that a mandatory requirement
would result in greater level of response from the regulated community, the potential burden
increase for the regulated community is a cause for concern, especially for the EPA. Some States
have indicated that a voluntary approach may require greater effort on the part of these agencies
to obtain a good level of response through follow up with RCRA Sites, for example, a site visit or
further correspondence. Other organizations might be unable to implement such a procedure
unless it is required by some Federal rule due to State regulatory restrictions. An alternative
option would be to mandate re-verification but only if a change has been made to the basic site
information.
Universe of regulated RCRA sites to be targeted
PAA participants commented generally on the poor quality of information about RCRA Sites in
national and organization specific systems, although this problem is generally felt to be more
acute for smaller, less closely regulated sites. The study will consider which universe of RCRA
Sites should be subject to verification procedures. At one extreme, verification might be required
for all regulated RCRA Sites having a valid EPA identification number including TSDFs, LQGs,
SQGs, transporters and any CESQGs, used oil handlers, or universal waste handlers that have
PAGE: 30 FINAL REPORT
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FINDINGS AND RECOMMENDATIONS
previously notified. Alternatively, the requirement could be simply for LQGs and TSDFs, the
biennial reporting universe, to verify basic site information at the same time as they submit the
waste report. Clearly, the wider the universe of RCRA Sites who are subject to verification, the
wider and therefore greater will be the impact on the regulated community and on the net
additional burden.
Frequency of verification process
The study will also consider the frequency at which the verification process should occur. Most
States who currently implement some form of periodic verification do so in association with their
existing waste reporting cycle, for example, annually or biennially. This approach offers several
advantages by streamlining the information collection process. When determining the ideal
frequency for verification of site information, the study will consider the reporting burden
imposed on the regulated community and the administrative burden to be borne by the
implementing agency.
Reporting mechanism
One possible mechanism for verification would be to use a pre-populated copy of a RCRA Site
Identification form containing the most recent identification information available that would be
sent to the relevant RCRA Sites for verification and return. This form will include information
such as the last reported name, owner, hazardous waste activity and so on.
The RCRA Site would mark up any changes in the information, sign it to certify its accuracy, and
return it to the implementing agency. This option provides a consistent, minimum level of
exchange that States and EPA can readily utilize.
Other possible mechanisms will also be considered such as electronic verification using the
Internet, or simple resubmission by the RCRA Site of a new RCRA Site Identification form within
a certain period, for example, 90 days from the date of any change to the information.
The design study will also quantify the effort required for different methods, taking account of
such factors as mass mailings, data entry costs, follow up costs and how returned or non-
responsive mailings might be handled.
Design Considerations
1) Federal regulatory change required supporting the biennial verification process.
2) Functionality would need to be developed in the national information system to produce the
pre-populated verification forms.
3) There will be some increase in reporting burden for the regulated community, primarily for
those RCRA Sites not currently required to submit biennial waste reports. Preliminary
benchmarking and survey results appear to indicate that this burden is not great, amounting to
less than 15 minutes completion time per RCRA Site (see above). A more accurate
assessment will be made during the design project.
4) Some additional burden on States to implement.
Other Options Considered
While this recommendation will result in some additional burden to be assumed by both the
regulated community and implementers, the resulting improvements in data quality and
completeness are likely to result in a net reduction in burden over time. The following options
were also considered:
FINAL REPORT PAGE: 31
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FINDINGS AND RECOMMENDATIONS
1) Collect information from TSDFs only. Remove any requirement for generators to provide
such information directly.
2) Eliminate the requirement for SQGs to notify or report at all.
3) Use inspections, compliance assistance visits, and other means to verify or update
notification information.
Dependencies
7) Merge common elements of site identification forms
This is a critical dependency.
If a common site identification form were not developed, the effort required to gather verification
information would be complicated by the multiple forms from which the information originates.
Regardless of the frequency or targeted universe for verification, a single reporting form would
greatly improve and simplify the reporting process.
23) Merge existing duplicate site data
This is partial dependency.
Any verification process would be complicated if efforts are not made to implement a single
integrated set of site information. This is because any form of verification is likely to depend on
pre-population of site information on a standard form to be used for verification. If this
information is to be accurate, it should ideally be derived from a single source. Additionally, the
administrative effort would be greater if updates are required to two information sources when
changes are received.
National Review Feedback
Although most States and Regions support the recommendation to perform periodic verification
as a means of improving data quality, they are generally very concerned about the resources that
might be required to implement it. Several States commented that they would be unable to
perform any kind of voluntary verification due to legal, political or resource constraints while
EPA OSW expressed strong concerns as to the political viability of mandating verification from
the regulated community.
These specific resource concerns will be evaluated as part of the recommended study before a
final pathforward is determined.
A number of States and Regions proposed that verification should be supported by a Federal rule
that would require RCRA Sites to re-notify within a certain time period if any basic site
information changes. This would replace any requirement for wholesale verification, although
such an approach would need to be implemented in conjunction with an initial one-time universal
verification process in order to be fully effective. These commenters felt that this approach
would better place the responsibility for data quality on the regulated site.
This alternative will be evaluated as part of the study, with attention being paid to the most
effective verification frequency.
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FINDINGS AND RECOMMENDATIONS
3) Track all notifying CESQGs nationally
Summary
All future site information that is collected by implementers through notification by CESQGs will
be made available at the national level where those CESQGs are assigned valid EPA
identification numbers.
Program Need
States need to be able to track the handlers that have been issued a valid EPA identification
number in their State, including those that are conditionally exempt from RCRA reporting
regulations.
A better understanding of the CESQG universe will support several needs, for example:
greater integration of data between regulatory programs (e.g. TRI and RCRA)
internal tracking of enforcement and compliance activities
pollution prevention assistance
compliance assistance targeting
waste minimization trend analysis
response to public information requests about RCRA Sites
response to queries from the business community, for example, CESQG information is
frequently requested both by companies doing property assessments associated with real
estate transfers, as well as businesses looking for potential customers
Although the quantity of waste generated by CESQGs represents only a small percentage of the
total national waste production, the impact to the environment can potentially be great since:
many CESQGs are service industries (e.g., dry cleaners) which are typically located in
residential areas
reduced regulations for handling of hazardous wastes may lead to a greater potential for spills
and releases
CESQGs tend to be smaller operations with fewer trained and knowledgeable staff
Problem Analysis
Currently, CESQGs are exempt from Federal reporting and notification requirements. Some
State-specific exceptions exist, for example, in Minnesota and California, which regulate the
generation of quantities of waste as small as one kilogram per year. However, in States that
capture this broader scope of facilities, the RCRA Sites are regulated as either LQGs or SQGs,
not CESQGs.
Some CESQGs do submit a Notification Form to obtain an EPA identification number. This is
often the case where they are required to have a valid number by their TSDF or transporter. Since
there is no Federal requirement for CESQGs to inform the relevant agency of any changes to their
information, the information available in the databases soon becomes out of date.
At the national level, because only a small percentage of CESQGs notify, the national
information systems can never report on the complete CESQG universe.
FINAL REPORT PAGE: 33
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FINDINGS AND RECOMMENDATIONS
CESQG data is often entered into the RCRIS implementer database by States and Regions, but is
excluded from the national oversight database unless the facility has had some other RCRA
regulated activity in the last five years. This decision was made because of the perceived poor
data quality and coverage of the CESQG information, as well as for streamlining efforts on the
part of EPA. CESQG information that is available therefore provides incomplete coverage of the
universe.
There is also concern over making this information available to the public for two reasons. The
first is the potential for misunderstanding the scope of the available information. The second is
the fact that these are conditionally exempt facilities and are not regulated by the RCRA program.
The public may incorrectly assume that if the hazardous waste program is collecting information
on them, the program regulates them.
Recommendation
In the future, where a valid EPA identification number is assigned, any information collected
about CESQGs will be made available at the national level, whether this information was
volunteered by the RCRA Site or collected by virtue of a broader-in-scope State requirement.
This recommendation will not apply retroactively although each implementer may choose to
make historical CESQG information available nationally if they wish.
This will allow implementers to know which CESQGs have notified. However, since only a
partial view of the CESQG universe will be presented, care must be taken to avoid potential
misunderstanding over the scope of facilities that are actually regulated.
Design Considerations
1) Develop explanatory materials to educate public and interested agencies of the impact of the
change.
2) Make necessary changes to national information systems.
3) Share all existing CESQG notification information within the national program information
systems.
4) Potentially make this information publicly available.
Other Options Considered
The team selected the recommendation since it provides consistent access to the widest possible
set of CESQG information.
The following options were also considered.
1) Implementers do not share CESQG information.
2) Require all CESQGs to notify.
Dependencies
2) Study feasibility of periodic verification of site information
This is a partial dependency.
If CESQG data is made available nationally, the number of RCRA Sites being tracked in national
systems will increase. To avoid redundancy and "cluttering" of the database, some form of
periodic verification would be required to ensure that the CESQG population is up to date.
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FINDINGS AND RECOMMENDATIONS
National Review Feedback
A number of commenting States indicated that they currently collect and manage some CESQG
information. Of these States, approximately half enter this CESQG information into RCRIS,
while the other halftrack the CESQGs in their own internal systems but not in RCRIS. The
numbers of CESQGs vary greatly by State, from the low hundreds to ten thousand or more. At
least two States indicated that the available CESQG data is of questionable quality or that the
available data is not detailed enough to allow determination of whether the sites are CESQGs or
simply non-hazardous waste sites.
FINAL REPORT PAGE: 35
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FINDINGS AND RECOMMENDATIONS
4) Track all emergency and temporary sites nationally
Summary
All emergency and temporary sites will be assigned a unique EPA identification number and
information about them will be made available nationally.
Program Need
The RCRA program needs to be able to differentiate between RCRA sites that generate hazardous
waste from ongoing processes and those sites that generate waste from a single event (e.g. spill
clean-up, site or equipment closure). A "single event site" is a location that handles RCRA
regulated wastes at one discrete point in time. This point in time may be a protracted period, but
waste generation activities are limited to that period. The period of operation as a RCRA Site
handling hazardous wastes is limited and the expectation is that the RCRA Site will not pose a
continuing waste generation concern to the regulatory agency. These single-event sites are
commonly termed emergency and temporary Sites.
Emergency sites
Emergency sites are those where the waste generation situation is unforeseen, uncontrollable and
short-term and not expected to exceed 30 days. Emergency sites need to be distinguished from
typical RCRA regulated sites since the standards of quality and completeness applied to the
associated information would probably be less stringent.
In the case of spills and accidental releases, implementers are frequently called upon to issue an
expedited identification number so that the hazardous waste can be moved off-site quickly. The
request may be oral and no Notification form may be received before the EPA identification
number is issued.
Temporary sites
A temporary RCRA Site is one that does not generate hazardous waste from ongoing industrial
processes, but rather through remediation or "one-time events," such as plant cleanout and
closure or process equipment change. Other examples include highway bridges and cruise ships.
Unlike emergency sites, the implementing agency usually receives a Notification form and issues
an EPA identification number. However, the period of operation as a hazardous waste RCRA
Site is limited and typically short.
Despite the transient nature of both of these types of single event sites there is a need to track
their activities and to gather information about the waste that is generated. For example:
Tracking information about emergency sites will allow an implementer the opportunity to
trace patterns in incident occurrence and waste generation by geography or perhaps
transporter. Preventative measures might then be taken.
The location of emergency incidents could be used in the future to investigate other
environmental problems. For example, if a well in the immediate area becomes contaminated
with the same constituents that were spilled a regulator could investigate the spill as a
possible source of contamination.
Hazardous waste and its proper management carry some "higher" level of need to know what
is generated and where it goes to be properly managed. This need for public reassurance
includes temporary and emergency events.
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FINDINGS AND RECOMMENDATIONS
Problem Analysis
RCRA regulations do not differentiate between "standard" RCRA Sites and temporary or
emergency sites. Review of the regulations indicate that residues, contaminated soils or debris
from spills that are to be discarded are regulated the same way as any other RCRA waste, and
associated site of generation. If waste is generated at or above SQG levels, an EPA identification
number is required, and BRS reporting is required if the quantity is at the LQG level.
Implementers differ in the treatment of such sites. Some assign "temporary" or tracking
identification numbers, while others issue normal EPA identification numbers. Of these, some
implementers record the sites in RCRIS, usually as one-time generators, and/or implementer
systems or paper files. Several implementers handle temporary and emergency sites differently
from one another.
For emergency sites, the person requesting the EPA identification number is usually not the
owner/operator, but rather a representative of law enforcement, emergency response and
management, or other agency. Although this person assumes the generator's responsibilities in
connection with the hazardous waste manifest, the person does not meet the regulatory definition
of a generator. Often, the available information about an emergency site is limited and
incomplete.
For both of these types of site, implementers need a mechanism to "close the loop," so that those
RCRA Sites that are no longer of interest can be distinguished from those of ongoing concern.
Some implementers effectively deactivate such a site as soon as it is recorded by issuing a
provisional number that effectively has a 30 day life span and automatically becomes invalid for
waste shipment purposes after that time. Some States currently require that such temporary sites
re-notify when they complete waste generation activities to indicate that they are no longer active.
To prevent cluttering of the national information systems, discussions have considered some type
of automated deactivation of temporary sites. While prompt deactivation of such temporary sites
is desirable, their complete removal from the national system would be detrimental since reports
of waste received by a TSDF would be incomplete in the absence of the temporary generator site
record.
Recommendation
The RCRA regulations do not distinguish between RCRA Sites that generate waste on an ongoing
basis or through a single event. Given this and since all generators of RCRA waste that report are
to be collected nationally, it is proposed that every single event site would be assigned an EPA
identification number.
Information about these RCRA Sites will be collected and made available nationally in common
with information about ongoing generators, providing a full picture of all regulated RCRA Sites
and waste movement from such sites.
Emergency sites
Notifications will not typically be received from emergency sites. A brief "telephone notification"
form might be used to take provisional details on the incident site, to ensure that an EPA
identification number has not already been assigned. Such locations will be indicated as
"emergency sites" to facilitate systematic reference and to indicate that a less stringent standard
for data quality is to be expected.
The period of activity of the emergency site may be difficult to determine in all cases. To close
the loop for such sites, functionality could be developed in the national system to provide a timed
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FINDINGS AND RECOMMENDATIONS
"tickler" notifying the regulator that the site is still active in the system and deactivation may be
required.
Temporary sites
A full Notification form would be required from all temporary sites (to be referred to as single
event sites). Again, a brief "telephone notification" form might be used to take provisional details
on a site before confirming that the single event site does not already have an EPA identification
number and assigning a new one.
The duration of the waste generation activity would be indicated using the site activity
information and associated activation and deactivation dates, which is how all RCRA Site activity
information is to be managed. Some form of periodic RCRA Site information verification
procedure will be used to track whether a single event site continues to be active.
Design Considerations
1) New guidance must be developed by States and EPA to ensure all parties are managing this
information consistently.
2) Implementers must enter all regulated sites into the national system, assigning a valid EPA
identification number to each.
3) Deactivation or "tickler" functionality may need to be developed.
Other Options Considered
The recommendation is expected to provide the comprehensive improvement in information
quality with no additional burden on the regulated community. The following option was also
considered:
1) Develop Federal regulation requiring that all RCRA Sites notify the implementing agency
when they cease hazardous waste handling activities.
Dependencies
The above recommendation is dependent upon:
2) Study feasibility of periodic verification of site information
This is a partial dependency.
If temporary and emergency site data is made available nationally, the number of RCRA Sites
being tracked will increase. To avoid redundancy and "cluttering" of the database, some form of
periodic verification would be required to provide a mechanism to determine if and when the sites
are no longer active. This would avoid the current problem of national and implementer systems
tracking many inactive sites as if they were still active.
National Review Feedback
Of those States who commented on this recommendation, the majority currently assign valid EPA
identification numbers to emergency and temporary sites. Several of the remainder assign State-
specific numbers. The number of such sites identified each year varies from state to state,
ranging from tens to thousands of sites.
Some concerns were expressed that such sites may be recorded only to remain apparently active
indefinitely if some verification mechanism is not put in place.
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5) Track all non-notifiers nationally
Summary
Adopt a consistent process for the classification and recording of sites that initially fail to submit
a formal notification to the responsible implementing agency.
Program Need
Non-notifiers are RCRA Sites that have not submitted a signed Notification form to the
implementing agency.
All implementers recognize a site as an "official" RCRA Site only if a Notification form is
submitted, a telephone notification is provided in the case of emergency sites, or as the result of a
formal site visit by State or EPA program staff. Sites that have not previously notified can be
initially identified through a variety of means including:
hazardous waste inspections
complaints
targeted initiatives using trade associations
phone books
industrial directories
TRI reports
other governmental agency referrals (e.g., DOT)
regulated community
There is a programmatic need to capture information about such sites in an organized and
consistent way.
Problem Analysis
Implementers assign an identification number to all RCRA Sites in order to track them in paper
files and in information systems. Non-notifiers must be identified for the same reasons. A non-
notifier is considered to have notified when they submit the Notification form or equivalent to
EPA or the authorized State. The implementing agency then issues an EPA identification number
if one has not already been assigned.
Some implementers track non-notifiers outside of the national information systems using various
systems of alternative identifiers. Data about these RCRA Sites is then not made widely available
to program staff.
Currently, the RCRIS Handler Module provides four values that can be entered into the non-
notifier indicator field:
X - Current non-notifier (known to State or EPA to be a hazardous waste RCRA Site, that has
not submitted a notification)
O - Former non-notifier that has since notified
E - Initially considered a non-notifier, subsequently determined to be exempt from
notification
Blank - Not currently a non-notifier and not known to have been a non-notifier in the past
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FINDINGS AND RECOMMENDATIONS
The primary issue concerns the need to identify non-notifying sites historically.
There is currently no common convention for assigning tracking numbers to non-notifiers.
The information about non-notifiers is usually only accessible to the implementing agency
which can sometimes result in inconsistent accounting in program activity reports.
Temporary tracking numbers assigned by implementers may last for many years before the
owner applies for an EPA identification number or the agency determines no EPA
identification number is needed.
Additionally, there is confusion about the use of the term non-notifier. The term applies to those
who are engaged in activities that require an EPA identification number. Many State and EPA
staff, however, also use the term to indicate those RCRA Sites with EPA identification numbers
who fail to submit required subsequent notification of additional - sometimes newly regulated -
hazardous waste activities (some regulated activities such as universal waste handling do not
require further notification if the RCRA Site already has an EPA identification number).
Finally, although PAA participants agreed to the need for information about non-notifiers to be
available to implementers, this information should not be made available to the public due to
potential enforcement sensitivity.
Recommendation
RCRA Sites may only be identified and tracked nationally through either submission of a formal
Notification form, by telephone or fax notification in the case of an emergency site, or a site visit
by a responsible agency.
The following process will be used to track non-notifiers:
1) Issue a valid EPA identification number to non-notifiers when they are discovered, recording
the date they were discovered.
2) If and when a non-notifier submits a notification, record the submission date. This would
validate the identification number already assigned to the RCRA Site
3) If and when the implementing agency determines that the non-notifier is in fact not a
hazardous waste RCRA Site, indicate that notification requirements are not applicable to this
site.
4) All non-notifiers would be made available in the national implementer data set although
would not necessarily be made available publicly due to enforcement sensitivity.
Design Considerations
1) Additional data elements would be required in the information system to track the discovery
date for a site and the fact that a site is "not required to have notified" even though it may
have an assigned EPA identification number.
2) Would require implementers to periodically review all non-notifiers to determine whether
they are truly RCRA Sites. Such sites would then become available nationally.
Other Options Considered
1) Create new terms to replace the differing situations now represented by "non-notifier. "
"Non-applicant" might be used for those who fail to apply for an EPA identification number,
"non-filer" (or "non-reporter") for those who fail to notify about changes in their hazardous
waste activities.
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FINDINGS AND RECOMMENDATIONS
2) Train all implementers about the proper use of the current procedures for entering non-
notifiers in the database. Use the term only for those RCRA Sites that may require an EPA
identification number.
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FINDINGS AND RECOMMENDATIONS
6) Collect both State and Federal generator status from States
Summary
In addition to reporting the Federal generator status for a RCRA Site, each State with regulations
that are "more stringent than" or "broader in scope" will also provide the State generator status if
different from the Federal status. This information will be made available nationally for all
generators.
Program Need
The basic Federal regulatory framework provides for three distinct classes of hazardous waste
generators: LQGs, who are subject to the most comprehensive regulations; SQGs, who comply
with a less stringent set of requirements; and CESQGs, who are not subject to reporting
requirements provided they comply with a set of simple requirements. Generators fall into these
regulated classes based on the volume and toxicity of hazardous waste they generate, accumulate
and/or store in any one month of the calendar year. Both LQGs and SQGs are required to notify
the agency of their activities, declare their generator category, and obtain EPA identification
numbers, to be used in manifesting and other waste reporting.
The definitions of these classes as described by the Instructions for the 1997 Biennial Reporting
forms are:
Large Quantity Generator
Site is an LOG if it meets any of the following criteria:
a) The site generated in one calendar month 1,000kg or more of RCRA hazardous waste; or
b) The site generated in one calendar month, or accumulated at any time, 1kg of RCRA acute hazardous
waste; or
c) The site generated or accumulated at any time more than 100kg of spill cleanup material contaminated
with RCRA acute hazardous waste.
Small Quantity Generator
Site is an SQG if it did all of the following:
a) In one or more months generated more than 100kg of hazardous waste, but in no month did the site
generate (1)1000kg or more of hazardous waste; or (2) 1 kg or more of acute hazardous waste; or (3)
100kg or more of material from cleanup of a spillage of acute hazardous waste; and
b) Accumulated no more than 1kg of acute hazardous waste and no more that 100kg of material from the
cleanup of a spillage of acute hazardous waste; and
c) Stored its wastes in tanks or containers in a manner consistent with regulatory provisions.
The site can also be an SQG if it:
a) Met all other criteria for a CESQG, but
b) Accumulated 1000kg or more of hazardous waste
Conditionally Exempt Small Quantity Generator
Site is a CESQG if in every month of the year, the site did all of the following:
a) Generated no more than 100kg of hazardous waste, and no more than 1 kg of acute hazardous waste,
and no more than 100kg of material from cleanup of a spillage of acute hazardous waste; and
b) Accumulated no more than 1000kg of hazardous waste, and no more than 1kg of acute hazardous
waste, and no more than 100kg of material from the cleanup of a spillage of acute hazardous waste;
and
c) Treated or disposed of the hazardous waste in a manner consistent with regulatory provisions.
While RCRA requires as a condition of authorization that State hazardous waste laws be at least
as stringent as Federal rules, it allows States to operate regulatory programs that are broader in
scope (BIS) or more stringent than (MST) the Federal program. For example, a State:
May impose the regulatory obligations of an LQG on facilities generating less than 1,000
kilograms of hazardous waste in a calendar month (which is more stringent than the Federal
scheme).
May regulate wastes not included in the Federal list of hazardous wastes (broader in scope).
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FINDINGS AND RECOMMENDATIONS
May require CESQGs to notify and obtain an EPA identification number (also broader in
scope).
This flexibility reflects both the essence of the State-Federal system of government and the
varying situations, concerns and needs of different States.
States need to know the status of a generator as defined by their own regulations which may or
may not be the same as the Federal regulations. Where State definitions are different from
Federal definitions, States have less need for the Federal status.
EPA uses the Federally defined generator status to support many of the agency's program
evaluation functions including various regulatory oversight activities, regulatory impact
assessment, fund allocation, and congressional reporting. The Federal LQG and SQG universe
sizes are also used to identify compliance rates, high-risk generator sectors, and facilities that
need to be inspected. Since States have varying definitions of large and small quantity
generators, the Federal definition must be used to ensure consistency and report meaningful
universe numbers when performing interstate comparisons analysis.
If an authorized State has rules more stringent than the Federal equivalent, EPA inspects by those
rules in that State: but if the State has rules that are broader in scope than the Federal program,
EPA can enforce only by the Federal regulations. EPA therefore needs to be able to distinguish
between generators categorized by the Federally defined or MST and BIS statuses.
Problem Analysis
Due to MST or BIS State regulations, a generator may identify itself as an LQG according to
State regulations, but be considered an SQG under the Federal definition (e.g., because of the
State of New York's inclusion of PCBs, and more extremely, the State of California's
all-inclusive LQG regulation). The same situation is also true for State SQGs and Federal
CESQGs (e.g., Kansas regulates generators of 25kg - 100kg as SQGs, where the Federal
definition considers any generation under 100 kg to be CESQG). A state-only LQG must follow
state regulations that are equivalent to federal LQG regulation requirements, even though it does
not meet the Federal definition of an LQG.
This situation has a number of implications. Firstly, States that apply regulations that affect
generator status definitions may have the burden of translating between State and Federal
statuses. Secondly, users of both State and EPA data (including the regulated community and
public) are provided with confusing and apparently contradictory representations of some
generators. Thirdly, EPA's impact analyses of a given Federal regulation on LQGs may not be
representative of the total population of those RCRA Sites that would need to comply with that
regulation.
The main source of generator status information is the Notification form. This normally
represents the generator's status as prescribed by State rule, if different to Federal rule, or in some
States, collects information about both State and Federal regulatory classifications. Additionally,
RCRA Sites that are LQGs and who are required to report waste generation information using
Biennial Reporting forms are required to report their generator status on those forms using the
Federal definition.
A brief survey was conducted of 17 States to evaluate the business practice with respect to
variations between State and Federal regulatory definitions and how they are handled. This
survey appears to indicate that this situation affects the minority of implementer States. The
survey also indicates that where the state generator status is different from the Federal status,
there is inconsistent reporting of the status values between states.
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FINDINGS AND RECOMMENDATIONS
Survey Results
8 of the 17 States who responded have implemented regulations that are broader in scope or more stringent
than the Federal regulations. In 6 of the 8 States, these regulations affect the number of generators, with
the affect on the number of regulated large and small quantity generators varying between one and several
thousand.
Survey respondents were asked to detail how any differences between their State regulations and the
Federal regulations affect the provision of generator information to the national RCRIS and BRS information
systems.
With respect to the RCRIS system:
All of the surveyed States provide information to the national RCRIS information system and include
both LQG and SQG information and in several cases any CESQG information collected.
Of the 6 respondents whose State-defined generator universe is different from the Federally defined
universe, 4 do not attempt to convert the State status to the equivalent Federal status prior to inputting
the information into RCRIS. The remaining 2 respondents collect the necessary information to perform
the conversion on their Notification forms.
The main reason cited for not making the conversion was "resource shortage".
With respect to the BRS system:
All of the surveyed States employ a mixture of manual and electronic reporting to the BRS system.
5 of 6 respondents whose State defined generator universe is different from the Federally defined
universe input only Federally defined LQGs into BRS. Only one respondent inputs all State-defined
LQGs additionally.
Conversion of the collected information is often unnecessary since the reporting forms or software used
to capture the report information from the regulated community typically make the distinction between
the State and Federal regulations.
Recommendation
States will report their generator universe as identified by their own regulatory definitions and
will also report the generator universe as identified by the Federal regulatory definition to the best
of their ability to translate the generator status. This reporting will occur for all generators that
are provided nationally.
The Federally defined generator status should be determined by the State either using information
collected directly from the regulated community or by extrapolation from waste generation
information provided on the Biennial Reporting forms or equivalents when it becomes available.
For those States having MST or BIS regulations that affect the generator status, the following
steps are proposed:
1) When a generator notifies, the State will assume that the reported generator status reflects
solely the State regulations unless the State collects sufficient information to determine both
Federal and State status values using a State-specific Notification form.
2) Periodic waste reports (manifests, Biennial Reporting forms, or similar) will be used to
confirm the relevant State and Federal status values. LQG status values may be determined
directly from waste generation information while SQG and CESQG status values can be
determined either directly, if they submit waste reports, or by examination of waste receipt
information submitted by TSDFs.
It should be noted that precise determination of the Federal status may not always be possible.
The PAA Team has agreed that the best approximation is acceptable in these cases. Supporting
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FINDINGS AND RECOMMENDATIONS
definitions will be provided to viewers of the information to ensure that the data is interpreted
correctly.
This recommendation will provide the following benefits:
Having the State defined status values in the national database will provide a more complete
picture of the total number of handlers that are regulated under the RCRA regulations across
the country.
Data will be more directly comparable across the nation, resolving many of the problems of
having different universe numbers between EPA and States.
A single approach will be used to determine the national universe of Federally regulated
generators instead of varying State by State practices.
EPA inspectors would be able to more accurately determine which regulations apply at a
given generator.
EPA could determine impact of Federal Rules both as written and as applied.
Design Considerations
1) Where States need to determine the Federal status using waste information, a translation
procedure will be required.
2) Where States need to determine the Federal status using waste information, a level of
accuracy must be defined for the calculation that will provide results suitable for EPA use.
3) States may need to collect additional data element(s) to allow calculation of the Federal status
if not determined in some other way.
4) Some States will assume a greater burden when calculating the Federal generator status at the
required frequency if they do not already do so.
Other Options Considered
This recommendation is proposed as providing the greatest improvement in quality. The
following options were also considered:
1) Use State definitions to determine and report generator status. For those States that have
MST/BIS rules, generators would report their status based on these rules.
2) Collect both State and Federal statuses from the regulated community.
3) Eliminate reporting of generator categories altogether.
National Review Feedback
Although this recommendation received widespread support, a number of States and Regions
disagreed with it, expressing concern as to the additional burden placed on States and suggesting
that States should only be required to provide the State definition to national systems.
The need for clear and consistent explanations of each of the two published status values was
clearly expressed by a number of reviewers.
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FINDINGS AND RECOMMENDATIONS
7) Merge common elements of current site identification forms
Summary
Develop and implement a single information collection form to record basic site information
whenever required by the RCRA program.
Program Need
Implementation of the RCRA program requires the collection of basic information about a site of
interest and the hazardous waste handling activities taking place at the site. This information is
used for waste activity monitoring, compliance monitoring, technical assistance, program
planning, waste minimization and other program activities.
There is an increasing need to streamline and enhance the existing information collection process
to reduce burden and improve the quality of data collected.
Problem Analysis
Site identification data is currently collected on several different forms using differing
instructions and differing definitions for key information needs. A single RCRA Site may be
required to submit the same information several times using forms that are structured somewhat
differently and which have different instructions. This can lead to variations in the information
submitted for that site.
Basic site information is collected from all regulated RCRA facilities on the Notification form
(8700-12). LQGs report site information on the Biennial Reporting Identification and
Certification (1C) form (8700-13A/B). Facilities that treat, store or dispose of hazardous waste
need to submit site information on the Part A Permit Application form (8700-23) to obtain a
permit from the relevant implementer organization.
Although the Part A Permit Application form does collect some process specific information,
most of the data elements collected on the three different forms that provide basic site
information are essentially duplicative of one another.
Recommendation
A new RCRA Site Identification form should be developed that would harmonize the site profile
information that is currently collected on the Notification form, the Part A Permit Application,
and BRS 1C form along with other non-standardized forms (e.g. Notice of Emergency Site,
Transporter Application).
The Notification and BRS 1C forms would be replaced. The Part A Permit Application form
would be modified to request only the process-specific information beyond the scope of the new
standard RCRA Site Identification form. Similarly, the other non-standardized forms would be
simplified to include only those data elements that are not captured on the new form.
The new RCRA Site Identification form would be submitted instead of each of the above forms
whenever the RCRA program requires basic site information. Any information other than this
basic site information will continue to be collected by those specific forms. The RCRA Site
would therefore continue to submit the information with the same frequency as they currently do,
but would only need to be familiar with one set of instructions and data fields. This
recommendation will improve data quality by removing redundant and inconsistent collection
mechanisms and by clarifying the information required.
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FINDINGS AND RECOMMENDATIONS
The instructions and data fields included on the new RCRA Site Identification form will reflect
the following program information needs captured during the PAA project.
National Information Needs
EPA identification number
Site name
Location address
Land owner type
Owner name
Owner type
Operator name
Operator type
Site contact name
Site contact phone
Mailing address
NAICS code
State generator status
Federal Generator Status
Hazardous waste transporter
Hazardous waste fuel marketer
Underground injection
Used oil transfer station
Used oil burner
Used oil processor
Used oil refiner
Used oil marketer
Used oil transporter
Universal waste handler
Hazardous waste import agent
Mixed radioactive waste handler
TSD unit type
Design Considerations
1) New RCRA Site Identification form would need to be developed with associated instructions.
2) Other supporting forms must be developed, such as the specific permit application form
needed to capture those data elements currently captured by the Part A form that would not
be included on the RCRA Site Identification form.
3) Regulatory changes to RCRA Notification requirements will be necessary to reflect the new
reporting requirements for the regulated community.
4) Collection of treatment, storage or disposal activity information must be carefully designed to
meet the identified need to distinguish between such sites while accommodating the fact that
this information is determined at the unit level and unit level information is not collected by
the Notification form.
5) Implementers and regulated community will need to be re-educated.
National Review Feedback
Several States noted that the new RCRA Site Identification form in some way should also satisfy
the previously identified information need for "TSD unit type". This concerns the RCRA
program's need to know what type of treatment, storage or disposal activities are being performed
at a site. Although the specific activities are performed at the management unit level, it is
important for the program to have visibility to these activities at a high level especially in the
period prior to detailed management unit information becoming available. This need is now
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included in the recommendation and the design process for this recommendation will determine
the most effective way of gathering this information.
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FINDINGS AND RECOMMENDATIONS
8) Add Additional Data Elements to Notification Form
Summary
Include additional fields on the Notification form to capture new nationally required information
needs.
Program Need
A number of nationally required information needs, are not currently collected on existing data
collection forms or managed in existing data systems.
Industrial activity
An indicator of the principal industrial activity at the RCRA Site would enable many targeting
and analysis operations. For example:
to assess the impact of rule changes
to provide technical and compliance assistance
waste generation and waste management trend analysis
waste minimization and pollution prevention outreach
informational mailings
Collection of industrial activity information supports the movement of the RCRA program
towards sector based approaches to hazardous waste management. As this trend continues, the
program needs to collect and integrate this type of information with the rest of the information
needed by the RCRA program.
Owner and operator name
PAA participants indicated that collection of both the owner name and the operator name using
the Notification form would be very useful to some implementers:
Implementers could evaluate the compliance history of both the owner and operator of a site.
This could allow for permit denial or inspection targeting based on past environmental actions.
For compliance and enforcement purposes, in cases where the owner and operator are either
public or private entities (e.g., the owner is public and the operator is private), it is very important
to make a distinction. An enforcement action can then be directed to the entity actually
responsible for non-compliance.
There would be an increased chance of the correct party receiving informational mailings.
Handlers of imported wastes
PAA participants identified the need to differentiate between imported hazardous wastes and
waste generated domestically.
Handlers of radioactive wastes
It is also necessary for program staff to be able to identify those RCRA Sites involved in
radioactive waste activities for program oversight and in response to external requests for
information.
Problem Analysis
Industrial activity
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FINDINGS AND RECOMMENDATIONS
Some industry type information is currently collected on the Biennial Reporting forms and the
RCRA Part A Permit Application form. It is voluntary information on the Biennial Reporting
forms and is required from TSDFs on the Part A form.
Industry type information has typically been collected using the Standard Industrial Classification
coding system (SIC). However, this coding system as a data standard is to be replaced by the use
of the North American Industrial Classification System (NAICS) over the next three years.
Owner and operator name
The current Notification form does not distinguish between the RCRA Site owner and operator
names.
Handlers of imported wastes
The current waste reporting forms and Notification form do not differentiate between generators
located in a State that produce waste themselves or that import waste and only appear to generate
the waste.
Handlers of radioactive wastes
Current waste activity reporting forms redundantly collect information about the mixed
radioactive waste handling activities at a RCRA Site. Additionally information on mixed
radioactive waste activity is not consistently available for SQGs, as they are not required to
submit a Biennial Report.
Recommendation
Include additional fields on the new RCRA Site Identification form to collect the necessary data
elements to meet the previously described needs.
At least one NAICS code will be requested corresponding to the primary industrial activity being
performed at the site. Both facility owner and operator names will be collected.
The activity of importing hazardous waste will also be captured. Collecting this information on
the RCRA Site Identification form would not exclude the reporting of additional site activities
(e.g., hazardous waste transporter).
Another new data element will capture the fact that the RCRA Site is engaged in the generation
and/or management of mixed radioactive waste. This will also provide currently unavailable
information about radioactive waste handling activities being conducted by SQGs.
Design Considerations
1) Forms and instructions will require revision.
2) Some burden will be associated with collection of additional information from the regulated
community.
3) Given that most businesses perform multiple operations, the design team will need to
consider the use of single versus multiple NAICS codes in future systems
4) Allowances will have to be made in future systems for historical SIC numbers for those
RCRA Sites that have previously provided SIC codes, and have not re-notified with their
NAICS code.
5) Historical information about RCRA Sites who handle mixed radioactive wastes may be
derived from existing biennial reporting data since this recommendation will only succeed in
capturing this information for RCRA Sites who notify or re-notify.
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FINDINGS AND RECOMMENDATIONS
9) Provide for standard notification by large quantity handlers of universal
wastes
Summary
Revise the Notification form to collect information about the activities of large quantity handlers
of universal waste in a consistent way.
Program Need
Unless and until an authorized State adopts the RCRA universal waste regulations, handlers of
universal wastes are not subject to Federal regulation for their activities, including notification
requirements. However, once the regulations are adopted, there is a Federal requirement for
handlers of large quantities of universal waste to notify the relevant implementing agency of these
activities and of the specific wastes being handled.
PAA participants expressed a clear need for a better picture of universal waste handling activities
to meet several needs, for example:
Understanding how many hazardous waste generators have become solely universal waste
large quantity handlers will provide a starting point to review the impacts of the universal
waste program.
Implementing agencies can, with this information, help support or take the lead on
establishing collection and management (primarily recycling) systems.
Inspection scheduling and knowing in advance the type of universal waste facilitates efficient
inspections.
Problem Analysis
A universal waste handler is a generator of universal waste or a facility that receives universal
waste from other handlers, accumulates universal waste or sends universal waste to another
universal waste handler or facility. This excludes persons who treat, dispose, of or recycle
universal wastes or persons engaged in the off-site transportation of universal wastes.
Large quantity handlers are those who accumulate 5,000 kilograms or more total of universal
waste (batteries, pesticides, or thermostats, calculated collectively) at any time. This designation
as a large quantity handler of universal waste is retained through the end of the calendar year in
which 5,000 kilograms or more total of universal waste is accumulated
Current Federal regulations require that large quantity handlers of universal wastes submit a one-
time written notification to receive an EPA identification number. This requirement is waived if
the site already has an EPA identification number or has previously notified EPA under the
Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). Small quantity universal waste
handlers, transporters and destination facilities are not required to notify under existing Federal
regulations as adopted by States.
Despite this regulatory requirement that large quantity universal waste handlers notify of their
activity and the wastes that they handle, the handler is not required to use the Federal Notification
form and there is currently no place on the form to indicate such activity. Some authorized
implementers may require use of a State-specific form for universal waste handlers to use when
notifying to collect additional information important to individual State needs.
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FINDINGS AND RECOMMENDATIONS
An incomplete national picture of universal waste sites and their activities exists due to current
notification requirements and because this information is not entered into the current national
information management system.
Recommendation
The Notification form should be amended to include an additional field indicating that the site is
conducting large quantity universal waste handling activities.
This will only provide information from those States that have adopted the appropriate Federal
regulations. Because some universal waste handlers already have an EPA identification number
or have notified under FIFRA and therefore do not need to re-notify, a complete national picture
of universal waste handling activities may always be difficult to achieve.
Additionally, this recommendation will not explicitly address the requirement for the site to also
indicate the wastes being handled. This recommendation should, however, provide some
consistency in the mechanism for notification.
Design Considerations
1) An Information Collection Request (ICR) for the Notification form has been developed and is
currently under review, that implements this recommendation. The design of this
recommendation will need to track the progress of this ICR, since its implementation may
supercede the need for design and implementation of this recommendation.
2) The design project should address the outstanding need for some means of allowing the site
to indicate on the Notification form, which wastes are being handled. This could possibly be
achieved through use of the comments fields on the existing form.
3) Educational outreach by implementing agencies would be required to ensure that generators
understand the changed information collection requirement.
Other Options Considered
The Team believes that the selected recommendation provides the greatest improvement in
information quality for the least increase in burden for both implementers and regulated
community. The following alternative solutions were considered.
1) Use Notification Form comment field to record a description of universal waste activities.
2) Obtain universal waste handler information through agency surveys or RCRA 3007
information requests.
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FINDINGS AND RECOMMENDATIONS
10) Remove waste codes from Notification Form
Summary
With the associated recommendation to gather waste activity information by means of Quarterly
Electronic Reporting by TSDFs, waste codes will no longer be collected on the notification
forms.
Program Need
To effectively plan for and perform activities such as inspections and technical assistance visits, it
is important for program staff to have an understanding of the types of hazardous waste being
handled at a RCRA Site.
There is an overall program need to simplify and streamline regulated community reporting
requirements. Additionally, to ensure proper implementation of the program, implementers
require data of reliable quality.
Problem Analysis
The Part A Permit Application provides some information about the waste being handled by
TSDFs, while Biennial Reporting data is a better source of waste information for both TSDFs and
LQGs. However, the Notification form is the only direct source of any information on wastes
handled by SQGs, as well as the only source of waste information for new RCRA sites, prior to
their first reporting event.
Some PAA participants expressed a low level of confidence in the quality of the waste code
information reported on the Notification form, especially by SQGs. It is believed that this is a
result of generators not understanding the waste codes that apply to their wastes. PAA
participants also indicated that this waste code information is not currently made available
nationally to the RCRA program. Others PAA participants indicated that the waste codes on the
notification form were the best source of waste data for SQGs given that there is currently no
other source for this information. However many of these participants expressed low confidence
in the accuracy of the data.
Recommendation
After implementation of the PAA Team's recommendation concerning quarterly electronic
reporting of waste handling information by TSDFs, waste codes will no longer be collected on the
Notification form. A RCRA Site's waste handling activities will be able to be determined through
quarterly TSDF reports. This mechanism will also provide current information about generation
activities for SQGs thereby replacing the need for reporting of waste codes on the Notification
form. Currently, waste code data for this universe becomes dated, as they are required to notify
only once, and are not required to submit biennial-reporting forms nationally.
For new RCRA Sites the implementer may also derive the RCRA site's waste activities by using
NAICS codes, which will be added to the Notification form as part of the PAA Team's
recommendation concerning the addition of data elements to the Notification form.
Implementing organizations may also access waste generation data through the national
information system on other like RCRA Sites, to derive initial generation activities for a new
RCRA Site, until the first TSDF report on the RCRA Site is submitted.
Design Considerations
1) Forms and instructions need to be changed to reflect the change.
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FINDINGS AND RECOMMENDATIONS
2) Modify EPA and State information systems to reflect the change.
3) Some PAA participants have indicated that they may continue to collect the waste codes, and
would like to have the mechanisms necessary to store this data in a national system.
Dependencies
11) Study feasibility of quarterly electronic reporting of TSDF waste receipts
This is a critical dependency.
For implementers to derive accurate waste activity information, Quarterly Electronic Reporting
by TSDFs must be implemented. If this recommendation is not implemented, waste codes cannot
be removed from the notification form.
National Review Feedback
When presented in the Draft Report for National Review, State reviewers were evenly divided in
their support for this recommendation.
Although many reviewers observed that the waste code information that is currently collected on
the Notification form is unreliable since there is no requirement to notify of changes to this
information, a large number of reviewers cited the following concerns with removing this
information from the form:
NAICS is not specific enough when trying to determine potentially responsible parties in the
event of a spill at a site. Waste codes are a better historical reference.
Generators are required by RCRA to perform waste determination prior to operating and
would therefore know their waste codes.
Drawing conclusions about wastes generated from NAICS codes is difficult and imprecise.
Waste codes provide a better source of information to inspectors.
Waste codes are often the only current source of such information for small businesses.
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FINDINGS AND RECOMMENDATIONS
11) Study feasibility of quarterly electronic reporting of TSDF waste receipts
Summary
The PAA Team proposes that further analysis should be conducted to assess the feasibility of the
following two recommendations:
1. Require all TSDFs that submit Waste Received (WR) forms (or State equivalent) to submit
quarterly electronic reports to their RCRA implementing agency describing all of the waste
shipments that they received and managed for that period.
2. Based on waste receipt data submitted by the TSDFs across the country, a pre-populated
Generation and Management (GM) form (or State equivalent) would be produced and sent to
generators by the implementing agency in the State in which the generator resides. The
generator would then confirm, add to, or correct the information detailed on the form.
The States and EPA would need to jointly implement these two improvements such that all
hazardous waste shipment and management information would be promptly consolidated into a
national information system from implementer systems. Any regulator would have access to this
system and be able to examine all shipments that originated from, or were delivered to a specific
State or Region.
Program Need
Currently, any RCRA Site that meets the definition of an LQG or who treats, stores or disposes of
hazardous waste must file Biennial Reporting forms. These forms are collected every two years
and capture one year of waste activity information. This provides an incomplete (only one year in
two) and delayed (collected a year in arrears) picture of waste management activities.
With the limited national reporting capabilities of BRS, the current visibility available to
implementers of shipments going out of State is poor. This is worse for those programs with
more frequent data submissions than biennially who have to wait until the end of the biennium
before they can compare their information to that of other implementers. They have the need to
perform cradle to grave and quality assurance comparisons at or near the same frequency in
which they collect waste data from their in-state generators and TSDFs.
State and Regional PAA participants strongly expressed the need for the waste information to be
collected more frequently without any "blackout" years.
EPA OSW Headquarters indicated that their information needs are adequately supported by
biennial updates. However, EPA Regional participants indicated that waste activity monitoring
data was needed on at least an annual basis. State participants concurred, with several expressing
a need for even more timely shipment level information.
Problem Analysis
The following issues were identified by PAA participants with respect to the current waste
activity reporting mechanisms:
The current biennial submission of hazardous waste data is viewed as too infrequent for
implementers to respond to potential violations or trends in waste generation. Some PAA
participants noted that many violations identified through the reported waste information are
two years old before they are visible to the regulating agency.
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FINDINGS AND RECOMMENDATIONS
Participants characterized the current use of data for analysis and oversight as a public trust
concern since there are credibility issues when responding to public requests for information
with data that is three years old.
Hazardous waste information is of concern to the public, and implementing agencies are
tasked with ensuring that this waste is properly managed, protecting public health and safety
and the environment. It is difficult to respond to these tasks when the only information
available is dated.
Through more frequent submission of hazardous waste data, implementers responsible for the
day to day compliance of RCRA Sites can better perform activities such as inspection
planning, waste minimization, enforcement, and environmental justice analysis.
More frequent data submission could also help determine whether facilities are meeting their
permit requirements and provide quicker response and intervention for those that are not.
Implementers are currently reacting to old data when issues are noted.
High quality, frequent data will allow States to better manage their fee programs. The fee
programs are an important source of operating revenue and also provide pollution prevention
incentives but require accurate defensible data for effective implementation.
Several States have modified the Biennial Reporting forms in one or more of the following ways:
Increasing the reporting frequency to annually or, in some cases, as frequently as monthly.
Collection of manifests resulting in more timely information, and a comprehensive
assessment of waste activities .
Including SQGs and other RCRA Sites in their reporting requirements.
The current minimum frequency of submission can in itself be a burden, as TSDFs have to
manage data for many generators over a two-year period, prior to submission. It can then be
difficult for the TSDFs to audit records and ensure data quality on dated information.
Recommendation
Figure 7: Recommended Approach for Waste Activity Reporting on the following page illustrates
how the information would be collected from the regulated community and can be described in
five sequential steps.
1) Instead of the traditional Biennial Report WR form, TSDFs would transmit data
electronically to their State or Region on a quarterly basis describing each shipment
received during the period. This reporting requirement would be supported by federal
rule. Information needs to be transmitted would include:
Originating EPA identification number
Manifest number of the shipment
Waste codes that describe the waste received
Quantity of waste received
Unit of measure
Date the waste was shipped by the generator
Date it was received
Management method used to manage the waste
Form code of the waste
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FINDINGS AND RECOMMENDATIONS
NOTE:
The form of the waste is not currently defined as a "national" program need. Further
analysis will be performed to confirm its inclusion.
Waste managed off-site
Waste
managed
on-site
TSDF
Generator
Waste
shipments
received /
managed
flat file
On Site
Generation /
Management
and Off Site
Shipments
Form
Off Site
Shipments
Form
(pre-populated)
aysiem
?,
{Biennially}
National
Waste Shipment
Repository
National
RCRA Information
Access System
Figure 7: Recommended Approach for Waste Activity Reporting
2) The State/Region would quality assure the waste receipt data and then electronically
transmit it into a national information system containing all shipment/management
information from across the country. Alternatively the TSDF would report directly to the
national information system if their implementing agency does not have an independent
information system. The implementer may also decide to provide additional shared
information needs, at their discretion.
3) Regulators will be able to access the national information system to review information
about all shipments of waste across the country. A user would be able to assess for any
generator (i.e., LQGs and SQGs) the types and quantities of waste they had recently
shipped to TSDFs across the nation. States would be able to assess the waste volumes
being shipped in and out of their State and from or to a given RCRA Site.
4) Biennially, or more frequently if required by State rule, LQGs (as the Federal minimum)
would be sent a summary verification report based on the information submitted by the
TSDFs describing the types and quantities of waste they had shipped. Implementers with
MST requirements will also be able to generate summary verification forms for their non-
LQG universe, as derived from reported TSDF waste receipt data.
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FINDINGS AND RECOMMENDATIONS
5) The LQGs would verify the shipment information and would also report the waste that
they had generated and managed on-site. This would be submitted to the implementing
agency, and subsequently to the national information system.
Benchmarking of existing implementations of this recommendation by the States of Ohio and
Texas provided the following information:
Survey Results
Two States that have used innovative approaches to collecting waste activity information were identified and
surveyed regarding their approach and experiences.
State of Texas
The Natural Resource Conservation Commission (TNRCC) currently requires all 200 TSDFs to electronically
report monthly their waste receipts at the shipment level. The data is input into an application called
STEERS for quality assurance and electronic reporting. Additionally the majority of their 800 LQGs use the
STEERS application for data submission annually. The data file is posted to a dial-up bulletin board by the
STEERS application.
TNRCC has seen a significant increase in data quality as a result of the quality checks in the application and
feels that the majority of the reporters like the application and find it convenient. It minimizes reporting due
to the data entry QA checks, and the reporters do not have to spend nearly as much time working with
TNRCC to correct data entry errors. Additionally, TNRCC estimates that they save approximately $50,000
yearly in data entry costs by using the electronic reporting system. They have also found that the turn
around time for data availability to organization staff has been cut significantly. Additionally, they have noted
that program staff have additional time to perform tasks that they previously did not have time to complete,
due to data entry and QA/QC follow-up issues.
TNRCC has many different uses for the data such as waste trending that is used for targeted outreach,
inspection planning and budgeting. In addition they use TSDF derived data to look at sites they otherwise
would not have knowledge of. For example, CESQG data from TSDFs is examined to ensure that the
generator is properly determining their generator status, They also use the data to work with all generators
for pollution prevention efforts. TNRCC has used the data for determining the quantity and types of wastes
that are coming into the state from across the country for trending and ensuring TSDF capacity and permit
compliance.
State of Ohio
The agency performs annual reporting from LQGs and TSDFs. Ohio has established a relationship in which
Michigan provides a listing of all wastes received that were generated in Ohio. Ohio then uses this data to
identify generators that are out of compliance. Examples include failure to report, or failure to identify waste
shipped to a TSDF (out of state). Ohio estimates that in the past they have found approximately 100 of such
violations yearly, of which 15-20% are a result of the Michigan derived data. Ohio has expressed interest in
visibility to other State's TSDF receipt data, as their generators send wastes to more than 200 TSDFs
nationwide. This data sharing is an example of the benefits a nationally available data system with frequent
reporting could provide. Implementing agencies can have the visibility to the waste that their generators
have shipped out of state to ensure compliance, identification for outreach as well as for support of revenue
structures. Currently the Michigan derived data is obtained in paper form, however a national repository
could provide advanced analysis features with reports tailored to capture such information.
Implementation of this improvement would realize the following benefits:
Provides more timely information about all hazardous waste shipments to States and Regions
for wastes shipped across the country.
Has potential to improve data quality on the part of TSDFs, as their data reporting will be
broken into smaller, more frequent submission increments. Smaller increments are easier to
QA/QC. The submission cycle is also frequent enough to allow data review while it is still
fresh and relevant.
Provides a potential improvement to the current TSDF reporting mechanism, which requires
that they manage and audit records for receipt of wastes for up to two years. Reporting the
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FINDINGS AND RECOMMENDATIONS
wastes soon after receipt will permit the TSDFs to verify and ensure the accuracy of their
data, as opposed to working with two year old receipt data.
Provides a more accurate indication of how effectively the waste is managed.
May significantly reduce the burden on manifesting States if they deem this approach an
acceptable alternative to their current manifest collection systems. Some States may opt to
cease collection of manifests from TSDFs, as they will be submitting their waste receipt data
to the implementer quarterly.
Reduces burden on LQGs by pre-populating their GM (or equivalent) forms with TSDF
reported data. The generator then confirms, corrects or appends to the data to reflect their
perspective of the hazardous waste information shipped.
Capture shipment level information for implementers to review. It has been suggested that
this level of detail is easier for the TSDFs to provide than aggregated receipt data on
generators. Views of aggregate data could be provided in the national repository.
Design Considerations
The following is a list of implications to be considered.
1) Significant effort required by EPA and States in modifying the reporting mechanisms and
developing new information systems.
2) The recommended improvement would have to consider and potentially incorporate the
recommendations from other related initiatives, such as electronic signature and electronic
data interchange standards.
3) Federal rule would be required to ensure that all TSDFs, including those without a RCRA
permit, send in waste receipt data electronically every quarter. This would be necessary to
ensure that a "national" picture of waste generation and management is provided.
4) Implementers that have developed customized information systems for RCRA data
management would have to modify their systems to interface with the national data
repository.
5) Some States would be concerned about possible loss of control if such an approach required
TSDF data to submit data directly to a national system without being quality assured by the
State first.
6) Common data quality standards would have to be agreed upon by all participants and
mechanisms would have to be built to ensure these standards.
7) Parties would have to agree upon a common time frame in which data would be made
available to the national information system. Excessive time lags would be unacceptable, as
other implementers would be depending on the data.
8) Some States have CBI restrictions on releasing information about a TSDF's clients. This
might result in a 'black hole' for some shipments going to those TSDFs.
9) The recommendation does not dismiss the generator from their responsibility to accurately
report the generation and management of their wastes. A common concern with the
recommendation expressed by commenting organizations was that generators should be
responsible for their own waste information. Implementation of the recommendation might
promote a reliance on the TSDF for their responsibilities.
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FINDINGS AND RECOMMENDATIONS
Feasibility Assessment
1) Further design this approach, survey TSDFs for their willingness to support it, and pilot the
concept to test its effectiveness.
2) Replace the current Biennial Reporting WR form with a regulatory requirement for TSDFs to
provide a slightly different set of information electronically on a more frequent basis.
3) Confirm that authorization requirements can be met through the workgroups that are
currently conducting electronic signature rulemaking.
4) Construct a new EPA/State information system for receiving TSDF quarterly files and a
National Repository for this shipment information, along with a regulator-only information
access component.
5) Restructure the Biennial Reporting GM forms to allow them to be pre-populated with the
waste shipment information.
6) The study should address the more "holistic" approach to capturing waste handling
information presented by the recommendation. It should consider the manifesting states
reporting structure, and this recommendation's potential for replacing this practice. The
potential for TSDFs to report all data elements included on a manifest should be considered.
Other Options Considered
The Team believes that the selected recommendation provides the greatest improvement in
information quality for the least increase in burden to both implementers and regulated
community. The following alternative solutions were considered.
1) Collect hazardous waste reports annually to remove 'blackout' years, and increase timeliness
2) Replace the Biennial Reporting forms with the collection of Manifests and separate on-site
management reporting
3) Collect two years of information biennially.
Dependencies
12) Confidential Business Information (CBI)
This is a critical dependency.
This recommendation attempts to resolve the issue of some TSDFs claiming their customer
generators as Confidential Business Information that would impact the completeness of the data
that would be available from TSDF reporting.
National Review Feedback
Although this recommendation was well supported by EPA and States, some States expressed
concern about the level of burden that the recommendation would impose on the reporting
community. Some of the concerned States were open to the concept of studying the feasibility to
obtain data on actual burden.
In contrast, some States felt that the recommendation would decrease the burden currently
imposed on handlers. This is especially true for those States that manifest. Handlers in this
situation submit manifests, as well as (at a minimum) Biennial Reports.
Several of the States indicated that they were uneasy using a verification form populated by
TSDF data for confirmation by generators. They felt that it is the generator's responsibility to
know and report their waste accurately, and that pre-population would remove this responsibility.
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FINDINGS AND RECOMMENDATIONS
EPA also had concerns about the internal costs of supporting the recommendation. These will
need to be addressed during the feasibility study.
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FINDINGS AND RECOMMENDATIONS
12) Confidential Business Information (CBI)
Summary
Develop and compile a clear national policy statement detailing for each of the data elements
designated as national, which are and are not likely to be substantiated as confidential business
information (CBI). This policy statement will facilitate the sharing of RCRA Site information in
a national system.
Program Need
During the information gathering sessions, PAA participants requested a more up to date and
expanded view of hazardous waste information. TSDFs claiming the identities of their customers
(generators) to be CBI would hinder access to this information. This would prevent visibility to
data for wastes shipped outside of their state boundary.
Problem Analysis
Although the practice is not widespread, some RCRA TSDFs have successfully claimed as CBI
the identity (name and EPA identification number) of the customers from whom they receive
waste shipments, on the basis that such information constitutes a customer list. States mask these
generator's EPA identification numbers with a dummy number in the national system. This
practice disassociates waste received data from its generator and prevents other States and EPA
from comprehensively tracking waste from cradle to grave across state boundaries.
The number of CBI claims varies from cycle to cycle, but it is not large: for example, in 1995,
less than 1% of the 800 TSDFs reporting claimed CBI on their "customer lists." These claims
prevent the public release of such information, but do not withhold it from the implementer.
However, there is no national standard or procedure for sharing and safeguarding confidential
information, except for the process used by EPA, which is primarily oriented to paper reports.
CBI protection of waste management information presents special concerns with respect to the
implementation of the PAA Team's recommendation to introduce quarterly electronic reporting
by TSDFs. If the actual identity of "confidential" generators is not visible to all using the system
it will be impossible to track wastes from cradle to grave. In these cases, regulators cannot use
TSDF reports to infer generation data about sites of concern.
Generally, State law governs the releasing (or confidentiality) of information, and since State
laws vary, there is a concern that, if an implementer shares with another State, data that is held as
confidential, it may be subject to release under the laws and procedures of the second State.
States handle CBI claims in a wide variety of ways.
Such CBI claims are not always challenged. There is no national guidance from EPA's Office of
General Counsel (OGC) on whether such information can in fact be deemed confidential. Lack of
uniformity can lead to inequity among TSDFs: some are able to keep "customer lists"
confidential, while others find that this information is made available to their competitors.
One State has a very "liberal" CBI state law in which all records in possession by a state agency
are pubic record, with the exception of specific correspondences of constitutional officers and
legislators personal records and open law enforcement issues. The business may claim certain
information as trade secrets. However, it is their policy that any materials submitted through the
required standard hazardous waste reporting may not be claimed as CBI.
Other States indicated that they "mask" or eliminate essential elements such as customer name,
EPA identification number and address, but they do not permit the claim for waste type
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FINDINGS AND RECOMMENDATIONS
information. They also release CBI material internally with warning of penalties if the
information is released outside the agency.
Most States are between these two extremes. Many discourage the claims or look negatively
upon them through strict evaluation or procedures such as questionnaires, and substantiation
making the filing of the claim less attractive. Others specifically denote in their state rules what
can be claimed CBI (e.g., manifest data cannot be claimed CBI). One sends the CBI request to
EPA for final approval.
Recommendation
Develop a clear national policy statement detailing whether the generator's EPA identification
number reported on the WR form can be substantiated as confidential business information. PAA
participants have indicated that there is much confusion over this issue, and a clear statement is
required nationally. Once provided with this policy statement implementers must routinely and
aggressively challenge CBI claims for such information.
The policy statement should be developed in such a way as to facilitate the sharing of generator
identities in a national system. Shipments of waste to States with stringent CBI policies, and
subsequent masking of generator identification runs contrary to the notion of tracking waste from
cradle to grave.
Much of the information declared as confidential is available through other indirect mechanisms
(e.g., from Manifest forms, or from generators' hazardous waste reports that identify the TSDFs
to which they ship their waste).
Given implementation of these recommendations, regulators will have national access to the
hazardous waste information needed to implement their programs. Additionally, a "level playing
field" will be developed in which all TSDFs are treated the same from State to State.
Design Considerations
1) The time that may be required to develop a nationally endorsed policy may be significant.
2) There is potential that a national policy may not be acceptable to all States, given that each
State may have its own CBI laws, and that States are not required to follow EPA Guidance
3) Ultimately, federal rule may be required to finally remedy the issue.
Other Options Considered
The Team believes that the selected recommendation provides the greatest improvement in
information quality for the least increase in burden to both implementers and regulated
community. The following alternative solutions were considered:
1) Seek a national policy allowing inter-agency sharing of CBI, but expressly disallowing its
release to the public.
2) Allow anyone to review information about the waste that was shipped from a generator to a
TSDF declaring CBI, but do not provide information about the TSDF that received it.
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FINDINGS AND RECOMMENDATIONS
13) Tracking Hazardous Waste Exports
Summary
Provide interface functionality to allow waste export data collected and tracked by OECA to be
made available to RCRA program users in national RCRA program information systems.
Program Needs
Authorized States are responsible for monitoring waste from "cradle to grave" and PAA
participants identified the need to know about waste generated in their State that is exported from
the country. For constitutional reasons, this information is collected by OECA at the national
level, bypassing State regulators. With access to this data States could undertake the same
analyses that are performed upon domestic wastes, such as compliance and enforcement and
targeted outreach for pollution prevention efforts. This data would also be used to confirm the
appropriate generator status and potentially assess fees. Border States have unique needs for
communication with their foreign counterparts. For example, the ability to identify generators
facilitates coordination of hazardous waste classification and inspection targeting at border
crossings. The overall program need is for a national picture and assessment on all wastes
handled in the United States, that is accessible to all implementers.
Problem Analysis
US generators of hazardous wastes are required to submit an Annual Export report detailing:
the exporter name, address and mailing label, calendar year covered
name and site address of each foreign consignee
by consignee for each waste, a description, waste codes, EPA ID of each transporter, total
quantity shipped, and number of shipments
Annual Export report data is submitted to OECA and is stored in a system called EXPORTS,
separate from Biennial Report and other hazardous waste data. Generators are not required to
submit generation data for exported wastes on the Biennial Reporting forms. However some
generators do complete the GM form detailing generation data for exported wastes. As a result,
exported waste generation data is not accurately and consistently captured in BRS. States,
therefore, do not have comprehensive access to all wastes generated within their jurisdiction but
exported from the country. Similarly, an integrated national picture of waste generation is not
readily available.
Recommendations
Integrate EXPORTS data into national RCRA program information systems.
This option presents an improvement with potentially no burden increase to the regulated
communities or implementing agencies. Additionally it will provide a mechanism for
implementers to communicate with their foreign counterpart, to facilitate tracking of wastes from
cradle to grave.
Design Considerations
1) The instructions for the Biennial Reporting forms will require amendment to explicitly
exclude reporting of exported wastes. Directions for this form request that "for wastes
shipped to ... foreign countries, if the facility does not have an EPA identification number,
enter 'FC' followed by the name of the country". This is in contradiction to current rules,
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FINDINGS AND RECOMMENDATIONS
which exclude export reporting on the Biennial Reporting forms. To date, voluntary
reporting of export data has been accepted to provide information that would otherwise be
unavailable.
2) Reconciliation of data elements would be required to integrate the two systems. For example
the Annual Export Report captures the number of shipments of a particular waste stream that
was exported from the country, while BRS does not capture this level of detail. Additionally,
if the WIN/INFORMED project defines a specific information need as being nationally
required, that information need would be supported with mandatory collection procedures.
For example, the source of waste is not currently captured on the Annual Export Report. This
would necessitate a rule change since the current data elements collected in the Annual
Export Report are detailed in Federal rule
3) In addition to information about the waste exported, PAA participants requested information
about the destination of the waste. Since foreign destinations of the waste do not receive a
unique EPA identification number, foreign receiving site address information would be
difficult to reconcile with other records for that site.
4) Individual shipment information may not be available for exported waste, as it is submitted as
totals for the year.
Other Options Considered
The Team believes that the selected recommendation provides the greatest improvement in
information quality for the least increase in burden to both implementers and regulated
community. The following alternative solutions were considered:
1) Continue to have Annual Export Reports submitted to OECA without data integration with
BRS.
2) Require reporting of exported waste generated in the Biennial Report.
FINAL REPORT PAGE: 65
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FINDINGS AND RECOMMENDATIONS
14) Tracking Imports of Hazardous Wastes
Summary
An indicator will be added to the Notification form to capture the activity of importing hazardous
waste. TSDFs will continue to report the EPA identification number of the importing agent as the
"generator" of the waste, but will also report the country of origin of the waste if other than the
United States.
Program Needs
PAA participants identified the need to differentiate between imported hazardous wastes and
waste generated domestically. This information will facilitate accurate generation and import
trending and associated oversight and inspection activities both nationally and for the importing
state.
Problem Analysis
All hazardous wastes transported into the United States must be imported through an import
agent, who assumes legal responsibility for the waste. Import agents who handle hazardous
wastes, currently apply for and receive an EPA identification number containing the prefix of the
state in which they do business. Current notification mechanisms do not include a means to
capture the specific activity of importing waste and importers are typically recorded as
generators.
This practice is problematic for the regulating State as it gives the appearance that the waste was
physically generated within their boundaries. As a result, waste generation totals are artificially
high for the State in question, as imported waste is counted as generated waste. The need to
differentiate between domestic generation and foreign generation is important and currently hard
to achieve.
Importing agents are currently not required to directly report the quantity of waste they have
received. There is a requirement to submit a notification of intent to import to EPA detailing the
proposed quantity. The TSDFs report the actual quantity of waste that they receive from a
"generator" (i.e., importing agent). However, the current TSDF reporting mechanism does not
provide the means to accurately determine that the waste was generated outside the country.
Recommendations
A reporting mechanism will be added to the Notification form to capture the activity of importing
hazardous waste. Adding this information on the Notification form would not exclude the
reporting of additional site activities (e.g., hazardous waste transporter).
The Team further proposes that the TSDF continue to report the EPA identification number of the
importer as the "generator" of the waste, but also report the country of origin if other than the
United States as indicated on the manifest.
Collecting the country of origin will permit implementers to derive that the waste reported by the
TSDF was imported into the country. For example: X quantity of waste was received at TSDF Y
from agent Z. The fact that agent Z imported the waste can be derived by the country of origin
for the waste and the activity of "Hazardous Waste Importer" on the agent's Notification form.
Implementing this suggestion will permit authorized programs to examine waste generation in
greater detail, with an understanding of the true origin of the imported wastes.
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FINDINGS AND RECOMMENDATIONS
Design Considerations
1) The requirement that agents report their hazardous waste importing activity is a minimal
burden increase. They are currently required to submit a notification form but the current
mechanisms do not accurately represent and capture their activities.
2) Current importers will have to be flagged as importers in current information systems.
Potential mechanisms to obtain this information include, requiring renotification by
importers, or deriving the activity through the request to import hazardous waste submitted to
OECA.
3) Information systems will have to be modified to clearly denote that the waste was not
generated in the United States. To resolve the issue of incorrectly counting imported waste in
a state's generation totals, current queries and reports will have to be modified.
4) Instructions on the current BRS forms, which direct that the TSDF report FC + Foreign
Country Name for wastes imported from a foreign country would need to be revised
5) The Team's recommendation will standardize the practice of reporting the import agent as the
generator, with the country of origin delineating foreign waste from domestic waste. The
explicit collection of the country of origin of the waste is a small burden increase to the
TSDF.
FINAL REPORT PAGE: 67
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FINDINGS AND RECOMMENDATIONS
15) Clarify Types of Hazardous Wastes to be reported
Summary
The Biennial Reporting requirements will be changed such that generators only report those
hazardous wastes used in determination of their generator status.
Program Needs
Implementers need to know the volumes and characteristics of hazardous waste generated and
managed in their States. However, since RCRA exempts certain waste management units and
processes from permitting and other substantive regulations, reporting of such wastes is
inconsistently implemented. As a consequence, there is confusion in the reporting community
between wastes that must be reported and ones that need not be. There is a national need for
clarity and consistency in the reporting of waste activity information and a connection between
RCRA regulatory authorities and program reporting mechanisms.
Problem Analysis
The reporting of hazardous wastes that are managed in units exempt from RCRA permitting has
been a longstanding issue in the Biennial Reporting process. There is confusion amongst
generators in determining the wastes that are to be reported on the Biennial Reporting forms.
This confusion is a result of the differences between RCRA regulations that limit the types of
wastes that should be used when making a generator status determination and the more expansive
list of wastes required by the Biennial Reporting forms.
RCRA regulations exclude the use of waste treated in exempt wastewater treatment units from the
determination of generator status. However, the GM form of the Biennial Reporting forms asks
the question "Did this site do any of the following to this waste... discharge to a sewer/POTW".
If they did discharge to a POTW the form requests that the generator detail the quantity and the
management method. Thus the contradiction, do not use waste treated in a wastewater treatment
unit in determining generator status, but do report the excluded waste if your generator status is
LQG.
This contradiction results in confusion for generators and represents a burden for both the
reporting generator and the program implementer. It is a burden for the generators as they are
required to report and monitor waste regulated under the Clean Water Act, and also are required
to report this waste on the Biennial Reporting forms for RCRA. It is a burden for the
implementer, as they have to provide assistance and clarification to the generator, as well as
collect, maintain and transmit the data to BRS for wastes that are monitored by another regulatory
program. The Clean Water Act maintains regulatory oversight by requiring that the generator
perform quantitative analysis of the constituents in the waste stream as well as volume of
discharge.
Recommendation
The Biennial Reporting form requirements should be changed such that generators only report
those hazardous wastes used in the determination of their generator status. Further, the Biennial
Reporting form instructions should be changed to clearly identify the wastes that are to be used in
making the status determination and associated recommended hazardous waste reporting. The
following is an example of text that might be used to detail the wastes that are to be counted and
those that will be excluded from the determination. This is not a proposal for language to be
included in the Biennial Reporting form instructions, it is for illustrative purposes only.
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FINDINGS AND RECOMMENDATIONS
COUNT AND REPORT: All quantities of listed and characteristic hazardous wastes that are:
accumulated on the property for any period of time before disposal or recycling, packaged
and transported off-site, placed directly in a regulated treatment or disposal unit on-site,
generated as still bottoms or sludges and removed from product storage tanks.
COUNT AND DO NOT REPORT: Wastes that are exported are to be used in the
determination of the generator's status, however, they are not to be reported using the
Biennial Reporting forms. This information is collected in the Annual Export Report
submitted by the generator.
DO NOT COUNT OR REPORT: Wastes that: are specifically exempted from counting (e.g.,
lead acid batteries that will be reclaimed, scrap metals that will be recycled, used oil,
universal wastes),
are reclaimed continuously on site without storing prior to reclamation,
are managed in an elementary neutralization unit, a totally enclosed treatment unit or a
wastewater treatment unit without being stored/accumulated first,
discharged directly to POTWs without being first stored or accumulated,
Such criteria should reduce the reporting inconsistency and result in significant burden reduction
for both generators and implementers.
Design Considerations
1) Changes to the quantities of wastes reported may effect analysis and comparisons to previous
Biennial Reporting cycles. This information could be gathered through other means such as
targeted surveys. Using this mechanism would allow the surveyor to target the specific
information required. Additional mechanisms may also be investigated to derive the
information from the Clean Water Act program. Information about constituents as well as
volume may be available.
2) Changes to the reporting forms, instructions and associated information systems will need to
occur. Additionally, outreach and training of both regulators and generators will be required
to ensure that both parties understand which wastes are now to be reported.
3) The management codes "M135-Direct Discharge to a POTW" and "M136-Direct Discharge
to surface water under NPDES Permit" would require amendment to remove the term
"Direct". It should be noted that this recommendation is compatible with the PAA Team's
recommendation concerning the streamlining of management method codes. These codes
would continue to be used, for example, when hazardous wastes, counted in the status
determination, are trucked off site for discharge to a POTW.
4) This recommendation addresses a portion of the "exempt unit issue". It will address those
wastes that are used in the determination of ones generator status. Wastes discharged to a
POTW without prior accumulation or storage are not to be used in the determination of
generator status. A POTW is an exempt unit, however the recommendation does not make
mention to other exempt units such as injection wells. As these other exempt units are not
explicitly excluded in the determination of generator status, it is assumed that wastes
discharged to these units are used in the determination of generator status and would be
reported. This is an important point given that several PAA participants indicated the need for
information on other exempt units such as underground injection wells, as they are not
regulated under other regulatory programs like wastewater is.
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FINDINGS AND RECOMMENDATIONS
Other Options Considered
The selected recommendation provides the greatest improvement in information quality for the
least increase in burden to both implementers and regulated community. The following
alternative solutions were considered.
1) Require reporting of the generation of all hazardous wastes by LQGs whether managed in
exempt units or not.
2) Require reporting of the activity of discharging aqueous hazardous waste to POTW/NPDES
outfalls on the Notification form.
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FINDINGS AND RECOMMENDATIONS
16) Streamline Source, Origin, Form, and Management Codes
Summary
The following three recommendations will be implemented to streamline and improve the
usefulness of reported waste information:
1) Current source codes will be consolidated, regrouped and merged with the current origin
codes to provide a simpler coding structure.
2) Form codes will be revised resulting in a reduction from 89 to 32 codes.
3) Management Method codes will be revised to eliminate overlap with form codes.
Program Needs
One of the objectives of the WIN/INFORMED initiative is to introduce information management
changes that realize efficiencies through burden reduction. Burden reduction must be achieved,
while at the same time ensuring that program implementers and analysts are provided data at the
level of detail required to achieve their program objectives. A review of the information needs
identified by PAA participants suggests that the existing Source, Origin, Form and Management
codes could be modified to contribute to burden reduction goals, and present higher quality data,
while at the same time providing the required programmatic data.
In performing the analysis for the code revision the PAA Team attempted to reduce the number of
codes that handlers are required to understand and report, through code aggregation and
elimination of duplicate coverage.
Table 5: Waste Reporting Code Categories describes the information need categories identified
by PAA participants.
Source
Form
Management Method
Wastes from ongoing
production and service
processes
Intermittent and one-time
processes
Spills and accidental
releases
Remediation of past
contamination
Pollution control and
waste management
Inorganic liquids
Organic liquids
Inorganic solids
Organic solids
Sludges
Other
Disposal
Reclamation and recovery
Storage
Treatment
Table 5: Waste Reporting Code Categories
FINAL REPORT
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FINDINGS AND RECOMMENDATIONS
Combining Source and Origin Code
Problem Analysis
There is significant complexity in the way the existing Biennial Reporting source of generation
and origin codes are defined. This complexity is a result of the overlap in the coverage areas of
the two coding structures, which has led to a number of data quality and consistency problems.
Analysis of the 1995 Biennial Report data has shown that 96% of GM forms submitted included
an origin code and 94% a source code. Given the high response rate, it is essential that
respondents understand their usage and the complexities and overlap be resolved.
The 1995 Biennial Report used the following five origin codes:
1. As-generated process-derived waste.
2. Cleanup, spills, remediation, and equipment decommissioning.
3. Residual from on-site management of a non-hazardous waste.
4. Received from off-site and NOT recycled or treated on-site.
5. Residual from on-site management of a hazardous waste.
The same report used some sixty source codes in the following seven high-level source groups:
Group 1 (A01-A19) Cleaning and degreasing
Group 2 (A21-A29) Surface preparation and finishing
Group 3 (A31-A49) Processes other than surface preparation
Group 4 (A51-A60) One-time and intermittent production-related processes
Group 5 (A61-A69) Remediation-derived waste
Group 6 (A71-A89) Pollution control and waste treatment processes
Group 7 (A91-A99) Other processes
Conceptually, there is significant overlap between the origin and source coding structures.
Origin 1 (as-generated) subsumes Source Groups 1, 2, and 3 (production and service
processes).
Origin 2 (cleanup, spills, etc.) generally includes Source Groups 4 and 5 (intermittent, one-
time and remediation).
Origin 4 (received from off-site, no TDR) has no corresponding Source Group.
Source Group 7 (other non-production processes) has no analogue Origin.
Wastes from Source Group 6 (pollution control and waste treatment) may have either Origin
5 (residual from managing hazardous waste) or Origin 3 (residual from managing non-
hazardous waste) and may also be viewed by some reporters as an integral part of their
production processes.
An example of the latter is K061 baghouse dust: it is definitively described by Source A78
(air pollution control devices), but is obviously tied to the production of steel. Is this more
appropriately an example of a residual from on-site management of a hazardous waste
(Origin 5) or of as-generated process-derived waste (Origin 1)?
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FINDINGS AND RECOMMENDATIONS
Correlation
The overall correlation at a high level between reported origin and reported source is good. Some
inconsistencies do appear, due in part to confusion on the part of reporters and the more specific
and complex nature of the source coding structure. Additionally, respondents often provide
ambiguous answers to some questions, typically by choosing "other" categories. In the 1995
Biennial Report, each source code group contained an "Other - specify in comments" choice and
overall, 20% of GM forms indicated one of these, including 4% using Source Code A99 (Other
Processes - Other).
Fulfilling Information Needs
Source codes in groups Al through A3 (cleaning and degreasing; surface preparation and
finishing; and other production processes) meet the PAA need to identify wastes from ongoing
generation from production and service processes and source codes in group A6 (remediation-
derived waste) meet the PAA need to identify waste generated by remediation of historic
contamination. Group A7 (pollution control and waste treatment) addresses the PAA need to
identify wastes that are residuals from active on-site management of hazardous waste. However,
Group A5 (one-time and intermittent production-related processes) includes specific codes for
both wastes generated once or sporadically and wastes generated by current spills or accidental
releases, two categories that should be distinct. Group A9 (other processes) does not correspond
to the information needs articulated by the PAA participants.
Recommendation
The current source codes will be consolidated, regrouped and merged with the origin codes to
provide a simpler coding structure. It is intended that this approach will provide more meaningful
and consistent responses, reduce at least some of the reporting burden, and support the high-level
information categorization needs of the PAA participants. This scheme would reduce the number
of choices from 60 to 30 and the groups from 7 to 5. The PAA participants feel that this proposal
will result in increased data accuracy and quality through reduced variation in response.
Table 6 provides a proposed coding structure, which is intended to provide a basis for evaluation
and discussion. Analysis and confirmation of these codes will take place during the next phase of
the project.
Code Source of Generation Old Code(s)
Wastes from ongoing production and service processes
GO 1 Dip, flush or spray rinsing A04, A05, A06, A31
G02 Stripping and acid or caustic cleaning AO1, A02, A03
G03 Plating and phosphating A22, A23, A24
G04 Etching A27
G05 Metal forming and treatment (pickling, heat treating, etc.) A25,A26,A40
G06 Painting and coating A21,A29
G07 Product and by-product processing A32,A35, A41, A49
G08 Cleaning out process equipment A09
G09 Removal of spent process liquids or catalysts A36, A37
G10 Removal of tank sludge, sediments or slag A38, A39, A60
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FINDINGS AND RECOMMENDATIONS
Gl 1 Solvent or product distillation or recovery
G12 Other production or service-related processes
Intermittent and one-time processes
G21 Discarding off-specification or out-of-date chemicals or products
G22 Lagoon or sediment dragout and leachate collection
G23 Process equipment change-out or discontinue use of equipment
G24 Oil changes and filter or battery replacement
G25 Other one-time or intermittent processes
Spills and accidental releases
G31 Accidental contamination of products, materials or containers
G32 Cleanup of spill residues
G33 Leak collection and floor sweeping
G34 Other cleanup of current contamination
Remediation of past contamination
G41 Closure of hazardous waste management unit under RCRA
G42 Corrective Action at a solid waste management unit under RCRA
G43 Remedial Action or Emergency Response under Superfund
G44 State-program or voluntary cleanup
G45 Underground storage tank cleanup
Pollution control and waste management
G51 Air pollution control devices
G52 Laboratory analytical wastes
G53 Wastewater treatment
G54 Hazardous waste management - indicate management method
Table 6: Proposed Source Codes
A33,A34,A73
A49, A29, A07, A08,
A19
A57, A58
A79, NEW
A56
A54, A55
A59,A60,A91
NEW
A53
A51,A92
NEW
A64
A63
A61,A62
A93, NEW
A65
A78
A94
A75
A71-A74,A76,A77,
A79, A89
Design Considerations
1) Revision of the source/origin coding structure could cause difficulty in providing historical
trending and analysis, since the number of code options has been decreased by 50%.
2) Program implementers and analysts would require training and thorough documentation of
old versus new coding structure.
3) There is the potential for the loss of detail through the aggregation of codes. This impact
should be minimized given that changes were elicited from code overlap and duplication.
4) Targeted surveying could be used to gather additional data for those implementers that
require additional data. PAA participants and commenters indicated that surveying is a
reliable method to capture information while minimizing burden for the entire reporting
universe.
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FINDINGS AND RECOMMENDATIONS
5) Comment from the regulated community is necessary to ensure, that the proposal will
represent a burden reduction for them, and to ensure that they support the proposal.
6) Additional analysis and input will be required during the Design phase, for the
recommendation to confirm the technical aspects of the proposal. The codes presented in the
recommendation represent a first draft, for further refinement.
7) Changes to coding structures will have impacts on implementer systems, as well as private
information systems used by industry. Changes will have to be made to these systems to
reflect the new coding structure, as well as providing mechanisms for cross-walking old and
new codes.
Simplify Management Method Codes
NOTE:
The term management method has been used throughout this report to refer to the system type
used to treat, store or dispose of the waste.
Problem Analysis
Although there is no conceptual overlap, the current management method coding structure
duplicates and conflicts with the use of form codes. For example, there are five distinct
management method codes for waste incineration, depending on the physical form of the waste
being incinerated. This leads to such reporting "anomalies" as a waste of the physical form B201
(concentrated solvent-water solution) being managed by system M043 (incineration - solids). It
is impossible to know which of these conflicting data points is accurate.
Recommendation
The existing management method coding structure will be revised to eliminate overlap with form
codes as represented in Table 7. This coding structure is based in part on analysis of the
frequency and perceived accuracy with which different management method codes were reported
in the 1995 BRS data. The impact of the LDR treatment codes was also considered in
establishing this list. This reduces the detailed list from 65 entries to 28 and the high-level groups
from 14 to 4. This proposal will result in increased data accuracy and quality through reduced
variation in response with a notable decrease in burden for both the handlers as well as program
implementers.
Code Waste handling method Old Code(s)
Disposal
HI 01 Deepwell or underground injection Ml 34
H102 Discharge to sewer or POTW or surface water under NPDES M135, M136
HI 03 Land treatment or application Ml 31
H104 Landfill M132,M137
Reclamation and recovery
H301 Energy recovery - use as fuel M051-M059
H302 Fuel blending M061
H303 Metals recovery MO 11-MO 19
H304 Solvents recovery M021-M029
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FINDINGS AND RECOMMENDATIONS
H305 Other recovery or reclamation for reuse (specify in comments)
Storage
H501 Storage or transfer (no treatment or disposal)
Treatment
H701 Absorption
H702 Adsorption
H703 Air or steam stripping
H704 Biological treatment
H705 Chemical oxidation
H706 Chemical precipitation
H707 Chemical reduction
H708 Cyanide destruction
H709 Dewatering
H710 Neutralization
H711 Evaporation
H712 Incineration - thermal destruction
H713 Macroencapsulation
H714 Phase separation
H715 Settling or clarification
H716 Stabilization or chemical fixation
H717 Wet air oxidation
H718 Other treatment (specify in comments)
M031-M039
M141
M103
M082, M092, M103
M083
M081,M091
M075
M071,M072,M074,M077
NEW
M073
M101,M102,M104,M109
M121
M122
M041-49
Ml 12, NEW
M124
M123
Mill
M076, M084, M093
M078, M079, M085, M089,
M094,M089,M099,M119,
M125,M129
Table 7: Proposed Management Method codes
Design Considerations
1) Revision of the management method coding structure could cause difficulty in providing
historical trending and analysis. The number of code options has been decreased by 56%.
2) Program implementers and analysts would require training and thorough documentation of
old versus new coding structure.
3) There is the potential for the loss of detail through the aggregation of codes. This should be
minimized since the changes were elicited from code overlap and duplication.
4) Targeted surveying could be used to gather additional data for those implementers that
require additional data. PAA participants and commenters indicated that surveying is a
reliable method to capture information while minimizing burden for the entire reporting
universe.
5) Comment from the regulated community is necessary to ensure, that the proposal will
represent a burden reduction for them, and to ensure that they support the proposal.
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FINDINGS AND RECOMMENDATIONS
6) Additional analysis and input will be required during the program system design phase for the
recommendation, to confirm the technical aspects of the proposal. The codes presented in the
recommendation represent a first draft, for further refinement.
7) Changes to coding structures will have impacts on implementer systems, as well as private
information systems used by industry. Changes will have to be made to these systems to
reflect the new coding structure, as well as providing mechanisms for cross-walking old and
new codes.
Other Options Considered
Replace current management method codes with Handling Codes For Treatment, Storage, and
Disposal Methods (40CFR 264 Appendix II Table 2).
Simplifying Form Codes in the Biennial Report
Problem Analysis
The physical form of a generated waste is collected on the Biennial Reporting forms using 89
specific codes in 9 high-level groups.
This is the most elaborate of the Biennial Reporting form coding structures and the most difficult
to analyze. It appears to be prone to error and ambiguity.
Recommendation
Table 8 presents the revisions to be made to the current list of form codes. The improvement
reduces the number of form codes from 89 to 32 with 6 high level groups. This improvement will
result in increased data accuracy and quality through reduced variation in response with a notable
decrease in burden for both the handlers as well as program implementers.
Inorganic liquids
C01 Acid solution
C02 Aqueous waste
COS Caustic solution
C04 Spent acid
COS Other inorganic liquid (specify in
comments)
Organic liquids
Cll Concentrated solvent
C12 Halogenated (e.g., chlorinated) solvent
C13 HalogenatedVnon-halogenated solvent
mixture
C14 Non-halogenated solvent
C15 Oil-water emulsion or mixture
C16 Waste oil
C17 Other organic liquid (specify in comments)
Inorganic solids
Organic solids
C31 Halogenated organic solids
C32 Non-halogenated organic solids
Sludges
C41 Drillings and other muds
C42 Oily sludge
C43 Resins, tars or tarry sludge
C44 Wastewater treatment sludge
C45 Other sludges (specify in comments)
Other
C51 Compressed gases
C52 Lab packs
C53 Liquid mercury
C54 Waste containing asbestos
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FINDINGS AND RECOMMENDATIONS
C21 Adsorbents, filters or spent carbon
C22 Ash
C23 Batteries and parts
C24 Contaminated soil
C25 Metal salts/chemicals
C26 Metal scale, filings
C27 Other "dry" ash, slag or thermal residue
C28 Reactive salts/chemicals
C29 Scrap metal
Table 8: Proposed Form Codes
Design Considerations
1) Revision of the coding structure could cause difficulty in providing historical trending and
analysis. The number of code options has been decreased by 64%.
2) Program implementers and analysts would require training and thorough documentation of
old versus new coding structure.
3) There is the potential for the loss of detail through the aggregation of code. The Team has
attempted to minimize this impact and ensure that changes were elicited from code overlap
and duplication.
4) Comment from the regulated community is necessary to ensure, that the proposal will
represent a burden reduction for them, and to ensure that they support the proposal.
5) Additional analysis and input will be required during the Design phase for the
recommendation, to confirm the technical aspects of the proposal. The codes presented in the
recommendation represent a first draft, for further refinement.
6) Changes to coding structures will have impacts on implementer systems, as well as private
information systems used by industry. Changes will have to be made to these systems to
reflect the new coding structure, as well as providing mechanisms for cross-walking old and
new codes.
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FINDINGS AND RECOMMENDATIONS
17) Removal of Data Elements from Biennial Reporting forms
Summary
A number of fields currently collected on the Biennial Reporting forms appear to no longer be
required and should be removed.
Program Need
During the PAA, participants identified the information needs required to support RCRA and
implement their authorized programs. The intent of the exercise was to capture the program's
data needs, without reference to current forms and collection mechanisms. A key objective of the
WIN/INFORMED initiative is to support burden reduction efforts through removal of form fields
that are not necessary to support current program activities.
Mixed Radioactive Waste Indicator
Problem Analysis
The Biennial Reporting forms currently request that LQGs reporting waste generation and TSDFs
reporting waste receipt, indicate whether the waste was previously mixed with nuclear source,
spent nuclear or by-product material, as defined by the Atomic Energy Act of 1954, as amended.
Response to this form element is currently optional providing an incomplete view of the affected
reporting universe.
However, it is necessary to identify those involved in radioactive waste activities for analysis
purposes. The PAA Team felt that the need should be met by identifying the RCRA sites
performing the activities, rather than by requiring detailed reporting at the waste stream level.
Recommendation
The mixed radioactive flags will be removed from the GM and WR forms. As a result, this
element will not be collected at the individual waste stream level of detail. Removal of this
element from the GM and WR form will support burden reduction goals.
A new data element will be added to the Notification form to capture the activity of handling
mixed radioactive waste. This will meet the need to know who is performing these activities.
This will also allow implementers to know which SQGs are generators of mixed radioactive
wastes. The current mechanism for collecting this information is through Biennial Reporting,
which SQGs are not required to perform. Providing this activity flag on the Notification form
will provide a more complete picture of the universe of generators of this waste. This will be
helpful in targeting for inspections and outreach
If more specific information is required, handlers should be surveyed based on the required
notification element (e.g., using a 3007H survey). This will result in better quality data than
collection of optional data reported on the GM and WR forms. Additionally, comprehensive
identification handlers of mixed radioactive wastes through the Notification form may facilitate
information exchange with other regulatory agencies, such as the Nuclear Regulatory Comission.
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Design Considerations
1) Any users of this data may have to adapt their collection and analysis mechanisms to fit the
proposed improvement.
2) Shifted reporting burden from the GM and WR forms (although optional) to the Notification
form. This burden will be minimized as the data collection is at the facility level, rather than
on the individual waste stream level.
3) OSW currently uses mechanisms and authority provided by RCRA and the Biennial Report,
to require this information of DOE sites. Other regulatory mechanisms and agreements will
require development, to continue the collection of this mechanism. To provide ample time
for development, it has been agreed by the PAA team that this improvement will not be
implemented until after the 2001 reporting cycle.
4) Some implementers have large nuclear facilities in their jurisdiction and want to continue the
collection of this information at the waste stream level. As a result, it has been determined
that national information systems will have to provide for collection of this information, as a
shared need.
Dependencies
8) Add Additional Data Elements to Notification Form
This is a critical dependency.
This recommendation includes the addition of a data element to the Notification form to capture
the fact that the RCRA Site is engaged in generation or management of mixed radioactive wastes.
If the activity flag is not added to the notification form, mixed radioactive flag cannot be removed
from the GM/WR forms. PAA participants expressed a clear need for information on mixed
wastes regardless of the level of reporting.
Point of Measurement
Problem Analysis
The Biennial Reporting forms currently inquires of any LQG reporting waste generation (using a
GM form) to indicate using one of the following four codes, whether the waste being reported
was mixed with other wastes prior to being measured or estimated. Response to this form
element is optional.
1 The hazardous waste was not mixed with any other waste prior to being measured.
2 The hazardous waste was measured after mixing with other hazardous wastes only
3 The hazardous waste was measured after mixing with non-hazardous wastes only
4 The hazardous waste was measured after mixing with other hazardous wastes and with non-
hazardous wastes
This data element is intended to support the designation of a specific waste produced by a
generator. However, PAA participants identified no significant need for this information.
Additionally, due to confusion on the part of the generator with respect to this element, the data is
often of questionable quality especially given the element's optionality.
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It has been suggested that this data is useful when attempting to identify fake waste minimization
activities. However, given the questionable quality of the reported data, the use of this data in
waste minimization analysis is of limited use.
Recommendation
Since the "point of measurement" data element appears to meet no current information need, it
will be removed from the current GM data collection forms and from the associated national
information systems. Removal of this element will reduce burden for both the generators and the
implementers who have to explain its use.
Implications
This data element will not be available to those program staff who might use it for waste
minimization analysis. This element may continue to be collected as an organization specific
element if required.
SIC Code
Problem Analysis
The collection of SIC code at the waste stream level was not identified as an information need,
especially given the proposal to add NAICS codes to the Notification form.
The Biennial Reporting GM form requests that respondents provide the overall SIC code for the
site, rather than the SIC code for the process(s) generating the waste reported on the individual
GM forms. Previously, each GM form captured the SIC code for the associated generating
process, but this requirement has been dropped. However, given no current mechanism for
collection of the SIC codes, the form element was kept on the GM form, with a change to the
instructions requiring, collection of the facility-wide SIC code. Thus a respondent may submit
several GM forms all with the same SIC code, as the same information is captured several times.
Recommendation
Remove the SIC code form element from the Biennial Reporting GM form.
Supplying SIC data on the GM form is currently optional. However, the collection of the NAICS
data through the Notification form will be mandatory and will improve the quality and confidence
in the data.
Dependencies
8) Add Additional Data Elements to Notification Form
This is a critical dependency.
Removal of the SIC codes from the waste reporting forms must be replaced by the collection of
some equivalent information on the Notification form.
Off-Site Availability
Problem Analysis
The Biennial Reporting forms use the off-site availability data element to indicate whether the
off-site facility is a commercial TSDF, or is only permitted to accept wastes from firms owned by
the same company. Completion of this form element is currently optional.
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PAA participants did not indicate any program uses for this information.
Recommendations
Remove the off-site availability form element from the Biennial Reporting forms and from
associated data systems, since this information is derivable from TSDF submitted data.
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FINDINGS AND RECOMMENDATIONS
18) Streamline Unit of Measurement Reporting
Summary
Waste quantities should be reported in weight units only, to reduce conversion errors and
confusion on the part of the regulated community.
Program Needs
PAA participants indicated that they have two needs specific to units of measurement:
The need for data that accurately represents the actual quantity of waste being generated,
transported or managed.
The need for consistency in the units of measurement meta-data used to describe waste
quantities.
A common unit of measurement provides consistency and facilitates trend analysis, reporting to
the public, legislature, and special interest groups.
Problem Analysis
PAA participants generally indicated a low level of confidence in the density data submitted by
the regulated community. Participants stated that they have experienced very inaccurate reported
density values or even a single density value for all reported waste.
The density data is used to perform unit conversions (e.g., volume to weight). Thus inaccurate
density data results in incorrect unit conversions and can skew data for analysis. One PAA
participant estimated that 20 % of all data quality problems requiring follow up contact with a
RCRA Site result from confusion over units or measure and density. Some handlers do not have
the facilities to measure density and use a standardized density value. Standardized densities
assume pure material while wastes are typically a mixture or have been changed in some manner.
Thus the use of a standard density is inappropriate.
There is also inconsistency across States in the implementation of reporting units. Some States
have mandated reporting in a standard unit (e.g., weight), while other States permit reporting in
many different units. When comparing waste volumes, the units must be converted to a
standardized unit. The inconsistency between States in the use of collection and conversion
methods has caused discrepancies to occur when comparing inter-state shipments.
Recommendation
Waste quantities must be reported in weight units only. Density data elements will be removed
from the Biennial Reporting forms and all associated information systems.
This recommendation will result in better quality data for comparison and analysis. The
recommendation will result in consistent reporting across States, and will facilitate State to State
analysis since TRI data is reported in pounds this improvement will facilitate data analysis
between the two reporting systems. The improvement will also simplify reporting generally.
Design Considerations
1) The availability of scales for weight determination poses a potential issue for the
recommended option. Some handlers may still convert from volumetric units requiring the
use of density data. Input from the regulated community should be solicited concerning this
recommendation, to ensure that it is a workable option for them.
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FINDINGS AND RECOMMENDATIONS
2) The recommended option will not provide visibility to the density used in the conversion,
which may have some implications for reconciling generator and TSDF data. However,
requiring reporting in weight units will discourage conversion across media, minimizing
reporting error.
3) The design team should examine the possibility of requiring that quantity be reported in
weight units on the manifest. This will encourage the use of weight units throughout the
transportation process, and discourage weight/volume conversions.
Other Options Considered
The Team believes that the selected recommendation provides the greatest improvement in
information quality for the least increase in burden to both implementers and regulated
community. The following alternative solutions were considered.
1) Reduce the UOM on the BRS Forms to pounds, gallons and cubic yards.
2) Drop density as a required element and use a standard density value with the assumption that
all wastes have the same density.
3) Drop density as a required element and develop standards for waste densities by industry and
waste code to facilitate conversion.
4) Report quantities by media, each media with its own standardized UOM.
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19) Issue guidance on TSDF nomenclature
Summary
A clearly defined set of terms is recommended for adoption by the RCRA program when
referring to TSDFs.
Program Need
Knowing about RCRA Sites that treat, store or dispose of hazardous waste is a central RCRA
program need. The term TSDF is often used when asking questions about regulated RCRA Sites
that manage waste. However, there appear to be different ways of categorizing such sites, which
result in very different answers. These distinctions are important to include in a definition of what
a "TSDF" should be assumed to be.
PAA participants also clearly stated the need for the RCRA program to be able to determine
whether a site receives and manages waste from other RCRA Sites (offsite wastes), and also need
to understand how waste is managed at the management unit level.
Problem Analysis
One of the most frequent Freedom of Information Act (FOIA) requests is for a list of TSDFs
within a particular State or Region. While there is a very general, high level category of RCRA
Sites that have TSDF activities, the typical information request is usually focused on a subset of
that group. To respond to these requests, the information needed must first be clarified. For
example, are we interested in TSDFs who are operating, closed, or under a post-closure permit,
permitted or in interim status; or commercial, non-commercial or captive TSDFs?
Currently some general information about the type of management activity that a RCRA Site
performs is collected on the Notification form: more specific information is only captured in the
site's permit application.
Although this issue is primarily a reporting issue, there may also be confusion stemming from
how the current system tracks TSDFs. There are at least three different structures for capturing
TSDF categories in RCRIS. Two of them are derived from specific information on TSDF units.
This unit level information drives reporting of TSDF categories on program specific groups
(subject to corrective action) and on the separate treatment, storage and disposal reporting
universes. The other structure is a facility-level flag that is entered based on notification or Part
A information.
Recommendation
Future systems should distinguish operating, closed, post-closure, commercial, non-commercial,
captive, treatment, storage, and disposal at the unit level. These reporting options should not be
either/or choices for each category. Instead, they should allow any combination of these. In
addition, this reporting mechanism should also allow ad-hoc development of the less frequently
requested TSDF categories (e.g., clean-closed).
The following definitions for both the broad high level TSDF category and the most frequently
used sub-categories of TSDFs should be used (operating, closed, post-closure, commercial, non-
commercial, captive, treatment, storage, disposal, combustion and miscellaneous):
Operating A unit that currently treats, stores and/or disposes of hazardous waste.
(Note: Permitted/Interim Status should be an additional select category.)
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Closed
Commercial
On-Site
Captive
Post-closure
Treatment Unit
Storage Unit
Disposal Unit
Miscellaneous unit
A unit that no longer operates and has been closed in accordance with
RCRA 40 CFR 264/265 Subpart G or equivalent State regulations, by
removal of wastes.
A unit that receives hazardous waste from off-site for processing and
which charges or is charged a fee for the processing service. This
category includes both "limited" and "non-limited" commercial facilities.
A unit that treats, stores or disposes only of hazardous waste initially
generated at that facility.
A unit that receives waste from off-site but only from another facility
controlled by the same owner/operator (e.g., UNC-Chapel Hill receives
waste from UNC-Wilmington.)
A unit that is closed with waste in place and has ongoing requirements
under a post-closure permit, post-closure plan or enforceable
order/agreement.
A hazardous waste management unit where hazardous waste is processed
by any method, technique, or process, including neutralization, designed
to change the physical, chemical, or biological character or composition
of any hazardous waste so as to neutralize such waste, or so as to recover
energy or material resources from the waste, or so as to render such
waste non-hazardous, or less hazardous; safer to transport, store, or
dispose of; or amenable for recovery; amenable for storage, or reduced in
volume. These units have a Txx unit designation as listed under 40 CFR
Part 264, Appendix I. An important subset of Treatment are combustion
facilities: Boiler and Industrial furnaces (BIF) and Incinerators. The unit
designation codes for these units are: Incineration Units T06 - T18, BIF
Units T80-T93.
A hazardous waste management unit where hazardous waste is contained
for a temporary period, or for a period of years, in a matter which does
not constitute permanent disposal. These units have a Sxx unit
designation as listed under 40 CFR Part 264.
A hazardous waste management unit where hazardous waste has been
permanently discharged, deposited, injected, dumped, spilled, leaked, or
placed into or on any land or water so that the hazardous waste or any
constituent thereof may have entered the environment or have been
emitted into the air or discharged into any waters, including ground
waters. These units have a Dxx unit designation as listed under 40 CFR
Part 264. This group excludes units that have a post-closure permit.
A hazardous waste management unit where hazardous waste is treated,
stored, or disposed of and that is not a container, tank, surface
impoundment, pile, land treatment unit, landfill, incinerator, boiler,
industrial furnace, underground injection well with appropriate technical
standards under 40 CFR Part 146, containment building, corrective
action management unit, or unit eligible for research, development, and
demonstration permit under Section 270.65. Examples include, open
detonation or open burning units. These units have an Xxx unit
designation as listed under 40 CFR Part 264.
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FINDINGS AND RECOMMENDATIONS
Information system functionality should be developed that allows a requestor to specifically
define what types of TSDFs they are requesting information on starting with the list above as a
standard and then allowing ad-hoc requests if necessary. This should be available for any system
where people are requesting information on TSDFs.
Since all TSDF activity occurs at the unit level information should be tracked and reported for
each unit. This will include whether the site is authorized to receive waste commercially at that
unit. The following design project will consider the optimum mechanism for collection of this
information given that unit level information is not collected by the Notification form. The
current use of a facility level flag to indicate TSDF activity will be reviewed and a new activity
definition mechanism will be designed.
Design Considerations
1) Collection of treatment, storage or disposal activity information on the Notification form and
instructions must be carefully designed to meet the need to distinguish such sites while
accommodating the fact that this information is determined at the unit level and unit level
information is not collected by the Notification form.
2) Supporting information system changes.
3) Need to educate regulated community and implementers.
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20) Implement standard definitions for programmatic TSDF universes
Summary
A standard set of definitions has been proposed to categorize and simplify the use of "universes"
or groupings of regulated sites to meet program management needs.
Program Need
The RCRA program often needs to highlight certain groups of regulated sites for specific
program management considerations. These groups, or universes, are used to manage the
permitting/closure/post-closure, enforcement, and corrective action programs. The universes that
support these areas are different from other RCRA universes such as large quantity generators,
because they are derived from management unit and facility level status-type information defined
by program staff as opposed to being directly identified by the regulated community.
A clear definition of certain universes of RCRA Sites is required to support the current
tracking/reporting needs of the program. This includes the universes needed by implementers to
manage the program (e.g., permit workload universe) and the universes needed for national
reporting such as the Baseline Universes for reporting under the Government Performance and
Results Act (GPRA).
In addition to supporting program management functions, the universe definitions are also helpful
to provide standard reporting capabilities for information that is frequently requested by the
public or other programs. Having standard reports saves time in responding to requests for
information and also provides for national consistency for certain reports. This need tends to be
more critical for EPA headquarters and regional offices.
Problem Analysis
The existing universe definitions are perceived to be complex and the derivation algorithms are
poorly understood by many program staff. Several of the existing definitions also "overlap" such
that a single RCRA Site may be found in more than one universe. This can lead to increased
confusion.
Process
A small sub-group from the PAA Team was formed to focus on the needs for programmatic
universe definitions. This TSDF Universe Group (TUG) reviewed the existing programmatic
universes and developed a draft set of revised universes based on current program priorities and
their experience with the problems using the current universes. The TUG team developed fact
sheets for each universe to facilitate review of the universes and to serve as an aid once the
universes were finalized. These fact sheets provide a formal definition for each universe and
describe the programmatic uses of the universe and its derivation from the database. In addition
to the universe specific fact sheets, a guideline for each broad area (e.g., permitting/closure/post-
closure) was developed to explain how the universes fit together for that program area and how
the proposed universes are different from the current ones. Once the fact sheets were drafted, the
team participated in conference calls with State and Regional RCRA programs to get feedback on
the revised universes.
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Recommendations
A number of revised universe definitions are proposed to help direct future RCRA program
management activities. These may be found in Appendix V together with the supporting fact
sheets that have been developed.
The universes cover permitting/closure/post-closure, enforcement, and corrective action. A major
part of this effort is to formalize the definitions for the permitting, post-closure and corrective
action Government Performance and Review Act (GPRA) baseline universes. The facilities
making up each of the Baseline universes were already defined by the program, so the job for the
TUG team focused on formally documenting the definition of each baseline universe and clearly
articulating the program usage of the GPRA universes.
The rest of the proposed universes are revisions to the existing programmatic universes. One of
the first decisions made by the team was to continue using the legal and operating status codes in
the database to identify and derive the universes. The Team believes this is the most effective
way of identifying universes based on facility level information. Then, the Team focused on each
set of universes for the three areas. For permitting/closure/post-closure, the State and Regional
implementers commented that it would be useful to retain the workload-type universes since
GPRA focuses only on a subset of all the facilities that were in the program as of October 1, 1997
and because the GPRA baselines will not change as facilities change. The workload universes
will allow the program to capture the current view of the permit track, closure track and post-
closure facilities. This feature will be especially critical for implementers who are trying to
directly manage these programs. The team determined that the "progress" universe is not being
used by the program and recommends dropping it.
The enforcement universes changed with the addition of two new universes. The first new
universe is designed to capture the operating facilities. This group is the highest priority for
annual inspections and is the principal universe being tracked by OECA. In addition to the
enforcement need, most FOIAs ask about operating facilities. The program has been using the
full CEI universe as a surrogate to meet these needs. The team believed the program needs
supported the development of a separate universe to specifically track operating facilities. The
current CEI universe is still available, although the name has been changed to address the
confusion created by the original name. The second new universe "Annual BOY Enforcement
Universe" is designed to identify facilities (TSDF, LQG and SQG) that are actively managing
hazardous waste and are a priority of the enforcement program. This beginning of the year
universe, which will consist of specific facilities, will show the RCRA's enforcement program's
activity throughout the fiscal year.
The Corrective Action program has been debating the structure of the universes for several years.
Under the WIN/INFORMED project, the team's task was to determine if the program needs had
changed, identify current needs, and determine how to modify the universes to meet those needs.
The most significant change results from GPRA making the GPRA Baseline universe the highest
priority for the corrective action program. In fact, concerns were raised during the
WIN/INFORMED process on whether the Team should even be looking at the other universes
because all resources needed to be focused on the GPRA facilities. However, since the
WIN/INFORMED project is tasked to look toward future needs as well, it was determined that the
basic program universes should also be evaluated.
There were many different types of concerns raised about the corrective action universes. They
can be broadly categorized into two distinct types: 1) disagreements with program priorities and
how the current universes reflect those priorities, and 2) concern over the complexity of the
universes and lack of clear definitions. Regarding the first issue, the TUG team attempted to
determine if the program still supported the same priorities that drove the development of the
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FINDINGS AND RECOMMENDATIONS
current universes. First and foremost, addressing the GPRA Baseline to meet the goals for 2005
must remain the program's focus and highest priority. However, the program has also publicly
committed that after addressing the facilities in the GPRA Baseline, the program will address the
remaining facilities in the current workload universe. Because of that commitment, OSW must
be able to continue to track this group of facilities and report to Congress, GAO, the OIG and
others on the progress toward this commitments.
Recognizing the need to continue to support tracking of workload facilities, it was determined
that the Team could address some of the other types of concerns with the existing universe
structure. Much of the complexity of the corrective action universes results from the duplication
and overlap between the "Subject to" and "Workload" universes. To alleviate the duplication, the
team is proposing to divide facilities into discreet universes instead of having facilities in multiple
universes. This configuration is intended to allow the program to report on the "workload"
facilities as needed but also make it easier for implementers to identify the correct universe for
each facility. The team has proposed definitions for each universe and has identified the
programmatic uses and how the universes will be derived from the database.
National Review Feedback
It was pointed out that the recommendation includes only three GPRA universe definitions and
that a fourth, the Annual BOY Enforcement Universe was not included in the PAA Team's
original recommendation. A working definition has been developed for this universe which may
be found with the other definitions in Appendix V. Additionally, an information need has been
added to the set of national information needs defined by the team to accommodate the
requirement to indicate that a RCRA Site is a member of this universe.
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FINDINGS AND RECOMMENDATIONS
21) Determine location coordinates for a RCRA Site
Summary
Provide address-matching functionality in national information systems to determine accurate
geographic location information from the location address.
Program Need
The increasing demand for place-based analysis is reflected in the need to specifically locate all
RCRA regulated sites. The demand from implementers, the public and other interested groups
for location based information is growing.
In the past, specific geographic coordinate information for a RCRA Site has only been collected
for TSDFs. Improvements in address matching software and global positioning systems (GPS)
technologies have provided increased opportunities for better locational tracking of all hazardous
waste and RCRA Sites.
The physical coordinates of a RCRA Site are clearly important information needs as indicated by
the EPA's adoption of the Locational Data Policy (LDP) in 1990. As stated in the March 1992
LDP guidance document, "Under this policy, collection and documentation of locational
information will be performed for all facilities, sites, monitoring points, and observation points
regulated or tracked by EPA under Federal environmental laws." Additionally, in the opening
paragraph of the April 11, 1994, Executive Order, locational information is recognized as
benefiting "..our stewardship of natural resources and protect the environment..." especially
given the capabilities offered by recent technological advances to acquire, distribute and utilize
such data.
Problem Analysis
Currently, the EPA's LDP is not well supported by the RCRA program. TSDFs seeking a permit
are required to report this information on the Part A Permit Application. Of the two national data
systems, only RCRIS captures latitude and longitude values but no information about the
determination method or accuracy of these values as required by the LDP.
Owners or operators often have difficulty securing precise geographic coordinates (in degrees,
minutes, and seconds) and therefore, do not always provide accurate, uniform, and complete
latitudes and longitudes for their facilities. Implementers have often found the coordinate
information to be inaccurate.
Based on the experience of other programs, requiring that coordinates be reported has not been a
very successful way to collect accurate data, and presents a significant burden. Some States have
invested in visiting each RCRA Site, using GPS units to collect high quality coordinates.
There is also an ancillary question about how many locational points should be collected. For
TSDFs, the coordinates of each waste management unit should be collected, as they may be fairly
spread out. For other RCRA Sites, if only one point is to be collected, what should it be - the
front door, the center of the site, or some other location?
Recommendation
The RCRA Site will be defined locationally by a specific location address if it is not available the
site may be defined by a description, or by geographic coordinates. Additionally, the specific
point used to locate the RCRA Site will be specified, for example, the map point of the address or
the site centroid.
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FINDINGS AND RECOMMENDATIONS
Locational data will be tracked for all RCRA Sites. RCRA information systems will include
automatic address-matching functionality to facilitate data entry by EPA and States.
Implementers would be free to use other methods, e.g., GPS to obtain locational data. Provide
implementers the option to record locational data at the unit level. Add data fields in keeping with
EPA's locational data standard for method, accuracy, description (MAD) meta-data. Eliminate
latitude and longitude data collection from the Part A Permit Application.
This option takes advantage of the current geospatial tools to obtain the coordinates for each
RCRA Site based on its physical address. Locational data for the front door of each RCRA Site
would provide data consistency and at the same time allow implementers flexibility for data
collection. Adding address-matching software that is easy to use would be inexpensive.
EPA HQ also would revise the Part A Permit Application to remove the geographic coordinates
from Section III of the Part A form and references to this information in the instructions. In
addition, EPA HQ would need to revise the RCRA permit regulations. Specifically, EPA HQ
would need to delete the requirement at 40 CFR 270.13(b) for owners or operators to provide the
latitude and longitude of facilities for which they are submitting a Part A Permit Application.
This action will complement the previous recommendation to merge common elements of current
site identification forms.
Design Considerations
1) The accuracy, uniformity, and completeness of geographic coordinates in RCRIS or the
subsequent national data system would improve significantly with respect to the baseline.
2) RCRA Sites tracked in national systems will need to be updated using address-matching
software to reflect geographic coordinates that are currently missing.
3) The address-matching software would eliminate the potential for human error in key
punching the coordinates provided by facilities with first or revised Part As.
4) The PAA Team feels that the address matching software should be an integrated part of
national information systems. This will ensure the population of the data for each RCRA
Site.
5) It should be noted that the degree of accuracy of address matching software can be limited,
especially for certain areas of the country (rural) and may not be compliant with the
Locational Data Policy. However, this improvement will provide much better locational data
over the current situation. Future systems must allow users to overwrite data from address
matching software with more accurate information, for example hand verified through GPS.
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22) Record historical changes to RCRA Site name, operator name, owner
name, and regulated activity status
Summary
Provide functionality in the national RCRA information systems to accommodate historical
records of the changes in RCRA Site name, operator name, owner name, and regulated activity
status.
Program Need
The name under which a RCRA Site operates may change numerous times. PAA participants
identified as an important requirement the need to be able to identify the name under which a
RCRA Site operated at a given point in time.
Similarly, the regulated activities that a RCRA Site conducts change regularly. A generator may
cease activity for a period of time before recommencing that activity. An important requirement
has been to be able to identify the period of time during which a RCRA Site performed a given
activity or operated within a specific regulatory category.
This information would support:
understanding the history of waste generation and management activities at a given site
the development of enforcement cases
waste minimization trend analysis
assessment of contamination cleanup and remediation needs
Problem Analysis
Current systems do not support this need.
Recommendation
Provide functionality in the national RCRA information systems to accommodate historical
records of the changes in RCRA Site name, operator name, owner name, and regulated status.
This functionality will allow recording of future changes in these points of information while
retaining existing values. The same functionality will also allow recording of past values
although this historical information will only be captured at the discretion of the implementer.
This recommendation will help to ensure the successful implementation of the PAA Team's
recommendation to generally assign only a single EPA identification number to a given RCRA
Site, since important changes to the basic site information will still be possible while retaining an
historical link to previous information.
Design Considerations
New system functionality required.
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23) Provide an integrated source of RCRA program information
Summary
Provide a single source of information for the RCRA program.
Program Need
A widespread need was identified during the information gathering sessions for a single
integrated information source for the RCRA program. Currently, the RCRIS and BRS systems
combine to provide this information.
Users specifically referenced the following needs:
single point of reference and access to information about RCRA regulated sites,
ready desktop access to information,
improved information reporting capabilities, and
removing redundant data sharing.
Problem Analysis
Much of the basic identification data about a RCRA Site is currently maintained redundantly in
both RCRIS and BRS. Additionally, the two systems are currently "fed" separately, causing
disparities in data quality. This is compounded by the information in RCRIS being updated on an
ongoing basis, whereas BRS represents multiple biennial snapshots.
Recommendation
The two systems should be merged so that they share one 'repository' of RCRA Site data and an
integrated set of data entry capabilities.
Consideration of the most appropriate and cost-effective way to achieve this recommendation will
be made during the subsequent design project.
Design Considerations
1) The benefits of this data integration were previously documented in the Final Report from the
Program Evaluation PAA.
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FINDINGS AND RECOMMENDATIONS
24) Additional Information Collection using the Manifest
Summary
Change the Uniform Manifest to capture the physical address of the collection location of a
hazardous waste shipment.
Program Need
A number of States meet their need for more frequent submission of generation and management
data by collecting manifest information from generators and TSDFs. The manifested EPA
identification number is used to identify both the "cradle" and "grave" of the waste.
Where the generator EPA identification number is unknown or unclear, the physical collection
location provides valuable supporting information. Currently, this location information is not
collected on the Uniform Manifest Document.
Additionally the point of generation is important to ensure that the manifest is sent by the TSDF
to the correct State.
Problem Analysis
The Uniform Manifest Document requires the reporting of the shipping generator's EPA
identification number but this information is sometimes incorrectly reported making it difficult to
precisely identify the origin of a waste shipment. An incorrect EPA identification number can
result from poor typing or handwriting.
The Uniform Manifest Document does not require the physical address from which the waste
shipment was collected. The generator's mailing address is currently required, but this can often
be very different to the generating site's physical address. For example waste may be generated
in state X but their headquarters and mailing address is in state Y. Alternatively one mailing
address may serve many RCRA Sites and associated EPA identification numbers. This can make
it difficult to tie the manifest to the point of generation. This issue may result in the manifest
being sent to the incorrect state causing a delay in processing or resulting in the manifest being
"lost" to the generating state.
Although CESQGs are not required to notify of waste activity, many CESQGs ship hazardous
wastes to TSDFs using the manifest, despite not being assigned an EPA identification number. It
is then difficult to determine the origin of the waste as there is no EPA identification number to
relate the mailing address detailed on the manifest to the physical generation address (which may
be different from the mailing address). This inhibits implementing agencies from monitoring
hazardous wastes from cradle to grave.
Recommendation
Revise the Uniform Manifest Document and associated instructions to record the physical site
address including country of the originating generator of the waste shipment. The physical
address will replace the mailing address on the manifest. This will provide the information
required by implementing agencies needed for timely cradle to grave tracking of wastes. It will
also provide information on CESQGs, who may not have an EPA identification number and may
not be tracked nationally, for inspection targeting to confirm status, or pollution prevention
outreach.
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FINDINGS AND RECOMMENDATIONS
Design Considerations
1) The Department of Transportation controls the content of the Uniform Manifest, and their
approval would be required before any modification to it could be made.
2) The manifest instruction and associated forms would require amendment for all 50 States.
Many States have customized the appearance of the manifest. Thus any efforts could not be
achieved through wholesale change but would require many individual efforts.
3) The Manifest Rulemaking Workgroup is charged with evaluating changes to the Uniform
Manifest. As a result the implementation and design of this recommendation will need to be
forwarded to this workgroup.
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FINDINGS AND RECOMMENDATIONS
25) Make Source of Waste a National Data Element
Summary
Require the collection of source code for reported wastes.
Program Need
PAA participants expressed the program's need to be able to distinguish among the following
classes of hazardous wastes:
Ongoing generation from production and service processes
Residuals from active on-site management (i.e., recycling, reclamation, treatment or disposal)
of hazardous waste
Generated once or sporadically (e.g., discarding off-specification or out-of-date chemicals,
process equipment change-out, lagoon drag-out)
Generated by current spills or accidental releases
Generated by remediation of historic contamination (e.g., Superfund or State cleanups,
RCRA closure or corrective action)
One State asserted a need to identify those hazardous wastes that are residuals from active on-site
management of non-hazardous waste.
Within each of the general categories above, participants reported the need to know in more detail
the specific types of industrial or waste management processes from which hazardous wastes
originate. For example, solvents are used by many industries in a number of quite different
processes - cleaning, degreasing, painting, etc. - and simply knowing that a given site generates
spent solvent does not provide enough information to determine whether they might benefit from
a new technique to eliminate the use of solvents in only one of those processes.
Key processes driving this need include:
Compliance monitoring and inspection - cleanups are regulated under different authorities for
generators or TSDFs, and spills and releases are a indicator of potential non-compliance.
Technical assistance and outreach - these are most often targeted toward routinely generated
wastes, requiring the ability to distinguish those wastes from all others. Many technical
assistance and waste reduction programs center around the specific waste producing
processes (e.g., parts cleaning), rather than the wastes such processes create (e.g., spent
solvent).
State fees and program planning - annual volumes of remediation waste fluctuate much more
than those of as-generated wastes, and some States do not charge fees on cleanup waste. In
addition, program planning needs to know broadly whether their efforts are successful - are
as-generated wastes being appropriately managed and minimized?
Legislative support and interstate information-sharing - a meaningful description of wastes
generated and/or managed requires all of these distinctions.
Problem Analysis
Currently, the reporting of source codes by generators of hazardous waste is not required.
Generators have the option of providing the information if they choose. As a result, there is not a
complete "national picture" of the sources of hazardous waste for all RCRA Sites.
FINAL REPORT PAGE: 97
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FINDINGS AND RECOMMENDATIONS
Recommendation
The source of hazardous waste will be made a national data element. This data element will be
collected from the generator and may be reported at the individual process level, at the manifest
shipment level or at the cumulative waste code level (within the reporting cycle). The
implementing agency will provide the source code to the national information system at the
greatest level of detail feasible within the parameters of their individual authorized programs.
Dependencies
16) Streamline Source, Origin, Form and Management Codes
This is a partial dependency.
The burden to the regulated community of requiring source code to be reported will be minimized
by the streamlining of the existing source and origin codes.
Design Considerations
In order to provide an accurate context behind the data, meta-data must reflect the level of source
code specificity, for use in analysis and comparison activities.
PAGE: 98 FINAL REPORT
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FINDINGS AND RECOMMENDATIONS
26) Record Source of RCRA Site Activity Information
Summary
Track the source (i.e., either Program or Site) of each new piece of information regarding the
RCRA regulated activities of a Site.
Program Need
Site identification information can be supplied by either a declaration on the part of the RCRA
Site (e.g., via a Notification Form, or a BR 1C Form), or through a program inspection/site visit.
Implementers have greater confidence in data provided by experienced agency personnel than in
data submitted by regulated entities. As a result, it is important to know whether the source of
the information was the RCRA Site or the regulating agency. For example:
To enable an implementer to evaluate and/or target inspections towards RCRA Sites that have
notified that they are performing RCRA regulated activities that conflict with the activities
that a program inspector had determined they are performing.
To respond to phone calls requesting the last time a site notified the program of its regulated
activities
To know what the Site certified as its regulated activity.
Problem Analysis
Currently, RCRIS provides a mechanism to track the source of the information, but tracks in
greater detail than the program needs. The current system is overly complex, because in addition
to indicating the source of the information, it also records the recipient of the information (that is,
region or state). The current system also allows for recording multiple occurrences of data
beyond site activity, again resulting in unnecessary complexity.
Recommendation
Track the source (i.e., either implementer or Site) of each new piece of information regarding the
RCRA regulated activities of a Site.
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FINDINGS AND RECOMMENDATIONS
Consolidated Overview of the Recommendations
Introduction
In the previous section, the recommendations from the UID and WAM PAA were described
individually to give the reviewer the opportunity to evaluate and comment on each individually.
However, many of the recommendations interrelate, and often depend upon one another. This
section provides an outline of how future information collection and management would be
accomplished if all of the recommendations were implemented. This consolidated overview
highlights the interdependencies between the recommendations and the benefits that might be
achieved.
Recommended Future Information Collection
Figure 8: Recommended Future Information Collection Mechanisms illustrates the ways in which
UID and WAM information would be collected based on the PAA recommendations. The figure
does not include references to the database systems that would support the management of the
information collected, since it is anticipated that all the collection mechanisms listed would be
supported by automated systems.
Figure 8: Recommended Future Information Collection Mechanisms
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FINDINGS AND RECOMMENDATIONS
However, one should keep in mind that the PAA Team has recommended that future RCRA
information systems be integrated, providing a single source for RCRA program information.
This integration will allow implementers to query based on site information, and also seamlessly
gain access to waste activity information. This integration will have a significant effect on how
information is accessed and will greatly enhance the impact of the recommendations reviewed in
the following discussion.
The ovals represent the internal processes that collect the information needed by the program.
The boxes represent the forms or files used to collect or distribute information from or to RCRA
Sites. The small icons represent the media that would typically be used for such collection or
distribution (i.e., paper, electronic files, or telephone). The arrows represent the flow of
information and the interdependencies between the internal processes.
In the remainder of this section, each of the internal processes is described in terms of the
activities that would be performed and the data collection mechanisms that would be employed.
Identifying a new RCRA Site
A new RCRA Site is identified and recorded because either a new RCRA Site Identification form
is received, an emergency site verbally notifies, or an inspection report is provided that identifies
a RCRA Site that had not previously notified the program of its activities. This form will also
capture import-handling activities. The table below identifies the types of information collected
by these mechanisms.
RCRA Site Identification Information
EPA identification number
Site name
Location address
Mailing address
Owner name
Owner type
Operator name
Operator type
Land owner type
Site contact name
Site contact phone
NAICS code(s)
RCRA Site Activity Information
Federal generator status
Underground injection
Used oil processor
Used oil transporter
Hazardous waste import agent
Hazardous waste transporter
Used oil transfer station
Used oil refiner
Universal waste handler
Mixed radioactive waste
handler
Hazardous waste fuel marketer
Used oil burners
Used oil marketer
State generator status
Waste codes
All RCRA Sites (including temporary sites, CESQGs, emergency sites, and sites that have been
discovered during an official site visit) will be assigned a Federal EPA identification number and
information about them will be shared nationally. EPA identification numbers will be assigned to
RCRA Sites based on the new guidance developed to avoid multiple identification numbers being
assigned to one RCRA Site, except in exceptional circumstances.
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FINDINGS AND RECOMMENDATIONS
Determine other RCRA Site information
For any newly identified RCRA Site the latitude and longitude will be calculated based on the
physical address of the Site, and the Facility Registry Identifier will be determined. Additionally,
any of the shared information needs that are collected by a State or the EPA could be recorded.
Track quantities of waste received and managed
TSDFs will electronically submit data about all shipments of hazardous waste they have received
during the preceding quarter. For wastes imported into the country, the TSDF will report the
EPA identification number of the importing agent as well as the country of origin of the waste,
providing the ability to distinguish between domestic and foreign generated wastes. Once this
data has been quality assured by the implementer it will be transmitted to a national repository
from which all regulators could access the information about waste being managed as well as
inferring the waste being shipped from each generator. The information reported is shown in the
following table.
Manifest number
Destination EPA ID
State only waste codes
Unit of measure
Management method
Originating EPA ID
Federal waste codes
Quantity
Originating country
Received date
Verify/track waste generated
Pre-populated generation forms are returned to the implementing agency reflecting changes or
amendments to waste generation data, as identified by the generator. The submission additionally
captures source code, unreported waste generation data, as well as any onsite management
activities.
Track waste exported
Generators that export hazardous wastes continue to submit their Annual Export Report to EPA
OECA for entry into the EXPORTS database. Data from the EXPORTS database will then be
integrated into the national information systems Regulators across the nation have access to data
on wastes generated and exported from their state. The regulators ability to track waste from
cradle to grave is significantly improved, and they now have a more complete picture of the
wastes generated in the state, for use in compliance assurance, inspection planning, program
development and analysis and revenue generation.
Send waste verification forms to all RCRA Sites
Every two years pre-populated RCRA Site Identification forms will be printed that include all the
identification information currently known about the RCRA Site. These will be sent to every
active RCRA Site for their review and update.
Jointly with this form, a pre-populated waste generation verification form would be sent to all
known LQGs and any non-LQGs that appear to have generated large quantities of waste based on
the shipment information reported by TSDFs. As determined by individual implementers, the
form would be pre-populated with the shipment level information or with aggregated periodic
totals based on TSDF reporting of wastes received from the generator during the prior biennium.
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FINDINGS AND RECOMMENDATIONS
This would allow generators to review, modify or append information about their shipments
during the period. The generator would also be able to report the source of generated wastes and
the on-site management of waste they have performed. This Waste Generation Verification form
could, at the discretion of the implementer, also be sent to all known generators (i.e., including
SQGs).
The types of information reported are shown in the following table.
Source of waste
Destination EPA ID
State only waste codes
Unit of measure
Reporting period
Originating EPA ID
Federal waste codes
Quantity
Destination country
Update RCRA Site identification information
Based on the pre-printed RCRA Site Identification forms returned biennially by all RCRA Sites,
changes to that RCRA Site's information would be recorded. Historical information about
changes to the site name, owner name, operator name or changes in the RCRA regulated
activities (e.g., generator status) would be retained for reference.
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FINDINGS AND RECOMMENDATIONS
Information Access Capabilities
One of the major objectives of WIN/INFORMED is to provide RCRA program staff with improved
capabilities to access and use the information that they collect and manage.
One of the main issues with the existing RCRA information systems that was identified during
the Information Strategy Planning projects that preceded this PAA project (and confirmed during
this project), was the lack of support to allow program staff to make use of the information
tracked within those systems.
This section of the Final Report provides a high level assessment of the ways in which RCRA
program staff need to be able to query and analyze information. This is intended to provide
reviewers with an overview of the required capabilities for comment. It is anticipated that these
needs would ideally be supported through some easy to use information access functionality7.
Based on an assessment of the types of questions that EPA and the States regularly need to
answer to implement the RCRA program, four generic types of data access needs can be
identified:
RCRA Site Profile answers questions about the identity and activities of one
specific RCRA Site,
Targeted Group of RCRA Sites answers questions regarding which set of RCRA Sites match
a set of specific criteria,
Regulated Universe Quantification answers questions about the size of the RCRA regulated
community within specific States, Regions or the country
Hazardous Waste Quantification answers questions regarding the total amounts of waste
being generated, managed or shipped within specific States,
Regions or the country,
Although the organization of these types of access need is subjective, the various questions that
make up each group require overlapping data sets. This classification is used for organization
purposes.
Many of the questions that make up these types include the need to consider changes that occur
over time. This provides a perspective of the trends in management practices and the impact of
regulatory and other initiatives.
Each of these four types of data access needs is described in the following way:
Example key questions provides examples of the types of questions that are
regularly asked of the program by either internal or external
audiences
Applicable criteria lists the specific criteria that individually, or in combination,
define the set of results that answer a question
Resulting data content describes how information would be presented (e.g., within a
report) that would answer a question
7 The term "report" has been used in this section to refer to general access functionality. This term is not intended to
suggest that access to the information would be limited to hardcopy alone.
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FINDINGS AND RECOMMENDATIONS
RCRA Site Profile
This provides the program with all the available details about an individual RCRA Site and
supports such program activities as:
preparing for an inspection,
responding to a public request for information,
processing a permit application,
enforcement case development,
reviewing the 'mass balance' of a Site's waste shipments, and
considering the applicability of technical assistance.
Example key questions
Where is Site X located, what RCRA regulated activities do they perform, and who should I
contact at the Site regarding my upcoming site visit?
What is the hazardous waste generation and management history at Site X?
What is the EPA identification number for facility named X?
Does this Site still perform any RCRA regulated activities?
Is this TSDF in an Environmental Justice Area?
Has this location/address ever been the site of RCRA activities?
Is Site X registered as a used oil or hazardous waste transporter
Applicable criteria
Has been assigned EPA ID X
Was previously named or owned/operated by X
Is currently named or owned/operated by X
Is located at, or nearby, X (e.g., street name, ZIP
code, latitude/longitude)
Resulting data content
These types of questions require a complete profile of a specific RCRA Site's identifying
information, RCRA regulated activities, and waste generation, shipment and management
activities. For example:
a report of the Site's name, location, owner, operator, site contact and mailing address;
a map showing the location of the Site, with overlays of various natural resources (e.g.
wetlands, population centers) and geopolitical boundaries (e.g. tribal lands, counties).
a description of the regulated activities occurring at the Site (as of the last time the Site
reported its activities or the agency visited the site);
a breakdown of all the hazardous waste that the Site had reported that it had generated,
shipped and/or managed;
a breakdown on all of the hazardous waste that other Sites had reported being received from,
or sent to that Site, along with any discrepancies between the individually reported wastes
(where applicable, for example, for an LQG).
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FINDINGS AND RECOMMENDATIONS
Targeted Group of RCRA Sites
This provides the program with the ability to identify a discrete set of RCRA Sites that fit a
variety of targeting criteria. This supports such program activities as:
planning inspection schedules
responding to a public request for information
targeting assistance and outreach activities
performing regulatory impact analyses
Example key questions
- Which TSDFs manage PBTs?
Which Sites manage waste onsite vs. offsite?
Which generators generated 10% more than the SQG limits?
Which commercial TSDFs manage waste of type X?
Which large quantity generators are within industry types X, Y or Z.
Which RCRA Sites are located within a 10 mile vicinity of X?
Who are the active small quantity generators?
Applicable criteria
Is in industry type X
Currently performs RCRA activity X (e.g.,
hazardous waste transporter)
Falls into the formal TSDF Universe X
Is currently a non-notifier
Receives waste from generator X
Is either a commercial, on-site, or captive TSDF
Generated a quantity of waste in excess of X pounds
Imports waste from another country
In geographic area X (e.g. a state, city, county,
legislative district)
Previously performed RCRA activity X (e.
sometime during the prior year)
g, LQGs
Owned by X corporation
Ships waste to TSDF X
Treats or disposes of waste code X
Generates waste code X
Generates hazardous waste from industrial
X
process
Exports waste to another country
Resulting data content
The response to this type of question would be a simple list containing EPA identification
numbers, names and locations of each RCRA Site that meets the criteria. Based on this list, and
the context of the question the following types of elaboration should be available:
If the information was to be used to mail information to each RCRA Site, a mailing list
should also be provided.
If the information was to be used to determine the effects that these RCRA Sites might be
having on nearby natural resources, a detailed map would locate each Site relative to those
natural resources.
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FINDINGS AND RECOMMENDATIONS
If more specific information was required about each RCRA Site that met the criteria, a user
could employ the capabilities associated with RCRA Site Profile described above. For
example, if a user wished to know what was the method used by each commercial TSDF to
manage the waste of waste code X, they could examine the waste management history for
each RCRA Site in the list.
Regulated Universe Quantification
This provides the program with the information about the number of RCRA Sites that are
regulated in varying ways, and how they are distributed geographically. This supports such
program activities as:
program planning and resource management
responding to a public request for information
policy development
risk assessment
legislative support
EPA oversight of States
regulatory impact analyses
Example key questions
How many generators in state ship X waste to out of state facilities?
How many RCRA Subtitle C facilities with waste management unit type A are located in
State B?
How many handlers generate wastes from the production of, for example, fertilizers?
How many facilities subject to permitting requirements are also undergoing corrective action?
How many high priority facilities are meeting environmental indicators (e.g., GPRA criteria)
X?
How many handlers with a specific generator status are there in each county, district, or other
geographic area (e.g., radius from a town)?
Applicable criteria
Falls into GPRA universe X
In geographic area X (e.g. a state, city, county,
legislative district, vicinity around a point)
Previously performed RCRA activity X (e.g., LQGs
sometime during the prior year)
Is in industry type X / performs industrial process Y
Currently performs RCRA activity X (e.g.,
hazardous waste transporter)
Falls into the formal TSDF Universe(s) X
Resulting data content
Although the main result is the number of RCRA Sites based on the activities for which they are
regulated (e.g., Federally defined LQGs, TSDFs, transporters, universal waste handlers), this
number often needs to be presented so that the percentage change over time can also be
considered.
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FINDINGS AND RECOMMENDATIONS
Hazardous Waste Quantification
This provides the program with the information about the amounts of hazardous waste that are
being generated, managed and shipped intra-state, inter-state and internationally. This supports
such program activities as:
responding to a public request for information
rule making and policy development
risk assessment
legislative support
EPA oversight of States
capacity planning
regulatory impact analyses
Example key questions
How much waste of waste type X was landfilled in the state during a particular quarter of the
year, and how much of it came from out of state?
How much has the generation of waste type X changed during the last few years?
How much waste is being generated in industry sector X, and geographic area Y?
How is waste of type X being managed before and after the implementation of a specific
rule/standard?
How much waste is being exported to country X?
What are the trends in waste management for certain types of waste?
What waste codes and volumes are being managed through combustion?
Applicable criteria
Generated/managed waste code X
Generated/managed in geographic area X
Exported to country X?
Managed using method X
Generated/managed in industry sector X
Imported from country X?
Resulting data content
The total quantity of hazardous waste should be described as an amount generated, an amount
managed, and/or an amount shipped in or out of the state/nation. Additionally, these quantities
will sometimes need to be additionally categorized by the type of the waste (e.g., by waste code),
and/or by the ways in which the waste is managed. Once again, the trending of these quantities
over periods of time is vital when considering the overall impacts of changing regulations, new
industrial processes, and waste minimization initiatives.
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IMPLEMENTATION PLAN
IMPLEMENTATION PLAN
This section of the report provides an outline of a possible approach to the detailed design and
implementation of the report's findings.
Implementation Planning Considerations
As described in the WIN/INFORMED Approach section of this report, the methodology employed
by this Program Area Analysis (PAA) calls for the project's recommendations to be further
developed by one or more Program System Design (PSD) projects. The PAA recommendations
have been organized into smaller, more manageable groupings. The scope of each design project
has been constructed to accommodate dependencies between recommendations.
There are two primary drivers for the planning and scoping of PSD projects.
1. Inter-dependencies between recommendations may be significant enough to require that
recommendations be developed in parallel with each other.
2. Some recommendations require modification of national reporting mechanisms including
regulatory change. Given the formal and time dependent processes required for regulatory
change, recommendations with similar regulatory impacts should clearly be implemented
together.
The manner in which these two drivers affect the specific PAA recommendations is described in
the next two sections.
Inter-dependencies between PAA Recommendations
The inter-dependencies described for each recommendation in the report are represented in Figure
9: Inter-dependencies between recommendations.
Each arrow on the diagram represents a dependency for the design and implementation of two
PAA Recommendations. The recommendation at the endpoint of the arrow is dependent upon the
recommendation at the start of the arrow.
The solid arrows represent critical dependencies where the source recommendation must be
implemented before the target can be implemented. Failure to observe these dependencies may
require a recommendation to be modified or abandoned. For example, waste codes cannot be
removed from the notification form until the reliant program needs are supported elsewhere (e.g.,
quarterly reporting of TSDF receipt data, or other means of receiving information about wastes).
The doited arrows represent partial dependencies. Failure to observe these dependencies may
require reanalysis and design of the dependent recommendation's implementation. For example,
if the universe of RCRA Sites reported nationally, were expanded to include all temporary and
emergency RCRA Sites without regular verification of the universe, then the current situation
with historical data that has not been re-verified since initial submittal, would simply proliferate
to a larger universe of RCRA Sites.
FINAL REPORT PAGE: 109
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IMPLEMENTATION PLAN
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The inter-dependencies influence the ways in which the recommendations can be grouped into
discrete PSD projects. This diagram should be used as a reference to ensure that there are no
adverse affects to other recommendations that rely upon it.
Regulatory Implications of PAA Recommendations
The PAA recommendations may require one or both of two types of regulatory action, including
development of Information Collection Requests (ICR), and/or revisions to RCRA rules. Table 9
identifies, for each recommendation, the types of anticipated regulatory change required. The
majority of the recommendations will require some modifications to one or more ICRs, as
indicated in the rightmost columns, while the three italicized recommendations will require
revisions to RCRA rules.
The PAA recommendations have been organized into five logical groupings based on the
dependencies described in Figure 9 and the regulatory impacts shown in Table 10. The leftmost
column identifies the four PSD projects into which the recommendations have been grouped.
NOTE:
24) Additional Information collection Using the Manifest has been excluded from consideration
here since the program's needs in this area are being considered by the Manifest Rulemaking
Workgroup.
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IMPLEMENTATION PLAN
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Streamline Source, Origin, Form, and Management Codes
Tracking Hazardous Waste Exports
Clarify Types of Hazardous Wastes to be Reported
Removal of Data Elements from Biennial Reporting forms
Make Source of waste a mandatory data point
Streamline Unit of Measurement Reporting
Collect both State and Federal generator status from States
Merge common elements of current site identification forms
Tracking Imports of Hazardous Wastes
Add Additional Data Elements to Notification Form
Provide for standard notification by large quantity handlers of universal waste
Issue guidance on TSDF nomenclature
Determine location coordinates for a RCRA Site
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10
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Study feasibility of periodic verification of RCRA Site information
Study feasibility of quarterly electronic reporting of TSDF waste receipts
Remove waste codes from Notification Form
Confidential Business Information (CBI)
X
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23
22
26
20
Provide an integrated source of RCRA program information
Record historical changes to RCRA Site name, operator name, owner name,
and regulated activity status
Track the source of Site Activity data
Implement standard definitions for programmatic TSDF universes
4
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3
4
5
Issue guidance on EPA identification number assignment
Track all notifying CESQGs nationally
Track all emergency and temporary sites nationally
Track all non-notifiers nationally
24 \Additional Information Collection using the Manifest
Table 9: Regulatory Impacts of Recommendations
Project 1 groups those recommendations that will require changes to ICRs only. By grouping
these recommendations together, the changes to the reporting forms, data entry screens and
regulations can be accomplished in unison, allowing for coordinated ICR changes and ensuring
consistent design and implementation.
Project 2 groups those recommendations that have the greatest impact to existing regulatory
and/or information management practices and recommendations that are critically dependent on
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IMPLEMENTATION PLAN
these. These have been segregated from the other recommendations due to their need for further
feasibility study8 and also due to length of time required perform the studies.
Project 3 groups recommendations that primarily impact information management systems, and
may also require adjustments to business practices, documentation and training.
Project 4 groups the remaining recommendations that either require new guidance to be
developed or which recommend practices that when implemented will improve the quality of
reported information.
Implementation Projects
This section further describes each of the implementation projects identified above including:
The recommendations included in the project
The internal and external dependencies between the recommendations included in the
projects
The schedule and milestones for the project
A summary of the specific tasks required during design.
Much of the information included here has been summarized from other sections of the report, to
provide a consolidated project discussion for evaluation. For more detailed information about
these projects the reader should refer to the individual PAA recommendations detailed in the
Recommended Information Management Improvements section of this report.
Each project has been designated as either EPA or State lead. This responsibility is intended to
mirror that of the PAA's lead responsibility, in that the lead organization provides a greater level
of support to the project. However, as with the PAA, both EPA and States will be active
participants in the decisions made during each project.
Project 1: ICR Reliant System Changes EPA Lead
This project will design the policies/procedures, reporting mechanisms, and information system
changes required by those PAA recommendations that require ICR changes, with the exception of
those that have been included in Project 2.
This design project should commence as soon as possible, to ensure that those recommendations
that are effected by the Biennial Report ICR will be implemented within the 2000 ICR process. If
this is not accomplished, then these recommendations will not be implemented until the 2002
Biennial Report ICR cycle.
This project will also require changes to the ICRs for the Notification form, Part A Permit
Application, Uniform Manifest Document, and Export Report. As a result, associated
information systems functionality will require analysis and development, to ensure consistency
with paper forms.
Some of the design tasks included within this project are:
Address matching software for determination latitude/longitude will be evaluated and piloted.
8 A "feasibility study" is an exercise to better understand the alternative ways in which the recommendation could be
implemented, along with soliciting more comprehensive input from all stakeholders, so that the costs and benefits of
those approaches can be better understood, and an informed decision can be made with respect to implementing the
recommendation.
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IMPLEMENTATION PLAN
The OECA Exports system data and technical infrastructure will be evaluated to determine
best way to integrate the system's data.
The Source, Form and Management codes will be streamlined. This effort will require
additional input from key stakeholders such as state agencies, and regulated community to
refine the level of detail presented in the codes.
A data transition strategy will be developed for changes to source/origin form and
management codes, unit of measure, NAICS codes, export data, generator status, latitude and
longitude, mixed radioactive waste indicator, and other identified RCRA Site identification
data elements.
PAA Recommendation
ICR revision required
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Streamline Source, Origin, Form, and Management Codes
Tracking Hazardous Waste Exports
Clarify Types of Hazardous Wastes to be Reported
Removal of Data Elements from Biennial Reporting forms
Make Source of waste a mandatory data point
Streamline Unit of Measurement Reporting
Collect both State and Federal generator status from States
Merge common elements of current site identification forms
Tracking Imports of Hazardous Wastes
Add Additional Data Elements to Notification Form
Provide for standard notification by large quantity handlers of universal waste
Issue guidance on TSDF nomenclature
Determine location coordinates for a RCRA Site
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Internal Dependencies
17) Removal of Data Elements from Biennial Reporting Forms is critically dependent upon 8)
Add Additional Data Elements to Notification Form.
25) Make Source code a National Data Element is critically dependent upon 16) Streamline
Source, Origin, Form and Management Codes.
High Level Scheduling and Milestones
The PSD would take approximately 5 months to complete.
The anticipated ICR changes would take approximately 6 months to complete.
The 2001 (biennial) Hazardous Waste Report ICR is due to be drafted on May 1st, 2000, and
finalized in November 2000.
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IMPLEMENTATION PLAN
Project 2: Site Verification and TSD Quarterly Reporting State Lead
Site Verification
This project will study the feasibility of alternative mechanisms by which identification data can
be verified by RCRA Sites. The project will estimate the cost / burden imposed upon the
regulated community and RCRA implementers. Major tasks will include:
Benchmarking of 2-3 States and data analyses to evaluate the burden on both implementer
and RCRA Sites of verifying based on :
universe,
optional vs. mandatory,
verification frequency ,
initial vs. ongoing verification,
cost of not verifying data.
Industry outreach.
Regulatory and ICR change.
Quantification of State support.
Design of the reporting form and information system additions / changes required.
TSDF Quarterly Electronic Reporting
This project will study the feasibility of the quarterly electronic reporting of waste receipt data
from the nation's TSDFs. This would include the evaluation and design of the reporting
mechanism, a national repository and State/EPA data interchange mechanisms, and the pre-
population of generators biennial hazardous waste reports.
Major tasks will include:
Outreach to TSDFs for input and to gauge their support
Detailed benchmarking with states implementing reporting mechanism that are similar to
recommendation (e.g., Texas)
Perform a pilot study of the design
Survey manifest states to evaluate the benefits and liabilities to their programs
Design reporting forms and
Analyze and design information systems (new or existing).
PAGE: 114 FINAL REPORT
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IMPLEMENTATION PLAN
PAA Recommendation
ICR revision required
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Sfudy feasibility of periodic verification of RCRA Site information
Study feasibility of quarterly electronic reporting of TSDF waste receipts
Remove waste codes from Notification Form
Confidential Business Information (CBI)
X
X
X
X
X
X
External Dependencies
2) Study feasibility of periodic verification of RCRA Site information is critically dependent upon
7) Merge common elements of current site identification forms included in Project 1.
2) Study feasibility of periodic verification of RCRA Site information is partially dependent on 23)
Provide an integrated source of RCRA program information included in Project 3.
Internal Dependencies
10) Remove waste codes from Notification Form is critically dependent upon 11) Study feasibility
of quarterly electronic reporting of TSDF waste receipts.
11) Study feasibility of quarterly electronic reporting of TSDF waste receipts is critically
dependent upon 12) Confidential Business Information (CBI).
High Level Scheduling and Milestones
The feasibility study for this project would take 6 months to complete and would include a
national review.
The Site Verification PSD would take approximately 4 months to complete and would include a
national review
The TSD Quarterly Reporting PSD would take approximately 9 months to complete and would
include a national review
The anticipated regulatory change would take approximately 2 years.
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IMPLEMENTATION PLAN
Project 3: Data Integration into RCRAInfo
State Lead
This project will determine how the RCRAInfo data and functionality for Site Identification
information will be integrated and modified. Major tasks would include:
Development of a detailed data integration strategy (the 1999 biennial report 1C forms would
be the basis for reconciling with the RCRIS data).
Interviewing implementers to evaluate data quality issues
Specify how the common systems functionality should be merged
PAA Recommendation
ICR revision required
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Provide an integrated source of RCRA program information
Record historical changes to RCRA Site name, operator name, owner name,
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Track the source of Site Activity data
Implement standard definitions for programmatic TSDF universes
External Dependencies
23) Provide an integrated source of RCRA program information is partially dependent on 2)
Study feasibility of periodic verification of RCRA Site information included in Project 2.
High Level Scheduling and Milestones
The PSD would take approximately 6 months to complete and would include a national review
Project 4: New Guidance EPA Lead
This project will design the policy/procedural changes for the recommendations that do not effect
the reporting mechanisms per se. The project will include the following tasks:
New guidance documents and training materials will be developed and disseminated to all
RCRA regulators
Define consistent national approach for identifying, classifying and recording information
about non-notifiers
The method(s) to identify as inactive sites are no longer active including for temporary sites
PAGE: 116
FINAL REPORT
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IMPLEMENTATION PLAN
PAA Recommendation
1
3
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Issue guidance on EPA identification number assignment
Track all notifying CESQGs nationally
Track all emergency and temporary sites nationally
Track all non-notifiers nationally
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External Dependencies
3) Track all notifying CESQGs nationally and 4) Track all emergency and temporary sites
nationally are partially dependent on 2) Study feasibility of periodic verification ofRCRA Site
information included in Project 2.
1) Issue guidance on EPA identification number assignment is partially dependent on 22) Record
historical changes to RCRA Site name, operator name, owner name, and regulated activity status
included in Project 3.
Internal Dependencies
4) Track all emergency and temporary sites nationally is partially dependent on 3) Track all
notifying CESQGs nationally.
High Level Scheduling and Milestones
The PSD would take approximately 6 months to complete.
Implementation Schedule
An implementation plan has been developed that takes into consideration the inter-dependencies
between the four projects discussed above and the EPA and State resources available to support
the performance of these projects.
Figure 10: Schedule of Implementation Projects presents a proposed schedule for the four
projects and associated tasks. Four types of implementation tasks are shown:
1. PSD projects -will examine and detail the manner in which existing regulations, reporting
forms, and information management systems will change.
2. Feasibility studies - will further consider the implications of the most significant changes to
existing reporting mechanisms and will determine the most practical mechanisms for
implementing the recommendations.
3. Regulatory change tasks - will perform the rulemaking or ICR processes required by some
PA A recommendations.
4. Implementation projects - will make the changes as specified by the PSD projects.
The following important considerations are not explicitly included in the implementation projects
or schedule but will impact the way that some of the PAA's recommendations are implemented.
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IMPLEMENTATION PLAN
Data Integration
Project 3 includes the recommendation to integrate the two sets of site identification data
currently managed in RCRAInfo's RCRIS and BRS datasets. This effort will require evaluating
and reconciling the differences between the two datasets. Given the scope and complexity of this
exercise, this effort has been scheduled to begin after the design and feasibility study included in
Projects 1 and 2. Projects 1 and 2 may significantly impact the definition of the data, and the
mechanisms used to collect and verify that data. As a result, these two projects will impact the
manner in which the existing datasets would be integrated.
Periodic Verification
A number of the information needs identified through the PAA require that existing data elements
be redefined or that entirely new data elements be added to forms and/or information systems.
The proposed changes to regulations, reporting forms and systems will support the information
collection for future data collection activities, but the data will not be available for current active
RCRA Sites. For example, adding NAICS codes to the notification form will only provide data
for RCRA Sites that submit a new RCRA Site Identification form or submit the Biennial
Reporting forms. However NAICS information will not be available for existing SQGs as they
are not required to re-notify or submit Biennial Reporting forms. This issue would be resolved if
2) Periodic Verification of RCRA Site Information were implemented. A verification exercise
would fill data gaps for existing RCRA Sites.
Information Access
One of the primary goals of the WIN/INFORMED initiative is to provide RCRA program staff with
improved access to information. The PAA has examined information needs and collection
mechanisms within its scopes and determined that on-line data access will best support the
primary goal. Information access mechanisms are partly dependent upon the implementation of
many of the PAA's recommendations. As a result the development of the new data access
capabilities will be best performed through a process that runs concurrently to the PAA's
implementation plan.
PAGE: 118 FINAL REPORT
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IMPLEMENTATION PLAN
ID
1
2
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4
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Task Name
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2001 Biennial Report Draft ICR Due
ICR Processes
Implementation
2) Site Verification & TSD Quarterly Report
Feasibility Study - State Lead
Decision/National Review
Site Verification PSD
Site Verification Decision/National Review
Site Verification Rule Making
TSD Quarterly Reporting PSD w/Pilot
TSD Quarterly Reporting Decision/National Review
TSD Quarterly Reporting Rule Making
3) Data Integration Into RCRAInfo
Site Identification Data PSD
1999 Biennial Report Data Received
Site Identification Data Implementation
Waste Activity Data Integration PSD
Waste Activity Data Integration Implementation
4) New Guidance
PSD
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APPENDICES
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APPENDIX I: PROGRAM AREA ANALYSIS PROCESS
The analysis of the UID and WAM program areas was conducted based on the following set of
tasks.
Information Gathering
The primary information gathering activities of the project were accomplished through
information gathering conferences termed Information Needs Assessments (INA) Sessions. INA
participants were selected based on their program expertise and included representatives from
States, EPA Regional Offices and EPA Headquarters Offices.
The goal of the sessions was to understand RCRA program information needs and their
supporting data collection mechanisms, including manual procedures, data collection forms, and
computer systems.
The sessions were tailored to fit the respective audience. The following general process was
employed:
Current Data Collection Workflow
Participants described the current procedures that their organization uses to collect
program information. This included both an assessment of the data collection
mechanisms and a definition of the universe of RCRA Sites from which information is
gathered. These collection procedures differed between organizations.
Data Uses
Participants were asked to describe how program area information is used by their
organization. This was approached in two ways.
Participants first explored the "key questions" concerning RCRA program area activities
that an implementing organization must answer in response to internal or external
demands for information. A key question is one that is asked on a regular basis and which
requires RCRA program area information to answer. For example, "How much waste
containing arsenic is incinerated in State X?"
Participants then identified the major program activities that would cause the question to
be asked. An example activity might include "Inspection Planning"
Information Needs
Participants then described the information needs required to answer the key questions
including the data source, the managing data systems, and the coverage and data quality
for each of the needs (collectively termed system support). The participants were then
asked to express their opinion concerning future collection and use of data.
Improvements
Using information gathered through the data collection workflow and the current and
future system support activities, participants were asked to explore avenues in which
ineffective or inefficient work processes and collection mechanism might be improved
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Policy and Procedure Issues
The final element of the INA session was a structured discussion of various policy and
procedural issues that had been identified during the session or during the project
planning phases. Participants were asked to elaborate upon each issue, including its
significance to RCRA program implementation and to explore potential resolutions.
Critical Review
The information that was collected during the INA Sessions was compiled and analyzed to
provide an overall outline of the UID and WAM program area needs. This outline is made up of
three main components, the Program Needs Assessment, the Future System
Recommendations, and the Policy and Procedural Issues.
Program Needs Assessment
This component describes the "conceptual" information processing needs, focusing on
what these needs are, rather than on how well they are currently being met.
Secondly, this section then illustrates how these conceptual program needs are supported by the
existing systems, including data collection forms, data systems, organizational structures and
other procedures. This analysis highlights how well the needs are currently supported, identifies
needs that are not being met, and existing collection procedures that might no longer be required.
Future System Recommendations
This component presents ways in which the existing systems should be changed to meet
the identified program needs more effectively. It also explores opportunities for process
improvements as well as efficiencies that might contribute to an overall reduction in the
program implementation.
Policy and Procedural Issues
During the project, a number of policy and procedural issues were highlighted that affect
the way in which information is collected and used by the program. These issues
interrelate the other analysis components, affecting both the use of current systems and
the implementation of future capabilities. This component presents an analysis of these
underlying issues and provides recommended resolutions.
Once these components were developed, a draft report was prepared outlining the findings and
recommendations. A key goal of the WIN/INFORMED initiative is to obtain nationwide review
and consensus to project findings. Before a national review can take place, an expert group of
reviewers was asked to evaluate the draft findings and recommendations through a process
termed critical review.
National Review
Once the critical review was completed, the project progressed to further detail the
recommendations for improvements to the current and future systems, taking into account the
comments provided by the critical reviewers. The enhancement of these recommendations also
included an evaluation of existing "benchmarking" examples of the proposed future system
capabilities.
The findings and detailed recommendations from both the UID and WAM PAA projects were
consolidated into a Draft Report that was circulated for nationwide review by States, Territories
and EPA Regional and Headquarters offices.
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Implementation Planning
Following the completion of the National Review, the PAA Team considered the comments
received from reviewers and made changes to the recommendations where appropriate. The PAA
Team then worked to prioritize the confirmed recommendations. The recommendations were
organized into logical groups based on their relative priority and degree of interdependency.
The groups of recommendations were reviewed by the WIN/INFORMED Executive Steering
Committee (ESC) for decisions concerning the future steps required to implement the
recommendations.
A plan was then developed that identified the priorities and dependencies involved in
implementing the changes to the current systems. The plan set out a list of the critical actions to
be taken and strategies different organizations might take. The planning takes account of the fact
that the strategy is intended to be acted upon by both the participating States and EPA. Each
group of recommendations will be implemented in separate Program System Design (PSD)
phases.
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APPENDIX II: PROGRAM SYSTEM DESIGN TASKS
This section provides a summary of the tasks that occur during a Program System Design (PSD)
project. They are included as reference, to provide reviewers with an understanding of the
activities to be undertaken for the UID and WAM program areas following the completion of the
PAA project.
Develop overall design structure
For the selected group of recommendations, an overall design will be produced to define the
implementation tasks. This will outline how the changes will be integrated and will identify all
manual and automated procedural changes required.
Design for data collection forms
Any forms that must be changed to support a recommendation will be redesigned. Forms will be
combined and restructured appropriately. Additional fields required by a recommendation will be
added to the appropriate sections of the forms and redundant fields will be removed. The
supporting instructions for each form will be updated to reflect changes to reporting schedules or
the regulated universe required to report and to reflect any revised definitions for data elements
collected on the forms.
Specify automated system changes
Depending upon the recommendations being implemented, existing systems may need to be
changed to capture more or fewer data elements, or to provide additional functionality. These
changes will be specified in the form of system prototypes, screen layouts, database designs,
functionality requirements, file transfer formats, system navigation, and report layouts. In some
cases, entirely new information systems or components, such as enhanced data display screens,
may be required. These again will require fully detailed specifications.
Design business procedure improvements and training plans
Some of the recommendations will call for changes to manual business procedures, for example,
where the existing EPA identification number assignment procedure might change. In such
cases, step-by-step models will be developed to implement these changes and training plans will
be outlined to ensure that changes are uniformly and efficiently adopted nation-wide.
Draft rule and policy changes and supporting documents
Changes to the RCRA regulations may be required to support a recommendation. Changes to the
relevant regulatory text will be drafted. In some cases, simple guidance documents will be
sufficient. Other documents, such as Information Collection Requests, may be required to
support implementation of certain recommendations.
Define data translation approach
Existing system(s) data will be analyzed and assessed to determine how it should be transitioned
into the future systems, whether those future systems are new or modified existing systems. This
assessment will identify both missing data as well as data quality or compatibility issues. This
will result in a data translation plan that defines what data cleaning efforts and data conversion
rules will be required to result in appropriately populated future information systems.
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Define system infrastructure requirements
Within the stipulations of the existing Technical Architecture, requirements will be defined for
the automated system infrastructure, i.e., system security, system help, meta-data, and data
interchange protocols. For example, respectively, context-sensitive data entry restrictions, on-line
data element definitions and policy documentation, data collection dates, and State-EPA data file
quality control rules.
Produce system implementation plan
A system implementation plan will be developed that will identify the detailed tasks to be
performed for the group of selected recommendations. This plan will include both resource
estimates and scheduling information. For example, changes to National and State-specific
systems will be estimated and assigned.
The costs of implementation will now be well understood. These costs will be contrasted with
the benefits to be realized from the implementation.
Conduct National Review
Once developed, the design specifications and implementation plan will be circulated for review
and consideration by all States, EPA Regions, and EPA HQ program offices before any changes
are actually implemented. Since existing processes will be changing, it is anticipated that there
will be a substantial need for outreach to the regulated community, and wide public comments,
perhaps using the Burden Reduction NODA model.
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APPENDIX III: INFORMATION NEED DEFINITIONS
RCRA Site Identification
EPA identification number
Unique RCRA identification number assigned by the implementing State or Region, to each
RCRA Site (e.g., generators, transporters, and treatment storage or disposal facilities).
Facility registry identification number
The program independent unique identification number that would be assigned to the RCRA Site
by EPA. The identifier will provide the mechanism to cross-reference a single RCRA Site that
might in practice be regulated by a number of different environmental programs.
Site name
The name by which the RCRA Site does business and is commonly known. Typically, this might
be the name displayed at the entrance to the RCRA Site.
Mailing address
The primary business mailing address to be used by the implementing environmental agency for
any correspondence. Only one mailing address is required for each RCRA Site. This is often
different from the physical RCRA Site address.
Location address
The physical address of the primary site entrance (front door) of the facility, including the street,
locality, state and USPS zip code. Where possible this should be the specific street address as
defined in the "911 system" used by State and Federal emergency services.
Location county
The name of the county (or county equivalent), in which the RCRA Site is physically located.
Where a RCRA Site spans a county boundary, the county corresponding to the official location
address will be used.
Location coordinates
The latitude and longitude coordinates of a specific point at the RCRA Site. As a general rule,
the point recorded should be the primary site entrance (front door) of the facility, however, the
collected coordinates may relate to a different location than the front door. This would be
indicated by the use of a different method, accuracy, description (MAD) code for the point.
Other coordinate system values may be derived from the latitude/longitude.
Location method, accuracy, description (MAD)
Describes the method by which the location coordinates were collected, a description of what the
point represents, and the accuracy of the collected values. As defined by the EPA's Locational
Data Policy (http://www.epa.gov/irmpoli8/irm_ldp/madmeta.txt.html).
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NAICS Code
The primary industrial activity of a RCRA Site as defined by a standard industrial coding system.
To date, SIC code has been the most commonly used coding structure. However, the newer five
digit North American Industrial Classification System (NAICS) has been established as the new
Federal standard for the collection, and presentation, of data relating to economic activity at
RCRA Sites.
Discovery date
The date on which the RCRA program first identified a site that is believed to be conducting
RCRA regulated activities (e.g., through site visit)
Notification date
The date on which a Notification form or emergency site notification was first received from a
site conducting RCRA regulated activities.
Exempt from Notification
Indicates, for a site that was previously believed to be conducting RCRA regulated activities, that
the site is in fact not regulated by the program and did not need to have notified.
Emergency site
Indicates that the RCRA Site is regulated as the result of a waste generation situation that was
unforeseen, uncontrollable and short-term and not expected to exceed 30 days.
Land owner type
Indicates in a general way the type of entity that legally owns the land on which the RCRA Site is
located. Possible values include - Federal, State, County, Local, Municipal, Tribal, Private.
State identification number
The unique identification number assigned to the RCRA Site by the applicable implementing
State agency.
Number of employees
Describes the number of people actively on the payroll at the RCRA Site on a permanent or semi-
permanent basis. This information is often used to classify the type of business operation, for
example, to determine a small business designation.
Site legal name
The legal name of the RCRA Site as registered with the appropriate Secretary of State.
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RCRA Site Responsibility and Contacts
Owner name
The name of the entity (individual, agency, corporation) having legal ownership of the physical
operation. The owner name may or may not be the same as the actual RCRA Site name or the
operator name.
Operator name
The name of the entity (individual, agency, corporation) who is responsible for the overall
operation of the facility. The operator name may or may not be the same as the actual RCRA Site
name or the owner name.
Owner type
Generally indicates the type of entity that legally owns the facility. Possible values include -
Federal, State, County, Local, Municipal, Tribal, Private
Operator type
Generally indicates the type of entity that is responsible for the overall operation of the facility.
Possible values include - Federal, State, County, Local, Municipal, Tribal, Private
Site contact name
The primary contact person for the RCRA Site location who should be reasonably expected to be
available at all times and to be fully aware of the regulated activities being performed at the
RCRA Site. In many cases this will be the RCRA Site emergency contact, but may also be the
plant manager, an environmental manager or some other individual.
Site contact phone
Phone number at which the RCRA Site contact may be reached
Site contact address
Mailing address for the RCRA Site contact.
D & B number
Nine-digit unique identification number assigned by the Dunn & Bradstreet organization to a
company that might own or operate a RCRA Site. The identifier serves as linkage for
commercially available information pertaining to the RCRA Site.
RCRA Site Activities
Federal generator status
The regulatory status of the RCRA Site with respect to the Federal rules to which it is subject as
determined by the quantity and or toxicity of hazardous wastes generated, stored or accumulated
over a specified period of time. The Federal program provides for three distinct classes: large
quantity generators (LQG), who are subject to the strictest regulations; small quantity generators
(SQG), who follow a less stringent set of procedures; and conditionally exempt small quantity
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generators (CESQG), who are not subject to reporting requirements provided they follow a set of
regulations.
State generator status
The regulatory status of the RCRA Site in view of the implementing State's "broader in scope" or
"more stringent than" rules. Although such an implementing State might use terms that differ for
their generators (e.g., "Fully Regulated Generator"), these would be translated to match the
Federal regulatory term (i.e., LQG, SQG or CESQG) which best represents the way that the State
regulates the generator. For example, a "Fully Regulated Generator" should be referred to as an
LQG, given that the State applies the Federal LQG requirements at a minimum to that Site.
Used oil transfer station
Indicates whether the RCRA Site acts as a transfer station for used oil. A transfer station is any
transportation related facility including loading docks, parking areas, storage areas and other
areas where shipments of used oil are held for more than 1 day and not longer than 35 days
during the normal course of transportation.
Used oil burner
A facility where off-specification used oil is burned for energy recovery in devices or processes
such as: 1) Industrial furnaces, boilers for facilities engaged in manufacturing processes, 2)
Boilers for the production of electric power, steam heated or cooled air or other gases or fluids for
sale, 3) Used oil space heaters provided that the used oil originates form the owner operator or
from do-it-yourself used oil generation, or 4) Hazardous waste incineration.
Used oil processor
A site that processes used oil. Processing means chemical or physical operations that are
designed to produce or make amenable for the production of fuel, oils, lubricants or other oil
derived products through activities such as blending, filtration, separation and distillation.
NOTE: Current regulations make no clear distinction between the "processing" and "refining"
activities for used oil.
Used oil refiner
A site that processes used oil. Processing means chemical or physical operations that are
designed to produce or make amenable for the production of fuel oils, lubricants or other oil
derived products through activities such as blending, filtration, separation and distillation.
NOTE: Current regulations make no clear distinction between the "processing" and "refining"
activities for used oil.
Used oil marketer
Any person who directs a shipment of off-specification used oil from their facility to a used oil
burner, or first claims used oil targeted for energy recovery, meets used fuel oil specifications.
Used oil transporter
Any person who transports or collects and transports used oil from more than one generator, or
owns and operates a transfer station. The transporter may aggregate loads for the purposes of
transportation but may not process the oil with the exception of incidental processing such as oil
water separation, that may occur during transportation.
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Hazardous waste transporter
A company engaged in the offsite transportation of hazardous wastes by air, rail, highway or
water.
Hazardous waste fuel marketer
Any person who directs a shipment of hazardous waste to be burned or processed in a boiler or
industrial furnaces (BIF) for the purposed of energy recovery, destruction, processing for
materials recovery or to be used as a process ingredient.
Universal waste9 handler
Is a generator of universal waste or a facility that receives universal waste from other handlers,
accumulates universal waste or sends universal waste to another universal waste handler or
facility. This excludes persons who treat, dispose, of or recycle universal wastes or persons
engaged in the off-site transportation of universal wastes.
Hazardous waste recycler
Indicates whether the RCRA Site is engaged in the recycling of hazardous waste through
activities such as use or reuse as ingredients in industrial processes to make product provided that
the materials are not being reclaimed, used or reused as effective substitutes for commercial
products, returned to the original process from which they are generated without first being
reclaimed.
Underground injection
Indicates whether the RCRA Site is engaged in the management of hazardous wastes by
subsurface emplacement of fluids through a bored, drilled or driven well, or a dug well where the
depth of the dug well is greater than its largest surface dimension.
Hazardous waste transfer station
Any transportation related facility including loading docks, parking areas, storage areas, and other
similar areas, where shipments of hazardous waste are held during the normal course of
transportation.
Hazardous waste import agent
Any person who imports hazardous wastes into the United States from a foreign country. Import
agents are required to obtain an EPA identification number prior to engaging in import activities.
Mixed radioactive waste handler
Any generator or TSDF who handles wastes mixed with nuclear source, special nuclear or by-
product material.
9 Universal waste is defined as including (a) Batteries as described in 40 CFR 273.2; (b) Pesticides as described in 40
CFR 273.3; and (c) Thermostats as described in 40 CFR 273.4; (d) Fluorescent light tubes as described in 7/6/99
Federal Register.
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Waste Codes
State or Federal codes corresponding to the hazardous wastes generated by a site as reported on
the site notification form. These codes are listed in 40 CFR Part 261, Subparts C and D or are
assigned by States for wastes that are either: 1) Regulated and defined as hazardous by the State
but are not regulated as RCRA hazardous waste, or 2) State equivalent waste codes for RCRA
regulated hazardous wastes.
GPRA corrective action universe
Indicates that the TSDF is a high priority for the Corrective Action program. This facility was
included in the Corrective Action Workload Universe and/or was also a high priority NCAPS
facility as of September 7th, 1997.
GPRA operating permit universe
Indicates that the TSDF had at least one unit that was operating or needed to obtain an operating
permit as of October 1, 1997
GPRA post closure universe
Indicates that this TSDF had at least one land disposal unit, or a storage/treatment unit that cannot
clean close, that ceased operating before October 1, 1997 and had not yet clean closed.
Annual BOY enforcement universe
The Annual Beginning of Year (BOY) Enforcement Universe identifies RCRA Sites (TSD, LQG
& SQG) that are actively managing hazardous waste and are a priority for the Enforcement
program. Unlike the other universes for the Permitting and Corrective Action program, the
universe for the enforcement program is not a static baseline; rather it is a standard definition
which is applied to the facilities at the beginning of each fiscal year beginning with FY2000.
The following information needs were identified during the PAA project and relate to the
operation of waste management units at TSDFs. This information is generally derived from
specific permit development activities, although a simple indication that the RCRA Sites is
engaged in treatment, storage or disposal activities is also made using the current Notification
and Biennial Report 1C Forms. While detailed analysis of these needs will be undertaken during
subsequent PAA projects, the information is also used to help define "universes" of sites for
RCRA implementation planning purposes and so has been included in this listing for
completeness.
TSDF unit type
Indicates the type of waste management process that is performed for a specific management unit
at a TSDF. This is typically referred to as the handling code for the management unit.
TSDF unit commercial type
Indicates whether the facility accepts and manages waste from other facilities. "Commercial"
facilities receive off-site waste for a fee. "On-site" facilities treat only their own wastes.
"Captive" facilities will accept wastes from a specific and narrow set of other facilities, typically
those owned or operated by the same parent company.
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TSDF unit operating status
Indicates the operating status of a TSDF management unit. Some typical values for these statuses
are: operating, clean closed, closing, under construction, abandoned.
TSDF unit legal status
Indicates the programmatic or legal status that determine the type of RCRA program activities
that take place at a TSDF management unit. Some typical values for these statuses: interim
status, permitted, permit terminated, post-closure permitted.
TSDF unit location
The location expressed as geospatial coordinates of a management unit operated by a TSDF.
Waste Activity Information Needs
Originating EPA ID
The unique assigned identifier of the RCRA Site that generated, or imported from another
country, hazardous waste.
Destination EPA ID
The unique assigned identifier of the RCRA Site that provides systematic separation, storage,
processing, treatment, recovery, and or disposal of hazardous wastes. This definition excludes
the collection and transportation of hazardous wastes.
Federal Waste Codes
Four character alphanumeric code that identifies each hazardous waste listed in 40 CFR Part 261,
Subpart D and to each characteristic identified in 40 CFR Part 261 Subpart C. "D codes" are
characteristic waste codes (reactive waste, arsenic, lindane); "F codes" are codes for wastes from
non-specific sources (spent cyanide plating bath solutions from electroplating operations); "K
codes" are wastes from specific sources (spent potliners from primary aluminum reduction); "P
codes" are acutely hazardous compounds (potassium cyanide); "U codes" are toxic compounds
(creosote, chloroform).
State Waste Codes
Four character alpha numeric hazardous waste code assigned by approved States for wastes that
are either: 1) Regulated and defined as hazardous by the State but are not regulated as RCRA
hazardous waste (e.g., X001 - Contaminated Pesticide Containers). 2) State equivalent waste
codes for RCRA regulated hazardous wastes.
Quantity
The amount of a given waste handled by a Generating or Managing RCRA Site during a specific
period of time.
Unit of Measure
The measuring unit of the quantity
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Management Method
The method used to separate, store, treat, process, recover, or dispose of hazardous waste.
Originating Country
The country in which the RCRA or State regulated waste was generated, if other than the United
States.
Destination Country
The country in which the RCRA or State regulated waste is to be managed, if other than the
United States.
Source of Wastes
Describes the production, service, waste management process or event that results in the
generation of the hazardous. For example, electroplating, plastics forming.
Waste Form
A code describing the physical form or chemical composition of a hazardous waste. For
example, spent acid with metals, halogenated solvent, aqueous waste with low solvents.
Waste Description
A general narrative description of the waste, the source and form, of the waste the type of hazard
posed and the primary hazardous constituents. For example, Ignitable spent solvent from
degreasing operation in tool production, consisting of a mixture of mineral spirits and kerosene.
Transporter EPA ID
The unique assigned identifier of a handler engaged in the offsite transportation of hazardous
waste by air, rail, highway or water.
Border Crossing
The physical location at which imported or exported hazardous waste crossed the US border to or
from an adjoining country.
Shipped Date
The date in which a given unit of hazardous waste is collected by a transporter for movement
from one RCRA Site to another.
Received Date
The date hazardous wastes are received by a Treatment, Storage or Disposal facility.
Manifest Number
A unique number used to identify a shipment and associated documentation of hazardous waste.
Mixed radioactive waste
Indicates that the wastes include or have been mixed with nuclear source, special nuclear or by-
product material.
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Foreign Recipient
Provides descriptive information about a foreign recipient of an exported waste. A foreign
recipient will typically not be assigned a valid EPA identification number but the RCRA program
still desires to have basic identification information about the foreign site for tracking purposes.
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APPENDIX IV: CURRENT SYSTEMS ASSESSMENT
Although the focus of a PAA is to identify the program's fundamental needs for information, an
understanding of the current systems is also necessary in order to highlight those areas where
support for information needs must be improved.
A high level representation of how information is currently collected and managed is presented in
Figure 11: Generalized Flow Diagram of Current Information Systems. The diagram is intended
to document the generalized situation and does not present all of the implementer-specific
variations. The boxes in the center of the diagram represent the procedures that are performed by
the implementer to collect information. The arrows indicate the flow of information, and the
circle on the right side of the diagram depicts the database systems used to manage the collected
information. There are four major national database systems that track UID and WAM
information. They are:
Resource Conservation and Recovery Information System (RCRIS),
Biennial Reporting System (BRS),
Waste International Tracking System (WITS), and
Hazardous Waste Exports System (HWES).
Although these systems serve different purposes, they each contain duplicate RCRA Site
identification information. This has resulted in:
information that is duplicated, of inconsistent quality and sometimes contradictory,
the development of workaround procedures to deal with the problems resulting from having
these non-integrated systems.
Some States have developed their own RCRA database systems either to provide a substitute
system tailored for their own specific needs, or to augment the national systems. For example,
Biennial Reporting software has been developed and distributed to States by some private
vendors and the State of Florida. To provide the waste activity information required by EPA,
States either:
do not track this information in-house but enter the information directly into the national
systems, or
enter the information into their own systems as well as the national system, or
enter information into their own system and use a translation mechanism to transmit the
information electronically into the national systems (termed translator States).
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Figure 11: Generalized Flow Diagram of Current Information Systems
Descriptions of Current Collection Mechanisms
The remainder of this section provides an overview of each of the information collection
procedures shown on the diagram. This includes descriptions of the Federal reporting
mechanisms along with some of the major State variants.
1)
Receive Notification form
RCRA Sites are required to submit a signed Notification form (EPA Form 8700-12) containing
basic site identification and RCRA activity information. Notification forms are submitted by sites
to the EPA Region or the authorized State to declare their RCRA activities (e.g., hazardous waste
generation, transportation, treatment, storage, disposal, or used oil activities). The Notification
form supports the reporting of the waste codes handled by each notifying RCRA Site (with the
exception of transporters who are not required to report this information). Some States have
developed alternative forms that contain modifications to the 8700-12.
Although most implementers receive notice of transporter activities on a Notification or similar
form, some States have broader regulations governing transporter activities, and require a
separate permitting or registration process be completed before allowing transporters to haul
hazardous waste in their state.
Current Federal regulations do not require RCRA sites to automatically submit subsequent
notifications. However, under certain circumstances, a regulatory agency may request that a
RCRA Site provide updated notification information. Such requests would occur when there is
some suspicion that the information currently held by the agency is inaccurate. For example,
based on a complaint, inspection, or information received from a TSDF that suggests
discrepancies in a generators RCRA activity records.
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In some cases, a Site may contact the agency to request that their information be updated.
Implementers will often receive voluntarily updated notification information from a site after the
initial notification. Some form of authorization is required by the implementing agency for most
but not all changes in notification information (e.g., some implementers would be willing to
record a change of a site contact name and phone number without a signed notification form
being submitted).
The State or Region records the information from the Notification form in RCRIS.
2) Assign EPA ID
The RCRA regulations require persons handling hazardous waste to obtain an EPA identification
number (with some exceptions, for example Conditionally Exempt Small Quantity Generators,
although they may still voluntarily notify). Once a Notification form has been received the
implementing agency assigns an EPA identification number to the applicant (i.e., technically, the
owner or operator; owner is used below to mean both). This number is then used for
correspondence between the Site and either regulators or other RCRA Sites (e.g., when shipping
waste).
The general understanding among State and EPA program staff is that an EPA identification
number is issued only once for any given location, although the basis for the policy is not stated
in Federal regulation. In practice, however, this principle has not been applied consistently, with
some implementers assigning more than one EPA identification number to the same RCRA Site.
For example some companies request that the implementer assign a new EPA identification
number when taking over an existing RCRA Site, to avoid association with the previous owner's
environmental record.
EPA Regions and some States assign EPA identification numbers using RCRIS or their own
automated systems. Some implementers assign false EPA identification numbers to temporary
sites as well as CESQGs, which are similar to the "federal" identification numbers but are not
entered into RCRIS.
3) Receive Part A Permit Application
Part A Permit Applications (EPA form 8700-23) are received by the implementing agency from
TSDFs wishing to receive a permit for a treatment, storage, or disposal process. Part A Permit
Applications are process based, and require detailed waste management and process-specific
information. Although a Part A Permit Application includes much of the same information a
Notification form must also have been submitted by the TSDF
The Part A Permit Application form collects information about the types of hazardous waste that
will be managed by a TSDF. The reporter identifies each waste code along with the process codes
that describe how they will be managing that waste, and an estimate of the annual volume that
will be managed. This waste code information is optional in RCRIS and is not always entered by
the implementer.
4) Receive notice of emergency site
During emergencies or for situations such as hazardous waste spills or drug lab cleanups, sites
may require an EPA identification number to be assigned quickly in order to prepare hazardous
waste manifests. The regulatory agency may receive an urgent letter or fax with the appropriate
information, or simply a telephone call. This will sometime be followed up at a later time with an
official Notification form, but in the case where a responsible party is not apparent, a Notification
form may never be received.
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For States who don't assign EPA identification numbers directly, emergency situations may
necessitate assigning a "temporary" or "emergency" identification number, sometimes from a
predefined list. No check is then performed to validate the site as a location within RCRIS.
5) Receive Biennial Report10 1C form
The Biennial Reporting Identification and Certification (1C) form requests basic site identification
and activity information. RCRA Sites may respond by filling out the paper form or by submitting
digital information produced with the aid of available software.
Some States implement their own waste reporting forms on a more frequent basis which include
(and sometime go beyond) the information required by the Biennial Reporting forms.
Sometimes the implementer includes a "postcard" so that if a RCRA Site receives a reporting
package but does not believe that they are required to report, they can indicate this on the card
and return it to the implementer.
6) Receive Biennial Reporting GM form
The Biennial Reporting GM form is the main Federally supported reporting mechanism used for
collecting information about waste generation, shipment, and on-site management. States that
have their own reporting requirements either subsume the Federal reporting requirements in their
own forms, or require Sites to complete the Federal forms along with the State's additional forms.
EPA requires reporting of one year's waste generation, shipment, and on-site management every
two years. Some States collect similar information annually or quarterly, and collect information
for all such periods, instead of every other period.
7) Receive Biennial Reporting WR form
The Biennial Reporting WR form is the main Federally supported reporting mechanism used for
collecting information about waste receipt and management11. States that have their own reporting
requirements either subsume the Federal reporting requirements in their own forms, or require
Sites to complete the Federal forms along with the State's additional forms.
10 The term "Biennial Reporting form" refers to the Hazardous Waste Report instructions and forms (i.e., EPA form
8700-13A/B) federally required to be submitted by LQGs and TSDFs every other (odd) year. Although SQGs and
Conditionally Exempt Small Quantity Generators (CESQGs) are exempt from Federal reporting requirements, they
may be required to report by the State in which they reside, or may report voluntarily.
Implementers use a variety of methods to determine which RCRA Sites should receive blank reporting forms. Methods
used include using the previous reporting cycle's mailing list, supplementing that list with new notifiers in RCRIS, or
obtaining a complete list of notifiers from RCRIS and excluding only the RCRA Sites that are not part of a State's
required reporting universe.
Some implementers allow reporters to submit their information electronically to the agency. In such cases, a signed
certification form is submitted along with the data files. Electronic reporters either use State developed, third party, or
internally developed software to capture the reported information and to format it to the specification required by the
implementer.
Regardless of how each implementer collects this waste activity information, all implementers must submit information
into the national Biennial Report System (BRS).
11 Federal reporting regulations also require used oil processors, refiners and collection centers to report their used oil
handling activities at least biennially although this is not achieved via the hazardous waste Biennial Reporting forms.
Because these regulations were promulgated pursuant to RCRA rather than HSWA, they are not effective in authorized
States until the State adopts them, and many States have not. Where this information is collected, paper forms are
received, and the data is entered into custom information systems.
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EPA requires reporting of one year's waste receipt and management every two years. Some
States collect similar information annually or quarterly, and collect information for all such
periods, instead of every other period.
8) Receive waste export and import forms
All RCRA Sites (with the exception of CESQGs) exporting hazardous wastes to countries that are
covered by the Organization for Economic and Commercial Development (OECD)12 from the US
must submit to OECA a report of hazardous wastes exported on an annual basis. OECA tracks
this reported information in the Hazardous Waste Exports System (HWES). Current rule excludes
generators who export wastes from having to report in the Biennial Reporting Cycle. Despite this
some generators also submit waste generation information on the Biennial Reporting forms.
There is a high degree of overlap between information required on the Annual Export Report and
that required by Biennial Reporting forms.
Hazardous waste management facilities (or their import agents) receiving hazardous waste from a
foreign country notify the appropriate EPA Regional office of its intent to receive a foreign
shipment four weeks before the initial shipment being received. Subsequent shipments from the
same source and the same type of hazardous waste do not require any additional notification.
OECA receives these forms and enters them into the Waste Import Tracking System (WITS).
Hazardous waste import information is captured in BRS through reporting on the WR forms by
the TSDF. Identification of the country of origin and generator is performed inconsistently across
the nation. Some State use special numbering systems to indicate foreign generators, while
instructions of the Biennial Reporting WR form instruct respondents to indicate FC + foreign
country name.
9) Receive hazardous waste manifest
Although the use of manifests by TSDFs, LQGs and SQGs is required (or the similar shipping
agreement / log allowed for SQGs), there is no Federal requirement to send copies of hazardous
waste manifests to States or EPA. However, approximately half of the States have a requirement
that RCRA Sites who generate or dispose within their jurisdiction must submit a copy of their
hazardous waste manifests to the agency. A copy of the manifest is sent to the State from both the
generator and the receiving TSDF.
In these States, the information obtained from manifests is entered directly into a State
information system, or filed. Some States are experimenting with electronic manifesting.
When hazardous waste loads are rejected by a TSDF, a rejected load report may be required by
the State. The Region or State environmental agencies may receive letters reporting
discrepancies in hazardous waste amounts. Discrepancy reports are required in certain cases, but
this information is difficult to collate and organize.
EPA OECA receives manifests from customs officials for each trans-border shipment of
hazardous waste via land.
12 OECD countries consist of Australia, Austria, Belgium, Denmark, Finland, France, Germany, Greece, Iceland,
Ireland, Italy, Japan, Luxembourg, Netherlands, New Zealand, Norway, Portugal, Spain, Sweden, Switzerland, Turkey,
and the United Kingdom. Canada and Mexico are considered OECD member only for the purpose of transit.
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APPENDIX V: TSDF UNIVERSE DEFINITIONS
The following definitions are proposed for a number of logical groups or universes of RCRA
Sites. Each of the following definitions is accompanied by a legal and operating status code
matrix. A key for these codes as applied to management units is provided at the end of this
section.
Guidelines for the Permitting / Closure / Post-closure
Programmatic Universes
Date of Last Revision: 7/20/99
Number of Universes: 5
Names: GPRA Operating Permit Baseline Universe
GPRA Post-Closure Baseline Universe
Permit Workload Universe
Closure Workload Universe
Post-Closure Workload Universe
Differences between the universes:
The primary difference between the universes is that the GPRA Baseline universes are static lists
of facilities that will not change over time. The GPRA Baseline universes will report on
achievements within that set list.
The Workload universes will change over time as events at a facility cause it to move from the
permit track to the closure or post-closure track or as new facilities apply for permits.
Changes from old universe system:
The principle universes that OSW will focus on for reporting progress will be the GPRA Baseline
Permit Universe and the GPRA Baseline Post-Closure Universe. GPRA is meant to focus on a
priority subset of the program. The GPRA universes do not include the entire scope of work of
the program. The Land disposal facilities on the post-closure track and the operating facilities
were identified as the priority groups for the RCRA program to track under GPRA. The
workload universes are available to support management of the ongoing permit, closure, and
post-closure tracks. The public should have access to both the GPRA and Workload information.
Clear explanations need to be provided to the public about what both the GPRA and Workload
universes cover and why they both exist.
Note that all of these universes, the GPRA Baseline universes and the Workload universes, are
derived from unit information. Therefore, it is possible for a single facility to be in more than one
universe, including being in both GPRA Baseline universes and being in more than one Workload
universe.
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GPRA Operating Permit Baseline Universe
DEFINITION OF UNIVERSE:
Any Treatment, Storage and/or Disposal Facility (TSDF) that had at least one unit that was
operating or needed to obtain an operating permit as of October 1, 1997. (For example, if in
1997, a facility had an operating unit in interim status waiting to be permitted, the facility would
be included in the GPRA Baseline Operating Permit Universe).
PURPOSE of UNIVERSE (who uses it and what for):
1. The purpose of this baseline universe is to track the permitting program's success in meeting
the GPRA goal for safe waste management practices through the year 2005.
2. This will be the principle universe used by OSW to track operating permits since OSW is
now focusing on progress toward the GPRA goals.
3. Regions and States will use this universe to track the progress made toward their GPRA goals
and report to OSW.
4. Regions and States have the responsibility of making sure that the data for every unit in the
baseline universe are up-to-date, especially the legal and operating status code data.
HOW IS UNIVERSE DETERMINED:
Every facility in this universe has a GPRA operating permit universe flag associated with it. The
universe is pulled based on this flag. The universe is designed to be a static universe. New
facilities/units will not enter the baseline universe and existing facilities/units in the baseline
universe will not be removed over time. The 1997 baseline was developed using the Permit
Workload Universe from October 1st, 1997. The list of facilities in the universe was pulled from
RCRIS and sent to the Regions and States for verification. Once the list was verified and revised,
the universe was set by the GPRA flags. While the program is no longer using the legal and
operating status codes to identify the facilities in the baseline universe, OSW will be using them
to measure success toward GPRA goals. The legal and operating status codes (of the units within
the baseline facilities) will indicate if safe waste management practices are being initiated.
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GPRA Post-Closure Baseline Universe
DEFINITION OF UNIVERSE:
Any Land Disposal Facility (LDF) that had at least one land disposal unit that ceased operating
before October 1, 1997 and had not yet clean closed. (For example, in 1997, if a facility had an
inactive land disposal unit, then the facility is included in the GPRA Baseline Post-Closure
Universe). Every facility that met the definition for the RCRIS Post-Closure Workload Universe
as of October 1, 1997, should be included in the GPRA Baseline Post-Closure Universe.
PURPOSE of UNIVERSE (who uses it and what for):
1. The purpose of this baseline post-closure universe is to track the success in meeting the
GPRA goal for safe waste management practices through 2005.
2. This will be the only universe used by OSW to track post-closure since OSW is now focusing
strictly on progress toward the GPRA goals..
3. Regions and States will use this universe to track the progress made toward their GPRA goals
and will use this universe to report to OSW on post-closure.
4. Regions and States have the responsibility of making sure that the data for every unit in the
baseline universe are up-to-date, especially the legal and operating status code data.
HOW IS UNIVERSE DETERMINED:
Every facility in this universe has a GPRA post-closure universe flag associated with it. The
universe is pulled based on this flag. The universe is designed to be a static universe. The 1997
baseline was developed using the Post-Closure Workload Universe numbers from October 1st,
1997. The Post-Closure Workload Universe was derived from the legal and operating status code
matrix in the permit module of RCRIS. The list of facilities in the universe was pulled and sent to
the Regions and States for verification. Once the list was verified and revised, the universe was
set by the GPRA flags. While the program is no longer using the legal and operating status codes
to identify the facilities in the baseline universe, OSW will be using them to measure success
toward GPRA goals. The legal and operating status codes (of the units within the baseline
facilities) will indicate if safe waste management practices are being initiated.
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Permit Workload Universe
DEFINITION OF UNIVERSE:
Any facility with units that are in the permit pipeline as well as units with active permits. The
permit pipeline includes any operating facility that is currently permitted or operating under
interim status, and any facility with new units that are proposed or in the process of being
constructed.
PURPOSE of UNIVERSE (who uses it and what for):
1. Allows the Regions and States to manage all the facilities that are in line to be permitted or
are currently permitted.
2. Provides information to the public on all permitted and "to be" permitted facilities in the
RCRA program.
3. Provides a changing universe which will allow the program to track or report on the current,
real-world status of the permit program (as opposed to the static GPRA Baseline operating
permit universe).
HOW IS UNIVERSE DETERMINED:
Uses the legal and operating status code matrix in the Permits Module of the RCRAInfo database.
The universe will include any facility that has at least one unit with any of the appropriate legal
and operating status code combinations (see matrix below). To enable the user to break the entire
universe out by type of operating TSDF or select only a particular type of TSDF (e.g.,
combustion facilities), the select logic will breakout these facilities according to the LIBST flag
in the handler module.
The applicable legal and operating status codes have been modified based on comments from the
program. Operating or constructing facilities that are also non-notifiers are no longer included in
the permit workload. They have been transferred to the closure workload to more closely reflect
the program practice of closing illegal facilities instead of giving them operating permits.
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Permit Workload Universe
PI
PC
PT
PR
IS
LI
IT
TA
PM
LP
NN
RQ
NR
DL
RD
RU
EM
SR
OP
X
X
X
X
X
CN
X
X
X
X
X
X
uc
X
X
X
X
X
X
BC
X
X
X
X
X
X
IN
cc
CP
CO
DC
CV
CR
AB
SF
PF
CA
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Closure Workload Universe
DEFINITION OF UNIVERSE:
Any facility with units that are closing. Facilities are included in the universe up to the time that
closure certification is verified by the Agency. This universe does not include facilities that have
completed closure and been verified by the Agency (i.e., certified clean closed or certified closed
with waste in place) and those facilities going through post-closure.
PURPOSE of UNIVERSE (who uses it and what for):
1. Allows the Regions and States to manage all the facilities that are on the closure track (e.g.,
inactive facilities that will close or are in the process of closing).
2. Provides information to the public on facilities with closing units.
3. This is the only universe that will track or report on closure.
HOW IS UNIVERSE DETERMINED:
Uses the legal and operating status code matrix in the Permits Module of the RCRAInfo database.
The universe will include any facility that has at least one unit with any of the appropriate legal
and operating status code combinations (see matrix below). To enable the user to break the entire
universe out by type of TSDF or select only a particular type of TSDF (e.g., combustion
facilities), the select logic will breakout these facilities according to the LIBST flag in the handler
module.
The applicable legal and operating status codes have been modified based on comments from the
program. Operating or constructing facilities that are also non-notifiers are now included in the
closure workload, instead of the permit workload as they were previously captured. They were
transferred to more closely reflect the program practice of closing illegal facilities instead of
giving them operating permits.
Also, units that have been transferred to Superfund have been removed from the universe since
they would no longer be in the RCRA program's "workload".
V-6
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Closure Workload Universe
PI
PC
PT
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TA
PM
LP
NN
RQ
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SR
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CN
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BC
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IN
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cc
CP
CO
DC
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cv
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CR
AB
X
X
X
X
X
X
X
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SF
PF
CA
V-7
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Post-Closure Workload Universe
DEFINITION OF UNIVERSE:
Facilities with closing land disposal units and storage units closing as landfills. If a unit clean
closes, it is removed from this universe once the clean closure is certified by the Agency.
PURPOSE of UNIVERSE (who uses it and what for):
1. Allows the Regions and States to manage all the land disposal facilities that are undergoing
post-closure or are currently inactive and planning to go through post-closure.
2. Provides information to the public on all post-closure activites in the RCRA program.
3. Provides a changing universe which will allow the program to track or report on the current,
real-world status of post-closure (as opposed to the static GPRA Baseline post-closure
universe).
HOW IS UNIVERSE DETERMINED:
Uses the legal and operating status code matrix in the Permits Module of the RCRAInfo database.
The universe will include any facility that has at least one unit with any of the appropriate legal
and operating status code combinations (see matrix below). Because the universe is limited to
the Land Disposal facilities only, the select logic will link to the LIBST flag in the handler
module and select only those facilites with an L flag.
Note: The applicable legal and operating status codes have been modified based on comments
from the program. Units that have been transferred to Superfund have been removed from the
universe since they would no longer be in the RCRA program's "workload".
Note on Storage facilities closing as landfills: To correctly document changes from a unit
currently listed as a storage unit that will close as a landfill, document a new landfill process code
(D80) for the existing unit. Do not erase or overwrite the previous process code. The system is
designed to pick up the most recent process code for a unit to determine the LIBST flag.
-------
Post-Closure Workload Universe
PI
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CN
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cc
CP
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CO
DC
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cv
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CR
AB
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SF
PF
CA
V-9
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Guidelines for the Enforcement Programmatic Universes
Date of Last Revision: 1/13/00
Number of Universes: 3
Names: Annual BOY Enforcement Universe
Full Enforcement Universe
Operating TSDF Universe
Differences between the universes:
Annual Beginning of Year Enforcement Universe
The Annual Beginning of Year (BOY) Enforcement Universe identifies RCRA Sites (TSDFs,
LQGs and SQGs) that are the highest priority for the enforcement program. Unlike other GPRA
universes for the Permitting and Corrective Action program, the Annual BOY Enforcement
universe is not a static baseline; rather it is a standard definition which is applied to the facilities
at the beginning of each fiscal year beginning with FY2000.
The Full Enforcement Universe
Previously referred to as the "Subject to CEI" universe, this universe is meant to capture any
TSDF that could potentially be evaluated for compliance with the applicable TSDF requirements
found in 40 CFR Parts 264/265, and/or authorized state equivalents (e.g., land disposal,
incinerator, BIF, storage or treatment).
The Operating TSDF Universe
New universe that captures the facilities that are required to have an biennial CEI, namely the
operating TSDFs. This universe is a sub-set of the Full Enforcement Universe (currently the
HUSUBJCEI). In addition, most FOIA requests for TSDFs want the operating TSDFs. This
universe will be able to be broken out by type of TSDF (e.g., land disposal, incineration, BIF,
storage or treatment).
Changes from old universe system:
The Operating TSDF Universe becomes the main universe for TSDF enforcement information
and FOIA requests on TSDFs.
V-10
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Annual Beginning of Year Enforcement Universe
DEFINITION OF UNIVERSE:
The Annual Beginning of Year (BOY) Enforcement Universe identifies facilities (TSD, LQG &
SQG) that are actively managing hazardous waste and are a priority for the Enforcement
program. Unlike the other universes for the Permitting and Corrective Action program, the
universe for the enforcement program is not a static baseline; rather it is a standard definition
which is applied to the facilities at the beginning of each fiscal year beginning with FY2000.
This beginning of year universe, which will consist of specific facilities by EPA identification
number, will show the RCRA enforcement program's activity throughout that fiscal year. This
universe will be identifiable by a repeating field with an associated year indicator to allow the
identification of which facilities make up the universe for each fiscal year.
PURPOSE of UNIVERSE (who uses it and what for):
1. The main purpose of this universe is to identify facilities that are actively treating, storing,
disposing or generating hazardous waste.
2. Regions and States will have the responsibility of making sure that the information on each
facility in this universe are up-to-date, including facility operating and legal status codes for
TSDs in the permits module and bankruptcy indicator flags in the handler module.
Enforcement data (evaluations, violations and enforcement actions, and Significant Non-
Complier (SNC) information) must also be up-to-date.
3. HQ, Regions and States will use this universe to track RCRA program activity.
4. Subsets of this universe will be used to analyze and measure the RCRA enforcement
programs's activity in the enforcement priority areas. These subsets will be used for GPRA
purposes.
HOW IS UNIVERSE DETERMINED:
This universe identifies facilities that have units that are actively treating, storing, disposing or
generating hazardous waste based on the hierarchy of combustion (boilers and industrial furnaces
and incinerators combined), land disposal, treatment/storage, large quantity generators and small
quantity generators.
TSDFs
For the treatment, storage and disposal universes, facilities that are not actively managing
hazardous waste are eliminated. TSD facilities in this universe are derived based on the operating
and legal status codes associated with each individual hazardous waste management unit in the
Permits Module of the data system. Facilities with HBANKRUPT not equal to 'F' (= responsible
parties have fled the country) OR 'C' (= RCRA responsibilities have transferred to the CERCLA
program) are selected.
LOGs
The Large Quantity Generator universe will be retrieved from the most current Biennial
Reporting System (BRS) data available (e.g.: FY 99 & FY 00 will use FY97 BRS data, other
years will use FY99 BRS data once it becomes available or until RCRAInfo and BRS data are
combined). These BRS LQG IDs will be then matched with RCRIS/RCRAInfo LQG IDS which
have had any enforcement activity in the last five years. (Any enforcement activity is defined as
having any evaluation, violation or enforcement data in the CM&E module with a date in the last
five years.) Facilities with HBANKRUPT not equal to 'F' (= responsible parties have fled the
country) OR 'C' (= RCRA responsibilities have transferred to the CERCLA program) are
V-ll
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selected. These LQG IDs will be flagged and included in the Annual BOY Enforcement
Universe.
The Small Quantity Generator universe will be retrieved from RCRIS/RCRAInfo SQG IDs which
have had any enforcement activity in the last five years. (Any enforcement activity is defined as
having any evaluation, violation or enforcement data in the CM&E module with a date in the last
five years.) Facilities with HBANKRUPT not equal to T' (= responsible parties have fled the
country) OR 'C' (= RCRA responsibilities have transferred to the CERCLA program) are
selected. These SQG IDs will be flagged and included in the Annual BOY Enforcement Universe.
Select Logic (originally sent out to the user community on June 30. 1998):
The latest process code, legal status code, and operating status code associated with a particular
unit is selected using PU_DATE. These process codes are translated into an associated TSD type
(B for BIF, I for Incinerator, L for Land Disposal, and S for Storage/Treatment). Facilities with
HBANKRUPT not equal to 'F' (= responsible parties have fled the country) OR 'C' (= RCRA
responsibilities have transferred to the CERCLA program) are selected. The following Legal
Status Codes will be included 'EM', 'IS', 'LP', 'NN', 'PI', 'PM', 'RD', 'RQ' or 'TA' ONLY if
the Operating Status Code is 'OP'. (See legal/operating matrix below.)
The following hierarchy is used for each facility and a facility can only fall into one universe:
Universe
Combustion, (INC & BIFs)
Land Disposal
Treatment Storage
LQG
SQG
V-12
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Annual BOY Enforcement Universe
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CC
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AB
SF
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CA
V-13
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Full Enforcement Universe (existing universe = HUSUBJCEI)
DEFINITION OF UNIVERSE:
The entire universe of TSDFs that could potentially undergo a Compliance and Evaluation
Inspection (CEI) to be evaluated for compliance with the applicable TSDF requirements found in
40 CFR Parts 264/265 and/or authorized State equivalents. Not every facility in this universe will
undergo an annual inspection. This universe includes both currently operating TSDFs as well as
closed but not yet certified closed TSDFs. This universe can be broken out by type of TSDF (i.e.,
incinerator, boiler and industrial furnaces (BIFS), combustion (combustion = incinerators +
BIFS), land disposal, treatment/storage, etc.)
PURPOSE of UNIVERSE (who uses it and what for):
1. Identify the full universe of TSDFs that are legally subject to TSDF operations and
management regulations under RCRA Subtitle C.
2. Used by State and Regional programs to identify all the facilities that could undergo a
Compliance and Evaluation Inspection (CEI) against the TSDF regulations. (The Operating
TSDF Universe identifies the TSDFs that are required to have a CEI biennially because they
are still operating).
3. OECA will use this universe for trend analysis to compare the "Operating universe" over
time to the "Full Enforcement universe". This analysis will provide valuable information for
RCRA enforcement oversight of resources and also program performance.
HOW IS UNIVERSE DETERMINED:
The Full Enforcement Universe is derived from the Legal and Operating status code matrix.
Since only the name has been changed, this universe still uses the same legal and operating status
code combinations as the TSDFs Subject to CEI Universe (HUSUBJCEI) logic listed below. To
enable the user to break the entire universe out by type of operating TSDF or select only a
particular type of TSDF (e.g., combustion facilities), the select logic will breakout these facilities
according to the LIBST flag in the handler module.
V-14
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Full Enforcement Universe
PI
PC
PT
PR
IS
LI
IT
TA
PM
LP
NN
RQ
NR
DL
RD
RU
EM
SR
OP
X
X
X
X
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X
X
X
X
X
CN
uc
BC
IN
X
X
X
X
X
X
X
X
X
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cc
CP
X
X
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CO
DC
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X
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cv
CR
AB
SF
PF
CA
X
X
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X
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V-15
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Operating TSDF Universe
DEFINITION OF UNIVERSE:
Captures every facility that currently has an operating Treatment, Storage, or Disposal unit. This
universe can be broken out by type of TSDF (i.e., incinerator, boiler and industrial furnaces
(BIFS), combustion (combustion = incinerators + BIFS), land disposal, treatment or storage,
commercial, etc.)
PURPOSE of UNIVERSE (who uses it and what for):
Operating TSDF facilities are subject to the full RCRA subtitle C requirements and are one of the
highest priorities to the RCRA enforcement program.
Uses for this universe are:
1. Primary enforcement reporting universe for TSDFs information. This universe includes
every facility that is required to undergo a Compliance and Evaluation Inspection (CEI)
biennially.
2. This universe will be used for developing State grant commitments on TSDF inspections and
reporting on the progress of State and Regional programs against their MO A requirements.
3. This universe will also be the basis for statistical work on national progress of the program
for inspection targets and accomplishments.
4. Provides the list of all currently operating TSDFs for FOIA requests. An additional reporting
feature includes the ability to break this universe out by type of TSD.
5. This universe will be used by the RCRA Enforcement program for Agency GPRA measures.
HOW IS UNIVERSE DETERMINED:
Facilities that are not actively managing hazardous waste have reduced regulatory requirements
and are excluded from this universe. This includes facilities where all units are closed with waste
in place, in closure or in post-closure care. The Operating TSDF universe is derived from the
Legal and Operating status code matrix: All facilities listed as operating with the legal status of:
PI, IS, TA, PM, LP, NN, RQ, RD and EM are included in the universe. Facilities with
HBANKRUPT not equal to 'F' (= responsible parties have fled the country) OR 'C' (= RCRA
responsibilities have transferred to the CERCLA program) will be selected. To enable the user to
break the entire universe out by type of operating TSDF or select only a particular type of TSDF
(e.g., combustion facilities), the select logic will breakout these facilities according to the LIBST
flag in the handler module.
V-16
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Operating TSDF Universe
PI
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V-17
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Guidelines for the Corrective Action Programmatic Universes
Date of Last Revision: 6/15/99
Number of Universes: 4
Names: GPRA Corrective Action Baseline Universe
TSDFs Potentially Subject to Corrective Action Under
3004(u)/(v)
TSDFs Only Subject to Corrective Action Under Discretionary
Authorities
Non-TSDFs where RCRA Corrective Action has been Imposed.
Differences between the universes:
The GPRA Baseline universe is a static list of facilities that will not change over time unless a
facility becomes unreachable by the RCRA program (e.g., abandoned or bankrupt). The GPRA
Baseline universe will report on achievements over time within that set list. The remaining
corrective action universes can change. For example, facilities will be added to the TSDFs
Potentially Subject to Corrective Action under 3004(u)/(v) Universe as new facilities apply for a
permit or if newly listed wastes create additional facilities with interim status. Non-notifiers will
be added to the TSDFs Only Subject to Corrective Action Under Discretionary Authorities as
they are identified.
The GPRA Baseline universe is now the only universe that overlaps with the other universes.
The remaining universes have been modified so that a facility will only fall into one universe (2-4
as listed above).
Changes from old universe system:
Based on comments, the universe structure has been changed. The Corrective Action universes
were formerly arranged as sets and subsets of a broad "Subject to CA" universe. Under the new
structure, the universes are segmented so that, with the exception of the GPRA Baseline universe,
each universe pulls a unique group of facilities. The GPRA Baseline universe is now the only
universe that overlaps with other universes. The revised configuration of the universes still
allows the program to capture the group facilities that are currently captured under the CA
Workload universe, and thus continues to support the program's priorities for addressing
corrective action.
With regards to how the universes are pulled from the database, the following changes have been
made: Units that have an operating code of SF (Superfund) are no longer captured in any
corrective action universe. In addition, for the TSDFs Potentially Subject to §3004(u)/(v)
Universe, units that are have an operating status code AB (abandoned) are not included. This
change was made because AB facilities will never be permitted.
V-18
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GPRA Corrective Action Baseline Universe
DEFINITION OF UNIVERSE
The 1997 baseline list of facilities that are the highest priority for the Corrective Action program.
PURPOSE of UNIVERSE (who uses it and what for):
1. The main purpose of this universe is to track the corrective action program's success in
meeting the GPRA clean-up sub-objective for the RCRA program against a 1997 baseline.
2. This will be the primary universe used by OSW to track the corrective action program
through 2005. (Note: The GPRA sub-objectives have specific milestones (Environmental
Indicators, events CA725 and CA750) to measure progress. These will continue to be the
sole reporting measures for GPRA progress. However, OSW will use the Corrective Action
GPRA Baseline Universe to track additional events in reviewing the overall progress of the
Corrective Action program.).
3. It is important that Regions and States keep the information on each facility in this universe
up-to-date in the database, especially the corrective action events and other information in the
Corrective Action Module.
4. Regions and States will use this universe to report to OSW on the progress made toward their
GPRA commitments.
5. Information regarding progress at these sites will be posted by OSW on EPA's Corrective
Action Web Page, including the status of the Environmental Indicators and other events
(http://www.epa.gov/correctiveaction/).
HOW IS UNIVERSE DETERMINED:
This universe is a static baseline universe; the facilities in it do not change over time, with the
rare exception of those facilities that become unreachable (e.g., abandoned or bankrupt). This
allows the RCRA program to measure progress over time against a fixed baseline. The facilities
on this list were selected jointly by HQ, Regions and States. The facilities are identified in a file
of RCRA Identification Numbers on the mainframe, maintained by OSW. Reports can be run
against this file of ID#s, so that only information regarding the facilities in this baseline universe
are selected and reported. The 1997 baseline was initially developed based on the Corrective
Action Workload Universe facilities that were also High NCAPS priority as of September 7th,
1997. The proposed list of facilities for the universe was pulled and sent to the Regions and
States for verification. The Regions and States had the opportunity to add in an additional 15% of
facilities that were identified as a priority in that Region or State. Once the list was verified and
revised, the official file of ID#s was created by OSW.
V-19
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TSDFs Potentially Subject to Corrective Action Under §3004(u)/(v)
DEFINITION OF UNIVERSE:
The universe consists of the Treatment, Storage and/or Disposal (TSD) Facilities that could
potentially be required to address corrective action through the statutory requirements under
§3004(u)/(v). An important feature to note is that this universe is not driven by what is used to
implement corrective action. It is only focused on which facilities are potentially subject to the
3004(u)/(v) requirements. Therefore, the universe will not change based on which authority is
actually used to implement the corrective action (i.e., 3004(u)/(v), 3008(h), 7003, 3013, State
only authorities).
PURPOSE of UNIVERSE (who uses it and what for):
1. The universe captures the TSDFs that have permits and those facilities in interim status that
have not yet clean closed. The statute requires all permitted facilities, both operating and
post-closure, to address corrective action (i.e., determine whether or not corrective action is
needed and implement it, if needed). Interim status facilities fall into this universe because
they will be permitted unless they clean close. The interim status facilities stay in this
universe until the Agency has confirmed that they have clean closed.
2. OSW will use this §3004(u)/(v) universe to identify the TSDFs that will have to address
corrective action under the statutory requirements §3004(u)/(v), if they are permitted. This
includes the §3004(u)/(v) Medium and Low NCAPS TSDFs that are not all captured by the
Corrective Action GPRA Baseline Universe.
3. Regions and States will use this universe as a prioritization tool to identify the Medium and
Low NCAPS TSDFs that have to address corrective action under the §3004(u)/(v)
requirements and to identify any new High NCAPS sites that come into the program after
September 7, 1997 (GPRA Baseline cut off date).
4. All of the facilities in this universe must be assessed for corrective action, per ongoing CA
guidance in the RCRA Implementation Plan (RIP).
HOW IS UNIVERSE DETERMINED:
The facilities making up the TSDFs Potentially Subject to Corrective Action Under §3004(u)/(v)
Universe are identified using the legal and operating status code matrix in the permits module of
the database. The universe will include any facility that has at least one unit in any of the
appropriate legal and operating status code combinations (see matrix below). Facilities with all
units transferred to Superfund (SF), or listed as abandoned (AB) are not captured in this universe.
V-20
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TSDFs Potentially Subject to Corrective Action Under §3004(u)/(v)
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V-21
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TSDFs Only Subject to Corrective Action under Discretionary Authorities
DEFINITION OF UNIVERSE:
The universe consists of the Treatment, Storage and/or Disposal (TSD) Facilities that are only
subject to corrective action under the discretionary corrective action authorities. (Primarily
3008(h) - although these facilities are also subject to §7003, not every RCRA handler subject to
§7003 is also subject to §3008(h)). Every facility in this universe is outside of the scope of the
§3004(u)/(v) permitting requirements. The facilities in this universe are only potentially subject
to corrective action under discretionary authority - not every facility listed here will need
corrective action or be required to do corrective action.
PURPOSE of UNIVERSE (who uses it and what for):
1. The purpose of this universe is to capture the TSDFs where the program only has
discretionary enforcement authority to require corrective action. These facilities are only
subject to enforcement authorities, not the 3004 (u)/(v) authority. This includes clean closed
facilities, non-notifiers, abandoned facilities, converters, loss of interim status, and permit by
rule facilities.
2. Using this universe in combination with the §3004(u)/(v) universe will allow the programs to
identify all the TSDFs potentially subject to the specific corrective action requirements in the
RCRA statute (i.e. 3004(u)/(v) and 3008(h)).
3. For reporting purposes, OSW will be more interested in capturing the facilities that have
initiated corrective action as opposed to the entire universe.
4. Several Regions use this universe, in addition to the TSDFs subject to corrective action under
§3004(u)/(v), to determine which TSDFs need to be assessed for corrective action.
HOW IS UNIVERSE DETERMINED:
The facilities making up the TSDFs Only Subject to Corrective Action Under Discretionary
Authority Universe are identified using the legal and operating status code matrix in the permits
module of the database. The universe will include any facility where at least one of the units has
the appropriate legal and operating status code combinations listed below plus none of the units
can have any of the 3004(u)/(v) status code combinations. This select logic prevents overlap
between the two universes. Facilities with all units transferred to Superfund (SF) are not captured
in this universe.
V-22
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TSDFs Only Subject to Corrective Action Under Discretionary Authorities
PI
PC
PT
PR
IS
LI
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TA
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EM
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CN
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IN
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SF
PF
CA
X
X
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X
X
X
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X
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V-23
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Non-TSDFs Where Corrective Action has been Imposed
DEFINITION OF UNIVERSE:
The universe consists of the RCRA handlers that are NOT Treatment, Storage and/or Disposal
(TSD) Facilities where corrective action has been imposed (e.g., generator conducting corrective
action under a §7003 order). Handlers are only included in this universe once they've initiated
corrective action through an RFI.
PURPOSE of UNIVERSE (who uses it and what for):
1. The purpose of this universe is to account for the additional handlers where the program is
conducting corrective action activities.
2. Regions and States can use this universe to track and account for non-TSDF corrective action
work.
3. Headquarters will use this universe in conjunction with the TSDFs Subject to Corrective
Action Under §3004(u)/(v) Universe and the TSDFs Only Subject to CA Under §3008(h)
when identifying and reporting on the entire scope of corrective action work taking place
within the program and, when needed, to capture the entire set of facilities formerly captured
under the CA Workload Universe.
HOW IS UNIVERSE DETERMINED:
Any non-TSDF handler with an RFI Imposed (CA100). Non-TSDFs will be identified in the
database (process TBD based on RCRAInfo design).
V-24
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Operating Status Code Definitions
AB Abandoned.
Use AB for units at which the owner or operator is unwilling/unable to accept legal responsibility
to close the unit.
BC Before Construction.
Use BC for proposed "new" units for which Parts A and B of the Permit Application have been
received. In most cases BC represents the "grassy field" scenario where no ground has been
broken.
CC Clean Closed.
Use CC to designate a unit that has completed clean closure. Closure is completed when all
closure activities have occurred, and closure has been verified. This usually includes closure
certification (sections 264.115 and 265.115), inspection of the unit to verify that the closure was
conducted in accordance with the approved closure plan, and release of the owner or operator
from financial assurance (sections 264.143(i) and 265.143(h)).
CN Constructed, Not Yet Managing Hazardous Waste.
Use CN for existing units entering the "RCRA process pipeline," but are not yet managing
hazardous waste. For example: Newly-permitted units that have completed construction but
have not yet begun managing hazardous waste; units that have managed only non-RCRA waste
but are pursuing RCRA permits to manage hazardous waste; units that are clean closed and then
upgraded to resume management of RCRA-regulated hazardous waste.
CO Completed Post-Closure Care.
Use CO to indicate that the post-closure care period at the unit has been completed.
CP Closed With Waste in Place.
Use CP to designate a unit that has completed closure with waste-in-place. Closure is completed
when all closure activities have occurred, and closure has been verified. This usually includes
closure certification (sections 264.115 and 265.115), inspection of the unit to verify that the
closure was conducted in accordance with the approved closure plan, and release of the owner or
operator from financial assurance (sections 264.143(i) and 265.143(h)).
CR Conducting Activities not Requiring a Permit.
Use CR to designate former TSDF units that conduct only activities not subject to permitting. CR
should be limited, however, to units that had no legal requirement to close.
CV Converted but Not RCRA Closed.
Use CV to designate units that converted to hazardous waste activities that do not require a permit
(e.g., less than 90-day storage, totally enclosed treatment) but were required to clean close and
did not.
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DC Delay of Closure.
Use DC to designate landfill, land treatment, or surface impoundment units that have received the
final volume of hazardous waste but, rather than begin closure, will continue to operate to receive
non-hazardous waste under the authority of the "delay of closure" provisions of sections
264.113(d) and (e) or 265.113(d) and (e).
IN Inactive/Closing, but not Yet RCRA closed.
Use IN to identify units that are subject to RCRA closure requirements, and have received the
final volume of hazardous waste, but have not completed closure activities as required to be
designated CC or CP. Units with a legal status of NN should be assigned an operating status of
IN if the unit will close.
OP Operating, Actively Managing RCRA-Regulated Waste.
Use OP to designate active units that are conducting hazardous waste management activities
subject to permitting. OP should be used regardless of the current legal status of the unit. For
example, OP should be used to designate units that are: Operating under interim status or pre-
mod authorization; operating under permits; allowed to continue operation under enforcement
orders, or interim status compliance letters; under temporary suspension of hazardous waste
activities pending decision to allow operation (e.g., awaiting permit issuance) where the intent is
to operate, rather than close, the unit.
A unit with a legal status of NN should be assigned an operating status of OP if: The unit is
allowed to continue to operate, or; the unit temporarily ceases to operate while seeking an
operating permit but there is no intent to close the unit.
PF Protective Filer.
Use PF to designate units that were submitted on a Part A, but are not RCRA-regulated, or do not
exist physically.
SF Referred to CERCLA.
Use SF to designate units (AB or other) that have been referred to CERCLA for cleanup.
UC Under Construction.
Use UC to designate a new unit that has received an operating permit and begun construction, but
has not yet started managing hazardous waste, or a unit that is "under construction" as defined in
the section 260.10 definition of "existing hazardous waste management facility."
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Legal Status Code Definitions
DL Delisted.
Use DL to designate units that have been delisted, or units at which all hazardous waste ever
handled by the unit have been delisted.
EM Emergency Permit. (Non-Core)
Use EM for units regulated by the provisions for emergency permits under section 270.61. An
EM unit should remain in that legal status throughout the life of the unit, including closure.
IS Interim Status.
Use IS to designate units that gain interim status under the provisions of section 270.70. A unit
that complies with those provisions is presumed to gain interim status upon receipt of the Part A.
IT Interim Status Terminated.
Use IT to designate units that have had interim status terminated under section 270.73(a) or (b).
For example: An interim status unit for which a permit was denied for any reason including
failure to submit a Part B in a timely manner or failure to submit a complete Permit Application.
LI Loss of Interim Status.
Use LI to designate units that have lost interim status for failure to comply with the requirements
of section 270.73 (c) through (g).
LP Loss of Pre-Mod Authorization.
Use LP for loss of pre-mod authorization in cases where a unit with pre-mod authorization (PM)
failed to comply with the appropriate requirements of section 270.42(g) for newly regulated units.
For example: Failure to submit a permit modification application within regulatory timeframes,
or failure to establish a groundwater monitoring system for a land disposal unit.
NN Non-notifier/Illegal.
Use NN to designate units that have operated illegally. For example: Units discovered to be
operating without interim status, pre-mod authorization, or a permit, or units that applied for
interim status or pre-mod authorization and failed to qualify, but operated.
NN should be used in these cases whether the unit is shut down or allowed to continue to operate
under an order or interim status compliance letter.
NR Never Regulated as a TSD.
Use NR to designate the following: Protective filers, or processes which were filed in error,
proposed new units that are withdrawn prior to permit issuance; where a Part A was submitted to
obtain interim status or pre-mod authorization, the unit was found to be ineligible, but the unit
never operated as a TSDF (e.g., less-then-90-day-storage units, exempt recycling units, units
which never managed hazardous waste, and units that never existed).
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PC Post-Closure Permitted.
Use PC to designate a unit for which a post-closure permit has been issued. When a permit is
issued during closure of the unit, the PC legal status should be used for units closing with waste
in place, and PI used for units that will clean close.
PI Permitted.
Use PI when an operating permit has been issued to a unit. The legal status of the unit should
remain PI until the permit expires and is not renewed, or the permit is terminated, or the permit is
modified to address only post-closure care, or a post-closure permit is issued to a unit that is
closing or has closed with waste in place
PM Pre-Mod Authorization.
Use PM to designate newly-regulated units at permitted facilities that are authorized to operate
under section 270.42(g) while a permit modification application is pending. For example: A
previously unregulated unit at a permitted facility that becomes regulated as a hazardous waste
unit due to a new waste listing.
PR Proposed.
Use PR to designate a "new" unit for which the owner/operator is pursuing an operating permit
where the unit is not constructed or, the unit has never been eligible for interim status or pre-mod
authorization, and has never operated illegally.
PT Permit Terminated/Permit Expired, not Continued.
Use PT to designate units for which an operating (PI) or post-closure (PC) permit has been
terminated under the authority of section 270.43, and units with permits that expire and are not
continued in accordance with section 270.51, Permitted units for which the permit is renewed
should retain the PI or PC legal status.
RD Research, Development, and Demonstration Permit.
Use RD for units regulated by the provisions for RD&D permits under section 270.65. An RD
unit should remain in that legal status throughout the life of the unit (i.e., from application
through closure).
RQ Requested but Not Approved.
Use RQ as a transitional status code for tracking increases in capacity of existing interim status
units (section 270.72(a)(2)) or changes in the process (section 270.72(a)(3)), additional capacity
at permitted units, or requests for temporary authorization.
RU Permit-by-Rule.
Use RU for units at which the only activities subject to RCRA permit requirements are processes
regulated under section 270.60. An RU unit should remain in that legal status throughout the life
of the unit, including closure. Examples: Ocean dumping (process code D82), UIC wells (D79),
publicly-owned treatment works that receive RCRA-regulated hazardous waste.
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SR State Regulated.
Use SR to designate units that are regulated only under broader or more stringent State standards,
and are not subject to RCRA permit requirements.
TA Temporary Authorization.
Use TA to designate a new unit that has received temporary authorization under the authority of
section 270.42(3) for installation and operation at a permitted facility.
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APPENDIX VI: RELATED INITIATIVE STATUS
Information Integration Initiative (I3)
Impact
Unknown at this time. The initiative is expected to impact various current efforts to develop new
data systems in a variety of individual programs including WIN/INFORMED.
Summary
EPA has recently launched an effort to create a single, unified data system for all of the agency's
programs. The objectives are to create a system that makes it easier for regulated entities to
submit information and easier for the public to access data. The EPA Administrator announced
the launch of the Information Integration Initiative (13) on October 27, 1999, as the first major
project of the new Office of Environmental Information. The goal of the project is to create a
single, integrated multi-media core of environmental data and tools that will deliver the vision of
integrated, multi-media information that is sought by the public and EPA's partners.
An action plan is expected by December 31, 1999 for establishing the new system.
OECA General Enforcement Management System (GEMS)
Impact
None identified.
Summary
OECA's Enforcement Planning Targeting and Data Division (EPTDD) is moving ahead with
GEMS, a system re-engineering initiative designed to produce a consolidated enforcement and
compliance data management system that will support the core information needs of EPA's
National Enforcement and Compliance Assurance program.
The GEMS initiative is being coordinated with the Office of Environmental Information's new
Information Integration Initiative (P). Gems will include basic components such as tracking of
facility inspections, violations and enforcement actions, and addresses more complex needs for
compliance assistance tracking, multi-media planning, targeting and evaluation. GEMS will
provide a consistent framework, process and structure for collecting and tracking compliance and
enforcement information. In 1999 OECA conducted a series of 5-day General Design Workshops
in three major Program Business areas: 1) Enforcement; 2) Compliance Monitoring/Assistance;
and 3) Program Management/ Evaluation.
Central Receiving
Impact
None identified.
Summary
The concept of Central Receiving (CR) is to establish a central point which supplements EPA
reporting systems by performing new and existing functions for receiving legally acceptable data
in various formats (e.g., electronic, paper, diskette), including consolidated/integrated data.
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For external "customers", the regulated community, state and local government, CR will offer a
single, common point-of-entry for data they send us.
For EPA reporting systems, CR will serve as a shared resource that provides consistent,
centralized management for all reporting transactions.
Proposed CR functions include:
receiving, authenticating, and logging submissions;
translating data to and from different electronic formats;
archiving submissions;
managing the security of network transactions; and
distributing data to EPA databases and possibly other entities.
There are five major steps planned for the development of CR:
Determine Functional Requirements: 1999
- Design, Pilot-testing and Prototyping: 1999 - 2000
Decision Point: Final Design/Option Section: early 2000
Interim Operation (based on prototype): mid-2000
- Establish Full Production CR: 2000 - 2002
Electronic Data Interchange (Manifest)
Impact
This initiative could have an impact on both the UID and WAM program areas although at this
time, no definitive recommendations have been issued.
This initiative relates closely to the following EPA "Cross-media electronic reporting and
recordkeeping rule workgroup" initiative.
Summary
An updated version of the SEES report has been released. The first of three phases of a pilot
electronic manifesting project is complete, although results have not yet been published. The
NPDES program is known to be considering a rule to allow submission of EDI transmissions of
Discharge Monitoring Reports in lieu of paper documentation.
Cross-Media Electronic Reporting and Record keeping Rule Workgroup
Impact
Although the scope of this workgroup overlaps with some of the recommendations included in
this Final Report, the schedule for any proposed rulemaking is beyond the schedule for this PAA.
As a result, no direct impact can be determined at this time.
This initiative relates closely to the previous State "Electronic Data Interchange Workgroup"
initiative.
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Summary
The workgroup starting meeting in May, 1999. The goal of the workgroup is to draft a rule that
will provide a uniform legal framework for paperless electronic reporting across all EPA
environmental compliance programs. Workgroup members include representatives from EPA
Headquarters offices and Region III. To date, the workgroup has been understanding the issues
and progress made in the area of electronic reporting, including gathering background
information on the new statute, the Government Paperwork Elimination Act, which requires the
Federal government to allow for electronic reporting for all information transactions by the year
2003. In addition, the workgroup has been meeting with Department of Justice on legal concerns
regarding electronic reporting and the Agency's information management office on the Computer
Security Act. The workgroup hopes to draft a Notice of Proposed Rulemaking by September,
2000 and work towards a Final Rule by September, 2001.
Manifest Rulemaking Workgroup
Impact
At this time, the full details of the new rule are still to be determined .
The proposed rule includes changes to collect information regarding international shipments. A
checkbox is proposed to be added to the manifest to indicate that the shipment is international in
nature. There will also be a new field to indicate the point of entry/exit for the US. Instructions
now include the requirement that a copy of the manifest be left with US Customs for both imports
and exports (currently this is only required for exports). This will allow the identification of how
much waste generated in a state is actually waste imported from another country.
These changes may have some impact on the recommendations for handling of waste imports and
exports included in this report. Following this national review and consideration of additional
comments received by the Manifest Rulemaking Workgroup, these recommendations may be
modified to remove any overlap.
Summary
An internal draft of the proposed manifest rule and the new manifest form has been released. A
proposed rule is due to be published in summer of 2000 with a probable phased implementation
of the new regulations in December 2001.
Burden Reduction
Impact
A number of the options included in the Burden Reduction NOD A conflicts with
recommendations from the UID and WAM PAAs. The confirmed recommendations from the
UID and WAM program area will be communicated to the workgroup charged with developing
rules based on the NOD A.
Summary
The PAA Team has reviewed the Burden Reduction team's draft NOD A. The final version of the
NODA was published to the Federal Register on June 18, 1999. A final rule specification is
planned for May 2000. Once the comments are all received and reviewed EPA will convene a
workgroup to begin the rulemaking. This workgroup will convene early in 2000.
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National Rulemaking
Impact
Implementation of the recommendation to "Provide for standard notification of universal waste
activities" may be accomplished by a soon to be published Information Collection Request (ICR).
Summary
An ICR is currently being reviewed which calls for the collection of an additional data element on
the Notification form that would indicate that the RCRA Site is a large quantity handler of
universal wastes.
RCRA Info Conversion
Impact
The PAA Team continues to work with the RCRAInfo Design Team to ensure that neither project
takes steps that may preclude greater integration at a later stage.
Summary
The existing RCRIS and BRS national systems are currently being redeveloped based on a new
technical architecture. The implementation platform will be changing although the basic system
functionality will remain constant.
Implementation of the new system is on schedule for first quarter 2000, with a phased
implementation planned by Regional Offices (Regions I, IV and VI will be the first to transfer to
the new system).
ECOS Core Performance Measures
Impact
None identified.
Summary
ECOS core performance measures have been developed to support NEPPS and GPRA.
SIC/NAICS
Impact
The new NAICS codes have been incorporated into the program area model.
Summary
Rules have been drafted mandating the use of NAICS codes as a replacement for SIC codes.
Facility Data Standards
Impact
The UID program area model will be compliant with the Facility Identification Data Standard.
The PAA Team will continue to coordinate with this initiative and will work with the Facility
Data Standard to build additional needs as required.
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Summary
The "Facility Identification Data Standard" (Standard) provides formats and definitions for basic
information used to identify facilities and sites that are of environmental and program interest to
EPA, State and local environmental agencies, communities and industry. This standard format
will result in improved data integration capabilities, data analysis and quality at all levels.
The Standard was developed by the Facility Data Standard Action Team chartered by the
EPA/State Information Workgroup. The Team used the "Interim Facility Identification Standard"
posted for comment by the EPA in February of 1998 and the "Facility Identification Template
For States" (FITS) developed by a multi-state initiative as its basis. The Team included
representatives from several States, all EPA Program offices, EPA Office of Enforcement and
Compliance Assurance, EPA Office of Information Resources Management staff and
representatives of the Environmental Council of the States (ECOS).
The Standard has been endorsed by the EPA/State Information Workgroup. ECOS has provided
the Standard to all 50 State commissioners for review. EPA will undertake review and adoption
through the Reinventing Environmental Information (REI) Subcommittee of the Information
Resources Management Executive Steering Committee. The FITS guidance document for States
will be revised to reflect the elements of the Standard.
Latitude/Longitude Workgroup
Impact
The recommendation to collect location coordinates for all RCRA Sites using address-matching
software is consistent with EPA's Locational Data Policy (LDP). The program area model that
has been developed has incorporated defined standards for latitude, longitude and MAD codes.
Summary
The March 1992 Locational Data Policy (LDP) guidance document states that "Under this policy,
collection and documentation of locational information will be performed for all facilities, sites,
monitoring points, and observation points regulated or tracked by EPA under Federal
environmental laws."
Following this guidance, standards have been developed for latitude, longitude and MAD codes.
Center for Environmental Information Statistics (CEIS)
Impact
Although the work of the CEIS will include waste activity information from the Biennial Report,
no direct impact is expected for the WAM program area.
Status
The goal of the CEIS, an EPA Headquarters program, is to increase public access to integrated
information on environmental quality, status and trends. CEIS displays of data are available
through EPA's Envirofacts system. For hazardous waste information, CEIS relies on Biennial
Report National Data and has links to the Biennial Report System (BRS) reports that are posted
on the Internet. The CEIS pages provide a description of the data and what it does and doesn't
mean.
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NGA Manifest Survey
Impact
None identified.
Summary
A comprehensive survey of a number of States was conducted by the National Governors
Association to understand States' needs for manifest information. The following results were
published:
1) States oppose complete elimination of the optional fields on the manifest form;
2) Standards for automation and manifest streamlining need to be developed through direct
consultation with States; and
3) EPA should provide as much funding as possible to support manifest automation.
Government Performance Review Act (GPRA)
Impact
The TUG team (Treatment, Storage, and/or Disposal Universe Group) worked closely with the
EPA OSW staff involved in identifying those facilities in the GPRA Corrective Action, Permits
and Post-Closure Baseline universes. These are those sites that were identified as requiring
controls in place (via permit, closure or post-closure), or as being the highest priority for
corrective action, in the baseline year of 1997, so that progress can be measured against work at
these sites annually through 2005. This work is covered by GPRA Goal 5.
Summary
A number of the GPRA goals appear to potentially impact the UID and WAM program areas.
The most significant and obvious area of impact is with respect to the regulated universes of
TSDF RCRA Sites.
Program Evaluation PAA
Impact
Lessons learned from the conduct of the Program Evaluation PAA project were incorporated into
planning for the UID and WAM PAA projects.
Summary
Each PAA project will conduct a "lessons learned" exercise to identify areas in which
improvements may be made to streamline the process and improve the quality of resulting
deliverable s.
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APPENDIX VII: SUPPLEMENTARY POLICY PROCEDURAL
ISSUES
Introduction
During the course of the PAA project, a number of policy and procedural issues were identified.
These issues result from the varied practices of the different agencies that implement the RCRA
hazardous waste program and from evolutionary changes to the program . Typically, such issues
have broad implications for the program and must be carefully considered before
recommendations are made that affect program information management.
Although the majority of the issues identified during the PAA have been addressed by
recommendations included in the main body of the report, others did not and have been compiled
here for reference purposes. These issues fall into two categories
Policy Procedural Issues without Recommendations
Those issues that have been considered and discussed by the PAA Team but for which the current
situation appears to be the most satisfactory. These issues are described in detail and the various
alternative options for resolution are discussed
Policy /Procedural Issues Excluded from Project Scope
Those issues that have been excluded from consideration during the analysis of the WAM
program area due to scope constraints, or their organization or design specific focus. For these
issues, a proposed path forward is presented, that might be used to address the issue in some
forum outside of this project.
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Policy Procedural Issues without Recommendations
Exceptions to the general definition of a RCRA Site
Program Need
Most RCRA Sites fit conveniently into a general definition comprising an industrial installation at
a fixed contiguous site controlled by a specific person. However, there are exceptions. Some
examples are:
Mobile sources, such as ships, that may generate wastes at ports or repair yards in different
locations and jurisdictions
Continuous sites, such as pipelines and roads
Non-contiguous sites under common control, such as utility manholes or county bridges
Non-industrial sites where the owner is not the generator, as in the case of hazardous waste
abandoned at a Goodwill loading dock or in a national park
Industrial parks, in which multiple generators operate on contiguous sites "controlled" by
another person (the owner)
Outside contractors who generate hazardous wastes at an industrial site controlled by another
person.
In each of these cases, one or more of the elements making up the general definition of a RCRA
Site is missing. However, the RCRA program must still identify the site and track waste
generated and managed at that site.
Problem Analysis
The way in which a unique RCRA Site is defined can vary from State to State. For example,
some States track utility manholes as separate RCRA Sites, while other States do not. Some
States may require a non-contiguous RCRA Site to notify as two RCRA Sites while other States
do not. These State-to-State variations do not normally pose problems for the implementers, but
where sites are defined and counted differently, it may be difficult to develop a "national" picture
of hazardous waste handling in terms of the numbers of RCRA sites regulated and to establish the
environmental record of large companies.
For the purposes of the RCRA program, a RCRA Site is identified as a specific location which is
currently, or has in the past, conducted waste handling activities of interest to the RCRA Subtitle
C program, as promulgated in either the Federal Register or individual State statutes. The
location may be described by physical address, by description or by geographic coordinates.
Since the number of exceptions to the general rule is small in comparison to the total universe and
there is virtually no effect across or between implementers, it is recommended that exceptions
should be handled on a case-by-case basis.
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Options Considered
1) Develop formal guidance for each class of exceptions to the general definition by which each
would be handled and accommodated in both manual and automated procedures.
Reporting of TSDF regulatory status
Program Need
States need to be able to track RCRA Sites performing waste management activities as regulated
by their own regulations. Due to "broader in scope" (B-I-S) or "more stringent than" (M-S-T)
State authorities, a RCRA Site may be identified as a TSDF but not be considered a TSDF by
Federal regulations.
Problem Analysis
A State (only) defined TSDF may have to follow the Federal TSDF regulations (at a minimum),
even though it does not fall into the Federal definition of a TSDF. This may lead to inconsistency
between definitions of Federal and State identification of the universe of TSDF's.
This issue impacts very few States.
Options Considered
1) Use State definitions to determine TSDF status.
2) Use Federal definitions to determine TSDF status
Consistent notification of transporters and transfer stations
Program Need
States need to be able to access notification information for transporters that receive their EPA ID
number in a different State from that in which they operate. States also need to understand where
transporters are conducting transfer operations for the purposes of identifying potential
compliance issues.
Problem Analysis
Transporters do not always need to notify to a State in which it does business or through which it
transports waste, providing the transporter has already submitted a notification to another State
and has received a valid EPA ID.
Additionally, a transporter has no regulatory obligation to report the location of transfer stations,
although a number of States feel that such transfer locations, where a transporter is changing
hazardous waste conveyance and packaging, or even simply temporarily "storing" the waste,
should be subject to greater scrutiny. Many transfer stations are not locations that would
typically be considered RCRA Sites, for example, roadside stops, parking lots and other
locations.
An additional issue identified is 'Transporters that mix hazardous waste of different DOT
shipping descriptions by placing them in a single container' are subject to 40 CFR 262, Standards
Applicable to Generators of Hazardous waste. This requires them to notify, however, when they
notify there is no specific way of identifying themselves as such a transporter.
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Options Considered
1) Prohibit repackaging of waste at un-permitted transfer stations.
Prohibit repackaging of waste at un-permitted transfer stations. If repackaging is to occur, it must
be done at a permitted TSDF and then remanifested. True transfer stations where no repackaging
occurs have no need for a permit or notification.
Bulk reconsolidation facilities exist who receive hazardous wastes from customers (original
generators of the waste) and consolidate these customers' wastes, based on compatibility, and
then remanifest these combined wastes to other TSDFs. These facilities must have a permit or
interim status (they have notified and received or are applying for a permit), and therefore, they
are already being handled in the system via State and Federal requirements.
2) Require comprehensive notification
Require transporters to notify in any States in which they do business, even if passing through the
State only. Also require that transporters formally notify the relevant State of any waste transfer
locations and activities.
Business status information for a RCRA Site
Program Need
When discussing the business status of a RCRA site, an important distinction must be made
between the conduct of RCRA-regulated activities at the site, and the actual operation of a
business at the site. During the INA sessions, the need for both of these dimensions was
expressed.
Problem Analysis
The term business status reflects whether the site is currently engaged in business activity. A
consistent mechanism for the collection of this information is not readily available at this time.
Waste Accounting and Movement
Program Need
PAA participants expressed the need for a full accounting of wastes generated and managed from
cradle to grave.
Problem Analysis
Waste storage facilities can accumulate wastes for extended periods of time and under certain
conditions may mix wastes prior to shipment for final treatment and disposal. Similarly,
transporters can combine wastes received from individual generators while such wastes are in
transit.
A new manifest is generated for the combined wastes, indicating the source of the waste as
the storage facility or transporter.
The new manifest severs the link to the original generators of the individual wastes.
Current Federal guidance indicates that if a transporter commingles wastes with different
DOT shipping descriptions by placing them in a single container (e.g., drum, tanker truck),
the previous manifests should accompany the waste shipment.
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For commingled waste shipments, the current Federal manifest does not allow for linking, by
manifest document numbers or other direct means, with any previous manifests associated
with the shipment.
Some transfer stations act in similar ways to Storage Facilities - i.e., merging wastes and
declaring themselves the 'generator' of that waste.
The original generator may report for the hazardous waste Biennial Reporting form (or other
comparable State periodic report) that the final destination of the waste is the storage or
transfer facility, severing the link to the disposal of the waste at a disposal unit.
The storage facility may report the waste as a newly generated waste for purposes of the
required periodic reporting process.
Because of the way these activities are reported, a full accounting of waste generated and
managed is made difficult with the potential double counting of waste generated and reported
by storage facilities and generators.
Options Considered
1) Continue to use appropriate waste origin and handling codes related to storage (transfer)
only.
Since complete "cradle to grave" tracking would always be challenging given the wide range of
exceptional circumstances, waste accounting should be achieved using a more rigorous
implementation of the current practice.
Continue to use appropriate waste origin and handling codes related to storage (transfer) only.
(M141 for the current Biennial Reports) Waste volumes reported as being managed by such
codes would not be counted for waste volume tracking (and, indirectly, waste management
capacity tracking) purposes. That is, the system logic could be designed to subtract out all waste
volumes identified, by a given management code (e.g., M141) as being received from off site and
not recycled, treated, or disposed on site. Only waste volumes that were actually treated or
disposed as the "final" management method would be counted for reporting purposes. Generators
would simply report on the waste handling method of the first TSDF to receive their waste.
This recommendation obviously will require added emphasis to educate generators, transporters,
and facilities that receive waste shipments to properly complete and use the manifest as well as
properly report waste shipment information.
Pros
Addresses the issue from the periodic waste movement tracking perspective.
Cons
Confusion may persist about completing the manifest and Biennial Reports creating
continued data quality gaps.
2) Link manifests created as a result of commingling, aggregating, or related handling to the
preceding manifests.
EPA, with stakeholder (States, waste management industry, and others) input, is preparing
recommended changes and improvements to the uniform manifest. A rulemaking proposal will
be prepared addressing the results of this joint effort. As part of this proposal, manifest linking
should be enforced in rule in one of the following two ways:
a) Provide for the manifest to have a field where linking or referencing to related manifests can
properly be done.
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b) Reaffirm Federal guidance that original manifests are to accompany the new manifest for the
commingled waste shipments. This is obviously a weaker means of ensuring national
uniformity for linking waste shipments involving commingling, transferring, and/or storing
prior to final treatment and/or disposal.
Pros
Addresses the issue for real-time waste movement (manifesting) purposes.
Dovetails in with the manifest reinvention work and therefore encompasses some of the
overall burden reduction benefits
Provides opportunity as a part of the outreach to generators, transporters, and TSDF facilities
to get direct feedback for further improvements.
Cons
Learning curve to implement new form or procedure for linking manifests.
Schedule for manifest rulemaking may not coincide with the future steps (design, etc.) of this
project.
Confusion may persist about completing the manifest and Biennial Reports creating
continued data quality gaps.
3) Remove the option for a generator to report on the Biennial Reporting form (or comparable
periodic report) that the management method was to store or transfer it.
Stated another wayfor periodic (biennial) reporting purposes, require generators to only report
final treatment/disposal method.
Pros
Accounts for "true" cradle-to-grave reporting by the original generator.
Reaffirms the generator's liability and therefore accountability for the waste generated
(cradle) and the associated proper waste disposal method (grave).
Minor burden reduction achieved by removing a current data element option available for
reporting purposes.
Cons
Only resolves a reporting issue rather than a "real-time" waste tracking (linking) one via the
manifests. Any desired direct link between original generators to commingled waste
shipments would not be available.
Volume discrepancies would likely continue between generator information and receiving
treatment/disposal facility information (i.e., mass balances would be difficult to provide).
Generators are often unfamiliar with the actual treatment and/or disposal methods used to
manage their wastes and would therefore report their "best guess."
Determine corporate relationships for a RCRA Site
Program Need
PAA Participants identified the information need to understand the corporate ownership of a
RCRA Site where compliance patterns are being researched.
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Problem Analysis
Currently, it can be difficult to relate the activities of one company to another since there is not
necessarily an obvious connection between a RCRA Site and its corporate ownership. There is
currently no clear way of assessing corporate relationships in order to build a comprehensive
picture of a given company's national compliance record.
A number of different data systems record this type of information, but names can be recorded
very differently between systems and no single number is currently recorded for each
owner/operator. The Dunn & Bradstreet system is used by EPA to provide some information on
company parentage and hierarchy, but this information is expensive and difficult to share.
For Permit Applications and enforcement actions, more detailed ownership information is often
collected, for example, financial assurance information, owner/operator parentage, history of
prior notifications, and company size.
Options Considered
1) Require a naming convention for corporate owner information.
The use of D&B numbers is too costly for States and still requires much of the same QA/QC a
corporate name would. While it will be a burden to make sure you had good information, and that
it either existed in the national RCRIS database already, or was entered as new data, it is not as
difficult to maintain as the D&B number.
Pros:
Provides a means to trace ownership by name versus number (D&B)
QA can be done by staff and standard search mechanisms
Easily shared across States
Cons:
Costs are indeterminate at this time but could be extensive when considering data cleanup,
and education.
Naming convention needs to be developed and agreed upon
QA/QC burden. Those entering information must do a thorough search to assure the
corporate owner is not already in RCRIS. The search must be standard and must be
conducted by all staff entering data in each State or Region.
States must accept the way another State entered the name (can be mitigated by naming
conventions used by all)
2) Obtain Dunn & Bradstreet Numbers for all RCRA handlers and use this information to trace
corporate ownership of RCRA handlers.
Pros:
Provides a simple numerical way to trace ownership across handlers
May implement over time by asking handlers to provide as part of a re-notification process
Cons:
Expensive
Can=t readily share
Requires burden to populate all current handler files with this data
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Added reporting burden for new sites to include this information when notifying or re-
notifying
QA/QC burden to see if D&B number is legitimate. Would require easy access to D&B data
to check
3) Use Secretary of State company registration information
Company registration information could be obtained from the relevant Secretary of State office,
including corporate relationship information. Address matching could be used to compare and
integrate this information with RCRA data.
Pros:
Provides relatively low-cost access to corporate relationship data.
Cons:
Multiple sources of data.
Reliant on accuracy of address matching routines.
Status
Given the difficult and complex nature of corporate relationships the PAA participants feel that
this need might best be managed by tracking of owner and operator names as specified in the
Recommended Information Needs in the main body of the report. This improvement in
information collection will permit the assignment of an Owner and or Operator, as well as type
(e.g., Private, Tribal, or Governmental). This issue will be further supported. While not a perfect
resolution to the issue, this recommendation provides better quality information than is currently
available.
Reporting RCRA waste activity by "waste stream"
The Biennial Reporting forms currently require waste to be reported as a set of individual wastes
rather than a single unit of hazardous waste. Wastes can be reported together 'if the wastes have
the same Origin code and Form code'. The term "waste stream" is used variably by the RCRA
program, yet a common understanding is required to facilitate communication
Options Considered
1. Maintain current situation
2. Provide agreed definition in the regulations and form instructions
Status
Given the term waste stream, commonly is used in the context of a unit of reportable waste, the
PAA participants have agreed to defer this issue until after the design of the new reporting
mechanisms as defined in Recommendation #11 Study Feasibility of Quarterly Electronic
Reporting. The final outcome this study and potential implementation will strongly influence the
final definition of a waste stream
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Policy / Procedural Issues Excluded from Project Scope
The following issues were excluded from consideration within the WAM program area for one or
more of the following reasons:
Scope Constraint The issue had been excluded from PAA initial scope, and the
findings of the information-gathering sessions did not suggest that
they are critical issues which would threaten the success of the
project if not resolved.
Organization Specific The issue is highly specific to a small number of organizations and is
not considered significant for national resolution.
Design/Implementation The issue will affect design and/or implementation of the project's
recommendations but does not have a bearing on information needs
and management.
These issues have been documented below. For each issue a proposal has been included
suggesting a process outside of the project that might best be employed to resolve the issue.
Inadequacies of Waste Codes
Reason for Exclusion: Scope Constraint
Issue Description
Some States and Regions have developed their own waste codes to supplement the Federal
waste codes. Some of these are due to additional State regulations, but others are to better
describe the waste (e.g., codes for PCBs, solid waste, and universal waste).
Waste codes do not provide adequate information about toxicity
Characteristic Waste Codes are often used inappropriately, as a way to describe a waste
without providing a more specific description
Waste Codes include some information that overlaps with form and source codes
information.
There is not a standard universal Waste Determination process currently in place to assist
generators with understanding what waste codes apply.
Pathforward
The redefinition or restructuring of the current system of waste codes employed in the RCRA
program will be a complex task requiring considerable programmatic and technical knowledge.
As such, any reevaluation can only realistically be pursued as a separate, dedicated exercise
undertaken in parallel to the progress of the PAA projects.
It is recommended that the WIN/INFORMED Coordinating Committee consider appointing a
separate workgroup to address the redefinition of the current waste code scheme, consisting of
representatives from States, EPA Regions and EPA Headquarters offices.
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Determining the Chemical Constituents and Composition of Waste
Reason for Exclusion: Scope Constraint
Issue Description
Many of EPA's activities require them to understand the types and concentration of
chemicals that constitute a hazardous waste.
Waste codes provide a very limited indication of chemical composition.
The LDR program collected constituent information during rule development (in the form of
paper comments from RCRA Sites), which could be used to generalize the types of chemicals
typically found in specific types of waste.
TRI collects information about chemicals in releases (in the form of CAS codes) for
approximately half of the current universe of TSDFs and LQGs.
Pathforward
During the information gathering sessions, participants identified a number of possible
approaches to resolve this information shortfall.
In some cases, profiles have been developed describing the typical chemical composition of
certain wastes from specific types of industry. A separate workgroup is recommended to evaluate
making information more widely accessible to all regulators.
An alternative proposal that could present a significant increase in the associated burden would be
to have TSDFs report detailed information about wastes that they manage to the regulators.
TSDFs currently maintain records of the chemical composition of wastes they receive to meet
permitting and land disposal restriction requirements.
Measuring a RCRA Site's Production
Reason for Exclusion: Organization Specific
Issue Description
To evaluate how well a generator has minimized its waste generation, the trend in quantities
generated alone can be a poor indicator. That quantity should be compared to volumetric
changes in the generator's activities that resulted in the waste. For example, a generator may
have halved its generated waste due only to the fact that it was manufacturing only half as
many products.
An indicator of volume of production would also provide EPA with a useful inspection
targeting criteria.
TRI reports include the production index of the process that led to a reporter's toxic releases.
However, TRI reporters only represent a subset of hazardous waste generators.
The Biennial Reporting forms used to include the production index of the process that led to
each waste, but this was recently removed along with the other waste minimization questions.
Analyses of the Biennial Report and TRI reported production indices suggest that the
reporters are using their overall facility production index (which is readily available to them)
instead of any process specific index.
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Pathforward
This issue was excluded from the scope of the WAM PAA project because of its organization
specific nature. However, production information is important to many areas of the RCRA
program and a separate project should be conducted jointly by those groups requiring the
information.
Two possible options that might be used to gather this information include:
1. To gather the production index information using the Biennial Report.
2. Use industry production index information as an approximation for each generator (collected
from Trade Associations).
The EPA Waste Minimization Team is currently evaluating solutions to this issue.
Cross Media Reporting of Releases/TRI Harmonization
Reason for Exclusion: Scope Constraint
Issue Description
The Toxic Release Inventory is based on the collection of EPA Form R from a universe of the
regulated community that overlaps to some extent with the biennially reporting universe. It
provides information about releases to land, air and water for a specific list of chemicals.
Given the desirability to be able to understand the cross media profile of sites that release
pollutants, along with the move to integrated reporting mechanisms, the possible merger of
the Biennial Report with the TRI Form R should be considered.
If the TRI model was used for RCRA, information about the generation of PBTs may also be
tracked satisfactorily.
A 1995 study of facilities showed that 43% of the Biennial Report respondents also reported
to TRI; these facilities produced more than 90% of the hazardous waste volumes reported to
BRS. With recent changes to TRI, the percentage of the Biennial Report respondents that
also submit TRI reports is expected to be even higher.
Pathforward
Integration of RCRA information collection with TRI information collection was excluded from
the scope of the WAM PAA in an effort to maintain a manageable scope for the project.
However, as discussed above, there are clearly a number of overlaps between RCRA and TRI in
terms of the reporting universe and the information collected.
While the WAM PAA was unable to tackle this issue, the Team recommends that an alternative
working group be charged with evaluating the potential for integration of the TRI report with the
Biennial Report. Based on the recommendations of this group, an implementation plan should be
developed to guide the integration process if appropriate.
Some options discussed by the Team were:
Eliminate Biennial Reporting for wastes covered under TRI
Reporters would not report any wastes that are also currently required for TRI reporting. Studies
have shown that facilities that report under the Biennial Report often also report to the Toxics
Release Inventory. The team is aware of the differences between these two information systems,
including the universe covered, the frequency of reporting, what is reported, and the definition of
facilities.
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Limit the Biennial Report to 1.400 top generators: rely on TRI for other RCRA facilities
A small number of facilities are responsible for the majority of the waste reported in BRS. This
option would require the top 1,400 facilities (or some other number) as measured by waste
volume reported to continue reporting under the Biennial Report. In 1995 only 1,372 reporters
generated more than 1,113.2 tons of hazardous waste managed in RCRA permitted units. No
other facilities would have to report biennially.
Collect all information under TRI
Under this option, the TRI form would be modified to take data elements currently only collected
by the Biennial Report, such as waste code description, waste code number, and RCRA permit
information and put them on the TRI form. EPA would eliminate the Biennial Report. The TRI
reporting universe would remain the same under this option.
Collect all information under TRI for all RCRA Sites
As the previous option except all RCRA Sites would be required to report on TRI form. The full
TRI reporters would remain the same as the previous option, however, the biennial reporters
would only submit hazardous waste information and would not complete TRI data, e.g., chemical
quantities.
Non-Hazardous Waste Managed in RCRA Subtitle C Units
Reason for Exclusion: Scope Constraint; Organization Specific
Issue Description
Some generators ship their non-hazardous waste to be managed as hazardous, for example in
a hazardous waste landfill.
If non-hazardous waste is being managed in hazardous waste management units then a
calculation of available capacity is made inaccurate.
When considering the impact of listing and existing solid waste, the burden expected to be
imposed may be much reduced if it is known that much of that solid waste is already being
managed as if it were a hazardous waste.
Some State RCRA programs already collect this information from TSDFs.
Pathforward
This issue affects primarily capacity assurance analysis. It was suggested that EPA Office of
Solid Waste should attempt to assess the scale of the problem that this practice presents and then
consider possible regulatory change to facilitate the collection of the additional information.
Third Party Manifesting
Reason for Exclusion: Organization Specific; Design/Implementation
Issue Description
Some States that collect manifests from out of State generators or TSDFs require that those
RCRA Sites also submit an additional copy of the manifest to the resident State agency.
Some of these agencies have no use for those manifests. This would seem to be reporting
burden (although a small one) which has little benefit.
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Pathforward
This issue was excluded from the scope of the WAM PAA project due to its organization specific
nature and relatively limited impact.
Waste Decharacterization
Reason for Exclusion: Organization Specific; Design/Implementation
Issue Description
Decharacterization is the process of making characteristically hazardous waste, non-
hazardous by removing or nullifying the characteristic component (e.g., mixing of wastes).
Courts have ruled that waste must be treated for characteristic components regardless of the
decharacterization.
Once decharacterized the waste no longer is required to be reported
Pathforward
This issue was not felt by the Team to have wide-ranging impact and any impact on the RCRA
program is usually organization specific. If required, the issue should be further examined by the
EPA Office of Solid Waste.
Hazardous Waste Transfer Stations
Reason for Exclusion: Scope Constraint
Issue Description
As transfer stations do not formally report their activities there is some suspicion that they are
illegally mixing wastes.
Transfer stations may mix and re-manifest wastes. However, the original manifests from the
generators are included with the new manifest when transferred for disposal.
Pathforward
Since full and complete tracking of transfer station activities would require greatly increased
reporting and regulation of these RCRA Sites, the Team agreed that there is little that could be
done within the scope of the PAA to support this issue.
Recycled Waste
Reason for Exclusion: Scope Constraint
Issue Description
There are two elements to this issue.
1) Firstly, there are inconsistent recycler reporting requirements amongst States, with some
States requiring recyclers to report the receipt of hazardous wastes while others do not.
40 CFR 264.1(g)(2) exempts certain recycling facilities from the BRS (40 CFR 264.75)
requirements. Those facilities that are exempt include those that treat the following wastes; those
that are covered in Subparts C through H of 40 CFR 266, industrial ethyl alcohol, scrap metal,
fuels produced from the refining of oil-bearing hazardous waste, petroleum coke products and
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used oil. There are of course numerous restrictions and caveats to those exemptions. Those
should be the only TSDF facilities that are not required to report the 9 items prescribed in 40 CFR
264.75.
2) Secondly, there is a desire for additional information on the quantities of hazardous
wastes that are recycled and into which product they are recycled. Currently:
The final destination of recycled hazardous wastes does not have to be reported if the material
is not stored long term.
EPA loses visibility to the fate of wastes due to recycling and no reporting requirement.
EPA is required to encourage recycling of hazardous wastes and must demonstrate (for
GPRA) their success through monitoring the quantity of hazardous waste recycled; however
this data is not comprehensively collected.
Pathforward
The scale and complexity of this issue led the team to consider it out of scope of the WAM
project. If deemed appropriate by the coordinating committee a separate detailed assessment
should be conducted to determine EPA and State information needs for hazardous wastes that are
managed by exempt recycling facilities and processes.
This study would clearly describe the specific information needs together with recommendations
on collection method.
Public information access
Reason for Exclusion: Scope Constraint; Design/Implementation
Issue Description
The PAA participants have differing opinions on what information should be made available
through "self-service" mechanisms, and which should have to be requested through FOIA
requests. Additionally this issue has agency wide implications beyond the remit of this PAA.
Pathforward
For the reasons cited above public information access will be referred to the Coordinating
Committee for review.
Tracking of State specific RCRA Sites information in a national system
Reason for Exclusion: Scope Constraint
Issue Description
The information need for this issue is based on some States need to be able to track non-RCRA
TSDFs and inspections of non-RCRA regulated sites.
Pathforward
This issue is beyond the scope of this PAA will be deferred to the Permitting and Corrective
Action and the Handler and Monitoring and Assistance PAAs.
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