TECHNICAL PROPOSAL AND JUSTIFICATION
    FOR REVISING THE 1987  ANNUAL/BIENNIAL
       REPORTING FORMS AND DATA SYSTEM
                    DRAFT
                Prepared for:

Office of Solid Waste and Emergency Response
    U.S. Environmental Protection Agency
             401 M.  Street.  S.W.
           Washington, D.C. 20460
                Prepared by:

   Center for  Policy Research and Analysis
       National  Governors' Association
          444 North Capitol Street
           Washington, D.C. 20001
                July 22,  1987

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                               ACKNOWLEDGEMENTS
    Many  people  contributed  to  and  assisted   in   the
report.   In  particular,  we  wish to  thank:  Mike Burns,
Eby,  Jim  Craig,   Larry  Rosengrant,  George  Bonino  and
Environmental Protection Agency, Office of Solid Waste;
ERM; John Rodgers  and  Garrett Moran  of Westat;  Mary Lou
of  DPRA;  members   of  Annual/Biennial  Report  Advisory
interested  parties  who   reviewed  our earlier   papers
comments.
 development  of  this
 Jo Ann Bassi,  Elaine
 Donna  Inman  at  the
 Raghu K. Raghavan  of
Marino and  Tom Graham
Committee;  and  other
and  provided  helpful

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                              TABLE OF CONTENTS

Chapter                                                              Page

1.  INTRODUCTION	   1-1

    A.  BACKGROUND	   1-1
    B.  ADVISORY COUNCIL RECOMMENDATIONS	   1-2
    C.  ORGANIZATION OF PROPOSED REPORTING FORMS	   1-4
    D.  IMPLEMENTATION OF THE REVISED FORMS	   1-12
    E.  REQUIRED REGULATORY CHANGES	   1-13
    F.  OUTLINE OF THE REPORT	   1-14

2.  REGULATORY STATUS	   2-1

    A.  INTRODUCTION AND OVERVIEW	   2-1
    B.  ADMINISTRATIVE REQUIREMENTS FOR THE DATA	   2-1
    C.  POLICY OPTIONS	   2-2 .
    D.  DATA AND INFORMATION REQUIREMENTS	   2-3
    E.  USEFULNESS OF CURRENT DATA	   2-5
    F.  DESCRIPTION OF THE PROPOSED FORMS	   2-6
    G.  SAMPLE OUTPUTS AND USES OF THE DATA	   2-10
    H.  PROS AND CONS OF THE PROPOSED SYSTEM	   2-19

3.  WASTE QUANTITY AND PROCESS TRACKING	   3-1

    A.  INTRODUCTION AND OVERVIEW	   3-1
    B.  ADMINISTRATIVE REQUIREMENTS FOR THE DATA	   3-2
    C.  POLICY OPTIONS	   3-3
    D.  DATA AND INFORMATION REQUIREMENTS	   3-3
    E.  USEFULNESS OF CURRENT DATA	   3-7
    F.  DESCRIPTION OF THE PROPOSED FORMS	   3-10
    G.  SAMPLE OUTPUTS AND USES OF THE DATA	   3-14

4.  WASTE CHARACTERIZATION	   4-1

    A.  INTRODUCTION AND OVERVIEW	*.	  4-1
    B.  ADMINISTRATIVE REQUIREMENTS FOR THE DATA	   4-2
    C.  POLICY OPTIONS	  4'2
    D.  DATA AND INFORMATION REQUIREMENTS	   4-3
    E.  USEFULNESS OF CURRENT DATA	  4-6
    F.  DESCRIPTION OF THE PROPOSED FORMS	  4-7
    G.  SAMPLE OUTPUTS AND USES OF THE DATA	  4-8

5.  CAPACITY ASSESSMENT	  5-1

    A.  INTRODUCTION AND OVERVIEW	  5-2
    B.  ADMINISTRATIVE REQUIREMENTS FOR THE DATA	  5-2
    C.  POLICY OPTIONS	  5'3
    D.  DATA AND INFORMATION REQUIREMENTS	  5-3

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                          TABLE OF CONTENTS (cont'd)

Chapter                                                               Page

    E.  USEFULNESS OF CURRENT DATA	  5-7
    F.  DESCRIPTION OF THE PROPOSED FORMS	  5-7
    G.  SAMPLE OUTPUTS AND USES OF THE DATA	  5-9

6.  WASTE MINIMIZATION	  6-1

    A.  INTRODUCTION AMD OVERVIEW	  6-1
    B.  ADMINISTRATIVE REQUIREMENTS FOR THE DATA	  6-1
    C.  POLICY OPTIONS	  6-3
    D.  DATA AND INFORMATION REQUIREMENTS	  6-4
    E.  USEFULNESS OF CURRENT DATA	  6-4
    F.  DESCRIPTION OF THE PROPOSED FORMS	  6-5
    G.  SAMPLE OUTPUTS AND USES OF THE DATA	  6-10
    H.  PROS AND CONS OF THE PROPOSED SYSTEM	  6-10

7.  ANNUAL/BIENNIAL REPORTING SYSTEM	:  7-1

    A.  PROJECT OVERVIEW AND SYSTEM CONCEPT	  7-1
    B.  SYSTEM OVERVIEW AND DATA FLOWS	  7-3
    C.  ISSUES	  7-7

APPENDICIES

    A.  Draft Revised Forms for the Annual/Biennial Report.
    B.  Draft Instructions for the Revised Forms
    C.  System Flow Diagrams for Report Data System
    D.  Project management Plan for the Report Data System

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                                   CHAPTER 1

                                 INTRODUCTION

A.  BACKGROUND

    A  proposal  for  revising  the  EPA  standard   forms  used  by  generators,
treaters,  storers,  and  disposers  of  hazardous  waste  in  reporting  their
hazardous waste  activities  to States and EPA  regional  offices is presented  in
this paper.   EPA requires states  to collect hazardous waste information on a
biennial,  annual,  or  more   frequent  basis  under  the  Resource Conservation
Recovery Act  (RCRA) of  1976,  for use by the agency, and State agencies,  in the
planning   and  evaluation  of   hazardous  waste   regulatory  programs.   The
information  is  also  valuable for reporting to  Congress,  state  legislatures,
and  the  public  on  locations, quantities,  and disposition of  the waste.  The
mandate  for  EPA to  require  handlers  of  regulated  wastes  to  submit reports
biennially  appears  in  40CFR,  sections  262.41  and  264.75.   In  addition  to
addressing   well-known   problems  with   the  current  biennial   report   (see
"Designing  a More  Effective  Hazardous Waste  Reporting  System:  A  Background
Paper,"  National Governors'  Association,  Center for  Policy Research, January
30,  1987), the  proposed  new  forms  have been  designed not  only for  covering
wastes  regulated as  hazardous  under RCRA,  but to  be  suitable as well  for
state-regulated  hazardous wastes.   This design feature  has been  incorporated
to encourage  state adoption of the form  for their own reporting purposes.

    The  proposed forms included in this  paper  are an outgrowth of  two prior
meetings  of  the  RCRA Annual/Biennial Reporting System Advisory Council,  eacft
preceded  by  widely  circulated  discussion  papers.    The  first  meeting  was
conducted  on  February 11, 1987,  and the second on  April  30  - May 1,  1987.   The
Advisory Council, which was formed at EPA's request by the National  Governors
Association (NGA),  consists of .representatives from States,  the  RCRA regulated
community,   interested   outside  information  users  (including   environmental
groups),  and EPA's  Office   of  Solid Waste  (OSW)  and Regional Offices.   In
addition  to  recommending the revised form to EPA, the Council,  in  subsequent
meetings,  will  consider  three   remaining  aspects  of the  biennial  reporting
system:

       •    Reporting  Considerations — Mechanisms  that  may  ease  handlers'
            reporting  burdens,  including  the  use  of electronic data-transfer
            techniques;

       •    Data  Processing -- Development  of  an automated system for managing
            data  reported on  State  and  EPA computers,  including screen entry,
            automated  editing, and retrieval of standard reports;

       •   State Reporting to  EPA — Issues  concerning  the flow  of data from
            States to EPA?  including  the  extent  of  EPA  access  to handlers'
            reporting  records,   and  interfaces  between  State  Annual/Biennial
            Report  data  bases   and  the Resource  Consideration and Recovery
            Information  System (RCRIS).

     In its first meeting, the Advisory Council reached consensus on  five

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 priority  information  areas   that  deserved  attention  in  revising  the  RCRA
 reporting  system  and EPA's  standard forms:

        •   Waste  Quantity  and Processing  Tracking --  Quantities  of RCRA and
            State  hazardous wastes  generated,  the  sources of such  quantities,
            and  the  manner  in  which such  quantities  are subsequently  managed
            including  quantities   transported   off-site  and  their   various
            destinations,  the   specific  quantities  managed  both  on-site  and
            off-site  in intermediate  storage and  treatment  processes,  and the
            actual quantities of hazardous wastes  ultimately  disposed of.

        •   Waste  Characterization ~ Nature of wastes regulated under RCRA and
            associated  State regulatory programs  including  data  on  intrinsic
            hazards  posed  by  such  wastes,  their  physical   form  and chemical
            composition,  and other  information necessary  to  assess  the  human
            health and environmental  risks posed by managing  such wastes.

    •       Regulatory  Status   —  Reporting  year  status  of  hazardous  waste
            handlersregulated under   RCRA and   associated  State   regulatory
            programs  including that  which  is  necessary  to  determine  which
            handlers  are  required  to  report,   and  the  numbers   of handlers
            falling within general categories of RCRA and  State hazardous  waste
            regulatory programs during the reporting period.

        •    Waste  Minimization  — Handlers'  practices  and  accomplishments  in
            reducing  both the  quantities of  hazardous waste  generated  at  the
            source and  its  residuals,  and  the  nature of  the hazards posed  by
            such wastes.

        •    Capacity  Assessment — Amount of  capacity remaining at  the  end  of
            the  reporting  period  for processes  used  in  treating,  storing,  and
            disposing of  hazardous wastes including information describing any
            changes  in  process  capacity that  occurred  during the  reporting
            period,  and  the. extent  to  which remaining  processing  capacity  is
            available  to  meet  future demands  or  the overall supply of  such
            capacity.

B.  ADVISORY COUNCIL RHXBMENDATIONS

    In  addition  to  general   comments  like  "keep   the  form  as   simple  as
possible,"  and  to  the extent possible, "the  annual/biennial  report  process
should  make  use  of the  data  available  in the 'manifest'  system,  and  be
compatible  with  it," specific requirements for  each of  the five  information
areas  above  were  identified   during  the   Council's second  meeting.    These
requirements were used  by staff to guide them  in producing the current drafts
of the revised EPA forms.  The  following section summarizes  these requirements:

       •   Waste Quantity Tracking

           — Generators   should  identify  and   quantify   each   waste   type
              generated   during  the   reporting   period    at   the   reporting
              establishment.

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 --  Generators    should    indicate    for   each   waste   type   their
    understanding of the ultimate method  of  disposal.

 --  Mode  of  transport  and  destination   should   be   reported  for
    generated wastes which are treated and  disposed of  off-site.

 --  TSDs should  indicate the generation source for each waste type
    received from off-site.

 —  TSDs should report sequences of  handling  methods applied to each
    reported waste type.

 --  Handling method codes used  for TSD reports should  include all 3
    character  codes   listed  in   EPA's  current  hazardous   waste
    regulations.

 --  Quantities  of  intermediate  products  in  a  sequence  of  handling
    methods will  not be required.

 —  Hazardous  residues   of  handling  methods  should  be  reported  as
    generated wastes.

 --  A 3-character  code  for  "transfer station" operations  should be
    included as a handling method.

    Provision should be  made  for reporting  what happens to hazardous
    wastes that are fuel-blended.

 Process Quantity Tracking

 —  TSDs  should  report  aggregate  quantities  of  hazardous  waste
    handled by each handling method.

 —  Waste   handlers  should  submit   information   describing  their
    "permitted and available" handling capacity for hazardous wastes.

 —  Information  on hazardous  waste  handling capacity  available to
    persons  other  than the respondent should be collected  including
    "how much is for them and how much is for others".

 -- Waste  handlers should indicate  any  plans  (e.g.,  as exemplified
    by  a  permit application,  etc.)  to  make  changes  in their waste
    handling capacity.

 — Some  indication should be  provided  as to  whether the  available
    handling capacity is dedicated  for  hazardous  waste or that  may
    be used  for both hazardous and non-hazardous waste.

Waste Characterization

 — Waste  stream data should  be characterized on  the basis  of:  (1)
    the current  4-character EPA Waste Codes; (2) physical  form;  and

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                                      1-4

              (3)  a   limited   number  of   other   characteristics.   Possible
              candidates include:  (1)  acid/base;  (2) percent solid/liquid;  (3)
              organic/inorganic;   (4)   halogenated/non-halogenated;   and   (4)
              presence of reactive anions.

       •   Regulatory Status

           -- All  regulated  parties  except  for  small  quantity  generators
              should  report  detailed, quantifiable,  hazardous  waste  handling
              information.    Small  quantity  generators  would be  required only
              to update relevant regulatory status information.

       •   Waste Minimization

           -- Generators should provide  general  information on  their efforts
              to minimize waste along with data on  their  past  practices.   All
              information would be  provided on  a waste  stream basis  by  SIC
              code.

           -- Subjective  questions  should  be  avoided  as  well as   questions
              about future practices.

           — The  instrument should include  some  sort  of  production  change
              indication ratio per SIC code by facility.

           -- Toxicity should be addressed in narrative form.

           — All  of  the information  collected should be  quantifiable to  the
              extent possible.

    For  the  most   part,  the  draft  forms  included  in  this  proposal  follow
closely  the guidance  provided  by the Advisory  Council.   There  are several
exceptions,  most notably  in the  areas   of:  (l)  waste  characterization  where
complementary waste  description code information  is  solicited  for the purpose
of compiling basic  information  on  the physical and chemical nature of reported
wastes;  (2)  waste  quantity  tracking, where  a  new listing of handling codes is
recommended;  and (3)  process   quantity tracking,  where  information   is  sought
regarding  the "availability" of waste handling capacity.  Differences between
the guidance provided  the Advisory Council and the draft forms were mainly  due
to  requirements identified  by EPA  as   necessary  in  fully carrying out  its
regulatory  mandates and are included for the  Council's consideration.   Other-
extensions  to the   forms were  necessary  in  order to make the Annual/Biennial
Report  data more  compatible with  other EPA  data   collection  efforts  (e.g.,
RCRIS).

C.  ORGANIZATION OF PROPOSED REPORTING FORMS

    Copies  of  the draft  reporting  forms  are  included  in Appendix A.   The
complete   set   consists of   ten  individual  forms,   including  a  respondent
identification  form,  a form to  assist handlers in determining who must  report
and what forms are  to be  reported, and  a Regulatory Status form.  A complete
list of  the proposed reporting  forms and  their  functions  is provided  below:

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                                  1-5

•  Form 1C: Identification and Certification

   —  Confirm or report location and mailing addresses.
   --  Report 4-digit SIC codes for site.
   —  Report tank accumulation capacity.
   --  Sign standard certification statement.

•  Form FS: Form Selection

   —  Indicate whether site generated (large quantity), shipped,
       or received RCRA hazardous wastes.
   --  Indicate whether site generated wastes required to be
       reported only by the state.
   --  Indicate whether site processed hazardous wastes in RCRA
       or RCRA-exempt units (excluding accumulation), or whether
       such units exist a the site.
   —  Indicate whether site has "active" (i.e., not formally
       withdrawn) Notification or Part A status for activities
       not occurring in reporting year (directs appropriate sites
       to Regulatory Status form).

•  Form RS; Regulatory Status

   —  Indicate whether site was a RCRA small quantity generator,
       a RCRA conditionally exempt small quantity generator, or a
       generated regulated under state quantity limits.
   ~  Indicate whether specifically excluded wastes were generated
       or processed at the site.
   —  Indicate whether the site has ever generated or processed
       hazardous wastes, if such wastes are expected to be generated
       or processed in the future and, if not, why the site filed
       a Notification or Part A.

•  Form WD: Waste Description

   --  Describe all hazardous wastes generated, shipped, received,
       or processed during the reporting year.
   --  Establish reference number for use on remaining forms.
   —  Processors provide extended characterization.

•  Form P6; Primary Waste Generation

   —  Quantify all hazardous wastes generated from primary
       processes during the reporting year  (excludes hazardous
       wastes generated as a result of hazardous waste processing
       operations (e.g., incinerator ash from FOOD).
   —  Reference wastes described on Form WD.
   --  Provide comparable quantities for previous year  to  assess
       waste minimization.
   —  Describe  industrial process(is) or other process(is)  that
       generate hazardous wastes.

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                                  1-6

   —  Provide production ratio(s) for hazardous waste generating
       operations.
   --  Indicate changes in toxicity and reasons for changes in
       toxicity or volumes from previous year.
   --  Indicate management sequence for waste (general codes for
       generators; detailed codes for processors).

•  Form WM; Waste Minimization

   --  Answer Yes/No and Multiple Choice questions about waste
       minimization efforts and activities at the site.

•  Form SO; Waste Shipped Off-Site

   --  Reference wastes described on Form WD.
   --  Report quantity shipped or to be shipped, ID number of
       receiving facility, number of shipments, transport mode,
       transport container, and off-site management sequence
       (general codes).

•  Form RO; Waste Received From Off-Site

   --  Reference wastes described on Form WD.
   —  Report quantity received, ID number of generator, number
       of shipments received, and on-site management sequence
       (detailed codes).

•  Form 01: Off-Site Identification

   --  Indicate the name, location, and ID number for each facility
       that hazardous wastes were shipped to, or generator hazardous
        wastes were received from, and the site's  relationship to the
       generator/faci1ity.
   —  indicate ID numbers and name only for all transporters used
       during the reporting year.

•  Form PS; Waste Management Process Summary

   —  Describe all existing hazardous waste management processes
       (including RCRA-exempt processes that handle hazardous wastes
       but not including accumulation tanks or containers).
   —  Report remaining capacities for each process (different.
       formats for storage, single unit treatment, multiple unit
       processes, and landfills), and indicate limiting factors
       affecting calculation.
   —  Describe planned changes in process capacity, and  indicate
       when changes are expected to occur.
   —  Quantify and generally describe total  influents to process;
       indicate percent hazardous.
   --  Quantify and generally describe non-hazardous effluents  from
       process.
   —  Quantify and reference wastes described on Form WD that  are
       hazardous residuals from the process.

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                                      1-7

    The  organization   of  the  proposed   form  package  is   the  result  of
considerable deliberation.   A number of  alternative organizational approaches
were evaluated.  Emphasis was  placed on minimizing aggregate respondent burden
by grouping  items  common to specific classes  of  handlers together on the  same
forms.   Clarity in  identifying which  handlers  are required  to file  and in
instructing  respondents  to  the  appropriate  forms  was  also   stressed.  In
addition to  addressing  the  functional specifications developed by the Advisory
Council,  the development team considered  ways  in  which the  reporting forms
could  be used  to  support State-specific  reporting  requirements, and  be  tied
into  other  existing  reporting  systems  such  as  manifest   reporting,  waste
registration systems (as in Texas),  etc.

    The  proposed  set of reporting  forms are distinguished  from EPA's  current
reporting  forms in  two  significant ways:   (1)  there are a  greater number of
data elements  required  to be reported; and (2) these data elements are spread
across  a greater number  of forms.   The  increase in the number of reportable
data elements  is somewhat  deceiving because many of the items that appear as
new questions  or  columns on the proposed  forms were, in fact, required on the
existing  forms  in  less  formal   ways.  Many  of  the  items  on  the   Primary
Generation form, for example,  describe the  process  that generated a hazardous
waste.   While   these  items  do  not  appear  as  formal elements  in the existing
forms,   a  careful   reading  of  the   instructions   to  the  narrative  waste
description  item  will reveal  that  similar or  identical information about the
process  was  asked  for the  waste  description.  Similar  statements can be  made
about  many  of  the  items  on  the  Waste Description  form   and  the Waste
Minimization  form.  Accordingly,   the  increase  in  the  number  of  reportable
elements  is  not as  great as the  sheer increase  in  forms would  suggest.   Much
of the  increase  is  a  result of  formalizing existing  requirements to ensure
that the data obtained through these  requirements are useful.

    There  is,   nonetheless,  an increase in  the  amount of  information to be
reported  in  the  proposed  forms.   There  are  two  major reasons  behind  this
increase:  a  greater emphasis  on  supporting  sound waste minimization analyses
(at  both  the  site  level   and  industry-wide);   and  the Advisory Council's
decision to  expand the  reporting  system to support analyses  of  hazardous waste
processing  capacities.    Waste minimization is  emerging  as perhaps  the key
issue  to be  addressed in the long-term development of the RCRA and  other waste
management  regulatory programs.   Significant new legislation  in this  area, is
pending  in Congress and  in many  state Legislatures.  Accordingly, increasing
the  waste  minimization  reporting  requirements  beyond  the  simple narrative
statement  required for  1985 is clearly  warranted.  In  addition to providing
necessary  information  to  federal  and state  regulators,  waste  minimization
reporting  can  be  helpful  to  the  regulated  community  in  demonstrating  tne
results  of  their  own efforts  to  reduce  the  quantity  and  toxicity  of  their
hazardous wastes.

    The   decision   to   expand  the  reporting   system  to   support   capacity
availability  analyses  was made largely in  response  to the new  state  capacity
certification   requirements   enacted   in   the   Superfund   Amendments   and
Reauthorization Act  (SARA).   Previously,  the  RCRA  reporting  system  dealt
primarily  with the demand  side  of  the  capacity   equation,  focusing  on
quantifying  hazardous  waste  generation.   With the   increasing  emphasis  on

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                                      1-8

knowledge  of   available  processing   capacities  brought  on   by  the  SARA
requirements  and  the  need  to  establish effective  dates  for  land disposal
restrictions, the  need for  comparable information on  the supply  side  of the
capacity  equation  became apparent.   Obtaining data  to support  both sides of
the  analysis  from  a  single  source,  the  RCRA  reporting  system has  the
advantages  of  consistency  in  definitions  and  scope,  efficiency  in avoiding
duplication  in  reporting  requirements,  and  convenience  in  analyzing  data
already  assembled   into  a single  repository.   Much  of  the  expansion  in the
number of reportable items results from the capacity concern.

    Aside  from  the  increases  related  to   capacity  and waste  minimization
analyses,  there  are  not a  great  many  new  reporting  items  in  the proposed
forms.   The  organization  of  these  reporting  items   has,   however,   changed
significantly.  This change  in organization  is due to the need  to  include more
reporting items, but  is  driven primarily from concerns about'ambiguities that
result from the current organization.    The  two-form format represented by the
1985  forms  lumps  a number  of  functions together,  resulting  in  substantial
difficulties in  analyzing the reported  data.   Hazardous waste  generation, for
example,  is  difficult to  determine in  many cases under  the  two-form  format.
The current Generator  form is in actuality  a shipper form, since  it addresses
primarily wastes  that were  shipped off-site  during  the  reporting  year.  Not
all wastes  shipped off-site  during a  reporting year  were actually generated
during that year,  but  such wastes  do  show up in manifest tracking systems and
are reported  currently as  if they  all  were generated  in the  reporting year.
Additional  generation  quantities  are reported  on the  current  Facility form.
Here, however, hazardous waste generation that is actually "regeneration", or
generation  resulting  from  the  processing   of  already   reporting hazardous
wastes,  can  not be distinguished,  resulting  in double,  triple,  and  further
counting of waste quantities.

    Accordingly, a premium  was  placed  on  designing  the  new  forms  to  clearly
quantify  "primary1  generation  (all  hazardous  waste  generation  except  that
generated  as  treatment  or  other  residuals  from hazardous  waste  processing
operations).  Waste shipments  and  receipts  are reported separately to avoid
confusion over what quantities were actually generated at a site.   Previously,
these functions were all combined.

    A  second organizational  area  that  distinguishes  the proposed  forms  from
the 1985 forms is  in  how waste processing  operations  are reported. The  1985
forms  lump processing and  generation together  under a single  quantification,
resulting  in  an  inability  to  quantify  actual processing  quantities.   Much
extrapolation  is  currently  required  to perform comparisons  of quantities  of
hazardous  wastes  land  disposed vs.  quantities  treated  in incinerators,  etc.
The  proposed  forms address  this concern,  pursuant  to the Advisory Council's
guidance,  by obtaining quantities  of hazardous  wastes processed  in-total  for
each  process.   Processing patterns for  individual generated hazardous wastes
are reported  as  a  sequence  of codes associated  with the  total  quantity of  the
waste  generated  during  the  reporting  year.   These  two  items  allow for waste
management by process  for different types or  different generators  of hazardous
waste,  and  enable  aggregate  comparison of  the utilization of  different types
of processing techniques.

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                                      1-9

    The  item  that  most clearly distinguishes  the  proposed forms from  the  1985
forms  is the  waste  referencing  system  built  into  the  proposed  forms.   All
wastes  managed at  a  site are  described in  one place,  the  Waste Description
form, and  are then referenced  by Waste Description  form page and line  number
on the  Primary Generation  form  (if  any of the waste was  generated  from primary
processes at  the  site),  the Waste Shipped  Off-site form  (if  any quantity  of
the waste was shipped off-site during the reporting  year),  the Received  From
Off-site  form (if any  of  the  waste was  received  from off-site),  and  the
Process  Summary  form (if  any of  the  waste  was  generated as  a  result  of
hazardous waste  processing  operations).   Use  of a  referencing system  has  a
number  of  advantages  over the current  system.   One major  advantage is  that
facilities that manage similar  or identical  wastes from  many different sources
or customers  need  only  describe  the waste  once.  The  waste  is  then  simply
referenced  when  identifying  the  quantities  received  from  each  generator.
Solvent processors  that deal  with numerous  customers are prevented in  this way
from  having  to  repeat descriptions  of  largely  identical wastes.   Commercial
disposal facilities that  receive similar wastes from  different  sources  will
also  benefit   from the  adoption  of   a  referencing  system.    The referencing
system  is necessary for greater clarity  in distinguishing quantities  generated
from  those shipped  or  received.   Currently,  a  single  quantity  identifies
generation and shipment.   Under  the  referencing approach, the  actual  quantity
of a waste  that  was generated  at  the  site  is reported  in  one place,  the
quantity of the same  waste that was shipped off-site during  the reporting  year
is reported in another.  These  two  quantities are frequently not  identical,  as
quantities  shipped may  include  quantities  that were  generated  in  previous
years,  and  all of  the waste that was generated -during  the  year may  not  have
actually  been  shipped  off-site  during  the  year.   Under the  referencing
approach,  these  quantities  are each  linked  to  single  place  where  the waste
stream  is fully  described.   The  referencing system avoids  the need to  repeat
waste  descriptions whenever  different  management operations  associated  with
the waste are described.   In this  way the referencing system has enabled the
proposed reporting  forms to be printed on standard 8.5  by 11  inch paper.

    The waste  referencing  system  also has a long-term advantage in that  it can
be related easily  to  separate waste reporting systems.   In the  State of  Texas,
for  example,   where  generators  are   required  to  "register"  their   hazardous
wastes   with   the   State    by  providing   extensive    descriptions   and
characterizations,  the waste referencing  system could  simply reference  the
State-assigned waste  registration  number,  provided  that the wastes  generated
or  otherwise  managed  at  the   site  still  fit  the   descriptions   submitted
previously to the  State.   EPA  is currently  investigating the need  for  a  RCRA
testing rule  that  would require development  of the same  kinds  of data that are
required to be reported under  the new  forms.   To the  extent that  such rules
take effect, characterizations  developed  in  accordance with  them may simply be
referenced, not repeated in each year's Annual or Biennial Report.

    The  waste referencing system  also  enables  states  to obtain information
beyond  that required  in the  proposed forms  by  developing additional  forms of
their own and including  the  waste  referencing item, as  opposed to redesigning
the proposed  forms  to build  in  their own items.  In  this way,  for  example, the
State  of Washington  can   require handlers  to  report  the quantities of  each

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                                     1-10

waste  shipment,  including reporting the  manifest number of  each shipment  and
any additional  data that are  not  already known  from  items  that appear on  the
proposed  forms.   The  sum  of  the  quantities shipped  over  the year  to each
different facility, as well  as the total  number of shipments, should equal  the
numbers reported  by the  handlers on the  proposed Waste Shipped Off-site  form,
enabling easy checks on the accuracy of the State-required data.

    Recognizing  that  adoption of  a  referencing  mechanism  adds  a  degree  of
complexity to the reporting  requirements, emphasis is placed on making  it easy
for  handlers  to  use.   The  page and  line number   approach  minimizes  the
likelihood of  reporting  error,  since  the  only  variable that  is not actually
preprinted on  the  form   is  the Waste  Description form  page number  (this  is
because only  one page of each form type is  expected  to be included in  State
raailouts; handler will  make copies of  multiple  page  forms).  Accordingly,  the
waste  referencing system  is  seen as a significant enhancement of the reporting
system,  easing  respondent  and  processing  (reduced  key-entry)   burdens  and
providing  links   to  other   existing  and  future  state-specific  reporting
requirements, all without increasing the  likelihood of  respondent error.

    Another  distinguishing feature of  the  proposed  reporting  forms over  the
1985  forms  is that  managers  of  facilities that  process hazardous wastes  are
asked  to provide  more waste  characterization  information  than  are handlers
that  simply  generate hazardous  wastes  and ship  them  off-site.   The rationale
for this  distinction  is  that operators  of waste  processing  operations are more
likely to have  the desired data on hand  for reporting purposes than are  those
who  generate  only.   Most  commercial  facilities  require  substantial  waste
characterization  information  to  be developed  prior  to  processing the  wastes
they  receive.  On-site managers  need  to ensure that the wastes  flowing  through
their  processes  meet their  design or  permit requirements.   Concern over  the
quality  of  information reported suggested that  the  extended characterization
items  be obtained  only  from  those most able to provide  them,  the facility
managers.  On  the other hand,  information  about  the  processes  responsible  for
generating  hazardous  wastes  (except  for  hazardous  wastes  regenerated  from
hazardous waste processing  operations) is obtained  only from  the  generators,
not  from  facilities  that  only  manage  other  handlers'  wastes.    A  similar
distinction  in  generator vs.  facility  reporting  is made in  the description of
the processing  sequence  applied  to a  waste.  Currently,  the federal forms do
not  require  generators  to  supply any information about what  happens to  the
wastes they  generate  other than to identify the facility to which  their waste
was  shipped.   Facility  operators were  only  required  to  report  the  final
disposition of the wastes they managed.   Under the proposed  reporting forms,
generators are  asked to  report  in general  terms what  they  expect  to happen to
the  wastes  they ship  off-site  (similar to the New  York   requirements),  and
facility  managers  are  asked  to  report  the  actual  sequence  of  management
processes, using more  detailed codes,  that were applied  to  the wastes they
managed.   The  distinction between  generator and facility  reporting   here is
based  on assessments  that generators  are  less  likely to  know the  details of
the waste management  process, but ought to know the ultimate disposition of
the waste they generate,  while facility operators can reasonably be  expected
to  report the  actual processes  that  they  applied to the  wastes they manage
(note,  however,  that pursuant  to the Advisory  Council's   guidance,  facility

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                                     1-11

managers need  only  report the sequence of  management process codes and do  not
have  to identify the  quantities of  each waste  as  it  enters  each subsequent
process).

    State  and EPA  Regional  Office  processing  burdens were  also considered
extensively  in  the  design  of  the  reporting  forms package.   The  forms  are
designed  to be  accompanied  by  computer-generated  mailing  and  site  location
labels.  The mailing  label  is affixed to  the  outgoing envelope.  The  location
labels  are  to be  affixed  by  handlers  to  any  forms  they are  required  to
complete.   The handler  Identification and  Certification  form  is  designed  to
minimize  implementor  data  entry  by  asking   first  whether  the   information
included on  each label  type  is  correct.   Only data  that  are incorrect on  the
labels  need  be reported  by  handlers  and entered by implementors.  Bar-coding
the  RCRA  identification numbers  on  these labels   is  being  investigated  to
further ease  processing  burden  through the use of  optical  character  readers
and wands.  Furthermore,  having  handlers affix  preprinted labels on each page
of  their  report  reduces respondent  burden  and  the likelihood of  errors  in
either  reporting  or  key-entering RCRA identification information.   Use of  the
labeling  system  will  make  it  easier  for  implementors  to  process  the  large
volume  of  reports from  small quantity  generators  who,  unless  instructed  to
complete further  reporting  by their State  (as  in New York), are required only
to  complete  the  Identification,  Form Selection,  and Regulatory Status forms.
For  this   large  group  of respondents,  the only data  that will  need  to  be
key-entered if existing data are correct are  the site's RCRA ID number (which
may be  optically read)  and  less than ten  Yes/No answers  requiring single  key
strokes for entry.

    The final  significant difference  between  the proposed forms and  the 1985
forms  is  that handlers  that  process hazardous  wastes  in units or processes
that  are  exempt  from RCRA permitting  requirements (e.g.,  NPDES-permitted tank
treatment  of  hazardous wastes)  are  none   the  less  required  to report
information about such processes and  the hazardous  wastes they manage in  such
processes. The rationale  for  this requirement  is that exempt processes account
for  the management  of  large quantities  of  generated  hazardous  wastes  (see
Figure  1).  It is  important  that  these  quantities  be  reported in  determining
the total  quantity  of  hazardous wastes  generated,  and  that the management of
these  large  quantities  be  properly  accounted  for  in  the  hazardous  waste
system.  Under the proposed  system,   all  wastes that meet  the definitions of
hazardous  wastes are   reported, even if  they  are  subsequently  managed  in
processes  exempt from RCRA  permitting  requirements,  enabling  for the  first
time  a  complete  assessment  of  the  nature and  scope of  the entire hazardous
waste system.  Exempt  processes  are  clearly identified,  as are  the  wastes that
flow  through  them.  Concerns over  the  large  volumes  of  wastewater  that  are
frequently  reported  as  hazardous wastes  are   also  addressed  in this  manner,
allowing  for  separation of  these   quantities   and processes  in reporting
hazardous waste information to Congress, legislatures, and the  public.

    The  form  package   divides  instructions into  a  separate  booklet.   This
allows  handlers  to  refer to  instructions or definitions  without turning  away
from  the  form they are working  on, easing  respondent burden.   All terms  that
might  require  definition are printed  in  italics and  formal  definitions  are
included in the  instructions.  A conservative approach was taken here: when in

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                                     1-12

doubt about the familiarity of a term, the term  is defined.

    The  reporting  form  design  team  recognized  that  implementation  of  the
proposed  reporting  forms  during  the  1987  reporting   cycle  would   present
problems  due  to  the lack  of prior  notice to  handlers  as  to what  would  be
required to be  reported.  Some  of  this concern  is addressed  in  differentiating
generator and  facility reporting requirements,  asking for necessary data  only
from those most likely  to have  it  without prior notice.   The report forms  also
allow  handlers  to  report data  at  many different levels  of aggregation,  even
though  the  data  are desired at specified levels of  disaggregation.    If,  for
example,  waste quantities  at  a  site  can  not  be broken  out  by individual
generating process  for 1987, waste quantities  can  be  grouped  up to whatever
level of detail the site  can report.   Economic  activity information associated
with the generating processes, required to evaluate changes in  generation  from
those  same  processes,  would  then  also be aggregated  to the same level  as  the
waste quantities, ensuring consistency in the  reported data.

    Nonetheless,  it  is  expected   that many  handlers  will  not  be   able  to
complete certain  items  included in the proposed forms  for  the 1987 reporting
cycle.   The   elements    included,   however,   represent   the  elements   deemed
necessary  to   support   sound  regulatory   analyses  and  management   of   the
regulatory program, within the  guidance parameters specified  by the Advisory
Council.   These  are  the  items  that  are  needed  now  and  in   the   future.
Including them on  the  1987  forms is  an effective way  of  communicating  the
reporting requirements  to  the  regulated  community,  so  that   in  the  future,
required data will  be  available from  existing records maintained by handlers.
The  1987  reporting  cycle is also  a testing  cycle  for  the revised reporting
system,  so  it  is desirable  to  include all  elements that  are anticipated  to
comprise  the  system during  the test  phase.  NGA  and the  report form  design
team will,  however, work with  industry groups  during the  month  prior  to  the
next meetings  of the Advisory  Council  to better assess  the acceptability  of
the proposed forms.

D.  .IMPLEMENTATION OF THE REVISED FORMS

    Use  of  the revised reporting  forms  is meant  to be  voluntary during  the
1987 reporting cycle for  all  non-authorized states and mandatory  in 1989 (1988
if  an  annual  reporting cycle is adopted), thus providing a field test  of  the
revised standard  EPA forms.   A  recent NGA survey indicated  that 25  states were
interested  in  using  the  revised  forms during  the  1987  reporting cycle,  the
final  number  being dependent   upon  their  complexity  and  eventual  date  of
availability.  Many other states would have opted  to use the forms during the
first year, but  because of the  need  for possible changes in State  regulations
were unable to do so.

    Few problems  are anticipated in the ability of the respondent  to  fill out
the revised forms.   The Form Selection questionnaire (Form FS) should  help to
clarify  and  properly   direct the  respondents  to   those  forms which   must  be
filled  out   and,   thus,   should   reduce   any  confusion   in  this   regard.
Additionally, the detail  provided  in the Regulatory Status  questionnaire (.Form
RS) should  allow the  handler to  readily  determine those forms that apply  to
their site.

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                                     1-13

    Small  facilities may  have  some difficulty  in  completing  the  detail  on
processes,  waste  characterization,  and  available  treatment,  storage,   and
disposal  capacity.   If they  are unable  to  provide  this  information, certain
gaps will exist  in  the  national  data base being developed but this will  mainly
be  with respect  to the  level of  detail.   The  forms  have been  developed  so
that,  at  the  very  least,  the  more   aggregate  information   will   still  be
available at  the national  level.   Through  the use  of  statistical  techniques
and recent survey data, it will be possible  to  fill-out the missing data.

E.  REQUIRED REGULATORY CHANGES

    With  regard  to generators,  only  active,   large quantity  generators  are
subject to  the biennial reporting  requirements under the present regulations.
However,  the  alternative  selected for the  Regulatory  Status  section  also
requires  that  small  quantity  generators  (SQG's)  and  inactive   generators
(including conditionally  exempt  SQG's)  with ID numbers  to file the  Regulatory
Status section of this report.

    This  additional  reporting  requirement  for small  quantity  and  inactive
generators could,  legally,  be implemented  through the use  of  Section 3007 of
RCRA  which requires  all generators and  handlers  to  provide  information  on
hazardous  waste activity  when  requested by  the Agency.   EPA has  used  this
authority to conduct a  variety of  surveys.   It was also the authority cited in
the 1985 Mail  Survey.   A similar approach would be to use 40 CFR 262.43,  which
allows  the  Administrator   to  request  that  generators  furnish   additional
information  on  the generation  and deposition  of  hazardous  wastes.   Small
quantity  generators are subject  to  this   requirement  even  though  they  are
exempt  from the Biennial  Report  under 261.44.   The  advantage  of  invoking
Section 3007 of RCRA or  40 CFR  262.43  is that the  time requirements  are much
shorter  than  is the  case  for  a  regulatory  change.   Given   the  tight  time
constraints, this approach  is advantageous for the 1987 Survey.   The  major
disadvantage of using  3007 of  RCRA and  40 CFR 262.43 is  that  OMB  approval
would  be  needed  each  year  the  Biennial Report  survey is  conducted.  40 CFR
262.43 has  the additional disadvantage  that it may not apply to conditionally
exempt  small  quantity  generators  since  they  are not  subject  to  Part  262 of
RCRA.

    Because of the  disadvantages of using Section  3007 or 262.43 on an  annual
or  biennial  basis,  a  regulatory  change would  be  desirable for  the  1989 and
subsequent  surveys.  One approach for  such a  change  would be to  expand the
special  reporting requirements  of  small quantity generators,  outlined  in 40
CFR 262.44, to include  the  Biennial Report.   However, generators with EPA ID'S
who are inactive or who are  conditionally exempt  small  quantity generators,
during a  survey year,  would still  be  exempt from the Biennial  Report in those
years  that  these conditions apply.  Thus, a better approach would be to alter
40  CFR 262.12  which covers notification of generation  activities.   As  262.12
presently  reads,  this  notification is  required only  once,  at  the time of
obtaining  an  EPA  ID  number.   An  additional  requirement  could  be  added to
262.12  requiring  annual/biennial   notification of  regulatory  status for all
generators  with an  EPA  ID number.  The Annual/Biennial Report  could  be the
stipulated vehicle for  accomplishing this requirement.

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                                     1-14

    With  regard  to TSD  facilities,  Part  264.75  (and 265.75)  is  not clear  if
these  facilities  are  required to  file  a Biennial Report  for  a survey year  in
which  they  are inactive.   Consequently, a  regulatory change  would  likely  be
necessary  to  clarify  the  reporting  requirements  for these  sites.   However,
given  the  tight  time constraints  for  the 1987 survey, use  of Section 3007  of
RCRA  would  likely be  necessary  to  clarify  the  reporting   requirements  of
inactive TSD facilities.

F.  OUTLINE OF THE REPORT

    Each of  the  five information  areas identified by the Advisory Council  is
addressed in a separate chapter of this  background  paper.  Each discusses the
rationale  of  staff  in responding to  the guidance  provided   by  the Advisory
Council, along with  the legal requirements for  the  information sought, policy
options   from  which   the   pertinent   questionnaire   section  was   selected,
information  required  to  address  the  policy issues,  and  the usefulness  of
relevant  data  which  is  currently available.   Each  chapter  also  provides  a
description of the proposed form  section, sample  outputs  and analyses planned
for the data, and perceived advantages and disadvantages of  the proposed form.

    In  addition  to  this  introduction,  the outline of  the report  is  as
follows.  Chapter  2 discusses  regulatory status,  Chapter 3 discusses  waste and
process  tracking,  Chapter  4  discusses  waste  characterization,   Chapter   5
discusses  capacity assessment,  and  Chapter  6  waste  minimization.   Finally,
Chapter 7  provides a discussion  of  the data  processing  system being proposed
and  several  issues  that require  the  attention of  the  Advisory  Council.   A
series of Appendices are  also included  in this  report including copies of the
revised  draft  forms  and  instructions,  data  flow  diagrams,  and  a project
management plan for development of the reporting data  system.

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                                   CHAPTER 2

                               REGULATORY STATUS

A.  INTRODUCTION AND OVERVIEW

    The  regulatory  status  section  of  the biennial  report  form  serves the
following two major objectives:'

       •  To establish that regulated activities were actually conducted at
          reporting sites during the survey year, and to signal to these
          sites that they must answer all applicable parts of the biennial
          report.

       •  To identify reasons why inactive  (including small quantity)
          generators and/or facilities did  not, during the reporting year,
          conduct specific regulated activities listed in Notification Forms
          or Permit applications for their  site.

    A secondary but  still  important  objective  of including a regulatory status
section  in  the biennial report  is to clarify who  is  subject  to the reporting
requirements in  any new year.   Such clarification  is  important to members  of
the regulated  community,  as  they must  determine  reporting responsibilities,
and also to State  and Federal  officials, who are responsible for enforcing the
reporting  requirements.   A  well designed Regulatory Status   section   could
provide useful  information  on the nature and  scope of the regulated community
as a  simple by-product  of instructing  the members of that community on what
forms, if any,  they are required to file for the reporting year.

    This  chapter  describes  the  staff's approach  to  accomplishing  the  above
objectives.  A draft form  is  presented  (in the Appendix),  sample outputs are
shown, and  the uses of  these  data are  discussed  in detail.  This discussion,
however,  is preceded  by  several sections which  present  the  rationale for
collecting  regulatory   status   information.    The  topics   covered  include
administrative  requirements  for  the   data,  optional  approaches,  data and
information  requirements,  and  the   usefulness  of currently  available  data
sources.

B.  ADMINISTRATIVE REQUIREMENTS FOR THE  DATA

    State and  Federal managers  of  the RCRA hazardous waste regulatory programs
have a need to describe the numbers  and types of handlers subject to Subtitle
C regulatory requirements.  These  data are primary inputs to program planning,
implementation (including enforcement) and  evaluation activities.

    All of the existing data sources, however,  are inadequate to satisfy this
need.   The  inadequacy of  the data  sources is discussed  in  detail in Section
E.  But  in general, the  major drawback  of the existing  data  sources is that
they  are   incomplete,    inconsistent,   and   not   updated  routinely.    These
shortcoming are further  compounded by the  fact  that some sites have differing
levels  of hazardous  waste  activity  from  year  to year,  which  can  change  a
site's status  under the regulation's.   Additionally, in the  early days of  the
RCRA program,  many sites that  did not  need to  file,  filed protectively.  Not

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                                      2-2

all of these sites have been removed from the existing HWDMS data bases.

    As  a  result  of  these  shortcomings,  State  and  Federal  managers  are
generally  hard-pressed  to  report  the  number  of  sites  at  which  regulated
hazardous  waste  generation  activities  are  actually  occurring  in  any given
year.  While  the situation  is somewhat  improved when describing  the facility
population, due  to the greater degree  of scrutiny applied  to  this subset and
the  more  rigid  requirements  governing  regulatory  status  (e.g.,  facilities
continue to be  regulated until formal closure  proceedings have been conducted
and  specific  reports  filed), difficulty persists  in  distinguishing  between
allowed  activities and activities  actually conducted.  The lack  of  a clear,
current  picture   of  which  types  of   regulated  activities   are  occurring
complicates program  planning, implementation  (including program enforcement),
and evaluation activities at both the State and Federal  levels.

    The  annual/biennial  reporting system offers an  opportunity to augment the
data  describing   allowed   activities   with  reports  on  activities  actually
conducted  during  the  reporting   year.    This  information, combined   with  a
regulatory status  section, which  carefully questions a respondent on why their
site  is  exempt  from the biennial reporting requirements, will result in more
accurate,  up-to-date  counts   of  the  population  regulated under  Subtitle  C
requirements.    It will  also   help  determine  which facilities should  not  be
included as part of the  regulatory system and  allow them  to  be removed from
the  list  of  regulated  facilities.   Additionally,  RCRA program  managers can
distinguish between  inactive  and  active sites, and determine  if  an inactive
site will  remain  inactive.  This  improvement  in data accuracy  and  quality will
help State and  Federal managers to  better plan their RCRA regulatory programs.
Additionally,   if  the  regulatory  status  section  is carefully structured,  it
will  provide  a mechanism for assessing  compliance with the  reporting system
and  also serve  to instruct respondents  on what  their  reporting  requirements
are under RCRA.

    In summary,  data on  regulatory status can provide answers  to the following
policy questions:

     •  How many  sites were subject to regulation  in the survey year?

     •  Which sites were active during the survey  year?

     e  Which sites should be removed from  the  regulatory program?

     •  Are sites  correctly complying with the  reporting requirements?

C.  POLICY OPTIONS

    This section briefly summarizes options  which were considered as  possible
approaches  to  designing  the  Regulatory  Status section and  discussed in  the
paper presented at the Advisory  Council  meeting  in May.  The  two  major issues
addressed  in developing  regulatory  status options  were:

      1.  What populations, within the universe of  handlers  subject to
         regulation  under Subtitle  C, should  be required to  comply with
         annual/biennial reporting  requirements?

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                                      2-3

     2.  What information should be required for submission by various
         populations that are required to comply with the reporting.

    With  regard  to  the  first  issue,  the  broadest  spectrum of  populations
considered required  reporting  by all entities  that are  required  to obtain or
have  ever obtained  EPA  identification  numbers  under  RCRA.  The  narrowest
spectrum  of  populations  considered  required  reporting  by  only  active large
quantity generators.  The two  reporting  options  considered were full reporting
(i.e.,  completes  all   applicable  quantity sections)   and  regulatory  status
reporting   (i.e.,    reports   regulatory   status,   only).    These   range   of
population/reporting options were  combined such   that  six alternatives  were
developed  for  generators  and  two  were  developed  for  facilities.   These
alternatives are summarized in Table 2-1.

    Alternative  2  was  chosen  for  generators,  requiring  reporting  from  all
sites  which  have an EPA ID number.   Large quantity  generators  must complete
the entire set  of forms while small quantity and  inactive  generators with an
EPA ID number need complete  only the Regulatory Status form.  This alternative
provides  critical  information  on  small  quantity  generators  and  inactive
generators  without  subjecting  them  to  the  much more burdensome  quantity
reporting.  As  such, this alternative represents  the  best compromise between:
(1) minimizing the  reporting burden for respondents,  states,  and regions, and
(2) data  availability  for RCRA  program  managers.   An  additional  advantage of
Alternative 2 is  that  it provides  those  states  that want quantity  information
from small quantity generators with the flexibility to obtain  this  information.

    Alternative 1   was  chosen as  the alternative  for  treatment,  storage, and
disposal facilities  because, of  the two  options examined, it  provides the most
complete information towards answering the policy  issues raised  in Section B.
Additionally,  it  does  not  represent an  increased  reporting  and processing
burden either to  the regulated population  or  to the states, because it is the
approach used for the 1985 report.

D.  DATA AND INFORMATION REQUIREMENTS

    The main  purpose of the Regulatory  Status  form is to determine why a  site
did  not  fill out   the  detailed  "waste  handling" sections  of  the Biennial
Report.   The regulatory section  can  indicate which  sites:   (1)  should  be
removed from  the  regulatory programs (e.g., non-generators and non-handlers);
(2)  are  periodic or one time  generators; and  13) are subject to  regulation
but are  not  required to  report.  As such,  the  regulatory status  section  must
cover  the  main  reasons  why  a  site   is not  providing  information  on  the
generation  and  handling  of  hazardous   waste.  To   assure   that  respondents
properly  choose  the  options which correctly describe   their  reasons for  not
filing, the  options  listed  in the  regulatory  status section  must  be  carefully
organized  and   worded.    The  selections  must   also   clearly   reflect   the
requirements and intent of the RCRA regulations.

    To this  end,  six main reasons  why a site would be  exempted  from providing
detailed  waste  handling  information were initially developed  as  follows:

-------
                                     2-4

                                  Table 2-1

                     ALTERNATIVES DEVELOPED FOR PREVIOUS
                           ADVISORY  COUNCIL MEETING
                                  (May  1987)

                   Generators Reporting System Alternatives
    Generator
Population Group
Inactive

    Large Quantity     RSR

    Small Quantity     RSR
  Alternatives

Active
Large -Quantity
Small Quantity
CA
TX
FR
FR
FL
OR
FR
RSR
NY and
NJ
FR
FR


FR
RSR
EPA,
1985
FR
--
._
• ~
FR
—
RSR

RSR
       RSR
                  Facility Reporting System Alternatives
                  Facility
              Population Group
       Alternatives
             Active

             Inactive
   FR

   RSR
FR
Notes:  FR • Full reporting required (Regulatory Status sections and any
             applicable "Quantity" sections).

        RSR » Only Regulatory Status Section  is required  to be  completed.

        --  • No Reporting Required.

-------
                                      2-5

       •  The site meets the requirements of a small quantity generator or
          conditionally exempt small quantity generator;

       •  The site generates/processes only excluded or delisted or wastes;

       •  The site has never generated/processed hazardous waste;

       •  The site has stopped previous hazardous waste activities;

       •  The site is a periodic or intermittent generator/processor
          of hazardous waste; and

       •  The site has never generated/processed hazardous waste, but
          intends to in the future.

    Under  each topic  a  series  of  more detailed,  selections  were developed
which  help answer  the  policy questions raised  in Section  B:   (1)  how many
regulated  sites  exist,  (2) which  sites are active,  (3)  which sites no  longer
belong in the regulatory  system, and (4) are sites properly complying with the
reporting requirements?   To help answer the  fourth question,  a form selection
section was  added  to regulatory status, which  through a series of brief "yes"
and  "no"  questions  directs  the  respondents  to those  forms which  they must
complete.    Additionally,   it  provides  EPA  and   the   states  with   enough
information  to determine  if respondents are  completing  the  proper sections  of
the form.

E.  USEFULNESS OF CURRENT DATA

    There  are  three major  sources  of  regulatory  status  information:   (1)
Hazardous Waste Data Management  System  (HWDMS);  (2)  1981 Mail Survey; and  (3)
State  Uniform Manifest  Systems.   HWDMS  is  a  large data base maintained  by  the
Office  of Solid  Waste  (OSW),  containing  information  on sites  regulated  by
RCRA.   It includes  several  fields,  which can  be used  together,  to describe
regulatory  status.   These  indicators   were  utilized to  develop  the   sample
survey  used  as   a  cross-check  of  1985  Biennial  Report  data.   A  major
disadvantage of using these data  fields for regulatory status is that they  are
not   applied  uniformly   across   states   and   regions.   Additionally,   this
information  is  not available for  all sites and  it is not always complete  for
those  sites  which  do  have  regulatory  status  information.   This  lack  of
completeness and  consistency makes  it  difficult to  answer  the type of  policy
issues raised above.  Also, there  is no well developed mechanism to change  the
data  in  these  fields  to  reflect  a  site's  status  change through  time.   A
modification to this information occurs only through  closure and the  rare  case
where a site happens to file  a modification.

    The  data from  the  "Notification of Hazardous Waste Activity  Form"  (EPA
Form  8700-12)  is  a subset  of HWDMS.  This form must be completed by  all sites
handling  regulated quantities of hazardous waste.   The notification  form  does
provide some information on  regulatory status,  but  these forms are  typically
not  updated.  Consequently,  they  provide  a  static,  outdated  picture   of  the
status of generators and  facilities.

    Data  from Part A and Part B  applications are  also  part of HWDMS.   These

-------
                                      2-6

applications  apply  only  to  treatment,  storage  and  disposal  facilities,  and
thus,  do  not  provide  information  on   the   status  of  generators.   Another
disadvantage of the permit  information is  that it reflects what activities are
allowed to occur at sites,  and  often overstates or otherwise fails to describe
the  activities that  are  actually  occurring  at  those sites.   As  such,  the
information does  not  address the  distinctions necessary  to completely answer
the  policy  questions  raised  in Section B above.  Additionally,  when filling
out  a  Part  A  application, facilities sometimes  file  protectively by reporting
activities  that they  may initiate  in  the future rather  than  reporting what
actually  exists.    Although  inspections  have helped  to  distinguish between
expected and  actual activities, the  bulk of  the  Part  A applications have not
been verified with an inspection.

    The  1981  Mail  Survey probably does  the   best  job  of  reporting  regulatory
status,  since  a  series  of  detailed  questions  addressing  this  issue  were
included on  this  form.   However,  only  a  statistical  sample of generators and
facilities were surveyed.  Consequently,  such data  are available  for  only  a
subset  of  the  sites  and, as such can  not  fully  answer  the policy  questions
raised  in  Section B.   Additionally,  this survey  provides  information on 1981
activities, only.   Consequently,  while  useful from  a historical  prospective,
it cannot accurately answer questions on current  regulatory status.

     The Uniform Manifest  System provides  information on hazardous wastes which
are  transported  off-site  and   it  does  provide  a  way  to  determine  active
facilities  and generators, who are transporting  waste off-site  for treatment
and  disposal.   However,  when  a  site  does  not  transport  hazardous waste
off-site  or  receive  it,  the  manifest  system  does   not  provide  a  way  to
determine   why   a   site  is   or  has   become    inactive   (e.g.,   one   time
generator/handler;  stopped hazardous waste   activities;  all  hazardous wastes
were delisted).  Additionally,  there isn't a direct method of  distinguishing
inactive  sites from  generators  who  handle  their  hazardous  waste  totally
on-site, without  cross-checking with past  history and permit applications.

F.   DESCRIPTION OF  THE PROPOSED FORM

     The regulatory status  portion of the Biennial Report will  consist  of  two
forms.  The   first,  Form Selection  (FS),  uses   a  series  of  brief  "yes/no
questions  to  direct  respondents  to those  parts  of  the  Biennial Report  that
they must complete.   The second  section, Regulatory Status (RS),  is answered
by  only those  facilities which are  not subject  to quantity reporting,  and  it
serves to  determine   specifically why  a facility is  not providing  quantity
information.   This two-staged  approach  to regulatory status was used, because,
as  was explained in detail in  the background  paper presented at the April 30tn
meeting,  the  following  two  questions  are integral  to  describing  regulatory
status?  (1)  who must report,  and (2) what must be  reported.   Rather than use
the 1985 survey's approach of  allowing  respondents to develop and answer these
questions  for  themselves, a  more   structured approach  is  proposed which wants
the respondent through  a  series  of questions that  are  key  to  determining a
 site's  reporting  status and  what  must  be  reported  for that site.   ™is
approach  has   the   following   three   advantages   in  that   it  provides:

-------
                                      2-7

       (1)  more control over (a) who provides quantity and handling
            information, (b) what is reported, and (c) where this
            information is reported,

       (2)  a clear and straight forward mechanism for respondents to
            determine what they must fill out; and

       (3)  a mechanism for helping RCRA program managers assess if sites
            are properly complying with the reporting requirements.

The  Form Selection  (FS)  and  Regulatory  Status (RS)  forms  are  presented in
Appendix  A.    The   contents  of  each  section  are  discussed  in  separate
subsections below.

    1.  Form Selection

    As was  stated above, the Form  Selection  form makes it clear who must  file
quantity  information and directs the  respondent to  those  forms of the report
which  must  be  filled  out.  To  resolve the  issue  of who must  file,  the  Form
Selection  section  consists of  three  main  questions.   The  first  addresses
hazardous waste generation activities, the  second  addresses off-site shipment
of hazardous waste,  and the third section  addresses hazardous waste processing
(treatment,  storage,  recycling  and disposal).   Under  each  question  are  a
series of subquestions which serve to further  delineate  specific sections of
the  form the  respondent  is  required  to  complete.   Below,  the rationale  for
each question is  briefly discussed.

    1.   Question 1:   During  the  reporting year,  did  this  site  generate
hazardous  waste   in  sufficient  quantities  to be  subject  to  Full   RCRA
Regulation, and were at least some of  these quantities generated from  primary
sources?

    The  purpose  of  this  question  is  to  distinguish between  large quantity
generators   (LQGs)   and   all    other   generators   (e.g.,   small  quantity,
conditionally  exempt,   inactive,  etc.)  and  it  directs LQGs  to those sections
dealing with generation.

    2.   Question 1A:  During  the  reporting  year,  did  this  site generate
quantities  or  types of  hazardous wastes subject  to  reporting  only  by  this
state?

    This  question,  which  is  considered optional, should  be included by  those
states who want  quantity and handling information  for  generators who do not
meet  the  federal  requirements for a LQG.  A  "yes" answer to this question will
allow  an easy method for  distinguishing between EPA LQGs and  those  generators
providing generation   and  handling  information because  the   state  they are
located   in   has   more  stringent  requirements  than  those  of   the   Federal
government.

     3.   Question  IB:  Has  this  site filed  and nor  formally withdrawn an EPA
Notification   of  Hazardous  Activity  form  (EPA   Form  8700-12)   indicating
Generator or  Snail  Quantity Generator

-------
                                      2-8

    Sites which did not meet  the  reporting criteria outlined in Questions 1 or
1A,  fill out  regulatory  status  if  in  the  past  they have  notified  EPA of
hazardous waste  generation  activity.   A respondent  answering "yes"  to this
question  is  directed  to  the Regulatory Status  section  which  is  designed to
determine why  this  site  did not generate hazardous  waste during  the  report
year   even   though   its   owner/operator   has   notified  EPA   of  generation
activities.   The  information  will  help reconcile  biennial report  data with
other  data sources  as well as provide  Federal  and State RCRA program  managers
with  better  estimates  of  the number of  regulated generators  for  the  report
year.

    4.   Question  2:  During  the  reporting  year,  did  this  site ship regulated
hazardous wastes off  site?

    This  question  directs respondents,  who ship  hazardous  waste off-site, to
fill  out  forms  dealing with this activity.   Off-site  shipment is covered by  a
separate  set of  forms  and a  separate question in Form Selection, not  only to
obtain  information  on such shipments,  but to deal  with -the situation  where  a
site  neither generated  nor managed  hazardous  waste during the report year, but
did  ship hazardous  waste off-site.   This  information should  help reconcile
generated waste estimates,  from the biennial  report, with  manifested waste
estimates.

    5.   Question  3:  During  the  reporting   year, was  any   hazardous waste
processed at this site  (including processing  in exempt units)?

    This  question  directs those  sites,  which processed hazardous waste during
the  report year,  to  answer that  section (Waste Management  Process Summary) of
the  report  dealing with hazardous  waste processing.   Sites using only exempt
handling  methods  are  also  directed  to  this  section.    The  rationale   for
requiring reporting  by these  sites  is dealt with  in Chapter 3,  which discusses
waste quantity and process tracking.

    6.  Question 5A:  Did this site  receive hazardous waste from off site?

    This  question   directs   respondents  whose   sites  received   wastes  from
off-site  during  the  survey  year, to fill  out forms  dealing  specifically  with
this  activity.   The  rationale for  dealing with  this  topic on a  separate  form
is  discussed  in   Chapter 3,  which  addresses   waste  quantity  and   process
tracking.

    7.   Question 3B:  Does  a  hazardous  waste management  process (exempt  or
nonexempt) exist at this site?

    Only those sites that did not process  hazardous waste during  the report
year  (i.e.,  answered no  to  Question 2) will answer  the  questions;  it directs
respondents  whose  sites  contain  inactive hazardous waste  processes  to  the
Waste Management  Process Summary so  that the status  of  these processes can be
tracked.  The  reasons for collecting this  information and what the information
is  intended for  is  discussed  in  Chapter  3, which covers waste  quantity and
process tracking.

-------
                                      2-9

    8.  Question  3Bi:   Did this site file  an EPA Part A  -  Permit Application
at any time in the past that has not been formally withdrawn?

    This question's purpose is  to  have respondents,  who have filled out Part A
applications  in  the past  and  who did  not  process hazardous waste  during the
report  year,   fill  out  the Regulatory Status  form.   The  Regulatory  Status
section will  help:  (1)  determine why  the site  did not process  hazardous waste
during  the  survey year;  (2)  reconcile biennial  report data with information
from other  surveys; and (3) estimate  more  accurately the  number of active TSD
facilities.   As  was  discussed in  Section  B  of  this  chapter,  this  latter
estimate is important to  RCRA  program planning, implementation, and evaluation
activities.

    2.  Regulatory Status

    The purpose of  the  Regulatory  Status  forms  is to determine why a site  that
has  notified   EPA of  hazardous waste  activities (i.e.,  obtained an  EPA ID)
and/or  filed  a  Part  A  application,  has  either  not  generated  regulated
quantities  of hazardous  waste  or not  processed hazardous  waste  during the
survey  year.   To this  end, four  major reasons why  this  situation  might  have
occurred were  developed and are represented by  the four questions which appear
on the  form shown in Appendix  A.  After each question are several subquestions
which  further specify  why the  site  is  exempt from  quantity  reporting.  The
rationale for  each of the four major  questions  is  discussed below.

    1.  Question  1:  Was  this site  a generator of  hazardous  wastes that was
not,  during  any  single  month of the reporting year,  subject  to  full  RCRA
regulation due to RoA  small quantity rules and exemptions?

    This question and  its  associated questions  deal with quantity  exemptions
and  are   designed  to   distinguish  between  small  quantity  generators  and
conditionally  exempt  small quantity  generators.   This  is also  the  section
where  states  can  add  additional subquestions if  their quantity limitation for
conditional exempt  small  quantity generators and for  small quantity  generators
is  different   than  those  used  by  the  EPA.   The  information provided by  this
question  and   its subquestions  is necessary to  obtain  an accurate count  of
federally  regulated  facilities  and  to  place  generators  within  the  proper
grouping  relative  to   their  status  under  federal  and state  hazardous  waste
regulations.   As  the  1985 form  is currently constructed,  sites subject  to the
Federal  quantity exemption are sometimes  difficult  to distinguish  from  those
which  are not  subject to  these  exemptions.

    2.   Question 2:  During  the  reporting  year,  did  this site generate  or
process  wastes  that  are specifically excluded  or  exempted  from  regulation
under  RCRA?

    This  question addresses wastes  which  have either been  excluded from the
regulations  or have  been  delisted.   The  subquestions  distinguish  among:  (1J
wastes excluded  by 261.4,  (2) recyclable  wastes  excluded by  261.5a3;   and  3)
wastes delisted  under  260.20  and 260.22.    Additionally,  subquestions can  be
added   to  delineate  specific  excluded  or  delisted wastes.   Information  on
excluded  and  delisted  wastes  is  necessary  because such wastes,  in  many cases,

-------
                                     2-10

would   be   considered  hazardous,  although   they   have  been  exempted   from
regulation.   Consequently,   they still  are  of  concern,  and  this  series of
questions  allows  tracking of  these wastes  for a minimal  amount  of reporting
burden.  Thus,  if  a  future assessment  of these wastes is desired by  the Agency
or Congress, information will be available.

    3.   Question  3:   Did   this  site  generate  or  process  RCRA-regulated
hazardous  wastes  at  some  point prior  to  the beginning of  the reporting  year
and are such wastes not expected to be  generated  again in the  future?

    This  question  addresses  sites which  are  past generators/processors of
hazardous  waste,  but that have  stopped these  activities  and  do not intend to
begin  them again  in the  future.   The  four subquestions  under this question
deal  with  the  following  four  possibilities:   (a) the   generated/processed
hazardous waste was  a one  time event (e.g., spill clean up),   (b)  the site has
terminated  its  generation/processing  activities but   the  site  is  still in
business,  (c)  same as "b," but the site is no  longer in business,  and   (d) all
hazardous waste processes at the site are in closure  or post-closure.

    4.   Question  4:   Does   this  site   expect   to  generate   or   process
RCRA-regulated hazardous wastes  in  the  future?

    This question  in combination with  information from Question 3  was included
to help delineate  the following  two situations:

       •   Sites  which are  intermittent  or  periodic  generator/processors of
           hazardous  waste -- .It is important  to identify such sites because
           RCRA  program managers may  not  want to include  these  sites in all
           analyses,  since  their handling  levels fluctuate from year to  year
           causing over  estimates  for  some  years  and  under  estimates  in
           others.   Being  able to identify such  sites allows  greater accuracy
           of  such  estimates  and  allows  RCRA program  managers  to  know  more
           about  the activities of sites which are  not necessarily  subject  to
           regulation each year.

        •   Sites  which have not as  yet  generated/processed  hazardous  waste,
           but  intend to  in the future -- This information  is  important for
           projecting future hazardous  waste activities.

    In  addition,  this question is  designed  to distinguish  from  all  other
sites,  those sites  which  have notified and/or filed a  Part A, but  have  never
generated  nor processed hazardous  waste and  have no intension of doing  so in
the  future.   This  distinction  is necessary  to identify those  sites  which
should  not be  included in  the  count  of presently  regulated  sites  nor should
they be included  in  RCRA program planning projections for  the  future.

G.  SAMPLE OUTPUTS AND  USES  OF THE  DATA

    The types  of questions  the  Regulatory  Status section  of  the form are
designed to  answer were listed in  section  B.   Exemplary output are  included in
Exhibits 2-1  through 2-8.

-------
                          2-11
                        EXHIBIT 2-1
PORTION OF NOTIFIERS THAT GENERATED RCRA-REGULATED
     QUANTITIES OF HAZARDOUS WASTE IN 1981
               41,641 Nonregulated
                 Notifiers (75%)
                          14.Q&8
                           Generator*
                             55.739 Notifiers
                             Source:  HWDMS, 8-1-82

-------
                   2-12
                 EXHIBIT 2-2

Characteristics of Nonregulated Notifiers that
Responded to the Survey
      Description               Percent

Non-generators                    43%
Potential Future Generators       18%
Small Quantity Generators         18%
100% Recyclers                     4%
Recently Retired Generators        3%
Delisted Waste Generators          1%
Nonregulated Notifiers
  NSK, NEC*	      13%

Total                           .  100%
*NSK • not specified by kind
 NEC = not elsewhere classified

-------
 REPOR-


 ID NUMBER, NAME AND  LOCATION


 AK1210022I57
                                                MASTER HANDLER RF
                                                            -- ---- LEGAL ------
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                                           QENERATOR,
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                                           BURNER/BLENDER I OTHER
                                                                    GT
                                                                    BT
                                                                             KG
                                                                             KB
ELMENDORF AIR FORCE BASE,  AK  99506-0069   TRANSPORTER,    RCRA
                                           BURNER/BLENDER, RCRA
USUOT-UB KODIAK SUPPORT CTR                GENERATOR,       STATE   GT 1000 KB
ELMENFORF AFB                              TBD,             DOTH
ELMENDUR" AIR FORCE BASE. AK 995*6-9*75   TRANSPORTER,     RCRA    COMMERCIAL
                                           BURNER/BLENDER,  BOTH    -----------
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                                                                    °T IBBa KB
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                                                                                                                            »        I
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                                                                                                             PPRT ft RECEIPT,
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                                                                                                              NOTIF RECEIPT,
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-------
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                 	  LEGAL 	
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                                     PART A RECi 00-00-00
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	EXISTING ENVIRONMENTAL PtRMITS	
I TYPE   PERMIT NUMBER      DESCRIPTION (OPTIONAL!
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32,002
32,004
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SOURCE
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DATE
12/30/86
12/30/86
12/30/86
12/30/86
12/30/86

12/30/86


12/30/86




12/30/bfc
	 ISU HHNULINH MtTHUDS 	
UNIT REPORT 1
AMOUNT TYPE STATUS AMOUNT IJOM COUNT DATE 1
DESIGN CAPACITY SUBMITTED/NOT EXIST 200,000 Q 39 12/30/Sb
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-------
                                     2-19

H.  PROS AND CONS OF TOE PROPOSED SYSTEM

    The pros and cons of the proposed system are listed below.

    1.  Pros

        •  The respondent is provided with a detailed, clearly defined
           set of options regarding exempt reporting status.  This
           approach helps prevent respondents from incorrectly claiming
           exempt status because of misunderstanding the exemptions.

        •  The detailed selections help solve some of the major problems
           associated with the regulatory system including:

            — Reconciling information reported by other data sources
               (Notification, Part A, other HWDMS data)

            •- Explaining why certain generators/facilities report  in one
               year and not in others.

            -- Helping to identify nonreporters.

        •  The form selection section walks the respondent through  a
           potentially difficult set of criteria to help them more  easily
           and correctly determine which sections of the biennial report
           they must fill out.  By making them  provide answers to these
           criteria, RCRA program managers can  more readily assess
           compliance with reporting requirements.
    2.  Cons
           The regulatory status options are  lengthy,  causing  an additional
           reading burden for the respondent.  However,  the  regulatory status
           form has been structured through grouping the selections  so that
           the respondent only reads those regulatory  options  which  most
           likely apply to his site.

           A greater reporting burden  for generators and facilities, since
           small quantity generators and inactive  sites  with EPA ID  numbers
           would be required to fill out the  regulatory  status section.

           A greater processing burden for states,  but this  has been minimized
           because of  the structure of the form.

-------
                                   CHAPTER 3

                     WASTE QUANTITY AND PROCESS TRACKING

A.  INTRODUCTION AND OVERVIEW

    Waste  tracking  refers to  maintaining information on  the  generation (i.e.
the particular types of waste  generated,  the amount,  where they were generated
and  by  whom)  and   management  (i.e.   the  specific  treatment,  storage,  and
disposal method  used,  the quantity  handled by each  method,  and the location)
of wastes  regulated  as hazardous  under RCRA.  Information on where and  in what
quantities wastes are generated,  treated,  stored,  and disposed of is needed to
adequately define  hazardous waste  generation and  management  practices.  This
information   enables  regulatory   agencies  to  determine  the  personnel  and
resources  necessary to  deal  with current  practices.   It  is also  needed to
enforce  the  regulations and analyze their  effectiveness.  Waste tracking can
also be  used  to  help identify  areas that most need waste-minimization efforts,
determine  the capacity for treatment,  storage, and disposal of hazardous waste
in certain areas,  and to  identify  communities and environments which could be
exposed  to hazardous substances.   Waste tracking  information  forms the basis
of  hazardous  waste  regulatory  programs.    It  also  provides  data  to serve
congressional'and public oversight needs.

    Different methods  have  been used  by  State   governments  to  provide  the
information  needed  to  meet  the goals  described  above.   These  sources of
information  on  waste tracking have  included:  registration of hazardous waste
generators,  applications  for  permits  to  store,   treat or  dispose hazardous
waste,  hazardous waste manifests,  and periodic reports  on the generation  and
management of hazardous wastes.

    Registrations   and  permit   applications,  however,   describe  only   the
expectations  of  hazardous waste handlers,  and are not accurate descriptors  of
actual  operations.   Hazardous  waste manifests provide for  accurate  tracking of
individual shipments of   hazardous  waste  off-site,  but  do  not  track  wastes
managed  on-site.  Nbnifest information  also does  not always provide a  readily
followed trail  of   the  final   destination or  disposal  of the shipped  waste.
Despite  the  value of individual  shipment data, many state governments  are now
augmenting manifest information  with  periodic (monthly, quarterly,  annual,  or
Biennial)  reports from  generators and  treatment,  storage, and  disposal  (JSDJ
facilities.

    For  EPA, the  primary source  of information  for tracking wastes has  been
the  biennial reporting system.   This  system currently  uses  two questionnaires
-- one  for generators who send their waste off-site  for treatment, storage, or
disposal,  and  a  second  for  owners  and  operators  of  TSD  facilities.   Both
questionnaires   require   information  on  the  identity  and   location  of  the
generator  or the  TSD facility,  including  the  EPA identification  number,  the
facility  name,  mailing  address,  and  location,  and  the name and  telephone
number  of a  contact person.   The questionnaires  require  waste identification
by  RCRA waste  codes for  each reported waste or waste  mixture,  and the amount
of  each waste.   Generators must supply  the identity  of  the TSD  facility to
which  the  waste  was   shipped,   and   TSD  facilities   must  provide  the  same
information   on  each  generator  from  which  waste  was  received.   The  TSD

-------
                                      3-2

questionnaire  also  requires  a  description  of  the  final  methods  used   for
treatment, storage,  and  disposal.   A list of applicable  handling method codes
is provided for this purpose.

    While  the  existing annual/biennial  reporting system enables  one to track
the  origin and  destination  of most hazardous  wastes,  the  descriptions  of
handling  methods  are inadequate to  fully describe the  treatment and disposal
of wastes.  The  list of  handling  method codes  is  simplistic and duplicative:
there  is no  requirement  for  TSD  facilities  to  describe  the  application of
preliminary   and   intermediate   hazardous   waste   treatment   methods;    the
instructions for reporting  hazardous residuals  from treatment methods as newly
generated  hazardous wastes  are  unclear;  and  generators are not  required to
state their understanding of the basic  treatment  and disposal methods applied
to  wastes they  ship  off-site  --  with  the  result  being,  that  there  is no
reference  means  for  confirming  the   reports  of   applied  handling  methods
submitted by TSD facilities which receive the wastes.

B.  ADMINISTRATIVE REQUIREMENTS FOR THE  DATA

    RCRA  states  that if  waste is generated, it  should be "treated,  stored, or
disposed  of  so as  to  minimize the  present  and  future threat  to human health
and the  environment".   Waste  tracking  is required to  define these  management
practices  for  each waste.  Standards   applicable  to  generators  of  hazardous
waste (40 CFR  Part  262)  require  that a  generator who ships his hazardous waste
off-site  must  prepare  and  submit a single copy of the Biennial Report to  the
Regional  Administrator  by March 1  of each even-numbered year.  The  generator
Biennial  Report  must  include waste identification  by  the  RCRA  waste codes
(from 40  CFR Part  261, Subpart C or D), transporter  information and quantities
(with units  of  measure)  for  each  waste shipped  off-site  to  a TSD  facility.
Regulations  (40  CFR Part  264)  for  owners  and  operators  of  hazardous waste
treatment,  storage, and  disposal  facilities  also require  that  the owner or
operator must prepare a Biennial Report.

    The  Hazardous  and Solid  Waste  Amendments of 1984  (HSWA)  of RCRA require
current data,  as  soon  as feasible,  on  the availability of capacity at TSDs to
manage particular  types  of wastes  using particular  types  of technologies  and
process methods.  Although  this  data is being  compiled by EPA  through national
TSD  Facility  and  Generator  Surveys,   the  information   obtained   represents
selected,  one-time  samples.   It should be updated through regular periodic
reports from the full population of  waste handlers  in the following  years.

    EPA's  long list of hazardous waste  rulemaking responsibilities  as defined
by  specific  Congressional  mandates  include  such  important  subjects  as:   land
disposal  restrictions,  revisions  to tank permitting  standards, accumulation
tank  standards,  best  demonstrated  available   technology   (BDAT)   standards,
revisions   to   underground   injection   well   standards,  and  air  emission
regulations.   Prior to  rulemaking in these  and  other related  subject areas —
both now  and in  the future, EPA needs technical  information  upon which  to  base
regulatory options  and  associated  regulations.  To meet  these  responsibilities
EPA must regularly upgrade and update waste tracking  information.

-------
                                      3-3

    Legislation has  already mandated environmental  agencies  in several states
to conduct statewide hazardous waste management studies and develop commercial
treatment facility  plans.  Typically,  these  state  regulations  have  required
the  following  steps to  be taken:   (1)  complete a  comprehensive inventory of
the types and quantities  of wastes  currently generated; (2) forecast hazardous
waste generation  in  the  future;  (3)  conduct  a capacity assessment of existing
and  planned  treatment,  storage,  and disposal  facilities; and  (4)  determine
capacity  shortfalls.   The  states   have   used  manifest   data,   generator  and
facility  annual  reports,  permit  applications,  and  surveys to  complete these
studies.   Many  of  these  state  plans  have   to  be  updated  now,  and  the
annual/biennial reporting system can become  a primary  data  source  for  this
purpose.

C.  POLICY OPTIONS

    Four  alternative methods  for tracking hazardous  waste have been proposed.
These  alternatives   are:   (1)  maintain  the  current  annual/biennial  reporting
system,  relying   on  limited  waste  handling  information  for  each  waste;   (2)
request  more  detailed  tracking  information   from  both  generator  and  TSD
facility  for each waste, reported including  full  information  on the sequences
of handling  methods applied  by TSD  facilities, description  by generators of
basic treatment and disposal practices  to which wastes  shipped off-site were
subjected, and  identification of hazardous  residuals resulting from treatment
methods;  (3)  request  data similar  to  that  of  alternative  two,  except  that
waste  handling method  quality   information  would  be  reported  as  aggregate
totals for wastes handled by  specific treatment, storage,  or  disposal methods,
and  not  on  an individual,  wastestream-by-wastestream basis;  or  (4)  greatly
simplify  the  existing annual/biennial  reporting system  by requiring only  the
reporting  of  general  handling   methods  (e.g.,  wastewater   treatment,  and
disposal, etc.) applied  to individual waste streams.

    The  current   annual/biennial  reporting  system,  alternative one,  has not
been able to provide sufficient  data for waste  tracking  purposes,  and the  data
collected have not been reliable.

    Alternative two  would best meet the need  for  providing  comprehensive  and
reliable  waste  tracking   information,  and   is recommended   because   of   its
perceived ability to  satisfy additional  information needs.  This  alternative
could  also  solve  the  problems  of  unreliable  and  insufficient  information
inherent  in the current  Biennial Report system.

    The  aggregate  quantity  information  for  specific handling  methods  that
could  be  developed by  the  use  of  alternative  three  would  be  useful  for
preparing  assessments  of  utilized  and  available  waste  handling  capacity.
Chapter  5 of  this  report --  Capacity Assessment  —  describes how  Biennial
Reports can be used  for TSD capacity analyses.

    Alternative four could provide  reliable data, but  it  would not be detailed
enough for anything  but  the simplest analytical uses.

D.  DATA  AND INFORMATION REQUIREMENTS

    This  section  identifies the data elements  required in Biennial Reports for

-------
                                      3-4

adequate tracking of wastes.   A justification for  requiring  each data element
is also provided.  These data elements have been organized under the following
five data categories:

          Data Category A - Waste Quantification;
          Data Category B - Generator Identification;
          Data Category C - TSD Facility Identification;
          Data Category D - Waste Transport Description; and
          Data Category E - Waste Management Methods.

    In  simple terms,  these five  data categories  will  answer  the  following
questions:  "how much  of" and  "where"  the wastes  were generated; "where" and
"how" the wastes were  managed;  and "how"  the wastes were transported, if there
was  a   shipment  of   waste  off-site.   While   these   questions  are  fairly
straightforward and can be directly answered,  the practices of hazardous waste
generation  and  management  vary  so widely  that accurate  tracking  of  wastes
calls for careful selection and design  of data elements in the five categories
mentioned above.   The data  elements selected  for  waste quantity and process
tracking, along  with  waste  characterization  data  (Chapter  4),   must  be also
designed  for  use  in  TSD  facility  capacity assessment  (Chapter  5)  and   in
evaluation  of waste minimization  (Chapter  6)  efforts  made  by hazardous waste
generators.

    1.  Data  Category A - Waste Quantification

    This data category is fundamental to  the  tracking  of hazardous wastes and
is  the  information most sought   by  hazardous  waste  management facilities,
regulators,  planners   and the  concerned  public.   Six  data  elements  must  be
provided in this category:

          Waste  Identification
          Amount of Primary Generation
          Amount of Hazardous Waste Treatment Residuals
          Amount of Wastes Shipped Off-site
          Amount of Wastes Received from Off-site
          Density of the  Waste

    Each of the  data elements are  described  in  the  section  below.

    Waste  Identification — Each hazardous waste  generated, and subsequently
handled  at  a TSD iaciiity must be accurately, and thoroughly  identified  for a
complete tracking  of wastes.   The existing RCRA  waste  codes  identify hazardous
wastes  by  characteristic,  source and/or  hazardous  constituents.   Additional
descriptions  of  certain physical and chemical characteristics  or  hazardous
wastes  are  also  required.

    Amount  of Primary Generation  -- Hazardous waste generation  during  a  year
due  to  manufacturing  processes  and  other  industrial operations  should  be
reported  separate  from  hazardous  treatment process  residuals.   These  wastes
represent  a  basic  demand  for  hazardous  waste  management  capacity, which  is
expected  to  vary  directly with   changes  in  industrial  activities.   Primary
hazardous   waste   generation   data  is   the   principal  basis   for  planning

-------
                                      3-5

public  and   private  waste   minimization   efforts,   and   evaluating  their
effectiveness.

    Amount of Hazardous Waste Treatment Residuals  --  A substantial fraction of
hazardouswastegenerationTsrepresented   by  treatment  residuals  from
management  of other  hazardous  wastes.    These  wastes  include,  for   example,
incinerator ash,  aqueous  hazardous waste treatment sludge,  and residuals from
the closure  or cleanup of  hazardous  waste management  facilities.   Certain of
the waste  minimization options  applicable for  hazardous wastes  from primary
generation sources  (e.g.,  redesign of manufactured product,  etc.) have  little
or  no direct  application  for the reduction  of treatment  process residuals,
while other options  (e.g.,  process substitution,  etc.)  may  be of even greater
significance  for  TSD  facilities than for primary generators.   By separating
hazardous  waste  generation information  into the  two,  discrete  populations,
waste minimization priorities and  possibilities  can be better highlighted.  In
addition,  by  calling  attention   to  hazardous  residuals  from   treatment
processes, chances  are increased  that the full  complement  of hazardous waste
generation will be reported.

    Amount  of Wastes  Shipped Off-site  --  Hazardous wastes  shipped  off-site
represent a demand for commercial  TSD facilities.   This waste may  include both
primary generation and hazardous waste treatment residuals.

    Amount  of  Wastes  Received  from  Off-site  —  Individual   wastes from
particular  generators,should  equalthe  amount  of wastes  shipped  off-site,
except for  small  discrepancies  due  to shipments during  the end of either  the
current or  previous year.  This data element is  required for comparison with
the amount of wastes shipped off-site.

    Density  of Wastes -- The  amount of wastes  in the data  elements  mentioned
above  should  bereported  in  comparable  units   of  measure,  preferably   by
weight.   Many  wastes, however,  are liquids  or  sludges,  and  are  commonly
quantified  by volume.  Waste density data (i.e.,  weight permit of volume)  is
needed   to  allow   for   the  conversion   of  reported   waste  volumes  into
corresponding weight  data.  Only when this is done can comprehensive  hazardous
waste totals  be established.

    2.  Data  Category B - Generator Identification

    The following data elements  must  be provided for  generator identification:

          EPA Identification Number
          Name of Generator
          Street  Address  of Generator
          Contact Name, title, and telephone  number
          SIC Code

    Basic  generator identification  and  location data  (i.e.,EPA identification
number,  name  of  generator,  street   address  of  generator)  are needed  as:  (I)
reference  information  comparisons  with  reports  of  hazardous waste receipts
from  TSD facilities;  and  (2) connector links  with other RCRA hazardous waste
databases.   Contact  information  is  required so  that follow-up  inquiries  can

-------
                                      3-6

be  made  regarding  reported  data.    SIC  codes  are  significant  for  relating
hazardous  waste  generation  to  major  industrial   operations,  and,  thereby,
focusing attention on potential targets for waste minimization programs.

    3.  Data Category C - TSDR Facility Identification

    The   following   data   elements   should  be   provided   for  TSDR  facility
identification:

          EPA Identification Number
          Name of Facility
          Street Address of Facility
          Contact Details
          SIC Code

    These data  elements will satisfy  the same objectives  as  those stated  for
generators,  except  that  TSD  identification  and  location data is needed as
reference   information   for  comparisons  with   reports   of   wastes  sent  by
generators, and not with reports of wastes received.

    4.  Data Category D - Waste Transport Description

    The   following   data   elements   must  be   provided  for   waste  transport
description:

       •  Mode of Transport
       •  Number of Shipments
       •  Type of Container

    These data elements provide a framework for establishing the  potential  for
releases  of hazardous  substances to  the environment  during  the shipment of
waste  materials.  Together,  the three data elements describe  the basic  manner
in which hazardous wastes are shipped, and the frequency of shipment.

    5.  Data Category E - Waste Management Methods

    Waste quantity  tracking describes only the "influent" to TSDR  facilities.
Waste  management  (treatment  and  recycling)  often   results   in  substantial
changes  in  the  amount  and  characteristics  of  this waste.    For  example,
chemical  oxidation  of  an  aqueous  hazardous  waste  containing  cyanide  will
result  in  the  generation  of  a non-hazardous  aqueous   stream which  can be
discharged  as  treated effluent.  Therefore,  some tracking of waste management
methods  is  required  besides  waste   quantity  tracking.   The  following  data
elements are required for tracking wastes by treatment  processes:

       •  Sequence of Management Methods  On-Site
       •  Understanding of Management  Methods Off-site

    Sequence  of  Management Methods  On-Site   ~   The complete   sequence of
management  methods should  be reported by TSD facilities for each  waste  managed
on-site.   This  sequence  should  identify  the  specific  processes  used 'for
treating  or recycling  each hazardous waste.   Complete information describing

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                                      3-7

each  handling  method  applied  to  particular  wastes,  together  with  waste
quantity data,  is  an essential prerequisite  for  guiding investigations of  the
possibility for harm that might result  from  hazardous  waste management.  Such
information  is  also needed  for planning  the staffing  of  regulatory  agencies
and developing  RCRA implementation  strategies.   Further uses are assessing  the
utilization of  available  treatment  and  disposal  capacity,  and as a  compendium
of practical waste management methods.

    Understanding  of  Management  Methods  Off-site  —  Generators  cannot   be
expected  to know  the complete  sequences of  treatment, storage  and  disposal
methods  applied to  wastes  that they  ship off-site, but  they are responsible
for knowing  the basic nature of how  those wastes are managed  and should have
no  difficulty  in   reporting  that  knowledge.   Such information  can  then  be
compared with the sequences of processes described by receiving facilities.

E.  USEFULNESS OF CURRENT DATA

    Waste  quantity  and  process  tracking  in  the  current  biennial  reporting
system  has  several  major  deficiencies.   Most  of   these  deficiencies   are
illustrated  by  a case study  involving hazardous wastewater treatment  on-site.
Figure  3-1 shows  the hazardous  waste  management  methods  as  they  existed in
1983.   A'facility  Biennial  Report was  submitted as shown  in Table 3-1.   The
facility  Biennial  Report  requires  a  line  entry  for  each  hazardous waste
managed  by  a  particular  method.   As  shown  in  Figure  3-1,   the  facility
identified four management methods:

       •   Storage  in Tanks (S02)
       •  Ammonia Stripping  (Treatment in  Tanks)  —  T01
       •   Chemical  Precipitation (Treatment  in  Tanks) -- T01
       •   Disposal  in Surface  Impoundments -- S04

    The  facility  identified four  wastes  -- two  wastes  treated  by  chemical
precipitation and  one each managed by the other two methods  —  by recognizing
the  treatment and  disposal  methods  to be the  final disposition  of different
wastes.  As a result, the facility  reported  the following amounts of wastes:

       •   Treated  in Tanks —  6,100 Metric Tons
       •   Disposed  in Surface  Impoundments -- 400 Metric Tons

    The   reported   amount  of  waste   included   both  primary  generation  and
treatment  residuals  and a  clear  description  of  hazardous  waste  generation
on-site  was not obtained.  The facility also  incorrectly identified all wastes
to  be the residuals of treatment  --  wastewater  treatment  sludges (F006).   The
density  of the  wastes was not  provided.

    Another facility with the same management  methods  may have recognized  only
the  disposal in surface  impoundment  to be the  final disposition of all wastes
and   reported   only disposed  wastes.   In  this  case   the amount  of primary
generation would not have been reported.

    By 1985, the  same  facility segregated  some of  the feed  wastes,  increased

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                                  3-8

                                    FIGURE 3-1
                   HAZARDOUS  WASTEWATER  TREATMENT  ON-SITE

                          METAL - FINISHING INDUSTRY
                                YEAR  1983
                  F006
                      800 MT
               Ammonia
               Stripping
               (Other Method)
                          TOl
Miscellaneous
Rinsewater
(non-haza
                  800 MT
1.000.000 MT
                                    F006
                                                           4.500 MT
Chemical
Precipitation
(Sodium Hydroxide)
                                                TOl
                               Neutralization/
                               Precipitation
                                                    P006
       1,000,000 MT
            Filtrate
          .^-Discharged
            Under NPDES
            Permit
                sou
                   HOW A FACILITY  INTERPRETED OPERATIONS in 1983

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                             3-9
                      Table  3-1
                  SAMPLE  WASTE  TRACKING  DATA

                    Existing aiennial Report

          Hazardous Wastewater Treatment On-Site (Metal finishing
          Industry) - Year 1983;  See Figure
                         Waste II  Waste »2  Waste 13  Waste 34
Waste Quantification

Waste Identification

Amount of Waste

Density
F006

800 MT

N.A.
Generator Identification Yes
F006

800 MT

N.A.


Yes
F006      F006

4500 MT   400 MT
N.A.
                    Yes
          N.A.
          Yes
Facility Identification  On-site   On-site   On-Site   On-site


Transport Description '   On-Site   On-Site   On-Site   On-Site
Process Tracking
S02
T01
S04
T01
S04
S02
T01
S04
                                                       S04
  Sequence of processes can be found by referring to permit
  application.

-------
                                     3-10

the number of  management methods and replaced  disposal  in surface impoundment
with filtration  as  shown in Figure 3-2.   Biennial  Report information for this
case  is  given  in Table  3-2.   Once  again,  a  clear  distinction was  not made
between  primary generation  and  treatment  residuals.   A  fifth waste  was now
generated which  was  stored in containers  and  sent  off-site for land disposal.
This waste was mentioned in a generator  Biennial  Report with:  adequate waste
identification; no density information; and no transport identification.

    Another problem  of  existing  generator Biennial  Reports has been the double
counting of wastes  by transfer stations  who  only  store wastes temporarily and
do  not  treat  them,  and by  generators  storing wastes  for more  than 90 days.
This  problem  would  have  occured if  the  facility  Biennial Report  for 1985  in
this study had mentioned storage of Waste No. 5 on-site.

F.  DESCRIPTION OF THE PROPOSED FORMS

    The  proposed system for reporting  waste quantity and process  tracking  is
presented  in  this  section.   Each  reported  waste  is  to  be  described  as  an
individual  line  entry  on  a  Biennial  Report  questionnaire  form  especially
designed  for  that  purpose  (Form  WD,  Waste Description).   This  form,  to  be
completed  by  all  RCRA  regulated  generators  and  for  all  TSD  facilities,
requires a  brief narrative  description  of  each waste,  corresponding EPA  (or
State) hazardous waste numbers,  a 3-digit waste code that provides  additional
details  of physical  and chemical characteristic, a designation of whether  the
waste  is regulated under  Federal  or State  statute,  a  pH value, heating  value
(if any), and  solids/liquids concentrations.

   • Amount of  Waste -- Waste  quantities  will  be reported by  generators  on  two
questionnaire  forms, Primary Generation  (PG)  and  Waste Shipped Off-site  (SO).
The PG  form  is for,  both  generators  who manage their wastes  on-site  and  those
who  send  them  elsewhere.  For  TSD facilities  handling  wastes  from  other
generation  sources,  waste  quantities will  be  reported on  the form  for  Waste
Received From  Off-site (RO).  Space  is  provided on those forms  for  indicating
the units of measure (UOM) to  be associated  with reported  quantities.

    Density  --   For each waste  reported   in volumetric   quantities  (e.g.,
gallons, etc.),  the density (i.e., weight per unit volume)  is to  be reported,
as well.  Space  for  this  is provided  on  each applicable  form.

    Identification    --   There   will   be   a   separate   Identification   and
Certification  form  (ID)  to  be  completed  by  all  questionnaire  respondents,
covering,  both,   generators   and  TSD   facilities.   This  form  will  collect
identification,  location, and contact  data  comparable  to  that sought  in  the
existing Biennial Report system.  An important addition will  be the inclusion
of a  requirement to  report the 4-digit  SIC for the  reporting entity.

    Waste Transport  Description  — All modes of transport used during the year
for  each  waste  type  will  Be  reported.   A  list  of   alternative  modes  of
transport  (road,  rail,   etc.)  will  be provided  with  instructions  on  the
report.  The  number of shipments for each waste will also be reported, as will

-------
                                       3-11

                                    FIGURE  3-2
                   HAZARDOUS  WASTEWATER  TREATMENT  ON-SITE
                           METAL - FINISHING INDUSTRY
                                 YEAR 1985
                   P006
              (:£rnn^nia:; sp?!1
              \1:-:-:-:-:-:-:-:'-:--: J
liscellaneous
Mnse water
(non-haza
                      600 MT
               Ammonia
                          TOl
               Stripping
               (Other Method)
                 F006
         P006

          1.500,000 MT
    600 MT,
                         Neutralization/
                         Precipitation
                                                 10,000 MT
                            TOl
 Chemical
 Precipitation
(Sodium Hydroxide)
                    Filtration
  Filtrate
^Discharged
  Under NPDES
  Permit
                      F006
                           F006
                                     *:i:.::;:;:; 302s
                                     • s . a . ••».«."_.
                                                                       3000 MT
Other
Wastewater
Treatment
                                                                          TOl
                                                                      «11ii
                                                                           F005
                                                                           D008
                    HOW THE -FACILITY -INTEHPBETED OPERATIONS IN 1Q:85

-------
                          3-12


                          Table  3-2

                  SAMPLE  WASTE  TRACKING  DATA

                    Existing Biennial Report

          Hazardous Wastewater Treatment On-Site  (Metal finishing
          Industry) - Year 1985; See Figure


                        Wastel  Waste2  Waste3  Waste4  Waste 5

Waste Quantification

Waste Identification    F006    F006    FW6   F006     F006,D008

Amount of Waste         600 MT  600 MT  10.000MT 3000MT  250 MT

Density                 N.A.    N.A.    Ji.A.    N.A.    N.A.


Generator Identification Yes    Yes     Yes     Yes     Yes


Facility Identification  On-    On-     On-     On-     Yes
                         Site   Site    Site    Site

Transport Description    On-    On-     On-     On-     N.A.
                         Site   Site    Site    Site

Process Tracking     '    S02    T01     S02     T01     S01
                                        T01             D80
  Sequence of processes can be found by referring to permit
  application and the facility biennial report for waste shipped
  off-site (F006,D008).

-------
                                     3-13
all types  of  containers used  during  shipments.   A list  of  different types of
containers (drum, tank  truck,  etc.)  will be provided  with instructions on the
report.   Such waste  transport information  is  to  be  reported  on  the Wastes
Shipped Off-site  (SO)  form.   An  identification of all  transporters  used to
make shipments  is to  be  reported on  a separate Off-site  Identification  (01)
form.

    Sequence  of  Waste  Management  Methods On-Site --  Sequences  of handling
methods  for   treating,storing,  or disposing  of  hazardous waste  are  to be
reported  for  each line entry on forms  PG  and  RO (primary Generation and Waste
Received  from Off-site).   A  new  listing  of  handling  codes,  based  upon one
thoroughly tested in  a  recent  EPA  survey of TSD facilities, is supplied  in the
questionnaire  instructions  (Appendix  B).   Additional  handling  codes   that
should be appended to this  list of process codes in order to report  a complete
sequence of processes for each waste managed on-site include the following:

          Transfer of waste to another facility
          Transfer of recovered product
          Transfer of hazardous treatment residuals off-site
          Transfer of non-hazardous residues off-site
          Discharge of  treated wastewater
          Disposal of non-hazardous residues on-site

These  new codes are more descriptive  than the existing  Biennial Report  codes,
and  eliminate  the  problems  of  overlapping  descriptions  prevalent  in  the
existing  codes.

    Understanding  of  Management  Methods  Off-site  —  A generalized  list  of
handling  codes  is  provided  in th"einstructions  for use  in form SO  (Waste
shipped Off-site),  by generators who  send  their hazardous wastes  off-site for
treatment, storage, and/or disposal.

    For this  purpose, the  broad description of treatment, storage  and disposal
methods  used  in the  existing  Biennial  Reports  is  adequate.   However,  the
following broad categories  will  be used  to enable  comparison of  generators'
information  with  the  detailed  sequence   of  management methods  reported  by
facilities receiving  wastes  from off-site:

           Incineration/Thermal Treatment
          Reuse  as fuel
          Fuel  blending
          Recovery of solvents and organics for  reuse
          Recovery of metals
          Wastewater  treatment
          Other treatment/recovery processes
           Storage
          Landfill
          Land  treatment
          Disposal  in surface impoundment
          Underground injection
           Other disposal  processes

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                                    '3-14

G.  SAMPLE OUTPUTS AND USES OF THE DATA

    Two examples of waste  tracking with  the proposed Biennial Report are shown
in Figure 3-3  and  3-4.  In these examples,  the hazardous wastewater treatment
on-site  facility has  been considered  again.   Tables  3-3  and 3-4  shows  the
results of completing the proposed Biennial Reports.

    As  shown  in  Figure  3-3,   the   facility  would  have   identified  primary
generation on-site to consist of two hazardous waste streams:

       •  Ammonia Containing Wastewater (D002)
       •  Acid and Alkaline Wastewater containing metals
       •  D002,D003,F007,F008,F009

    The amount  of  primary hazardous waste  generation would  have been reported
to be 5300 metric  tons.   The  generation  of treatment residuals would have been
estimated to be 100  metric tons.  There  was no shipment of hazardous wastes
off-site  in  this case.   The  density would have indicated  that primary waste
generation was aqueous in  form.

    The generator  and facility  identification  would have been the same as  in
existing Biennial Reports.  Transport description would not  have been reported
because all wastes were managed on-site.

    The complete sequence of management  methods would have been reported  for
each  waste.    For   example,   the  process  tracking  for   ammonia   containing
wastewater would have been:

          Ammonia Stripping (other method)
          Chemical Precipitation  (sodium hydroxide)
          Holding for Equalization
          Neutralization of Supernatant
          Disposal of Bottoms to  Surface Impoundment
          Filtration
          Discharge of Treated Wastewater

    The   1985  operations  would  have  been reported  to   involve  a  primary
generation  of 13600  metric  tons; hazardous waste treatment  residuals of  250
metric  tons; and  shipment of all  residual  waste  for  disposal off-site.   The
changes  in  physical form  of  the waste would have  been indicated by  change  in
density  of  residuals.   Transport  description would  have   been  provided  for
residuals  shipped off-site.  A  detailed  description of  changes in  management
methods would  have been  also  indicated by  the new sequence of process codes.

    The   additional  waste  quantification,   waste  transport  description,  and
process  tracking will make  the  proposed  Biennial  Report capable  of producing
more  detailed  and consistent  information  on  hazardous waste generation  and
management practices.

-------
                                  3-15
                                    FIGURE    3-3
                   HAZARDOUS  WA3TEWATER TREATMENT  ON-SITE

                           METAL-FINISHING INDUSTRY

                                 YEAR  1983
                      D002
                      800  MT
                          29WT
               Ammonia
               Stripping
               (Other Method)
Miscellaneous   I.QQO.OOO MT
Rlnsewater
                   xwws
                                             F008, F009
                                           D002.D003.FOp7
                                                      %ni>::~*\
                                                    4500
                                          Chemical
                                          Precipitation
                                          (Sodium Hydroxide)
                                                         11WT
                               Neutral ization/
                               Precipitation
        1.000,000 MT
                      Filtrate
                   -^-Discharged
o
o
o
o
                              Under NPDES
                              Permit

                WASTE QUANTITY and PROCESS TRACKING

            ALTERNATIVE METHOD of INTERPRETING OPERATIONS

            Better Identification of waste by RCRA Waste Codes
            Use of process codes
            Sequence of management methods
            Complete coverage of ALL waste streams.

-------
                                  3-16
                                   FIGURE   3-4
                   HAZARDOUS WASTEWATER  TREATP1ENT ON-SITE
                          tlETAL - FINISHING  INDUSTRY
                                YEAR  1985
                   D002
                                           0002, D003,
                                         P007.F008.F009
                     600 MT
               Ammonia
               Stripping
               (Other Method)
                          39WT
                        10000 MT
                 Chemical
                 Precipitation
                (Sodium Hydroxide)
                              11WT
Miscellaneous  1.500.000 MT
Rinsewater                X	X"
 XWWL      	        	X	
Neutralization/
Precipitation

          60VT
                                               Filtration
                              Filtrate
                            .Discharged
                                                P006
                              Under NPDES
                              Permit
                                           OQ02
                                             3000MT
Other
Wastewater
Treatment
         60WT
                                                                        xwws

-------
                               3-17
Example
                  Table  3-3

        SAMPLE  WASTE  TRACKING  DATA

          Proposed Biennial Report

Hazardous Wastewater Treatment On-Site (Metal finishing
Industry) - Year 1983; See Figure 2-3
                         Waste »1  Waste »2  Waste 13
Waste Quantification

Waste Identification



Amount of Waste

Density
               0002



               800 MT

               8.4
0002,0003  XWWL
F007,F008
F009
8.4
 8.3
                                                          Waste
                                                F006
4500 MT    1000000 MT  10°
Generator Identification Yes
                         Yes
Process Tracking
               29WT
               11WT
               3D/60WT
               34WT
11WT
3D/60WT
34WT
          Yes
Facility Identification  On-Site   On-Site   On-Site
Transport Description    On-Site   On-Site   On-Site
60WT
34WT
             Yes


             On-Slte


             On-Slte


             3D
Note  : Waste fl and #2 represents "Primary Generation"

       Wast* #3 will  not  be reported, because the waste Is  only
       managed with other non-hazardous wastes. It would have been
       reported as shown, if managed with primary generation

       Waste *4 is treatment residual.

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                          TABLE 3-4     SAMPLE  WASTE  TRACKING   DATA



                                        Proposed  Biennial  Report




Hazardous Hastewater Treatment On-Site  (Metal finishing
Haste Quantification
Haste Identification
Amount of Haste
Density
Generator Identification
Facility Identification
Transport Description
Process Tracking
Haste 11

D002
600 MT
8.4
Yes
On-Site
On-Site
29HT
11HT
37HT
60HT
34HT
Haste 12 Haste 13 Haste 14 Haste 15 Haste 16

D002fD003 XHHL
F007fF008
F009
10000 MT 1500.000 MT
8.4 8.3
Yes Yes
On-Site On-Site
On-Site On-Site
11WT 60WT
37HT 34HT
60WT
34HT

D002 F006 XWWS
3000 MT 50 MT 200 MT w
i
8.4 12.0 12.5 »
Yes Yes Yes
On-Site Yes Yes
On-Site Yes Yes
66WT 1ST 1ST
60WT ID ID
34WT

-------
                                   CHAPTER 4

                            WASTE CHARACTERIZATION
A.  INTRODUCTION AND OVERVIEW

    Waste  characterization   refers   to  the   physical,   chemical  and  other
intrinsic properties  of wastes  regulated as  hazardous  under the  RCRA.   The
"other  intrinsic  properties" are  those which  determine  the hazards  posed by
the  wastes   to human  health  and the  environment  when  they  are  generated,
transported,  stored,  treated,  or finally disposed.   Knowledge of the specific
nature  of hazardous wastes  is  essential  for:  (1)  projecting  potential  harm
to  populations at  risk;  (2)   implementing  governmental  programs  to regulate
hazardous wastes;   (3)  planning  for  manufacturing  changes to  miminize waste
generation;   and (4)  selecting  alternative  methods  for managing wastes which
are generated.

    There   is  a   great  need   to   improve   the  current   hazardous  waste
characterization system.   Under the existing  approach,  waste characterization
depends   largely   on   identifying   the   hazardous  characteristics   and/or
constituents  in the waste.  A waste is  deemed hazardous  if it exhibits  one of
several   hazardous   characteristics    (i.e.,    ignitability,   corrosivity,
reactivity,   and/or  toxicity).   Some  hazardous  wastes,  which are  usually
generated from a specific production  process, are  specifically listed  due to
the  presence  of  certain  hazardous  constituents.    EPA  uses  a  4-character
numbering system  -  RCRA waste  codes   -  for  identifying  individual  hazardous
wastes  Ce.g.,  D001,  F008,  etc.).   The  RCRA waste -codes  do  provide waste
characterization,  but they  do  not provide  much  needed  information  concerning
the  physical state or  chemical character of  the  waste.   Furthermore,  they do
not  adequately identify the  type of  hazard  involved.   Unfortunately, waste
characterization data available from the existing Biennial Reports  are  limited
to  these RCRA waste codes  and a brief narrative description of  the wastes.

     The two  issues  which   need  to  be  resolved- concerning  better waste
characterization  data from  Biennial  Reports  are:  (1) what  are the  needs and
uses of waste characterization data in the biennial reporting  system,  and (2)
what data requirements need  to  be achieved  to meet the needs or uses?

     Waste characterization data are required  in periodic  reporting  systems for
three main  reasons:   (1)  wastes may be  generated and managed  on  a "one-time
basis;  (2)   patterns  of  hazardous waste types  change  with  time,  because  of
variations  in  demand  for manufactured  products,  manufacturing  processes, and
similar circumstances;  and  (3)  waste  characteristics  vary  within the  same
industry due to differences  in  the generators' waste management practices.

     By  obtaining   improved  waste  characterization  data  from  the  Biennial
Reports,  state governments  and EPA  can  also make  a  better  evaluation of:
current hazardous waste  generation  and management  practices;  and alternatives
to  these practices.

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                                      4-2

B.  ADMINISTRATIVE REQUIREMENTS FOR THE DATA

    Under RCRA, any  waste that are generated, have  to be "treated, stored, or
disposed of  so as to  minimize the present  and  future threat to  human health
and  the  environment."  Waste  characterization  data are required  to evaluate
these management  practices for  each  waste  generated.   Regulations applicable
to  handlers  of   hazardous  waste  (40  CFR  Parts  262  and  264) require   that
hazardous waste generators and TSD facility owners and  operators  prepare and
submit Biennial Reports  to the EPA Regional Administrators  by March 1 of  each
even-numbered year.  The  Biennial  Reports  are  to describe the wastes generated
and handled, and provide  information on their treatment and disposal.

    The  Hazardous and Solid Waste Amendments of  1984  (HSWA)  of  RCRA require
current  data  as  soon  as  feasible  on  the availability  of capacity  at TSDRs to
manage particular types  of wastes  using  particular types of technologies and
process  methods.   Although this data will be  compiled by EPA through national
TSD  Facility  and Generator  Surveys,  the  information obtained  from surveys
needs to be updated through Biennial Reports in  succeeding years.

    EPA's  rulemaking  responsibilities  for  hazardous  waste  management   under
RCRA and other statutory authority require  the  agency to develop  and maintain
detailed and consistent waste characterization data.

    Legislation has  already mandated environmental  agencies in several states
to conduct  statewide hazardous waste  management studies  and  develop  commercial
treatment facility plans.  Typically  these state regulations have  required the
following steps to be taken:  complete a  comprehensive  inventory  of the  types
and  quantities   of    wastes   currently  generated;  forecast hazardous   waste
generation  in  the  future;  conduct  a  capacity  assessment  of existing  and
planned  treatment,  storage,  and  disposal  facilities;  and  determine  capacity
shortfalls.  The  states have used  manifest data, generator and  facility annual
reports, permit applications,  and surveys to  complete these studies.  Many  of
these  state plans require  updating, and  the  biennial reporting system  can
function as a  primary  data  source  for this purpose.

C.  POLICY OPTIONS

    Because  of the differing  requirements,  a decision must be made as to the
needs and  uses of characterization data in the Biennial Reports, so  that the
proper  information can  be included.   Four  alternatives have been considered.
These waste characterization system alternatives are:  (1) maintain the present
4-digit  RCRA  waste  code  system and provide  a narrative  description of each
waste;   (2)  implement a  system  which  is  presently  used  by the  State  of
California  requiring  TSD facilities to  define physical properties, and list
all   hazardous  constituents  present   in  each  waste  with   their  specific
concentrations;   (3)  use the  comprehensive coding system  being  developed  by
EPA  that employs  coding  sequences to more systematically describe  each waste s
hazardous  characteristics,  physical  form,  and  constituent content;  or (4)
develop  a  system based  on the agency's generator and TSDR  facility  survey
questionnaires which  also  require  4-digit waste  codes,  but  employ  concise
waste  description codes  to describe the physical-chemical  form,  and  require
additional  physical-chemical characteristic  information.

-------
                                      4-3

    Alternative  one,   the   current  waste   characterization   system,  relies
exclusively on the  4-digit  waste code and narrative  description of wastes. It
is  inadequate  to meet  the  needs  and uses of  waste characterization  data as
indicated   previously.     The   second   alternative,    California's   waste
characterization  system,  has  an  advantage  over  the  other  alternatives  by
meeting  a  number 'of  information needs outlined  above.   However,  this system
will  involve  substantially   greater  reporting  and  information  processing
burdens.   The   comprehensive,  new   classification  of  wastes,   the  third
alternative, is not ready for implementation.

    The  system  selected  for  Biennial  Reports  should be  compatible  with the
characterization  systems  selected  for  other   complementary  data  sources.
Alternative four,  based  on EPA's  experience with  survey  questionnaires,  has
this  feature  and is  the  option that has been  selected for  the new  biennial
reporting system.

D.  DATA AND INFORMATION REQUIREMENTS

    This section identifies the  data  elements required in Biennial Reports for
adequate  waste  characterization.   A  justification  for  requiring  each  data
element  is  also  provided.  These data  elements  have been organized under  the
following three data categories:

       •  Data Category A - Waste Identification
       •  Data Category B - Physical-Chemical Form
       •  Data Category C - Physical-Chemical Characteristics

    Waste   identification  refers   to  identifying   hazardous   characteristics
and/or  constituents of wastes.   Physical-Chemical Form  provides a  definition
of  the  predominant constituents that give a particular  physical state  and/or
hazard  characteristic  to  the waste.  Physical-Chemical Characteristics provide
information on special properties of  the  waste.

    1. Data Category A -  Waste Identification

    The  RCRA waste   codes  provide  the  best  available  identification  of
hazardous  constituents and  characteristics.  The  TSD  facility and  generator
surveys  conducted by  EPA use this  data element  for identifying wastes.   For
consistency with waste identification  in other  data sources,  RCRA waste codes
should  be  continued  in  the proposed system for Biennial Reports.  As  in the
existing Biennial Reports,  all applicable waste  codes should be reported.

    The  deficiencies  of this  data  element  are expected to  be  compensated for
by  the  other data  categories.  For example, to  make up for the fact that the
constituents   are  not   known  for   ignitable   (D001)   wastes,  a   relevant
physical-chemical   characteristic  should also  be  reported  to better  define
ignitability.

    2.   Data  Category B - Physical-Chemical  Form

    This data category is  required  primarily to describe  the  treatability of

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                                      4-4

wastes  in  the absence  of detailed  analytical  data.  A  comprehensive list of
waste  description  codes  (A/B  Codes) has  been  developed by  EPA to supplement
the  description  provided by  RCRA  waste  codes.   These  codes describe  the
physical state of  the waste  and  identify their major or hazardous constituents
and are used  in  other  EPA surveys of generators and treatment facilities.  For
example,  "caustic  solution  with  metals  and   cyanides"  or " metal   scale,
fillings,  or  scrap",  etc.,  are   included  in  this  waste  code  system.
Different  description  codes  have   been  developed  for  listed  wastes  and
characteristic/mixed  wastes.  For  the   purpose  of  compatibility  with other
survey  information,  the  Biennial  Reports  should  use   the  same  codes.  The
information  to  be  reported  is  readily  available  to   generators  and  TSD
facilities.

    Complete, detailed  information on physical  properties will  not be provided
by  these  waste description  codes.   Neither do  these  codes provide a complete
chemical  profile  of  wastes.   The  A/B codes,  however,  greatly  expand   the
information  available from  the   4-character  EPA Hazardous Waste Numbers, and
imply  a  significant amount  of additional data  describing  chemical nature and
physical state.

    3.  Data Category C - Physical-Chemical Characteristics

    A  waste  characterization  system  based only on  a   comprehensive list  of
physical-chemical   characteristics  can  be  developed   for   hazardous   wastes
without  relying on  either  waste  identification  by RCRA waste  codes or waste
description  codes.   In  fact,  hazardous  waste  management facilities  require
substantial  analytical  data  prior to receiving wastes.  Table 4-1  shows a  list
of  the characteristic information required by two commercial  incinerators.   In
addition  to  this  information, these facilities  require  a  chemical profile  of
the  wastes.   Although  such  information  is  available at many  TSD  facilities,
there  are inconsistencies  in  the analytical  data  recorded,  or required,   by
different  facilities.   For  the   purpose  of  the biennial report,  therefore,
consistent  information  is  not   readily  available  on   the  full  panopoly  of
physical-chemical  characteristics.   Certain  characteristics  are  universally
known  and used,  however.  Five  of  these, in particular,  find  wide  usage  and
provide basic descriptive information.   These  five are:

       •  pH
       •  BTU
       •  Density
       •  Percent  Solids
       •  Percent  Water

     pH — This data  element  is  important because  a substantial  fraction  of
characteristic  wastes  show  corrosivity.   Waste description codes  (i.e.,  A/B
Codes) for these  wastes  can only  identify whether a given  waste  is corrosive
due to   the presence  of  acidic  or  caustic  materials.   The  property  of
corrosivity   is  better  described by a  pH number,  which also provides  very
important  analytical  data  for  carrying  out treatment  of  aqueous  wastes  by
physical-chemical-biological methods.   As shown in Table  4-1,  hazardous waste
incinerators also require this  characteristic.  For  incineration,  however, pH
is  required mainly to confirm the compatibility of  wastes with the material of

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                                4-5
                            TABLE 4-1
         Physical -Chemical Characteristics  Required
                 By Commercial  Incineration
Characteristics
Facility 1
Facility 2
* Solids
Total Oisolved Solids
Specific Gravity/Density
PH
Ash  (% WT.)
Heat Content  (BTU/lb.)
Flash Point
Sulpher (% WT.)
Halogens (% WT.)
Total Organic Halogens
Total Organic Carbon
Total Nitrogen
    X
    X
    X
    X
    X
    X
    X
    X

    X
    X
    X
     X
     X
     X
     X
     X
     X
     X

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                                      4-6

construction  of  process  equipment.   pH  is  also  required  as  a  "negative"
indicator for  other  waste management  technologies,  including energy recovery,
stabilization, solvent recovery, and metal recovery from liquid wastes.

    BTU1  —  This  data  element defines  the  heating value  of  wastes during
combustion  and  is  a  prime descriptor due to  the  large  occurence of ignitable
wastes.   Waste  description  codes  for  these  wastes  can  only  indicate   the
presence  of ignitable constituents (organic compounds)  in "low", "medium", or
"high"   concentration.    Although   ignitability   is   correctly  described  by
flashpoint  (temperature  at  which   waste  vapor  ignites  under  prescribed  test
conditions),  BTU was  selected  in  preference  because of  the use  of heating
value  data  at  facilities  carrying  out  energy  recovery  or  incineration.
Besides  being used for energy  balance of operations  at  these facilities,  BTU
is also  used  as an indicator of the  general incinerability of certain wastes.
With   the   impending   ban  on   land  disposal   of  certain  hazardous  wastes,
incineration  technologies are  being  seriously considered  as  an   alternative
method of management.

    Density --This  data element has  already  been selected for  waste  quantity
and process tracking  (Chapter  3).   Therefore  a  separate justification of  this
data  element  is not  required.   However,  it  should be pointed out that density
(for  both  liquid  and  solid   wastes) is  a  good  basis  for confirming  and
quantifying the physical state  of waste given  by waste description codes.

    Percent Solids and  Percent Water  —  In  the  total  absence  of  a  chemical
profile,  these  two  data elements will  be  very useful  for  quantifing  the
physical  form  given  by waste description  codes  for  several wastes.   For
example,  percent solids for a  sludge described  as  "lime sludge with  metals",
or percent  water for  an  "aqueous  waste with  low solvents".  These data  items
can be very  easily determined  and are used  for hazardous waste management at
different  facilities.    These   facilities   include:     energy    recovery,
incineration,   waste   stabilization,   solvent   recovery,   metal   recovery,   and
cheraical-physical-biological treatment of aqueous  wastes.

E.  USEFULNESS  OF CURRENT DATA

    Besides waste identification by  RCRA waste codes, a  narrative  description
of waste and the DOT  Hazard Codes  are the only other two data elements  in the
existing Biennial  Reports for providing waste characterization.  The  narrative
descriptions   obtained  have   not  been  useful   for  analyses because   the
information could not be  computerized.   The existing  biennial report  gives
specific instructions  only  for  a narrative  description  of unlisted  wastes.
There are no  instructions given for  describing mixed wastes.   As a result, the
characterization  data   available   in  narrative    description   has   been
inconsistent,  if not  totally inadequate.
     Ifiritish Thermal  Unit (BTU).   The amount  of heat  required to  raise the
 temperature of one  pound of water  one  degree Fahrenheit.  The  BTU value of a
 substance  indicates  the  magnitude  of  its  potential  to release  heat  when
 combusted.

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                                      4-7

    The 2-digit DOT hazard codes used in the existing .biennial report
provide a  limited  amount  of additional information  pertaining  to the physical
form  and/or  hazard  characteristic  of wastes.   This   information,  although
useful for addressing waste transportation  issues,  is not comprehensive enough
for RCRA waste management considerations.

    The  RCRA  waste  codes   are   suitable  for   identifying   the  hazardous
constituents  and/or characteristics  of the  wastes.   This  data  element must
therefore  be  retained in the  proposed  revision of  the  biennial report.  This
data  element   has  also  been  included  in  EPA's  generator  and  TSDR facility
surveys.

F.  DESCRIPTION OF THE PROPOSED FORMS

    The  proposed  waste  characterization  data  items  to be  included  in  the
biennial reporting system are described below :

    Waste  Identification  —  Each  waste  reported   is  to be  identified  as  a
separate line entry on  a   special  Waste Description  (WD)  form.  Reporting  of
waste  generation  quantities,   handling methods,  and  similar  information  on
other  forms  (e.g., RO, SO, PG,  etc.) pertaining to  specific  wastes are  to  be
linked to  the WD line entries  by "Waste Reference" page  and line numbers.  The
RCRA  waste codes  and  narrative  description  used   in  the  existing Biennial
Reports will  be  also used  for  identifying each hazardous waste  in the proposed
biennial report.   Instead  of  using  the narrative  description  for  additional
characterization  of wastes, as  in the  existing  reports,  the   instructions  on
the  proposed   Biennial Reports will  require use  of narrative  description  if
more  than  one waste  stream uses the same  combination  of RCRA waste codes  for
identification.   If non-hazardous wastes have  to  be identified,  the following
additional codes will be used  ;

     • NWWL -  Non-hazardous wastes  (Liquid)
     • NWWS -  Non-hazardous wastes  (Solid/Sludges)

    Waste  that is  considered hazardous by federal or state regulations  will be
identified by appropriate  4-digit codes.   If  a specific  code does not  exist
for  a  state  regulated  hazardous  waste,  a  narrative  description  must  be
provided.  All applicable  waste codes will be  used  for  identification,  without
a  limit on the  number of  codes.   A  complete list  of applicable  waste  codes
will be given with instructions  on the  report.

    Waste  Description  Codes   --   The   waste  description  codes  (A/B  Codes)
developed  specifically  for generator  surveys and  survey  of   land  treatment
facilities will be  also used  to  describe  the physical-chemical form  of each
waste  on the  Waste Description (WD) forms.   If more than one waste description
code  applied  to  a waste,  the waste will  be  assigned  to the  code  which best
describes  its physical-chemical  form.

     rfl --  Reporting  of  this  data  element  will  be  required  on the  Waste
Description  (WD) forms only for liquid wastes and waste sludges.   pH of both
hazardous  and  non-hazardous  wastes   of   the  right  physical   state  will   be
provided.  This  information is to  be provided only by TSD facilities.

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                                      4-8

    BTU  --  This  data  element  on the  Waste  Description  (WD)  form  will  be
required  to be reported  for  wastes  that  are either  identified by  the  RCRA
waste code  of D001  (ignitable waste) or  assigned to  waste description codes
indicating  the  presence of  organic constituents.  Thus "wastewater treatment
sludge with toxic organics"   will  be  required to report a heating value.   This
information is to be reported only by TSD facilities.

    Density  —  The  density,  in  terms  of  weight  per unit  volume,  will  be
reported  for  each waste  that  is  quantified  with volumetric  units.   Density
will  be on  the  Primary  Generation  (PG),  Wastes  Shipped Off-site  (SO),  and
Waste   Received   From  Off-site   (RO)   forms.   The   WD   form  asks   for  no
quantification data,  so that  density  query is not  appropriate.   Any  suitable
unit  of measure  may  be used  to give this  information.  A  set  of  conversion
factors  from  different units  of  measure to a  standard unit of measure (e.g.,
metric tons per cubic meter) will be given with instructions on the report.

    Percent Solids —  This data  element  will be provided for all  liquid wastes
and sludges.This" information is  to be  provided only by the TSD  facilities.

    Percent Water —  This  data element  will  be provided for all  wastes.   This
information is to be provided  only by the TSD  facilities.

G.  SAMPLE OUTPUTS AND USES OF THE DATA

    An  example  of waste characterization with the proposed biennial report is
shown  in Figure  4-1  which  is  reproduced  here for  easy  reference.    In  this
example,  a  wastewater  treatment on-site facility is  shown.   Table 4-2  shows
the results of completing the  proposed biennial report.

    The  improvement   in  characterization data is apparent  from  this  example.
The  physical-chemical  form  of  the  wastes   indicates that  all  the  primary
generation  wastes (Waste §1,2 and  3)  are   inorganic liquids.  However, the
fact  that one waste  stream (Waste *1) contains ammonia will  not  be revealed by
the proposed  data elements.   The presence of  cyanides  in  Waste * 3 is revealed
by  RCRA waste codes  (F007,  F008  and  F009)  and not  by waste description code
(B07).   The pH of  the three influent  wastes indicates  that  only  two wastes
meet  the criteria of  corrosivity (pH  2.0 or  pH  |12.5).  The proposed criteria
for  providing data  elements  do not  require BTU  to  be  determined for these
wastes.   All  primary  generation  wastes will  be  characterized  to be aqueous
(|99% water) with negligible  solids (  1%).

    Although  a  dramatic improvement  in  waste characterization is not  expected
from  the proposed Biennial Reports, the additional waste  characterization data
along  with  improved  process  tracking  will   help  to  assign most  wastes to
appropriate  treatability  categories  for  the purpose of  facility  capacity
assessment.

-------
                                    4-9
                                    FIGURE 4-1
                   HAZARDOUS  WASTEWATER TREATMENT ON-SITE
                           flETAl - FINISHING INDUSTRY
                                 YEAR  IQflS
                    D002
     D002
               Ammonia.:
                      600  MT
               Ammonia
               Stripping
               (Other Method)
ni seel 1aneous  1.500.000 MT
                                                 10.000 MT
 Chemical
 Precipitation
(Sodium Hydroxide)
              11WT
Rinsewater
  NWWL
                         Neutralization/
                         Precipitation

                         	60VT
      Filtration
              37WT
                              Filtrate
                                               P006
                              Under NPOES
                              Permit
 F007,FOOVP00<5
           N
                                                                VJ::':':
                              3000 MT
Other
Westewater
Treatment
         60WT
                               xwws
                     WASTE QUANTITY and PROCESS TRACKING
          ALTHWATTV* METHOD of IMTERPRBTIMO  OPERATIONS (1Q85)

-------
                                                          TABLE  4-2

                                            SAMMPLE  HASTE  CHARACTERIZATION DATA

                                                  Proposed Biennial Report
          Hazardous Nastewater Treatment On-Site  (Metal finishing
          Industry) - year 1985; See Figure
                         Waste il  Waste J2  Waste §4    waste J3
                                             WasteiS   Haste 16
Waste Identification

RCRA HASTE CODES



NARRATIVE DESCRIPTION


Physical-Chemical Form

HASTE DESCRIPTION CODE


Physical-ChemicaI
DI02
D002
 B03
B03
NWWL
                     Misc.
                     Rinsewater
B18
0002,0003  F006
F007,F008
F009
 B07
B22
                                                       xwws
                                                                 I
                                                                 K-
                                                                 o
                                                        B22
Characteristics
PH
BTO
Density
I Solids
% Hater

1.8
	
8.4
< 1%
> 99%

5
-
8
<
>

.6
—
.4
1%
99%

6.
—
8.
<
>

3
-
3
1%
99%

12
--
8
<
>

.7
-
.4
1%
99%

	
	
12.0
25%
75%

_ _
—
12.
28%
72%

_
-
5



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                                   CHAPTER 5

                              CAPACITY ASSESSMENT


A.  INTRODUCTION AND OVERVIEW

    Capacity  assessment  refers to  compiling and analyzing  information on the
capabilities  and usage  of  different  management  methods  at  hazardous waste
treatment,  storage,  and  disposal  (TSD) facilities to  evaluate the present and
future  availability  of  capacity   to  manage  particular  wastes  regulated as
hazardous  under RCRA.   Since  the  supply  of TSD  facilities  are  expected to
change over  time, capacity assessment must  take into  consideration,  both, the
management  methods  existing at facilities  and  planned changes.  Processes not
regulated  under RCRA but  involving the  management  of a  hazardous waste  (for
example,   discharge   of  treated   wastewater  under  NPDES  permits  from  TSD
facilities)   should   also   be  included   in  the   assessment.   Finally,  the
regulatory,  economic, and  other  operational  limitations of  using particular
management methods at particular facilities  should be considered.

    A good  understanding of the current  and future  capacity of TSD facilities
to  handle  hazardous wastes  is  required   for:  (1)  effectively  implementino
existing  regulations; (2)  revising rules  for managing  hazardous wastes;  (3)
planning  for,  siting and permitting new hazardous waste management facilities;
and  (4)  developing  workable  waste minimization  programs.    To meet  some of
these  goals,  several state  government  agencies   have   compiled information
from  different  sources  (manifest   forms,  permit applications,  annual  reports
and surveys)  to perform facility  capacity  assessments by broad categories of
wastes and  management methods.  However,  there is no single  existing  source of
information  containing   all  the data  required to make comprehensive  capacity
assessments.

    For  example, the planned  capabilities of TSD facilities are described  in
permit  applications.  However, the actual usage of management methods at TSD
facilities  may  vary  from the  planned usage.

    By   tracking   waste   quantities   and   waste   management  methods,   the
Annual/Biennial  Report can provide certain  information on the  current  usage  of
TSD  facilities.   This  information   will   be   enhanced   by  implementing  the
Annual/Biennial  Report  revisions  made  in  Chapter  3 -  Waste  Quantity  and
Process  Tracking.   However, in addition  to the process tracking  by particular
wastes  recommended   in  Chapter  3,  aggregate  capacity,  by  particular  waste
management   methods,  is  required.   This  questionnaire   section should  be
designed   to   update  and   upgrade   permit   information,   provide   capacity
information  not covered in  the waste  tracking  section of  the Annual/Biennial
Report questionnaire and seek information on future  plans for TSD facilities.

    There is no provision in the  existing Annual/Biennial  Report to  enable  a
capacity  assessment.  The Annual/Biennial  Report   revisions  proposed  in  this
chapter,  if implemented, will substantially increase  the  use and applicability
of  the  annual/biennial  reporting system.   However,   the additional  capacity

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                                      5-2
information provided by these revisions will not result in the creation
of  detailed  mass  and  energy  balances  for   each  process   in  use  at  TSDR
facilities.  To  fully evaluate  waste management methods,  therefore,  separate
TSDR facility surveys or inspections will be required.

B.  ADMINISTRATIVE REQUIREMENTS FOR THE DATA

    Development  of  regulations  under the  Resource  Conservation  and  Recovery
Act  (RCRA)  as amended  by  the Hazardous  and  Solid Waste Amendments  of 1984
(HSWA)  requires   current  data as  soon  as feasible  on  the  availability   of
capacity  at  TSD  facilities  to  manage  particular  types   of  wastes  using
particular types of  technologies  and  process  methods.   Although this data will
be compiled by EPA  through national TSD Facility and Generator Surveys to meet
the  schedule  of  restrictions  and  bans  called for  in HSWA,  the  information
obtained  from surveys   must   be  updated  through Annual/Biennial  Reports   in
future years.

    Among   EPA's   rulemaking   responsibilities   as    defined   by   specific
Congressional  mandates  are:   land  disposal  restrictions,  revisions  to tank
permitting standards,  accumulation  tank standards,  best demonstrated available
technology (BOAT)  standards,  revisions to underground injection well standards
and  air  emission  regulations.   Prior  to  rulemaking,   EPA  needs technical
information  upon which  to  base regulatory  options.    EPA must  also perform
technical  assessments   -   Regulatory Impact  Analysis  (RIA) and Regulatory
Flexibility Analysis (RFA)  -  to  determine the  need for future  ruleraaking.
EPA  must  also be prepared to develop  future  hazardous waste  regulations.   To
meet   these  responsibilities EPA  must  develop  and  maintain a  comprehensive
database   on   hazardous   waste  generation  and  management   practices,   waste
characteristics, and  the   capacity of TSDR facilities  to manage wastes.

     EPA and  the  states  must  also perform  technical  analyses  specified  by  the
new  Superfund  Amendments  and  Reauthorization  Act  (SARA)  of  1986.   SARA
requires  each state  to  assure  the  Federal government  that  adequate  capacity
will  exist for  disposal or  treatment of all hazardous wastes expected  to be
generated  in  the   state   within a   20-year   period   following   the   date  of
assurance.   This  applies  to  RCRA  wastes as  well  as  wastes  generated  by
response  or remedial actions at Superfund  sites.  Each state, in preparing its
capacity  assurance document,  and EPA, for evaluating the  assurance statement,
must be  prepared  to estimate  how   much  hazardous  waste treatment,  storage,
disposal,  and  recycling  capacity exists  within  the state's boundaries.

     TSD  facilities'  capacity  assessments are already mandated  by legislation
in  several states.   These laws typically request state environmental  agencies
to  develop statewide hazardous waste facilities plans.   The  plans involve an
analysis  of the number  and types of facilities  needed based  both on  a  survey
of  wastes produced and  the capacity  of existing facilities.   Both the current
and  future hazardous' waste generation and management are considered  in these
plans   to determine  the   needs  of   TSD   facilities.   In response  to  state
statutes,  several have already  developed facility plans.  Many  of these plans
require   periodic  updating,   and  the  annual/biennial  reporting  system   can
function  as  the  primary  data source for this purpose.

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                                      5-3

C.  POLICY OPTIONS

    There  is  no  direct provision  in  the  existing  annual/biennial  reporting
system   to obtain  capacity-related  information.   Two  new  alternatives  were
considered to address  the  issue  of  how the annual/biennial report system could
be  useful  in  developing  information  on  available  capacity  for  handling
hazardous  waste.   The first  alternative  was to  request  TSD  facilities  to
simply  update  information  provided in their  permits or  permit applications.
The  second alternative  was  to  obtain  information  on   both  "permitted"  and
"available" capacities for handling hazardous wastes  at the facilities.

    The  main  advantage   of   the   first   alternative  is  that  the  required
information could be  easily  compared with permit  applications.   While this
will simplify the response of TSD  facilities  to  capacity-related questions in
the Annual/Biennial  Report,  the  data obtained may  result  in  a less reliable
capacity  assessment.   First,  the  availability  of  underutilized  capacity for
commercialization would  not  be  known.  Next,  some  of the  permitted capacity
might be  used  for non-hazardous  wastes.   Finally,  the  throughput capacity of
treatment/disposal   methods   reported  in  permit  applications   does  not,
necessarily, mean that these methods  are operated  on a continuous basis.  The
additional information on  the availability of  capacity  that could be obtained
by implementing the  second alternative,  on the other hand, would enable a more
realistic capacity assessment.

    The Advisory  Council  recommended  that the Annual/Biennial Report be used
to obtain information on  both "permitted  and  available" handling capacities.
The availability  of  capacity  should  address  commercialization and handling of
non-hazardous  waste.   The current  usage  of   management  methods  and future
plans for changing handling capacity should be  also reported.

D.  DATA AND INFORMATION REQUIREMENTS

    This  section  identifies  the  data elements   required  in  Annual/Biennial
Reports  for  obtaining  capacity-related   information.    A   justification   for
requiring  each  data element  is  also  provided.   These  data elements have  been
organized under the following five  data categories:

          Data Category A  - Available  Capacity
          Data.Category B  - Status  of  Management Methods
          Data Category C  - Current Use of  Capacity
          Data Category D  - Residual Generation and Management
          Data Category E  - Plans to  Change Available Capacity

    1.  Data Category  A -  Available Capacity

    Available  capacity refers to  the maximum  quantity of  waste that can  be
managed by each  method  available at  a facility under  the existing regulatory,
economic  and  physical  limitations.   Available  capacity,  rather than the design
capacity  of the  management  method as originally  installed,  is required  for
sound  capacity  assessments.   In  order to  link capacity assessment  with waste
tracking   information   (Chapter  3),   the  management methods  and  descriptive
reporting  codes  for  this  data  element  should be the  same  as for  the  waste

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                                      5-4

quantity and processing tracking provisions in Chapter 3.

    The following data elements must be provided in this category:

       •  Throughput Capacity
       •  Annual Capacity
       •  Ranking of Factors Influencing Annual Capacity
       •  Percent of Annual Capacity for Commercial Use

    Throughput Capacity  --  This data element  represents  the  maximum amount of
waste that  can  be managed by a  particular method in a  "given"  period of time
(e.g., gallons  per hour).  For  most waste handling methods,  this is the form
in which permitted capacity  is  known to hazardous waste handlers although this
does not apply to permitted landfill capacities.

    Throughput  capacity  is  an  essential  data  element,  but,  alone,  is   not
sufficient  for  capacity  assessments.    For  economic   and   other  reasons,  a
facility  is  not  likely  to operate  at  its short-term  throughput capacity  for
extended periods  of  time.  The  number  of shifts  operated per day, the number
of days  per year that  operations  are conducted,  and  maintenance downtime  all
combine to determine long-term capacity availability.

    Annual  Capacity  -- Annual  capacity refers  to the quantity of waste that
can be  managed  during a  year;  it can  be expected to  be less  than  throughput
capacity  due  to  the  factors mentioned  above.  This data element is required
for comparisons with actual  use of capacity (see below)  to estimate  the excess
capacity of each management method at a facility.

    Ranking of Factors  Influencing Annual Capacity -- More than one  factor  may
be  responsible  for the  fact that the  annual capacity  of a  management method
cannot  be directly calculated  from throughput  capacity.  Although  it  is  not
necessary for  the purpose  of  capacity assessment to find  out  how much annual
capacity  is  affected  by each factor,  it  will be very useful to know  how  these
factors  compare  with each  other.   For example,  the  full design capacity of  a
particular  management  method may be limited  by the operating permit.   If  this
fact  can  be recognized during capacity  assessment,  additional  capacity may be
made  available simply by modifying the permit.

    Percent  of Annual  Capacity  for Commercial  Use  -- While  evaluating  the
treatment capacity of TSD  facilities,  it  is  necessary to determine  this  data
element   for  each  management  method.   This   is  because   excess   treatment
capacity,  particularly  for  TSD facilities operated on-site by  manufacturing
firms, may not be available to  other parties.

    2.  Data Category B  -   Status  of Management Methods

    Waste  management methods  available  at the  same  facility  may   differ in
commercial,  regulatory  or operational  status.   For example,  a  facility  may
receive  wastes from  all generators  off-site for  physical-chemical-biological
treatment  but  only  from  certain  generators  for  other  processes.   Another
facility  may  have  closed  particular  operations,  temporarily.   Without an
understanding of  these limitations, capacity  information may be misinterpreted

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                                      5-5

to  make  incorrect  estimates   of   available  capacity.    The  following  data
elements must be provided in this category:

       •  Commercial Status
       •  Regulatory Status
       •  Operational Status

    Commercial Status  — Many facilities  receive wastes  from generators owned
by  the  same  company.   Other  facilities  are  strictly  non-commercial.   This
status must be reported  for each management method.

    Regulatory  Status —  Hazardous  wastes  are  sometimes managed  by methods
that are not  regulated under RCRA.   For example,  facilities that are  treating
aqueous  wastes and  discharging  treated  effluent under a NPDES permit are given
"permit  by rule",  and  management methods  at  this  facility  are  not  regulated
under  RCRA authority.   Hazardous  waste   fuel  burned  for energy  recovery  in
industrial  furnaces  and boilers  are  regulated  separately  under  RCRA..    The
regulatory  status  of each  management  method  at   such  facilities  should  be
identified,  because  capacity  assessment  must  consider  both  regulated   and
exempt hazardous waste management methods.

    Operational Status  -- Since capacity assessment evaluates  the  availability
of  capacity  at  present and   in  the  future,  both  closed  (but  also  to  be
reactivated) or active management methods  at facilities must  be identified.

    3.   Data Category C  - Current Use of Capacity

    The   difference  between  annual  capacity   and  current  use  of  capacity
represents   the  excess  capacity  available  at   facilities.    However,   both
hazardous and  non-hazardous wastes are managed at many  facilities  and affects
the  actual excess  capacity available.   The available capacity  for  commercial
use   minus  capacity  actually  used,  on  the  other   hand,  represents   the
underutilized  capacity  available  for  commercialization.   The  following  data
elements should be included in  this category:

        •  Quantity Managed  Last Year
        •  Percent Hazardous Waste
        •  Percent Commercial  Use

     Quantity Managed  Last  Year  — This  data  element is required  to make an
estimate  of  excess  capacity  available  for   each  management  method at  the
facility.  It should be pointed out that this  quantity  may  not  be the same as
the   amount of waste   either  generated  or   received  from  off-site at  the
facility during the same year.

     Percent Commercial  Use  --  This  data  element  is  required  to make an
estimate  of  the   excess  capacity  available  at  each  management  method   for
commercial waste management.   This data  element represents  the  percent of  the
quantity managed  last  year  that  was received  from off-site  in the  past  Uot
necessarily last year).

     Percent Hazardous Waste —  This  data  element represents the percent of the

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                                      5-6

quantity  of  waste  managed  in the  reporting year  that  was hazardous.   It  is
reasonable to  project,  on the basis of  data for the reporting year, a similar
breakdown  of  available  excess  capacity between  hazardous and  non-hazardous
wastes for the immediate future.

    4. Data Category D - Residual Generation and Management

    Hazardous  waste  management   methods that  generate  residuals  produce  a
demand for treatment,  storage,  and disposal  capacity.   In  order to understand
the magnitude  and  type  of  this  demand,  residuals will have  to  be separately
tracked  as  a  part of  capacity  assessment.   In  the  absence  of  this  data
category, no accurate  estimates  can be  made of  the percent of waste generated
as residuals from different  hazardous  waste management methods.  The following
data elements must be provided in this category:

       •  Quantity of Residuals Generated Last Year
       •  Percent Hazardous Waste
       •  Sequence of Management Methods

    Quantity  of  Residuals  Generated  Last  Year  --  The   total   quantity  of
residuals (.including both hazardous and non-hazardous wastes) generated  during
a year must  be known and compared  with the quantity of waste actually managed
by  the  same  method  for a   complete  residual  analysis.   Management  methods
involving continuous processes  for physical-cheraical-biological processes,  for
example,  usually  discharge  the  total  quantity  of  "influent"  wastes   as
residuals.   However,  for  a particular year,  there  may  be  a  build-up  of
treatment  sludges  in  one  of   the  processes  resulting  in   a   quantity  of
"effluent" residuals  smaller than  the  "influent" wastes.   The  next year,  the
quantity  of  "effluent"  residuals  may  be  higher  than   "influent"  wastes.
Incinerators,  on  the other  hand, usually  generate only a  part of "influent"
waste as residuals.

    Percent Hazardous Waste  --  This data element represents the percent  of the
quantity  of  residual  waste  generated  last  year  that  was hazardous.   It  is
required  in  order  to   track  the  ultimate generation  of   hazardous   waste
residuals from treatment, storage, and  disposal  facilities.

    Sequence of  Management Methods --  The processes by which each hazardous
waste residual generated  by  a process are managed at a  treatment,  storage,  and
disposal  facility  are defined  by  this  data  element.   This  information  is
required  in  order to complete the  tracking of hazardous waste residuals which
are  generated  at  treatment,  storage,  and disposal  facilities.   Management
methods  for  residual  management will  be  the same as  the  processes uses  for
tracking primary  generation.

    5.  Data Category £ - Plans to  Change Capacity

    Regulatory,   economic    and   operational   considerations   may   motivate
facilities to  change  their  capacities and/or capabilities.  If reported  in the
format used  to report  current availability  of capacity  - namely,  by management
methods  - this  data  category  will  be  invaluable in  updating  and  upgrading
capacity  assessment  to  forecast  future  trends in  capacities available  for

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                                      5-7

hazardous waste  management.   The following  data elements must  be  provided  in
this category:

       •  Change in Available Capacity
       •  Change in Percent of Available Capacity for Commercial Use
       •  Year for Changing Capacity
       •  Reason for Changing Capacity

    Change  in Available Capacity —  This data  element  is  required to make  an
estimate  oftHeavailablecapacity  in  future.    If  the   demand   for   each
management  method  can  be  forecast,  an  estimate  of  the   available  excess
capacity can  also be made.

    Change  in Percent  of Available Capacity  for Commercial Use — Any  future
business  plan for changing  the commercial availability of management methods
should be disclosed in  this data element.

    Year  for  Changing Capacity  --  This data  element will  be used to forecast
the   expectedfutureavailability   of  treatment,   storage,  and   disposal
capacities.

    Reason  for Changing Capacity -- This data element  is required  to establish
the  existenceof  patternsan3  trends  in  the  availability  of  treatment,
storage,  and  disposal capacity.

E.  USEFULNESS OF CURRENT DATA

    There  is  no provision  for  a complete  capacity assessment  in  the existing
Annual/Biennial  Reports  or  permit  applications.   The  capacity  information
available   in permit  applications  provides  only  design  capacity  of  broad
categories  of processes  regulated  under  RCRA.   The commercial status of the
processes  is  not clearly identified by permit information.   The current  use of
capacity   is   tracked   only   by   final   management   methods  in   existing
Annual/Biennial  Reports.  Even  at  facilities with only  one  management method,
use  of capacity cannot always  be  compared with design  capacity due  to the use
of  different  units  of  measure.   Residual  generation  and  management are not
specifically   tracked   by  current  data.   Future  plans  for  changing  design
capacity  are  known  only  through  revised  permit  applications.  The provision
for  capacity  assessment in  the biennial  reports  will  provide,  therefore, a
substantial  improvement of  current  data.

F.  DESCRIPTION  OF THE PROPOSED FORMS

    The  proposed data  items to  be  included  in the biennial  reporting system
for capacity  assessment are described below:

    Available Capacity — Both throughput and annual  capacity will be reported
on  the Process  Summary (PS) form  for each management  method at the facility.
Design capacity will  be the basis  for  reporting  throughput,  with  applicable
regulatory,   economic,   and   operational   limits   used   to  estimate  annual
treatment,  storage,  and disposal capacities.

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                                      5-8

    The  percent  of  annual  capacity  for commercial  use  will  be  estimated  by
considering the current business plans of the facility.

    Although  data   elements   in   this   category  will  be  largely  based   on
assumptions  made  by facilities,   the information  obtained will  describe  the
existing situation better than any other existing data sources.

    Status of Management  Method -- The  commercial, regulatory and operational
status will  be  reported on  the Process Summary  (PS)  form for each  management
method.  Simple characteristic  codes  will  be used.   The commercial status will
be selected from the following categories  :

       •  Commercial
       •  Limited Number of Other Firms
       •  Limited Number of Firms Owned  by the Same Company
       •  Non-commercial

The   regulatory   status   will   determine  whether  the  management   method   is
regulated under RCRA or exempt.   The  operational status will determine  whether
the management method  is active, closed  or temporarily closed.

    Use  of Capacity -•  The  amount  of  hazardous  waste  managed  last  year  by
each   method will  be  reported  in the  same unit  of measure  used  for  annual
capacity.   The  facility  will  also  report  the percent   of  this  amount  for
commercial   use.    The   breakdown  of   current  use   between  hazardous   and
non-hazardous wastes will be reported, as well.

    Residual  Generation  and Management  —  Each management method  resulting in
the  generation  of  residuals  will be identified on the PS form and residuals
will  be  determined  to be  hazardous  or  non-hazardous  effluents.  The  quantity
and  sequence of  management  methods  for each residual will  be also reported.
Management methods  for residual  management  will be  the  same as  the processes
used  for tracking  wastes.

    Plans  to Change Capacity  --  Each change of annual  capacity  in  the future
is  reported- by  providing  tne  expected new annual  capacity.   The year  for
expected changes  during the  next five years  is  to  be  reported.   The reason for
each  change  is  to be  reported  as a code corresponding to  one  of  the following
categories:

          Change  in  Production
          Change  in  Production Methods
          Change  in  Waste Management  Methods
          Change  in  Regulatory  Status of Waste  Management  Method
          Change  in  Commercial  Status of Waste  Management  Method
          Other Reasons

Any  change  in percent  annual capacity for commercial  use  will  also be reported
by providing  the  new percentage.

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                                      5-9

G  SAMPLE oirmrrs AND USES OF DATA

    An  example  of capacity  assessment with  the  proposed biennial  report are
shown in  Figures  5-1 and  5-2.   In this example, the  available capacity of an
on-site hazardous wastewater  treatment facility  is  shown  for the  year  1983
(Figure 5-1).   The planned modifications of  this facility are shown in Figure
5-2 for the year  1985.   The  results of completing the proposed biennial report
for 1983 for capacity assessment by management methods are shown in Table 5-1.

    Both throughput  capacity and annual capacity are given for each management
method  at  this  facility.   The  ranking  of  factors  for  influencing  annual
capacity shows  that  "physical  limitations" prevent  the  facility from having a
higher capacity.  These limitations are coded in Table 5-1 as follows  :

       •  Operational schedule (3a)
       •  Planned downtime (3b)
       •  Other physical limitation,  such as  physical  limitation on
          another management method (3c)

The facility  is entirely non-commercial."  Three out of the existing management
methods are regulated  under RCRA.   These are either the  treatment or disposal
of  hazardous  wastes.  All management methods are  active.  The current use  of
the  capacity  for  each management  method is  given.  Four  management  methods
receive hazardous wastes - 100 percent of "influent"  waste as  hazardous in all
four  cases.   Only three out  of these four methods  generate hazardous  waste
residuals;  the   fourth  method   is  a  disposal  process.   The  sequence  of
subsequent  management  methods  for these  three hazardous waste residuals  are
also  given.

    Plans  for changing capacity by 1985 includes  :  increase in capacity  of  a
hazardous waste treatment  process; closure of disposal method;  and  replacement
of  disposal by  filtration.   The changes in capacity  expected  by 1985  for these
three methods are also  given.   The reasons  for changes  are given as  :  change
in  production or  change  in management method.

    This  example  illustrates  how  the  additional  data  elements  proposed  for
biennial  reports  will  enable  For  the  first  time  periodic updates  of  capacity
information   to   track   the  availability of  excess  capacity  by   individual
treatment, storage,  and  disposal methods.

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                                   FIGURi  s-i
                     HAZARDOUS  WASTEWATER  TREATI1ENT ON-SiTE
                            METAL - FINISHING INDUSTRY
                                   YEAR  1983
               \j:' '•:'•:'•:•:'•:'•:'• '•   '-^>
Miscellaneous
Rinsewatsr
                Ammonia
                Stripping
                (Other Method)
                         **iooo
                                    800 MT
          •2000   .

         Filtration - U-°00.^°
                            MT
                                       *2000

                              Neutralization/
                              Precipitation

                                    «*2xl06
            01 Hazardous
                Waste
                                           300MT
           Filter
          I Cake
          
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                                         5-11
                                     FIGURE   5-2
                    HAZARDOUS  WASTEWATER TREATMENT ON-SITE
                           METAL - FINISHING  INDUSTRY
                                  YEAR  1985
liscellaneous
5inseweter
                                                                 ('••.'••.••.••.[•.'••.'••.'••.•:'-:-\
                                         V:-:-
               Ammonia   *4
               Stripping
               (Other Method)
                        ••1000
    600MT
 _u   .   ,      *20
 Chemical
 Precipitation
(Sodium Hydroxide)
          **15,000
                         Neutralization/
                         Precipitation

                         	  **2xlO
         *20
Other
Wostewater
Treatment
      **5000
              .012 Hazardous
                    Waste
                        .5% Hazardous
                              Waste
                  MT
  Filtrate
-^Discharged
                              Under NPDES
                              Permit
                   ADDITIONAL INTERPRETATIONS of OPERATIONS
                           For CAPACITY ASSESSMENT

            FEATURES
          o    Available  Capacity  for  each Management  Method
          o    Residual Generation plus  % hazard  waste in  residual

                   *    Throughput Capacity (MT) in 8 Hrs.
                   *«   Annual Capacity (MT)

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                                                      Table    :>-!
                                              SAHPLt  CAPACITY ASSESSMENT DATA
                                                  Proposed  Biennial  Report
        :  Haiardoua Naatawatar Traalnant On-Slta IHatal  llnlahlng
          Induetiy) - tear Hllj  »•« rlgtua >•-!
             METHODB I   l»Mt      IIMT       MHT        ID         MHT       14HT     17WT
*v«H«bU Capacity
Throu,hp«t Capacity         4        !•        "-»•           »       lfii
IHatcIc Tona pat Shift)

Annual Capacity          !•••      7»M        -.».         "•    »•"••    ""•»
(Natflc Toaa par laar)
l.nklo, ar Pactaia         Jb        la        M.».          lc         lc         Jc    —
(Only blghaat Bank I
Peccant at Capacity         •         •          •           B          -          •    ---
fai CaaaMiclal Uaa
atatua el Hanagaaant HathoJa
CaaaMcelal ftatoa           ....................... "•» Ca—a,clal ..................
•agalatacy Itataa           »         »           •           *          B          B   —
oparatlonal  Stakaa          »         »           A           A          A          »                                                          u,
                                                                                                                                               H-
Currant  Uaa  ol Capacity                                                                                                                       N>
Ouaat.t, H..^a« I. MM  •••       *)••         SJM          «•      !••••••     INMM  —
 litatcle To«a)
 % H...r4ou. llaata         IN       IN         >••          IM
          Oa«.ratlon and Maaagaa^nt
          of ...ldu.1      •••      SIN        »»•         >••      »•"•••   1MM"  —
 In !»•! INT)
 • N.i.rdoua N.ata         IN       IN  ,7.5           •            •         •  —
                           IIMT      ««ff         JO         ---        -"      ......
 •aquanc. of Ha».,— ot    ««      1D/NW
 Nathada                   JB/iMT   J«»rT

 Plant to Chanoa Capacity
 Chang.  In  Ikvallabla       —       !«••        —            •       ......    ""•
 Capacity  IMaw
 Capacity  In HT)
                                     I,.S
  •aaaon  lor Char^a                     >

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                                   CHAPTER 6

                              WASTE MINIMIZATION

A.  INTRODUCTION AND OVERVIEW

    EPA is  in the process  of defining a  strategy  for  waste minimization.  In
designing such a  strategy,  it is  particularly important to distinguish between
short-term  and  long-term  objectives.   It is  clear that  in  the  short-term,
waste  minimization   efforts   must  concentrate   on   data   development  and
information transfer.

    Information  that  discusses  waste  reductions   technologies,   as well  as
statistics  on  the  basic  economic  benefits  of waste  reduction  is  readily
available.  What  is  not  available is quantitative  information,  e.g., per unit
of production in  specific industries,  on waste generation  and  reduction that
has occurred.  Without this  information,  it is impossible to determine whether
waste minimization activities are  really  occuring-or  if  the reduction is due
to reduced productivity, and  in what  sectors  of the economy  the reductions are
being made.

    It  is also  accepted  that  the most  positive  change in  waste  management
takes place  when  generators  eliminate or  reduce  the  production  of  hazardous
waste.  To assist  regulatory  agencies  in  their  waste  minimization efforts,
quantititative  information on waste  minimization  activities  must  be reported
by the regulated community.

    This  chapter  discusses  how  the  requirements  of  EPA for  more   waste
minimization data  mesh with  the  recommendations of the  NGA Advisory Council.
A draft questionnaire  form is presented,  along with a  rationale explaining the
questions that are asked and how the data  will be used.

B.  ADMINISTRATIVE REQUIREMENTS FOR THE DATA

    Section  3002  (Standards  Applicable to Generators  of Hazardous  Waste) of
the Resource Conservation  Recovery Act  (.also  commonly  referred  to as  RCRA,
from the  1976 Title  of the statute,  "Resource Conservation Recovery Act"), as
amended by the Hazardous  and  Solid  Waste Amendments  (HSWA)  of  1984,  states
that  "the  Administrator  shall   promulgate  regulations  establishing  such
standards,  applicable  to  generators  of  hazardous  waste  identified  -or  listed
under  this subtitle,  as  may be  necessary  to  protect  human health  and the
environment.  Such standards  shall establish  requirements  respecting...

    (6) submission of report  to the Administrator (or the State agency  in any  '
        case in which such agency  carries  out  a  permit  program pursuant  to
        this subtitle) at  least once every two years setting  out—

       (A) the quantities and nature of hazardous waste identified  or listed
           under this subtitle that he has generated during  the year;

       (B) the disposition of all  hazardous waste reported under the
           subparagraph (A);

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                                      6-2

       (C) the efforts undertaken during the year to reduce the volume and
           toxicity of waste generated; and

       (D) the changes in volume and toxicity of waste actually achieved
           during the year in question in comparision with previous years,  to
           the extent such information is available for years prior to
           enactment of the Hazardous and Solid Waste Amendments of 1984."

    Requirements  (C)  and  (D)  of  Item (6)  were mandated  by HWSA  and became
effective  in  September  of  1985.   The 1985  Biennial  Report  was subsequently
modified  to  incorporate  the   two  new  waste   minimization   requirements.  A
"narrative  description"  of  both  the  efforts  undertaken during  the  year to
reduce the volume and  toxicity  and the changes in volume and toxicity of waste
to previous years was required as part of the 1985 Biennial Report submission.

    EPA   has   found   it   impossible,   however,  to   analyze  the  "narrative
descriptions" that were  submitted.  Since there was no  uniform reporting  form
(except  for  a  blank  page)  to  report  waste  minimization  practices,   the
generators provided as little or  as much information as they felt necessary to
fulfill the requirement.  In general,  however,  generators failed to adequately
identify  the  waste that was  reduced  and  the  narrative  descriptions provided
little  detail  on  waste minimization techniques.   Consequently,  these forms
provided  little useful  information on  waste minimization practices.   Only a
few  narrative  descriptions  actually  provided  documentation  of   changes in
volume and toxicity.

    In  view   of  this  poor   mechanism  for   reporting  waste  minimization
information and data,  EPA  is  proposing to  revise the  Annual/Biennial Report
to:  (1)  streamline  the waste minimization section to  increase the likelihood
of the  generator reporting the  data and  information  fully and correctly;  and
(2)  ensure  that generators  report   their  waste  minimization  efforts  in a
consistent format that lends itself to analysis.  In turn, this will allow EPA
to  assess  the   progress  and  trends  in  waste minimization  and  fulfill   the
statutory requirements of the HSWA.

    This  information  will  be  used  in  the  development   of  a   1990  Waste
Minimization  Report  to Congress  (RTC).    In  October  of  1986,  EPA submitted a
RTC on  the  desirability  and feasibility of  establishing "command and control"
regulations  for the  minimization  of hazardous waste.   This  report  was in
response  to  a statutory mandate  in HSWA.  The report concluded that existing
data  and  information  on  waste  generation   patterns  were   insufficient to
recommend a  major new regulatory program  in  the area  of waste minimization.
It  was recommended  that  the  Agency aggressively  attempt  to  gather better
information  and data  on  waste  generation   patterns  and  trends in  order to
better understand  the nation's  hazardous  waste generation  profile and assess
the need  for regulatory action.   EPA committed to report back to Congress on
the need  for command  and  control  regulations  by December  1990, the earliest
date that they felt a decision could be made.

    In  light of this  commitment,  it  is  essential  that  the  Agency gather
comprehensive and uniform  data  in a consistent manner on waste  generation and
minimization.   The  proposed  Biennial  Report  form offers  this opportunity by

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                                      6-3

providing  EPA with  a  consistent  mechanism to  collect and  monitor hazardous
waste data and information.

    In addition, it  is anticipated that the reporting results from  the  revised
format  will  allow  EPA  to  structure  a  more  effective  and  comprehensive
information   dissemination   and   technology   transfer   program   on   waste
minimization.

C.  POLICY OPTIONS

    This  section briefly summarizes options which  were considered  as possible
approaches  to  the   waste  minimization  section  and  discussed  in  the paper
presented at the Advisory Council  meeting in May.

    The  first  option   is   to   repeat  the  1985  Generator  Biennial  Report
Questionnaire  and  ask for a narrative description  of all waste-minimization
activities.  A slight variation  of this would be to also ask TSD facilities  to
answer  a   narrative  question  on  their   activities.  The  1985Facilities
Questionnaire did not ask for any  information on waste  minimization.

    One advantage to the narrative  option  is that  it  minimizes the burden  on
respondents by allowing  them to write whatever  they wish.   In some instances,
respondents have given very  detailed accounts of their minimization activities
— more  information  than would  most likely be  received  in a question  format.
The major  disadvantage of  a narrative  is that  it  leaves to the discretion  of
the respondents what information  they  wish to  provide.  This  makes it almost
impossible  for EPA  to  determine  how  minimization activities  are occurring
nationwide.

    Another alternative  is one  that  is proposed by Exxon  Corporation  and  the
Chemical  Manufacturers  Association.   This proposal   calls  for  dividing  the
information  requested   into  two  parts;  one   for  management  practices   for
minimizing waste and the  other  for information on waste-minimization  results
for any two-year period  that would  allow comparisons.   The reporting is  to  be
requested by year in tons  and is to be divided  into waste  generated and wastes
disposed  of.   The  second   part   also .requests   information  on   the  total
production of  saleable  goods from the facility, so that waste generation  can
be calculated on a normalized, per unit  of production,  basis.

    Two major  advantages to  this  alternative are that  the questions are  short
and easy  to understand,  and  that totals will  be easy  to  aggregate and  enter
into  a national  data  system.    The information  received  from this  type  of
reporting will be far more than EPA has  received in  the past.

    The disadvantages to this option are that a lot of the specific details of
a  facility's  waste-minimization  efforts  will  not  be  disclosed  by  simple
"Yes/No"  responses,  nor  will it  be possible to determine  whether  changes   in
toxicity have occurred.

    The third  option,  which reflects the comments  of the Advisory  Council  and
meets  the required  data and  information needs of  EPA,  is presented  in  the
draft  proposed  form.    Many of   the  questions  and the  format  are  modified

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                                      6-4

versions  of  New  Jersey's  annual  waste-minimization   report.    This   option
represents  a compromise  between  minimizing reporting burdens  and meeting  the
data  requirements  of  RCRA managers.   The pros  and cons  of  this option  are
presented in greater detail in Section H.

D. DATA AND INFORMATION REQUIREMENTS

    As  discussed  in Section B,  Section 3002  (6He)  and (d) of SWDA  requires
EPA to  promulgate  regulations  that require at a minimum biennial  reporting of
efforts undertaken during the  year to reduce  the volume  and  toxicity  of  wastes
generated,  and changes   in  volume  and  toxicity of  waste  actually achieved
during the year in comparison with previous years.

    Six broad  areas were  found  to be crucial  to meet  this intent of Congress
as  well  as  fulfill  EPA's  need  for  waste-minimization data  for  regulatory
analysis:

       •   The current status of the waste-minimization  program;

       •   Minimization practices;

       •   Waste generation and management practices;

       •   Production levels;

       •   Past and future waste-minimization  activities; and

       •   Supplemental  information that  would  allow  analyses of health  and
           environmental  impacts of treatment  and disposal.

Under each of of these  topics,  additional detailed questions were  required to
answer  the  six broad   topic  areas.   More  specifically,  these   requirements
address the need for information that establishes:

       •   A baseline  with regard  to  toxicity and  volume  of waste streams by
           industrial category*  geographic area  and  size,  and unit of product
           output;

       •   A baseline .with regard  to source  reduction, recycling,  treatment,
           and disposal capacities for those waste streams;

       •   Short term trends in these figures;

       •   Changes   in   manufacturing   processes   that   result   in  reduced
           generation of  waste; and

       •   Changes in recycling, treatment, and disposal  practices.

E.  USEFULNESS OF CURRENT DATA

    The best  data  available  to  EPA on  the  amount  and  content   of  hazardous
wastes were  developed  by  surveys  conducted in 1981  and 1983.  These data are

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                                      6-5

no  longer  current  and are known  to be of uneven  quality  because of reporting
errors   and   the   small   sample   sizes  from   which  the   information  was
extrapolated.    Neither   survey   requested   specific  information   on  waste
minimization.  As  stated  earlier,  the narrative waste minimization  information
reported  on  the  1985 Biennial   Report  is  also  of  little  use  to   EPA in
determining minimization practices.

    Other  potential   sources  for  EPA   to  obtain  information   on  waste
minimization data  are the New Generator  Survey,  the TSD  Survey,  the  Uniform
Manifest System, TSCA Section 8 Reporting Requirements and the SARA Title III
Toxic Chemical Inventory  Form.  Case  studies  and modeling activities are also
being developed  by EPA's  Office of Research  and Development that will  enhance
EPA's  understanding  of  waste  minimization.   Although   these  sources   will
provide  some information  to  EPA  that can then  be used to meet  the statutory
and  regulatory  requirements, the  Biennial Report  is believed to  be the  most
appropriate  mechanism to  receive  complete  information from all generators and
TSD's on a  periodic  basis.   Information  derived  from TSCA Section 8  and the
SARA  Title  III  Toxic  Inventory  Form  will  not be  available  in   time  to be
included in  EPA's  1990 Report to Congress.

F.  DESCRIPTION OF THE PROPOSED FORKS

    In response  to Section  3002  (6)(c), of the SWDA,  a  set of questions  have
been  developed  to  assess a  generator's "efforts" toward  waste minimization.
While some of  these  questions  may be considered  "soft information" they  will
add  to  EPA's  ability  to understand  waste  minimization   activities  that are
occuring.    In  response  to  Section  3002  (6)(d) of SWDA,   additional   data
elements  have  been  developed  to  assess  the changes  in  volume  and  toxicity
actually achieved  during  the  reporting year.

    Described  below  are  the proposed  waste  minimization components  of the
Biennial Report  and a justification  for including the information  on  the  1987
Biennial Report  form.  As the proposed form is currently structured, there are
10  exclusive waste minimization  questions and another 9  descriptors  that are
needed  for  waste  minimization analysis  but  are  included on  other  proposed
forms.   The  waste minimization questions  are  included  in  the- special  Waste
Minimization  (WM)  form.    The   descriptors  are   contained  in  the  Waste
Description  (WD),  and   Process   Generation  (PG)   forms.    For  purposes  of
discussion,  this section  lists  the justifications for all  of  the  questions and
descriptors  that apply to waste minimization.

    1. Waste Minimization Questions

    Question 1;  Does  this  facility  have a  written  statement which  outlines
goals,  objectives,  and  practices  of waste  minimization?  — As  part of  tne
waste  minimization manliest  certification and  as a  condition for an on-site
treatment,  storage,  and  disposal  permit, generators must  certify that  they
have a waste minimization program  in place.  This question will  identify those
generators   that   have  made,  at   least  in  writing,  a  commitment  to  waste
minimization and have identified  goals, objectives,   and operational  practices
for waste  minimization.

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                                      6-6

     Information  on the proportion and  patterns  of such commitments  across  the
 nation are  valuable  for targeting public  agency  waste minimization programs.

     Question  2;   In  the past  two  years,  has  this  facility  conducted a  waste
 minimization  assessment that  identifies  ways  to  reduce  the  volume of  waste
 generated?  —  An important first step  towards  achieving waste  minimization is
 to  conduct  a  "waste  minimization assessment" (WMA).  An essential element of a
 waste  minimization  program  is the planning  and  execution  of  a  WMA.   The
 primary  objective of a WM\ is  to  reduce the quantity and/or  toxicity of  waste
 leaving  a production or manufacturing  process.   In many cases,  the  assessment
 process,  is the  cornerstone of  a generator's  overall WM program.  It provides
 the key  inputs for  the  generation  of  WM options, as well  as  the decision of
 which  WM measures  should be  implemented.  Aggregate information,  describing
 who has   conducted WNA  efforts, and  where,  is  useful  to  RCRA  agencies  for
 planning waste minimization campaigns.

     Question  5: Were any of the recommendations made  in the  waste minimization
 assessment   implemented?r=THeimplementation6Tanoptionoroptions
 identified  in  a  WMA is another  indicator of a generator's commitment to waste
 minimization and  their acknowledgement  of the benefits of waste minimization.

     Question  4;   Does  this  facility have a training and  rewards  program to
 train  employees  on waste  minimization  and to encourage  the  identification ot
 new ways to minimize  hazardous  waste  generation? — cine  component  of  a  waste
 minimization  program  that has  been identified   by  many  industries  as  a  key
 element  is  an  employee training and reward program  for waste minimization.   It
 is  important  for  management to  make the  commitment to minimization.  The most
 effective way  management  can  do this is  by training  employees and by rewarding
 those that  do  a  good job.   In addition,  it creates  an overall awareness at  the
 facility  of  the   importance  of waste  minimization.  The establishment  of  a
 training/rewards  programs  within a  company is  considered a  strong  effort in
 waste minimization.

     Question  5; Has  this facility  utilized the services of a  Waste Exchange or
 a  Waste   Broker   to  minimize  the  amount of  hazardous waste  to be  treated,
 stored,  or disposed  of?--Thisinformation  willdemonstrate the  number of
 facilitiesthatareutilizing the services  of  a  waste  exchange or  waste
 broker,  and  if   the  services are  being  provided only to  a  select group of
 industries,  in  one  region  of  the  country.   The  data  can  then  be used to
 encourage other  markets for these services  in  other regions  of the  country as
 what  is   "waste"   to  one  firm  may  be  of economic  value to  another.   Waste
 minimization  can be  accomplished  by  putting  waste  materials  to  use  and
 information describing  the  extent   to  which  "exchanges"  are undertaken is
 valuable   for  public  agencies  planning  waste  minimization  programs,  and
 evaluating  their  success.

     Question  6;   Has  this  facility  applied  for  and/or  received  technical
 assistance,  monetary grants, or benefits from  States to implement  techniques
 to  reduce the volume  and/or  toxicity  ot  the hazardous  waste  generated?  — It
Tsimportanttoknow whetherfacilitiesareseekingoutsidesources  for
 assistance  on waste  minimization  in order  to develop  a  profile  of "efforts"
 made  to  minimize  hazardous  waste.   Company  inertia, lack  of  information  and

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                                      6-7

resistance  to  change have been identified as  the three major stumbling blocks
to  waste  minimization.   This question  will  also determine  whether or not  the
need for  outside  sources/funds  is  also  a major stumbling block to  implementing
waste minimization.

    Question 7;  Has this  facility  ever received any  information or  technical
assistance  on  waste minimization  that has resulted  in waste minimization?   It
yes, indicate  how that  information  was  obtained. — This question  is  important
for gaining an understanding of how current  information is being  disseminated
and will  allow EPA to  target the  transfering of waste minimization  information
in the future.

    Question  8;  Why were  waste  minimization  programs  implemented  at   this
facility? -- This question  isimportant because it  enables EPA to understand
thereasons why  waste  minimization  activities  are  occuring.   EPA  can  then
encourage  other  facilities  to implement  such  programs  showing   nationwide
statistics  on  why others  are  implementing  programs.  It  will  also enable  EPA
to target their research and development efforts on those activities  that  are
known to be well  received.

    Question 9;  What effect does  this  facility's  waste minimization  programs
have  on  the  quantity  of  water  effluent  generated?  ~  In  discussing waste
minimization activities  for RCRA waste  it  isimportant to understand whether
those  activities  have   also meant  an  increase in  pollutants  that  are   not
regulated under  RCRA.   It  is  therefore crucial to  have  some  indication  of
whether there  has been any increase in  the  quantities of waste water  that  will
also need to  be  properly disposed  of,  so that  waste  minimization activities
can be properly targeted.
    Question  10;  What effect does  this  facility's waste minimization  programs
have on air emissions?  —  In discussing waste minimization activities  tor  KLKA
waste  it  is  important  to  understand whether those  activities have also meant
an  increase  in  pollutants  to  another  media   that may  be  less  stringently
regulated.  If  RCRA waste is being  reduced  at  the expense of increases  in air
emissions then waste minimization activities will  need to be  refocused.

    2. Other Waste Minimization Descriptors

    Descriptors from other forms that  apply to waste  minimization are  listed
and justified below:

    EPA  Hazardous  Waste  Number --  It  is  a   regulatory  requirement  that  a
generatoridentifyhazardouswaste  generated  by  the  EPA Hazardous Waste
Number.  For waste  minimization  it  is important to  know the  particular type of
waste generated.

    A/B Waste Description  Code  —  EPA has  developed a  complementary  coding
system  for  hazardous waste  providing  additional  physical  state and  chemical
nature  data.   This  new  information will be  important  in attempting to assess
the  nation's  hazardous  waste  profile.   This  profile,   in  turn,   will  be
important  when  considering  priorities   for  regulatory   action  in  waste
minimization.

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                                      6-8

    Narrative Description of  Waste Generating Process --  It  is important from
a waste minimization  perspective to know where  the  waste is coming from.  Not
only is this  information  required under Section  3002(6)(D)  of the SWDA, it  is
important for EPA to  have this  information  when they assess the need for waste
minimization regulations.

    The information required  after identifying the  waste  by  the EPA hazardous
waste  codes,  is  "how"  or  "why"  the  waste was  generated.   Without  this
information,  it  is difficult to  determine  whether a waste  code  refers  to a
manufacturing process  residual,  contaminated  material,  etc.   This information
is  already  provided  for  some  listed wastes,  however problems  have occurred
when the  "characteristic" wastes  are reported.  This "field  descriptor" will
allow  for a description of all  the waste generating  processes for all wastes
using a narrative.

    4-digit SIC code  -- The Standard Industrial Classification (SIC) Code is a
classification structure  which  categorizes  industries  on the  basis  of their
principal product  or activity.   The purpose  of  the SIC  is  to facilitate the
collection,   tabulation, and  analysis  of  data  for promoting  uniformity and
comparability in the presentation  of  statistical  data.

    For  waste  minimization  purposes,  the   (450)  four-digit  SIC  Code  for
generators  will  be   used  to   provide   baseline   information  on particular
industries.   Such  baseline  data  is  valuable  for focusing attention  on waste
minimization  potentials for  certain generators.   The advantage  of  a  4-digit
SIC over a  2-digit SIC is that  with the 4-digit, one  is able  to determine more
precisely the  industry that  is  involved.   For example,  SIC  34 represents the
fabricated  metal  products  industry, whereas SIC  3471  refers more  specifically
to the electroplating, polishing and  coloring  industries.

    Another option to  the 4-digit  SIC code  is the 7-digit SIC code.  The extra
information  that  would  be  described   in  the  last  3-digits   would allow
comparisons of the processes  the industry is using.  Although  this information
is  crucial  for waste  minimization analysis,  it  is  expected that  the previous
descriptor,   requesting  a  narrative  description  of  the   waste generating
process, will satisfy this  requirement.   It is also believed  to be much easier
for most  generators  to complete.  Although  economic information on particular
production  processes  by 7-digit  SIC code is reported annually  to  the Bureau  of
Census, for the  purposes of  the Biennial Report,  most  generators will have a
difficult time determining their correct  7-digit  SIC  product code  from  the
11,000 categories available.

    Source  Code  —  In  order  to  understand  the  nation's   hazardous waste
generation  profile,  it is  important to  know  why the  waste was generated.   In
assessing the  need for waste minimization  regulations  and  targeting them,  it
is  essential   to  know,   for  example,   whether  the   waste  came   from   a
manufacturer's degreasing operations or is  a residual  from waste  treatment.
Waste minimization potential  is dependent upon the  origin  of the waste.

    Current  Year Quantity  Generated and  Previous  Year Generated --   It is a
requirement  that a  generatorreportthe  changesin volume  and toxicity  of
waste  actually achieved during the  year in question in comparison to  previous

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                                      6-9

years.  In  fulfillment of this  requirement,  it  is  recommended that  generated
wastes  be  reported  for  1986 and  1987.   It  is  important  for  some  unit  of
measure (e.g.,  gallons,  tons, etc.)  to be reported  along with the generation
quantity in order for the information to be analyzed  properly.

    Productivity  Code --  In  order  to accurately   assess  patterns  in waste
generation,it  is essential  that  one take into  account production variations
over  time.   For  this  reason it  is important  to  normalize waste minimization
data  in terms  of the ratio of units  of  waste  to  units  of production.   For
example,  an  industry may  experience   a  production growth  of  150%  with  a
subsequent  150%  increase  in waste  generation.  In terms of units of  waste per
unit  of production  no change is evident.   However,   if some waste minimization
technique   has   been   implemented,  this  would  be   illustrated    in  their
waste/production ratio.

    For  these  reasons,  it  is  important   for  EPA   to  have an  indication  of
economic activity and  its  relationship  to  hazardous  waste generation.   In the
revised Biennial  Report,  an economic  activity  ratio  for each  of  the  wastes
reported is proposed.

    To  preserve confidentiality,  the  production  data  will  be  reported  as  a
ratio  of  the  1987  production  generating  that  particular  waste   to  1986
production.   This is the same  as  assuming that  the  1986 production  is  a  base
year  with  the value of 1.0.  An example of the production ratio follows for a
D002 waste field description:

       — 1986 production of widget x =  10.5  million
       -- 1987 production of widget x =  12.5  million

       -- 1987 production ratio for D002 waste  =  12,500,000 / 10,500,000

                                                =1.19 normalized  1987
                                                  production for D002 waste
                                                  from the production of widget
                                                  x

    In the  revised  biennial  report it is proposed that  for each  waste reported
an economic activity ratio also be  reported.

    Reasons   for   Change  in   Quantity  —  In   the  absence   of   production
fluctuations,  ft  is  important  for  EPA  to  know  why  waste generation rates
increased  or  decreased.   Therefore,   the  revised  reporting  form  provides  a
coded  list   of   reasons,   including  waste  minimization,  to   describe  these
fluctuations.   This  type  of  information   will allow  EPA  to  more  accurately
assess  the national waste  generation profile  and determine what decreases in
waste   generation  can  be   attributed   to   waste  minimization,   production
variation,  or some other reasons.   The  codes  being proposed are the  following:

       •    Equipment modification
       •    Process modification
       •   Raw material substitution
       •    Product  substitution

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                                     6-10

       •   Good housekeeping and improved handling

           On-site recycling or reclamation
           On-site burning in boilers
           Off-site recycling or reclamation
           Off-site burning in boilers

           Accumulation of wastes
           Wastewater treatment on-site
           Air Pollution control on-site
           Modifies hazardous waste management methods
           One-time quantify
           Other

    Reasons  for Qiange  in Toxicity  --The  regulatory requirement  for waste
minimization requires  that a generator  describe the changes  in "toxicity" of
the waste  actually achieved during  the  year  in  comparison to previous years.
Although changes  in toxicity are  difficult to measure, we are proposing  that
generators report  changes  in percent  toxicity from 1986 to 1987 for each waste
that is reported.

G.  SAMPLE OUTPUTS AND USES OF THE DATA

    Some of  the major  uses of  waste minimization data from EPA and the  State's
standpoint   are:   the   ability   to  disseminate  the  information  learned to
facilities that will incorporate the  successes into their own  programs; and to
use the data  to  effectively manage  a regulatory  waste minimization program.
In  addition,  EPA must  also collect this  data so  that  they can  report to
Congress in  1990 the  status  of our nation's  efforts  to reduce the volume and
toxicity of  hazardous waste.

    Without  baseline minimization data it is difficult  to  assess whether  there
is  a  need  for  Congress  or EPA to  enact  new mandatory  waste minimization
measures or  if the regulated  community  is  making  the best effort possible in
the most reasonable time-frame.

    It  will  also  be  impossible  without a  baseline  of quality data on  waste
minimization activities  to  set  priorities for  technical  assistance  programs
either  at  the  state or federal level  to  promote  source  reduction and recycling
programs.  This data will  also enable  EPA to target research and  development
efforts that will be  the most  successful  in reducing  threats  to human health
and the environment.

H.  PROS AMD CONS OP PROPOSED SYSTEM

    The pros and  cons  of the proposed system are listed below.

    1.  Pros

        o   For the  first  time,  a   comprehensive  national  database on   waste
           minimization activities  will exist.   The information will  satisfy
           the  needs  of  program managers conducting  regulatory  analyses and

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                                 6-11

       developing regulations,  and will  provide EPA with  the information
       necessary to report to the Congress.

   •   The  10  exclusively  waste  minimization  questions  are  easy  to
       understand  and  complete,   and  national   totals  will  be  easy  to
       aggregate and enter into a national data system.

   •   Detailed,  clearly   defined  questions   are  less   likely  to  be
       misinterpreted than the existing narrative question.

   •   The  information  compiled   will  be  useful  to  EPA  and  the  state
       agencies  for  planning  public  waste  minimization   activities,  and
       gauging their effectiveness.

   •   Waste generators  will  be able  to  cite, and  quantify,  the positive
       nature of their waste minimization handling actions.
2.  Cons
       There will  be  a greater processing  burden for  states  that are not
       already  collecting this  level  of  information,  but  this  will be
       minimized by providing software designed for ease in data entry*

       There will be a greater reporting  burden for the respondents, since
       the form requests information from two calendar years.

       The questions asking for:  (1) a  percent  change in toxicity, and (2)
       productivity  ratio  by  units  of  waste/units  of  production,  are
       difficult to answer and may result in incorrect responses.

       The relatively extensive list of questions and descriptors will add
       to the  bulk of the  questionnaires,  and may  lead  to  incomplete or
       credible reporting.

       The  "soft"  nature  of the  questions  may encourage  respondents to
       "stretch" facts in order to claim credit for positive actions.

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                                   CHAPTER 7

                       ANNUAL/BIENNIAL REPORTING SYSTEM
                  1987  DATA ENTRY/VALIDATION/RETRIEVAL SYSTEM


A. _ PROJECT OVERVIEW AND SYSTEM CONCEPT

    The Office  of Solid Waste  (OSW),  EPA's Regional  Offices,  the states, and
interested  outside  parties  are  cooperating  in   revising  the   RCRA  Annual/
Biennial  Reporting System.   Problems  with  the current reporting system fall
into two general categories:

       •   Reported data are inconsistent across states and are
           often insufficient to support necessary analyses; and,

       •   The quality of data provided to EPA  is inconsistent
           across states.

    The National  Governors'  Association,  through its Reporting System Advisory
Council, is assisting  OSW  in addressing  the first problem area by facilitating
the  identification and  development  of  commonly defined  data elements  to be
obtained  through  a  reporting  system that   serves  impleraentor  and oversight
needs.  To  date, the Advisory  Council has  identified the general  information
objectives  to  be fulfilled  by  the reporting system,  and  provided guidance on
specific  data  elements that  should  be  included  in  the  revised reporting
system.   The  draft revised  forms  discussed  in  the  previous six  chapters  (and
presented in Appendix  A) are designed to fulfill  the stated objectives of the
biennial  reporting  system  and  reflect  the  guidance provided  by the NGA
Advisory Council.

    To address  the reporting system's second problem area,  OSW has  undertaken
the development  of specifications for an automated  data  processing system to
accompany the  reporting forms  once  they  are  finalized.   These  specifications
are being developed to  assist  implementors (states  and  EPA Regional Offices)
in their  management  of reported data and to promote  consistent entry, editing,
validation, and  retrieval/transmission  of reported data  across  the 56  states
and U.S.  territories  and  the  10 EPA Regional Offices.  The project  entails
development of formal  functional specifications for the management  of reported
data,  and also  includes delivery  of an actual programmed  system based  upon
these  specifications.   Once   the  functional   specifications  are   finalized,
implementors will have three options:

       •   Adopt OSW's programmed  system  as  is,  for  use in their
            states  (augmented, as desired,  to address State-specific
            reporting requirements);
                         I
       •   Develop their own automated systems  based upon  the  functional
            specifications provided through this project; or,

       •    Process reported  data manually in accordance with the
            specifications developed through  this project.

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                                      7-2

    The  purpose of  this  chapter  is to  provide  an overview  of  OSW's  1987
Biennial  Report system  development  effort,  to  outline  the  major components
that  are  currently  proposed  for  inclusion  in  the  system,  and  to  solicit
comments  on  a  number of  issues  that  must be resolved  in  developing the final
specifications for the data processing system.

    Data  management  under the RCRA Annual/Biennial  Reporting System conforms
generally  to  the two-domain concept: data  are  obtained and  processed  at the
implementor  level  (states and EPA Regional  Offices),  and certain data (core
data) are  transmitted to  the oversight  level (OSW).  Data obtained through the
system  support  functions  in both  domains.   The two  domain  concept also forms
the  basis  for   development  of  the  new  Resource  Conservation   and  Recovery
Information  System  (RCRIS),  which   is   intended   to  replace   the  existing
Hazardous  Waste Data  Management  System  (HWDMS).  Data  obtained  through the
reporting system are intended to update and augment data residing  in RCRIS.

    Development  of  system specifications  under  the  two  domain  concept  is
proposed to occur in four phases:

       •   Phase   1:   Implementor  Data   Entry  and  Key-Entry   Editing  --
           Specifications will be developed for screen entry of  reported data
           into  automated  files,  based   upon  the  final   reporting  forms
           recommended by  the  NGA Advisory  Council.   Specifications will also
           be developed for simple editing  of entered data to ensure automated
           processing  of  data   provided  by   handlers   on  report   forms.
           Procedures  will  also  be  developed  for  loading  automated  data
           provided  directly by handlers (electronic reporting).

       •   Phase  2;   Implementor  Data   Validation  —   Data  validation  by
           implementors  isthe   keytoqualitycontrol   in  the reporting
           system.   Specifications will be  developed to  check each handler's
           reported  data  for  internal  consistency  and  consistency  across
           handlers    within    each    state    (intra-state     consistency).
           Specifications will also be  developed  to compare reported data with
           external   data   sources,   including   Notification    and   Permit
           Application  files,  inspection  records,  etc.   The system  will  be
           designed  to  assist   implementors  in  identifying  problems  and  in
           establishing priorities for follow-up.

       •   Phase   3;   Implementor  Data   Retrieval   and   Transmission  —
           Specifications  will   bedevelopedForstandardretrievals  and
           reports,  ad hoc queries,  transfers  to RCRIS,  and transfers to the
           oversight domain.

       •   Phase  4;  Oversight  Data  Automation,  Auditing,  and  Retrieval —
           Specificationswill  bedevelopedForautomatingdatathat are
           transmitted to oversight in  manual form, for auditing  routines that
           ensure  transmitted  data are  of specified quality and  that  perform
           inter-state  consistency checks,  and  standard/ad  hoc  retrieval of
           oversight data.

    OSW  is  proposing to  develop the  system  specifications and the programmed

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                                      7-3

system  based  upon those  specifications  in phases  in  order to  deliver  the
earliest  components  in  time  for  use  by  states  and  Regions   during   their
processing of  1987  reporting  data.   Life cycle management guidelines are  being
followed  in  the  development  of  each  system  component,  including extensive
third-party  testing.  A detailed  project management plan has been developed to
ensure  that  system components  are  completed  in  sufficient  time  to allow  for
training  implementors  in-the  use  of  each  component  before it  is actually
employed (a  copy  of the entire  project management plan  is provided  in Appendix
Attachment D).  Proposed  release dates  for the  each component  of the  fully
programmed and tested system are as  follows:

       •   Implementor Entry/Editing:        1/21/88

       •   Implementor Data Validation:      4/04/88

       •   Implementor Data Retrieval:       4/15/88

       •   Oversight Auditing/Retrieval:     6/29/88

    Fully  developed functional  specifications  for each implementor component
will  be  released  considerably  earlier to States  that  choose to program  their
own systems.

B.  SYSTEM OVERVIEW AND DATA FLOWS

    To provide a  proper understanding of the Biennial  Report data  system,  it
is important to understand both the interface with the "outside world" and  the
structure of the  system itself.   We provide this understanding through the  use
of  diagrams  that  depict  the  components  of  the  system,   relevant external
entities, and data  flowing among them.   Included here are three such diagrams
(Figures 7-1,  7-2,  7-3).   These  diagrams are intended  to  provide  an overview
or logical  description or the  system.  Detailed  diagrams  and definitions  are
found in Appendix C.

    The diagram appearing  in  Figure 7-1  depicts the two domain concept and  the
external entities  which interface  with each  of  the  domains.   These external
entities  represent  the  sources  and  destinations  of  reporting  data.    The
processes labeled 100 and  200 represent  the processing done  by the  implementor
domain  and the oversight  domain,  respectively.    Each  of   these  processes  is
presented in detail in the following two figures.

    Figure 7-2  illustrates  how  the  three  components  of the  implementor domain
described  previously  (data  entry,  validation  and  reporting) are  related  to
each  other and to the implementor  domain.   The  diagram shows that  the handler
is the  primary source of system  data  and traces  the  flow  of the data through
the validation process and  to  the  storage and retrieval  module.  The arrows
represent the  flow of data between  processes.  The validation process depends
on both data provided by the  data entry component and external sources of data
which are used for comparison.

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                   7-4



                  FIGURE 7-1
ANNUAL/BIENNIAL   REPORTING
        PROCESSING  OVERVIEW
EE 6
EXTERNAL
IMPLEMENTOR
DATA
SOURCES


External
Implement or
. Data
IEE i
Annual/Biennial
fleoort Form _
RESPONDENT m
(HANDLER)
EE 2
IMPLEMENTOR
USE OF
REPORTS
i
1
Imp leu
Report
100
IMPLEMENTOR
HANDLING OF
DATA
EE 4
RCRIS
IMPLEMENTOR
DOMAIN
I
entor ;
3 I
laplementor
Domain
RCRIS Data )

                             Transmitted
                             Oversight
                             Data
                External
                Oversight
                Data
                            200
 OVERSIGHT
 HANDLING
 OF DATA
Oversight
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BCHIS Data
                              Oversight
                              Reports
         EE 7

          EXTERNAL
          OVERSIGHT

          SO°UARTCAES
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 OVERSIGHT
 USES OF
   DATA
                                          EE 5
        RCRIS
       OVERSIGHT
        DOMAIN

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                                          7-5

                                       FIGURE 7-2
                       EE 6

                        EXTERNAL
                       IMPLEMENTOR
                          DATA
                         SOURCES
EE 1
RESPONDENT
 (HANDLER)
      Annual/Bienni
      Report  Forn
EE  2


 MPLEMENTOR
  USE OF
 REPORTS
                            External
                            Inplementor
                            Data
                                 IMPLEMENTOR
                          100.2
                        VALIDATE
                          DATA
EE 4
   RCRIS
IMPLEMENTOR
  DOMAIN
      Imp lenient on
      Reports
     HANDLING  OF  DA11A
      Inplementor
      Domain
      RCRIS Data
                                           Validated
                                           Data
                                      Implementor
                                      Data
                        Dl IMPLEMENTOR DATA BASE
                            Transmitter
                            Oversight
                            Data
                                                                        200
                                                                     OVERSIGHT
                                                                     HANDLING
                                                                      OF DATA

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                                    7-6
                                 FIGURE  7-3
                                        EE 7

                                         EXTERNAL
                                         OVERSIGHT
                                           DATA
                                          SOURCES
             /'ZOO
Transmitted
Oversight
Data
        OVERSIGHT  HANDLING  OF  DATA
                                             External
                                             Oversight
                                             Data
200.1
                   RECEIVE
                  OVERSIGHT
                     DATA
         Received
         Data
                           Oversight
                           Data	
                                           201
                                             Audited
                                             Data
                         .3
                      STORE
                        S
                     RETRIEVE
                    OVERSIGHT
                       DATA
Oversight
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RCHIS Data
                                             Oversight
                                             Reports
          02 OVERSIGHT DATA BASE
                    £ 3


                    OVERl__
                     USES OF
                       DATA
                                                              EE 5
            RCRIS
            ERSI
           DOMAIN
                                                               OVERSIGHT

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                                      7-7

    Validated  data  is  then  shown  flowing  to   the   storage  and   retrieval
process.   This  process  contains  all  subprocesses  which  perform   standard
retrievals and  reports,  ad hoc reports, and  interactive queries.   In  addition
to  reporting,  this diagram also  shows  that  the  storage and retrieval  process
maintains the  implementor  data base and provides  a mechanism for the  transfer
of Annual/Biennial Report  data to the implementor domain of RCRIS.  The nature
of the transfer has not  been  determined — this diagram only serves to present
the requirement of an interface with RCRIS.

    Oversight domain  processing is shown  in Figure 7-3.   This  diagram, which
closely parallels Figure 7-2,  depicts data being accepted from the implementor
domain through an unspecified  mechanism.   Within the oversight domain,  one  can
recognize   the  three   processing   components:    acceptance,   auditing,   and
reporting.  No  component  for  data entry is  specified  at the oversight domain.
However,  a  similar  process   for acceptance (entry)  of  the  data   from  the
implementor domain  must  be provided  to enable the oversight domain to accept
data from implementors in manual form.

    There is  no distinction at  this  point whether the  data accepted  has been
manually  collected  or automated.   The intent of  the  data  flow  is to  present
the  requirement for  some  type  of transmission  of data  from  the implementor
domain.   The  figure illustrates  the  flow  of data  from the acceptance  process
through the oversight domain auditing process which enforced quality assurance
requirements.   Like the  validation  process  in  the implementor  domain, this
process depends on external sources of  information  for comparison.

    In the  oversight domain,  the storage  and  reporting  process  is  very much
similar to  its counterpart  in the  implementor  domain. Reporting is  provided
for, as is maintenance of  the  oversight data base  and interface with  the RCRIS
oversight domain.  The oversight  data base will  also be available  for query by
implementors  seeking information about  handlers  or  activities  beyond  their
boundaries.

    These diagrams  depict the two domains  and  the three types of- components
within each  domain.   More detailed  diagrams are provided in Appendix  C.   The
Appendix also contains the current system  specifications  in the form  of a data
dictionary, where  each external entity, process, data  store, and data flow is
described in detail.

C.  ISSUES

    The  following  discussion  addresses  two major issue  areas  involved  in
developing   the   automated    system    requirements  for   the   revised  RCRA
Annual/Biennial  Reporting  System:   (1)   data   flows  from  implementors   to
oversight; and  (2)  the  nature of  the operating  environment to be  supported by
the  system.   Various  options  for resolving the  specific  issues  in  each  of
these  areas  are presented in  the following sections, along with a  specific
recommendation  for  each.   The  recommendations  presented  represent  choices
deemed  most  appropriate  by  the  project  team based  on  assumptions  made  and
facts currently available, and are intended as a starting point for discussion
at the next meeting of the Advisory Council.

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                                      7-8

    1.  Data Flow From Implenenters to Oversight

    The two-domain  nature of the  reporting system  requires  that decisions  be
made concerning the  specific  roles to be played, or functions to be performed,
by  implementors and  overseers.   Similar decisions are also required concerning
the extent  and nature of  data  that will  reside in each  domain and data  that
are to be passed between domains.

    Three   major   types   of   data  exist   within  the   two-domain   system:
"irapleraentor"  data  (data, which may  or may not  be  commonly  defined,  that  are
obtained by implementors  and retained  exclusively  in the implementor domain);
"core"  data   (commonly-defined data   that  are  obtained  and  processed   by
implementors  and  transmitted  to  oversight);  and "oversight" data  (data  that
are  obtained   and  processed   directly  by   oversight  without   irapleraentor
involvement).  Roles  and  responsibilities of  implementors and  overseers  vary
with each   type of  data.    Development  of  system specifications  is therefore
dependent upon resolution of several specific  issues:

       •   Designation of "Core" Data Elements  — Which  of the data
           elements included in the final report  forms should be
           designated as "core" for required   transmission from
            implementors to oversight?

       •   Level of Transmitted Data —  Are implementors  to transmit
           coredataatth"ehandler  level  (validated  case  records)   or
           aggregated by state?

       •   Mode of Transmission — Are core data  to  be transmitted
            in automated or non-automated  (manual) form?

       •   Quality   Requirements   for   Transmitted   Data  —   What   quality
            requirements   should b~eplaced  on  core  dTta  that  are   to  be
           transmitted from implementors  to oversight?

    Designation of Core Data Elements.   Core  data  elements are often a subset
of  commonly-defined  elements  that  implementors are required to  obtain,  process
in  accordance  with  specified criteria,  and transmit to the  oversight  domain.
The  draft  reporting  forms accompanying  this  report  represent  the  set  of
commonly-defined elements to  be obtained by implementors through the reporting
system.  Which of  the elements included in the  forms are to be designated as
core?

       •   Option  1  —  All  elements  included in  the  model  reporting  forms
           developed by the Advisory Council are  designated as core.

       •   Option  2  —  Only  a  subset  of   elements   included  in  the  model
           reporting  forms  are designated  as  core.    Remaining  elements  are
           either  retained  at   the   impleraentor   level  or   transmitted  to
           oversight without validation by  implementors.

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                                      7-9

    Recommendation: Option 1.

    Oversight  participants   on   the   Advisory  Council  have  approached   the
development  process  of   the  forms  from  the  perspective  that  all  elements
included would  be obtained  and  processed  by implementors  and  transmitted  to
oversight.   Elements included in  the  forms  are intended to support iraplementor
and oversight  data needs, including  developing  program management, regulatory
development,  and  program evaluation  information.    It  is anticipated   that
implementors  may  obtain  state-specific  data  in addition  to  those  elements
included in  these reporting  forms.   These would represent the  types of  data
that  would  not  be transmitted  to  oversight.  In addition  to other  types  of
data,   implementors may  require  additional  handlers  to  complete  the  report
forms beyond those designated in  the  federal  Who Must File  section (e.g.,  many
states are expected to require  RCRA Small  Quantity  Generators  to complete the
Primary Generation, Waste Description,  and  Shipped Off-site forms, even though
federal  requirements  for  such  forms  do not apply  to such generators).   In
these cases, data  reported by additional handlers would not be included within
the   core   designation,   even  though   they   are  the   same   data   elements.
Implementors that  desire  to  obtain such data would  not be required to process
them according to the standard specifications and would not be required to
transmit them to the oversight domain.

    Since  the   draft  reporting   forms  essentially  specify  oversight   data
requirements, any  data not  obtained,  processed, and  transmitted to  oversight
by  implementors   would   have  to  be   obtained   and  processed  directly  by
oversight.   There  would be high probability  of  duplication  in  data collection
under  such  conditions,  unless  the  elements  in question  are  truely  "stand
alone" items.  An  alternative is  for implementors to  obtain  certain elements
in conjunction with the  other elements  obtained  through the reporting system,
and pass  them through to oversight with out validating  them  (similar  to  the
way  the  Waste  Minimization  statements  were managed   in  the   1985   reporting
cycle).

    This alternative  increases  the  processing burden  at  the  oversight level,
and presumes  that  impleraentors  have no need or  use for such  elements.   The
purpose  of  the  NGA Advisory Council process,  however, has been  to identify
those elements that are  of common interest to implementors and  overseers.  It
is hoped that  implementors will agree  that all  elements included  in  the  final
report forms are of sufficient value to be  designated as core.

    Level of Transmitted Data --

       •   Option 1 — Core data are to  be  transmitted  to  oversight
           at the handler level (validated  case records).

       •   Option 2 — Core data are to  be  aggregated by state (after
           validation) prior to transmission  to oversight.

    Recommendation — Option 1

    Prior  to  the  1985   reporting  cycle,   implementors  transmitted  data  to
oversight exclusively  in  aggregated  (summary) form.  These  summary data  proved
difficult to work  with at the oversight level.   Summary data are  difficult to
assess from  a quality control  perspective  and  even  more difficult  to  rectify

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                                     7-10

once  errors  have  been  identified.   Problems  with  summary  data  were   so
difficult to pin-down and  resolve  in 1983 that no national summary report was
produced.  In response  to  this problem, OSW  began  in the 1985 reporting cycle
to require impleraentors  to transmit certain  handler-level  data  in addition  to
the   summary   data.   The   handler-level   data  allowed   for  many  internal
consistency checks  to  be  performed  that  were  not  possible  at  the oversight
level in  1983.   Accordingly,  OSW has greater confidence  in the 1985 reporting
data, and expects  to  be  able to  release a  1985  national summary  report  in
August.

    In  addition to  the quality  control  problems  associated  with aggregated
data transmissions, summary data are much  less useful in supporting the varied
types of  analyses performed  at the  oversight level.  Handler-level  data are
considerably more flexible, allowing users to sort  and select data differently
for  different  purposes.   Finally,  transmission  of  handler-level  data   to
oversight will  provide for  establishment  of  a  national waste  flow data base
that may  be called upon  by implementors in assessing interstate flows that are
of concern.   Confirmations that out-of-state shipments  were actually received
would be possible under such a system.

    Accordingly, OSW  proposes  to  eliminate  summary  reporting requirements  in
favor of obtaining validated core data at  the handler level.

    Mode of Data Transmission —

       •   Option 1 -- Implementors are required to automate all
           core data and transmit them to  oversight in automated form.

       •   Option 2 -- Implementors are required to transmit core
           data to oversight in manual (hard copy) form.

    Recommendation  —   Implementors  are requested,  but  not   required,   to
automate  core  data and  transmit  them  in  automated form.  Core  data  that are
not  automated  may  be  transmitted  in  manual  form,  to be  automated  in the
oversight domain.

    Oversight uses  of  reporting data, particularly handler-level  data, require
that data be  automated.  Many  implementors also find  automation of reporting
data to be essential.   None the less,  not all implementors currently automate
reporting  data.   Rather  than  impose   mandatory  automation   requirements   on
implementors that  may  not have the capacity to do  so,  OSW proposes to  accept
core data  in  manual form  where such data are  not  automated.   Where reporting
data  are  automated,   OSW  obviously prefers  have  core  data  transmitted   in
automated  form.  As  referenced  in  previous  sections  of  this  chapter,  the
oversight  component  of  the  data  processing  system  will   include  a data
automation  function   to   accommodate   transmission   of  manual  data  from
implementors that can not  or  choose not to automate their  reporting data.  OSW
recognizes that supporting an  automation  component  will be more expensive than
requiring  implementors -to automate.   However,  iraplementors   are not  as yet
required  to transmit  automated data under RCRIS, and will not be required  to
do so under the reporting system.

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                                     7-11

    Quality Requirements for Transmitted Data —

       •   Option 1 --  Iraplementors  transmit  to oversight  only those data that
           meet   QA/QC  specifications.    Data   that   do   not   meet   QA/QC
           specifications remain  in  the implementor domain  until sufficiently
           validated.

       •   Option 2 -- Implementors  transmit to  oversight all required  data.
           Data that  do not  meet QA/QC specifications  are  either  flagged by
           implementors  or  identified  and  flagged through  oversight auditing
           processes.

    Recommendation —  Option 2.

    Under  Option  1,  the oversight  data base  contains  an  incomplete  set of
fully  validated  data.   Under Option  2, the oversight  data  base  contains a
complete set  of  all  required  report data,  but  not  all of  the  oversight data
are validated.   If  it  is assumed that  implementors have  sufficient resources
to validate  all  required data to specified QA/QC levels, Options  1 and 2  are
identical.   It is more  likely, however, that  implementors  will face resource
limitations that  constrain  their ability to fully validate all data that  are
required to be transmitted  to  oversight.  In fact, the design of the automated
data processing system is  based  on  the  assumption that implementors will want
to use  the system  to establish  priorities  for their expenditure  of time  and
resources  in  validating reported data  (e.g.,  rank problem cases  by  size to
ensure that the most  important errors  are  addressed first; address  problems at
sites with history of compliance problems, etc.).

    The  advantage  of Option  2  over  Option 1  is  that a  complete  data  set
containing  some  amount  of  unvalidated data   provides  greater  latitude to
overseers  in  conducting population  analyses.    If  desired,  analyses  may be
limited to data that  do meet  QA/QC specification (flagging mechanisms or QA/QC
checks  built  into  the  analytical  routines  themselves).   In  this  case,  the
analyses conducted  under Option 1 and  Option 2 are identical.   Under Option 2,
however, unvalidated   data  may  be  incorporated  into  analyses  under  varying
degrees  of   qualification.   For   example,   data  within  */-  X  of   QA/QC
specifications may  be  incorporated  into one analysis, while  data with  +/• 3X
may be incorporated  into   another  analysis.  Results  of each  analysis   can be
appropriately  qualified.  Additionally, under  Option 2,  analysts may  replace
unvalidated data  with assumptions informed  by the unvalidated data,  as  opposed
to making the blind assumptions necessitated  under Option  1.

    Accordingly,  OSW  proposes that  iraplementors transmit  to  oversight  all
required data (Option  2).  Data  that  do not meet QA/QC specifications  can be
flagged either by  implementors or  in the  oversight  domain  through the  use of
the  auditing  process.  It  is  important  to  clarify,  however,  that  primary
responsibility   for  validation   of  core   reporting   data  remains   at   the
implementor  level.    Implementors  are  "owners" of core  data and  as such  are
responsible   for   their  upkeep.   Oversight   may   assist  implementors   in
identifying  data  quality   problems  (particularly  in  the case of  interstate
inconsistencies).   But responsibility  for  responding  to or following-up on on
identified  problems   remains  at  the   implementor   level.    Recognizing  that
implementor resources  are

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                                     7-12

limited, however,  oversight may also  assist  implementors in actual  follow-up.
Such arrangements  need  to be negotiated on  a case-by-case basis, as oversight
resources are also limited.

    2.  Operating Environment Specifications

    As indicated in  section A,  the primary product of this project is a  set of
processing  specifications  which  are  to be  applied  to  the  data collection,
entry,  validation,  and  reporting  process.   Because  EPA has  judged  that it
would  speed  acceptance  of those  specifications,  EPA  will  also  deliver  a
computerized system  which  implements  them.   This system may be used  for  actual
processing  of  the data.   However, it  will  also  serve  as a  prototype  of the
specifications for those states choosing to develop their own system  in-house.

    A second  issue,  of  special interest to  those states likely to adopt EPA's
processing  system,   is  that  of  hardware/software  specification.    It  is
important  to  thoroughly  consider  the  operating  environments   EPA  has  the
resources  to  support.   Determination of operating  environment specifications
has  impacts on other decisions yet  to be made,  such  as  language or data  base
package  selection,   data   transmission  capabilities,  provision  for   data
conversion  facilities,  and  alternatives for data collection.  The two  issues
which need to be addressed are:

       •   Hardware  Environment Specification  --  What hardware environment(s)
           will  be   directly  supported   by   EPA    for   implementors  using
           EPA-supplied software?

       •   Software  Specification  —  Given  that  hardware  requirements  have
           been decided  upon,  what language(s)  will  be  used  to  implement the
           system on that hardware?

    Hardware Specification  —

       •   Option  1  —  Implement the  system on  microcomputers.   This  option
           would  specify  that EPA would  support  running  the   EPA-supplied
           software on designated PC's.

       •   Option 2  — Implement the system on  the NCC mainframe.
           The system  would be implemented on  the IBM mainframe at
           NCC.    Access   to   this   system   would   be   provided  through
           telecommunications and the  time-sharing feature of the  system.

       •   Option  3  ~  Implement the  system  on  the Regional  LMF's.   States
           would   access   the   EPA-provided   system  by  way  of  EPA  Logical
           Mainframe (LMF) network.

    While  generally  it  is  preferable  to  perform software  selection prior to
determining hardware specifications,   because  of the diverse  potential  user
base which will need  to be supported  and  the. limited  universe of  candidate
hardware, the system definition process must depend on the hardware  already or
easily made available.

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                                     7-13

    The most accessible piece of  hardware  is the PC.  Based on recent data, an
IBM PC/AT,  COMPAQ Deskpro 286 or 386 or equivalent will  be  required to store
and manage  information  of the estimated volume  with reasonable response time.
This type of  computer seems to be widely  available and, where not immediately
accessible,  it  is  generally the easiest type  of hardware to acquire.  However
due to  storage  and processing limitations of  PCs,  it  is clear that the larger
states' data cannot be managed on PCs alone.

    The  second  alternative  is  to provide  sufficient  access and  resources on
Regional  logical  mainframe  (LMF)  computers  for  data  entry  and management.
While  specific  cost  data  has  not  been  developed,   it  is  generally   very
expensive to use a mainframe for extensive  data entry activities.  Data entry
uses  little  processing  power  and   it  requires  an  insignificant  number of
input/output (I/O) transactions.  The primary  cost  is  the connect time and the
overhead cost  of running and monitoring an interactive  session.   The cost is
high relative to the amount of computing  performed and the data entry session
uses system resources even  if  little activity  takes  place.   In addition,  for
most local  data entry  sites telecommunication  links  must be  established  and
proper equipment obtained.

    The  third  alternative  is  the   use  of  the EPA  mainframe  at  NCC.    The
inefficiency  of the  previous  alternative  is  present  here.   Each  data entry
user new to NCC would need to  gain access  through  a port  in  EPA's network
topology.   This may  require obtaining  communications processors  or may  mean
suffering   from  limited  terminal   capabilities   where   this  equipment  is
unavailable.

    It  is  clear that,  for the  larger  states   at  least,  that  PCs  will  not
provide  all the  resources  necessary  to store  and  manage the volume of  data
projected.   Similiarly,  it  does not seem  like a reasonable  alternative to
propose that data  entry activity be  implemented on mainframe computers.   Some
hybrid  solution seems  to be required.   Implementors  themselves may  be   in  a
position to provide  mainframe computing capabilities for  this effort.  Support
of mainframe computers  at the  implementor level will depend on such  factors as
compatibility with EPA standards for  mainframe  computing and the  availability
and accessibility  of that equipment  to  implementation personnel.  Where  local
mainframe equipment  is incompatible or unavailable,  computing resources  must
be provided through  EPA's logical mainframe network.  To  take advantage of the
characteristics  of  each  type  of  hardware environment,  the  system  must be
designed to provide  for data entry on the PC  and data  management  and reporting
on a mainframe computer.  This  implies the need for file transfer  capability
between PC  and mainframe.

    Recommendation ~  The recommended approach  is  for EPA to develop  a system
which"has  thetime-intensive  components  (namely,  data  entry)  running on
microcomputers  and the storage and  processing-intensive  components  running on
the NCC IBM mainframe.   The actual  components  which  will need  to run on the
mainframe may vary  by state.   This  alternative requires that  the system be
easily  ported  between mainframe and  micro  and be designed in a highly modular
fashion.

-------
                                     7-14

    Software Environment  Specification --  Such  an implementation will  require
the  implementation  of two systems  --  one  to execute  on the microcomputer  and
one  for  the mainframe ~ or  the  development  of  a  single  system  which will
execute  on  both micro  and  mainframe  hardware.  FOCUS,  a fourth-generation
package  with data  base  management  and reporting  as  its  central  feature,  is
approved  by the  EPA for  use  in  both hardware  environments.    FOCUS  has  had
recent exposure  and use in  data entry and management applications in  support
of OSW projects, including  RCRIS.   It  therefore seems  that  to implement  the
hybrid PC/mainframe  approach dictates  the  use of FOCUS  as the data management
environment.

    Recommendation --  It  is  recommended that the system be  implemented  on a PC
using  FOCUS.   For larger  states,  a procedure will be  developed to allow  the
data  entry to be performed  on  the PC and a  mainframe will be  used for data
storage,  validation,  reporting,  and manipulation.  This is similar in  concept
with  how HWDMS  data entry is  implemented  presently.   All states' data  will be
stored  on  the  NCC  mainframe  in  the form  of a  national  data  base  when
complete.   It  may  be  possible  for  smaller  states  to  perform  all  three
activities: entry, validation, and  reporting on the PC.

    National  reports and  inter-state  comparisons  will   be  obtained from this
data  base.   Data for  states which choose  not to or  not able  to automate  the
data  entry or validation  processes will provide required information  to EPA.
EPA will be responsible for entry of this data into the  national  data  base.

-------
**+*
          National Governors' Association                              BUI ointon
                                                                            Governor of Arkansas
                                                                            Chairman

                                                                            Raymond C Scheppach
                                                                            Executive Director
                                         APPENDIX A

                              1987 Biennial  Report Draft Forms
            HALL OF THE STATES • 444 North Capitol Street • Washington, D.C. 20001-1572- (202) 624-5300

-------
             PLACE IDENTIFICATION LABEL HERE
                        OR
                 ENTER YOUR EPA ID NO.
                                                 Form

                                                 1C
                                              Identification
                                                  and
                                              Certification
                       ENVIRONMENTAL PROTECTION AGENCY
                            Hazardous Waste Report for 1987
                                           DRAFT
                   IDENTIFICATION AND CERTIFICATION
                       READ COMPLETE INSTRUCTIONS ON PAGES	TO	
      Note:   1)    Please answer all questions below, providing corrected information as necessary.
             2)    All terms in Italics are defined on Page _ of the instructions.
    Is the information on the Site Label correct?
    LJ   YES

    |	|   NO -> Please enter corrections ->
    Site Name
    Site Street Address
    Site Street Address
    City
                                                          Site EPA ID
              State
i  i   i  i   i  i  _  i  i   i  i   i
          ZIP Code
2.   In what County is this Site located?
    County Name

3   What is the Name, Title, and Phone Number of the person to be contacted with questions regarding the
    information in this report?
    Last Name
First Name
                                                             M.I.
    Title
    (Area Code)   Phone Number
                                            [OVER]

-------
          PLACE IDENTIFICATION LABEL HERE
                      QB.
               ENTER YOUR EPA ID NO.
                                                          Form

                                                          FS
                                                          Form
                                                          Selection
                     ENVIRONMENTAL PROTECTION AGENCY
                           Hazardous Waste Report for 1987
                                           DRAFT

                                FORM SELECTION
                     READ COMPLETE INSTRUCTIONS ON PAGES	TO	
   Note:    1)    Use this page to determine which forms must be completed for this site.

           2)    Answer questions 1,2, and 3, and all sub-questions as the directions indicate.

           3)    All terms in /ra//cs are defined on Page	of the instructions.
During the reporting year, did this site generate hazardous waste in sufficient quantities to be subject to Full RCRA
Regulation, and were at least some of these quantities generated from Primary Sources'? [Note:  Conditionally
Exempt Small Quantity Generators, RCRA Small Quantity Generators, generators regulated ONLY by their State,
and facilities which generate hazardous wastes ONLY as the result of hazardous waste processing should answer
NO to this question.]
  |	| YES~> Complete:
              Go to 2.

  |	| NO->  Go to 1 A.
Form WD: Waste Description
Form PG: Primary Waste Generation
Form WM: Waste Minimization
              1 A.    During the reporting year, did this site generate quantities or types of hazardous wastes
                    subject to reporting only by this State?

                    |	| YES->  Complete:   Form WD: Waste Description
                                            Form PG: Primary Waste Generation
                                 Go to IB.

                    |	| NO->   GotolB.

              1B.    Has this site filed and not formally withdrawn an EPA Notification of Hazardous Waste
                   Activity torn (EPA Form 8700-12) indicating Generator or Small Quantity Generator?

                    |	|YES->  Complete Form RS: Regulatory Status
                             .   Go to 2.
                    |	| NO->  Go to 2.

-------
              PLACE IDENTIFICATION LABEL HERE
                          QR
                  ENTER YOUR EPA ID NO.
  Form

 RS
Regulatory
  Status
                         ENVIRONMENTAL PROTECTION AGENCY
                               Hazardous Waste Report for 1987
                                               DRAFT
                                 REGULATORY STATUS
                         READ COMPLETE INSTRUCTIONS ON PAGES	TO	
      Note:   1)   This form asks about the regulatory status of this site.
              2)   Answer §J1 questions 1 through 4 and follow any instructions associated with your answers.
              3)   All terms in Italics are defined on Page	of the instructions.
1 .   Was this sfte a generator of hazardous wastes that was NOT. flurinfl «™/ single month of the reporting year, subject to
    full RCRA regulation due to RCRA small quantity rules and exemptions?

    | _ |   YES - > Check the item that best describes your generator status during the reporting year.

           I   I   This site  met all of the requirements for a RCRA Conditionally Exempt Small Quantity Generator in
           —   every month of the reporting year, and was NOT subject to regulation under lower State quantity
                 limits.

           I   I   This site met all of the RCRA requirements for a Conditionally Exempt Small Quantity Generator in
                 every month of the reporting year, but was subject to regulation under lower State quantity limits.

                 -    Specify State quantity limit or category that applied to this site during the reporting year (see
                     page _ of instructions):  _

           | _ |   This site was a RCRA Small Quantity Generator in one or more months of the reporting year.
2.   During the reporting year, did this site generate or process wastes that are specifically excluded or exempted from
    regulation under RCRA?

    | _ |   YES - > [Check fill Items that applied during the reporting year]

           | _ |  wastes were generated or processed at this site that were delisted pripr to the beginning of the
                 reporting year.

           | _ |  Wastes were generated or processed at this site that are specifically excluded from RCRA regulation
                 (see Page xx of the instructions for list of RCRA regulatory exclusions).

           | _ |  Wastes were generated or processed at this site that are Recyclable Materials (see Page yy of the
                 instructions for list of Recyclable Materials).

     LJ   NO

-------
              PLACE IDENTIFICATION LABEL HERE
                          OR
                  ENTER YOUR EPA ID NO.
  Form
WM
  Waste
Minimization
                         ENVIRONMENTAL PROTECTION AGENCY
                              Hazardous Waste Report for 1987
                                              DRAFT
                                WASTE MINIMIZATION
                        READ COMPLETE INSTRUCTIONS ON PAGES	TO	
       Note:   1)    This form describes your site's efforts to minimize generation of hazardous wastes.
              2)    Answer every question as ind icated.
              3)    All terms in /te//cs are defined on Page	of the instructions.
1.   Does this site have a written statement which outlines goals, objectives and practices of waste minimization?
    |	|  YES
          NO
2.   In the past two years, has this site conducted a waste minimization assessment that identifies ways to reduce
    volume of waste generated?
    |	|   YES
          NO
3.   Were any of the recommendations made in the waste minimization assessment implemented?
    LJ  YES
          NO
4.   Does this site have employee training or incentives programs to encourage the identification of new ways to
    minimize the generation of hazardous waste?
    LJ  YES
          NO
5.   Has this site utilized the services of a Waste Exchange or a Waste Broker to minimize the amount of hazardous
    waste to be treated, stored, or disposed?
    |	|   YES
    LJ   NO

-------
          PLACE SITE IDENTIFICATION LABEL HERE
                       OR
                ENTER YOUR EPA ID NO.
                                   ENVIRONMENTAL PROTECTION AGENCY
                                        Hazardous Waste Report for 1987
                                                        DRAFT
                                           WASTE  DESCRIPTION
                                                        Form
                                                      WD
                                                        Watte
                                                       Description
                                                                                                             Page
                                          READ COMPLETE INSTRUCTIONS ON PAGES	TO	
    NOTE:  1) This form should list ALL hazardous waste streams generated, processed, shipped off site, or received from oft site during the reporting year.
          2) If this site does not process any hazardous wastes then columns E to H need not be completed.
          3) Form accepts 12 pitch type.	
1
A. DMcriptlonofWnt*
  mVttUGuOft rfr
B. EPAHamtoui
  WmtaNo.
 Instnjction Pff. _
                                                  I  I  I  I  I I  I  I
                                                                         c.
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                                                                      WHO Cod*
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                                                                                            PROCESSING FACtUTlEa ONLY
   r.
aiUp*r pound
                                                                                               1  1  1  1  1
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 H.
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WMr
                                                                                                   1  1  1
                                                        i  1
_ v^uai
                                                    i  i i 1

 COMMENTS (Refer to specific line numbers)

-------
          PLACE SITE IDENTIFICATION LABEL HERE
                       OR
                ENTER YOUR EPA ID NO.
                                                       ENVIRONMENTAL PROTECTION AGENCY
                                                            Hazardous Waste Report for 1987
                                                                            DRAFT

                                                             PRIMARY GENERATION
                               Form
                              PG
                                                                                                              Primary
                                                                                                             Generation
                                                                                                            Page_
                                          READ COMPLETE INSTRUCTIONS ON PAGES	TO	
    NOTE:  1) hi Section I dmerllM • process (or processes) that generates hazardous wastes from primary sources.
          2) In Section II Net the hazardous wastes that reauH from the process described In Section I.
          3) Use the Waste Reference column to Indicate the page and line number of Form WD on which you have described the waste.
          4) Form accepts 12 pHch type.
     MA.  Process Description:
        tuftucltan ftp* _
8  SEaS?00^  .  t	i  ... .   i  11
                                                                             C. Production Ratio
                                                                                                          \  |
II
                   B. MponlngVMf Quantity
                        (1M7)
                      •TttftUCOOfl rtQ9
                                         C. Prartoui ₯**r Quantity
                                             fl*lf)
                                            Instruction ftg* _
r. i
 H.
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  Cod*
                                                                        D
    J,L_L_L_I1L
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                                      I  I  I  I
        l  i  I
                                                                  DSK  D-
                                                                                           i l  i  l  l
COMMENTS (Refer to specific section and item)

-------




ENVIRONMENTAL PROTECTION AGENCY Form
PLACE SITE IDENTIFICATION LABEL HERE .. . ... . „ _m. m ..__-.
QB Hazardous Waste Report for 1987 f\ \
ENTER YOUR EPA ID NO. \J 1
DRAFT
Off-She
| , , , , , ., , . , , , | OFF-SITE IDENTIFICATION ld"""lea'fc>n
Page
READ COMPLETE INSTRUCTIONS ON PAGES TO
NOTE: 1) This foim should list ALL transporters iiMd and ALL off-site Installations to which you shipped or from which you received hazardous wastes
during the reporting year.
2) Address Information may be omHted for transporters ONLY.
3) Form accepts 12 pitch type.
UlM
No.
1
2
3
4
5

ln**ucVonP*Qf _
1 	 1

1 	 1

1 	 1

1 	 1

1 	 1

a
81*
tn»
1*_
L_l
L_l
L_J
LJ
L_J
c.
Itatat
Iff-
L_l
L_J
L_J
LJ
l_l
D. HMM Mid AddraM IntoniuAtan
BUttULDOn rUQ9
NAME
HUUKtttB
CTfY BIHIE! Zlr CODE _
1 1 1 J 1 1 l~ I 1 1 J

NAME
ADDRESS
MiV BIAICI xirumic
1 1 1 1 1 1 l~ 1 1 1 I
NAME
ADDfatas
CITV m Aiti AIP CUDfe

NAME
ADDHESa
QTV BIAIK! cIPCUDE
i i i i i i r i i i i

HABlt
ADDRESS
errv "' siAiii^ii'uuut
i 1 i i i i ~ i i i i











-------




PLACE SITE IDENTIFICATION LABEL HERE
SB
ENTER YOUR EPA ID NO.
1 	 I

NOTE: 1) Thl
2) Uw
3) Foi
UM
No.
1
2
3
4
5
A.
FatrnWD
WMtoMMMM
»"*•_
UlM | 	 |
Peg*
Urn 1 1
P«0*
1 1 1 1 1
Urn | 	 |
Pagt
1 1 1 1 1
Urn | 	 |
Pig*
1 1 1 1 1
Urn | 	 |
P.8*
1 1 1 1 1
• form should list ALL hazardous waste s
in accepts 12 pltcn typo.
a. FMimyEPAiDNo.
In&ucHon ftg> IM
l 	 i

I 	 i

i 	 i

i 	 i

i 	 i

ENVIRONMENTAL PROTECTION AGENCY
Hazardous Waste Report for 1 987
DRAFT
WASTE SHIPPED OFF SITE
READ COMPLETE INSTRUCTIONS ON PAGES 	 TO 	
(reams shipped off she during the reporting year.
the page and line number of Form WD on which you have described the waste.

frtsfrucffon 4*49*
1 1 1 1 1 1 1 !• 1 1 1

1 1 1 1 1 1 1 Im 1 1 1

1 1 1 1 1 1 1 1. 1 1 1

1 1 1 1 1 1 1 !• 1 1 1

1 1 1 1 1 1 1 ll 1 1 1
•
D.
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**_
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i i i»i i i
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a.
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U«MMl
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LJ
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LJ
LJ
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H.
No. erf
•tilpnwnt*
»*_
1 1 1 1

1 1 1 1

11(1

1 1 1 1

1 1 1 1

1.
Tranipwt
Modi
»*_
1 1 1
1 1 1
1 ' '
' ' '
1 1 1
Form
SO
Shipped
Off Site
Page

J.
Traiwport
CMlMlMI
»*_
• ' '
1 ' '
I 1 1
1 1 1
1 ' '
K.
on-siM
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i i i i
i i i i
i i i i
i i i i
i i i i
.1.1
i . . i
i i i i
i i i i
i i i i
COMMENTS (Refer to specific line numbers)

-------





PLACE SITE IDENTIFICATION LABEL HERE
QR
ENTER YOUR EPA ID NO.
1 	 	 1

NOTE: 1) Th
2) Uft
3) Fo
UM
No.
1
2
3
4
5
A.
FormWD
WMt.fMMvM.
P*»_
UM 1 1
Pig*
1 1 1 1 1

UM | 	 |
Pig*
1 1 1 1 1

UM | 	 |
Pig.
1 I.I 1 1

UM | 	 |
Pig.

UM | 	 |
Pig.
1 1 1 1 1
• form should list ALL hazardous watts s
ft MIA Wftftte HatoMiif A dvJi mill M liui^ftfM
rm accepts 12 pitch type.
B. OMMntorCPAtDMo.
•TMaTUCVOn r9Qt
\ 	 1

1 	 1

1 	 1

1 	 I

1 	 1

ENVIRONMENTAL PROTECTION AGENCY , -...,
Hazardous Waste Report for 1987 p Q
DMFT
WASTE RECEIVED FROM OFF SITE " °"8"*""

Paoe
READ COMPLETE INSTRUCTIONS ON PAGES 	 TO 	
treama received from off sKe during the reporting year.
the page and Hrw number of Form WD on which you have described the watt*.

(wLiJCOOf) rt^9
1 1 1 1 1 1 1 !• 1 1 1

1 1 1 1 1 1 1 !• 1 1 1

1 1 1 1 1 1 1 !• 1 1 1

1 1 1 1 1 1 1 1. 1 1 1

1 1 1 1 1 1 1 !• 1 1 1

D.
UOM
**_
L_l
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mttvilCoQfl r9Q9
I I I i I i I ii i I i
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I I I i I i I II i I i
I I I ii I I II | I I

i i i i i i i i i i i i
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1 1 1 1

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1 1 1 1

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COMMENTS (Refer to specific lino numbers)

-------
           PLACE SITE IDENTIFICATION LABEL HERE
                         OR
                 ENTER YOUR EPA ID NO.
                                                               Form

                                                             PS
                                                              Process
                                                             Summary
                                                                                         Page
                        ENVIRONMENTAL PROTECTION AGENCY
                              Hazardous Waste Report for 1987
                                                DRAFT
             WASTE MANAGEMENT PROCESS SUMMARY
                             READ COMPLETE INSTRUCTIONS ON PAGES	TO.
1. Complete one copy of this 2 elded form to describe each hazardous watte treatment proet
2. If tiie process type Is STORAGE, complete sections A, B and F.
3. If the process type Is TREATMENT IN SINGLE UNTO, complete sections A, C and F.
4. If the process type Is TREATMENT IN UNITS IN SEQUENCE, complete sections A. D and F.
5. If the process type Is LANDFILL, complete sections A, E and F.
6. This form accepts 12 pttch type.
                                       t at this she.
A  Describe the process.
                         OPMMMUI
   Capacity for STORAGE Is the total capacity at the end of the year of all tanks, Impoundments, waste piles,
   or container storage areas.
    Capacity Is to be measured In weight (pounds, tons, kilograms, metric tons) units.
    i/vtrucbon PA^V
   Capacity In IM7
            I	I
                       I   I  I
                               WL
   Capacity for TREATMENT IN SINGLE UNITS Is the flow through the system In the time specified.
    Capacity Is to be measured In weight (pounds, tons, kilograms, metric tons) units.
    «UaViJCftGf) rBffO
   AnniMl Capacity
                 I	I
I Hr. Shift Capacity
                                                I a
UOM
WL
                                                                Number ol Until
   Capacity for TREATMENT IN UNITS IN SEQUENCE Is the How through the system In the time specified.
    Capacity!* to be measured In weight (P, T, K, M) or volume (G, L) unit*. Specify the density If volume units are used.

   i   i   i
                               t Hi. Sum Capacity
                                                           UOM
                                  Danalty
                                                                                       Unit   Numbaret
   Capacity for • LANDFILL Is the total remaining capacity for waste excluding dally and final cover at the END of the year.
    Capacltyls to be measured In weight (pounds, tons, kilograms, metric tons) units.
         *
   Remaining Capacity, and at ISST
   I   I   I  I  I   I   I   I  I  I
                                     I   I  I   I
                                                [OVER]

-------
+*+*
          National Governors' Association                              wuciinton
                                                                           Governor of Arkansas
                                                                           Chairman

                                                                           Raymond C Scheppach
                                                                           Executive Director
                                        APPENDIX B

                   Instructions to the  1987  Biennial Report Draft Forms
            HALL OF THE STATES • 444 North Capitol Street • Washington, D.C. 20001-1572- (202) 624-5300

-------
                                         DRAFT

                       ENVIRONMENTAL PROTECTION AGENCY
                             Hazardous Waste Report Tor 1987

                                   General Introduction
      The Hazardous Waste Report for 1987 consists of ten separate forms, as follows:

      1)    FORM 1C — IDENTIFICATION AND CERTIFICATION

      2)    FORM FS — FORM SELECTION

      3)    FORM RS — REGULATORY STATUS

      4)    FORM WM  -  WASTE MINIMIZATION

      5)    FORM WD — WASTE DESCRIPTION

      6)    FORM PC — PRIMARY WASTE GENERATION

      7)    FORM OI ~ OFF-SITE IDENTIFICATION

      8)    FORM SO — WASTE SHIPPED OFF SITE

      9)    FORM RO ~ WASTE RECEIVED FROM OFF SITE

      10)    FORM PS — WASTE MANAGEMENT PROCESS SUMMARY


      Only two of these  forms, Form 1C and Form FS, must be completed by every recipient of
the Hazardous Waste Report.  Site identification information is obtained on Form 1C.  Form FS
includes questions  about the hazardous waste activities of a site and  indicates  which additional
forms must  be completed.   The titles of the remaining forms are suggestive of their contents,
and detailed descriptions and  instructions for each are included in the pages which  follow.
Each form  also includes a brief instruction box on the form page(s), and there are instruction
page references associated with individual items.  Any remaining questions can be addressed to
the Hazardous Waste Report Hotline at (800)	-	.

      Consistent with  recently passed  legislation concerning hazardous  wastes, there  are some
new areas of emphasis in the Report.  These include:

      1)     Waste  Minimization.   There  is  a questionnaire  (Form WM) which  asks some
            generators of hazardous wastes about their overall efforts to minimize  the quantity
            and  toxicity of  the  wastes  they generate.    In  addition.  Form  PG requests
            information relating to efforts at waste minimization for individual waste streams.

      2)     Waste  Management Processes.   For  the  first  time,  the  Hazardous Waste  Report
            requests detailed  information about  processes used to treat, store, or dispose  of
            hazardous  wastes.   Information  about capacity,  influents,  effluents,  commercial
            availability, and planned changes in capacity or operating status is requested.

-------
      3)    Waste Description.  Some additional information about the character  of hazardous
           wastes is solicited.  In recognition of their superior knowledge of the  chemical and
           physical characteristics of wastes, more detailed questions are asked of processing
           facilities than of simple generators.

      4)    Special  Forms for Special  Purposes.   Items which  had been thrown together  on
           single forms are sometimes relegated to separate pages. For  instance,  all hazardous
           wastes  are  described on  Form WD, and  reference  is made  to  the page and line
           number of  Form WD when indicating where that waste came from and  how it was
           handled.  There  is also  a separate  page to provide  the  names  and  addresses  of
           transporters and external sites (Form OI).   This approach  reduces redundancy and
           should minimize the total amount of  paper to be processed.

      The  sections which follow  provide detailed  instructions  for each of  the  forms in  the
Report package.  To summarize quickly:

      1)    Start by completing Form 1C — Identification  and Certification and Form FS  --
           Form Selection.

      2)    Follow the  instructions associated with  your answers to the questions on Form FS to
           determine which  other forms in the package must be completed and included in
           your site's submission.

      3)    Detailed  instructions are included in this  booklet, and there are brief instruction
           boxes and item by item instruction references on the individual forms.

      4)    If an item or question remains unclear after reviewing the  available instructions,
           call the  Hazardous Waste  Report Hotline at (800)

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                               INSTRUCTIONS FOR COMPLETING

                                           FORM 1C

                        IDENTIFICATION  AND CERTIFICATION
I.     INTRODUCTION

      Form 1C, Identification and Certification, is intended primarily to confirm information on location,
      mailing  address, EPA ID number,  and  contact person  for  your site.   In  addition,  it  requests
      information  on the Standard  Industrial  Classification  (SIC)  codes at  your  site  associated  with
      hazardous waste activities, and asks about numbers and  capacity of tanks for non-permitted, short-
      term accumulation  of  hazardous  wastes.  This form is  to be  completed by every  recipient of the
      Report Package.


II.    FORM COMPLETION INSTRUCTIONS

      Site Identification Label/EPA  ID

      Attach one copy of the preprinted site identification label, if  provided, in the upper left corner of
      the form.  If no site identification labels are provided, enter your EPA ID in  the upper left corner
      of the form.

      Question 1

      Read the preprinted site  identification  label,  if provided, and verify that the site  location address
      and EPA ID  number are correct.

      •    If correct, check the "YES" box and go to Question 2.

      •    If incorrect, check the "NO" box, enter  the correct information in the space provided, and go
           on to Question 2.

      Question 2

      Enter the name of the  county  in which the site is located, and  go to Question 3.

      Question 3

      Enter the full  name, title and phone number of the person to be contacted  if there are questions
      regarding information provided in the Hazardous Waste Report submitted by your site.

      Question 4

      Check the mailing address on  the envelope in which this package was mailed.

      •    If the  mailing address is identical to the site identification label, check  the box on line 4 and
           go on to  Question 5.

      m    If the  mailing label on  the envelope is not available, enter the  mailing address in the  space
           provided.

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FORM 1C INSTRUCTIONS (Continued)
      •    If the mailing address and  the site identification label  address are  not  identical,  but the
           information provided  on the mailing label  is  correct,  check the "YES" box  and go  on to
           Question 5.

      •    If the information on the mailing label is incorrect, check the "NO"  box, enter  the correct
           information in the space provided, and go on to Question 5.

      Question 5

      Enter the Primary and Secondary Standard Industrial Classication Codes for your site which describe
      the hazardous waste activities undertaken.

      Question 6

      Read the definition  for "accumulate" provided on page	.

      •    If your  site  accumulates  hazardous  waste in  tanks, check the "YES"  box.   In the  space
           provided, enter the number of tanks on site available for accumulation  and  their total capaicty
           in gallons.

      •    If your site does not accumulate hazardous waste in tanks, check the "NO" box.

      Certification

      •  . Check carefully  that  all forms  required for  your submission are  present,  complete,  and
           correct.

      •    Type or print your name, title, and the date.

      •    Sign the  form and mail the completed package to the address below:

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                              INSTRUCTIONS FOR COMPLETING


                                          FORM FS

                                    FORM SELECTION
      Form FS, Form  Selection, is a series of questions intended to  determine which forms within  the
Hazardous Waste Report Package must be completed for your site.   The questions have been  carefully
worded to coorespond  to regulatory requirements.  Next to the answers for each question are instructions
on which forms must be completed and which question to answer next.  This form must be completed bv
every recipient of the Hazardous Waste Report Package.  Note the following key features of this form:

      •     Key terms which require definition are printed in italics.  The full definitions of these terms
           are found starting on page	.

      •     At the end of the second page of the form is a Form Checklist on which you should indicate
           all of the forms which are to be completed and included in your site's submission.

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                               INSTRUCTIONS FOR COMPLETING


                                          FORM RS

                                 REGULATORY STATUS
      Form  RS, Regulatory Status, consists  of  a series  of questions about your site's  hazardous waste
activities. This form need be completed only by those sites directed to do so by Form FS.  In most cases,
those will be sites which are not required  by  EPA to provide detailed quantity reporting as a generator or
as a facility, although  States may still  require submission of a full report.  The  questions are carefully
worded to correspond to regulatory provisions. They should be read with care, and instructions associated
'with the answers should be followed.  Key terms which require definition are printed in  italics.  The full
definitions of these terms are found starting on page	.

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                             INSTRUCTIONS FOR COMPLETING


                                       FORM WM

                               REGULATORY STATUS
     Form  WM,  Waste  Minimization, consists  of a series of ten questions about your  site's efforts to
minimize the generation of hazardous waste.  This  form need be completed only by those  sites which
generate regulated quantities of  hazardous waste from primary sources, as indicated by an  affirmative
answer  to Question 1 of Form FS, Form Selection.

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                               INSTRUCTIONS FOR COMPLETING

                                          FORM WD

                                  WASTE DESCRIPTION
I.     INTRODUCTION

      Form WD, Waste Description, is the cornerstone of the entire Hazardous Waste Report.  It provides
      the detailed  description  of  the  hazardous  waste  streams which are then  referenced on the other
      forms  in  the package.  For example, if a waste is shipped off site, information on the quantity,
      destination, and  expected  management methods will  be  found  on  Form SO.   However,  the
      description of that waste stream will be on Form WD, and  there will only be a Form WD page  and
      line reference on Form SO to indicate which waste is being  shipped  off site.

      Form WD requests a narrative description of the waste  stream, one or more EPA Hazardous waste
      numbers,  a 3-digit A/B waste code (indicating the physical/chemical  form of the waste),  and an
      indicator  of  the  regulatory  status of the waste.   In  addition,  waste processing  facilities only are
      asked to provide the pH, BTU per pound, percent solids, and percent water of the waste.

      In  case more space is required to complete  the  narrative description or the  full list of  EPA
      Hazardous Waste number, the description may be continued on  the  line below, after placing an "X"
      in the  "check if continued" box.

      Pages must be numbered in sequence and care taken  to cite Form WD waste references accurately.
      Failure to do so will make it impossible to determine  which wastes are  being described on the other
      forms  in the  Report.


II.    FORM COMPLETION INSTRUCTIONS

      1.    Site Identification Label/EPA ID

           Attach one copy of the preprinted  site identification label,  if  provided,  in  the  upper  left
           corner of  the form.   If no site identification labels are provided, enter your EPA ID in the
           upper left corner of the form.  Only two copies of the form  are provided  in the package.  If
           you need to reproduce the form,  attach the site identification label OJ& enter your site's EPA
           ID  number before making copies.

      2.    Page Number

           Enter the page number in the appropriate box on  the top  right corner  of the  form.   For
           example, if five copies of Form WD are required to list all of the wastes referenced anywhere
           in the Hazardous Waste Report, then the forms are to be numbered  1 through 5.

      3.    Waste Stream Related  Information

           Complete  Sections A  through H  for each waste  or waste stream  if you are a  Processing
           Facility.   Complete only Sections  A through D if your site  receives, ships or generates
           does not process any hazardous waste.

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WD INSTRUCTIONS (Continued)
     Use a separate line entry for each waste or waste mixture.  If more than one line is required
     to identify  and describe a waste stream,  continue on the  next line and place an "X" in the
     space immediately before the "check if continued" box.

     A.    Description of Waste

          •     Enter the USEPA  listed  name, abbreviated  if necessary,  of  hazardous wastes
                listed under 40 CFR Part 261, Subpart D.  If the waste stream  is a mixture of
                listed wastes, enter the  description which best describes the waste mixture

          •     For  unlisted  hazardous  wastes  identified  by  characteristic  (e.g.,  ignitable,
                corrosive, reactive, or  EP  toxic) under  40  CFR Part 261,  Supart C, enter the
                following:

                     The description  from the list of characteristics which best describes the
                     waste; and

                     The chemical or generic chemical name of the waste.

                Example:
     B.    EPA Hazardous Waste Number

          •     Enter the 4-character USEPA Hazardous Waste Number for listed wastes from 40
                CFR Part 261, Subpart D which identifies the waste.

          •     Enter the 4-character USEPA Hazardous  Waste Number of  unlisted wastes  from
                40 CFR Part 261, Subpart C that identifies the waste.

          •     Enter all of the  relevant USEPA Hazardous  Waste  Numbers,  if the waste  is a
                mixture of more than one listed or unlisted waste.  If the waste mixture has  more
                than 4 USEPA Hazardous Waste Numbers, continue on the next line and place an
                "X" in the space immediately before the "check  if continued" box.

                Example:
     C.   3-DJgit A/B Waste Code  —  Enter the 3-digit A/B Waste Code that  best describes the
          waste or waste mixture entry. The A/B Waste Codes are listed on Page	.

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ORM WD INSTRUCTIONS (Continued)
          D.    Regulatory  Status  —  Enter  the  Regulatory  Status  Code  for  each  waste  entry.
                Regulatory Status Codes are listed below.

                   Code           Regulatory Status

                     R   	 Waste is  RCRA Regulated
                     S    	 Waste is  ONLY State Regulated
                     £   	 Waste is  exempt (neither RCRA or State Regulated)

          E.    oH — Enter the pH of the  waste entry.

          F.    BTU per Pound —  Enter the BTU per pound, for the waste entry.

          G.    % Solids — Enter the percentage of solids for the waste entry.

          H.    % Water — Enter the percentage of water for the waste entry.

    4.    Comments

          This space  may be used to explain, clarify, or continue  any entry.  If used, cross-reference
          the comment  by entering  in the appropriate Section and line number.
                                                 10

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                                INSTRUCTIONS FOR COMPLETING


                                            FORM  PG

                                  PRIMARY GENERATION
I.     INTRODUCTION

      Form  PG  —  Primary Waste  Generation.  Consistent with a new emphasis on waste  minimization.
      Form  PG is structured to associate a waste stream with the process which generated it. Information
      is requested  on the quantity  both this year and last, and on what factors might account for any
      differences between the  two.

      The term  primary  waste  generation is  used here  to distinguish between  wastes resulting  from
      production, service,  or  other processes  or  one  time events,  and  wastes  which result  from the
      treatment,  storage, or disposal of  previously existing hazardous  wastes.  This latter  group, wastes
      resulting from the treatment,  storage, or disposal of previously existing  hazardous wastes, are not to
      be described on this form—they are described on Form PS.

      Form PG is divided into two sections.

      Section I provides a description of  the primary generation  process  which produced one or  more
      waste  streams.   This could  include anything  from an electroplating process  to  a  dry cleaning
      operation to an air pollution control  device to a spiil cleanup.  Ideally,  a single process is described
      in Section  I,  with  its resulting  waste streams listed  in Section II.  It is recognized,  however, that
      existing record keeping may not make it possible to indicate what quantity of a waste  resulted  from
      a  single process.   In such  cases Section I would  describe  the two or more  processes which
      collectively produced the waste streams described in  Section II of the form.  Item A should include
      a detailed narrative description of the process or processes responsible for the  waste stream(s).  Item
      B  lists the  Standard Industrial Classification (SIC) code(s) associated with that  process;  while Item C
      indicates the production  ratio  associated with that process or processes.

      Section II  provides detailed  descriptive information about individual  waste  streams which  result
      from the process or processes described in Section I.  This includes  the quantity generated during
      the reporting  year, the quantity generated during the previous year, UOM and density, the detailed
      source and management sequence  of the  waste, an indicator of changes in toxicity, and a  code
      indicating what efforts were undertaken to minimize  generation.

      If more than three wastes are generated by the process or processes described  in Section I, complete
      a  second  copy  of the Form  PG  on which Section I information is repeated  and the additional
      streams are described.
                                                    11

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'ORM PG INSTRUCTIONS (Continued)



II.    FORM COMPLETION INSTRUCTIONS

      Site Identification Label/EPA ID

      Attach one copy of the preprinted site identification label,  if provided,  in the upper left corner of
      the form.  If no site identification labels are provided, enter your EPA  ID in the upper left corner
      of the form.  Only two copies of the form are provided in the package.  If you need to reproduce
      the form,  attach the site identification label QR  enter your site's  EPA ID number before making
      copies.

      Page Number

      Enter  the page number in the appropriate box on  the top right corner of the form.  For example, if
      five copies of Form PG are required to list all of. the primary waste generation  processes, then  the
      forms  are to be  numbered 1 through 5.


      Section I

      A.    Process Description

            •    Enter the process that generates  the  primary  hazardous waste in  Section IA.  Include
                 one-time  events  and  spill  cleanups.    If  your site has more  than one  process  that
                 generates  primary hazardous waste, you  must complete a separate form for each process.

            •    If you are unable to break down waste stream quantities by  processes that generated  the
                 waste stream, you  may  enter a  group  of processes in Section IA.   Indicate in  the
                 "Comments" section  that these processes are different  and your reasons for grouping
                 them together.

                 Example:
      B.    Process SIC Codefai

            •    Enter in Section IB the Process SIC Code(s) for the process described in Section I A.

            •    If there are no SIC code(s) that describe the process, check the "Not App." box.
                                                     12

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FORM PG INSTRUCTIONS (Continued)
      C.    Production Ratio

            (This description and instruction has been taken from  the  1986  New Jersey Hazardous Waste
            Generator Waste Minimization Report.)


            The Production Ratio =

            Measure of Production in 1987
               (gallons, tons, pounds)            =»     420 units produced    m    20
            Measure of Production in 1986              210 units produced
            (units of production, sales dollars)

            Points to consider when computing waste generation on a unit basis:

            a.    Report wastes separately  that  were not generated in the  course of normal operations
                 (e.g.,  spill wastes).

            b.    The production unit should be applicable to  your operation.  If units of production are
                 not applicable, then use sales dollars.

            c.    Once you select a unit of production, it must remain the same in ALL future reporting
                 years.

            d.    You are responsible for properly  computing  your firm's  waste  generation  in terms of
                 production units.  Amounts of  manifested wastes may be used if the units of production
                 are propertly applied to the period for which those wastes  are generated.


            •     Using the  above formula,  calculate  and enter  the  Production Ratio for  the  process
                 described in Section IA.

            B     For processes where the Production Ratio cannot be calculated, as in the case of one-
                 time events like spill cleanups,  check the "Not App." box.


      Section II: Waste  Stream Related Information

      Complete Sections  A through I for each waste or waste mixture.  Enter each waste stream on a new
      line.

      A.    Waste  Reference — Enter the line and  page number from Form WD on which the waste or
            waste mixture is described.

      B.    Reporting Year Quantity (1987) — Enter the total quantity of the waste stream generated by
            the process described in Section IA during calendar year 1987.

      C.    Previous Year  Quantity H986) — Enter the  total quantity of the waste stream generated by
            the process described in Section IA during calendar year 1986.
                                                    13

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 FORM PC INSTRUCTIONS (Continued)
       D.    Unit of Measure (UOM) — Enter the  UOM code  for the quantity of waste entry.  Quantities
                   be reported in the units of measure listed below.
                       Code
  Unit of Measure
                          P    	   Pounds
                          T    	   Short tons (2,000 pounds)
                          K    ...	   Kilograms
                          M    ..	   Metric tonnes (1,000 kilograms)
                          G    	   Gallons
                          L    	   Liters

       E.    Qgnsjtt — If gallons or liters are used as  the UOM, enter the density.  Provide the density in
             pounds per gallon (Ibs/gal) or specific gravity (sg).  Check the appropriate box.

       F.    Management Sequence  — Enter the sequence of 3-digit management codes that best describes
             the management process for the waste or waste mixture entry.- The management process codes
             are listed on page	.

       G.    Source  Code — Enter  the 3-digit source  code that best describes the source  of the waste  or
             waste  mixture.   The  appropriate  source  code  would  be  a specific  stage  in  the process
             described in Section IA that resulted in the generation of the waste stream.  A list of possible
             source codes follow.
WASTE SOURCE CODES

Cteamng/DegiMaing Processes
SOI  Stripping with corrosives
S02  vapor degreasing
SOS  Steam cleaning
S04  Dip nnsing
SOS  Rush nnsing
SOS  Pill and gravity draining
S07  Backflush nnsing
S08  Physical scraping/removal
SOS  Pickling
S10  Other cleaning/degreasing process
     (specify m the answer space
     provided)

Production Processes
C11  Light ends condensation
S12  Heavy ends removal
S13  Reaction/synthesis media processing
S14  Crystallization
SIS  Slag removal
S18  Bottoms removal
S17  Molding/forming
S18  Byproduct processing
S19  Improper formulation
S20  Other production processes (specify
     in the answer space provided)

One-Time or Sporadic Processes)
S21  Discarding of off-spec material
S22  Discarding of out-of-date products or
     chemicals
S23  Discarding of spent or used product
     (not including spent or used solvents)
S24  Cleanup of spill residues
S2S  Cleanout of treatment impoundment
S26  Closure of lagoon
S27  Closure of process equipment
S2S  Discarding of contaminated cleanup
     equipment
S29  Other remedial action/cleanup (spea-
     fy m me answer space p/ov/aeo)
S30  Other one-lime or sporadic processes
     (specify m Me answer space provided;
Pollution control or waste; treatment
processes
S31  Flue gas desulfunzation
S32  Caustic scruDOing
S33  Bectrostnnc precipitation
S34  Condensate from VOC removal
S3S  Filtering/screening
S36  Oewatenng
S37  Regenerating
S38  pH adiustmem
S39  Quench cooling
S40  CentnfugaMn
S41  Incineration
S«2  Wastewater treatment
S43  Onnking water treatment
S44  Distillation
S4S  Rotation or skimming
£46  Oecantation or settling
S47  Other pollution control or waste treat-
     ment process (specify in tne answer
     space p/ovK»oV
                                                    14

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'ORM PG INSTRUCTIONS (Continued)
      H.   Toxicitv Change — Enter the Toxicity Change code that describes the change in  toxicity  of
           the waste stream from calendar year 1986 to 1987.  Toxicity Change codes are listed below.

                     Code           Toxicitv Change

                       I     	    Increase in toxicity
                       D    	    Decrease in toxicity
                       N    	    No change in toxicity

      I.    Reduction Code  —  Enter the Reduction Code  from the list below that  described the  waste
           minimization methods applied to the waste or waste mixture. Reduction Codes 8 through  12
           require an explanation in the "Comments" section.  .

                       01    	    Recycling (reuse) on site
                       02    	    Recycling (reuse) off site
                       03    	    Equipment/technology modifications
                       04    	    Process procedure modifications
                       05    	    Reformulation/redesign  of product
                       06    	    Substituting raw materials
                       07    	    Improved  operations due to housekeeping/training/inventory control
                       08    	    Increase in waste/unit product and decrease in toxicity
                       09    	    No change
                       10    	    Increase in waste/unit product, no  change or increase in toxicity
                       11    	    One-time  spill or corrective action cleanup
                       12    	    Miscellaneous


      Comments

      This space may  be used to explain,  clarify,  or continue any entry.   If  used, cross-reference the
      comment by  entering  in the appropriate Section and  line  number.
                                               15

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                               INSTRUCTIONS FOR COMPLETING


                                           FORM 01

                               OFF-SITE  IDENTIFICATION
I.     INTRODUCTION

      Form OI, Off-Site Identification, is to be used to provide name, address, site type, and relationship
      information on all external sites which transported, shipped or received hazardous waste to or from
      your site.  Site type refers to whether the external site is a generator from which your site received
      waste, a facility to which you sent waste, or a waste transporter.  Site relationship indicates whether
      the external site is a corporate relative or an  independent* firm.   Note the following key features of
      this form:

      •    Any facility listed on Form SO should be represented by an entry on Form OI.  If vour site is
           required to complete  Form SO. then Form OI must be completed as well.

      •    Any generator listed on Form RO should be represented by an entry on Form OI.  If vour site
           is required to complete Form RO. then  Form OI must be completed as well.

      •    For transporters ONLY, provision  of address  information  is optional.   EPA ID number, site
           type, site relationship, and name information must still be provided.


II.    FORM COMPLETION INSTRUCTIONS

      1.    Site Identification Label/EPA ID

           Attach one copy of  the  preprinted site identification  label,  if provided, in the upper left
           corner of the form.  If no site identification  labels are provided, enter your EPA ID in the
           upper left corner of the form.  Only two copies of the  form are provided in the  package.  If
           you need to reproduce  the form, attach the site identification label OR enter your site's EPA
           ID number before making copies.

      2.    Page Number

           Enter the page number in the appropriate box on the top right corner of the form.  For
           example, if five copies  of Form OI are  required to list all of the external sites, then the forms
           are to be numbered 1 through 5.

      3.    Off-Site Installation Information

           Complete Section A through D for each off-site installation to whom  you shipped and from
           who you received hazardous wastes during the reporting period.  Complete Sections A through
           C and the name line of Section D for all transporters used to ship waste off site.

           A.    Off-Site  Installation or Transporter  EPA ID Number — Enter  the  12-digit EPA ID
                 number of  the installation to whom  you shipped  hazardous  waste  Q& from whom you
                 received hazardous waste OR the transporter who shipped  hazardous waste to or from
                 your site.   If the site  is not RCRA regulated and  does not have  an EPA  ID number,
                 write in the word "NONE" in the space.
                                             16

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ORM OI INSTRUCTIONS (Continued)
          B.    Site Tvoe — Enter the Site  Type Code for the site entered in Section  A.  Site  type
                codes are listed below.

                   Code           Site Type

                      G   	   Generator
                      F   	   Facility
                      T   	   Transporter

          C.    Site  Relationship —  Enter the Site Relationship  Code that describes the relationship
                between  you and  the site entered in Section A. '  Site Relationship Codes  are  listed
                below.

                   Code           Site Relationship

                      S   	   Same or related owner
                      D   	   Unrelated

          D.    Name and Address Information — Enter the name and address of the site entered in
                Section A.  The address need not  be completed for transporters.

     4.    Comments

          This space may be used to explain, clarify, or continue any entry.  If used, cross-reference
          the comment by entering in the appropriate Section and line number.
                                               17

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                               INSTRUCTIONS FOR COMPLETING


                                          FORM SO

                               WASTE  SHIPPED OFF SITE
I.     INTRODUCTION

      Form SO,  Waste Shipped Off Site,  is to be used to  provide  information on all  hazardous wastes
      shipped off site.  On each line item, information is requested on the quantity of a single type of
      waste shipped to a  particular facility, the time period of generation, the method  of accumulation,
      the number of shipments of that type of  waste sent, the container and method of transport, and the
      methods expected to be employed for the management of  the  waste.   Note the following  key
      features of this form:

      •     The  waste  type  is indicated by reference to  a detailed waste description  which is  to  be
           provided on Form WD, Waste Description.  If vour site is required to complete Form SO. then
           Form WD must be completed as well.

      •     The  name and address of the facility to  which the waste was sent is to be provided on Form
           OI, Off-Site  Identification.  If vour site is required to complete  Form SO. then Form  OI
           must be completed as well.

      •     It is possible  to describe wastes shipped to multiple  facilities on a single page of the form.
           For example,  if your site shipped single  waste types to each of five different facilities, all of
           these waste shipments could be described on one copy of Form SO.


II.    FORM COMPLETION INSTRUCTIONS

      1.    Site Identification Label/EPA ID

           Attach one copy  of  the  preprinted site identification label, if provided,  in the  upper left
           corner of the  form.  If no site identification labels are provided, enter your  EPA ID  in the
           upper left corner of the form.  Only two copies of the form are provided in the package.  If
           you need to reproduce  the form, attach the site  identification label QR. enter your site's EPA
           ID number before making copies.

      2.    Page Number

           Enter the page number in the appropriate box on  the  top right corner of the  form.  For
           example, if five copies of Form SO are required to list all of the wastes shipped off site, then
           the forms are to be numbered 1 through  5.

      3.    Waste Stream  Related Information

           Complete Sections A  through K for each waste or waste  mixture entered.  Use a separate line
           entry for each waste or waste mixture.

           A.    Waste Reference  — Enter the line and page number from Form WD on which the waste
                 or waste mixture is described.

           B.    Facility  EPA ID Number—  Enter the   12-digit  EPA  Identification  Number of the
                 facility to whom the waste or waste mixture was shipped.

                                               18

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FORM SO INSTRUCTIONS (Continued)
           C.    Quantity Shipped — Enter the quantity of the waste or waste mixture shipped during
                 the reporting 'year.

           D.    Unit of Measure (UOM) — Enter the UOM  Code for the quantity of  waste  entry.
                 Quantities can be reported in the units of measure listed below.

                    Code           Unit of Measure

                      P    	   Pounds
                      T    	   Short tons (2,000 pounds)
                      K   	   Kilograms
                      M   	   Metric tonnes (1,000 kilograms)
                      G   	   Gallons
                      L    	   Liters

           E.    Density — If gallons or liters  are used as the UOM, enter the density.  Provide the
                 density in  pounds per gallon (Ibs/gal) or specific gravity (sg).  Check the appropriate
                 box.

           F.    Time Period  — Enter the Time Period Code for each waste  entry.  Time Period  Codes
                 are listed below.

                    Code           Time Period

                      L    	   Generated in previous years and shipped  this year
                      P    	   Generated and shipped this year

           G.    Accumulation Method —  Enter  the method by which the waste or waste mixture was
                 accumulated  prior to shipment.  [Accumulation,  which differs from permitted storage,
                 is defined in  detail on page	.]  Accumulation Method Codes are listed below.

                    Code           Accumulation Method

                      C    	   Containers
                      T    	   Tanks
                      N    	   Not Accumulated

           H.    Number of Shipments — Enter the number of shipments (waste manifests) of that waste
                 type that were sent to the facility.

           I.     Transport Mode — Enter the Transport  Mode Code used to ship the waste or  waste
                 mixture. Transport Mode Codes are listed below.

                     Code          Transport Mode

                      01   	   Dump Truck
                      02   	   Tank Truck
                      03   	   Train
                      04   	   Pipe Line
                      05   	   Ship
                      06   	   Air transport
                      07   	   Other, Specify in "Comments"
                                              19

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FORM SO INSTRUCTIONS (Continued)
           j.     Transport Container — Enter the Transport Container Code in which the waste or waste
                 mixture was stored during shipment to the facility.  Transport Container Codes are
                 listed below.

                     Code          Transport Container

                      DM  	  Metal drums, barrels, or kegs
                      DW  	  Wood drums, barrels, or kegs
                      DF   	  Fiberboard or plastic drums, barrels, or kegs
                      TP   	  Portable tanks
                      TT   	  Cargo tanks (tank trucks)
                      TC   	  Tank cars
                      DT   	  Dump  trucks
                      CY   	  Cylinders
                      CM  	  Metal boxes, cartons, or cases
                      CW  	  Wood boxes, cartons, or cases
                      CF   	  Fiber or plastic boxes, cartons, or cases
                      BA   	  Burlap, cloth, paper, or plastic bags
                      OT   	  Other, Specify in "Comments"

           K.    Off-Site Management Codes — Enter the Management Process  Code that you believe
                 will be used by the facility receiving the waste or waste mixture entered.  Management
                 process codes are listed below.

                     Code          Off-Site Management Process

                      C01  	  Burning in boiler
                      C02  	  Recovery/reclamation
                      C03  	  Incineration
                      C04  	  Landfill
                      COS  	  Surface impoundment
                      C06  	  Underground injection
                      C07  	  Discharge to POTW
                      COS  	  Discharge to surface water under NPDES
                      C09  	  Discharge to privately-owned wastewater treatment works
                      CIO  	  Land application
                      Cll  	  Other, Specify in "Comments"

      4.    Comments

           This space may be used  to explain, clarify,  or continue any entry.  If used, cross-reference
           the comment by entering in the appropriate Section and line number.
                                               20

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                              INSTRUCTIONS FOR COMPLETING

                                         FORM RO

                        WASTE RECEIVED FROM OFF SITE
I.     INTRODUCTION

      Form RO,  Waste Received From Off Site, is to be used to provide information on all hazardous
      wastes received from off site.  On each line item, information is requested on the quantity of a
      single type of waste received from a particular generator, the number of shipments  of that type of
      waste received, and the methods employed for  the management of the  waste.  Note the following
      key features of this form:

      •     The  waste  type  is indicated by  reference to  a detailed waste  description which is  to  be
           provided on Form WD, Waste Description.  If  vour site is required to complete Form RO.
           then Form WD must be completed as well.

      •     The  name  and address of the generator from  which the  waste was  received  is  to  be
           provided on Form OI,  Off-Site Identification.  If vour site is required  to complete Form
           RO.  then Form OI must be completed as well.

      •     It is  possible to describe  wastes received  from multiple generators on a single page of the
           form.  For example, if your site received only one  waste from each  of  five generators,  all
           of these receipts could be described on a single copy of Form RO.


II.    FORM COMPLETION INSTRUCTIONS

      1.    Site Identification Label/EPA ID

           Attach one copy of the preprinted site identification, label,  if provided, in  the upper left
           corner of the form.  If no site  identification labels are provided, enter your  EPA ID in the
           upper left corner of the form.   Only two copies  of the form are provided in the package.
           If you  need to reproduce the form, attach the site identification label OR enter your site's
           EPA ID number before making copies.

      2.    Page Number

           Enter the page number in the  appropriate box on the top right corner of the form.  For
           example, if five copies  of Form RO are required to list all of the wastes  received  from off
           site,  then the forms are to be numbered 1  through 5.

      3.    Waste Stream Related Information

           Complete Sections A through G for each  waste or waste mixture entered.  Use a separate
           line entry for each waste or waste mixture.

           A.   Waste Reference  — Enter  the line  and page  number  from Form WD on which  the
                waste or waste mixture is described.

           B.    Generator EPA ID  Number— Enter the 12-digit U.S.  EPA Identification Number  of
                the generator from whom the waste  or waste mixture was received.


                                            21

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FORM RO INSTRUCTIONS (Continued)
           C.    Quantity Generated — Enter  the quantity of the waste or waste mixture  received
                 during the reporting year.

           D.    Unit of Measure  (UOM) ~ Enter the UOM code  for the quantity  of waste entry.
                 Quantities must be reported in  the units of measure listed below.

                    Code          Unit of Measure

                       P   	  Pounds
                       T   	  Short tons (2,000  pounds)
                       K.   	  Kilograms
                       M   	  Metric tonnes (1,000 kilograms)
                       G   	  Gallons
                       L   	  Liters

           E.    Density — If gallons or liters  are used as the UOM, enter the density.  Provide  the
                 density in pounds per gallon (Ibs/gal) or specific gravity (sg).  Check the appropriate
                 box.

           F.    Management Sequence — Enter  the sequence of 3-digit management codes that best
                 describes  the  management process   for  the  waste  or waste  mixture  entry.   The
                 management process codes are listed on page	.

           G.    Number of Shipments —  Enter  the  number of  shipments  (waste manifests) of that
                 waste type that were received from the generator.

      4.    Comments

           This space may be used to explain, clarify, or continue any entry. If used, cross-reference
           the comment by entering in the appropriate Section and line number.
                                             22

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                               INSTRUCTIONS FOR COMPLETING


                                           FORM  PS

                   WASTE MANAGEMENT PROCESS SUMMARY
I.     INTRODUCTION

      Form PS,  Waste Management Process  Summary, is  to  be used to describe  the  hazardous waste
      management processes which occur on  site during the reporting  year.   The waste  management
      processes to be described on Form PS are the same as the on-site processes used in the description
      of the management sequence for each waste stream on Form RO (Section F) and Form PG (Section
      F).  A list  of possible waste management processes codes appears on  page	.

      Complete one copy  of Form  PS for each unique combination of  process (defined  by its  process
      code) regulatory status (State or Federally  regulated)  and  Operational Status  (in operation, under
      construction, etc.).

      For  each process/regulatory status/operational status  combination,  the  information  requested is a
      description of the process, the capacity of the process, the number of units  represented, information
      on  the  expected changes  in the capacity, the quantity of material entering  the process, and the
      quantities  of material  leaving the  process.  The  hazardous material leaving the process (secondary
      generation of hazardous waste) is described in detail.

      The definition of capacity  is different for different types of processes, therefore Form PS has four
      sections  in which capacity is defined (Sections B through E),  corresponding to each of 4 different
      types of processes.  For  each process,  complete only  the sections which  applies to  the type  of
      process being described.  Complete sections A and F for all  processes, and the appropriate section of
      B through  E as described below:

      •    Complete  Section B if the process described  is  STORAGE.   For storage, the capacity is the
           total amount of waste which might be stored in  the storage area, tank, impoundment, or waste
           pile.

      •    Complete  Section C  if the process is treatment in single units  characterized by a maximum
           flow rate.  Section C is to  be completed for units which are connected in  parallel and any
           process  which is limited  by the  maximum flow  rate even  if it  is not usually considered
           treatment, such as underground injection.

      •    Complete  Section D if the process  is treatment in a sequence  in dependent units.   A sequence
           of treatment units which can be operated independently are to be described in section C.

      •    Complete  Section E for landfill type processes.

      The waste  type is indicated by reference to a detailed waste description which  is to be provided on
      Form WD, Waste Description.  If vou are required to complete Form PS  then Form WD must be
      completed  also.
                                               23

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?ORM PS INSTRUCTIONS (Continued)



II.    FORM COMPLETION INSTRUCTIONS

      1.    Site Identification Label/EPA ID

           Attach one copy of the preprinted site identification label,  if provided, in the upper  left
           corner of the form.   If no site identification labels  are provided, enter your EPA ID in the
           upper left  corner of the form.  Only two copies of the form are provided in the package.  If
           you need to reproduce the form,  attach the site identification label OR enter your site's  EPA
           ID number before making copies.

      2.    Page Number

           Enter the  page number in the appropriate box on  the  top right corner of the form.   For
           example, if five copies of Form PS are required to describe the hazardous waste management
           processes used during the year, then the forms are  to be numbered 1  through 5.

      3.    Waste Management Process Related  Information

           A.    Description of the process — Note that a separate copy of Form PS must  be completed
                 for each  combination of process type, regulatory status, and operational status.

                 1)     Process Code  — Enter  the process code  for the waste management  process being
                       described from the list on page	.

                 2)     Regulatory  Status — Enter the appropriate  code from the list  below which
                       describes how this process is regulated:

                           Code           Regulatory Status

                            R    	   RCRA Regulated
                            S     	    State Regulated only
                            N    	   Not regulated

                 3)     Operational Status  —  Enter the appropriate  code from the list  below which
                       describes the operation  of this process  at the end of the reporting year

                           Code           Operational Status

                            A    	    Active
                            B     	    Temporarily Closed
                            C     	    Permanently Closed

                 4)     Process Description — Enter a  narrative description of the process.
                                               24

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FORM PS INSTRUCTIONS (Continued)
            B.    Capacity for Storage Processes — Complete this section only if the process described is
                 STORAGE.

                 1)    Capacity in 1987 — Enter the capacity of the storage  process at the end of 1987.
                       The  capacity is  the  total  amount of waste which might be  stored in the storage
                       area, tank, impoundment, or waste pile including waste presently stored.  When
                       calculating capacity, consider the design size and any other limitations  (physical,
                       regulatory, etc.)  which determine the maximum usable capacity.

                       Report the capacity  in weight units assuming the  total volume for storage will be
                       used  in a  manner similar to its present use.  If the storage is  used for  wastes
                       typically measured  in volume units (gallons, barrels, etc.) convert the volume  to
                       weight using the density  of the wastes.  If different types of waste are stored,
                       convert all volumes to  weight using the appropriate  density and determine the
                       total weight for all wastes (liquid and dry) which might be stored.

                 2)    UOM Wt. — Enter  the unit of  weight measure for the capacity.  Quantities can
                       be reported in the weight units listed below.

                            Code           Units of
                             P     ...........  Pounds
                             T     ...........  Short Tons (2000 pounds)
                             K.     ...........  Kilograms
                             M     ...........  Metric Tonnes (1000 kilograms)

                 3)    Number  of  Units — Enter the number of storage units  (tanks, impoundments,
                       waste  piles  or  storage  areas) with  the  listed  combination  of process  type,
                       regulatory status, and operational status.

          • C.    Capacity for Treatment  processes in  single  units —  Complete this section only if  the
                 process described  is TREATMENT  IN  SINGLE  UNITS (including  units  operating  in
                 parallel and injection wells).

                 1)    Annual Capacity — Enter the annual capacity  of the treatment process.   The
                       capacity  is the total amount of waste which  can be treated in the  process in a
                       year  assuming typical  operating  schedules,  mixture  of  wastes and expected
                       maintenance downtime, a regulatory constraints.

                       Report the capacity in weight units.   If the treatment is used for wastes typically
                       measured in  volume units (gallons,  barrels, etc.) convert the  volume to weight
                       using the density of the wastes.  If different  types of  waste are  treated,  convert
                       all  volumes  to weight  using  the appropriate density  and determine the total
                       weight for all  wastes (liquid and dry)  which were treated.
                                                25

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PS INSTRUCTIONS (Continued)
          2)    8 Hour Shift Capacity — Enter the design capacity or maximum capacity of the
                treatment process for an 8 hour shift.  The capacity  is the total amount of waste
                which can be treated in the process during an 8 hour shift.

                Report the capacity  in weight units.  If the treatment is used for wastes typically
                measured in volume units  (gallons, barrels, etc.) convert  the  volume  to  weight
                using the density of the wastes.  If different types of waste are treated, convert
                all  volumes to  weight using  the  appropriate  density  and  determine the  total
                weight for all wastes (liquid and dry) which were treated.

          3)    UOM Wt. — Enter  the unit of weight measure for the capacity.  Quantities can
                be reported  in the weight units listed below.

                     Code          Units of Measures

                      P     	  Pounds
                      T     	  Short Tons (2000 pounds)
                      K.     	  Kilograms
                      M    	  Metric Tonnes (1000 kilograms)

          4)    Number  of Units  —  Enter  the  number of  treatment  units  with  the listed
                combination of process type, regulatory status, and operational status.

     D.   Capacity for Treatment processes in a sequence on treatments units —  Complete this
          section only if  the process  described is TREATMENT IN UNITS  IN SEQUENCE.

          1)    Annual Capacity —  Enter the annual capacity of the treatment process.  The
                capacity  is the  total  amount  of waste (entering the  first  treatment unit  of  the
                sequence) which can be  treated  in  the process  in a  year  assuming  typical
                operating schedules, mixture  of wastes and expected maintenance downtime, a
                regulatory constraints.

                Report the capacity in weight units.  If the treatment is used for wastes typically
                measured in volume  units  (gallons, barrels, etc.) convert  the  volume to  weight
                using the density of the wastes.  If different types of waste are treated, convert
                all  volumes to  weight using  the  appropriate  density  and  determine the total
                weight for all wastes (liquid and dry) which were treated.

          2)    8 Hr. Shift Capacity — Enter  the design capacity or  maximum capacity (amount
                of material  entering the first  treatment unit of the  sequence)  of the treatment
                process for an 8 hour shift. The capacity is the total  amount of waste which can
                be treated in the process during an  8 hour shift.

                Report the capacity in weight units.  If the treatment is used for wastes typically
                measured in volume  units (gallons, barrels, etc.) convert  the  volume to  weight
                using the density of the wastes.  If different types of waste are treated, convert
                all  volumes to  weight using  the  appropriate  density  and  determine the total
                weight for all wastes (liquid and dry) which were treated.
                                         26

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FORM PS INSTRUCTIONS (Continued)
                 3)    UOM Wt. —  Enter  the  unit of  measure for the capacity.   Quantities can  be
                       reported in the weight units listed below.

                           Code           Units of Measure

                             P    	   Pounds
                             T    	   Short Tons (2000 pounds)
                             K    	   Kilograms
                             M    	   Metric Tonnes (1000 kilograms)
                             G    	   Gallons
                             L    	   Liters

           D.    Unit  of  Measure fUQMl ~ Enter the  UOM  code for the quantity of waste entry.
                 Quantities must be reported in the units of measure listed below.

                    Code           Unit of Measure

                       P   	   Pounds
                       T   	   Short tons (2,000 pounds)
                       K.   	   Kilograms
                       M   	   Metric tonnes (1,000 kilograms)
                       G   	   Gallons
                       L   	   Liters

                 4)    Density ~ If  gallons or liters are  used as the UOM,  enter the density.  Provide
                       the density in pounds  per gallon  (Ibs/gal) or specific gravity (sp).  Check the
                       appropriate box.

                 5)    Unit Tvoe and Number of Units « Enter the number of treatment units by unit
                       type which make up  the sequence of units in this process.  Possible unit types are:

                          • Code           Unit Type

                             T    	   Tank
                             I    	   Impoundment
                             O    	  Other

           E.    Capacity for Landfill  type processes  —  Complete this section only  if the process
                 described is LANDFILL.

                 1)    Remaining Capacity, end of 1987 — Enter the capacity of the storage process at
                       the end of  1987.   The  total remaining  capacity  at  the end of  1987  does not
                       include daily  cover  and final cover.  When calculating capacity, consider the
                       design size and any other limitations (physical, regulatory, etc.) which affect the
                       maximum usable capacity.

                       Report the capacity  in weight units assuming the total volume for waste will be
                       used in a manner similar to its present use.
                                                27

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"ORM PS INSTRUCTIONS (Continued)
                 2)     UOM Wt. -- Enter the unit of weight measure for the capacity.  Quantities can
                       be reported in the weight units listed below.

                           Code           Units of  Measure

                            P     	  Pounds
                            T     	  Short Tons (2000 pounds)
                            K    	  Kilograms
                            M    	  Metric Tonnes (1000 kilograms)

                 3)     Number of Units  —  Enter the number  of  landfill  units  with  the  listed
                       combination of process type, regulatory status, and operational status.

           F.    Additional information for all management processes —
                 Line 1, limitations on capacity.

                 1)     Limitations  on capacity — Enter  codes to describe the limitations on capacity, in
                       order of importance.    The  relevant  codes are  shown  below.   Enter N (no
                       limitations)  only  if Capacity in  1987, Annual Capacity, ar  Remaining Capacity.
                       end of 1987 is limited  ONLY by engineering design.

                    Code          Limitations on Capacity

                       A   	  Operating permit
                       B   	  Compliance with permit standards
                       C   	  Other regulatory limitations
                       D   	  Planned  maintenance downtime
                       E   	  Number  of shifts operated/yr.
                       F   	  Other Physical Factors
                       O   	  Other Factors
                       N   	  No limitations beyond design

                 2)     Percent of capacity which is commercially available — Enter the percent of the
                       capacity (as defined in section B, C, D, or E) which is available to  commercial
                       use.

                 3)     Commercial Availability Code — Enter the  commercial availability  code  below
                       which best describes the portion of the capacity which is available for commercial
                       use.

                           Code           Commercial Availability

                            A    	  Commercial use
                            B     	  Commercial use for a limited number of other firms.
                            C     	  Use by firms owned by  the same company only.
                            D    	  No commercial use  available.
                                                28

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ORM PS INSTRUCTIONS (Continued)
          F.    Line 2. Changes in capacity —

                1)    Planned  Change in Annual or End of Year Capacity —  Enter  any changes in
                     capacity  (as defined in  sections B through  E) expected in the next 5 years.   Use
                     the same unit of measure used in  section B, C, D, or E.

                2)    Expected Year of  the  Change  -- Enter  the  expected  year of  the  change in
                     capacity  noted above.

                3)    Change Code — Enter  the code below  which best describes the expected change
                     in capacity.

                          Code      x    Change Status

                           A     	   Change in production
                           B     	   Change in production methods
                           C     	   Change in waste management methods
                           D     	   Change in regulatory status of waste management method
                           E     	   Change in commercial status of waste  management method
                           O     	   Other reasons

                4)    Percent of capacity change  which is commercially available — Enter the percent
                     of the expected capacity change which is available to commercial use.

                5)    Commercial  Availability Code. —  Enter the commercial availability code below
                     which best describes the  portion of  the capacity change which is  available  for
                     commercial use.

                          Code           Commercial Availability

                           A     	  Commercial use
                           B     	  Commercial use for a limited number  of other firms.
                           C     	  Use  by firms owned by the same company only.
                           D     	  No commercial use available.

          F.    Line 3, Describe influent flows.

                1)    Waste Description — Enter a narrative  description of the influent material to the
                     process.

                2)    Annual  Quantity  — Enter the  total  quantity of  material entering the waste
                     management process.
                                               29

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*ORM PS INSTRUCTIONS (Continued)
                 3)    UOM  —  Enter the  unit of measure for the annual quantity of  influent material
                      above  using the unit of measure codes below.

                           Code           Regulatory Status

                             P     	   Pounds
                            T     	   Short Tons (2000 pounds)
                             K    	   Kilograms
                             M    	   Metric Tonnes (1000 kilograms)
                            G    	   Gallons
                             L     	   Liters

                 4)    Density — If quantity above is reported with volume unit of measure (gallons or
                      liters)  enter the density of the material, and the unit of measure for the density
                      (by checking  the  appropriate box).  If several materials enter  the process with
                      different  densities, convert all to a common weight unit of measure.

                 5)    % Hazardous —  Enter the percent  of the  influent material  which is RCRA
                      regulated  hazardous  waste.

           F.    Line 4, Describe non-hazardous effluent flows.

                 1)    Waste  Description — Enter a narrative description of the non-hazardous effluent
                      flow from the process.

                 2)    Annual Quantity —  Enter  the  total  quantity of  non-hazardous material leaving
                      the waste management process.

                 3)    UOM  —  Enter the  unit of measure  for the quantity of non-hazardous material
                      leaving the waste management process.

                           Code           Regulatory Status

                            P     	   Pounds
                            T     	   Short Tons (2000 pounds)
                            K    	   Kilograms
                             M    	   Metric Tonnes (1000 kilograms)
                            G    	   Gallons
                             L     	   Liters

                 4)    Density — If quantity above is reported with volume unit of measure (gallons or
                      liters)  enter the density of the material, and the unit of measure for the density
                      (by checking the appropriate  box).  If several non-hazardous  materials  leave the
                      process with different densities, convert all to a common  weight unit of measure.
                                               30

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FORM PS INSTRUCTIONS (Continued)
           F.    Lines 5 to 8,  Describe  hazardous  effluent flows.   For each flow of hazardous  waste
                 from the process, enter thee following information.

                 1)    Form WD  Waste Reference ~ Enter the line and page number from Form WD on
                       which the  waste or waste mixture is described.

                 2)    Annual Quantity -- Enter the total quantity of this hazardous stream leaving the
                       waste management process.

                 3)    UOM  —  Enter the  unit of measure for the quantity of the hazardous  waste
                       stream leaving the waste management process.

                           Code            Regulatory Status

                            P     	   Pounds
                            T    	   Short Tons (2000 pounds)
                            K.    	   Kilograms
                            M    	   Metric  Tonnes (1000 kilograms)
                            G    	   Gallons
                            L     	   Liters

                 4)    Density — If quantity above is reported with volume unit of measure (gallons or
                       liters) enter the density  of the material, and the unit of measure  for the density
                       (by checking the appropriate box).

                 5)    Management Sequence — Usual...
                                                31

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   SIC
   Cod*
SIC
Cod*  Industry
   0111  Wheat
   0112  Rico
   0115  Com
   Oil*  Soybean*
   0119  Cash grains, nac
   0131  Cotton
   0132  Tobacco
   0133  Sugar crops
   0134  Iran potatoes
   0139  Field crops, except cash grains, nee
   Oi 61  Vegetables and melons
   0171  Berry crops
   0172  Grapes
   0173  Tree nuts
   0174  Citrus fruits
   0175  Deciduous tree fruits
   0179  Fruits and tree nuts, nee
   0181  Ornamental nursery products
   0182  Food crops grown under cover
   Q189  Horticultural specialties, nee
   0191  General farms, primarily crops
   02i i  Beef cattle feedlots
   0212  Beef cattle, except feedlots
   0213  Hogs
   0214  Sheep and goats
   02*9  General livestock, nee
   02^1  Dairy farms
   0251  Broiler, fryer, and roaster chickens
   0252  CMicken eggs
   0253  Turkeys and turkey eggs
   025^  Poultry hatcnenes
   0259  Poultry and eggs, nee
   0271  Fur-oearmg animals and rabbits
   0272  Horses and otner equmes
   0279  Animal specialties, nee
   0291  General farms, pnmanry livestock
   0711  Soil preparation services
   0721  Crop planting and protection
   0722  Crop harvesting
   0723  Crap preparation services for market
   0724  Cotton ginning
   0729  General crop services
   0741  Vetennary services, farm livestock
   07^2  Vetennary services, specialties
   0751  Livestock services, except specialties
   0752  Animal specialty services
   0761  Farm labor contractors
   0762  Farm management services
   0781  Landscape counseling and planning
   0782  Lawn and garden services
   0783  Ornamental snruo ano tree services
   08U  Timoer tracts
0821   Forest nurseries and seed gathering
0843   Extraction of pine gum
0849   Gatnenng of forest products, nee
08S1   Forestry services
0912   Finfish
0913   Shellfish
0919   Miscellaneous manne products
0921   Fish hatchenes and preserves
0971 •  Hunting, trapping, game propagation
1011   Iron ores
1021   Copper ores
1031   Lead and zinc ores
1041   Gold ores
1044   Silver ores
1051   Bauxite and other aluminum ores
1061   Ferroalloy ores, except vanadium
1081   Metal mining services
1092   Mercury ores
1094   Uranium,  radium, vanadium ores
1099   Metal ores, nee
1111   Anthracite
1112   Antnracte mining services
1211   Bitumir!c*s coal and lignite
1213   Bituminous and lignite services
1311   Crude se-oieum and natural gas
1321   Natural gas  HQUKJS
1381   Drilling on ana gas wells
1382   Oil ana gas exploration services
1369   Oil and gas field services, nee
1^11   Dimension stone
1422   Crushed ana Broken limestone
1423   Crusnea arc sroxert granite
1429   Crusnea anc 3.-o*en stone  nee
144.2   Construction sana  anc gravei
1446   industrial  sana
1452   Sentamte
1453   Preciay
1454   Fullers eann
1455   Kaolin ana sail clay
i4£ ;   Clay ana reiatea nmerais. nee
1472   Barite
1473   Fluorspar
1471   Potash. soaa ana Sarate minerals
1475   Phospnate rocx
1476   Rock salt
1477   Sulfur
1479   Chemical and fertilizer mining, nee
1481   Nonmetaidc minerals services
1492   Gypsum
1496   Talc, soaostone. and oyroonyihte
1499   Nonmetailic minerals, nee
1521   Single-family nousing construction
Note: nee • not elsewhere classified.
                                                 32

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   SIC
   Co*  taductry
SIC
Cod*  Industry
   1522  Residential construction, nee
   1531  Operative builders
   1541  Industrial buildings and warehouses
   15^2  Nonresidential construction, nee
   1611  Highway and street construction
   1622  Bndge. tunnel, and elevated highway
   1623  Water, sewer, and utility lines
   1C29  Heavy construction, nee
   1711  Ptumoing. heating, air conditioning
   1721  Painting, paper hanging, decorating
   1731  Electrical work
   1741  Masonry and other stone* ark
   1742  Plastering, drywall. and insulation
   1743  Terrazzo. tile, marble, mosaic work
   1751  Carpentering
   1752  Floor laying and floor work, nee
   1761  Roofing and sheet metal work
   1771  Concrete work
   1781  Water well drilling
   1791  Structural metal erection
   1793  Glass and glazing work
   1794  Excavating and foundation work
   1795  Wrecking and demolition work
   1796  installing building equipment, nee
   1799  Special trade contractors, me
   2011  Meat packing plants
   2013  Sausages and other prepared meats
   2016  Poultry dressing plants
   20i 7  Poultry ana egg processing
   2C21  Creamery Suiter
   2022  Cheese, natural and processed
   2023  Condensed and evaoorateo milk
   2024  ice cream and frozen desserts
   2028  Fluid milk
   2032  Canned specialties
   2033  Canned fruits and vegetables
   2034  Dehydrated fruits, vegetables. SOUPS
   2035  Pickles, sauces, and salad dressings
   2037  Frozen fruits and vegetaoies
   2038  Frozen specialties
   2041  Hour and other gram mill products
   2043  Cereal breakfast foods
   2044  Rice milling
   2045  Blended and prepared flour
   2046  Wet corn milling
   2047  Dog. cat. and other pet food
   2048  Prepared feeds, nee
   2051  Bread, cane, and related products
   2052  Cookies and crackers
   2061  Raw cane sugar
   2062  Cane sugar refining
   2063  Beet sugar
2065   Confectionery products
2088   Chocolate and cocoa products
2067   Chewing gum
2074   Cottonseed oil mills
2075   Soybean oil mills
2078   Vegetable oil mills, nee
2077   Animal and marine fats and oils
2079   Shortening and cooking oils
2082   Mattoeverages
2063   Man
2084   Wines, brandy, and brandy spirits
2085   Distilled liquor, except brandy
2086   Bottled and canned soft drinks
2087   Flavonng extracts and syrups, nee
2091   Canned and cured seafoods
2092   Fresn or frozen packaged fish
2095   Roasted coffee
2097   Manufactured ice
2098   Macaroni and spaghetti
2099   Food preparations, nee
2111   Cigarettes
2*2'   Cigars
2 * 3'   Chewing and smoking tobacco
2'-'   Tooacco stemming and reorymg
22''   Weaving mills, cotton
222'   weaving mills, synthetics
223i   weaving and finishing mills, wool
2241   Narrow fabric mills
2251   Women's hosiery, except SOCKS
2252   Hosiery, nee
2253   Knit outerwear mills
2254   Kmt uncerwear -mils
2257   C.rcaiar *nn faopic ^'ils
2253   War: «mt faonc -mils
2259   Kmtttng mills, nee
2261   F-nisnmg plants, cotton
22S2   Fin-.snmg plants, synthetics
2269   F'-msning plants, nee
227i   Woven carpets and rugs
22^2   Tufted carpets ana rugs
22*9   Caraets ana rugs,  nee
2281   Yarn mills, except wool
2282   Throwing and winding mills
2283   Wooi yam mnis
2284   Thread mills
2291   Felt gooes, except woven felts and hats
2292   Lacs gooas
2293   Paddings and upholstery filling
2294   Processed textile waste
2295   Coated faoncs. not ruooenzed
2296   Tire cord and faonc
2297  Nonwoven faoncs
Note: nee • not elsewhere classified.   33

-------
   SIC
SIC
Code  Industry
   2298   Cordag* and twin*
   2299   Te*tfla goods, nee
   2311   Men's and boys'suits and coats
   2321   Men's and boy's shirts and mghtwear
   2322   Men's and boys'underwear
   2323   Man's and boys' nsckwaar
   2327   Man's and boys' separate trousers
   2328   Man's and beys'work clothing
   2329   Men's and boys'doming, nee
   2331   Women's and misses' blouses and waists
   2335   Women's and misses' dresses
   2337   Women's and misses' suits and coats
   2339   Women's and misses' outerwear, nee
   2341   Women's and children's underwear
   2342   Brassieres and allied garments
   2351   Millinery
   2352   Hats and caps, except millinery
   2361   Children s dresses and blouses
   2363   Children's coats and suits
   2369   Children's outerwear, nee
   2371   Fur goods
   2331   Fabric dress and work gloves
   2334   Roees and dressing gowns
   2235   Waterproof outergarmems
   2336   Leather and sheep tinea clothing
   2387   Apparel belts
   2339   Apparel and accessories, nee
   2391   Curtains and draperies
   2392   House fumianings. nee
   2393   Textile bags
   2394   Canvas and related products
   2395   Pleating and stitcnmg
   2396   Automotive and apparel trimmings
   2397   ScrnrHi macnme emoroidsnes
   2399   Fabricated textile products, nee
   24ii   Logging camps and fogging contractors
   2421   Sawmills and planing mills, general
   2426   Hardwood dimension and flooring
   2429   Special product sawmills, nee
   2431   Millwork
   2434   wood kitchen cabinets
   2435   Hardwood veneer and plywood
   2436   Softwood veneer and plywood
   2439   Structural wood members, nee
   2441   Nailed wood boxes and snook
   2448   WOOD pallets ana sxias
   2449   wood containers, nee
   2431   Moonenomas
   2452   Pretaoncated wood buildings
   2491   wood preserving
   2492   Pamcieooard
   2499   Wood products, nee
2511  Wood household furniture
2512  Upholstered household furniture
2514  Metal household furniture
2515  Mattresses and bedspnngs
2517  Wood TV and radio cabmets
2519  Household furniture, nee
2521  Wood office furniture
2522  Metal office furniture
2531.  Public building and related furniture
2541  Wood partitions and fixtures
2542  Metal partitions and fixtures
2591  Drapery hardware and Minds and shades
2599  Furniture and fixtures, nee
2611  Pulp mills
2621  Paper mills, except building paper
2631  Papertaoard mills
2641  Paper coating and glazing
2642  Envelopes
2643  Bags, except textile bags
2645  Die-cut paper and board
2646  Pressed and molded pulp goods
2647  Sanitary oaper products
2648  Slauone-/ aroducis
2649  Convene: pacer products, nee
2651  Foicirg : asercoard boxes
2552  Set-uo caserooaro boxes
2653  Corruc,a:a3 and solid fiber boxes
2654  Sanitary 'cod containers
2655  Fiber cans, drums, ana similar products
2661  Budding oaoer ana Doara mills
2?i 1  Newspapers
272".  Periodicals
2731  BOCK puoi.snmg
2732  BOOK pnn:ng
2741  Misceiianecv.3 3-3lisrting
2751  Commercial anming. lenercress
2752  Commercial annt-rg. litncc/asnic
2753  Engraving ana state prntmg
2T54  Commercai anming. gravure
2781  Manifold ausiness 'orms
2771  Greeting cara auousnmg
2782  BlanKoaoKs ana 'ooseieaf binders
2789  Bookoincmg and related worn
2791  Typesetting
2793  Photoengraving
2794  E!ec:rotyomg ana stereotyping
2795  Utrtograonic oiatemamng services
26i2  Alkalies ana cmorme
2813  industrial gases
28^6  inorganic pigments
2819  Industnai inorganic chemicals,
2821  Plastics materials ano resins
Note: nee • not eisewnere classified.

-------
   SIC
   Cod* industry
SIC
Cod* Industry
   2822  Synthetic rubber
   2823  Cettutasic man-mad* fibers
   282*  Organic fibers, noncellulosic
   2831  Biological products
   2833  Medicmais and botanicals
   2834  Pharmaceutical preparations
   2841  Soap and other detergents
   2842  Polishes and sanitation goods
   2843  Surface active agents
   2844  Toilet preparations
   2851  Paints and allied products
   2881  Gum and wood chemicals
   2865  Cyclic crudes and intermediates
   2869  Industrial organic chemicals, nee
   2873  Nitrogenous fertilizers
   2874  Phospnanc fertilizers
   2875  Fertilizers, mixing only
   2879  Agricultural chemicals, nee
   2891  Adhesive* ana sealants
   2892  Explosives
   2893  Pnnting mx
   2895  Carbon alack
   2899  Chemical preparations, nee
   291 i  Petroleum refining
   2951  Paving mixtures and blocks
   2952  Asphalt felts and coatings
   2992  Luoncating oils and greases
   2999  Petroleum and coal products, nee
   3d 1  Tires and inner tubes
   3C21  Rubber and plastics footwear
   3031  Reclaimed rubcer
   30-1  Rubber and plastics hose and belting
   3C63  Facrrcated ruooer products, nee
   3079  Miscellaneous plastics orooucts
   3i i1  Leather tanning ana finishing
   3131  Boot and shoe cut stock ano findings
   3142  House slippers
   3143  Men's footwear, except athletic
   3144  women's footwear, except athletic
   3149  Footwear, except rubber, nee
   3151  Leather gloves and mittens
   3161  Luggage
   3171  Women s handbags and purses
   3i 72  Personal leather goods, nee
   3i99  Leather gooos. nee
   32n  Rat glass
   3221  Glass containers
   3229  P'essed  and biown glass, nee
   323i  P'ooucts of ourcnased glass
   32*1  Camem. hydraulic
   3251  3".ex and structural clay tile
   3253  Ceramic  wail ano 'loor tile
3255
3259
3281
3262
3263
3264
3269
3271
3272
3273
3274
3275
3281
3291
3292
3293
3295
3296
3297
3299
331 2
33 1 3
33 * 5
33 ' e
33 i "
332*
3322
3324
3325
3331
3332
3333
333*
3339
335 1
3353
335-t
3355
3355
3357
336 1
3362
3369
3398
3399
34U
3412
3421
3423
3425
      Clay refractories
      Structural clay products, nee
      Vitreous plumbing fixtures
      Vitreous china food utensils
      Fine earthenware food utensils
      Porcelain electrical supplies
      Pottery products, nee
      Concrete Woe* and bnek
      Concrete products, nee
      Ready-mixed concrete
      Lime
      Gypsum products
      Cut stone and stone products
      Abrasive products
      Asbestos products
      Gaskets, packing, and sealing devices
      Minerals, ground or treated
      Mineral wool
      Nonclay refractories
      Nometallic mineral products, nee
      Blast furnaces and steel mills
      Eiectrometallurgical products
      S :eei wire and related products
      Z aid finishing of steel shapes
      Steel pipe and tubes
      Gray iron foundries
      Malleable iron foundries
      Sceel investment foundries
      Steel Sundries, nee
      Pf-mary copper
      Primary lead
      P-ir-ary zinc
      P'-r-ary aluminum
      °'imarv nonferrous metals, nee
      Secondary ndnferrous metais
      Cocoe' roiling and drawing
      Aluminum sneet. oiate. anc 'oil
      Aiurrvnur- extruced products
      Aluminum roiling and drawing, nee
      Nonferrous rolling and drawing, nee
      Nonferrous wire drawing and insulating
      Alumnum foundries
      Brass, aronze. and coooer 'oundr.es
      Nonferrous fdundr-es. nee
      Metal neat treating
      Primary metal products, nee
      Metaicans
      Metal barrels, drums, and sails
      Cuiie-y
      Hand and edge tools, nee
      Hand saws and saw biaces
      Hardware, nee
Note: nee * not elsewhere classified.
                                       35

-------
   SIC
                                                  SIC
                                                  Cod*  Industry
   3431
   3432
   3433
   3441
   3442
   3443
   3444
   3446
   3448
   3449
   3451
   34S2
   3462
   3463
   3465
   3466
   3469
   3471
   3479
   3482
   3463
   3464
   3469
   3493
   3494
   3495
   3496
   3497
   3496
   3499
   3511
   35'9
   3523
   3524
   3531
   3532
   3533
   3534
   3535
   3536
   3537
   3541
   35*12
   3S44
   3545
   3546
   3547
   35*9
   3551
   35=2
   3553
   355-1
Metal sanitary wart
Plumbing fittings and brass goods
Heating equipment, except electric
Fabricated structural metal
Metal doors, sash, and trim
Fabricated plate work (boiler shops)
Sheet metal work
Architectural metal work
Prefabricated metal buildings
Miscellaneous metal work
Screw machine products
Bolts, nuts, nvets. and washers
lion and steel forgings
Nonferrous forgtngs
Automotive stampings
Crowns and closures
Metal stampings, nee
Plating and polishing
Metal coating and allied services
Small arms ammunition
Ammunition, except tor small arms, nee
Small arms
Ordnance and accessories, nee
Steal springs, except wire
Valves and pipe fittings
Wire springs
Miscellaneous fabncated wire products
Metal (oil and leaf
Fabricated pipe and fittings
Fabricated metal prooucts. nee
Turbines and turc'ne generator sets
internal comcustion engines, nee
Farm macnmery and equipment
Lawn and garden equipment
Construction machinery
Mining machinery
OH flew macnmery
Sevatora and moving stairways
Conveyors and conveying machinery
Hoists, cranes), and monorails
Industnattru
Ml
Macmne tools, metal cutting types
Machine tools, metal forming types
Special dies, tools, jigs, and fixture
Macnme tool accessones
Power driven nand tools
Polling mill machinery
Metalwormng macnmery, nee
Food products machinery
Textile macnmery
Wocdworxmg macnmery
Paper industries macnmery
3555   Printing trades machinery
3559   Special industry machinery, nee
3561   Pumps and pumping equipment
3562   Ball and roller peanngs
3563   Air and gas compressors
3564   Blowers and fans
3565   Industrial patterns
3566  . Speed changers, drives, and gears
3567   Industnal furnaces and ovens
3568   Power transmission equipment, nee
3569   General industrial machinery, nee
3572   Typewriters
3573   Electronic computing equipment
3574   Calculating and accounting machines
3576   Scales and balances, except laboratory
3579   Office machines, nee
3581   Automatic merchandising machines
3582   Commercial laundry equipment
3585   Refrigeration and heating equipment
3586   Measunng and dispensing pumps
3589   Service industry machinery, nee
3592   Carou'9':-s pistons, nngs. valves
3599   Macrve1-  except electrical, nee
3612   Transit'—•J'S
3613   Switcngea • and switchboard apparatus
3621   Motors ar : generators
3622   Industrial camrols
3623   Welding apparatus, electrical
3624   Carbon ana graphite products
3629   Electrical industrial apparatus, nee
3€3i   HousenoiC :ccning equipment
3632   Hcusencic -elrige'ators and freeze'S
3623   Housenoic aurc-y acuoment
363-1   E ec:nc nousewarss and 'ans
3635   t-cusencic ^ac-jum cleaners
3636   Sewing -nac-vies
3639   Housenoid aooiiances. nee
2641   E'actric iarr;s
3643   Current-caring 
-------
  SIC
  Coo*  Industry
SIC
Cod*  Industry
   3879  Electronic capacitMB
   3676  Eloctranic resistors
   3677  Electronic coils and transformers
   3678  Electronic connectors
   3679  Btctrontc component j. ntc
   3691  Storage batteries
   3692  Primary batteries, dry and wot
   3693  Xway apparatus and tubes
   3694  Engino olactncal equipment
   3699  Elactrical equipment and supplies, nac
   3711  Motor vetidaa and car bodies
   3713  Truck a : bus bodies
   3714  Motor venide parts and accassonea
   371S  Truck trailers
   3716  Motor homes on purchased chassis
   3721  Aircraft
   3724  Aircraft engines and engine parts
   3728  Aircraft equipment, nee
   3731  Snip building and repairing
   3732  Boat building and repairing
   3743  Railroad equipment
   3751  Motorcycles, bicycles, and parts
   3761  Guided missiles and space vemdes
   3764  Space propulsion units and parts
   3769  Space vehicle equipment, nac
   3752  Travel trailers and campers
   3795  Tanks and tank components
   3799  Transportation equipment, nee
   3611  Engineering and scientific instruments
   3822  Environmental controls
   3623  Process control instruments
   3824  Ffuid mete's and counting devices
   3825  instruments to measure electricity
   3829  Measunng and controlling devices, nee
   3832  Optical instruments and lenses
   3841  Surgical and medical instruments
   3842  Surgical appliances and supplies
   3843  Dental equipment and supplies
   3651  Ophthalmic goods
   3861  Photograph* equipment and supplies
   3873  Watches, dock*, and watchcases
   3911  Jewelry, preooua  metal
   3914  Silverware and plated ware
   391S  Jewelers' materials and lapidary work
   3931  Musical instruments
   3942  Dolls
   3944  Games, toys, and  children s vehicles
   3949  Soornng and athletic gooes, nee
   3951  Pens and mechanical pencils
   3952  lead pencils ana art gooos
   3953  Marking devices
   3955  Caroon paper and mKed ribbons
3961  Costume jewelry
3962  Artificial flowers
3963  Button*
3964  Needles, pins, and fasteners
3991  Brooms and brushes
3993  Signs and advertising displays
3995  Burial caskets
3996  Hard surface floor coverings
3999  Manufacturing industries, nee
4011  Railroads, line-haul operating
4013  Switching and terminal devices
4041  Railway express service
4111  Local and suburban transit
4119  Local passenger transportation', nee
4121  Taxieabs
4131  Intercity highway transportation
4141  Local passenger charter service
4142  Charter semes, except local
4151  School buses
4171  Bus terminal facilities
4172  Bus service facilities
4212  Local trucking, without storage
4213  True' ng. except local
4214   Local Tucking and storage
4221   Farm aroduct warehousing and storage
4222  Refngerated warehousing
4224   Household goods warehousing
4225   General warenousing and storage
4226   Special warehousing and storage, nee
4231   TrucKing terminal facilities
4311   U.S. Postal Service
4411   Deep sea foreign transoortation
4421   Noncontiguous area transacnation
4422   Coastwise transportation
4423   tntercoastai transoortation
4431   Great Lanes transportation
4441   Transoonauon on nvers and canals
4452   Femes
4453   bgnterage
4454  Towing and tugboat service
4459   Local water transportation, nee
4463   Marine cargo nancling
4464  Canal operation
4469  Water transoortation services, nee
45i1   Certified air transportation
4521   Noncemhed air transoortation
4582   Airports ano flying fields
4583  Air terminal services
4612  Crude petroleum pipelines
4613  Refined petroleum pipelines
4619  Pipelines, nee
4712  Preigm'orwaromg
Note: nee • not elsewhere classified.
                                             37

-------
    SIC
    Codt Industry
SIC
Cod*  Industry
    4722  Passenger transportatidn arrangement
    4723  Freigm transportation arrangement
    4742  Railroad ear rental with service
    4743  Railroad ear rental without service
    4782  Inspection and weighing services
    4783  Packing and crating
    4784  Fixed facilities tor vehicles, nee
    478*  Transportation services, nee
    4811  Telephone communication
    4821  Telegraph communication
    4832  Radio broadcasting
    4833  Television broadcasting

    4911  Beeinc services
    4922  Natural gas transmission
    4923  Gee transmission and distribution
    4924  Natural gas distribution
    4929  Gas production and/or distribution
    4931  Sectnc and other services comomed
    4932  Gas and other services combined
    4939  Comomaoon utility services. nee
    4941  Water supply
    4952  Sewerage systems
    4953  Refuse systems
    4959  Sanitary services, nee
    4981  Steam supply
    4971  irrigation systems
    5012  Automobiles and other motor venicfes
    S013  Automotive parts and supplies
    SOY 4  Tires and tubes
    5021  Furniture
    5023  Home furnishings
    5031  Lumoer. plywood, and millwork
    5039  Construction materials, nee
    5041  Sporting and recreational goods
    5042  Toys and hobby goods and supplies
    50«3  Photographic equipment and supplies
    5051  Metals service centers and offices
    5052  Coal and other minerals and ores
    5063  Electrical apparatus and equipment
    5084  Becmcal appliance* TV and radios
    5065  Electronic pans and equipment
    5072  Hardware
    5074  Plumbing and hydronic heating supplies
    5075  Warm air netting and air conditioning
    5078  Refrigeration equipment and supplies
    5081  Commercial machines and equipment
    5082  Construction and mining machinery
    5083  Farm machinery and equipment
    5084  industnal machinery and equipment
    5065  Industnal supplies
    5086  Professional equipment and suppi «s
5087
5068
5093
5094
5099
5111
5112
5113
5122-
5133
5134
5138
5137
5139
5141
5142
5143
51*4
5145
5148
5147
5148
5149
5tS2
5)53
5159
Si*?'
5l~1
5172
5T81
5182
5191
5198
5199
5211
5231
5251
5261
5271
5311
5331
5399
5411
5422
5423
5431
S4A1
5451
5462
5463
Service establishment equipment
Transportation equipment and supplies
Scrap and waste materials
Jewelry, watches, and precious stones
Durable goods, nee
Printing and writing paper
Stationery supplies
Industnal and personal service paper
Drugs, proprietaries, and sundries
Notions and other dry goods
Men's clothing and furnishings
Women's and children's dotting
Footwear
Groceries, general lino
Frozen foods
Dairy products
Poultry and poultry products
Confectionery
Fish and seafoods
Meats and meat products
Fresh fruits and vegetables
Groceries and related products, nee
Cotton
Srain
uvestocK
Farm-oroduct raw materials, nee
Chemicals and allied products
Petroleum oulk stations and terminals
Petroleum products, nee
Beer and ale
Wines and distilled beverages
Farm suoooes
Tobacco and tooacco products
Paints, varmsnes. ana supplies
Nonduraoie goods, nee
Lumber and otrter ouildmg materials
Paint, glass, and wallpaper stores
Hardware stores
Retail nurseries and gardens
Mobile home dealers
Department stores
Variety stores
Miscellaneous general merchandise stores
Grocery stores
Freezer and locxer meat provisioned
Meat and fish  (seafood) markets
Fruit stores and vegetable markets
Candy, nut. and confectionery stores
Dairy products stores
Retail bakeries, oakmg and selling
Retail oakeries, selling only
Note: nee • not elsewhere classified.
                                                38

-------
                                                         SIC
                                                         Code  Industry
5499  Miscellaneous food stores
5911  New and used car dealers
S921  UMd car (toilers
5531  Auto and home supply stores
5541  Gasoline service stations
5991  Boat dealers
9961  Recreation and utility trailer dealers
5971  Motorcycle dealer*
5599  Automotive dealers, nee
5611  Men's and boys' clothing and furnishings
5621  Women's ready-to-wear stores
5631  Women's accessory and specialty stores
5641  Children's and infants' wear stores
5651  Family dotting stores
5661  Shoe stores
5661  Fumers and fur stops
5699  Miscellaneous apparel and accessories
5712  Furniture stores
5713  Floor covering stores
5714  Drapery and uohcistery stores
5719  Miscellaneous tame Furnishings stores
5722  Housenoid appliance stores
5732  Radio ana televis.cn stores
5733  Music stores
5612  Eating places
5613  Drinking places
5912  Drugstores and proprietary stores
5921  Lauor stores
5931  used mercnandise stores
5941  Sporting goods and Bicycle shops
5942  BOOK stores
5343  Stationery stores-
5944  Jewelry stores
5946  Hooey, toy. and game shops
5946  Camera and pnotograpnic supply stores
5947  Gift novelty, and souvenir shoos
5946  Luggage and leather goods stores
5949  Sewnng, needlework, and piece goods
5961  Mad order houses
5962  Merchandising machine operators
5963  Direct selling organizations
5962  Fuel and «e dealers, nee
5983  Fuet oil dealers
5964  uauefied petroleum gas dealers
5992  Florists
5993  C.gar stores and stands
5994  News dealers ana newsstands
S999  Miscellaneous retail stores, nee
60i i  Federal Rese-ve oanws
6022  State canits. F«cerai Reserve
6023  State oanxs. tot Federal Reserve. FQiC
6024  State panns. not Federal Reserve  notFQiC
6029  National bank*. Federal Reserve)
6026  National banks, not Federal Reserve. FOlC
6027  National banks, not FOlC
6026  Private banks, not incorporated, not FOlC
6032  Mutual savings banks. Federal Reserve
6033  Mutual savings banks, nee
6034  Mutual savmgs banks, not FOlC
6042  Nondepesrt trust*. Federal Reserve
6044  Nondeeoarttrusta.net FOlC
6092  ForeigftexcriangaeataWisitmenta

6059  Cleannghouee aaanrlaMetia
6096  Corporations) for bantdng abroad
6059  Functwne related to banking, nec
6112  Bedis«ovntlng. not for agricultural
6113  Redtscoummg. for agricultural
6122  Federal savings and lean aatadatlena
6123  State aaaooaoona. insured
6124  State associations, nonmsured. FMLB
6129  State associacons. noninsurod. nee
6i3i  AgneuKural credit institution*
6' *2  Federal credit unions
5 • - 3  State credit unions
5 • --t  Nondeposit mdustnal loan companies
6 • -5  Lcensed small loan lenders
€ • -o  i nstaiiment sales finance companies
6 * -9  Miscellaneous personal credit institution:
6i53  Short-term ousmess credit
6153  Miscellaneous ousmess  credit institution
6162  Mortgage banners and correspondents
6'53  Laansroners
62'i  Secur.ty crows ana dealers
622'  Conmocity contracts 3rc«e'9. dealers
623"  3«C4fty ana commoany exchanges
629*  S^cunty and commocity se'vices
63*i  L fe-nsurance.
622 *  Ace-dent and neaitn insurance
€22-  Hosoxai and -nedical se*v ce plans
633''  F-re marine, and casualty nsurance
6351  Surety -nsurance
6361  Title insurance
6371  Pension, health, and wei'a-e runos
6399   Insurance carriers, nee
641 T   insurance agems. crone's and servic
6512   Nonresidennal building oserators
€513  Apartment building operators
65 T 4  Dwelling operators, exceat apartment
6515   Mobile nom* sue operators
6517   Railroad property lessors
6519   Real property lessors, nee
6531   Real estate agents and managers
6541  Title aostract offices
.-• n»f . not elsewhere classified.
                                   39

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   SIC
                                                  SIC
                                                  Cod*  Industry
   65S2
   6553
   6611
   6711
   6722
   6723
   6724
   6729
   6732
   6733
   6792
   6793
   6794
   6798
   6799
   7011
   7021
   7032
   7033
   7041
   721 1
   7212
   7213
   7214
   72-5
   72T6
   7217
   -2« 8
   7219
   7221
   723t
   72S1
   7291
   7299
   7311
   73T2
   7313
   7319
   7321
   7331
   7332
   7333
   7339
   7341
   7342
   7349
   735 1
   7361
   7362
   7369
   7372
Subdivide* and developers, nee
Cemetery subdnndefs and developers
Combined real estate, insurance, etc.
Hotting offiees 	
Management investment, opon*4nd
Management investment, closed-end
Unit investment trusts
Face-amount certificate offices
        iaJ. religious, etc. trusts
Trusts, nee
OU royalty traders
Commodity traders
Patent owners and lesson
fli
itr
t trusts
investors, nee
Hotets. motets, and tounst courts
Rooming and boarding nouses
Soomng and recreational camps
TruJenng pants for transients
Memeersnip-basia organization hotels
Power laundnes. Family and commercial
Garment pressing and cleaners  agents
Unen supply
Diaper service
Coin-operated laundnes and cleaning
Ory cleaning plants, axcaot rug
Carpet and uonolstery cleaning
inoustnai launderers
Laundry and garment services, nee
Ptcrograpmc studios, portrait
Beaury snopa
Barear snoes
Shoe repair and hat cleaning snocs
Funeral  service and crematones
Miscsiianeoua personal services
Advertising agencies
Outdoor advertising services
Radio. TV. publisher representatives
Advernatng. nee
Credit reporting and collection
aiueenrmng and photocopying
GomnitnCetf oftoto^npny tv^d «ur
Stsnograome and reproduction, nee
Window cleaning
Disinfecting and exterminating
Building maintenance services, nee
News syndicates
Employment agencies
Temporary neio supply services
Personnel supply services, nee
Computer programming and software
7374  Data processing sen/wee
7379  Computer related services, nee
7391  Research and development laboratories
7392  Management and public reiationa
7393  Detective and protective services
7394  Equipment rental and leasing
7395  Photoflniarung laboratories
7396  Trading stamp services
7397' Commercial testing laboratonea
7399  Business services, nee
7912  Passenger car rental and leasing
7513  Truck rental and (easing
7519  Utility trailer rental
7523  Parking tots
7525  Parking structures
7531  Top and body repair shops
7934  Tire retreading and repair shops
7535  Paint shoos
7536  General automotive repair shops
7539  Automotive repair snops. nee
7542  Carwasnes
7549  Automotive services, nee
7622  Radio a-c -revision repair
7623  Refnge'a: en service and repair
7629  E!.ec:rcai -eaair snoos. nee
7831  Watcn  rccx. and jewelry repair
7641  Reuancisis-y and furniture repair
7692  Welding reoair
7694  Armature rewinding snops
7653  Repair services, nee
7813  Motion oicture orcduction. exceot TV
781-t  Motion aicture aroducticn 'or TV
78*9  Services aiiiac :o .-notion oictures
7823  Motion gic:.re 'iim »xc.iano.es
7824  Filmor?aoediS(rioit:cn?orTV
7829  Motion cicture astncution services
7832  Motion octure theaters exceot arwe-n
7833  Onve^n motion picure theaters
79i t  Oance nails, studios, and scnoots
7922  Tneatncai craaucem and services
7929  Entertainers and entertainment jrauas
7932  Billiard and oool estaonsnmenis
7933  Bowling alleys
7941  Scons clues and promoters
7946  Racing, including track operation
7992  Pueiie golf courses
7993  Coin*ooeratea amusement devices
7996  Amusement earns
7997  Memoersnio soons and recreation duos
7999  Amusement and recreation,  nee
SOU  Offices of onysicians
8021  Offices of oentists
Note: nee • not elsewhere classified.
                                                40

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                                                              SIC
                                                              Code Industry
   8031  Offices of oeteocatnic physicians
   8041  Offices of chiropractors
   3042  Offices of optometrists
   8049  Offices of health practitioners, nee
   8051  Skilled nurse care facilities
   8059  Nursing and personal care, nee
   8062  General medical and surgical hospitals
   8083  Psychiatric hospitals
   8069  Specialty hospitals, except psychiatric
   8071  Medical laboratones
   8072  Dental laboratories
   8081  Outpatient care facilities
   8091  Health and allied services, nee
   8111  Legal services
   8211  Elementary and secondary schools
   8221  Colleges and universities, nee
   8222  Junior colleges
   8231  Libraries and information canters
   8241  Correspondence schools
   8243  Data processing schools
   8244  Busirass and secretarial schools
   8249  Voca.ional schools, nee
   8299  Schools and educational services, nee
   8321  Individual and family services
   8331  Joo training and related services
   8351  Child day care services
   8361  Residential care
   8399  Social services, nee
   8411  MLiflums and art galleries
   8421  Botanical and zoological gardens
   8611  Business associations
   8621  Professional orgamzations
   8631  Labor organizations
   8641  Civic ano social associations
   8651  Political organizations
8661   Religious organizations
8699   Memeership organizations, nee
8811   Pnvate households
8911   Engineering and architectural services
8922   Noncommercial research organizations
8931   Accounting, auditing, and bookkeeping
8999   Services, nee
9111   Executive offices
9121   Legislative bodies
9131   Executive and legislative combined
9199   General government, nee
9211   Courts
9221   Police protection
9222   Legal counsel and prosecution
9223   Correctional institutions
9224   Fire protection
9229   Public order and safety, nee
9311   Finance, taxation, and monetary policy
9« 11   Administration of educational programs
9431   Administration of public health programs
9441   Administration of social and manpower programs
9451   Administration of veterans' affairs
9511   * '  water, and solid waste management
9512   w i" ". mineral, wildlife conservation
9531   Housing programs
9532   t rr 30 and community developm ent
96 n   Ac-mistration of general economic programs
9621   Peculation, administration of '.ransoonation
9631   Pagination, administration of utilities
9641   Hec>a:ion of agricultural marxeting
9651   Regulation miscellaneous commercial sectors
9651   Soace -esearcn and technology
9711   Nararai security
9721   imernar.cnai art airs
SS99   Nonc.'ass.ftaa'e estaoiisnment
Note: nee • not elsewhere classified.
                                           41

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    or
                                                                               ^gr oe/ /»r/o>v
WASTE DESCRIPTION CODES FOR RCRA F. K. P. and U WASTE CODES
A01 K waste, exactly as described'
A02 (=001-POOS, as a spent solvent (organic
    liquid)
A03 F001-F005. as a still bottom (organic
    sludge)
A04 (=0064=028 waste, exactly as described*
ACS Aqueous wastes by mixture/derivation
    rule containing F, K. P. or U (e.g..
    leacnate, scrubber water, or other
    wastawanra)
A06 Soil or cleanup residue contaminated
    with F. K. P. or U
A07 P or U. as a concentrated off-
    specification or discarded product
A08 Empty containers that held a P or U
    waste
A09 Incinerator ash from the treatment of
    F. K. P. or U
A10 Solidification residual from the treat-
    ment of F. K. P. or U
A11 Wastewater treatment residual from the
    treatment of F, K. P, or U
A12 Other
•"Exactly as described" means that we need no further clarification of the description provided in the list of RCRA waste codes in Appendix C of
 the Instructions booklet.
WASTE DESCRIPTION CODES FOR RCRA D and X WASTE CODES
INORGANIC UQUIOS—Waste that Is
primarily aqueous and is highly flute.
with low-to-moderate suspended inor-
ganic solids and tew organic content
B01 Solvent-water mixture
802 Oil-water emulsion or mixture
803 Concentrated water solution of or-
    ganics
804 Wastewater with trace organics
80S Concentrated spent acid with no
    metais
806 Spent acids with metals
807 Acidic aoueous waste
808 Concentrated noncorrosive. aqueous
    solution of metals
809 Wastewater or dilute solution with
    metals
810 Caustic aqueous waste with metals
    only
S'' Caustic acueous waste with cyanic.es
    ars retals
S12 Caustic acueous waste with cyanides
    oniy
3:3 Caustic acueous waste with suffices
5••* Caustic aqueous waste
5:5 Concentrated waste caustic
=,'5 Acuecus waste with strong oxidizers
B'7 Acueous waste with strong reducants
318 Aqueous waste with explosives
819 Waste liquid mercury
820 Other aqueous waste with high dis-
    solved solids (brine)
821 Other aqueous waste with low dis-
    solved solids content
822 Other inorganic liquid

INORGANIC SLUDGES—Waste that is
primarily inorganic, with moderate organ-
ic content and/or moderate water con-
tent; potentially settles into two phases
823 Inorganic sludge contaminated primari-
    ly wttn solvents, oil. or other organics
824 Higniy acidic sludge with metals
825 Other highly acidic sludge
826 Metal hycroxide sludge
827  SuHide slucge
828 Suifate or suitite sludge
829 Cyanide sludge
830 Other caustic sludge
831  Sludge with strong oxidizers
832  Sludge with strong reductants
833  Sludge with explosives
834  Brine sludge (with high chloride, fluo-
      ride. or bromide)
83S  Nutrient sludge (with high nitrate,
      phosphate, or urea)
836  Spent filtering aids
837  Wet scrubber sludge (fly ash), metal
      oxides, or ores
838  Sludge of metal scale, filings, or
      scrap (crushed drums)
839  Inorganic paint or pigment sludges
840  Other inorganic sludges

INORGANIC SOLIDS— Waste that is
primarily inorganic and solid, with low
organic content and low water content
841   Soil or debris contaminated primarily
      with solvents, oil. or other organics
842  Other contanina-:-r :cil o>- reons
8-13  Sail of a strong ::•:
844  Sait of a string : m
      (solid NaCH. KC-. *::.)
8^5  Suifare or SL:r,:e
846  Cyamce sail
847  Chtorae. 'lucrse. :r  --or- ~a salts
8*8  Nitrate. pnc::n;:r. :r jrea salts
849  Other metai sail
850  Strong oxioizer salt
851   Strong reductant salt
852  Solid explosive or propeilant
853  Solid spent filters
854  Dry fly asn. metal oxide. or ores
855  Solid metal scale, filings, or scrap
      (crushed drums)
855  Inorganic paint or pigment solids
857  Batteries and battery parts, casings,
      cores, etc
      Other inorganic solids
                                         858
                                         ORGANIC UQUIOS— Waste that is primar-
                                         ily organic and is highly fluid, with low in-
                                         organic, solids content and low water
                                         content
                                         859  Halogenated solvent
                                         360  Ncnnatogenated solvent
                                         B61  Waste oil
                                         862  Any organic liquid with PCSs
                                         B63  Any organic liquid/solution of otner
                                              toxic organics

                                                   U?
                                                                                 864

                                                                                 865

                                                                                 866

                                                                                 867
                                                                                 868
     Organic paint or coating (lacquer.
     varnish, epoxies)
     Paint thinner or spent petroleum
     distillates
     Reactive or polymerizeable organic
     liquid
     Other combustible organic liquid
     Other organic liquid
                                                                                 ORGANIC SLUDGES—Waste that is
                                                                                 primarily organic, with moderate
                                                                                 inorganic solids content and moderate
                                                                                 water content; potentially settles into
                                                                                 phases
                                                                                 869  Still bottoms of halogenated solvents
                                                                                       or liquid
                                                                                 870  Still bottoms of nonhalogenated
                                                                                       solvents or liquid
                                                                                 671   Oily sludge
                                                                                 E72  SlLCge with PCSs
                                                                                 =73  Siurge with ctner 'oxic organics
                                                                                 . E~-  Crcsnic :amt s'u^ge
                                                                                 ="  Siu"j;e with cetrc:e..T! r.'stiliates
                                                                                 575  3eac:;ve or poiymenisac.e or-arvc
                                                                                 c-7
                                                                                 E73
                                                                                 B79
                                                                                 880
      Ses:rs cr viscous, ncntar-y organics
      Tars or rarry slucge
      Sioicgicai slucge
      Other organic siuoge
ORGANIC SOLIDS—Waste that is primar-
ily organic and solid, with low inorganic
content and low water content
881   Solid waxes or polymerized organics
882   Spent caroon contaminated wnn ;cx:<
   .   organics
883   Reactive organic solid
884   Halogenated off-spec or discarded
      solid organic chemical
885   Organo-nitrogen organic chemical
      (nitrogen pesticide)
886   Phosphoro-thioate organic cne-nicai
887   Miscellaneous off-spec organic
      chemical
388   Other organic solid

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                                        PROCESS COOES
TREATMENT AND RECYCLING
Incineration/thermal treatment
11     Liquid injection incineration
21     Rotary kiln incineration
31     Fluidized bed incineration
41     Multiple hearth chamber incineration
SI     Pyralytic destruction
61     Other incineration/thermal treatment
ROHM aa fuel
1R    Cement kiln
2R    Aggregate kiln
3R    Asphalt kiln
4R    Other kiln
SR~   Blast furnace
6R    Sulfur recovery furnace
7P    Smelting, melting, or refining furnace
8R    Coke oven
9R    Other furnace
lOfi   Industrial boiler
HR   Utility boiler
12R   Process heater
13R   Other reuse as fuel unit
Fuel blending
iFB   Fuel blending
Solidification
1S    Cement-based processes
2S    Pozzolanic processes
3S    Asonaltic processes
45    Thermoplastic techniques
       Organic polymer techniques
       Jacketing (macro-encapsulation)
       Other solidification
£5
63
7S
Recovery of solvents and other organic chemicals
1SR  Fractionation
2SR  Batch stiH distillation
3SR  Solvent extraction
      Thtn film evaporation
      Other solvent recovery
Recovery of metala
i MR  Activated carbon (for metala recovery)
2MR  Electrodialysiii (for metals recovery)
      Electrolytic metal  recovery
      Ion exchange (for metals recovery)
      Reverse osmosis  (for i-etals recovery)
      Solvent extraction (for  meiais recovery)
      Ultrafillration (for metals recovery)
      Other metals recovery
Waatewater treatment
  Cyanide oxidation
      1W    Alkaline chlonnation
      2W    Ozone
      3W    Bectrochemical
      4W    Other cyanide oxidation
  Chemical precipitation (see Note 1)
      5W    Lime
      flW    Sodium hydroxide
      7W    Sodaasti
      8W    Sulfide
      9V\    Otner precipitation
  Chromium reduction
      10W   Sodium bisulfite
      11W   Sulfur dioxide
      12W   Ferrous sulf ate
      13W   Other reduction
  Complexed metals treatment
      14W   HIC-I art precipitation
      15W   Of-er comptexed metals treatment
  Emulsion brea-.ig
      16W   The'tial
      17W   Chemical
      18W   Other emulsion breaking
  Adsorption
      19W   Caroon adsorption
      20W   ion excnange
      2'W   flesm aasorpKon
      22W   Otner adsorption
  Stnpomg
      23W
      24W
5SR
3MR
4MR
5MR
6MR
7MR
8MR
  Filtration
      25W
      26W
      27W
      28W
          Air stnoomg
          Steam stripping (see Note 2)

          Oiatomaceous earth
          Sand
          Muitimeoia
          Otner filtration
Oewatenng operations
    29W  Gravity thickening
    30 W  Vacuum filtration
          Pressure filtration (belt, plate, frame, and
          leaO
          Centrifuge
          Other oewatenng
      32W
      33W
                                                          Air flotation
                                                              34W  Dissolved air flotation
                                                              35W  Otner air flotation
                                                43
                                                                                                   (continued)

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TREATMENT AND RECYCLING (continued)
Waatewater treatment (continued)
  Oil skimming
      36W  Gravity separation
      37V»  Coalescing plate separation
      38W  Other oil skimming
  Aerobic biological treatment
      39W Activated sludge
      40W Rotating biological contactor
      41W  Trickling filter
      42W  Waste stabilization pond
      43W  Other aerobic treatment
  Anaerobic biological treatment
      44W  Anaerobic digestion
      45W Other anaerobic treatment
  Other wastewater treatment
      46W  Wet air oxidation
      47W  Neutralization
      48W  Nitrification
      49W  Oenrtnfication
      SOW  Rocculanon
      Si W  Settling (clarification)
      52W. Other wastewater treatment
                                     OTHER WASTE TREATMENT
                                     1T   Other waste treatment


                                     ACCUMULATION
                                     1A   'Containers
                                     2A   Tanks


                                     STORAGE
                                     1ST  Container (i.e.. barrel, drum)
                                     2ST  Tank
                                     3ST  Waste pile
                                     4ST  Surface impoundment
                                     SST  Other storage


                                     DISPOSAL
                                     10   Landfill
                                     20   Land treatment
                                     3D   Surface impoundment (to be dosed as a landfill)
                                     40   Underground injection well
 Off-Site Management Codes —  Enter the Management Process  Code that you believe
 will be used by the facility receiving the waste or waste mixture entered.  Management
 process codes are listed below.
     Code
        Off-Site Management Process
C01
C02
C03
C04
COS
C06
C07
COS
.........
.........
                    Burning in boiler
                    Recovery/reclamation
                    Incineration
                    Landfill
                    Surface impoundment
                    Underground injection
                    Discharge to POTW
             ---------  Discharge to surface water under NPDES
       C09  ... ......  Discharge to privately-owned wastewater treatment works
       CIO  .........  Land application
       Cll   ..... —  Other, Specify in 'Comments*
                                          44

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                                      DEFINITIONS
CONDITIONALLY EXEMPT SMALL  QUANTITY GENERATOR — A site is a  conditionally
exempt small quantity generator (CESQG)  in any  given month,  if for that  month it meets  the
following criteria:  (1) the site generated no more than 100 kilograms of hazardous waste, AND
no  more  than  1 kilogram of acutely hazardous waste, AND no more than 100  kilograms of
material from  the cleanup of a  spillage  of acutely hazardous  wastes;  AND  (2)  the  site
accumulated no more than 1,000 kilograms of hazardous waste, AND no more than 1 kilogram
of acutely hazardous waste, AND no more than 100 kilograms of material from the cleanup of a
spillage of acutely hazardous wastes; AND (3)  the site treated or  disposed of the hazardous
wastes in a manner consistent with regulatory provisions.  (261.5f3 and 261.5g3)

To  be a CESQG for the entire  survey  year, a site must meet these criteria each month of that
year.  If a site  meets the criteria for Full Regulation (see definition below) in any month of  the
survey year, the site is subject to quantity reporting requirements for that month.

EPA NOTIFICATION OF HAZARDOUS WASTE ACTIVITY FORM (EPA FORM 8700-12) -
Under RCRA regulations, generators and processors must notify EPA of their hazardous waste
activities. The EPA Notification of Hazardous Waste Activity form is used to make this formal
notification.  After receiving such a form, the Agency  assigns an EPA  Identification number to
the site submitting this form.  So if your site has  an EPA number, this form has  already been
submitted; however, to  have indicated  generator or small quantity  generator status, those boxes
indicating this status had to  have been  checked on the  "hazardous waste activity" section of this
form.   If you  are unsure, refer to the  form you  submitted to EPA  to  obtain your  EPA  ID
number and  look  at Section A, "Hazardous  Waste Activity,"  under "VI.  Type  of Regulated
Waste Activity."

EPA PART A PERMIT APPLICATION — This is  the first step in  obtaining a RCRA permit to
treat, store, or dispose of hazardous waste.  This application defines the processes to be  used  for
treatment, storage, and  disposal of hazardous waste; the design capacity of such processes; and
the  specific hazardous wastes to be  handled at the applying facility.  A Part  A application must
have been filed to obtain "interim  status" to allow hazardous waste facilities,  existing  prior to
promulgation of the RCRA regulations, to continue operations until their final permit is issued.
Thus, if your site has either  interim status or a final RCRA permit to handle hazardous  waste, a
Part A application  has  been submitted for your site.  If you submitted a Part A application as a
protective measure, but you have never handled hazardous waste nor submitted a  modification
to your original application,  you should answer yes to the form selection question  which asks if
you have ever submitted such an application.

EXIST — A treatment, storage, or disposal method whose intended function is hazardous waste
handling is felt to  "exist" at  a site regardless of whether or not it is operational or used.  Thus,
this term  not only  includes methods which  are- operational, and used, but those  which were not
used, were not operational, or were  being built during the survey year.

FORMALLY WITHDRAWN  — ?

FULL  RCRA REGULATION — This term is used with regard  to hazardous waste generation.
Those generators subject to  full RCRA regulation are  those which meet the following  criteria:
(1) generated within any single month of the reporting year   1,000 or more  kg of hazardous
waste,  more than  1 kg of acute hazardous waste, or more than 100 kg of acute hazardous spill

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debris; or (2) accumulated at any  time  during the reporting  year  more than:   1,000 kg  of
hazardous waste, 1 kg of acute hazardous  waste, or  100 kg acute hazardous spill debris.

MANAGEMENT — Includes  the  following hazardous waste handling methods:  (1)  storage in
units  requiring a RCRA permit, (2)  treatment in permitted or RCRA exempt processes, (3)
recycling  in  permitted or RCRA exempt processes, and  (4) disposal  in permitted  or  RCRA
exempt units. Excluded are containers and  tanks subject  to an accumulation exemption under
262.34.

The major  requirements  for the  262.34  accumulation exemption  vary  by  level of waste
generation.   For  generators  subject to full  RCRA  regulation, the waste cannot be  stored for
more  than 90 days and there are specific  labeling .and  handling  requirements.   For small
quantity generators, the storage limit is 180  days, unless the generator must  transport his waste
or offer his waste for transportation over a distance of 200 miles  or more.  Then, the  storage
period is extended to 270  days.  Small quantity generators are subject to an accumulation  limit
of 6,000 kilograms as well as labeling and handling requirements.

PRIMARY SOURCES — This term refers to the  non-hazardous waste  material from which a
hazardous waste  was  originally  generated.    Wastes or residues  which are  derived   from  a
hazardous waste are considered to have been generated from a secondary source.

REGULATED FACILITY  -- This is a site which treats, stores, or disposes  of hazardous waste
and is subject to regulation,  i.e., required to have a  RCRA  permit.   Facilities which  have
interim status are included.

SMALL QUANTITY  GENERATOR (SQG) — A site is  a small quantity generator  in any given
month if it meets the following criteria:  (1) in every single month, the site generated more than
100 but no  more than 1,000 kilograms of hazardous waste, AND  no more  than 1 kilogram of
acutely hazardous waste, AND no more  than  100  kilograms of material from  the  cleanup of a
spillage of acutely hazardous wastes; AND (2) the site accumulated no more than 1 kilogram of
acutely hazardous waste, AND no more  than  100  kilograms of material from  the  cleanup of a
spillage of acutely hazardous wastes; AND (3) the site stored its wastes  in tanks or  containers in
a manner consistent with regulatory provisions.

To be an SQG for the entire survey year,  a site must meet  these criteria  each month of the
survey year. If a site meets  the criteria  for full regulation (see definition below) in  any month
of  the survey year, the site is  subject to the  reporting requirements for that  month.
                                       46

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                                   EXCLUDED WASTES
                         (Reference 261.4 and 261.3c2ii of 40 CFR)
Waste Category
                          Waste Description
Acid
Agriculture,
Irrigation

Cement Kiln Dust
Potentially recyclable spent sulfuric acid that is  used to produce virgin
sulfuric  acid.   To  be  exempt,  the acid  must  not be  accumulated
speculatively as defined in 40 CFR 261.1c.

Irrigation return flow.
Waste from a cement kiln.
Chromium,
Leather Tanning
Drilling Fluids
Emission Control
Wastes
Fertilizer
Household
A waste which is considered hazardous because (1) it is a listed due to
the presence of chromium  or (2) it ha filed  the characteristics of HP
toxicity due to  chromium's  presence.  This waste  must also meet  the
criteria for exclusion listed  in  261.4b6.   See flowchart on page  for
reference.

A drilling fluid,  produced  water or other waste  associated with  the
exploration,  development or production of crude  oil, natural  gas  or
geothennal energy.

Fly ash waste, bottom ash waste, slag waste or flue gas emission control
waste generated primarily from  the combustion of coal or other fossil
fuels.

Solid wastes generated  from growing  and  harvesting  of  agriculture
crops or  raising of  animals (including  manure), where the  waste is
returned to soil  as a fertilizer.

Household waste, including household  waste  that  has been collected,
transported,  store,  treated,  disposed,  recovered (e.g.,  refuse-derived
fuel),  or  reused.    "Household waste"  means any  waste  material
(including garbage,  trash, and sanitary  wastes in septic tanks) derived
from households (including  single and  multiple residences, hotels and
motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic
grounds, and day use recreation areas).

Note:   A  resource  recovery facility managing municipal  solid  waste
shall not be deemed to be treatment, storing, disposing of, or otherwise
managing hazardous wastes  for the purposes of regulation under RCRA
if that  facility:  (1) receives and burns only household wastes  (from
single  and multiple  dwellings,   hotels,  motels and  other residential
sources) and  solid waste from commercial or industrial  sources that
does not  contain  hazardous waste;  and (2) does not  accept hazardous
wastes  and  the owner or  operator of  the  facility  has  established
contractual requirements or  other appropriate  notification or inspection
procedure to assure that hazardous  wastes are neither received  nor
burned in  the facility.
                                            47

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Excluded Wastes (Continued)
Waste Category
                          Waste Description
Mining



Mining, In-situ


Mining, Overburden

Nuclear
Precipitation
Runoff

Pulping Liquor
Sewage, Domestic
A solid waste from the extraction, beneficiation and processing of ores
and minerals. (This includes phosphate rock and overburden from the
mining of uranium ore.)

Material subjected to  in-situ mining techniques where the material  is
not removed as part of the extraction process.

Mining overburden returned to the mine site.

Source, special nuclear or byproduct material as defined by the Atomic
Energy Act  of  1954,  as  amended 42  U.S.C.  2011 et seq.  From the
Atomic Energy Act,  these terms are defined as follows:

"Byproduct  material"  means:   (1) any radioactive  material (except
special nuclear material) yielded in or made radioactive by exposure  to
the radiation  incident to  the process of producing or utilizing special
nuclear  material,  and (2)   the  tailings  or  wastes  produced by  the
extraction  or concentration  of uranium  or  thorium  from any  ore
processed primarily for its source material content.

"Source material"  means:  (1) uranium,  thorium, or any  other material
which is determined  by the Commission pursuant to the provisions  of
Section 2091 of this  title to be source material; or (2) ores  containing
one or  more  of the  foregoing  materials in such  concentration as the
Commission may by  regulation determine from  time to time.

"Special  nuclear material" means:   (1) plutonium,  uranium enriched  in
the isotope 233 or in the  isotope 235, and any other material which the
Commission, pursuant  to the provisions of Section  2071  of  this title,
determines to be  special nuclear material,  but  does not  include source
material;  or  (2)  any  material  artificially enriched  by  any  of the
foregoing, but does not include  source material.

If the excluded  material described above  is  mixed  with a  hazardous
waste, the  material  is regulated under  RCRA as well  as  under the
Nuclear  Regulatory Act.

Precipitation runoff  generated by the treatment, storage, or disposal of
hazardous waste.

Potentially recyclable pulping liquor (black  liquor) reclaimed in pulping
liquor recovery  furnace so long as the material is reused in the pulping
process  and is  not  accumulated  speculatively as  defined  in 40 CFR
261.Ic.

Domestic sewage  — any  untreated sanitary wastes that pass  through a
sewer system.
                                            48

-------
Excluded Wastes (Continued)
Waste Category                                   Waste Description


Sewage, Domestic       Any mixture of domestic sewage and other wastes that pass through a
                       sewer system to a publicly owned treatment works (POTW).

Wastewater, Point       Industrial wastewater discharges that are point source discharges subject
Source                 to regulation under Section 402 of the  Clean  Water Act, as amended.
                       This exclusion applies only to the actual point source discharge.  It does
                       not  exclude industrial wastewaters  while they  are  being collected,
                       stored, or treated before discharge, nor does it exclude sludges that are
                       generated by industrial wastewater treatment.

Wood, Wood           A solid waste consisting of discarded  wood or wood products which
Products               fail the test for the characteristics of EP toxicity (but is not considered
                       hazardous for any other reason) and is generated by persons who utilize
                       the arsenical-treatment wood and  wood products for these materials'
                       intended end uses.
                                            49

-------
*,
 M.
 JT  National Governors'Association                               wuointon
^                                                                     Governor of Arkansas
<*"                                                                     Chairman

                                                                       Raymond C Scheppach
                                                                       Executive Director
                                          APPENDIX C

                                  Detail System  Flow Diagrams
             HALL OF THE STATES • 444 North Capitol Street • Washington. D.C 20001 -1572 • (202) 624-5300

-------
                                  APPENDIX C

                              SYSTEM DEFINITION

    This appendix  presents  the  current  logical description  of the  system in
the form  of diagrams  generated  by  a system development  tool.   Following the
diagrams are written  descriptions of  the  entities appearing on  the diagrams.
For clarity,  some  of  the   terms  used  in  the diagrams  are  defined  in the
following paragraphs.

    The items  appearing on  the  diagrams  are  external entities,  data stores,
data flows,  and processes.    These diagrams are  intended  to show  the flow of
data from  sources  to sinks  (destinations)  through  a variety  of  transforma-
tions,   represented by  processes.   External   Entities,   processes,   and  data
stores  each  have  a  code   associated  with  them  to  facilitate  reference.
External entities  are represented  by a box and have  identifiers  prefixed by
"EE" (for  example "EE  1"  is the  entity named "RESPONDENT  (HANDLER}").  Data
stores have  identifiers  prefixed by "D".  Data stores  local to a process will
have the  form  "Dxx/n" where  "xx"  is  the  process  number  and "n"  is a  unique
number,  for example  "D01/1" is  a data store used  by process  01 exclusively.
Processes  are   numbered using  a  decimal  code.   At  the  highest  level, the
numbers  are  two  digit numbers.   More  decimal  places  are  added  to  show
increasing  levels  of  detail.   For  example,  01.01  is   a  subprocess  of 01.
Processes which are "exploded" in  another  diagram have that diagram referenced
in the bottom of the process box.

    Data  flows  are  represented  by  a  single-headed  arrow.   The   arrowhead
designates  the  direction of  the  data flow.  Data  flows do not  show flows of
control nor do  they indicate concurrency of activities.   The intent  is simply
to show where the  data comes from and where it goes, not  how, not why, and not
when.

    The following definitions are applicable to these diagrams:

       o   Entity --  (1) External entity:  a source  or destination  of
           data on a data flow diagram; and  (2) something  about which
           information is stored in a  data store, e.g., customer,
           employees.

       o   External Entity (EE) — An entity that represents the
           scope of the  system being  identified.  Each external entity
           in the system needs to  be  represented by  a  decision maker
           that will help in  determining the scope and protecting
           the entity's  position.

       o   Data Flow  --  A group of data moving  on a  data flow diagram
           connecting  one function to another.  The  origin of the
           data is the source, and the receiver of the data, the
           destination.  One  data  flow (identified by a  name) can
           occur multiple times  on a diagram and will  be logged
           separately in the  dictionary as unique  occurrences for
           the same data flow name.

-------
                                     02

       o   Data Store — A resting place for data, once captured
           by a system, that includes facts about a system's external
           entities, past transactions, business policy, and
           rules.  Data Stores provide the 'slack' or 'give' in a
           system that uses information about real-world events
           across disjointed intervals of time; facts that cannot
           be expressed by an algorithm are recorded.

       o   Process -- (Transform, Transformation). A set of operations
           transforming data, logically or physically, according
           to some process logic.

    Following  the  twelve  pages  of  data  flow  diagrams,  the  various entities
appearing in the  diagrams  are defined.  The  definitions  are presented by  type
of entity:

       o   External Entities,
       o   Data Stores, and
       o   Processes.

    Each  entry  for these  entities  contains  a  short  description of the  entity
and other information  that aids  in  understanding the purpose of the entity and
its relationship with  other entities  in the  system.   The next section of  this
appendix  contains   the  data  dictionary  for  the data  flows appearing  in  the
system descriptions.  This appendix concludes with a summary of each of
the processes appearing  in the  diagrams.   The summary provides in  tabular  form
a  description  of  each  diagram  in  terms  of  the  entitites  it  contains.  These
sections  comprise  the system data  dictionary as it now  stands.   They will  be
refined   and   expanded   as  system   development  proceeds.   Once  the   issues
presented  in  this  paper  are  resolved,  sections  will  be  added  to  this
dictionary.  These sections will define data  bases,  data structures, and  data
elements.   At  this  point  the  data  dictionary  will  serve  as  the   system
functional description.

-------
DATA FLOW DIAGRAMS

-------
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-------
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-------
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-------

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-------
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EXTERNAL  ENTITY DESCRIPTIONS

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                                                                                                                               1...
                                                                               -EXItrXNfil.  ENTITY DCSCRII I JON- -  	
        EXTERNAL ENTITY  ID  :  EE  1

                      NAME  :  RESPONDENT
                               (HANDLER)

              LAST UPDATED  :  07-11-87
         The aggregate of the entities  completing the
         Annual/Etienni a 1 Report collection •form.   In general, these
         are the generators and regulated  handlers of hazardous
         waste.  States may specify  additional  criteria for
         requiring a response to  the local collection effort
                                                               	PRIMARY / PHONE	
                                                               «•• NO REPRESENTATIVE  •••
                                                               • ••NO PHONE NUMBER **•
                                        	AL1EFNATF / PHONE — -
                                        • •» NO ALTEPUA1F. **«
                                        •«M NO PHONE NUMBER «••
                                                                               -EXTERNAL  ENTITY DESCRIPTION--
        EXTERNAL ENTITY  ID  :  EE  2
                      NAME
              LAST UPDATED  :
                               IHPLEMENTOR
                               USE  OF
                               REPORTS

                               &/2&/B7
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         uses of implement.or reports.   This includes:
            - reports to legislatures and  local  governments.
            - responses to public  information requests.
            - support for program  management  activities.
            - use and distribution o(  state summary reports.
            - analysis of in-state waste management ^/sterns.
                                                               	PRIMARY / PHONF	
                                                               ••• NO REPRESENTATIVE  •»•
                                                               •«« NO FHONE NUMBER «•«
                                        	ALTERNATE / fHONL---
                                        »•«  NO ALTEP-NA1I  «••
                                        ***  NO FHONE NUI1&CR •••

                                                                               -EXTERNAL  ENTITY DESCRIPTION-
        EXTERNAL ENTITY  ID  :  EE  3

                      NAME  :  OVERSIGHT
                              USES  OF
                              DATA
              LAST UPDATED  :
                               6/26/B7
         This is an aggregate entity  representing all  uses of ami
         uses of oversight reports.   This includes:
            - reports to Congress  including the national  sun.mdry.
            - responses to public  information requests..
            - support for program  management  activities.
            - analysis of inter-state waste management system.
»*« CONTINUED *•*

-------
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                                                                           	PRIMARY / PHONE	     	ALTERNATE / FHONE	
                                                               *** NO REPRESENTATIVE • ••     • •• NO ALTERNATE •••
                                                               •** NO PHONE NUMBER »••       •••NO PHONE NUMBER •••
        EXTERNAL ENTITY  ID  :  EE 4
                      NAME  :  RCRIS
                               IMPLEMENTOR
                              DOMAIN
              LAST UPDATED  :
                                6/26/87
                                                                              -EXTERNAL ENTITY DESCR1PTIOH-
         This entity is the RCRIS data system  at  the  implementor
         domain.  All data requested by  implementors  (in  RCRIS) Mill
         be transferred at this point.
         	PRIMARY / PHONE	
         •*• NO REPRESENTATIVE  •••
         ••• NO PHONE NUMBER •••
	ALTERNATE / PHONE—
••* NO ALTERNATE •••
• •• NO PHONE NUMBER •••

        EXTERNAL ENTITY  ID  :  EE 5

                      NAME  :  RCRIS
                              OVERSIGHT
                              DOMAIN

              LAST UPDATED  :    6/26/87
                                                                              -EXTERNAL ENTITY DESCRIPT10N-
         This entity represents  the RCRIS  data  system  at  the
         oversight domain.  All  data requested  by  oversight
         personnel will be transferred  at  this  point.
         	PRIMARY / PHONE	
         *«• NO REPRESENTATIVE  «•»
         • •• NO PHONE NUMBER •••
	ALTERNATE / FHONF-—
••• NO ALTERNATE •••
••• NO PHONE NUMBER • ••
        EXTERNAL ENTITY  ID  :   EE  &
                      NAME  :   EXTERNAL
                               IMPLEMENTOR
                               DATA
                               SOURCES
              LAST UPDATED  :
                                7/12/37
                                                                              -EXTERNAL ENTITY DESCR1HTION-
         Thpse are sources o( data  external  to the annual/hiennial
         reporting process which  are  used to verify and validate the
         data which has been reported.
         	PRIMARY  / PHONE	
         ••• NO REPRESENTATIVE  •••
         ••• NO PHONE  NUMBER •••
	ALTERNATE / FHONt	
•••NO ALTERNATE ••*
••• NO PHQNC NUMBER *•*


-------
                                                                  "
                     ,  6
                                                      EXTERNAL  ENTITY ATTRIBUTES
       = CSSSSBS = ^S;CB = BSS — — — — -- — — -- — — -- — --- — __ — __ — — __ __ __
                   --- ----  ---- ~ ----------- -- == = = = = == = = = = = = = = = = = = = = = = = = = = = = = = = = = = = =.= = = = = = = = .= == = = _ j i = == = = = =s; = = =.=. = = = = = = =

                                                               ---------------- EXTERNAL ENTITV DESCRIPTION

        EXTERNAL ENTITY ID :  EE 7                             These are sources o«  data available at the oversight level
                                                               Mhich are external  to the annual /biennial  reporting
                      NAME :  EXTERNAL                         process.  They are used to insure  reported  data is
                              OVERSIGHT                        consistent with the "real  world".
                              DATA
                              SOURCES

              . .__ 11DMTcn                                     ----- PRIMARY /  PHONE -----     ---- ALTERNATE / PHONE ----
              LAST UPDATED s   7/12/B7                         *•• NO REPRESENTATIVE •••     ••» NO ALTERNATE •••
                                                               •«• NO PHONE NUMBER •••        ••• NO PHONE NUMBER •••
                —-  —- — —
TOTAL NUMBER OF EXTERNAL ENTITIES ON PROJECT DICTIONARY  VERSION 6 s        7

TOTAL NUMBER OF EXTERNAL ENTITIES ON REPORT:                               7

-------
DATA STORE  DESCRIPTIONS

-------
Prc
ID:
           YSf
       /STEM VERSION: 6
                 Annual/Hi
                               I  Report System
                                                                              ANAKL'O?
                                                                              O^/lB/b
                                             UiL
                                                       DATA Slu..^ ATTRIBUTES
DO1/1
            -DATA STORE ID & NAME	

                UNEDITED DATA STORAGE
                                                                                     -DATA STORE DESCRIPTION-
LAST UPDATEi  07/17/87
                     KEY
                     SEQ
                            EXT
                           INDEX
      TOTAL ITEMS IN DATA STORE:
                                                              This is the respository for all data accepted by the data
                                                              entry process.  It has been subjected to no editing or
                                                              validation procedures.  As data passes the Key entry
                                                              editing process, it is removed from this data base store.
NORMALIZED: NO

CONTAINS
\DATA STRUCTURES, ELEMENTS

  \REPORT FORM PACKAGE
    EPA IDENTIFIER
   \FORM SUBPACKAGE - ALL
    NFQRM 1C - IDENT & CERT
    \FQRM FS - FORM SELECTION '
  C \FORM RS - REGULATORY STATUS 1
  [ \FORM WD - WASTE DESCRIPTION ]
   \FORM SUBPACKAGE - TSD
  C \FORM 01 - OFFSITE IDENT. ]
  C \FORM RO - REC. FROM OFFSITE D
  C \FORM PS - PROCESS SUMMARY 3
   \FOWI SUBPACKAGE - GENERATOR
    \FORM PG - PRIMARY GENERATION
  C \FORM UN - WASTE MINIMIZATION ]
  [ \FORM SO - SHIPPED OFFSITE 3
ALTERNATE\                      MA XIMUM
DISCRIMINANT    TYPE    SIZE    ITERATION   DECIMALS
                                                                                                           12
                                                                              TOTAL DATA STORE SIZE:
                                                                                                           12
D02/I
            -DATA STORE ID S. NAME	

                INVALIDATED DATA STORAGE
                                                                                     -DATA STORE DESCRIPTION-
                                                              This is data has passed the key-entry editing processes and
                                                              is accumulated until data validation  (a batch process) is
                                                              performed.  As data passes the validation processes,  it is
                                                              removed from this data store.
LAST UPDATE:  O7/17/B7
                                   NORMALIZED: NO
                     KEY    EXT    CONTAINS
                     SEQ   INDEX   SCATA STRUCTURES, ELEMENTS

                                     \REPORT FORM PACKAGE
                                       EPA IDENTIFIER
                                      \FORM SUBPACKAGE - ALL
                                       \FORM 1C - I DENT & CERT
                                       \FORM FS - FORM SELECTION
                                     C \FORM RS - REGULATORY STATUS
                                                                                AL TERNATE\                      MAXIMUM
                                                                                DISCRIMINANT    TYPE    SIZE    ITERATION   DECIMALS
                                                                                                          12
*** CONTINUED **•

-------
fro1
ID
         STEM VERSION:  6
                                        Annual/En

                                           DAI A S
                               I Report System

                               ATTRIBUTES
                                                                                                                  H7/1I3/1
                                                                                                                             IV:7':71
	DATA STORE  ID t, NAME-
*** CONTINUED *••
D02/1
                UNVALIDATED DATA STORAGE
                     KEY
                     SEQ
                EXT
               INDEX
      TOTAL ITEMS  IN DATA STOREI
CONTAINS
\DATA STRUCTURES, ELEMENTS

  C \FQRM UD - WASTE DESCRIPTION 1
   \FORM SUBPACKAGE - TSD
  [ \FORM OI - OFFSITE IDENT. 1
  [ \FORM RO - REC. FROM OFFSITE 1
  C \FORM PS - PROCESS SUMMARY 1
   \FORM SUBFACKAGE - GENERATOR
    \FORM PG - PRIMARY GENERATION
  C \FORM UM - WASTE MINIMIZATION :
  C \FORM SO - SHIPPED OFFSITE 1
                                      15
ALTERNATES
DISCRIMINANT
                                                                                                TYPE
                                                                                                        SIZE
MAXIMUM
ITERATION
                                                                                                                             DECIMALS
                                                                              TOTAL DATA STORE SIZE:
                                                                                                           12
                                                                                                                        12
DOS/1
-DATA STORE ID S. NAME	

    UNAUDITED DATA STORAGE
                                                                                      -DATA STORE DESCKIPT10N-
                                                              This data has been received front the implementor domain.
                                                              At this point the data has been certified as valid by  the
                                                              implementors creating it.  Data is stored at this point
                                                              until data auditing  (a batch process) is performed.  When
                                                              data passes the auditing processes, it is removed from this
                                                              data store.
LAST UPDATE:  O7/17/B7
                                   NORMALIZED: NO
                     KEY    EXT    CONTAINS
                     SEQ   INDEX   \DATA STRUCTURES, ELEMENTS

                                     \REPORT FORM PACKAGE
                                       EPA IDENTIFIER
                                      \FORM SUBPACKAGE - ALL
                                       \FORM 1C - IDENT & CERT
                                       \FORM FS - FORM SELECTION
                                       \FORM RS - REGULATORY STATUS 1
                                       \FORM WD - WASTE DESCRIPTION 1
                                      \FORM SUBPACKAGE - TSD
                                       \FORM 01 - OFFSITE IDENT. 1
                                       \FORM RO - REC. FROM OFFSITE 3
                                       \FORM PS - PROCESS SUMMARY 1
                                      \FORM SUBPACKAGE - GENERATOR
                                       \FORM P6 - PRIMARY GENERATION
                                     C \FORI1 WM - WASTE MINIMIZATION 3
                                                                    ALTERNATES                       MAXIMUM
                                                                    DISCRIMINANT    TYPE    SIZE    ITERATION   DECIMAL?
                                                                                              12
*•• CONTINUED •*•

-------
 Fr     *ANAI.YS1
 II     .YS1EM VERSION:  6
------------- DATA STQRE
**• CONTINUED *«•
                  Annual/T      al  Report  System

                     DATA i.   .t  ATTRIBUTES
                                                                                                                            ~AGE:
                                                                                                                  07/ia/
                              NAME —
 DOS/1
                 UNAUDITED DATA STORAGE

                      KEY    EXT    CONTAINS
                      SEQ   INDEX   \DATA STRUCTURES, ELEMENTS
                                                                                ALTERNATES
                                                                                DISCRIMINANT
                                                                                                 TYPE
       TOTAL  ITEMS IN DATA STORE:
                                     I NFORM SO - SHIPPED OFFS1TE 3

                                     IS
                                                                               TOTAL DATA STORE SIZE:
                                                                             MAXIMUM
                                                                     SIZE    ITERATION    DECIMALS
                                                                                                           12           12
Dl
            -DATA STORE ID I. NAME	

                IMPLEMENTQR DATA BASE
                                                                                      -DATA STORE DESCRIPTION-
LAST UPDATE:  O7/17/B7
                     KEY
                     SEQ
                            EXT
                           INDEX
      TOTAL ITEMS IN DATA STORE:
                                                               This data base stores all  accepted and validated data at
                                                               the implementor level.  Typically one data base Mill  exist
                                                               far each state.  A state may be responsible its own data
                                                               base or have it created managed by the Region.
NORMALIZED: NO

CONTAINS
\DATA STRUCTURES, ELEMENTS

  \REPORT FORM PACKAGE
    EPA IDENTIFIER
   \FORM SUBPACKAGE - ALL
    \FORM 1C - IDENT & CERT
    \FORM FS - FORM SELECTION
  C \FORM RS - REGULATORY STATUS 1
  [ \FORM WD - WASTE DESCRIPTION 1
   NFORM SUBPACKAGE - TSD
  C NFORM 01 - QFFSITE I DENT. ]
  C NFORM RQ - REC. FROM QFFSITE 1
  C NFORM PS - PROCESS SUMMARY ]
   \FORM SUBPACKAGE - GENERATOR
    NFORM PG - PRIMARY GENERATION
  C NFORM MM - WASTE MINIMIZATION D
  C NFORM SO - SHIPPED OFFSITE ]
ALTERNATEN                      MAXIMUM
DISCRIMINANT    TYPE    SIZE    ITERATION   DECIMALS
                                                                                                           12
                                                                               TOTAL  DATA STORE SIZE:
                                                                                                           12
                                                                                                                        12
D2
            -DATA STORE  ID & NAME	

               OVERSIGHT DATA BASE
                                                                                      -DATA STQRE DESCRIPTION-
                                                              This data base stares  all data received from the
                                                              implementor domain.  The data stored here has been
»** CONTINUED *•*

-------
P-    ^"ANALYST
I      SYSTEM  VERSION:  b
                         Annual/'
                                         Report Svsteir
                                                        DATA - ^«E ATTRIBUTES
                                                                                      ANAK2'
                                                                                      07/1B
                                                                                                f rtGK
                   STQRE  ID  g,  NflME-
 *•* CONTINUED  ••»
                                                                                      -DATA STORE  DESCRIPTION-
D2
                OVERSIGHT  DATA  BASE
LAST UPDATE:  O&/26/B7
                     KEY
                     SEQ
 EXT
INDEX
      TOTAL ITEMS  IN DATA STORE:
                                                               subjected  to a  level  of  auditing beyond  the  QA activities
                                                               performed  on implementor data.  This  assures the
                                                               suitability of  this data for nationwide  summary and
                                                               analyses and validity in producing  intrastate waste
                                                               management system reports.
NORMALIZED: NO

CONTAINS
\DATA STRUCTURES, ELEMENTS

  \REPORT FORM PACKAGE
    EPA IDENTIFIER
   \FORM SUBPACKAGE - ALL
    SFORM 1C - I DENT S. CERT
    \FORM FS - FORM SELECTION
  C \FORM RS - REGULATORY STATUS 1
  [ \FORM UD - WASTE DESCRIPTION 1
   \FORM SUBPACKAGE - TSD
  I \FQRM 01 - OFFSITE IDENT. 1
  C \FORM RO - REC. FROM QFFSITE 1
  I \FORM PS - PROCESS SUMMARY ]
   \FORM SUBPACKAGE - GENERATOR
    \FORM PG - PRIMARY GENERATION
  C \FORM MM - WASTE MINIMIZATION 1
  [ \FORM SO - SHIPPED OFFSITE 3
                                      IS
ALTERNATE\                      MAXIMUM
DISCRIMINANT    TYPE    SIZE    ITERATION   DECIMALS
                                                                                                           12
                                                                               TOTAL DATA STORE SIZE:
                                                                                                           12
                                                                                                                        12
TOTAL NUMBER OF DATA STORES ON PROJECT DICTIONARY VERSION  6  :        5

TOTAL NUMBER OF DATA STORES ON REPORT:                               5

-------
f-r     'ANALYST
ID     YSTEM VLRS1UN:
                                        Annual/br     il Keport System

                                         DATA STRi..  .IRE ATTRIBUTES
                                                                                                                " rti.L'
                                                                                                                 D7/1G
	DATA STRUCTURE NAME-

REPORT FORM PACKAGE
                                                 -DATA STRUCTURE DESCRIPTION-
  TOTAL ITENS IN DATA STRUCTURE!
                                        This is the data structure defined by a collection of forms
                                        completed and submitted by a Haste generator or handler.
                                        This is the primary source of information for this system.
                                        Not all handlers Mill be required to complete all parts of
                                        the form.  This determination is made by instructions
                                        associated with certain answers to questions on the form.
                                        In addition, the modular nature of the form allows
                                        implementors (states) to collect additional information by
                                        inserting additional forms into the collection package and
                                        providing additional questions and/or instructions to aid
                                        handlers in completing the forms.
                                   CONTAINS
                                   \DATA STRUCTURES, ELEMENTS

                                     EPA IDENTIFIER
                                    \FORM SUBPACKAGE - ALL
                                     \FORM 1C - IDENT fc CERT
                                   .  \FORM FS - FORM SELECTION
                                   C \FORM RS - REGULATORY STATUS 1
                                   C \FQRM WD - WASTE DESCRIPTION 1
                                  C \FQRM SUBPACKAGE - TSD ]
                                   t \FORM 01 - OFFSITE IDENT. 1
                                   C \FORM RO - REC. FROM QFFSITE 1
                                   [ \FORM PS - PROCESS SUMMARY 1
                                  [ \FORM SUBPACKAGE - GENERATOR 1
                                     \FORM PG - PRIMARY GENERATION
                                   C \FORM MM - WASTE MINIMIZATION ]
                                   C \FORM SO - SHIPPED OFFSITE 1
                                      14
                                IS CONTAINED IN THESE:
DATA STORES
	ID	NAME
D01/1
                    	DATA FLOWS	

UNEDITED DATA STORA ANNUAL/BIENNIAL REPORT FORM




                    EDITED DATA




                    UNEDITED DATA
                                                                    ALTERNATE\
                                                                    DISCRIMINANT
                       TYPE

                        C
                   SIZE

                     12
                                       MAXIMUM
                                       ITERATION
DECIMALS
                                                               TOTAL DATA STRUCTURE SIZE:
                                                                                                           12
                                                                                                                        12
 -SOURCE	 DESTINATION
                                                                                             -DATA STRUCTURES-
EE 1
EE 1
EE 1
EE 1

01.04.03
Ol
01. O4
01

01.01
D01/1
001/I
D01/1
01.03.01
01
O1.O1
01. OZ

O2
O2
O2
02.01

D01/1
O1.O4.O1
O1.O2
O1.O4
                                                                                                 ••• NOT  IN ANY  DATA STRUCTURE  *••
•** CONTINUED *••

-------
l-ri
ID.
             VERSION: 6
Auriiidl/bi     il Report System

 DATA SIKL... .JRE ATTRIBUTES
	DATA STRUCTURE NAME-
**• CONTINUED «•*

REPORT FORM PACKAGE
                                 IS CONTAINED  IN THESE:
DATA STORES
	ID	f—NAME	     	DATA FLOWS	SOURCE	DESTINATION	DATA STRUCTURES	D/ I


                                TURNAROUND  DOCUMENT                      01.02       O1.O3.OI
                                                                          01.02       01.03

                                KEY-ENTRY CORRECTED DATA                 01.O4.O2    01.04.03
TOTAL NUMBER OF DATA STRUCTURES ON PROJECT  DICTIONARY VERSION 6 :

TOTAL NUMBER OF DATA STRUCTURES ON REPORT:
                   16

                    1

-------
Fr
II
»ANALYST
iYSTEM VERSION:  6
Annual /('     al  Report System

   DAI A i.   wTURE CONTENTS
         ANAK2L
         07/IB/
                    ftliL
	DATA STRUCTURE NAME-

REPORT FORM PACKAGE
  TOTAL ITEMS IN DATA STRUCTURE:
                             CONTAINS
                             \DATA STRUCTURES, ELEMENTS
                                     EPA  IDENTIFIER
                                     \FORM SUBPACKAGE - ALL
                                     \FORM  1C -  IDENT & CERT
                                     \FORM  FS -  FORM SELECTION
                                    [ \FORM  RS -  REGULATORY STATUS  1
                                    I \FORM  WD -  WASTE DESCRIPTION  1
                                  [  \FORM SUBPACKAGE - TSD D
                                    C \FORM  01 -  QFFSITE IDENT.  1
                                    E \FORM  RQ -  REC. FROM QFFSITE  1
                                    C \FQRM  PS -  PROCESS SUMMARY 1
                                  [  \FQRM SUBPACKAGE - GENERATOR 1
                                     \FORM  PG -  PRIMARY GENERATION
                                    C \FORM  MM -  WASTE MINIMIZATION  ]
                                    C \FORM  SO -  SHIPPED OFFSITE 1
                                       14
                            ALTERNATE\
                            DISCRIMINANT    TYPE
        MAXIMUM
SIZE    ITERATION   DECIMALS
                                                                                                    12
                                                                           TOTAL DATA STRUCTURE SIZE:
                                                                                                           12
                                                                                                                        12
TOTAL NUMBER OF DATA STRUCTURES ON PROJECT DICTIONARY VERSION 6  :       16

TOTAL NUMBER OF DATA STRUCTURES ON REPORT:                               1

-------
DATA FLOW DESCRIPTIONS

-------
 PrOKi t"ANALYST
 ID:  BRSYSTEM   SIGN:  6
 	DATA FLOW NAME-

 ANNUAL /BIENNIAL REPORT FORM


 LAST  UPDATED] O7-12-B7
                 Annual/Biennial  Repr  h  System

                     DATA  FLOW ATTR    18
 ANAR2OD3,  PAGE
 07/20/87,   21:OQ
                                        -DATA FLOW DESCRIPTION-
               RepresentE  information collected on the EPA Annual/Biennial
               Report -form.
                                    DATA FLOW TYPEi  NORMAL

                                    CONTAINS
                                    \DATA STRUCTURES, ELEMENTS

                                      \REPORT FORM PACKAGE
                                        EPA IDENTIFIER
                                       \FORM SUBPACKAGE - ALL
                                        \FORM 1C - IDENT & CERT
                                        \FORM FS - FORM SELECTION
                                        \FORM RS - REGULATORY STATUS 1
                                        \FORM WO - WASTE DESCRIPTION 1
                                       \FQRM SUBPACKAGE - TSD 3
                                        \FORM QI - OFFSITE IDENT. 1
                                        \FORM RO - REC. FROM OFFSITE 3
                                        \FORM PS - PROCESS SUMMARY 1
                                     C  \FORM SUBPACKAGE - GENERATOR 3
                                        \FORM PG - PRIMARY GENERATION
                                      I  \FORM MM - WASTE MINIMIZATION 3
                                      C  \FORM SO - SHIPPED OFFSITE 3
                                              ALTERNATEX
                                              DISCRIMINANT
                                                              TYPE
                                                                      SIZE
                                                                         12
MAXIMUM
ITERATION
                                                                                           DECIMALS
      TOTAL ITEMS  IN DATA FLOW:
                                                                                TOTAL DATA FLOW SIZE:
                                                                                                            12
                                                                                                                         12
	 SOURCE 	 DESTINATION
EE 1 01.O3.01
EE 1 01
EE 1 O1.O1
EE I 01. O3
	 KEY 1
«»* NO KEYS
*»* NO
*»* NO
**« NO
KEYS
KEYS
KEYS
	 DATA FLOW OCCURRENCES INFORMATION 	
ON DATA
ON
ON
ON
DATA
DATA
DATA
FLOW ***
FLOW •«*
FLOW «*«
FLOW «**

	DATA FLOW NAME-

AUDIT CORRECTED DATA


LAST UPDATED: O7-18-87

«*• CONTINUED ««*
                                     	DATA FLOW  DESCRIPTION	
               The portion of the Validated data  to which audit
               corrections have been applied.
DATA FLOW TYPE: NORMAL

-------
:>roKit*ANALYSt
IDi BRSYSTEM     JON: 6
                                    Annual/Biennial  Reppr   System

                                        DATA FLOW ATTRII    i
	DftTA
»** CONTINUED • »»
-UJD1T CORRECTED DATA
                                   CONTAINS
                                   \DATA STRUCTURES, ELEMENTS
                                                                ALTERNATE\
                                                                DISCRIMINANT
                                                                                                TYPE

                                     NOT DETERMINED

      TOTAL ITEMS IN DATA FLOW:        1                                         TOTAL DATA FLOW SIZE:

	DATA FLOW OCCURRENCES INFORMATION	:	

	SOURCE	    DESTINATION     	KEY 1 <\DX OR DE)	      	KEY 2 (\DX OR DE)	

05.O4.02        05.04.03        «** NO KEYS ON DATA FLOW »«•
                                                                                                        *-»**

                                                                                                           0*
                                                                ANAR2003, PAGE
                                                                O7/2O/B7,  ZllOOl
                                                               MAXIMUM
                                                       SIZE    ITERATION    DECIMALS
                                                                                                                        O*
                                                                                                          	KEY 3  <\DX OR DE)	
	DATA FLOW NAME	

1UDIT CORRECTIONS


-AST UPDATED: O7-12-87
                                                          -DATA FLOW DESCRIPTION-
      TOTAL ITEMS IN DATA FLOW:
                                  The corrections that have been determined to be necessary
                                  by the comparison process.
                                   DATA FLOW TYPE: NORMAL

                                   CONTAINS
                                   \DATA STRUCTURES, ELEMENTS
                                                                ALTERNATE\
                                                                DISCRIMINANT
                                     EPA IDENTIFIER
                                     XCHANGE DESCRIPTION
                                       EPA IDENTIFIER
                                               TYPE

                                                C

                                                C

                              TOTAL DATA FLOW SIZE:

-DATA FLOW OCCURRENCES INFORMATION	
                                                                                                        SIZE

                                                                                                          12

                                                                                                          12

                                                                                                          24
MAXIMUM
ITERATION
                                                                                                                       24
                                                                                                             DECIMALS
	SOURCE	

05.O3.O4

05.03

OS. 03

05.03
DESTINATION     	KEY 1 (\DX OR DE)	

05.04           •** NO KEYS ON DATA FLOW ***

OS.04           *«» NO KEYS ON DATA FLOW *«*

05.O4.01        *** NO KEYS ON DATA FLOW *«»

05.04.O2        **» NO KEYS ON DATA FLOW »**
                      -KEY 2 (\DX OR DE)-
                                                         	KEY 3  (\DX OR  DE)-

-------
    «Rr     >c,nw  *.                              Annual/Biennial  P     ».  System                                ANAR2OD3,  PAGE
    BRSYBTf     KIONi 6                                                                                           O7/20/B7.   21I
                                                         DATA FLOW AT.     ,ES
        	DATA FLOW NAHE	           	DATA FLOM  DESCRIPTION	
AUDIT ERRORS FROM EXTERNAL CHECKS                 Error* which have been detected by coaparison at data bame
                                                  contente  with  external sources of data available at the
                                                  oversight level,

LAST UPDATED! 07-12-87             DATA FLOW TYPEl EXCEPTION

                                   CONTAINS                                     ALTERNATES                      MAXIMUM
                                   \DATA STRUCTURES, ELEMENTS                   DISCRIMINANT    TYPE    SIZE    ITERATION   DECIMALS

                                     EPA IDENTIFIER                                              C        12
                                     \ERROR DESCRIPTION
                                       EPA IDENTIFIER                                            C        12

      TOTAL ITEMS IN DATA FLOWl       3                                        TOTAL DATA FLOW SIZEi      24           24

	DATft FLOW QCCURRENCES INFORMATION	

	SOURCE	    DESTINATION     	KEY 1 I\DX OR DEI	      	KEY 2  (\DX OR DE)	       	KEY 3  C\DX OR DE)	

OS.03.O1        03.O3.04        ••• NO KEYS ON DATA FLOW ***
            -DATA FLOW NAHE	          	DATA FLOW DESCRIPTION-
AUDIT ERRORS FROM INTERNAL CHECKS                 Thesa are errors detected through data examination and by
                                                  consistency checks.

LAST UPDATEDi O7-12-B7             DATA FLOW TYPEl EXCEPTION

                                   CONTAINS                                     ALTERNATES                      MAXIMUM
                                   \DATA STRUCTURES, ELEMENTS                   DISCRIMINANT    TYPE    SIZE    ITERATION   DECIMALS

                                     EPA IDENTIFIER                                              C        12
                                     \ERROR DESCRIPTION                                   '
                                       EPA IDENTIFIER                                            C        12

      TOTAL ITEMS IN DATA FLOW:       3                                        TOTAL DATA FLOW SIZE,      24           24

	DATA FLOW OCCURRENCES INFORMATION	

	SOURCE	    DESTINATION     	KEY 1 (\DX OR DE)	      	KEY 2  C\DX OR DE)	       	KEY 3 (\DX OR DE)	

OS.03.O2        OS.O3.04        ••* NO KEYS ON DATA FLOW ***

-------
ProKit•ANALYST
IDi BRSYSTF     tSIQNi 6
                                     Annual/Biennial Rennrt System

                                        DATA FLOW AT'.     ES
                                                                                  ANAR2QD3, PAGE
                                                                                  07/20/87,  21:
	DATA FLOW NAME	

AUDIT ERRORS FROM INTERSTATE CHECKS
                                   	DATA FLOW DESCRIPTION	

                                   Audit errors dactected by comparison of information between
                                   states.
LAST UPDATED: O7-12-87
                                    DATA FLOW TYPEl  EXCEPTION

                                    CONTAINS
                                    \DATA STRUCTURES, ELEMENTS
                                                                ALTERNATEX
                                                                DISCRIMINANT
                                     EPA  IDENTIFIER
                                     \ERROR  DESCRIPTION
                                       EPA IDENTIFIER
      TOTAL ITEMS  IN DATA FLOUl
	SOURCE	

OS.03.O3
DESTINATION

OS.O3.04
                                                                 TYPE

                                                                 C

                                                                 c

       3                                        TOTAL  DATA FLOW  SIZEl

	DATA FLOW OCCURRENCES INFORMATION	

 	KEY 1  <\DX OR DE)	      	KEY  2 (\DX  OR DE)	

 •••NO KEYS  ON DATA FLOW •••
                                                                                        SIZE

                                                                                          12

                                                                                          12

                                                                                          24
      MAXIMUM
      ITERATION   DECIMALS
                                                                                                                       24
 -KEY 3 (\DX OR DE)	
	DATA FLOW NAME-

AUDIT EXCEPTION REPORT



LAST UPDATED: 07-12-87
                                                          -DATA FLOW DESCRIPTION-
      TOTAL ITEMS IN DATA FLOMi
	SOURCE	

05.02

05.02

OS. 02
DESTINATION

05.03

O5.O3.O1

O5.O3.O3
                   A report  used  aa  a  source  document  for the performance of
                   both internal  and external  audit  checks.  Automated
                   consistency check results  appear  in this  listing.

    DATA FLOW TYPE:  NORMAL

    CONTAINS
    \DATA STRUCTURES, ELEMENTS

      EPA IDENTIFIER

       1

	DATA FLOW OCCURRENCES INFORMATION

 	KEY 1 (\DX OR DE)	      	KEY  2 (\DX  OR DE)

 ••• NO KEYS ON DATA FLOW *«•

 ••• NO KEYS ON DATA FLOW *••

 ••• NO KEYS ON DATA FLOW ***
ALTERNATEX MAX IMUM
DISCRIMINANT TYPE SIZE ITERATION DECIMALS
C 12
•QTAL DATA FLOW SIZE: 12

12
—KEY 3 <\DX  OR DE)	
«•• CONTINUED ***

-------
ProKit»ANALYSt
ID: BRSYSTEM     3IONs 6
            i
------------ DftTA
*** CONTINUED ***
AUDIT EXCEPTION REPORT
                                                    Annual/Biennial Record System

                                                        DATA FLOW ATTR     :S
	DATA FLQW OCCURRENCES INFORMATION	

	SOURCE	    DESTINATION     	KEY 1  <\DX OR DE)	      	KEY 2  <\DX OR DE)	

03.02           05.03.02        *** NO KEYS ON DATA FLOW *«*
                 ANAR20D3, PAGE
                 O7/20/87,  2liOC
                                                                                                          	KEY 3 (\DX OR DE>	
	DATA FLOW NATE	

AUDITED DATA


LAST UPDATED: O7-18-87
                                                  	DATA FLOW DESCRIPTION-
                                                  Data which hae completed the auditing process and  is  ready
                                                  for storage in the oversight data base.
      TOTAL ITEMS IN DATA FLOW:
                                   DATA FLOW TYPE: NORMAL

                                   CONTAINS
                                   \DATA STRUCTURES, ELEMENTS

                                     NOT DETERMINED

                                      1
                                                                                ALTERNATEN.
                                                                                DISCRIMINANT
TYPE
                                                                               TOTAL DATA FLOW SIZE:
        SIZE

        »***

           0*
MAXIMUM
ITERATION
                                                                                                                         0»
                                                                                                                             DECIMALS
                                                  -DATA FLOW OCCURRENCES INFORMATION—
	SOURCE	    DESTINATION     	KEY 1  (\DX OR DE)	

OS              O6              »** NO KEYS ON DATA FLOW ***

05              06.01           •*« NO KEYS ON DATA FLOW «*«

O5.04           O6              »*» NO KEYS ON DATA FLOW «•»

OS.04.O3        06              *»* NO KEYS ON DATA FLOW «**
                                                                        -KEY 2  (\DX OR DE)	
                                                                                                            -KEY 3  —
                                                                                               ==::==:== ss===s==
                                                                           -DATA FLOW DESCRIPTION-
DATA NOT REQUIRING AUDIT CORRECTIONS


LAST UPDATED: 07-1B-B7             DATA FLOW TYPE: NORMAL

»•* CONTINUED •*»
                                                  The portion of the validated data stream not requiring
                                                  changes.

-------
ProKit"ANALYST
10: BRSYSTEM     >IONi 6
                                    Annual/Biennial Rep™-* System

                                        DATA FLOW ATTR1    S
    	DATA FLOW NAME-
    CONTINUED »*»
DATA NOT REQUIRING AUDIT CORRECTIONS
                                   CONTAINS
                                   \DATA STRUCTURES, ELEMENTS
                                                                ALTERNATEX
                                                                DISCRIMINANT
      TOTAL ITEMS IN DATA FLOWi
	SOURCE	

OS.04.01
                                                                                 TYPE

                      NOT DETERMINED

                       1                                        TOTAL DATA FLOW SIZEi

	DATA FLOW OCCURRENCES INFORMATION	

 DESTINATION     	KEY 1 (XDX OR DE>	      	KEY 2 (\DX OR DE)	

 05.04.03        •** NO KEYS ON DATA FLOW ***
                                                                                                        ***«

                                                                                                           0*
                                                                                                  ANAR20D3,  PAGE
                                                                                                  O7/20/B7,   21:OO
        MAXIMUM
SIZE    ITERATION   DECIMALS
                                                                                                                        O*
                                                                                      	KEY 3 <\DX OR DE)	
	DATA FLOW

DATA NOT REQUIRING KEY-ENTRY CORRECTIONS
                                                           -DATA FLOW DESCRIPTION-
                                                  The portion of the unedited data stream not requiring
                                                  changes.
LAST UPDATED: 07-18-87
                                   DATA FLOW TYPE: NORMAL

                                   CONTAINS
                                   SDATA STRUCTURES, ELEMENTS
                                                                ALTERNATEX
                                                                DISCRIMINANT
      TOTAL ITEMS IN DATA FLOWi
	SOURCE	

O1.O4.O1
DESTINATION

O1.O4.03
                                                                                 TYPE    SIZE

                      NOT DETERMINED                                                     **»«

                       1                                     "  TOTAL DATA FLOW SIZE:       0*

                	DATA FLOW OCCURRENCES INFORMATION	

                 	KEY 1 (XDX OR DE)	      	KEY 2 (XDX OR DE)	

                 •»» NO KEYS ON DATA FLOW ***
        MAXIMUM
        ITERATION   DECIMALS
                                                                                                                        O*
    KEY Z (XDX OR DE)	
	DATA FLOW NAME	

DATA NOT REQUIRING VALIDATION CORRECTION
                                                           -DATA FLOW DESCRIPTION-
                                                  The portion of the edited data stream not requiring
                                                  corrections.
LAST UPDATED: O7-IB-B7

**» CONTINUED ***
                   DATA FLOW TYPE: NORMAL

-------
ProKit«ANAL*'
IDi  BRSYSTT
                 >IONi 6
                                     Annual /Biennial Rr

                                         DATA FLOW ATT.
                                                           System
                                 ANAR2OD3.  PAGE
                                 O7/20/B7,   211 (
	DATA FLOW NAME	
••• CONTINUED •••

DATA NOT REQUIR1NQ VALIDATION CORRECTION
                                   CONTAINS
                                   \DATA STRUCTURES, ELEMENTS
                                                                ALTERNATEX
                                                                DISCRIMINANT
      TOTAL ITEMS  IN DATA FLOW:
	SOURCE-—

O2.04.O1
                                                                                 TYPE

                      NOT DETERMINED

                       1                                        TOTAL DATA FLOW SIZE:

	DATA FLOW OCCURRENCES INFORMATION	

 DESTINATION     	KEY 1 (\DX OR DE)	      	KEY 2 (\DX OR DE)	

 O2.O4.03        »•• NO KEYS ON DATA FLOW •*•
                                MAXIMUM
                        SIZE    ITERATION   DECIMALS
                                                                                        ***«

                                                                                           0*
                                                                                                                        o»
                                                                                         	KEY 3  (\DX OR DE)	
	DATA FLOW NAME	

DATA REQUIRING. AUDIT CORRECTIONS



LAST UPDATED: O7-18-87
      TOTAL ITEMS IN DATA FLOW:
                                                  	DATA FLOW DESCRIPTION	
                                  The portion of the validated data stream which requires
                                  corrections.  These errors were detected by the audit
                                  process.
                    DATA FLOW TYPEI  NORMAL

                    CONTAINS
                    NDATA STRUCTURES, ELEMENTS

                      NOT DETERMINED

                       1
ALTERNATE\
DISCRIMINANT    TYPE
	SOURCE	

OS.04.O1
DESTINATION

05.04.02
                                                                TOTAL DATA FLOW SIZEI

                                        FLQW OCCURRENCES INFORMATION

                 	KEY 1 (NDX OR DE)	      	KEY 2 <\DX OR DE)	

                 *•• NO KEYS ON DATA FLOW *••
                                                                                                        SIZE
                                                                                                           0*
                                                                                                MAXIMUM
                                                                                                ITERATION
                                                                                                                        O»
                                                                                                                            DECIMALS
                         	KEY 3 (VOX OR DE)	
	DATA FLOW NAME	

DATA REQUIRING KEY-ENTRY CORRECTIONS
                                                 	DATA FLOW DESCRIPTION-
                                                  The protion ol the unedited data stream which requires
                                                  corrections.  These errors Here detected by comparison of
                                                  entered data with the collection forms.
LAST UPDATED: O7-18-87

**• CONTINUED **»
                   DATA FLOW TYPE: NORMAL

-------
ProKit^ANALV"                                      Annual/Biennial Rf  -* System                                ANAR2OD3. PAGE
IDs BRSYSTr     >SION: 6                                                                                          O7/2O/B7,  21:
                                                        DATA FLOW AT\     £6
	DATA FLOW NAME	
«•• CONTINUED •*•

DATA REQUIRING KEY-ENTRY CORRECTIONS

                                   CONTAINS                                     ALTERNATE\                      MAXIMUM
                                   \DATA STRUCTURES. ELEMENTS                   DISCRIMINANT    TYPE    SIZE    ITERATION   DECIMALS

                                     NOT DETERMINED                                                     ••«•

      TOTAL ITEMS IN DATA FLOWI       I                                        TOTAL DATA FLOW SIZE:       0«           0»

	DATA FLQW OCCURRENCES INFORMATION	

	SOURCE	    DESTINATION     	KEY 1  (\DX OR DE)	      	KEY 2  <\DX OR DE)	       	KEY 3  <\DX OR DE>	

01.04.O1        01.O4.02        **• NO KEYS ON DATA FLOW •*•
       	DATA FLOW NAME	          	DATA FLOW DESCRIPTION	
DATA REQUIRING VALIDATION CORRECTIONS             The portion of the edited data strean requiring
                                                  corrections.  These errors Mere detected by the validation
                                                  process.

LAST UPDATEDI 07-18-87             DATA FLQW TYPE: NORMAL

                                   CONTAINS                                     ALTERNATE\                      MAXIMUM
                                   \DATA STRUCTURES, ELEMENTS                   DISCRIMINANT    TYPE    SIZE    ITERATION   DECIMALS

                                     NOT DETERMINED                                                     *••*

      TOTAL ITEMS IN DATA FLOWi       1                                        TOTAL DATA FLOW SIZE:       0»           0»

	DATA FLOW OCCURRENCES INFORMATION	
	SOURCE	    DESTINATION     	KEY 1 <\DX OR DE)	      	KEY 2  (\DX OR DE)	       	KEY 3 <\DX OR DE)	

02.04.O1   .     02.O4.02        **• NO KEYS ON DATA FLOW •*»
	DATA FLOW NAME	          	Da™ pun, DESCRIPTION
EDITED DATA                                       Data which has passed or been corrected by the editing
                                                  process.

LAST UPDATED: O7-12-B7             DATA FLOW TYPE: NORMAL

»•• CONTINUED ***

-------
PrciKit-ANALYST
IDi BRSYBTEP   ISlONi 6
	DATA FLOW NAME-
••• CONTINUED *«•

EDITED DATA
      TOTAL ITEMS IN DATA FLOW:
	SOURCE	

01.04.03

Ol

01.04

Ol
DESTINATION

O2

O2

02

02.01
                                    Annual/Biennial Recoct System

                                        DATA FLOW ATTti    FES
                                                                                 ANAR2OD3. PASE
                                                                                 07/20/87,  21s'
                                   CONTAINS
                                   \DATA STRUCTURES, ELEMENTS

                                     \REPORT FORM PACKAGE
                                       EPA IDENTIFIER
                                      \FORM SUBPACKASE - ALL
                                       \FORM 1C - IDENT b CERT
                                       \FORM FS - FORM SELECTION
                                     C \FORM RS - REGULATORY STATUS 1
                                     C \FORM UD - WASTE DESCRIPTION 1
                                    C \FORM SUBPACKAGE - TSD 1
                                     C \FORM Ol - OFFSITE IDENT. 1
                                     C \FORM RO - REC. FROM OFFSITE 1
                                     C \FORM PS - PROCESS SUMMARY 3
                                    C \FORM SUBPACKASE - GENERATOR ]
                                       \FQRM PQ - PRIMARY GENERATION
                                     C \FORM MM - WASTE MINIMIZATION I
                                     C \FORM SO - SHIPPED OFFSITE 1
                                                                ALTERNATES
                                                                DISCRIMINANT
                                                                TYPE
                                             MAXIMUM
                                     SIZE    ITERATION   DECIMALS
                                                                                          12
                     15
                                               TOTAL DATA FLOW SIZE:

                —DATA FLOW OCCURRENCES INFORMATION	
                                       12
            12
	KEY 1 (\DX OR DE)	

••• NO KEYS ON DATA FLOW •••

••• NO KEYS ON DATA FLOW *«*

••• NO KEYS ON DATA FLOW •••

**• NO KEYS ON DATA FLOW •*•
	KEY 2 (\DX OR DE)	
-KEY 3 <\DX OR DE>-
	DATA FLOW NAME-

EXTERNAL IMPLEMENTOR DATA



LAST UPDATED: O7-18-87

••• CONTINUED •••
                                                         	DATA FLOW DESCRIPTION	
                                  Data at the implementor level Mhich is supplied by entities
                                  and/or processes outside the annual/biennial report
                                  collection process.
                   DATA FLOW TYPE: NORMAL

-------
ProKit«ANALv
IDt BRSYST'
                 alONt 6
                                    Annual/Biennial Rr   «• Systc

                                        DATA FLOW ATI     £3
                                                                                                  ANAR2OD3, PAGE
                                                                                                  O7/2O/B7,  211'
	DATA FLOW NAME	
••• CONTINUED **•

EXTERNAL IMPLEMENTOR DATA
                                   CONTAINS
                                   \DATA STRUCTURES, ELEMENTS
                                                                ALTERNATEX
                                                                DISCRIMINANT
      TOTAL ITEMS IN DATA FLOWi
	SOURCE	

EE 6

EE 6

EE 6
DESTINATION

O2

O2.O3.01

02.03
                                                                                 TYPE

                      NOT DETERMINED

                       1                                        TOTAL DATA FLOW SIZE:

                      	DATA FLOW OCCURRENCES INFORMATION	

                      -KEY 1 (XDX OR DE)	      	KEY 2 (XDX OR DE>	
                                                                                        SIZE

                                                                                        ***•

                                                                                           0*
        MAXIMUM
        ITERATION   DECIMALS
                                                                                       	KEY 3 (NDX OR DE)	
                 **• NO KEYS ON DATA FLOW •••

                 *•• NO KEYS ON DATA FLOW •••

                 *•• NO KEYS ON DATA FLOW «••
	>--DATA FLOW NAME	

EXTERNAL OVERSIGHT DATA
                                                          -DATA FLOW DESCRIPTION	
                                                  Data at the oversight level nhich is supplied by entities
                                                  and/or processes outside the Annual/Biennial Report
                                                  collection process.
LAST UPDATED! O7-18-87
                                   DATA FLOW TYPEi NORMAL

                                   CONTAINS
                                   \DATA STRUCTURES, ELEMENTS
                                                                ALTERNATEX
                                                                DISCRIMINANT
      TOTAL ITEMS IN DATA FLOWi
	SOURCE	

EE 7

EE 7

EE 7
                                                                                 TYPE

                      NOT DETERMINED

                       1                                        TOTAL DATA FLOW SIZEs

	Dftja FLOW OCCURRENCES INFORMATION	

 DESTINATION     	KEY 1 (XDX OR DE)	      	KEY 2 (XDX OR DE)	

 OS              »•• NO KEYS ON DATA FLOW *«*

 05.03           ••• NO KEYS ON DATA FLOW *••

 05.O3.01        ••* NO KEYS ON DATA FLOW *••
SIZE

»*»*

   0«
MAX IMUM
ITERATION
                                                                                                                        O*
                                                                                                            DECIMALS
                                                                                           —KEY 3 (\DX OR DE)	

-------
jKlt-ANALYST
  BRBYBTEfl »
  ON I 6
                  Annual/Biennial Report Syatea

                      DATA FLOW ATTRI
	DATA FLOW NAME	

>LENEMTOR DATA

IT UPDATEDl O7-18-B7
                                  	DATA FLOM DE8CRIPTION-

                                  loplemantor dooain annual/biennial report data.

                   DATA FLOW TYPEl NORMAL
                                 CONTAINS
                                 \DATA STRUCTURES,  ELEMENTS
                                                                ALTERNATES
                                                                DISCRIMINANT
    TOTAL ITEMS IN DATA FLOWl
                                                              TYPE

   NOT DETERMINED

     I                                        TOTAL DATA FLOW SlZEi

   	DATA FLOW OCCURRENCES INFORMATION	
•SOURCE	
 01
DESTINATION     	KEY 1 (\DX OR DE)	

Dl              ••• NO KEYS ON DATA FLOW •••

03.04           ••• NO KEYS ON DATA FLOW •••

O3.O3           ••• NO KEYS ON DATA FLOW ••«

03.O2           ••• NO KEYS ON DATA FLOW •••

01              ••• NO KEYS ON DATA FLOW ••*
                                                                   	KEY 2 <\DX OR DEI	
                                                                                                 ANAR20D3, PAGE   li
                                                                                                 O7/2O/B7.  21iOOr'
        MAXIMUM
SIZE    ITERATION   DECIMALS
                                                                                                      •*«•

                                                                                                         0*
                                                                                                        o*
                                                                                                       	KEY 3 <\DX OR DE)	
      	DATA FLOW NAHE-
 LEMENTOR DOMAIN RCRIB DATA

 T UPDATEDI  O7/1B/B7
    TOTAL ITEMS IN DATA FLOUl
 SOURCE	    DESTINATION

 04           EE 4

  CONTINUED •*•
                                                               	DATA FLO* DESCRIPTION	
                                  Data auppliad to the inplenentor donaIn of RCRIB

                   DATA FLOW TYPEl NORMAL
                                 CONTAINS
                                 \DATA STRUCTURES, ELEMENTS
                                                                ALTERNATES
                                                                DISCRIMINANT
                                                               TYPE

    NOT DETERMINED

     1                                         TOTAL DATA FLOW SIZEj

	DATA FLOW OCCURRENCES INFORMATION	

	KEY 1 (\DX OR DE>	      	KEY 2 <\DX OR DE)	
                ••• NO KEYS ON DATA FLOW *••
        MAXIMUM
SIZE    ITERATION   DECIMALS
                                                                                                      **••

                                                                                                         0*
                                                                                                        0*
                                                                                                         -KEY 3 (\DX OR DE)-

-------
-nKit'ANALYST
>t  WSYSTEM
  
-------
•Ml'ANALYST
 BRGYBTEH '
INl  6
	DATA FLOW NAME-
 CQNTINUEO •••

'-ENTRY CORRECTED DATA
Annual/Biennial Report System

    DATA FLOW ATTRI
    TOTAL  ITEMS  IN DATA FLOUi
                                CONTAINS
                                \DATA STRUCTURES, ELEMENTS

                                    \FORH  1C -  IDENT fc CERT
                                    \FQRH  FB -  FORM SELECTION
                                   C \FORM  RS -  REGULATORY STATUS  J
                                   C \FQRH  UD -  WASTE DESCRIPTION  1
                                  C SFORM SUBPACKABE - TSD ]
                                    \FORM  01 -  OFFBITE IDENT.  1
                                    \FORH  RO -  REC. FROM OFF6ITE  1
                                    \FQRH  PS -  PROCESS SUMMARY 1
                                   \FORH SUBPACKAGE - GENERATOR J
                                    \FORH  PG -  PRIMARY GENERATION
                                    \FORM  MM -  WASTE MINIMIZATION 3
                                    \FORH  SO -  SHIPPED OFFSITE 3
                   IS
                                                                                               ANAR20D3,  PAGE   13
                                                                                               07/20/87.   21lOOf
                                                              ALTERNATEX
                                                              DISCRIMINANT
                                            TYPE
        MAXIMUM
SIZE    ITERATION   DECIMALS
                                                                             TOTAL DATA FLOW SIZEl
                                                                                        12
                                                                   12
 SOURCE	    DESTINATION

 04.O2       O1.O4.O3
             	DATA FLOW OCCURRENCES INFORMATION	

              	KEY 1 <\DX OR DE)	      	KEY 2 (NDX OR DE)	

              *•• NO KEYS ON DATA FLOW «*•
                                                                                                       	KEY  3  (\DX OR  DE)	
          -DATA FLOW  NAHE-

 -ENTRY CORRECTIONS


!T UPDATEDi  07-12-B7
                                                                       —DATA FLOW DESCRIPTION-
    TOTAL ITEMS IN DATA FLOWi



 SOURCE	    DESTINATION

 03           01.04

  CONTINUED •••
                                Corrections which have been determined necessary to bring
                                data base contents into agreement with the report fora.

                 DATA FLOW TYPEi EXCEPTION

                 CONTAINS                                     ALTERNATEX
                 \DATA STRUCTURES, ELEMENTS                   DISCR

                   EPA IDENTIFIER  *
                   \CHAN8E DESCRIPTION
                     EPA IDENTIFIER
              	DATA FLOW OCCURRENCES INFORMATION	

              	KEY  1  (NDX OR DE)	      	KEY 2  (\DX OR DEJ

              ••* NO KEYS ON DATA FLOW ••*
E\
NANT TYPE
C
C
A FLOW SIZEl
MAXIMUM
SIZE ITERATION DECIMALS
12
12
24
1

24
                                                    	KEY 3  l\DX OR DE) —

-------
                                                       DM  FLOW ATTRlo  ES
                 FLOW NM1E-
• • CONTINUE*.

.Y-ENTRV CORRECTIONS
 -SOURCE	

 .03

 .O3.O2

 .03
DESTINATION

O1.O4.OI

O1.O4

O1.O4.02
                                                -DATA FLOW OCCURRENCES INFORMATION-
	KEY 1 <\DX OR DE)	

••• NO KEYS ON DATA FLOW ••*

**• NO KEYS ON DATA FLOW *••

•*• NO KEYS ON DATA FLOW •*•
                                                                  	KEY 2 <\DX OR DE)	
                                                                                                         —KEY 3 (\DX OR DE)-
        	DATA FLOW NAHE-
                                                           -DATA FLOW DESCRIPTION	
 V-ENTRY EXCEPTION REPORT


 5T UPDATEDi  O7-12-87
     TOTAL ITEMS IN DATA FLOUa
                                  This is a MOM of exceptions detected by comparison of data
                                  basa contents Nith the turnaround document.
                   DATA FLOM TYPEI EXCEPTION

                   CONTAINS
                   \DATA STRUCTURES, ELEMENTS

                     EPA IDENTIFIER
                     \ERROR DESCRIPTION
                       EPA IDENTIFIER
                                                                               ALTERNATES
                                                                               DISCRIMINANT    TYPE    SIZE

                                                                                                C        12

                                                                                                C        12

                                                                              TOTAL DATA FLQU SIZEl      24
                                                                                MAXIMUM
                                                                                ITERATION
                                                                                                       24
DECIMALS
 	DATA FLOW OCCURRENCES INFORMATION	

 --SOURCE	    DESTINATION     	KEY 1 (\DX OR DE)	      	KEY 2  (\DX OR DE)	       	KEY 3 (VOX OR DE)	

 .O3.O1         01.O3.02        **• NO KEYS ON DATA FLOW ••*
 	DATA FLOW NAME	

 -JtBIBHT DATA

 ,T UPDATED: 07-1B-B7

 »  CONTINUED •••
                                                                         —DATA FLOW DESCRIPTION	
                                  Oversight domain  annual/biennial report data.

                   DATA FLOW  TYPEl  NORMAL

-------
aKit•ANALYST
  BRSVBTEH V  »ION| 6
                                    Annual/Biannial Report Byttt

                                        DATA FLOW ATTRI
                                                                                  ANAR20D3, PAGE   16
                                                                                  07/20/87,  21,iOO
          -DATA FLOW NAHE-
                                                          -DATA FLOW DESCRIPTIOM-
ERBI8HT REPORTS


3T UPDATEDI 07-19-87
                                  Report* UMd at the oversight level.  Theae are both-
                                  standard and ad hoc report.
                   DATA FLOW TYPEi NORMAL

                   CONTAINS
                   \OATA STRUCTURES, ELEMENTS
                                                                              ALTERNATEV
                                                                              DISCRIMINANT
                                                                                 MAXIMUM
                                                                                 ITERATION   DECIMALS
    TOTAL ITEMS IN DATA FLOUl
-SOURCE	
 02
DESTINATION

EE 3

EE 3
                                                           TYPE    SIZE

NOT DETERMINED                                                     •*••

 1                                        TOTAL DATA FLOW SIZEi       O«           O»

	DATA FLOW OCCURRENCES INFORMATION	

     1  (\DX OR DE)	      	KEY 2 (\DX OR DE>	       	KEY 3 <\DX OR DE>
 ••• NO KEYS ON DATA FLOM •••

 ••• NO KEYS ON DATA FLOW •••
 	DATA FLOW NAME	
:EIVED DATA
IT UPDATED! O7-1B-B7
    TOTAL ITEMS IN DATA FLOUl
                  	          	DATA FLOW DESCRIPTION-

                                  Data received from variou* iaplcmentore.

                   DATA FLOW TYPEt NORMAL
                                 CONTAINS
                                 \DATA STRUCTURES, ELEMENTS
                                                                ALTERNATEX
                                                                DISCRIMINANT
 SOURCE	
DESTINATION

09

O3.01
                                                                 TYPE

      NOT DETERMINED

       1                                         TOTAL DATA FLOW BIZEi

	DATA FLOW OCCURRENCES INFORMATION	

 	KEY 1  (\DX OR DE)	      	KEY 2 (\DX OR DE)	

 ••* NO KEYS  ON DATA FLOW •••

 «•• NO KEYS  ON DATA FLOW •••
                                                                           MAXIMUM
                                                                   SIZE    ITERATION   DECIMALS
                                                                                        *•••

                                                                                           0*
                                                                                   o*
                                                                 	KEY 3 C\DX OR DE)-

-------
uM t» ANAL Via r
)| ORSVBTEr
tONl  6
Annual/Biennial Report Bystt

    DATA FLOW ATTF      S
                                                                                                ANAR2QD3, PA8E   17
                                                                                                O7/20/B7,  21lO'
 	DATA FLOM NAME—

 ANSniTTED OVERSIGHT DATA


 ST UPDATEDi 07-18-87
                                                                         -DATA FLOW DESCRIPTION-
     TOTAL  ITEMS  IN DATA FLOMl
                                 Data transmitted fro* the Implementor to the oversight
                                 domain.
                  DATA FLOW TYPEi NORMAL

                  CONTAINS
                  \DATA STRUCTURES, ELEMENTS

                    NOT DETERMINED

                     1
                                                                              ALTERNATES
                                                                              DISCRIMINANT    TYPE
                                                                             TOTAL DATA FLOW SIZEi
                                                    SIZE

                                                    *•••

                                                       O*
 -SOURCE	    DESTINATION     	KEY  1  I\DX OR  DE)	

              04              ••• NO KEYS  ON DATA  FLOW •••

 .02           04              ••• NO KEYS  ON DATA  FLOW *••
                                                -DATA FLOW OCCURRENCES  INFORMATIQN-
                                                  	KEY 2 (\DX OR DEI	
MAXIMUM
ITERATION
                                                                                                                      O*
                                                                        DECIMALS
                                                                                                          -KEY 3  <\DX OR DE)-
 	DATA FLOW NAME-

 RNAROUND DOCUMENT



 ST  UPDATEDi O7-12-B7
                                                                	DATA FLOW  DESCRIPTION-
     TOTAL ITEMS IN DATA FLQWi

   CONTINUED •••
                                 This is a computer produced report nhlch closely resembles
                                 the input form.  The primary purpose oi printing it is to
                                 compare to the original input form.
                  DATA FLOW TYPEi NORMAL

                  CONTAINS
                  \DATA STRUCTURES, ELEMENTS

                    \REPORT FORM PACKAGE
                      EPA IDENTIFIER
                     \FORM EUBPACKAGE - ALL
                      \FORM 1C - IDENT & CERT
                      \FORM FS - FORM SELECTION
                    C \FORM RS - REGULATORY STATUS 1
                    C \FORM WD - WASTE DESCRIPTION 3
                   C \FORM SUBPACKA6E - TSD 1
                    C \FORH 01 - OFFBITE IDENT. 1
                    C \FORM RO - REC. FROM QFFSITE 1
                    C \FORM PS - PROCESS SUMMARY 1
                   C \FORM SUBPACKAGE - GENERATOR 1
                      \FORM PG - PRIMARY GENERATION
                    C \FORM MM - WASTE MINIMIZATION 1
                    C \FORM SO - SHIPPED OFFSITE ]
                    15
                                                                              ALTERNATES
                                                                              DISCRIMINANT
                                            TYPE    SIZE
                                                                                                         12
MAXIMUM
ITERATION
                                                                        DECIMALS
                                                                              TOTAL DATA FLOW SIZE:
                                                                                                         12
                                                                                                                      12

-------
 OK it•ANALYST
111 BRSYBTF    ->SIONl 6
                    Annual/Biennial Report System

                        DATA FLOW ATT    TEB
                 ANAR20D3, PAGE   IB
                 07/2O/B7,  21 ir  ~4
         	DATA FLOW NAME-
>• CONTINUED **•

 RNAROUND DOCUMENT
 -SOURCE	    DESTINATION

 .02           O1.O3.01

 .02           O1.O3
                                                -•-DATA FLOW OCCURRENCES INFORriATION-
	KEY 1 (\DX OR DE)	

*•• NO KEYS ON DATA FLOW •••

•••NO KEYS ON DATA FLOW •*•
                                                                       -KEY 2  (\DX OR DE)-
                                                                      	KEY 3 
-------
ro*. it "ANALYST
Di BREYSTF   -RBIONi A
	DATA FLOW NAME-
•• CONTINUED •*•

^EDITED DATA
     TOTAL ITEMS IN DATA FLOW:
                  Annual/Biennial Report Bysti

                     DATA FLOW AT      TE8
                 ANAR20D3, PAGF   19
                 O7/2O/B7,  2'     4
                                  CONTAINS
                                  \DATA STRUCTURES, ELEMENTS

                                    \REPORT FORM PACKA6E   •
                                      EPA IDENTIFIER
                                     \FORM SUBPACKABE - ALL
                                      \FORM 1C - IDENT fc CERT
                                      \FORn FB - FORM SELECTION
                                    C \FORM R8 - REGULATORY STATUS 1
                                    C \FORM NO - WASTE DESCRIPTION 1
                                   C \FORM 6UBPACKAGE - TSD I
                                    C \FORH 01 - OFFBITE IDENT. 3
                                    C \FORH RO - REC. FROM OFFSITE 1
                                    C \FORH PS - PROCESS SUMMARY 3
                                   C \FORM SUBPACKABE - GENERATOR 3
                                      \FORM PQ - PRIMARY GENERATION
                                    C \FORM MM - WASTE MINIMIZATION 3
                                    C \FQRM BO - SHIPPED OFFSITE 3
                                             ALTERNATEV
                                             DISCRIMINANT
TYPE


 C
                                                                     SIZE


                                                                        12
MAXIMUM
ITERATION
DECIMALS
  IS
-SOURCE 	
.01
•1/1
>1/1
•1/1
SB v aa, s • sVavfli •§ s
— 	 ____ 	 UHIH ri_uw i
DESTINATION 	 KEY 1 (\DX OR DE) 	
DO1/1 *•* NO KEYS ON DATA FLOW ••*
O1.O4.O1 ••• NO KEYS ON DATA FLOW •••
O1.O2 *•• NO KEYS ON DATA FLOW •••
O1.O4 *•• NO KEYS ON DATA FLOW ••»
                                                                              TOTAL DATA FLOM SIZEI

                                                 DATA FLOW OCCURRENCES INFORMATION	

                                                                  	KEY 2 (\DX OR DE)	
                                                                        12
                       12
                                                                                                     	KEY 3 (\DX OR DE)-
 	DATA FLOW NAME-

 VALIDATED DATA


 ST UPDATEDi O7-18-B7
                                       -DATA FLOW DESCRIPTION-
               Data which has passed the key-entry editing process but
               Nhich has not yet been subjected to validation.
DATA FLOW TYPEi NORMAL

CONTAINS
\DATA STRUCTURES, ELEMENTS
                                                                               ALTERNATES.
                                                                               DISCRIMINANT    TYPE
        SIZE
MAXIMUM
ITERATION
DECIMALS
 • CONTINUED *••

-------
c.k it'ANALYST
>l BRSYBTEM '
-lOHt 6
               Annual/Biennial Report SystM

                   DATA FLOW ATTRJ    [6
         ANAR20D3, PAGE
         O7/2O/Q7.
                                                                                                                  2O
	DATA FLOW NAME-
• CONTINUED •••

VALIDATED DATA
                                 CONTAINS
                                 \DATA STRUCTURES, ELEMENTS
                                                                ALTERNATEX
                                                                OIBCRIHINANT
    TOTAL  ITEMS  IN DATA FLOUt
-SOURCE 	 DESTINATION 	 1
i
/I
2/1
2/1

01
O2.
02.
O2.
O2
04.01
O4
D02/1
• •• NO
••• NO
• •» NO
• •• NO
CEV 1
KEYS
KEYS
KEYS
KEYS
.___ — -ut
IXDX OR
ON
ON
ON
ON
DATA
DATA
DATA
DATA
ill* n
DE) —
FLOW
FLOW
FLOW
FLOW
.UN 1
B^«WI
• *•
• ••
• ••
«•»
s«sm
                                                           TYPE

NOT DETERMINED

 1                                        TOTAL DATA FLOW SIZE*

             DATA FLOW OCCURRENCES INFORMATION	

                                       2 (\DX OR DE>	
        MAXIMUM
SIZE    ITERATION   DECIMALS
                                                                                                                      o*
                                                                                                       	KEY  Z -
 	DATA FLOW NAME—

 .1DATED DATA



 3T UPDATED: O7-18-B7
     TOTAL  ITEMS IN DATA FLOMi
                                                         —DATA FLOW DESCR1PT1ON-
                                  Data which has passed both the key-entry edition and
                                  validation processes.  All Input data eventually beconas
                                  part of this stream.
                   DATA FLOW TYPEI NORMAL

                   CONTAINS
                   XDATA STRUCTURES, ELEMENTS

                     NOT DETERMINED

                      1
                                                                               ALTERNATEX
                                                                               DISCRIMINANT
                                                           TYPE
                                                                              TOTAL DATA FLOW SIZEi
SIZE

*•••

   O«
                                                                           MAXIMUM
                                                                           ITERATION
                                                                                                                       O*
                    DECIMALS
                                                -DATA FLOW OCCURRENCES INFORMATIQN-
 -SOURCE	

 O4

 .04.03
DESTINATION     	KEY 1 C\DX OR DE>	

O3              ••• NO KEYS ON DATA FLOW •*•

03              ••* NO KEYS ON DATA FLOW •«•
                                                                    	KEY 2 4\DX OR DE)	
                                                                                          	KEY 3 
-------
 ro» . ..•ANALY'Jl
(Dl  DHSY6TEM VERSION! 6
	DATA FLOW NAME-
••• CONTINUED •••

ALIDATED DATA
 —SOURCE	    DESTINATION

 2               OS

 2               03.Ol
                     Annual/Biennial Report System

                         DATA FLOW ATT     TE8
                 ANAR20D3, PA6E   21
                 07/20/87,  211'-  "4
	DATA FLOW OCCURRENCES INFORMATION	

 	KEY 1 (\DX OR DE)	      	KEY 2 <\DX OR DE)-

 ••• NO KEYS ON DATA FLOW •••

 *•• NO KEYS ON DATA FLOW ••*
         	KEY 3 (\DX OR DE) —
 	DATA FLOW NAME-

 4LIDATION CORRECTED DATA


 AST UPDATED:  O7-18-B7
     TOTAL  ITEMS IN DATA FLOMl
                                          —DATA FLOW DESCRIPTION-
                   The stream of  data to Mhtch validation corrections have
                   been applied.
    DATA FLOW TYPEI  NORMAL

    CONTAINS
    \DATA STRUCTURES.  ELEMENTS
                                                                                ALTERNATEX
                                                                                DISCRIMINANT    TYPE
 -SOURCE	     DESTINATION

 7.04.02         O2.O4.03
      NOT DETERMINED

       1                                         TOTAL DATA FLOW SIZEi

 	DATA FLOW OCCURRENCES INFORMATION

 	KEY 1  (\DX OR DE)	      	KEY 2 (\DX OR DE)	

     NO KEYS  ON DATA FLOW •*•
                MAXIMUM
        SIZE    ITERATION   DECIMALS
                                                                                                           O*           0*
         	KEY 3 (\DX OR DE)-
 	DATA FLOW NAHE-

 *.IDATION CORRECTIONS



 ,ST UPDATED:  07-12-87
                                  	DATA FLOW DESCRIPTION-
                   Correctiana that  have determined to be necessary by the
                   examination process.'  These corrections Mill  be applied to
                   the data  stream.
    DATA FLOW TYPE:  NORMAL

    CONTAINS
    \DATA STRUCTURES,  ELEMENTS

      EPA IDENTIFIER
                                                                                ALTERNATEX
                                                                                DISCRIMINANT
TYPE

 C
SIZE

  12
MAXIMUM
ITERATION
DECIMALS
 ••  CONTINUED •••

-------
I'roKlt "ANALYST
11)1 BRBV6TEM "ERSIONl 6
                                    Annual/Biennial Report System

                                        DATA FLOW ATT    TEB
                                                                                 ANAR2OD3, PAoE   22
                                                                                 O7/20/B7,   21lOOi34
••• CONTINUED •••

'ALIDATION CORRECTIONS
                                   CONTAINS
                                   \DATA BTRUCTUREB, ELEMENTS

                                     \CHANGE DESCRIPTION
                                                                ALTERNATES
                                                                OISCRiniNANT
                                                                TYPE
        MAXIMUM
SIZE    ITERATION   DECIMALS

TOTAL
—SOURCE 	
'2.03
•2.03.O4
2.03
2.03

ITEMS IN DATA FLOW:
DESTINATION
O2. 04
02.04
02.O4.O1
02.O4.O2
EPA IDENTIFIER C 12
3 TOTAL DATA FLOW SIZE: 24 24
	 KEY 1 CXDX OR DE) 	 	 KEY 2 (\DX OR DE) 	 	 KEY 3 <\DX OR DEI 	
»•• NO KEYS ON DATA FLOW •••
•*• NO KEYS ON DATA FLOW •••
*•• NO KEYS ON DATA FLOW •••
••• NO KEYS ON DATA FLOW *•»
 	DATA FLOW NAME	

 ALIDATION ERRORS FROM EXTERNAL CHECKS
                                                                 	DATA FLOW DESCRIPTION	
                                  These are errors detected by validation comparisons between
                                  the data base contents "and external implementor data.
 AST UPDATEDi 07-12-B7
                   DATA FLOW TYPEl EXCEPTION

                   CONTAINS
                   \DATA STRUCTURES, ELEMENTS
                                                                                ALTERNATES
                                                                                DISCRIMINANT
                                     EPA IDENTIFIER
                                     \ERROR DESCRIPTION
                                       EPA IDENTIFIER
      TOTAL ITEMS IN DATA FLOW:
  -SOURCE	

  .03.01
DESTINATION

O2.03.04
                                                                 TYPE

                                                                  C

                                                                  C

       3                                        TOTAL DATA FLOW SIZE:

	DATA FLOW OCCURRENCES INFORMATION	

 	KEY 1  <\DX OR DE)	      	KEY 2 (\DX OR DE)	

 •••NO KEYS  ON DATA FLOW •••
SIZE

  12

  12

  24
                                                                                MAXIMUM
                                                                                ITERATION
                                                                                                                       24
DECIMALS
                                                                                                      	KEY 3  (\DX OR DE) —

-------
ToK it "ANALYST                                      Annual /Biennial  R»~>rt Systea                               ANAR2OD3.  PAGE   *>3
-Di BRSYSTF      SI ON,  a                                                     X                                   O7/2O/B7.   21      *
                                                        DATA FLOW AT      EB
         	DATA FLOW NAME	          	DATA FLOW DESCRIPTION-
ALIDATION ERRORS FROM INTERNAL CHECKS            Validation errors detected by internal consistency check
                                                  activities.

AST UPDATED! O7-12-67             DATA FLOW TVPEi  EXCEPTION

                                   CONTAINS                                    ALTERNATEX                      MAXIMUM
                                   \DATA STRUCTURES.  ELEMENTS                  DISCRIMINANT    TYPE    SIZE    ITERATION   DECIMALS

                                     EPA IDENTIFIER                                             C        12
                                     NERROR DESCRIPTION
                                       EPA IDENTIFIER                                           C        12

     TOTAL  ITEMS IN DATA FLOMt        3                                       TOTAL DATA FLOW SIZEi      24           24

 	DATA FLOW OCCURRENCES  INFORMATION	
 -SOURCE	    DESTINATION  '    	KEY 1  (\DX OR DE>	      	KEY 2  (\DX OR DE)	       	KEY 3  <\DX OR DEI-

 .03.02        02.O3.O4         ••• NO KEYS  ON  DATA FLOW  •*•
 	DATA FLOW NAME	          	DATA FLOW DESCRIPTION	

 i-IDATION ERRORS FROM INTRABTATE CHECKS          Validation errors detected by comparisons of facilities'
                                                 reports Mithin one state.

 3T UPDATEDl O7-12-B7             DATA FLOW TYPEs EXCEPTION

                                  CONTAINS                                     ALTERNATEN                      MAXIMUM
                                  \DATA STRUCTURES, ELEMENTS                   DISCRIMINANT    TYPE    SIZE    ITERATION   DECIMALS

                                    EPA IDENTIFIER                                              C        12
                                    \ERROR DESCRIPTION
                                      EPA IDENTIFIER                                            C        12

     TOTAL ITEMS IN DATA FLOWt       3                                        TOTAL DATA FLOW SIZE*      24           24

 	DATA FLOW OCCURRENCES INFORMATION	

 -SOURCE	    DESTINATION     	KEY 1 <\DX OR DE)	      	KEY 2 (\DX OR DE)	       	KEY 3 (\DX OR DE)	

  03.OS        O2.O3.04        •*• NO KEYS ON DATA FLOW •••

-------
•roK-,l.ANALYST
ID,  ORBVBTr    SSION,  6
                                                    Annual /Biennial  R.port Sy.te.
 	DATA FLOW NAME-

 AL1DATION REPORT



 AST UPDATEDi O7-18-B7
                                             FLOW DESCRIPTION	

               A formatted report performing some validation activities
               automatically and allotting others to be done manually (for
               example reasonableness checks).
DATA FLOW TYPEl NORMAL


XOAT^BTRUCTURES, ELEMENTS
ALTERNATEN
DISCRIMINANT
      TOTAL ITEMS IN DATA FLOW!
                	                                   TYPE

NOT DETERMINED

 I                                        TOTAL DATA FLOW BIZEl
SIZE

*••*

   0«
                                                                           MAXIMUM
                                                                           ITERATION
                                                                                                                        O.
                                                                                                                            DECIMALS

—SOURCE 	
2.02
2. 02
2.02
2.02

OTAL NUMBER
OTAL NUMBER

DESTINATION
02.03
O2.O3.O3
O2.O3.O1
02.03.02

OF DATA FLOWS ON
OF DATA FLOWS ON
•SEA* • i%nv oo net _ - 	 - 	 KFV 1 1\DX OR DE> 	 	 KEY 3 <\DX OR DE)--- ~ —

••• NO KEYS ON DATA FLOW •••
••• NO KEYS ON DATA FLOW •••
••• NO KEYS ON DATA FLOW *»•
*•• NO KEYS ON DATA FLOW ••*

PROJECT DICTIONARY VERSION 6 : 39
REPORT t 39

-------
PROCESS  DESCRIPTIONS

-------
                                                     Annual/'     ial Report System
                       6
                                                          PRU  ..a ATTRIBUTES
 ™"~™~™^to~~™'»~""-S —— SBSECSS3CS S S SS~ SS2S£SS±SSCl5 = CZSf3SC™~~l~ —-"~ — — —— — — — — ___« __ _ ___ _ _ _ __     ______
                                           — ~~~~~ —— — "" — — — — —— — — — -- ——  — — — — — —— — S_SBS:2_E	— — — — = = = = = = = = = = = = =3== = _=_=_S = = SS_=^ = = = _SS_S_== = iS:_s_s_

 PROCESS ID      	NAME	     --IMPL-BY--      LAST UPDATED
 01               ENTER «• «'T DATA                                                           Diagram „         07/I3/B7

                 	'•	PROCESS NARRATIVE	

                 In this process, data from the report form is entered into the system.
                 Editing is performed to assure that the contents of the data base matches
                 the values on the reporting form.



 PROCESS ID      	NAME	     __IMPL-BY—      LAST UPDATED
 01.01            ACCEPT I ENTER DATA                                                                            O6/26/B7

                 	PROCESS NARRATIVE	

                 This is the data entry (input)  process.   Data is entered via a terminal and
                 stored in an intermediary data store for editing.

                                             =====—==========S= ===!SS:B = :S=SSS======S====S=SS:—==:




                 	PROCESS NARRATIVE	

                 This process take the contents  of  the unedited data store and produces a
                 listing in a format similar to  the report  form.

 ======================================================================-_--=____=_==____=__.

 PROCESS  ID       	NAME	
 O1.03            EXAMINE DATA FOR KEY-ENTRY  ERRORS

                 	PROCESS NARRATIVE	

                 The  turnaround  document  is  compared to the input  form.   Any  exceptions are
                 noted and  changes required  are  determined.

 ======a=======================M=============M=================«

PROCESS  ID       	NAME	     __1MPL_BY—      LAST UPDATED
01.03.01         COMPARE T.A.D WITH REPORT FORM                                                                  oI/26/B7

                 	PROCESS NARRATIVE	

                 The  turnaround  document Mill  be compared with  the original input  form
                 submitted.   Any exceptions  (discrepancies)  Mill be  noted and  forwarded to
                 the  next process which is where required corrections Mill  be  determined.

-------
                                                                                                                  07/1L       16:04:51
                                                         PROucSS ATTRIBUTES
 ™™~*™"™aC™SS™"*'" = = ~™™"™~o~™"—= = SSSS5SSBSSE5SSSSS S wSSSSSSSSSSSS = SSS = 2SSSSSf*~~~™ —~" — — — — — .. ____ _. — — •._  _    __

 PROCESS  ID         —
 01.03.02       DETE^'R^RE^C^S""*                                       -mPL-BV-      ^WW*

                	PROCESS NARRATIVE	

                Discrepancies detected  in the previous process Mill be received by  this
                process.  In this process, the changes required  to correct the problem Mill
                be determined and forwarded to the editing process.

 ""  ———  —— — ————  ______SB____—=========== = =======E=========B==== = = B==== = = = ss====a=B ==== ====: = = ==— = = = = = s= = = = = = === = = = = = = = = a== = = t= = = = =.. -

 PROCESS  ID      	NAME	     — IHPL-BY--      LAST UPDATED
 01.04           HAKE KEY-ENTRY CORRECTIONS                                                  D.iji. M         O7/13?£

                	PROCESS NARRATIVE	

                The editing changes required are applied to the  data.  All data from the
                data stare passes through this process.  Changes are made to those  items
                determined to be in error.
                                             •


 PROCESS  ID      	NAME	     --IMPL-BY—      LAST UPDATED
 01.04.01        DETERMINE IF KEY-ENTRY CORRECTIONS ARE REQUIRED                                                O7/02/87

                	PROCESS NARRATIVE	

                The stream of input data is examined and divided  logically into two flows:
                those records requiring key entry corrections and those not.

   ""    "" ~""==~==""~~~=~====s===a=====0=ss=============================B=======================================================—=====-

PROCESS  ID      	NAME	     __IMPL_BY__      LAST UPDATED
01.04.02        HAKE KEY-ENTRY CORRECTIONS                                                                     07/02/87

                	PROCESS NARRATIVE	

                Corrections determined to be necessary to bring the data into conformance
                with the report forms are made to the data base.



PROCESS  ID      	NAME	     __IMF.L_BY__      LAST UPDATED
01.04.03        COMBINE KEY-ENTRY EDITED STREAMS                                                               O7/O2/B7

                	PROCESS NARRATIVE	

                The two data streams are combined.

-------
    it*ANALYSf                                      Annual    inial Report System                                AN»-     , F nf>l
    BRSYSTEM VERSION: 6                                                                                          »"•    .  lb:
                                                         FRDCESS ATTRIBUTES
= — = === = = = = = = = = = = = = = = = = = = = = = =3 = = =: = = = = = = =.= = = = = = = = = .2 = = = = = = = == = = = = = = = = = = === = === = = = = = = = = = = = = = = = = —= = = = = = = = = = —= = = = = = = = = = —= = = = = !- — — = = ==-.;

PROCESS ID      	NAME	     --1MPL-BY—      LAST UFDA1LD
02              VALIDATE DATA                                                               Diagram 115         07/13/B7

                	PROCESS NARRATIVE	

                Data from the entry and editing process is accepted and subjected to
                validation procedures.  Validation involves checks for responsibility
                internal consistency and consistency MIth other data in the implementor
                domain.  Validated data is stored in the implementar data base by a storage
                procedure.

===============================================================================================================================

PROCESS ID      	NAME	     —IMPL-BY—      LAST UPDATED
02.01           ACCEPT DATA FOR VALIDATION                                                                     06/26/87

                	PROCESS NARRATIVE	

                Data is accepted from the edit and entry process.



PROCESS ID      	NAME	     --IMPL-BV--      LAST UPDATED
O2.02           PRODUCE VALIDATION REPORT                                                                      06/26/B7

                	PROCESS NARRATIVE	

                Summary and detailed tables are produced.  These tables Mill provide
                information Mhich must be verified manually  (through telephone calls,
                comparison with other data sources, etc.).

B —s = a = SBSSS=sssS = = BSSSSS = SSS = = BSS&BSSSSSBSSS = = = = = a = ===aSSSSS = = = = = SSSSSSSl = = = BS=SSSSSS = = B= = SSSS9 = = SSSS = B9 = = = S SB = S=: = = = = = = = = = = = = = = = = = ==S==

PROCESS ID      	NAME	     —IMPL-BY—      LAST UPDATED
02.03           EXAMINE DATA FOR REPORTING ERRORS                                           Diagram H6         07/1^/87

                	PROCESS NARRATIVE	

                The  information provided by validation report generation  is analyzed.
                Exceptions are noted and any changes required are  formulated.



PROCESS ID      	NAME	     —IMPL-BY—      LAST UPDATED
02.03.01        COMPARE REPORT WITH EXTERNAL DATA                                                              07/02/87

                	PROCESS NARRATIVE	

                The  contents of the validation reports are compared Mith  external data
                sources.  Discrepancies are researched and either  explained or rectified.

-------
F-    %«ANAL VST
I     SVblF.M VFR510N: 6
                                    Annual/'

                                         F'FiL
lal  Report  System
                                                                                                                 07/1L
              I ftl iC    1
               m:i>4:M
                                                                . AlTRIBUTES
FROCESS ID
02.03.O2
	NAME	
EXAMINE REPORT FOR INTERNAL CONSISTENCY
                            --1MPL-DV—
LAST UPDATED
  07/12/S"7
                                            -PROCESS NARRATWE-
                The validation report is examined to insure that data base contents are
                internally consistent.  This involves two levels of checks:
                     - consistency MI thin a given facility (totals and details are
                       consistent)
                     - consistency between handlers (totals shipped to and received by a
                       given handler are consistent).
                This process implements the former check to insure that data reported by a
                single facility is consistent within itself.
PROCESS ID
02.O3.O3
	NAME	
EXAMINE REPORT FOR INTRASTATE CONSISTENCY
                            —1MPL-BY--
LAST UPDATED
  O7/12/87
                                            -PROCESS NARRATIVE-
                The validation report is examined to insure tat data base contents are
                internally consisten.  This involves two levels of checks:
                     - consistency within a given facility (totals and details are
                       consistent.
                     - consistency between handlers (totals shipped to and received by a
                       handler are consistent)
                This process implements the second of these checks to insure that the
                totals and detail between all state reports are consistent.
PROCESS ID
O2.O3.O4
                                -NAME-
                                                                            —IMPL-BY--
DETERMINE VALIDATION CORRECTIONS
                                             LAST UPDATED
                                               O7/17/87
                                            -PROCESS NARRATIVE-
                Based on results of the internal and external consistency checks,
                corrections needing to be made to the data are determined.  These
                corrections are passed to another process in which they are applied to the
                data stream.

02.04

CORRECT REPORTING ERRORS



Diagram M7
1 ACT IIPRATPn
O7/ 13/87
                                            -PROCESS NARRATIVE-
                Any changes determined to be necessary by the validation process are made
                to the data.  All unvalidated data passes through this process.  Changes
*•* CONTINUED *•*

-------
P    "-ANALYST                                       Annual/'     lal  Report
1     SYSTEM VEKS10N: 6                                                                                           07/It
                                                          hRL    , ATTRIBUTES
= = = = = = = = = ==E = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = J = = = = = = = = = = = = = = = = = = = = = = = S. = ii= = = = I.i.J = = = = = = = = =

PROCESS ID      	NAME	     —1MPL-BY--      LAST UPDATED
O2.O4           CORRECT REPORTING ERRORS                                                     Diagram «7         07/13/87
*•• CONTINUED ••»

                	PROCESS NARRATIVE	

                are made to those items determined to be  in error.



PROCESS ID      	NAME	     --IMPL-BY—      LAST UPDATED
02.04.01        DETERMINE IF REPORTING CHANGES ARE REQUIRED                                                     07/02/87

                	PROCESS NARRATIVE	

                The stream of edited data is examined and separated  (logically) into  two
                flows: those records requiring repair and those not.



PROCESS ID      	NAME	     —IMPL-BY—      LAST UPDATED
02.O4.02        MAKE REPORTING ERROR CORRECTIONS                                                                O7/02/87

                	PROCESS NARRATIVE	

                Reporting errors are repaired through changes to erroneous  data.

SSSSSSSSSSESSSSSSSSESSaBS^SSSSSSSSSSDCSSSSSSSSSSS^SSSSSSSSSSSSSISSSSSSSSSSSSSSSSaSSSSSSSSSSS'CSSSSSSSSSSSSCSSSCSSSSSSSSSiSSSSSBSESSSSKCS

PROCESS ID      	NAME	     —IMPL-BY—      LAST UPDATED
O2.04.O3        COMBINE VALIDATED DATA STREAMS                                                                  07/02/87

                	PROCESS NARRATIVE	

                The two data streams are combined.

S!K BS33SSSS8S«33SSSSSES3SEEB3S = SSSSSSSSSSSS25SSSSSSS = SSSSS = SSSSS = = SSESS5SasS:S = 3S3SlSSSSSSCS5S3:s:S = ESSBSSSS = SSBS;E«SS3SESS — T?^S~"STr~r

PROCESS ID      	NAME	     —IMPL-BY—      LAST UPDATED
02.09           COMPARE REPORT WITH EXTERNAL DATA                                                               O7/02/B7

                	PROCESS NARRATIVE	

                The contents of the validation reports are compared  with external data
                sources.  Discrepancies are researched and wither explained or rectified.

-------
                     : 6
                                                                                                                 "7/1     ,   LH:ij4:51
                                                         F    jS ATTRIBUTES
         ====================================== =========== ---------------------------------
                                                         ------------------- — ----------- — — = = = = as = = = = = = ~=s = .== = =^^a. = s==.sssf 2=. = :. = = = = =.=

         ,0      --^-_..._r---_.__


                ----------------------------- PROCESS NARRATIVE ------------------------------

                This process performs three major functions.  It created land maintains)
                the  implement tor domain data base, perform retrievals and report generation
                and  transmits the implement or data to the oversight domain.   In addition,
                this process provides any required reporting data to the imp lament or domain
                of RCRIS.

===============================°===============«^

PROCESS  ID      -------------------------- • ------- NAME ----------------------------------     — IMPL-BY __      LOST
03.01           STORE IMPLEMENTOR DATA                                                        IMPL BY

                ----------------------------- PROCESS NARRATIVE

                This process Hntes the validated data to the implement or data base.

=============================== _ =.========s==— — ===__— ===___                              ___ _ ___ _  _


                TRANSmT"ovER^6HT"oATA          """ ----------------------------------     -inPL-BV-

                ----------------------------- PROCESS NARRATIVE ------------------------------

                This process transmits data to the oversight domain of  the reporting
                system.

— = = = = 3— SSS5SS = SS = = = S= == = f= — — e — — — — — — — — —-,___ — __________
                             ~""""~~~"                 =~~ = = = = = = ===== = = = == = :=== == = = = === = = ==== = = = === = ==== = = = === = = ss = = = = = = = = = = ^ =

PROCESS ID      ~"~~~— —————————————————— ———— ———NAMP-— ————— — —«———-.«                       i k*m nu
03.03           PRODUCE  WASTE GEN.  «, H«NA6E«ENT REPORTS                                     "IMPL-BV

                ----------------------------- PROCESS NARRATIVE --------------------- ' ---------

                This process fulfills all  standard and ad hoc reporting requirements.   This
                process  Mill allow interactive query as MB! 1  as  batch production of
                reports.

=================M==™==================================™

PROCESS ID                                       NAME ----------------------------------     — IMPL-BV—      LAST UPDATED
03.04           TRANSMIT DATA TO RCRIS                                                                        O6/26/B7

                ----------------------------- PROCESS NARRATIVE ------------------------------
                This process Mill  perform any reformatting,  translation or summarization
                required and transmit implement or  data to the RCRIS  implementor domain.

-------
f     '-.•ANALYST                                       Annual/      lal  heoort Svstem                                ANtiK?
1     iSYSTEM VERSION: 6                                                                                          O7/1L       UJ:«.4:£|
                                                          H'Ri.   „:> ATTRIBUTES
                                                                                                  ==
PROCESS  ID      -------------------------------- TNAME ----------------------------------     — |nPL-BY--      LAST UPDATED
03.05           TRANSMIT DATA  TO RCRIS                                                                         O7/IXVB7
                                              PROCESS  NARRATIVE
                 Implementor-Domain data which has passed the validation process is
                 transformed  as  necessary  and transferred to RCRIS.
PROCESS  ID      --------------------------------- NAME ----------------------------------     — JMPL_BY__      LAST UPDATED
04              RECEIVE OVERSIGHT DATA                                                                         O6/26/B7
                                             PROCESS NARRATIVE
                This process will accept data  from  the  implement or domain and provide it to
                the auditing procedure  in  the  oversight domain.
PROCESS ID      --------------------------------- NAME ----------------------------------     __IMPL_BY—      LAST UPDATED
OS              AUDIT OVERSIGHT DATA                                                        Diagram «9         O7M3/B7
                                             PROCESS NARRATIVE
                Data received from the implementor domain  is subjected to auditing
                procedures.  Auditing involves checks for  resonabtlity and consistency with
                other data in the data store.  Data that passed the auditing process is
                stared in the national data base by a following storage procedure.
PROCESS ID      --------------------------------- NAME ----------------------------------     __IHPL_BY__      LAST UPDATED
09.01           ACCEPT DATA FOR AUDITING                                                                       O6/26/B7
                ----------------------------- PROCESS NARRATIVE

                Data is accepted from the data transmission/receipt process.
PROCESS ID      --------------------------------- NAME ----------------------------------     — IMPL-BY —      LAST UPDATED
OS. O2           PRODUCE AUDIT EXCEPTION REPORT                                                                 O6/ 26/87
                                             PROCESS NARRATIVE
                Summary, detail and comparison reports are produced.  These listing Mill
                provide information on exceptions which may be detected by machine and
                information which must be verified manually.  These checks go beyond checks
                performed in the validation process as interstate comparisons may be
                performed and evaluated.
                                                                                                      ======.==&

-------
FT-    "ANALYST                                      Annual/B      =>1 Report  System
"      YSTE" VERSION:  6
                                                          PROL     ATTRIBUTES
•5S_±CS_5_5_S_5S__;:_>_53_5SS_;_5_3_S_5S_5_5_5_5_5_5_S_3_5_5S_S3SS_=S_;_S_S — ~~ — — — — — — — -»______.___ ______ ___._,._,__.____„„,_____ ___________

PROCESS ID       	NAME	      _.IripL_BY—      LAST UPDATED
03-03            PERFORM CONSISTENCY CHECK & AUDITS                                           Diagram ttlO        O7/J3/B7

                 	PROCESS NARRATIVE	

                 The reports are examined.  Any exceptions Mill be identified and
                 corrections to problems Mill be defined.

===BBEBSS8s=(ssssE=s_'sa&ac5Bssssss=OE===s===E:e=ssss==Esss==ss=sssa======sssssaa=se±=====s=

PROCESS ID       	NAME	      —IMPL-BV—      LAST UPDATED
03.03.01         COMPARE AUDIT WITH EXTERNAL DATA                                                                O7/O2/B7

                 	PROCESS NARRATIVE	

                 The contents of the audit reports are compared Nith external data sources.
                 One class of exception is generated by this check.

= = = ===a = B=== = ==BBS ===B ==== = ==0==B = = = Ba0:S = = = = = = = = = === = EB === = = S: = = = = = = a ===S==B=E = E= = aS!=: = SSBEE=EE = E = = S=E = = = = == = = = = EB = = = = = = «l = = = = =

PROCESS ID       	NAME	      __lMPL_By__      LAST UPDATED
09.03.02         EXAMINE REPORT FOR INTERNAL AUDIT CONSISTENCY                                                   O7/12/B7

                 	PROCESS NARRATIVE	

                 The audit report is examined to insure that data base contents are
                 internally consistent.  This involves two levels of checks:
                     -  consistency MI thin a given facility (totals and details are
                       consistent)
                     -  consistency between states (totals shipped to and received  by a
                       state)
                 This process implements the first of these two checks.  This is similar  to
                 the process performed at the implementor level.
PROCESS  ID
09.03.03
	NAME	
EXAMINE REPORT FOR  INTERSTATE CONSISTENCY
—iriPL-BY—
                 LAST UPDATED
                   O7/12/87
                                             -PROCESS NARRATIVE-
                The  audit  report  is examined to insure that data base contents are
                internally consistent.   This involves two levels of checks:
                     -  consistency MI thin a given handler report (totals and details  are
                        consistent with each other).
                     -  consistency within and between states (totals shipped to or
                        generated  by a handler agrees with the amounts reported handled.
                This process implements the second of these two activities.

-------
     A=.STEM VERSION:
                                    Annual,     lal Report System

                                         PR.   .a ATTRIBUTES
    AWAR
    07/1
PROCESS ID
OS.03.04
                                -NAME-
DETERMINE AUDITING CORRECTIONS
                                            -PROCESS NARRATIVE-
                Based on results of the internal and external consistency checks,
                corrections needing to be made to the data are determined.  They are then
                passed to another process in which the corrections are applied to the data
                stream.
                                                                            — IMPL-BY--•
LAS1 UPDATED
  07/12/B/
PROCESS ID v     	NAME	     --IMPL-BY--       LAST  UPDATED
OS.04           APPLY AUDIT CHANGE                                                          Diagram  Mil        O7/13/87

                	PROCESS NARRATIVE	

                Changes determined necessary through the auditing process are supplied to
                the data base.  All data passes through this process.  Changes are made  as
                per corrections specified by the audit process.

====== ===ES=====s=s=:=E3cE==============E=s:ssss:s=:=s:s==:=ss==========s== = ===B======s==s== =s====s====== ==s = ==sc===s===.= = ====:=::=:==

PROCESS ID	NAME	     —IMFL-BY—       LAST  UI'DATED
05.04.01        DETERMINE IF AUDIT CHANGES ARE REQUIRED                                                        07/L.2/B7

                	PROCESS NARRATIVE	

                The data stream consisting of all unaudited  (yet validated) data  is split
                (logically) into two subsets, that requiring changes and that not requiring
                changes.  This determination is made on the presence or absence of an
                "audit correction" for a given element.



PROCESS ID      	NAME	     --IMPL-BY—       LAST  UPDATED
05.04.02        HAKE AUDIT ERROR CORRECTIONS                                                                   O7/O2/B7

                	PROCESS NARRATIVE	

                Audit error corrections are applied to those data elements requiring such
                changes.



PROCESS ID      	NAME	     — IMPL-BY—       LAST  UPDATED
OS.O4.03        COMBINE AUDITED DATA STREAMS                                                                   O7/02/87

                	PROCESS NARRATIVE	

                The two data streams are combined.  This process demonstrates that all

*** CONTINUED ••»

-------
F'     «ANttl.YSl                                       Annual/'     \a\  Report.  System                                 ANAR2'     f i'il .L    !••
I     SYSTEM VERSION: t>                                                                                           07/1B      H3:i.4:Sl
                                                         FRL.   -> ATTRIBUTES
= = = ==== = = = =BSS = = = = ^ = ±£ = ± = Bss = s = s=s = = zss^s = = s = s = s = a = = = s = ^ = = s=:s: = ss = = =: = s = = s = = = = = s£.s;== = = = = = = = === = = = = = = == = —s = = ^ = = = = = = = = = =2 = = = = = = =.=:=:.= =	== ==. i.^_

PROCESS ID      	NAME	     --IMPL-BY--      LAST UPDATED
03.04.03        COMBINE AUDITED DATA STREAMS                                                                   O7/02/B7
**» CONTINUED «**

                	PROCESS NARRATIVE	'	

                data, both that which required audit changes and that which does not is
                passed to the store and receive process.



PROCESS ID      	NAME	     — IMPL-BY—      LAST UPDATED
06              STORE Si RETRIEVE OVERSIGHT DATA                                             Diagram N12        07/17/87

                	PROCESS NARRATIVE	

                In this process, the -final oversight domain data is  stored  and managed.
                Oversight reports are produced by this process.   Additionally, data is
                transferred to the oversight RCRIS by this process.



PROCESS ID      	NAME	     —IMPL-BY—      LAST UPDATED
06.Ol           STORE OVERSIGHT DATA                                                                           07/02/87

                	PROCESS NARRATIVE	

                Oversight data received from the auditing process is transformed as
                necessary and stared in the oversight data base.



PROCESS ID      	NAME	     —IHPL-BY—      LAST UPDATED
06.02           PRODUCE REPORTS                                                                                O7/02/B7

                	PROCESS NARRATIVE	

                Ad hoc and standard oversight reports are produced at this  level.  For a
                description of these reports, see the description of EE 3.



PROCESS ID      	NAME	     —IMPL-BY—      LAST UPDATED
06.03           TRANSFER OVERSIGHT DATA TO RCRIS                                                               07/02/B7

                	PROCESS NARRATIVE	

                Data which has been subjected to the auditing process and has been accepted
                as oversight data is transferred to  RCRIS.  Any transformations required
                for compatibility with the RCRIS data system are made.
TOTAL NUMBER OF PROCESSES ON PROJECT DICTIONARY  VERSION 6  :       46

TOTAL NUMBER OF PROCESSES ON REPORT:                          '    46

-------
DIAGRAM SUMMARIES

-------
Fro)
II):
        MAI NL.T
        STEM VERSION: 6
 Amuidl/hiF       Report  System

DATA FLOW D)^ur.AM INFORMATION
                                                                                                                     U//1B/13
                                                                                   'il
                                                                                   '1 : -1
                                    LOGICAL/
              DFD NAME    LEVEL     PHYSICAL

              01          (  2       LOGICAL

              LAST UPDATED:  06-26-87
    CURRENT
    / NEW

      NEW
EE1
EE1
01.01
D01/1
D01/1
01.04
O1.O3
01.O2
TOTAL NUMBER OF DATA FLOWS ON DIAGRAM:
DATA QTflRF'Q • — — 1 H— —
DOl/l
TOTAL NUMBER OF DATA STORES ON DIAGRAM:

O1.O1
01.02
01.03
01.04
02
02.01
02.03
02. 04
03
04
O6
TOTAL NUMBER OF PROCESSES ON DIAGRAM:
EXTERNAL ENTITIES: 	 ID 	
01.03 ANNUAL/BIENNIAL REPORT FORM
01.01 ANNUAL/BIENNIAL REPORT FORM •
DOI/1 UNEDITED DATA
01.02 UNEDITED DATA
01.04 UNEDITED DATA
02 EDITED DATA
O1.O4 KEY-ENTRY CORRECTIONS
01.03 TURNAROUND DOCUMENT
B

UNEDITED DATA STORAGE
1

— — _____ 	 	 NAME 	 	 	 	 — — -IMPL6Y —
ACCEPT t< ENTER DATA
PRODUCE TURNAROUND DOCUMENT
EXAMINE DATA FOR KEY-ENTRY ERRORS Diagram t»3
MAKE KEY-ENTRY CORRECTIONS Diagram «4
VALIDATE DATA Diagram N5
ACCEPT DATA FOR VALIDATION
EXAMINE DATA FOR REPORTING ERRORS Digram tt&
CORRECT REPORTING ERRORS Diagram «7
STORE RETRIEVE & TRANSMIT DATA Diagram KB
RECEIVE OVERSIGHT DATA
STORE It RETRIEVE OVERSIGHT DATA Diagram HI2
11
	 KI&MP 	
                              EE 1

TOTAL NUMBER  OF  EXTERNAL ENTITIES ON DIAGRAM:
RESPONDENT  (HANDLER)

-------
Pr    "ANALYST                                      Annual/F      al  Repcir t  System                                ANAR2F    PttGL
IL    3YS1EM VERSION: 6                                                                                           O7/10      19:47:'::
                                                    DATA  FLOW    .uRAM INFORMATION


                                   LOGICAL/      CURRENT
             DFD NAME    LEVEL     PHYSICAL      /  NEW         	DESCRIPTION	

             O1.O2         3       LOGICAL          MEM

             LAST UPDATED: O6-25-B7


                DATA FLOWS:  —SOURCE	     DESTINATION     	NAME	

••• NO DATA FLOWS FOUND ON THE DIAGRAM


               DATA STORES:  	ID	     	NAME	

•** NO DATA STORES FOUND ON THE DIAGRAM


                 PROCESSES:  	ID	     	NAME	     —IHPLBY--

••• NO PROCESSES FOUND ON THE DIAGRAM


         EXTERNAL ENTITIES:  	ID	     	NAME	

**• NO EXTERNAL ENTITIES FOUND ON THE DIAGRAM

-------
raKit«ANALYST                                        Annual/Biennial Repor*-  System                                   ANAR2ESA, PAGE
D: BRSYSTEM V    IN:  6                                                                                                 O7/1B/B7,   19:47:3
                                                     DATA FLOW DIAGRAM  INFO..  TIGN


                                    LOGICAL/      CURRENT
             DFD NAME     LEVEL     PHYSICAL      / NEW         	DESCRIPTION	

             01.03          3       LOGICAL         NEW

             LAST UPDATED:  O6-24-B7


                DATA FLOWS:   —SOURCE	      DESTINATION     	NAME	
                              EE1              O1.O3.O1         ANNUAL/BIENNIAL REPORT  FORM
                              Ot.O3.01         01.03.02         KEY-ENTRY EXCEPTION REPORT
                              O1.O3.02         01.O4            KEY-ENTRY CORRECTIONS
                              O1.O2            01.O3.Ot         TURNAROUND  DOCUMENT

OTAL NUMBER OF DATA FLOWS  ON DIAGRAM:               4
==— s======== a===^—»===== = *»»=aass5aa^e3CB»=^ss=^asas=ssasa^==as—»^==s^ == ===; a:====t ss ===^ss==a=s = =^=K.SSSSSS^B = ss=a:===:=: s ====== = = == = s; =^==:c^==;==—== s

               DATA STORES:   	ID	      	NAME	

*» NO DATA STORES FOUND  ON THE DIAGRAM
=== = = =ss3======s===*«ss=ss=i=«=:s=s=;s===s=:=3s=sa==ss=s==5s=;s==s ========ss= = ?== ==s= = === = = = =:K:====S=:S = :B= = ====,= ====—s= = ==«==; =s=s= ===55==== = = :=s=:====ss=:===:=== = = ===== =

                 PROCESSES:   	ID	      	NAME	     —IMPLBY	
                              01.02            PRODUCE TURNAROUND DOCUMENT
                              01.O3.O1         COMPARE T.A.D  WITH REPORT FORM
                              O1.O3.02         DETERMINE  REQUIRED CHANGES
                              O1.04            MAKE KEY-ENTRY CORRECTIONS                                                      Diagram #4

OTAL NUMBER OK PROCESSES ON DIAGRAM:                4
= = = = = = = = .= =; = == = =:=s===s=s:s=s^=sss==ss=======:====a =:==:==:======; = === === = = = ==== = a — = ==s==; = = ==== = = = =^= = =^=s== == = === === ==^s = = == = = = ==== ==^ = = = ====

        EXTERNAL ENTITIES:   	ID	      	NAME	
                              EE 1             RESPONDENT (HANDLER)

OTAL NUMBER OF EXTERNAL  ENTITIES ON DIAGRAM:       1

-------
 Pr
       SYSTEM VERSION:  6
  Annual/'

 DATA FLO.
====?=======
>ial  Huport byiLiim

.GRAM INFORMATION
                                                                                                                     /1L
                                    LOGICAL/      CURRENT
              DFD  NAME    LEVEL     PHYSICAL      / NEW        	DESCRIPTION	

              O1.O4         3       LOGICAL         NEW

              LAST UPDATED:  06-24-87


                DATA FLOWS:   —SOURCE	     DESTINATION     	NAME	
                              D01/1           01.04.01        UNEDITED  DATA
                              01.04.O3        02              EDITED  DATA
                              O1.03           01.O4.O2        KEY-ENTRY CORRECTIONS
                              01.03           01.04.01        KEY-ENTRY CORRECTIONS
                              01.O4.01        01.O4.O2        DATA REQUIRING  KEY-ENTRY  CORRECTIONS

                              01.04.01 '       01.04.03        DATA NOT  REQUIRING KEY-ENTRY  CORRECTIONS
                              01.O4.02        01.04.03        KEY-ENTRY CORRECTED  DATA

TOTAL NUMBER  OF DATA FLOWS  ON DIAGRAM:              7
-====================00===================================================== ==ss=========ss==============-_=--- =======__====-. _________

               DATA  STORES:   	ID	     	NAME	
                              D01/1           UNEDITED DATA STORAGE

TOTAL NUMBER  OF DATA STORES ON DIAGRAM:              1
==================================================================================—

                  PROCESSES:   	ID	     	NAME	     —IMPLBY---
                              01.03           EXAMINE DATA FOR KEY-ENTRY ERRORS                                            Diagram *Z
                              O1.04.O1        DETERMINE IF KEY-ENTRY  CORRECTIONS ARE REQUIRED
                              01.O4.02        MAKE KEY-ENTRY CORRECTIONS
                              01.O4.03        COMBINE KEY-ENTRY EDITED  STREAMS
                              02              VALIDATE DATA                                                                Dxagran, «5

TOTAL NUMBER  OF PROCESSES ON DIAGRAM:               5
c: = = = = Si~ ——=z = ~=Z£~~^^===sss=s=szszsxztzs==^ssssssKssssssssss^&sz:== = s-^sfss ==^=.s^ = = ^sssxszz = ^= ==s^szsi^^ — ---~& — s^-- — s=—— — '-'-~ — — — '-	— —	*_	— —	

         EXTERNAL  ENTITIES:   	ID	     	NAME	

«** NO EXTERNAL ENTITIES  FOUND ON THE DIAGRAM

-------
      'lANALVbl
       SYSTEM VtKSION:  6
 Annudl/F

DATA FLQU
Keport Svstem

 INFORMATION
                                                                                                                   "//IB.
PAUL    r
 19:47:;
                                                                                                                        = .= =..= -==£ = =. = _===. ; -
                                    LOGICAL/      CURRENT
              DFD NAME    LEVEL     PHYSICAL      / NEW         	DESCRIPTION	

              O2            2       LOGICAL         NEW

              LAST UPDATED:  O7-12-87


                 DATA FLOWS:   —SOURCE	     DESTINATION      	NAME	
                              O2.04           03               VALIDATED DATA
                              01              O2.O1            EDITED  DATA
                              D02/1           02.02            INVALIDATED DATA
                              D02/1           02.04            INVALIDATED DATA
                              02.01           DO2/1            INVALIDATED DATA

                              02.O3           02.04            VALIDATION CORRECTIONS
                              O2.O2           O2.03            VALIDATION REPORT
                              EE6             02.03            EXTERNAL  IMPLEMENTOR  DATA

TOTAL NUMBER  OF DATA FLOWS  ON DIAGRAM:              B
—=—=——-================================================================================--—======_=—==__—==_===____&___________

                DATA STORES:   	ID	     	NAME	
                              D02/1           UNVALIDATED DATA STORAGE

TOTAL NUMBER  OF DATA STORES ON DIAGRAM:             1
SS = aSSSSS3S = SSSSS = = = SSSSiSS5SSSCSSS3S5 = 5 = S = SSSESSSSSS;55;SS = SSSSS:s:SSSS~~"~I"*l»'""~"—>~—— — — — — —. — — — — — — _«_________________________  ____ _

                  PROCESSES:   	ID	     	NAME	     — |MpLBY—
                              01               ENTER * EDIT DATA                                                           Diagram »-
                              02.OI           ACCEPT DATA FOR  VALIDATION
                              02.02           PRODUCE VALIDATION REPORT
                              02.03           EXAMINE DATA FOR REPORTING ERRORS                                            Diagram »6
                              02.04           CORRECT REPORTING ERRORS                                                     Diagram «7
                              03              STORE RETRIEVE «. TRANSMIT  DATA                                              Diagram HE)
                              OS              AUDIT OVERSIGHT  DATA                                                         Diagram «9

TOTAL NUMBER  OF PROCESSES ON DIAGRAM:               7
=====oats»s«==ao====ss==oc= = =3=s====c==«=e3CEC3=s=s===:=B=s=s=====c = S3 =====s:= = = = = = = = ==== = =S ====KSSS==KS = = = = = = = = = = = == = = = = = = = = = === = = s= = = .s = s=s; = s

         EXTERNAL ENTITIES:   	ID	     	NAME	
                              EE  6            EXTERNAL IMPLEMENTOR DATA  SOURCES
  i
TOTAL NUMBER  OF EXTERNAL  ENTITIES ON DIAGRAM:       1

-------
Fr     ANALYST
in     .VS1EM VERSION: 6
                                                     Annual/B:     at  Report  System
                                                                                                                             AGP.    o
                                                                                                                  07/18/..    19:-J7::a
                                                    DATA  FLOW DIAGRAM INFORMATION
==	=========================================================«^

                                   LOGICAL/      CURRENT
             DFD NAME    LEVEL     PHYSICAL      /  NEW         	DESCRIPTION	

             O2.Ot         3       LOGICAL          NEW

             LAST UPDATED: O6-24-87


                DATA FLOWS:  —SOURCE	     DESTINATION     	NAME	

• •• NO DATA FLOWS FOUND ON THE DIAGRAM
========a=M=======M===================================================«

               DATA STORES:  	ID	     	NAME	

*«» NO DATA STORES FOUND ON THE DIAGRAM


                 PROCESSES:  	ID		NAME	_	     — IMPLBY	

•*• NO PROCESSES FOUND ON THE DIAGRAM


         EXTERNAL ENTITIES:  	ID	     	NAnE	

•*» NO EXTERNAL ENTITIES FOUND ON THE DIAGRAM

-------
 F     t*ANALYST                                       Annual,      ,al  Report Sv^.n                                .^NfiR-     I AGC
      .SYSTtM VERSION: 6                                                                                           0™/U      19-47- -£J
                                                    DAT A FIG.    ^GRAM INFORMATION
 ="=======«================= ============M=================M==^^

                                    LOGICAL/       CURRENT
             DFD NAME    LEVEL      PHYSICAL       /  NEW        	DESCRIPTION	

             O2.O3         3        LOGICAL          NEW

             LAST UPDATED: 07-12-87


                DATA FLOWS:  —SOURCE	      DESTINATION     	NAME	
                             O2.03.04         02.04            VALIDATION CORRECTIONS
                             02.02            02.03.02        VALIDATION REPORT
                             O2.O2            O2.03.O3        VALIDATION REPORT
                             O2.O2            02.03.01        VALIDATION REPORT
                             02.03.02         02.03.04        VALIDATION ERRORS FROM INTERNAL CHECKS

                             02.03.01         02.03.04        VALIDATION ERRORS FROM EXTERNAL CHECKS
                             EEA              02.03.01        EXTERNAL IMPLEMENTOR DATA
                             02.03.03         02.03.04        VALIDATION ERRORS FROM INTRASTATE CHECKS

 TOTAL NUMBER OF DATA FLOWS ON DIAGRAM:               8


               DATA STORES:  	ID	      	NAME	

*»* NO DATA STORES FOUND ON THE DIAGRAM
=====================================================================================================================================_-

                 PROCESSES:  	ID	      	NAME	     —IHPLBY —..
                             02.02            PRODUCE  VALIDATION REPORT
                             02.O3.01         COMPARE  REPORT WITH EXTERNAL  DATA
                             02.03.02         EXAMINE  REPORT FOR INTERNAL CONSISTENCY
                             02.03.03         EXAMINE  REPORT FOR INTRASTATE CONSISTENCY
                             02.03.04         DETERMINE VALIDATION  CORRECTIONS
                             02.04            CORRECT  REPORTING ERRORS                                                    Diagram «7

TOTAL NUMBER OF PROCESSES ON DIAGRAM:               6


         EXTERNAL ENTITIES:  	ID	      	NAME	
                             EE 6             EXTERNAL IMPLEMENTOR  DATA  SOURCES

TOTAL NUMBER OF EXTERNAL ENTITIES ON DIAGRAM:        1

-------
      t*ANAL YS1
      RSYSTEM VERSION:  6
 Annual/    nial Report System

DATA FLOW DIAGRAM INFORMATION
ANAIV
07/1L
FrtOC    D
 I1?. 47: 70
                                    LOGICAL/      CURRENT
              DFD NAME    LEVEL     PHYSICAL      / NEW        	DESCRIPTION	

              O2.O4         3       LOGICAL         NEW

              LAST UPDATED:  06-24-87


                 DATA FLOWS:   —SOURCE	     DESTINATION     	NAME	
                              02.04.03        03              VALIDATED DATA
                              DO2/I            02.O4.0I        UNVALIDATED DATA
                              02.03           02.04.02        VALIDATION CORRECTIONS
                              °2.03           02.04.01        VALIDATION CORRECTIONS
                              02.04.01        02.04.03        DATA NOT REQUIRING VALIDATION CORRECTION

                              02.04.01        02.04.02        DATA REQUIRING VALIDATION CORRECTIONS
                              02.04.02        02.04.03        VALIDATION CORRECTED DATA

TOTAL NUMBER  OF  DATA FLOWS  ON DIAGRAM:               7
                                    ——————   ~~    ——	—	= === = ===============================s============== = ss==s:=====

               DATA  STORES:   	ID	     	NAME	
                              D02/1            UNVALIDATED DATA STORAGE

TOTAL NUMBER  OF  DATA STORES ON DIAGRAM:              1
E = SSS3 = = SSS = S£SSSS=SSSS = S = = = s;ES = ss = S5; = SSS = SS:=. = —— —— •—	— — —	—	— —	 _ _

                  PROCESSES:   	ID	     	NAME	     _.,MPLBY._.
                              02.03            EXAMINE DATA FOR REPORTING ERRORS                                           Diaaram  *L
                              02.04.01        DETERMINE IF REPORTING CHANGES ARE REQUIRED
                              02.04.02        MAKE REPORTING ERROR CORRECTIONS
                              02.04.03        COMBINE VALIDATED DATA STREAMS
                              03              STORE RETRIEVE & TRANSMIT DATA                                              Diauram  IIP
                              04              RECEIVE OVERSIGHT DATA                                                         *
                              05.03            PERFORM CONSISTENCY CHECK 8, AUDITS                                          Diagram  »!•

TOTAL NUMBER OF PROCESSES ON DIAGRAM:                7
ESSSSS&SSSSCCS555S&«CSSSSSSSS&SSSSSSSSSS3C3SSS=CSESSSS""~—— — ~ —~-—i —= —»——.~ __«««_______ —_«•...___      __

         EXTERNAL ENTITIES:   	ID	     	NAnE	

•••NO EXTERNAL ENTITIES FOUND ON THE DIAGRAM

-------
 Fr     "ANALYST                                      Annual/p      al  Report  System                                ,-,NfiR T     PAI I
 II     ,YS1EM VERSION:  6                                                P                                           ^j^      ^47.-f
                                                    DATA FLQU     jRAM INFORMATION
 ===—======"-===-====================================-===-==============================================!S=== = ===Ji=.=:	.= =._=.=,.-.= ._:==_.=

                                    LDGICAL/      CURRENT
              DFD NAME     LEVEL     PHYSICAL      / NEW        	DESCRIPTION

              O3            2       LOGICAL         NEW

              LAST UPDATEDt O&-26-87


                 DATA FLOWS:  —SOURCE	     DESTINATION     	NAME	
                              02              03.01           VALIDATED DATA
                              03.Ot           Dl              1MPLEMENTOR DATA
                              01              O3.O4           IMPLEMENTOR DATA
                              01              03.03           IMPLEMENTOR DATA
                              Dl              03.02           IMPLEMENTOR DATA

                              03.O3           EE2             IMPLEMENTOR REPORTS
                              O3.02           04              TRANSMITTED OVERSIGHT  DATA
                              03.04           EE4             IMPLEMENTOR DOMAIN  RCRIS DATA

 TOTAL NUMBER OF DATA FLOWS ON DIAGRAM:              B
 ===========================================™

                DATA STORES:  	ID	     	NAME	
                              Dl              IMPLEMENTQR DATA BASE

 TOTAL NUMBER OF DATA STORES ON DIAGRAM:             1


                  PROCESSES:  	ID	     	NAME	     — IMPLBY
                              02              VALIDATE DATA                                                                Diagram »S
                              O3.01           STORE IMPLEMENTOR DATA
                              O3.02           TRANSMIT OVERSIGHT DATA
                              03.03           PRODUCE WASTE GEN. S, MANAGEMENT REPORTS
                              O3.04           TRANSMIT DATA TO RCRIS
                              O4              RECEIVE OVERSIGHT DATA

TOTAL NUMBER  OF  PROCESSES ON DIAGRAM!                6
BSS5aaSSSSSS8SSES5SCSSSSSSCSBSS3SSSSS = S= = SSSElCSSSSBSBSSSa = CK:sSSa = = CSSBE3 = aSS = E3 = S&aS=3——es — — —• — — e — E — S	— — — — —•	— — — — — — — -_-.— —		  _

         EXTERNAL ENTITIES:  	ID	     	NAME	
                              EE 2            IMPLEMENTOR USE OF REPORTS
                              EE 4            RCRIS IMPLEMENTQR DOMAIN

TOTAL NUMBER  OF  EXTERNAL  ENTITIES ON DIAGRAM:       2

-------
F'r
1C
'ANALYST
 YSItM VEKSIDN: h
 Annual/It      al  Report L>ysti>ni

DATA FLOW ....43RAM INFORMATION
ANAR2C
..//IB/
                                                                                                                                  IV: -I/: 7H
                                     LOGICAL/      CURRENT
              DFD NAME    LEVEL      PHYSICAL      / NEW         	DESCRIPTION	

              04            2        LOGICAL         NEW

              LAST UPDATED: O6-19-B7


                 DATA FLOWS:  —SOURCE	     DESTINATION      	NAME	

*»* NO DATA FLOWS FOUND ON THE  DIAGRAM


                DATA STORES:  	ID	     	NAME	

*»• NO DATA STORES FOUND ON THE DIAGRAM
KSS = ^B = ^aS^3a=SS = ^SBBSSSSSSSaSSSaSSSSaBBSSSS^ = 3^BS^SSSSSBBSSS^SS^aB = = aSS^S^^BS^^S = ^ = BSSS = = = SSSSSESSSSSSSSS = = ^ = = = = = = = = 3I== = = = = SB = =^^^ = ==BS^£. = S =

                  PROCESSES:  	ID	     	NAME	     —1MPLBY	
                              OS              AUDIT OVERSIGHT  DATA                                                          Diagram H9

TOTAL NUMBER OF PROCESSES ON DIAGRAM:               1
™s=sssscs=SBBBBBBBBisBSBsss:s=sas:ss:ss:EBSSssssBSBBBBssss;ss::s=sBBBBBBBBSBBB3BBB;BBSBBBBBs = = BssBBSBB=BBBB = ss=:::s:±s±::=ssBSB = = ssBusss = ss=:BB;Bs = = =

         EXTERNAL ENTITIES:  	ID	     	NAME	

*** NO EXTERNAL ENTITIES FOUND  ON  THE DIAGRAM

-------
 f-
 I
•ANALYST
SYSTEM VERSION: 6
Annual/'
                Report System
                                                                                                                   07/10
                                                                               1 1
                                                                         1'f .47: "H
                                                    DATA FLOh   .^GRAM  INFORMATION
 ======================================-=====_==__===_=====================_=====_====_========t===i========_=_

                                    LOGICAL/      CURRENT
              DFD NAME    LEVEL     PHYSICAL      / NEW        	DESCRIPTION

              OS            2       LOGICAL         NEW

              LAST UPDATED:  O7-I1-B7


                 DATA FLOWS:   —SOURCE	     DESTINATION     	NAME	
                              05.Oi           DOS/1           UNAUDITED DATA
                              DOS/1           03.04           UNAUDITED DATA
                              DOS/1           OS.02           UNAUDITED DATA
                              05.04           06              AUDITED DATA
                              O4              05.Ol           RECEIVED DATA

                              05.02           05.O3           AUDIT EXCEPTION REPORT
                              EE7             05.O3           EXTERNAL OVERSIGHT DATA
                              05.O3           05.04           AUDIT CORRECTIONS

TOTAL NUMBER  OF DATA FLOWS  ON DIAGRAM:               8
s======s=====s====s========================= s s ;s==ss:s s===sss==sss£5=s======e===ssss==s3ss==:ssass===ss=K=ss= = £=3s= = = s=s=== = ~ = S:s

                DATA  STORES:   	ID	     	NAME	
                              DOS/1           UNAUDITED DATA STORAGE

TOTAL NUMBER  OF DATA STORES  ON DIAGRAM:              1
  ————— ~—~'~—~-"—"—B===—=!=====—==s===!======ss=======s==e=asss=c=====ss====sss======s======Ea====ss——==—=—————————— — ——__

                  PROCESSES:   	ID	     	NAME	      — IMPLBY	
                              01               ENTER C, EDIT DATA                                                            Diagram »2
                              02              VALIDATE DATA                                                                Diagram ttS
                              03              STORE RETRIEVE S. TRANSMIT DATA                                               Diagram «B
                              04              RECEIVE OVERSIGHT DATA
                              05.01           ACCEPT DATA FOR AUDITING
                              OS.02           PRODUCE AUDIT EXCEPTION REPORT
                              05.03           PERFORM CONSISTENCY CHECK & AUDITS                                           Diagram *10
                              05.04           APPLY AUDIT CHANGE                                                           Diagram Nil
                              06              STORE & RETRIEVE OVERSIGHT DATA                                              Diagram HI2

TOTAL NUMBER  OF PROCESSES ON DIAGRAM:                9
= = = = = = = = = = = === = = = = = = = = = = = = = === = ========== = = = = = = = = = = = = = === = = = = = = = = = = = = = = = = = = = = = = = = = = = = =S = = = =. = = = = 5S = = S= = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = =. = =

         EXTERNAL ENTITIES:   	ID	     	NAME	
                              EE 7            EXTERNAL OVERSIGHT DATA SOURCES

TOTAL NUMBER  OF EXTERNAL  ENTITIES ON DIAGRAM:       1

-------
FT    •ttNALYST
II     JYSIEM VERSION: 6

LOGICAL/
run Puvcirai
Annual /H
DATA FLOU
CURRENT
/ MCTU
al Keport System
jRftM INFORMATION

ONAR2K
07/lD

F'flfiK
19:^7:

-r

             DFD NAME

             OS.O3         3       LOGICAL

             LAST UPDATED: O7-11-B7
                                                   NEW
                DATA FLOWS:
                             —SOURCE—
                             05.02
                             OS. 02
                             05.02
                             EE7
                             05.03.01

                             05.O3.02
                             05.03.04
                             05.03.03
TOTAL NUMBER OF DATA FLOWS ON DIAGRAM:
               DATA STORES:  	ID	

»•• NO DATA STORES FOUND ON THE DIAGRAM
DESTINATION
05.03.O2
05.O3.O1
05.03.03
05.03.01
O5.O3.O4

05.03.04
05.04
05.03.O4

       8
                                                             	NAnE	
                                                             AUDIT EXCEPTION REPORT
                                                             AUDIT EXCEPTION REPORT
                                                             AUDIT EXCEPTION REPORT
                                                             EXTERNAL OVERSIGHT DATA
                                                             AUDIT ERRORS FROM'EXTERNAL CHECKS
                                                             AUDIT ERRORS FROM
                                                             AUDIT CORRECTIONS
                                                             AUDIT ERRORS FROM
INTERNAL CHECKS
                                                                               INTERSTATE CHECKS
                                             	NAME	
                 PROCESSES:  	ID	     	NAME	
                             05.O2           PRODUCE AUDIT EXCEPTION REPORT
                             O5.O3.01        COMPARE AUDIT WITH EXTERNAL DATA
                             05.03.02        EXAMINE REPORT FOR INTERNAL AUDIT CONSISTENCY
                             O5.O3.03        EXAMINE REPORT FOR INTERSTATE CONSISTENCY
                             OS.03.04        DETERMINE AUDITING CORRECTIONS
                             05.04           APPLY AUDIT CHANGE
TOTAL NUMBER OF PROCESSES ON DIAGRAM:
         EXTERNAL ENTITIES:  	ID-
                             EE 7
                                                                                                                          —IMPLBY	
                                                                                                                          Diagram Nil
                                                                             --NAME-
                                             EXTERNAL OVERSIGHT DATA SOURCES

TOTAL NUMBER OF EXTERNAL ENTITIES ON DIAGRAM:       1

-------
u
•ANALYST
3YSTEM VERSION: 6
                                                     Annual/f
                                                                  al Report System
ANAR2'
07/1B
                                                    DATA FLOW u.rtGRttM INFORMATION
                   = = = = = = == = = = = ==== s=s = s=: = = = = = = =:=s = = ==s: = := = = =:=:=:£=:£ss = = = = = s== === = s= :=:=:=::== = = = = = := = :£ = = =:3:!= = = = = = = =-= = =L£ f — =-£::=:= = .=. = = := = ££ .= = = = =:;

                                    LOGICAL/      CURRENT
             DFD NAME    LEVEL      PHYSICAL      / NEW        	DESCRIPTION	

             O5.O4         3        LOGICAL         NEW

             LAST UPDATED: 06-25-87


                DATA FLOWS:  —SOURCE	     DESTINATION     	NAME	
                             DOS/1            05.04.01        UNAUDITED DATA
                             05.04.03        06              AUDITED DATA
                             05.03            05.04.02        AUDIT CORRECTIONS
                             05.03            05.O4.O1        AUDIT CORRECTIONS
                             05.04.01        05.04.02        DATA REQUIRING AUDIT CORRECTIONS

                             05.04.01        05.O4.O3        DATA NOT REQUIRING AUDIT CORRECTIONS
                             O5.O4.O2        O5.O4.03        AUDIT CORRECTED DATA

TOTAL NUMBER OF DATA FLOWS ON DIAGRAM:              7


               DATA STORES:  	ID	     	NAME	
                             DOS/I            UNAUDITED DATA STORAGE

TOTAL NUMBER OF DATA STORES ON DIAGRAM:             1


                 PROCESSES:  	ID	     	NAME	     --IMPLBY- —
                             05.03            PERFORM CONSISTENCY CHECK & AUDITS                                           Diagram  «10
                             OS.O4.01        DETERMINE IF AUDIT CHANGES ARE REQUIRED
                             05.04.02        MAKE AUDIT ERROR CORRECTIONS
                             05.04.03        COMBINE AUDITED DATA STREAMS
                             06               STORE & RETRIEVE OVERSIGHT DATA                                              Diagram  012

TOTAL NUMBER OF PROCESSES ON DIAGRAM:               5


         EXTERNAL ENTITIES:  	ID	     	NAME	

»•» NO EXTERNAL ENTITIES FOUND ON THE DIAGRAM

-------
Fr     "ANALYST                                       Annual/"      al  Report  System                                ANfil^r    FftlJL    K.
1      iYSILM VERSION:  6                                                                                           O7/JQ.      1-7:47:'
                                                    DATA FLOW    JRAM INFORMATION
======================================================================================================== = -i=====1.-_^==:.J_J=_=.s.s.JJ__..__

                                    LOGICAL/      CURRENT
             DFD NAME     LEVEL     PHYSICAL      /NEW        	DESCRIPTION	

             O6             2       LOGICAL         NEW

             LAST  UPDATED:  O7-12-87


                DATA FLOWS:   —SOURCE	     DESTINATION     	NAME	
                              OS      '        O6.01           AUDITED DATA
                              06.Ol            D2              OVERSIGHT DATA
                              D2              06.03           OVERSIGHT DATA
                              D2              06.02           OVERSIGHT DATA
                              06.02            EE3             OVERSIGHT REPORTS

                              O6.O3            EES             OVERSIGHT DOMAIN RCRIS  DATA

TOTAL NUMBER OF DATA FLOWS  ON DIAGRAM:               6
=====s===ss-============s============================================================s=-=====sa========sa===================s====.===

               DATA STORES:   	ID	     	NAME---	
                              02              OVERSIGHT DATA BASE

TOTAL NUMBER OF DATA STORES ON DIAGRAM:              1


                 PROCESSES:   	ID	     	NAME	     — IMPLBY —
                              OS              AUDIT OVERSIGHT DATA                                                         Diagram H9
                              06.01            STORE OVERSIGHT DATA
                              06.O2            PRODUCE REPORTS
                              O6.03            TRANSFER OVERSIGHT DATA TO RCRIS

TOTAL NUMBER OF PROCESSES ON DIAGRAM:               4
    ™«*"" — ™ —••••••• ™«M ••»•«-•«______«.»B _ »_ _ _ s —B —« —««EM_«HMMM_ESS&SSSSSSSSSSSSSS™™S&KSSX5SSS S = = SCS = = = SSS S SCSS2 !S = SS SS = S^ SSSESSZZBSSSS&KSlH

         EXTERNAL ENTITIES:   	ID	     	NAME	
                              EE 3            OVERSIGHT USES OF DATA
                              EE 5            RCRIS OVERSIGHT DOMAIN

TOTAL NUMBER OF EXTERNAL  ENTITIES ON DIAGRAM:       2

-------
 Fr    v«ANALYST
 I      SYSTEM VERSION:  6
                                    LOGICAL/
              DFD  NAME    LEVEL     PHYSICAL

              BRSYSTEM      1        PHYSICAL

              LAST UPDATED:  O7-12-87
       Annual/F

      DATA FLOW
==================

    CURRENT
    /  NEW
                    »al  Report  System

                   .GRAM INFORMATION
ANAR?
07/1G
PAGE
       1 ;-,
      NEW
                                                 DESCRIPTION
                 ANNUAL/BIENNIAL  INFORMATION SYSTEM
                 PRIMARY  DATA FLOU  DIAGRAM
DATA FLOWS: — SOURCE 	
O2
03
EE1
01
05
06
03
04
O6
03
03
06
EE6
EE7
TOTAL NUMBER OF DATA FLOWS ON DIAGRAM:
DATA STORES: 	 ID 	
DESTINATION
03
Dl
01
O2
06
D2
EE2
OS
EE3
04
EE4
EE5
02
05
14
	 1

VALIDATED DATA
IMPLEMENTQR DATA
ANNUAL/ BIENNIAL REPORT FORM
EDITED DATA
AUDITED DATA
OVERSIGHT DATA
IMPLEHENTOR REPORTS
RECEIVED DATA
OVERSIGHT REPORTS
TRANSMITTED OVERSIGHT DATA
IMPLEMENTQR DOMAIN RCRIS DATA
OVERSIGHT DOMAIN RCRIS DATA
EXTERNAL IMPLEMENTOR DATA
EXTERNAL OVERSIGHT DATA

JAMP 	
                             Dl
                             D2
TOTAL NUMBER OF DATA STORES ON DIAGRAM:
IMPLEMENTQR DATA BASE
OVERSIGHT DATA BASE
PROCESSES: 	 ID 	
01
02
03
04
OS
05.03
05.04
06

ENTER 8. EDIT DATA
VALIDATE DATA
STORE RETRIEVE S, TRANSMIT DATA
RECEIVE OVERSIGHT DATA
AUDIT OVERSIGHT DATA
PERFORM CONSISTENCY CHECK S. AUDITS
APPLY AUDIT CHANGE
STORE & RETRIEVE OVERSIGHT DATA

	 — IMPLBY 	
Diagram *2
Diagram US
Diagram *Q
Di agram #9
Diagram Ik 10
Diagram Mil
Diagram Ml 2
TOTAL NUMBER OF PROCESSES ON DIAGRAM:
         EXTERNAL ENTITIES:  	ID	
                             EE 1
                             EE 2
**• CONTINUED «••
RESPONDENT (HANDLER)
IMPLEMENTQR USE OF REPORTS
                               --NAME-

-------
     t»ANAI VST
      ^SYSTEM VERSION:
       Annual/
                   11al report System
                                    LOGICAL/
             DFD NAME    LEVEL      PHYSICAL

             BRSYBTEH       1        PHYSICAL

             LAST UPDATED:  O7-12-87
      DATA FLOW _iAGRAM  JNFDFvtlAI IUN


    CURRENT
    / NEW        	
                                                                     ANAK
                                                                     U7/1.
I i tl >l    i '
 19:47: ;C
                                                 DESCRIPTION
      NEW
         EXTERNAL ENTITIES:  	ID	
**• CONTINUED •»*
                             EE 3
                             EE 4
                             EE 5
                             EE 6
                             EE 7

TOTAL NUMBER OF EXTERNAL ENTITIES ON  DIAGRAM:
OVERSIGHT USES OF DATA
RCRIS IMPLEMENTQR DOMAIN
RCRIS OVERSIGHT DOMAIN
EXTERNAL IMPLEMENTQR DATA SOURCES
EXTERNAL OVERSIGHT DATA SOURCES

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****
          National Governors' Association                              unointon
      ^                                                                   Governor of Arkansas
   .  **"                                                                   Chairman

                                                                           Raymond C Scheppach
                                                                           Executive Director
                                         APPENDIX 0

                        Project Management Plan For Annual/Biennial
                                Report Software Development
            HALL OF THE STATES • 444 North Capitol Street • Washington. D.C. 20001 -1572 • (ZOZ) 624-5300

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                  PROJECT PLAN FOR

                  ANNUAL/BIENNIAL

                  REPORT SOFTWARE

                   DEVELOPMENT
                      Presented to:
             Environmental Protection Agency
                   Office of Solid Waste
              Information Management Section
                   401 M Street, S.W.
                  Washington, DC 20460
                      Prepared by:

                   CRC Systems. Inc.
                 11242 Waples Mill Road
                 Fairfax, Virginia 22030
                     (703) 359-9400
SEPA
                                              July 22,1987
                                           The Systems Specialists

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                                      SECTION 1

                       UNDERSTANDING THE REQUIREMENTS

 1.1          BACKGROUND

             EPA's  mission  to protect  human health  and  the  environment  includes the
 responsibility of jointly regulating with the  states  all  parties  involved in the management of
 hazardous waste, as hazardous waste is defined by the Resource Conservation and Recovery Act
 (RCRA) of 1976. As part of this regulatory activity, EPA is required to collect information on a
 biennial basis from generators  and other handlers of hazardous waste, as a means to report to
 Congress and the public on locations, quantities, and disposition of the waste and to be able to assess
 the effectiveness of existing regulations. The  mandate for EPA to require handlers of regulated
 wastes to submit reports biennially appears in the 40CFR, section 264.75.

             Although the various states have individual reporting requirements for their handlers,
 all the generators in all states are responsible to EPA, as well. It is of great concern to the EPA, and
 vital to the mission of protection of health and environment, that certain information on generation,
 treatment, storage and disposal of hazardous waste nationwide be  available and kept up-to-date
 through biennial reporting. The information must be uniform across states, to be amenable to
 analysis. The EPA needs such information to assess the state of the hazardous waste industry on a
 national basis, and to measure EPA nationwide  progress in its mission. The information must also
 be readily available outside the EPA because states and regions need immediate access to data to
 support activities in enforcement, permitting, and program management

             Within the existing Biennial Reporting System, EPA has the capability of producing
reports, but they are not accurate nor are they timely. Software is required to support the Biennial
Report This Project Plan addresses the software development effort

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7.2          PROJECT PLAN

             The Biennial Report software development project consists of four major elements:

             o     Data Entry Screens - The screens and software which will allow states to
                   enter  the data required for  the  Biennial Report. This  software  must be
                   consistent with the final forms developed by the Advisory Council, and must
                   allow entry of data as reported by handlers, even if it is incorrect.
             o     Quality Assurance - Software which will allow validation of the data entry,
                   including the  mechanisms required to  follow up on incomplete forms or
                   inaccurate data submitted by handlers.
             o     Summary  Reports  -  Software  which  will  produce the  Summary Report
                   information required  by Headquarters, and for Congressional reports.
             o     National Data Base - Software and operating protocols to provide for national
                   processing of data.

             The first three of these elements are most critical for release, while the national data
base can be developed after report data entry has begun. This Project Plan addresses the project for
the development of a complete automated system to support the data entry, quality assurance, other
reports, and the national data base requirements to  fulfill EPA's mandate for the biennial reporting
system.

1.3          EFFORTS TO DATE

             At the request of the U.S. Environmental Protection Agency  (EPA),  the  National
Governors' Association (NGA)  has formed  a RCRA Annual/Biennial Reporting System Advisory
Council to participate in revising RCRA's primary reporting system for handlers of hazardous waste.
The  Council is  composed of representatives from  State  Governments,  the RCRA-regulated
community, interested outside parties (including environmental groups), and representatives from
EPA's headquarters and regional offices. NGA and EPA provide staff support to the Advisory
Council.

-------
             The first aspect of the reporting system which is being addressed by the Council is

the redesign of the forms to be used by handlers in reporting information on their hazardous-waste

activities to States and EPA regional offices. The Advisory Council defined five major information

objectives to be achieved through the reporting system:


             (1)   Waste Characterization - Information describing the nature of wastes subject
                   to regulation under RCRA and associated State regulatory programs.

             (2)   Waste and Process Quantity Tracking - Information detailing the quantities
                   of RCRA and State hazardous wastes that are generated, the sources of such
                   quantities, and the manner in which such quantities are subsequently managed.

             '(3)   Regulatory  Status  -  Information describing  the reporting-year status of
                   hazardous-waste handlers subject to regulation  under RCRA and associated
                   State regulatory programs.

             (4)   Waste Minimization  -  Information describing  handlers'  practices  and
                   accomplishments in reducing both the quantities of hazardous waste and the
                   nature of the hazards posed by such wastes.

             (5)   Capacity Availability  -  Information  detailing  the  amount  of capacity
                   remaining at the end of the reporting period for processes used in treating,
                   storing, or disposing of hazardous wastes.


             A paper discussing alternatives and recommendations  for these five (5) areas, titled

"Five Priority Subject Areas to be addressed in the 1987 Biennial Report"  was prepared, and will

likely be the primary basis for the forms to be developed for use by the states.


             The Software Development Project is progressing in concert with the development of

Biennial Report forms by the Advisory Council, and the remainder of  this Project Plan addresses the

following for the Software Development Project:


             o     Project Organization and Responsibilities

             o     Methodology and Tools

             o     Documentation Requirements

             o     Schedule and Milestones

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                                    SECTION 2

                PROJECT ORGANIZATION AND RESPONSIBILITIES

2.1         PROJECT TEAM COMPOSITION
            The Biennial  Report Software Development Project will be addressed by a team
consisting of the following EPA organizations and outside contractors:
            o    Office of Solid Waste (OSW) Information Management Staff (IMS)
            o    Office of Information Resources Management (OIRM)
            o    National Governors Association Council (NGA) Advisory Council
            o    CRC Systems, Inc.
            o    Development Planning and Research Associates (DPRA)
            o    TECHLAW
            The roles and responsibilities of each are described in the following sections.
2.2         OFFICE OF SOLID WASTE, INFORMATION MANAGEMENT STAFF
2.2.1        RESPONSIBILITIES
            The following tasks will be the primary responsibility of OSW staff:
            o    Development  of Mission Element Needs (MENS) statement, required by the
                  OSWER Life Cycle Management Guidelines
            o    Development  of the  Annual/Biennial Report forms, in conjunction  with the
                  National Governors' Association Advisory Council
            o    Development of the Feasibility Study
            o    Development  of the Requirements definition  for  the  system, including
                  identifying all interviewees
            o    Development of system architecture

-------
             o    Development of system design
             o    Overall  project  management,  design,  and coordination  with  functional
                  requirements

222         STAFF ASSIGNMENTS

             Donna Inman is the Project Manager within OSW, working under the direction of
George Bonina.

              Michael  Bums  is responsible for forms development, coordination between the
Advisory Council and the  software development project team, and for final decisions on  all
functional and EPA program aspects of user requirements.

             Alex Salpeter is responsible for all coordination with the OSWER Configuration
Management Board and Steering Committee.

2.3          OFFICE OF INFORMATION RESOURCES MANAGEMENT

23.1         RESPONSIBILITIES

             OIRM will review products during  the  Software Development Project, and will
provide advice and oversight related to EPA's software and hardware directions.

2.4          DEVELOPMENT PLANNING AND RESEARCH ASSOCIATES (DPRA)

2.4.1         RESPONSIBILITIES

             The following tasks will be completed by DPRA:

                  Maintain the Project Notebook, including minutes of weekly progress meetings
o
o
o
                  Provide assistance to OSW in system requirements, architecture, and design
                  Provide  programming for data entry screens, summary  reports,  quality
                  assurance, and the national database

-------
             o    Act as the project librarian for storage and dissemination of all materials to all
                  Project Team members

             o    Provide User Support after implementation

             o    Provide logistical support to OSW for scheduling of meetings and notification
                  to all team members


2.42         STAFF ASSIGNMENTS

             Thomas Graham will serve as the Responsible Corporate Officer for DPRA. He will
                  supervise DPRA's activities during system requirements,  specification, design
                  and programming activities.  He  will  provide  technical  assistance  in  the
                  development of  system  specifications  and determination  of  the  system
                  architecture.

             Sue Graham will serve as the Project Manager for the system development effort. She
                  will be responsible for DPRA's deliverables and staff assignments during the
                  specification, design, programming,  and testing activities. She will provide
                  technical support to all phases of system development

             Kathy Corcoran will be the Project Librarian and will maintain the Project Notebook.

             Programming staff will be assigned to this project  as resource  requirements are
                  finalized.


2.5          TECHLAW


2J.7         RESPONSIBILITIES


             The following tasks will be completed by TECHLAW:


             o    Assistance  in  Requirements Definition, by providing interviews related to
                  problems which existed in the last Biennial Report cycle.

             o    Assistance  in  developing  system operation and maintenance cost estimates
                  based upon TECHLAW's work on the 1985  Alabama Biennial Report.

             o    Assistance  in developing specifications for turnaround reports and summary
                  reports for the system.

             o    Preparing a test data set by developing requirements for sample data forms to
                  be used to test the system, and completing sample test forms.

             o    Manually preparing turnaround and  summary  reports for  comparison with
                  system generated reports.

-------
252         STAFF ASSIGNMENTS

             Brian Eaton will be the primary consultant and Project Manager for TECHLAW.

             Karen Kraynak will be the Staff Associate assigned to this project.

             Additional staff for test form preparation and manual report preparation will be
                  identified as resource requirements are finalized.


2.6          CRC SYSTEMS

2.6.1         RESPONSIBILITIES

             The following tasks will be completed by CRC:

             o    Preparation  of  the task plans  for data entry, the summary reports, quality
                  assurance, and the national database.

             o    Independent testing  and  acceptance of  software for  data entry,  summary
                  reports, quality assurance, and the national database.

             o    Review of all  project  deliverables for compliance to OSW standards  and
                  project plan requirements.

             o    Preparation of training materials and presentation of training to users for data
                  entry, quality assurance, and summary reports.

             o    Project management support to OSW, including maintenance of the Project
                  Plan on MICROSOFT PROJECT, and tracking of deliverables.

             o    Project plan preparation.

            * o    Preparation of Documentation Standards for all documents to be produced on
                  the project

             o    Data entry support, analytical reports, and maintenance for data flow diagrams.

2.62         STAFF ASSIGNMENTS

             Theresa Bousquin will serve as Project Manager for CRC Systems, providing key
                  technical and administrative support in the overall  project management and
                  coordination of the tasks for this project

              Julia Towler will be the Junior Analyst assigned. She will provide support in project
                  scheduling, tracking, testing and training activities.

             A senior  analyst and  additional  staff for  testing will  be  assigned as resource
                  requirements are finalized.

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2.7         NATIONAL GOVERNOR'S ASSOCIATION

            The National Governors' Association will staff the Advisory Council and will be
responsible for verifying the requirements of the system for State users.

2.8         CMS AND OSWER STEERING COMMITTEE

2.8.1        RESPONSIBILITIES

            All OSWER  Life Cycle  Management  Guidelines  will be followed,  including
submission of all required documents to the  Configuration Management Board and Steering
Committee. Alex Salpeter will coordinate these efforts.
                                       8

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                                       SECTION 3

                             METHODOLOGY AND TOOLS

3.1           DESIGN TOOLS

              This project will follow a structured design and development approach, using data
flow diagrams for representation of the system and operations.

              Visible Analyst, a  product of Visible Systems Corporation,  will be used   as  an
automated design  tool for structured systems analysis tasks. Visible Analyst is a multi-purpose
design tool which operates on personal computers, and is comprised of  three basic software
modules:

              o    A module as an analyzing tool;
              o    A diagramming module:
              o    A data dictionary as an organizing module.

              The diagramming module provides the standard diagram symbols, and contains a
level-to-level balancing feature which  verifies the conservation  of data flows  by comparing a
specific process with its lower level diagrams. Processes can be nested, and customized symbols can
be added to diagrams as needed.

              The data dictionary module serves as the  central repository for all data and other
information about a system's design. Entries for the processes, data flows, data stores, sources, and
sinks  are  created  as diagrams are stored. Additional information  can  be  added  and stored  in
VISIBLE  ANALYST  about each  data dictionary entry, including data structures, files, charts,  or
narratives. ASCH file links with the data dictionary are possible, easing the documentation efforts.
The analysis features,  coupled with the  reports which can be produced from the Data Dictionary
module, allow analysts to check the consistency of diagrams, inputs, outputs, and relationships early
in the design process, thereby avoiding costly design errors.

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             VISIBLE ANALYST provides analysts with a powerful tool for monitoring and
controlling complex systems. In addition, for projects such as this where multiple analysts are used,
changes can be audited and tracked, thereby avoiding the mishaps which result from communication
errors.

3.2          PROJECT MANAGEMENT TOOLS

             MICROSOFT PROJECT will be used as the Project Management tool, to track all
deliverables, due dates, and resource requirements. It will be maintained by CRC Systems, and will
be used by OSW. Weekly presentations of progress  toward deliverables will occur at the weekly
progress meetings.
                                        10

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                                   SECTION 4

                       DOCUMENTATION REQUIREMENTS

4.1         GENERAL

            Two types of documentation will be produced during this project:

            o    Documentation to comply with OSWER Life Cycle Management Guidelines,
                 and
            o    Project  Documents as  the  working  documentation  for  the  software
                 development

            The working documentation will be combined to provide the System Decision Paper
(SDP) documents required for presentation to the Configuration Management Board.

            Outlines of the major elements of the documentation are presented in the following
sections.

42         COMPLIANCE WITH OFFICE OF SOLID WASTE LIFE CYCLE
            MANAGEMENT GUIDELINES

            The project will comply with the Life Cycle Management Guidelines of the Office of
Solid Waste and Emergency Response. The contents of documents for each phase of the Life Cycle
are summarized in the following sections.

42.1        PHASE 1-SYSTEM INITIATION ,
            o    Mission Element Needs Statement (MENS)

4.2 2        PHASE 2- CONCEPT DEVELOPMENT (SDP1)
            o    Proposed project plan
            o    System requirements documentation
            o    Feasibility and economic analysis
                                      11

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423         PHASE 3- DEFINITION AND DESIGN (SDP2)
             o    Configuration Management Plan
             o    Test plans, technical and user documentation, and training plan
             o    Documentation of structured walk throughs of the system (Physical data base
                  design, detailed system design)
             o    System design documentation
42.4         PHASE 4- SYSTEM DEVELOPMENT (SDP3)
             o    Program coding
             o    Unit and Integration Testing Results
             o    Certification that the system meets user needs
             o    Certification that the system meets the needs identified in the MENS
             o    Training Materials
423         PHASE 5- OPERATIONS AND MAINTENANCE (SDP4)
             o    Certification that the system continues to meet needs
             o    System Audit and Review
4J          PROJECT DOCUMENTS
             The following documents are required for the development team to complete this
project, following a structured design approach. The documents are sub-divided into two areas: Life
Cycle Management and Appendix documents.

4.3.1         LIFE CYCLE DOCUMENTS
43.1.1       Feasibility Paper

             The Feasibility Paper  will include  the  project overview and  will identify all
assumptions and constraints. Information about State/Regional hardware/software capabilities will
be addressed at this time. Analysis of the potential volume of utilization and the  potential funding
sources will be included in the paper. An understanding of the data volume  anticipated (state by
state) and potential user access methods/resource requirements will be included, as well as staffing
information, system development, operation, maintenance cost and  time. The paper will present
conclusions and offer recommendations based upon the analysis.
                                        12

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4.3.1 .2       Requirements Definition

              The Requirements  Definition will present  the project background followed by an
overview of all required components. The following components will be addressed in detail:

              o    Data Entry Components
              o    Quality Assurance Components
              o    Summary Report Components
              o    National Database Components

              The Requirements Definition will include a detailed description of the scope of the
project.

4.3.1.3       Documentation Standards

              The documentation standards will include a list of all documents to be developed in
support of this project. A description of general and  specific  standards will be included with a
document delivery schedule.

4.3.1 .4       Architectural Design

              The Architectural Design will describe the hardware and software configuration to be
used for this project, including alternatives which may be possible.
4. 3.1 3       System Specifications Document

             The System Specification document will  describe in detail the  conceptual and
detailed design. It will include consistency factors, error checking design, the system data flow,. and
the data element dictionary.

4. 3.1 .6       Test and Acceptance Han

             The Test and Acceptance plan developed for this project will describe the scope of
testing and provide  the minimum acceptable  levels of performance.  It will  include  a  detailed
description of the testing process and system error reporting. A timetable/schedule for testing phases
is required for each portion of the development. A process describing acceptance, error notification
and notification of corrections will be included.
                                          13

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 43.1.7       Change Control Management Document

              The Change Control Management document will provide guidelines and procedures
 for requests for changes to be submitted to the Configuration Management Review Board. Copies of
, OSWER AIS Configuration Change Request Forms and instructions will also be included.

 43.1.8       User Manual

              The User Manual will include a brief system overview with goals and objectives. The
 manual will provide examples of all menus, screens, and outputs. User instuctions will be presented
 in a clean and concise manner. A glossary of terminology and error messages will be included.

 43.1.9       Maintenance Manual

              The Maintenance Manual will provide a technical description of the system and will
 contain  pseudo code as  well as all  coding, system flow  charts, file structure,  edits, and field
 definitions.  System  requirements  (hardware/software)  and installation  instructions  must  be
 addressed.

 4.3.1.10      Training Manual

              The Training  Manual  will, at a minimum,  include all menu, screen, and output
 examples with clear descriptions of the relationships. Lessons and instructions  demonstrating the
 system will be included, for both the initial training sessions and for  self-training by those who do
 not attend the initial training.
                                           14

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4.32         APPENDIX DOCUMENTS
4.32.1       Project Notebook

             The Project Notebook will contain all copies of communications and meeting notes
pertaining to this project. It will identify in  detail all resource allocations  required for project
completion. Any problems/issues and their corresponding resolutions will be described and tracked
in an organized manner for reference.

4.32.2       Project Plan

             The Project Plan will describe the goals and objectives to be accomplished by this
project. It will include a timeline and schedule, identify deliverables, and document assignment of
project responsibilities.
                                         15

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                                    SECTION 5
                          SCHEDULE AND MILESTONES
       TASK
 1.     Prepare Project Plan

 2.     1st Draft of Forms

 3.     Submit MENS to Steering

       Committee

 4.     Submit Issue Paper #1 to NGA

 5.     2nd Draft of Forms

 6.     Feasibility Study

 7.     Configuration Management Plan

 8.     System Architecture

 9.     Data Entry System Specs

10.     Data Entry Walkthru

11.    NGA Evaluation of Forms

12.    Requirements Definition

13.    Submit SDP1 to Steering Committee

14.    Develop Test Data
START
DATE
6/02/87
6/22/87
7/02/87
7/02/87
7/01/87
6/24/87
8/03/87
7/23/87
7/22/87
8/18/87
8/19/87
7/13/87

7/27/87
COMF1
DATE
6/15/87
6/22/87
7/02/87
7/22/87
7/22/87
7/31/87
8/03/87
8/14/87
8/18/87
8/18/87
8/20/87
8/24/87
8/24/87
8/28/87
                                      16

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 15.   Forms Final
8/21/87
9/30/87
 16.   Data Entry Development of
       Test Plan
 17.   Data Entry Coding & Unit Testing
 18.    Revise SDP1
 19.    Submit SDP2 to Steering Committee
       for Data Entry
 20.    Data Entry 1st Pass Testing
 21.    QA System Specification
 22.    Data Entry 1st Pass Revisions
 23.    Submit SDP2 to Steering Committee
       forQA
24.    QA Walkthru requirements
25.    Data Entry 2nd Pass Testing
26.    Data Entry 2nd Pass Revisions
27.    QA Development Test plan
28.    Summary System Specification
29.   Summary Walkthru requirements
8/31/87
8/19/87
8/25/87

10/01/87
10/01/87
10/29/87

11/11/87
11/12/87
11/19/87
11/12/87
11/12/87
11/30/87
9/30/87
9/30/87
10/06/87
10/07/87
10/28/87
11/11/87
11/11/87
11/11/87
11/11/87
11/18/87
11/25/87
11/25/87
11/25/87
12/02/87
                                         17

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 30.    Data Entry 3rd Pass Testing
11/30/87
12/04/87
 31.     Submit SDP2 to Steering Committee
        for Summary Reporting
 32.   QA Coding & Unit Testing
 33.    Data Entry 3rd Pass Revisions
 34.    Data Entry Walkthru 2
 35.    Data Entry Integration
 36.    Summary Development Test Plan





 37.    Data Entry Integration Testing
 38.    Data Entry Finalize
 39.    QA 1st Pass Testing
40.    Summary Report System Coding & Unit
       Testing
41.    Submit SDP3 to Steering Committee
       for Data Entry
42.    Data Entry Release
43.    QA 1st Pass Revisions
44.   QA 2nd Pass Testing

11/12/87
12/07/87
12/11/87
12/14/87
11/30/87
12/17/87
12/24/87
12/14/87
12/14/87

1/15/88
1/13/88
1/27/88
12/09/87
12/11/87
12/11/87
12/11/87
12/16/87
12/18/87
12/23/87
1/08/88
1/12/88
1/12/88
1/15/88
1/15/88
1/26/88
2/02/88
                                         18

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 45.    Data Entry Training (East-
        West-Midwest)
1/25/88
2/09/88
 46.    1 st Pass Testing of
        Summary Reporting
1/13/88
2/09/88
 47.    National Data Base Design
        and Concept Paper
 48.   QA 2nd Pass Revisions
 49.   QA 3rd Pass Testing
 50.    Summary 1st Pass Revisions
 51.    QA 3rd Pass Revisions
 52.    Summary 2nd Pass Testing
 53.    QA Walkthru 2
 54.    Summary 2nd Pass Revisions
55.    Summary 3rd Pass Testing
56.    Summary 3rd Pass Revisions
57.    Summary Walkthru 2
58.    QA Integration
59.    Summary Integration
1/13/88
2/03/88
2/10/88
2/10/88
2/17/88
2/24/88
2/24/88
3/02/88
3/09/88
3/16/88
3/23/88
3/03/88
4/07/88
2/09/88
2/09/88
2/16/88
2/23/88
2/23/88
3/01/88
3/02/88
3/08/88
3/15/88
3/22/88
3/25/88
4/06/88
4/13/88
                                         19

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