Biennial Hazardous Waste Data: Opportunity for
Improvement
#7100114
EXECUTIVE SUMMARY
PURPOSE
The purpose of the audit was to evaluate the Environmental Protection Agency's (EPA) process for collecting
and reporting on biennial hazardous waste information. Our specific objectives were to determine if the overall
process: (1) results in the users obtaining the information needed to make sound regulatory decisions, and (2)
provides complete, accurate, and timely information to help manage EPA's hazardous waste program.
BACKGROUND
Subtitle C of the 1976 Resource Conservation and Recovery Act (RCRA) establishes a program to manage
hazardous wastes from "cradle-to-grave" to ensure that they are handled in a manner that protects human health
and the environment. RCRA requires EPA to collect information on the generation and disposal of hazardous
waste every two years. To meet these requirements, EPA established a process that produces the National
Biennial RCRA Hazardous Waste Report (Biennial Report).
EPA develops the package of biennial reporting forms and instructions and sends them to the states every two
years. After the states receive the forms, they send them to and collect them from the generators, and treatment,
storage, and disposal facilities (TSDs), check data quality, and send the information back to EPA regional
offices. Most, but not all states also enter the data into EPA's Biennial Reporting System (BRS). The regions
accumulate the states' data, further check data quality and then send the results to EPA's Office of Solid Waste
(OSW) in the Office of Solid Waste and Emergency Response (OSWER). OSW accumulates the regional data,
and does final quality checks, consulting with the regions and states to identify potential errors. According to
OSW, states must verify and correct the errors. OSW then develops and publishes the Biennial Report every
two years.
RESULTS IN BRIEF
We found that EPA's overall Biennial Report process can be improved. Specifically, we found that the:
—	Biennial Report process and the BRS are complex for many users.
—	Biennial Report changes made by the Agency for 1997 will eliminate the collection of some future
hazardous waste data.
EPA has taken some steps to ease the reporting burden for entities required to submit data for the 1997 Biennial
Report. The Office of Solid Waste created a Biennial Report Project Team to study and recommend ways to
improve the program. In addition, OSW is working to improve RCRA information overall through the Waste
Information Needs (WIN) initiative. However, our interviews of state and EPA officials, reports by the National
Governors Association (NGA) and other organizations and additional analyses and documents identify key
issues that need to be considered and improved.

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We commend the Agency on their efforts, and believe the efforts will help Biennial Reports to present a more
accurate picture of hazardous waste in the U.S.
PRINCIPAL FINDINGS
Our findings are summarized below and discussed in detail in CHAPTERS 2 and 3 of this report.
Biennial Report Process and the BRS Need Improvement
The overall Biennial Report process reflects the complexity of RCRA and is difficult for generators and TSDs
that have to report hazardous waste information. During the audit, we found that the regions and states often
view the Biennial Report process and BRS as being a complex and difficult information reporting process.
Biennial reporting forms and instructions need to be streamlined. EPA's instruction and forms package for the
1995 Biennial Report is lengthy and complex to fill out according to state officials we interviewed who deal
directly with the regulated community. States have devised their own, shorter versions of the package and have
adopted other techniques to ease the reporting burden.
To help reduce errors and increase reporting accuracy, OSW should revise codes (system type, form and source)
or data elements unique to the Biennial Report so they more closely parallel the data categories regularly used
by facilities. Potential for data errors increases when facilities have to fill out biennial report forms using some
codes that they are not used to dealing with in daily management of their hazardous wastes. This has been a
longstanding concern among some state officials.
Data Are Not Easily Obtained From BRS
The BRS was designed by EPA to meet the statutory requirement of reporting every two years on the amount
and types of hazardous waste generated in this country. OSW officials told us they provide the user community
with the ability to request enhancements to make BRS data more "obtainable." We found many users have
raised concerns about obtaining useable data from BRS. One of the main concerns is that the BRS programming
language, FOCUS, is a difficult language to learn and to use. We were told that only a few people have the
requisite expertise with FOCUS to program necessary reports from BRS.
EPA Needs to Emphasize Electronic Enhancements and Reporting
Implementers of the Biennial Report believe that expanded use of electronic technology and reporting is
needed. Similar concerns were raised in a recent report by NGA, and by an EPA sponsored study covering
implementation of BRS and the Resource Conservation and Recovery Information System (RCRIS). OSW
should work to make enhancements better known to the states which would improve their electronic reporting
activities in connection with BRS.
Planned Changes for 1997 Biennial Report May Not Meet Statutory Requirements
A statutory requirement for EPA requires facilities to report efforts undertaken to reduce the volume and
toxicity of hazardous wastes generated. EPA and state regulatory agencies have used Biennial Report data to
measure the efforts of waste minimization. However, waste minimization reporting was removed from the 1997
Biennial Report process. To assure waste minimization is occurring, EPA must be able to accurately assess and
measure the progress of waste minimization.
EPA has made other 1997 Biennial Report changes that affect the Agencies' ability to characterize and manage
the nation's hazardous waste program. EPA is no longer collecting capacity planning data in the Biennial Report

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process. In addition, the Agency has initiated changes to ensure that wastewater data does not skew Biennial
Report information.
RECOMMENDATIONS
All of our specific recommendations follow the findings in CHAPTERS 2 and 3. In summary, we are
recommending that the Assistant Administrator for the Office of Solid Waste and Emergency Response initiate
the following actions for the 1999 Biennial Report process, or as soon as possible to:
—	Streamline and redesign the Biennial Report forms and instructions to make them clearer and easier
for generators and TSDs to complete.
—	Revise the Biennial Report codes (system type, form and source) to avoid the confusion experienced
by generators and TSDs.
—	Educate the states regarding the use of existing electronic enhancements to improve their data
collection and reporting activities.
—	Improve the availability and access for all users by making BRS available at users desktop computers.
—	Assess the type of data required and specify how the RCRA Section 3002(a) reporting requirement
will be met.
—	Ensure states receive specific information for their waste planning efforts from any future Agency
waste capacity reassessments.
AGENCY COMMENTS AND OIG EVALUATION
In their February 11, 1997 response to our draft report, OSWER officials stated they agree with the
recommendations contained in the report. They further state they have planned appropriate actions to implement
changes in the biennial reporting process and the BRS according to the recommendations in our report. They
said the recommendations that we developed were both meaningful and practical ones that will improve the
biennial reporting process and the BRS (see Appendix I for the full response).
We believe the Agency's response to our draft report and their willingness to plan and initiate corrective actions
based on the findings and recommendations will bring significant improvement and changes to the current
situation. We further believe that the biennial reporting process and the BRS will be strengthened, and thus, the
corrective actions will result in a better and more usable Biennial Report.
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