FINAL
06­
19­
00
2001
HAZARDOUS
WASTE
REPORT
(
Biennial
Report),
PART
A
PERMIT
APPLICATION,
and
NOTIFICATION
of
REGULATED
WASTE
ACTIVITY
INFORMATION
COLLECTION
REQUEST
BACKGROUND
DOCUMENT
June
21,
2000
2
Acknowledgments
This
document
was
prepared
by
the
WIN/
INFORMED
Program
System
Design
ICR
Reliant
System
Change
team.
We
would
like
to
thank
the
following
WIN/
INFORMED
individuals
for
their
help
with
developing
this
document:

Elizabeth
Bols
Debbie
Goodwin
Bud
McCarty
(
Michigan
DEQ)
(
North
Caroline
DEQ)

Robert
Burchard
Jack
Griffith
Les
Otte
(
Florida
DEP)

Paula
Canter
Michael
Hillard
Jane
Ratcliffe
(
Ohio
EPA)
(
EPA
Region
5)

Walter
DeRieux
Dave
Levy
3
BACKGROUND
Introduction
The
WIN/
INFORMED
initiative
was
established
jointly
by
the
States
and
the
Environmental
Protection
Agency
(
EPA).
WIN
stands
for
Waste
Information
Needs
and
derives
from
planning
work
undertaken
by
the
EPA.
INFORMED
stands
for
Information
Needs
for
Making
Environmental
Decisions
and
derives
from
the
State
planning
work.

The
objective
of
this
initiative
is
to
reassess
the
information
needs
of
the
Hazardous
Waste
Management
Program
operating
under
Subtitle
C
of
the
Resource
Conservation
and
Recovery
Act
(
RCRA).
With
WIN/
INFORMED,
the
EPA
and
the
States
aim
to
jointly
identify,
and
share
where
appropriate,
the
information
needed
to
effectively
manage
the
RCRA
Program.

The
goals
of
WIN/
INFORMED
are
to:
1.
Streamline
how
we
collect,
use,
and
manage
hazardous
waste
information,
at
the
national
level;
2.
make
that
information
readily
available
to
the
States,
EPA,
Tribes,
and
the
public;
and
3.
support
the
effective
implementation
of
the
Hazardous
Waste
Program.

To
achieve
these
goals,
the
WIN/
INFORMED
initiative
employs
a
structured
approach
called
the
Information
Engineering
Methodology
(
IEM)
to
plan,
analyze,
design,
and
implement
information
management
systems
to
support
the
RCRA
Program.
Each
phase
will
consist
of
a
number
of
inter­
dependent
projects;
structured
to
allow
constant
progress
towards
the
objectives
without
the
risks
associated
with
a
very
large­
scale
redevelopment
effort.
This
full
life­
cycle
methodology
facilitates
developing
complex,
enterprise­
wide
information
systems,
particularly
those
that
require
a
high
degree
of
data
sharing.

Implementing
the
RCRA
Program
is
complex,
requiring
multiple
organizations
to
share
large
amounts
of
information.
By
applying
IEM
principles
to
break
down
the
program's
complexity
into
a
number
of
discrete
"
program
areas,"
the
WIN/
INFORMED
initiative
can
focus
attention
and
resources
effectively.

Project
Background
The
States
and
the
EPA
conducted
separate
planning
projects
to
broadly
document
their
own
information
needs.
Completed
in
late
1996,
these
efforts
resulted
in
two
Information
Strategy
Plans
(
ISPs),
both
of
which
identified
priority
improvements
needed
for
the
information
collection
and
management
systems
used
to
support
program
implementation.

An
ISP
identifies
logical
groupings
of
program
functions
and
information
needs,
referred
to
as
"
program
areas."
The
strategic
planning
for
the
WIN/
INFORMED
initiative
divided
the
RCRA
Program
into
five
program
areas.
They
are:

­
Universe
Identification
(
UID)

­
Waste
Activity
Monitoring
(
WAM)

­
Handler
Monitoring
and
Assistance
(
HMA)

­
Permitting
and
Corrective
Action
(
PCA)
4
­
Program
Evaluation
(
PE)

A
summary
of
the
EPA
WIN
ISP
and
State
Informed
ISP
is
available
at
the
following
web
site:
http://
www.
epa.
gov/
epaoswer/
hazwaste/
data/
win/
index.
htm
The
States
and
the
EPA
agreed
to
form
a
partnership
to
conduct
the
above
mentioned
phases
of
the
WIN/
INFORMED
Initiative
for
the
five
program
areas.
Each
program
area
will
be
beginning
with
the
analysis
of
that
program
area.

UID
WAM
Program
Area
Analysis
Project
The
purpose
of
the
Program
Area
Analysis
(
PAA)
is
to
understand
the
program's
needs
for
information,
consider
how
well
those
needs
are
supported
by
existing
systems,
and
identify
improvements.

The
Universe
Identification
(
UID)
PAA
began
in
October
1998,
and
the
project's
preliminary
findings
and
recommendations
were
presented
for
review
by
selected
program
experts
during
March
1999.
In
January
1999,
the
WIN/
INFORMED
Executive
Steering
Committee
asked
the
UID
PAA
Team
to
begin
analyzing
the
Waste
Activity
Monitoring
(
WAM)
Program
area
in
tandum
with
the
UID
Program
area.
This
strategy
effectively
realized
significant
time
and
cost
savings
by
combining
the
national
review
and
later
systems
implementation
planning
stages
of
these
closely
related
projects.
Analysis
of
the
WAM
Program
area
began
in
February
1999,
with
the
project's
preliminary
findings
and
recommendations
presented
for
review
by
selected
program
experts
during
June
1999.
After
completing
this
review,
the
UID
and
WAM
analysis
projects
were
combined.

During
September
and
October
of
1999,
the
preliminary
findings
and
recommendations
from
both
projects
were
refined
and
presented
in
the
form
of
a
Draft
Report
for
national
review
by
all
of
the
States,
Territories,
the
EPA
Regional
Offices,
and
the
EPA
Offices
of
Solid
Waste
and
Enforcement
and
Compliance
Assistance.
Subsequently,
the
project
findings
were
updated
to
reflect
input
from
reviewers.
A
plan
was
also
developed
to
guide
the
design
and
implementation
of
the
recommendations
from
the
project.

The
WIN/
INFORMED
Executive
Steering
Committee
approved
the
recommendations
and
initial
stages
of
the
implementation
plan
in
December
1999.

The
Final
Report
presents
the
PAA
project's
confirmed
recommendations
for
future
RCRA
Program
information
management,
together
with
an
implementation
plan.
This
report
is
available
at
the
EPA's
or
Association
of
State
and
Territorial
Solid
Waste
Management
Officials
(
ASTSWMO's)
web
site;
the
addresses
are:

http://
www.
epa.
gov/
epaoswer/
hazwaste/
data/
win/
r00­
004.
pdf
;
and
www.
astswmo.
org.

The
report
presents
the
PAA
Team's
findings,
in
three
main
project
deliverables:

o
Information
Needs
The
information
that
must
be
made
available
to
successfully
implement
the
RCRA
Program.

o
Recommended
Improvements
The
changes
to
current
information
collection
and
management
procedures
that
are
necessary
to
meet
the
required
information
needs.

o
Implementation
Plan
An
outline
for
how
these
recommendations
should
be
organized
and
further
designed
and
implemented.
This
plan
aggregates
related
recommendations
together
to
define
the
scope
of
a
number
of
discrete
design
projects.
5
The
following
list
summarizes
the
four
different
design
and
implementation
projects
to
be
undertaken
relative
to
the
UID/
WAM
Program
Area
Analysis
recommendations
for
improvements
to
the
current
RCRA
Program
information
collection
and
management
procedures.

Project
1:
Information
Collection
Request
(
ICR)
Reliant
System
Changes
This
project
will
design
the
policies/
procedures,
reporting
mechanisms,
and
information
system
changes
required
by
those
PAA
recommendations
that
require
ICR
changes,
with
the
exception
of
two
major
recommendations
to
be
considered
as
part
of
Project
2
described
below.
Once
design
tasks
are
complete,
the
ICR
changes
will
be
published
and
automated
system
changes
will
be
implemented.
These
are
the
recommendations
that
this
background
paper
discusses.

Project
2:
Site
Verification
and
Treatment,
Storage,
Disposal
Facility
(
TSDF)
Electronic
Reporting
This
project
will
study
the
feasibility
of
two
major
changes
to
current
RCRA
information
management
practices.
The
first
study
will
consider
the
alternative
mechanisms
by
which
identification
data
can
be
verified
by
RCRA
sites.
The
project
will
estimate
the
cost
and
burden
imposed
upon
the
regulated
community
and
RCRA
implementers.
The
second
study
will
consider
the
feasibility
of
the
electronic
reporting
of
waste
receipt
data
from
the
nation's
TSDFs.
This
would
include
the
evaluation
and
design
of
the
reporting
mechanism,
a
national
repository
and
State/
EPA
data
interchange
mechanisms,
and
the
pre­
population
of
generators'
biennial
hazardous
waste
reports.

Following
the
feasibility
studies,
a
national
review
will
be
conducted
to
confirm
the
recommended
direction.
The
solution
will
then
be
forwarded
to
the
WIN/
INFORMED
Executive
Steering
Committee
for
direction
on
design,
approval,
and
implementation,
including
all
associated
business
process
and
automated
system
changes.

Project
3:
Data
Integration
into
RCRAInfo
This
project
will
determine
how
the
data
and
functionality
included
in
RCRAInfo
for
RCRA
site
identification
and
waste­
monitoring
information
should
be
integrated
and
modified
to
provide
a
single
source.
Once
the
integration
has
been
designed,
the
necessary
automated
system
changes
will
be
implemented.

Project
4:
Implement
New
Guidance
This
project
will
design
the
policy/
procedural
changes
for
the
recommendations
that
do
not
directly
affect
the
current
reporting
mechanisms.
Once
the
guidance
has
been
designed,
new
guidance
documents
and
training
materials
will
be
developed
and
distributed
to
RCRA
regulators
to
facilitate
the
implementation
of
the
relevant
recommendations.
6
CHANGES
TO
DATA
COLLECTION
FORMS
Universe
Identification
(
UID)
and
Waste
Activity
Monitoring
(
WAM)
Program
System
Design
Projects
The
Program
System
Design
(
PSD)
describes
how
the
existing
systems
should
change
to
effect
improvement
recommendations
identified
by
the
program
area
analysis.
It
also
provides
an
understanding
of
the
costs
and
effort
involved
in
implementing
program
changes.
One
of
the
key
design
tasks
is
to
make
the
changes
to
data
collection
forms
proposed
by
the
recommendations.

The
States
and
the
EPA
are
currently
working
together
on
design
projects
that
include
Project
1:
Information
Collection
Request
(
ICR)
Reliant
System
Changes.
This
project
is
designing
the
policies/
procedures,
reporting
mechanisms,
and
information
system
changes
for
the
UID/
WAM
recommendations
that
require
ICR
changes.
The
following
discussion
describes
the
ICR
Reliant
System
Changes
project,
and
specifically
provides
a
discussion
of
the
proposed
changes
to
forms
and
instructions
for
the
following:

o
Hazardous
Waste
Report
(
Biennial
Report)
(
EPA
Form
8700­
13
A/
B)
Identification
and
Certification
 
Form
IC
Waste
Generation
and
Management
 
Form
GM
Waste
Received
from
Off­
Site
 
Form
WR
Off­
Site
Identification
­
Form
OI;
o
Notification
of
Regulated
Waste
Activity
(
EPA
Form
8700­
12);
and
o
RCRA
Part
A
Permit
Application
(
EPA
Form
8700­
23).

Biennial
Report,
Site
Identification,
and
Part
A
Data
Collection
Form
Changes
This
discussion
describes
the
design
changes
to
the
above
mentioned
forms
and
instructions.
Each
form
needs
revising
to
include
the
changes
proposed
by
the
recommendations.
We
are
appropiately
combining
and
restructuring
forms.
We
will
incorporate
recommendations
requiring
addition
of
fields,
or
removing
nonessential
fields
from
appropriate
sections.
Each
forms
instructions
will
be
updated
to
reflect
changes
to
reporting
schedules
or
the
regulated
universe
and
to
reflect
any
revised
definitions
for
data
elements
collected
on
the
forms.
This
discussion
describes
the
changes
to
the
content
of
the
forms
and
instructions.
We
will
be
developing
the
formating
of
the
forms
later
this
year.
Changes
to
existing
business
procedures
for
improvements
and
training
plans
will
be
developed
later
this
summer.

We
first
present
a
summary
list
of
the
recommendations,
followed
by
a
description
of
the
form
changes
proposed
for
each
recommendation
to
existing
form
fields
(
i.
e.,
the
spaces
where
reporters
enter
data)
and
associated
instructions.
Form
changes
are
being
considered
for
the
Hazardous
Waste
Report,
Notification
of
Regulated
Waste
Activity,
and
the
RCRA
Part
A
Permit
Application.

The
following
list
summarizes
each
of
the
UID/
WAM
PAA
Recommendations
covered
by
this
ICR
Renewal
Notice.
The
numbering
of
the
recommendations
matches
that
used
in
the
PAA
Final
report.
Complete
descriptions
and
program
area
analysis
can
be
found
in
the
UID/
WAM
PAA
Final
Report,
available
at
the
following
web
sites:
http://
www.
epa.
gov/
epaoswer/
hazwaste/
data/
win/
r00­
004.
pdf
;
and
www.
astswmo.
org.
7
Summary
List
of
Recommendations
Being
Proposed
6)
Collect
both
state
and
federal
generator
status
from
states
In
addition
to
reporting
the
federal
generator
status
for
a
RCRA
site
to
the
EPA,
each
state
with
regulations
that
are
"
more
stringent
than"
or
"
broader
in
scope"
than
the
federal
requirements
will
also
provide
the
state
generator
status
if
different
from
the
federal
status.
This
information
will
be
made
available
nationally
for
all
generators.

7)
Merge
common
elements
of
current
site
identification
forms
Reconcile
the
similar
but
different
instructions
and
data
fields
on
the
Notification
of
Regulated
Waste
Activity,
Hazardous
Waste
Report
­
Form
IC,
and
the
RCRA
Part
A
Permit
Application.
Develop
and
implement
a
single
information
collection
form
to
record
basic
site
information.

8)
Add
additional
data
elements
to
Notification
Form
Include
additional
data
fields
on
the
Notification
of
Regulated
Waste
Activity
Form
to
capture
new
nationally
required
information
needs.

9)
Provide
for
standard
notification
by
large
quantity
handlers
of
universal
wastes
Revise,
in
a
consistent
manner,
the
Notification
of
Regulated
Waste
Activity
Form
to
collect
information
about
the
activities
of
large
quantity
handlers
of
universal
waste.

13)
Tracking
hazardous
waste
exports
Make
waste
export
data
collected
and
tracked
by
the
EPA
Office
of
Enforcement
and
Compliance
Assurance
available
to
RCRA
Program
users
in
national
RCRA
Program
information
systems.
Biennial
Report
instructions
will
be
modified
to
clearly
indicate
that
waste
exports
should
not
be
reported.

14)
Tracking
imports
of
hazardous
wastes
An
importer
of
hazardous
waste
will
complete
the
Form
GM
and
use
the
appropriate
code
to
identify
that
the
waste
was
imported
from
a
foreign
country.

15)
Clarify
types
of
hazardous
wastes
to
be
reported
The
Biennial
Report
requirements
will
be
changed
so
that
generators
only
report
hazardous
wastes
used
in
determination
of
their
generator
status.
This
includes
wastes
that
are
generated,
accumulated
and
subsequently
managed
on­
site,
or
shipped
off­
site.

16)
Streamline
Source,
Origin,
Form,
and
Management
Codes
The
following
three
recommendations
will
be
implemented
to
streamline
and
improve
the
usefulness
of
reported
waste
information:
1)
Current
Source
codes
will
be
consolidated,
regrouped,
and
merged
with
the
current
Origin
codes
to
provide
a
simpler
coding
structure.
2)
Form
codes
will
be
revised
resulting
in
a
reduction
of
codes.
3)
Management
Method
codes
will
be
revised
to
eliminate
overlap
with
Form
codes.

17)
Remove
data
elements
from
Biennial
Reporting
Forms
Several
data
fields
currently
collected
on
the
Biennial
Reporting
Forms
are
to
be
removed.

21)
Determine
location
coordinates
for
a
RCRA
Site
Provide
address­
matching
capability
in
national
information
systems
to
determine
accurate
geographic
location
information
from
the
location
address.

25)
Make
Source
of
waste
a
mandatory
data
element
Require
the
collection
of
Source
code
for
reported
wastes.
8
Recommendations
­
Form
Changes
Each
issue
paper
for
the
recommendations
provides
the
following:

Background
describes
the
underlying
RCRA
Program
need.

Recommendation
describes
the
PAA
Team's
recommendation.

Recommended
Form
describes
the
changes
or
additions/
deletions
to
existing
forms
and
Amendment
instructions.

The
issue
papers/
recommendations
that
follow
are
organized
into
two
groups.
The
first
group
includes
those
recommendations
that
affect
the
site
identification
information
currently
collected
on
the
Hazardous
Waste
Report
(
Biennial
Report)
Identification
and
Certification
Form
(
Form
IC),
the
Notification
of
Regulated
Waste
Activity
Form,
and
the
RCRA
Part
A
Permit
Application
Form.
The
second
group
aggregates
those
recommendations
primarily
affecting
the
waste
activity
information
included
in
the
Biennial
Report
forms
for
Waste
Generation
and
Management
(
Form
GM)
and
Waste
Received
from
Off­
Site
(
Form
WR).
The
recommendations
complement
one
another.

We
also
want
to
identify
that
an
important
result
of
the
PAA
work
is
the
internal
dependencies
of
these
recommendations
upon
each
other.
The
recommendations
as
presented
here
are
in
agreement
with
the
states
and
the
EPA
dependency
findings
from
the
Program
Area
Analysis
work.
Site
Identification
9
6
)
COLLECT
BOTH
STATE
AND
FEDERAL
GENERATOR
STATUS
Background
The
basic
federal
RCRA
regulatory
framework
provides
for
three
distinct
classes
of
hazardous
waste
generators:
1.
large
quantity
generator
of
hazardous
waste
(
LQGs),
who
are
subject
to
the
most
comprehensive
regulations;
2.
small
quantity
generators
of
hazardous
waste
(
SQGs),
who
comply
with
a
less
stringent
set
of
requirements;
and
3.
conditionally
exempt
small
quantity
generators
of
hazardous
waste
(
CESQGs),
who
are
not
subject
to
reporting
requirements
provided
they
comply
with
a
set
of
simple
requirements.
Generators
fall
into
these
regulated
classes
based
on
the
volume
and
toxicity
of
hazardous
waste
they
generate,
accumulate
and/
or
store
in
any
one­
month
of
the
calendar
year.
Both
LQGs
and
SQGs
are
required
to
notify
EPA
of
their
activities,
declare
their
generator
category,
and
obtain
Environmental
Protection
Agency
(
EPA)
identification
numbers
by
submitting
the
Notification
of
Regulated
Waste
Activity
(
EPA
Form
8700­
12).
The
EPA
ID
numbers
are
used
in
manifesting
and
other
waste
reporting
(
for
example
the
Hazardous
Waste
Report,
also
called
the
Biennial
Report;
EPA
Form
8700­
13
A/
B).

While
the
Resource
Conservation
and
Recovery
Act,
Subtitle
C
(
RCRA)
requires
as
a
condition
of
authorization
that
state
hazardous
waste
laws
be
at
least
as
stringent
as
federal
rules,
it
allows
states
to
operate
regulatory
programs
that
are
broader
in
scope
(
BIS)
or
more
stringent
than
(
MST)
the
federal
program.
For
example,
a
state:
­
May
impose
the
regulatory
obligations
of
an
LQG
on
facilities
generating
less
than
1,000
kilograms
of
hazardous
waste
in
a
calendar
month
(
which
is
more
stringent
than
the
federal
scheme).
­
May
regulate
wastes
not
included
in
the
federal
list
of
hazardous
wastes
(
broader
in
scope).
­
May
require
CESQGs
to
notify
and
obtain
an
EPA
identification
number
(
also
broader
in
scope).

This
flexibility
reflects
both
the
essence
of
the
state­
federal
system
of
government
and
the
varying
situations,
concerns,
and
needs
of
different
states.

States
need
to
know
the
status
of
a
generator
as
defined
by
their
own
regulations,
which
may
or
may
not
be
the
same
as
the
federal
regulations.
Where
state
definitions
are
different
from
federal
definitions,
the
states
have
less
need
for
the
federal
status.

The
EPA
uses
the
federally
defined
generator
status
to
support
many
of
the
agency's
program
evaluation
functions,
including
various
regulatory
oversight
activities,
regulatory
impact
assessment,
fund
allocation,
and
congressional
reporting.
The
federal
LQG
and
SQG
universe
sizes
are
also
used
to
identify
compliance
rates,
high­
risk
generator
sectors,
and
facilities
that
need
to
be
inspected.
Since
states
have
varying
definitions
of
large
and
small
quantity
generators,
the
federal
definition
must
be
used
to
ensure
consistency
and
to
report
meaningful
universe
numbers
when
performing
interstate
comparison
analysis.

Recommendation
States
will
report
their
generator
universe
as
identified
by
their
own
regulatory
definitions,
and
will
also
report
the
generator
universe
as
identified
by
the
federal
regulatory
definition
to
the
best
of
their
ability
to
translate
the
generator
status.
This
reporting
will
occur
for
all
generators
that
are
required
to
report
nationally.

The
federally
defined
generator
status
should
be
determined
by
the
state,
using
information
extrapolated
from
waste
generation
information
provided
on
the
Biennial
Reporting
Forms,
or
equivalents,
when
it
becomes
available,
or
with
information
collected
directly
from
the
regulated
community.

For
those
states
having
MST
or
BIS
regulations
that
affect
the
generator
status,
the
following
steps
are
proposed:

1)
When
a
generator
notifies,
the
state
will
assume
that
the
reported
generator
status
reflects
solely
the
state
Site
Identification
10
regulations
unless
the
state
collects
sufficient
information
to
determine
both
federal
and
state
status
using
a
state­
specific
Notification
Form.

2)
Periodic
waste
reports
(
manifests,
Biennial
Reporting
Forms,
or
similar)
will
be
used
to
confirm
state
and
federal
status
values.
LQG
status
values
may
be
determined
directly
from
waste
generation
information
while
SQG
and
CESQG
status
values
can
be
determined
either
directly,
if
they
submit
waste
reports,
or
by
examination
of
waste
receipt
information
submitted
by
TSDFs.

Precise
determination
of
the
federal
status
may
not
always
be
possible.
The
best
approximation
is
acceptable
in
these
cases.

This
recommendation
will
provide
the
following
benefits:

­
Having
the
state
defined
status
values
in
the
national
database
will
provide
a
more
complete
picture
of
the
total
number
of
handlers
regulated
under
RCRA
regulations
across
the
country.

­
Data
will
be
more
directly
comparable
across
the
nation,
resolving
many
of
the
problems
of
having
different
universe
numbers
between
the
EPA
and
the
states.

­
A
single
approach
will
be
used
to
determine
the
national
universe
of
federally
regulated
generators
instead
of
the
varying
state­
by­
state
practices.

­
EPA
inspectors
would
be
able
to
more
accurately
determine
which
regulations
apply
at
a
given
generator.

­
EPA
could
determine
impact
of
federal
rules,
both
as
written
and
as
applied
(
includes
federal
requirement
and
states
more
stringent
than
requirement)
.

Recommended
Form
Amendments
Form
Revisions
The
Biennial
Report
and
Notification
forms
will
not
being
changed.

Instruction
Revisions
Notification
of
Regulated
Waste
Activity
Booklet
(
December
1999)
Page
7,
Section
I,
How
to
Determine
if
you
Handle
a
Regulated
Hazardous
Waste
Add
a
new
paragraph
at
the
end
of
this
section
stating:
Many
states
have
requirements
that
vary
from
the
federal
regulations.
These
state
regulations
may
be
more
strict
than
the
federal
requirements
by
identifying
additional
wastes
as
hazardous,
or
may
not
yet
include
all
wastes
currently
regulated
under
RCRA.
It
is
your
responsibility
to
comply
with
all
regulations
that
apply
to
you.
For
more
information
on
state
requirements,
you
are
strongly
urged
to
contact
the
appropriate
addressee
listed
for
your
state
in
Table
1
of
these
instructions.
An
insert
may
be
included
with
this
booklet
that
identifies
your
state
as
having
more
stringent
requirements,
along
with
a
contact
to
answer
your
questions.

In
addition,
available
state
web
site
addresses
that
provide
additional
information
will
be
added
to
Table
1.

Page
11,
Section
IV,
C,
Where
Should
I
Send
My
Completed
Form?
The
current
instructions
to
"
C"
will
be
modified
to
add
"
state
web
site
information
where
available..
.
."

Page
15­
22,
Table
1,
Alphabetized
State
Listing
of
Contacts
for
.
.
.
The
web
site
address,
where
available,
will
be
added
to
each
state's
information.
Site
Identification
11
Notice/
instructions
to
state
authorized
agencies
Notice
and
instructions
will
be
provided
to
state
authorized
agencies
informing
them
of
the
change
in
collection
of
generator
status
information
as
part
of
the
their
Biennial
Report
process.
The
instructions
will
also
cover
reporting
generator
status
information
for
SQGs
and
CESQGs
through
their
normal
notification
process.
The
generator
status
instructions
will
not
require
changes
to
the
Biennial
Report
or
Notification
forms.

The
instructions
will
also
include
a
suggestion
that
states
with
MST/
BIS
provisions
include
an
addendum
to
the
Notification
booklet
that
provides
instructions
on
their
state's
MST/
BIS
provisions.
Site
Identification
12
7)
MERGE
COMMON
ELEMENTS
OF
CURRENT
SITE
IDENTIFICATION
Background
Implementation
of
the
Resource
Conservation
and
Recovery
Act,
Subtitle
C
(
RCRA)
program
requires
collecting
basic
information
about
sites
and
the
hazardous
waste
handling
activities
taking
place
their.
This
information
is
used
for
waste
activity
monitoring,
compliance
monitoring,
technical
assistance,
program
planning,
waste
minimization,
and
other
program
activities.
There
is
an
increasing
need
to
streamline
and
enhance
the
existing
information
collection
process
to
reduce
burden
and
improve
the
quality
of
data
collected.

Analysis
shows
that
site
identification
data
is
currently
collected
on
several
different
forms
using
differing
instructions
and
differing
definitions
for
key
information
needs.
This
can
lead
to
variations
in
the
information
submitted
for
a
site.
Basic
site
information
is
collected
from
all
regulated
RCRA
facilities
on
the
Notification
of
Regulated
Waste
Activity
Form
(
8700­
12).
Large
quantity
generators
of
hazardous
waste
(
LQGs)
and
treatment,
storage,
and
disposal
facilities
(
TSDFs)
report
site
information
on
the
Hazardous
Waste
Report
(
Biennial
Report;
8700­
13A/
B)
Identification
and
Certification
Form
(
Form
IC).
Facilities
that
treat,
store
or
dispose
of
hazardous
waste
need
to
submit
site
information
on
the
RCRA
Part
A
Permit
Application
Form
(
8700­
23)
to
obtain
a
permit
from
the
relevant
implementer
organization.
Although
the
Part
A
Permit
Application
Form
also
collects
process
specific
information,
most
of
the
data
elements
collected
on
the
three
different
forms
that
provide
basic
site
information
are
essentially
duplicative.

We
also
want
to
make
the
readers
aware
that
the
UID/
WAM
Program
Area
Analysis
Final
Report
includes
a
recommendation
for
removing
hazardous
waste
codes
from
the
Notification
form
(
Recommendation
10),
once
the
associated
recommendation
to
gather
waste
activity
information
by
means
of
frequent
electronic
reporting
by
TSDF's
is
implemented.
These
TSDF
reports
would
provide
waste
activity
information
about
the
wastes
they
receive
from
sites.
We
are
currently
studying
the
feasibility
of
electronic
reporting
of
this
TSDF
data
on
a
national
basis.
This
includes
an
evaluation
of
the
reporting
mechanism,
a
national
repository,
and
data
interchange
mechanisms.

Recommendation
Create
a
new
RCRA,
Subtitle
C,
Site
Identification
Form
(
hereafter
Site
Identification
Form)
that
will
harmonize
the
site
profile
information
that
is
currently
collected
on
the:

Hazardous
Waste
Report
(
Biennial
Report;
EPA
Form
8700­
13
A/
B)
Identification
and
Certification
Form
­
IC
Form.
Notification
of
Regulated
Waste
Activity
(
EPA
Form
8700­
12).
RCRA
Part
A
Permit
Application
(
EPA
Form
8700­
23).

The
Site
Identification
Form
will
replace
the
site
identification
data
portions
(
see
the
table
below)
for
the
following:

­
In
the
Biennial
Report
replace
the
Identification
Certification
Form
(
Form
IC).
­
In
the
Notification
of
Regulated
Waste
Activity
booklet
replace
most
of
the
current
form
(
except
waste
code
information).
And
­
In
the
Hazardous
Waste
Permit
Application
Part
A
replace
the
site
identification
part
of
the
current
form;
all
the
process­
specific
information
will
entered
on
a
seperate
form
in
the
booklet.

The
Site
Identification
Form
would
be
submitted
as
a
component
of
each
information
collections
requirement
along
with
the
any
other
forms
as
appropriate.
Owners/
operators
would,
therefore,
continue
to
submit
the
Site
Identification
13
information
with
the
same
frequency
as
they
currently
do,
but
would
only
need
to
be
familiar
with
one
set
of
instructions
and
data
fields.
A
copy
of
the
completed
Site
Identification
form
as
submitted
for
Notification
would
be
sufficient
for
submission
as
a
component
of
a
Part
A
Application
or
a
Biennial
Report.
Reporters
will
only
need
to
correct
or
update
any
of
the
site
identification
information
that
may
have
changed;
they
would
not
need
to
complete
an
entirely
new
RCRA
Site
Identification
Form.

Recommended
Form
Amendments
Form
Revisions
The
following
is
a
listing
of
site
identification
information
that
will
be
included
on
the
form
and
the
current
data
field
name
on
the
three
aforementioned
forms.

The
shaded
data
fields
will
no
longer
be
collected
as
per
the
Universe
Identification
PAA
Final
Report
recommendations
(
see
Table
2
in
the
final
WIN/
Informed
UID
&
WAM
PAA
report).

Recommended
RCRA
Site
Identification
Form
Notification
of
Regulated
Waste
Activity
(
EPA
Form
8700­
12)
RCRA
Part
A
Permit
Application
(
EPA
Form
8700­
23)
Hazardous
Waste
Report
(
Biennial
Report)
Identification
and
Certification
­
Form
IC
(
EPA
Form
8700­
13
A/
B)
Name
name
of
site
name
of
installation
name
of
facility
site/
company
name
Number
site
EPA
id
number
installations
EPA
id
number
EPA
id
number
EPA
id
number
Location
address
line
1
location
of
site
 
street
name
and
number
location
of
installation
 
street
facility
location
 
street
location
address
 
street
name
and
number
location
address
line
2
location
of
site
 
street
name
and
number
location
of
installation
 
street
(
cont)
facility
location
 
street
(
cont)
location
address
 
street
name
and
number
location
address
city
name
location
of
site
 
city,
town,
village
location
of
installation
 
city
or
town
facility
location
 
city
or
town
location
address
 
city,
town,
village
location
address
state
name
location
of
site
 
state
location
of
installation
 
state
facility
location
 
state
location
address
 
state
location
address
zip
code
location
of
site
 
zip
code
location
of
installation
 
zip
code
facility
location
 
zip
code
location
address
 
zip
code
location
address
county
name
location
of
site
 
county
name
location
of
installation
 
county
name
facility
location
 
county
name
county
Site
Identification
14
mailing
address
line
1
site
mailing
address
 
street
or
PO
box
installation
mailing
address
 
street
or
PO
box
facility
mailing
address
 
street
or
PO
box
mailing
address
 
number
and
street
name
mailing
address
line
2
site
mailing
address
 
street
or
PO
box
facility
mailing
address
 
street
or
PO
box
mailing
address
 
number
and
street
name
mailing
address
city
name
site
mailing
address
 
city,
town,
village
installation
mailing
address
 
city
or
town
facility
mailing
address
 
city
or
town
mailing
address
 
city,
town,
village
mailing
address
state
name
site
mailing
address
 
state
installation
mailing
address
 
state
facility
mailing
address
 
state
mailing
address
 
state
mailing
address
zip
code
site
mailing
address
 
zip
code
installation
mailing
address
 
zip
code
facility
mailing
address
 
zip
code
mailing
address
 
zip
code
land
owner
type
land
owner
type
for
the
site
land
type
land
type
type
hazardous
waste
activity
­
greater
than
1000kg/
mo
or
equivalent
state
status
hazardous
waste
activity
­
greater
than
1000kg/
mo
RCRA
generator
status
 
LQG
hazardous
waste
activity
 
100
to
1000kg/
mo
or
equivalent
state
status
hazardous
waste
activity
 
100
to
1000kg/
mo
RCRA
generator
status
 
SQG
hazardous
waste
activity
 
less
than
100kg/
mo
or
equivalent
state
status
hazardous
waste
activity
 
less
than
100kg/
mo
RCRA
generator
status
 
CESQG
RCRA
generator
status
 
nongenerator
hazardous
waste
activity
 
treater,
storer,
disposer
or
equivalent
state
status
hazardous
waste
activity
 
treater,
storer,
disposer
storage
subject
to
RCRA
permitting
regulations
treatment,
disposal
or
recycling
subject
to
RCRA
permitting
regulations
Site
Identification
15
exempt
boiler
and/
or
industrial
furnace
 
a.
smelting,
melting,
and
refining
furnace
exemption
b.
small
quantity
on­
site
burner
exemption
hazardous
waste
fuel
marketer
underground
injection
Underground
injection
used
oil
transporter
used
oil
transporter
used
oil
transfer
facility
used
oil
transfer
facility
used
oil
processor
used
oil
processor
used
oil
re­
refiner
used
oil
re­
refiner
off­
specification
used
oil
burner
off­
specification
used
oil
burner
used
oil
fuel
marketer
used
oil
fuel
marketer
who
directs
shipment
of
off­
specification
used
oil
to
used
oil
burner
used
oil
fuel
marketer
who
first
claims
the
used
oil
meets
the
specifications
large
quantity
handler
of
universal
waste
large
quantity
handler
of
universal
waste
type
generate
accumulate
over
5000kg
batteries
pesticides
thermostat
s
lamps
Site
Identification
16
other
_________

_________

_________
universal
waste
destination
facility
Listed
hazardous
Waste
Listed
hazardous
Waste
Characteristics
of
Nonlisted
Hazardous
Wastes
Characteristics
of
Nonlisted
Hazardous
Wastes
Other
Wastes
Other
Wastes
importer
mixed
radioactive
waste
handler
hazardous
waste
transporter
hazardous
waste
activity
 
transporter­
for
own
waste
only
or
equivalent
state
status
hazardous
waste
activity
­
transporter
 
for
commercial
purposes
or
equivalent
state
status
mode
of
transportation
­
air,
rail,
highway,
water,
or
other
­
specify
NAICS
code
site
NAICS
code
NAICS
code
(
four)
[
currently
on
GM
Form
and
not
IC
Form
­
SIC
code]
1
2
3
4
site
contact
site
contact
 
first
name
installation
facility
contact
 
contact
 
first
Site
Identification
17
full
name
contact
 
first
name
first
name
name
site
contact
 
last
name
installation
contact
 
last
name
facility
contact
 
last
name
contact
 
last
name
site
contact
 
middle
initial
installation
contact
­
facility
contact
­
contact
 
middle
initial
site
contact
title
installation
contact
 
job
title
facility
contact
 
title
contact
 
title
site
contact
phone
number
site
contact
 
telephone
number
installation
contact
 
phone
number
facility
contact
 
phone
number
contact
 
telephone
number
site
contact
mailing
address
line
1
installation
contact
 
address
(
mailing)
 
street
or
PO
box
facility
contact
address
(
mailing)
 
street
or
PO
box
site
contact
mailing
address
line
2
installation
contact
­
address
(
mailing)
 
street
or
PO
box
facility
contact
address
(
mailing)
 
street
or
PO
box
site
contact
mailing
address
city
name
installation
contact
­
address
(
mailing)
 
city
or
town
facility
contact
address
(
mailing)
 
city
or
town
site
contact
mailing
address
state
name
installation
contact
­
address
(
mailing)
 
state
facility
contact
address
(
mailing)
 
state
site
contact
mailing
address
zip
code
installation
contact
­
address
(
mailing)
 
zip
code
facility
contact
address
(
mailing)
 
zip
code
owner
name
site
name
of
legal
owner
ownership
­
installation
legal
owner
facility
owner
 
name
of
facility's
legal
owner
owner
type
type
owner
type
ownership
 
owner
type
facility
owner
 
owner
type
operator
name
site
name
of
operator
operator
information
 
name
of
operator
operator
type
site
operator
type
operator
information
­
operator
type
signature
(
s)
262.12
no
longer
references
270.11
owner(
s)
and
operator(
s)
(
as
specified
in
270.11)
ask
for
person
completing
form
(
does
not
reference
270.11)
signatory's
name
last
name,
first
name
and
middle
initial
name
(
see
owner
&
operator
name)
last
name,
first
name
and
m.
i..
signatory's
official
title
Name
&
Official
title
Site
Identification
18
title
Title
date
signed
(
notification
date)
date
signed
date
signed
certificatio
n
statement
use
certification
statement
in
notification
of
regulated
waste
activity
see
below
see
below
see
below
We
are
proposing
to
use
the
current
certification
statement
for
Notification
of
Hazardous
Waste
Activity
Form
(
8700­
12)
described
below,
for
the
new
RCRA
Site
Identification
Form.
This
certification
will
also
become
the
certification
for
the
Hazardous
Waste
Report
(
Biennial
Report)
because
the
new
Site
Identification
Form
will
replace
the
current
IC
Form
­
Identification
and
Certification.

Certification
statement
for
Notification
of
Regulated
Waste
Activity
(
EPA
Form
8700­
12):
I
certify
under
penalty
of
law
that
this
document
and
all
attachments
were
prepared
under
my
direction
or
supervision
in
accordance
with
a
system
designed
to
assure
that
qualified
personnel
properly
gather
and
evaluate
the
information
submitted.
Based
on
my
inquiry
of
the
person
or
persons
who
manage
the
system,
or
those
persons
directly
responsible
for
gathering
the
information,
the
information
submitted
is,
to
the
best
of
my
knowledge
and
belief,
true,
accurate,
and
complete.
I
am
aware
that
there
are
significant
penalties
for
submitting
false
information,
including
the
possibility
of
fine
and
imprisonment
for
knowing
violations.

Certification
statement
for
Hazardous
Waste
Report
(
Biennial
Report)
Identification
and
Certification
is
provided
here
for
reference
­
IC
Form
(
EPA
Form
8700­
13
A/
B:
I
certify
under
penalty
of
law
that
this
document
and
all
attachments
were
prepared
under
my
direction
or
supervision
in
accordance
with
a
system
designed
to
assure
that
qualified
personnel
properly
gather
and
evaluate
the
information
submitted.
Based
on
my
inquiry
of
the
person
or
persons
who
manage
the
system,
or
those
persons
directly
responsible
for
gathering
the
information,
the
information
submitted
is,
to
the
best
of
my
knowledge
and
belief,
true,
accurate,
and
complete.
I
am
aware
that
there
are
significant
penalties
under
Section
3008
of
the
Resource
Conservation
and
Recovery
Act
for
submitting
false
information,
including
the
possibility
of
fine
and
imprisonment
for
knowing
violations.

Certification
statement
for
the
RCRA
Part
A
Permit
Application
is
provided
here
for
reference
(
EPA
Form
8700­
23):
I
certify
under
penalty
of
law
that
this
document
and
all
attachments
were
prepared
under
my
direction
or
supervision
in
accordance
with
a
system
designed
to
assure
that
qualified
personnel
properly
gather
and
evaluate
the
information
submitted.
Based
on
my
inquiry
of
the
person
or
persons
who
manage
the
system,
or
those
persons
directly
responsible
for
gathering
the
information,
the
information
submitted
is,
to
the
best
of
my
knowledge
and
belief,
true,
accurate,
and
complete.
I
am
aware
that
there
are
significant
penalties
for
submitting
false
information,
including
the
possibility
of
fine
and
imprisonment
for
knowing
violations.

The
Hazardous
Waste
Permit
Application
Part
A
Form
(
8700­
23)
will
continue
to
contain
the
following
process­
specific
information
listed
below.
The
new
Site
Identification
Form
will
be
used
in
conjunction
with
a
revised
Hazardous
Waste
Permit
Application
Part
A
Form.

Other
environmental
permits
(
page
2
of
7)
permit
type
permit
number
description
Site
Identification
19
Nature
of
business
(
brief
description)
(
page
3
of
7)
Process
codes
and
design
capabilities
(
page
4
of
7)
process
code
process
design
capacity
amount
process
design
capacity
unit
of
measure
process
total
number
of
units
Other
processes
(
page
4
of
7)
process
code
process
design
capacity
amount
process
design
capacity
unit
of
measure
process
total
number
of
units
Description
of
hazardous
wastes
(
pages
6
of
7
and
8
of
7)
EPA
hazardous
waste
number
estimated
annual
quantity
of
waste
unit
of
measure
process
codes
process
description
Site
Identification
20
8)
Add
Additional
Data
Elements
to
Notification
Form
Background
Note:
This
item
recommends
that
the
following
be
included
on
the
form
in
the
Notification
of
Regulated
Waste
Activity
(
EPA
Form
8700­
12)
to
capture
new,
nationally
required
information
needs.
Recommendation
#
7­
"
Merge
common
elements
of
current
site
identification
forms"
is
also
being
submitted
at
this
time.
The
discussion
below
references
additions
to
the
instructions
in
the
Notification
booklet;
the
submitter
would
enter
the
required
data
on
the
new
Resource
Conservation
and
Recovery
Act,
Subtitle
C,
(
RCRA)
Site
Identification
Form,
which
would
be
included
in
the
booklet.

Recommendation
These
data
elements
would
be
added
for
all
RCRA
sites:

1)
North
American
Industrial
Classification
System
(
NAICS)
codes
for
industrial
activity
information.
2)
Operator
information
in
addition
to
the
currently
collected
owner
information.
This
would
be
the
same
information
now
collected
for
Treatment,
Storage,
Disposal
Facility's
(
TSDFs)
on
the
RCRA
Part
A
Permit
application.
3)
Mixed
waste
(
hazardous
and
radioactive)
generated
under
hazardous
waste
activities.
4)
United
States
Importer
for
hazardous
waste
activities.

Each
data
element
is
presented
separately
below.

Recommended
Form
Amendments
Form
Revisions
Notification
of
Regulated
Waste
Activity
Booklet,
December
1999
1.
North
American
Industrial
Classification
System
(
NAICS)
Codes
Revise
the
Site
Identification
Form
by
adding
a
new
section
in
the
Notification
instructions
and
data
elements
on
the
form
to
collect
the
NAICS
code.

Note:
We
are
removing
the
Standard
Industrial
Classification
(
SIC)
Code
from
the
Hazardous
Waste
Report
­
Generation
and
Management
Form
(
Form
GM).

The
SIC
codes
were
replaced
with
NAICS
codes
in
the
December
1999
revision
to
the
RCRA
Part
A
Permit
Application
(
EPA
Form
8700­
23).
The
NAICS
will
be
removed
from
the
Part
A
Form
in
Section
IX;
the
timing
for
this
deletion
is
dependent
on
merging
the
site
identification
information
into
one
form.
This
section
would
be
added
after
Section
VIII.
Ownership
(
currently
numbered
VII;
see
#
2
below)
subsequent
sections
would
be
renumbered
This
change
will
allow
for
up
to
four
codes
to
be
entered,
and
these
classifications
may
differ
from
the
NAICS
codes
describing
the
operation
generating
the
hazardous
wastes.

The
Notification
instructions
section
would
read:

Item
IX­
NAICS
Codes:

List,
in
descending
order
of
hazardous
waste
activity
significance,
the
North
American
Industry
Classification
System
(
NAICS)
codes
that
best
describe
your
facility
in
terms
of
the
principal
products
or
services
you
produce
or
provide.
Enter
each
5
or
6­
digit
NAICS
code
starting
in
the
left
most
box.
If
you
Site
Identification
21
use
a
5­
digit
code,
leave
the
sixth
box
blank.
These
classifications
may
differ
from
the
NAICS
codes
describing
the
operation
generating
the
hazardous
wastes.

2.
Operator
information
Include
operator
information
on
the
Site
Notification
Form.
This
is
information
now
collected
for
TSDFs
on
the
RCRA
Part
A
Permit
Application.
This
section
would
be
added
in
the
Notification
instructions
before
the
current
Section
VII.
Ownership;
subsequent
sections
would
be
re­
numbered.

Item
VII
­
Operator
Information:

A.
Name:
Give
the
name,
as
it
is
legally
referred
to,
of
the
person,
firm,
public
organization,
or
any
other
entity
which
operates
the
facility
described
in
this
notification.
This
may
or
may
not
be
the
same
name
as
the
facility.
The
operator
of
the
facility
is
the
legal
entity
that
controls
the
facility's
operation
rather
than
the
plant
or
site
manager.
Do
not
use
a
colloquial
name.

B.
Operator
Type:
Using
the
codes
listed
below,
indicate
in
VII.
B.
the
code
which
best
describes
the
legal
status
of
the
current
operator
of
the
facility:

F
=
Federal
S
=
State
I
=
Indian
P
=
Private
C
=
County
M
=
Municipal*
D
=
District
O
=
Other
*
If
the
Operator
Type
is
best
described
as
Indian,
County,
or
District,
please
use
those
codes.
Otherwise,
use
Municipal.

C.
Change
of
Operator
Indicator:

Note:
If
this
is
your
facility's
first
submission
of
a
notification,
leave
VII.
C.
blank
and
skip
to
Item
VIII.
If
this
is
a
revised
notification
submission,
complete
Item
VII.
C.
as
directed
below.

If
the
operator
of
this
facility
has
changed
since
the
facility's
previous
notification
was
submitted,
place
an
"
X"
in
the
box
marked
"
Yes"
and
enter
the
date
the
operator
changed.

If
the
operator
of
this
facility
has
not
changed
since
the
facility's
previous
notification
was
submitted,
place
an
"
X"
in
the
box
marked
"
No"
and
skip
to
Item
VIII.

If
any
additional
operators
have
been
added
or
replaced
since
the
facility's
previous
notification
was
submitted,
place
an
"
X"
in
the
box
marked
"
Yes."
Use
the
comment
section
to
list
any
additional
operators,
the
dates
they
became
operators,
and
which
operator(
s)
(
if
any)
they
replaced.
If
necessary,
attach
a
separate
sheet
of
paper.

3.
Mixed
waste
generator
Remove
the
Mixed
Waste
Generator
box
from
the
Hazardous
Waste
Report
 
Generation
and
Management
(
GM)
Form
and
the
Waste
Received
from
Off­
Site
(
WR)
Form.
Site
Identification
22
Add
mixed
waste
generator
to
the
Site
Identification
Form.
A
Mixed
Waste
Generator
check
box
will
be
added
to
the
activities
in
the
current
Section
VIII.,
Type
of
Regulated
Waste
Activity,
A.
Hazardous
Waste
Activity.
(
Note:
the
addition
of
the
Mixed
Waste
check
box
on
the
Site
Identification
Form
will
be
implemented
upon
approval.
However,
the
mixed
waste
questions
will
not
be
removed
from
the
Hazardous
Waste
Report
GM
Form
and
WR
Form
until
the
2003­
reporting
year.)
The
new
section
in
the
instructions
will
reads:

Section
VIII
­­
Type
of
Regulated
Waste
Activity:

A.
Hazardous
Waste
Activity
Mark
an
"
X"
in
the
appropriate
box(
es)
to
show
which
hazardous
waste
activities
are
being
conducted
at
this
installation.

6.
Mixed
waste
(
hazardous
and
radioactive)
generator:
If
you
generate
a
hazardous
waste
that
is
mixed
with
source
special
nuclear
or
by­
product
material
regulated
under
the
Atomic
Energy
Act
of
1954,
mark
an
"
X"
in
the
box.

4.
United
States
Importer
Add
United
States
Importer
to
the
new
Site
Identification
Form
under
activities
in
the
current
Section
VIII.,
Type
of
Regulated
Waste
Activity,
A.
Hazardous
Waste
Activity.
The
new
section
in
the
instructions
will
reads:

Section
VIII
­­
Type
of
Regulated
Waste
Activity:

A.
Hazardous
Waste
Activity
Mark
an
"
X"
in
the
appropriate
box(
es)
to
show
which
hazardous
waste
activities
are
being
conducted
at
this
installation.

7.
United
States
Importer:
Any
person
who
imports
hazardous
waste
from
a
foreign
country
into
the
United
States,
mark
an
"
X"
in
the
box.

This
recommendation
will
only
affect
RCRA
sites
in
the
future
that
complete
or
update
the
Notification
of
Regulated
Waste
Activity.
Site
Identification
23
9)
Provide
for
Standard
Notification
for
Large
Quantity
Handlers
of
Universal
Wastes
Background
The
WIN/
Informed
Program
area
analysis
participants
expressed
a
clear
need
for
a
better
picture
of
universal
waste
handling
activities
to
meet
several
needs;
for
example:
­
Understanding
how
many
hazardous
waste
generators
have
become
solely
universal
waste
large
quantity
handlers
will
provide
a
starting
point
to
review
the
impacts
of
the
universal
waste
program.
­
Implementing
agencies
can,
with
this
information,
help
support
or
take
the
lead
on
establishing
collection
and
management
(
primarily
recycling)
systems.
­
Inspection
scheduling
and
knowing
in
advance
the
type
of
universal
waste
facilitates
efficient
inspections.

Note:
This
item
recommends
that
the
following
be
included
on
the
form
in
the
Notification
of
Regulated
Waste
Activity
(
EPA
Form
8700­
12)
to
capture
new,
nationally
required
information
needs.
Recommendation
#
7­
"
Merge
common
elements
of
current
site
identification
forms"
is
also
being
submitted
at
this
time.
The
discussion
below
references
additions
to
the
instructions
in
the
Notification
booklet;
the
submitter
would
enter
the
required
data
on
the
new
Resource
Conservation
and
Recovery
Act,
Subtitle
C,
(
RCRA)
Site
Identification
Form,
which
would
be
included
in
the
booklet.

Recommendation
Collect
information
about
the
activities
of
large
quantity
handlers
of
universal
waste
in
a
consistent
manner
on
the
Site
Identification
Form.

Recommended
Form
Amendments
Instructions
and
Form
Revisions
Include
additional
data
elements
on
the
Site
Identification
Form.
to
allow
notifiers
to
indicate
the
type
of
universal
waste
the
facility
is
handling
and
accumulating.
There
will
be
a
check
box
for
handling,
accumulation,
and
destination
for
the
following
categories
of
waste:
batteries
(
40
CFR
273.2),
pesticides
(
40
CFR
273.3),
thermostats
(
40
CFR
273.4),
lamps
(
40
CFR
273.5),
and
other.
Site
Identification
24
14)
Tracking
Imports
of
Hazardous
Wastes
Background
All
hazardous
wastes
transported
into
the
United
States
must
be
imported
through
an
importer,
who
assumes
legal
responsibility
for
the
waste.
There
is
a
requirement
to
submit
a
notification
to
the
Environmental
Protection
Agency
(
EPA)
of
intent
to
import
hazardous
waste
from
a
foreign
country
with
details
about
the
proposed
shipment
(
See
40
CFR
262.60).
United
States
Importers
who
handle
hazardous
wastes
currently
apply
for
and
receive
an
EPA
identification
number
containing
the
prefix
of
the
state
in
which
they
do
business.
Current
information
submitted
in
Notification
of
Regulated
Waste
Activity
(
EPA
Form
8700­
12)
and
the
Hazardous
Waste
Report
(
EPA
Form
8700­
13A/
B;
also
known
as
the
Biennial
Report)
does
not
include
a
means
to
capture
the
specific
activity
of
importing
waste;
therefore,
importers
are
typically
recorded
as
generators.
This
is
problematic
for
the
regulating
state
because
it
appears
that
the
waste
was
physically
generated
within
that
state's
boundaries.
As
a
result,
waste
generation
totals
are
artificially
high
for
the
state
in
question
since
imported
waste
is
counted
as
generated
waste.

The
need
to
differentiate
between
domestic
generation
and
foreign
generation
is
important
and
currently
hard
to
achieve.
The
treatment,
storage,
and
disposal
facilities
(
TSDFs)
report
the
actual
quantity
of
waste
that
they
receive
from
generators,
some
of
which
are
importers.
The
current
TSDF
reporting
mechanism,
however,
does
not
provide
the
means
to
accurately
determine
that
the
waste
was
generated
in
a
foreign
country.

Recommendation
The
Hazardous
Waste
Report
Instructions
and
Forms
booklet
(
EPA
Form
8700­
13A/
B;
also
known
as
the
Biennial
Report)
will
be
revised
to
require
any
United
States
importer
of
hazardous
waste
who
submits
a
Generation
and
Management
­
GM
Form
to
enter
a
code
on
the
form
that
identifies
the
source
of
the
hazardous
waste
as
"
imported
from
a
foreign
country."
We
will
delete
the
related
current
instructions
on
the
Generation
and
Management
 
GM
Form,
Waste
Received
from
Off­
Site
 
WR
Form,
and
Off­
Site
Identification
 
OI
Form.
This
recommendation
is
linked
to
Recommendation
#
8
for
the
addition
of
the
regulated
waste
activity
of
United
States
Importer.

The
imported
waste
can
be
distinguished
from
domestic
waste
by
the
source
code
listed
on
the
Form
GM
by
the
United
States
Importer.
Imported
wastes
reported
on
Form
WR
by
the
receiving
TSD
can
be
tracked
to
the
importer's
Form
GM
through
the
listed
Off­
site
handler
EPA
ID
number
on
Form
WR.

Recommended
Form
Amendments
Form
Revisions
The
Biennial
Report
forms
are
not
being
changed.

Instruction
Revisions
The
Biennial
Report
instructions
will
be
revised
to
require
an
importer
filing
the
GM
Form
to
enter
a
code
in
the
EPA
source
code
section
of
the
form.
There
are
several
changes
to
the
instructions
described
below.

1999
Hazardous
Waste
Report
Instructions
and
Forms
(
EPA
Form
8700­
13A/
B)
Page
i,
The
instructions
for
"
Who
Must
File
the
[
year]
Hazardous
Waste
Report"
will
be
revised
to
include
United
States
Importers:
The
instructions
are
being
revised
to
say.

WHO
MUST
FILE
THE
[
year]
HAZARDOUS
WASTE
REPORT
Sites
Required
to
File
the
Hazardous
Waste
Report
Site
Identification
25
You
are
required
by
Federal
statute
to
complete
and
file
the
[
year]
Hazardous
Waste
Report
if
your
site:

­
Met
the
definition
(
see
box
below)
of
a
Resource
Conservation
and
Recovery
Act
(
RCRA)
Large
Quantity
Generator
(
LQG)
of
hazardous
waste
during
[
year];
AND/
OR
­
Treated,
stored,
or
disposed
of
RCRA
hazardous
wastes
on­
site
during
[
year
;
AND/
OR
NEW
­
Imported
hazardous
wastes
from
a
foreign
country
and
manifested
or
treated,
stored,
or
disposed
the
hazardous
wastes
in
the
United
States
during
[
year].

Page
2,
WHICH
FORMS
TO
SUBMIT
AND
WHAT
TO
REPORT
The
instructions
will
be
revised
to
say:
Form
GM
A
separate
Form
GM
must
be
submitted
for
each
RCRA
hazardous
waste
that
was:

­
Generated
on­
site
and
subsequently
managed
on­
site
or
shipped
off­
site
in
[
year];
­
Generated
on­
site
in
[
year]
but
not
managed
on­
site
or
shipped
off­
site
until
after
[
year];
or
­
Generated
on­
site
prior
to
[
year]
but
either
managed
on­
site
or
shipped
off­
site
in
[
year];
or
NEW
­
Imported
from
a
foreign
country
and
either
managed
on­
site
or
shipped
off­
site
in
[
year].

RCRA
hazardous
wastes
to
be
reported
include
those
that
were:

­
Generated
on­
site
from
a
production
process,
service
activity,
or
routine
cleanup;
­
Resulted
from
equipment
decommissioning,
spill
cleanup,
or
remedial
cleanup
activity;
­
Shipped
off­
site,
including
hazardous
waste
that
was
received
from
off­
site
(
reported
on
Form
WR)
and
subsequently
shipped
off­
site
without
being
treated
or
recycled
on­
site;
­
Derived
from
the
management
of
non­
hazardous
waste;
or
­
Derived
from
the
on­
site
treatment,
disposal,
or
recycling
of
previously
existing
hazardous
waste
(
i.
e.,
a
residual);
NEW
­
Imported
from
a
foreign
country
and
manifested
or
treated,
stored,
or
disposed
in
the
United
States.

Page
12,
WASTES
TO
BE
REPORTED
The
Form
GM
instructions
will
be
revised
to
say:
"
Wastes
To
Be
Reported"
section
,
add
the
new
line
below.
NEW
­
Imported
from
a
foreign
country
and
manifested
or
treated,
stored,
or
disposed
in
the
United
States.

Page
14,
Section
I:
Waste
Characteristics
­
Box
F:
Source
code.
NOTE:
The
reporter
will
select
the
code
from
the
revised
Source
Codes
list
(
see
Recommendation
#
16)
that
reads:

Code
#
G62
­
Hazardous
waste
received
from
a
foreign
country
(
not
a
foreign
Department
of
Defense
site,
Maquiladora,
U.
S.
Territory
or
Protectorate).
This
site
was
the
generator
of
record.

Page
19
and
20,
NOTE:
The
Form
GM
instructions
will
be
revised
as
follows:
Delete
"
and
from
foreign
countries"
from
the
Notes
on
pages
19
and
20
to
the
instructions
for
the
Form
WR.
Also
delete
the
Definitions
section
in
the
Special
Instructions
on
page
39
that
currently
reads:

Wastes
shipped
from
foreign
countries
­
Report
on
Form
WR
all
wastes
received
by
your
facility
from
a
foreign
site
that
were
managed
on­
site.
If
the
foreign
site
has
an
EPA
Identification
(
ID)
Number,
report
receipts
from
that
site
just
as
you
would
report
receipts
from
a
domestic
site.
If
the
site
does
not
have
an
Site
Identification
26
EPA
ID
Number,
report
the
code
"
FC"
for
foreign
country
followed
by
the
name
of
the
country
in
the
space
for
the
EPA
ID
Number.
Report
on
Form
OI
the
name
and
address
of
all
foreign
generators,
if
this
form
is
required
by
your
state.

Page
39,
DEFINITIONS
Add
a
new
definition
as
it
appears
in
the
new
Site
Identification
form
instructions
as
proposed
in
Recommendation
#
8:
United
States
Importer:
Any
person
who
imports
hazardous
waste
from
a
foreign
country
into
the
United
States.

Page
FORM
OI,
OFF­
SITE
IDENTIFICATION,
INSTRUCTIONS
FOR
FILLING
OUT
FORM
OI
 
OFF­
SITE
IDENTIFICATION,
ITEM­
BY­
ITEM
INSTRUCTIONS,
BOX
B:
Name
of
off­
site
installation
or
transporter
The
Form
OI
instructions
will
be
revised
as
follows:
Revise
the
wording
in
the
instructions
to
delete
"
or
received
from"
in
the
last
sentence.
The
TSD
will
no
longer
enter
the
name
of
the
foreign
country
in
the
EPA
ID
Number
field.
The
proper
EPA
ID
Number
should
be
available
on
the
manifest
as
required
by
§
262.60
(
b)(
1).
Site
Identification
27
21)
Determine
Location
Coordinates
for
a
RCRA
Site
Background
The
increasing
demand
for
place­
based
analysis
is
reflected
in
the
need
to
specifically
locate
all
Resource
Conservation
and
Recovery
Act,
Subtitle
C,
(
RCRA)
regulated
sites.
The
demand
from
implementers,
the
public,
and
other
interested
groups
for
location
based
information
is
growing.
In
the
past,
specific
geographic
coordinate
information
for
a
RCRA
site
has
only
been
collected
for
treatment,
storage,
and
disposal
facilities
(
TSDFs).
Improvements
in
address
matching
software
and
global
positioning
systems
(
GPS)
technologies
have
provided
increased
opportunities
for
better
locational
tracking
of
all
hazardous
waste
and
RCRA
sites.

Currently,
only
TSDFs
seeking
a
permit
are
required
to
report
coordinates
on
the
RCRA
Part
A
Permit
Application
(
EPA
Form
8700­
23).
The
RCRAInfo
data
system
contains
these
latitude
and
longitude
values,
but
no
information
about
the
determination
method
or
accuracy
of
these
values
as
required
by
EPA's
Latitude/
Longitude
Data
Standard
(
November
1999).

Based
on
the
experience
of
RCRA
and
other
Environmental
Protection
Agency
(
EPA)
programs,
requiring
facilities
to
report
coordinates
has
not
been
a
very
successful
way
to
collect
accurate
data.
This
requirement
presents
a
significant
burden,
also.
Owners
or
operators
often
have
difficulty
securing
precise
geographic
coordinates
(
in
degrees,
minutes,
and
seconds).
Therefore,
they
do
not
always
provide
accurate,
uniform,
and
complete
latitudes
and
longitudes
for
their
facilities.
Implementers
have
often
found
the
coordinate
information
to
be
inaccurate.
Some
states
have
invested
in
visiting
each
RCRA
site
and
using
GPS
units
to
collect
high
quality
coordinates.

Recommendation
The
EPA
will
no
longer
collect
geographic
information
(
latitude/
longitude)
on
the
Part
A
Permit
Form.
Instead,
the
State
or
EPA
will
determine
the
locational
coordinates
for
the
RCRA
Site
based
on
the
site's
specific
location
address.
If
it
is
not
available,
the
site
may
be
defined
by
a
description
or
by
geographic
coordinates.
Additionally,
the
exact
point
used
to
locate
the
RCRA
site
will
be
specified,
for
example,
the
map
point
of
the
address
or
the
site
centroid.
Locational
data
for
the
front
door
of
each
RCRA
site
will
provide
data
consistency
and
at
the
same
time
allow
implementers
flexibility
for
providing
the
data.

Locational
data
will
be
tracked
for
all
RCRA
sites.
RCRA
information
systems
will
include
automatic
address­
matching
functionality
to
facilitate
data
entry
by
EPA
and
states.
Implementers
would
be
free
to
use
other
methods,
e.
g.,
GPS
to
obtain
locational
data.
This
option
takes
advantage
of
the
current
geospatial
tools
to
obtain
the
coordinates
for
each
RCRA
site,
based
on
its
physical
address.
EPA
will
provide
implementers
the
option
of
providing
locational
data
at
the
unit
level.
Data
fields
will
be
added
in
keeping
with
EPA's
locational
data
standard
for
method,
accuracy,
description
(
MAD)
meta­
data.

Recommended
Form
Amendments
Form
Revisions
EPA
will
delete
the
latitude/
longitude
data
element
on
the
RCRA
Part
A
Permit
Application
Form
(
EPA
Form
8700­
23)
in
Section
III.
Facility
Location,
C.
Geographic
Location
and
references
to
this
information
in
the
instructions.
This
will
be
deleted
in
the
revision
of
the
form
after
RCRAInfo
has
been
modified
to
accept
all
the
data
elements
of
the
Latitude/
Longitude
Data
Standard
(
November
1999).
There
are
no
changes
to
the
current
Notification
of
Regulated
Waste
Activity
or
Hazardous
Waste
Report
Forms.
The
data,
however,
will
be
carried
for
the
site
identification
information
in
RCRAInfo.

EPA
will
also
need
to
delete
the
requirement
at
40
CFR
270.13(
b)
for
owners
or
operators
to
provide
the
latitude
and
longitude
for
facilities
on
the
Part
A
Permit
Application.
Site
Identification
28
Notice/
Instructions
to
Authorized
State
Notice
to
state
authorized
agencies
will
be
provided
that
describes
this
process.
The
Program
System
Design
Team
will
address
this
process
under
one
of
its
next
tasks
that
cover
design
of
business
procedure
improvements
and
training.
State
implementers
will
be
able
to
enter
this
information
for
all
RCRA
sites
if
the
data
is
in
conformance
with
the
Latitude/
Longitude
Data
Standard
(
November
1999).
The
EPA
will
provide
addressmatching
functionality
in
the
national
information
systems
for
sites
that
do
not
have
implementor
specified
coordinates.
RCRAInfo
will
carry
all
these
required
data
elements
in
the
site
identification
data.
Implementers
would
be
free
to
use
other
sources
or
methods
(
for
example,
GPS)
to
obtain
locational
data;
they
will
also
have
the
option
to
provide
locational
data
at
the
unit
level.
Waste
Activity
Information
29
13)
TRACKING
HAZARDOUS
WASTE
EXPORTS
Background
The
current
Hazardous
Waste
Export
Data
System
(
HWES)
contains
most
data
elements
present
on
the
national
uniform
manifests
including
the
names,
addresses,
and
the
Environmental
Protection
Agency
Identification
Number
(
EPA
ID
Number)
of
the
generator
(
exporter),
transporter(
s),
the
designated
facility
(
consignees)
in
the
foreign
land,
U.
S.
Department
of
Transportation
(
DOT)
shipping
information,
container
type,
number;
volume,
waste
number,
the
port
of
exit
from
the
United
States
and
date
of
export.
The
required
forms
­
either
Notification
of
Intent
to
Export
Hazardous
Waste
or
the
annual
report
of
hazardous
waste
exports
provides
this
information.

EPA
lacks
Resource
Conservation
and
Recovery
Act
(
RCRA)
jurisdiction
over
foreign
persons
outside
the
United
States.
While
EPA
ID
Numbers
are
a
requirement
of
40
CFR
262­
279
and
they
are
not
required
under
the
bilateral,
OECD,
Basel
Convention,
etc.,
agreements.
Therefore,
only
information
about
management
of
the
waste
in
the
United
States
is
available.

The
HWES
data
system,
is
the
current
record/
repository
for
export
information
that
is
required.
Along
with
other
information,
the
EPA
ID
Number
is
provided
for
the
hazardous
waste
receiving
facilities
in
the
United
States
that
will
export
the
waste
(
United
States
exporter).

Recommendation
Integrate
the
current
data
in
the
EPA's
HWES
into
a
national
Resource
Conservation
and
Recovery
Act,
Subtitle
C,
program
information
system
(
RCRAInfo),
so
that
states
and
other
users
can
easily
track
hazardous
waste
exports.

Recommended
Form
Amendments
Form
Revisions
No
changes
to
Hazardous
Waste
Report
Forms
(
EPA
Form
8700­
13A/
B;
Biennial
Report).

Instruction
Revisions
The
Biennial
Report
Instructions
are
being
revised
as
follows.

Page
2,
WHICH
FORMS
TO
SUBMIT
AND
WHAT
TO
REPORT
The
2001
Hazardous
Waste
Report.
.
.
.

Form
GM
A
separate
Form
GM
.
.
..

Radioactive
wastes
mixed
with
RCRA
hazardous
waste
should
also
be
reported,
as
well
as
hazardous
wastes
regulated
only
by
your
state
(
if
required
by
your
state)
The
current
instructions
will
be
modified
to
add
the
following
new
sentence.

DO
NOT
create
a
GM
Form
for
hazardous
waste
shipped
directly
to
a
foreign
country."

Page
17,
Section
III:
Off­
site
Shipment
of
Hazardous
Waste
Box
B:
EPA
ID
No.
of
facility
hazardous
waste
was
shipped
to
enter
the
12­
digit
EPA
Identification
Number
of
the
facility
to
which
the
waste
was
shipped.
The
current
instructions
will
be
modified
to
add.
"
DO
NOT
create
a
GM
Form
for
hazardous
waste
shipped
directly
to
a
foreign
country."
Waste
Activity
Information
30
Page
26,
EXCLUDED
WASTES,
Waste
Category
Waste
Description
The
current
instructions
will
be
modified
to
add
the
following
new
description.

Exported
Waste
Hazardous
waste
that
is
exported
to
a
foreign
country
is
not
included
in
this
report.
Instead,
the
facility
must
complete
an
annual
report
as
required
under
40
CFR
262.56.
Waste
Activity
Information
31
15)
CLARIFY
TYPES
OF
HAZARDOUS
WASTES
TO
BE
REPORTED
Background
This
recommendation
clarifies
what
hazardous
wastes
are
to
be
reported
in
the
Hazardous
Waste
Report
(
Biennial
Report)
(
EPA
Form
8700­
13
A/
B).
In
general,
interim
status
or
permitted
treatment,
storage
and
disposal
facilities
(
TSDFs)
report
hazardous
waste
received
from
off­
site,
the
management
of
the
hazardous
waste
while
on­
site,
and
any
shipments
of
hazardous
waste
off­
site.
Large
quantity
generators
(
generators),
in
general,
report
any
hazardous
waste
generated
on­
site
that
was
used
to
make
the
regulatory
status
quantity
determination
(
40
CFR
261.5),
hazardous
wastes
that
are
treated
on­
site,
and
hazardous
waste
that
is
shipped
off­
site.

The
agencies
that
implement
the
Biennial
Reporting
System
need
to
know
the
quantities
and
characteristics
of
hazardous
waste
generated
and
managed
in
their
states,
hence
the
regulatory
requirements
under
Section
3002
and
3004
of
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
and
Sections
262.41,
264.75,
and
265.75
in
40
CFR.
Nevertheless,
40
CFR,
Parts
260
to
273,
exempt
specific
hazardous
waste
and
exclude
distinct
hazardous
waste
management
processes
from
certain
regulations,
such
as
biennial
reporting.
The
reporting
of
hazardous
wastes
that
are
managed
in
processes
excluded
from
permitting
is
currently
inconsistently
implemented
and
has
been
a
longstanding
issue
in
the
Biennial
Reporting
Program.
Additionally,
there
is
confusion
amongst
generators
in
determining
the
hazardous
wastes
that
are
to
be
reported
on
the
Biennial
Reporting
Forms.
Therefore,
the
purpose
of
this
recommendation
is
to
provide
clarity
and
consistency
in
the
reporting
of
waste
activity
information,
specifically
on
the
hazardous
waste
Generation
and
Management
Form
(
GM).

Recommendation
The
Biennial
Reporting
instructions
will
be
changed
to
clarify
that
generators
should
report
only
the
hazardous
wastes
which
count
toward
the
determination
of
their
generator
status
(
except
as
otherwise
required
by
your
state
agency).
This
includes
wastes
that
are
generated,
accumulated
and
subsequently
managed
on­
site,
or
shipped
off­
site.
TSDFs
should
report
hazardous
waste
received
from
off­
site,
the
management
of
the
hazardous
waste
while
on­
site,
and
any
shipments
of
hazardous
waste
off­
site.

Recommended
Form
Amendments
Form
Revisions
The
Biennial
Report
Forms
are
being
revised
as
follows:

FORM
GM
 
WASTE
GENERATION
AND
MANAGEMENT
Section
II,
Box
C,
currently
contains
this
language:
Did
this
site
do
any
of
the
following
to
this
waste:
treat
onsite
dispose
on­
site,
recycle
on­
site,
or
discharge
to
a
sewer/
POTW?
This
sentence
is
being
revised
to
read:
Did
this
site
manage
hazardous
waste
on­
site
in
a
process
that
is
not
excluded
from
regulation
(
see
Waste
to
be
Reported
on
page
_
).

Instruction
Revisions
The
instructions
to
the
Biennial
Report
are
being
modified
as
described
below:

Page
2,
WHICH
FORMS
TO
SUBMIT
AND
WHAT
TO
REPORT
Form
GM
A
separate
Form
GM
must
be
submitted
for
each
hazardous
waste
required
to
be
reported
that
was
used
to
determine
the
site
regulatory
status
and
was
generated,
managed
and/
or
shipped
offsite
in
2001.

Hazardous
waste
that
may
need
to
be
reported
include
those
that
were:

Generated
on­
site
.
.
.
.
no
changes
Waste
Activity
Information
32
RCRA
hazardous
wastes
to
be
reported
include
those
that
were:

Generated
on­
site
.
.
.
.
no
changes
Radioactive
wastes
mixed
with
RCRA
hazardous
wastes
should
also
be
reported,
as
well
as
hazardous
wastes
regulated
only
by
your
state
(
if
required
by
your
state).
­
remove
portion
of
the
sentence
about
radioactive
mixed
wastes
Page
11,
INSTRUCTIONS
FOR
FILLING
OUT
FORM
GM
Page
11,
WHO
MUST
SUBMIT
THIS
FORM
Revised
Instructions:
A
site
required
to
file
the
2001
Hazardous
Waste
Report
must
submit
Form
GM
if,
during
2001,
the
site
generated
hazardous
wastes
that
were
accumulated,
managed
on­
site
in
a
treatment,
storage,
or
disposal
unit,
or
shipped
off­
site.
[
see
Waste
to
be
Reported
for
any
exclusions
or
exemptions
­
page
_
]

Page
11,
PURPOSE
OF
THIS
FORM
Revised
Instructions:
Form
GM
summarizes
on­
site
hazardous
waste
generation
and
management
in
2001.
Form
GM
is
divided
into
three
sections
that
together
document
the
source,
characteristics,
and
quantity
of
hazardous
waste
that
must
be
reported;
the
quantity
of
hazardous
waste
managed
on­
site;
and
the
quantity
of
hazardous
waste
shipped
off­
site
for
treatment,
disposal,
or
recycling
along
with
the
off­
site
management
method.

Page
12,
WASTES
TO
BE
REPORTED,
this
heading
will
be
revised
to
read
HAZARDOUS
WASTES
WHICH
ARE
COUNTED
TOWARD
REGULATED
STATUS
Revised
Instructions:

A
separate
Form
GM
must
be
submitted
for
each
hazardous
waste
that
is
required
to
be
reported,
was
used
to
determine
the
site
regulatory
status,
and
was
generated,
managed
and/
or
shipped
off­
site
in
2001.

Hazardous
wastes
that
are
not
counted
toward
your
regulatory
status
should
not
be
reported.
These
include:

­
Hazardous
waste
exempt
from
regulation
because
the
waste
has
not
exited
the
raw
material
storage
or
production
unit
yet
as
specified
in
40
CFR
261.4(
c­
f)
or
40
CFR
261.5(
c)(
1).

­
Hazardous
waste
that
has
been
collected
as
a
sample(
s)
for
the
purpose
of
determining
its
characteristic
or
composition,
as
specified
in
40
CFR
261.4(
d)
or
40
CFR
261.5(
c)(
1).

­
Sample(
s)
undergoing
treatability
studies,
as
specified
in
40
CFR
261.4(
e)
and
40
CFR
261.5(
c)(
1).

­
Sample(
s)
undergoing
treatability
studies
at
the
laboratory
or
testing
facility,
as
specified
in
40
CFR
261.(
e)
or
40
CFR
261.5(
c)(
1).

­
Hazardous
waste
that
is
a
recyclable
material
such
as
ethyl
alcohol
or
scrap
metal,
as
specified
in
40
CFR
261.6(
a)(
3)
and
is
recycled.
Or
as
specified
in
40
CFR
261.5(
c)(
1).

­
A
residue
of
hazardous
waste
in
an
empty
container
less
than
the
amounts
specified
in
261.7(
a)(
1)
or
as
specified
in
40
CFR
261.5(
c)(
1).
Waste
Activity
Information
33
­
Managed
immediately
upon
generation
only
in
on­
site
elementary
neutralization
units,
wastewater
treatment
units,
or
totally
enclosed
treatment
facilities
without
being
stored
or
accumulated
first
(
40
CFR
261.5(
c)(
2)).
[
Note:
if
the
residue
generated
from
these
units
is
a
hazardous
waste,
it
is
counted
toward
the
site's
regulatory
status
and
is
reported.]

­
Recycled
on­
site
without
prior
storage
or
accumulation
(
40
CFR
261.5(
c)(
3)).

­
Recycled
used
oil
that
is
hazardous
waste
solely
because
it
exhibits
a
hazardous
waste
characteristic
and
is
managed
under
40
CFR
Part
279
or
(
40
CFR
261.5(
c)(
4)).

­
Spent
lead
acid
battery
managed
under
the
requirements
of
40
CFR
Part
266,
Subpart
G
which
includes
persons
who
reclaim
spent
lead­
acid
batteries
that
are
recyclable
materials,
persons
who
generate,
transport,
or
collect
spent
batteries,
who
regenerate
spent
batteries,
or
who
store
them
(
other
than
spent
batteries
that
are
to
be
regenerated.
(
40
CFR
261.5(
c)(
5).

­
Universal
waste
and
is
managed
as
such
under
40
CFR
261.9
or
40
CFR
261.5(
c)(
6).

­
Hazardous
waste
when
removed
from
on­
site
storage
that
was
counted
prior
to
entering
storage
(
40
CFR
261.5(
d)(
1)).
[
Note:
since
the
hazardous
waste
is
counted
prior
to
entering
storage,
the
shipment
of
this
waste
must
be
reported.]

­
Hazardous
waste
produced
from
on­
site
treatment
so
long
as
the
hazardous
waste
that
is
treated
was
counted
once
(
40
CFR
261.5(
d)(
2)).
[
Note:
since
the
hazardous
waste
is
counted
prior
to
being
treated
on­
site,
it
must
be
reported.]

­
A
spent
material
that
is
generated,
reclaimed,
and
subsequently
re­
used
on­
site
so
long
as
such
spent
material
was
counted
once
(
40
CFR
261.5(
d)(
3)).
[
Note:
since
the
hazardous
waste
is
counted
prior
to
being
reclaimed
on­
site,
it
must
be
reported.]

­
Materials
which
are
excluded
from
being
a
waste
such
as
any
mixture
of
domestic
sewage
and
other
wastes
that
pass
through
a
sewer
system
to
a
publicly
owned
treatment
works
unless
they
are
stored
or
treated
in
regulated
units
prior
to
being
discharged.
(
40
CFR
261.4
specifically
261.4(
a)(
1)(
ii)).

­
Wastes
that
are
excluded
form
being
hazardous
waste
such
as
petroleum­
contaminated
media
and
debris
that
fail
the
test
for
the
toxicity
characteristic
D018
through
D043
only
and
are
subject
to
corrective
action
regulations.
(
40
CFR
261.4
specifically
261.4(
b)(
9)).

­
Hazardous
waste
exported
to
a
foreign
country.
These
wastes
are
to
be
used
in
the
determination
of
the
generator's
status
but
are
not
to
be
reported
using
the
Biennial
Reporting
Forms.
This
information
is
collected
in
the
Annual
Export
Report
submitted
by
the
generator
to
the
United
States
Environmental
Protection
Agency.
262.56
(
40
CFR
262.41(
a)).

Page
15,
ITEM
BY
ITEM
INSTRUCTIONS
Section
II:
On­
site
Generation
and
Management
of
Hazardous
Waste
During
2001
Revised
instructions:
Remove
last
sentence
in
paragraph
one
and
the
bullets
which
follow
this
sentence
("
For
each
hazardous
wastewater
managed
on­
site
and
ultimately
discharged:").
The
bullets
refer
to
NPDES,
POTW,
and
injection
wells.

Page
A­
1,
APPENDIX
A,
EXAMPLES
OF
COMPLETED
2001
HAZARDOUS
WASTE
FORMS
Waste
Activity
Information
34
The
current
instructions
will
be
modified
to
add
the
following
new
examples.
Please
provide
any
other
examples
that
you
believe
would
be
helpful.

A
Waste
solvent
shipped
off­
site
A
Waste
solvent
that
is
accumulated
on­
site
before
being
reclaimed
on­
site
and
the
distillation
bottoms
shipped
off­
site
A
Generation
of
electroplating
sludge
from
a
wastewater
treatment
unit
A
Corrosive
waste
that
is
shipped
off­
site
to
a
POTW
A
Waste
disposed
on­
site
in
a
deep
well/
underground
injection
Waste
Activity
Information
35
16)
Streamline
Source,
Origin,
Form,
and
Management
Codes
Background
The
following
three
recommendations
will
be
implemented
to
streamline
and
improve
the
usefulness
of
reported
waste
information:

1)
Current
source
codes
will
be
consolidated,
regrouped
and
merged
with
the
current
origin
codes
to
provide
a
simpler
coding
structure.
2)
Form
codes
will
be
revised
resulting
in
a
reduction
from
89
to
47
codes.
3)
Management
Method
codes
will
be
revised
to
eliminate
overlap
with
form
codes.

Combining
Source
and
Origin
Code
Analysis
There
is
significant
complexity
in
the
way
the
existing
Biennial
Reporting
source
of
generation
and
origin
codes
are
defined.
This
complexity
is
a
result
of
the
overlap
in
the
coverage
areas
of
the
two
coding
structures,
which
has
led
to
a
number
of
data
quality
and
consistency
problems.
Analysis
of
the
1995
Biennial
Report
data
has
shown
that
96%
of
GM
forms
submitted
included
an
origin
code
and
94%
a
source
code.
Given
the
high
response
rate,
it
is
essential
that
respondents
understand
their
usage
and
the
complexities
and
the
overlap
be
resolved.

The
1995
Biennial
Report
used
the
following
five
origin
codes:

1.
As­
generated
process­
derived
waste.
2.
Cleanup,
spills,
remediation,
and
equipment
decommissioning.
3.
Residual
from
on­
site
management
of
a
non­
hazardous
waste.
4.
Received
from
off­
site
and
NOT
recycled
or
treated
on­
site.
5.
Residual
from
on­
site
management
of
a
hazardous
waste.

The
same
report
used
some
sixty
source
codes
in
the
following
seven
high­
level
source
groups:

Group
1
(
A01­
A19)
Cleaning
and
degreasing
Group
2
(
A21­
A29)
Surface
preparation
and
finishing
Group
3
(
A31­
A49)
Processes
other
than
surface
preparation
Group
4
(
A51­
A60)
One­
time
and
intermittent
production­
related
processes
Group
5
(
A61­
A69)
Remediation­
derived
waste
Group
6
(
A71­
A89)
Pollution
control
and
waste
treatment
processes
Group
7
(
A91­
A99)
Other
processes
Overlap
Conceptually,
there
is
significant
overlap
between
the
origin
and
source
coding
structures.
­
Origin
1
(
as­
generated)
subsumes
Source
Groups
1,
2,
and
3
(
production
and
service
processes).
­
Origin
2
(
cleanup,
spills,
etc.)
generally
includes
Source
Groups
4
and
5
(
intermittent,
one­
time
and
remediation).
­
Origin
4
(
received
from
off­
site,
no
TDR)
has
no
corresponding
Source
Group.
­
Source
Group
7
(
other
non­
production
processes)
has
no
analogue
Origin.
­
Wastes
from
Source
Group
6
(
pollution
control
and
waste
treatment)
may
have
either
Origin
5
(
residual
from
managing
hazardous
waste)
or
Origin
3
(
residual
from
managing
non­
hazardous
waste)
and
may
also
be
viewed
by
some
reporters
as
an
integral
part
of
their
production
processes.
Waste
Activity
Information
36
­
An
example
of
the
latter
is
K061
baghouse
dust:
it
is
definitively
described
by
Source
A78
(
air
pollution
control
devices),
but
is
obviously
tied
to
the
production
of
steel.
Is
this
more
appropriately
an
example
of
a
residual
from
on­
site
management
of
a
hazardous
waste
(
Origin
5)
or
of
as­
generated
process­
derived
waste
(
Origin
1)?

Correlation
The
overall
correlation
at
a
high
level
between
reported
origin
and
reported
source
is
good.
Some
inconsistencies
do
appear,
due
in
part
to
confusion
on
the
part
of
reporters
and
the
more
specific
and
complex
nature
of
the
source
coding
structure.
Additionally,
respondents
often
provide
ambiguous
answers
to
some
questions,
typically
by
choosing
"
other"
categories.
In
the
1995
Biennial
Report,
each
source
code
group
contained
an
"
Other
+
specify
in
comments"
choice
and
overall,
20%
of
GM
forms
indicated
one
of
these,
including
4%
using
Source
Code
A99
(
Other
Processes
+
Other).

Fulfilling
Information
Needs
Source
codes
in
groups
A1
through
A3
(
cleaning
and
degreasing;
surface
preparation
and
finishing;
and
other
production
processes)
meet
the
programmatic
need
to
identify
wastes
from
ongoing
generation
from
production
and
service
processes
and
source
codes
in
group
A6
(
remediation­
derived
waste)
meet
the
programmatic
need
to
identify
waste
generated
by
remediation
of
historic
contamination.
Group
A7
(
pollution
control
and
waste
treatment)
addresses
the
programmatic
need
to
identify
wastes
that
are
residuals
from
active
on­
site
management
of
hazardous
waste.
However,
Group
A5
(
one­
time
and
intermittent
production­
related
processes)
includes
specific
codes
for
both
wastes
generated
once
or
sporadically
and
wastes
generated
by
current
spills
or
accidental
releases,
two
categories
that
should
be
distinct.
Group
A9
(
other
processes)
does
not
correspond
to
current
information
needs
identified
by
the
RCRA
program.

Recommendation
The
current
source
codes
will
be
consolidated,
regrouped,
and
merged
with
the
origin
codes
to
provide
a
simpler
coding
structure.
It
is
intended
that
this
approach
will
provide
more
meaningful
and
consistent
responses,
reduce
at
least
some
of
the
reporting
burden,
and
support
the
high­
level
information
categorization
needs
of
the
RCRA
program.
This
scheme
would
reduce
the
number
of
choices
from
60
to
30
and
the
groups
from
7
to
6.
We
believe
that
this
proposal
will
result
in
increased
data
accuracy
and
quality
through
reduced
variation
in
response.

Table
1
provides
a
proposed
coding
structure,
which
is
intended
to
provide
a
basis
for
evaluation
and
discussion.

Table
1.
Source
Codes
Code
Old
Code(
s)
Wastes
directly
from
ongoing
production
and
service
processes
G01
Dip,
flush
or
spray
rinsing
A04,
A05,
A06,
A31
G02
Stripping
and
acid
or
caustic
cleaning
G03
Plating
and
phosphating
G04
Etching
A27
G05
Metal
forming
and
treatment
(
pickling,
heat
treating,
etc.)
G06
Painting
and
coating
G07
Product
and
by­
product
processing
G08
Removal
of
spent
process
liquids
or
catalysts
Waste
Activity
Information
37
G09
Other
production
or
service­
related
processes(
specify
in
comments)
A49,
A29,
A07,
A08,
A19
Other
Intermittent
events
or
processes
G11
Discarding
off­
specification
or
out­
of­
date
chemicals
or
products
G12
Lagoon
or
sediment
dragout
and
leachate
collection
G13
Cleaning
out
process
equipment
G14
Removal
of
tank
sludge,
sediments
or
slag
G15
Process
equipment
change­
out
or
discontinue
use
of
equipment
G16
Oil
changes
and
filter
or
battery
replacement
G19
Other
one­
time
or
intermittent
processes(
specify
in
comments)
Pollution
control
and
waste
management
process
residuals
G21
Air
pollution
control
devices
(
baghouse
dust,
etc)
G22
Laboratory
analytical
wastes
(
used
chemicals)
G23
Wastewater
treatment
(
sludge,
filter
cake,
etc)
G24
Solvent
or
product
distillation
or
recovery
(
sludge,
waste)
G25
Hazardous
waste
management
­
indicate
management
method
A71­
A74,
A76,
A77,
A79,
A89
Spills
and
accidental
releases
G31
Accidental
contamination
of
products,
materials
or
containers
G32
Cleanup
of
spill
residues
A53
G33
Leak
collection
and
floor
sweeping
G39
Other
cleanup
of
current
contamination(
specify
in
comments)
NEW
Remediation
of
past
contamination
G41
Closure
of
hazardous
waste
management
unit
under
RCRA
G42
Corrective
action
at
a
solid
waste
management
unit
under
RCRA
G43
Remedial
action
or
emergency
response
under
Superfund
G44
State­
program
or
voluntary
cleanup
G45
Underground
storage
tank
cleanup
G49
Other
remediation(
specify
in
comments)
Waste
not
physically
generated
on­
site
G61
Hazardous
waste
received
from
off­
site
for
storage/
bulking
and
transfer
off­
site
for
treatment
or
disposal.
A89,
NEW
(
Origin
=
4)

G62
Hazardous
waste
received
from
a
foreign
country,(
not
a
foreign
Department
of
Defense
site,
Malquiladora,
US
territory
or
protectorate)
This
site
was
the
generator
of
record.
NEW
Simplify
Management
Method
Codes
NOTE:
The
term
management
method
is
being
used
to
refer
to
the
system
type
used
to
treat,
store,
or
dispose
of
the
waste.
Analysis
Although
there
is
no
conceptual
overlap,
the
current
management
method
coding
structure
duplicates
and
conflicts
with
the
use
of
form
codes.
For
example,
there
are
five
distinct
management
method
codes
for
waste
incineration,
depending
on
the
physical
form
of
the
waste
being
incinerated.
This
leads
to
such
reporting
"
anomalies"
as
a
waste
Waste
Activity
Information
38
of
the
physical
form
B201
(
concentrated
solvent­
water
solution)
being
managed
by
system
M043
(
incineration
+
solids).
It
is
impossible
to
know
which
of
these
conflicting
data
points
is
accurate.

Recommendation
The
existing
management
method
coding
structure
will
be
revised
to
eliminate
overlap
with
form
codes.
This
coding
structure
is
based
in
part
on
analysis
of
the
frequency
and
perceived
accuracy
with
which
different
management
method
codes
were
reported
in
the
1995
BRS
data.
The
impact
of
the
LDR
treatment
codes
was
also
considered
in
establishing
this
list.
This
reduces
the
detailed
list
from
65
entries
to
28
and
the
high­
level
groups
from
14
to
4.
We
believe
this
proposal
will
result
in
increased
data
accuracy
and
quality
through
reduced
variation
in
response
with
a
notable
decrease
in
burden
for
both
the
handlers
as
well
as
program
implementers.

Table
2
provides
a
proposed
coding
structure,
which
is
intended
to
provide
a
basis
for
evaluation
and
discussion.
To
avoid
confusion
and
re­
training
issues
the
present
list
of
Management
Method
codes
has
been
revised
and
consolidated
under
the
old
numeric
coding
scheme
but
using
the
new
designation
of
"
H"
rather
than
creating
an
entirely
new
list.
Table
Y
presents
the
revisions
to
the
current
list
of
Management
Method
codes.

Table
2:
Management
Method
Codes
Code
Waste
handling
method
Old
Code(
s)
Reclamation
and
recovery
H010
Metals
recovery
including
retorting,
smelting,
chemical,
etc.
M011­
M019
H020
Solvents
recovery
M021­
M029,
M104
H039
Other
recovery
or
reclamation
for
reuse
including
acid
regeneration,
organics
recovery,
etc.(
specify
in
comments)
M031­
M039
H050
Energy
recovery
at
this
site
­
use
as
fuel
(
includes
on­
site
fuel
blending)
M051­
M059
H061
Fuel
blending
prior
to
energy
recovery
at
another
site.
M061
Treatment
H040
Incineration
­
thermal
destruction
other
than
use
as
a
fuel
M041­
49
H071
Chemical
reduction
with
or
without
precipitation
M071
H073
Cyanide
destruction
with
or
without
precipitation
M073
H075
Chemical
oxidation
M075
H076
Wet
air
oxidation
M076,
M084,
M093
H077
Other
chemical
precipitation
with
or
without
pre­
treatment
M072,
M074,
M077
H081
Biological
treatment
with
or
without
precipitation
M081,
M091
H082
Adsorption
M082,
M092,
M103
H083
Air
or
steam
stripping
M083
H101
Sludge
treatment
and/
or
dewatering
M101,
M102,
M109
H103
Absorption
M103
H111
Stabilization
or
chemical
fixation
prior
to
disposal
at
another
site.
M111
H112
Macro­
encapsulation
prior
to
disposal
at
another
site.
M112,
NEW
H121
Neutralization
only
M121
H122
Evaporation
M122
H123
Settling
or
clarification
M123
H124
Phase
separation
M124
Waste
Activity
Information
39
H129
Other
treatment
(
specify
in
comments)
M078,
M079,
M085,
M089,
M094,
M089,
M099,
M119,
M125,
M129
Disposal
H131
Land
treatment
or
application
(
to
include
on­
site
treatment
and/
or
stabilization)
M131
H132
Landfill
or
surface
impoundment
closed
as
landfill
(
to
include
on­
site
treatment
and/
or
stabilization)
M132,
M133
H134
Deepwell
or
underground
injection
(
with
or
without
treatment)
M134
H135
Discharge
to
sewer/
POTW
or
NPDES
(
with
prior
storage
­
with
or
without
treatment)
M135,
M136
Storage
and
Transfer
H141
Storage,
bulking,
and/
or
transfer
off­
site
(
no
treatment,
fuel
blending,
or
disposal
on­
site)
M141
Simplifying
Form
Codes
in
the
Biennial
Report
Analysis
The
physical
form
of
a
generated
waste
is
collected
on
the
Biennial
Reporting
forms
using
89
specific
codes
in
9
high­
level
groups.
This
is
the
most
elaborate
of
the
Biennial
Reporting
form
coding
structures
and
the
most
difficult
to
analyze.
It
appears
to
be
prone
to
error
and
ambiguity.
The
form
codes
are
being
revised
to
meet
the
current
information
needs
of
the
RCRA
program.

The
existing
form
codes
are
used
by
the
EPA
and
States
to
further
describe
the
waste
as
a
whole
and
to
collect
information
in
some
cases
not
included
in
the
Waste
codes.
An
example
of
this
is
the
presence
or
absence
of
Cyanides
in
F006
plating
sludge,
which
is
an
important
factor
in
determining
proper
handing
and
minimization
strategies.
The
new
Form
codes
combine
very
similar
old
codes
using
the
information
that
is
included
in
the
Waste
codes
to
reduce
the
complexity
and
overlap
of
information
between
the
two.
This
maintains
the
level
of
information
needed
by
the
EPA
and
the
States
to
effectively
implement
Pollution
prevention
and
compliance
oversight
management
strategies.
At
the
same
time,
wastes
that
were
hard
to
correctly
choose
a
form
code
for
before
have
been
better
described
and
categorized,
both
decreasing
confusion
for
the
reporters
and
yielding
better
defined
data
for
the
implementer.

Recommendation
The
current
form
codes
will
be
revised
to
streamline
the
codes.
The
improvement
reduces
the
number
of
form
codes
from
89
to
47
with
7
high
level
groups.
This
improvement
will
result
in
increased
data
accuracy
and
quality
through
reduced
variation
in
response
with
a
notable
decrease
in
burden
for
both
the
handlers
as
well
as
program
implementers.

Table
3
provides
a
proposed
coding
structure,
which
is
intended
to
provide
a
basis
for
evaluation
and
discussion.
To
avoid
confusion
and
re­
training
issues
the
present
list
of
form
codes
has
been
revised
and
consolidated
under
the
old
numeric
coding
scheme
but
using
the
new
designation
of
"
W"
rather
than
creating
an
entirely
new
list.
In
some
cases,
there
is
not
an
exact
translation
from
the
old
form
codes
to
the
new
ones,
but
generally
there
is
an
easy
migration
path
to
ensure
continuity
for
trend
analysis.
Table
Z
presents
the
revisions
to
the
current
list
of
Form
codes.
Waste
Activity
Information
40
Table
3:
Form
Codes
Code
Form
Group
Old
Code
Mixed
Media/
Debris
/
Devices
­
Waste
that
is
a
mixture
of
organic
and
inorganic
or
liquid
and
solid
wastes
or
devices
are
not
easily
categorizable.

W001
Lab
packs
with
no
acute
hazardous
waste
B001,
B003,
B009
W002
Contaminated
debris:
paper,
clothing,
rags,
wood,
empty
fiber
or
plastic
containers,
glass,
piping,
other
solids
B002,
B406,
NEW
W004
Lab
packs
containing
acute
hazardous
waste
B004
W301
Contaminated
soil
B301,
B302,
W309
Batteries,
battery
parts,
cores,
casings
B309
W310
Filters,
solid
adsorbents,
ion
exchange
resins
and
spent
carbon
B310,
B404
W320
Electrical
devices
(
lamps,
thermostats,
CRTs,
etc)
NEW
W512
Sediment
or
lagoon
dragout,
drilling
or
other
muds
,
B512,
B513,
B514
W801
Compressed
gases
B701,
B801
Inorganic
liquids
­
Waste
that
is
primarily
inorganic
and
highly
fluid
(
e.
g.,
aqueous),
with
low
suspended
inorganic
solids
and
low
organic
content
W101
Very
dilute
aqueous
waste
containing
more
than
99%
water
B101,
B102,
B114,
B116
W103
Spent
concentrated
acid
B103,
B104
W105
Acidic
aqueous
wastes
less
than
5%
acid
B105
W107
Aqueous
waste
containing
cyanides
B107,
B108
W110
Caustic
aqueous
waste
without
cyanides
B106,
B109,
B110
W113
Other
aqueous
waste
or
wastewaters
B111,
B112,

W117
Waste
liquid
mercury
B117
W119
Other
inorganic
liquid
(
specify
in
comments)
B119
Organic
liquids
­
Waste
that
is
primarily
organic
and
is
highly
fluid,
with
low
inorganic
solids
content
and
low­
to­
moderate
water
content
W200
Still
bottoms
in
liquid
form.
B601,
B602,
NEW
W202
Concentrated
halogenated
(
E.
G.
chlorinated)
solvent
B202
W203
Concentrated
non­
halogenated
(
E.
G.
chlorinated)
solvent
B203
W204
Concentrated
halogenated/
non­
halogenated
solvent
mixture
B204,
B201
W205
Oil­
water
emulsion
or
mixture
B205
W206
Waste
oil
B206
W209
Paint,
ink,
lacquer,
or
varnish
B209
W210
Reactive
or
polymerizable
organic
liquids
and
adhesives
B210,
B212
W211
Paint
thinner
or
petroleum
distillates
B211
Waste
Activity
Information
41
W219
Other
organic
liquid
(
specify
in
comments)
B207,
B208,
B219
Inorganic
solids
­
Waste
that
is
primarily
inorganic
and
solid,
with
low
organic
content
and
low­
to­
moderate
water
content;
not
pumpable
W303
Ash
B303
W304
Slags,
drosses,
and
other
solid
thermal
residues
B303,
B304
W307
Metal
scale,
filings
and
scrap
(
including
metal
drums)
B307,
B308
W312
Cyanide
or
metal
cyanide
bearing
solids,
salts
or
chemicals
B312,
B313
W316
Metal
salts
or
chemicals
not
containing
cyanides
B316,
W319
Other
inorganic
solids
(
specify
in
comments)
B311,
B319,
B314,
B315
Organic
solids
­
Waste
that
is
primarily
organic
and
solid,
with
low­
to­
moderate
inorganic
content
and
water
content;
not
pumpable
W401
Pesticide
solids
B401,
B402
W403
Solid
resins,
plastics
or
polymerized
organics
B403
W405
Explosives
or
reactive
organic
solids
B405
W409
Other
organic
solids
(
specify
in
comments)
B407,
B409
Inorganic
Sludges
­
Waste
that
is
primarily
inorganic,
with
moderate­
to­
high
water
content
and
low
organic
content;
mostly
pumpable
W501
Lime
and/
or
metal
hydroxide
sludges
and
solids
with
no
cyanides
B501,
B502,
B305,
B306
W503
Gypsum
sludges
from
wastewater
treatment
or
air
pollution
control
B503
W504
Other
sludges
from
wastewater
treatment
or
air
pollution
control.
B504,
B511
W505
Metal
bearing
sludges
(
including
plating
sludge)
not
containing
cyanides
B505,
B510
W506
Cyanide­
bearing
sludges
B506,
B507
W519
Other
inorganic
sludges
(
specify
in
comments)
B508,
B509,
B515,
B516,
B519,
B607
Waste
Activity
Information
42
Organic
Sludges
­
Waste
that
is
primarily
organic
with
low­
to­
moderate
inorganic
solids
content
and
water
content;
pumpable
W603
Oily
sludge
B603
W604
Paint
or
ink
sludges,
still
bottoms
in
sludge
form.
B601,
B602,
B604
W606
Resins,
tars,
polymer
or
tarry
sludge
B605,
B606
W609
Other
organic
sludge
(
specify
in
comments)
B608,
B609
Waste
Activity
Information
43
17)
Removal
of
Data
Elements
from
Biennial
Reporting
Forms
Background
During
the
analysis
phase
of
the
WIN/
INFORMED
project,
participants
identified
the
information
needs
required
to
support
the
Resource
Conservation
and
Recovery
Act,
Subtitle
C
(
RCRA)
and
implement
their
authorized
state
programs.
This
recommendation
supports
burden
reduction
efforts
through
removal
of
form
fields
that
are
not
necessary
to
support
current
program
activities.

Note:
This
item
recommends
that
the
following
be
included
on
the
form
in
the
Notification
of
Regulated
Waste
Activity
(
EPA
Form
8700­
12)
to
capture
new,
nationally
required
information
needs.
Recommendation
#
7­
"
Merge
common
elements
of
current
site
identification
forms"
is
also
being
submitted
at
this
time.
The
discussion
below
references
additions
to
the
instructions
in
the
Notification
booklet;
the
submitter
would
enter
the
required
data
on
the
new
Resource
Conservation
and
Recovery
Act,
Subtitle
C,
(
RCRA)
Site
Identification
Form,
which
would
be
included
in
the
booklet.

Recommendation
A
number
of
data
fields
currently
collected
in
the
Hazardous
Waste
Report
(
EPA
Form
8700­
13A/
B;
Biennial
Report)
appear
to
no
longer
be
needed
and
will
be
removed.
State
implementers
and
the
Environmental
Protection
Agency
(
EPA)
have
determined
that
the
Point
of
Measurement,
SIC
Code,
and
off­
site
availability
indicators
would
be
removed
from
the
Biennial
Report.

Recommended
Form
Amendments
Point
of
Measurement
Problem
Analysis
The
Biennial
Report
Forms
currently
require
respondents
filling
out
a
Generation
and
Management
(
GM)
Form
and
to
indicate,
using
one
of
the
following
four
codes,
whether
the
waste
being
reported
was
mixed
with
other
wastes
prior
to
being
measured
or
estimated.
Response
to
this
form
element
is
optional.

WIN/
Informed
participants
identified
no
significant
need
for
this
information.
Additionally,
due
to
confusion
on
the
part
of
the
generator
with
respect
to
this
element,
the
data
is
often
of
questionable
quality.

Recommendation
Since
the
"
point
of
measurement"
data
element
appears
to
meet
no
current
information
need,
it
will
be
removed
from
the
Biennial
Report
GM
form.

SIC
Code
Problem
Analysis
The
collection
of
the
Standard
Industrial
Classification
(
SIC)
code
at
the
waste
stream
level
was
not
identified
as
an
information
need
by
most
states
and
the
EPA,
especially
given
the
proposal
to
add
North
American
Industrial
Classification
Standard
(
NAICS)
codes
to
the
new
RCRA
Site
Identification
Form.

The
Biennial
Report
GM
Form
requests
that
respondents
provide
the
overall
SIC
code
for
the
site,
rather
than
the
SIC
code
for
the
process(
es)
generating
the
waste.

Recommendation
Remove
the
SIC
code
form
element
from
the
Biennial
Reporting
GM
Form.
Associated
system
information
will
be
maintained
for
SIC
or
NAICS
Code.
Supplying
SIC
data
on
the
GM
Form
is
currently
optional.
However,
the
collection
of
the
NAICS
data
on
the
new
RCRA
Site
Identification
Form
will
be
mandatory.
Waste
Activity
Information
44
Off­
Site
Availability
Problem
Analysis
The
Biennial
Report
Forms
use
the
off­
site
availability
data
element
to
indicate
whether
the
off­
site
facility
where
the
waste
is
sent
is
a
commercial
treatment,
storage
or
disposal
facility
(
TSDF),
or
is
only
permitted
to
accept
wastes
from
firms
owned
by
the
same
company.
Completing
this
data
element
is
optional
currently.
WIN/
INFORMED
participants
did
not
indicate
any
program
uses
for
this
information.

Recommendations
Remove
the
off­
site
availability
form
element
from
the
Biennial
Report
Forms
and
from
associated
data
systems,
since
this
information
is
derivable
by
other
means.

RCRA/
Radioactive
Mixed
Waste
Problem
Analysis
The
Biennial
Reporting
Forms
currently
request
that
LQGs
reporting
waste
generation
and
TSDFs
reporting
waste
receipt
indicate
whether
the
waste
was
previously
mixed
with
nuclear
source,
spent
nuclear
or
by­
product
material,
as
defined
by
the
Atomic
Energy
Act
of
1954,
as
amended.
Response
to
this
form
element
is
optional,
which
means
we
receive
an
incomplete
view
of
the
affected
reporting
universe.

However,
it
is
necessary
to
identify
those
sites
involved
in
radioactive
waste
activities
for
program
management
purposes.
The
WIN/
INFORMED
participants
felt
that
the
need
should
be
met
by
identifying
the
RCRA
sites
performing
the
activities,
rather
than
by
requiring
detailed
reporting
at
the
waste
stream
level.
Certain
Department
of
Energy,
State,
and
EPA
compliance
reporting
agreements
are
based
on
the
Biennial
Report,
so
it
has
been
requested
that
this
data
be
collected
for
one
more
cycle.

Recommendations
Remove
radioactive
mixed
waste
reporting
from
the
Biennial
Report
forms.
An
associated
site
activity
check
box
to
indicate
Radioactive
Mixed.
"
Check
if
Radioactive
Mixed
Waste"
is
being
added
to
the
new
site
identification
form.
Waste
Activity
Information
45
25)
Make
Source
Code
a
National
Element
Background
WIN/
INFORMED
participants
expressed
a
program
need
to
distinguish
among
the
following
classes
of
hazardous
wastes:

­
Ongoing
generation
from
production
and
service
processes
­
Residuals
from
active
on­
site
management
(
i.
e.,
recycling,
reclamation,
treatment
or
disposal)
of
hazardous
waste
­
Generated
once
or
sporadically
(
e.
g.,
discarding
off­
specification
or
out­
of­
date
chemicals,
process
equipment
change­
out,
lagoon
drag­
out)
­
Generated
by
current
spills
or
accidental
releases
­
Generated
by
remediation
of
historic
contamination
(
e.
g.,
Superfund
or
State
cleanups,
RCRA
closure
or
corrective
action)

Within
each
of
these
general
categories,
participants
reported
the
need
to
know
in
more
detail
the
specific
types
of
industrial
or
waste
management
processes
from
which
hazardous
wastes
originate.
For
example,
solvents
are
used
by
many
industries
in
a
number
of
quite
different
processes
 
cleaning,
degreasing,
painting,
etc.
 
and
simply
knowing
that
a
given
site
generates
spent
solvent
does
not
provide
enough
information
to
determine
whether
they
might
benefit
from
a
new
technique
to
eliminate
the
use
of
solvents
in
only
one
of
those
processes.

This
information
provides
detail
on
the
specific
types
of
processes
from
which
hazardous
wastes
originate.
It
can
be
used
for
compliance
monitoring,
technical
assistance
and
outreach,
state
fees
and
program
planning,
and
information
sharing.
Requiring
a
Source
Code
will
impose
a
minimal
burden
increase
on
the
implementers
and
the
regulated
community
because
over
90%
of
submissions
of
the
Hazardous
Waste
Report
(
EPA
Form
8700­
13A/
B;
Biennial
Report)
already
include
it.

Recommendation:
The
source
of
hazardous
waste
will
be
made
a
required
data
element.
This
data
element
will
be
collected
from
the
large
quantity
generators
of
hazardous
waste
and
may
be
reported
at
the
individual
process
level,
at
the
manifest
shipment
level,
or
at
the
cumulative
waste
code
level
(
within
the
reporting
cycle).
The
implementing
agency
will
provide
the
source
code
to
the
national
information
system
at
the
greatest
level
of
detail
feasible
within
the
parameters
of
their
individual
authorized
programs.

Recommended
Form
Amendments:

Form
Revisions
The
Biennial
Report
forms
are
not
being
changed.
Source
Code
is
already
on
the
report
form.
