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WIN/INFORMED Site Activity Workgroup

This report provides 22 recommendations for improving the accuracy and completeness of RCRAInfo site activity status reports. These recommendations include flagging sites as active or inactive, incorporating state-specific activities, considering CM&E data, and implementing phased implementation.

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WIN/INFORMED Site Activity Workgroup

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  1. WIN/INFORMEDSite Activity Workgroup Overview of Site Activity Status Report Recommendations

  2. Recommendation 1: Flagging sites as “active” or “inactive” • Automated RCRAInfo process (universe calculation) based on existing data • No new data entry fields • The Active Flag uses the acronym HPACS to show which data source(s) are causing the site to be “active.” H - Handler, P – Permitting, A – Corrective Action, C – Converter, and S – State-specific. RCRAInfo National Users Conference

  3. Recommendation 2: Treatment, Storage, Disposal (TSD) Activities • A TSDF is considered active if it has at least one active unit based on its Legal/Operating Status (see pg 16 of report) • Subject to change by the WIN/INFORMED Permit Corrective Action Workgroup (PCA PAA) RCRAInfo National Users Conference

  4. Recommendation 3:Inclusion of Converters • Have EPA public access Web sites define the term “Converter” and use to distinguish from TSDFs • Converter unit – not yet clean closed as a TSD, but no longer conducts activities requiring a TSD permit RCRAInfo National Users Conference

  5. Recommendation 4: Corrective Action Activities • Determine a site’s corrective action active or inactive status by its presence in the Corrective Action Workload Universe • Again, specifics to be determined by the PCA PAA recommendations RCRAInfo National Users Conference

  6. Recommendations 5-14:State-specific Activities • Comes into play only when the State chooses to implement • Recommended because it will provide a more accurate picture of site regulatory history • Because the Usage designation will determine if a state activity is included in the calculation, states should review Usage for all state-specific codes • Subcategories: State TSD, State Generator Status, and Multiple State-specific Activities RCRAInfo National Users Conference

  7. Recommendations 5-14:State-specific Activities (cont.) • No state-specific corrective action (CA) activities since all corrective action (even that done under state-analogous authority) must satisfy federal CA requirements. • State TSD activity will cause a site to be determined “active” and will be reflected as *TSDF (recommendations 6 and 7) RCRAInfo National Users Conference

  8. Recommendations 5-14:State-specific Activities (cont.) • Include both state and federal generator statuses (recommendation 8 – previous UID/WAM recommendation) • Allow each state to decide when and which state generator statuses are used (recommendation 9) • Standardization of state generator status codes, i.e., national code “same as federal” (recommendation 10) RCRAInfo National Users Conference

  9. Recommendations 5-14:State-specific Activities (cont.) • Additional values for state generator status Usage (recommendation 11) • Expand state generator status code from 1 to 10 characters (recommendation 12) RCRAInfo National Users Conference

  10. Recommendations 5-14:State-specific Activities (cont.) • Allow each state to decide when and which of its state-specific activities (including state-specific Universal Waste) will be used in the active/inactive universe calculation (recommendation 13) • Additional values for state-specific activity Usage (recommendation 14) RCRAInfo National Users Conference

  11. Recommendations 15-17:Consideration of CM&E Data • All data modules should be checked for information before inactivating a RCRA EPA ID Number; however, CM&E data does not determine a site’s active status (recommendation 15) • Create a pop-up warning box for sites with ongoing 400-series enforcement action flagged as inactive (recommendation 16, but not in V3) RCRAInfo National Users Conference

  12. Recommendations 15-17: Consideration of CM&E Data • Enhance RCRAInfo’s Handler Detail screen to report all activities that contribute to a site’s activity status (recommendation 17, but not in V3), including certain CM&E data elements • New inspection type, Focused Compliance Inspection (FCI), includes a Routine/Standardized Focus Area Code of ISI for an Inactive Site Inspection RCRAInfo National Users Conference

  13. Recommendation 18:Phased Implementation • Implementers need to be allowed time to study/review their active universes before they are released to the public • EPA public access Web sites can prepare to display active/inactive information during the Implementer review period RCRAInfo National Users Conference

  14. Recommendations 19-21: EPA Web-based Public Access • Inactive sites routinely suppressed, but users will have the option to display them also • Add a table to RCRAInfo with a row for each state to provide an overview of its activities as well as URLs or other sources of information • Have RCRAInfo screens advise Implementers to standardize their state generator status and activity descriptions RCRAInfo National Users Conference

  15. Recommendation 22: Study Methods to Improve Data Quality • UID/WAM final report, January 2000 (http://www.epa.gov/epaoswer/hazwaste/data/win/r00-004.pdf) • Site verification – August 2001 guide (http://www.epa.gov/epaoswer/hazwaste/data/win/sitever.pdf) • Quarterly TSDF electronic reporting • Site ID Procedures and Preferences Questionnaire (reviewed in another session) RCRAInfo National Users Conference

  16. Recommendation 23:Track All Sites Nationally • Previous UID/WAM recommendation • ALL LQG and SQG sites are to be assigned a RCRA EPA ID Number regardless of its temporary or emergency nature and tracked in RCRAInfo • Data is not expected to be entered retroactively RCRAInfo National Users Conference

  17. Recommendation 24:Non-notifiers and CESQGs • Previous UID/WAM recommendation • Discussed in the RCRA Subtitle C EPA Identification Number, Site Status, and Site Tracking Guidance • Discontinue using ID numbers that do not begin with a valid postal code RCRAInfo National Users Conference

  18. Recommendations 26-27: Biennial Report Data • BR data can be used as an indicator, but should not be the sole source for activity level status • Develop a report to compare a state’s RCRA EPA ID Numbers against customer ID number in BR WR data • Develop a report to provide a reverse search of WR data to find shipment information for a specific RCRA EPA ID Number RCRAInfo National Users Conference

  19. Recommendations 28-32:Second ID Field • Not being implemented in Version 3 • Rename the Previous ID table to Other ID • Move Second ID field to the renamed Other ID table and convert values • Add an element to hold characterization codes for these IDs • Have searches check the Other ID field • Have Other ID info displayed on screens and in reports, when appropriate RCRAInfo National Users Conference

  20. Recommendation 33:Follow-up Standing Committee • Analyze ID-related issues • Seek input from the User Community • Forward the consensus recommendations for implementation • Part of the new Change Management Process RCRAInfo National Users Conference

  21. RCRA Subtitle C SiteActivity Status Project Report • The final report is posted as part of the Version 3 documentation within RCRAInfo • Copies may also be obtained from René Anderson at Rene.Anderson@deq.idaho.gov or 208.373.0210 RCRAInfo National Users Conference

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