WIN/INFORMED Site Activity Workgroup

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