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V5 Overview

V5 Overview. 2010 RCRAInfo National Users Conference. Debbie Goodwin EPA – Headquarters Office of Resource Conservation and Recovery. Why Did We Have to Do V5?. In Fall 2008, EPA Administrator Stephen Johnson signed two final rules affecting Subtitle C facilities:

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V5 Overview

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  1. V5 Overview 2010 RCRAInfo National Users Conference

  2. Debbie GoodwinEPA – HeadquartersOffice of Resource Conservation and Recovery

  3. Why Did We Have to Do V5? In Fall 2008, EPA Administrator Stephen Johnson signed two final rules affecting Subtitle C facilities: • 1) Revisions to the Definition of Solid Waste (DSW) and, • 2) Hazardous Waste at Academic Laboratories • (Subpart K). • Both of these rules require notification by facilities using the Site Identification Form. Additionally, the RCRAInfo Change Management Process (CMP) had referred issues to the RCRAInfo Team for implementation and the RCRAInfo USITS system contained several enhancement requests to the handler and biennial report modules. 3

  4. What’s New in the Handler Module? • Handler Detail: • Added Out of State SNC • Site Identification Form: • Removed Number of Employees • Provided better explanation for Initial Notification Reason for Submission (Box 1) • Added Country to Site Location (Box 4) • Added a dropdown box for Site Location - State District (Box 4) • Added a utility to help find NAICS codes (Box 6) • Added Contact Title (Box 8) • Added Contact Fax (Box 8a) • Added Short Term Generator (Box 10.1) 4

  5. What’s New in the Handler Module? (cont.) • Added Hazardous Waste Transfer Facility under Transporter of Hazardous Waste (Box 10.2) • Added Receives Hazardous Waste from Off-site (Box 10.7) • Added Eligible Academic Entities with Laboratories (Box 10.D) • Added Notification of Hazardous Secondary Material (Box 12) • - If “Yes”, data on the “Addendum to the Site Identification Form: Notification of Hazardous Secondary Material Activity” must be provided • Increased the length of the Certification Title to 45 characters (Box 14) 5

  6. What’s New in the Handler Module? (cont.) • Notification of Hazardous Secondary Material (HSM) Activity Screen • Reason for Notification and Effective Date • Description of HSM Activity: • - Facility Code • - Waste Code(s) • - Estimated Short Tons • - Actual Short Tons • - Land-based Unit • Facility has Financial Assurance 6

  7. What’s New in Other Areas of RCRAInfo? • Added HSM and lab citations to the CM&E Module (violations) • Increased HOTHER_PERMIT_DESC to 80 characters • Removed the NOTES field from: HCERTIFICATION5, HNAICS5, HOTHER_PERMIT5, HSTATE_ACTIVITY5, and HUNIVERSAL_WASTE5 • Increased HHANDLER5 NOTES field to 4,000 characters • Removed the OWNER field from: LU_COUNTY, LU_STATE, and LU_COUNTRY; Removed COUNTY_OWNER from HHANDLER5 7

  8. What’s New in Other Areas of RCRAInfo? (cont.) • Created HPART_A5 table for Part A contact information – corresponding information was removed from HHANDLER5 • Removed DUNN_BRADSTREET_NUMBER from OWNER_OPERATOR5 • Search options removed (Latitude / Longitude, Universes / Baselines, Activities, NAICS, Mail Address, Contact, and Permit Contact) • National Reports: - where possible, now allows download into text format which can be loaded into Excel - County/State District now has a dropdown box. 8

  9. Translation • With V5, we have ensured all business rules for translation are the same as the business rules for data entry • Translator Guide has been posted in RCRAInfo since July 2009 • XML schemas have been posted in RCRAInfo since September 2009 • Software for both flat file and XML submissions has been available for testing since January 14, 2010 • We expect translators will have their translation software modified for V5 and begin translation no later than July 1, 2010 9

  10. Universe Calculation • Runs every 3 hours, and can be run for a single site from the Permitting, Corrective Action, and CM&E main menus • 5 New Universes Added With V5: • SHORT_TERM_GENERATOR (Y/N) • TRANSFER_FACILITY (Y/N) • OFF_SITE_RECEIPT (Y/N) • SUBPART_K (C-College; H-Hospital; N-Nonprofit; W–Withdrawal) • HSM (Y-Opted in; N-Not Opted in; S-Stopped) 10

  11. Universe Calculation (cont.) • All sources types now require a “Y” or “N” for all activities in Box 10 (no more “U” - Unknown allowed) • Universe calculation will use the most recent source based on the certification date (if no certification date, the receive date will be used) • For records with same certification date, this hierarchy will apply: • I Implementer • N Notification – initial or subsequent • B Biennial report with subsequent notification • R Biennial report • A Part A • T Temporary • E Emergency • HSM activity flag is based on most recent HSM_BASIC5 information regardless of source 11

  12. What’s New With Biennial Reporting (BR)? • Added the collection of waste minimization activities on the GM Form • A new Source Code – “G17”, has been added for facilities opting into Subpart K to report the amount of waste shipped or managed during clean-out • When loading BR data, the Handler data is loaded so that universe information is updated immediately • State Summary Report will be provided in spreadsheet form • New BR Load Process 12

  13. Lori FurrEPA – HeadquartersOffice of Resource Conservation and Recovery

  14. Facilities Submit BR Data to State • Regulation - data is to be submitted by March 1st. • Mechanism to provide data to States • Electronic submissions • Paper

  15. Data Gets Loaded Into RCRAInfo

  16. Data Gets Loaded Into RCRAInfo (cont.) • New for 2009 BR Cycle -- Handler data is available immediately • Run QA/QC reports from National Reports Main Menu

  17. QA/QC Process • Notify Headquarters when data is ready to run State Summary Report (April – September 2010) • New for 2009 BR Cycle -- Each Region is assigned an HQ contact to assist with data quality • HQ runs various analysis on data and prepares State Summary Report • HQ sends copies of State Summary Report to State, Regional, and HQ contacts

  18. QA/QC Process (cont.) • States/Regions review State Summary Report and corrects data (Complete set of data must be reloaded.) • Run QA/QC from National Reports Main Menu, again • New for 2009 BR Cycle -- Update State Summary Report and send responses back to HQ

  19. Preliminary Report • Deadline for data to be loaded for generation of report is June 7, 2010 • BR Load software is unavailable for approximately two weeks to generate report • Preliminary Report is published internally within RCRAInfo on July 6, 2010

  20. Final Report • HQ does final review to verify that data is correct • Deadline for final data to be loaded to generate report is October 4, 2010 • Final Report is prepared and published on the internet on December 13, 2010

  21. Amanda GeldardEPA – HeadquartersOffice of Resource Conservation and Recovery

  22. We did it! • Site ID form now incorporates the DSW and Academic Labs rules! • RCRAInfo Version 5 includes the new data elements for these changes!

  23. First, DSW… • The Definition of Solid Waste (DSW) final rule conditionally excludes certain reclaimed materials from Subtitle C regulation. • The final rule includes two conditional exclusions for hazardous secondary materials… • Reclaimed under the control of the generator • Transferred to another person for reclamation • DSW final rule is an optional rule • States can choose to adopt the rule or not • Facilities in states that have adopted can choose to manage hazardous secondary material under the rule or maintain compliance with existing Subtitle C regulations.

  24. Indian Country Virgin Islands Puerto Rico American Samoa Northern Mariana Islands Guam Where the DSW Rule is Effective Tribal Areas Virgin Islands Puerto Rico American Samoa Northern Mariana Islands Guam

  25. As of February 2010, we have received 24 notifications: 10 generators reclaiming onsite 5 generators reclaiming within the “same company” 9 generators transferring offsite for reclamation 3 facilities receiving from offsite for reclamation Hazardous secondary materials being reclaimed include: spent solvents, electric arc furnace dust, and metal-bearing wastes. Who’s Using the Rule?

  26. Facilities must send a notification prior to operating under the exclusion and by March 1 of each even numbered year thereafter to the Regional Administrator using the Site ID form. The following reports will be available in RCRAInfo V5: Who is operating under DSW, including type and quantity of materials they manage. Who has stopped managing HSM under DSW. Who is managing materials in land-based units. Who didn’t re-notify as required. Report-astic!

  27. We have many DSW resources available: BR Instructions DSW Implementation website: http://www.epa.gov/epawaste/hazard/dsw/impresource.htm DSW Users Group DSW Rule Training DSW Inspector Checklist (Coming Soon!) DSW Compilations – Contained Standard, Reasonable Efforts, and Legitimate Recycling Contact: Amanda Geldard at geldard.amanda@epa.gov or 703-347-8975 What if I Need Help?

  28. Now, the Academic Labs Rule… • Establishes new Subpart K in 40 CFR Part 262 for laboratories owned by eligible academic entities • Labs typically operate under the satellite accumulation area (SAA) regulations of 40 CFR 262.34(c) • Subpart K provides alternate RCRA generator regulations for managing hazardous waste in academic labs • Subpart K is an optional rule • Authorized states can choose to adopt the rule or not • Participants in states that adopt the rule can choose to comply with existing regulations or Subpart K

  29. Where the Labs Rule is Effective Rule is effective in states and territories that are not authorized to run RCRA programs Alaska Iowa Indian Country Territories: American Samoa, Northern Mariana Islands, US Virgin Islands Four authorized states have adopted the rule New Jersey Pennsylvania Mississippi Montana

  30. Where the Labs Rule is Effective (cont.) Two additional states where the rule is in use Wisconsin South Dakota Additional states that will adopt the Labs Rule by June 2010 Alabama Georgia Illinois Idaho Oklahoma Other states are in the process of adopting the Labs Rule but won’t have completed the process by June

  31. Eligible academic entities must send a notification that they are opting into Subpart K. Entities must also notify when they are withdrawing from Subpart K. The following reports will be available in RCRAInfo V5: List and count of individual facilities that are opting into Subpart K List and count of individual facilities that are withdrawing form Subpart K List and count of facilities conducting Lab Cleanouts under Subpart K (according to BR data) Report-astic!

  32. We have many Labs rule resources available: BR Instructions Labs rule website: http://www.epa.gov/osw/hazard/generation/labwaste/implementation.htm “Managing Laboratory Hazardous Waste” Brochure and other implementation tools available on the website Frequent Questions Labs Rule Full Day Training, Tuesday, May 18, 2010,available via webcast- help us spread the word! Contact: Jessica Biegelson at biegelson.jessica@epa.gov or 703-308-0026 What if I Need Help?

  33. Final thoughts… Do you have plans to update your State Site ID form to incorporate the changes made to the Federal Site ID form? Do you know your State’s plans for adopting either the DSW or Labs rules? (Please let us know!)

  34. Questions?

  35. Proposed Activity Conversion • Convert existing U’s – Unknown to N’s - No • Definition of N - ‘No’ • I, E, T, R – N means No or Unknown • N, A, B – N just means No • Y – ‘Yes’ is what is really important • Final Discussion / Vote on Thursday

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