The Future of Hazardous
Waste Reporting
David Green
Current Reporting Requirements
Generator's
Hazardous Waste
Summary Report
(MO 780-1097)
Facility Summary
Report (MO 780-
0...
Current Reporting Statistics
Statistics for the July 1,
2011 to June 30, 2012
reporting year
Generator's
Hazardous
Waste
S...
The Hazardous Waste Program is beginning
to modernize the means by which we accept
electronic reporting.
What is driving this change?
• HB1251
– Allows for LQGs and
TSDFs to report annually if
they report electronically by
the ...
What is being done now?
• The Hazardous Waste Program has
begun working with information technology
staff to develop a new...
What will reporting look like?
Based on Hazardous Waste Forum discussions, we believe that
reporters would like a system w...
How will the Electronic Manifest impact reporting?
• We plan to make the schema that we use
as close as possible (hopefull...
Will the Electronic Manifest change state reporting requirements?
• Two elements must exist in the Electronic Manifest sys...
What will change if those requirements are met?
It would be possible to eliminate the reporting requirements
with the foll...
Have an idea about electronic reporting?
Please tell me about it!
David Green
(573) 751-3204
david.green@dnr.mo.gov
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The Future of Hazardous Waste Reporting by David Green, MDNR, at REGFORM's Missouri Hazardous Waste Seminar, Nov. 15 2012

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The Future of Hazardous Waste Reporting by David Green, MDNR, at REGFORM's Missouri Hazardous Waste Seminar, Nov. 15 2012

  1. 1. The Future of Hazardous Waste Reporting David Green
  2. 2. Current Reporting Requirements Generator's Hazardous Waste Summary Report (MO 780-1097) Facility Summary Report (MO 780- 0408) "Biennial Report" (EPA form 8700-13 A/B)* Small Quantity Generator (SQG) Annually NO NO Large Quantity Generator (LQG) Quarterly NO YES Treatment, Storage, or Disposal Facility (TSDF) assumed to be LQG Quarterly YES Resource Recovery Certificate holder (RR) assumed to be SQG or LQG Quarterly YES * Federal Requirement
  3. 3. Current Reporting Statistics Statistics for the July 1, 2011 to June 30, 2012 reporting year Generator's Hazardous Waste Summary Report (MO 780-1097) Facility Summary Report (MO 780-0408) Total reports received 3200 190 %Paper 70% 49% %Excel 30% 51% Total records in the reports 16000 26100 %Paper 60% 6% %Excel 40% 94%
  4. 4. The Hazardous Waste Program is beginning to modernize the means by which we accept electronic reporting.
  5. 5. What is driving this change? • HB1251 – Allows for LQGs and TSDFs to report annually if they report electronically by the means specified by the department. – This must be implemented by the July 1, 2015, to June 30, 2016, reporting year. • “Hazardous Waste Electronic Manifest Establishment Act” – Signed into law by the president last month. – Must be implemented within three years of the law being enacted (by October of 2015).
  6. 6. What is being done now? • The Hazardous Waste Program has begun working with information technology staff to develop a new electronic reporting system. This system will need to be able to handle the large amounts of data that will be received at one time when LQGs and TSDFs begin filing their reports annually.
  7. 7. What will reporting look like? Based on Hazardous Waste Forum discussions, we believe that reporters would like a system with the following features: – Web based – Allows for both direct data entry and loading data from reporter’s own data systems – The ability to take the data submitted to us and use it to create the reporter’s “Biennial Report” • The reporter will still have to go into the biennial report and add codes that we do not collect on our reports • Since the state reporting cycle and the biennial reporting cycles do not coincide, we would have to add a field to determine when the waste was shipped/received. Without that additional field, this feature will not be possible.
  8. 8. How will the Electronic Manifest impact reporting? • We plan to make the schema that we use as close as possible (hopefully identical) to the schema that EPA will use to accept electronic manifest data from the TSDFs. This will allow those that want to upload data to use a single application in their data systems.
  9. 9. Will the Electronic Manifest change state reporting requirements? • Two elements must exist in the Electronic Manifest system before state reporting requirements could be changed. – All manifests, both paper and electronic, must be entered into the national manifest database • The law allows for rules to be written to require this. – The amount of waste shipped must be easily converted to tons. • This will require that the weight of the waste will be able to be determined from the information on the manifest, or entered into the national manifest database. • The current paper manifest does not allow for this when the waste is shipped by volume. • The HWP would like to see the EPA require the TSDFs to enter a “weight received” into the national manifest database, even if that field is not added to the actual manifest.
  10. 10. What will change if those requirements are met? It would be possible to eliminate the reporting requirements with the following exceptions. – Any waste that you currently report that is not manifested will still need to be reported as you do currently. – TSDFs that receive waste and then ship the waste to another TSDF on a new manifest ,will still need to file their report indicating that this is the case. Currently, this is done by marking “A” in the tax code field of the “Generators Hazardous Waste Summary Report”. – Sites that have a state approved remedial plan and enter “B” in the tax code field will also need to file a report.
  11. 11. Have an idea about electronic reporting? Please tell me about it! David Green (573) 751-3204 david.green@dnr.mo.gov

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