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36

World Cement

North America 2019

The process

Waste materials processing normally starts with

the submission of a waste material profile and

pre‑qualification sample by a generating facility

(Figure 2 for the WFIMS high-level workflow).

After accepting a waste stream for processing,

a pre‑qualification identity is assigned. Each

pre‑qualified waste stream is associated with a

specific billing name and a generating facility. The

pre-qualification data is maintained in the laboratory

module and qualification creation applications.

Inbound shipments are scheduled against

pre‑qualified waste streams. The new shipment

function creates a shipment record identified by waste

material category and transportation mode, which

can be scheduled for arrival at a specific date and

time. When a shipment arrives onsite, the receiving

process includes creating the load record for the

carrier and recording detailed manifest information.

Further analysis of an acceptance sample may be

required before unloading. Unloading assigns the

received material to one or more storage/processing

locations. Containers are individually identified with a

bar code and unloaded to a storage location to await

acceptance sampling and categorisation, before going

into processing. The waste tracking process ends

when the waste is accepted for processing onsite,

sent to another destruction facility, or returned to

the generator. The WFIMS includes the provision of

‘death certificate’ documentation for waste streams to

meet regulatory requirements.

Environmental Protection Agency

Across the US, the Uniform Hazardous Waste

Manifest (UHWM) is a paper form required by the

Environmental Protection Agency (EPA) and the

Department of Transportation. Generators must

produce the UHWM to transport hazardous waste to

treatment, storage, and disposal facilities (TSDFs).

This is a key document that includes tracking

information related to the waste being transported,

instructions on how to handle the material, and

signatures and dates for each party involved in the

transportation and disposal of the waste. Each party

involved in the handling of the waste retains a signed

copy of the manifest. Once the waste reaches its

destination, the TSDF sends a signed copy of the final

manifest back to the generator to inform them that the

waste has reached its destination.

Historically, it was each party’s responsibility to

maintain its own copy of the signed paper manifests.

The submission of paper manifests to the EPA was

not required.

The proposal to move from paper-based manifests

to electronic manifests was initiated by the EPA in

May 2001.

2

The stated benefits were the following:

z

z

Cost savings.

z

z

Better and more timely information on hazardous

waste shipments.

z

z

Faster notification on discrepancies related to

shipments.

z

z

A single portal for the reporting of manifest data to

both the EPA and states.

z

z

Improved compliance monitoring of waste

shipments by regulators.

z

z

The integration of manifest reporting

with the biennial report from the

Resource Conservation and Recovery Act

(RCRA).

On 5 October 2012, the Hazardous Waste

Electronic Manifest Establishment Act was enacted,

authorising the EPA to implement a nationwide

electronic manifest system. This act requires that

the cost of developing and operating this system be

recovered by user fees that are charged to users of

the electronic manifest system to track hazardous

waste manifests for offsite shipments of hazardous

waste. The fee schedule at that time was not finalised,

but it was known that submitting paper manifests

would be significantly more expensive than submitting

a manifest electronically. The fee schedule at the time

of writing is shown in Table 1.

3

Essentially, TSDFs that would be able to submit

their manifests electronically would be able to save

more per manifest than those that would continue to

record (and thus submit) their manifests via paper. In

the short term, those that could take advantage of the

cheaper option could see an immediate cost savings

benefit. In the long term, the EPA is only planning

to support the submission of paper manifests until

30 June 2021, at which time an electronic method of

submission will be required by all TSDFs.

4

Development of the EPA’s e-Manifest system started

in 2014, with architecture discussions of the back-end

system. Not until June 2017 were a series of web

services made available for user experience testing.

The target production release date was still on track

for official release on 30 June 2018.

Figure 4. Liquid waste tanker.

Table 1. Current fee schedule.

Manifest submission type Fee/manifest

Paper

US$15.00

Scanned image

US$10.00

Data + image

US$6.50

Fully electronic

US$5.00