Waste Tire Manifest System Discussion of Proposed Revisions to the Waste Tire Manifest System Special Waste Committee November 4, 2004

WTMS Introduction Issues and Problems with Current WTMS Board Direction Background/History Areas and Issues Considered in Analysis Options for Board Discussion and Direction Comparison of Options in Key Areas

Issues and Problems 10-12,000 generators now required to submit forms High volume of reporting forms submitted Unreadable, incorrect or incomplete forms Inconsistent adherence to reporting Lack of adequate staffing for implementation of current system requirements Lack of full participation in EDT.

Board Direction Staff directed to develop options for the Board to simplify the tracking and reporting process Improve efficiency and effectiveness Reduce volume of paperwork

Background History of WTMS SB 744 (1993) – Established Hauler Registration Program and original manifest system AB 117 (1998) – Req’d legislative report on Tire Program Board recommended basis of current manifest system SB 876 (2000) – Current system

History of WTMS Public workshops Testing phase Regulatory package and comment periods Implementation July 1, 2003 Additional workshops in 2004 on ways to simplify and improve WTMS

Areas and Issues Considered Goals and Objectives of the Tire Program and Manifest System Enforcement Needs Market Development Needs Data Submittal Stakeholder impacts Impact on Board staffing resources Legal impacts Fiscal impacts

Questions

Tire Enforcement Program

Goals and Objectives of the Tire Program To reduce illegal storage and disposal of tires to minimize the effect on public health and the environment To foster alternative uses or reuse of waste tires

Tire Management Program

Enforcement Programs

Enforcement Regulatory Stakeholders Generators Tire Dealers, Auto Dismantlers, Anyone generating 10 or more tires Haulers Anyone hauling 10 or more tires End Users Landfills, Transfer Stations, Recyclers

Tools in Enforcement Inspections Investigating Complaints Surveillance Permitting of Tire Facility Hauler Registration Manifest System WTMS database

Manifest Information as an Enforcement Tool During inspections To target businesses operating illegally As evidence in enforcement cases

Manifest Information as an Enforcement Tool - Inspections Generators Helps determine if using Registered Haulers Haulers Number of tires picked up and dropped off Are tires going to authorized facility End User Reports unregistered Haulers Verify that Hauler is using authorized facility

Manifest Information as an Enforcement Tool Reports on potentially illegal activities Generators not submitting manifests Haulers with expired registrations Account for tires picked up and delivered by Hauler

Manifest Information as Evidence in Enforcement Cases Manifests can show that: A Generator has used an unregistered hauler Unregistered haulers hauled illegally to an authorized facilities Lack of manifests at a Generator can be evidence that they are not using Registered Haulers Multiple manifests can show Hauler potentially illegally dumped tires

WHAT Violations WHERE Address of generator (pickup) Address of end user (delivery) WHO TPID #, Business name Role & Relationship: Generator, Hauler, End use WHEN Date of violation Manifest Information as Evidence in Enforcement Cases

Questions

Waste Tire Manifest System A Discussion of Options

Objectives of the Waste Tire Manifest System Specific to the Manifest System, SB 876, sought to: Provide an accurate accounting that track tires from point of generation to disposal Close the loop on accountability by including each party in the system (generator, hauler and end user).

Option 1 -- Current Waste Tire Manifest System Option 2 -- Proposed Comprehensive Trip Log Option 3 -- Monthly Summary Report Discussion of Options

Option 1 Current Waste Tire Manifest System “Closes the Loop on Accountability” by requiring each party to a tire transaction – Generator, Hauler and End Use Facility to report on specific tire transactions. Ability to cross check load and tire amount data between Hauler and Generator and End User at the trip level. Provides detailed transaction data on tire pick up/delivery and hauler activity.

CIWMB

Option 2 -- Comprehensive Trip Log Places responsibility on the Hauler to report for Generator and End Use Facility. Generator, End Use Facility sign off and are provided “receipt” for tires picked up and delivered. Provides detailed tire transaction data at the “load” level; date, tire, tire amt, etc. for enforcement. Reduces reporting entities from 11,000 to 800+ and significantly reduces paper form submittal.

Comprehensive Trip Log Common Pick up and Delivery Generator 1 Generator 2 Receipt A Receipt B End Use Site Receipt C CIWMB Only Hauler Reports - Hauler reports for both Generator and End Use Facility clients. There is only one form. Each client receives a Receipt for their records Hauler sends copy of CTL form to CIWMB for processing.

Option 3 -- Monthly Summary Report Requires Generator, Hauler and End Use Facility to report Monthly. Provide summary information and totals on tires exchange activity. Reduction in paper forms submitted.

CIWMB Monthly Summary Report Hauler Monthly Summary Report Generator Monthly Summary Report End Use Facility Monthly Summary Reporting * Important* If the business plays more than one role, i.e. Generator as Hauler, they must complete a form for that role. In other words, a Generator who is also a Hauler must submit a form listing all Generator activity and submit a form for all Hauling activity. Each stakeholder business must report monthly

Questions

How EDT works

Electronic Data Transfer (EDT) EDT Hauler Invoice Generator 1 Generator 2 End Use Site EDT Approved Hauler: - Generates WTMS information as part of their internal automated invoice and accounting systems. -- Uses their own Invoice as approved by CIWMB. -- Reports on behalf of their clients – Generators and End Users. -- Submits information monthly in a “batch” mode via Internet to CIWMB for processing. CIWMB Internet Site Common Pick up and Delivery

Web Based EDT Hauler Invoice Generator 1 Generator 2 End Use Site Web Based EDT Approved Hauler: -- Generates WTMS information on a transaction basis using their computer and accessing the Web based EDT data entry screen within the Board’s Tires Website. -- Reports on behalf of their clients – Generators and End Users. -- Uses their own Invoice as approved by CIWMB. -- Data entered daily, weekly. CIWMB Internet Tires Web Site Web Based Electronic Data Transfer Common Pick up and Delivery

Distinctions between Paper and EDT Reporting Paper All parties report (except CTL) Must use CIWMB approved forms Must send in paper forms for processing within 14 days or monthly if Summary Report. EDT Hauler reports on behalf of Generator and End User Can use their own invoice, as approved by CIWMB Can send WTMS data either in “batch” mode or through daily data entry into Web based EDT portal.

Questions

Comparison of Options

Regulated Community Required to Report by Option – Chart 1 Regulated Participant Number in Community Option 1 Existing WTMS Option 2 Comprehensive Trip Log Option 3 Monthly Summary Report Generator 10,000 to 12,000 XX Registered Hauler 800XXX End Use Facility Operator 200XX

Paper Forms to be Submitted Annually by Option - Chart 2 Paper Form Volume Option 1 Existing WTMS Option 2 Comprehensive Trip Log Option 3 Monthly Summary Report Forms to be submitted Annually 300,00075,000 (Est)132,000 (Est)

Information Captured/Potential use for Enforcement - Chart 3 Enforcement Information Option 1 Existing WTMS Option 2 Comprehensive Trip Log Option 3 Monthly Summary Report Potential of System to provide detailed data for Enforcement High Current System captures detailed transaction data with reconciliation to Trip Level High/Medium Comprehensive Trip Log will provide detailed transaction data to the load level. Medium/Low Monthly Summary Totals on Tire Transactions provide less detail regarding transactions.

Automated System Development and Support – Chart 4 Automation Systems Option 1 Existing WTMS Option 2 Comprehensive Trip Log Option 3 Monthly Summary Report Level of Automation Support WTMS Automated System is currently in production, including batch EDT and Web Based EDT CTL will contain core WTMS data base with minor modifications. Can be put into production quickly No System in place. Will require new system development.

CIWMB Implementation Impacts -- Chart 5 CIWMB Implementation Impacts Option 1 Existing WTMS Option 2 Comprehensive Trip Log Option 3 Monthly Summary Report Implementation Tasks by Option Current system is developed and implemented. Ongoing tasks include EDT efforts, training and enforcement actions Modifying current system; developing a new form; training of Hauler community; minimal development of new business processes; enforcement; regulatory package. Development of automated system, new CIWMB business processes, and new forms; training of 11,000 + regulated community; enforcement; regulatory package.

Conclusion of Presentation Questions Concerns

End of Presentation Slides

EXTRA Slides

Comparison of Options Attachment 4 Information captured Scannable Load Tracking Trip Reconciliation Data for Enforcement Market Development

Comparison of Options Forms submitted annually Reporting Frequency Who Reports Options for reporting Automated system in place

Summary Option 1 Electronic data submittal – hauler reports Paper based forms – all report Tracks at load and trip level Costs for development already incurred Current 300,000 forms plus 132,000 EDT records

Summary Option 2 Electronic data submittal – hauler reports Paper based form – hauler reports Tracks at load level Can be built on existing system, major costs for development already incurred Estimate 75,000 forms (without electronic data submittal)

Summary Option 3 Electronic data submittal – all report Paper based form – all report Tracks at monthly activity level per hauler, generator and end user Cannot be built on existing system, major costs for development Estimate 132,000 forms (without electronic data submittal)

Comprehensive Trip Log Multiple Pick up and Delivery Hauler completes Part I Receipts A B CA B C Gen 1End Use 1 Hauler Sends 2 nd Copy to CIWMB, retains 3 rd Copy Gen 2Gen 3Gen 4End Use 2 New Trip Log, No Master Log Number

Options for Simplifying the Manifest System Option 1  Development of a Comprehensive Trip Log whereby Haulers report on behalf of Generators and End Users  Option 2  Continued Expansion of Electronic Data Transfer (EDT)

Options for Simplifying the Manifest System Option 3 Develop Web Based EDT reporting method for Haulers Option 4 Development of software for Hauler data entry of client information, tire pick up and deliveries. Designed to run on a single PC with printing capability, client list reports.

Option 2— Continue Expansion of EDT Electronic Data Transfer (EDT) has proven very successful with approved EDT Haulers reporting on behalf of Generators and End Users. Very similar to Comprehensive Trip Log. Expansion expected given that WTMS is here to stay and that Comprehensive Trip Log is built on the same approach as EDT.

Option 3 – Expand Options for Web Based EDT Proposed development of Internet Based EDT entry for approved Haulers. CIWMB proposes a Web based data entry screen for Haulers to enter in Trip Log data via the Internet, should they wish to continue to use their own forms and who do not have a high level of in-house computer support. Current EDT data sent in batches. EDT participants are responsible for creating and submitting data to CIWMB from their own automated systems. EDT participants use their own forms.

Waste Tire Trip Log Purpose: To document and summarize each pick up or delivery/disposal of waste tires. To cross reference the Manifest Number with the Trip Log Number Use: Hauler enters Manifest number and Load Info from each pick up or delivery or disposal. One entry for each pick up or delivery/disposal. Tire counts for pick ups must equal tires off for delivery or disposal at end of trip. The Trip Log is completed by the Hauler only L

Waste Tire Manifest Form Purpose : Document the pick up or delivery or disposal of waste tires. Part I is completed by the Hauler Part II is completed by the Generator or End Use Facility Use: To provide a record for the hauler and the generator or end use facility operator of tires exchanged. M

Option 1— Comprehensive Trip Log A single WTMS Trip Log that would enable the Hauler to report on behalf of the Generator and End User. Comprehensive Trip Log has three perforated receipts for Generators or End Use site transactions. Generator or End Use representatives must initial receipt before it is detached from Comprehensive Trip Log. Comprehensive Trip Log may be held until all receipts are used or within 14 days of initial use. Upon completion of Comprehensive Trip Log or 14 days calendar elapsed time, 2 nd Copy to CIWMB.

Other WTMS requirements remain the same - Generators to use authorized, registered Haulers Generators, End Users to hold receipts for 3 years at their place of business. Hauler sends in 2 nd copy of Comprehensive Trip Log to CIWMB for processing and documentation Hauler retains 3 rd copy for their records for 3 years at their place of business. Option 1— Comprehensive Trip Log

Option 1 – Comprehensive Trip Log Form Hauler Information Customer or End Use Site Information 3 Tear Off Receipts

Option 1 – Comprehensive Trip Log Form Contains both Trip Log and Manifest Information Replaces Manifest for Pick Up and Delivery 3 perforated receipts for customers 3 part form. 3 Perforation Receipts for customers, 2 nd Copy to CIWMB, 3 rd Copy for Hauler records.

Comprehensive Trip Log Form Hauler Information Generator or End Use Site Information 3 Tear Off Receipts

Comprehensive Trip Log Form Hauler Information….. …….much the same as Current Trip Log Driver Printed Name Signature Date Driver Info Comprehensive Trip Log Numbers begin with “C” Hauler Truck Decal And License Plate No. Hauler Business Name and Address, City and Zip

Comprehensive Trip Log Form Customer Receipt Hauler Information Load Information Pick Up / Delivery Date Load Type Amount Generator or End Use Site Information Business or Site TPID Business or Site Telephone Business or Site Address; Street and City, Zip

Comprehensive Trip Log Common Pick up and Delivery Hauler Completes Part I Generator 1 Generator 2 Receipt A Receipt B End Use Site Receipt C Hauler Sends 2 nd Copy to CIWMB, retains 3 rd Copy

Option 1 -- Continue Existing WTMS while seeking to expand EDT Pro Significantly reduces number of forms submitted to CIWMB (with electronic data submittal) Significantly reduces staff time in processing forms Reduces costs to CIWMB (postage, forms)

Con Hauler is responsible and accountable for reporting Electronic data submittal not mandatory, so will still receive unknown number of paper forms May require statutory/regulatory changes Option 1 -- Continue Existing WTMS while seeking to expand EDT

Option 2 -- CTL Pros Hauler reports on behalf of generator and end-user Report format is simpler (single form) If reporting via electronic data submittal, hauler uses own invoice Captures all key information except trip level for enforcement purposes

Option 2 -- CTL Pros Ability to cross reference to load level Significantly reduces number of forms submitted to CIWMB (75%) Significantly reduces staff time in processing forms Reduces costs to CIWMB (postage, forms)

Option 2 -- CTL Cons Hauler is responsible and accountable for reporting Cannot associate a specific pickup or delivery to a specific trip Does not capture all information captured under Option 1 Electronic data submittal not mandatory, so will still receive unknown number of paper forms May require statutory/regulatory changes

Option 3 – Summary Reporting Pros All parties report and remain part of the system Simplifies reporting re: per transaction and multiple forms Provides summary information for enforcement and market development Ability to cross reference at summary level Less burden on hauler

Option 3 – Summary Reporting Pros Reduces forms by 40-45% Significantly reduces staff time in processing forms Reduces costs to CIWMB (postage, forms)

Option 3 – Summary Reporting Cons For enforcement, will not provide load dates/amounts, type of tires, or hauler registration or truck decal information Burden on each party to maintain accurate records over month to report accurately All parties must report, even if no activity that month May be a workload management issue for staff as all reports due at same time

Option 3 – Summary Reporting Pros May require statutory/regulatory changes Electronic data submittal will not be mandatory, so will still receive an unknown number of paper based reports May require multiple reports if hauler also acting as generator and/or end user

Monthly Summary Report Generator Generators submit the following : Name, Address and TPID Total Number of Tires removed during this reporting period Listing of Haulers used - Name and TPID Monthly Summary Report Hauler Monthly Summary Report End Use Facility CIWMB

Monthly Summary Report Hauler Monthly Summary Report End Use Facility CIWMB Monthly Summary Report Generator Haulers submit the following: Name, Address and TPID Total Number of Tires picked up for that reporting period from each Generator Name and TPID of each Generator Numbers of tires delivered to End Use Facilities. Name and TPID of End Use Facilities

Monthly Summary Report End Use Facility Monthly Summary Report Hauler Monthly Summary Report Generator CIWMB End Use Facilities submit the following: Name, Address and TPID Total Number of Tires received from each Registered Hauler for the reporting period. Name and TPID of Haulers Total Number of tires from Unregistered Haulers, Name and Address, License Plate of Unregistered Haulers. Number of Tires processed during reporting period – incinerator, landfilled, etc. Number of Tires shipped off site during reporting period.