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Our e-Manifest Data Has Been Edited! Though data in e-Manifest is getting better, there are a LOT of errors! Many of these errors related to tonnage make the data nearly unusable. Tons / Volumes / Units of Measure There are many errors that greatly inflate volumes/tons in e-Manifest if the data is taken "as is" directly from the data sources. One common error responsible for large numbers of records with incorrect tonnage, is the wrong unit selected for the Total Quantity in box 12 of the manifest. For example, a common error is "T" (tons) being reported on a manifest when "P" (pounds) was obviously intended. There are many manifests where 40,000 tons is reported instead of pounds, grossly inflating the volumes for that generator, zip code and state. That one particular error overstates volumes by a factor of 2000.A specific example of the gigantic errors in the system, one manifest is reported as weighing 939,500 tons! This is for one shipment! That amount of tonnage is more than all generators in Texas combined shipped the first half of 2020. The next largest shipment was a shipment logged as weighing over 193,000 tons, again this is far more tonnage than entire states ship in one year. Tank Cars In our review of tank car data in e-Manifest we found many more tank cars logged than the tonnage would suggest. After further digging, one record in particular had "40,606" logged for container quantity for container type "TC" with a total weight of 7 tons. There were a small amount of records of TC shipments with container quantity over 1 and based on the weights these were obvious errors. We now currently edit all TC shipments to be a container quantity of "1." How We Are Fixing These Errors. We have done our best to correct errors such as selecting the wrong unit of measure, by reviewing the container units, total weight of the manifest and then refactoring the tonnage based on averages and what is legally and practically possible for trucks, tankers, tank cars, gondolas, etc. We have written software to analyze these factors and update tonnages when they are outside of certain parameters. We will continue to review and update our software for better quality results as time goes on. We Also Keep All Original Data For Analysis! For reports where we are evaluating compliance such as determining generator status (LQG, SQG, VSQG), we use the actual e-Manifest volumes and tons. It is our opinion that macro level analysis cannot be accurately performed without performing major revisions to e-Manifest data. We do store both the original volumes and our revised volumes in our data tables, so we are able to provide both when needed. Unique Generator Analysis Analysis utilizing the number of unique generators cannot be 100% accurate due to VSQGs / CESQGs not being required to have a unique EPA ID number. Many of these generators will put "Exempt" for EPA ID or another identifier, because of this we cannot accurately count the number of exempt generators shipping. How We Count Exempt Generators In our analyses for number of Generators, we count the unique values of EPA ID numbers shipped in the e-Manifest system. We overwrite common industry EPA ID numbers assigned arbitrarily to exempt generators like state prefix and "CESQG" (ex."TXCESQG") and "EXEMPT" to state prefix, "CESQG" and Zip Code. This does not identify every exempt generator but is a little more accurate. Also, because some of the industry practices of using common ID numbers for exempt generators, when we perform volume analysis by EPA ID number some of the largest shippers in various states are "CESQG", etc. By breaking apart these common IDs to state and zip code, we can better determine the largest shippers in the various states. Why Don't You Use Address Information For Counting Exempt Generators In e-Manifest, if EPA's system recognizes the EPA ID number, it uses the data from RCRAInfo's Handler database. If it does not recognize the Handler ID, it uses the name and address information submitted by the destination facility submitted in each manifest. If we used the physical address in our analyses, ANY change in the physical address would be counted as a unique generator, this would greatly inflate the number of exempt generators shipping due to typographical errors and data inconsistencies between destination facilities.

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